ML14357A447
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Enclosure to AEP-NRC-2013-33 DONALD C. COOK NUCLEAR PLANT Emergency Plan, Revision 32 IMPLEMENTING PROCEDURES RMT-2080-EOF-001, Activation and Operation of the EOF, Revision 22 RMT-2080-EOF-002, Emergency Termination and Recovery, Revision 5 RMT-2080-JIC-001, Activation and Operation of the ENC/JIC, Revision 6 RMT-2080-OSC-001, Activation and Operation of the OSC, Revision 15 RMT-2080-TSC-001, Activation and Operation of the TSC, Revision 19
Page 1 of 221 DONALD C. COOK NUCLEAR PLANT EMERGENCY PLAN REVISION 32 UNITS 1 & 2 DOCKET NOS. 50-315 & 50-316 LICENSE NOS. DPR-58 & DPR-74 Effective Date X1>-e'//to3 PORC Meeting _-___
Reviewed -I A4a'S //-}&, Date 4/. 4/. Z0/S Emergency Preparddrss Manager Approved _S"I Date Ji-*-LL Title Title AA73/4- &9Ah'/46iZ-
Page 2 of 221 Cook Emergency Plan Revision 32 Changes:
Changed emergency planning to emergency preparedness throughout. (Administrative change)
Planning Standard A. Organizational Control Figure 1:
Replaced Law Enforcement with Berrien County Sheriffs Department.
Changed Department of Commerce to Licensing and Regulatory Affairs.
Changed Family Independence Agency to Human Services Titles have changed (Administrative change)
Planning Standard B, Emergency Response Organization B. IA moved "Site Protective Services, and organizational/administrative activities at the plant" from Vice President-Site Support Seivices to the Site Vice President. This is due to organizational changes.
(Administrative change)
B. 1 .d, B. L.e and B. 1.f Changed title from Manager-Security and Emergency Planning to Director Nuclear Site Services. (Administrative change)
B.5a. I sub step 4 added "responsibilities that may not be delegated". This change was made to agree with procedure PMP-2080-EPP-100, Emergency Response.
B.5C. 1sub step 2 added "responsibilities that may not be delegated". This change was made to agree with procedure PMP-2080-EPP-I100, Emergency Response.
(Administrative change)
B.5.e.l third sentence changed "other liaison" to "A second liaison". A third liaison is discussed in new item. (To comply with 2012 EP rule making)
Added item B.5e3, Incident Command Post Liaison and the duties of that person. (To comply with 2012 EP rule making)
B.9.a corrected the location of the Berrien County EOC, (Administrative change)
B.9.a second paragraph added hostile threat and Incident Command Post. (To comply with 2012 EP rule making)
B.9.b first paragraph added hostile threat. (To comply with 2012 EP rule making)
B.9.a.4, B.9.b.1 .a and B.9.b. 1.b, B.9.c changed Department of Natural Resources to Department of Environmental Quality (DNRE to DEQ). The department has reversed back to old name. (Administrative change)
B.9.b.2.b changed Department of Commerce to Licensing and Regulatory Affairs. The department name has changed. (Administrative change)
B.9.b.2.h changed Family Independence Agency to Human Services. Department has changed names.
(Administrative change)
Figure 2 updated Performance Assurance Manager to Director, Manger Business Services to Director and Learning Organization to Performance Improvement Department. These changes are due to organizational title changes. (Administrative change)
Figure 3 corrected title of Manager Emergency Preparedness and Site Protective Services to Director Nuclear Site Services and added additional reporting chain. Changed title of Assistant Director Rad/Chem/Env to Radiation Protection Manager Rad/Chem/Env to Radiation. Changes are due to organizational changes. (Administrative change)
0-- ve. 3 Page 3 of 221 Figure 4 added the ICP Liaison position into the reporting chain. (To comply with 2012 EP rule making).
Also added Work Control SRO, 2 AEO Phone Talkers and Fire Brigade to reflect what is depicted on Table B-1. (AR 2013-2144)
Revised Figures 5 and 6 to add the Off-Site Liaison positions (ICP,BCSD, MSP) into the reporting chain.
(To comply with 2012 EP rule making)
Planning Standard C. Emergency Response Support and Resources C.2.b added Incident Command Post to list of where liaisons are provided. (To comply with 2012 EP rule making)
Planning Standard D, Emergency Classification System Added item D.2. 1, that emergency declaration must be made within 15 minutes of determining that an emergency action level has been exceeded. (To comply with 2012 EP rule making) GT 2012-12625-5 Planning Standard E, Notification of Emergency Response Personnel and Organizations.
E. I third paragraph removed "approximately" as the notification must be made within 15 minutes. (To comply with 2012 EP rule making)
E. 1 fifth paragraph replaced Office of Emergency Preparedness with Office of Emergency Management/Homeland Security. The department name has changed. (Administrative change)
E. I last paragraph removed "Emergency Plan" as this is not part of the phone directory title.
(Administrative change)
E.2.b added a paragraph describing that personnel report to an alternate location in the event of a hostile action threat. (To comply with 2012 EP rule making)
E.6 added a paragraph describing the ANS system and the backup method for alerting population within the EPZ. (To comply with 2012 EP rule making)
Figure 9 added ICP to the communications flow. (To comply with 2012 EP rule making)
Planning Standard H, Emergency Facilities and Equipment Added a fourth item to designate an alternate location that may be used in the event that the response facility is not available due to the event. (To comply with 2012 EP rule making)
H. L.b. and H.3.b added the alternate location in the event that the facility is not available due to the event.
(To comply with 2012 EP rule making)
H.5.b last paragraph changed FSAR to UFSAR, H.5.b.2 last paragraph re-written to state that the RMS listing can either be found in the computer system or in the reference section of the booklists that contain the Implementing Procedures. The location of RMS listings can be obtained readily from the computer located in the facilities. (Administrative change)
H.6.b removed "Radiation Protection Procedures" as the requirements have been moved to Emergency Plan' Procedures. (Administrative change)
Item H.8 changed Job Order to Work Order as the name of the document to designate work has changed.
(Administrative change)
CEP 6e.3 Page 4 of 221 Table 5 removed the note "Effective in Unit 1 post Cycle 22 Refueling Outage. Effective in Unit 2 post Cycle 17 Refueling Outage" as the refueling outages have since been completed. (Administrative change)
Planning Standard I, Accident Assessment 1.2 second paragraph re-written to state that the RMS listing can either be found in the computer system or in the reference section of the booklists that contain the Implementing Procedures. (Administrative change) 1.4 Updated the description of the Dose Assessment Program features.
Planning Standard J. Protective Response Added to J.8 when the Evacuation Time Estimates are performed. This implements 10 CFR50. Appendix E IV 3-6.
Planning Standard K, Radiological Exposure Controls K.3.a, K.5.a and K.6.c changed Department of Natural Resources to Department of Environmental Qualj, (DNRE to DEQ)- The department name has changed. (Administrative change)
Planning Standard N, Exercises and Drills Added items N.2.f.2 and N.2.f.3 describing fast breaking and minimal radiological releases drills. (To comply with 2012 EP rule making)
Planning Standard 0, Radiological Emergency Response Training 0.2 corrected TPD title from "Emergency Plan" to "Emergency Preparedness".
0.2, O.4.j replaced "qualification cards" with "Job Familiarization Guides". The qualification method is now titled Job Familiarization Guide. (Administrative change) 0.3, O.4.f replaced "Emergency Medical Technicians" with Medical Emergency Response Team members (MERT). (Administrative change) 0.5 replaced "qualification" with "job familiarization". To be consistent with the new title for qualification.
(Administrative change)
Appendix A, Index of Plant Procedures and Cross Reference Added procedure SPP-2060-SFI-216 to E.2 as this procedure also describes actions to take to notify on-site personnel. (Administrative change)
Added procedure EPP-2080-ERO-00 Ito H.6.b as this is the procedure that performs the equipment inventory. (Administrative change)
Appendix B, Agreements With Off-Site Support Agencies Replaced the Mutual Assistance Agreement with a new one dated 01/09/2013. (Administrative change)
Added a letter from FEMA describing the backup ANS system. (To comply with 2012 EP rule making)
Appendix J, Eight Year Plan Matrix Removed the monthly columns from the annual, semi-annual, quarterly and monthly matrix. The exact scheduling of items is dependant on outside agencies and to avoid non-compliance with the arbitrary dates on the matrix the months have been removed.
(Administrative change)
CEP Rey-- .3 Page 5 of 221 Copy of 50.54(q)
Reference RMA-2080-EPA-008 I Rev. #15 [ Page 36 of 44 IEmergency Plan Management Data Sheet I Screen Evaluation Form g35-s36 Change Evaluation 1- 13-08 Year - Sequence #
Activity Description and
References:
Cook Emergency Plan (CEP), Rev 32 Activity Scope: Revision 32 to the CEP reflects changes to address the 2012 Emergency Preparedness (EP) Rule Making, the incorporation of the Incident Command Post Liaison, an updated description of the dose assessment model capabilities, and general administrative maintenance items to reflect current names and titles.
The scope of changes included the following to address 2012 EP Rule Making:
- B.5.e.I third sentence changed "other liaison" to "A second liaison". A third liaison is discussed in new item.
a Added item B.5c3, Incident Command Post Liaison and the duties of that person
- B.9.a second paragraph added hostile threat and Incident Command Post
- B.9.b first paragraph added hostile threat
- Figure 4 added the ICP Liaison position into the reporting chain
- Revised Figures 5 and 6 to add the Off-Site Liaison positions (ICP,BCSD, MSP) into the reporting chain
- C.2.b added Incident Command Post to list of where liaisons are provided
- Added item D.2. 1, that emergency declaration must be made within 15 minutes of determining that an emergency action level has been exceeded
" E.1 third paragraph removed "approximately" as the notification must be made within 15 minutes.
" E.2.b added a paragraph describing that personnel report to an alternate location in the event of a hostile action threat
" E.6 added a paragraph describing the Alert and Notification System (ANS) and the backup method for alerting population within the EPZ
- Figure 9 added ICP to the communications flow.
" H. Added a fourth item to designate an alternate location that may be used in the event that the response facility is not available due to the event
" H. I.b. and H.3.b added the alternate location in the event that the facility is not available due to the event.
" Added items N.2.f.2.and N.2F3 describing fast brcaldng and minimal radiological releases drills
" Added a letter from FEMA describing the backup ANS
Page 6 of 221 C EP Rev 3 :-L Reference RMA-80-EPA-0 I Rev. #15 [ Page 37 of 441 Emergency Plan Management Data Sheet 1 I Screen Evaluation Form I Pages:
35 - 36 General CEP maintenance items:
- Updated organizational and agency titles, both on-site and off-site, to reflect current titles and positions.
" Updated the Dose Assessment Model capabilities Specifics are included on the attached Scope of Revision.
[0 The activity is a change to the emergency plan Change #: Revision 0 The activity is not a change to the emergency plan Change Type: Change Type:
D The change is editorial or typographical IMThe change does conform to an activity that -
has prior approval
[l The change is not editorial or typographical 0 The change does not conform to an activity that has prior approval Planning Standard Impact Determination:
Planning Standard Potential Impact 10 CFR 50.47(b)(1) - Assignment of Responsibility (Organization [H] EUYes Control) _ Im No 10 CFR 50.47(b)(2) - Onsite Emergency Organization [l E Yes
_M No 10 CFR 50.47(b)(3) - Emergency Response Support and Resources [] U Yes 1 NO 10 CFR 50.47(b)(4) - Emergency Classification System U 103Yes
_[ No 10 CPR 50.47(b)(5) - Notification Methods and Procedures 1] 0 Yes
[El No 10 CFR 50.47(b)(6) - Emergency Communications Th 0 Yes
[0 No 10 CFR 50.47(b)(7) - Public Education and Information U 0 Yes
[El No 10 CFR 50.47(b)(8) - Emergency Facility and Equipment O Ul Yes 0[ No 10 CFR 50.47(b)(9) - Accident Assessment [E El Yes
[]_ No
Page 7 of 221 CUFP P ew.3. a Reference RMA-2080-EPA-008 I Rev. #15 Page 38 of 44 Emergency Plan Management Pages:
Data Sheet I [ Screen Evaluation Form I 35 - 36 10 CFR 50.47(b)(10) - Protective Response U 0 Yes I] No 10 CFR 50.47(b)(1I) - Radiological Exposure Control U 0) Yes I] No 10 CFR 50.47(b)(12) - Medical and Public Health Support E! 0 Yes 09 No 10 CFR 50.47(b)(13) - Recovery Planning and Post-accident El Q Yes Operations I] No 10 CFR 50.47(b)(14) - Drills and Exercises U (2 Yes
[0 No 10 CFR 50.47(b)(15) - Emergency Responder Training El (21Yes 0 No 10 CFR 50.47(b)(16) - Emergency Plan Maintenance 0 0 Yes E93 No Commitment Impact Determination:
[I The activity does involve a site specific EP commitment Record the commitment or commitment reference; None of the current EP related commitments are impacted by the proposed changes.
[] The activity does not involve a site specific EP commitment
C-F-P Rev. z& Page 8 of 221 Reference RMA-2080-EPA-008 Rev. #15 Page 39 of 44 Emergency Plan Management Pages:
Data Sheet I ] Screen Evaluation Form I 35 - 36 Screening Evaluation Results:
IE The activity can be implemented without performing a 10 CFR 50.54(q) effectiveness evaluation fl The activity cannot be implemented without performing a 10 CFR 50.54(q) effectiveness evaluation Justification for determination that the activity can be implemented without performing a 10 CFR 50.54(q) effectiveness evaluation.
Justification:
The proposed changes either support the 2012 EP Rule Making or are enhancements that add:d~tail or bring titles and organization names up to date. None of the proposed changes to CEP Revision 32 adversely impact the timeliness or function of any planning standard. Therefore, a 10 CFR 50.54(q) effectiveness evaluation is not required.
Preparer Name: Jar Date:
Dave Walton .- 1 /<J//z Reviewer Name:
Dale Prie
Page 9 of 221 TABLE OF CONTENTS INTRODUCTION PAGE A. P u rpo se ............................................................................................................................ 16 B. O bjec tive .......................................................................................................................... 16 C. Sco p e .............................................................................................................................. 16 D. Organization of the Emergency Plan ......................................................................... 16 E. D e fin itio n s ......................................................................................................................... 17 PLANNING STANDARDS A. ORGANIZATIONAL CONTROL 20 A.1 Organizational Control .................................................................................. 21 A.2 Not Applicable ................................................................................ 22 A.3 Agreements .................................................................................... 22 A.4 Continuous Protracted Operations .......................................................... 22 B. EMERGENCY RESPONSE ORGANIZATION 24 B.1 Normal On-Site Operating Organization........................................................ 25 B.2 On-Shift Emergency Coordination ................................................................. 28 B.3 Emergency Coordination Line of Succession ............................................... 28 B.4 Non-delegable Emergency Coordinator Duties ............................................ 28 B.5 Emergency Response Organization ........................................................... 28 B.5.a Technical Support Center ................................................................. 29 B.5.b Operations Support Center ............................................................... 31 B.5.c Emergency Operations Facility ....................................................... 33 B.5.d Emergency News Center/Joint Information Center .......................... 35 B.5.e Liaisons ............................................................................................. 36 B.6 Overall Organization and Communication ..................................................... 37 B.7 Plant Staff Augmentation ........................................................................... . 37 B.8 Offsite Agencies and Organizations .............................................................. 38 B.9 Offsite Groups ............................................................................................... 38 C. EMERGENCY RESPONSE SUPPORT AND RESOURCES 52 C.1 Federal Radiological Assistance .................................................................... 53 C.2 Liaisons ......................................................................................................... 54 C.3 Radiological Laboratories ............................................................................ 54 C.4 Offsite Agencies and Organizations (non Governmental) ............................. 55 D. EMERGENCY CLASSIFICATION SYSTEM 56 D.1 Emergency Action Levels ...................... .............. 57 D.2 Initiating Conditions ........................................ 59 E. NOTIFICATION METHODS AND PROCEDURES 71 E.1 Notification of Offsite Response Organizations .............................................. 72 Table of Contents Revision 32
Page 10 of-221 E.2 ERO Alert, Notification and Mobilization ........................................................ 73 E.2.a Onsite (Plant Staff) ............................................................................. 73 E.2.b Offsite (Plant Staff) ................................................ 74 E.3 Content of Initial Emergency. Messages ....................................................... 74 E.4 Content of Follow-up Emergency Messages ................................................. 75 E.5 Not Applicable (State and Local Public Information System) ......................... 75 E.6 Public Notification ........................................................................................... 75 E.7 Public Information Messages ......................................................................... 76 F. EMERGENCY COMMUNICATIONS 80 F.1 Licensee, Local, State, and NRC Emergency Communications .................... 81 F.2 Medical Support Communications ........................................ 7........................ 84 F.3 Communications Systems Testing ................................................................. 84 G. PUBLIC EDUCATION AND INFORMATION 85 G.1 Public Information .......................................................................................... 87 G.2 Distribution of Public Information .................................................................. 87 G.3 Emergency News Center/Joint Information Center ...................................... 87 G.4 ENC/JIC Spokespersons and Public Inquiry ................................................ 88 G.5 Annual Media Briefing .................................................................................... 88 H. EMERGENCY FACILITIES AND EQUIPMENT 89 H.1 Technical Support Center (TSC) ................................................................... 90 H.2 Emergency Operations Facility (EOF) ............................................................ 93 H.3 Operations Support Center (OSC) ................................................................. 95 H.4 AEP Emergency Organization Staffing and Activation ....................................... 96 H.5 Emergency Detection ................. ;..................... 97 H.6 Offsite Monitoring and Analysis Equipment .............................................. 101 H.7 Radiological Environmental Monitoring ................................................... 102 H.8 Meteorological System ........................................................................ 102 ACCIDENT ASSESSMENT 107 1.1 Release Identification and Event Classification 108 1.2 Radiation Monitoring System 108 1.3 Release Source Term and Magnitude Determination 108 1.4 Dose Assessment Evaluation 109 1.5 Meteorological Assessment 110 1.6 Not Addressed 110 1.7 Radiological Field Monitoring 110 1.8 Liquid and Gaseous Release Assessment 110 1.9 Off-site Radioiodine Monitoring 110 1.10 Not Addressed 110 J. PROTECTIVE RESPONSE 111 J.1 Owner Controlled Area Warning and Advisement ............................................. 112.
J.2 Evacuation Routes ............................................................................................. 112 J.3 Evacuee Monitoring .......................................................................................... 113 J.4 Evacuee Decontamination ................................................................................. 113 J.5 Personnel Accountability. .................................................................................. 113 J.6 Protective Measures for Those Remaining, or Reporting to the Site ................ 114 J.7 Off-Site Protective Actions ................................................................................. 114 J.8 Evacuation Times .............................................................................................. 115 Table of Contents Revision 32
Page 11 of 221 J.9 Not Applicable .................................................................................................... 115 J.10 Plume Exposure Pathway Protective Measures Implementation ...................... 115 K. RADIOLOGICAL EXPOSURE CONTROL 118 K.1 Emergency Exposure ......................................................................................... 120 K.2 Emergency Exposure Authorization and Control ............................................... 120 K.3 Emergency Personnel Dosimetry ..................................................................... 120
..K.4 Not Applicable .................................................................................................... 120 K.5 Decontamination ................................................................................................ 121 K.6 Contamination Control .................................................................. . ..... 121 K.7 Decontamination of Relocated Onsite Personnel .............................................. 122 L. MEDICAL AND PUBLIC HEALTH SUPPORT 124 L.1 Offsite Medical Support ....................................................................................... 125 L.2 Onsite Medical Support ...................................................................................... 126 L.3 Not Applicable .................................................................................................... 126 L.4 Victim Transport ................................................................................................. 126 M. RECOVERY AND RE-ENTRY PLANNING AND POST ACCIDENT OPERATIONS 127 M.1 Reentry and Recovery ....................................................................................... 128 M.2 Not Addressed ..................................................................................................... 129 M.3 Recovery Initiation Notification .......................................................................... 129 M.4 Not Addressed .................................................................................................. 129 N. EXERCISES AND DRILLS 130 N.1 Exercise s ........................................................................................................... 13 1 N.2 D rills ................................................................................ t.................................. 13 1 N.3 Drill and Exercise Execution ....................................... 132 N.4 Official Observation and Critique ................... .................................................
- 133 N.5 . Results Evaluation and Corrective Actions ........................................................ 133
- 0. RADIOLOGICAL EMERGENCY RESPONSE TRAINING 134 0.1 Organization Training ....................................................................................... 135 0.2 . Onsite ERO Training .......................................................................................... 135 0.3 First Aid Team Training ..................................................................................... 135 0.4 ERO Training and Qualification .................... .............. 135 0.5 Initial and Annual Retraining .... ......................................................................... 137 P. RESPONSIBILITY FOR PLANNING EFFORT 138 P.1 -Emergency Planner Training ............................................................................ 139 P.2 Emergency Plans Administration Responsibility .................... 139 P.3 Emergency Planning Coordinator Designation (Not Addressed) ...................... 139 P.4 Periodic Reviews, Updates, and Audits ............................................................. 139 P.5 Emergency Plan Change Communication ......................................................... 139 P.6 Emergency Response Organization Support Plans .......................................... 140 P.7 Implementing Procedures ................................... 140 P.8 Table of Contents & Cross-reference ................................................................ 140 P.9 Independent Emergency Program Review ........................................................ 140 P.10 ERO Telephone Number Updates ............................. 140 Table of Contents Revision 32
Page 12 of 221 APPENDICES APPENDIX A. 1. Index of Plant Emergency Plan Procedures ...................... 142
- 2. Cross Reference Between CNP and the Plant Emergency Procedures 143 B. Agreements with Off-Site Support Agencies 151 C. Emergency Kits and Equipment Locations 189 D. Emergency Preparedness Brochure 192 E. Description of Federal Radiological Assistance 194 F. Berrien County Road Map 202 G. Population Distribution 204 H. Radiological Response Support Service Capabilities 206 I. Notification of American Nuclear Insurers 209 J. Eight Year Plan Matrix 213 K. Agreements with Off-Site Agencies, Hazardous Material Spills 218 Table of Contents Revision 32
Page 13 of 221 LIST OF FIGURES Figure TITLE Section Page
- 1. Michigan Nuclear Accident Response Organization A ........................ 23
- 2. Management Structure of the Nuclear Generation Group B ............ 45
- 3. Site Operations B ........................ 46
- 4. On Shift Emergency Response Organization B ....................... 47
- 5. *CNP Emergency Response Organization at an Alert Classification B ............................. 4 8
- 6. Organization of the Emergency Director's Staff at the EOF B ........................ 49
- 7. CNP Emergency News Center/Joint Information Center Organization B ........................ 50
- 8. Nuclear Incident Initial Notification Process E ............ 78
- 9. CNP Emergency Response Communications Flow E........................ 79
- 10. Locations of Emergency Response Centers H........................... 104
- 11. CNP Emergency Response Center Locations H ........................... 105
- 12. Primary Evacuation Routes J........................... 117
- 13. Accident Notification Procedures for ANI Insurers Appendix I ............ 212 Table of Contents Revision 32
Page 14 of 221 LIST OF TABLES Table TITLE Section Paae
- 1. CNP Staffing for Radiological Emergencies ........ ........ B 51
- 2. Fission Product Barrier Matrix - Mode 1-4 ....................................... D 6059
- 3. Initiating Conditions, Mode 1- 4 ........................................................ D 62
- 4. Initiating Conditions, Modes 5-6 and Defueled ................................. D 67
- 5. Critical NUREG 0737 Parameters .................................................... H 106
- 6. Maximum Allowable Contamination Limits for On Site Facilities U sed by the P ublic ............................................................................ K 123 Table of Contents Revision 32
Page 15 of 221 INTRODUCTION Introduction Revision 32
Page 16 of 221 INTRODUCTION A. Purpose The purpose of the Cook Nuclear Plant Emergency Plan is to fulfill the requirements as
.set forth in 10 CFR 50, Appendix E, and the planning objectives set forth in NUREG-0654/FEMA-REP-1, Revision 1.
B. Objective The Cook Nuclear Plant Emergency Plan has the fundamental objective of protecting the health and safety of the general public, persons temporarily visiting or assigned to the reactor facility, and employees of the plant.
C. Scope The specific details for the implementation of this emergency plan are incorporated in the Cook Nuclear Plant Emergency Plan Procedures pursuant to the requirements specified in "Purpose", above. The Cook Nuclear Plant Emergency Plan applies to both of the nuclear units and the on-site Independent Spent Fuel Storage Installation (ISFSI). The Emergency Plan procedures include or reference procedures developed for plant operating, radiological, security, and administrative functions as necessary to ensure that all requirements are adequately defined. Appendix A to this Plan contains a list of Plant Emergency Plan Procedures. This plan is primarily concerned with an accidental release of radioactive material, but it is also concerned with major non-nuclear accidents which could prove hazardous to the safe operation of the plant. This includes supplementing our procedures for responding to hazardous material spills to meet Michigan Hazardous Waste Operations and Emergency Response (HAZWOPER) and hazardous waste regulations.
D. Organization of the Emergency Plan The information describing the D.C. Cook Nuclear Power Plant Emergency Plan follows the numerology of NUREG-0654/FEMA-REP-1, Revision 1.
The organization of NUREG-0654/FEMA-REP-1, Revision I sequences evaluation criteria by subject. Some criteria apply to licensee only, and some apply to offsite organizations only. The result is that there would be gaps in the Emergency Plan numbering if the licensee only criteria were listed. When this occurs the NUREG numbering is maintained by listing the criteria number and labeling it as Not Applicable.
Some criteria in the Emergency Plan are not addressed. Again, to maintain the NUREG numbering the criteria is listed but is labeled as Not Addressed.
Introduction Revision 32
Page 17 of 221 E. Definitions 1 Berrien County Emergency Operations Center (BCEOC) This facility provides an area to coordinate efforts of local agencies and organizations involved in the emergency response. It is a center established and controlled by the Berrien County Sheriffs Department and is located in St. Joseph, Michigan.
- 2. Civil Disturbance One or more persons violently protesting plant operations or activities at the site.
- 3. Confinement Boundary The barrier(s) between areas containing radioactive substances and the environment.
- 4. Control Rooms Control and monitoring functions for Units I and 2 are provided for in separate Control Rooms. Each Control Room has a controlled access entrance located off the turbine building main operating floor at Elevation 633'.
Personnel assigned to the Control Room during the emergency will be as indicated in Figure 4 (until the Technical Support Center is activated).
Should conditions require the presence, in the Control Room, of personnel other than those listed in Figure 4, approval must be obtained from the Shift Manager or his alternate.
- 5. Cook Nuclear Plant Procedures Documents defining the details necessary to specify manipulation of controls and equipment to place the facility in a safe condition and to prescribe other appropriate protective measures to be taken by employees of the licensee.
- 6. Emergency Action Levels Radiation dose rates; specific levels of airborne, waterborne, or surface-deposited concentrations of 'radioactive materials; or specific instrument indications (including their rates of change) that may be used as thresholds for designating the appropriate class of emergency.
- 7. Emergency News Center (ENC) The Emergency News Center is located in the Nuclear Generation Group Headquarters Building located approximately 14 miles southeast of the Plant in Buchanan, Michigan. This facility will provide for dissemination of emergency information to the news media prior to activation of the Joint Information Center.
- 8. Emergency Operations Facility (EOF) This facility is in the Nuclear Generation Group Headquarters Building located approximately 14 miles southeast of the Plant in Buchanan, Michigan. This facility is activated at the declaration of an Alert, or higher, emergency classification. The EOF houses the support personnel whose primary responsibilities are to assist in offsite dose assessment and protective action recommendations, communication with offsite agencies, exposure control, technical support of plant operations and other related activities. Representatives from various support agencies and groups may use this facility as a working space to prepare short and long term plans and procedures to mitigate the incident.
- 9. Emergency Plan Procedures (EPP's) The specific procedures that provide instructions, identify responsibilities, and implement the emergency plan. A list of Emergency Plan Procedures is contained in Appendix A.
Introduction Revision 32
Page 18 of 221
- 10. HAZMAT Team The hazardous material spill response team (HAZMAT Team) is a group of plant personnel designated to respond to emergencies involving hazardous materials. They are trained as required by Michigan Hazardous Waste Operations and Emergency Response (HAZWOPER) rules and respond to emergencies using spill pre-plan procedures. The Shift Manager, or a qualified Incident Commander, will act as the Incident Commander in charge of the plant spill response. A designated HAZMAT Team Safety Officer will have responsibility for the on-scene safety of response personnel.
- 11. Hostile Action An act toward a Nuclear Power Plant (NPP) or its personnel that includes the use of violent force to destroy equipment, takes hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience, or felonious acts that are not part of a concerted attack on the NPP or ISFSI. Non-terrorism-based EALs should be used to address such activities, (e.g., violent acts between individuals in the owner controlled area.)
- 12. Hostile Force One or more individuals who are engaged in determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.
- 13. Independent Spent Fuel Storage Installation (ISFSI) A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.
- 14. Joint Information Center (JIC) This facility is operated by AEP personnel for the purpose of disseminating information to the news media, conducting press briefing and as an area where the representatives from various emergency response organizations can meet, review, and release material to the press. The JIC uses the same facilities as the Emergency News Center (ENC).
- 15. NRC Licensed Personnel Those plant personnel holding current operator's or senior operator's licenses from the United States, Nuclear Regulatory Commission as defined in 10 CFR Part 55.
- 16. Off-Site means outside the area which is under the control of Cook Nuclear Plant.
- 17. Off-Site Survey Teams These are teams of personnel assigned to monitor radiological parameters anywhere outside of the plant protected area or the ISFSI protected area. At least one member of the team shall be trained in radiation protection.
- 18. On-Site defined as the owner controlled area inclusive of the protected area and all property outside the plant protected and ISFSI protected areas but under the control of Cook Nuclear Plant.
- 19. Operations Support Center (OSC) This area is located in the basement/shelter area of the plant's lakeside office building. The OSC is the area that will house the operations support personnel for assignment to respond to Control Room and Technical Support Center requests. Communication links are established as needed with the Control Rooms and Technical Support Center.
Introduction Revision 32
Page 19 of 221
- 20. Protected Area The area encompassed by physical barriers to control .access to the plant and to the ISFSI.
- 21. Protective Action Guides (PAG) The projected dose to an individual from an unplanned release of radioactive material at which a specific protective action to reduce or avoid that dose is recommended. Protective actions would be warranted provided the reduction in individual dose expected to be achieved by carrying out the protective action is not offset by excessive risks to individual safety in taking the protective action. The PAG does not include the dose that has unavoidably occurred prior to the initiation of a protective action.
- 22. State Emerqency Operations Center (SEOC) This facility provides a central location from which the emergency functions of state government may be carried out in response to emergency conditions. The primary State EOC is located at 4000 Collins Road, Lansing, Michigan.
- 23. State Field Team Center (FTC) This facility provides the operational working area for State representatives assigned to coordinate the dispatch of field teams to monitor for radioactive contamination. The facility will be directed by a Field Team Center Coordinator assigned by the Michigan Department of State Police/Emergency Management and Homeland Security Division. A representative of the Department of Environmental Quality/Drinking Water and Radiological Protection Division will be assigned to this facility as the Radiological Monitoring Team Leader. The location for the FTC is the Michigan Department of Transportation's Coloma garage at the intersection of Red Arrow Highway and 1-196.
- 24. Technical Support Center (TSC) This facility is located adjacent to the Control Rooms at Elevation 644'. This center is physically separated from both Control Rooms. ThiN facility has communication links to each Control Room, to the Emergency Operations Facility, Emergency News Center/Joint Information Center, Operations Support Center and offsite emergency operations centers established by State/County authorities. This area contains access to instrumentation and necessary reference material for plant management and support personnel.
The primary function of the TSC is to provide an area in close proximity to the Control Room from which plant operators can receive technical support and assistance from personnel who have the experience and expertise in nuclear plant operations, maintenance, safety and design. Their function is to mitigate the cause(s) of a nuclear incident and act as a data gathering center for plant parameters.
Access to the TSC will typically be limited immediately to those individuals listed in Figure 5, and as the situation demands, those individuals required by the SEC or alternate.
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Page 20 of 221 PLANNING STANDARD A ORGANIZATION CONTROL Planning Standard A Revision 32
Page 21 of 221 ORGANIZATIONAL CONTROL A. 1. Or-ganizational Control In order for any emergency plan to be effective it is necessary to ensure that every organization that provides support services has prepared in advance an emergency plan and/or procedures.
These plans and/or procedures should define the individual responsibilities for coordinating and directing the support effort and the level of response each organization is prepared to make to meet its defined response capability on a continuous basis.
Assistance from private organizations having nuclear industry affiliations can also be expected and are identified in Section C.4.
A.l.a. Response Organizations Descriptions of the primary response organizations and their operational roles are outlined in Section B. The "state" column of Figure 1 shows the Primary Response Agencies and Support Response Agencies that comprise the State of Michigan's nuclear accident response organization. The Primary Response Agencies and their duties are performed at the State Emergency Operations Center (SEOC). The Support Response Agencies are the resources available to the SEOC for implementing actions in response to an emergency.
A.l.b. Concept of Operations In the event of an emergency situation, the Shift Manager (or Senior NRC licensed individual) will call upon any additional members of the plant organization as needed. These additional individuals form, along with the on-duty operating shift, the plant Emergency Response Organization. The initiation of any aspects of this emergency plan allows for the use of the total plant organization, at the discretion of the Shift Manager.
The major assignments of the on-duty operating shift and the supplemental personnel in the Emergency Plan Organization are delineated in Table 1.
The extent to which the Emergency Response Organization is staffed will be dependent upon the emergency classification and the discretion of the Site Emergency Coordinator (SEC). For an Unusual Event, only the Control Room will be staffed. For an Alert, Site Area Emergency, and General Emergency the TSC, OSC, ENC/JIC, and EOF will be activated and staffed.
Senior plant management and technical personnel representing the licensee and the NRC are located in the TSC. TSC personnel will provide support to the Control Room operating personnel in the management of abnormal conditions and in accident mitigation. During recovery operations the TSC provides plant systems support for the management personnel located in the EOF. The TSC functions as the primary information source to the EOF and to the NRC (via EOF) on plant status.
The Operations Support Center (OSC) is an onsite assembly area separate from the Control Room and the TSC where licensee operations support personnel report in an emergency. This is an assembly area for personnel to report for instructions from the OSC Manager.
Communications are provided to the Control Room, TSC, and EOF on the Boardwriter's and Manager's Bridges. Teams are dispatched from the OSC to provide for Damage Control, Rescue, and Surveys.
The EOF will provide current information on conditions potentially affecting the public to the NRC, state and county emergency response agencies. Radiological assessment, determination of recommended public protective actions and coordination of offsite response will be transferred to the EOF once the EOF is activated. EOF personnel coordinate the offsite radiological monitoring Planning Standard A Revision 32
Page 22 of 221 during nuclear emergencies and recovery operations. The EOF will function as the post-accident recovery management center for both onsite and offsite activities.
The CNP Emergency Public Information Organization is structured to provide a correct and consistent flow of information to the public and the news media throughout an emergency at CNP. During the initial phases of any emergency, all public information relating to the emergency will be released via the Emergency News Center. The ENC becomes the JIC when the State of Michigan declares the JIC activated.
A.1.c. Organization Interrelationships The relationships between Cook Nuclear Plant normal operating and Emergency Response Organizations are presented in numbered Figures 1 through 10. The figures are referenced throughout this Emergency Plan, and especially in Planning Section B, the Onsite Emergency Organization.
A.1.d. Persons in Charqe The Emergency Director (ED) is responsible for control and co-ordination of all Cook Nuclear Plant emergency and recovery operations.
A.1.e. 24 Hour Response The CNP Emergency Response Organization (ERO) is capable of continuous 24-hour operations for a protracted period.
A.2. Not applicable A.3. Agreements The CNP Emergency Plan provides f6r agreements with various offsite support organizations that are part of the overall response organization within the Plume Exposure Pathway Emergency Planning Zone. These agreements are listed in Appendix B to this plan.
In addition to the offsite support agencies listed in Appendix B, it is assumed that assistance will be provided, as necessary, by those State, County and Federal agencies that are mandated by their charter, public law or regulations to protect the public health and safety, i.e., the NRC and FEMA. It is not expected that letters of agreement are required with these agencies.
A.4. Continuous Protracted Operations The CNP Emergency Response Organization (ERO) is capable of continuous 24-hour operations for a protracted period.
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Page 23 of 221 FIGURE 1 MICHIGAN NUCLEAR ACCIDENT STATE RESPONSE ORGANIZATION PRIMARY RESPONSE AGENCIES FEDERAL State Police Environmental Quality Direction, Control & Monitoring & Sampling Federal Emergency Management Coordination Technical Advice Agency Evacuation Authority Decontamination Advice Nuclear Regulatory Commission Warning/Notification Occupational Health Department of Energy Security Medical & Health Support Damage Assessment Accident & Dose Assessment Federal Coordination Public Information Radiological Exposure Control Resource Support In-place Shelter Protective Actions Technical Advice Local Plans Ground Water Terrorist Activities Municipal Water Supplies Federal Liaison Military Weapon Accident SUPPORT RESPONSE AGENCIES Agriculture Licensing and Regulatory Affairs PLANT OWNER/OPERATOR Food Contamination Food Supply Public Utilities Liaison Sampling Energy Disruption Site Emergency Response Organization Corrections Education Temporary Housing Housing Notification Transportation Assist. Mass Transportation Onsite Control Feeding and Clothing Support Community Health Military Affairs Crisis Counseling Transportation Temporary Housing Security LOCAL Aerial &Ground Monitoring Support Natural Resources Human Services Public Works Health Fire Berrien County Environmental Impact Housing/Registration Social Services Sheriffs Fish/Game Contamination Feeding and Clothing Department Sampling Assistance Centers Warning Support Volunteer Agency Support Meteorological Analysis Warning Surface Water Evacuation Sheltering Transportation Blockading Public Information Transportation - Railroads - Air Traffic Re-entry Traffic Regulations Blockade Planning Standard A Revision 32
Page 24 of 221 PLANNING STANDARD B EMERGENCY RESPONSE ORGANIZATION Planning Standard B Revision 32
Page 25 of 221 B. EMERGENCY RESPONSE ORGANIZATION The purpose of this section is to describe the CNP organization during normal operations and during emergencies. Figure 2 shows the management structure for the Nuclear Generation Group (NGG). The Senior Vice President is the primary interface with local and state officials in matters concerning emergency preparedness.
B.1 Normal On-Site Operating Ormanization The normal on-site operating organization chart for the CNP is shown in Figure 3.
B.1.a. Vice Presidents The Vice President-Nuclear Generation Group is responsible for implementing all activities at the CNP in accordance with all applicable laws, regulations, AEP. and NGG policies while meeting the business needs of AEPNGG.
The Senior Vice President has the full authority and responsibility for operating, maintaining, and modifying the plant within established parameters and procedures. These responsibilities include ensuring effective implementation of the radiation protection program, directing the production, safety, work control and outage activities and Site Protective Services. and organizationalladministrative activities at the plant.
The Vice President-Site Support Services is responsible for personnel training and qualification.
B.1.b. Plant Mana-ger The Plant Manager is accountable to the Site Vice President for the operations, maintenance, radiation protection, chemistry and environmental functional areas of plant production. The primary responsibility for the Plant Manager is the safe operation of the nuclear facility in accordance with applicable corporate policies, laws, regulations, licenses, and technical requirements, to ensure that public health and safety, including that of employees, is protected from undue nuclear and industrial safety risks.
B.1.c. Maintenance Manager The Maintenance Manager reports to the Plant Manager and is accountable for managing and directing the activities related to the maintenance of all site equipment, structures, grounds and yards, and fire protection program. Managers that report to the Maintenance Manager provide the tools and support services necessary to optimize the safe, environmentally sound, cost effective efforts of the plant production organizations.
B.1.d. Director Nuclear Site Services The Director Nuclear Site Services is accountable to the Site Vice President and is responsible for oversight of the Security Plan, Emergency Plan, and is responsible for integration of the emergency response and security functions.
B.l.e. Emergency Preparedness Manager The Emergency Preparedness Manager ensures that the on-site and off-site emergency preparedness programs can protect the health and safety of the general public and site personnel while minimizing damage to the property and the environment in the event of an emergency. The Emergency Preparedness Manager is accountable to the Director Nuclear Site Services.
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Page 26 of 221 B.1.f. Security Manager Security Manager is accountable to the Director Nuclear Site Services and is responsible for developing and directing the nuclear security, access authorization, and fitness for duty programs.
B.1.g. Training Manager The Training Manager reports to the Vice President-Site Support Services and is accountable for the maintenance of INPO accreditation for eligible training programs, as well as non-accredited programs. This includes managing the development and presentation of training materials; maintenance of training materials, inclusive of the plant simulator and training aids; maintenance of training records and methods for assessing training effectiveness.
B.1.h. Operations Manager The Operations Manager reports to the Plant Manager and is accountable for operating the nuclear generating units in a safe, environmentally sound, cost effective, reliable and efficient manner in accordance with applicable corporate policies, laws, regulations, licenses, and technical requirements. The primary responsibility of the Operations Manager is the safe operation of the generation units to ensure that the public health and safety, including those of employees, is protected from undue industrial and nuclear safety risks.
B.1.i. Chemistry Manager The Chemistry Manager reports to the Plant Manager and is accountable for all activities related to plant system chemistry sampling, analysis, and control operations at CNP by optimizing fission product barrier effectiveness, maximize the life of plant equipment, and protect the health and safety of the public.
B.1.j. Radiation Protection Manager The Radiation Protection Manager, who is accountable to the Plant Manager, serves as the regulatory Radiation Protection Manager. The Radiation Protection Manager is responsible for the implementation and maintenance of the radiation protection programs. As such, the function of the Radiation Protection Manager is to establish and maintain the highest level of radiological safety attainable for the protection of plant employees, the public, and the environment.
B.1.k. On-Shift Operations Personnel The major assignments of the on-duty operating shift and the supplemental personnel in the Emergency Plan Organization are delineated in Table 1, CNP Staffing for Radiological Emergencies. Figure 4 is the chart for the On-shift Response Organization.
The Shift Manager, acting as the SEC, has overall responsibility for directing and implementing emergency and abnormal procedures to bring the unit to a safe condition. The Shift Manager retains the Emergency Direction and Control functions until relieved by a qualified Site Emergency Coordinator (SEC) or Emergency Director (ED). This position is the Table 1 on-shift column Shift Manager position for the Emergency Direction and Control functional area and Plant Operations functional area.
One of the two Unit Supervisors on shift aids and assists the Shift Manager. This position is the Table 1, CNP Staffing for Radiological Emergencies, On -Shift Plant Operations functional area Unit Supervisor.
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Page 27 of 221 The Work Control SRO reports to the Control Room in the event of an emergency to assist the Operations shift. The Work Control SRO provides staffing of the Table 1, CNP Staffing for Radiological Emergencies, On-Shift Plant Operations functional area Assistant Shift Manager/WCC-SRO.
One of the Reactor Operators provides staffing of the Table 1, CNP Staffing for Radiological Emergencies, Radiological Accident Assessment and Support functional area On-Shift Offsite Dose Assessment until relieved of that responsibility by the EOF.
Two of the Auxiliary Equipment Operators (AEOs) provide staffing of the Table 1, CNP Staffing for Radiological Emergencies, Notification/Communication functional area until relieved of that responsibility by the EOF. An additional AEO performs the Plant System Engineering, Repair and Corrective Actions functional area Repair and Corrective Actions Rad Waste Operator as part of the normal AEO duties.
The on-duty Shift Technical Advisor (STA) reports to the Control Room in the event of an emergency. The STA function is monitoring the Critical Safety Function Status Trees and recommending necessary procedure transitions. The Core/Thermal Hydraulic conditions are monitored by the Critical Safety Function Status Trees. The STA provides staffing of the Table 1, CNP Staffing for Radiological Emergencies, Plant System Engineering, Repair and Corrective Actions functional area On-Shift Core/Thermal Hydraulics and STA Technical Support. The STA reports to the SM and acts in an advisory capacity. Other STAs called in will report to the TSC, as needed.
B.1.I. On Shift non-Operations (Supplemental) Personnel The major assignments of the on-duty operating shift and the supplemental personnel in the Emergency Plan Organization are delineated in Table 1, CNP Staffing for Radiological Emergencies. Figure 4 is the chart for the On-shift Response Organization.
Three RP Technicians are assigned to each shift to provide the Table 1, CNP Staffing for Radiological Emergencies, Radiological Accident Assessment and Support functional area On-Shift Offsite, Onsite, and In-plant surveys. They also provide Protective Actions functional area On-Shift Radiation Protection coverage. The on-shift RP Technician staffing is augmented with the on-shift Chemistry Technicians and ten (10) RP Technicians called in for 60 minute supplemental staffing.
Two Chemistry Technicians are assigned to each shift to provide the Table 1, CNP Staffing for Radiological Emergencies, Radiological Accident Assessment and Support functional area On-Shift Chemistry positions making expertise immediately available to address chemistry issues.
The on-shift Chemistry staffing is augmented with one (1) Chemistry technician called in for 60 minute supplemental staffing.
The Mechanic, Electrician, and I & C Technician assignment ensures the Plant System Engineering Repair and Corrective Actions functional area On-Shift Repair and Corrective Actions maintenance disciplines expertise are immediately available to address maintenance issues. The on-shift Maintenance staffing is augmented with one each Mechanic, Electrician, and I&C Technician called in for 60 minute supplemental staffing.
The Fire Brigade provides the staffing for the On-Shift Fire Protection Functional Area and the Rescue and First Aid functional area. The brigade shift staffing is maintained as specified in the Technical Requirements Manual. Staffing for sixty minute response is provided by supporting local fire departments.
The Security force provides the staffing for the On-Shift and 60 minute Access Control and Accountability Functional Area. Security staffing is maintained as specified in the Security Plan.
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Page 28 of 221 B.2. On-Shift Emergency Coordination The Shift Manager, acting as the SEC, has overall responsibility for directing and implementing emergency and abnormal procedures to bring the unit to a safe condition.
B.3. Emergency Coordination Line of Succession The authority for initiation of the Emergency Plan is delegated to the senior supervisor of the on-duty operating shift (e.g., the Shift Manager).
Upon the classification of an emergency event, the Shift Manager (SM) assumes the position of Site Emergency Coordinator (SEC). The Shift Manager retains the Emergency Direction and Control functions until relieved by a qualified Site Emergency Coordinator (SEC) or Emergency Director (ED).
Upon arrival at the appropriate emergency response facility, the SEC reviews the emergency situation with the Shift Manager, assumes the SEC responsibilities for overall management of plant and emergency response functions, and assures that proper actions are being taken to mitigate the event. The SEC ensures that the proper State/County authorities, NRC and AEP officials are notified.
The SEC will function as acting Emergency Director until such responsibilities are assumed at the EOF.
Upon activation of the EOF the Emergency Director reviews the emergency situation with the SEC and assumes responsibility for control and co-ordination of all emergency and recovery operations from the SEC.
B.4. Non-delegable Emergency Coordinator Duties During the initial phase of a nuclear incident prior to activation of the EOF, the SEC has the non-delegable responsibility to make Protective Action Recommendations (PARs) to State/County authorities responsible for offsite emergency measures.
Upon activation of the EOF the Emergency Director assumes the non-delegable responsibility for making Protective Action Recommendations (PARs) to State/County authorities responsible for offsite emergency measures.
B.5 Emergency Response Organization The CNP Emergency Response Organization is presented in Figures 4 through 7.
Every effort is made to match professional skills with those needed in the ERO positions listed below. However, there may be some instances where, in actual assignments, the professional skill description may not match those listed with their respective position. In such cases, the individual in question has been determined to effectively fulfill the requirements of the position through training and qualification for the ERO staff position or because of similar current, or past professional experiences or duties.
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Page 29 of 221 B.5.a. Technical Support Center (TSC)
The TSC Emergency Response Organization is presented in Figure 5.
B.5.a.l. Site Emergqency Coordinator Upon arrival at the appropriate emergency response facility, the SEC reviews the emergency situation with the Shift Manager and assumes the following SEC responsibilities:
- 1. Overall management of plant and emergency response functions.
- 2. Assures that proper actions are being taken to mitigate the event.
- 3. Ensures that the proper State/County authorities, NRC and AEP officials are notified.
- 4. Until activation of the EOF, overseeing event classification and notification, responsibilities that may not be delegated.
- 5. Until activation of the EOF, making Protective Action Recommendations (PARs) to State/County authorities responsible for offsite emergency measures, a responsibility that may not be delegated.
- 6. Authorize dose extensions for emergency response related activities.
- 7. Authorize the distribution of potassium iodide tablets to plant personnel.
In addition to these immediate duties noted above, the SEC also has the authority to make policy decisions and expend funds necessary to cope with the event The SEC will function as acting Emergency Director until such responsibilities are assumed at the EOF.
The SEC provides staffing of the Table 1, CNP Staffing for Radiological Emergencies, Emergency Direction. and Control functional area sixty minute Senior Manager (SEC).
B.5.a.2 Assistant SEC The Assistant SEC reports directly to the SEC and is responsible for the overall operation of the TSC including;
- 1. Ensuring all TSC staff carry out their assigned functions;
- 2. Ensuring the timely exchange of information within the TSC staff and among various onsite and offsite emergency facilities;
- 3. Reviewing results of calculations performed by the Radiological Assessment Coordinator;
- 4. Managing the activities of the Plant Evaluation Team, and;
- 5. Organizing, prioritizing, and coordinating repair and corrective action with the Shift Manager and OSC Manager.
- 6. Assuming SEC duties if another senior manager is not available.
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Page 30 of 221 If the SEC is required to relocate to the EOF, the Assistant SEC will assume the joint responsibilities of the Assistant SEC and SEC unless relieved of SEC duties by an additional senior manager.
B.5.a.3. Plant Evaluation Team The Plant Evaluation Team (PET) operates out of the TSC and is made up of individuals from appropriate disciplines including Reactor Engineering, Maintenance Engineering, Operations, and Training.
The PET reports to the Assistant SEC and is responsible for but not limited to the following:
- 1. Providing an independent technical analysis of plant conditions;
- 2. Developing corrective action recommendations;
- 3. Providing technical assistance to operations personnel when requested;
- 4. Responding to queries from offsite agencies, as directed by the Assistant SEC; and
- 5. Assuming Severe Accident Management responsibilities if conditions dictate.
Members of the PET fill the following Table 1, CNP Staffing for Radiological Emergencies, Plant System Engineering, Repair and Corrective Actions functional area sixty minute positions:
Core/Thermal Hydraulics Electrical Mechanical B.5.a.4. Radiological Assessment Coordinator The RAC reports to the Assistant SEC and is responsible for, but not limited to, performing analysis of onsite radiological conditions and development of appropriate protectiVe actions for onsite response teams.
The RAC provides staffing of one (1) of the two (2) Table 1, CNP Staffing for Radiological Emergencies, Radiological Accident Assessment and Support functional area In-Plant Surveys sixty minute RP Technicians.
B.5.a.5. Shift Technical Advisor The on duty Shift Technical Advisor (STA) reports to the Control Room in the event of an emergency. Other STAs called in will report to the TSC and provide the relief to the Control Room STA for the Plant System Engineering, Repair and Corrective Actions functional area Core/Thermal Hydraulic sixty minute position.
B.5.a.6. Security Director The Security Director is responsible to the SEC for controlling the movement of personnel and vehicles onsite, ensuring continuing security, safety of personnel, and allowing efficient mobilization of emergency resources.
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Page 31 of 221 B.5.a.7. Administrative Coordinator Upon arrival at the TSC the Administrative Coordinator reports directly to the Assistant SEC and is responsible for but not limited to compiling information to be reported offsite, coordinating input from the PET and Radiological Assessment Coordinator, and obtaining the approval of the Assistant SEC prior to release of any information offsite.
B.5.a.8. Administrative Support Personnel Additional personnel needed to provide administrative support to the TSC include:
Administrative Support - duties include, but not limited to, transmission, receipt, duplication and distribution of documents.
Computer Analyst - duties include but not limited to, solving computer and software related problems.
Boardwriter - duties include, but not limited to, maintaining communication with other Emergency facilities and maintaining a chronological event status board.
B.5.b. Operations Support Center (OSC)
The OSC Emergency Response Organization is presented in Figure 5.
B.5.b.1. Operations Support Center Manager Upon arrival at the Operations Support Center (OSC) the OSC Manager assumes the following responsibilities:
- 1. Overall control and coordination of all OSC activities.
- 2. Coordinating with the TSC to identify the skills and number of personnel required to combat the emergency.
- 3. Notification of the TSC if appropriate skill levels and quantities of personnel are not available.
- 4. Oversee the implementation of accountability upon activation of a nuclear emergency alarm.
B.5.b.2. Assistant Operations Support Center Manager The Assistant Operations Support Center Manager aids and assists the OSC Manager as necessary.
B.5.b.3. Skill Supervisors and Contingency Director Skills Supervisors (Maintenance, Instrumentation and Control, Chemistry, Radiation Protection, Fire Brigade Leader) and the Contingency Director, when reporting to the OSC, are responsible for the following:
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Page 32 of 221
- 2. Direction of cognizant departmental personnel including non-licensed operators in the performance of emergency response activities as specified by the OSC Manager.
- 3. As appropriate, participate in pre-deployment briefings of Damage Control Teams.
Participation is limited to the supervisor's departmental responsibilities.
The positions of skill supervisor for Maintenance, Instrumentation and Control, Chemistry, Radiation Protection, and Fire Brigade Leader are held by therespective supervisors.
The Contingency Director is filled by a Senior Reactor Operator (SRO) as assigned by the Shift Manager.
The skills supervisors report to the OSC Manager.
B.5.b.4. Radiation Protection Director Upon arrival at the OSC a Radiation Protection Director assumes the following responsibilities:
- 1. Assessing the habitability of the OSC for the duration of the emergency.
- 2. Assessing the radiological aspects of Damage Control Team assignments and specifying the radiation protection measures to be taken for a given assignment.
- 3. Briefing Damage Control Teams on radiation protection measures prior to deployment.
- 4. The activation, direction, briefing and debriefing of Re-entry and Rescue Teams and Radiation Monitoring Teams.
The Radiation Protection Director reports directly to the OSC Manager.
B.5.b.5. Operations Support Center Boardwriter Upon arrival at the OSC the OSC Boardwriter assumes responsibility for establishing and maintaining communications with the TSC.
B.5.b.6. Damaqe Control Team The Damage Control Team reports directly to the OSC Manager and is responsible for the repair and restoration of damaged plant systems, equipment, or components.
Members of the Damage Control Team will be selected based on the type of damage that must be dealt with at the time.
B.5.b.7. Rescue Team Rescue Teams are used for rescue of injured and trapped personnel.
Rescue Teams shall be made up of at least two people, one person qualified in radiation protection and at least one other person.
B.5.b.8. In-Plant/On-Site Survey Team In-Plant/On-Site Survey Teams are used for radiological survey during reentry of site facilities, as well as support of other emergency teams which must gain access for decontamination, repair, and other activities that support event mitigation or recovery operations.
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Page 33 of 221 B.5.c. Emeraency Operations Facility (EOF)
The EOF Emergency Response Organization is presented in Figure 5 and Figure 6.
B.5.c. 1. Emergency Director Upon arrival at the EOF the Emergency Director is responsible for control and coordination of all emergency and recovery operations including, but not limited to, the following:
- 1. Overseeing activation of the EOF.
- 2. Overseeing event classification and notification, responsibilities that may not be delegated.
- 3. Ensuring the EOF assumes responsibility for communications with offsite organizations.
- 4. Ensuring the EOF assumes dose assessment responsibilities and directirng the activities of the Environmental Assessment Director in response to the emergency.
- 5. Making Protective Action Recommendations (PARs) to State/County authorities responsible for offsite emergency measures, a responsibility that may not be delegated.
- 6. Ensuring that access and security controls are established at the EOF.
- 7. Directing the development of recovery plans and procedures.
- 8. Event Termination.
The ED provides staffing of the Table 1, CNP. Staffing for Radiological Emergencies, Radiological Accident Assessment and Support functional area sixty minute Direction and Control Emergency Director (ED).
B.5.c.2. Communication Director Upon arrival at the EOF the Communication Director reports to the Emergency Director and is responsible for but not limited to the following:
- 1. Establishing a chronological history log of events and making this log available to EOF personnel;
- 2. Ensuring communications and dose assessment personnel are regularly updated on information required to perform their functions;
- 3. Establishing communications with the Berrien County Sheriff's Department, Michigan State Police, Nuclear Regulatory Commission, American Nuclear Insurers, INPO and the ENC/JIC.
B.5.c.3. Environmental Assessment Director Upon arrival at the EOF the Environmental Assessment Director (EAD) reports to the Emergency Director and is responsible for the direction and control of all offsite radiological aspects of the emergency. This includes dose projection calculations, protective action recommendation development, and the collection and analysis of radiological samples.
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Page 34 of 221 The EAD provides staffing of the Table 1, CNP Staffing for Radiological Emergencies, Radiological Accident Assessment and Support functional area Offsite Dose Assessment sixty minute EAD.
B.5.c.4. Environmental Assessment Coordinators (2)
Upon arrival at the EOF the Environmental Assessment Coordinators report to the Environmental Assessment Director and are responsible for but not limited to calculating offsite radiation exposures, accumulating offsite radiation measurement data, keeping track of in-plant effluent radiation monitors, and projecting radiation dose estimates based on actual or potential releases.
The EAC provides staffing of one (1) of the three (3) Table 1, CNP Staffing for Radiological Emergencies, Radiological Accident Assessment and Support functional area Offsite Survey sixty minute RP Technicians.
B.5.c.5. Offsite Radiation Monitoring Offsite Radiation Monitoring is performed by survey teams assembled in the OSC. Upon leaving the OSC the Offsite Survey Team(s) report to the Environmental Assessment Director in the EOF via the Field Monitoring Team Communicator to receive briefing and instructions. It is the responsibility of the Offsite Survey Team(s) to survey and record offsite radiological data at selected locations and routes, as defined in mission briefings and subsequent instructions.
Qualified RP Technicians fill the position for persons performing the survey.
B.5.c.6. Field Monitoring Team Communicator The Field Monitoring Team Communicator reports to the Environmental Assessment Director and is responsible for communications between the Environmental Assessment Director and the Offsite Survey Team(s) performing Offsite Radiation Monitoring.
B.5.c.7. Industry Support Communicator The primary responsibility of the Industry Support Communicator is to provide an interface between the EOF and the designatedagency (i.e., INPO, NSSS/Fuel vendor(s), and American Nuclear Insurers). This interface will include initial notification of an event at CNP and periodic updates as to the status of the plant.
B.5.c.8. Engineering, Design and Site Services Manager The Engineering, Design and Site Services Manager reports to the ED and is responsible for coordinating the design and construction activities of the utility, NSSS supplier, and other outside vendors. The Engineering, Design and Site Services Manager is assigned to the EOF.
B.5.c.9. Scheduling and Planning Manager The Scheduling and Planning Manager serves as a support resource for the ED in the areas of planning, scheduling and expediting of recovery operations. The Scheduling and Planning Manager is assigned to the EOF and reports to the Engineering Design and Site Services Manager.
B. 5.c. 10. Public Affairs Liaison The Public Affairs Liaison confers with the EOF staff to determine responses to public affairs personnel requests for information and communicates with public affairs personnel at the ENC/JIC to provide information about the emergency when requested.
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Page 35 of 221 B.5.c. 11. Administrative Support Personnel Additional personnel needed to provide administrative support to the EOF include Communicators, Boardwriters, Runners, Computer Analysts and Fax Operators.
Administrative Support - duties include, but not limited to, transmission, receipt, duplication and distribution .of documents.
Computer Analyst - duties include but not limited to, solving computer and software related problems.
Boardwriter - duties include, but not limited to, maintaining communication with other Emergency facilities and maintaining a chronological event status board.
B.5.d. Emergency News Center/Joint Information Center (ENC/JIC)
The ENC, located at the Nuclear Generation Group Headquarters Building, approximately 14 miles southeast of the Plant in Buchanan, Michigan, will be staffed by individuals from the Energy Information Center, CNP, and Corporate Communications - Generation. The ENC will be under the direction of the Media Center Manager. Throughout the operation of the ENC, the Media Center Manager maintains constant communication with AEP Corporate Communications -
Generation. See Figure 7 for an organization chart illustrating staffing and information flow for the ENC/JIC. Figure 5 illustrates ENC/JIC functional relationship to the remainder of the Emergency Response Organization.
When the Governor of the State of Michigan declares a "State of Disaster or Emergency" the ENC becomes the Joint Information Center at the governor's declaration. See Figure 7 for an organization chart illustrating staffing and information flow for the ENC/JIC.
B.5.d.1. Media Center Manager The Media Center Manager is responsible for coordinating all information at the ENC/JIC with counterparts from the county, state, and federal agencies and others involved with the emergency. The Media Center Manager will maintain contact with utility management dealing with the emergency to develop news releases, supervise all communications with the news media and relay information to other appropriate utility employees.
B.5.d.2. Technical Communicator The Technical Communicator establishes communication between the ENC/JIC, TSC, and EOF.
The Technical Communicator obtains plant status from the TSC and assists in preparation of press releases.
B.5.d.3 Media Area Coordinator The Media Area Coordinator is responsible for ensuring media representatives have adequate facilities to properly cover media briefings and to provide press kits, related general background information, and written statements from each briefing. The Media Area Coordinator is not to perform any briefings or explanations to the media.
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Page 36 of 221 B.5.d.4. Utility Spokesperson The Utility Spokesperson is the "single utility spokesperson" when dealing with the news media.
The Utility Spokesperson reports to the Media Center Manager and will be the source of utility statements quoted in press briefings or releases and will represent the utility at formal press briefings to answer technical questions about the incident.
B.5.d.5. JIC Set-up Coordinator The JIG Set-up Coordinator is responsible for the physical arrangements of the setting up of the ENC/JIC.
B.5.d.6. Public Inquiry/Media Monitoring Coordinator The Public Inquiry/Media Monitoring Coordinator operates out of the ENC/JIC and reports to the Media Center Manager. The Public Inquiry/Media Monitoring Coordinator is responsible for logging all telephone calls and is expected to work with personnel in the JIG Command Center to correct misinformation. It is also the responsibility of the Public Inquiry/Media Monitoring Coordinator to monitor radio and television broadcasts to make certain information about the incident is being reported accurately.
B.5.d.7. Support Office Coordinator The Support Office Coordinator is responsible for the operations of the Support Office. The Support Office contains a back-up telephone system as well as facilities for outside media calls, faxing, reproduction, and other communication supplies.
B.5.e. Liaisons B.5.e.1. Offsite Liaisons Upon declaration of an Alert, or higher classification, liaisons will be sent to their respective offsite emergency facilities. One liaison will be sent to the Berrien County Emergency Operations Center (EOC) to provide an interface between the ED and the Berrien County Sheriffs Department. A second liaison will be sent to the State EOC to provide interface between the ED and the Michigan State Police. A third liaison will be sent to the Incident Command Post for security related events. The duties of these liaisons will be responsible for, but not limited to:
- 1. Receiving plant reports.
- 2. Assisting in the interpretation of data originating from the plant.
- 3. Providing and clarifying information on plant operations and requirements.
- 4. Coordinating the efforts of these offsite organizations.providing assistance with the plant.
emergency response management.
- 5. Responding to questions from representatives of the various agencies involved in the offsite EOCs.
Planning Standard B Revision 32
Page 37 of 221 B.5.e.2. Emergency Response Facility Liaison If called upon, the Operations Manager or designee reports to the affected Control Room and becomes the Emergency Response Facility (ERF) Liaison and may assume the following responsibilities:
- 1. Assists the SM/SEC by communicating with the other emergency response centers via the Managers telephone bridge circuit.
- 2. Communicates SM/SEC developed/approved priorities, mitigation strategies, protective action recommendations, and other pertinent information.
The alternates for this position are the other Plant Operations supervisors.
B.5.e.3 Incident Command Post Liaison If called upon, a plant knowledgeable person is dispatched to the Offsite Response Organization to act as the Incident Command Post Liaison (ICPL).
The Incident Command Post (ICP) Liaison position responds to security related events at the plant. The ICP Liaison, during security events, reports to the ICP and provides communication between the Site Security force, Local Law Enforcement Agency (LLEA) personnel and the EOF.
Additional resources such as Security, Radiation Protection, Fire Brigade, and/or Operations may be dispatched to assist.
B.6. Overall Organization and Communication The communication links between various emergency centers established as a result of implementing the Emergency Plan are delineated by Functional Organization Charts in Figures 8 and 9.
Initial notification flow sequence is shown in Figure 8.
Figure 9 shows the relationship between various emergency centers and organizations after the incident has occurred and all channels, of communication have been established.
B.7. Plant Staff Augmentation B.7.a. Logistics Support Emergency Director directs the development of recovery plans and procedures.
The Scheduling and Planning Manager serves as a support resource for the ED in the areas of planning, scheduling and expediting of recovery operations. The Scheduling and Planning Manager is assigned to the EOF and reports to the Engineering Design and Site Services Manager.
B.7.b. Reentry/Recovery Technical Support The Plant Evaluation Team (PET), operating out of the TSC develops corrective action recommendations. When the corrective action plans are decided upon, the Engineering, Design and Site Services Manager, operating out of the EOF and reporting to the ED, coordinates the design and construction activities of the utility, NSSS supplier, and other outside vendors to support the corrective actions for recovery.
Planning Standard B Revision 32
Page 38 of 221 B.7.c. Management Level Interface with Government During an event the Emergency Director is responsible for control and coordination of all emergency and recovery operations including communications with offsite organizations, and interface with governmental authorities.
B.7.d. Releases to Media The Media Center Manager coordinates all information at the ENC/JIC with counterparts from the county, state, federal agencies, and others involved with the emergency.
The Utility Spokesperson is the "single utility spokesperson" when dealing with the news media.
B.8. Offsite Agencies and Or-ganizations Appendix B, Agreements with Off-Site Support Agencies, identifies the primary response agencies that can be relied upon in an emergency to provide assistance. In addition various nuclear industry organizations can be called upon to provide technical assistance as needed.
Procedures have been developed and are in place that assures the ability to notify and request assistance from those agencies identified in Appendix B. These procedures also provide the ability to notify and request assistance from other nuclear industry organizations. These include, but are not limited to:
- 1. NSSS Supplier.
- 2. Consultants on radiological and radwaste requirements.
- 3. Nuclear Fuel Supplier.
B.8.a. Notification of American Nuclear Insurers The American Nuclear Insurers notification criteria for nuclear emergencies has been brought into alignment with the emergency classification (EAL) system described in Section D and also identifies methods for follow-up communications.
American Nuclear Insurers requires notification in the event of an Alert, Site Area Emergency or General Emergency.
A representative of the NGG shall notify American Nuclear Insurers via the American Nuclear Insurers emergency notification number.
American Nuclear Insurers requires that periodic updates be supplied of releases of radioactive material from the plant, plant status and impending protective action for members of the public.
These updates are the responsibility of the Industry Support Communicator in the EOF.
Appendix I, Notification of American Nuclear Insurers, and Figure 13 show the ANI notification procedure.
B.9. Offsite Groups Although many offsite groups may be used in the event of an emergency, there are three offsite groups that have agreed to serve in the capacities outlined in this plan should an incident occur.
These groups are the Berrien County Sheriffs Department, the State of Michigan, and the Federal Government. The responsibilities and authorities of the County, State and Federal Governments and their interrelationship with this emergency plan are outlined in the following Planning Standard B Revision 32
Page 39 of 221 paragraphs. Written agreements with various offsite agencies that are part of the overall response organization within the Plume Exposure Pathway Emergency Planning Zone are listed in Appendix B of this plan.
B.9.a. Berrien County Sheriffs Department The Berrien County Sheriffs Department, which is the lead agency in implementing the Berrien County Radiological Emergency Plan, has established an Emergency Operating Center (BCEOC) in accordance with the Berrien County Emergency Plan. This center is located in Benton Harbor, Michigan about 14 miles from the plant. It is equipped with the appropriate communications equipment to coordinate all the local offsite protective actions.
The Berrien County Sheriff has the responsibility and authority for coordination of all local resources in the event of a hostile threat or a radiological emergency, including establishing an Incident Command Post when applicable.
The Sheriffs Department also has a marine division within its organization for the control of water traffic should it be necessary. Although the Sheriffs Department is primarily responsible for coping with an emergency using its own resources, the County Sheriff will call upon state resources to supplement the local resources when the local resources are clearly insufficient to cope with the emergency.
Once the Governor of Michigan has declared a State of Disaster under Act 390, the Berrien County Sheriffs Department will implement the Governor's Orders and will perform the following:
- 1. Contact other local agencies as needed for assistance.
- 2. Control offsite vehicular traffic.
- 3. Initiate the warning system and issue clear instructions of what protective action is required for the populace.
- 4. Take other appropriate action, if so advised by the Michigan State Department of Environmental Quality (DEQ) or upon notification by the SEC or ED that conditions requiring immediate offsite protective action have been reached. (For further details see the Berrien County Plan- Warning Annex.)
B.9.b. State of Michigan The State of Michigan has developed the Michigan Emergency Management Plan. In the event that offsite protective action is required due to a hostile threat or a radiological emergency at CNP, this Michigan Emergency Management Plan can also be placed into effect to assist the Berrien County Sheriffs Department. A brief outline follows of the plan's provisions for nuclear facility emergencies.
Under the Michigan Emergency Management Plan, the Department of State Police will provide guidance for the development of state and local nuclear incident emergency plans for dealing with peacetime radiological incidents. These are defined as situations in which normal control over radioactive materials is accidentally lost, with resulting hazard to the health and safety of the general public.
The State Director of Emergency Management and Homeland Security is responsible for planning and coordinating the Disaster Relief Forces and their activities for the state. The Nuclear Power Plant Project Coordinator, Emergency Management and Homeland Security Division, State Police is designated as the Emergency Planning Coordinator for the State's radiological emergency response planning portion of the plan.
Planning Standard B Revision 32
Page 40 of 221 The State Police, Emergency Management and Homeland Security Division, at the direction of the Governor, will coordinate all organizations in the State for nuclear incident activities, maintaining liaison with all levels of government.
The primary State Emergency Operations Center (SEOC), acting in support of the BCEOC, will perform all state governmental functions. This SEOC is located at 4000 Collins Road, Lansing, Michigan.
Alternate sites to the primary State EOC will be located in one of the State Police District Headquarters as indicated in the Michigan Emergency Management Plan.
The basic responsibilities and duties of the State Government agencies that provide support during a nuclear incident are outlined below.
B.g.b.1. The Primary State Response Agencies and a summary of their responsibilities are:
B.9.b.l.a. The Department of Michigan State Police (MSP)
- Receives notification of nuclear incidents from the utility and alerts state agencies and warns affected local governments (adjacent states and adjacent counties are also alerted);
- Operates the State Emergency - Operations Center, and the field team centers;
- Provides overall direction and control of all activated state and local disaster relief forces;
- Provides notification to local jurisdictions based on technical advice by the DEQ to evacuate and/or shelter in-place.
- Assists local jurisdictions to est~blish security around restricted area;
- Collects and compiles damage assessment information;
" Prepares and coordinates emergency public information releases and advises the .news media;
" Assists local jurisdictions with any transportation accidents;
- Establishes procedures to handle terrorist activities at nuclear power plants; and
" Provides liaison to various federal organizations and agencies.
B.9.b.l.b. The Department of Environmental Quality (DEQ) a Monitors the environment, personnel, and equipment in support of emergency operations;
- Evaluates the public health and medical aspects of radiological effects;
- Recommends measures and establishes limits to mitigate radiological effects on public health; Planning Standard B Revision 32
Page 41 of 221
" Recommends measures to control the spread of radioactivity;
" Establishes radiological safety criteria for recovery, re-occupancy, and rehabilitation of affected areas;
- Provides technical advice and assistance for offsite decontamination activities and support.
- Sample surface water.
- Conduct other monitoring as requested.
- Monitor areas for contamination of the environment and recommend suitable countermeasures to reduce the impact of contamination of the environment.
" Provide meteorological support and technical advice for use in analyzing or projecting radiological release hazards.
B.9.b.2. The State Support Response Agencies and a summary of their responsibilities are:
B.9.b.2.a. Department of Agriculture 0 Responsible for sampling agriculture areas for food contamination and recommending appropriate counter measures in conjunction with the Department of Public Health.
0 Responsible for taking appropriate actions to prohibit contaminated foods from entering the market.
B.9.b.2.b. Licensing and Regulatory Affairs 0 Provide liaison to the public utility companies.
- Provide recommendations for handling energy disruptions resulting from a shutdown due to a nuclear incident.
- Provide advice and guidance to affected persons regarding insurance claims and adjustments.
B.9.b.2.c. Department of Corrections
- Provide for mass care, feeding, clothing and sheltering.
- Provide mass transportation assistance for affected persons and disaster relief workers.
B.9.b.2.d. Department of Education
- Provide support for mass care, feedingand housing.
" Provide mass transportation assistance.
Planning Standard B Revision 32
Page 42 of 221 B.9.b.2.e. Department of Community Health
- Provide crisis counseling and intervention center assistance to affected persons.
- Provides coordination of medical and emergency medical services to affected areas.
B.9.b.2.f. Department of Military Affairs
- Provide transportation and manpower support for evacuation counter measures.
- Provide security support to local law enforcement operations, including control of access to restricted or evacuated areas within the Emergency Planning Zone (EPZ).
B.9.b.2.g. Department of Natural Resources
" Monitor areas accessible by fish and game.
- Take action to prevent or minimize contamination of fish and game.
- Take samples of fish and game, which may have been exposed or contaminated.
- Assist local authorities to warn and evacuate occupants of state parks, beaches, and other recreational areas if necessary.
B.9.b.2.h. Human Services
- Assist with sheltering and housing evacuated population;
- Provide feeding and clothing if required to persons affected.
" Establish assistance centers for affected individuals and families to receive advice and assistance.
" Coordinate assistance made available by volunteer relief agencies and the American Red Cross.
B.9.b.2.i. Department of Transportation 6 Provide for mass transportation assistance to local jurisdictions if required.
- Provide advice and assistance support regarding barricades and security measures around an evacuated or restricted area.
" Provide advice on traffic regulation and control for the evacuation of designated areas.
- Provide assistance for the rescue of entrapped workers and persons.
Planning Standard B Revision 32
Page 43 of 221 The Michigan Department of State Police is notified of an emergency condition in the manner described in Section E by the SEC or designee. The State Police will set up a command post at the SEOC at 4000 Collins Road in Lansing, Michigan. The State Police will also set up a Field Team Center (FTC) to coordinate the dispatch of field teams to monitor for radiological contamination. The FTC will be established at the Michigan Department of Transportation Coloma Service Garage on Red Arrow Highway at 1-196. The State Police will coordinate their efforts with the BCEOC and with the EOF, as needed. After notification has been given, the Michigan Department of State Police will assist Berrien County and perform the actions listed in Section B.9.b.
B.9.c. Federal Government The Federal Government has established the Nuclear/Radiological Incident Annex under the National Response Plan to coordinate Federal radiological assistance. The Nuclear/Radiological Incident Annex establishes:
" A means of requesting and providing Federal radiological assistance from existing Federal resources, and
- An operational framework for coordinating the radiological monitoring and assessment activities of Federal agencies during radiological emergencies occurring within the United States and its territories.
The Nuclear Regulatory Commission (NRC) as the Coordinating Agency is responsible for coordinating the response of all other federal agencies in accordance with the National Response Plan.
The Department of Energy (DOE) Chicago Operations Office, located at Argonne National Laboratory, has radiation monitoring capability available. It will, as requested by NGG Management or any of the indicated offsite groups (Sheriff, State Police or DEQ), assist in the offsite emergency program.
The Chicago Operations Office will, upon request by NGG Management or any of the indicated offsite groups, participate in the monitoring of the offsite areas affected and in the analysis of field data and will recommend measures to be taken offsite for protecting the public. It will also advise the ED of the recommendations.
The DOE Operations Office will, to the extent they are available during the protection and recovery stage, continue to advise the Emergency Management and Homeland Security Division of the Michigan Department of State Police and provide monitoring and analytical capability as requested.
B,9.d. Fire Department CNP maintains an onsite fire fighting brigade; this capability is expected to be sufficient for all fires onsite. In the event offsite assistance is desired or needed, local fire departments may be called upon. The Fire Protection Shift Supervisor is responsible for fire fighting activity onsite as well as notifying offsite departments when assistance is needed.
The primary fire departments that will respond to a fire emergency at CNP are:
Lake Township Fire Department Bridgman Fire Department Letters of agreement to provide fire fighting assistance to CNP can be found in Appendix B of this Plan.
Planning Standard B Revision 32
Page 44 of 221 B.9.e. HAZMAT Team CNP maintains an onsite hazardous material spill response team that is capable of responding to most emergency spill events. If there is insufficient manpower or material available, assistance from the Berrien County HAZMAT Team will be requested. A letter of agreement offering their services can be found in Appendix K of this plan.
AEP has also contracted with environmental firms to provide emergency spill response assistance. These contractors are listed in the Spill Prevention Control and Countermeasures (SPCC) Plan and Pollution Incident Prevention (PIP) Plan, copies of which are located in the Shift Manager's office.
Planning Standard B Revision 32
Page 45 of 221 Figure 2 Management Structure of the Nuclear Generation Group
- ------------- --- --- --- --- --- --- ----- --- --- --- Senior Vice President LI Counsel Corp. Legal Services I HF a esou Site Vice Vice President Performance Assurance Employee Cc 1--- Manager upr Services Manag(
AEP Corporate HR President Site Support Director S Mana er
.;oCenter Manager Nuclear Corporate M g Information Communications Manager Technology Planning Standard B Revision 32
Page 46 of 221 Figure 3 Site Operations Planning Standard B Revision 32
Page 47 of 221 Figure 4 On Shift Response Organization Shh Technical Advisor "Fire Brigade Planning Standard B Revision 32
Page 48 of 221 Figure 5 COOK NUCLEAR PLANT EMERGENCY RESPONSE ORGANIZATION AT AN ALERT CLASSIFICATION Emergency News Ergeny*
t Di'edo.
CenterlJoint Control - ----- Information Center Room -
Meae ente
- 4 ed Dinenten Anit
,,,I.=s I -................
Corponat. Co d.atko-Reporting Responsibility Coordination Information Flow ----
Indicates Location Outside Facility Planning Standard B Revision 32
Page 49 of 221 Figure 6 Organization of the Emergency Directors Staff at the EOF I Site Emergency Coordinator I PlantSta-ff PeTSC/OSC Personnel L
Off-site Survey Reporting Responsibility IL Teams Coordination Information Flow r-------
L -- Indicates Location Outside Facility Planning Standard B Revision 32
Page 50 of 221 Figure 7 Emergency News Center/Joint Information Center Organization rIe n I Director Emergency I r Vice President and Director L Corporate Communications I Reporting Responsibility Coordination Information Flow I - Location Outside Facility Indicates L.---
Planning Standard B Revision 32
e GIý1[ Q TABLE 1 CNP Staffing for Radiological Emergencies Functional Area Major Tasks Emergency Position On-Shift 60 mins.'
Plant Operations and Control Room Staff Shift Manager 1 Assessment of Operational Assistant Shift ManagerlWCC-SRO I Aspects Unit Supervisor 2*
Control Room Operator 4*
Auxiliary Equipment Operator 4*
Emergency Direction and Command and Control Shift Manager 12 Control Senior Manager (SEC) 1 Notification/Communication Licensee Reactor Operators Local / State Qualified Operator 1 Federal Qualified Operator 1 Augmenting ERO members 2 Radiological Assessment Direction and Control Emergency Director (EOF) 1 Offsite Dose Assessment Reactor Operator/EAD 12 1 In-Plant Surveys RP Technician 1 2 Onsite Surveys RP Technician 1 1 Offsite Surveys RP Technician 1 3 Chemistry Chemistry Technician 2 1 Plant System Engineering, Technical Support - OPS Shift Technical Advisor 1 Repair and Corrective Core Damage Shift Technical Advisor 12 1 Actions Electrical I Mechanical I Repair and Corrective Actions Mechanical Maintenance 12 1 Electrical Maintenance 22,3 1 Instrument & Controls Maintenance 1 1 Radiological Waste ,1 In Plant Protective Actions Radiation Protection RP Technicians 2; 4 Fire Protection Fire.Fighting Fire Brigade 5 Local support Rescue and First-Aid Fire Brigade ..............2 Local support Access control & Security, Communications, Personnel Shift Security Supervisor 1 As per Security accountability Accountability Security Personnel Per Security Plan Plan Total 27 23 L __________________23-
- 1. The augmentation times presented in this table are goals developed from the guidance of Table B-1 in NUREG-0654, FEMA-REP-1, Rev. 1 "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants."
- 2. May be provided by shift or other personnel assigned from other functions. Not included in the total.
The number indicated is for two operating units. With the unaffected unit in operation, maintain at least 1 Unit Supervisor, I Control Room Operator, and 1 Auxiliary Equipment Operator assigned to the unaffected unit.
Planning Standard B Revision 32
Page 52 of 221 PLANNING STANDARD C EMERGENCY RESPONSE SUPPORT AND RESOURCES Planning Standard C Revision 32
Page 53 of 221 EMERGENCY RESPONSE SUPPORT AND RESOURCES C.1. Federal Radiological Assistance C.1.a. Requesting Federal Assistance The Emergency Director (ED) or the Site Emergency Coordinator (SEC) has the authority to request federal radiological assistance.
A request for federal radiological assistance should be made through the Department of Energy's (DOE)
Chicago Operations Office located at 9800 S. Cass Avenue, Argonne, Illinois 60439. The Chicago Operations Office is designated to provide the primary assistance following a radiological incident in the Radiological Assessment Program (RAP) Region 5.
When a request for RAP assistance is made, the following information should be provided:
- 1. Nature of the incident.
- 2. Name, title, location and telephone number of person requesting assistance.
- 3. Time of the incident.
- 4. Location of the incident.
- 5. Accessibility of location.
- 6. Whether a fire is involved.
- 7. Relative seriousness of incident.
- 8. Weather conditions.
- 9. Personnel involved (injuries, contamination, etc.).
- 10. Local/state/federal agencies that have been notified..
- 11. Whether the news media is aware of the incident; whether false or exaggerated reports are known to have circulated.
C.1.b. Federal Resources The immediate objective of the DOE's Chicago Operations Office is to dispatch a team of specialists to the incident site where the team will:
- 1. Evaluate the hazard.
- 2. Take or recommend action to counteract and control any acute hazard offsite from the licensee's site.
- 3. Establish communication with State and local authorities and the press.
If the Chicago Operations Office determines a need for additional assistance beyond its own capabilities, it may initiate the Nuclear/Radiological Incident Annex.
Planning Standard C Revision 32
Page 54 of 221 The Nuclear/Radiological Incident Annex has been established by the federal government to coordinate federal radiological assistance. The Nuclear/Radiological Incident Annex establishes:
- A means of requesting and providing Federal radiological assistance from existing federal resources, and
- An operational framework for coordinating the radiological monitoring and assessment activities of Federal agencies during radiological emergencies occurring within the United States and its territories.
Through the Nuclear/Radiological Incident Annex the DOE's Chicago Operations Office has the capability to call upon resources located throughout the United States and will provide this assistance where necessary or when requested. Some of the immediate resources that can be provided are (but not limited to):
- 1. Provide team(s) of RAP personnel to assist in offsite monitoring.
- 2. Provide portable direct reading radiological measuring instruments.
- 3. Provide counting equipment.
- 4. Provide aerial surveillance and measurement.
- 5. Provide analytical capability to augment the licensee and state's capability.
- 6. Provide resources as may be available at the Argonne National Laboratory.
- 7. Provide health physics assistance.
- 8. Provide environmental control assistance.
- 9. Provide remote handling equipment on an as needed basis.
Additional information pertaining to federal radiological assistance can be found in Appendix E, Description of Federal Radiological Assistance, to this plan. Appendix E is divided into three sections.Section I is a brief introduction to the federal radiological assistance.Section II describes typical capabilities and expected mobilization and travel times for some of the Region 5 radiological assistance resources available within Region 5 of the DOE's radiological assistance program.Section III describes additional DOE capabilities that can be activated dependent on the assistance needed and how it is activated.
C.1.c. Federal Response Support Resources Appendix E contains information on the local resources required to support the RAP.
C.2. Liaisons C.2.a. Liaisons to CNP Not applicable C.2.b. Liaisons from CNP Section B.5.e.1. details the liaisons provided to the Berrien County EOC, Incident Command Post and the Michigan SEOC.
C.3. Radioloqical Laboratories Section H.6.c Offsite Laboratory Facilities discusses offsite laboratory availability.
Planning Standard C Revision 32
Page 55 of 221 C.4. Offsite Agencies and Organizations Appendix B identifies the primary response agencies that can be relied upon in an emergency to provide assistance. In addition various nuclear industry organizations can be called upon to provide technical assistance as needed. Procedures have been developed and are in place that assures the ability to notify and request assistance from those agencies identified in Appendix B. These procedures also provide the ability to notify and request assistance from other nuclear industry organizations. These include, but are not limited to:
- 1. NSSS Supplier.
- 2. Consultants on radiological and radwaste requirements.
- 3. Nuclear Fuel Supplier.
C.4.a. American Nuclear Insurers The American Nuclear Insurers notification criteria for nuclear emergencies has been brought into alignment with the. emergency classification (EAL) system described in Section D and also identifies methods for follow-up communications.
American Nuclear Insurers requires notification in the event of an Alert, Site Area Emergency or General Emergency.
A representative of the NGG shall notify American Nuclear Insurers via the American Nuclear Insurers emergency notification number.
American Nuclear Insurers requires that periodic updates be supplied of releases of radioactive material from the plant, plant status and impending protective action for members of the public. These updates are the responsibility of the Industry Support Communicator in the EOF.
Appendix I and Figure 13 show the ANI notification procedure.
C.4.b. Nuclear Transportation Accidents A Voluntary Assistance Agreement has been entered into between electric utilities involved in the transportation of source material, special nuclear material and by-product material received, possessed, used or transferred. This agreement sets forth the understanding and agreement with respect to the mutual undertaking to each other in the situation where an emergency occurs by reason of a nuclear materials transportation accident and assistance is provided by one utility to another. A copy of this agreement can be found in Appendix B.
C.4.c. Nuclear Power Plant Accidents A voluntary assistance agreement has been entered into between electric utilities involved in the operation of nuclear power plants. This agreement sets forth the understanding and agreement with respect to their mutual undertaking to each other in a situation where an emergency occurs at a nuclear power plant and assistance is provided by one utility to another. A copy of this agreement can be found in Appendix B, and contact information is contained in the Emergency Plan Procedures.
Planning Standard C Revision 32
Page 56 of 221 PLANNING STANDARD D EMERGENCY CLASSIFICATION SYSTEM
.Planning Standard D Revision 32
Page 57 of 221 D. EMERGENCY CLASSIFICATION SYSTEM In general, Initiating Conditions (ICs) describe conditions that require implementation of emergency actions. Emergency Action Levels (EALs) are, where possible, pre-designated, non-subjective thresholds for entry into a particular Emergency Classification Level (ECL). The action to be taken by the operating shift depends on the severity of the incident, its effects and type.
The SEC or ED will exercise subjective judgment to ensure all incidents are classified at the highest appropriate ECL based on the following criteria:
- Conditions warrant a declaration of an Unusual Event when events are in processor have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.
" Conditions warrant a declaration of an Alert when events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of Hostile Action. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.
. Conditions warrant a declaration of a Site Area Emergency when events are in process or have occurred which involve an actual or likely major failures of plant functions needed for protection of the public or Hostile Action that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or, (2) that prevent access to equipment needed for the protection of the public.
Any releases are not expected to result in exposure levels which exceed EPA Protective Acton Guideline exposure levels beyond the site boundary.
" Conditions warrant a declaration of a General Emergency when events are in process or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity or Hostile Action that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels beyond the site boundary.
The ICs/EALs were created following the methodology of NUMARC/NESP-007, Rev. 2. The ICs/EALs will classify an event or condition into one of four Emergency Classification Levels (ECLs) if an emergency classification is appropriate.
D. 1. Emergency Action Levels Emergency Action Levels are pre-determined, site specific, observable thresholds for plant Initiating Conditions that place the plant in a given emergency class. An EAL can be an instrument reading; an equipment status indicator, a measurable parameter (onsite or offsite); a discrete, observable event; results of analyses; entry into specific emergency operating procedure; or another phenomenon which, if it occurs, indicates entry into a particular emergency class.
Planning Standard D Revision 32
Page 58 of 221 The severity of the emergency. classification may change over time with the emergency being upgraded from one classification level to another.
Incidents will typically be classified in a lower emergency classification at first and then escalated to a higher classification if the situation deteriorates.
Each of the four emergency classification levels has characteristic Emergency Action Levels for various parameters.
Planning Standard D Revision 32
Page 59 of 221 Table 2 is the Fission Product Barriers matrix for modes 1 through 4 used to determine EALs. Table 3 describes the EAL Initiating Conditions for the various Emergency Condition Categories (ECCs) for Modes 1 through 4. Table 4 describes the Initiating Conditions for Modes 5 and 6 and defueled condition (shutdown).
D.2. Initiating Conditions Initiating Condition - One of a predetermined subset of nuclear power plant conditions where either the potential exists for a radiological emergency or such an emergency has occurred.
Some of the initiating conditions and events are directly identifiable by their existence, such as operation of a safety system or a fire, while others require observation of process or radiation monitoring instrumentation.
Station procedures contain the specific instrumentation, equipment status, and non-process conditions and. events that are used to establish the emergency classification.
Table 2 is the Fission Product Barriers matrix for modes 1 through 4 used to determine EALs. Table 3 describes the EAL Initiating Conditions for the various Emergency Condition Categories (ECCs) for Modes 1 through 4. Table 4 describes the Initiating Conditions for Modes 5 and 6 and defueled condition (shutdown).
D.2.1 Emergency Declaration Timeliness Station procedures contain instructions to declare an emergency within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and shall promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.
Planning Standard D Revision 32
Page 60 of 221 Table 2 FISSION PRODUCT BARRIER MATRIX - Mode 1-4 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Loss of TWO Fission Product Any TWO of the Following: Loss or Potential Loss of Either Fuel Clad Loss or Potential Loss of Containment Barrier.
Barriers AND Potential Loss of 1. Loss or Potential Loss of Fuel Clad. or RCS Barrier.
Third Barrier. 2. Loss or Potential Loss of RCS.
- 3. Loss of Containment Barrier.
1.FUEL CLAD BARRER LOSS (L) POTENTIAL LOSS (P)
.1Core Cooling CSFST Core Cooling CSFST - RED Core Exit Thermocouples > 7570 OR RVLIS Level < 46% (NarrowRange)
.2Containment Radiation > 200 R/hr. None
.3 Primary Coolant Activity >300 uCi/cc 1-131 dose equivalent None OR Core Damage > 5.0% clad failure
.4 SEC Judgment Any condition in the opinion of the SEC that indicates loss of the Fuel Any condition inthe opinion of the SEC that indicates potential loss of the Clad barrier. E Fuel Clad barrier. E
- 2. RCS BARRIER LOSS (L) POTENTIAL LOSS (P)
.1RCS Leak Rate (unisolable) > available makeup capacity as indicated by complete loss of RCS > capacity of one centrifugal charging pump in normal charging subcooling. line up.
.2 Steam Generator Leakage Entry into OHP 4023.E-3, SGTR Ruptured SG with leak > capacity of one charging pump in AND normal charging line up.
A Non-isolable secondary line break or a prolonged release (>30 minutes) of contaminated secondary coolant resulting in a radioactive release to the environment from the affected SG.
.3 Containment Radiation > 10 R/hr None
.4RCS Integrity CSFST None RCS Integrity CSFST - RED
.5Heat Sink CSFST None Heat Sink CSFST - RED
.6 SEC Judgment Any condition in the opinion of the SEC that indicates loss of the RCS Any condition inthe opinion of the SEC that indicates potential loss of the barrier. E RCS barrier. E Does not include a release through the condenser air ejectors, or the gland steam condenser vents for the purpose of declaration of a SITE AREA EMERGENCY.
z EAL's in these tables are NOT complete. Refer to referenced basis page (PMP-2080-EPP-101, Attachment 3) for complete description.
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Page 61 of 221 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Loss of TWO Fission Product Any TWO of the Following: Loss or Potential Loss of Either Fuel Clad Loss or Potential Loss of Containment Barrier.
Barriers AND Potential Loss of 1. Loss or Potential Loss of Fuel Clad. or RCS Barrier.
Third Barrier. 2. Loss or Potential Loss of RCS.
- 3. Loss of Containment Barrier.
- 3. CONTAINMENT BARRIER LOSS (L) POTENTIAL LOSS (P)
.1 Containment Radiation None > 1000 R/hr.
_Core damage > 20% clad failure.
.2 Containment Integrity Unisolable breach of containment. None OR Rapid unexplained containment pressure or sump level drop following pressure rise caused by a LOCA.
OR Containment pressure/sump level NOT performing as expected for conditions.
OR Entry into ECA-1.2, LOCA Outside Containment.
.3 SG Secondary Side Release Primary to secondary leak rate > Tech. Spec. limit. None AND Release of secondary coolant from the associated steam generator to the.
environment isoccurring:I
.4 Containment CSFST None Containment CSFST - RED
.5 Containment Hydrogen None >4.0%
OR Containment Hydrogen >0.5% AND any Hydrogen Control equipment inoperable.
.6 Containment Pressure Control None BOTH CTS trains OR BOTH containment air retire fans inoperable OR fail to auto start on their containment pressure setpoint OR containment pressure
>!2p~sig.
.7 Core Exit Thermocouples None Core Cooling CSFST -RED AND Restoration procedures; not effective within 15 minutes.
.8 SEC Judgment Any condition in the opinion of the SEC that indicates loss of the Any condition inthe opinion of the SEC that indicates potential loss of the Containment barrier. Y Containment barrier. X 1 Does not include a release through the condenser air ejectors, or the gland steam condenser vents for the purpose of declaration of a SITE AREA EMERGENCY.
Planning Standard D Revision 32
Page 62 of 221 Table 3 INITATING CONDITIONS - Mode 1 - 4 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT SEC Judgment - All Modes H-1 SEC Judgment H-1 SEC Judgment H-1 SEC Judgment H-1 SEC Judgment Conditions indicate actual or imminent substantial Conditions indicate likely or actual major failures Conditions indicate that plant safety systems may Conditions indicate a potential degradation of the core damage with potential loss of containment or of plant functions needed to protect the public, be degraded and additional personnel are needed level of safety of the plant.
the potential exists for an uncontrolled radioactive for additional monitoring.
release that may exceed EPA limits at the site boundary.
GENERAL EMERGENCY (SITE AREA EMERGENCY (ALERT UNUSUAL EVENT HAZARDS AND OTHER CONDITIONS H-2 Security H-2 Security H-2 Security H-2 Security HOSTILE ACTION resulting inLoss of Physical HOSTILE ACTION within the PROTECTED HOSTILE ACTION within the OWNER Confirmed Security Condition which indicates a Control of the Facility. AREA CONTROLLED AREA or airborne attack threat. potential degradation inthe level of safety of the plant.
- 1. A HOSTILE ACTION isoccurring or has I. A HOSTILE ACTION isoccurring or has 1.SECURITY CONDITION that does not 1.A HOSTILE ACTION has occurred such that occurred within the PROTECTED AREA as occurred within the OWNER CONTROLLED involve a HOSTILE ACTION as reported by plant personnel are unable to operate reported by the Security Shift Supervisor. AREA as reported by the Security Shift Security Shift Supervision.
equipmentlisted functions required to maintain safety below: .
Supervisor. OR O
- 2. A credible site-specific security threat
" Reactivity Control (ability to shut down OR notification.
the reactor and keep it shutdown) - 2. A validated notification from the NRC of a OR
" RCS Inventory (ability to cool the core) LARGE AIRCRAFT attack threat within 30 3. A validated notification from NRC
" Secondary Heat Removal (ability to minutes of the site. providing information of an aircraft threat.
maintain heat sink)
- 2. A HOSTILE ACTION has caused failure of spent fuel cooling systems and IMMINENT fuel damage is likely. E H-3 CR Evacuation H-3 CR Evacuation Control Room evacuated AND control not Control Room evacuation initiated.
established in 15 minutes. "z"_'
H-4 Fire H-4 Fire.
Fire OR explosion affecting plant operations. Fire inProtected Area NOT extinguished S within 15 minutes of detection.
H-5 Toxic Gas H-5 Toxic Gas Toxic OR flammable gas release that threatens Toxic OR flammable gas release lives OR affects ability to achieve and maintain affecting plant operation.
Mode 5.
H-8 ISFSI Damage to a loaded cask CONFINEMENT BOUNDARY.
Planning Standard D Revision 32.
Page 63 of 221 FGENERAL EMERGENCY I SITE AREA EMERGENCY -FALERT UNUSUAL EVENT NATURAL/DESTRUCTIVE PHENOMENA N-1 Seismic N-1 Seismic Seismic event indicated by: Seismic event indicated by:
1.Seismic instrument activated. I.Seismic instrument activated OR OR 2.Ground motion detected by Control Room crew 2.-round motion detected by Control Room AND crew.
I.Visble major damage in vital area.
OR 2.Plant Trip.
N-2 Tornado/wind N-2 Tornado/wind 1.Tornado strike in Vital Area I.Tornado strike within Protected Area.
OR 2.>90 mph wind for >15 minutes.
N-3 Structural Visible damage to a structure containing systems required to achieve and maintain Mode 5.
N-4 Vehicle Collision N-4 Vehicle Collision Vehicle collision affecting Vital Area. Vehicle collision affecting systems or structures within the Protected Area.
N-5 MT Failure N-5 MT Failure Main turbine generated missile penetrates Vital Area. Main turbine rotating component failure causes visible damage or damages generator seals.
N-6 Flooding Flooding in Vital Area affects safety related equipment.
N-7 Explosion Unanticipated explosion within Protected Area causes visible damage to permanent structures or equipment.
Planning Standard D Revision 32
Page 64 of 221 GENERAL EMERGENCY I SITE AREA EMERGENCY ALERT UNUSUAL EVENT ABNORMAL RADIATION LEVELS/EFFLUENTS R-1 Effluent release R-1 Effluent release R-1 Effluent release R-1 Effluent release Site boundary dose > 1 REM TEDE or 5 REM CDE to Site boundary dose > 100 mrem TEDE Unplanned Rad release >200X ODCM limits for Unplanned Rad release >2X ODCM limits for thyroid based on: or 500 mrem CDE to thyroid based on: >15 minutes based on: > 60 minutes based on:
- 1. Survey results 1. Survey results.
OR OR 1. Effluent Rad monitor 200X high alarm 1. Effluent Rad monitor 2X high alarm setpoint.
- 3. Effluent monitor readings >15 minutes 3. Effluent monitor readings >15 minutes. OR E 2. Release Rad monitor 200X high alarm 3. Gas or liquid sample results 2X ODCM release limit.
setpoint.
- 3. Gas or liquid sample results 200X ODCM release limit.
E R-2 Plant Rad level R-2 Plant Rad level Rad levels that impede plant operations based on: Unexpected reading on Area Monitor 1000X the 24 hr average.
1.> 15 mR/hr in Control Rm(s) /CAS OR 2.>100 mR/hr at remote S/D areas.
E R-3 Loss of level R-3 Loss of level Major damage to irradiated fuel or loss of level Uncontrolled lowering in refueling cavity, SFP that has or will uncover fuel outside of the reactor or Transfer Canal indicated by:
vessel based on:
- 1. Inability to maintain > 643'4" in SFP or Transfer Canal 1.Visual observation of levels. with irradiated fuel present OR OR 2.Rad monitor alarms 2. Inability to maintain > 643'4" in the refueling cavity OR with irradiated fuel in containment.
3.Level < 632'4" SFP or Transfer Canal.
___________________________ ______________________________E Planning Standard D Revision 32
Page 65 of 221 F GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT SYSTEM MALFUNCTIONS S-1 RPS failure S-1 RPS failure S-1 RPS failure
- 1. Auto and manual Reactor Trip fails from Auto and manual Reactor Trip fails. from Auto Reactor Trip fails AND manual trip Control Room AND Subcriticality and Core Control Room. successful from Control Room.
- 2. Subcriticality and Heat Sink CSFSTs are RED.
S-2 Loss of AC S-2 Loss of AC S-2 Loss of AC S-2.Loss of AC
- 1. Prolonged loss of all AC (A and D -T buses) AND Loss of all AC (A and D - T buses) for AC power supply to T buses reduced to a Loss of ALL OFF-SITE power (Auxiliary, Reserve Core Cooling CSFST- ORANGE. >15 minutes. single source for > 15 minutes. and 69kv Transformers) to the T Buses for > 15 OR minutes.
- 2. Loss of all AC (A and D - T buses) expected to last for > 4 hrs.
S-3Loss of DC power Loss of ALL vital DC buses AB AND CD for >
15 minutes (bus volts < 220v)
S-5Loss of Hot SD sys.
Loss of ability to achieve or maintain hot shutdown based on entry into:
1.OHP 4023.FR-H.1, Response to Loss of Secondary Heat Sink OR 2.OHP 4023.FR-C.1, Response to Inadequate Core Cooling.
Planning Standard D Revision 32
Page 66 of 221 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT SYSTEM MALFUNCTIONS S-6 Loss of Alarms S-6 Loss of Alarms S-6 Loss of Alarms Loss of ability to monitor alarms during 1.Loss of either: 1.Loss of either:
a transient indicated by: a. Safety system annunciator panels in a unit for > 15 minutes a. Safety system annunciator panels in a unit for >
- 1. Loss of Safety System annunciator panel(s) for -OR- 15 minutes:
> 15 minutes. b. A known loss of Attachment 2 Critical -OR-AND Parameters indications for > 15 minutes: b. A known loss of Attachment 2 Critical 2.A known loss of Attachment 2 Critical -AND- Parameters indications for > 15 minutes:
Parameters indications for > 15 minutes. 2. Additional monitoring is required. -AND-AND -AND- 2. Additional monitoring is required.
available (PPC, SPDS). a NO 3. Annunciator/Indicator PLANNED action. loss does not result from 3. Annunciator/Indicator-AND-loss does not result from aib -AND- PLANNED action.
AND 4. Either -AND-
- 4. A significant transient is in progress. a. A significant transient is in progress, 4. Compensatory Indications are available.
-OR-
- b. Compensatory Indications NQT available z
S-7 Degraded Clad I.RCS activity> 1.0 uCi/gramn 1-131 dose equivalent for > 48 hrs.
OR 2.RCS activity > 100/E uCi/gram.
S-8 RCS Leakage RCS leakage exceeds 10 gpm pressure boundary leakage, SG tube leakage or unidentified leakage OR
> 25 gpm identified leakage.
S-9 Tech Spec Unit not in required mode within LCO time limits.
S-10 Loss of Comm.
Unplanned loss of all on or off-site communications E
Planning Standard D Revision 32
Page 67 of 221 Table 4 INITIATING CONDITIONS - Mode 5 & 6 and Defueled GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT HAZARDS AND OTHER CONDITIONS H-I SEC Judgement H-i SEC Judgement H-1-SEC Judgement H-1 SEC Judgement Conditions indicate actual or imminent substantial Conditions indicate likely or actual major failures Conditions indicate that plant safety systems may Conditions indicate a potential degradation of the core damage with potential loss of containment or of plant functions needed to protect the public, be degraded and additional personnel are needed level of safety of the plant.
the potential exists for an uncontrolled radioactive for additional monitoring.
release that may exceed EPA limits at the site boundary.
H-2 Security H-2 Security H-2 Security H-2 Security HOSTILE ACTION resulting in Loss of Physical HOSTILE ACTION within the PROTECTED HOSTILE ACTION within the OWNER Confirmed Security Condition which indicates a Control of the Facility. AREA CONTROLLED AREA or airborne attack threat, potential degradation inthe level of safety of the plant.
1.A HOSTILE ACTION has occurred such that 1. A HOSTILE ACTION is occurring or has 1.A HOSTILE ACTION is occurring or has I. SECURITY CONDITION that does not plant personnel are unable to operate occurred within the PROTECTED AREA as occurred within the OWNER CONTROLLED involve a HOSTILE ACTION as reported by equipment required to maintain safety reported by the Security Shift Supervisor. AREA as reported by the Security Shift Security Shift Supervision.
functions listed below: Supervisor. OR
" Reactivity Control (ability to shut down the reactor and keep it shutdown) OR 2.A credible site-specific security threat
" RCS Inventory (ability to cool-the core) 2. A validated notification from the NRC of a notification.
- Secondary Heat Removal (ability to LARGE AIRCRAFT attack threat within 30 OR maintain heat sink). minutes of the site. 3.A validated notification from NRC OR providing information of an aircraft threat.
E
- 2. A HOSTILE ACTION has caused failure of spent fuel cooling systems and IMMINENT fuel.
damage is likely. E z
H-3 CR Evacuation H-3 CR Evacuation Control Room evacuated AND control not Control Room evacuation initiated.
established in 15 minutes. Z H-4 Fire H-4 Fire Fire OR explosion affecting plant operations. Fire inProtected Area NOT extinguished
_ _ __ within 15 minutes of detection.
H-5 Toxic Gas H-5 Toxic Gas Toxic OR flammable gas release that threatens Toxic OR flammable gas release affecting plant lives OR affects ability to achieve and maintain operation.
Mode 5.
H-8 ISFSI Damage to a loaded cask CONFINEMENT I BOUNDARY Planning Standard D Revision 32
Page 68 of 221 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT NATURAL/DESTRUCTIVE PHENOMENA N-1 Seismic N-1 Seismic Seismic event indicated by: Seismic event indicated by:
I.Seismic instrument activated.
1.Seismic instrument activated.
OR OR 2.Ground motion detected by Control Room crew. 2.Ground motion detected by ControlRoom AND crew.
l.Visble major damage inVital Area.
OR 2.Plant Trip.
N-2 Tornado/wind N-2 Tornado/wind I.Tomado strike in Vital Area I.Tomado strik-e in Protected Area.
OR 2>90 mph wind for >15 minutes.
N-3 Structural Visible damage to a structure containing systems required to achieve and maintain Mode 5.
N-4 Vehicle Collision N-4 Vehicle Collision Vehicle collision affecting Vital Area. Vehicle collision affects systems or structures inthe Protected Area.
N-5 MT Failure N-5 MT Failure Main turbine generated missile penetrates Vital Area. Main turbine rotating component failure causes visible damage or damages generator seals.
N-6 Flooding Flooding in Vital Area affects safety related equip.
N-7 Explosion Unanticipated explosion within Protected Area causes visible damage to permanent structures or equipment.
Planning Standard D Revision 32
Page 69 of 221 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT ABNORMAL RADIATION LEVELS/EFFLUENTS R-1 Effluent release R-1 Effluent release R-1 Effluent release R-1 Effluent release Site boundary dose > 1 REM TEDE or 5 REM Site boundary dose> 100 mrem TEDE Unplanned Rad release >200X ODCM limits for >15 Unplanned Rad release >2X ODCM limits for CDE to thyroid based on: or 500 mrem CDE to thyroid based on: minutes based on: > 60 minutes based on:
l.Suveyresuts1 .Survey results results O.Survey OR 1. Effluent Rad monitor 2X high alarm setpoint 2.Dose assessment 2.Dose assessment 1.Effluent Rad monitor 200X high alarm setpoint. OR OR OR OR 2. Release Rad monitor 2X high alarm setpoint 3.Effluent monitor readings >15 minutes 3.Effluent monitor readings >15 minutes. 2. Release Rad monitor 200X high alarm setpoint. OR OR 3. Gas or liquid sample results 2X ODCM release limit.
- 3. Gas or liquid sample results 200X ODCN release limit.
I:
R-2 Plant Rad level R-2 Plant Rad level Rad levels that impede plant operations based on: Unexpected reading on Area Monitor 1O0OX the 24 hr average.
1.> 15 mR/hr in Control Room(s) or CAS OR
- 2. >100 mR/hr at remote S/D areas.
R-3 Loss of level R-3 Loss of level Major damage to irradiated fuel or loss of Uncontrolled lowering in refueling cavity, level that has or will uncover fuel outside of SFP or Transfer Canal indicated by:
the reactor vessel based on:
I.Visual observation of levels. I. Inability to maintain > 643'4" in SFP or Transfer OR Canal with irradiated fuel present 2.Rad monitor alarms OR OR 2. Inability to maintain > 643'4" in the refueling cavity 3.Level < 632'4" SFP or Transfer Canal. with irradiated fuel in containment.
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Page 70 of 221 GENERAL EMERGENCY SITE AREA EMERGENCY [ ALERT [UT-uNUSUAL EVENT COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTIONS C-3 Loss of AC C-3 Loss of AC Loss of ALL AC power to A and D T-buses for Loss of ALL OFF-SITE power (Auxiliary,
> 15 minutes. Reserve and 69kv transformers) to the T buses for> 15 minutes.
Mode 5,6 Mode 5,6 and defueled C-4Loss of Water Level in the Reactor Vessel C-4 Inability to Maintain a Unit in that has or will Uncover Fuel in the Reactor Cold Shutdown Vessel 1.Loss ofshutdown cooling as evidenced by entry i.Loss of shutdown cooling as evidenced by entry into OHP into OHP 4022.017.001, "Loss of RHR 4022.017.001, "Loss of RHR Cooling" Cooling" AND AND 2.Core uncovery as indicated by: 2.Temperature rise that either:
- b. Reactor Vessel Water Level <614 feet b. Results in an UNCONTROLLED RCS temperature rise approaching the cold Mode 5,6 shutdown T/S limit of200'F Mode 5,6 C-5 Degraded Clad l.RCS activity >i.0ý.Ci/grams 1-131 dose equivalent for > 48 hrs.
OR 2.RCS activity> 100/E uCi/gram.
Mode 5,6 C-6 Loss of Comm.
Unplanned loss of all on or off-site communications.
Mode 5,6 C-7 Loss of DC power Unplanned loss of ALL vital DC buses AB AND CD for >15 minutes (bus volts _<220v)
Modes 5,6 Planning Standard D Revision 32
Page 71 of 221 PLANNING STANDARD E NOTIFICATION METHODS AND PROCEDURES Planning Standard E Revision 32
Page 72 of 221 E. NOTIFICATION OF EMERGENCY RESPONSE PERSONNEL AND ORGANIZATIONS E. 1. Notification of Offsite Response Organizations During an emergency condition, control of offsite actions rests with the appropriate government authorities with technical assistance provided by various members of the plant staff. This technical assistance is provided through the use of the plant's communication system.
A current list of all key support agencies with their telephone numbers is maintained in the Shift Manager's office so that they may be notified of any emergency condition. This call list is incorporated into the plant Emergency Plan Procedures and is checked quarterly to verify that all phone numbers on the list are correct. It is the responsibility of the SM, acting as the SEC early in an event, the SEC, or the ED, once the EOF is operational, to ensure that these offsite response organizations are notified. Notification shall include the message authentication in order to permit further action by the Sheriffs Department.
Notification is given to the Berrien County Sheriffs Department and to the Michigan State Police Operations Office in Lansing, Michigan within 15 minutes following the recognition and verification of an Unusual Event, Alert, Site Area Emergency, or General Emergency condition. Any incident that requires initiation of the Nuclear Emergency Alarm requires notification of the NRC and notification of the appropriate offsite groups.
Upon notification with authentication, the Berrien County Emergency Operations Plan will be implemented.
The Berrien County Sheriffs Department has established a county Emergency Operating Center (EOC) in Benton Harbor, Michigan, which will be the focal point for immediate offsite county agency actions when notified of an emergency condition. The Berrien County Sheriff is the Berrien County Administrator of the Office of Emergency Management/Homeland Security and is responsible for coordinating all local resources when notified of an emergency condition. An offsite liaison is sent to the Berrien County EOC at the emergency classification of Alert or higher classification. The liaison assists in the interpretation of incoming plant reports, and acts as the liaison between the Plant and the Berrien County Sheriff's Department.
The organization of the Department of State Police is such that initial notification is made to the State Police Operations Office in Lansing, Michigan, The Michigan State Police will then set up an EOC at 4000 Collins Road in Lansing, Michigan. An offsite liaison will also be sent to the State EOC upon activation by the State Police to perform a function similar to that of the person at the Berrien County EOC. Plant status updates will be provided to the State and County using separate lines. All communications, where practical, to the State and County will be via the offsite liaison at their respective EOCs.
Immediately following the initial notification of the Berrien County Sheriffs Department and the Michigan State Police, the SM/SEC/ED shall also notify the Nuclear Regulatory Commission's Operations Center, and the appropriate senior AEPNGG management.
The decision to evacuate offsite individuals or to take other protective action rests with the appropriate civil authorities. The SEC or ED is responsible for notifying the appropriate State/County authorities that the conditions for offsite protective actions have been reached.
Figure 8 shows the initial notification process for nuclear incidents. A current list of all appropriate company officials and county, state and federal authorities with their telephone numbers is maintained as part of the plant ERO Phone Directory. A listing of offsite support groups is attached as Appendix B.
Planning Standard E Revision 32
Page 73 of 221 E.l.a Notification of Nuclear Transportation Accidents Incidents involving nuclear material that result from transportation accidents offsite as specified in Section C.4.b and within the service territory of AEP shall be reported to the applicable state government. The appropriate information required in Sections E.3 and E.4 and other pertinent information shall be provided as necessary. If the Plant has been requested to respond to a transportation accident involving nuclear material by another utility under the Voluntary Assistance Agreement, the Plant shall inform the state and Berrien County government of the request, nature and location of the accident, expected response and recommended precautions to be taken by the responsible offsite authorities.. The response team shall keep the on-scene government representatives and the Plant informed on the status of the accident.
E.2 ERO Alert, Notification and Mobilization E.2.a Onsite (Plant Staff)
If an emergency condition should arise that would affect individuals on or offsite, this emergency plan will be initiated. There are two plant emergency alarms: A Fire Alarm and a Nuclear Emergency Alarm. Each audible signal is unique and easily distinguishable so that no confusion as to its purpose will develop.
If the incident or condition is a fire, the Fire Alarm is sounded.
The Nuclear Emergency Alarm is a horn designed to produce a distinct sound different from any other alarms in the plant. It may be activated manually from either the Unit 1 Control Room or Unit 2 Control Room. The senior supervisor of the on-duty shift (e.g., the Shift Manager) has the authority to activate the Nuclear Emergency Alarm. In the absence of the Shift Manager, the senior NRC licensed operator assigned in the Control Room has the authority to activate the Nuclear Emergency Alarm. An announcement over the Plant Public Address System (PA) identifying the incident will be made including a brief description of the incident, and the appropriate alarm for the determined condition will be sounded throughout the plant and at the switchyard. In addition, in. certain areas where the PA system and/or the Nuclear Emergency Alarm are not audible, strobe lights are installed to provide a visual warning signal.
In the case of some Security events, the Nuclear Emergency Alarm would not be sounded.
Persons responding to the NEA could become targets of opportunity. Instructions to onsite personnel would be made using the Plant PA system.
Immediate sounding of the Nuclear Emergency Alarm is required for incidents which, in the judgment of the Shift Manager, result in:
" release of radioactivity that could cause conditions for excessive exposure to plant personnel, or
" plant conditions that could cause conditions for excessive exposure to plant personnel, or
" a Site Area Emergency, or General Emergency, except where harm to personnel is possible (e.g. Security event driving the SAE or GE).
The sounding of the Nuclear Emergency Alarm dictates an immediate evacuation of all plant personnel and plant visitors to the onsite assembly areas identified in Section J.1. with the exceptions that:
- 1. The operators on duty for each unit report to their respective Control Room.
- 2. Personnel designated as part of the Plant Emergency Response Organization report to their assigned facilities. (i.e. TSC, OSC, EOF, ENC/JIC)
Planning Standard E Revision 32
Page 74 of 221
- 3. Individuals in outlying areas of the plant are informed by Site Protective Services of the emergency classification in effect and the action to be taken.
- 4. Security personnel will remain on post unless otherwise directed.
- 5. Initiation of the procedures for evacuation of all employees and visitors within the Cook Energy Information Center.
Immediately after initiation of the Nuclear Emergency Alarm, the emergency call list is initiated, if not already initiated, and measures are taken by the Shift Manager and Shift Technical Advisor to evaluate conditions on the site.
The decision to take onsite protective actions, beyond sounding of the Nuclear Emergency Alarm is the responsibility of the SEC. Any Emergency Plan incident other than routine tests that requires initiation of the Nuclear Emergency Alarm requires notification of the NRC by the SEC or ED and notification of appropriate offsite groups as determined by the SEC or ED.
E.2.b Offsite (Plant Staff)
An Emergency Plan Procedure for notification of plant personnel and an ERO Phone Directory have been developed to provide the information that is necessary to summon plant personnel during emergency conditions to staff the Emergency Response Facilities. This procedure may be implemented anytime the SEC determines that it is necessary to augment on duty emergency personnel with off-duty plant personnel.
A current list of all key personnel with their telephone numbers is maintained in the Shift Manager's office so that they may be notified. This call list is incorporated into the ERO Phone Directory and is checked quarterly to verify that all phone numbers on the list are correct. When the Nuclear Emergency Alarm is sounded, notification of the Site Vice President (or Alternate),
and Operations Director is the responsibility of the Shift Manager or designee. Calls made by on-shift personnel initiate the ERO call out to staff the Emergency Response Facilities. If the automated paging/call out fails, a backup manual call out procedure is initiated.
Personnel that are called out, or are on call, report to their assigned Emergency Response Facility immediately upon receiving notification to respond at an Alert or higher emergency classification.
In the event of security related event the notification alerts the emergency response personnel, who normally report to on-site facilities, to report to an alternate location such as the Buchanan Office Building.
Once the Nuclear Emergency Alarm has sounded, only authorized personnel are permitted to enter the Owner Controlled Area. This access control is a function of the Plant Security Force which may be further augmented by the Berrien County Sheriff and/or the Michigan State Police.
E.3. Content of Initial Emergency Messages Initial emergency messages sent from the Plant to appropriate offsite response organizations shall contain the information listed below, as it becomes available.
- 1. Class of Emergency.
- 2. Date and time of classification.
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Page 75 of 221
- 3. Indicate if a release is occurring or has occurred.
- 4. Wind direction and wind speed.
- 5. Protective Measures recommended (if known) based on magnitude or severity of an actual release and current meteorological conditions, or the condition of the core/containment.
- 6. Potentially affected population areas.
- 7. Plant name
- 8. Verification to confirm authenticity of call.
E.4 Content of Follow-up Emergency Messages Follow-up messages sent from the Plant to appropriate offsite response organizations should contain the following information, as it becomes available:
- 1. Location of incident, name and telephone number (or communication channel identification) of caller.
- 2. Type and description of release (airborne, waterborne, surface spill) and estimated duration/impact times (actual or projected).
- 3. An estimate of the quantity of radioactive material released or being released and the release point.
- 4. Physical form of released material, including estimates of the relative quantities of noble gases; iodines and particulates.
- 5. Meteorological conditions (wind speed, direction, atmospheric stability, or precipitation,* if any).
- 6. Projected dose rate at site boundary, integrated dose from time of message to projected end of release at site boundary.
- 7. Projected dose rate and integrated dose for 2, 5 and 10 miles.
- 8. Prognosis for worsening or terminating the event based on plant information.
E.5 Not Applicable E.6. Public Notification The Berrien County Sheriff is responsible for overall supervision of the warning function for offsite actions.
The Berrien County Emergency Operations Plan-Nuclear Power Plant Incident Procedures contain the time estimated for adverse and favorable conditions for various sectors in the 10 mile EPZ for 2 mile, 5 mile, and 10 mile radii. The time estimates include the times required for:
- Notification
- Public Preparation Planning Standard ER Revision 32
Page 76 of 221
- Movement
- Total Evacuation
- Confirmation
- Evacuation & Confirmation Special Considerations to include or consider in each sector The Berrien County Plan includes provisions for:
- 1. Alerting local radio, television stations and, local news media to be prepared to transmit Emergency Public Information. This initial notification will be accomplished via a radio receiver/transmitter that will record the emergency information transmitted by the Sheriffs Department to designated locations simultaneously. Additional information will be provided as described in Section G.
- 2. Coordination with other law enforcement and fire services to extend public notification of the appropriate Emergency Plan areas utilizing public address systems on emergency vehicles.
- 3. Warning of the Warren Dunes park (recreation) area populace of the emergency and action to be taken.
- 4. Activation and use of the emergency warning system consisting of sirens located throughout the 10 mile EPZ. Activation of this system is controlled solely by the Berrien County Sheriff and is based upon recommendations made by the appropriate authority.
The D. C. Cook Plant Emergency Preparedness Department has overall responsibility for testing, maintenance, and repair of the Alert and Notification System (ANS) Sirens.
The ANS is the primary method for alerting and notifying the population within the plume exposure EPZ. Backup ANS for the EPZ is achieved through Route Alerting which is contained within the State of Michigan and Berrien County Radiological Emergency Response Plans. Refer to Appendix B for FEMA letter describing the provisions for backup ANS.
A description of the warning system is in the emergency preparedness brochure/calendar provided in Appendix D, Emergency Preparedness Brochure.
E.7. Public Information Messagqes The State of Michigan and Berrien County have developed and incorporated in their respective emergency plans sample messages for release of information to the public.
These messages will utilize supporting information obtained directly from the Plant or from the plant liaison persons located at the Berrien County EOC, State EOC and at the JIC (when activated).
Using the information gathered from various sources, the message(s) will contain pertinent information to the public for the declared emergency classification. The message(s) describe the Planning Standard E Revision 32
Page 77 of 221 warning, sheltering, evacuation and other protective measures deemed necessary by the appropriate County and/or State officials.
Additionally, Berrien County has prepared sample Public Information Bulletins to provide pertinent information on protective actions that may be taken in the event of a nuclear incident. These bulletins are shown in the Berrien County Emergency Plan.
Planning Standard E Revision 32
Page 78 of 221 Figure 8 Nuclear Incident Initial Notification Process
-j
- Selectively notified for support Planning Standard E Revision 32
Page 79 of 221 Figure 9 CNP Emergency Response Communications Flow CONTROL TCMA F ROOM SUPPORT CENTER EMERGENCY NEWS CENTEý:A.
OPERATIONS JOINT INFORMATION - -
SUPPORT CENTER -
CENTER
.- ' STATE
.- `COMMUNICATIONS I- COORDINATOR I !
NEWS EMERGENCY MEDIA &
NRC OPERATIONS PUBLIC FACILITY GOVERNOR ICP NSSS/FUEL PROVIDER(S)
STATE EOC . 0 CONSULTANTS SBERRIEN BERRIEN... 4 AMERICAN 10N[ RR NUCLEAR Planning Standard E Revision 32
Page 80 of 221 PLANNING STANDARD F EMERGENCY COMMUNICATIONS Planning Standard F Revision 32
Page 81 of 221 F. EMERGENCY COMMUNICATIONS F.1. Licensee, Local, State, and NRC Emergency Communications Implementation procedures for the use of communication networks to notify all parts of the emergency organization are outlined in the CNP Emergency Plan Procedures that are available in each of the emergency response facilities. The communications network consists of communications systems that are available on a 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day basis to communicate with AEP personnel, State, County, and the NRC during emergency conditions.
F.l.a. State and Local Communications The Berrien County Sheriffs Department and the Michigan State Police dispatch are continuously staffed so capability exists for 24-hour radio and telephone communication with the Plant. The telephone and radio links to the Berrien County Sheriff's Department dispatchers also accesses the county emergency response organizations. The 911 system is an alternate method to access the county emergency response organizations.
The primary means of notification to the Sheriffs Department is by telephone. As an alternate, notification of an emergency to the Sheriffs Department in Berrien County is made with a transmitter and receiver combination device from the Unit 1 Control Room. This device is operated with a frequency and a license maintained by the State of Michigan. Controls for the device are also available on the Plant Security consoles. This establishes a communication link between the Control Room and the Sheriff's Department in Berrien County.
The primary means of notification. to the State Police Operations Center in Lansing is by telephone. A back-up radio system is maintained between CNP and the Michigan Department of State Police in Niles, Michigan. In this system, a radio transceiver maintained at the CNP is set at a frequency used by the State Police. These radios are equipped such that the State Police are assured that any transmissions to them originated at the Cook Plant.
Communications between CNP and the local fire departments are by means of telephone calls.
The fire departments would respond immediately upon notification of an emergency at CNP.
Radio Radio communication capability is provided to contact the Berrien County Sheriffs Department and the Michigan Department of State Police Post 53 (in Niles) from the Unit I Control Room, Central Alarm Station (CAS), and the Secondary Alarm Station (SAS) in the event of failure of telephone company circuits. Suitable normal and back-up power supplies are also provided.
Bridgman Local Telephone Service.
Local commercial telephone service provides circuits between Bridgman and the CNP.
F.l.b. Communications with Contiguous Governments in the EPZ's Notifying the State of Indiana and the Michigan counties within a 50 mile radius of CNP of the incident classification, protective actions recommended, etc. is the responsibility of the Berrien County Sheriff's Department and the Michigan Department of State Police. Berrien County and Michigan is the only county and state within a 10 mile radius of CNP.
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Page 82 of 221 F.1.c. Communications with Federal Emergency Response Organizations The "Communications" section of Appendix E, Description of Federal Radiological Assistance, outlines communication with the DOE Radiological Assistance Plan responders.
F.l.d Offsite Communications The communications system at CNP provides the versatility required in the event of a nuclear incident. The system operation utilizes private telephone lines, dedicated microwave links (OPX),
2-way radio, the normal in-plant communication system (PABX), and the capability to reach outside extensions through various system company switchboards. The emergency response centers will have the following communications capability:
PABX/ OPX Private Fire/Emer. Offsite ENS HPN Microwave Lines Radio Radios Control Room X X_ X X X TSC (53) X X X X X X OSC X X x EOF I X1 X X X X X Plant Mgr's Office X ENC/JIC X X 1 The EOF utilizes the Buchanan Office Building PABX and has access to a local commercial provider and AEP microwave capability.
2 Two telephone lines in each Control Room automatically bypass the plant PABX if it fails.
Communications between CNP and the Offsite Survey Team(s) are made by portable radios.
These radios are maintained in the dedicated survey vehicles, emergency facilities, and are assigned for use to plant operating departments.
AEP Microwave/Fiber Optics System This system allows direct communication to major media stations and AEP offices. It provides fast and reliable support for the plant in the event of an emergency. The CNP switchboard has "tie trunks" to Buchanan, Michigan and Fort Wayne, Indiana. Direct, dedicated microwave channels are established 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day between Cook Plant, and both Fort Wayne, Indiana and Buchanan, Michigan.
The microwave facilities at CNP are powered by their own battery that is constantly serviced by a trickle charger, powered from an AC station auxiliary. In the event of a failure in this AC line, an emergency generator automatically takes over the supply of power to the charger. The battery alone is capable of operating the microwave facilities for approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
F.l.e. Alerting and Activating Emergency Response Organization and Personnel Plant Public Address System The Plant Public Address (PA) System is powered by the Critical Control Room Power Supply and is automatically switched to a backup supply from the diesel generator in the event that the normal power supply is lost.
The Plant PA System provides paging to all major buildings of the plant including the office and service building. This system includes a five-party channel system for two-way communications.
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Page 83 of 221 It should be noted that this system cannot be used to notify offsite persons of an incident. Other systems are available for this use.
Plant Private Automatic Branch Exchanqe Plant Telephone System The Private Automatic Branch Exchange Plant Telephone System (PABX) is powered by its own battery on a trickle charger. PABX System installations are located in areas most frequently occupied by plant personnel, including the plant's emergency response organization.
Security Radio A portable radio system is installed for security communications. This system uses dual transmitters to provide a dual frequency capability. Radio coverage includes all general areas onsite. If necessary, this system can be used as a back-up means of communication onsite in the event of an emergency.
Fire and Emergency Radio A portable radio system is installed for fire and emergency communications. This system is powered from a non-emergency bus and provided with backup battery power. The fire and emergency radio coverage includes all general areas onsite, excluding containment. This system is also utilized for medical emergencies, field team communications, etc.
F.1.f Emergiencv Communications with the NRC Communications with the NRC Headquarters is by dedicated telephone lines from the Control Rooms, TSC, and EOF. The Federal Telecommunications System (FTS) is used to communicate with NRC Headquarters, in White Flint, Maryland. Communications with Region III headquarters, located in Lisle, Illinois, is by commercial telephone lines .and the FTS.
A FTS telephone line has been installed between the Plant and the NRC, which is primarily intended for use during an emergency and will function as the Health Physics Network (HPN) dedicated line. A total of three extensions are located at AEP facilities in:
NRC Resident Inspector's Office TSC EOF This line will be utilized to provide specific information to the NRC regarding significant radiological events at the Plant. Information transmitted to the NRC, excluding that originating from the Resident Inspectors Office, must be approved by the appropriate emergency response management personnel prior to its transmittal.
The HPN telephones will be staffed by the licensee.
Emergency Notification System (ENS)
The Emergency Notification System (ENS) is intended for use as the primary means for the Plant to report emergencies and other significant events to the NRC. This FTS line will serve as a dedicated line to provide operational data to the NRC during a declared emergency.
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Page 84 of 221 A total of five extensions are located at AEP facilities in:
TSC Control Rooms NRC Resident Inspector's Office EOF Communications over the ENS telephone will be initiated by Control Room personnel if a nuclear emergency occurs at CNP. Licensee personnel will staff the ENS telephones at the EOF when the EOF is activated.
Emerqency Response Data System (ERDS)
The Emergency Response Data System (ERDS) is a direct electronic data link between CNP computer systems and the NRC Operations Center. It is activated during the declaration of an Alert or higher emergency classification. Types of data transmitted include information on the plant's primary and secondary coolant systems, safety injection system, and radiation monitoring systems. Data is updated at approximately 5-second intervals.
F.2 Medical Support Communications Communications between CNP and the offsite medical facilities are made by telephone calls and are authenticated for contaminated patients only.
F.3 Communications Systems Testing Communication links between the NRC Operations Centers and the CNP TSC and EOF via the Emergency Notification System (red phone) are tested monthly for operability. In addition, the Control Room communication link with the NRC Operations Centers is tested for operability on a daily basis.
Communication links between the Plant and Berrien County Sheriffs Department, and the Michigan Department of State Police have been established and are tested monthly at a minimum.
Communications with Offsite Survey Teams will be tested at least annually to ensure an understanding of the content of the messages in the drills.
The majority of the. communications systems are tested on a daily basis through normal use. The radio communications to the Berrien County Sheriffs Department and Michigan Department of State Police are tested daily. An annual drill is conducted with the offsite emergency response personnel including those of State and County agencies if these authorities desire to participate.
As a minimum, each annual drill (exercise) tests the communication links and notification procedures with State and County agencies to ensure the proper flow of information in the event of a nuclear incident.
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Page 85 of 221 PLANNING STANDARD G PUBLIC EDUCATION AND INFORMATION Planning StandardyQ Revision 32
Page 86 of 221 This page intentionally left blank Planning Standard G Revision 32
Page 87 of 221 G. PUBLIC EDUCATION AND INFORMATION The utility industry's experience has consistently shown that offsite public reaction is more favorable when information originates with the utility, and that notification of appropriate county, state and federal agencies is made prior to any public announcement to ensure that the information presented is fully understood by all parties and does not conflict with news reports and information transmitted to any agencies by other sources. Press briefings will be arranged in conjunction with appropriate agency officials to permit a consistent and timely exchange of information.
The ENC/JIC personnel manage information release on the incident by:
" Gathering information on the incident, preparing, and approving information releases to the media.
" Providing a single location for use by the media for obtaining information about the incident.
- Monitoring the broadcast media for discrepancies between approved media releases and broadcast information.
- Answering questions posed by callers to the Public Inquiry telephone lines.
The ENC/JIC facility shall be activated for any Alert, Site Area Emergency, or General Emergency. The goal is to have ENC/JIC staffed approximately 90 minutes after declaration of an Alert, Site Area Emergency, or General Emergency.
G.1. Public Information American Electric Power (AEP) annually distributes emergency educational information to the public within the Emergency Planning Zone (EPZ) in conjunction with Berrien County and the Michigan Department of State Police - Emergency Management and Homeland Security Division. Such information includes the warning methodology used in notification of the public, educational information on radiation, personnel or agencies to contact for additional information, and sheltering and evacuation procedures used in the event of a nuclear incident. Appendix D is an example of the emergency educational information material that is distributed annually.
G.2 Distribution of Public Information The above emergency educational information was distributed to the public initially and is updated annually. This information is sent to all Berrien County residences and businesses, as well as Niles and other locations served by municipal power. This mailing includes those living and working both inside and near the 10 mile EPZ. New electric service customers are sent a copy of the emergency educational information and are added to the annual mailing.
The brochure is also distributed to Warren Dunes State Park, local motels, hotels, nursing homes, marinas, and apartment complexes. Selected camping and recreational areas that are part of the 10 mile EPZ most frequently used by large segments of the transient population will also be provided with similar information. The Cook Energy Information Center Manager is responsible for the annual distribution of emergency educational information to the public within the 10 mile EPZ.
G.3. Emergency News Center/Joint Information Center (ENC/JIC)
The Emergency News Center/Joint Information Center (ENC/JIC) provides a single location for issuing information on incidents and Company response about incidents to the news media.
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Page 88 of 221 The Emergency News Center/Joint Information Center (ENC/JIC) is located in the Nuclear Generation Group Headquarters Building located approximately 14 miles southeast of the plant site in Buchanan, Michigan. The ENC/JIC shares the first floor of the building with the EOF.
Media access is allowed to an auditorium area, media work area, and lobby area of the building through a guarded main entranceway. Access to all other areas and entrances to the building are locked, barricaded, or guarded to prevent media intrusion into the EOF, corporate offices, or the ERO staffed portion of the ENC/JIC.
The auditorium provides the location for briefings by the utility Spokesperson and representatives of any other agencies responding to the incident. Space and electrical power are provided for media cameras to be set up for broadcasting briefings. An area adjacent to but separate from the auditorium is set up as a media work area with desks, chairs, and phones for media use, as well as distribution of press kits and copies of releases.
A Support Staff area is set up adjacent to, but separate from the auditorium and areas accessible to the media, for communicators, statement writers and others working to support ENC/JIC operation. Fax machines, telephone lines and computers are set up to support obtaining current information and preparing press statements.
GA. ENC/JIC Spokespersons and Public Inquiry G.4.a. Spokesperson Information Later in the event as off-site agencies activate, the ENC/JIC becomes the single location for coordinated response to the news media by the spokespersons of the Company, local and state government, the NRC, and any other agencies responding to the incident. The ENC/JIC does not become a Joint Information Center until after the declaration of a Site Area Emergency and when a representative from the state is present and declares the JIC activated.
G.4.b Spokesperson Information Exchange The ENC/JIC is staffed to provide for media release preparation and presentation, media monitoring, and public inquiry. The ENC/JIC staff also provides for support of off-site agency responders to the facility as well as support for the media representatives that use the facility.
G.4.c. Public Inquiry A Media Monitoring and Public Inquiry area is set up with radios, televisions, and telephones.
Media Monitors watch releases televised by the local media and listen to radio reports for any inaccurate information. Public Inquiry Communicators record and respond to any questions called in to the Public Inquiry extensions.
G.5 Annual Media Briefing Information is sent annually to the local news media to explain the emergency preparedness plans of the State, County, and utility. This is sent just prior to the annual Cook Emergency Plan exercise and invites the media to participate in the exercise. The role of the media in providing emergency information to the public is also explained.
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Page 89 of 221 PLANNING STANDARD H EMERGENCY FACILITIES AND EQUIPMENT Planning Standard.H Revision 32
Page 90 of 221 H. EMERGENCY FACILITIES AND EQUIPMENT Plant personnel who are needed and are not onsite will be notified of the existing plant condition and will be directed to report to one of the following locations:
1 TSC 2 EOF 3 OSC 4 Or an alternate location in the event of unsafe plant conditions.
H.1. Technical Support Center H.l.a. TSC Functions The onsite Technical Support Center (TSC) provides plant management and technical support to plant operations personnel during emergency conditions from a location outside the Control Room.
During the short-term emergency conditions, the TSC is capable of serving the following purposes until all required response centers both on and offsite have been activated.
- Providing technical support to operations personnel as requested..
- Directing the activities of site personnel.
" Evaluating offsite agency requests and recommendations to ensure compatibility with emergency response objectives.
The TSC shall be activated for any Alert, Site Area Emergency or General Emergency.
The TSC, combined with the Control Room, can perform the functions of the EOF until the EOF is activated.
Sufficient data to determine the plant steady state and dynamic behavior prior to and throughout the course of an accident is available for analysis in the TSC. TSC personnel shall have ready acces.s to plant records and procedures to support detailed technical analysis and evaluation of plant conditions.
The TSC facilities may be used by plant personnel for normal daily operations as well as for training and emergency drills provided that these activities do not interfere with the immediate activation of the TSC or the continuing TSC operations in the event of an accident.
The primary NRC role in the TSC will be supportive, advisory, and observational.
H.l.b. TSC Location The TSC is located adjacent to the Control Room to readily allow face-to-face interaction between Control Room personnel and the senior plant management working in the TSC. (See Figures 10 and 11)
An alternate location for the TSC is the Buchanan Office Building in the event of unsafe conditions at the plant.
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Page 91 of 221 H.1.c. TSC Staffing The TSC is staffed to provide technical support to the Control Room operating staff during accidents. The number and type of personnel assigned to the TSC and their time of arrival in the TSC may vary according to the emergency class. The TSC staff assignments are contained in Section B. The SEC, or in the absence of the SEC, the Assistant SEC shall coordinate activities in the TSC and interface with the Control Room and the EOF.
H.l.d. TSC Design The CNP TSC-is located in the Turbine Building adjacent to the two Control Rooms. This location readily allows for face-to-face interaction between the Control Room personnel and TSC personnel. Because of the proximity of the TSC to the Control Room, it will normally take less than 2 minutes to travel from one facility to the other. The lower level of the TSC (elevation 634')
is comprised primarily of the Shift Manager's Office and a briefing room. The upper level (elevation 643') houses the Plant Evaluation Team area which contains the computer consoles, communications area, and a separate office with sufficient working space for five NRC representatives. The staffing and use of the TSC has been tested in emergency exercises with the result that there is sufficient space for plant emergency personnel to perform their assigned functions.
The TSC has been constructed to provide the same degree of radiological habitability as the Control Room under accident conditions. Concrete shielding has been provided to significantly reduce the effects of containment building radiation shine during an accident. Radiation monitoring is provided to indicate radiation dose rates as well as airborne radioactivity levels.
The CNP TSC has been designed to:
- 1. Provide technical support to plant operations personnel during emergency conditions.
- 2. Relieve the reactor operators of peripheral duties not directly related to reactor system manipulation.
- 3. Prevent congestion in the Control Room.
- 4. If necessary, perform EOF functions for an Alert, Site Area Emergency or General Emergency until the EOF is fully functional.
The following communication systems have been provided in the TSC:
- Offsite emergency radio to communicate with the Offsite Survey Teams as well as with in-plant teams, and EOF.
- Dedicated line on the NRC Health Physics Network (HPN) and two dedicated lines on the NRC Emergency Notification System (ENS).
- Plant intercom/PA System.
" Dedicated communication circuit to the Control Room, OSC and EOF.
" Fax capability.
" 2 private lines off the CNP PBX are dedicated for NRC use with outside capability.
- Additional telephones to be used as needed.
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Page 92 of 221 The TSC will not contain, but will have ready access to plant records, drawings and other documentation as required. The concept of operation of the AEP Emergency Response Organization is described in Section A.i.b.
H.l.e. TSC Data Availability Personal Computers and printers are available in the TSC that allow access to the plant LAN, stand alone programs, and access to Plant Process Computer information.
H.1.e.1 Plant Process Computer (PPC)
The CNP Plant Process Computer (PPC) System has been developed and designed using the guidelines of NUREG-0696 and NUREG-0737, Supplement 1 to provide the plant operating and technical support personnel with the pertinent plant information to facilitate the emergency response to an accident in a timely manner and to assess the status of the critical safety functions. This system can also be used during normal plant operations for other functions such as plant performance analysis and personnel training.
The PPC network is a data gathering, analysis, and display system that interfaces with multiple computer systems. This system consists of two similar computerized data acquisition, processing and display systems, one for each unit. The Unit I and Unit 2 PPCs acquire, validate, and convert analog, digital, pulse, and sequence of events. inputs from process instruments into engineering units. In addition, data is acquired from the RMS, MIDAS, and from various recorders located throughout the plant. The Unit 1, Unit 2, and Simulator PPCs and the Realtime Data Repository (RDR) computers are part of a computer network. The PPC network is used to send emergency response data to the NRC via ERDS. The Safety Parameter Display System (SPDS) is also a function that is performed by the PPC network.
The PPC system information is accessed with personal computers that access the PPC through the Real Time Data Repository (RDR)-system and the information so obtained is usually referred to as PPC data. PCs that have access to the PPC in this fashion are available in the Control Rooms, TSC, OSC, ENC/JIC, and the EOF.
H.1.e.2. Emer-qency Response Data System Emergency Response Data System (ERDS) is a direct electronic data link between CNP PPC system and the NRC Operations Center. It is activated during the declaration of an Alert or higher emergency classification. Types of data transmitted include information on the plant primary and -secondary coolant systems, safety injection system, and radiation monitoring systems.
H.l.e.3 Dose Assessment Program (DAP)
A Dose Assessment Program (DAP) is available in the TSC, EOF, and the Control Room. DAP is discussed in section 1.4.
H.1.e.4 MIDAS Access to meteorological information via the Meteorological Information and Dispersion Assessment (MIDAS) System display is available on any of the computers in the Control Rooms, OSC, TSC, and EOF that have access to the PPC. The meteorological information is used for offsite dose assessment purposes.
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Page 93 of 221 H.1.e.5. Radiation Monitoring System RMS data is available on any of the computers located in the Control Room, OSC, TSC, ENC/JIC and EOF facilities that have access to the PPC.
H.2. Emergency Operations Facility H.2.a. EOF Functions The EOF provides coordination and evaluation of licensee activities during an emergency. The EOF shall be activated during an Alert, Site Area Emergency and General Emergency.
Once fully activated and staffed, the function of the EOF shall provide for:
" Management of overall licensee emergency response,
" Coordination of radiological and environmental assessment,
- Determination of recommended public protective actions,
- Coordination of emergency response activities with federal, state, and local agencies, and
" Recovery functions.
To accomplish these functions, personnel shall be provided in the EOF for communications with off site agencies and the evaluation of pertinent radiological, meteorological, and plant system data.
Once the Emergency Response Organization (ERO) has been established in the EOF, the Engineering, Design and Site Services Manager will coordinate communications with the engineering support personnel as needed to respond to the emergency.
The EOF personnel shall coordinate the emergency response activities with those of county, state and federal emergency response organizations, including the NRC and FEMA.
H.2.b. EOF Location The EOF is located on the first floor in the NGG Headquarters building in Buchanan, Michigan, which is approximately 14 miles from CNP. The EOF shares the first floor of the building with the ENC/JIC, but the media is segregated from all but a lobby area and auditorium where briefings occur and do not have access to the EOF or the EOF staff. (See Figure 11)
H.2.c. EOF Staffing The EOF shall be staffed to provide overall management of the plant resources and evaluation and coordination of plant activities during and after an accident. The EOF staff will include personnel to perform radiological evaluations, interface with offsite, and manage offsite resources. The EOF staff assignments are contained in Section B. The ED shall be in charge of all activities in the EOF.
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Page 94 of 221 H.2.d. EOF Design The EOF is located in the NGG Headquarters building in Buchanan, Michigan, which is approximately 14 miles from CNP. It occupies approximately 6400 square feet of the first floor of the building, approximately 2500 square feet of which is reserved for use by NRC personnel.
The EOF contains an operations room which includes the crisis management team, communicators, the NRC office, the dose assessors and the data display terminals. The communications are to the:
- ENC/JIC
- State and local representatives in their respective Emergency Operation Centers
" NRC Emergency Operations Center (ENS and HPN telephones have been installed)
" TSC and Control Room
" Licensee Offsite Survey Teams A Communications Director will be located in this operations room and will be in charge of all the operations room communicators and status displays.
The following communication systems have been provided in the EOF:
- Dedicated line on the NRC Health Physics Network (HPN) and on the NRC Emergency Notification System (ENS).
- Fax capability.
- 3 private lines dedicated for NRC use with outside capability.
a Additional telephones to be used as needed.
The design of the EOF structure and organization ensures its ability to perform the following functions:
- Management of overall licensee emergency response.
" Coordination of radiological and environmental assessment.
- Determination of recommended public protective actions.
- Coordination of emergency response activities with federal, state and local agencies.
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Page 95 of 221 The EOF was designed for occupancy by approximately 70 persons. The approximate occupancy, by function, is as follows:
ERO Managers 5 NRC Personnel 23 FEMA, State and County Personnel 3 Communicators 9 Clerical and Extra Staff 15 Assessment Staff _5 60 Ample parking spaces exist outside the EOF in the NGG Headquarters Building parking lot for the number of vehicles that can be expected during an emergency as well as space for mobile vans that Will be brought in by offsite support agencies. In addition, space exists near the building that can be used for landing a helicopter should the need arise.
H.2.e. EOF Data Availability The same computer capability (PC, PPC, LAN, DAP, etc.) described for the TSC in H.l.e. is available in the EOF.
H.3. Operations Support Center (OSC)
H.3.a OSC Functions The Operations Support Center (OSC) is an onsite assembly area separate from the Control Room and the TSC where licensee operations support personnel report in an emergency.
The OSC:
- Provides a location where plant logistic support can be coordinated during an emergency, and
" Restricts Control Room access to those support personnel specifically requested by the shift manager.
The OSC shall be activated for any Alert, Site Area Emergency, or General Emergency.
This is an assembly area for personnel to report for instructions from the OSC Manager.
Communications are provided to the Control Room, TSC, and EOF on the Boardwriter's Bridge and the Managers Bridge. Communications are provided to Damage Control, Rescue, and Survey Teams with portable radios.
H.3.b. OSC Location The OSC is located in the basement of the Lakeside Office Building on the plant site. The classrooms, storage rooms, and offices on the north end of the basement comprise the area where the staff assigned to the OSC stage and perform their function. The remainder of the office building complex is used for assembly of the remainder of the plant staff when accountability is performed. (See Figures 10 and 11)
The OSC will normally be located in the basement area of the Lakeside Office Building; however, this area is not intended to be "fixed" and may be re-located to other areas of the plant that will permit the orderly progression of work to restore the plant/unit to operational status. Any area that is used as an OSC shall be approved by the SEC after the RP Department surveys the area and it is found to be radiologically acceptable.
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Page 96 of 221 An alternate location for the OSC is the Buchanan Office Building in the event of unsafe conditions at the plant H.3.c, OSC Staffing The OSC staff assignments are contained in Section B. The OSC Manager shall be in charge of all activities in the OSC.
H.3.d. OSC Design The OSC is located in the basement of the plant's lakeside office building. Classroom space is available for assembling, briefing, and de-briefing response teams, as well as storage space for emergency response equipment such as anti-contamination clothing and survey equipment.
There shall be direct communications between the OSC and the Control Room and between the OSC and the TSC so that the personnel reporting to the OSC can be assigned to duties in support of emergency operations.
Means for analyzing air samples and environmental samples are located in the OSC. Offsite Survey Teams can return samples to the OSC for analysis. If the OSC is unavailable or inaccessible samples can be counted at Palisades Nuclear Plant (about 25 miles from CNP) or other of the contingency Offsite Laboratory Facilities.
The following communication systems have been provided in the OSC:
- Fax capability.
- Additional telephones to be used as needed.
H.3.e. OSC Data Availability The same computer capability (PC, PPC, LAN, etc.) described for the TSC, with the exception of DAP, is available in the OSC. In addition the OSC has access capability to the Radiation Protection Dose Tracking and Control System.
H.4. AEP Emergency Organization Staffing and Activation The concept employed by AEP is to support the plant operating staff in an emergency by activating all of the Emergency Response Facilities when the operating shift determines that additional resources are necessary to respond to an event.
At the plant, the TSC would be activated upon an Alert, or higher emergency classification and would perform its functions to support Control Room operation within the goal of 60 minutes.
These functions are to provide plant management and technical support to operations personnel; relieve the Control Room personnel of peripheral duties not directly related to plant operation; prevent congestion in the Control Room, and perform EOF functions until the EOF is activated.
The EOF will be activated for any Alert, Site Area Emergency or General Emergency and for any lesser classification as determined by the SEC. The goal is to activate the EOF within 60 minutes of an Alert, or higher emergency classification. Pre-designated members of the NGG staff will report to the EOF to provide management and operations support.
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Page 97 of 221 When ERO members arrive at the EOF, the EOF functions are transferred from the TSC or the Control Room to the EOF. These functions are: management of overall licensee emergency response,. coordination of radiological and environmental assessment, including determination of protective action recommendations for the public (when the Emergency Director position is activated), and coordination of emergency response activities with federal, state and local agencies. During this time, the EOF is in communication with the TSC.
The ENC/JIC facility will be activated at the Alert level, and becomes the JIC at a Site Area Emergency and when declared as the JIC by the State of Michigan. The goal is to activate the ENC/JIC within 90 minutes of an Alert, or higher emergency classification. The EOF will be in communication with the ENC/JIC as well as with the state and county emergency operations center. Press releases will be coordinated with the NRC, state, local and AEP ERO.
Long Term Recovery. At the plant, the TSC is providing support to the Control Room and plant operations staff. The ED is responsible for the entire recovery operation and is located in the EOF. The EOF staff obtains its information on the plant status from the PPC terminals located in the EOF. The dose assessment and communication with the licensee's Offsite Survey Teams and all other communications with offsite parties continues to be performed at the EOF. The Engineering, Design and Site Services Manager is responsible for obtaining supplementary assistance, if needed, from the other NGG personnel.
H.5. Emergjency Detection CNP has nuclear and process instrumentation to detect abnormal situations. This instrumentation will provide warning to the operators so that action can be taken to avoid or mitigate the consequences of plant incidents. Detection capability is provided in the following areas:
- 1. Instrumentation for detecting seismic activity on the plant site and meteorological towers for monitoring and recording weather data.
- 2. A system for monitoring of radiation levels in selected areas of the plant, radioactivity of process streams in the plant, and liquid and gaseous discharges from the plant.
- 3. Instrumentation to measure tank levels in various plant systems and the pressures, temperatures, and flows of process streams.
- 4. Instrumentation for detecting fires in the plant and security events.
Specifically the instrumentation available to assist in determining the severity of a nuclear incident inside the containment is listed in Table 5, "Critical NUREG-0737 Parameters".
Events that do not have a potential for radiological releases but which may have a public interest are detected through the plant's monitoring instrumentation, the plant computer system, audio-visual, alarm/trip indications, fire protection system, and seismic monitoring system.
H.5.a. Seismic Monitoring The seismic monitoring system consists of two forms of monitoring instrumentation, the strong motion triaxial accelerometers and the peak recording accelerometers' The strong motion triaxial system is composed of seismic triggers, control panel, recorder, panels, accelerometers, and power supply. These components provide a means of recording the time history of a seismic event. The power supply to the system, excluding the playback instrument, is designed to provide power from a battery backup source should the AC input supply be lost.
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Page 98 of 221 The peak recording system utilizes triaxial film recorders that do not require a power source for operation. The films are removed, developed and interpreted with a calibrated magnifier. The accelerometers for these two systems have been placed in various locations throughout the plant in such positions as to minimize inadvertent system activations.
H.5.b Radiation Monitoring System The instrumentation for determining the extent and magnitude of accidental releases of radioactive materials offsite includes the Radiation Monitoring System and meteorological instrumentation. Information from each of these sources is .available in the Unit 1 and Unit 2 Control Rooms, as well as any PC with access to the RDR. The RMS and Meteorological System data is available to the EOF, TSC, ENC/JIC and OSC from the PPC through the Real Time Data Repository (RDR) system.
Alarms are provided for high radiation, RMS malfunctions and, where applicable, loss of sample flow on the local indication and control panel, and at the main Control Room display console via the RMS communications system.
A release can be determined from either in-plant RMS, or portable radiation instrumentation dispatched from the plant when it is possible that there has been an accidental gas release which could not be monitored by the plant RMS. Information from readings of this portable instrumentation may then be used to determine the extent of the release.
For accidents where there has been no significant release to the environs, but readings on Control Room instruments indicate a release within the containment, samples can be taken to determine the level of radioactivity therein. Tables relating the radiation levels in the containment for various accident conditions as a function of time and power history are used for comparison with actual data as an aid in determining the possible type of and severity of the accident and are contained in the Emergency Plan Procedures.
The major source of liquid effluent from the plant is through the circulating water discharge.
Identified potential sources of radioactive releases to the circulating water system are monitored by the process monitors of the Radiation Monitoring System.
For long-term events which may have some impact on the environment, additional REMP sampling stations may be provided as necessary.
The Radiation Monitoring System instrumentation is divided into analog and digital systems.
Additional information on the monitor functions and range can be found in the UFSAR, Offsite Dose Calculation Manual, "OP Drawings", and Technical Specifications Bases sections.
H.5.b.1 Analog System
- 1. The Process Radiation Monitoring Systems monitor various fluid streams for indication of radiation levels. The radiation levels are indicated by meter, recorded by a multipoint recorder, and high radiation level alarms are annunciated in the Control Room.
- 2. The Area Radiation Monitoring System monitors radiation levels in various areas of the plant. The radiation level is indicated locally and in the Control Room where it is recorded. A predetermined increase in the radiation level detected by this system is alarmed both locally and in the Control Room.
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Page 99 of 221 H.5.b.2 Digital System
- 1. The Process Radiation Monitoring Systems monitor various fluid streams for indication of radiation levels. This data is processed by a local microprocessor. Display of the data is available upon operator request via terminals in the Control Rooms. A common high radiation alarm is annunciated and the initiating device(s) identity is printed or logged at the control terminals.
The Eberline digital RMS consists of a series of radiation detectors, monitor controllers or local processors, and control terminals together. with appropriate ancillary components including display devices. The local processor gathers data, performs routine calculations, retains channel parameter information, and a history file for all detectors served by that processor.* It also determines operation and alarm status and communicates with the central control terminals. A digital display provides status and alarm outputs and a display of selected channel data.
Alarms are provided for high radiation, RMS malfunctions and, where applicable, loss of sample flow on the local indication and control panel, and at the main Control Room display console via the RMS communications system..
Each reactor unit at CNP has an RMS control terminal. The two central control terminals are functionally identical. One control terminal performs the functions of polling each local processor for. operational status and data, logging any changes in status and associated data, logging history files, annunciating status conditions, communication error messages and, upon keyboard request, performing calculations on data in the history files. One control terminal performs system operating functions while the other is in standby ready to take over system fun6tions. In the event of control terminal failure or outage, the standby system controller is capable of controlling RMS in both units to provide updated data. The control terminal is the operator interface with the rest of the system.
- 2. Area Radiation Monitors monitor radiation levels in most rooms and passageways of the Auxiliary Building and each contaifiment. . This data is processed by the local microprocessor and transmitted to the redundant control terminals.
A complete listing of the RMS monitors, their identification number, type of monitor, location, and range is available via computer or in the Reference Section of facility binders containing the Emergency Plan Implementing Procedures issued for use.
H.5.b.3. Release Assessment Dose Assessment software is available in each Control Room, the TSC, and the EOF that calculates:
- 1. The site boundary dose as a function of time, meteorological conditions and release rate,
- 2. The dose rate as a function of distance from the plant for site boundary and beyond, and meteorological conditions.
The above DAP software is only applicable to gaseous releases which are directly measurable from plant effluent and containment area monitors, or Offsite Survey Team measurements of plume dose rate.
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Page 100 of 221 In addition to the instrumentation which is immediately used by the plant personnel in detecting a radiation release from the plant, a Radiological Environmental Monitoring Program is available from which samples can be taken and analyzed.
The Radiological Environmental Monitoring Program (REMP) monitors the environment surrounding the plant. The stations from which sampling of airborne particulate, airborne 1-131, lake water, well water, external radiation, etc. are located in the Plant's surrounding environs and are identified in appropriate plant procedures.
With the existing instrumentation available to plant personnel, the evaluation of the release and the estimation of the resultant radiation levels at distances from the site boundary can be made without the need to use the Radiological Environmental Monitoring Program sample stations.
For long-term events which may have some impact on the environment, additional REMP sampling stations may be established.
H.5.c. Process Monitoring Plant operating parameters including pressures, temperatures, volumes, and flowrates for systems, as well as RMS and meteorology are available throughout the ERO facilities on PCs that access the PPC information through the Real Time Data Repository (RDR) system.
H.5.d Fire Protection The fire protection detection system is comprised of two general types of detectors. They are thermal detectors and products of combustion detectors. The thermal detectors are designed to detect thermal energy output (i.e., heat from a fire). The products of combustion detectors are designed to detect particles, smoke, or infrared radiation.
The fire detection systems provide an alarm and/or actuate fire suppression systems. Alarm functions generally include:
- Annunciation in the Control Rooms,
" Audible overall plant fire horns for those suppression systems which are actuated by detection systems,
" Audible and/or visual alarms for gaseous suppression systems actuated by detection systems.
H.5.d.1 Types of thermal detectors in use at the plant are as follow:
Thermistor A thermistor is a continuous line heat detector. When an over heat condition occurs anywhere along the thermistor, the resistance drops which is sensed by the control panel. The control panel activates an alarm and/or automatic fire suppression systems.
Fusible Entity Detector/Actuators Fusible Entity Detectors are used to activate sprinkler systems by melting at predetermined temperatures allowing water to be released from the sprinkler heads. The types of plant sprinkler systems employing this type of detector/actuators are:
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Page 101 of 221 0 .Wet Pipe Sprinkler System The piping is always full of water under pressure, so that, if exposed to fire, the sprinkler head is activated and water will instantly flow from the open head onto the fire, and at the same time provides an alarm of such activation and water flow.
- Preaction Sprinkler System These systems are used in areas subject to freezing temperatures or where there is a possibility of water damage from accidental operation or a break in the piping system. In these systems, there are two piping systems one for air (pilot) and one for water. Sprinklers (pilot heads) with a lower temperature rating are installed in the air (pilot) piping system as compared to those installed in the water piping system. The air pressure in the pilot piping keeps a control valve closed. When the pilot heads operate from a fire, the air in the pilot piping is vented and the control valve opens allowing water to fill the water piping. At this point, the system operates the same as a wet pipe sprinkler system.
H.5.d.2 Types of products of combustion detectors in use at the plant are as follow:
Ionization Type Responds to an abnormally high concentration of invisible particles of combustion products that are ionized by a radioactive source located in the detector chamber.
Photoelectric Type Responds to visible smoke in the detector chamber which causes a light source in the detector to be refracted and reflected into a photoelectric cell.
Infrared Flame Detector Responds directly to the presence of the infrared radiation emanating from flames, which flicker between the frequencies of 5 to 30 C.P.S.
H.6 Offsite Monitoring and Analysis Equipment H.6.a. Geophysical (Meteorological, hydrologic, seismic)
A contract is maintained with a commercial weather service for meteorological forecast services, and for an alternate source of meteorological data if the plant site meteorological system is unavailable. As a back up for the contract service the NOAA Weather Service Forecast broadcasts are accessed through a plant phone extension, as well as being available from weather radios.
Phone numbers for the National Earthquake Information Center are maintained in the ERO Phone Directory. The center can be contacted for confirmation of, or information on seismic events.
H.6.b. Radiological Monitoring Emergency Plan Procedures establish the means of assuring that adequate emergency equipment is stocked at designated points for use in emergencies dealing with radiological hazards. The emergency equipment includes, but is not limited to:
- Air samplers with assorted cartridges
" Ion chambers Planning Standard H Revision 32
Page 102 of 221
- Geiger counters
- Respirators
" Personal dosimetry Plant procedures identify the requirement for emergency equipment to be inventoried and checked at specified times to ensure that the supplies and equipment are properly maintained and available for use. Emergency equipment is kept at some offsite locations see Appendix C, Emergency Kits and Equipment Locations, for locations.
Appendix B contains agreements with offsite support agencies including agreements with other utilities for assistance during emergencies at nuclear power stations.
Appendix E contains information about assistance and resources, including instrumentation, available through the DOE Radiological Assistance Plan.
H.6.c Offsite Laboratory Facilities In the event that it becomes necessary to use offsite laboratories for analysis of samples the following facilities may be contacted and the analysis performed depending on the type of samples (See Appendix H, Radiological Response Support Service Capabilities):
" Teledyne Isotopes Inc.
" Argonne Laboratory (DOE)
- There is also a Reciprocal Laboratory Use Agreement with Palisades Nuclear Plant (see Appendix B).
H.7. Radiological Environmental Monitoring The CNP uses a pressurized water reactor with a radwaste holdup and treatment system that has been designed to keep radioactive releases to as low as practical levels. However, small quantities of noble gases and other radionuclides that are released to the environment are expected to be minuscule and insignificant as a source of potential exposure to flora and fauna in the area. However,, direct radiation exposure to the public and radionuclide accumulations in various components of food chains to man is carefully monitored through the REMP. Further information on the REMP.can be found in the Offsite Dose Calculation Manual (ODCM).
H.8 Meteorological System The system's meteorological towers are located inside the thermal internal. boundary layer and have the ability to measure unmodified onshore airflow to detect the presence of a lake breeze.
The meteorological system consists of monitoring information located on three towers. The primary and backup towers are located about 1-mile inland from the plant site to provide a representative determination of the meteorological conditions for emergency planning purposes.
The primary tower has instruments at the 10 and 60-meter elevations. Each elevation has a measurement of wind speed and direction. Temperature is measured at both elevations and is used to determine a delta temperature (delta T). This delta T is used in dose assessment to determine atmospheric stability. A precipitation gauge is located near the primary tower site.
The backup tower has wind speed and wind direction instrumentation located at the 10-meter elevation. Separate communication lines are provided for the main and backup towers.
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Page 103 of 221 The shoreline tower also has wind speed and wind direction instrumentation at the 10-meter elevation. Temperature detectors are located at the 2-meter and 10 meter elevations of the tower. The shoreline tower is located just northwest of the plant on the shore of Lake Michigan.
The three towers are controlled by a central computer located at CNP site. The towers are polled every 15 minutes for meteorological data. The data are stored in the central computer.
Meteorological data are available from any PC with access to the PPC data.
Daily checks of the digital data are performed to ensure reliability. Erroneous data are flagged on these displays and triggers the issuance of a Work Order (WO). The WO system is used to notify the appropriate department of the problem and provides notification of the resolution to the problem. An adequate spare parts inventory is maintained at the primary tower site. Calibration of the system is performed semi-annually and is documented by the plant Instrumentation and Control Section.
Meteorological information can be obtained directly from the primary tower site using a keypad if communications with the central computer are lost. Backup meteorological information can also be obtained from a consulting firm. Forecasting information is available from the consulting firm as well as a plant extension that continuously plays NOAA weather information, and Weather Service radio.
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Page 104 of 221 Figure 10 Warehouse LOCATIONS OF EMERGENCY RESPONSE CE TERS and Office Spent Fuel Maintenance Pool IBuilding we~..muumm..n....u..um...
- SUUI*U*M**S*S**3.S~hE..VE\ .~.v.3SE.3... .nova~
'111.......1I ii:111 . ...
Visitors Center M
Emergency News Center/Joint Emergency Operations Facility Information Center in the in the Nuclear Generation Nuclear Generation Group Group Headquarters Building Headquarters Building in Planning Standard H Revision 32 in Buchanan Buchanan
Page 105 of 221 FIGURE 11 CNP EMERGENCY RESPONSE CENTER LOCATIONS Control Room Entry at Elev. 633' Turbine Building Technical Support Center (TSC) Above SM's Office Complex Adjacent to Units 1 and 2 Control Rooms Operations Support Center (OSC) Plant Offices - Basement ShelterElev. 587' Emergency Operations Facility (EOF) In Nuclear Generation Group Headquarters Buchanan - Approximately 14 miles Southeast of CNP Emergency News Center/Joint Information Center (ENC/JIC) In Nuclear Generation Group Headquarters Buchanan - Approximately 14 miles Southeast of CNP Planning Standard H Revision 32
Page 106 of 221 TABLE 5 CRITICAL NUREG 0737 PARAMETERS PARAMETER INSTRUMENTATION Neutron Flux (Gammametrics) NRI-21, NRI-23 Reactor Coolant Pressure (Wide Range) NPS-110, NPS-111, MR-13 Reactor Coolant Outlet Temperature Thor (Wide Range) NTR-1 10, 120, 130 140 Reactor Coolant Inlet Temperature Tcld (Wide Range) NTR-210, 220, 230 240 Incore Thermocouples (Core Exit Thermocouples) T/C 1-65 Reactor Coolant System Subcooling Margin Monitor QR-1 10-3 Reactor Coolant Inventory System (Reactor Vessel Level NLI-110, 111, 120, 121, 130, 131 Indication)
Pressurizer Water Level NLP-151, 152, 153 Charging Pump Flow IFI-51, 52, 53, 54 Charging Pump Breaker Status 1E, 1W, 2E, 2W Control Room Position Indicating Lights for Breakers, Safety Injection Pump Breaker Status .1N, 1S, 2N, 2S Control Room Position Indicating Lights for Breakers, Safety Injection Flow IFI-260, 266 Refueling Water Storage Tank Water Level ILS-950, 951 Containment Water Level NLI-320, 321, 330, 331, 340, 341 Containment Recirculation Sump Water Level NLI-300, NLI-301 Containment Pressure (Wide Range) PPA-310, 312 Containment Pressure (Narrow Range) PPP-300, 301, 302, 303 Containment Hydrogen Monitoring ESR-1 thru 9, PAS-H2-A-CRI, PAS-H2-B-CRI Containment Isolation Valve Position Monitoring Control Room Position Indicating Lights Containment Area Radiation Monitors (High Range) Unit 1 VRA-1310, 1410, Unit 2 VRA-2310,2410 Steam Line Pressure MPP-210, 211, 212, 220, 221, 222,230, 231, 232, 240, 241, 242 Steam Generator Water Level (Wide Range) BLI-110, 120, 130, 140 Steam Generator Water Level (Narrow Range) BLP-110, 111, 112, 120, 121,122, 130, 131, 132, 140, 141,142 Auxiliary Feedwater Flow Rate FFI-210, 220, 230, 240 CCW Flow to ESF System, CCW Pump Breaker Status PP-10E, PP-10W Reactivity Control, Control Rod Position CAI-8(UI), CB1-4(U1), CAI-4(U2), CB1-8(U2), CC1-8, CD1-9, SA1-8, SB1-8, SCI-4, SD1-4 Condensate Storage Tank Level CLI-113, CLI-114 Planning Standard H Revision 32
Page 107 of 221 PLANNING STANDARD I ACCIDENT ASSESSMENT Planning Standard I Revision 32
Page 108 of 221 I. ACCIDENT ASSESSMENT The purpose of this section is to describe the systems, equipment, and methods for monitoring and assessing offsite consequences of actual or potential radiological emergencies.
1.1 Release Identification and Event Classification The Emergency Plan Procedures contain the information used to establish the emergency classification category based on plant system and effluent parameter values. Those initiating conditions are identified in NUMARC/NESP-007. Section D contains the plant specific EALs and initiating conditions in the Emergency Classification System tables.
1.2 Radiation Monitorinq System The RMS monitors area radiation levels in most rooms and passageways of the Auxiliary Building and each containment. Effluent and process flows are monitored for radioactive material. The monitors and channels of most interest for monitoring and evaluating events for radiological impact are:
Containment Radio Gas monitors, 2 per unit Condenser Air Ejector Radio Gas monitors, 1 per unit Unit Vent Radio Gas Monitors, 1 per unit Gland Steam Leak Off Monitors, 1 per unit Steam Generator Power Operated Relief Valve (PORV) Monitors, 4 per unit Containment High Range Area Radiation Monitors, 2 per unit A complete listing of the RMS monitors, their identification number, type of monitor, location, and range is available via computer or in the Reference Section of facility binders containing the Emergency Plan Implementing Procedures issued for use. Section H.5.b contains the description of the RMS system.
1.3. Release Source Term and Magnitude Determination 1.3.a. Release Source Term Calculations correcting containment dose rates as a function of time and reactor power history are contained in the plant core damage assessment procedure. Tables use the corrected containment dose rate results to provide estimates of core damage.
Estimates of core damage are used to select the source term used in the Dose Assessment Program for assessing releases.
1.3.b. Release Magnitude Effluent monitor radiation readings and effluent pathway flow rates are used to calculate the magnitude of releases.
When it is possible that there has been an accidental gas release which could not be monitored by the plant RMS survey teams dispatched from the plant perform surveys offsite with portable radiation instrumentation. Information from readings of this portable instrumentation may be used to determine the extent of the release.
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Page 109 of 221 1.4 Dose Assessment Evaluation A dose assessment program to quickly relate measured release rates and containment dose rates to dose and dose rates at the site boundary and beyond are maintained in the Control Rooms, TSC, and the EOF. The determination of the meteorological stability class to perform offsite dose calculations is described in the Plant Emergency Plan Procedures. Once the meteorological stability class is determined, the offsite radiation dose and dose rates at the site boundary can be estimated using the information obtained from the plant radiation monitoring instruments and/or measured offsite radiation dose rates and the dose assessment program.
A dose assessment computer program, DAP, provides a method of calculating conservative estimates of dose and dose rates at the offsite area most probably affected by a gaseous release to assist in emergency classification and Protective Action Recommendations (PAR). The Dose Assessment Program allows evaluation of several types of release scenarios with the flexibility for meteorological and radiological inputs to perform alternate evaluations to best characterize an event and the resulting protective measures. The program also allows calculations based on offsite survey results for cross comparison purposes, or a means for evaluating unmonitored releases.
In order to calculate a dose/dose rate, the program requires data on:
the radiological effluent.
containment area monitor dose rates, or offsite dose rate measurement results.
This information can be obtained from the plant's RMS or from Offsite Survey Teams.
Other features included in the program are as follows:
- Variable Trajectory Plume Segment Model
- Radioactive decay after reactor shutdown
- Decay and daughter in-growth during transit
" Ground level release
- Finite cloud correction
- Option to input offsite field survey data.
" NuReg - 1228 Event Tree Modeling for Source Term
- Multi Accident Assessment Capability The program is run on personal computers.
The DAP program will be used as the primary means of performing a dose assessment.
Dose Assessment Program (DAP) is a PC computer program that calculates conservative estimates of Total Effective Dose Equivalent (TEDE) and Thyroid Committed Dose Equivalent (CDE) dose rates and total projected dose, based on a radiological release, at the plant boundary and at 2, 5, and 10 mile distances. The program also uses the information to determine the Emergency Classification Level (ECL) associated with the release.
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Page 110 of 221 1.5 Meteorological Assessment The system's meteorological towers are located inside the thermal internal boundary layer and have the ability to measure unmodified onshore airflow to detect the presence of a lake breeze.
Meteorological data are available from any PPC capable computer. Section H.8 contains a description of the Meteorological System.
Meteorological data from the onsite meteorological tower is input into the dose assessment program. The data is used to calculate the atmospheric diffusion factor, X/Q, to determine atmospheric dispersion of radioactive material as part of the Dose Assessment Program for calculating off site doses and dose rates. Weather forecast information is also used to project changes in plume dispersion and location, which can cause changes to Protective Action Recommendations.
1.6. Not Addressed.
1.7 Radioloqical Field Monitoring As part of the response to any Alert, Site Area Emergency or General Emergency, one or more Offsite Survey Teams are formed, as per plant procedures, and dispatched for sampling under radio contact. Qualified RP Technicians fill the position for persons performing the survey. If adequate RP and other personnel are not available onsite, personnel to staff Offsite Survey Team(s) would be summoned per Emergency Plan procedures.
1.8. Liquid and Gaseous Release Assessment A minimum of two vehicles dedicated to Emergency Plan Off Site Surveys is available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. Additionally, keys for all normally available plant vehicles are available in the OSC in the Office Building Basement. Offsite Survey Team(s) deployed from onsite would have such vehicles available for use.
Each of the two dedicated Off Site Survey vehicles, the office building basement, and the EOF have air sampling equipment, dose rate, and count rate instrumentation in addition to radio equipment for communication with the plant.
Previous experience indicates that deployment of personnel from onsite to offsite areas takes approximately 30 minutes from the time of notification.
1.9. Off-site Radioiodine Monitorinq Measurements of radio-iodine yielding sensitivity to the range of 10-8 uCi/cc can be obtained by returning the sample to the regular counting facility or to the counting area independent of the regular counting facility located in the basement area of the Office Building.
1.10. Not Addressed.
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Page 111 of 221 PLANNING STANDARD J PROTECTIVE RESPONSE Planning Standard J Revision 32
Page 112 of 221 J. PROTECTIVE RESPONSE J.1. Owner Controlled Area Warning and Advisement Since the PA system within the plant is extensive, an announcement of the nature of the emergency can be made to most personnel immediately.
Upon sounding of the Nuclear Emergency Alarm personnel in the outlying areas of the plant site are notified using the methods described in section E.2.a of this plan.
J.1.a. Non ERO Employees Plant employees without ERO duties and personnel temporarily assigned to the plant for training or other purposes, are required to know the location and routes to the assembly areas and be familiar with the emergency alarm procedure. Personnel already onsite immediately proceed to their appropriate assembly area upon sounding of the Nuclear Emergency Alarm.
J.1.b. Visitors Groups on tour are escorted to an assembly area by their tour guide, should the Nuclear Emergency Alarm be sounded. Personnel already onsite immediately proceed to their appropriate assembly area upon sounding of the Nuclear Emergency Alarm.
J.1.c. Contractors and Construction Contractors, supervisors, and/or foremen (i.e., outside labor) are provided with instructions, prior to beginning work as to the emergency alarm procedure and as to their responsibility for assembling the people under their supervision in the area designated by the SEC or designated alternate. Personnel already onsite immediately proceed to their appropriate assembly area upon sounding of the Nuclear Emergency Alarm.
J.1.d Others The decision to commence evacuation of the Cook Energy Information Center is made by the SEC on the basis of the. evaluation of the condition of the plant and the extent of the emergency.
The Manager of the Cook Energy Information Center or designee is responsible for the accountability of all Energy Information Center employees and all visitors of the Center should the Nuclear Emergency Alarm be sounded.
When State Police and National Guard are assigned to the plant their disposition will be determined by the nature of the emergency. If the plant is under attack the MSP and National Guard are considered essential personnel and become Emergency Workers for the event. If the emergency does not involve attack of the plant the MSP and National Guard are considered non-essential personnel and evacuated from site upon evacuation of non-essential personnel.
J.2. Evacuation Routes If the SEC deems evacuation of personnel from the plant site necessary, the evacuation route to be taken is determined by the nature of the incident. Personnel evacuate the plant and site as directed by the SEC. Evacuation of individuals shall not commence until it is determined that personnel exposure for such evacuation is within the limits of 10 CFR Part 20, or if this is not practical due to the nature of the emergency, the most expeditious and non-hazardous evacuation route shall be used.
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Page 113 of 221 The SEC designates the evacuation route. One of the below designated routes is utilized (see Figure 12)
- 1. East along the plant main access road.
- 2. North along the Lake Michigan Beach to the plant property line or Rosemary Road.
- 3. South along the Lake Michigan Beach to Livingston Road.
The Security Director (or alternate) is responsible for the accountability of evacuated personnel from the plant site and reports any missing persons to the SEC.
J.3. Evacuee Monitoring If evacuation is initiated a personnel monitoring station is established for those evacuated by a person trained in radiation protection. The Radiation Protection Plan specifies the acceptable limits for contamination to the body and clothing for exiting the plant. Suitable equipment intended for such personnel monitoring stations will be stored in both the OSC and the Training Center.
Other equipment is available from the Radiation Protection Access Control (RPAC), if access to that area is feasible.
J.4 Evacuee Decontamination If any of the evacuated personnel are contaminated, the OSC Manager will institute the necessary steps for movement of these personnel to decontamination facilities and initiate surveys of the surrounding areas.
J.5 Personnel Accountability Control of all personnel entering, leaving and at various locations throughout the plant is a function of the plant security force. The accountability of all personnel in the protected area of the plant is maintained via the security computer system. The security computer records provide the primary means of assuring the accountability of all persons of the site. Use of this computer will enable the accountability to be performed rapidly with a stated goal of achieving completion of personnel accountability within 30 minutes.
During some postulated events, assembly and accountability may pose a greater danger to plant personnel than directing a rapid egress of personnel from the Protected Area, or directing personnel to remain at their work areas. SM/SEC discretion, with input from the Security Director (or Security if. Facilities are not yet activated) should be used when deciding to perform accountability and/or evacuation under these conditions.
Once the Nuclear Emergency Alarm has been sounded all personnel onsite shall report to their pre-assigned assembly areas. The SEC will notify personnel via the PA system of any changes in the areas to be used due to the release or expected release of radiological effluents from the plant.
Personnel reporting to their assembly area onsite will be accounted for using the plant security access list and security computer.: This list provides an up-to-date listing of all personnel onsite by area location. The results of the accountability process will be transmitted to the individual in charge of personnel accountability.
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Page 114 of 221 If personnel are unaccounted for, the security computer will be queried to determine the individuals last known location. The individual(s) will be paged on the PA system, the individual's supervisor will be notified and if required, the SEC will initiate search and rescue operations.
J.6 Protective Measures for Those Remaining, or Reporting to the Site Personnel remaining onsite after the sounding of the Nuclear Emergency Alarm will be required to assemble in an area that is free from ionizing radiation and contamination, or presents the minimum exposure to personnel engaged in emergency operations. Surveys of the assembly area(s) will be conducted to ensure continued habitability.
Personnel remaining onsite who are engaged in emergency operations where there is an actual or potential radiological hazard, shall upon the direction of the RP Director, wear the required protective clothing and respiratory protection. The RP Department shall perform the required surveys and establish the type and quantity of clothing, and other protective measures required.
The Plant Security Force will control access to the Owner Controlled Area at the 1-94 Gatehouse as directed by the SEC.
Personnel arriving at the plant to assist in the emergency will be allowed access to the plant via minimal exposure routes as identified by the Plant RP Department and approved by the SEC.
The RP Department will establish a Controlled Area Access Point for personnel arriving at (and departing from) the plant from offsite if the access route exceeds the criteria for "Clean Areas" as identified in the Radiation Protection Plan. The amount of exposure personnel receive in reporting to the plant will be included in the individual's dose records.
Additionally, other precautions, such as decontamination, will be taken as necessary prior to entering the plant and reporting to the assigned assembly area. Equipment decontamination and controls are described in detail in the Radiation Protection Plan.
J.6.a. Respiratory Protection The Radiation Protection Plan and Radiation Protection Procedures identify the instructions and requirements pertaining to respiratory protection requirements and respiratory protection equipment usage.
J.6.b. Protective Clothing The Radiation Protection Plan and Radiation Protection Procedures identify the instructions and requirements pertaining to protective clothing requirements and protective clothing usage.
J.6.c. Radio-protective Drugs The procedures and precautions for the issuance and use of thyroid prophylaxis, e.g., individual thyroid protection, by emergency workers will be based on existing conditions. The provisions for stockpiling, inventory, storage and use are included in Emergency Plan Procedures. However, since the medical aftereffects of the agent cannot be determined, wholesale (wide) distribution cannot be incorporated as a responsible protective measure for personnel onsite.
J.7 Off-site Protective Actions For incidents that fall under the ECLs as defined herein, the SEC or ED will notify the Michigan State Police, the Berrien County Sheriff's Department, the NRC, and the AEP Emergency Response Organization described in this plan that such an incident has occurred.
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Page 115 of 221 It is the responsibility of the Governor of Michigan, or authorized representative, to issue Protective Action Orders (PAOs) such as sheltering, evacuation, administration of thyroid blocking agents, etc. These decisions are based upon the protective action guides in Annex S of the Michigan Emergency Management Plan (MEMP). Since copies of the MEMP are maintained and readily available at the various Emergency Response Facilities, the protective action guides and their bases will not be reproduced here.
For incidents involving actual or imminent releases of radioactive material to the atmosphere the Control Room or EOF protective action recommendation procedures, as appropriate, will be used as the basis for recommendations for protective actions to the public. These procedures are based on the current issue of the "Manual for Protective Action Guides and Protection Action for Nuclear Incidents" (EPA 400-R-92-001). The EPA Guide provides Protective Action Guides (PAGs) for whole body external gamma radiation and for inhalation of radioactive material in an airborne plume.
The most effective actions to be recommended to the public are evacuation, sheltering, and access control. Evacuation potentially provides the greatest margin of protection. On the other hand, because sheltering may be implemented in less time than evacuation, it may be the protective action of choice if rapid evacuation is impeded for any reason. Also, since sheltering is less disruptive than evacuation, it may be the protective action of choice when the dose reduction factor associated with shelter is adequate to reduce the projected dose to less than PAG levels.
Access control is an effective action to avoid exposure of personnel who might otherwise enter areas of high exposure unnecessarily.
Emergency Plan Procedures have been established to provide the mechanism and criteria for recommending protective actions to state and local government.
Additionally the protective action guides for emergency workers and those engaged in lifesaving activities exposed to airborne radioactive materials are listed in Section K.I., Emergency Exposure, and in the Plant Radiation Protection Plan.
J.8. Evacuation Times Evacuation time estimates and informational county maps are contained in the Berrien County Emergency Operations Plan submitted to the Nuclear Regulatory Commission (NRC).
Evacuation time estimates are performed within 365 days after the availability of the most recent decennial census data. Yearly reviews of the Evacuation time estimates are performed to estimate the Emergency Planning Zone permanent resident population changes.
J.9. Not Applicable J.10 Plume Exposure Pathway Protective Measures Implementation J.10.a. Route and Facility Location Maps Maps for the 10 and 50 mile EPZ, developed by the Michigan State Police are provided for use at the following locations:
Control Rooms TSC EOF OSC ENC/JIC Berrien County EOC Cook Energy Information Center Planning Standard J Revision 32
Page 116 of 221 These maps show information such as sector designations, emergency center locations topographical information, and when used in conjunction with Berrien County plan indicates preferred evacuation routes.
J.10.b. Population Distribution Maps Evacuation time estimates and informational county maps are contained in the Berrien County Emergency Operations Plan submitted to the Nuclear Regulatory Commission (NRC).
J.10.c. Population Notification The Berrien County Plan includes provisions for alerting local radio and television stations and, local news media to be prepared to transmit Emergency Public Information. Section E.6 addresses Public Notification J.10.d. Protective Action Basis The Dose Assessment Program and off-site survey team results, as well as plant system and equipment status, are the basis for Protective Action Recommendations. DAP and off-site surveys are addressed in sections 1.4 and 1.5.
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Page 117 of 221 Figure 12 Cook Nuclear Plant PrimaryEvacuation Routes Planning Standard J Revision 32
Page 118 of 221 PLANNING STANDARD K RADIOLOGICAL EXPOSURE CONTROL Planning Standard K Revision 32
Page 119 of 221 K. RADIOLOGICAL EXPOSURE CONTROL The CNP Radiation Protection Plan (PMI-6010) specifies the base criteria for the implementation of the Radiation Protection (RP) program and the methods to be used to control the exposure to radiation and radioactive materials. The standards listed in PMI-6010 and the programs to be followed consist of:
- 1. RP Training and Qualifications
- 2. ALARA Program
- 3. Radiation Work Permits
- 4. Dosimetry Program
- 5. Area Postings
- 6. Contamination Control
- 7. Internal Exposure Control
- 8. Radioactive Material Control Program
- 9. Survey Program
- 10. Instrumentation Program
- 11. Radiological Environmental Monitoring Program
- 13. Review and Surveillance Program Related sub-tier RP procedures have been developed to provide a detailed and comprehensive method of performing the daily and emergency assignments. The procedures cover the following areas:
- 1. Exposure Monitoring and Control
- 2. Respiratory Protection
- 3. Contamination Control
- 4. Radiological Controls
- 5. Instrumentation
- 6. Instrumentation Calibration
- 7. Radioactive Effluent Control
- 8. Abnormal Condition Response
- 9. RMS Instrumentation
- 10. RMS Instrumentation Calibration
- 11. RMS Alarm Response Planning Standard K Revision 32
Page 120 of 221 K.1. Emergency Exposure It is possible that emergency situations may arise which transcend the normal requirements for limiting dose.
Dose to penetrating radiation during emergency response or response to accidents may be up to 10 rem Total Effective Dose Equivalent (TEDE), 100 rem Committed Dose Equivalent (CDE) to the thyroid for non-life-saving actions.
Life saving doses may be up to 25 rem TEDE or 250 rem CDE to the thyroid. However, in all situations, every reasonable effort shall be made to minimize dose.
In no case shall this type of dose be permitted unless rescue personnel are wearing monitoring devices capable of monitoring these doses.
Situations may also rarely occur in which a dose in excess of 25 rem for emergency exposure would be unavoidable in order to carry out a lifesaving operation or to avoid extensive exposure of large populations. However, persons undertaking any emergency operation in which the dose will exceed 25 rem to the whole body should do so only on a voluntary basis and with full awareness of the risks involved, including the numerical levels of dose at which acute effects of radiation will be incurred and numerical estimates of the risk of delayed effects.
K.2. Emergency Exposure Authorization and Control Doses in excess of 10 CFR 20 limits may be authorized by the SEC in order to prevent serious property damage, serious bodily injury, or for life saving measures.
The assessment and recording of radiation exposures will be the assigned duty and responsibility of the person so designated by the RP Director. The SEC shall be made aware of any changes in cumulative exposures which would affect emergency team assignments.
The exposure of personnel who were in the immediate area of a radiation incident must be determined before they are assigned to any emergency or recovery team. Self-reading dosimeters, electronic dosimeters, area monitor records, or thermoluminescent dosimeters will be used to establish accumulated exposure for each individual.
K.3. Emer-gency Personnel Dosimetry K.3.a Dose Determination Radiation Exposure Records for exposed personnel will be maintained by the plant and will be available for review by the State of Michigan Department of Environmental Quality (DEQ).
K.3.b. Dosimetry Use and Dose Records PMI-6010 and applicable sub-tier procedures identify criteria and methods for reading, recording and maintaining dose records.
K.4. State and Local Emer-gency Exposure Authorization Not Applicable.
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Page 121 of 221 K.5. Decontamination K.5.a. Decontamination Criteria PMI-6010 and applicable sub-tier procedures identify the criteria for decontamination of personnel, personnel wounds, and equipment.
Survey data and records of data taken by the licensee resulting from a nuclear incident at the licensee's plant will be made available to the State for review upon written request to plant management by the Michigan DEQ or other designated State agency.
K.5.b. Decontamination Methods PMI-6010 and applicable sub-tier procedures identify the means and methods for decontamination of personnel, personnel wounds, and equipment.
There are two separate decontamination facilities which may be used during an emergency. The main facility is located in the Radiation Protection Access Control (RPAC) on the 609' elevation east of the auxiliary building. The other facility is located in the Auxiliary Building access at the Turbine Radiation Protection Access Control (TRPAC) on the. 609' elevation of the Unit ITurbine Building.
The decontamination facility associated with the RPAC consists of a decontamination area and a personnel shower. Additional space available in the area may also be used. Personnel protective clothing and equipment are also available in the RPAC.
Both decontamination facilities have adequate water supplies for both showers and wash basins. All floor and sink drains in the adjoining areas drain either into the laundry and hot shower drain tank or other contaminated liquid tanks for complete control of potentially contaminated wastes.
Information on equipment and inventory of supplies as well as detailed written procedures and standing orders, are found in the Administrative Procedures and the Emergency Plan Procedures, as well as the RP Plan and the RP Procedures. A list of Emergency Kit Locations is shown in Appendix C. Inventory procedures are specified in the RP procedure indicated in the Plant Procedure column in Appendix A.
K.6. Contamination Control K.6.a. Area Access Control PMI-6010 and applicable sub-tier procedures identify the means and methods for area access for control of contamination.
K.6.b. Waterand Food Contamination Control Not addressed.
K.6.c. Returninq Items and Areas to Normal Use PMI-6010 and applicable sub-tier procedures identify the means and methods for decontaminating and returning areas and items to normal use.
The public will be restricted from areas within the Owner Controlled Area normally open to the public (i.e.,
Energy Information Center) which have been contaminated with radioactive material in excess of the limits defined in Table 6, Maximum Allowable Contamination Limits for On-Site Facilities Used by the Public. Prior to the release of these areas for public use, the plant will notify the DEQ and provide the required data for review at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in advance of release of these areas to the public.
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Page 122 of 221 K.7. Decontamination of Relocated Onsite Personnel Personnel evacuated from onsite will be decontaminated as required by the plant RP procedures and Emergency Plan Procedures. If necessary and where possible, suitable protective clothing will be used during the evacuation.
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Page 123 of 221 Table 6 MAXIMUM ALLOWABLE CONTAMINATION LIMITS FOR ON-SITE FACILITIES USED BY THE PUBLIC*
Beta-Gamma Counts per Minute (cpm)1 2
Skin, Personal Clothing, and < 2 X Background Items Directly Associated With the Human Body 2
Material or Facilities Not < 2 X Background Directly Associated With the Human Body 1
Measured with GM and side window probe with beta shield opened or with thin window pancake probe.
2 Use background readings in cpm as measured pursuant to footnote 1. Gamma background must be 0.2 mR/hr, or less, as measured with a GM and a side window probe with the beta shield closed.
- Ref. Michigan Emergency Management Plan Planning Standard K Revision 32
Page 124 of 221 PLANNING STANDARD L MEDICAL AND PUBLIC HEALTH SUPPORT Planning Standard L Revision 32
Page 125 of 221 L. MEDICAL AND PUBLIC HEALTH SUPPORT L.1. Offsite Medical Support Lakeland Regional Medical Center, Saint Joseph, in St. Joseph, Michigan has an emergency room which is open 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day year round and arrangements have been made with them for the care of contaminated persons. There is a physician constantly on duty at the hospital.
Lakeland Regional Medical Center, St. Joseph is the primary site for the handling of contaminated patients from CNP. The hospital is approximately 9.5 miles from the plant site.
In addition, Niles Community Hospital, Niles located in Niles, Michigan, about 19 miles from the plant site, has facilities and staff for the handling of contaminated patients from CNP. This facility is the back-up site for Lakeland Regional Medical Center, St. Joseph.
The Radiation Emergency Area (REA) at Lakeland Regional Medical Center, St. Joseph, lends itself well to controlling the access of non-essential personnel. The REA at both St. Joseph and Niles is located in a section of the hospital remote from any other treatment facilities. A contaminated or potentially contaminated patient is wrapped and placed on a clean gumey when taken from the ambulance before being taken into the facility to avoid the spread of contamination.
The REA facility in both hospitals consists of a room designed for easy decontamination, should this be required. Adequate water is supplied for any necessary personnel or equipment decontamination. The facilities include a fiberglass table with a special drain to allow control of liquids for later removal from the hospital. If the injury does not require special handling because of contamination levels or high radiation levels, the facilities of the emergency room and other parts of the hospital are available.
In addition to that equipment normally found in hospital emergency facilities for routine non-nuclear emergencies, other specialized equipment includes such items as plastic and absorbent paper for contamination control, protective clothing, equipment for the control of liquid and solid wastes and their removal from the hospital to the plant for treatment and/or disposal, and assorted signs, barriers, and supplies. Also available at the hospital are such items as survey instruments, dosimeters, samplers, and associated equipment.
There are no limitations with regard to duration of. admissions of casualties or contaminated patients. Special rooms have been arranged so the patients can be kept as long as necessary before being transferred to a different facility or until released.
Onsite decontamination of the injured person, as well as the design of the REA with respect to the rest of the hospital, negates any limitations on the availability of the offsite medical facilities with respect to contamination levels. The only limitation due to direct radiation levels from a contaminated injured person is to the people directly concerned with treatment of the contaminated injured person because the REA is located in a part of the building remote from the patients and staff in most conditions. The limitation on the exposure of the physician or hospital staff remains a medical judgment made by the physician for individual cases. This judgment will be made using data obtained from portable radiation monitoring equipment.
Detailed procedures have been developed for activation of the hospital assistance plan. A comprehensive training program has been conducted for the hospital staff and employees who would be involved as a part of the offsite medical support. This program includes training in the principles of radiation protection, basic radiation protection procedures, applicable parts of the emergency plan and emergency procedures, and an exercise simulating radiological and physical injury. This training program shall be periodically reviewed and repeated at least once each year.
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Page 126 of 221 Plant personnel will monitor all persons leaving the treatment room after removal of protective clothing. The treatment room, all equipment used in the room and during patient treatment is surveyed by plant personnel for contamination. Any contaminated equipment or areas will be decontaminated by plant personnel to the Plant RP Protection Plan "Clean Area" specifications.
All radioactive waste is sealed and transported to the plant for disposal in accordance with current DOT and State regulations.
Subsequent therapy for individuals who have been exposed or contaminated is provided in the kind and extent which is required under the direction of the hospital physician. Additionally, consultation service is available from the Department of Energy's Radiation Emergency Assistance Center/Training Site on radiation related injuries.
L.2. Onsite Medical Support In the event of serious injury, medical treatment must always take precedence over decontamination of the individual. First Aid training is provided within several plant departments, providing emergency medical expertise within the plant. All plant personnel are trained in the proper response to a medical emergency. No physicians or nurses are located on-site.
The CNP has the necessary facilities and supplies at the site for decontamination and monitoring of personnel as well as the facilities and necessary medical supplies for appropriate emergency first aid treatment.
L.3 State Medical Support Listing Not Applicable.
L.4. Victim Transport Medic-1 Ambulance Service is located approximately 4 miles from the plant and provides the primary emergency medical services for the Plant. As a back up a plant emergency vehicle is available.
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Page 127 of 221 PLANNING STANDARD M RECOVERY AND RE-ENTY PLANNING AND POST ACCIDENT OPERATIONS Planning Standard M Revision 32
Page 128 of 221 M. RECOVERY AND RE-ENTRY PLANNING AND POST ACCIDENT OPERATIONS M.1. Reentry and Recovery The exact nature and details of a specific emergency determine the procedures that are used for the resumption of normal plant activities. The procedures formulated to regain the services of plant systems lost through such an incident follow the practices of good engineering judgment.
After the Emergency Plan has been activated, the plant personnel initiate a survey of plant damage and contamination. The plant systems or components involved in the incident are evaluated by any number of the following methods:
- 1. Radiation Surveys
- 2. Process instrumentation
- 3. Visual inspections (where possible)
- 4. Reactor Protection System Instrumentation
- 5. Reactor Control System Instrumentation
- 6. Out of core and in core nuclear instrumentation
- 7. Engineering safety features instrumentation
- 8. Radiation monitoring system
- 9. Post Accident Sampling Capability (where possible)
Re-Entry Survey or personnel monitoring teams are sent out to gather information prior to re-entry and report such findings to the individuals designated in the Emergency Plan Procedures in the TSC and/or the EOF.
The Radiation Protection Director (RPD) is responsible for protecting plant personnel re-entering the plant. The RPD is responsible for ensuring that radiation doses are under Federal limits for a radiation worker involved in plant re-entry before resuming normal plant operation.
Survey teams will measure radiation levels on and around the site and re-entry will be made when radiation hazards are reduced to permissible levels. The SEC will approve re-entry procedures based on existing and potential conditions of the plant.
Recovery Operations Where control of the incident has been attained and there is no further danger to personnel, the emergency phase shall be at an end. Restoration and recovery operations shall continue, but not under the same criteria as the emergency operation. During restoration and recovery operations, activity levels and personnel exposures will be based on 10 CFR 20 limits.
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Page 129 of 221 The recovery procedures that must be developed following a radiological incident will vary, but in general they will include the following activities:
- 1. Damage evaluation
- 2. Decontamination measures
- 3. Repair procedures
- 4. Disposal procedures
- 5. Ensure adequate offsite response readiness
- 6. Test and start-up procedures M.2. Recovery Organization The Recovery Organization is addressed in the Emergency Plan Procedures. See Appendix A for cross-reference.
M.3. Recovery Initiation Notification Normal communications channels will be utilized to notify State, County and other response organizations of the start of recovery operations and any changes occurring within the plans, procedures and response organization. Recovery operations affecting or interfacing with offsite responsibilities will be reviewed and approved by the appropriate response manager.
M.4. Estimating Population Total Exposure Not addressed.
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Page 130 of 221 PLANNING STANDARD N EXERCISES AND DRILLS Planning Standard N Revision 32
Page 131 of 221 N. EXERCISES AND DRILLS N.1 Exercises N.l.a. Exercise Content Each exercise will be conducted in accordance with a unique scenario developed for that exercise. Each exercise tests portions of emergency preparedness plans within the AEP system, State and County. The plant will also participate in joint exercises initiated and coordinated by the NRC and FEMA to test the effectiveness of the emergency plan(s) at all levels.
The ultimate criteria against which the results of exercises are to be measured will be effective implementation of the plant's and participating response organization emergency response plans to a simulated event, and the manner in which all agencies, public and private, interface their plans to assure that the public health and safety is protected.
N.i.b. Exercise Scheduling An annual emergency exercise is conducted at CNP to test various basic elements of the emergency preparedness program. Biennially, this exercise is conducted with participation of offsite emergency personnel, including those of State and County agencies.
Off-hours shift augmentation drills ensure that the goals of Table 1, CNP Staffing for Radiological Emergencies, are being met. These drills are to be conducted semi-annually. One of these drills per calendar year will include the contacted personnel reporting to their assigned emergency facilities and activating the facility. Credit can be taken for normal shift personnel above that indicated for "On-shift" to meet the augmentation goals.
Scenarios will be varied from year to year such that all major elements of the Emergency Plan, Emergency Plan Procedures and Emergency Response Organizations are tested within a 5 year period (see Appendix J, Eight Year Plan Matrix, for 8 year plan).
N.2 Drills N.2.a. Communication Drills Communications is a part of each drill and exercise. Links are established between the off-site agencies and the Cook ERO, or plant personnel playing the part of the off-site agencies communicate with the ERO communicators.
Communication links between the Plant emergency facilities are established as a part of each drill or exercise. Anytime Offsite Survey Teams are dispatched for drill or exercises communication and control with the teams is established.
N.2.b. Fire Drills Quarterly fire drills are conducted to ensure participation biannually by site fire brigade members.
An annual fire drill is held that includes participation of an offsite fire department.
N.2.c. Medical Emergency Drills An exercise simulating radiological and physical injury shall be conducted with the offsite medical personnel annually.
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Page 132 of 221 N.2.d. Radiological Monitoring Drills Drills involving response to, and analysis of, simulated airborne, liquid, and environmental (vegetation, snow, soil, etc.) samples and direct radiation measurements in the environment shall be conducted semi-annually.
N.2.e. Health Physics Drills N.2.e.1. Environmental Monitoring Drills involving response to, and analysis of, simulated airborne, liquid, and environmental (vegetation, snow, soil, etc.) samples and direct radiation measurements in the environment shall be conducted semi-annually.
N.2.e.2. Plant Liquid Monitoring PASS removed by Operating License change #261 and 244 for Ul and 2 respectively delete requirements for Post Accident Sampling System.
N.2.f. Other drills N.2.f.1 Hostile Action Based Drills Drills involving response to the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an. end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. (NRC Commitment 8373.)
N.2.f.2 Fast Breaking Drills Drills involving an initial classification of, or rapid escalation to, a Site Area Emergency or General Emergency.
N.2.f.3 No radiological release or minimal release.
Drills involving declaration of a Site Area Emergency but not a General Emergency that involve no radiological release or an unplanned minimal radiological release.
N.3. Drill and Exercise Execution Each scenario shall be jointly developed by appropriate response agencies participating in the exercise and shall include:
N.3.a Basic objective(s) of the exercise N.3,b. Date, time and place and participating response agencies, and the extent to which participating agencies will respond.
N.3.c. Simulated events, which may include offsite radiological releases.
N.3.d. Time Line of real and simulated events.
N.3.e. Narrative summary describing the conduct of the exercise.
N.3.f. Arrangements for official observers, and advance materials to official observers.
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Page 133 of 221 N.4. Official Observation and Critique After the drill or exercise, a critique shall be conducted involving participants, controllers and observers. The critique should be held as soon as practicable after completion of the drill or exercise.
N.5. Results Evaluation and Corrective Actions A formal evaluation of exercises, with lessons learned, shall be prepared and submitted through the Corrective Action Program. The Emergency Preparedness Manager (or alternate) shall review and assign action items to upgrade those areas where deficiencies were noted. These action items will be assigned, tracked and closed using the plant corrective action program.
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Page 134 of 221 PLANNING STANDARD 0 RADIOLOGICAL EMERGENCY RESPONSE TRAINING Revision 32
Page 135 of 221
- 0. RADIOLOGICAL EMERGENCY RESPONSE TRAINING 0.1 Organization Training Cook Nuclear Plant provides training to agencies or organizations that provide onsite assistance to the plant. Types of organizations provided this training are as follows:
Local Law Enforcement Ambulance Service Fire Departments Hospitals Training should be offered annually. Should any of these agencies requestthe additional request.training, taken to facilitate either in scope or schedule, every possible action should be The training of Berrien County and State of Michigan emergency response personnel is the responsibility of the Michigan State Police Emergency Management and Homeland Security Division. The Cook Nuclear Plant is committed to assist in the endeavor upon request.
0.2. Onsite ERO Training The plant training program is the responsibility of the Training Manager.
A general employee training program provides initial orientation training and annual (every 12 months) retraining to CNP employees in the general emergency plan response. They are familiarized with the sounding of the Nuclear Emergency Alarm, assembly areas and routes to take to these assembly areas. This training also includes general aspects of the Emergency Plan.
ERO position specific training and qualification is administered through TPD-600-EPT Emergency Preparedness Training Program Description. Position specific Job Familiarization Guides are used for on-the-job training and qualification of the ERO responders.
0.3. First Aid Team Training Personnel who respond to medical emergencies at the Cook Nuclear Plant receive either first-aid training or are.qualified as Medical Emergency Response Team members (MERT).
0.4 ERO Traininq and Qualification To the maximum extent practicable, emergency plan training and qualification should be incorporated into functional training and qualification programs.
Specialized initial training and retraining programs will be provided as outlined below for the following categories of emergency personnel.
0.4.a. Directors and Key Personnel Initial specialized training in emergency plan and procedures implementation is provided to the directors and coordinators of the response organizations including emergency plan drill participation and annual reviews of the same. Training for execution of the emergency plan is provided by completion of senior licensed operator training, or equivalent training that applies to emergency plan execution.
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Page 136 of 221 O.4.b. Personnel Responsible for Accident Assessment Initial specialized training in emergency plant operations, emergency plan and procedures implementation is provided including an annual review of the same. Further training includes participation in emergency plan drills.
O.4.c. Radiological Monitoring Teams Radiation Protection personnel receive Emergency Plan training as part of their Initial RP Technician training. Continuing Training and drill participation requirements addressed in TPD-600-EPT, Emergency Preparedness Training Program Description.
O.4.d. Security-& Fire Brigade Fire Brigade staff receive Initial and annual retraining in fire fighting techniques and first aid.
The Plant Security force is considered the Emergency Security Team. All actions required during emergencies are included in security officer training.
O.4.e. Onsite Repair & Damage Control The Damage Control Team is responsible for the repair and restoration of damaged plant systems, equipment, or components. Training, exercises and drills involving the Damage Control Team will be conducted in a manner consistent with established Emergency Plan Procedures.
O.4.f. First Aid & Rescue Teams The first-aid training program is administered by the Training Department.
The MERT program is administered by an accredited offsite institution.
O.4.g. Local Service Personnel (Offsite Fire Department Personnel and Local Sheriff)
The local Fire Departments receive familiarization in specific plant access and control procedures and participate annually in plant fire drills.
Sheriffs department receives annual Emergency Alert System (EAS) training and participates in the annual plant emergency exercise.
O.4.h. Medical Support Personnel An exercise simulating radiological and physical injury shall be conducted with the offsite medical personnel annually.
O.4.i. Licensee Headquarters Support Not addressed.
O.4.j. Personnel Transmitting Emergency Information and Instructions ERO Communicators receive ERO initial training and position specific Job Familiarization Guides for their specific communication duties.
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Page 137 of 221 0.5. Initial and Annual Retraining Initial training and qualification, as well as continuing training requirements addressed in TPD-600-EPT, Emergency Preparedness Training Program Description.
Initial training and job familiarization completed prior to assignment to the ERO.
Continuing training consists of the following (as minimum):
Drill participation at least once every two years.
ERO Facility training.
Annual ERO Classroom training or a requalification challenge exam.
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Page 138 of 221 PLANNING STANDARD P RESPONSIBILITY FOR PLANNING EFFORT Planning Standard P Revision 32
Page 139 of 221 P. RESPONSIBILITY FOR PLANNING EFFORT P.1 Emergency Planner Training Emergency Preparedness Coordinator position specific training and qualification is administered through TPD-600-EPC Emergency Preparedness Coordinator Training Program Description.
Position specific training and qualification card are used for training and qualification of Emergency Preparedness Coordinators.
P.2 Emergency Plan Administration Responsibility The Senior Vice President - Nuclear Generation Group shall have overall authority, and responsibility for radiological emergency response planning. In this effort he has the authority to delegate responsibility in the planning effort to enhance the overall readiness and ensure that the plan is updated as necessary. Normally plan updating and review will be the responsibility of the Vice President - Site Support Services. The training of individuals in the CNP Emergency Response Organization (ERO) in the Emergency Plan shall be the responsibility of the Training Manager.
P.3 Emergency Planning Coordinator Designation Not addressed.
P.4. Periodic Reviews Updates and Audits The responsibilities of the individuals, groups, agencies, the Emergency Plan, and implementation procedures to be followed during an emergency condition are reviewed at a minimum, on an annual basis and updated as required. All written agreements with offsite support groups are reviewed and updated if necessary, on a two year basis. This review will take into account changes identified by drills and exercises. The plant maintains up-to-date approved emergency response plans from the state and county. Changes to these offsite plans are reviewed to maintain an effective interface with the Cook Emergency Plan.
The Plant Operations Review Committee is responsible for the review of changes to the Emergency Plan. The Plant Operations Review Committee is also responsible for the review of changes, other than editorial corrections, to. the Emergency Plan Implementing Procedures. The Senior Vice President - Nuclear Generation Group, or designee, shall approve changes to the Emergency Plan.
All reviews shall be documented. The Senior Vice President-Nuclear Generation Group shall be sent copies of the changes. NRC approval shall be obtained as appropriate.
P.5. Emeraency Plan Change Communication Approved Emergency Plan revisions and/or applicable procedural changes will be promptly forwarded to appropriate offsite emergency support organizations.
A list of changes to the Emergency Plan shall be submitted with each plan revision. Changes to the Plant's Emergency Plan Procedures shall be made in accordance with plant practice for revising procedures.
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Page 140 of 221 P.6 Emergency Response Organization Support Plans Plan Source Emergency Operations Plan Berrien County Sheriffs Office Michigan Emergency State of Michigan Management Plan Regional Plan Handbook - RAP Department of Energy Region V INPO Emergency Response Institute of Nuclear Power Operations Manual National Response Plan, Department of Homeland Security with NRC Nuclear/Radiological Incident as Coordinating Agency Annex P.7. Implementing Procedures Detailed procedures for implementing and providing additional information on the Emergency Plan are available in the Emergency Plan Procedures. The written procedures indicated in Appendix A cover the following but are not limited to:
- 1. Authority and responsibility for completing specific tasks.
- 2. Action levels requiring implementation of protective measures outlined.
- 3. Medical treatment procedures and handling of contaminated individuals.
- 4. Necessary equipment for medical treatment, radiation detection, and rescue operations.
- 5. Identification of emergency communications equipment.
- 6. Emergency center description and operation.
- 7. Restoration procedures from emergency to normal conditions.
- 8. Communications P.8 Table of Contents & Cross-reference Table of Contents and Appendix A fulfill this requirement.
P.9. Independent Emergency Program Review Audits of the Emergency Plan and implementing procedures are performed as delineated in 10 CFR 50.54(t)(1). These audits shall be performed by the Plant Performance Assurance Department and may include items relating to training, readiness testing, equipment, State/lfocal plant interfaces, medical arrangements, etc.
Audit findings shall be reported, evaluated and recommendations completed as described in the Audit Program Policy. The results of the audit, along with the recommendations for improvements shall be documented and reported to plant management and retained for a period of five years.
Reviews involving the adequacy of interface with State/local agencies shall be available to the appropriate agency.
P.10. ERO Telephone Number Updates Appendix J fulfils this requirement.
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Page 141 of 221 APPENDIX A
- 1. INDEX OF PLANT EMERGENCY PLAN PROCEDURES
- 2. CROSS REFERENCE BETWEEN THE COOK NUCLEAR PLANT AND THE PLANT EMERGENCY PROCEDURES Appendix A Revision 32
Page 142 of 221 DONALD C. COOK NUCLEAR PLANT PLANT MANAGER PROCEDURES EMERGENCY PLAN PROCEDURES CONTROL ROOM IDENTIFICATION NUMBER TITLE RMA-2080-EPA-008 EMERGENCY PLAN MANAGEMENT PMP-2080-EPP-1 00 EMERGENCY RESPONSE PMP-2080-EPP-101 EMERGENCY CLASSIFICATION PMP 2080-EPP-108 INITIAL DOSE ASSESSMENT PMP 2080-EPP-200 INITIATING CHANGES TO THE EMERGENCY PLAN OR EMERGENCY PLAN IMPLEMENTING PROCEDURES PMP-2081-EPP-105 CORE DAMAGE ASSESSMENT RMT-2080-EOF-001 ACTIVATION AND OPERATION OF THE EOF RMT-2080-EOF-002 EMERGENCY TERMINATION AND RECOVERY RMT-2080-JIC-001 ACTIVATION AND OPERATION OF THE ENC/JIC RMT-2080-OSC-001 ACTIVATION AND OPERATION OF THE OSC RMT-2080-TSC-001 ACTIVATION AND OPERATION OF THE TSC Appendix A Revision 32
Page 143 of 221 NUREG-0654 - EMERGENCY PLAN - PROCEDURE CROSS REFERENCE At Cook Nuclear Plant, NUREG-0654 is applied as guidance in plan and procedure development with consideration to plant organization, administrative policies and operating procedures.
NUREG-0654 (11Planning EMERGENCY Standards and Evaluation PLAN SECTION PLANT PROCEDURE Criteria)
A.1.a A.1.a Not applicable B.8 B.9 A.1.b A.1.b Not applicable A.1.c A.1.c Not applicable
.Figure 1 Figure 2 Figure 3 Figure 4 Figure 5 Figure 6 Figure 7 Figure 8 Figure 9 Figure 10 A.l.d A.1.d PMP-2080-EPP-100 RMT-2080-EOF-001 A.1.e A.1.e RMT-2080-EOF-001 Table I A.2. Not applicable Not applicable A.3 A.3 RMA-2080-EPA-008 Appendix B A.4 A.4 RMT-2080-EOF-001 RMT-2080-OSC-001 RMT-2080-TSC-001 B.1 B.1 Not applicable Figure 3 Figure 4 Appendix A Revision 32
Page 144 of 221 B.2 B.2 PMP-2080-EPP-100 B.1.j.
B.5.a.1 B.5.c.1 B.3 B.3 PMP-2080-EPP-100 RMT-2080-TSC-001 RMT-2080-EOF-001 B.4 B.4 PMP-2080-EPP-100 RMT-2080-EOF-001 B.5 B,5 RMT-2080-OSC-001 Table I RMT-2080-TSC-001 Figure 5 RMT-2080-EOF-001 Figure 6 RMT-2080-JIC-001 Figure 7 ERO On-Shift Staffing Figure 8 Analysis Report B.6 B.6 Not applicable Figure 8 B.7 B.5 ERO On-Shift Staffing Table 1 Analysis Report B.7.a B.7.a RMT-2080-EOF-001 B.5.c.9 B.7.b B.7.b RMT-2080-TSC-001 B.5.c.8 B.7.c B.7.c RMT-2080-EOF-001 B.5.c.1 B.7.d B.7.d RMT-2080-JIC-001 B.5.d.1 B.8 B.8 Not applicable C.4 Appendix B B.9 B.9 Not applicable L.1 Appendix B C.I.a C.1.a Not applicable C.1.b C.1.b Not applicable Appendix E C.1 .c Appendix E Not applicable C.2.a Not applicable Not applicable C.2.b B.5.e.1 RMT-2080-EOF-001 C.3 H.6.c RMT-2080-EOF-001 Appendix B Appendix A Revision 32
Page 145 of 221 Appendix H C.4 C.4 RMT-2080-EOF-001 B.8 Appendix B Appendix H D.1 D.1 PMP-2080-EPP-101 Table 2 Table 3 Table 4 D.2 D.2 PMP-2080-EPP-101 Table 2 Table 3 Table 4 D.3 Not applicable Not applicable D.4 Not applicable Not applicable E.1 E.1 PMP-2080-EPP-1 00 E.2 E.2 PMP-2080-EPP-100 SPP-2060-SFI-216 E.3 E.3 PMP-2080-EPP-100 E.4 E.4 PMP-2080-EPP-1 00 RMT-2080-EOF-001 E.5 Not applicable Not applicable E.6 E.6 Not applicable Appendix D E.7 E.7 PMP-2080-EPP-100 RMT-2080-EOF-001 F.1.a F.1.a PMP-2080-EPP-100 F.1.b F.1.b RMT-2080-EOF-001 F.1.c F.1.c. RMT-2080-EOF-001 Appendix E F.1.d F.1.d RMT-2080-EOF-001 F.1.e F.1.e. PMP 2080-EPP-100 F.1.f F.1.f RMT-2080-EOF-001 F.2 F.2 Not applicable F.3 F.3 EPP-2080-ERO-001 G.1 G.1 Not applicable Appendix D Appendix A Revision 32
Page 146 of 221 G.2 G.2 Not applicable G.3.a G.3. RMT-2080-JIC-001 G.3.b Not addressed Not applicable G.4.a G.4.a RMT-2080-JIC-001 G.4.b G.4.b. RMT-2080-JIC-001 G.4.c G.4.c. RMT-2080-JIC-001 G.5 G.5. Not applicable H.1 H.1 (TSC) RMT-2080-TSC-001 H.3 (OSC) RMT-2080-OSC-001 H.2 H.2 RMT-2080-EOF-001 H.3 Not applicable (SEOC/CEOC) Not applicable H.4 H. PMP-2080-EPP-1 00 H.5 H.5 RMT-2080-TSC-001 H.5.a H.5.a RMT-2080-EOF-001 RMT-2080-OSC-001 H.5.b H.5.b RMT-2080-TSC-001 H.5.c H.5.c RMT-2080-TSC-001 H.5.d H.5.d Not applicable H.6 H.6 RMT-2080-EOF-001 H.6.a H.6.a RMT-2080-EOF-001 ERO PHONE DIRECTORY H.6.b H.6.b RMT-2080-EOF-001 EPP-2080-ERO-001 H.6.c H.6.c RMT-2080-EOF-001 H.7 H.7 EPP-2080-ERO-001 H.8 H.8. RMT-2080-EOF-001 H.9 H.3 RMT-2080-OSC-001 H.10 Appendix J EPP-2080-ERO-001 H. 11 Appendix C EPP-2080-ERO-001 H.12 H.3.d. RMT-2080-EOF-001 Appendix A Revision 32
Page 147 of 221 1.1 1.1. PMP-2080-EPP-101 Table 2 Table 3 Table 4 1.2 1.2 RMT-2080-EOF-001 1.3.a 1.3.a. RMT-2080-EOF-001 1.3.b 1.3.b. RMT-2080-EOF-001 1.4 1.4 RMT-2080-EOF-001 1.5 1.5 RMT-2080-EOF-001 1.6 Not addressed Not applicable 1.7 1.7 RMT-2080-EOF-001 1.8 1.8 RMT-2080-EOF-001 1.9 1.9 RMT-2080-EOF-001 1.10 Not addressed RMT-2080-EOF-001 1.11 Not applicable RMT-2080-EOF-001 J.1.a J.1.a RMT-2080-TSC-001 J. 1.b. J.1.b. RMT-2080-TSC-001 J.1.c. J.1.c. RMT-2080-TSC-001 J.1.d. J. 1.d. RMT-2080-TSC-001 J.2 J.2 RMT-2080-TSC-001 Figure 14 J.3 J.3 RMT-2080-TSC-001 J.4 J.4 RMT-2080-TSC-001 J.5 J.5 RMT-2080-TSC-001 J.6.a J.6.a. RMT-2080-EOF-001 J.6.b J.6.b. RMT-2080-EOF-001 J.6.c J.6.c. RMT-2080-EOF-001 J.7 J.7 RMT-2080-EOF-001 J.8. J.8, PMP-2080-EPP-100 Berrien County Emergency RMT-2080-EOF-001 Operations Plan Appendix A ý Revision 32
Page 148 of 221 J9 Not Applicable Not Applicable J.19.a. J.10.a. Not applicable J.10.b J.10.b. Not Applicable J.10.c. J.10.c. Not Applicable E.6.
J.10.m. J.10.d. PMP-2080-EPP-100 1.4. RMT-2080-EOF-001 1.5.
K.1la-g K.1 RMT-2080-TSC-001 K.2 K.2 RMT-2080-TSC-001 K.3.a K.3.a. RMT-2080-OSC-001 K.3.b. RMT-2080-OSC-001 K. Not Applicable Not Applicable K.5.a K.5.a. PMI-6010 K.5.b K.5.b EPP-2080-ERO-001 K.6.a. K.6.a. PMI-6010 K.6.b. Not Addressed K.6.c. K.6.c. PMI-6010 K.7 K.7 PMI-6010 L.1 L.i. PMI-6010 L.2 L.2. Not applicable L.3. Not Applicable Not applicable L.4 L.4 Not applicable M.1 M.A RMT-2080-OSC-001 M.2 M.2 RMT-2080-EOF-002 M.3 M.3 RMT-2080-EOF-002 M.4 Not addressed Not applicable N.1.a N.i.a PMI-2080 N.1.b. N.1.b. PMI-2080 AppendixJ Appendix A Revision 32
Page 149. of 221 N.2.a N.2.a. PMI-2080 N.2.b Tech. Spec. PMI-2270 N.2.c N.2.c. EPAM-2080-000 Appendix J N.2.d N.2.d. PMP-2080-EPP-500 N.2.e N.2.e PMP-2080-EPP-500 N.3 N.3 PMP-2080-EPP-500 N.4 N.4 PMP-2080-EPP-500 N.5 N.5 PMP-2080-EPP-500 0.1 0.1 TPD-600-EPT O.1.a. 0.1 TPD-600-EPT 0.1.b. Not applicable Not applicable 0.2 0.2 TPD-600-EPT 0.3 0.3 EPAM-2080-000 0.4.a 0.4.a. TPD-600-EPT 0.4.b 0.4.b. TPD-600-EPT 0.4.c. 0.4.c. TPD-600-EPT 0.4.d. 0.4.d. Not addressed 0.4.e. 0.4.e. TPD-600-EPT 0.4.f. 0.4.f. Not addressed 0.4.g. 0.4.g. Not addressed 0.4.h. 0.4.h. Not addressed 0.4.i. Not addressed Not addressed 0.4.j. 0.4.j. TPD-600-EPT 0.5 0.5. TPD-600-EPT P.1 P.1 TPD-600-EPC P.2 P.2 PMI-2080 P.3 Not addressed PMI-2080 Appendix A Revision 32'
Page 150 of 221 P P.4. PMI-2080 P.5 P.5 PMP-2030-DOC-001 P.6 P.6 Not applicable P.7 Appendix A Not applicable P.8 Table of Contents Not applicable Appendix A P.9 P.9 Not applicable P.10 Appendix J EPAM-2080-000 Appendix A Revision 32
Page 151 of 221
-APPENDIX B AGREEMENTS WITH OFF-SITE SUPPORT AGENCIES Appendix B Revision 32
Page 152 of 221 APPENDIX B Agreements with Off-Site Support Agencies
- 1. Sheriff Department, Berrien County, Michigan 1 page July 13, 2012
- 2. Lakeland Medical Center 1 page September 17, 2012
- 3. Lake Township Fire Department 1 page September 14, 2012
- 4. City of Bridgman Fire Department 1 page September 19, 2012
- 5. Medic 1 Community Emergency Service 2 pages September 13, 2012
- 6. Reciprocal Laboratory Use Agreement 2 pages December 15, 2011
- 7. Mutual Assistance Agreement Between Detroit Edison 6 pages January 09, 2013 Company, Entergy Nuclear Palisades and Indiana Michigan Power Co.
- 8. Institute of Nuclear Power Operations Emergency Resources 1 page October 30, 2012
- 9. Voluntary Assistance Agreement By and Among Electric Utilities 9 pages January 17, 2003 Involved in Transportation of Nuclear Materials
- 10. Nuclear Power Plant Emergency Response Voluntary 12 pages January 17, 2003 Assistance Agreement
Page 153 of 221 Sheriff Department, Berrien County, Michigan 1 page BwwE CoUr'rry EMEIGENCY MANAGEmtNT D.v-sIoN. OF B R"EN COUNTY S RiDTx'S .O.V*ýc DAVEYPAGEL 2100 E. EiolpreAvenae, Bentonl Harbor, *tfidiigan 49022 'kXRD0'CoAWM,1sAi0 Telephone (269).983-7141, Fihx: (269) 983-5726
- 1. PAUL RAILEY C.'*PT,COREYDURKS 7113/2012 Mr. James W. Chambers Cook Nuclear plant Onehcook Place Brldgman., Ml 49106
Dear Mr. Chambers:
We Wish to reaffirm thewillingnesg ofh'e BdrlAri County heriff's Depkqr..en. tospornd upon request to Any Amfergency which could occ*r attlte DC.. 0Cok facility. Beilten "
County Emergency Managenient/Office of'Homeland Security has the obligation to respond ppon n0lification that an emergency exists.. Berrien County wuid Implement the r NuclearAccident PtocbdUres (Appendix 1) 6f the Emergency Operations Pian and take Appropriate actionsas outlined therein, In addition, the Sheriff's.Department has basic patrol and Investigative services ahd currently has a fourteen member Hazardous Materials Response Team who Is trained to Technician Level, Five of the f6urteeri Haz-Mat team members are cross-trained as bomb tachniclans, all of Whom have su.coeasfdslycomplted the United States A y Haxardous wevice School at Redstone Arsenal in lRedstonr, Alabahia. Our tacical unk corrisit:O f 21 pemonnel who conduct a monthly training.
May we again assire you that th sve ,r*q bf the Badnjoh Countly Sheriffds Department will b9 available to you uponr request in aiy area within the jdrsdictlon of this age*loy.
Sincerely, L.RPaul Bailey SlherfffIDire~clor, *Emergency Manlagement L:PBlgr6 ORIGINAL Appendix B Revision 32
Page 154 of 221 1 page Lakeland Medical Center Lakeland HealthCare Medical Excellence. Compassionate Care.
September 17, 2012 Mr. Joel Gobble Sr. Vice President & Chief Nuclear Officer Cook Nuclear Plant One Cook Place Bridgman, MI 49106
Dear Mr. Gobble:
This letter is to confirm that Lakeland HealthCare provide care for the injured radioactively-contaminated patient at the St. Joseph and Niles Emergency Department sites to Include Donald C. Cook personnel on site and members of the general public off-site that may require services from Plant operations.
Annual training and drills will be conducted to assure staff competency in caring for this patient population, with evaluation by FEMA. A policy and procedure manual Is available at each site and updated regularly to incorporate changes in patient management. An identified Radiation Emergency Area (REA) is available at each site that allows for stabilization, treatment, and management of the radioactive component ofthe emergency. I understand that the training for hospital personnel, equipment, and stocking of the disaster cart will be provided byDonald C. Cook Nuclear Plant.
This agreement shall remain in effect from the date of signing unless the agreement Is terminated. Any party upon ninety (90) days prior written notice to the other party, may terminate this agreement.
Please contact Kathy Effa, Manager of Emergency Services, at 269-983-8670 for any assistance that you require.
Sincerelvr
-L-6ren B. Hamel, MD President &CEO Lakeland HealthCare LBH:nb 1234 Napier Avenue, St. Joseph, Ml 49085 (269) 983-8300 www.lakelandhealth. org
. ... Revision 32 Appendix 1:
Page 155 of 221 Lake Township Fire Department 1 page LAKE TOWNSHIP FIRE AND RESCUE P.O. BOX 818 3169 SHAWNEE ROAD BRIDGMAN, MICHIGAN 49106 269-465-6351 Emergeenv Presaredness Asreement Between Lake Charter Township Fire DMartment and Donald C. Cook Nuclear Plant Upon receipt of a request for -assistance from the Cook Nuclear Plant, Lake Charter Township Fire Department agrees to respond by sending personnel, apparatus, and equipment to the Cook Nuclear Plant site.
The Cook Nuclear Plant agrees to lead Lake Charter Township Fire Department responders from the Security Control Center to the scene and agrees to provide escorts for Lake Charter Township Fire Fighting vehicles and personnel while in the Protected Area, or other owner controlled areas.
The Cook Nuclear Plant and Lake Charter Township Fire Department agree that for all fires in the Plant Protected Areas, the Plant Fire Brigade Leader will be responsible for fire extinguishment with the assistance of Lake Charter Township Fire Department personnel and advice and counsel of the Lake Charter Township Fire Chief or his designee.
For fires outside the Plant Protected Area, the Lake Charter Township Fire Chief shall be responsible for fire extinguishment with the advice and counsel of the Plant Fire Brigade Leader or designee if they are present.
The Cook Nuclear Plant agrees to provide and Lake Charter Township Fire Department agrees to participate in annual site specific training and drills conducted at the Cook Nuclear Plant site.
This agreement shall remain in effect from the date of signing unless the agreement is terminated.
Any party upon ninety (90) days prior written notice to the other party may terminate this agreement.
As an indication of your agreement to the above statements concerning our mutual responsibilities, please sign below.
Sincerely, Accepted and agreed to this 4 4 day ot.6 "1 h ,&b, 2012 Joel Gebbie Site Vice President Supervisor Cook Nuclear Plant Lake Charter Township Fire Chief Lake Charter Township Fire Department Appendix B Revision 32
Page 156 of 221 City of Bridgman Fire Department 1 page BRIDGMAN FIRE RESCUE P.O. BOX 366 4234 VINE STREET BRIDGMAN MICHIGAN 49106 (269)-465-3803 (269)-465-5144 FAX (269)-465-3701 EMERGENCY 911 Emergency Preparedness Agreement Between Bridgman City Fire Department and Donald C.
Cook Nuclear Plant Upon receipt of a request for assistance from the Cook Nuclear Plant, Bridgman City Fire Department agrees to respond by sending personnel, apparatus, and equipment to the Cook Nuclear Plant site.
The Cook Nuclear Plant agrees to lead Bridgman City Fire Department responders from the Security Control Center to the scene and agrees to provide escorts for Bridgman City Fire Fighting vehicles and personnel while in the Protected Area, or other owner controlled areas.
The Cook Nuclear Plant and Bridgman City Fire Department agree that for all fires In the Plant Protected Areas, the Plant Fire Brigade Leader will be responsible for fire extinguishment with the assistance of Bridgman City Fire Department personnel and advice and counsel of the Bridgman City Fire Chief or his designee.
For fires outside the Plant Protected Area, the Bridgman City Fire Chief shall be responsible for fire extinguishment with the advice of Lake Charter Township Fire Chief and counsel of the Plant Fire Brigade Leader or designee if they are present The Cook Nuclear Plant agrees to provide and Bridgman City Fire Department agrees to participate in annual site specific training and drills conducted at the Cook Nuclear Plant site.
This agreement shall remain In effect from the dale of signing unless the agreement is terminated.
Anyparty upon ninety (90) days prior written notice to the other party may terminate this agreement.
As an indication of your agreement to the above statements concerning our mutual responsibilities, please sign below.
Sincerely, Accepted and agreed to this
____day of S 9 4&- .2012 Joel Gebbie Non Birmingham Site Vice President Bridgman City Mayor Cook NuclearPlant Rich Knuth Fire Chief Bridgman City Fire Department Appendix B Revision 32
Page 157 of 221 Medic I Community Emergency Service 2 pages
- ravxrnxiliIc MDIC Emergency PlanningAgreetnent Between Medic 1 Ambudance and DonaldC Cook Nuclear Plant The purpose of this letter is to establish an agreement between Indiana and Michigan Electric Company's Donald C. Cook Nuclear Plant and Medic 1 Ambulance. In the event of an emergency at the Cook Nuclear Plant involving an injury, Medic I Ambulance agrees to provide medical care whether the victim has been injured.as the result of an accident involving radioactive contamination, hazardous waste, or a regular work accident.
Upon receipt of a request for an EMS vehicle from the Cook Nuclear Plant Control Room, Medic 1 Ambulance agrees to respond by sending personnel, apparatus, and equipment to the Plant site.
Cook Nuclear Plant agrees to provide an escort for.EMS vehicles and personnel while in the protected area.
Cook Nuclear Plant agrees to provide the necessary health physics support to Medic I Ambulance staff during the treatment of victims who are injured in an accident involving radioactive contamination.
In the event of an injury involving a hazardous waste, specific chemical information will be provided to Medic I Ambulance staff.
The communication link between Medic I Ambulance and Cook Nuclear Plant will be provided via telephone communication through the Berrien County dispatch radio.
Cook Nuclear Plant agrees to provide training for emergency room and EMS personnel in order to prepare them for handling oftradiologically contaminated victims. Such training will consist of, but not be limited to, a discussion of types of radiation, types of contamination, methods of decontamination, and methods of controlling the spread of contamination.
Cook Nuclear Plant agrees to conduct and Medic I Ambulance agrees to participate injoint drills that include plant personnel, EMS personnel, and emergency room personnel. These drills will meet Joint Commission on Accredited Hospitals (JCAHT) requirements.
Cook Nuclear Plant agrees to decontaminate all Medic I Ambulance equipment and facilities including EMS vehicles that have become contaminated as a result ofetreatment ofa victim in a timely fashion and to dispose of the associated waste.
Cook Nuclear Plant agrees to provide emergency kits for the emergency room and the ambulance.
P.O. Box 1563 / Benton Harbor, MI 49023 / Phone (269) 925-2141 Appendix B Revision 32
Page 158 of 221 Medic 1 Ambulance agrees that medical care provided under this agreement includes any assistance rendered through existing mutual aid agreements entered into by Medic 1 Ambulance.
Any party, upon ninety (90) days prior notice to the other party, may terminate this agreement.
As indication of your agreement to the above statement concerning our mutual responsibility, please sign below.
Jack *lsher, Jr.-
Site Vice President Executive Director Cook Nuclear Plant Medic I Ambulance Dated: 9/l'b,1 2- Dated: Septembex 7, 2012.
Appendix B Revision 32
Page 159 of 221 Reciprocal Laboratory Use Agreement 2 pages RECIPROCAL LABORATORY USE AGREEMENT WITNESSETH THAT WHEREAS, INDIANA MICHIGAN POWER, (hereinafter called IMP) and ENTERGY NUCLEAR PALISADES, L.L.C., (hereinafter called "ENTERGY") have chemical and radiochemical analytical laboratories at their Donald C Cook Nuclear Plant and Palisades Nuclear Plant, respectively, which laboratory facilities are suitable for performing chemical analyses following a nuclear-related accident (NRA), and WHEREAS, IMP and Entergy each desire to provide the temporary use of their respective existing laboratory facilities and personnel to perform chemical analyses for the other in the event the other has lost use of its laboratory facilities due to a NRA, NOW, THEREFORE, the parties hereto do hereby mutually agree as follows:
- 1. In the event either party hereto is unable to use its laboratory facilities due to a NRA, the other party agrees to temporarily use Its existing laboratory facilities and personnel, to the extent practical, to analyze without charge, samples delivered to it by the party which suffered the NRA. Each party agrees, in connection with such sampling, handling and analyses, to comply with the requirements of NUREG-0578 and NUREG-0737 and such other requirements as may be specified by the Nuclear Regulatory Commission in regard to past-accident sample analysis.
- 2. Each party agrees, in performing analyses for the other, to provide a high standard of professional service, provided, however, that neither party shall have any obligation or liability for damages, including, but not limited to, consequential damages, arising out of or in connection with the others use of, or reliance on, the results of such analyses.
- 3. This agreement shall be effective on the date hereof and shall continue until terminated as hereinafter set forth. Either party hereto may terminate this agreement at any time hereafter upon sixty (60) days written notice of termination to the other party.
Appendix B Revision 32
Page 160 of 221 INDIANA MICHIGAN POWER BY: ~ r'VI4~ z4~1 Joel P. Gebbie Date Site Vice President DC Cook Nuclear Plant ENTERGY NUCLEAR PALISADES, L.L.C.
BY: &~AJJLL1LJ2 Anthony d. Date Site Vicex dent - Palisades Appendix B Revision 32
Page 161 of 221 Mutual Assistance Agreement Between Detroit Edison Company, Entergy Nuclear 6 pages Palisades and Indiana Michigan Power Co.
MUTUAL ASSISTANCE AGREEMENT BETWEEN DETROIT EDISON, ENTERGY NUCLEAR PAUSADES, L.LC.
AND INDIANA MICHIGAN POWER Appendix B Revision 32
Page 162 of 221 0.1 Entergy Nuclear Palisades, LL.C., Detroit Edison and Indiana Michigan Power, WITNESSETH 0.2 WHEREAS, Entergy Nuclear Palisades, (LLC), Detroit Edison and Indiana Michigan Power own electric facilities, Including nuclear generation stations and are engaged In the generation of electric power In Michigan; and 0.3 WHEREAS, the parties desire to help assure the availability of adequately trained and experienced emergency personnel in the event of an emergency situation at any of their nuclear generating stations; 0.4 NOW, THEREFORE, in consideration of the promises and mutual covenants herein set forth, the parties agree as follows:
ARTICLE I DEFINITIONS 1.1 "Alert" shall be defined as a situation in which events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant.
1.2 "Emergency" shall be defined consistent with the definition of osite area emergency as set forth in NUREG 0654 as a situation in which events are In process or have occurred which Involve actual or likely major failures of plant functions needed for protection of the public.
1.3 "Requesting party" shall be defined as any party to this Agreement who, upon the occurrence of an emergency at one of its nuclear generating stations, seeks emergency assistance, pursuant to this Agreement, from one or more of the parties hereto.
1.4 "Responding party" or responding parties shall be defined as any party or parties to this Agreement who are presented with a request for emergency assistance pursuant to this Agreement.
Appendix B Revision 32
Page 163 of 221 ARTICLE II REQUESTS FOR EMERGENCY ASSISTANCE 2.1 In the event of an Alert at one of its nuclear generating stations, any party to this Agreement may notify any or all of the other parties that an Alert exists and that their emergency assistance may be required.
2.2 In the event of an emergency at one of its nuclear generating stations, any party to the Agreement may request emergency assistance from any or all of the other parties.
2.3 Requests for emergency assistance shall be made between and among the following party personnel:
Entergy Nuclear Palisades, L.L.C. Site Vice President- Palisades Nuclear Plant Detnoit Edison Site Vice President - Fermi Nuclear Plant Indiana Michigan Power Site Vice President - Cook Nuclear Plant ARTICLE III EXCUSED FAILURE TO RESPOND 3.1 Failure to respond to a request for emergency assistance pursuant to this Agreement shall be excused if, in order to respond, the requested party or parties would be forced In its or their sole judgment or judgments to:
3.1.1 Violate its duties relating to the care and staffing at its own nuclear generating stations; or 3.1.2 Jeopardize the public health or safety at a location other than the location of the requesting party emergency.
ARTICLE IV SCOPE OF ASSISTANCE 4.1 If requested under this Agreement, the responding party or parties will provide trained and experienced personnel to perform off-site radiation protection activities to the requesting party. All equipment intended for use by the responding personnel, except personal dosimeters and certification documents (such as certifications of Health Physics training, instrument training and dose exposure records), shall be the responsibility of the requesting party to provide. The responding party or parties may use their own equipment ifagreeable to the requesting party. However, use by the responding party or parties of their own equipment shall in no way alter the duties and obligations imposed upon the parties by this Agreement.
4.2 Emergency assistance provided by the responding party or parties shall continue until their personnel are dismissed by the requesting party, or are recalled by the responding party to support operations at its own facilities.
Appendix B Revision 32
Page 164 of 221 4.3 Responding party or parties' personnel exposure shall be limited to off-site radiation, and such exposure shall not exceed federal requirements as set forth in 10CFR20.
4.4 Wages, hours and other terms and conditions of employment applicable to loaned personnel shall be those of the party providing such personnel.
4.5 Personnel provided by responding party or parties shall, at all times during the period In which emergency assistance is being provided, continue to be employees of the responding party or parties. The responding party, and not the requesting party, shall be liable to loaned personnel for any wages, salaries, cost and expenses associated with the provision of emergency assistance.
ARTICLE V REIMBURSEMENT FOR EMERGENCY ASSISTANCE RENDERED 5.1 The requesting party shall reimburse each responding party for all costs and expenses Incurred by each responding party In providing emergency assistance hereunder. Such costs and expenses shall include:
5.1.1 Salaries and wages paid to loaned personnel (Including supervisors) for paid time spent In the requesting party service area, and paid time for travel to and from such service area; 5.1.2 A percentage of the total of such wages and salaries, as determined by the responding party, reflecting expenses incurred for:
6.1.2.1 Compliance with Worker Compensation laws; 5.1.2.2 Payroll taxes; 5.1.2.3 Hospitalization, surgical and medical coverage; 5.1.2.4 Pensions and life insurance; 5.1.2.5 Vacation, holiday and sick pay; 5.1.2.6 Travel accident insurance; 5.1.3 Transportation to and from the requesting party service area, Including the cost of travel accident insurance purchased expressly for coverage during such transportation; 5.1.4 Food and lodging; 5.1.5 Personal expenses specifically agreed to between the requesting and responding parties; 5.1.6 Charges, at the rates Internally used by the responding party, for the use of transportation equipment and other equipment requested; and 5.1.7 Any further costs specifically agreed to between the requesting and responding Appendix B Revision 32
Page 165 of 221 parties.
5.2 All time sheets and work records pertaining to loaned personnel shall be maintained by the responding party.
5.3 All charges shall be paid by the requesting party to each responding party within ten (10) days after receipt of an invoice, itemized to the satisfaction of the requesting party.
ARTICLE VI INDEMNIFICATION 6.1 The requesting party shall Indemnify and hold harmless each responding party from and against any and all liability for loss, damage, cost or expense which the responding party shall Incur by reason of bodily Injury, including death, to any person or persons, or by reason of damage to or destruction of any property, including the loss of use thereof, arising out of or in any manner connected with the giving of emergency assistance to the requesting party.
6.2 Inthe event of bodily Injury, including death, to any employee of the responding party, or In the event of damage to or destruction of any property of the responding party, the requesting party shall indemnify the responding party for such loss In the following manner:
6.2.1 Ifsuch loss Is covered by an insurance policy purchased by the responding party from a third party carrier, the requesting party shall make reimbursement to the extent such losses Increase the responding party Insurance coass; 6.2.2 Ifsuch loss Is not covered by an Insurance policy purchased by the responding party or exceeds such coverage, the requesting party shall make reimbursement to the extent of the claims or benefits actually paid or the losses sustained by the responding party.
ARTICLE VII MODIFICATION 7.1 At any lime after the date of this Agreement any party, by giving not less than thirty days written notice to the other parties, may from time to time call for reconsideration of the terms and conditions of this Agreement. Ifsuch reconsideration Is called for, the authorized representatives of the parties shall meet as promptly as convenient and discuss any of the terms and conditions of the Agreement. No party shall be under any obligation to agree to any modification or supplement not satisfactory to it. Any agreement modifying or supplementing such terms and conditions shall be In writing, signed by all parties, and shall specify the date such modification or supplement shall become effective.
ARTICLE VIII PLAN EXERCISING 8.1 The parties agree to provide, at their own expense, personnel to observe or assist In Appendix B Revision 32
Page 166 of 221 demonstrating the effectiveness of a nuclear generating station emergency plan as may be required by that nuclear generating station NRC approved emergency plan.
ARTICLE IX TERM OF AGREEMENT 9.1 This Agreement shall continue Indefinitely from the date of signing unless and until terminated as provided for In Section 9.2 below.
9.2 Any party, upon sixty (60) days prior written notice to all other parties, may. terminate this Agreement.
IN WITNESS WHEREOF, the parties hereto cause this Agreement to be executed by their duly authorized officers on duplicate original pages attached hereto and made a part hereof.
ENTEPY NUCLEAR P AL>E 7 ZA IAth h VDate Site Vice Prsbnti Palisades DETROIT EDISON COMPANY 4J. 'r,C~t. OVI09 p3 James T. n Date Site Vice Iaent - Fermi INDIANA MICHIGAN POWER Joel . G.blbe Date Site Vice President Cook Nuclear Plant Appendix B Revision 32
Page 167 of 221 Institute of Nuclear Power Operations Emergency Resources 1 page I 1!P Institute ofSut10 NuclearPower Operations 700 6allerlaParkway, SE Atlanta, MA30339-5943 770-W44-8000 FAX 770-644-8549 October 30, 2012
Dear Ladies and Gentlemen:
This letter certifies that the plant emergency. assistance agreement between INPO and its member utilities remains in effect. In the event ofan emergency at your utility, INPO will assistyou in acquiring the help of other organizations in the industry, as described in Section 1 of the Emergency Resources Manual, INPO 03-001, and in the United States Nuclear Industry Response Framework. If requested, INPO will provide the following assistance:
" coordinate technical information flow from the affected utility to the nuclear industry and government agencies
" coordinate the procurement and shipping of equipment and supplies
" locate personnel with technical expertise
" 'facilitate industry vendor and commercial supplier support
- obtain technical information and industry operating experience regarding plant comporients and systems
" provide an INFO liaison to facilitate interface This agreement will remain in effect until terminated in writing. Should you have any questions, please call Steve Meng at (770) 644-8548 or e-mail at MengSW@inpo.org.
Sincerely, Jeffrey T Gasser Vice President Emergency Response JTG:cjm Appendix B Revision 32
Page 168 of 221 EMERGENCY RESOURCES MANUAL INSTITUTE OF NUCLEAR POWER OPERATIONS INPO 03-001 January 2003 LlrAII W. 1IX IHIMiUnuM; Ccmip'l:liwl'l O l i , r :: r lrAii :: *I ku:.ur- Irv.v*!l Vv *xC;lululfrLga.*4 Ic in " r i ii i:-'iuJi LUiw.
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.hco civcreiln re.loc..*-.p'yO,' C'trc- :Ibsljr.rnmr.rt Appendix B Revision 32
Page 169 of 221 Voluntary Assistance Agreement By and Among Electric Utilities Involved in 9 pages Transportation of Nuclear Materials 6.2 Voluntary Assistance Agreement By and Among Electric Utilities Involved in Transportation of Nuclear Materials This Voluntary Assistance Agreement (hereinafter."Agreement") has been entered into by and among electric utilities involved in transportation of source material, special nuclear material, or byproduct material received, possessed, used, or transferred under a general or specific license Issued by the U.S. Nuclear Regulatory Commission pursuant to Title 10 of the Code of Federal Regulations (hereinafter "nuclear materials") and which have subscribed counterpart signature pages in the form attached hereto (hereinafter "Parties').
The Parties wish to set forth herein their understanding and agreement with respect to their mutual undertaking to each other in the situation wherein an Emergency arises during the transportation of nuclear materials shipped by or on behalf of a Party and a request for assistance is issued to another Party in respect to such Emergency and such assistance Is provided. This Agreement is intended only to define the terms and conditions Under which such assistance, if volunteered, will be rendered and received. It is understood that this Agreement does not Impose any obligation on any Party to render or continue to render any such assistance, but this Agreement does record the understanding of the Parties with respect to the rights and obligations which will be incurred in responding to requests for assistance.
NOW, THEREFORE, It is agreed, that:
- 1. Assistance rendered by a party as described hereunder shall be entirely voluntary and, when given in response to a request by any Party for help during an Emergency arising by reason of the transportation of nuclear materials, shall be rendered In accordance with the terms and conditions herein.
- 2. The Party that requests assistance shall be known as the "Requesting Company" and the Party furnishing assistance shall be known as the "Responding Company."
Attachment A Is a suggested letter confirming an agreement whereby assistance will be furnished pursuant to this Agreement.
8-5 Appendix B Revision 32
Page 170 of 221
- 3. (a) Requesting Company shall notify Responding Company of the type of assistance requested and the anticipated duration during which such assistance is desired. Requesting Company may also provide general direction as to the actions to be taken by Responding Company. Responding Company shall furnish such assistance as it may decide. Except as such companies may agree otherwise, Responding Company shall be responsible for determining the procedures to be followed in furnishing such assistance and for supervising work at the site of the Emergency.
Requesting Company, incooperation with Responding Company, shall make any report to governmental authorities and the news media. Requesting Company will notify Responding Company when its assistance is no longer needed.
(b) The furnishing of assistance hereunder shall be deemed to. have commenced when personnel of the Responding Company are assigned to other-than-normal duties or.transportalion of equipment commences pursuant to a determination by the Responding Company to provide assistance to a Requesting Company under this Agreement and shall be deemed to have terminated when the transportation of such personnel or equipment back to their working base, or home (for personnel returning at other than regular working hours), Is completed.
(c) The Responding Company shall make all arrangements for the transportation of Its personnel and equipment from and to their working base or home.
- 4. (a) Employees of Responding Company shall at all times continue to be employees of and remain under the supervision and control of the Responding Company and shall at no time and for no purpose be deemed to be servants, agents, employees, or representatives of the Requesting Company.
(b) Wages, hours, and other terms and conditions of employment applicable to personnel of the Responding Company, Including work procedures and/or safety rules, shall be those of the Responding Company.
(c) All personnel of the Responding Company shall be equipped by the Responding Company with such normal working and protective equipment as shall be compatible with the circumstances under which said personnel shall 6-6 Appendix B Revision 32
Page 171 of 221 function hereunder; Requesting Company shall inform Responding Company of any specific equipment which may be required in a particular situation.
- 5. (a) Responding Company shall furnish the requested personnel and equipment to the extent that the Responding Company may determine to do so in its sole judgment and discretion.
(b) Responding Company shall have the right, at any time and In its sole judgment and discretion, to withdraw personnel and equipment furnished to the Requesting Company and return such personnel and equipment to their working base. Responding Company shall give written notice at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in advance to Requesting Company of the permanent withdrawal of personnel or equipment furnished. Responding Company's withdrawal of personnel or equipment shall not affect any obligations which may have been incurred hereunder prior to such withdrawal or which may arise out of events occurring prior to such withdrawal.
- 6. All time sheets and work records pertaining to Responding Company personnel and equipment shall be kept by the Responding Company. The Responding Company shall furnish -the Requesting Company with a detailed statement of all costs and expenses paid or incurred by the Responding Company in connection with the furnishing of assistance to the Requesting Company, which statement shall be paid by Requesting Company within thirty (30) days after receipt.
- 7. The Requesting Company shall reimburse Responding Company for all direct and Indirect costs and expenses, not including a profit, incurred by Responding Company in giving assistance pursuant to this Agreement, including but not limited to costs and expenses related to or resulting from compliance with governmental requirements such as Title 10 of the Code of Federal Regulations, Part 20. Such costs and expenses shall be computed in accordance with Responding Company's standard rates and accounting practices including such overheads as are determined by Responding Company to be applicable to such direct and indirect costs and expenses incurred by Responding Company.
6-7 Appendix B Revision 32
Page 172 of 221 Requesting Company shall have the right to audit the records of Responding Company relative to work performed pursuant to this Agreement.
- 8. (a) In addition, and subject to the provisions of paragraph 8(b) hereof, Requesting Company shall Indemnify and hold Responding Company, its officers, directors, and employees, jointly and severally, harmless from and against any and all lability or loss, damage, cost, or expense which any of them may Incur by reason of bodily Injury, Including but not limited to death, to any person or persons, or by reason of damage to or destruction of any property, including but not limited to the loss of the use thereof, which results from furnishing assistance pursuant to this Agreement, whether due In whole or In part to any act, omission, or negligence of Responding Company, Its officers, directors, or employees.
(b) Where payments are made by Responding Company or its insurers to Responding Company's officers, directors, or employees or their beneficiaries for bodily injury or death resulting from furnishing assistance pursuant to this Agreement, including but not limited to workers' compensation, disability, pension plan, medical and hospitalization, or other such payments, Requesting Company shall make reimbursement to Responding Company to the extent such payments increase the Responding Company's employee-related costs, whether such Increase in costs occurs in the form of an Increase In premiums or contributions, a reduction In dividends or premium refunds, or otherwise. Requesting Company shall also reimburse Responding Company for any deductible amounts or for any amounts paid by Responding Company as a self-insurer. Responding Company will request Its Insurer to waive any right of subrogation it may have against Requesting Company as a result of any payment described in this paragraph 8(b) which such insurer may make on behalf of Responding Company because of Responding Company's furnishing of assistance pursuant to this Agreement.
(c) In the event any claim or demand Is made or suit, action, or proceeding is filed against Responding Company, Its officers, directors, or employees, jointly or severally, alleging liability for which Requesting Company 6-8 Appendix B Revision 32
Page 173 of 221 shall indemnify and hold harmless Responding Company, its officers, directors and employees under paragraph 8(a) hereof, Responding Company shlall promptly notify Requesting Company thereof, and Requesting Company, at its sole cost and expense, shall settle, compromise, or defend the same in such manner as it in its sole discretion deems necessary or prudent. Responding Company shall cooperate with Requesting Company in the resolution of any such matter.
(d) Each party to this Agreement agrees to carry financial protection required by the Atomic Energy Act of 1954, as amended, and self-Insurance or comprehensive liability Insurance, Including contractual liability coverage covering the Indemnification and defense obligations set forth herein, subject to such types and amounts of self-insurance, retentions, or deductibles as are consistent with good business practice in the industry.
(e) In the event a Responding Company provides assistance pursuant to this Agreement through an affiliate or subsidiary, the Indemnification provided in this paragraph 8 to the officers, directors, and employees of that Responding Company shall apply with equal force to the officers, directors, and employees of that affiliate or subsidiary.
- 9. Each Party shall provide the Institute of Nuclear Power Operations (hereinafter "INPO*) with an executed counterpart signature page to this Agreement and to any amendments heretoý This Agreement shall become effective when counterpart signature pages executed by at least two Parties shall have been received by INPO. This Agreement shall remain In effect as to any Party until such Party has withdrawn from the Agreement as provided below. Any electric utility involved in the transportation of nuclear materials may become a Party upon execution of the Agreement.
- 10. (a) INPO may provide certain administrative and emergency response support services in furtherance of this Agreement, such as maintaining and distributing to the Parties a roster of the signatories to this Agreement; providing copies of the Agreement and any amendments thereto to all Parties; and 6-9 Appendix B Revision 32
Page 174 of 221 preparing and distributing to the Parties other documents, such as a list of sources of emergency manpower and equipment. INPO may provide such other services as may be requested of INPO from time to time by the Parties. The Parties recognize that INPO shall not be responsible for implementing, enforcing, or interpreting this Agreement.
(b) The Parties shall defend, indemnify, and hold harmless INPO, its officers, directors, and employees, jointly and severally, from and against any and all liability or loss, damage, cost, or expense which results from performance of INPO functions described In paragraph 10(a) of this Agreement, except as may result from the sole negligence or willful misconduct of INPO, its officers, directors, or employees. Each Party hereby expressly waives any right it may have to assert any claim against INPO, Its officers, directors, or employees arising out of its or their performance of the duties described In paragraph 10(a),
except as may result from the sole negligence or willful misconduct of INPO, its officers, directors, or employees.
(c) Following the occurrence of an emergency involving the transportation of nuclear materials INPO may, if asked to do so by a Requesting Company, help to locate sources of emergency manpower and equipment with which the Requesting Company may contract for assistance. If INPO does furnish such assistance and, unless otherwise agreed by INPO and the Requesting Company, the Requesting Company and INPO shall have the same rights and obligations as if INPO were a Responding Company (including but not limited to the Requesting Company's obligations to INPO, its officers, directors, and employees under paragraph 8 hereof), except that paragraphs 6 and 7 shall not apply either to Requesting Company or INPO and paragraph 8(d) shall not apply to INPO.
- 11. This Agreement will not create any rights or defenses in favor of an entity or person not a signatory to this Agreement except to the extent provided in this paragraph and in paragraphs 8 and 10 of this Agreement. This Agreement shall be binding upon and inure to the benefit of each signatory to this Agreement and the subsidiaries and affiliates of each such signatory.
6-10 Appendix B Revision 32
Page 175 of 221
- 12. Except as otherwise provided in paragraph 13, any Party may withdraw from this Agreement upon at least thirty (30) days' prior written notice to INPO with a copy to all of the other Parties. Notice of withdrawal shall not affect any obligations which may have been incurred hereunder prior to the effective date of such notice or which may arise out of events occurring prior to that date. No party may withdraw from this Agreement while it is receiving assistance pursuant to this Agreement.
- 13. This Agreement may be amended by agreement of a majority of the Parties hereto. Such amendment shall be effective and binding upon all Parties thirty (30) days after INPO has received counterpart signature pages for the amendment executed by at least a majority of the Parties to the Agreement. INPO shall notify all Parties when at least a majority of the Parties have executed an amendment to the Agreement. No amendment shall affect any obligation which may have been Incurred hereunder prior to the effective date of such amendment or which arises out of events occurring prior to that date. Notwithstanding the first sentence of paragraph 12, any Party may withdraw from this Agreement by submitting written notice to INPO at any time during the thirty (30) day period prior to the effective date of such amendment with a copy to all of the other Parties.
- 14. If any provision of this Agreement is determined to be Invalid or unenforceable as to any Party or otherwise, such determination shall not affect the validity or enforceability of the other provisions of this Agreement as to that Party or otherwise.
6-11 Appendix B Revision 32
Page 176 of 221 6.1 Signatories to the Voluntary Assistance Agreement By and Amono Electric Utilities Involved In Transportation of Nuclear Materials The following organizations have signed the Voluntary Assistance Agreement By and Among Electric Utilities Involved in Transportation of Nuclear Materials.
AmerenUE (Union Electric Company)
AmerGen Energy Company, LLC Arizona Public Service Company Constellation Energy Group Dominion Generation Duke Energy Corporation Energy Northwest Entergy Nuclear Exelon Corporation FirstEnergy Nuclear Operating Company FPL Group, Inc.
Indiana Michigan Power Company Nebraska Public Power District Nuclear Management Company, LLC Omaha Public Power District Pacific Gas and Electric Company PPL Susquehanna, LLC Progress Energy, Inc.
PSEG Nuclear LLC Rochester Gas and Electric Corporation South Carolina Electric & Gas Company 6-3 Appendix B Revision 32
Page 177 of 221 6.1 Siginatories to the Voluntary Assistance Actreement By and Amona Electric Utilities Involved in Transportation of Nuclear Materials (continued)
Southern California Edison Company Southern Nuclear Operating Company STP Nuclear Operating Company Tennessee Valley Authority The Detroit Edison Company TXU Energy Wolf Creek Nuclear Operating Corporation 6-4 Appendix B Revision 32
Page 178 of 221 Nuclear Power Plant Emergency Response Voluntary Assistance Agreement 10 pages 6.3 Sicinatories to the Nuclear Power Plant Emergency Response Voluntary Assistance Agreement The following organizations have signed the Nuclear Power Plant Voluntary Assistance Agreement.
AmerenUE (Union Electric Company)
AmerGen Energy Company, LLC Arizona Public Service Company Constellation Energy Group Dominion Generation Duke Energy Corporation Energy Northwest Entergy Nuclear Exelon Corporation FirstEnergy Nuclear Operating Company FPL Group, Inc.
Indiana Michigan Power Company Nebraska Public Power District Nuclear Management Company, LLC Omaha Public Power District Pacific Gas and Electric Company PPL Susquehanna, LLC Progress Energy, Inc.
PSEG Nuclear LLC Rochester Gasand Electric Corporation South Carolina Electric & Gas Company 6-15 Appendix B Revision 32
Page 179 of 221 6.3 Signatories to the-Nuclear Power Plant Emergency Response Voluntary Assistance Agreement (continued)
Southern California Edison Company Southern Nuclear Operating Company STP Nuclear Operating Company Tennessee Valley Authority The Detroit Edison Company TXU Energy Wolf Greek Nuclear Operating Corporation 6-16 Appendix B Revision 32
Page 180 of 221 6.4 Nuclear Power Plant Emergency Response Voluntary Assistance Apreement This Nuclear Power Plant Emergency Response Voluntary Assistance Agreement (hereinafter "Agreement") has been entered into by and among electric utilities which have responsibility for the construction or operation of commercial nuclear power plants under a license issued by the U.S. Nuclear Regulatory Commission pursuant to Title 10 of the Code of Federal Regulations (hereinafter "nuclear power plants') and which have subscribed counterpart signature pages In the form attached hereto (hereinafter "Parties").
The Parties wish to set forth herein their understanding and agreement
.with respect to their mutual undertaking to each other in the situation wherein an emergency occurs at a nuclear power plant under the control of or operated on behalf of a Party and a request for assistance Is issued to another Party hereto in respect to such emergency and such assistance is provided. This Agreement is intended only to define the terms and conditions under which such assistance, If
- volunteered, will be rendered and received. ItIs understood that this Agreement does not impose any obligation on any Party to render or continue to render any such assistance, but this Agreement does record the understanding of the Parties with respect to the rights and obligations which will be incurred In responding to requests for assistance.
NOW, THEREFORE, it is agreed, that
- 1. Assistance rendered by a Party as described hereunder shall be entirely voluntary and, when given in response to a request by any Party for help following an emergency arising at a nuclear power plant, shall be rendered in accordance with the terms and conditions herein.
- 2. The Party that requests assistance shall be known as the "Requesting Company" and the Party furnishing assistance shall be known as the "Responding Company." Attachment A is a suggested letter confirming an agreement whereby assistancewill be furnished pursuant to this Agreement.
6-17 Appendix B Revision 32
Page 181 of 221
- 3. (a) Requesting Company shall notify Responding Company of the type of assistance requested and the anticipated duration during which such assistance is desired. Responding Company shall furnish such assistance as It may decide. Except as such companies may agree otherwise, Requesting Company shall be responsible for determining the procedures to be followed relative to the furnishing of such assistance, directing the work, and making any reports to governmental authorities and the news media regarding the emergency or the furnishing of assistance pursuant to this Agreement. Requesting Company shall notify Responding Company when Its assistance is no longer needed.
(b) The furnishing of assistance hereunder shall be deemed to have commenced when personnel of the Responding Company are assigned to other than normal duties or transportation of equipment commences pursuant to a determination by the Responding Company to provide assistance to a Requesting Company under this Agreement and shall be deemed to have terminated when the transportation of such personnel or equipment back to their working base, or home (for personnel returning at other than regular working hours), Is completed.
(c) The Responding Company shall make all arrangements for the transportation of its personnel and equipment from and to.their working base or home.
- 4. (a) Employees of Responding Company shall at all times continue to be employees of the Responding Company and shall at no time and for no purpose be deemed to be servants, agents, employees, or representatives of the Requesting Company.
(b) Wages, hours, and other terms and conditions of employment applicable to personnel of the Responding Company shall be those of the Responding Company.
Work procedures, security, and safety rules for such personnel shall be those of the Requesting Company.
6-18 Appendix B Revision 32
Page 182 of 221 c) Unless otherwise agreed, all personnel of the Responding Company shall be equipped by the Responding Company with such normal working and protective equipment as shall be compatible with the circumstances under which said personnel shall function hereunder, Requesting Company shall inform Responding Company of any specific equipment which may be required in a particular situation.
- 5. (a) Responding Company shall fumish the requested personnel and equipment to the extent that the Responding Company may determine to do so In its sole judgment and discretion.
(b) Any Information which Responding Company may provide to Requesting Company (including drawings, reports, and analyses) or which Requesting Company provides to Responding Company, which either the Responding Company or the Requesting Company considers proprietary or confidential, shall be so designated.
Such proprietary information shall be held in confidence and shall be used exclusively in connection with the emergency at the nuclear power plant at which the emergency has occurred (including necessary disclosures on a proprietary basis to others in that connection) and shall not be published or otherwise disclosed to others, except as may be required by law.
(c) Responding Company shall have the right, at any time and in its sole judgment and discretion, to withdraw personnel and equipment furnished to the Requesting Company and return such personnel and equipment to its working base.
Without limiting Responding Company's rights under the preceding sentence, Responding Company shall attempt to schedule any such withdrawal of its personnel or equipment to accommodate the needs of Requesting Company. Responding Company shall give written notice at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in advance to Requesting Company of the permanent withdrawal of personnel or equipment furnished. Responding Company's withdrawal of personnel or equipment shall not affect any obligations which may have been incurred hereunder prior to such withdrawal or which may arise out of events occurring prior to such withdrawal.
- 6. All time sheets and work records pertaining to Responding Company personnel and equipment shall be kept by the Responding Company. The Responding 6-19 Appendix B Revision 32
Page 183 of 221 Company shall furnish the Requesting Company with a detailed statement of all costs and expenses paid or incurred by the Responding Company In connection with the furnishing of assistance to the Requesting Company, which statement shall be paid by Requesting Company within thirty (30) days after receipt.
- 7. The Requesting Company shall reimburse Responding Company for all direct and indirect costs and expenses, not including a profit, incurred by Responding Company In giving assistance pursuant to this Agreement, Including but not limited to costs and expenses related to or resulting from compliance with governmental requirements such as Title 10 of the Code of Federal Regulations Part 20. Such costs and expenses shall be computed In accordance with Responding Company's standard rates and accounting practices Including such overheads as are determined by Responding Company to be applicable to such direct and Indirect costs and expenses incurred by Responding Company. Requesting Company shall have the right to audit the records of Responding Company relative to work performed pursuant to this Agreement.
- 8. (a) In addition, and subject to the provisions of paragraph 8(b) hereof, Requesting Company shall Indemnify and hold Responding Company, its officers, directors, and employees, jointly and severally, harmless from and against any and all liability or loss, damage, cost or expense which any of them may incur by reason of bodily injury, including but not limited to death, to any person or persons, or by reason of damage to or destruction of any property, Including but not limited to any property located at the site of the Requesting Company's nuclear power plant or the loss of use.
of any property, which results from furnishing assistance pursuant to this Agreement, whether due In whole or in part to any act, omission, or negligence of Responding Company, its officers, directors, or employees.
(b) Where payments are made by Responding Company or its insurers to Responding Company's officers, directors, or employees or their beneficiaries for bodily injury or death resulting from furnishing assistance pursuant to this Agreement, including but not limited to workers' compensation, disability, pension plan, medical and hospitalization, or other such payments, Requesting Company shall make reimbursement to Responding Company to the extent such payments increase the 6-20 Appendix B Revision 32
Page 184 of 221 Responding Company's employee-related costs, whether such Increase In costs occur in the form of an Increase in premiums or contributions, a reduction in dividends or premium refunds, or otherwise. Requesting Company shall also reimburse Responding Company for any deductible amounts or for any amounts paid by Responding Company as a self-insurer. Responding Company will request its Insurer to waive any right of subrogation it may have against Requesting Company as a result of any payment described in this paragraph 8(b) which such insurer may make on behalf of Responding Company because of Responding Company's furnishing of assistance pursuant to this Agreement (c) Responding Company makes no warranty with respect to any goods or services provided to Requesting Company and NO WARRANTY, EITHER EXPRESS OR IMPLIED, ORAL OR WRITTEN, SHALL APPLY TO THE GOODS OR SERVICES PROVIDED, INCLUDING, WITHOUT LIMITATION, THE WARRANTIES OF MERCHANTABILITY AND OF FITNESS FOR SPECIFIED OR INTENpED PURPOSE.
All equipment and services furnished by Responding Company pursuant to this Agreement are furnished as Is.
(d) In the event any claim or demand is made or suit, action, or proceeding is filed against Responding Company, its officers, directors, or employees, jointly or severally, alleging liability for which Requesting Company shall indemnify and hold harmless Responding Company, its officers, directors, and employees under this paragraph 8 hereof, Responding Company shall promptly notify Requesting Company thereof, and Requesting Company, at its sole cost and expense, shall settle, compromise, or defend the same in such manner.as it in its sole discretion deems necessary or prudent. Responding Company shall cooperate with Requesting Company in the resolution of any such matter.
(e) Each Party to this Agreement agrees to carry the amount of financial protection required by the Atomic Energy Act of 1954, as amended, and self-insurance or comprehensive liability insurance, including contractual liability coverage, covering the indemnification and defense obligations set forth herein,.subject to such types and amounts of self-insurance, retentions, or deductibles as are consistent with good business practice In the Industry.
6-21 Appendix B Revision 32
Page 185 of 221 (f) In the event a Responding Company provides assistance pursuant to this Agreement through an affiliate or subsidiary, the indemnification provided In this paragraph 8 to the officers, directors, and employees of that Responding Company shall apply with equal force to the officers, directors, and employees of that affiliate or subsidiary.
- 9. Each Party shall provide the Institute of Nuclear Power Operations (hereinafter "INPO') with an executed counterpart signature page to this Agreement and to any amendments hereto. This Agreement shall become effective when counterpart signature pages executed by at least two Parties shall have been received by INPO.
This Agreement shall remain In effect as to any Party until such Party has withdrawn from the Agreement as provided below. Any electric utility with responsibilities for the construction or operation of a nuclear power plant may become a Party upon execution of the Agreement.
- 10. (a) INPO may provide certain administrative and emergency response support services in furtherance of this Agreement, such as maintaining and distributing to the Parties a roster of the signatories to this Agreement; providing copies of the Agreement and any amendments thereto to all Parties; and preparing and distributing to the Parties other documents, such as a list of sources of emergency manpower and equipment. INPO may provide such other services as may be requested of INPO from time to time by the Parties. The Parties recognize that INPO shall not be responsible for implementing, enforcing, or Interpreting this Agreement.
(b) The Parties shall defend, Indemnify, and hold harmless INPO, its officers, directors, and employees, jointly and severally, from and against any and all liability or loss, damage, cost, or expense which results from performance of INPO's functions described in paragraph 10(a) of this Agreement, except as may result from the sole negligence or willful misconduct of INPO, its officers, directors, or employees. Each Party hereby expressly waives any right it may have to assert any claim against INPO, its officers, directors, or employees arising out of its or their performance of INPO's functions described in paragraph 10(a), except as may result from the sole negligence or willful misconduct of INPO, its officers, directors, or employees.
6-22 Appendix B Revision 32
Page 186 of 221 (c) Following an emergency at a nuclear power plant, INPO may, Ifasked to do so by a Requesting Company, help to locate sources of emergency manpower and equipment with which the Requesting Company may contract for assistance. The.
Requesting Company may ask INPO to furnish personnel or equipment followingan emergency arising at a nuclear power plant. If INPO does furnish such assistance and unless otherwise agreed by INPO and the Requesting Company, the Requesting Company and INPO shall have the same rights and obligations as if INPO were a Responding Company (including but not limited to the Requesting Company's.
obligations to INPO, its officers, directors, and employees under paragraph 8 hereof),
except that paragraphs 6 and 7 shall not apply either to Requesting Company or INPO and paragraph 8(e) shall not apply to INPO.
- 11. This Agreement will not create any rights or defenses in favor of any entity or person not a signatory to this Agreement except to the extent provided in this paragraph and In paragraphs 8 and 10 of this Agreement. This agreement shall be binding upon and inure to the benefit of each signatory to this Agreement and the subsidiaries and affiliates of each such signatory.
- 12. Except as otherwise provided in paragraph 13, any Party may withdraw from this Agreement upon at least thirty (30) days prior written notice to INPO with a copy to all of the other Parties. Notice of withdrawal shall not affect any obligations which may have been incurred hereunder priorto the effective date of such notice or which may arise out of events occurring prior to the date. No Party may withdraw from this Agreement while it is receiving assistance pursuant to this Agreement.
6-23 Appendix B Revision 32
Page 187 of 221
- 13. This Agreement may be amended by the agreement of a majority of the Parties hereto. Such amendment shall be effective and binding upon all Parties thirty (30) days after INPO has received counterpart signature pages for the amendment executed by at least a majority of the Parties to the Agreement. INPO shall notify all Parties when at least a majority of the Parties have executed an amendment to the Agreement. No amendment shall affect any obligation which may have been incurred hereunder prior to the effective date of such amendment or which may arise out of events occurring prior to that date. Notwithstanding the first sentence of paragraph 12, any Party may withdraw from this Agreement by submitting written notice to INPO at any time during the thirty (30) day period prior to the effective date of such amendment with a copy to all of the other Parties.
- 14. If any provision of this Agreement is determined to be invalid or unenforceable as to any Party or otherwise, such determination shall not affect the validity or enforceability of the other provisions of this Agreement as to that Party or otherwise.
- 15. In the event (i) an emergency occurs at a nuclear power plant under the control of or operated on behalf of a Party; (ii) a request for assistance is issued to another Party hereto In respect to such emergency; and (iii) such assistance Is provided, this Agreement shall be construed in accordance with the law of the State In which the nuclear power plant is located with respect to all, rights and obligations arising out of such emergency.
6-24 Appendix B Revision 32
Page 188 of 221 FEMA Letter describing Backup ANS U.S. Departnent ofHomeland Security Region V 536 South Clark Stee, Floor 6 Chicago, IL 60605 FEMA December 10, 2012 Thomas Higinbotham, Manager Radiological Emergency Preparedness Unit Emergency Management and Homeland Security 4000 Collins Road Lansing, Michigan 48910
Dear Mr. Higinbotharn:
This letter is to confirm the status of provisions for Backup Alert and Notification (ANS) for the D.C.
Cook Nuclear Power Plant Emergoncy Planning Zone (EPZ).
Backup ANS for this EPZ is achieved through Route Alerting, which is contained within the Radiological Emergency Response Plans and procedures for the State of Michigan and the County of Berrien. These plans and procedures have been approved by the Federal Emergency Management Agency (FEMA) in accordance with Tide 44 of the Code of Federal Regulations (CFR) §§350.12 and 14.
These plans, procedures and associated equipment and facilities are the responsibility of State and local Offsite Response Organizations, are not under the control of the U.S. Nuclear Regulatory Commission licensee and are subject to regular FEM4A review and evaluation. As of this date no deficiencies with the backup ANS for D.C. Cook exist. Deficiencies found at any time are subject to the provisions of 44 CFR
§350.13.
Licensees are required per Appendix E.IV.D.3 ofPart 50 of Tide 10 of the Code of Federal Regulations to demonstrate that the appropriate governmental authorities have the administrative and physical means for a backup method of public alerting and notification. Further, in 10 CFR Part 50, Appendix E, Section IV.D.4 requires that if FEMA has approved a design report, to include the backup ANS capability, as of December 23, 2011, then the backup ANS requirements in Section IV.D.3 must be implemented by December 24, 2012. This letter identifies that such an approval existed on December 23, 2011, and that the approved backup ANS incorporated in State and local plans, procedures, and associated equipment and facilities be incorporated into the D.C. Cook ANS design report. A copy of this letter should be appended to the design report.
If you should have any questions, please call me at 3 12-408-5575 or contact Dwaine Warren at 312-408-5342.
Sincerely, - -
William E. King, Chairman Regional Assistance Committee www.fema.gov Appendix B Revision 32
Page 189 of 221 APPENDIX C EMERGENCY KITS AND EQUIPMENT LOCATION Appendix C Revision 32
Page 190 of 221 Emergency Kits and Equipment Location KIT LOCATION Radiation Protection Emergency Kit Operations Support Center (OSC)
Emergency Operations Facility (EOF)
Survey Vehicles (1 in each of the 2 dedicated Survey Vehicles)
First Aid - Decon Equipment Radiation Protection Access Control (RPAC)
Anti-C Equipment for Ambulance Security Control Center In-Plant/On-Site Driver to Hospital Vehicle Search Portal Emergency Anti-C Equipment Technical Support Center (TSC)
Operations Support Center Area Training Center Emergency Operations Facility (EOF)
Both Control Rooms Control Room Emergency Cabinet Survey Vehicle Hospital Emergency Cabinet Lakeland Regional Medical Center, St. Joseph Niles Community Hospital, Niles Shift Supervisor Office Radiation Protection 633' Turbine Deck at TSC stairs Emergency Locker Appendix C Revision 32
Page 191 of 221 SCBAs 17 Auxiliary Building 10 RPAC 10 Basement Assembly Area (OSC) 10 633' Turbine Deck by TSC 2 Each Control Room 10 609' Turbine Bldg. - for Turbine Building use only Stretcher Lockers 10 Locations in Plant Appendix C Revision 32.
Page 192 of 221 APPENDIX D EMERGENCY PREPAREDNESS BROCHURE Appendix D Revision 32
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Read this now and then display it for easy access.
0 CALL IF YOU HAVE QUESTIONS OR REQUESTS Please call or write either of the offices below if you:
" Have questions or comments about the calendar.
" Need more information about emergency planning.
" Need more copies of the calendar.
" Would like to schedule a guest speaker to discuss the Berrien County Emergency Plan with your organization, company or service club.
Cook Energy Information Center Division of Berrien County Sheriff's Office
Dear Berrien County Resident:
800-548-2555 Berrien County Emergency Management One Cook Place 269-983-7141 Ext. 4916 If there is a serious emergency in Berrien County, this calendar tells you exactly what to do. That's why it is so important for you to read it now Bridgman, MI 49106 2100 E. Empire Ave.
so you are prepared. It is written especially for people who live, work or go Benton Harbor, MI 49022 to school within 10 miles of the Cook Nuclear Plant in Bridgman. It is also for use by boaters, campers and all visitors to the area. 0 TABLE OF CONTENTS Read this emergency information now. Then display it where you can Upfront with Larry Weber ..................................... 2 find it.
This calendar explains exactly what you should do if there is a nuclear What you should do if you hear sirens .................. 16 accident, chemical spill or an emergency weather condition such as a What you should do if you are told to seek shelter ..... 16 tornado or another dangerous condition.
Area radio and television stations ......................... 16 The best way to be safe in an emergency is to know what to do and how to help others. Please share this information with your family. Make sure they Functional Needs information and card ................... 16 know what to do if an emergency occurs. Talk over the information with What you should do if you are told to evacuate ......... 17 people at your work. Discuss it with your neighbors and friends. Find out Things you will want to bring with you .................. 17 if anyone will need special help in an emergency. Inform your neighbors if you will need special help. If you know people who are blind or have Cook Nuclear Plant Emergency Planning Zone .......... 17 difficulty reading, please read this information to them. Make sure they Nuclear emergency terms ................................... 18 understand it. We want everyone in our communities to be prepared to handle emergencies calmly and safely. Facts about radiation ........................................... 18 Sincerely, Notice to farmers, food processors and distributors ... 19 Indiana Michigan Power KI tablet voucher ............................................. 21 Berrien County Emergency Caring for our community ...................................... 22 Management Office Tribute to Don Ames .......................................... 22 Michigan State Police Emergency Management and Start preparing now/Important phone numbers ......... 22 Homeland Security Division Cook calendar photo contest ...................... back cover
UPFRONT WITH LARRY WE One of the hallmarks of Cook Nuclear Plant is its transparency.
In its nearly 40 years of operation, it has never taken an out-of-sight, out-of-mind approachto informing you or your neighbors about its operation. This calendar is an opportunity for Senior Vice Presidentand Chief Nuclear Officer Larry Weber to provide an update on Cook and the nuclear industry.You'll find his interview To continue operatingsafely and reliably over its extended on this and the next page. license life, Cook Plant is replacingmajor components, such as these turbines.
In 2012 Inin Mihia Powe anone tha Coo Plant is begII Imining aL5U six-year Lif Cyclej Maaemn Ii ~I [
I Project.I Wha is it an ho wil it beei hoewern IF YOU EVER HAVE QUESTIONS in Bere Couty OR CONCERNS ABOUT bsinse COOK PLANT, or wish to host a speaker to talk Larry: All nuclear plants were licensed $1.2 billion project. While this is a about nuclear power or energy initially to operate for 40 years. Many large investment in the plant, the Life topics at a club, organization or plants, including Cook Nuclear Plant's Cycle Management costs are 0 employee meeting, please contact: two units, have been relicensed for an significantly less than building a new Cook Energy Center additional 20 years. Cook's Unit 1 is plant with Cook's generation capacity.
P.O. Box 850 licensed until 2034 and Unit 2 to 2037. Our plan is to replace major Bridgman, MI 49106 Many of the structures and components components and systems during z 800-548-2555 at the plant, however, were engineered normal refueling outages over the next cookinfo@aep.com and manufactured on the basis of the six years. We will contract with many Z Facebook.com/CookN uclear 40-year service life. To ensure that the local workers, trades people and 0 plant continues to operate safely and vendors, as well as use local z
reliably for the extended licensed life, warehousing. Workers who come in Cook must monitor and manage the from out of town will stay in local aging of these components. hotels, eat at local restaurants and boost The Life Cycle Management program the regional economy. It's an investment 2 will help us accomplish this. This is a in the plant and in the community.
0
Yo metoe tha the dry cas strg failt i ig l cas. hyw asathreaee seue 00a ha Coo Larry: We recently had 14 Larry: The federal government has an Larry: The Berrien County Sheriff's employees complete an 18-month obligation to the nation to take used Department is the only sheriff initial license training class at Cook.
Larry: Vote for members of Congress nuclear fuel and store it safely offsite. department in the nation that is badged This is the fourth consecutive class The federal government has not met that see the need for a strong energy to enter a nuclear power plant. They with 100 percent pass rate on an policy that includes nuclear fuel that obligation. After two expansions, train with our security force inside our extremely challenging Nuclear storage or reprocessing. If we our spent fuel pool is nearly full, so we facility on a regular basis. We also have Regulatory Commission written introduced nuclear used nuclear fuel had to create new storage or we would drilled with the FBI and State of exam. This not only speaks well of reprocessing, as they do in Europe, have to stop operation in 2015. We Michigan's tactical response units. Our our reactor operators, but of our have built a two-acre concrete pad we could reduce our waste by 99 already strong security saw Operations Training Department for near the center of our 650-acre percent. We need forward-thinking considerable upgrades after 9/11, developing and presenting training property where we are currently storing people in office. including increases in staffing, training, that results in exceptional success.
12 licensed casks each loaded with 32 weapons, detection equipment and used nuclear fuel assemblies from our barriers. We completed another spent fuel pool. The dry cask storage is multi-million dollar upgrade in late in a highly secure area and is strictly 2012 in response to the latest threat regulated by the federal government. intelligence. I believe this maintains our position as one of the leading nuclear scurity forces in the industry.
Fuel is moved underwaterinto a cask (above). In order to continue operation, Cook will load an additional11 casks every three years.
Cook enlisted special equipment to move the dry casks loaded with used nuclear fuel to a highly secure storage site in a remote area on Cook's campus (right).
COOK PLANT'S SAFETY CULTURE GAINS INTERNATIONAL ATTENTION AT ASIAN SYMPOSIUM IN JAPAN.
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In Oct. 201Z the Japanesegovernment asked Cook's Senior V.P and Chief Nuclear Officer Larry Weber to meet in Japan.
He talked with them about how Cook successfully compels personnel to be I i 0i ýt accountablefor plantsafety.
'I sliuM In July 2012 Japa relase its ineedn invstgaio How cn .S.
repor rearin th Fuum aciet How wil Cook plantsincmlu-ding'ook, Plan an other U.S. nula plnt use thesoslere 0el th 0aans nuclear fro Fuum to imrv thi stutrs procedur0 indstr 0s it mvs an0aey Larry: The biggest lesson learned seismic and flooding mitigation. We Larry: I went with a team, including our Larry: In our industry it is critical to z from Fukushima is the importance of have process and procedure upgrades plant manager and radiation protection thoroughly understand the root causes.
setting high standards and having a for expanded emergency conditions manager, to Japan in October 2012. We are dealing with nuclear safety, so strong nuclear safety culture. Cook similar to Fukushima. Other The Japanese nuclear safety regulators we need to know how the "fix" will Z
-H meets our original safety design basis enhancements to our Emergency invited us for eight days to talk with impact other equipment and systems Z but we continue to do more. We're Preparedness plans will help us plant owners and regulators about our at the plant. Just as when the airline adding portable generators and fire- protect the public in the unlikely nuclear safety culture. The Japanese industry has issues, it conducts an 3
z truck-sized diesel pumps in addition event of an emergency. recognize that they are advanced engineering analysis to make sure the to performing extensive analyses on technically, but are not as strong at the solution doesn't result in a different m
human performance level. We talked hazard, we have to do the same z
about how our nuclear safety culture analysis. This does take time. We have would have helped reduce the impact to make sure an improvement does not 3 of the events at Fukushima. adversely affect other equipment.
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Enclosure to AEP-NRC-2013-33 DONALD C. COOK NUCLEAR PLANT Emergency Plan, Revision 32 IMPLEMENTING PROCEDURES RMT-2080-EOF-001, Activation and Operation of the EOF, Revision 22 RMT-2080-EOF-002, Emergency Termination and Recovery, Revision 5 RMT-2080-JIC-001, Activation and Operation of the ENC/JIC, Revision 6 RMT-2080-OSC-001, Activation and Operation of the OSC, Revision 15 RMT-2080-TSC-001, Activation and Operation of the TSC, Revision 19
Page 1 of 221 DONALD C. COOK NUCLEAR PLANT EMERGENCY PLAN REVISION 32 UNITS 1 & 2 DOCKET NOS. 50-315 & 50-316 LICENSE NOS. DPR-58 & DPR-74 Effective Date X1>-e'//to3 PORC Meeting _-___
Reviewed -I A4a'S //-}&, Date 4/. 4/. Z0/S Emergency Preparddrss Manager Approved _S"I Date Ji-*-LL Title Title AA73/4- &9Ah'/46iZ-
Page 2 of 221 Cook Emergency Plan Revision 32 Changes:
Changed emergency planning to emergency preparedness throughout. (Administrative change)
Planning Standard A. Organizational Control Figure 1:
Replaced Law Enforcement with Berrien County Sheriffs Department.
Changed Department of Commerce to Licensing and Regulatory Affairs.
Changed Family Independence Agency to Human Services Titles have changed (Administrative change)
Planning Standard B, Emergency Response Organization B. IA moved "Site Protective Services, and organizational/administrative activities at the plant" from Vice President-Site Support Seivices to the Site Vice President. This is due to organizational changes.
(Administrative change)
B. 1 .d, B. L.e and B. 1.f Changed title from Manager-Security and Emergency Planning to Director Nuclear Site Services. (Administrative change)
B.5a. I sub step 4 added "responsibilities that may not be delegated". This change was made to agree with procedure PMP-2080-EPP-100, Emergency Response.
B.5C. 1sub step 2 added "responsibilities that may not be delegated". This change was made to agree with procedure PMP-2080-EPP-I100, Emergency Response.
(Administrative change)
B.5.e.l third sentence changed "other liaison" to "A second liaison". A third liaison is discussed in new item. (To comply with 2012 EP rule making)
Added item B.5e3, Incident Command Post Liaison and the duties of that person. (To comply with 2012 EP rule making)
B.9.a corrected the location of the Berrien County EOC, (Administrative change)
B.9.a second paragraph added hostile threat and Incident Command Post. (To comply with 2012 EP rule making)
B.9.b first paragraph added hostile threat. (To comply with 2012 EP rule making)
B.9.a.4, B.9.b.1 .a and B.9.b. 1.b, B.9.c changed Department of Natural Resources to Department of Environmental Quality (DNRE to DEQ). The department has reversed back to old name. (Administrative change)
B.9.b.2.b changed Department of Commerce to Licensing and Regulatory Affairs. The department name has changed. (Administrative change)
B.9.b.2.h changed Family Independence Agency to Human Services. Department has changed names.
(Administrative change)
Figure 2 updated Performance Assurance Manager to Director, Manger Business Services to Director and Learning Organization to Performance Improvement Department. These changes are due to organizational title changes. (Administrative change)
Figure 3 corrected title of Manager Emergency Preparedness and Site Protective Services to Director Nuclear Site Services and added additional reporting chain. Changed title of Assistant Director Rad/Chem/Env to Radiation Protection Manager Rad/Chem/Env to Radiation. Changes are due to organizational changes. (Administrative change)
0-- ve. 3 Page 3 of 221 Figure 4 added the ICP Liaison position into the reporting chain. (To comply with 2012 EP rule making).
Also added Work Control SRO, 2 AEO Phone Talkers and Fire Brigade to reflect what is depicted on Table B-1. (AR 2013-2144)
Revised Figures 5 and 6 to add the Off-Site Liaison positions (ICP,BCSD, MSP) into the reporting chain.
(To comply with 2012 EP rule making)
Planning Standard C. Emergency Response Support and Resources C.2.b added Incident Command Post to list of where liaisons are provided. (To comply with 2012 EP rule making)
Planning Standard D, Emergency Classification System Added item D.2. 1, that emergency declaration must be made within 15 minutes of determining that an emergency action level has been exceeded. (To comply with 2012 EP rule making) GT 2012-12625-5 Planning Standard E, Notification of Emergency Response Personnel and Organizations.
E. I third paragraph removed "approximately" as the notification must be made within 15 minutes. (To comply with 2012 EP rule making)
E. 1 fifth paragraph replaced Office of Emergency Preparedness with Office of Emergency Management/Homeland Security. The department name has changed. (Administrative change)
E. I last paragraph removed "Emergency Plan" as this is not part of the phone directory title.
(Administrative change)
E.2.b added a paragraph describing that personnel report to an alternate location in the event of a hostile action threat. (To comply with 2012 EP rule making)
E.6 added a paragraph describing the ANS system and the backup method for alerting population within the EPZ. (To comply with 2012 EP rule making)
Figure 9 added ICP to the communications flow. (To comply with 2012 EP rule making)
Planning Standard H, Emergency Facilities and Equipment Added a fourth item to designate an alternate location that may be used in the event that the response facility is not available due to the event. (To comply with 2012 EP rule making)
H. L.b. and H.3.b added the alternate location in the event that the facility is not available due to the event.
(To comply with 2012 EP rule making)
H.5.b last paragraph changed FSAR to UFSAR, H.5.b.2 last paragraph re-written to state that the RMS listing can either be found in the computer system or in the reference section of the booklists that contain the Implementing Procedures. The location of RMS listings can be obtained readily from the computer located in the facilities. (Administrative change)
H.6.b removed "Radiation Protection Procedures" as the requirements have been moved to Emergency Plan' Procedures. (Administrative change)
Item H.8 changed Job Order to Work Order as the name of the document to designate work has changed.
(Administrative change)
CEP 6e.3 Page 4 of 221 Table 5 removed the note "Effective in Unit 1 post Cycle 22 Refueling Outage. Effective in Unit 2 post Cycle 17 Refueling Outage" as the refueling outages have since been completed. (Administrative change)
Planning Standard I, Accident Assessment 1.2 second paragraph re-written to state that the RMS listing can either be found in the computer system or in the reference section of the booklists that contain the Implementing Procedures. (Administrative change) 1.4 Updated the description of the Dose Assessment Program features.
Planning Standard J. Protective Response Added to J.8 when the Evacuation Time Estimates are performed. This implements 10 CFR50. Appendix E IV 3-6.
Planning Standard K, Radiological Exposure Controls K.3.a, K.5.a and K.6.c changed Department of Natural Resources to Department of Environmental Qualj, (DNRE to DEQ)- The department name has changed. (Administrative change)
Planning Standard N, Exercises and Drills Added items N.2.f.2 and N.2.f.3 describing fast breaking and minimal radiological releases drills. (To comply with 2012 EP rule making)
Planning Standard 0, Radiological Emergency Response Training 0.2 corrected TPD title from "Emergency Plan" to "Emergency Preparedness".
0.2, O.4.j replaced "qualification cards" with "Job Familiarization Guides". The qualification method is now titled Job Familiarization Guide. (Administrative change) 0.3, O.4.f replaced "Emergency Medical Technicians" with Medical Emergency Response Team members (MERT). (Administrative change) 0.5 replaced "qualification" with "job familiarization". To be consistent with the new title for qualification.
(Administrative change)
Appendix A, Index of Plant Procedures and Cross Reference Added procedure SPP-2060-SFI-216 to E.2 as this procedure also describes actions to take to notify on-site personnel. (Administrative change)
Added procedure EPP-2080-ERO-00 Ito H.6.b as this is the procedure that performs the equipment inventory. (Administrative change)
Appendix B, Agreements With Off-Site Support Agencies Replaced the Mutual Assistance Agreement with a new one dated 01/09/2013. (Administrative change)
Added a letter from FEMA describing the backup ANS system. (To comply with 2012 EP rule making)
Appendix J, Eight Year Plan Matrix Removed the monthly columns from the annual, semi-annual, quarterly and monthly matrix. The exact scheduling of items is dependant on outside agencies and to avoid non-compliance with the arbitrary dates on the matrix the months have been removed.
(Administrative change)
CEP Rey-- .3 Page 5 of 221 Copy of 50.54(q)
Reference RMA-2080-EPA-008 I Rev. #15 [ Page 36 of 44 IEmergency Plan Management Data Sheet I Screen Evaluation Form g35-s36 Change Evaluation 1- 13-08 Year - Sequence #
Activity Description and
References:
Cook Emergency Plan (CEP), Rev 32 Activity Scope: Revision 32 to the CEP reflects changes to address the 2012 Emergency Preparedness (EP) Rule Making, the incorporation of the Incident Command Post Liaison, an updated description of the dose assessment model capabilities, and general administrative maintenance items to reflect current names and titles.
The scope of changes included the following to address 2012 EP Rule Making:
- B.5.e.I third sentence changed "other liaison" to "A second liaison". A third liaison is discussed in new item.
a Added item B.5c3, Incident Command Post Liaison and the duties of that person
- B.9.a second paragraph added hostile threat and Incident Command Post
- B.9.b first paragraph added hostile threat
- Figure 4 added the ICP Liaison position into the reporting chain
- Revised Figures 5 and 6 to add the Off-Site Liaison positions (ICP,BCSD, MSP) into the reporting chain
- C.2.b added Incident Command Post to list of where liaisons are provided
- Added item D.2. 1, that emergency declaration must be made within 15 minutes of determining that an emergency action level has been exceeded
" E.1 third paragraph removed "approximately" as the notification must be made within 15 minutes.
" E.2.b added a paragraph describing that personnel report to an alternate location in the event of a hostile action threat
" E.6 added a paragraph describing the Alert and Notification System (ANS) and the backup method for alerting population within the EPZ
- Figure 9 added ICP to the communications flow.
" H. Added a fourth item to designate an alternate location that may be used in the event that the response facility is not available due to the event
" H. I.b. and H.3.b added the alternate location in the event that the facility is not available due to the event.
" Added items N.2.f.2.and N.2F3 describing fast brcaldng and minimal radiological releases drills
" Added a letter from FEMA describing the backup ANS
Page 6 of 221 C EP Rev 3 :-L Reference RMA-80-EPA-0 I Rev. #15 [ Page 37 of 441 Emergency Plan Management Data Sheet 1 I Screen Evaluation Form I Pages:
35 - 36 General CEP maintenance items:
- Updated organizational and agency titles, both on-site and off-site, to reflect current titles and positions.
" Updated the Dose Assessment Model capabilities Specifics are included on the attached Scope of Revision.
[0 The activity is a change to the emergency plan Change #: Revision 0 The activity is not a change to the emergency plan Change Type: Change Type:
D The change is editorial or typographical IMThe change does conform to an activity that -
has prior approval
[l The change is not editorial or typographical 0 The change does not conform to an activity that has prior approval Planning Standard Impact Determination:
Planning Standard Potential Impact 10 CFR 50.47(b)(1) - Assignment of Responsibility (Organization [H] EUYes Control) _ Im No 10 CFR 50.47(b)(2) - Onsite Emergency Organization [l E Yes
_M No 10 CFR 50.47(b)(3) - Emergency Response Support and Resources [] U Yes 1 NO 10 CFR 50.47(b)(4) - Emergency Classification System U 103Yes
_[ No 10 CPR 50.47(b)(5) - Notification Methods and Procedures 1] 0 Yes
[El No 10 CFR 50.47(b)(6) - Emergency Communications Th 0 Yes
[0 No 10 CFR 50.47(b)(7) - Public Education and Information U 0 Yes
[El No 10 CFR 50.47(b)(8) - Emergency Facility and Equipment O Ul Yes 0[ No 10 CFR 50.47(b)(9) - Accident Assessment [E El Yes
[]_ No
Page 7 of 221 CUFP P ew.3. a Reference RMA-2080-EPA-008 I Rev. #15 Page 38 of 44 Emergency Plan Management Pages:
Data Sheet I [ Screen Evaluation Form I 35 - 36 10 CFR 50.47(b)(10) - Protective Response U 0 Yes I] No 10 CFR 50.47(b)(1I) - Radiological Exposure Control U 0) Yes I] No 10 CFR 50.47(b)(12) - Medical and Public Health Support E! 0 Yes 09 No 10 CFR 50.47(b)(13) - Recovery Planning and Post-accident El Q Yes Operations I] No 10 CFR 50.47(b)(14) - Drills and Exercises U (2 Yes
[0 No 10 CFR 50.47(b)(15) - Emergency Responder Training El (21Yes 0 No 10 CFR 50.47(b)(16) - Emergency Plan Maintenance 0 0 Yes E93 No Commitment Impact Determination:
[I The activity does involve a site specific EP commitment Record the commitment or commitment reference; None of the current EP related commitments are impacted by the proposed changes.
[] The activity does not involve a site specific EP commitment
C-F-P Rev. z& Page 8 of 221 Reference RMA-2080-EPA-008 Rev. #15 Page 39 of 44 Emergency Plan Management Pages:
Data Sheet I ] Screen Evaluation Form I 35 - 36 Screening Evaluation Results:
IE The activity can be implemented without performing a 10 CFR 50.54(q) effectiveness evaluation fl The activity cannot be implemented without performing a 10 CFR 50.54(q) effectiveness evaluation Justification for determination that the activity can be implemented without performing a 10 CFR 50.54(q) effectiveness evaluation.
Justification:
The proposed changes either support the 2012 EP Rule Making or are enhancements that add:d~tail or bring titles and organization names up to date. None of the proposed changes to CEP Revision 32 adversely impact the timeliness or function of any planning standard. Therefore, a 10 CFR 50.54(q) effectiveness evaluation is not required.
Preparer Name: Jar Date:
Dave Walton .- 1 /<J//z Reviewer Name:
Dale Prie
Page 9 of 221 TABLE OF CONTENTS INTRODUCTION PAGE A. P u rpo se ............................................................................................................................ 16 B. O bjec tive .......................................................................................................................... 16 C. Sco p e .............................................................................................................................. 16 D. Organization of the Emergency Plan ......................................................................... 16 E. D e fin itio n s ......................................................................................................................... 17 PLANNING STANDARDS A. ORGANIZATIONAL CONTROL 20 A.1 Organizational Control .................................................................................. 21 A.2 Not Applicable ................................................................................ 22 A.3 Agreements .................................................................................... 22 A.4 Continuous Protracted Operations .......................................................... 22 B. EMERGENCY RESPONSE ORGANIZATION 24 B.1 Normal On-Site Operating Organization........................................................ 25 B.2 On-Shift Emergency Coordination ................................................................. 28 B.3 Emergency Coordination Line of Succession ............................................... 28 B.4 Non-delegable Emergency Coordinator Duties ............................................ 28 B.5 Emergency Response Organization ........................................................... 28 B.5.a Technical Support Center ................................................................. 29 B.5.b Operations Support Center ............................................................... 31 B.5.c Emergency Operations Facility ....................................................... 33 B.5.d Emergency News Center/Joint Information Center .......................... 35 B.5.e Liaisons ............................................................................................. 36 B.6 Overall Organization and Communication ..................................................... 37 B.7 Plant Staff Augmentation ........................................................................... . 37 B.8 Offsite Agencies and Organizations .............................................................. 38 B.9 Offsite Groups ............................................................................................... 38 C. EMERGENCY RESPONSE SUPPORT AND RESOURCES 52 C.1 Federal Radiological Assistance .................................................................... 53 C.2 Liaisons ......................................................................................................... 54 C.3 Radiological Laboratories ............................................................................ 54 C.4 Offsite Agencies and Organizations (non Governmental) ............................. 55 D. EMERGENCY CLASSIFICATION SYSTEM 56 D.1 Emergency Action Levels ...................... .............. 57 D.2 Initiating Conditions ........................................ 59 E. NOTIFICATION METHODS AND PROCEDURES 71 E.1 Notification of Offsite Response Organizations .............................................. 72 Table of Contents Revision 32
Page 10 of-221 E.2 ERO Alert, Notification and Mobilization ........................................................ 73 E.2.a Onsite (Plant Staff) ............................................................................. 73 E.2.b Offsite (Plant Staff) ................................................ 74 E.3 Content of Initial Emergency. Messages ....................................................... 74 E.4 Content of Follow-up Emergency Messages ................................................. 75 E.5 Not Applicable (State and Local Public Information System) ......................... 75 E.6 Public Notification ........................................................................................... 75 E.7 Public Information Messages ......................................................................... 76 F. EMERGENCY COMMUNICATIONS 80 F.1 Licensee, Local, State, and NRC Emergency Communications .................... 81 F.2 Medical Support Communications ........................................ 7........................ 84 F.3 Communications Systems Testing ................................................................. 84 G. PUBLIC EDUCATION AND INFORMATION 85 G.1 Public Information .......................................................................................... 87 G.2 Distribution of Public Information .................................................................. 87 G.3 Emergency News Center/Joint Information Center ...................................... 87 G.4 ENC/JIC Spokespersons and Public Inquiry ................................................ 88 G.5 Annual Media Briefing .................................................................................... 88 H. EMERGENCY FACILITIES AND EQUIPMENT 89 H.1 Technical Support Center (TSC) ................................................................... 90 H.2 Emergency Operations Facility (EOF) ............................................................ 93 H.3 Operations Support Center (OSC) ................................................................. 95 H.4 AEP Emergency Organization Staffing and Activation ....................................... 96 H.5 Emergency Detection ................. ;..................... 97 H.6 Offsite Monitoring and Analysis Equipment .............................................. 101 H.7 Radiological Environmental Monitoring ................................................... 102 H.8 Meteorological System ........................................................................ 102 ACCIDENT ASSESSMENT 107 1.1 Release Identification and Event Classification 108 1.2 Radiation Monitoring System 108 1.3 Release Source Term and Magnitude Determination 108 1.4 Dose Assessment Evaluation 109 1.5 Meteorological Assessment 110 1.6 Not Addressed 110 1.7 Radiological Field Monitoring 110 1.8 Liquid and Gaseous Release Assessment 110 1.9 Off-site Radioiodine Monitoring 110 1.10 Not Addressed 110 J. PROTECTIVE RESPONSE 111 J.1 Owner Controlled Area Warning and Advisement ............................................. 112.
J.2 Evacuation Routes ............................................................................................. 112 J.3 Evacuee Monitoring .......................................................................................... 113 J.4 Evacuee Decontamination ................................................................................. 113 J.5 Personnel Accountability. .................................................................................. 113 J.6 Protective Measures for Those Remaining, or Reporting to the Site ................ 114 J.7 Off-Site Protective Actions ................................................................................. 114 J.8 Evacuation Times .............................................................................................. 115 Table of Contents Revision 32
Page 11 of 221 J.9 Not Applicable .................................................................................................... 115 J.10 Plume Exposure Pathway Protective Measures Implementation ...................... 115 K. RADIOLOGICAL EXPOSURE CONTROL 118 K.1 Emergency Exposure ......................................................................................... 120 K.2 Emergency Exposure Authorization and Control ............................................... 120 K.3 Emergency Personnel Dosimetry ..................................................................... 120
..K.4 Not Applicable .................................................................................................... 120 K.5 Decontamination ................................................................................................ 121 K.6 Contamination Control .................................................................. . ..... 121 K.7 Decontamination of Relocated Onsite Personnel .............................................. 122 L. MEDICAL AND PUBLIC HEALTH SUPPORT 124 L.1 Offsite Medical Support ....................................................................................... 125 L.2 Onsite Medical Support ...................................................................................... 126 L.3 Not Applicable .................................................................................................... 126 L.4 Victim Transport ................................................................................................. 126 M. RECOVERY AND RE-ENTRY PLANNING AND POST ACCIDENT OPERATIONS 127 M.1 Reentry and Recovery ....................................................................................... 128 M.2 Not Addressed ..................................................................................................... 129 M.3 Recovery Initiation Notification .......................................................................... 129 M.4 Not Addressed .................................................................................................. 129 N. EXERCISES AND DRILLS 130 N.1 Exercise s ........................................................................................................... 13 1 N.2 D rills ................................................................................ t.................................. 13 1 N.3 Drill and Exercise Execution ....................................... 132 N.4 Official Observation and Critique ................... .................................................
- 133 N.5 . Results Evaluation and Corrective Actions ........................................................ 133
- 0. RADIOLOGICAL EMERGENCY RESPONSE TRAINING 134 0.1 Organization Training ....................................................................................... 135 0.2 . Onsite ERO Training .......................................................................................... 135 0.3 First Aid Team Training ..................................................................................... 135 0.4 ERO Training and Qualification .................... .............. 135 0.5 Initial and Annual Retraining .... ......................................................................... 137 P. RESPONSIBILITY FOR PLANNING EFFORT 138 P.1 -Emergency Planner Training ............................................................................ 139 P.2 Emergency Plans Administration Responsibility .................... 139 P.3 Emergency Planning Coordinator Designation (Not Addressed) ...................... 139 P.4 Periodic Reviews, Updates, and Audits ............................................................. 139 P.5 Emergency Plan Change Communication ......................................................... 139 P.6 Emergency Response Organization Support Plans .......................................... 140 P.7 Implementing Procedures ................................... 140 P.8 Table of Contents & Cross-reference ................................................................ 140 P.9 Independent Emergency Program Review ........................................................ 140 P.10 ERO Telephone Number Updates ............................. 140 Table of Contents Revision 32
Page 12 of 221 APPENDICES APPENDIX A. 1. Index of Plant Emergency Plan Procedures ...................... 142
- 2. Cross Reference Between CNP and the Plant Emergency Procedures 143 B. Agreements with Off-Site Support Agencies 151 C. Emergency Kits and Equipment Locations 189 D. Emergency Preparedness Brochure 192 E. Description of Federal Radiological Assistance 194 F. Berrien County Road Map 202 G. Population Distribution 204 H. Radiological Response Support Service Capabilities 206 I. Notification of American Nuclear Insurers 209 J. Eight Year Plan Matrix 213 K. Agreements with Off-Site Agencies, Hazardous Material Spills 218 Table of Contents Revision 32
Page 13 of 221 LIST OF FIGURES Figure TITLE Section Page
- 1. Michigan Nuclear Accident Response Organization A ........................ 23
- 2. Management Structure of the Nuclear Generation Group B ............ 45
- 3. Site Operations B ........................ 46
- 4. On Shift Emergency Response Organization B ....................... 47
- 5. *CNP Emergency Response Organization at an Alert Classification B ............................. 4 8
- 6. Organization of the Emergency Director's Staff at the EOF B ........................ 49
- 7. CNP Emergency News Center/Joint Information Center Organization B ........................ 50
- 8. Nuclear Incident Initial Notification Process E ............ 78
- 9. CNP Emergency Response Communications Flow E........................ 79
- 10. Locations of Emergency Response Centers H........................... 104
- 11. CNP Emergency Response Center Locations H ........................... 105
- 12. Primary Evacuation Routes J........................... 117
- 13. Accident Notification Procedures for ANI Insurers Appendix I ............ 212 Table of Contents Revision 32
Page 14 of 221 LIST OF TABLES Table TITLE Section Paae
- 1. CNP Staffing for Radiological Emergencies ........ ........ B 51
- 2. Fission Product Barrier Matrix - Mode 1-4 ....................................... D 6059
- 3. Initiating Conditions, Mode 1- 4 ........................................................ D 62
- 4. Initiating Conditions, Modes 5-6 and Defueled ................................. D 67
- 5. Critical NUREG 0737 Parameters .................................................... H 106
- 6. Maximum Allowable Contamination Limits for On Site Facilities U sed by the P ublic ............................................................................ K 123 Table of Contents Revision 32
Page 15 of 221 INTRODUCTION Introduction Revision 32
Page 16 of 221 INTRODUCTION A. Purpose The purpose of the Cook Nuclear Plant Emergency Plan is to fulfill the requirements as
.set forth in 10 CFR 50, Appendix E, and the planning objectives set forth in NUREG-0654/FEMA-REP-1, Revision 1.
B. Objective The Cook Nuclear Plant Emergency Plan has the fundamental objective of protecting the health and safety of the general public, persons temporarily visiting or assigned to the reactor facility, and employees of the plant.
C. Scope The specific details for the implementation of this emergency plan are incorporated in the Cook Nuclear Plant Emergency Plan Procedures pursuant to the requirements specified in "Purpose", above. The Cook Nuclear Plant Emergency Plan applies to both of the nuclear units and the on-site Independent Spent Fuel Storage Installation (ISFSI). The Emergency Plan procedures include or reference procedures developed for plant operating, radiological, security, and administrative functions as necessary to ensure that all requirements are adequately defined. Appendix A to this Plan contains a list of Plant Emergency Plan Procedures. This plan is primarily concerned with an accidental release of radioactive material, but it is also concerned with major non-nuclear accidents which could prove hazardous to the safe operation of the plant. This includes supplementing our procedures for responding to hazardous material spills to meet Michigan Hazardous Waste Operations and Emergency Response (HAZWOPER) and hazardous waste regulations.
D. Organization of the Emergency Plan The information describing the D.C. Cook Nuclear Power Plant Emergency Plan follows the numerology of NUREG-0654/FEMA-REP-1, Revision 1.
The organization of NUREG-0654/FEMA-REP-1, Revision I sequences evaluation criteria by subject. Some criteria apply to licensee only, and some apply to offsite organizations only. The result is that there would be gaps in the Emergency Plan numbering if the licensee only criteria were listed. When this occurs the NUREG numbering is maintained by listing the criteria number and labeling it as Not Applicable.
Some criteria in the Emergency Plan are not addressed. Again, to maintain the NUREG numbering the criteria is listed but is labeled as Not Addressed.
Introduction Revision 32
Page 17 of 221 E. Definitions 1 Berrien County Emergency Operations Center (BCEOC) This facility provides an area to coordinate efforts of local agencies and organizations involved in the emergency response. It is a center established and controlled by the Berrien County Sheriffs Department and is located in St. Joseph, Michigan.
- 2. Civil Disturbance One or more persons violently protesting plant operations or activities at the site.
- 3. Confinement Boundary The barrier(s) between areas containing radioactive substances and the environment.
- 4. Control Rooms Control and monitoring functions for Units I and 2 are provided for in separate Control Rooms. Each Control Room has a controlled access entrance located off the turbine building main operating floor at Elevation 633'.
Personnel assigned to the Control Room during the emergency will be as indicated in Figure 4 (until the Technical Support Center is activated).
Should conditions require the presence, in the Control Room, of personnel other than those listed in Figure 4, approval must be obtained from the Shift Manager or his alternate.
- 5. Cook Nuclear Plant Procedures Documents defining the details necessary to specify manipulation of controls and equipment to place the facility in a safe condition and to prescribe other appropriate protective measures to be taken by employees of the licensee.
- 6. Emergency Action Levels Radiation dose rates; specific levels of airborne, waterborne, or surface-deposited concentrations of 'radioactive materials; or specific instrument indications (including their rates of change) that may be used as thresholds for designating the appropriate class of emergency.
- 7. Emergency News Center (ENC) The Emergency News Center is located in the Nuclear Generation Group Headquarters Building located approximately 14 miles southeast of the Plant in Buchanan, Michigan. This facility will provide for dissemination of emergency information to the news media prior to activation of the Joint Information Center.
- 8. Emergency Operations Facility (EOF) This facility is in the Nuclear Generation Group Headquarters Building located approximately 14 miles southeast of the Plant in Buchanan, Michigan. This facility is activated at the declaration of an Alert, or higher, emergency classification. The EOF houses the support personnel whose primary responsibilities are to assist in offsite dose assessment and protective action recommendations, communication with offsite agencies, exposure control, technical support of plant operations and other related activities. Representatives from various support agencies and groups may use this facility as a working space to prepare short and long term plans and procedures to mitigate the incident.
- 9. Emergency Plan Procedures (EPP's) The specific procedures that provide instructions, identify responsibilities, and implement the emergency plan. A list of Emergency Plan Procedures is contained in Appendix A.
Introduction Revision 32
Page 18 of 221
- 10. HAZMAT Team The hazardous material spill response team (HAZMAT Team) is a group of plant personnel designated to respond to emergencies involving hazardous materials. They are trained as required by Michigan Hazardous Waste Operations and Emergency Response (HAZWOPER) rules and respond to emergencies using spill pre-plan procedures. The Shift Manager, or a qualified Incident Commander, will act as the Incident Commander in charge of the plant spill response. A designated HAZMAT Team Safety Officer will have responsibility for the on-scene safety of response personnel.
- 11. Hostile Action An act toward a Nuclear Power Plant (NPP) or its personnel that includes the use of violent force to destroy equipment, takes hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience, or felonious acts that are not part of a concerted attack on the NPP or ISFSI. Non-terrorism-based EALs should be used to address such activities, (e.g., violent acts between individuals in the owner controlled area.)
- 12. Hostile Force One or more individuals who are engaged in determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.
- 13. Independent Spent Fuel Storage Installation (ISFSI) A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.
- 14. Joint Information Center (JIC) This facility is operated by AEP personnel for the purpose of disseminating information to the news media, conducting press briefing and as an area where the representatives from various emergency response organizations can meet, review, and release material to the press. The JIC uses the same facilities as the Emergency News Center (ENC).
- 15. NRC Licensed Personnel Those plant personnel holding current operator's or senior operator's licenses from the United States, Nuclear Regulatory Commission as defined in 10 CFR Part 55.
- 16. Off-Site means outside the area which is under the control of Cook Nuclear Plant.
- 17. Off-Site Survey Teams These are teams of personnel assigned to monitor radiological parameters anywhere outside of the plant protected area or the ISFSI protected area. At least one member of the team shall be trained in radiation protection.
- 18. On-Site defined as the owner controlled area inclusive of the protected area and all property outside the plant protected and ISFSI protected areas but under the control of Cook Nuclear Plant.
- 19. Operations Support Center (OSC) This area is located in the basement/shelter area of the plant's lakeside office building. The OSC is the area that will house the operations support personnel for assignment to respond to Control Room and Technical Support Center requests. Communication links are established as needed with the Control Rooms and Technical Support Center.
Introduction Revision 32
Page 19 of 221
- 20. Protected Area The area encompassed by physical barriers to control .access to the plant and to the ISFSI.
- 21. Protective Action Guides (PAG) The projected dose to an individual from an unplanned release of radioactive material at which a specific protective action to reduce or avoid that dose is recommended. Protective actions would be warranted provided the reduction in individual dose expected to be achieved by carrying out the protective action is not offset by excessive risks to individual safety in taking the protective action. The PAG does not include the dose that has unavoidably occurred prior to the initiation of a protective action.
- 22. State Emerqency Operations Center (SEOC) This facility provides a central location from which the emergency functions of state government may be carried out in response to emergency conditions. The primary State EOC is located at 4000 Collins Road, Lansing, Michigan.
- 23. State Field Team Center (FTC) This facility provides the operational working area for State representatives assigned to coordinate the dispatch of field teams to monitor for radioactive contamination. The facility will be directed by a Field Team Center Coordinator assigned by the Michigan Department of State Police/Emergency Management and Homeland Security Division. A representative of the Department of Environmental Quality/Drinking Water and Radiological Protection Division will be assigned to this facility as the Radiological Monitoring Team Leader. The location for the FTC is the Michigan Department of Transportation's Coloma garage at the intersection of Red Arrow Highway and 1-196.
- 24. Technical Support Center (TSC) This facility is located adjacent to the Control Rooms at Elevation 644'. This center is physically separated from both Control Rooms. ThiN facility has communication links to each Control Room, to the Emergency Operations Facility, Emergency News Center/Joint Information Center, Operations Support Center and offsite emergency operations centers established by State/County authorities. This area contains access to instrumentation and necessary reference material for plant management and support personnel.
The primary function of the TSC is to provide an area in close proximity to the Control Room from which plant operators can receive technical support and assistance from personnel who have the experience and expertise in nuclear plant operations, maintenance, safety and design. Their function is to mitigate the cause(s) of a nuclear incident and act as a data gathering center for plant parameters.
Access to the TSC will typically be limited immediately to those individuals listed in Figure 5, and as the situation demands, those individuals required by the SEC or alternate.
Introduction Revision 32
Page 20 of 221 PLANNING STANDARD A ORGANIZATION CONTROL Planning Standard A Revision 32
Page 21 of 221 ORGANIZATIONAL CONTROL A. 1. Or-ganizational Control In order for any emergency plan to be effective it is necessary to ensure that every organization that provides support services has prepared in advance an emergency plan and/or procedures.
These plans and/or procedures should define the individual responsibilities for coordinating and directing the support effort and the level of response each organization is prepared to make to meet its defined response capability on a continuous basis.
Assistance from private organizations having nuclear industry affiliations can also be expected and are identified in Section C.4.
A.l.a. Response Organizations Descriptions of the primary response organizations and their operational roles are outlined in Section B. The "state" column of Figure 1 shows the Primary Response Agencies and Support Response Agencies that comprise the State of Michigan's nuclear accident response organization. The Primary Response Agencies and their duties are performed at the State Emergency Operations Center (SEOC). The Support Response Agencies are the resources available to the SEOC for implementing actions in response to an emergency.
A.l.b. Concept of Operations In the event of an emergency situation, the Shift Manager (or Senior NRC licensed individual) will call upon any additional members of the plant organization as needed. These additional individuals form, along with the on-duty operating shift, the plant Emergency Response Organization. The initiation of any aspects of this emergency plan allows for the use of the total plant organization, at the discretion of the Shift Manager.
The major assignments of the on-duty operating shift and the supplemental personnel in the Emergency Plan Organization are delineated in Table 1.
The extent to which the Emergency Response Organization is staffed will be dependent upon the emergency classification and the discretion of the Site Emergency Coordinator (SEC). For an Unusual Event, only the Control Room will be staffed. For an Alert, Site Area Emergency, and General Emergency the TSC, OSC, ENC/JIC, and EOF will be activated and staffed.
Senior plant management and technical personnel representing the licensee and the NRC are located in the TSC. TSC personnel will provide support to the Control Room operating personnel in the management of abnormal conditions and in accident mitigation. During recovery operations the TSC provides plant systems support for the management personnel located in the EOF. The TSC functions as the primary information source to the EOF and to the NRC (via EOF) on plant status.
The Operations Support Center (OSC) is an onsite assembly area separate from the Control Room and the TSC where licensee operations support personnel report in an emergency. This is an assembly area for personnel to report for instructions from the OSC Manager.
Communications are provided to the Control Room, TSC, and EOF on the Boardwriter's and Manager's Bridges. Teams are dispatched from the OSC to provide for Damage Control, Rescue, and Surveys.
The EOF will provide current information on conditions potentially affecting the public to the NRC, state and county emergency response agencies. Radiological assessment, determination of recommended public protective actions and coordination of offsite response will be transferred to the EOF once the EOF is activated. EOF personnel coordinate the offsite radiological monitoring Planning Standard A Revision 32
Page 22 of 221 during nuclear emergencies and recovery operations. The EOF will function as the post-accident recovery management center for both onsite and offsite activities.
The CNP Emergency Public Information Organization is structured to provide a correct and consistent flow of information to the public and the news media throughout an emergency at CNP. During the initial phases of any emergency, all public information relating to the emergency will be released via the Emergency News Center. The ENC becomes the JIC when the State of Michigan declares the JIC activated.
A.1.c. Organization Interrelationships The relationships between Cook Nuclear Plant normal operating and Emergency Response Organizations are presented in numbered Figures 1 through 10. The figures are referenced throughout this Emergency Plan, and especially in Planning Section B, the Onsite Emergency Organization.
A.1.d. Persons in Charqe The Emergency Director (ED) is responsible for control and co-ordination of all Cook Nuclear Plant emergency and recovery operations.
A.1.e. 24 Hour Response The CNP Emergency Response Organization (ERO) is capable of continuous 24-hour operations for a protracted period.
A.2. Not applicable A.3. Agreements The CNP Emergency Plan provides f6r agreements with various offsite support organizations that are part of the overall response organization within the Plume Exposure Pathway Emergency Planning Zone. These agreements are listed in Appendix B to this plan.
In addition to the offsite support agencies listed in Appendix B, it is assumed that assistance will be provided, as necessary, by those State, County and Federal agencies that are mandated by their charter, public law or regulations to protect the public health and safety, i.e., the NRC and FEMA. It is not expected that letters of agreement are required with these agencies.
A.4. Continuous Protracted Operations The CNP Emergency Response Organization (ERO) is capable of continuous 24-hour operations for a protracted period.
Planning Standard A Revision 32
Page 23 of 221 FIGURE 1 MICHIGAN NUCLEAR ACCIDENT STATE RESPONSE ORGANIZATION PRIMARY RESPONSE AGENCIES FEDERAL State Police Environmental Quality Direction, Control & Monitoring & Sampling Federal Emergency Management Coordination Technical Advice Agency Evacuation Authority Decontamination Advice Nuclear Regulatory Commission Warning/Notification Occupational Health Department of Energy Security Medical & Health Support Damage Assessment Accident & Dose Assessment Federal Coordination Public Information Radiological Exposure Control Resource Support In-place Shelter Protective Actions Technical Advice Local Plans Ground Water Terrorist Activities Municipal Water Supplies Federal Liaison Military Weapon Accident SUPPORT RESPONSE AGENCIES Agriculture Licensing and Regulatory Affairs PLANT OWNER/OPERATOR Food Contamination Food Supply Public Utilities Liaison Sampling Energy Disruption Site Emergency Response Organization Corrections Education Temporary Housing Housing Notification Transportation Assist. Mass Transportation Onsite Control Feeding and Clothing Support Community Health Military Affairs Crisis Counseling Transportation Temporary Housing Security LOCAL Aerial &Ground Monitoring Support Natural Resources Human Services Public Works Health Fire Berrien County Environmental Impact Housing/Registration Social Services Sheriffs Fish/Game Contamination Feeding and Clothing Department Sampling Assistance Centers Warning Support Volunteer Agency Support Meteorological Analysis Warning Surface Water Evacuation Sheltering Transportation Blockading Public Information Transportation - Railroads - Air Traffic Re-entry Traffic Regulations Blockade Planning Standard A Revision 32
Page 24 of 221 PLANNING STANDARD B EMERGENCY RESPONSE ORGANIZATION Planning Standard B Revision 32
Page 25 of 221 B. EMERGENCY RESPONSE ORGANIZATION The purpose of this section is to describe the CNP organization during normal operations and during emergencies. Figure 2 shows the management structure for the Nuclear Generation Group (NGG). The Senior Vice President is the primary interface with local and state officials in matters concerning emergency preparedness.
B.1 Normal On-Site Operating Ormanization The normal on-site operating organization chart for the CNP is shown in Figure 3.
B.1.a. Vice Presidents The Vice President-Nuclear Generation Group is responsible for implementing all activities at the CNP in accordance with all applicable laws, regulations, AEP. and NGG policies while meeting the business needs of AEPNGG.
The Senior Vice President has the full authority and responsibility for operating, maintaining, and modifying the plant within established parameters and procedures. These responsibilities include ensuring effective implementation of the radiation protection program, directing the production, safety, work control and outage activities and Site Protective Services. and organizationalladministrative activities at the plant.
The Vice President-Site Support Services is responsible for personnel training and qualification.
B.1.b. Plant Mana-ger The Plant Manager is accountable to the Site Vice President for the operations, maintenance, radiation protection, chemistry and environmental functional areas of plant production. The primary responsibility for the Plant Manager is the safe operation of the nuclear facility in accordance with applicable corporate policies, laws, regulations, licenses, and technical requirements, to ensure that public health and safety, including that of employees, is protected from undue nuclear and industrial safety risks.
B.1.c. Maintenance Manager The Maintenance Manager reports to the Plant Manager and is accountable for managing and directing the activities related to the maintenance of all site equipment, structures, grounds and yards, and fire protection program. Managers that report to the Maintenance Manager provide the tools and support services necessary to optimize the safe, environmentally sound, cost effective efforts of the plant production organizations.
B.1.d. Director Nuclear Site Services The Director Nuclear Site Services is accountable to the Site Vice President and is responsible for oversight of the Security Plan, Emergency Plan, and is responsible for integration of the emergency response and security functions.
B.l.e. Emergency Preparedness Manager The Emergency Preparedness Manager ensures that the on-site and off-site emergency preparedness programs can protect the health and safety of the general public and site personnel while minimizing damage to the property and the environment in the event of an emergency. The Emergency Preparedness Manager is accountable to the Director Nuclear Site Services.
Planning Standard BR Revision 32
Page 26 of 221 B.1.f. Security Manager Security Manager is accountable to the Director Nuclear Site Services and is responsible for developing and directing the nuclear security, access authorization, and fitness for duty programs.
B.1.g. Training Manager The Training Manager reports to the Vice President-Site Support Services and is accountable for the maintenance of INPO accreditation for eligible training programs, as well as non-accredited programs. This includes managing the development and presentation of training materials; maintenance of training materials, inclusive of the plant simulator and training aids; maintenance of training records and methods for assessing training effectiveness.
B.1.h. Operations Manager The Operations Manager reports to the Plant Manager and is accountable for operating the nuclear generating units in a safe, environmentally sound, cost effective, reliable and efficient manner in accordance with applicable corporate policies, laws, regulations, licenses, and technical requirements. The primary responsibility of the Operations Manager is the safe operation of the generation units to ensure that the public health and safety, including those of employees, is protected from undue industrial and nuclear safety risks.
B.1.i. Chemistry Manager The Chemistry Manager reports to the Plant Manager and is accountable for all activities related to plant system chemistry sampling, analysis, and control operations at CNP by optimizing fission product barrier effectiveness, maximize the life of plant equipment, and protect the health and safety of the public.
B.1.j. Radiation Protection Manager The Radiation Protection Manager, who is accountable to the Plant Manager, serves as the regulatory Radiation Protection Manager. The Radiation Protection Manager is responsible for the implementation and maintenance of the radiation protection programs. As such, the function of the Radiation Protection Manager is to establish and maintain the highest level of radiological safety attainable for the protection of plant employees, the public, and the environment.
B.1.k. On-Shift Operations Personnel The major assignments of the on-duty operating shift and the supplemental personnel in the Emergency Plan Organization are delineated in Table 1, CNP Staffing for Radiological Emergencies. Figure 4 is the chart for the On-shift Response Organization.
The Shift Manager, acting as the SEC, has overall responsibility for directing and implementing emergency and abnormal procedures to bring the unit to a safe condition. The Shift Manager retains the Emergency Direction and Control functions until relieved by a qualified Site Emergency Coordinator (SEC) or Emergency Director (ED). This position is the Table 1 on-shift column Shift Manager position for the Emergency Direction and Control functional area and Plant Operations functional area.
One of the two Unit Supervisors on shift aids and assists the Shift Manager. This position is the Table 1, CNP Staffing for Radiological Emergencies, On -Shift Plant Operations functional area Unit Supervisor.
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Page 27 of 221 The Work Control SRO reports to the Control Room in the event of an emergency to assist the Operations shift. The Work Control SRO provides staffing of the Table 1, CNP Staffing for Radiological Emergencies, On-Shift Plant Operations functional area Assistant Shift Manager/WCC-SRO.
One of the Reactor Operators provides staffing of the Table 1, CNP Staffing for Radiological Emergencies, Radiological Accident Assessment and Support functional area On-Shift Offsite Dose Assessment until relieved of that responsibility by the EOF.
Two of the Auxiliary Equipment Operators (AEOs) provide staffing of the Table 1, CNP Staffing for Radiological Emergencies, Notification/Communication functional area until relieved of that responsibility by the EOF. An additional AEO performs the Plant System Engineering, Repair and Corrective Actions functional area Repair and Corrective Actions Rad Waste Operator as part of the normal AEO duties.
The on-duty Shift Technical Advisor (STA) reports to the Control Room in the event of an emergency. The STA function is monitoring the Critical Safety Function Status Trees and recommending necessary procedure transitions. The Core/Thermal Hydraulic conditions are monitored by the Critical Safety Function Status Trees. The STA provides staffing of the Table 1, CNP Staffing for Radiological Emergencies, Plant System Engineering, Repair and Corrective Actions functional area On-Shift Core/Thermal Hydraulics and STA Technical Support. The STA reports to the SM and acts in an advisory capacity. Other STAs called in will report to the TSC, as needed.
B.1.I. On Shift non-Operations (Supplemental) Personnel The major assignments of the on-duty operating shift and the supplemental personnel in the Emergency Plan Organization are delineated in Table 1, CNP Staffing for Radiological Emergencies. Figure 4 is the chart for the On-shift Response Organization.
Three RP Technicians are assigned to each shift to provide the Table 1, CNP Staffing for Radiological Emergencies, Radiological Accident Assessment and Support functional area On-Shift Offsite, Onsite, and In-plant surveys. They also provide Protective Actions functional area On-Shift Radiation Protection coverage. The on-shift RP Technician staffing is augmented with the on-shift Chemistry Technicians and ten (10) RP Technicians called in for 60 minute supplemental staffing.
Two Chemistry Technicians are assigned to each shift to provide the Table 1, CNP Staffing for Radiological Emergencies, Radiological Accident Assessment and Support functional area On-Shift Chemistry positions making expertise immediately available to address chemistry issues.
The on-shift Chemistry staffing is augmented with one (1) Chemistry technician called in for 60 minute supplemental staffing.
The Mechanic, Electrician, and I & C Technician assignment ensures the Plant System Engineering Repair and Corrective Actions functional area On-Shift Repair and Corrective Actions maintenance disciplines expertise are immediately available to address maintenance issues. The on-shift Maintenance staffing is augmented with one each Mechanic, Electrician, and I&C Technician called in for 60 minute supplemental staffing.
The Fire Brigade provides the staffing for the On-Shift Fire Protection Functional Area and the Rescue and First Aid functional area. The brigade shift staffing is maintained as specified in the Technical Requirements Manual. Staffing for sixty minute response is provided by supporting local fire departments.
The Security force provides the staffing for the On-Shift and 60 minute Access Control and Accountability Functional Area. Security staffing is maintained as specified in the Security Plan.
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Page 28 of 221 B.2. On-Shift Emergency Coordination The Shift Manager, acting as the SEC, has overall responsibility for directing and implementing emergency and abnormal procedures to bring the unit to a safe condition.
B.3. Emergency Coordination Line of Succession The authority for initiation of the Emergency Plan is delegated to the senior supervisor of the on-duty operating shift (e.g., the Shift Manager).
Upon the classification of an emergency event, the Shift Manager (SM) assumes the position of Site Emergency Coordinator (SEC). The Shift Manager retains the Emergency Direction and Control functions until relieved by a qualified Site Emergency Coordinator (SEC) or Emergency Director (ED).
Upon arrival at the appropriate emergency response facility, the SEC reviews the emergency situation with the Shift Manager, assumes the SEC responsibilities for overall management of plant and emergency response functions, and assures that proper actions are being taken to mitigate the event. The SEC ensures that the proper State/County authorities, NRC and AEP officials are notified.
The SEC will function as acting Emergency Director until such responsibilities are assumed at the EOF.
Upon activation of the EOF the Emergency Director reviews the emergency situation with the SEC and assumes responsibility for control and co-ordination of all emergency and recovery operations from the SEC.
B.4. Non-delegable Emergency Coordinator Duties During the initial phase of a nuclear incident prior to activation of the EOF, the SEC has the non-delegable responsibility to make Protective Action Recommendations (PARs) to State/County authorities responsible for offsite emergency measures.
Upon activation of the EOF the Emergency Director assumes the non-delegable responsibility for making Protective Action Recommendations (PARs) to State/County authorities responsible for offsite emergency measures.
B.5 Emergency Response Organization The CNP Emergency Response Organization is presented in Figures 4 through 7.
Every effort is made to match professional skills with those needed in the ERO positions listed below. However, there may be some instances where, in actual assignments, the professional skill description may not match those listed with their respective position. In such cases, the individual in question has been determined to effectively fulfill the requirements of the position through training and qualification for the ERO staff position or because of similar current, or past professional experiences or duties.
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Page 29 of 221 B.5.a. Technical Support Center (TSC)
The TSC Emergency Response Organization is presented in Figure 5.
B.5.a.l. Site Emergqency Coordinator Upon arrival at the appropriate emergency response facility, the SEC reviews the emergency situation with the Shift Manager and assumes the following SEC responsibilities:
- 1. Overall management of plant and emergency response functions.
- 2. Assures that proper actions are being taken to mitigate the event.
- 3. Ensures that the proper State/County authorities, NRC and AEP officials are notified.
- 4. Until activation of the EOF, overseeing event classification and notification, responsibilities that may not be delegated.
- 5. Until activation of the EOF, making Protective Action Recommendations (PARs) to State/County authorities responsible for offsite emergency measures, a responsibility that may not be delegated.
- 6. Authorize dose extensions for emergency response related activities.
- 7. Authorize the distribution of potassium iodide tablets to plant personnel.
In addition to these immediate duties noted above, the SEC also has the authority to make policy decisions and expend funds necessary to cope with the event The SEC will function as acting Emergency Director until such responsibilities are assumed at the EOF.
The SEC provides staffing of the Table 1, CNP Staffing for Radiological Emergencies, Emergency Direction. and Control functional area sixty minute Senior Manager (SEC).
B.5.a.2 Assistant SEC The Assistant SEC reports directly to the SEC and is responsible for the overall operation of the TSC including;
- 1. Ensuring all TSC staff carry out their assigned functions;
- 2. Ensuring the timely exchange of information within the TSC staff and among various onsite and offsite emergency facilities;
- 3. Reviewing results of calculations performed by the Radiological Assessment Coordinator;
- 4. Managing the activities of the Plant Evaluation Team, and;
- 5. Organizing, prioritizing, and coordinating repair and corrective action with the Shift Manager and OSC Manager.
- 6. Assuming SEC duties if another senior manager is not available.
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Page 30 of 221 If the SEC is required to relocate to the EOF, the Assistant SEC will assume the joint responsibilities of the Assistant SEC and SEC unless relieved of SEC duties by an additional senior manager.
B.5.a.3. Plant Evaluation Team The Plant Evaluation Team (PET) operates out of the TSC and is made up of individuals from appropriate disciplines including Reactor Engineering, Maintenance Engineering, Operations, and Training.
The PET reports to the Assistant SEC and is responsible for but not limited to the following:
- 1. Providing an independent technical analysis of plant conditions;
- 2. Developing corrective action recommendations;
- 3. Providing technical assistance to operations personnel when requested;
- 4. Responding to queries from offsite agencies, as directed by the Assistant SEC; and
- 5. Assuming Severe Accident Management responsibilities if conditions dictate.
Members of the PET fill the following Table 1, CNP Staffing for Radiological Emergencies, Plant System Engineering, Repair and Corrective Actions functional area sixty minute positions:
Core/Thermal Hydraulics Electrical Mechanical B.5.a.4. Radiological Assessment Coordinator The RAC reports to the Assistant SEC and is responsible for, but not limited to, performing analysis of onsite radiological conditions and development of appropriate protectiVe actions for onsite response teams.
The RAC provides staffing of one (1) of the two (2) Table 1, CNP Staffing for Radiological Emergencies, Radiological Accident Assessment and Support functional area In-Plant Surveys sixty minute RP Technicians.
B.5.a.5. Shift Technical Advisor The on duty Shift Technical Advisor (STA) reports to the Control Room in the event of an emergency. Other STAs called in will report to the TSC and provide the relief to the Control Room STA for the Plant System Engineering, Repair and Corrective Actions functional area Core/Thermal Hydraulic sixty minute position.
B.5.a.6. Security Director The Security Director is responsible to the SEC for controlling the movement of personnel and vehicles onsite, ensuring continuing security, safety of personnel, and allowing efficient mobilization of emergency resources.
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Page 31 of 221 B.5.a.7. Administrative Coordinator Upon arrival at the TSC the Administrative Coordinator reports directly to the Assistant SEC and is responsible for but not limited to compiling information to be reported offsite, coordinating input from the PET and Radiological Assessment Coordinator, and obtaining the approval of the Assistant SEC prior to release of any information offsite.
B.5.a.8. Administrative Support Personnel Additional personnel needed to provide administrative support to the TSC include:
Administrative Support - duties include, but not limited to, transmission, receipt, duplication and distribution of documents.
Computer Analyst - duties include but not limited to, solving computer and software related problems.
Boardwriter - duties include, but not limited to, maintaining communication with other Emergency facilities and maintaining a chronological event status board.
B.5.b. Operations Support Center (OSC)
The OSC Emergency Response Organization is presented in Figure 5.
B.5.b.1. Operations Support Center Manager Upon arrival at the Operations Support Center (OSC) the OSC Manager assumes the following responsibilities:
- 1. Overall control and coordination of all OSC activities.
- 2. Coordinating with the TSC to identify the skills and number of personnel required to combat the emergency.
- 3. Notification of the TSC if appropriate skill levels and quantities of personnel are not available.
- 4. Oversee the implementation of accountability upon activation of a nuclear emergency alarm.
B.5.b.2. Assistant Operations Support Center Manager The Assistant Operations Support Center Manager aids and assists the OSC Manager as necessary.
B.5.b.3. Skill Supervisors and Contingency Director Skills Supervisors (Maintenance, Instrumentation and Control, Chemistry, Radiation Protection, Fire Brigade Leader) and the Contingency Director, when reporting to the OSC, are responsible for the following:
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Page 32 of 221
- 2. Direction of cognizant departmental personnel including non-licensed operators in the performance of emergency response activities as specified by the OSC Manager.
- 3. As appropriate, participate in pre-deployment briefings of Damage Control Teams.
Participation is limited to the supervisor's departmental responsibilities.
The positions of skill supervisor for Maintenance, Instrumentation and Control, Chemistry, Radiation Protection, and Fire Brigade Leader are held by therespective supervisors.
The Contingency Director is filled by a Senior Reactor Operator (SRO) as assigned by the Shift Manager.
The skills supervisors report to the OSC Manager.
B.5.b.4. Radiation Protection Director Upon arrival at the OSC a Radiation Protection Director assumes the following responsibilities:
- 1. Assessing the habitability of the OSC for the duration of the emergency.
- 2. Assessing the radiological aspects of Damage Control Team assignments and specifying the radiation protection measures to be taken for a given assignment.
- 3. Briefing Damage Control Teams on radiation protection measures prior to deployment.
- 4. The activation, direction, briefing and debriefing of Re-entry and Rescue Teams and Radiation Monitoring Teams.
The Radiation Protection Director reports directly to the OSC Manager.
B.5.b.5. Operations Support Center Boardwriter Upon arrival at the OSC the OSC Boardwriter assumes responsibility for establishing and maintaining communications with the TSC.
B.5.b.6. Damaqe Control Team The Damage Control Team reports directly to the OSC Manager and is responsible for the repair and restoration of damaged plant systems, equipment, or components.
Members of the Damage Control Team will be selected based on the type of damage that must be dealt with at the time.
B.5.b.7. Rescue Team Rescue Teams are used for rescue of injured and trapped personnel.
Rescue Teams shall be made up of at least two people, one person qualified in radiation protection and at least one other person.
B.5.b.8. In-Plant/On-Site Survey Team In-Plant/On-Site Survey Teams are used for radiological survey during reentry of site facilities, as well as support of other emergency teams which must gain access for decontamination, repair, and other activities that support event mitigation or recovery operations.
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Page 33 of 221 B.5.c. Emeraency Operations Facility (EOF)
The EOF Emergency Response Organization is presented in Figure 5 and Figure 6.
B.5.c. 1. Emergency Director Upon arrival at the EOF the Emergency Director is responsible for control and coordination of all emergency and recovery operations including, but not limited to, the following:
- 1. Overseeing activation of the EOF.
- 2. Overseeing event classification and notification, responsibilities that may not be delegated.
- 3. Ensuring the EOF assumes responsibility for communications with offsite organizations.
- 4. Ensuring the EOF assumes dose assessment responsibilities and directirng the activities of the Environmental Assessment Director in response to the emergency.
- 5. Making Protective Action Recommendations (PARs) to State/County authorities responsible for offsite emergency measures, a responsibility that may not be delegated.
- 6. Ensuring that access and security controls are established at the EOF.
- 7. Directing the development of recovery plans and procedures.
- 8. Event Termination.
The ED provides staffing of the Table 1, CNP. Staffing for Radiological Emergencies, Radiological Accident Assessment and Support functional area sixty minute Direction and Control Emergency Director (ED).
B.5.c.2. Communication Director Upon arrival at the EOF the Communication Director reports to the Emergency Director and is responsible for but not limited to the following:
- 1. Establishing a chronological history log of events and making this log available to EOF personnel;
- 2. Ensuring communications and dose assessment personnel are regularly updated on information required to perform their functions;
- 3. Establishing communications with the Berrien County Sheriff's Department, Michigan State Police, Nuclear Regulatory Commission, American Nuclear Insurers, INPO and the ENC/JIC.
B.5.c.3. Environmental Assessment Director Upon arrival at the EOF the Environmental Assessment Director (EAD) reports to the Emergency Director and is responsible for the direction and control of all offsite radiological aspects of the emergency. This includes dose projection calculations, protective action recommendation development, and the collection and analysis of radiological samples.
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Page 34 of 221 The EAD provides staffing of the Table 1, CNP Staffing for Radiological Emergencies, Radiological Accident Assessment and Support functional area Offsite Dose Assessment sixty minute EAD.
B.5.c.4. Environmental Assessment Coordinators (2)
Upon arrival at the EOF the Environmental Assessment Coordinators report to the Environmental Assessment Director and are responsible for but not limited to calculating offsite radiation exposures, accumulating offsite radiation measurement data, keeping track of in-plant effluent radiation monitors, and projecting radiation dose estimates based on actual or potential releases.
The EAC provides staffing of one (1) of the three (3) Table 1, CNP Staffing for Radiological Emergencies, Radiological Accident Assessment and Support functional area Offsite Survey sixty minute RP Technicians.
B.5.c.5. Offsite Radiation Monitoring Offsite Radiation Monitoring is performed by survey teams assembled in the OSC. Upon leaving the OSC the Offsite Survey Team(s) report to the Environmental Assessment Director in the EOF via the Field Monitoring Team Communicator to receive briefing and instructions. It is the responsibility of the Offsite Survey Team(s) to survey and record offsite radiological data at selected locations and routes, as defined in mission briefings and subsequent instructions.
Qualified RP Technicians fill the position for persons performing the survey.
B.5.c.6. Field Monitoring Team Communicator The Field Monitoring Team Communicator reports to the Environmental Assessment Director and is responsible for communications between the Environmental Assessment Director and the Offsite Survey Team(s) performing Offsite Radiation Monitoring.
B.5.c.7. Industry Support Communicator The primary responsibility of the Industry Support Communicator is to provide an interface between the EOF and the designatedagency (i.e., INPO, NSSS/Fuel vendor(s), and American Nuclear Insurers). This interface will include initial notification of an event at CNP and periodic updates as to the status of the plant.
B.5.c.8. Engineering, Design and Site Services Manager The Engineering, Design and Site Services Manager reports to the ED and is responsible for coordinating the design and construction activities of the utility, NSSS supplier, and other outside vendors. The Engineering, Design and Site Services Manager is assigned to the EOF.
B.5.c.9. Scheduling and Planning Manager The Scheduling and Planning Manager serves as a support resource for the ED in the areas of planning, scheduling and expediting of recovery operations. The Scheduling and Planning Manager is assigned to the EOF and reports to the Engineering Design and Site Services Manager.
B. 5.c. 10. Public Affairs Liaison The Public Affairs Liaison confers with the EOF staff to determine responses to public affairs personnel requests for information and communicates with public affairs personnel at the ENC/JIC to provide information about the emergency when requested.
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Page 35 of 221 B.5.c. 11. Administrative Support Personnel Additional personnel needed to provide administrative support to the EOF include Communicators, Boardwriters, Runners, Computer Analysts and Fax Operators.
Administrative Support - duties include, but not limited to, transmission, receipt, duplication and distribution .of documents.
Computer Analyst - duties include but not limited to, solving computer and software related problems.
Boardwriter - duties include, but not limited to, maintaining communication with other Emergency facilities and maintaining a chronological event status board.
B.5.d. Emergency News Center/Joint Information Center (ENC/JIC)
The ENC, located at the Nuclear Generation Group Headquarters Building, approximately 14 miles southeast of the Plant in Buchanan, Michigan, will be staffed by individuals from the Energy Information Center, CNP, and Corporate Communications - Generation. The ENC will be under the direction of the Media Center Manager. Throughout the operation of the ENC, the Media Center Manager maintains constant communication with AEP Corporate Communications -
Generation. See Figure 7 for an organization chart illustrating staffing and information flow for the ENC/JIC. Figure 5 illustrates ENC/JIC functional relationship to the remainder of the Emergency Response Organization.
When the Governor of the State of Michigan declares a "State of Disaster or Emergency" the ENC becomes the Joint Information Center at the governor's declaration. See Figure 7 for an organization chart illustrating staffing and information flow for the ENC/JIC.
B.5.d.1. Media Center Manager The Media Center Manager is responsible for coordinating all information at the ENC/JIC with counterparts from the county, state, and federal agencies and others involved with the emergency. The Media Center Manager will maintain contact with utility management dealing with the emergency to develop news releases, supervise all communications with the news media and relay information to other appropriate utility employees.
B.5.d.2. Technical Communicator The Technical Communicator establishes communication between the ENC/JIC, TSC, and EOF.
The Technical Communicator obtains plant status from the TSC and assists in preparation of press releases.
B.5.d.3 Media Area Coordinator The Media Area Coordinator is responsible for ensuring media representatives have adequate facilities to properly cover media briefings and to provide press kits, related general background information, and written statements from each briefing. The Media Area Coordinator is not to perform any briefings or explanations to the media.
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Page 36 of 221 B.5.d.4. Utility Spokesperson The Utility Spokesperson is the "single utility spokesperson" when dealing with the news media.
The Utility Spokesperson reports to the Media Center Manager and will be the source of utility statements quoted in press briefings or releases and will represent the utility at formal press briefings to answer technical questions about the incident.
B.5.d.5. JIC Set-up Coordinator The JIG Set-up Coordinator is responsible for the physical arrangements of the setting up of the ENC/JIC.
B.5.d.6. Public Inquiry/Media Monitoring Coordinator The Public Inquiry/Media Monitoring Coordinator operates out of the ENC/JIC and reports to the Media Center Manager. The Public Inquiry/Media Monitoring Coordinator is responsible for logging all telephone calls and is expected to work with personnel in the JIG Command Center to correct misinformation. It is also the responsibility of the Public Inquiry/Media Monitoring Coordinator to monitor radio and television broadcasts to make certain information about the incident is being reported accurately.
B.5.d.7. Support Office Coordinator The Support Office Coordinator is responsible for the operations of the Support Office. The Support Office contains a back-up telephone system as well as facilities for outside media calls, faxing, reproduction, and other communication supplies.
B.5.e. Liaisons B.5.e.1. Offsite Liaisons Upon declaration of an Alert, or higher classification, liaisons will be sent to their respective offsite emergency facilities. One liaison will be sent to the Berrien County Emergency Operations Center (EOC) to provide an interface between the ED and the Berrien County Sheriffs Department. A second liaison will be sent to the State EOC to provide interface between the ED and the Michigan State Police. A third liaison will be sent to the Incident Command Post for security related events. The duties of these liaisons will be responsible for, but not limited to:
- 1. Receiving plant reports.
- 2. Assisting in the interpretation of data originating from the plant.
- 3. Providing and clarifying information on plant operations and requirements.
- 4. Coordinating the efforts of these offsite organizations.providing assistance with the plant.
emergency response management.
- 5. Responding to questions from representatives of the various agencies involved in the offsite EOCs.
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Page 37 of 221 B.5.e.2. Emergency Response Facility Liaison If called upon, the Operations Manager or designee reports to the affected Control Room and becomes the Emergency Response Facility (ERF) Liaison and may assume the following responsibilities:
- 1. Assists the SM/SEC by communicating with the other emergency response centers via the Managers telephone bridge circuit.
- 2. Communicates SM/SEC developed/approved priorities, mitigation strategies, protective action recommendations, and other pertinent information.
The alternates for this position are the other Plant Operations supervisors.
B.5.e.3 Incident Command Post Liaison If called upon, a plant knowledgeable person is dispatched to the Offsite Response Organization to act as the Incident Command Post Liaison (ICPL).
The Incident Command Post (ICP) Liaison position responds to security related events at the plant. The ICP Liaison, during security events, reports to the ICP and provides communication between the Site Security force, Local Law Enforcement Agency (LLEA) personnel and the EOF.
Additional resources such as Security, Radiation Protection, Fire Brigade, and/or Operations may be dispatched to assist.
B.6. Overall Organization and Communication The communication links between various emergency centers established as a result of implementing the Emergency Plan are delineated by Functional Organization Charts in Figures 8 and 9.
Initial notification flow sequence is shown in Figure 8.
Figure 9 shows the relationship between various emergency centers and organizations after the incident has occurred and all channels, of communication have been established.
B.7. Plant Staff Augmentation B.7.a. Logistics Support Emergency Director directs the development of recovery plans and procedures.
The Scheduling and Planning Manager serves as a support resource for the ED in the areas of planning, scheduling and expediting of recovery operations. The Scheduling and Planning Manager is assigned to the EOF and reports to the Engineering Design and Site Services Manager.
B.7.b. Reentry/Recovery Technical Support The Plant Evaluation Team (PET), operating out of the TSC develops corrective action recommendations. When the corrective action plans are decided upon, the Engineering, Design and Site Services Manager, operating out of the EOF and reporting to the ED, coordinates the design and construction activities of the utility, NSSS supplier, and other outside vendors to support the corrective actions for recovery.
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Page 38 of 221 B.7.c. Management Level Interface with Government During an event the Emergency Director is responsible for control and coordination of all emergency and recovery operations including communications with offsite organizations, and interface with governmental authorities.
B.7.d. Releases to Media The Media Center Manager coordinates all information at the ENC/JIC with counterparts from the county, state, federal agencies, and others involved with the emergency.
The Utility Spokesperson is the "single utility spokesperson" when dealing with the news media.
B.8. Offsite Agencies and Or-ganizations Appendix B, Agreements with Off-Site Support Agencies, identifies the primary response agencies that can be relied upon in an emergency to provide assistance. In addition various nuclear industry organizations can be called upon to provide technical assistance as needed.
Procedures have been developed and are in place that assures the ability to notify and request assistance from those agencies identified in Appendix B. These procedures also provide the ability to notify and request assistance from other nuclear industry organizations. These include, but are not limited to:
- 1. NSSS Supplier.
- 2. Consultants on radiological and radwaste requirements.
- 3. Nuclear Fuel Supplier.
B.8.a. Notification of American Nuclear Insurers The American Nuclear Insurers notification criteria for nuclear emergencies has been brought into alignment with the emergency classification (EAL) system described in Section D and also identifies methods for follow-up communications.
American Nuclear Insurers requires notification in the event of an Alert, Site Area Emergency or General Emergency.
A representative of the NGG shall notify American Nuclear Insurers via the American Nuclear Insurers emergency notification number.
American Nuclear Insurers requires that periodic updates be supplied of releases of radioactive material from the plant, plant status and impending protective action for members of the public.
These updates are the responsibility of the Industry Support Communicator in the EOF.
Appendix I, Notification of American Nuclear Insurers, and Figure 13 show the ANI notification procedure.
B.9. Offsite Groups Although many offsite groups may be used in the event of an emergency, there are three offsite groups that have agreed to serve in the capacities outlined in this plan should an incident occur.
These groups are the Berrien County Sheriffs Department, the State of Michigan, and the Federal Government. The responsibilities and authorities of the County, State and Federal Governments and their interrelationship with this emergency plan are outlined in the following Planning Standard B Revision 32
Page 39 of 221 paragraphs. Written agreements with various offsite agencies that are part of the overall response organization within the Plume Exposure Pathway Emergency Planning Zone are listed in Appendix B of this plan.
B.9.a. Berrien County Sheriffs Department The Berrien County Sheriffs Department, which is the lead agency in implementing the Berrien County Radiological Emergency Plan, has established an Emergency Operating Center (BCEOC) in accordance with the Berrien County Emergency Plan. This center is located in Benton Harbor, Michigan about 14 miles from the plant. It is equipped with the appropriate communications equipment to coordinate all the local offsite protective actions.
The Berrien County Sheriff has the responsibility and authority for coordination of all local resources in the event of a hostile threat or a radiological emergency, including establishing an Incident Command Post when applicable.
The Sheriffs Department also has a marine division within its organization for the control of water traffic should it be necessary. Although the Sheriffs Department is primarily responsible for coping with an emergency using its own resources, the County Sheriff will call upon state resources to supplement the local resources when the local resources are clearly insufficient to cope with the emergency.
Once the Governor of Michigan has declared a State of Disaster under Act 390, the Berrien County Sheriffs Department will implement the Governor's Orders and will perform the following:
- 1. Contact other local agencies as needed for assistance.
- 2. Control offsite vehicular traffic.
- 3. Initiate the warning system and issue clear instructions of what protective action is required for the populace.
- 4. Take other appropriate action, if so advised by the Michigan State Department of Environmental Quality (DEQ) or upon notification by the SEC or ED that conditions requiring immediate offsite protective action have been reached. (For further details see the Berrien County Plan- Warning Annex.)
B.9.b. State of Michigan The State of Michigan has developed the Michigan Emergency Management Plan. In the event that offsite protective action is required due to a hostile threat or a radiological emergency at CNP, this Michigan Emergency Management Plan can also be placed into effect to assist the Berrien County Sheriffs Department. A brief outline follows of the plan's provisions for nuclear facility emergencies.
Under the Michigan Emergency Management Plan, the Department of State Police will provide guidance for the development of state and local nuclear incident emergency plans for dealing with peacetime radiological incidents. These are defined as situations in which normal control over radioactive materials is accidentally lost, with resulting hazard to the health and safety of the general public.
The State Director of Emergency Management and Homeland Security is responsible for planning and coordinating the Disaster Relief Forces and their activities for the state. The Nuclear Power Plant Project Coordinator, Emergency Management and Homeland Security Division, State Police is designated as the Emergency Planning Coordinator for the State's radiological emergency response planning portion of the plan.
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Page 40 of 221 The State Police, Emergency Management and Homeland Security Division, at the direction of the Governor, will coordinate all organizations in the State for nuclear incident activities, maintaining liaison with all levels of government.
The primary State Emergency Operations Center (SEOC), acting in support of the BCEOC, will perform all state governmental functions. This SEOC is located at 4000 Collins Road, Lansing, Michigan.
Alternate sites to the primary State EOC will be located in one of the State Police District Headquarters as indicated in the Michigan Emergency Management Plan.
The basic responsibilities and duties of the State Government agencies that provide support during a nuclear incident are outlined below.
B.g.b.1. The Primary State Response Agencies and a summary of their responsibilities are:
B.9.b.l.a. The Department of Michigan State Police (MSP)
- Receives notification of nuclear incidents from the utility and alerts state agencies and warns affected local governments (adjacent states and adjacent counties are also alerted);
- Operates the State Emergency - Operations Center, and the field team centers;
- Provides overall direction and control of all activated state and local disaster relief forces;
- Provides notification to local jurisdictions based on technical advice by the DEQ to evacuate and/or shelter in-place.
- Assists local jurisdictions to est~blish security around restricted area;
- Collects and compiles damage assessment information;
" Prepares and coordinates emergency public information releases and advises the .news media;
" Assists local jurisdictions with any transportation accidents;
- Establishes procedures to handle terrorist activities at nuclear power plants; and
" Provides liaison to various federal organizations and agencies.
B.9.b.l.b. The Department of Environmental Quality (DEQ) a Monitors the environment, personnel, and equipment in support of emergency operations;
- Evaluates the public health and medical aspects of radiological effects;
- Recommends measures and establishes limits to mitigate radiological effects on public health; Planning Standard B Revision 32
Page 41 of 221
" Recommends measures to control the spread of radioactivity;
" Establishes radiological safety criteria for recovery, re-occupancy, and rehabilitation of affected areas;
- Provides technical advice and assistance for offsite decontamination activities and support.
- Sample surface water.
- Conduct other monitoring as requested.
- Monitor areas for contamination of the environment and recommend suitable countermeasures to reduce the impact of contamination of the environment.
" Provide meteorological support and technical advice for use in analyzing or projecting radiological release hazards.
B.9.b.2. The State Support Response Agencies and a summary of their responsibilities are:
B.9.b.2.a. Department of Agriculture 0 Responsible for sampling agriculture areas for food contamination and recommending appropriate counter measures in conjunction with the Department of Public Health.
0 Responsible for taking appropriate actions to prohibit contaminated foods from entering the market.
B.9.b.2.b. Licensing and Regulatory Affairs 0 Provide liaison to the public utility companies.
- Provide recommendations for handling energy disruptions resulting from a shutdown due to a nuclear incident.
- Provide advice and guidance to affected persons regarding insurance claims and adjustments.
B.9.b.2.c. Department of Corrections
- Provide for mass care, feeding, clothing and sheltering.
- Provide mass transportation assistance for affected persons and disaster relief workers.
B.9.b.2.d. Department of Education
- Provide support for mass care, feedingand housing.
" Provide mass transportation assistance.
Planning Standard B Revision 32
Page 42 of 221 B.9.b.2.e. Department of Community Health
- Provide crisis counseling and intervention center assistance to affected persons.
- Provides coordination of medical and emergency medical services to affected areas.
B.9.b.2.f. Department of Military Affairs
- Provide transportation and manpower support for evacuation counter measures.
- Provide security support to local law enforcement operations, including control of access to restricted or evacuated areas within the Emergency Planning Zone (EPZ).
B.9.b.2.g. Department of Natural Resources
" Monitor areas accessible by fish and game.
- Take action to prevent or minimize contamination of fish and game.
- Take samples of fish and game, which may have been exposed or contaminated.
- Assist local authorities to warn and evacuate occupants of state parks, beaches, and other recreational areas if necessary.
B.9.b.2.h. Human Services
- Assist with sheltering and housing evacuated population;
- Provide feeding and clothing if required to persons affected.
" Establish assistance centers for affected individuals and families to receive advice and assistance.
" Coordinate assistance made available by volunteer relief agencies and the American Red Cross.
B.9.b.2.i. Department of Transportation 6 Provide for mass transportation assistance to local jurisdictions if required.
- Provide advice and assistance support regarding barricades and security measures around an evacuated or restricted area.
" Provide advice on traffic regulation and control for the evacuation of designated areas.
- Provide assistance for the rescue of entrapped workers and persons.
Planning Standard B Revision 32
Page 43 of 221 The Michigan Department of State Police is notified of an emergency condition in the manner described in Section E by the SEC or designee. The State Police will set up a command post at the SEOC at 4000 Collins Road in Lansing, Michigan. The State Police will also set up a Field Team Center (FTC) to coordinate the dispatch of field teams to monitor for radiological contamination. The FTC will be established at the Michigan Department of Transportation Coloma Service Garage on Red Arrow Highway at 1-196. The State Police will coordinate their efforts with the BCEOC and with the EOF, as needed. After notification has been given, the Michigan Department of State Police will assist Berrien County and perform the actions listed in Section B.9.b.
B.9.c. Federal Government The Federal Government has established the Nuclear/Radiological Incident Annex under the National Response Plan to coordinate Federal radiological assistance. The Nuclear/Radiological Incident Annex establishes:
" A means of requesting and providing Federal radiological assistance from existing Federal resources, and
- An operational framework for coordinating the radiological monitoring and assessment activities of Federal agencies during radiological emergencies occurring within the United States and its territories.
The Nuclear Regulatory Commission (NRC) as the Coordinating Agency is responsible for coordinating the response of all other federal agencies in accordance with the National Response Plan.
The Department of Energy (DOE) Chicago Operations Office, located at Argonne National Laboratory, has radiation monitoring capability available. It will, as requested by NGG Management or any of the indicated offsite groups (Sheriff, State Police or DEQ), assist in the offsite emergency program.
The Chicago Operations Office will, upon request by NGG Management or any of the indicated offsite groups, participate in the monitoring of the offsite areas affected and in the analysis of field data and will recommend measures to be taken offsite for protecting the public. It will also advise the ED of the recommendations.
The DOE Operations Office will, to the extent they are available during the protection and recovery stage, continue to advise the Emergency Management and Homeland Security Division of the Michigan Department of State Police and provide monitoring and analytical capability as requested.
B,9.d. Fire Department CNP maintains an onsite fire fighting brigade; this capability is expected to be sufficient for all fires onsite. In the event offsite assistance is desired or needed, local fire departments may be called upon. The Fire Protection Shift Supervisor is responsible for fire fighting activity onsite as well as notifying offsite departments when assistance is needed.
The primary fire departments that will respond to a fire emergency at CNP are:
Lake Township Fire Department Bridgman Fire Department Letters of agreement to provide fire fighting assistance to CNP can be found in Appendix B of this Plan.
Planning Standard B Revision 32
Page 44 of 221 B.9.e. HAZMAT Team CNP maintains an onsite hazardous material spill response team that is capable of responding to most emergency spill events. If there is insufficient manpower or material available, assistance from the Berrien County HAZMAT Team will be requested. A letter of agreement offering their services can be found in Appendix K of this plan.
AEP has also contracted with environmental firms to provide emergency spill response assistance. These contractors are listed in the Spill Prevention Control and Countermeasures (SPCC) Plan and Pollution Incident Prevention (PIP) Plan, copies of which are located in the Shift Manager's office.
Planning Standard B Revision 32
Page 45 of 221 Figure 2 Management Structure of the Nuclear Generation Group
- ------------- --- --- --- --- --- --- ----- --- --- --- Senior Vice President LI Counsel Corp. Legal Services I HF a esou Site Vice Vice President Performance Assurance Employee Cc 1--- Manager upr Services Manag(
AEP Corporate HR President Site Support Director S Mana er
.;oCenter Manager Nuclear Corporate M g Information Communications Manager Technology Planning Standard B Revision 32
Page 46 of 221 Figure 3 Site Operations Planning Standard B Revision 32
Page 47 of 221 Figure 4 On Shift Response Organization Shh Technical Advisor "Fire Brigade Planning Standard B Revision 32
Page 48 of 221 Figure 5 COOK NUCLEAR PLANT EMERGENCY RESPONSE ORGANIZATION AT AN ALERT CLASSIFICATION Emergency News Ergeny*
t Di'edo.
CenterlJoint Control - ----- Information Center Room -
Meae ente
- 4 ed Dinenten Anit
,,,I.=s I -................
Corponat. Co d.atko-Reporting Responsibility Coordination Information Flow ----
Indicates Location Outside Facility Planning Standard B Revision 32
Page 49 of 221 Figure 6 Organization of the Emergency Directors Staff at the EOF I Site Emergency Coordinator I PlantSta-ff PeTSC/OSC Personnel L
Off-site Survey Reporting Responsibility IL Teams Coordination Information Flow r-------
L -- Indicates Location Outside Facility Planning Standard B Revision 32
Page 50 of 221 Figure 7 Emergency News Center/Joint Information Center Organization rIe n I Director Emergency I r Vice President and Director L Corporate Communications I Reporting Responsibility Coordination Information Flow I - Location Outside Facility Indicates L.---
Planning Standard B Revision 32
e GIý1[ Q TABLE 1 CNP Staffing for Radiological Emergencies Functional Area Major Tasks Emergency Position On-Shift 60 mins.'
Plant Operations and Control Room Staff Shift Manager 1 Assessment of Operational Assistant Shift ManagerlWCC-SRO I Aspects Unit Supervisor 2*
Control Room Operator 4*
Auxiliary Equipment Operator 4*
Emergency Direction and Command and Control Shift Manager 12 Control Senior Manager (SEC) 1 Notification/Communication Licensee Reactor Operators Local / State Qualified Operator 1 Federal Qualified Operator 1 Augmenting ERO members 2 Radiological Assessment Direction and Control Emergency Director (EOF) 1 Offsite Dose Assessment Reactor Operator/EAD 12 1 In-Plant Surveys RP Technician 1 2 Onsite Surveys RP Technician 1 1 Offsite Surveys RP Technician 1 3 Chemistry Chemistry Technician 2 1 Plant System Engineering, Technical Support - OPS Shift Technical Advisor 1 Repair and Corrective Core Damage Shift Technical Advisor 12 1 Actions Electrical I Mechanical I Repair and Corrective Actions Mechanical Maintenance 12 1 Electrical Maintenance 22,3 1 Instrument & Controls Maintenance 1 1 Radiological Waste ,1 In Plant Protective Actions Radiation Protection RP Technicians 2; 4 Fire Protection Fire.Fighting Fire Brigade 5 Local support Rescue and First-Aid Fire Brigade ..............2 Local support Access control & Security, Communications, Personnel Shift Security Supervisor 1 As per Security accountability Accountability Security Personnel Per Security Plan Plan Total 27 23 L __________________23-
- 1. The augmentation times presented in this table are goals developed from the guidance of Table B-1 in NUREG-0654, FEMA-REP-1, Rev. 1 "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants."
- 2. May be provided by shift or other personnel assigned from other functions. Not included in the total.
The number indicated is for two operating units. With the unaffected unit in operation, maintain at least 1 Unit Supervisor, I Control Room Operator, and 1 Auxiliary Equipment Operator assigned to the unaffected unit.
Planning Standard B Revision 32
Page 52 of 221 PLANNING STANDARD C EMERGENCY RESPONSE SUPPORT AND RESOURCES Planning Standard C Revision 32
Page 53 of 221 EMERGENCY RESPONSE SUPPORT AND RESOURCES C.1. Federal Radiological Assistance C.1.a. Requesting Federal Assistance The Emergency Director (ED) or the Site Emergency Coordinator (SEC) has the authority to request federal radiological assistance.
A request for federal radiological assistance should be made through the Department of Energy's (DOE)
Chicago Operations Office located at 9800 S. Cass Avenue, Argonne, Illinois 60439. The Chicago Operations Office is designated to provide the primary assistance following a radiological incident in the Radiological Assessment Program (RAP) Region 5.
When a request for RAP assistance is made, the following information should be provided:
- 1. Nature of the incident.
- 2. Name, title, location and telephone number of person requesting assistance.
- 3. Time of the incident.
- 4. Location of the incident.
- 5. Accessibility of location.
- 6. Whether a fire is involved.
- 7. Relative seriousness of incident.
- 8. Weather conditions.
- 9. Personnel involved (injuries, contamination, etc.).
- 10. Local/state/federal agencies that have been notified..
- 11. Whether the news media is aware of the incident; whether false or exaggerated reports are known to have circulated.
C.1.b. Federal Resources The immediate objective of the DOE's Chicago Operations Office is to dispatch a team of specialists to the incident site where the team will:
- 1. Evaluate the hazard.
- 2. Take or recommend action to counteract and control any acute hazard offsite from the licensee's site.
- 3. Establish communication with State and local authorities and the press.
If the Chicago Operations Office determines a need for additional assistance beyond its own capabilities, it may initiate the Nuclear/Radiological Incident Annex.
Planning Standard C Revision 32
Page 54 of 221 The Nuclear/Radiological Incident Annex has been established by the federal government to coordinate federal radiological assistance. The Nuclear/Radiological Incident Annex establishes:
- A means of requesting and providing Federal radiological assistance from existing federal resources, and
- An operational framework for coordinating the radiological monitoring and assessment activities of Federal agencies during radiological emergencies occurring within the United States and its territories.
Through the Nuclear/Radiological Incident Annex the DOE's Chicago Operations Office has the capability to call upon resources located throughout the United States and will provide this assistance where necessary or when requested. Some of the immediate resources that can be provided are (but not limited to):
- 1. Provide team(s) of RAP personnel to assist in offsite monitoring.
- 2. Provide portable direct reading radiological measuring instruments.
- 3. Provide counting equipment.
- 4. Provide aerial surveillance and measurement.
- 5. Provide analytical capability to augment the licensee and state's capability.
- 6. Provide resources as may be available at the Argonne National Laboratory.
- 7. Provide health physics assistance.
- 8. Provide environmental control assistance.
- 9. Provide remote handling equipment on an as needed basis.
Additional information pertaining to federal radiological assistance can be found in Appendix E, Description of Federal Radiological Assistance, to this plan. Appendix E is divided into three sections.Section I is a brief introduction to the federal radiological assistance.Section II describes typical capabilities and expected mobilization and travel times for some of the Region 5 radiological assistance resources available within Region 5 of the DOE's radiological assistance program.Section III describes additional DOE capabilities that can be activated dependent on the assistance needed and how it is activated.
C.1.c. Federal Response Support Resources Appendix E contains information on the local resources required to support the RAP.
C.2. Liaisons C.2.a. Liaisons to CNP Not applicable C.2.b. Liaisons from CNP Section B.5.e.1. details the liaisons provided to the Berrien County EOC, Incident Command Post and the Michigan SEOC.
C.3. Radioloqical Laboratories Section H.6.c Offsite Laboratory Facilities discusses offsite laboratory availability.
Planning Standard C Revision 32
Page 55 of 221 C.4. Offsite Agencies and Organizations Appendix B identifies the primary response agencies that can be relied upon in an emergency to provide assistance. In addition various nuclear industry organizations can be called upon to provide technical assistance as needed. Procedures have been developed and are in place that assures the ability to notify and request assistance from those agencies identified in Appendix B. These procedures also provide the ability to notify and request assistance from other nuclear industry organizations. These include, but are not limited to:
- 1. NSSS Supplier.
- 2. Consultants on radiological and radwaste requirements.
- 3. Nuclear Fuel Supplier.
C.4.a. American Nuclear Insurers The American Nuclear Insurers notification criteria for nuclear emergencies has been brought into alignment with the. emergency classification (EAL) system described in Section D and also identifies methods for follow-up communications.
American Nuclear Insurers requires notification in the event of an Alert, Site Area Emergency or General Emergency.
A representative of the NGG shall notify American Nuclear Insurers via the American Nuclear Insurers emergency notification number.
American Nuclear Insurers requires that periodic updates be supplied of releases of radioactive material from the plant, plant status and impending protective action for members of the public. These updates are the responsibility of the Industry Support Communicator in the EOF.
Appendix I and Figure 13 show the ANI notification procedure.
C.4.b. Nuclear Transportation Accidents A Voluntary Assistance Agreement has been entered into between electric utilities involved in the transportation of source material, special nuclear material and by-product material received, possessed, used or transferred. This agreement sets forth the understanding and agreement with respect to the mutual undertaking to each other in the situation where an emergency occurs by reason of a nuclear materials transportation accident and assistance is provided by one utility to another. A copy of this agreement can be found in Appendix B.
C.4.c. Nuclear Power Plant Accidents A voluntary assistance agreement has been entered into between electric utilities involved in the operation of nuclear power plants. This agreement sets forth the understanding and agreement with respect to their mutual undertaking to each other in a situation where an emergency occurs at a nuclear power plant and assistance is provided by one utility to another. A copy of this agreement can be found in Appendix B, and contact information is contained in the Emergency Plan Procedures.
Planning Standard C Revision 32
Page 56 of 221 PLANNING STANDARD D EMERGENCY CLASSIFICATION SYSTEM
.Planning Standard D Revision 32
Page 57 of 221 D. EMERGENCY CLASSIFICATION SYSTEM In general, Initiating Conditions (ICs) describe conditions that require implementation of emergency actions. Emergency Action Levels (EALs) are, where possible, pre-designated, non-subjective thresholds for entry into a particular Emergency Classification Level (ECL). The action to be taken by the operating shift depends on the severity of the incident, its effects and type.
The SEC or ED will exercise subjective judgment to ensure all incidents are classified at the highest appropriate ECL based on the following criteria:
- Conditions warrant a declaration of an Unusual Event when events are in processor have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.
" Conditions warrant a declaration of an Alert when events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of Hostile Action. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.
. Conditions warrant a declaration of a Site Area Emergency when events are in process or have occurred which involve an actual or likely major failures of plant functions needed for protection of the public or Hostile Action that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or, (2) that prevent access to equipment needed for the protection of the public.
Any releases are not expected to result in exposure levels which exceed EPA Protective Acton Guideline exposure levels beyond the site boundary.
" Conditions warrant a declaration of a General Emergency when events are in process or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity or Hostile Action that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels beyond the site boundary.
The ICs/EALs were created following the methodology of NUMARC/NESP-007, Rev. 2. The ICs/EALs will classify an event or condition into one of four Emergency Classification Levels (ECLs) if an emergency classification is appropriate.
D. 1. Emergency Action Levels Emergency Action Levels are pre-determined, site specific, observable thresholds for plant Initiating Conditions that place the plant in a given emergency class. An EAL can be an instrument reading; an equipment status indicator, a measurable parameter (onsite or offsite); a discrete, observable event; results of analyses; entry into specific emergency operating procedure; or another phenomenon which, if it occurs, indicates entry into a particular emergency class.
Planning Standard D Revision 32
Page 58 of 221 The severity of the emergency. classification may change over time with the emergency being upgraded from one classification level to another.
Incidents will typically be classified in a lower emergency classification at first and then escalated to a higher classification if the situation deteriorates.
Each of the four emergency classification levels has characteristic Emergency Action Levels for various parameters.
Planning Standard D Revision 32
Page 59 of 221 Table 2 is the Fission Product Barriers matrix for modes 1 through 4 used to determine EALs. Table 3 describes the EAL Initiating Conditions for the various Emergency Condition Categories (ECCs) for Modes 1 through 4. Table 4 describes the Initiating Conditions for Modes 5 and 6 and defueled condition (shutdown).
D.2. Initiating Conditions Initiating Condition - One of a predetermined subset of nuclear power plant conditions where either the potential exists for a radiological emergency or such an emergency has occurred.
Some of the initiating conditions and events are directly identifiable by their existence, such as operation of a safety system or a fire, while others require observation of process or radiation monitoring instrumentation.
Station procedures contain the specific instrumentation, equipment status, and non-process conditions and. events that are used to establish the emergency classification.
Table 2 is the Fission Product Barriers matrix for modes 1 through 4 used to determine EALs. Table 3 describes the EAL Initiating Conditions for the various Emergency Condition Categories (ECCs) for Modes 1 through 4. Table 4 describes the Initiating Conditions for Modes 5 and 6 and defueled condition (shutdown).
D.2.1 Emergency Declaration Timeliness Station procedures contain instructions to declare an emergency within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and shall promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.
Planning Standard D Revision 32
Page 60 of 221 Table 2 FISSION PRODUCT BARRIER MATRIX - Mode 1-4 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Loss of TWO Fission Product Any TWO of the Following: Loss or Potential Loss of Either Fuel Clad Loss or Potential Loss of Containment Barrier.
Barriers AND Potential Loss of 1. Loss or Potential Loss of Fuel Clad. or RCS Barrier.
Third Barrier. 2. Loss or Potential Loss of RCS.
- 3. Loss of Containment Barrier.
1.FUEL CLAD BARRER LOSS (L) POTENTIAL LOSS (P)
.1Core Cooling CSFST Core Cooling CSFST - RED Core Exit Thermocouples > 7570 OR RVLIS Level < 46% (NarrowRange)
.2Containment Radiation > 200 R/hr. None
.3 Primary Coolant Activity >300 uCi/cc 1-131 dose equivalent None OR Core Damage > 5.0% clad failure
.4 SEC Judgment Any condition in the opinion of the SEC that indicates loss of the Fuel Any condition inthe opinion of the SEC that indicates potential loss of the Clad barrier. E Fuel Clad barrier. E
- 2. RCS BARRIER LOSS (L) POTENTIAL LOSS (P)
.1RCS Leak Rate (unisolable) > available makeup capacity as indicated by complete loss of RCS > capacity of one centrifugal charging pump in normal charging subcooling. line up.
.2 Steam Generator Leakage Entry into OHP 4023.E-3, SGTR Ruptured SG with leak > capacity of one charging pump in AND normal charging line up.
A Non-isolable secondary line break or a prolonged release (>30 minutes) of contaminated secondary coolant resulting in a radioactive release to the environment from the affected SG.
.3 Containment Radiation > 10 R/hr None
.4RCS Integrity CSFST None RCS Integrity CSFST - RED
.5Heat Sink CSFST None Heat Sink CSFST - RED
.6 SEC Judgment Any condition in the opinion of the SEC that indicates loss of the RCS Any condition inthe opinion of the SEC that indicates potential loss of the barrier. E RCS barrier. E Does not include a release through the condenser air ejectors, or the gland steam condenser vents for the purpose of declaration of a SITE AREA EMERGENCY.
z EAL's in these tables are NOT complete. Refer to referenced basis page (PMP-2080-EPP-101, Attachment 3) for complete description.
Planning Standard D Revision 32
Page 61 of 221 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT Loss of TWO Fission Product Any TWO of the Following: Loss or Potential Loss of Either Fuel Clad Loss or Potential Loss of Containment Barrier.
Barriers AND Potential Loss of 1. Loss or Potential Loss of Fuel Clad. or RCS Barrier.
Third Barrier. 2. Loss or Potential Loss of RCS.
- 3. Loss of Containment Barrier.
- 3. CONTAINMENT BARRIER LOSS (L) POTENTIAL LOSS (P)
.1 Containment Radiation None > 1000 R/hr.
_Core damage > 20% clad failure.
.2 Containment Integrity Unisolable breach of containment. None OR Rapid unexplained containment pressure or sump level drop following pressure rise caused by a LOCA.
OR Containment pressure/sump level NOT performing as expected for conditions.
OR Entry into ECA-1.2, LOCA Outside Containment.
.3 SG Secondary Side Release Primary to secondary leak rate > Tech. Spec. limit. None AND Release of secondary coolant from the associated steam generator to the.
environment isoccurring:I
.4 Containment CSFST None Containment CSFST - RED
.5 Containment Hydrogen None >4.0%
OR Containment Hydrogen >0.5% AND any Hydrogen Control equipment inoperable.
.6 Containment Pressure Control None BOTH CTS trains OR BOTH containment air retire fans inoperable OR fail to auto start on their containment pressure setpoint OR containment pressure
>!2p~sig.
.7 Core Exit Thermocouples None Core Cooling CSFST -RED AND Restoration procedures; not effective within 15 minutes.
.8 SEC Judgment Any condition in the opinion of the SEC that indicates loss of the Any condition inthe opinion of the SEC that indicates potential loss of the Containment barrier. Y Containment barrier. X 1 Does not include a release through the condenser air ejectors, or the gland steam condenser vents for the purpose of declaration of a SITE AREA EMERGENCY.
Planning Standard D Revision 32
Page 62 of 221 Table 3 INITATING CONDITIONS - Mode 1 - 4 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT SEC Judgment - All Modes H-1 SEC Judgment H-1 SEC Judgment H-1 SEC Judgment H-1 SEC Judgment Conditions indicate actual or imminent substantial Conditions indicate likely or actual major failures Conditions indicate that plant safety systems may Conditions indicate a potential degradation of the core damage with potential loss of containment or of plant functions needed to protect the public, be degraded and additional personnel are needed level of safety of the plant.
the potential exists for an uncontrolled radioactive for additional monitoring.
release that may exceed EPA limits at the site boundary.
GENERAL EMERGENCY (SITE AREA EMERGENCY (ALERT UNUSUAL EVENT HAZARDS AND OTHER CONDITIONS H-2 Security H-2 Security H-2 Security H-2 Security HOSTILE ACTION resulting inLoss of Physical HOSTILE ACTION within the PROTECTED HOSTILE ACTION within the OWNER Confirmed Security Condition which indicates a Control of the Facility. AREA CONTROLLED AREA or airborne attack threat. potential degradation inthe level of safety of the plant.
- 1. A HOSTILE ACTION isoccurring or has I. A HOSTILE ACTION isoccurring or has 1.SECURITY CONDITION that does not 1.A HOSTILE ACTION has occurred such that occurred within the PROTECTED AREA as occurred within the OWNER CONTROLLED involve a HOSTILE ACTION as reported by plant personnel are unable to operate reported by the Security Shift Supervisor. AREA as reported by the Security Shift Security Shift Supervision.
equipmentlisted functions required to maintain safety below: .
Supervisor. OR O
- 2. A credible site-specific security threat
" Reactivity Control (ability to shut down OR notification.
the reactor and keep it shutdown) - 2. A validated notification from the NRC of a OR
" RCS Inventory (ability to cool the core) LARGE AIRCRAFT attack threat within 30 3. A validated notification from NRC
" Secondary Heat Removal (ability to minutes of the site. providing information of an aircraft threat.
maintain heat sink)
- 2. A HOSTILE ACTION has caused failure of spent fuel cooling systems and IMMINENT fuel damage is likely. E H-3 CR Evacuation H-3 CR Evacuation Control Room evacuated AND control not Control Room evacuation initiated.
established in 15 minutes. "z"_'
H-4 Fire H-4 Fire.
Fire OR explosion affecting plant operations. Fire inProtected Area NOT extinguished S within 15 minutes of detection.
H-5 Toxic Gas H-5 Toxic Gas Toxic OR flammable gas release that threatens Toxic OR flammable gas release lives OR affects ability to achieve and maintain affecting plant operation.
Mode 5.
H-8 ISFSI Damage to a loaded cask CONFINEMENT BOUNDARY.
Planning Standard D Revision 32.
Page 63 of 221 FGENERAL EMERGENCY I SITE AREA EMERGENCY -FALERT UNUSUAL EVENT NATURAL/DESTRUCTIVE PHENOMENA N-1 Seismic N-1 Seismic Seismic event indicated by: Seismic event indicated by:
1.Seismic instrument activated. I.Seismic instrument activated OR OR 2.Ground motion detected by Control Room crew 2.-round motion detected by Control Room AND crew.
I.Visble major damage in vital area.
OR 2.Plant Trip.
N-2 Tornado/wind N-2 Tornado/wind 1.Tornado strike in Vital Area I.Tornado strike within Protected Area.
OR 2.>90 mph wind for >15 minutes.
N-3 Structural Visible damage to a structure containing systems required to achieve and maintain Mode 5.
N-4 Vehicle Collision N-4 Vehicle Collision Vehicle collision affecting Vital Area. Vehicle collision affecting systems or structures within the Protected Area.
N-5 MT Failure N-5 MT Failure Main turbine generated missile penetrates Vital Area. Main turbine rotating component failure causes visible damage or damages generator seals.
N-6 Flooding Flooding in Vital Area affects safety related equipment.
N-7 Explosion Unanticipated explosion within Protected Area causes visible damage to permanent structures or equipment.
Planning Standard D Revision 32
Page 64 of 221 GENERAL EMERGENCY I SITE AREA EMERGENCY ALERT UNUSUAL EVENT ABNORMAL RADIATION LEVELS/EFFLUENTS R-1 Effluent release R-1 Effluent release R-1 Effluent release R-1 Effluent release Site boundary dose > 1 REM TEDE or 5 REM CDE to Site boundary dose > 100 mrem TEDE Unplanned Rad release >200X ODCM limits for Unplanned Rad release >2X ODCM limits for thyroid based on: or 500 mrem CDE to thyroid based on: >15 minutes based on: > 60 minutes based on:
- 1. Survey results 1. Survey results.
OR OR 1. Effluent Rad monitor 200X high alarm 1. Effluent Rad monitor 2X high alarm setpoint.
- 3. Effluent monitor readings >15 minutes 3. Effluent monitor readings >15 minutes. OR E 2. Release Rad monitor 200X high alarm 3. Gas or liquid sample results 2X ODCM release limit.
setpoint.
- 3. Gas or liquid sample results 200X ODCM release limit.
E R-2 Plant Rad level R-2 Plant Rad level Rad levels that impede plant operations based on: Unexpected reading on Area Monitor 1000X the 24 hr average.
1.> 15 mR/hr in Control Rm(s) /CAS OR 2.>100 mR/hr at remote S/D areas.
E R-3 Loss of level R-3 Loss of level Major damage to irradiated fuel or loss of level Uncontrolled lowering in refueling cavity, SFP that has or will uncover fuel outside of the reactor or Transfer Canal indicated by:
vessel based on:
- 1. Inability to maintain > 643'4" in SFP or Transfer Canal 1.Visual observation of levels. with irradiated fuel present OR OR 2.Rad monitor alarms 2. Inability to maintain > 643'4" in the refueling cavity OR with irradiated fuel in containment.
3.Level < 632'4" SFP or Transfer Canal.
___________________________ ______________________________E Planning Standard D Revision 32
Page 65 of 221 F GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT SYSTEM MALFUNCTIONS S-1 RPS failure S-1 RPS failure S-1 RPS failure
- 1. Auto and manual Reactor Trip fails from Auto and manual Reactor Trip fails. from Auto Reactor Trip fails AND manual trip Control Room AND Subcriticality and Core Control Room. successful from Control Room.
- 2. Subcriticality and Heat Sink CSFSTs are RED.
S-2 Loss of AC S-2 Loss of AC S-2 Loss of AC S-2.Loss of AC
- 1. Prolonged loss of all AC (A and D -T buses) AND Loss of all AC (A and D - T buses) for AC power supply to T buses reduced to a Loss of ALL OFF-SITE power (Auxiliary, Reserve Core Cooling CSFST- ORANGE. >15 minutes. single source for > 15 minutes. and 69kv Transformers) to the T Buses for > 15 OR minutes.
- 2. Loss of all AC (A and D - T buses) expected to last for > 4 hrs.
S-3Loss of DC power Loss of ALL vital DC buses AB AND CD for >
15 minutes (bus volts < 220v)
S-5Loss of Hot SD sys.
Loss of ability to achieve or maintain hot shutdown based on entry into:
1.OHP 4023.FR-H.1, Response to Loss of Secondary Heat Sink OR 2.OHP 4023.FR-C.1, Response to Inadequate Core Cooling.
Planning Standard D Revision 32
Page 66 of 221 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT SYSTEM MALFUNCTIONS S-6 Loss of Alarms S-6 Loss of Alarms S-6 Loss of Alarms Loss of ability to monitor alarms during 1.Loss of either: 1.Loss of either:
a transient indicated by: a. Safety system annunciator panels in a unit for > 15 minutes a. Safety system annunciator panels in a unit for >
- 1. Loss of Safety System annunciator panel(s) for -OR- 15 minutes:
> 15 minutes. b. A known loss of Attachment 2 Critical -OR-AND Parameters indications for > 15 minutes: b. A known loss of Attachment 2 Critical 2.A known loss of Attachment 2 Critical -AND- Parameters indications for > 15 minutes:
Parameters indications for > 15 minutes. 2. Additional monitoring is required. -AND-AND -AND- 2. Additional monitoring is required.
available (PPC, SPDS). a NO 3. Annunciator/Indicator PLANNED action. loss does not result from 3. Annunciator/Indicator-AND-loss does not result from aib -AND- PLANNED action.
AND 4. Either -AND-
- 4. A significant transient is in progress. a. A significant transient is in progress, 4. Compensatory Indications are available.
-OR-
- b. Compensatory Indications NQT available z
S-7 Degraded Clad I.RCS activity> 1.0 uCi/gramn 1-131 dose equivalent for > 48 hrs.
OR 2.RCS activity > 100/E uCi/gram.
S-8 RCS Leakage RCS leakage exceeds 10 gpm pressure boundary leakage, SG tube leakage or unidentified leakage OR
> 25 gpm identified leakage.
S-9 Tech Spec Unit not in required mode within LCO time limits.
S-10 Loss of Comm.
Unplanned loss of all on or off-site communications E
Planning Standard D Revision 32
Page 67 of 221 Table 4 INITIATING CONDITIONS - Mode 5 & 6 and Defueled GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT HAZARDS AND OTHER CONDITIONS H-I SEC Judgement H-i SEC Judgement H-1-SEC Judgement H-1 SEC Judgement Conditions indicate actual or imminent substantial Conditions indicate likely or actual major failures Conditions indicate that plant safety systems may Conditions indicate a potential degradation of the core damage with potential loss of containment or of plant functions needed to protect the public, be degraded and additional personnel are needed level of safety of the plant.
the potential exists for an uncontrolled radioactive for additional monitoring.
release that may exceed EPA limits at the site boundary.
H-2 Security H-2 Security H-2 Security H-2 Security HOSTILE ACTION resulting in Loss of Physical HOSTILE ACTION within the PROTECTED HOSTILE ACTION within the OWNER Confirmed Security Condition which indicates a Control of the Facility. AREA CONTROLLED AREA or airborne attack threat, potential degradation inthe level of safety of the plant.
1.A HOSTILE ACTION has occurred such that 1. A HOSTILE ACTION is occurring or has 1.A HOSTILE ACTION is occurring or has I. SECURITY CONDITION that does not plant personnel are unable to operate occurred within the PROTECTED AREA as occurred within the OWNER CONTROLLED involve a HOSTILE ACTION as reported by equipment required to maintain safety reported by the Security Shift Supervisor. AREA as reported by the Security Shift Security Shift Supervision.
functions listed below: Supervisor. OR
" Reactivity Control (ability to shut down the reactor and keep it shutdown) OR 2.A credible site-specific security threat
" RCS Inventory (ability to cool-the core) 2. A validated notification from the NRC of a notification.
- Secondary Heat Removal (ability to LARGE AIRCRAFT attack threat within 30 OR maintain heat sink). minutes of the site. 3.A validated notification from NRC OR providing information of an aircraft threat.
E
- 2. A HOSTILE ACTION has caused failure of spent fuel cooling systems and IMMINENT fuel.
damage is likely. E z
H-3 CR Evacuation H-3 CR Evacuation Control Room evacuated AND control not Control Room evacuation initiated.
established in 15 minutes. Z H-4 Fire H-4 Fire Fire OR explosion affecting plant operations. Fire inProtected Area NOT extinguished
_ _ __ within 15 minutes of detection.
H-5 Toxic Gas H-5 Toxic Gas Toxic OR flammable gas release that threatens Toxic OR flammable gas release affecting plant lives OR affects ability to achieve and maintain operation.
Mode 5.
H-8 ISFSI Damage to a loaded cask CONFINEMENT I BOUNDARY Planning Standard D Revision 32
Page 68 of 221 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT NATURAL/DESTRUCTIVE PHENOMENA N-1 Seismic N-1 Seismic Seismic event indicated by: Seismic event indicated by:
I.Seismic instrument activated.
1.Seismic instrument activated.
OR OR 2.Ground motion detected by Control Room crew. 2.Ground motion detected by ControlRoom AND crew.
l.Visble major damage inVital Area.
OR 2.Plant Trip.
N-2 Tornado/wind N-2 Tornado/wind I.Tomado strike in Vital Area I.Tomado strik-e in Protected Area.
OR 2>90 mph wind for >15 minutes.
N-3 Structural Visible damage to a structure containing systems required to achieve and maintain Mode 5.
N-4 Vehicle Collision N-4 Vehicle Collision Vehicle collision affecting Vital Area. Vehicle collision affects systems or structures inthe Protected Area.
N-5 MT Failure N-5 MT Failure Main turbine generated missile penetrates Vital Area. Main turbine rotating component failure causes visible damage or damages generator seals.
N-6 Flooding Flooding in Vital Area affects safety related equip.
N-7 Explosion Unanticipated explosion within Protected Area causes visible damage to permanent structures or equipment.
Planning Standard D Revision 32
Page 69 of 221 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT ABNORMAL RADIATION LEVELS/EFFLUENTS R-1 Effluent release R-1 Effluent release R-1 Effluent release R-1 Effluent release Site boundary dose > 1 REM TEDE or 5 REM Site boundary dose> 100 mrem TEDE Unplanned Rad release >200X ODCM limits for >15 Unplanned Rad release >2X ODCM limits for CDE to thyroid based on: or 500 mrem CDE to thyroid based on: minutes based on: > 60 minutes based on:
l.Suveyresuts1 .Survey results results O.Survey OR 1. Effluent Rad monitor 2X high alarm setpoint 2.Dose assessment 2.Dose assessment 1.Effluent Rad monitor 200X high alarm setpoint. OR OR OR OR 2. Release Rad monitor 2X high alarm setpoint 3.Effluent monitor readings >15 minutes 3.Effluent monitor readings >15 minutes. 2. Release Rad monitor 200X high alarm setpoint. OR OR 3. Gas or liquid sample results 2X ODCM release limit.
- 3. Gas or liquid sample results 200X ODCN release limit.
I:
R-2 Plant Rad level R-2 Plant Rad level Rad levels that impede plant operations based on: Unexpected reading on Area Monitor 1O0OX the 24 hr average.
1.> 15 mR/hr in Control Room(s) or CAS OR
- 2. >100 mR/hr at remote S/D areas.
R-3 Loss of level R-3 Loss of level Major damage to irradiated fuel or loss of Uncontrolled lowering in refueling cavity, level that has or will uncover fuel outside of SFP or Transfer Canal indicated by:
the reactor vessel based on:
I.Visual observation of levels. I. Inability to maintain > 643'4" in SFP or Transfer OR Canal with irradiated fuel present 2.Rad monitor alarms OR OR 2. Inability to maintain > 643'4" in the refueling cavity 3.Level < 632'4" SFP or Transfer Canal. with irradiated fuel in containment.
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Page 70 of 221 GENERAL EMERGENCY SITE AREA EMERGENCY [ ALERT [UT-uNUSUAL EVENT COLD SHUTDOWN/REFUELING SYSTEM MALFUNCTIONS C-3 Loss of AC C-3 Loss of AC Loss of ALL AC power to A and D T-buses for Loss of ALL OFF-SITE power (Auxiliary,
> 15 minutes. Reserve and 69kv transformers) to the T buses for> 15 minutes.
Mode 5,6 Mode 5,6 and defueled C-4Loss of Water Level in the Reactor Vessel C-4 Inability to Maintain a Unit in that has or will Uncover Fuel in the Reactor Cold Shutdown Vessel 1.Loss ofshutdown cooling as evidenced by entry i.Loss of shutdown cooling as evidenced by entry into OHP into OHP 4022.017.001, "Loss of RHR 4022.017.001, "Loss of RHR Cooling" Cooling" AND AND 2.Core uncovery as indicated by: 2.Temperature rise that either:
- b. Reactor Vessel Water Level <614 feet b. Results in an UNCONTROLLED RCS temperature rise approaching the cold Mode 5,6 shutdown T/S limit of200'F Mode 5,6 C-5 Degraded Clad l.RCS activity >i.0ý.Ci/grams 1-131 dose equivalent for > 48 hrs.
OR 2.RCS activity> 100/E uCi/gram.
Mode 5,6 C-6 Loss of Comm.
Unplanned loss of all on or off-site communications.
Mode 5,6 C-7 Loss of DC power Unplanned loss of ALL vital DC buses AB AND CD for >15 minutes (bus volts _<220v)
Modes 5,6 Planning Standard D Revision 32
Page 71 of 221 PLANNING STANDARD E NOTIFICATION METHODS AND PROCEDURES Planning Standard E Revision 32
Page 72 of 221 E. NOTIFICATION OF EMERGENCY RESPONSE PERSONNEL AND ORGANIZATIONS E. 1. Notification of Offsite Response Organizations During an emergency condition, control of offsite actions rests with the appropriate government authorities with technical assistance provided by various members of the plant staff. This technical assistance is provided through the use of the plant's communication system.
A current list of all key support agencies with their telephone numbers is maintained in the Shift Manager's office so that they may be notified of any emergency condition. This call list is incorporated into the plant Emergency Plan Procedures and is checked quarterly to verify that all phone numbers on the list are correct. It is the responsibility of the SM, acting as the SEC early in an event, the SEC, or the ED, once the EOF is operational, to ensure that these offsite response organizations are notified. Notification shall include the message authentication in order to permit further action by the Sheriffs Department.
Notification is given to the Berrien County Sheriffs Department and to the Michigan State Police Operations Office in Lansing, Michigan within 15 minutes following the recognition and verification of an Unusual Event, Alert, Site Area Emergency, or General Emergency condition. Any incident that requires initiation of the Nuclear Emergency Alarm requires notification of the NRC and notification of the appropriate offsite groups.
Upon notification with authentication, the Berrien County Emergency Operations Plan will be implemented.
The Berrien County Sheriffs Department has established a county Emergency Operating Center (EOC) in Benton Harbor, Michigan, which will be the focal point for immediate offsite county agency actions when notified of an emergency condition. The Berrien County Sheriff is the Berrien County Administrator of the Office of Emergency Management/Homeland Security and is responsible for coordinating all local resources when notified of an emergency condition. An offsite liaison is sent to the Berrien County EOC at the emergency classification of Alert or higher classification. The liaison assists in the interpretation of incoming plant reports, and acts as the liaison between the Plant and the Berrien County Sheriff's Department.
The organization of the Department of State Police is such that initial notification is made to the State Police Operations Office in Lansing, Michigan, The Michigan State Police will then set up an EOC at 4000 Collins Road in Lansing, Michigan. An offsite liaison will also be sent to the State EOC upon activation by the State Police to perform a function similar to that of the person at the Berrien County EOC. Plant status updates will be provided to the State and County using separate lines. All communications, where practical, to the State and County will be via the offsite liaison at their respective EOCs.
Immediately following the initial notification of the Berrien County Sheriffs Department and the Michigan State Police, the SM/SEC/ED shall also notify the Nuclear Regulatory Commission's Operations Center, and the appropriate senior AEPNGG management.
The decision to evacuate offsite individuals or to take other protective action rests with the appropriate civil authorities. The SEC or ED is responsible for notifying the appropriate State/County authorities that the conditions for offsite protective actions have been reached.
Figure 8 shows the initial notification process for nuclear incidents. A current list of all appropriate company officials and county, state and federal authorities with their telephone numbers is maintained as part of the plant ERO Phone Directory. A listing of offsite support groups is attached as Appendix B.
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Page 73 of 221 E.l.a Notification of Nuclear Transportation Accidents Incidents involving nuclear material that result from transportation accidents offsite as specified in Section C.4.b and within the service territory of AEP shall be reported to the applicable state government. The appropriate information required in Sections E.3 and E.4 and other pertinent information shall be provided as necessary. If the Plant has been requested to respond to a transportation accident involving nuclear material by another utility under the Voluntary Assistance Agreement, the Plant shall inform the state and Berrien County government of the request, nature and location of the accident, expected response and recommended precautions to be taken by the responsible offsite authorities.. The response team shall keep the on-scene government representatives and the Plant informed on the status of the accident.
E.2 ERO Alert, Notification and Mobilization E.2.a Onsite (Plant Staff)
If an emergency condition should arise that would affect individuals on or offsite, this emergency plan will be initiated. There are two plant emergency alarms: A Fire Alarm and a Nuclear Emergency Alarm. Each audible signal is unique and easily distinguishable so that no confusion as to its purpose will develop.
If the incident or condition is a fire, the Fire Alarm is sounded.
The Nuclear Emergency Alarm is a horn designed to produce a distinct sound different from any other alarms in the plant. It may be activated manually from either the Unit 1 Control Room or Unit 2 Control Room. The senior supervisor of the on-duty shift (e.g., the Shift Manager) has the authority to activate the Nuclear Emergency Alarm. In the absence of the Shift Manager, the senior NRC licensed operator assigned in the Control Room has the authority to activate the Nuclear Emergency Alarm. An announcement over the Plant Public Address System (PA) identifying the incident will be made including a brief description of the incident, and the appropriate alarm for the determined condition will be sounded throughout the plant and at the switchyard. In addition, in. certain areas where the PA system and/or the Nuclear Emergency Alarm are not audible, strobe lights are installed to provide a visual warning signal.
In the case of some Security events, the Nuclear Emergency Alarm would not be sounded.
Persons responding to the NEA could become targets of opportunity. Instructions to onsite personnel would be made using the Plant PA system.
Immediate sounding of the Nuclear Emergency Alarm is required for incidents which, in the judgment of the Shift Manager, result in:
" release of radioactivity that could cause conditions for excessive exposure to plant personnel, or
" plant conditions that could cause conditions for excessive exposure to plant personnel, or
" a Site Area Emergency, or General Emergency, except where harm to personnel is possible (e.g. Security event driving the SAE or GE).
The sounding of the Nuclear Emergency Alarm dictates an immediate evacuation of all plant personnel and plant visitors to the onsite assembly areas identified in Section J.1. with the exceptions that:
- 1. The operators on duty for each unit report to their respective Control Room.
- 2. Personnel designated as part of the Plant Emergency Response Organization report to their assigned facilities. (i.e. TSC, OSC, EOF, ENC/JIC)
Planning Standard E Revision 32
Page 74 of 221
- 3. Individuals in outlying areas of the plant are informed by Site Protective Services of the emergency classification in effect and the action to be taken.
- 4. Security personnel will remain on post unless otherwise directed.
- 5. Initiation of the procedures for evacuation of all employees and visitors within the Cook Energy Information Center.
Immediately after initiation of the Nuclear Emergency Alarm, the emergency call list is initiated, if not already initiated, and measures are taken by the Shift Manager and Shift Technical Advisor to evaluate conditions on the site.
The decision to take onsite protective actions, beyond sounding of the Nuclear Emergency Alarm is the responsibility of the SEC. Any Emergency Plan incident other than routine tests that requires initiation of the Nuclear Emergency Alarm requires notification of the NRC by the SEC or ED and notification of appropriate offsite groups as determined by the SEC or ED.
E.2.b Offsite (Plant Staff)
An Emergency Plan Procedure for notification of plant personnel and an ERO Phone Directory have been developed to provide the information that is necessary to summon plant personnel during emergency conditions to staff the Emergency Response Facilities. This procedure may be implemented anytime the SEC determines that it is necessary to augment on duty emergency personnel with off-duty plant personnel.
A current list of all key personnel with their telephone numbers is maintained in the Shift Manager's office so that they may be notified. This call list is incorporated into the ERO Phone Directory and is checked quarterly to verify that all phone numbers on the list are correct. When the Nuclear Emergency Alarm is sounded, notification of the Site Vice President (or Alternate),
and Operations Director is the responsibility of the Shift Manager or designee. Calls made by on-shift personnel initiate the ERO call out to staff the Emergency Response Facilities. If the automated paging/call out fails, a backup manual call out procedure is initiated.
Personnel that are called out, or are on call, report to their assigned Emergency Response Facility immediately upon receiving notification to respond at an Alert or higher emergency classification.
In the event of security related event the notification alerts the emergency response personnel, who normally report to on-site facilities, to report to an alternate location such as the Buchanan Office Building.
Once the Nuclear Emergency Alarm has sounded, only authorized personnel are permitted to enter the Owner Controlled Area. This access control is a function of the Plant Security Force which may be further augmented by the Berrien County Sheriff and/or the Michigan State Police.
E.3. Content of Initial Emergency Messages Initial emergency messages sent from the Plant to appropriate offsite response organizations shall contain the information listed below, as it becomes available.
- 1. Class of Emergency.
- 2. Date and time of classification.
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Page 75 of 221
- 3. Indicate if a release is occurring or has occurred.
- 4. Wind direction and wind speed.
- 5. Protective Measures recommended (if known) based on magnitude or severity of an actual release and current meteorological conditions, or the condition of the core/containment.
- 6. Potentially affected population areas.
- 7. Plant name
- 8. Verification to confirm authenticity of call.
E.4 Content of Follow-up Emergency Messages Follow-up messages sent from the Plant to appropriate offsite response organizations should contain the following information, as it becomes available:
- 1. Location of incident, name and telephone number (or communication channel identification) of caller.
- 2. Type and description of release (airborne, waterborne, surface spill) and estimated duration/impact times (actual or projected).
- 3. An estimate of the quantity of radioactive material released or being released and the release point.
- 4. Physical form of released material, including estimates of the relative quantities of noble gases; iodines and particulates.
- 5. Meteorological conditions (wind speed, direction, atmospheric stability, or precipitation,* if any).
- 6. Projected dose rate at site boundary, integrated dose from time of message to projected end of release at site boundary.
- 7. Projected dose rate and integrated dose for 2, 5 and 10 miles.
- 8. Prognosis for worsening or terminating the event based on plant information.
E.5 Not Applicable E.6. Public Notification The Berrien County Sheriff is responsible for overall supervision of the warning function for offsite actions.
The Berrien County Emergency Operations Plan-Nuclear Power Plant Incident Procedures contain the time estimated for adverse and favorable conditions for various sectors in the 10 mile EPZ for 2 mile, 5 mile, and 10 mile radii. The time estimates include the times required for:
- Notification
- Public Preparation Planning Standard ER Revision 32
Page 76 of 221
- Movement
- Total Evacuation
- Confirmation
- Evacuation & Confirmation Special Considerations to include or consider in each sector The Berrien County Plan includes provisions for:
- 1. Alerting local radio, television stations and, local news media to be prepared to transmit Emergency Public Information. This initial notification will be accomplished via a radio receiver/transmitter that will record the emergency information transmitted by the Sheriffs Department to designated locations simultaneously. Additional information will be provided as described in Section G.
- 2. Coordination with other law enforcement and fire services to extend public notification of the appropriate Emergency Plan areas utilizing public address systems on emergency vehicles.
- 3. Warning of the Warren Dunes park (recreation) area populace of the emergency and action to be taken.
- 4. Activation and use of the emergency warning system consisting of sirens located throughout the 10 mile EPZ. Activation of this system is controlled solely by the Berrien County Sheriff and is based upon recommendations made by the appropriate authority.
The D. C. Cook Plant Emergency Preparedness Department has overall responsibility for testing, maintenance, and repair of the Alert and Notification System (ANS) Sirens.
The ANS is the primary method for alerting and notifying the population within the plume exposure EPZ. Backup ANS for the EPZ is achieved through Route Alerting which is contained within the State of Michigan and Berrien County Radiological Emergency Response Plans. Refer to Appendix B for FEMA letter describing the provisions for backup ANS.
A description of the warning system is in the emergency preparedness brochure/calendar provided in Appendix D, Emergency Preparedness Brochure.
E.7. Public Information Messagqes The State of Michigan and Berrien County have developed and incorporated in their respective emergency plans sample messages for release of information to the public.
These messages will utilize supporting information obtained directly from the Plant or from the plant liaison persons located at the Berrien County EOC, State EOC and at the JIC (when activated).
Using the information gathered from various sources, the message(s) will contain pertinent information to the public for the declared emergency classification. The message(s) describe the Planning Standard E Revision 32
Page 77 of 221 warning, sheltering, evacuation and other protective measures deemed necessary by the appropriate County and/or State officials.
Additionally, Berrien County has prepared sample Public Information Bulletins to provide pertinent information on protective actions that may be taken in the event of a nuclear incident. These bulletins are shown in the Berrien County Emergency Plan.
Planning Standard E Revision 32
Page 78 of 221 Figure 8 Nuclear Incident Initial Notification Process
-j
- Selectively notified for support Planning Standard E Revision 32
Page 79 of 221 Figure 9 CNP Emergency Response Communications Flow CONTROL TCMA F ROOM SUPPORT CENTER EMERGENCY NEWS CENTEý:A.
OPERATIONS JOINT INFORMATION - -
SUPPORT CENTER -
CENTER
.- ' STATE
.- `COMMUNICATIONS I- COORDINATOR I !
NEWS EMERGENCY MEDIA &
NRC OPERATIONS PUBLIC FACILITY GOVERNOR ICP NSSS/FUEL PROVIDER(S)
STATE EOC . 0 CONSULTANTS SBERRIEN BERRIEN... 4 AMERICAN 10N[ RR NUCLEAR Planning Standard E Revision 32
Page 80 of 221 PLANNING STANDARD F EMERGENCY COMMUNICATIONS Planning Standard F Revision 32
Page 81 of 221 F. EMERGENCY COMMUNICATIONS F.1. Licensee, Local, State, and NRC Emergency Communications Implementation procedures for the use of communication networks to notify all parts of the emergency organization are outlined in the CNP Emergency Plan Procedures that are available in each of the emergency response facilities. The communications network consists of communications systems that are available on a 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day basis to communicate with AEP personnel, State, County, and the NRC during emergency conditions.
F.l.a. State and Local Communications The Berrien County Sheriffs Department and the Michigan State Police dispatch are continuously staffed so capability exists for 24-hour radio and telephone communication with the Plant. The telephone and radio links to the Berrien County Sheriff's Department dispatchers also accesses the county emergency response organizations. The 911 system is an alternate method to access the county emergency response organizations.
The primary means of notification to the Sheriffs Department is by telephone. As an alternate, notification of an emergency to the Sheriffs Department in Berrien County is made with a transmitter and receiver combination device from the Unit 1 Control Room. This device is operated with a frequency and a license maintained by the State of Michigan. Controls for the device are also available on the Plant Security consoles. This establishes a communication link between the Control Room and the Sheriff's Department in Berrien County.
The primary means of notification. to the State Police Operations Center in Lansing is by telephone. A back-up radio system is maintained between CNP and the Michigan Department of State Police in Niles, Michigan. In this system, a radio transceiver maintained at the CNP is set at a frequency used by the State Police. These radios are equipped such that the State Police are assured that any transmissions to them originated at the Cook Plant.
Communications between CNP and the local fire departments are by means of telephone calls.
The fire departments would respond immediately upon notification of an emergency at CNP.
Radio Radio communication capability is provided to contact the Berrien County Sheriffs Department and the Michigan Department of State Police Post 53 (in Niles) from the Unit I Control Room, Central Alarm Station (CAS), and the Secondary Alarm Station (SAS) in the event of failure of telephone company circuits. Suitable normal and back-up power supplies are also provided.
Bridgman Local Telephone Service.
Local commercial telephone service provides circuits between Bridgman and the CNP.
F.l.b. Communications with Contiguous Governments in the EPZ's Notifying the State of Indiana and the Michigan counties within a 50 mile radius of CNP of the incident classification, protective actions recommended, etc. is the responsibility of the Berrien County Sheriff's Department and the Michigan Department of State Police. Berrien County and Michigan is the only county and state within a 10 mile radius of CNP.
Planning Standard F Revision 32
Page 82 of 221 F.1.c. Communications with Federal Emergency Response Organizations The "Communications" section of Appendix E, Description of Federal Radiological Assistance, outlines communication with the DOE Radiological Assistance Plan responders.
F.l.d Offsite Communications The communications system at CNP provides the versatility required in the event of a nuclear incident. The system operation utilizes private telephone lines, dedicated microwave links (OPX),
2-way radio, the normal in-plant communication system (PABX), and the capability to reach outside extensions through various system company switchboards. The emergency response centers will have the following communications capability:
PABX/ OPX Private Fire/Emer. Offsite ENS HPN Microwave Lines Radio Radios Control Room X X_ X X X TSC (53) X X X X X X OSC X X x EOF I X1 X X X X X Plant Mgr's Office X ENC/JIC X X 1 The EOF utilizes the Buchanan Office Building PABX and has access to a local commercial provider and AEP microwave capability.
2 Two telephone lines in each Control Room automatically bypass the plant PABX if it fails.
Communications between CNP and the Offsite Survey Team(s) are made by portable radios.
These radios are maintained in the dedicated survey vehicles, emergency facilities, and are assigned for use to plant operating departments.
AEP Microwave/Fiber Optics System This system allows direct communication to major media stations and AEP offices. It provides fast and reliable support for the plant in the event of an emergency. The CNP switchboard has "tie trunks" to Buchanan, Michigan and Fort Wayne, Indiana. Direct, dedicated microwave channels are established 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day between Cook Plant, and both Fort Wayne, Indiana and Buchanan, Michigan.
The microwave facilities at CNP are powered by their own battery that is constantly serviced by a trickle charger, powered from an AC station auxiliary. In the event of a failure in this AC line, an emergency generator automatically takes over the supply of power to the charger. The battery alone is capable of operating the microwave facilities for approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
F.l.e. Alerting and Activating Emergency Response Organization and Personnel Plant Public Address System The Plant Public Address (PA) System is powered by the Critical Control Room Power Supply and is automatically switched to a backup supply from the diesel generator in the event that the normal power supply is lost.
The Plant PA System provides paging to all major buildings of the plant including the office and service building. This system includes a five-party channel system for two-way communications.
Planning Standard F Revision 32
Page 83 of 221 It should be noted that this system cannot be used to notify offsite persons of an incident. Other systems are available for this use.
Plant Private Automatic Branch Exchanqe Plant Telephone System The Private Automatic Branch Exchange Plant Telephone System (PABX) is powered by its own battery on a trickle charger. PABX System installations are located in areas most frequently occupied by plant personnel, including the plant's emergency response organization.
Security Radio A portable radio system is installed for security communications. This system uses dual transmitters to provide a dual frequency capability. Radio coverage includes all general areas onsite. If necessary, this system can be used as a back-up means of communication onsite in the event of an emergency.
Fire and Emergency Radio A portable radio system is installed for fire and emergency communications. This system is powered from a non-emergency bus and provided with backup battery power. The fire and emergency radio coverage includes all general areas onsite, excluding containment. This system is also utilized for medical emergencies, field team communications, etc.
F.1.f Emergiencv Communications with the NRC Communications with the NRC Headquarters is by dedicated telephone lines from the Control Rooms, TSC, and EOF. The Federal Telecommunications System (FTS) is used to communicate with NRC Headquarters, in White Flint, Maryland. Communications with Region III headquarters, located in Lisle, Illinois, is by commercial telephone lines .and the FTS.
A FTS telephone line has been installed between the Plant and the NRC, which is primarily intended for use during an emergency and will function as the Health Physics Network (HPN) dedicated line. A total of three extensions are located at AEP facilities in:
NRC Resident Inspector's Office TSC EOF This line will be utilized to provide specific information to the NRC regarding significant radiological events at the Plant. Information transmitted to the NRC, excluding that originating from the Resident Inspectors Office, must be approved by the appropriate emergency response management personnel prior to its transmittal.
The HPN telephones will be staffed by the licensee.
Emergency Notification System (ENS)
The Emergency Notification System (ENS) is intended for use as the primary means for the Plant to report emergencies and other significant events to the NRC. This FTS line will serve as a dedicated line to provide operational data to the NRC during a declared emergency.
Planning Standard F Revision 32
Page 84 of 221 A total of five extensions are located at AEP facilities in:
TSC Control Rooms NRC Resident Inspector's Office EOF Communications over the ENS telephone will be initiated by Control Room personnel if a nuclear emergency occurs at CNP. Licensee personnel will staff the ENS telephones at the EOF when the EOF is activated.
Emerqency Response Data System (ERDS)
The Emergency Response Data System (ERDS) is a direct electronic data link between CNP computer systems and the NRC Operations Center. It is activated during the declaration of an Alert or higher emergency classification. Types of data transmitted include information on the plant's primary and secondary coolant systems, safety injection system, and radiation monitoring systems. Data is updated at approximately 5-second intervals.
F.2 Medical Support Communications Communications between CNP and the offsite medical facilities are made by telephone calls and are authenticated for contaminated patients only.
F.3 Communications Systems Testing Communication links between the NRC Operations Centers and the CNP TSC and EOF via the Emergency Notification System (red phone) are tested monthly for operability. In addition, the Control Room communication link with the NRC Operations Centers is tested for operability on a daily basis.
Communication links between the Plant and Berrien County Sheriffs Department, and the Michigan Department of State Police have been established and are tested monthly at a minimum.
Communications with Offsite Survey Teams will be tested at least annually to ensure an understanding of the content of the messages in the drills.
The majority of the. communications systems are tested on a daily basis through normal use. The radio communications to the Berrien County Sheriffs Department and Michigan Department of State Police are tested daily. An annual drill is conducted with the offsite emergency response personnel including those of State and County agencies if these authorities desire to participate.
As a minimum, each annual drill (exercise) tests the communication links and notification procedures with State and County agencies to ensure the proper flow of information in the event of a nuclear incident.
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Page 85 of 221 PLANNING STANDARD G PUBLIC EDUCATION AND INFORMATION Planning StandardyQ Revision 32
Page 86 of 221 This page intentionally left blank Planning Standard G Revision 32
Page 87 of 221 G. PUBLIC EDUCATION AND INFORMATION The utility industry's experience has consistently shown that offsite public reaction is more favorable when information originates with the utility, and that notification of appropriate county, state and federal agencies is made prior to any public announcement to ensure that the information presented is fully understood by all parties and does not conflict with news reports and information transmitted to any agencies by other sources. Press briefings will be arranged in conjunction with appropriate agency officials to permit a consistent and timely exchange of information.
The ENC/JIC personnel manage information release on the incident by:
" Gathering information on the incident, preparing, and approving information releases to the media.
" Providing a single location for use by the media for obtaining information about the incident.
- Monitoring the broadcast media for discrepancies between approved media releases and broadcast information.
- Answering questions posed by callers to the Public Inquiry telephone lines.
The ENC/JIC facility shall be activated for any Alert, Site Area Emergency, or General Emergency. The goal is to have ENC/JIC staffed approximately 90 minutes after declaration of an Alert, Site Area Emergency, or General Emergency.
G.1. Public Information American Electric Power (AEP) annually distributes emergency educational information to the public within the Emergency Planning Zone (EPZ) in conjunction with Berrien County and the Michigan Department of State Police - Emergency Management and Homeland Security Division. Such information includes the warning methodology used in notification of the public, educational information on radiation, personnel or agencies to contact for additional information, and sheltering and evacuation procedures used in the event of a nuclear incident. Appendix D is an example of the emergency educational information material that is distributed annually.
G.2 Distribution of Public Information The above emergency educational information was distributed to the public initially and is updated annually. This information is sent to all Berrien County residences and businesses, as well as Niles and other locations served by municipal power. This mailing includes those living and working both inside and near the 10 mile EPZ. New electric service customers are sent a copy of the emergency educational information and are added to the annual mailing.
The brochure is also distributed to Warren Dunes State Park, local motels, hotels, nursing homes, marinas, and apartment complexes. Selected camping and recreational areas that are part of the 10 mile EPZ most frequently used by large segments of the transient population will also be provided with similar information. The Cook Energy Information Center Manager is responsible for the annual distribution of emergency educational information to the public within the 10 mile EPZ.
G.3. Emergency News Center/Joint Information Center (ENC/JIC)
The Emergency News Center/Joint Information Center (ENC/JIC) provides a single location for issuing information on incidents and Company response about incidents to the news media.
Planning Standard / C Revision 32
Page 88 of 221 The Emergency News Center/Joint Information Center (ENC/JIC) is located in the Nuclear Generation Group Headquarters Building located approximately 14 miles southeast of the plant site in Buchanan, Michigan. The ENC/JIC shares the first floor of the building with the EOF.
Media access is allowed to an auditorium area, media work area, and lobby area of the building through a guarded main entranceway. Access to all other areas and entrances to the building are locked, barricaded, or guarded to prevent media intrusion into the EOF, corporate offices, or the ERO staffed portion of the ENC/JIC.
The auditorium provides the location for briefings by the utility Spokesperson and representatives of any other agencies responding to the incident. Space and electrical power are provided for media cameras to be set up for broadcasting briefings. An area adjacent to but separate from the auditorium is set up as a media work area with desks, chairs, and phones for media use, as well as distribution of press kits and copies of releases.
A Support Staff area is set up adjacent to, but separate from the auditorium and areas accessible to the media, for communicators, statement writers and others working to support ENC/JIC operation. Fax machines, telephone lines and computers are set up to support obtaining current information and preparing press statements.
GA. ENC/JIC Spokespersons and Public Inquiry G.4.a. Spokesperson Information Later in the event as off-site agencies activate, the ENC/JIC becomes the single location for coordinated response to the news media by the spokespersons of the Company, local and state government, the NRC, and any other agencies responding to the incident. The ENC/JIC does not become a Joint Information Center until after the declaration of a Site Area Emergency and when a representative from the state is present and declares the JIC activated.
G.4.b Spokesperson Information Exchange The ENC/JIC is staffed to provide for media release preparation and presentation, media monitoring, and public inquiry. The ENC/JIC staff also provides for support of off-site agency responders to the facility as well as support for the media representatives that use the facility.
G.4.c. Public Inquiry A Media Monitoring and Public Inquiry area is set up with radios, televisions, and telephones.
Media Monitors watch releases televised by the local media and listen to radio reports for any inaccurate information. Public Inquiry Communicators record and respond to any questions called in to the Public Inquiry extensions.
G.5 Annual Media Briefing Information is sent annually to the local news media to explain the emergency preparedness plans of the State, County, and utility. This is sent just prior to the annual Cook Emergency Plan exercise and invites the media to participate in the exercise. The role of the media in providing emergency information to the public is also explained.
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Planning Standard?( 6ý Revision 32
Page 89 of 221 PLANNING STANDARD H EMERGENCY FACILITIES AND EQUIPMENT Planning Standard.H Revision 32
Page 90 of 221 H. EMERGENCY FACILITIES AND EQUIPMENT Plant personnel who are needed and are not onsite will be notified of the existing plant condition and will be directed to report to one of the following locations:
1 TSC 2 EOF 3 OSC 4 Or an alternate location in the event of unsafe plant conditions.
H.1. Technical Support Center H.l.a. TSC Functions The onsite Technical Support Center (TSC) provides plant management and technical support to plant operations personnel during emergency conditions from a location outside the Control Room.
During the short-term emergency conditions, the TSC is capable of serving the following purposes until all required response centers both on and offsite have been activated.
- Providing technical support to operations personnel as requested..
- Directing the activities of site personnel.
" Evaluating offsite agency requests and recommendations to ensure compatibility with emergency response objectives.
The TSC shall be activated for any Alert, Site Area Emergency or General Emergency.
The TSC, combined with the Control Room, can perform the functions of the EOF until the EOF is activated.
Sufficient data to determine the plant steady state and dynamic behavior prior to and throughout the course of an accident is available for analysis in the TSC. TSC personnel shall have ready acces.s to plant records and procedures to support detailed technical analysis and evaluation of plant conditions.
The TSC facilities may be used by plant personnel for normal daily operations as well as for training and emergency drills provided that these activities do not interfere with the immediate activation of the TSC or the continuing TSC operations in the event of an accident.
The primary NRC role in the TSC will be supportive, advisory, and observational.
H.l.b. TSC Location The TSC is located adjacent to the Control Room to readily allow face-to-face interaction between Control Room personnel and the senior plant management working in the TSC. (See Figures 10 and 11)
An alternate location for the TSC is the Buchanan Office Building in the event of unsafe conditions at the plant.
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Page 91 of 221 H.1.c. TSC Staffing The TSC is staffed to provide technical support to the Control Room operating staff during accidents. The number and type of personnel assigned to the TSC and their time of arrival in the TSC may vary according to the emergency class. The TSC staff assignments are contained in Section B. The SEC, or in the absence of the SEC, the Assistant SEC shall coordinate activities in the TSC and interface with the Control Room and the EOF.
H.l.d. TSC Design The CNP TSC-is located in the Turbine Building adjacent to the two Control Rooms. This location readily allows for face-to-face interaction between the Control Room personnel and TSC personnel. Because of the proximity of the TSC to the Control Room, it will normally take less than 2 minutes to travel from one facility to the other. The lower level of the TSC (elevation 634')
is comprised primarily of the Shift Manager's Office and a briefing room. The upper level (elevation 643') houses the Plant Evaluation Team area which contains the computer consoles, communications area, and a separate office with sufficient working space for five NRC representatives. The staffing and use of the TSC has been tested in emergency exercises with the result that there is sufficient space for plant emergency personnel to perform their assigned functions.
The TSC has been constructed to provide the same degree of radiological habitability as the Control Room under accident conditions. Concrete shielding has been provided to significantly reduce the effects of containment building radiation shine during an accident. Radiation monitoring is provided to indicate radiation dose rates as well as airborne radioactivity levels.
The CNP TSC has been designed to:
- 1. Provide technical support to plant operations personnel during emergency conditions.
- 2. Relieve the reactor operators of peripheral duties not directly related to reactor system manipulation.
- 3. Prevent congestion in the Control Room.
- 4. If necessary, perform EOF functions for an Alert, Site Area Emergency or General Emergency until the EOF is fully functional.
The following communication systems have been provided in the TSC:
- Offsite emergency radio to communicate with the Offsite Survey Teams as well as with in-plant teams, and EOF.
- Dedicated line on the NRC Health Physics Network (HPN) and two dedicated lines on the NRC Emergency Notification System (ENS).
- Plant intercom/PA System.
" Dedicated communication circuit to the Control Room, OSC and EOF.
" Fax capability.
" 2 private lines off the CNP PBX are dedicated for NRC use with outside capability.
- Additional telephones to be used as needed.
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Page 92 of 221 The TSC will not contain, but will have ready access to plant records, drawings and other documentation as required. The concept of operation of the AEP Emergency Response Organization is described in Section A.i.b.
H.l.e. TSC Data Availability Personal Computers and printers are available in the TSC that allow access to the plant LAN, stand alone programs, and access to Plant Process Computer information.
H.1.e.1 Plant Process Computer (PPC)
The CNP Plant Process Computer (PPC) System has been developed and designed using the guidelines of NUREG-0696 and NUREG-0737, Supplement 1 to provide the plant operating and technical support personnel with the pertinent plant information to facilitate the emergency response to an accident in a timely manner and to assess the status of the critical safety functions. This system can also be used during normal plant operations for other functions such as plant performance analysis and personnel training.
The PPC network is a data gathering, analysis, and display system that interfaces with multiple computer systems. This system consists of two similar computerized data acquisition, processing and display systems, one for each unit. The Unit I and Unit 2 PPCs acquire, validate, and convert analog, digital, pulse, and sequence of events. inputs from process instruments into engineering units. In addition, data is acquired from the RMS, MIDAS, and from various recorders located throughout the plant. The Unit 1, Unit 2, and Simulator PPCs and the Realtime Data Repository (RDR) computers are part of a computer network. The PPC network is used to send emergency response data to the NRC via ERDS. The Safety Parameter Display System (SPDS) is also a function that is performed by the PPC network.
The PPC system information is accessed with personal computers that access the PPC through the Real Time Data Repository (RDR)-system and the information so obtained is usually referred to as PPC data. PCs that have access to the PPC in this fashion are available in the Control Rooms, TSC, OSC, ENC/JIC, and the EOF.
H.1.e.2. Emer-qency Response Data System Emergency Response Data System (ERDS) is a direct electronic data link between CNP PPC system and the NRC Operations Center. It is activated during the declaration of an Alert or higher emergency classification. Types of data transmitted include information on the plant primary and -secondary coolant systems, safety injection system, and radiation monitoring systems.
H.l.e.3 Dose Assessment Program (DAP)
A Dose Assessment Program (DAP) is available in the TSC, EOF, and the Control Room. DAP is discussed in section 1.4.
H.1.e.4 MIDAS Access to meteorological information via the Meteorological Information and Dispersion Assessment (MIDAS) System display is available on any of the computers in the Control Rooms, OSC, TSC, and EOF that have access to the PPC. The meteorological information is used for offsite dose assessment purposes.
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Page 93 of 221 H.1.e.5. Radiation Monitoring System RMS data is available on any of the computers located in the Control Room, OSC, TSC, ENC/JIC and EOF facilities that have access to the PPC.
H.2. Emergency Operations Facility H.2.a. EOF Functions The EOF provides coordination and evaluation of licensee activities during an emergency. The EOF shall be activated during an Alert, Site Area Emergency and General Emergency.
Once fully activated and staffed, the function of the EOF shall provide for:
" Management of overall licensee emergency response,
" Coordination of radiological and environmental assessment,
- Determination of recommended public protective actions,
- Coordination of emergency response activities with federal, state, and local agencies, and
" Recovery functions.
To accomplish these functions, personnel shall be provided in the EOF for communications with off site agencies and the evaluation of pertinent radiological, meteorological, and plant system data.
Once the Emergency Response Organization (ERO) has been established in the EOF, the Engineering, Design and Site Services Manager will coordinate communications with the engineering support personnel as needed to respond to the emergency.
The EOF personnel shall coordinate the emergency response activities with those of county, state and federal emergency response organizations, including the NRC and FEMA.
H.2.b. EOF Location The EOF is located on the first floor in the NGG Headquarters building in Buchanan, Michigan, which is approximately 14 miles from CNP. The EOF shares the first floor of the building with the ENC/JIC, but the media is segregated from all but a lobby area and auditorium where briefings occur and do not have access to the EOF or the EOF staff. (See Figure 11)
H.2.c. EOF Staffing The EOF shall be staffed to provide overall management of the plant resources and evaluation and coordination of plant activities during and after an accident. The EOF staff will include personnel to perform radiological evaluations, interface with offsite, and manage offsite resources. The EOF staff assignments are contained in Section B. The ED shall be in charge of all activities in the EOF.
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Page 94 of 221 H.2.d. EOF Design The EOF is located in the NGG Headquarters building in Buchanan, Michigan, which is approximately 14 miles from CNP. It occupies approximately 6400 square feet of the first floor of the building, approximately 2500 square feet of which is reserved for use by NRC personnel.
The EOF contains an operations room which includes the crisis management team, communicators, the NRC office, the dose assessors and the data display terminals. The communications are to the:
- ENC/JIC
- State and local representatives in their respective Emergency Operation Centers
" NRC Emergency Operations Center (ENS and HPN telephones have been installed)
" TSC and Control Room
" Licensee Offsite Survey Teams A Communications Director will be located in this operations room and will be in charge of all the operations room communicators and status displays.
The following communication systems have been provided in the EOF:
- Dedicated line on the NRC Health Physics Network (HPN) and on the NRC Emergency Notification System (ENS).
- Fax capability.
- 3 private lines dedicated for NRC use with outside capability.
a Additional telephones to be used as needed.
The design of the EOF structure and organization ensures its ability to perform the following functions:
- Management of overall licensee emergency response.
" Coordination of radiological and environmental assessment.
- Determination of recommended public protective actions.
- Coordination of emergency response activities with federal, state and local agencies.
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Page 95 of 221 The EOF was designed for occupancy by approximately 70 persons. The approximate occupancy, by function, is as follows:
ERO Managers 5 NRC Personnel 23 FEMA, State and County Personnel 3 Communicators 9 Clerical and Extra Staff 15 Assessment Staff _5 60 Ample parking spaces exist outside the EOF in the NGG Headquarters Building parking lot for the number of vehicles that can be expected during an emergency as well as space for mobile vans that Will be brought in by offsite support agencies. In addition, space exists near the building that can be used for landing a helicopter should the need arise.
H.2.e. EOF Data Availability The same computer capability (PC, PPC, LAN, DAP, etc.) described for the TSC in H.l.e. is available in the EOF.
H.3. Operations Support Center (OSC)
H.3.a OSC Functions The Operations Support Center (OSC) is an onsite assembly area separate from the Control Room and the TSC where licensee operations support personnel report in an emergency.
The OSC:
- Provides a location where plant logistic support can be coordinated during an emergency, and
" Restricts Control Room access to those support personnel specifically requested by the shift manager.
The OSC shall be activated for any Alert, Site Area Emergency, or General Emergency.
This is an assembly area for personnel to report for instructions from the OSC Manager.
Communications are provided to the Control Room, TSC, and EOF on the Boardwriter's Bridge and the Managers Bridge. Communications are provided to Damage Control, Rescue, and Survey Teams with portable radios.
H.3.b. OSC Location The OSC is located in the basement of the Lakeside Office Building on the plant site. The classrooms, storage rooms, and offices on the north end of the basement comprise the area where the staff assigned to the OSC stage and perform their function. The remainder of the office building complex is used for assembly of the remainder of the plant staff when accountability is performed. (See Figures 10 and 11)
The OSC will normally be located in the basement area of the Lakeside Office Building; however, this area is not intended to be "fixed" and may be re-located to other areas of the plant that will permit the orderly progression of work to restore the plant/unit to operational status. Any area that is used as an OSC shall be approved by the SEC after the RP Department surveys the area and it is found to be radiologically acceptable.
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Page 96 of 221 An alternate location for the OSC is the Buchanan Office Building in the event of unsafe conditions at the plant H.3.c, OSC Staffing The OSC staff assignments are contained in Section B. The OSC Manager shall be in charge of all activities in the OSC.
H.3.d. OSC Design The OSC is located in the basement of the plant's lakeside office building. Classroom space is available for assembling, briefing, and de-briefing response teams, as well as storage space for emergency response equipment such as anti-contamination clothing and survey equipment.
There shall be direct communications between the OSC and the Control Room and between the OSC and the TSC so that the personnel reporting to the OSC can be assigned to duties in support of emergency operations.
Means for analyzing air samples and environmental samples are located in the OSC. Offsite Survey Teams can return samples to the OSC for analysis. If the OSC is unavailable or inaccessible samples can be counted at Palisades Nuclear Plant (about 25 miles from CNP) or other of the contingency Offsite Laboratory Facilities.
The following communication systems have been provided in the OSC:
- Fax capability.
- Additional telephones to be used as needed.
H.3.e. OSC Data Availability The same computer capability (PC, PPC, LAN, etc.) described for the TSC, with the exception of DAP, is available in the OSC. In addition the OSC has access capability to the Radiation Protection Dose Tracking and Control System.
H.4. AEP Emergency Organization Staffing and Activation The concept employed by AEP is to support the plant operating staff in an emergency by activating all of the Emergency Response Facilities when the operating shift determines that additional resources are necessary to respond to an event.
At the plant, the TSC would be activated upon an Alert, or higher emergency classification and would perform its functions to support Control Room operation within the goal of 60 minutes.
These functions are to provide plant management and technical support to operations personnel; relieve the Control Room personnel of peripheral duties not directly related to plant operation; prevent congestion in the Control Room, and perform EOF functions until the EOF is activated.
The EOF will be activated for any Alert, Site Area Emergency or General Emergency and for any lesser classification as determined by the SEC. The goal is to activate the EOF within 60 minutes of an Alert, or higher emergency classification. Pre-designated members of the NGG staff will report to the EOF to provide management and operations support.
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Page 97 of 221 When ERO members arrive at the EOF, the EOF functions are transferred from the TSC or the Control Room to the EOF. These functions are: management of overall licensee emergency response,. coordination of radiological and environmental assessment, including determination of protective action recommendations for the public (when the Emergency Director position is activated), and coordination of emergency response activities with federal, state and local agencies. During this time, the EOF is in communication with the TSC.
The ENC/JIC facility will be activated at the Alert level, and becomes the JIC at a Site Area Emergency and when declared as the JIC by the State of Michigan. The goal is to activate the ENC/JIC within 90 minutes of an Alert, or higher emergency classification. The EOF will be in communication with the ENC/JIC as well as with the state and county emergency operations center. Press releases will be coordinated with the NRC, state, local and AEP ERO.
Long Term Recovery. At the plant, the TSC is providing support to the Control Room and plant operations staff. The ED is responsible for the entire recovery operation and is located in the EOF. The EOF staff obtains its information on the plant status from the PPC terminals located in the EOF. The dose assessment and communication with the licensee's Offsite Survey Teams and all other communications with offsite parties continues to be performed at the EOF. The Engineering, Design and Site Services Manager is responsible for obtaining supplementary assistance, if needed, from the other NGG personnel.
H.5. Emergjency Detection CNP has nuclear and process instrumentation to detect abnormal situations. This instrumentation will provide warning to the operators so that action can be taken to avoid or mitigate the consequences of plant incidents. Detection capability is provided in the following areas:
- 1. Instrumentation for detecting seismic activity on the plant site and meteorological towers for monitoring and recording weather data.
- 2. A system for monitoring of radiation levels in selected areas of the plant, radioactivity of process streams in the plant, and liquid and gaseous discharges from the plant.
- 3. Instrumentation to measure tank levels in various plant systems and the pressures, temperatures, and flows of process streams.
- 4. Instrumentation for detecting fires in the plant and security events.
Specifically the instrumentation available to assist in determining the severity of a nuclear incident inside the containment is listed in Table 5, "Critical NUREG-0737 Parameters".
Events that do not have a potential for radiological releases but which may have a public interest are detected through the plant's monitoring instrumentation, the plant computer system, audio-visual, alarm/trip indications, fire protection system, and seismic monitoring system.
H.5.a. Seismic Monitoring The seismic monitoring system consists of two forms of monitoring instrumentation, the strong motion triaxial accelerometers and the peak recording accelerometers' The strong motion triaxial system is composed of seismic triggers, control panel, recorder, panels, accelerometers, and power supply. These components provide a means of recording the time history of a seismic event. The power supply to the system, excluding the playback instrument, is designed to provide power from a battery backup source should the AC input supply be lost.
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Page 98 of 221 The peak recording system utilizes triaxial film recorders that do not require a power source for operation. The films are removed, developed and interpreted with a calibrated magnifier. The accelerometers for these two systems have been placed in various locations throughout the plant in such positions as to minimize inadvertent system activations.
H.5.b Radiation Monitoring System The instrumentation for determining the extent and magnitude of accidental releases of radioactive materials offsite includes the Radiation Monitoring System and meteorological instrumentation. Information from each of these sources is .available in the Unit 1 and Unit 2 Control Rooms, as well as any PC with access to the RDR. The RMS and Meteorological System data is available to the EOF, TSC, ENC/JIC and OSC from the PPC through the Real Time Data Repository (RDR) system.
Alarms are provided for high radiation, RMS malfunctions and, where applicable, loss of sample flow on the local indication and control panel, and at the main Control Room display console via the RMS communications system.
A release can be determined from either in-plant RMS, or portable radiation instrumentation dispatched from the plant when it is possible that there has been an accidental gas release which could not be monitored by the plant RMS. Information from readings of this portable instrumentation may then be used to determine the extent of the release.
For accidents where there has been no significant release to the environs, but readings on Control Room instruments indicate a release within the containment, samples can be taken to determine the level of radioactivity therein. Tables relating the radiation levels in the containment for various accident conditions as a function of time and power history are used for comparison with actual data as an aid in determining the possible type of and severity of the accident and are contained in the Emergency Plan Procedures.
The major source of liquid effluent from the plant is through the circulating water discharge.
Identified potential sources of radioactive releases to the circulating water system are monitored by the process monitors of the Radiation Monitoring System.
For long-term events which may have some impact on the environment, additional REMP sampling stations may be provided as necessary.
The Radiation Monitoring System instrumentation is divided into analog and digital systems.
Additional information on the monitor functions and range can be found in the UFSAR, Offsite Dose Calculation Manual, "OP Drawings", and Technical Specifications Bases sections.
H.5.b.1 Analog System
- 1. The Process Radiation Monitoring Systems monitor various fluid streams for indication of radiation levels. The radiation levels are indicated by meter, recorded by a multipoint recorder, and high radiation level alarms are annunciated in the Control Room.
- 2. The Area Radiation Monitoring System monitors radiation levels in various areas of the plant. The radiation level is indicated locally and in the Control Room where it is recorded. A predetermined increase in the radiation level detected by this system is alarmed both locally and in the Control Room.
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Page 99 of 221 H.5.b.2 Digital System
- 1. The Process Radiation Monitoring Systems monitor various fluid streams for indication of radiation levels. This data is processed by a local microprocessor. Display of the data is available upon operator request via terminals in the Control Rooms. A common high radiation alarm is annunciated and the initiating device(s) identity is printed or logged at the control terminals.
The Eberline digital RMS consists of a series of radiation detectors, monitor controllers or local processors, and control terminals together. with appropriate ancillary components including display devices. The local processor gathers data, performs routine calculations, retains channel parameter information, and a history file for all detectors served by that processor.* It also determines operation and alarm status and communicates with the central control terminals. A digital display provides status and alarm outputs and a display of selected channel data.
Alarms are provided for high radiation, RMS malfunctions and, where applicable, loss of sample flow on the local indication and control panel, and at the main Control Room display console via the RMS communications system..
Each reactor unit at CNP has an RMS control terminal. The two central control terminals are functionally identical. One control terminal performs the functions of polling each local processor for. operational status and data, logging any changes in status and associated data, logging history files, annunciating status conditions, communication error messages and, upon keyboard request, performing calculations on data in the history files. One control terminal performs system operating functions while the other is in standby ready to take over system fun6tions. In the event of control terminal failure or outage, the standby system controller is capable of controlling RMS in both units to provide updated data. The control terminal is the operator interface with the rest of the system.
- 2. Area Radiation Monitors monitor radiation levels in most rooms and passageways of the Auxiliary Building and each contaifiment. . This data is processed by the local microprocessor and transmitted to the redundant control terminals.
A complete listing of the RMS monitors, their identification number, type of monitor, location, and range is available via computer or in the Reference Section of facility binders containing the Emergency Plan Implementing Procedures issued for use.
H.5.b.3. Release Assessment Dose Assessment software is available in each Control Room, the TSC, and the EOF that calculates:
- 1. The site boundary dose as a function of time, meteorological conditions and release rate,
- 2. The dose rate as a function of distance from the plant for site boundary and beyond, and meteorological conditions.
The above DAP software is only applicable to gaseous releases which are directly measurable from plant effluent and containment area monitors, or Offsite Survey Team measurements of plume dose rate.
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Page 100 of 221 In addition to the instrumentation which is immediately used by the plant personnel in detecting a radiation release from the plant, a Radiological Environmental Monitoring Program is available from which samples can be taken and analyzed.
The Radiological Environmental Monitoring Program (REMP) monitors the environment surrounding the plant. The stations from which sampling of airborne particulate, airborne 1-131, lake water, well water, external radiation, etc. are located in the Plant's surrounding environs and are identified in appropriate plant procedures.
With the existing instrumentation available to plant personnel, the evaluation of the release and the estimation of the resultant radiation levels at distances from the site boundary can be made without the need to use the Radiological Environmental Monitoring Program sample stations.
For long-term events which may have some impact on the environment, additional REMP sampling stations may be established.
H.5.c. Process Monitoring Plant operating parameters including pressures, temperatures, volumes, and flowrates for systems, as well as RMS and meteorology are available throughout the ERO facilities on PCs that access the PPC information through the Real Time Data Repository (RDR) system.
H.5.d Fire Protection The fire protection detection system is comprised of two general types of detectors. They are thermal detectors and products of combustion detectors. The thermal detectors are designed to detect thermal energy output (i.e., heat from a fire). The products of combustion detectors are designed to detect particles, smoke, or infrared radiation.
The fire detection systems provide an alarm and/or actuate fire suppression systems. Alarm functions generally include:
- Annunciation in the Control Rooms,
" Audible overall plant fire horns for those suppression systems which are actuated by detection systems,
" Audible and/or visual alarms for gaseous suppression systems actuated by detection systems.
H.5.d.1 Types of thermal detectors in use at the plant are as follow:
Thermistor A thermistor is a continuous line heat detector. When an over heat condition occurs anywhere along the thermistor, the resistance drops which is sensed by the control panel. The control panel activates an alarm and/or automatic fire suppression systems.
Fusible Entity Detector/Actuators Fusible Entity Detectors are used to activate sprinkler systems by melting at predetermined temperatures allowing water to be released from the sprinkler heads. The types of plant sprinkler systems employing this type of detector/actuators are:
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Page 101 of 221 0 .Wet Pipe Sprinkler System The piping is always full of water under pressure, so that, if exposed to fire, the sprinkler head is activated and water will instantly flow from the open head onto the fire, and at the same time provides an alarm of such activation and water flow.
- Preaction Sprinkler System These systems are used in areas subject to freezing temperatures or where there is a possibility of water damage from accidental operation or a break in the piping system. In these systems, there are two piping systems one for air (pilot) and one for water. Sprinklers (pilot heads) with a lower temperature rating are installed in the air (pilot) piping system as compared to those installed in the water piping system. The air pressure in the pilot piping keeps a control valve closed. When the pilot heads operate from a fire, the air in the pilot piping is vented and the control valve opens allowing water to fill the water piping. At this point, the system operates the same as a wet pipe sprinkler system.
H.5.d.2 Types of products of combustion detectors in use at the plant are as follow:
Ionization Type Responds to an abnormally high concentration of invisible particles of combustion products that are ionized by a radioactive source located in the detector chamber.
Photoelectric Type Responds to visible smoke in the detector chamber which causes a light source in the detector to be refracted and reflected into a photoelectric cell.
Infrared Flame Detector Responds directly to the presence of the infrared radiation emanating from flames, which flicker between the frequencies of 5 to 30 C.P.S.
H.6 Offsite Monitoring and Analysis Equipment H.6.a. Geophysical (Meteorological, hydrologic, seismic)
A contract is maintained with a commercial weather service for meteorological forecast services, and for an alternate source of meteorological data if the plant site meteorological system is unavailable. As a back up for the contract service the NOAA Weather Service Forecast broadcasts are accessed through a plant phone extension, as well as being available from weather radios.
Phone numbers for the National Earthquake Information Center are maintained in the ERO Phone Directory. The center can be contacted for confirmation of, or information on seismic events.
H.6.b. Radiological Monitoring Emergency Plan Procedures establish the means of assuring that adequate emergency equipment is stocked at designated points for use in emergencies dealing with radiological hazards. The emergency equipment includes, but is not limited to:
- Air samplers with assorted cartridges
" Ion chambers Planning Standard H Revision 32
Page 102 of 221
- Geiger counters
- Respirators
" Personal dosimetry Plant procedures identify the requirement for emergency equipment to be inventoried and checked at specified times to ensure that the supplies and equipment are properly maintained and available for use. Emergency equipment is kept at some offsite locations see Appendix C, Emergency Kits and Equipment Locations, for locations.
Appendix B contains agreements with offsite support agencies including agreements with other utilities for assistance during emergencies at nuclear power stations.
Appendix E contains information about assistance and resources, including instrumentation, available through the DOE Radiological Assistance Plan.
H.6.c Offsite Laboratory Facilities In the event that it becomes necessary to use offsite laboratories for analysis of samples the following facilities may be contacted and the analysis performed depending on the type of samples (See Appendix H, Radiological Response Support Service Capabilities):
" Teledyne Isotopes Inc.
" Argonne Laboratory (DOE)
- There is also a Reciprocal Laboratory Use Agreement with Palisades Nuclear Plant (see Appendix B).
H.7. Radiological Environmental Monitoring The CNP uses a pressurized water reactor with a radwaste holdup and treatment system that has been designed to keep radioactive releases to as low as practical levels. However, small quantities of noble gases and other radionuclides that are released to the environment are expected to be minuscule and insignificant as a source of potential exposure to flora and fauna in the area. However,, direct radiation exposure to the public and radionuclide accumulations in various components of food chains to man is carefully monitored through the REMP. Further information on the REMP.can be found in the Offsite Dose Calculation Manual (ODCM).
H.8 Meteorological System The system's meteorological towers are located inside the thermal internal. boundary layer and have the ability to measure unmodified onshore airflow to detect the presence of a lake breeze.
The meteorological system consists of monitoring information located on three towers. The primary and backup towers are located about 1-mile inland from the plant site to provide a representative determination of the meteorological conditions for emergency planning purposes.
The primary tower has instruments at the 10 and 60-meter elevations. Each elevation has a measurement of wind speed and direction. Temperature is measured at both elevations and is used to determine a delta temperature (delta T). This delta T is used in dose assessment to determine atmospheric stability. A precipitation gauge is located near the primary tower site.
The backup tower has wind speed and wind direction instrumentation located at the 10-meter elevation. Separate communication lines are provided for the main and backup towers.
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Page 103 of 221 The shoreline tower also has wind speed and wind direction instrumentation at the 10-meter elevation. Temperature detectors are located at the 2-meter and 10 meter elevations of the tower. The shoreline tower is located just northwest of the plant on the shore of Lake Michigan.
The three towers are controlled by a central computer located at CNP site. The towers are polled every 15 minutes for meteorological data. The data are stored in the central computer.
Meteorological data are available from any PC with access to the PPC data.
Daily checks of the digital data are performed to ensure reliability. Erroneous data are flagged on these displays and triggers the issuance of a Work Order (WO). The WO system is used to notify the appropriate department of the problem and provides notification of the resolution to the problem. An adequate spare parts inventory is maintained at the primary tower site. Calibration of the system is performed semi-annually and is documented by the plant Instrumentation and Control Section.
Meteorological information can be obtained directly from the primary tower site using a keypad if communications with the central computer are lost. Backup meteorological information can also be obtained from a consulting firm. Forecasting information is available from the consulting firm as well as a plant extension that continuously plays NOAA weather information, and Weather Service radio.
Planning Standard H Revision 32
Page 104 of 221 Figure 10 Warehouse LOCATIONS OF EMERGENCY RESPONSE CE TERS and Office Spent Fuel Maintenance Pool IBuilding we~..muumm..n....u..um...
- SUUI*U*M**S*S**3.S~hE..VE\ .~.v.3SE.3... .nova~
'111.......1I ii:111 . ...
Visitors Center M
Emergency News Center/Joint Emergency Operations Facility Information Center in the in the Nuclear Generation Nuclear Generation Group Group Headquarters Building Headquarters Building in Planning Standard H Revision 32 in Buchanan Buchanan
Page 105 of 221 FIGURE 11 CNP EMERGENCY RESPONSE CENTER LOCATIONS Control Room Entry at Elev. 633' Turbine Building Technical Support Center (TSC) Above SM's Office Complex Adjacent to Units 1 and 2 Control Rooms Operations Support Center (OSC) Plant Offices - Basement ShelterElev. 587' Emergency Operations Facility (EOF) In Nuclear Generation Group Headquarters Buchanan - Approximately 14 miles Southeast of CNP Emergency News Center/Joint Information Center (ENC/JIC) In Nuclear Generation Group Headquarters Buchanan - Approximately 14 miles Southeast of CNP Planning Standard H Revision 32
Page 106 of 221 TABLE 5 CRITICAL NUREG 0737 PARAMETERS PARAMETER INSTRUMENTATION Neutron Flux (Gammametrics) NRI-21, NRI-23 Reactor Coolant Pressure (Wide Range) NPS-110, NPS-111, MR-13 Reactor Coolant Outlet Temperature Thor (Wide Range) NTR-1 10, 120, 130 140 Reactor Coolant Inlet Temperature Tcld (Wide Range) NTR-210, 220, 230 240 Incore Thermocouples (Core Exit Thermocouples) T/C 1-65 Reactor Coolant System Subcooling Margin Monitor QR-1 10-3 Reactor Coolant Inventory System (Reactor Vessel Level NLI-110, 111, 120, 121, 130, 131 Indication)
Pressurizer Water Level NLP-151, 152, 153 Charging Pump Flow IFI-51, 52, 53, 54 Charging Pump Breaker Status 1E, 1W, 2E, 2W Control Room Position Indicating Lights for Breakers, Safety Injection Pump Breaker Status .1N, 1S, 2N, 2S Control Room Position Indicating Lights for Breakers, Safety Injection Flow IFI-260, 266 Refueling Water Storage Tank Water Level ILS-950, 951 Containment Water Level NLI-320, 321, 330, 331, 340, 341 Containment Recirculation Sump Water Level NLI-300, NLI-301 Containment Pressure (Wide Range) PPA-310, 312 Containment Pressure (Narrow Range) PPP-300, 301, 302, 303 Containment Hydrogen Monitoring ESR-1 thru 9, PAS-H2-A-CRI, PAS-H2-B-CRI Containment Isolation Valve Position Monitoring Control Room Position Indicating Lights Containment Area Radiation Monitors (High Range) Unit 1 VRA-1310, 1410, Unit 2 VRA-2310,2410 Steam Line Pressure MPP-210, 211, 212, 220, 221, 222,230, 231, 232, 240, 241, 242 Steam Generator Water Level (Wide Range) BLI-110, 120, 130, 140 Steam Generator Water Level (Narrow Range) BLP-110, 111, 112, 120, 121,122, 130, 131, 132, 140, 141,142 Auxiliary Feedwater Flow Rate FFI-210, 220, 230, 240 CCW Flow to ESF System, CCW Pump Breaker Status PP-10E, PP-10W Reactivity Control, Control Rod Position CAI-8(UI), CB1-4(U1), CAI-4(U2), CB1-8(U2), CC1-8, CD1-9, SA1-8, SB1-8, SCI-4, SD1-4 Condensate Storage Tank Level CLI-113, CLI-114 Planning Standard H Revision 32
Page 107 of 221 PLANNING STANDARD I ACCIDENT ASSESSMENT Planning Standard I Revision 32
Page 108 of 221 I. ACCIDENT ASSESSMENT The purpose of this section is to describe the systems, equipment, and methods for monitoring and assessing offsite consequences of actual or potential radiological emergencies.
1.1 Release Identification and Event Classification The Emergency Plan Procedures contain the information used to establish the emergency classification category based on plant system and effluent parameter values. Those initiating conditions are identified in NUMARC/NESP-007. Section D contains the plant specific EALs and initiating conditions in the Emergency Classification System tables.
1.2 Radiation Monitorinq System The RMS monitors area radiation levels in most rooms and passageways of the Auxiliary Building and each containment. Effluent and process flows are monitored for radioactive material. The monitors and channels of most interest for monitoring and evaluating events for radiological impact are:
Containment Radio Gas monitors, 2 per unit Condenser Air Ejector Radio Gas monitors, 1 per unit Unit Vent Radio Gas Monitors, 1 per unit Gland Steam Leak Off Monitors, 1 per unit Steam Generator Power Operated Relief Valve (PORV) Monitors, 4 per unit Containment High Range Area Radiation Monitors, 2 per unit A complete listing of the RMS monitors, their identification number, type of monitor, location, and range is available via computer or in the Reference Section of facility binders containing the Emergency Plan Implementing Procedures issued for use. Section H.5.b contains the description of the RMS system.
1.3. Release Source Term and Magnitude Determination 1.3.a. Release Source Term Calculations correcting containment dose rates as a function of time and reactor power history are contained in the plant core damage assessment procedure. Tables use the corrected containment dose rate results to provide estimates of core damage.
Estimates of core damage are used to select the source term used in the Dose Assessment Program for assessing releases.
1.3.b. Release Magnitude Effluent monitor radiation readings and effluent pathway flow rates are used to calculate the magnitude of releases.
When it is possible that there has been an accidental gas release which could not be monitored by the plant RMS survey teams dispatched from the plant perform surveys offsite with portable radiation instrumentation. Information from readings of this portable instrumentation may be used to determine the extent of the release.
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Page 109 of 221 1.4 Dose Assessment Evaluation A dose assessment program to quickly relate measured release rates and containment dose rates to dose and dose rates at the site boundary and beyond are maintained in the Control Rooms, TSC, and the EOF. The determination of the meteorological stability class to perform offsite dose calculations is described in the Plant Emergency Plan Procedures. Once the meteorological stability class is determined, the offsite radiation dose and dose rates at the site boundary can be estimated using the information obtained from the plant radiation monitoring instruments and/or measured offsite radiation dose rates and the dose assessment program.
A dose assessment computer program, DAP, provides a method of calculating conservative estimates of dose and dose rates at the offsite area most probably affected by a gaseous release to assist in emergency classification and Protective Action Recommendations (PAR). The Dose Assessment Program allows evaluation of several types of release scenarios with the flexibility for meteorological and radiological inputs to perform alternate evaluations to best characterize an event and the resulting protective measures. The program also allows calculations based on offsite survey results for cross comparison purposes, or a means for evaluating unmonitored releases.
In order to calculate a dose/dose rate, the program requires data on:
the radiological effluent.
containment area monitor dose rates, or offsite dose rate measurement results.
This information can be obtained from the plant's RMS or from Offsite Survey Teams.
Other features included in the program are as follows:
- Variable Trajectory Plume Segment Model
- Radioactive decay after reactor shutdown
- Decay and daughter in-growth during transit
" Ground level release
- Finite cloud correction
- Option to input offsite field survey data.
" NuReg - 1228 Event Tree Modeling for Source Term
- Multi Accident Assessment Capability The program is run on personal computers.
The DAP program will be used as the primary means of performing a dose assessment.
Dose Assessment Program (DAP) is a PC computer program that calculates conservative estimates of Total Effective Dose Equivalent (TEDE) and Thyroid Committed Dose Equivalent (CDE) dose rates and total projected dose, based on a radiological release, at the plant boundary and at 2, 5, and 10 mile distances. The program also uses the information to determine the Emergency Classification Level (ECL) associated with the release.
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Page 110 of 221 1.5 Meteorological Assessment The system's meteorological towers are located inside the thermal internal boundary layer and have the ability to measure unmodified onshore airflow to detect the presence of a lake breeze.
Meteorological data are available from any PPC capable computer. Section H.8 contains a description of the Meteorological System.
Meteorological data from the onsite meteorological tower is input into the dose assessment program. The data is used to calculate the atmospheric diffusion factor, X/Q, to determine atmospheric dispersion of radioactive material as part of the Dose Assessment Program for calculating off site doses and dose rates. Weather forecast information is also used to project changes in plume dispersion and location, which can cause changes to Protective Action Recommendations.
1.6. Not Addressed.
1.7 Radioloqical Field Monitoring As part of the response to any Alert, Site Area Emergency or General Emergency, one or more Offsite Survey Teams are formed, as per plant procedures, and dispatched for sampling under radio contact. Qualified RP Technicians fill the position for persons performing the survey. If adequate RP and other personnel are not available onsite, personnel to staff Offsite Survey Team(s) would be summoned per Emergency Plan procedures.
1.8. Liquid and Gaseous Release Assessment A minimum of two vehicles dedicated to Emergency Plan Off Site Surveys is available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. Additionally, keys for all normally available plant vehicles are available in the OSC in the Office Building Basement. Offsite Survey Team(s) deployed from onsite would have such vehicles available for use.
Each of the two dedicated Off Site Survey vehicles, the office building basement, and the EOF have air sampling equipment, dose rate, and count rate instrumentation in addition to radio equipment for communication with the plant.
Previous experience indicates that deployment of personnel from onsite to offsite areas takes approximately 30 minutes from the time of notification.
1.9. Off-site Radioiodine Monitorinq Measurements of radio-iodine yielding sensitivity to the range of 10-8 uCi/cc can be obtained by returning the sample to the regular counting facility or to the counting area independent of the regular counting facility located in the basement area of the Office Building.
1.10. Not Addressed.
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Page 111 of 221 PLANNING STANDARD J PROTECTIVE RESPONSE Planning Standard J Revision 32
Page 112 of 221 J. PROTECTIVE RESPONSE J.1. Owner Controlled Area Warning and Advisement Since the PA system within the plant is extensive, an announcement of the nature of the emergency can be made to most personnel immediately.
Upon sounding of the Nuclear Emergency Alarm personnel in the outlying areas of the plant site are notified using the methods described in section E.2.a of this plan.
J.1.a. Non ERO Employees Plant employees without ERO duties and personnel temporarily assigned to the plant for training or other purposes, are required to know the location and routes to the assembly areas and be familiar with the emergency alarm procedure. Personnel already onsite immediately proceed to their appropriate assembly area upon sounding of the Nuclear Emergency Alarm.
J.1.b. Visitors Groups on tour are escorted to an assembly area by their tour guide, should the Nuclear Emergency Alarm be sounded. Personnel already onsite immediately proceed to their appropriate assembly area upon sounding of the Nuclear Emergency Alarm.
J.1.c. Contractors and Construction Contractors, supervisors, and/or foremen (i.e., outside labor) are provided with instructions, prior to beginning work as to the emergency alarm procedure and as to their responsibility for assembling the people under their supervision in the area designated by the SEC or designated alternate. Personnel already onsite immediately proceed to their appropriate assembly area upon sounding of the Nuclear Emergency Alarm.
J.1.d Others The decision to commence evacuation of the Cook Energy Information Center is made by the SEC on the basis of the. evaluation of the condition of the plant and the extent of the emergency.
The Manager of the Cook Energy Information Center or designee is responsible for the accountability of all Energy Information Center employees and all visitors of the Center should the Nuclear Emergency Alarm be sounded.
When State Police and National Guard are assigned to the plant their disposition will be determined by the nature of the emergency. If the plant is under attack the MSP and National Guard are considered essential personnel and become Emergency Workers for the event. If the emergency does not involve attack of the plant the MSP and National Guard are considered non-essential personnel and evacuated from site upon evacuation of non-essential personnel.
J.2. Evacuation Routes If the SEC deems evacuation of personnel from the plant site necessary, the evacuation route to be taken is determined by the nature of the incident. Personnel evacuate the plant and site as directed by the SEC. Evacuation of individuals shall not commence until it is determined that personnel exposure for such evacuation is within the limits of 10 CFR Part 20, or if this is not practical due to the nature of the emergency, the most expeditious and non-hazardous evacuation route shall be used.
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Page 113 of 221 The SEC designates the evacuation route. One of the below designated routes is utilized (see Figure 12)
- 1. East along the plant main access road.
- 2. North along the Lake Michigan Beach to the plant property line or Rosemary Road.
- 3. South along the Lake Michigan Beach to Livingston Road.
The Security Director (or alternate) is responsible for the accountability of evacuated personnel from the plant site and reports any missing persons to the SEC.
J.3. Evacuee Monitoring If evacuation is initiated a personnel monitoring station is established for those evacuated by a person trained in radiation protection. The Radiation Protection Plan specifies the acceptable limits for contamination to the body and clothing for exiting the plant. Suitable equipment intended for such personnel monitoring stations will be stored in both the OSC and the Training Center.
Other equipment is available from the Radiation Protection Access Control (RPAC), if access to that area is feasible.
J.4 Evacuee Decontamination If any of the evacuated personnel are contaminated, the OSC Manager will institute the necessary steps for movement of these personnel to decontamination facilities and initiate surveys of the surrounding areas.
J.5 Personnel Accountability Control of all personnel entering, leaving and at various locations throughout the plant is a function of the plant security force. The accountability of all personnel in the protected area of the plant is maintained via the security computer system. The security computer records provide the primary means of assuring the accountability of all persons of the site. Use of this computer will enable the accountability to be performed rapidly with a stated goal of achieving completion of personnel accountability within 30 minutes.
During some postulated events, assembly and accountability may pose a greater danger to plant personnel than directing a rapid egress of personnel from the Protected Area, or directing personnel to remain at their work areas. SM/SEC discretion, with input from the Security Director (or Security if. Facilities are not yet activated) should be used when deciding to perform accountability and/or evacuation under these conditions.
Once the Nuclear Emergency Alarm has been sounded all personnel onsite shall report to their pre-assigned assembly areas. The SEC will notify personnel via the PA system of any changes in the areas to be used due to the release or expected release of radiological effluents from the plant.
Personnel reporting to their assembly area onsite will be accounted for using the plant security access list and security computer.: This list provides an up-to-date listing of all personnel onsite by area location. The results of the accountability process will be transmitted to the individual in charge of personnel accountability.
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Page 114 of 221 If personnel are unaccounted for, the security computer will be queried to determine the individuals last known location. The individual(s) will be paged on the PA system, the individual's supervisor will be notified and if required, the SEC will initiate search and rescue operations.
J.6 Protective Measures for Those Remaining, or Reporting to the Site Personnel remaining onsite after the sounding of the Nuclear Emergency Alarm will be required to assemble in an area that is free from ionizing radiation and contamination, or presents the minimum exposure to personnel engaged in emergency operations. Surveys of the assembly area(s) will be conducted to ensure continued habitability.
Personnel remaining onsite who are engaged in emergency operations where there is an actual or potential radiological hazard, shall upon the direction of the RP Director, wear the required protective clothing and respiratory protection. The RP Department shall perform the required surveys and establish the type and quantity of clothing, and other protective measures required.
The Plant Security Force will control access to the Owner Controlled Area at the 1-94 Gatehouse as directed by the SEC.
Personnel arriving at the plant to assist in the emergency will be allowed access to the plant via minimal exposure routes as identified by the Plant RP Department and approved by the SEC.
The RP Department will establish a Controlled Area Access Point for personnel arriving at (and departing from) the plant from offsite if the access route exceeds the criteria for "Clean Areas" as identified in the Radiation Protection Plan. The amount of exposure personnel receive in reporting to the plant will be included in the individual's dose records.
Additionally, other precautions, such as decontamination, will be taken as necessary prior to entering the plant and reporting to the assigned assembly area. Equipment decontamination and controls are described in detail in the Radiation Protection Plan.
J.6.a. Respiratory Protection The Radiation Protection Plan and Radiation Protection Procedures identify the instructions and requirements pertaining to respiratory protection requirements and respiratory protection equipment usage.
J.6.b. Protective Clothing The Radiation Protection Plan and Radiation Protection Procedures identify the instructions and requirements pertaining to protective clothing requirements and protective clothing usage.
J.6.c. Radio-protective Drugs The procedures and precautions for the issuance and use of thyroid prophylaxis, e.g., individual thyroid protection, by emergency workers will be based on existing conditions. The provisions for stockpiling, inventory, storage and use are included in Emergency Plan Procedures. However, since the medical aftereffects of the agent cannot be determined, wholesale (wide) distribution cannot be incorporated as a responsible protective measure for personnel onsite.
J.7 Off-site Protective Actions For incidents that fall under the ECLs as defined herein, the SEC or ED will notify the Michigan State Police, the Berrien County Sheriff's Department, the NRC, and the AEP Emergency Response Organization described in this plan that such an incident has occurred.
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Page 115 of 221 It is the responsibility of the Governor of Michigan, or authorized representative, to issue Protective Action Orders (PAOs) such as sheltering, evacuation, administration of thyroid blocking agents, etc. These decisions are based upon the protective action guides in Annex S of the Michigan Emergency Management Plan (MEMP). Since copies of the MEMP are maintained and readily available at the various Emergency Response Facilities, the protective action guides and their bases will not be reproduced here.
For incidents involving actual or imminent releases of radioactive material to the atmosphere the Control Room or EOF protective action recommendation procedures, as appropriate, will be used as the basis for recommendations for protective actions to the public. These procedures are based on the current issue of the "Manual for Protective Action Guides and Protection Action for Nuclear Incidents" (EPA 400-R-92-001). The EPA Guide provides Protective Action Guides (PAGs) for whole body external gamma radiation and for inhalation of radioactive material in an airborne plume.
The most effective actions to be recommended to the public are evacuation, sheltering, and access control. Evacuation potentially provides the greatest margin of protection. On the other hand, because sheltering may be implemented in less time than evacuation, it may be the protective action of choice if rapid evacuation is impeded for any reason. Also, since sheltering is less disruptive than evacuation, it may be the protective action of choice when the dose reduction factor associated with shelter is adequate to reduce the projected dose to less than PAG levels.
Access control is an effective action to avoid exposure of personnel who might otherwise enter areas of high exposure unnecessarily.
Emergency Plan Procedures have been established to provide the mechanism and criteria for recommending protective actions to state and local government.
Additionally the protective action guides for emergency workers and those engaged in lifesaving activities exposed to airborne radioactive materials are listed in Section K.I., Emergency Exposure, and in the Plant Radiation Protection Plan.
J.8. Evacuation Times Evacuation time estimates and informational county maps are contained in the Berrien County Emergency Operations Plan submitted to the Nuclear Regulatory Commission (NRC).
Evacuation time estimates are performed within 365 days after the availability of the most recent decennial census data. Yearly reviews of the Evacuation time estimates are performed to estimate the Emergency Planning Zone permanent resident population changes.
J.9. Not Applicable J.10 Plume Exposure Pathway Protective Measures Implementation J.10.a. Route and Facility Location Maps Maps for the 10 and 50 mile EPZ, developed by the Michigan State Police are provided for use at the following locations:
Control Rooms TSC EOF OSC ENC/JIC Berrien County EOC Cook Energy Information Center Planning Standard J Revision 32
Page 116 of 221 These maps show information such as sector designations, emergency center locations topographical information, and when used in conjunction with Berrien County plan indicates preferred evacuation routes.
J.10.b. Population Distribution Maps Evacuation time estimates and informational county maps are contained in the Berrien County Emergency Operations Plan submitted to the Nuclear Regulatory Commission (NRC).
J.10.c. Population Notification The Berrien County Plan includes provisions for alerting local radio and television stations and, local news media to be prepared to transmit Emergency Public Information. Section E.6 addresses Public Notification J.10.d. Protective Action Basis The Dose Assessment Program and off-site survey team results, as well as plant system and equipment status, are the basis for Protective Action Recommendations. DAP and off-site surveys are addressed in sections 1.4 and 1.5.
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Page 117 of 221 Figure 12 Cook Nuclear Plant PrimaryEvacuation Routes Planning Standard J Revision 32
Page 118 of 221 PLANNING STANDARD K RADIOLOGICAL EXPOSURE CONTROL Planning Standard K Revision 32
Page 119 of 221 K. RADIOLOGICAL EXPOSURE CONTROL The CNP Radiation Protection Plan (PMI-6010) specifies the base criteria for the implementation of the Radiation Protection (RP) program and the methods to be used to control the exposure to radiation and radioactive materials. The standards listed in PMI-6010 and the programs to be followed consist of:
- 1. RP Training and Qualifications
- 2. ALARA Program
- 3. Radiation Work Permits
- 4. Dosimetry Program
- 5. Area Postings
- 6. Contamination Control
- 7. Internal Exposure Control
- 8. Radioactive Material Control Program
- 9. Survey Program
- 10. Instrumentation Program
- 11. Radiological Environmental Monitoring Program
- 13. Review and Surveillance Program Related sub-tier RP procedures have been developed to provide a detailed and comprehensive method of performing the daily and emergency assignments. The procedures cover the following areas:
- 1. Exposure Monitoring and Control
- 2. Respiratory Protection
- 3. Contamination Control
- 4. Radiological Controls
- 5. Instrumentation
- 6. Instrumentation Calibration
- 7. Radioactive Effluent Control
- 8. Abnormal Condition Response
- 9. RMS Instrumentation
- 10. RMS Instrumentation Calibration
- 11. RMS Alarm Response Planning Standard K Revision 32
Page 120 of 221 K.1. Emergency Exposure It is possible that emergency situations may arise which transcend the normal requirements for limiting dose.
Dose to penetrating radiation during emergency response or response to accidents may be up to 10 rem Total Effective Dose Equivalent (TEDE), 100 rem Committed Dose Equivalent (CDE) to the thyroid for non-life-saving actions.
Life saving doses may be up to 25 rem TEDE or 250 rem CDE to the thyroid. However, in all situations, every reasonable effort shall be made to minimize dose.
In no case shall this type of dose be permitted unless rescue personnel are wearing monitoring devices capable of monitoring these doses.
Situations may also rarely occur in which a dose in excess of 25 rem for emergency exposure would be unavoidable in order to carry out a lifesaving operation or to avoid extensive exposure of large populations. However, persons undertaking any emergency operation in which the dose will exceed 25 rem to the whole body should do so only on a voluntary basis and with full awareness of the risks involved, including the numerical levels of dose at which acute effects of radiation will be incurred and numerical estimates of the risk of delayed effects.
K.2. Emergency Exposure Authorization and Control Doses in excess of 10 CFR 20 limits may be authorized by the SEC in order to prevent serious property damage, serious bodily injury, or for life saving measures.
The assessment and recording of radiation exposures will be the assigned duty and responsibility of the person so designated by the RP Director. The SEC shall be made aware of any changes in cumulative exposures which would affect emergency team assignments.
The exposure of personnel who were in the immediate area of a radiation incident must be determined before they are assigned to any emergency or recovery team. Self-reading dosimeters, electronic dosimeters, area monitor records, or thermoluminescent dosimeters will be used to establish accumulated exposure for each individual.
K.3. Emer-gency Personnel Dosimetry K.3.a Dose Determination Radiation Exposure Records for exposed personnel will be maintained by the plant and will be available for review by the State of Michigan Department of Environmental Quality (DEQ).
K.3.b. Dosimetry Use and Dose Records PMI-6010 and applicable sub-tier procedures identify criteria and methods for reading, recording and maintaining dose records.
K.4. State and Local Emer-gency Exposure Authorization Not Applicable.
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Page 121 of 221 K.5. Decontamination K.5.a. Decontamination Criteria PMI-6010 and applicable sub-tier procedures identify the criteria for decontamination of personnel, personnel wounds, and equipment.
Survey data and records of data taken by the licensee resulting from a nuclear incident at the licensee's plant will be made available to the State for review upon written request to plant management by the Michigan DEQ or other designated State agency.
K.5.b. Decontamination Methods PMI-6010 and applicable sub-tier procedures identify the means and methods for decontamination of personnel, personnel wounds, and equipment.
There are two separate decontamination facilities which may be used during an emergency. The main facility is located in the Radiation Protection Access Control (RPAC) on the 609' elevation east of the auxiliary building. The other facility is located in the Auxiliary Building access at the Turbine Radiation Protection Access Control (TRPAC) on the. 609' elevation of the Unit ITurbine Building.
The decontamination facility associated with the RPAC consists of a decontamination area and a personnel shower. Additional space available in the area may also be used. Personnel protective clothing and equipment are also available in the RPAC.
Both decontamination facilities have adequate water supplies for both showers and wash basins. All floor and sink drains in the adjoining areas drain either into the laundry and hot shower drain tank or other contaminated liquid tanks for complete control of potentially contaminated wastes.
Information on equipment and inventory of supplies as well as detailed written procedures and standing orders, are found in the Administrative Procedures and the Emergency Plan Procedures, as well as the RP Plan and the RP Procedures. A list of Emergency Kit Locations is shown in Appendix C. Inventory procedures are specified in the RP procedure indicated in the Plant Procedure column in Appendix A.
K.6. Contamination Control K.6.a. Area Access Control PMI-6010 and applicable sub-tier procedures identify the means and methods for area access for control of contamination.
K.6.b. Waterand Food Contamination Control Not addressed.
K.6.c. Returninq Items and Areas to Normal Use PMI-6010 and applicable sub-tier procedures identify the means and methods for decontaminating and returning areas and items to normal use.
The public will be restricted from areas within the Owner Controlled Area normally open to the public (i.e.,
Energy Information Center) which have been contaminated with radioactive material in excess of the limits defined in Table 6, Maximum Allowable Contamination Limits for On-Site Facilities Used by the Public. Prior to the release of these areas for public use, the plant will notify the DEQ and provide the required data for review at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in advance of release of these areas to the public.
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Page 122 of 221 K.7. Decontamination of Relocated Onsite Personnel Personnel evacuated from onsite will be decontaminated as required by the plant RP procedures and Emergency Plan Procedures. If necessary and where possible, suitable protective clothing will be used during the evacuation.
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Page 123 of 221 Table 6 MAXIMUM ALLOWABLE CONTAMINATION LIMITS FOR ON-SITE FACILITIES USED BY THE PUBLIC*
Beta-Gamma Counts per Minute (cpm)1 2
Skin, Personal Clothing, and < 2 X Background Items Directly Associated With the Human Body 2
Material or Facilities Not < 2 X Background Directly Associated With the Human Body 1
Measured with GM and side window probe with beta shield opened or with thin window pancake probe.
2 Use background readings in cpm as measured pursuant to footnote 1. Gamma background must be 0.2 mR/hr, or less, as measured with a GM and a side window probe with the beta shield closed.
- Ref. Michigan Emergency Management Plan Planning Standard K Revision 32
Page 124 of 221 PLANNING STANDARD L MEDICAL AND PUBLIC HEALTH SUPPORT Planning Standard L Revision 32
Page 125 of 221 L. MEDICAL AND PUBLIC HEALTH SUPPORT L.1. Offsite Medical Support Lakeland Regional Medical Center, Saint Joseph, in St. Joseph, Michigan has an emergency room which is open 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day year round and arrangements have been made with them for the care of contaminated persons. There is a physician constantly on duty at the hospital.
Lakeland Regional Medical Center, St. Joseph is the primary site for the handling of contaminated patients from CNP. The hospital is approximately 9.5 miles from the plant site.
In addition, Niles Community Hospital, Niles located in Niles, Michigan, about 19 miles from the plant site, has facilities and staff for the handling of contaminated patients from CNP. This facility is the back-up site for Lakeland Regional Medical Center, St. Joseph.
The Radiation Emergency Area (REA) at Lakeland Regional Medical Center, St. Joseph, lends itself well to controlling the access of non-essential personnel. The REA at both St. Joseph and Niles is located in a section of the hospital remote from any other treatment facilities. A contaminated or potentially contaminated patient is wrapped and placed on a clean gumey when taken from the ambulance before being taken into the facility to avoid the spread of contamination.
The REA facility in both hospitals consists of a room designed for easy decontamination, should this be required. Adequate water is supplied for any necessary personnel or equipment decontamination. The facilities include a fiberglass table with a special drain to allow control of liquids for later removal from the hospital. If the injury does not require special handling because of contamination levels or high radiation levels, the facilities of the emergency room and other parts of the hospital are available.
In addition to that equipment normally found in hospital emergency facilities for routine non-nuclear emergencies, other specialized equipment includes such items as plastic and absorbent paper for contamination control, protective clothing, equipment for the control of liquid and solid wastes and their removal from the hospital to the plant for treatment and/or disposal, and assorted signs, barriers, and supplies. Also available at the hospital are such items as survey instruments, dosimeters, samplers, and associated equipment.
There are no limitations with regard to duration of. admissions of casualties or contaminated patients. Special rooms have been arranged so the patients can be kept as long as necessary before being transferred to a different facility or until released.
Onsite decontamination of the injured person, as well as the design of the REA with respect to the rest of the hospital, negates any limitations on the availability of the offsite medical facilities with respect to contamination levels. The only limitation due to direct radiation levels from a contaminated injured person is to the people directly concerned with treatment of the contaminated injured person because the REA is located in a part of the building remote from the patients and staff in most conditions. The limitation on the exposure of the physician or hospital staff remains a medical judgment made by the physician for individual cases. This judgment will be made using data obtained from portable radiation monitoring equipment.
Detailed procedures have been developed for activation of the hospital assistance plan. A comprehensive training program has been conducted for the hospital staff and employees who would be involved as a part of the offsite medical support. This program includes training in the principles of radiation protection, basic radiation protection procedures, applicable parts of the emergency plan and emergency procedures, and an exercise simulating radiological and physical injury. This training program shall be periodically reviewed and repeated at least once each year.
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Page 126 of 221 Plant personnel will monitor all persons leaving the treatment room after removal of protective clothing. The treatment room, all equipment used in the room and during patient treatment is surveyed by plant personnel for contamination. Any contaminated equipment or areas will be decontaminated by plant personnel to the Plant RP Protection Plan "Clean Area" specifications.
All radioactive waste is sealed and transported to the plant for disposal in accordance with current DOT and State regulations.
Subsequent therapy for individuals who have been exposed or contaminated is provided in the kind and extent which is required under the direction of the hospital physician. Additionally, consultation service is available from the Department of Energy's Radiation Emergency Assistance Center/Training Site on radiation related injuries.
L.2. Onsite Medical Support In the event of serious injury, medical treatment must always take precedence over decontamination of the individual. First Aid training is provided within several plant departments, providing emergency medical expertise within the plant. All plant personnel are trained in the proper response to a medical emergency. No physicians or nurses are located on-site.
The CNP has the necessary facilities and supplies at the site for decontamination and monitoring of personnel as well as the facilities and necessary medical supplies for appropriate emergency first aid treatment.
L.3 State Medical Support Listing Not Applicable.
L.4. Victim Transport Medic-1 Ambulance Service is located approximately 4 miles from the plant and provides the primary emergency medical services for the Plant. As a back up a plant emergency vehicle is available.
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Page 127 of 221 PLANNING STANDARD M RECOVERY AND RE-ENTY PLANNING AND POST ACCIDENT OPERATIONS Planning Standard M Revision 32
Page 128 of 221 M. RECOVERY AND RE-ENTRY PLANNING AND POST ACCIDENT OPERATIONS M.1. Reentry and Recovery The exact nature and details of a specific emergency determine the procedures that are used for the resumption of normal plant activities. The procedures formulated to regain the services of plant systems lost through such an incident follow the practices of good engineering judgment.
After the Emergency Plan has been activated, the plant personnel initiate a survey of plant damage and contamination. The plant systems or components involved in the incident are evaluated by any number of the following methods:
- 1. Radiation Surveys
- 2. Process instrumentation
- 3. Visual inspections (where possible)
- 4. Reactor Protection System Instrumentation
- 5. Reactor Control System Instrumentation
- 6. Out of core and in core nuclear instrumentation
- 7. Engineering safety features instrumentation
- 8. Radiation monitoring system
- 9. Post Accident Sampling Capability (where possible)
Re-Entry Survey or personnel monitoring teams are sent out to gather information prior to re-entry and report such findings to the individuals designated in the Emergency Plan Procedures in the TSC and/or the EOF.
The Radiation Protection Director (RPD) is responsible for protecting plant personnel re-entering the plant. The RPD is responsible for ensuring that radiation doses are under Federal limits for a radiation worker involved in plant re-entry before resuming normal plant operation.
Survey teams will measure radiation levels on and around the site and re-entry will be made when radiation hazards are reduced to permissible levels. The SEC will approve re-entry procedures based on existing and potential conditions of the plant.
Recovery Operations Where control of the incident has been attained and there is no further danger to personnel, the emergency phase shall be at an end. Restoration and recovery operations shall continue, but not under the same criteria as the emergency operation. During restoration and recovery operations, activity levels and personnel exposures will be based on 10 CFR 20 limits.
Planning Standard M Revision 32
Page 129 of 221 The recovery procedures that must be developed following a radiological incident will vary, but in general they will include the following activities:
- 1. Damage evaluation
- 2. Decontamination measures
- 3. Repair procedures
- 4. Disposal procedures
- 5. Ensure adequate offsite response readiness
- 6. Test and start-up procedures M.2. Recovery Organization The Recovery Organization is addressed in the Emergency Plan Procedures. See Appendix A for cross-reference.
M.3. Recovery Initiation Notification Normal communications channels will be utilized to notify State, County and other response organizations of the start of recovery operations and any changes occurring within the plans, procedures and response organization. Recovery operations affecting or interfacing with offsite responsibilities will be reviewed and approved by the appropriate response manager.
M.4. Estimating Population Total Exposure Not addressed.
Planning Standard M Revision 32
Page 130 of 221 PLANNING STANDARD N EXERCISES AND DRILLS Planning Standard N Revision 32
Page 131 of 221 N. EXERCISES AND DRILLS N.1 Exercises N.l.a. Exercise Content Each exercise will be conducted in accordance with a unique scenario developed for that exercise. Each exercise tests portions of emergency preparedness plans within the AEP system, State and County. The plant will also participate in joint exercises initiated and coordinated by the NRC and FEMA to test the effectiveness of the emergency plan(s) at all levels.
The ultimate criteria against which the results of exercises are to be measured will be effective implementation of the plant's and participating response organization emergency response plans to a simulated event, and the manner in which all agencies, public and private, interface their plans to assure that the public health and safety is protected.
N.i.b. Exercise Scheduling An annual emergency exercise is conducted at CNP to test various basic elements of the emergency preparedness program. Biennially, this exercise is conducted with participation of offsite emergency personnel, including those of State and County agencies.
Off-hours shift augmentation drills ensure that the goals of Table 1, CNP Staffing for Radiological Emergencies, are being met. These drills are to be conducted semi-annually. One of these drills per calendar year will include the contacted personnel reporting to their assigned emergency facilities and activating the facility. Credit can be taken for normal shift personnel above that indicated for "On-shift" to meet the augmentation goals.
Scenarios will be varied from year to year such that all major elements of the Emergency Plan, Emergency Plan Procedures and Emergency Response Organizations are tested within a 5 year period (see Appendix J, Eight Year Plan Matrix, for 8 year plan).
N.2 Drills N.2.a. Communication Drills Communications is a part of each drill and exercise. Links are established between the off-site agencies and the Cook ERO, or plant personnel playing the part of the off-site agencies communicate with the ERO communicators.
Communication links between the Plant emergency facilities are established as a part of each drill or exercise. Anytime Offsite Survey Teams are dispatched for drill or exercises communication and control with the teams is established.
N.2.b. Fire Drills Quarterly fire drills are conducted to ensure participation biannually by site fire brigade members.
An annual fire drill is held that includes participation of an offsite fire department.
N.2.c. Medical Emergency Drills An exercise simulating radiological and physical injury shall be conducted with the offsite medical personnel annually.
Planning Standard N Revision 32
Page 132 of 221 N.2.d. Radiological Monitoring Drills Drills involving response to, and analysis of, simulated airborne, liquid, and environmental (vegetation, snow, soil, etc.) samples and direct radiation measurements in the environment shall be conducted semi-annually.
N.2.e. Health Physics Drills N.2.e.1. Environmental Monitoring Drills involving response to, and analysis of, simulated airborne, liquid, and environmental (vegetation, snow, soil, etc.) samples and direct radiation measurements in the environment shall be conducted semi-annually.
N.2.e.2. Plant Liquid Monitoring PASS removed by Operating License change #261 and 244 for Ul and 2 respectively delete requirements for Post Accident Sampling System.
N.2.f. Other drills N.2.f.1 Hostile Action Based Drills Drills involving response to the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an. end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. (NRC Commitment 8373.)
N.2.f.2 Fast Breaking Drills Drills involving an initial classification of, or rapid escalation to, a Site Area Emergency or General Emergency.
N.2.f.3 No radiological release or minimal release.
Drills involving declaration of a Site Area Emergency but not a General Emergency that involve no radiological release or an unplanned minimal radiological release.
N.3. Drill and Exercise Execution Each scenario shall be jointly developed by appropriate response agencies participating in the exercise and shall include:
N.3.a Basic objective(s) of the exercise N.3,b. Date, time and place and participating response agencies, and the extent to which participating agencies will respond.
N.3.c. Simulated events, which may include offsite radiological releases.
N.3.d. Time Line of real and simulated events.
N.3.e. Narrative summary describing the conduct of the exercise.
N.3.f. Arrangements for official observers, and advance materials to official observers.
Planning Standard N Revision 32
Page 133 of 221 N.4. Official Observation and Critique After the drill or exercise, a critique shall be conducted involving participants, controllers and observers. The critique should be held as soon as practicable after completion of the drill or exercise.
N.5. Results Evaluation and Corrective Actions A formal evaluation of exercises, with lessons learned, shall be prepared and submitted through the Corrective Action Program. The Emergency Preparedness Manager (or alternate) shall review and assign action items to upgrade those areas where deficiencies were noted. These action items will be assigned, tracked and closed using the plant corrective action program.
Planning Standard N Revision 32
Page 134 of 221 PLANNING STANDARD 0 RADIOLOGICAL EMERGENCY RESPONSE TRAINING Revision 32
Page 135 of 221
- 0. RADIOLOGICAL EMERGENCY RESPONSE TRAINING 0.1 Organization Training Cook Nuclear Plant provides training to agencies or organizations that provide onsite assistance to the plant. Types of organizations provided this training are as follows:
Local Law Enforcement Ambulance Service Fire Departments Hospitals Training should be offered annually. Should any of these agencies requestthe additional request.training, taken to facilitate either in scope or schedule, every possible action should be The training of Berrien County and State of Michigan emergency response personnel is the responsibility of the Michigan State Police Emergency Management and Homeland Security Division. The Cook Nuclear Plant is committed to assist in the endeavor upon request.
0.2. Onsite ERO Training The plant training program is the responsibility of the Training Manager.
A general employee training program provides initial orientation training and annual (every 12 months) retraining to CNP employees in the general emergency plan response. They are familiarized with the sounding of the Nuclear Emergency Alarm, assembly areas and routes to take to these assembly areas. This training also includes general aspects of the Emergency Plan.
ERO position specific training and qualification is administered through TPD-600-EPT Emergency Preparedness Training Program Description. Position specific Job Familiarization Guides are used for on-the-job training and qualification of the ERO responders.
0.3. First Aid Team Training Personnel who respond to medical emergencies at the Cook Nuclear Plant receive either first-aid training or are.qualified as Medical Emergency Response Team members (MERT).
0.4 ERO Traininq and Qualification To the maximum extent practicable, emergency plan training and qualification should be incorporated into functional training and qualification programs.
Specialized initial training and retraining programs will be provided as outlined below for the following categories of emergency personnel.
0.4.a. Directors and Key Personnel Initial specialized training in emergency plan and procedures implementation is provided to the directors and coordinators of the response organizations including emergency plan drill participation and annual reviews of the same. Training for execution of the emergency plan is provided by completion of senior licensed operator training, or equivalent training that applies to emergency plan execution.
Planning Standard 0 Revision 32
Page 136 of 221 O.4.b. Personnel Responsible for Accident Assessment Initial specialized training in emergency plant operations, emergency plan and procedures implementation is provided including an annual review of the same. Further training includes participation in emergency plan drills.
O.4.c. Radiological Monitoring Teams Radiation Protection personnel receive Emergency Plan training as part of their Initial RP Technician training. Continuing Training and drill participation requirements addressed in TPD-600-EPT, Emergency Preparedness Training Program Description.
O.4.d. Security-& Fire Brigade Fire Brigade staff receive Initial and annual retraining in fire fighting techniques and first aid.
The Plant Security force is considered the Emergency Security Team. All actions required during emergencies are included in security officer training.
O.4.e. Onsite Repair & Damage Control The Damage Control Team is responsible for the repair and restoration of damaged plant systems, equipment, or components. Training, exercises and drills involving the Damage Control Team will be conducted in a manner consistent with established Emergency Plan Procedures.
O.4.f. First Aid & Rescue Teams The first-aid training program is administered by the Training Department.
The MERT program is administered by an accredited offsite institution.
O.4.g. Local Service Personnel (Offsite Fire Department Personnel and Local Sheriff)
The local Fire Departments receive familiarization in specific plant access and control procedures and participate annually in plant fire drills.
Sheriffs department receives annual Emergency Alert System (EAS) training and participates in the annual plant emergency exercise.
O.4.h. Medical Support Personnel An exercise simulating radiological and physical injury shall be conducted with the offsite medical personnel annually.
O.4.i. Licensee Headquarters Support Not addressed.
O.4.j. Personnel Transmitting Emergency Information and Instructions ERO Communicators receive ERO initial training and position specific Job Familiarization Guides for their specific communication duties.
Planning Standard 0 Revision 32
Page 137 of 221 0.5. Initial and Annual Retraining Initial training and qualification, as well as continuing training requirements addressed in TPD-600-EPT, Emergency Preparedness Training Program Description.
Initial training and job familiarization completed prior to assignment to the ERO.
Continuing training consists of the following (as minimum):
Drill participation at least once every two years.
ERO Facility training.
Annual ERO Classroom training or a requalification challenge exam.
Planning Standard 0 Revision 32
Page 138 of 221 PLANNING STANDARD P RESPONSIBILITY FOR PLANNING EFFORT Planning Standard P Revision 32
Page 139 of 221 P. RESPONSIBILITY FOR PLANNING EFFORT P.1 Emergency Planner Training Emergency Preparedness Coordinator position specific training and qualification is administered through TPD-600-EPC Emergency Preparedness Coordinator Training Program Description.
Position specific training and qualification card are used for training and qualification of Emergency Preparedness Coordinators.
P.2 Emergency Plan Administration Responsibility The Senior Vice President - Nuclear Generation Group shall have overall authority, and responsibility for radiological emergency response planning. In this effort he has the authority to delegate responsibility in the planning effort to enhance the overall readiness and ensure that the plan is updated as necessary. Normally plan updating and review will be the responsibility of the Vice President - Site Support Services. The training of individuals in the CNP Emergency Response Organization (ERO) in the Emergency Plan shall be the responsibility of the Training Manager.
P.3 Emergency Planning Coordinator Designation Not addressed.
P.4. Periodic Reviews Updates and Audits The responsibilities of the individuals, groups, agencies, the Emergency Plan, and implementation procedures to be followed during an emergency condition are reviewed at a minimum, on an annual basis and updated as required. All written agreements with offsite support groups are reviewed and updated if necessary, on a two year basis. This review will take into account changes identified by drills and exercises. The plant maintains up-to-date approved emergency response plans from the state and county. Changes to these offsite plans are reviewed to maintain an effective interface with the Cook Emergency Plan.
The Plant Operations Review Committee is responsible for the review of changes to the Emergency Plan. The Plant Operations Review Committee is also responsible for the review of changes, other than editorial corrections, to. the Emergency Plan Implementing Procedures. The Senior Vice President - Nuclear Generation Group, or designee, shall approve changes to the Emergency Plan.
All reviews shall be documented. The Senior Vice President-Nuclear Generation Group shall be sent copies of the changes. NRC approval shall be obtained as appropriate.
P.5. Emeraency Plan Change Communication Approved Emergency Plan revisions and/or applicable procedural changes will be promptly forwarded to appropriate offsite emergency support organizations.
A list of changes to the Emergency Plan shall be submitted with each plan revision. Changes to the Plant's Emergency Plan Procedures shall be made in accordance with plant practice for revising procedures.
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Page 140 of 221 P.6 Emergency Response Organization Support Plans Plan Source Emergency Operations Plan Berrien County Sheriffs Office Michigan Emergency State of Michigan Management Plan Regional Plan Handbook - RAP Department of Energy Region V INPO Emergency Response Institute of Nuclear Power Operations Manual National Response Plan, Department of Homeland Security with NRC Nuclear/Radiological Incident as Coordinating Agency Annex P.7. Implementing Procedures Detailed procedures for implementing and providing additional information on the Emergency Plan are available in the Emergency Plan Procedures. The written procedures indicated in Appendix A cover the following but are not limited to:
- 1. Authority and responsibility for completing specific tasks.
- 2. Action levels requiring implementation of protective measures outlined.
- 3. Medical treatment procedures and handling of contaminated individuals.
- 4. Necessary equipment for medical treatment, radiation detection, and rescue operations.
- 5. Identification of emergency communications equipment.
- 6. Emergency center description and operation.
- 7. Restoration procedures from emergency to normal conditions.
- 8. Communications P.8 Table of Contents & Cross-reference Table of Contents and Appendix A fulfill this requirement.
P.9. Independent Emergency Program Review Audits of the Emergency Plan and implementing procedures are performed as delineated in 10 CFR 50.54(t)(1). These audits shall be performed by the Plant Performance Assurance Department and may include items relating to training, readiness testing, equipment, State/lfocal plant interfaces, medical arrangements, etc.
Audit findings shall be reported, evaluated and recommendations completed as described in the Audit Program Policy. The results of the audit, along with the recommendations for improvements shall be documented and reported to plant management and retained for a period of five years.
Reviews involving the adequacy of interface with State/local agencies shall be available to the appropriate agency.
P.10. ERO Telephone Number Updates Appendix J fulfils this requirement.
Planning Standard P Revision 32
Page 141 of 221 APPENDIX A
- 1. INDEX OF PLANT EMERGENCY PLAN PROCEDURES
- 2. CROSS REFERENCE BETWEEN THE COOK NUCLEAR PLANT AND THE PLANT EMERGENCY PROCEDURES Appendix A Revision 32
Page 142 of 221 DONALD C. COOK NUCLEAR PLANT PLANT MANAGER PROCEDURES EMERGENCY PLAN PROCEDURES CONTROL ROOM IDENTIFICATION NUMBER TITLE RMA-2080-EPA-008 EMERGENCY PLAN MANAGEMENT PMP-2080-EPP-1 00 EMERGENCY RESPONSE PMP-2080-EPP-101 EMERGENCY CLASSIFICATION PMP 2080-EPP-108 INITIAL DOSE ASSESSMENT PMP 2080-EPP-200 INITIATING CHANGES TO THE EMERGENCY PLAN OR EMERGENCY PLAN IMPLEMENTING PROCEDURES PMP-2081-EPP-105 CORE DAMAGE ASSESSMENT RMT-2080-EOF-001 ACTIVATION AND OPERATION OF THE EOF RMT-2080-EOF-002 EMERGENCY TERMINATION AND RECOVERY RMT-2080-JIC-001 ACTIVATION AND OPERATION OF THE ENC/JIC RMT-2080-OSC-001 ACTIVATION AND OPERATION OF THE OSC RMT-2080-TSC-001 ACTIVATION AND OPERATION OF THE TSC Appendix A Revision 32
Page 143 of 221 NUREG-0654 - EMERGENCY PLAN - PROCEDURE CROSS REFERENCE At Cook Nuclear Plant, NUREG-0654 is applied as guidance in plan and procedure development with consideration to plant organization, administrative policies and operating procedures.
NUREG-0654 (11Planning EMERGENCY Standards and Evaluation PLAN SECTION PLANT PROCEDURE Criteria)
A.1.a A.1.a Not applicable B.8 B.9 A.1.b A.1.b Not applicable A.1.c A.1.c Not applicable
.Figure 1 Figure 2 Figure 3 Figure 4 Figure 5 Figure 6 Figure 7 Figure 8 Figure 9 Figure 10 A.l.d A.1.d PMP-2080-EPP-100 RMT-2080-EOF-001 A.1.e A.1.e RMT-2080-EOF-001 Table I A.2. Not applicable Not applicable A.3 A.3 RMA-2080-EPA-008 Appendix B A.4 A.4 RMT-2080-EOF-001 RMT-2080-OSC-001 RMT-2080-TSC-001 B.1 B.1 Not applicable Figure 3 Figure 4 Appendix A Revision 32
Page 144 of 221 B.2 B.2 PMP-2080-EPP-100 B.1.j.
B.5.a.1 B.5.c.1 B.3 B.3 PMP-2080-EPP-100 RMT-2080-TSC-001 RMT-2080-EOF-001 B.4 B.4 PMP-2080-EPP-100 RMT-2080-EOF-001 B.5 B,5 RMT-2080-OSC-001 Table I RMT-2080-TSC-001 Figure 5 RMT-2080-EOF-001 Figure 6 RMT-2080-JIC-001 Figure 7 ERO On-Shift Staffing Figure 8 Analysis Report B.6 B.6 Not applicable Figure 8 B.7 B.5 ERO On-Shift Staffing Table 1 Analysis Report B.7.a B.7.a RMT-2080-EOF-001 B.5.c.9 B.7.b B.7.b RMT-2080-TSC-001 B.5.c.8 B.7.c B.7.c RMT-2080-EOF-001 B.5.c.1 B.7.d B.7.d RMT-2080-JIC-001 B.5.d.1 B.8 B.8 Not applicable C.4 Appendix B B.9 B.9 Not applicable L.1 Appendix B C.I.a C.1.a Not applicable C.1.b C.1.b Not applicable Appendix E C.1 .c Appendix E Not applicable C.2.a Not applicable Not applicable C.2.b B.5.e.1 RMT-2080-EOF-001 C.3 H.6.c RMT-2080-EOF-001 Appendix B Appendix A Revision 32
Page 145 of 221 Appendix H C.4 C.4 RMT-2080-EOF-001 B.8 Appendix B Appendix H D.1 D.1 PMP-2080-EPP-101 Table 2 Table 3 Table 4 D.2 D.2 PMP-2080-EPP-101 Table 2 Table 3 Table 4 D.3 Not applicable Not applicable D.4 Not applicable Not applicable E.1 E.1 PMP-2080-EPP-1 00 E.2 E.2 PMP-2080-EPP-100 SPP-2060-SFI-216 E.3 E.3 PMP-2080-EPP-100 E.4 E.4 PMP-2080-EPP-1 00 RMT-2080-EOF-001 E.5 Not applicable Not applicable E.6 E.6 Not applicable Appendix D E.7 E.7 PMP-2080-EPP-100 RMT-2080-EOF-001 F.1.a F.1.a PMP-2080-EPP-100 F.1.b F.1.b RMT-2080-EOF-001 F.1.c F.1.c. RMT-2080-EOF-001 Appendix E F.1.d F.1.d RMT-2080-EOF-001 F.1.e F.1.e. PMP 2080-EPP-100 F.1.f F.1.f RMT-2080-EOF-001 F.2 F.2 Not applicable F.3 F.3 EPP-2080-ERO-001 G.1 G.1 Not applicable Appendix D Appendix A Revision 32
Page 146 of 221 G.2 G.2 Not applicable G.3.a G.3. RMT-2080-JIC-001 G.3.b Not addressed Not applicable G.4.a G.4.a RMT-2080-JIC-001 G.4.b G.4.b. RMT-2080-JIC-001 G.4.c G.4.c. RMT-2080-JIC-001 G.5 G.5. Not applicable H.1 H.1 (TSC) RMT-2080-TSC-001 H.3 (OSC) RMT-2080-OSC-001 H.2 H.2 RMT-2080-EOF-001 H.3 Not applicable (SEOC/CEOC) Not applicable H.4 H. PMP-2080-EPP-1 00 H.5 H.5 RMT-2080-TSC-001 H.5.a H.5.a RMT-2080-EOF-001 RMT-2080-OSC-001 H.5.b H.5.b RMT-2080-TSC-001 H.5.c H.5.c RMT-2080-TSC-001 H.5.d H.5.d Not applicable H.6 H.6 RMT-2080-EOF-001 H.6.a H.6.a RMT-2080-EOF-001 ERO PHONE DIRECTORY H.6.b H.6.b RMT-2080-EOF-001 EPP-2080-ERO-001 H.6.c H.6.c RMT-2080-EOF-001 H.7 H.7 EPP-2080-ERO-001 H.8 H.8. RMT-2080-EOF-001 H.9 H.3 RMT-2080-OSC-001 H.10 Appendix J EPP-2080-ERO-001 H. 11 Appendix C EPP-2080-ERO-001 H.12 H.3.d. RMT-2080-EOF-001 Appendix A Revision 32
Page 147 of 221 1.1 1.1. PMP-2080-EPP-101 Table 2 Table 3 Table 4 1.2 1.2 RMT-2080-EOF-001 1.3.a 1.3.a. RMT-2080-EOF-001 1.3.b 1.3.b. RMT-2080-EOF-001 1.4 1.4 RMT-2080-EOF-001 1.5 1.5 RMT-2080-EOF-001 1.6 Not addressed Not applicable 1.7 1.7 RMT-2080-EOF-001 1.8 1.8 RMT-2080-EOF-001 1.9 1.9 RMT-2080-EOF-001 1.10 Not addressed RMT-2080-EOF-001 1.11 Not applicable RMT-2080-EOF-001 J.1.a J.1.a RMT-2080-TSC-001 J. 1.b. J.1.b. RMT-2080-TSC-001 J.1.c. J.1.c. RMT-2080-TSC-001 J.1.d. J. 1.d. RMT-2080-TSC-001 J.2 J.2 RMT-2080-TSC-001 Figure 14 J.3 J.3 RMT-2080-TSC-001 J.4 J.4 RMT-2080-TSC-001 J.5 J.5 RMT-2080-TSC-001 J.6.a J.6.a. RMT-2080-EOF-001 J.6.b J.6.b. RMT-2080-EOF-001 J.6.c J.6.c. RMT-2080-EOF-001 J.7 J.7 RMT-2080-EOF-001 J.8. J.8, PMP-2080-EPP-100 Berrien County Emergency RMT-2080-EOF-001 Operations Plan Appendix A ý Revision 32
Page 148 of 221 J9 Not Applicable Not Applicable J.19.a. J.10.a. Not applicable J.10.b J.10.b. Not Applicable J.10.c. J.10.c. Not Applicable E.6.
J.10.m. J.10.d. PMP-2080-EPP-100 1.4. RMT-2080-EOF-001 1.5.
K.1la-g K.1 RMT-2080-TSC-001 K.2 K.2 RMT-2080-TSC-001 K.3.a K.3.a. RMT-2080-OSC-001 K.3.b. RMT-2080-OSC-001 K. Not Applicable Not Applicable K.5.a K.5.a. PMI-6010 K.5.b K.5.b EPP-2080-ERO-001 K.6.a. K.6.a. PMI-6010 K.6.b. Not Addressed K.6.c. K.6.c. PMI-6010 K.7 K.7 PMI-6010 L.1 L.i. PMI-6010 L.2 L.2. Not applicable L.3. Not Applicable Not applicable L.4 L.4 Not applicable M.1 M.A RMT-2080-OSC-001 M.2 M.2 RMT-2080-EOF-002 M.3 M.3 RMT-2080-EOF-002 M.4 Not addressed Not applicable N.1.a N.i.a PMI-2080 N.1.b. N.1.b. PMI-2080 AppendixJ Appendix A Revision 32
Page 149. of 221 N.2.a N.2.a. PMI-2080 N.2.b Tech. Spec. PMI-2270 N.2.c N.2.c. EPAM-2080-000 Appendix J N.2.d N.2.d. PMP-2080-EPP-500 N.2.e N.2.e PMP-2080-EPP-500 N.3 N.3 PMP-2080-EPP-500 N.4 N.4 PMP-2080-EPP-500 N.5 N.5 PMP-2080-EPP-500 0.1 0.1 TPD-600-EPT O.1.a. 0.1 TPD-600-EPT 0.1.b. Not applicable Not applicable 0.2 0.2 TPD-600-EPT 0.3 0.3 EPAM-2080-000 0.4.a 0.4.a. TPD-600-EPT 0.4.b 0.4.b. TPD-600-EPT 0.4.c. 0.4.c. TPD-600-EPT 0.4.d. 0.4.d. Not addressed 0.4.e. 0.4.e. TPD-600-EPT 0.4.f. 0.4.f. Not addressed 0.4.g. 0.4.g. Not addressed 0.4.h. 0.4.h. Not addressed 0.4.i. Not addressed Not addressed 0.4.j. 0.4.j. TPD-600-EPT 0.5 0.5. TPD-600-EPT P.1 P.1 TPD-600-EPC P.2 P.2 PMI-2080 P.3 Not addressed PMI-2080 Appendix A Revision 32'
Page 150 of 221 P P.4. PMI-2080 P.5 P.5 PMP-2030-DOC-001 P.6 P.6 Not applicable P.7 Appendix A Not applicable P.8 Table of Contents Not applicable Appendix A P.9 P.9 Not applicable P.10 Appendix J EPAM-2080-000 Appendix A Revision 32
Page 151 of 221
-APPENDIX B AGREEMENTS WITH OFF-SITE SUPPORT AGENCIES Appendix B Revision 32
Page 152 of 221 APPENDIX B Agreements with Off-Site Support Agencies
- 1. Sheriff Department, Berrien County, Michigan 1 page July 13, 2012
- 2. Lakeland Medical Center 1 page September 17, 2012
- 3. Lake Township Fire Department 1 page September 14, 2012
- 4. City of Bridgman Fire Department 1 page September 19, 2012
- 5. Medic 1 Community Emergency Service 2 pages September 13, 2012
- 6. Reciprocal Laboratory Use Agreement 2 pages December 15, 2011
- 7. Mutual Assistance Agreement Between Detroit Edison 6 pages January 09, 2013 Company, Entergy Nuclear Palisades and Indiana Michigan Power Co.
- 8. Institute of Nuclear Power Operations Emergency Resources 1 page October 30, 2012
- 9. Voluntary Assistance Agreement By and Among Electric Utilities 9 pages January 17, 2003 Involved in Transportation of Nuclear Materials
- 10. Nuclear Power Plant Emergency Response Voluntary 12 pages January 17, 2003 Assistance Agreement
Page 153 of 221 Sheriff Department, Berrien County, Michigan 1 page BwwE CoUr'rry EMEIGENCY MANAGEmtNT D.v-sIoN. OF B R"EN COUNTY S RiDTx'S .O.V*ýc DAVEYPAGEL 2100 E. EiolpreAvenae, Bentonl Harbor, *tfidiigan 49022 'kXRD0'CoAWM,1sAi0 Telephone (269).983-7141, Fihx: (269) 983-5726
- 1. PAUL RAILEY C.'*PT,COREYDURKS 7113/2012 Mr. James W. Chambers Cook Nuclear plant Onehcook Place Brldgman., Ml 49106
Dear Mr. Chambers:
We Wish to reaffirm thewillingnesg ofh'e BdrlAri County heriff's Depkqr..en. tospornd upon request to Any Amfergency which could occ*r attlte DC.. 0Cok facility. Beilten "
County Emergency Managenient/Office of'Homeland Security has the obligation to respond ppon n0lification that an emergency exists.. Berrien County wuid Implement the r NuclearAccident PtocbdUres (Appendix 1) 6f the Emergency Operations Pian and take Appropriate actionsas outlined therein, In addition, the Sheriff's.Department has basic patrol and Investigative services ahd currently has a fourteen member Hazardous Materials Response Team who Is trained to Technician Level, Five of the f6urteeri Haz-Mat team members are cross-trained as bomb tachniclans, all of Whom have su.coeasfdslycomplted the United States A y Haxardous wevice School at Redstone Arsenal in lRedstonr, Alabahia. Our tacical unk corrisit:O f 21 pemonnel who conduct a monthly training.
May we again assire you that th sve ,r*q bf the Badnjoh Countly Sheriffds Department will b9 available to you uponr request in aiy area within the jdrsdictlon of this age*loy.
Sincerely, L.RPaul Bailey SlherfffIDire~clor, *Emergency Manlagement L:PBlgr6 ORIGINAL Appendix B Revision 32
Page 154 of 221 1 page Lakeland Medical Center Lakeland HealthCare Medical Excellence. Compassionate Care.
September 17, 2012 Mr. Joel Gobble Sr. Vice President & Chief Nuclear Officer Cook Nuclear Plant One Cook Place Bridgman, MI 49106
Dear Mr. Gobble:
This letter is to confirm that Lakeland HealthCare provide care for the injured radioactively-contaminated patient at the St. Joseph and Niles Emergency Department sites to Include Donald C. Cook personnel on site and members of the general public off-site that may require services from Plant operations.
Annual training and drills will be conducted to assure staff competency in caring for this patient population, with evaluation by FEMA. A policy and procedure manual Is available at each site and updated regularly to incorporate changes in patient management. An identified Radiation Emergency Area (REA) is available at each site that allows for stabilization, treatment, and management of the radioactive component ofthe emergency. I understand that the training for hospital personnel, equipment, and stocking of the disaster cart will be provided byDonald C. Cook Nuclear Plant.
This agreement shall remain in effect from the date of signing unless the agreement Is terminated. Any party upon ninety (90) days prior written notice to the other party, may terminate this agreement.
Please contact Kathy Effa, Manager of Emergency Services, at 269-983-8670 for any assistance that you require.
Sincerelvr
-L-6ren B. Hamel, MD President &CEO Lakeland HealthCare LBH:nb 1234 Napier Avenue, St. Joseph, Ml 49085 (269) 983-8300 www.lakelandhealth. org
. ... Revision 32 Appendix 1:
Page 155 of 221 Lake Township Fire Department 1 page LAKE TOWNSHIP FIRE AND RESCUE P.O. BOX 818 3169 SHAWNEE ROAD BRIDGMAN, MICHIGAN 49106 269-465-6351 Emergeenv Presaredness Asreement Between Lake Charter Township Fire DMartment and Donald C. Cook Nuclear Plant Upon receipt of a request for -assistance from the Cook Nuclear Plant, Lake Charter Township Fire Department agrees to respond by sending personnel, apparatus, and equipment to the Cook Nuclear Plant site.
The Cook Nuclear Plant agrees to lead Lake Charter Township Fire Department responders from the Security Control Center to the scene and agrees to provide escorts for Lake Charter Township Fire Fighting vehicles and personnel while in the Protected Area, or other owner controlled areas.
The Cook Nuclear Plant and Lake Charter Township Fire Department agree that for all fires in the Plant Protected Areas, the Plant Fire Brigade Leader will be responsible for fire extinguishment with the assistance of Lake Charter Township Fire Department personnel and advice and counsel of the Lake Charter Township Fire Chief or his designee.
For fires outside the Plant Protected Area, the Lake Charter Township Fire Chief shall be responsible for fire extinguishment with the advice and counsel of the Plant Fire Brigade Leader or designee if they are present.
The Cook Nuclear Plant agrees to provide and Lake Charter Township Fire Department agrees to participate in annual site specific training and drills conducted at the Cook Nuclear Plant site.
This agreement shall remain in effect from the date of signing unless the agreement is terminated.
Any party upon ninety (90) days prior written notice to the other party may terminate this agreement.
As an indication of your agreement to the above statements concerning our mutual responsibilities, please sign below.
Sincerely, Accepted and agreed to this 4 4 day ot.6 "1 h ,&b, 2012 Joel Gebbie Site Vice President Supervisor Cook Nuclear Plant Lake Charter Township Fire Chief Lake Charter Township Fire Department Appendix B Revision 32
Page 156 of 221 City of Bridgman Fire Department 1 page BRIDGMAN FIRE RESCUE P.O. BOX 366 4234 VINE STREET BRIDGMAN MICHIGAN 49106 (269)-465-3803 (269)-465-5144 FAX (269)-465-3701 EMERGENCY 911 Emergency Preparedness Agreement Between Bridgman City Fire Department and Donald C.
Cook Nuclear Plant Upon receipt of a request for assistance from the Cook Nuclear Plant, Bridgman City Fire Department agrees to respond by sending personnel, apparatus, and equipment to the Cook Nuclear Plant site.
The Cook Nuclear Plant agrees to lead Bridgman City Fire Department responders from the Security Control Center to the scene and agrees to provide escorts for Bridgman City Fire Fighting vehicles and personnel while in the Protected Area, or other owner controlled areas.
The Cook Nuclear Plant and Bridgman City Fire Department agree that for all fires In the Plant Protected Areas, the Plant Fire Brigade Leader will be responsible for fire extinguishment with the assistance of Bridgman City Fire Department personnel and advice and counsel of the Bridgman City Fire Chief or his designee.
For fires outside the Plant Protected Area, the Bridgman City Fire Chief shall be responsible for fire extinguishment with the advice of Lake Charter Township Fire Chief and counsel of the Plant Fire Brigade Leader or designee if they are present The Cook Nuclear Plant agrees to provide and Bridgman City Fire Department agrees to participate in annual site specific training and drills conducted at the Cook Nuclear Plant site.
This agreement shall remain In effect from the dale of signing unless the agreement is terminated.
Anyparty upon ninety (90) days prior written notice to the other party may terminate this agreement.
As an indication of your agreement to the above statements concerning our mutual responsibilities, please sign below.
Sincerely, Accepted and agreed to this
____day of S 9 4&- .2012 Joel Gebbie Non Birmingham Site Vice President Bridgman City Mayor Cook NuclearPlant Rich Knuth Fire Chief Bridgman City Fire Department Appendix B Revision 32
Page 157 of 221 Medic I Community Emergency Service 2 pages
- ravxrnxiliIc MDIC Emergency PlanningAgreetnent Between Medic 1 Ambudance and DonaldC Cook Nuclear Plant The purpose of this letter is to establish an agreement between Indiana and Michigan Electric Company's Donald C. Cook Nuclear Plant and Medic 1 Ambulance. In the event of an emergency at the Cook Nuclear Plant involving an injury, Medic I Ambulance agrees to provide medical care whether the victim has been injured.as the result of an accident involving radioactive contamination, hazardous waste, or a regular work accident.
Upon receipt of a request for an EMS vehicle from the Cook Nuclear Plant Control Room, Medic 1 Ambulance agrees to respond by sending personnel, apparatus, and equipment to the Plant site.
Cook Nuclear Plant agrees to provide an escort for.EMS vehicles and personnel while in the protected area.
Cook Nuclear Plant agrees to provide the necessary health physics support to Medic I Ambulance staff during the treatment of victims who are injured in an accident involving radioactive contamination.
In the event of an injury involving a hazardous waste, specific chemical information will be provided to Medic I Ambulance staff.
The communication link between Medic I Ambulance and Cook Nuclear Plant will be provided via telephone communication through the Berrien County dispatch radio.
Cook Nuclear Plant agrees to provide training for emergency room and EMS personnel in order to prepare them for handling oftradiologically contaminated victims. Such training will consist of, but not be limited to, a discussion of types of radiation, types of contamination, methods of decontamination, and methods of controlling the spread of contamination.
Cook Nuclear Plant agrees to conduct and Medic I Ambulance agrees to participate injoint drills that include plant personnel, EMS personnel, and emergency room personnel. These drills will meet Joint Commission on Accredited Hospitals (JCAHT) requirements.
Cook Nuclear Plant agrees to decontaminate all Medic I Ambulance equipment and facilities including EMS vehicles that have become contaminated as a result ofetreatment ofa victim in a timely fashion and to dispose of the associated waste.
Cook Nuclear Plant agrees to provide emergency kits for the emergency room and the ambulance.
P.O. Box 1563 / Benton Harbor, MI 49023 / Phone (269) 925-2141 Appendix B Revision 32
Page 158 of 221 Medic 1 Ambulance agrees that medical care provided under this agreement includes any assistance rendered through existing mutual aid agreements entered into by Medic 1 Ambulance.
Any party, upon ninety (90) days prior notice to the other party, may terminate this agreement.
As indication of your agreement to the above statement concerning our mutual responsibility, please sign below.
Jack *lsher, Jr.-
Site Vice President Executive Director Cook Nuclear Plant Medic I Ambulance Dated: 9/l'b,1 2- Dated: Septembex 7, 2012.
Appendix B Revision 32
Page 159 of 221 Reciprocal Laboratory Use Agreement 2 pages RECIPROCAL LABORATORY USE AGREEMENT WITNESSETH THAT WHEREAS, INDIANA MICHIGAN POWER, (hereinafter called IMP) and ENTERGY NUCLEAR PALISADES, L.L.C., (hereinafter called "ENTERGY") have chemical and radiochemical analytical laboratories at their Donald C Cook Nuclear Plant and Palisades Nuclear Plant, respectively, which laboratory facilities are suitable for performing chemical analyses following a nuclear-related accident (NRA), and WHEREAS, IMP and Entergy each desire to provide the temporary use of their respective existing laboratory facilities and personnel to perform chemical analyses for the other in the event the other has lost use of its laboratory facilities due to a NRA, NOW, THEREFORE, the parties hereto do hereby mutually agree as follows:
- 1. In the event either party hereto is unable to use its laboratory facilities due to a NRA, the other party agrees to temporarily use Its existing laboratory facilities and personnel, to the extent practical, to analyze without charge, samples delivered to it by the party which suffered the NRA. Each party agrees, in connection with such sampling, handling and analyses, to comply with the requirements of NUREG-0578 and NUREG-0737 and such other requirements as may be specified by the Nuclear Regulatory Commission in regard to past-accident sample analysis.
- 2. Each party agrees, in performing analyses for the other, to provide a high standard of professional service, provided, however, that neither party shall have any obligation or liability for damages, including, but not limited to, consequential damages, arising out of or in connection with the others use of, or reliance on, the results of such analyses.
- 3. This agreement shall be effective on the date hereof and shall continue until terminated as hereinafter set forth. Either party hereto may terminate this agreement at any time hereafter upon sixty (60) days written notice of termination to the other party.
Appendix B Revision 32
Page 160 of 221 INDIANA MICHIGAN POWER BY: ~ r'VI4~ z4~1 Joel P. Gebbie Date Site Vice President DC Cook Nuclear Plant ENTERGY NUCLEAR PALISADES, L.L.C.
BY: &~AJJLL1LJ2 Anthony d. Date Site Vicex dent - Palisades Appendix B Revision 32
Page 161 of 221 Mutual Assistance Agreement Between Detroit Edison Company, Entergy Nuclear 6 pages Palisades and Indiana Michigan Power Co.
MUTUAL ASSISTANCE AGREEMENT BETWEEN DETROIT EDISON, ENTERGY NUCLEAR PAUSADES, L.LC.
AND INDIANA MICHIGAN POWER Appendix B Revision 32
Page 162 of 221 0.1 Entergy Nuclear Palisades, LL.C., Detroit Edison and Indiana Michigan Power, WITNESSETH 0.2 WHEREAS, Entergy Nuclear Palisades, (LLC), Detroit Edison and Indiana Michigan Power own electric facilities, Including nuclear generation stations and are engaged In the generation of electric power In Michigan; and 0.3 WHEREAS, the parties desire to help assure the availability of adequately trained and experienced emergency personnel in the event of an emergency situation at any of their nuclear generating stations; 0.4 NOW, THEREFORE, in consideration of the promises and mutual covenants herein set forth, the parties agree as follows:
ARTICLE I DEFINITIONS 1.1 "Alert" shall be defined as a situation in which events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant.
1.2 "Emergency" shall be defined consistent with the definition of osite area emergency as set forth in NUREG 0654 as a situation in which events are In process or have occurred which Involve actual or likely major failures of plant functions needed for protection of the public.
1.3 "Requesting party" shall be defined as any party to this Agreement who, upon the occurrence of an emergency at one of its nuclear generating stations, seeks emergency assistance, pursuant to this Agreement, from one or more of the parties hereto.
1.4 "Responding party" or responding parties shall be defined as any party or parties to this Agreement who are presented with a request for emergency assistance pursuant to this Agreement.
Appendix B Revision 32
Page 163 of 221 ARTICLE II REQUESTS FOR EMERGENCY ASSISTANCE 2.1 In the event of an Alert at one of its nuclear generating stations, any party to this Agreement may notify any or all of the other parties that an Alert exists and that their emergency assistance may be required.
2.2 In the event of an emergency at one of its nuclear generating stations, any party to the Agreement may request emergency assistance from any or all of the other parties.
2.3 Requests for emergency assistance shall be made between and among the following party personnel:
Entergy Nuclear Palisades, L.L.C. Site Vice President- Palisades Nuclear Plant Detnoit Edison Site Vice President - Fermi Nuclear Plant Indiana Michigan Power Site Vice President - Cook Nuclear Plant ARTICLE III EXCUSED FAILURE TO RESPOND 3.1 Failure to respond to a request for emergency assistance pursuant to this Agreement shall be excused if, in order to respond, the requested party or parties would be forced In its or their sole judgment or judgments to:
3.1.1 Violate its duties relating to the care and staffing at its own nuclear generating stations; or 3.1.2 Jeopardize the public health or safety at a location other than the location of the requesting party emergency.
ARTICLE IV SCOPE OF ASSISTANCE 4.1 If requested under this Agreement, the responding party or parties will provide trained and experienced personnel to perform off-site radiation protection activities to the requesting party. All equipment intended for use by the responding personnel, except personal dosimeters and certification documents (such as certifications of Health Physics training, instrument training and dose exposure records), shall be the responsibility of the requesting party to provide. The responding party or parties may use their own equipment ifagreeable to the requesting party. However, use by the responding party or parties of their own equipment shall in no way alter the duties and obligations imposed upon the parties by this Agreement.
4.2 Emergency assistance provided by the responding party or parties shall continue until their personnel are dismissed by the requesting party, or are recalled by the responding party to support operations at its own facilities.
Appendix B Revision 32
Page 164 of 221 4.3 Responding party or parties' personnel exposure shall be limited to off-site radiation, and such exposure shall not exceed federal requirements as set forth in 10CFR20.
4.4 Wages, hours and other terms and conditions of employment applicable to loaned personnel shall be those of the party providing such personnel.
4.5 Personnel provided by responding party or parties shall, at all times during the period In which emergency assistance is being provided, continue to be employees of the responding party or parties. The responding party, and not the requesting party, shall be liable to loaned personnel for any wages, salaries, cost and expenses associated with the provision of emergency assistance.
ARTICLE V REIMBURSEMENT FOR EMERGENCY ASSISTANCE RENDERED 5.1 The requesting party shall reimburse each responding party for all costs and expenses Incurred by each responding party In providing emergency assistance hereunder. Such costs and expenses shall include:
5.1.1 Salaries and wages paid to loaned personnel (Including supervisors) for paid time spent In the requesting party service area, and paid time for travel to and from such service area; 5.1.2 A percentage of the total of such wages and salaries, as determined by the responding party, reflecting expenses incurred for:
6.1.2.1 Compliance with Worker Compensation laws; 5.1.2.2 Payroll taxes; 5.1.2.3 Hospitalization, surgical and medical coverage; 5.1.2.4 Pensions and life insurance; 5.1.2.5 Vacation, holiday and sick pay; 5.1.2.6 Travel accident insurance; 5.1.3 Transportation to and from the requesting party service area, Including the cost of travel accident insurance purchased expressly for coverage during such transportation; 5.1.4 Food and lodging; 5.1.5 Personal expenses specifically agreed to between the requesting and responding parties; 5.1.6 Charges, at the rates Internally used by the responding party, for the use of transportation equipment and other equipment requested; and 5.1.7 Any further costs specifically agreed to between the requesting and responding Appendix B Revision 32
Page 165 of 221 parties.
5.2 All time sheets and work records pertaining to loaned personnel shall be maintained by the responding party.
5.3 All charges shall be paid by the requesting party to each responding party within ten (10) days after receipt of an invoice, itemized to the satisfaction of the requesting party.
ARTICLE VI INDEMNIFICATION 6.1 The requesting party shall Indemnify and hold harmless each responding party from and against any and all liability for loss, damage, cost or expense which the responding party shall Incur by reason of bodily Injury, including death, to any person or persons, or by reason of damage to or destruction of any property, including the loss of use thereof, arising out of or in any manner connected with the giving of emergency assistance to the requesting party.
6.2 Inthe event of bodily Injury, including death, to any employee of the responding party, or In the event of damage to or destruction of any property of the responding party, the requesting party shall indemnify the responding party for such loss In the following manner:
6.2.1 Ifsuch loss Is covered by an insurance policy purchased by the responding party from a third party carrier, the requesting party shall make reimbursement to the extent such losses Increase the responding party Insurance coass; 6.2.2 Ifsuch loss Is not covered by an Insurance policy purchased by the responding party or exceeds such coverage, the requesting party shall make reimbursement to the extent of the claims or benefits actually paid or the losses sustained by the responding party.
ARTICLE VII MODIFICATION 7.1 At any lime after the date of this Agreement any party, by giving not less than thirty days written notice to the other parties, may from time to time call for reconsideration of the terms and conditions of this Agreement. Ifsuch reconsideration Is called for, the authorized representatives of the parties shall meet as promptly as convenient and discuss any of the terms and conditions of the Agreement. No party shall be under any obligation to agree to any modification or supplement not satisfactory to it. Any agreement modifying or supplementing such terms and conditions shall be In writing, signed by all parties, and shall specify the date such modification or supplement shall become effective.
ARTICLE VIII PLAN EXERCISING 8.1 The parties agree to provide, at their own expense, personnel to observe or assist In Appendix B Revision 32
Page 166 of 221 demonstrating the effectiveness of a nuclear generating station emergency plan as may be required by that nuclear generating station NRC approved emergency plan.
ARTICLE IX TERM OF AGREEMENT 9.1 This Agreement shall continue Indefinitely from the date of signing unless and until terminated as provided for In Section 9.2 below.
9.2 Any party, upon sixty (60) days prior written notice to all other parties, may. terminate this Agreement.
IN WITNESS WHEREOF, the parties hereto cause this Agreement to be executed by their duly authorized officers on duplicate original pages attached hereto and made a part hereof.
ENTEPY NUCLEAR P AL>E 7 ZA IAth h VDate Site Vice Prsbnti Palisades DETROIT EDISON COMPANY 4J. 'r,C~t. OVI09 p3 James T. n Date Site Vice Iaent - Fermi INDIANA MICHIGAN POWER Joel . G.blbe Date Site Vice President Cook Nuclear Plant Appendix B Revision 32
Page 167 of 221 Institute of Nuclear Power Operations Emergency Resources 1 page I 1!P Institute ofSut10 NuclearPower Operations 700 6allerlaParkway, SE Atlanta, MA30339-5943 770-W44-8000 FAX 770-644-8549 October 30, 2012
Dear Ladies and Gentlemen:
This letter certifies that the plant emergency. assistance agreement between INPO and its member utilities remains in effect. In the event ofan emergency at your utility, INPO will assistyou in acquiring the help of other organizations in the industry, as described in Section 1 of the Emergency Resources Manual, INPO 03-001, and in the United States Nuclear Industry Response Framework. If requested, INPO will provide the following assistance:
" coordinate technical information flow from the affected utility to the nuclear industry and government agencies
" coordinate the procurement and shipping of equipment and supplies
" locate personnel with technical expertise
" 'facilitate industry vendor and commercial supplier support
- obtain technical information and industry operating experience regarding plant comporients and systems
" provide an INFO liaison to facilitate interface This agreement will remain in effect until terminated in writing. Should you have any questions, please call Steve Meng at (770) 644-8548 or e-mail at MengSW@inpo.org.
Sincerely, Jeffrey T Gasser Vice President Emergency Response JTG:cjm Appendix B Revision 32
Page 168 of 221 EMERGENCY RESOURCES MANUAL INSTITUTE OF NUCLEAR POWER OPERATIONS INPO 03-001 January 2003 LlrAII W. 1IX IHIMiUnuM; Ccmip'l:liwl'l O l i , r :: r lrAii :: *I ku:.ur- Irv.v*!l Vv *xC;lululfrLga.*4 Ic in " r i ii i:-'iuJi LUiw.
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I*.ZD.ur rim!) iri-': rwrirbems.WK)') poritbipml:. nil nAiy pmetalnc.mrstii 'Em110-A Er [hell lV.)rinh~eialiy tniwily u-
- epýmjmaeeilehI wcuamnd a;Iiirgsle. -Aihi ewixl LLU e mrJJztiFA LuMUNiitiel. ViIj*LIhen ,f lie ilibiciii.t LcllhilniC I. aili ti.r'd ritlhL,,o0b)
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.hco civcreiln re.loc..*-.p'yO,' C'trc- :Ibsljr.rnmr.rt Appendix B Revision 32
Page 169 of 221 Voluntary Assistance Agreement By and Among Electric Utilities Involved in 9 pages Transportation of Nuclear Materials 6.2 Voluntary Assistance Agreement By and Among Electric Utilities Involved in Transportation of Nuclear Materials This Voluntary Assistance Agreement (hereinafter."Agreement") has been entered into by and among electric utilities involved in transportation of source material, special nuclear material, or byproduct material received, possessed, used, or transferred under a general or specific license Issued by the U.S. Nuclear Regulatory Commission pursuant to Title 10 of the Code of Federal Regulations (hereinafter "nuclear materials") and which have subscribed counterpart signature pages in the form attached hereto (hereinafter "Parties').
The Parties wish to set forth herein their understanding and agreement with respect to their mutual undertaking to each other in the situation wherein an Emergency arises during the transportation of nuclear materials shipped by or on behalf of a Party and a request for assistance is issued to another Party in respect to such Emergency and such assistance Is provided. This Agreement is intended only to define the terms and conditions Under which such assistance, if volunteered, will be rendered and received. It is understood that this Agreement does not Impose any obligation on any Party to render or continue to render any such assistance, but this Agreement does record the understanding of the Parties with respect to the rights and obligations which will be incurred in responding to requests for assistance.
NOW, THEREFORE, It is agreed, that:
- 1. Assistance rendered by a party as described hereunder shall be entirely voluntary and, when given in response to a request by any Party for help during an Emergency arising by reason of the transportation of nuclear materials, shall be rendered In accordance with the terms and conditions herein.
- 2. The Party that requests assistance shall be known as the "Requesting Company" and the Party furnishing assistance shall be known as the "Responding Company."
Attachment A Is a suggested letter confirming an agreement whereby assistance will be furnished pursuant to this Agreement.
8-5 Appendix B Revision 32
Page 170 of 221
- 3. (a) Requesting Company shall notify Responding Company of the type of assistance requested and the anticipated duration during which such assistance is desired. Requesting Company may also provide general direction as to the actions to be taken by Responding Company. Responding Company shall furnish such assistance as it may decide. Except as such companies may agree otherwise, Responding Company shall be responsible for determining the procedures to be followed in furnishing such assistance and for supervising work at the site of the Emergency.
Requesting Company, incooperation with Responding Company, shall make any report to governmental authorities and the news media. Requesting Company will notify Responding Company when its assistance is no longer needed.
(b) The furnishing of assistance hereunder shall be deemed to. have commenced when personnel of the Responding Company are assigned to other-than-normal duties or.transportalion of equipment commences pursuant to a determination by the Responding Company to provide assistance to a Requesting Company under this Agreement and shall be deemed to have terminated when the transportation of such personnel or equipment back to their working base, or home (for personnel returning at other than regular working hours), Is completed.
(c) The Responding Company shall make all arrangements for the transportation of Its personnel and equipment from and to their working base or home.
- 4. (a) Employees of Responding Company shall at all times continue to be employees of and remain under the supervision and control of the Responding Company and shall at no time and for no purpose be deemed to be servants, agents, employees, or representatives of the Requesting Company.
(b) Wages, hours, and other terms and conditions of employment applicable to personnel of the Responding Company, Including work procedures and/or safety rules, shall be those of the Responding Company.
(c) All personnel of the Responding Company shall be equipped by the Responding Company with such normal working and protective equipment as shall be compatible with the circumstances under which said personnel shall 6-6 Appendix B Revision 32
Page 171 of 221 function hereunder; Requesting Company shall inform Responding Company of any specific equipment which may be required in a particular situation.
- 5. (a) Responding Company shall furnish the requested personnel and equipment to the extent that the Responding Company may determine to do so in its sole judgment and discretion.
(b) Responding Company shall have the right, at any time and In its sole judgment and discretion, to withdraw personnel and equipment furnished to the Requesting Company and return such personnel and equipment to their working base. Responding Company shall give written notice at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in advance to Requesting Company of the permanent withdrawal of personnel or equipment furnished. Responding Company's withdrawal of personnel or equipment shall not affect any obligations which may have been incurred hereunder prior to such withdrawal or which may arise out of events occurring prior to such withdrawal.
- 6. All time sheets and work records pertaining to Responding Company personnel and equipment shall be kept by the Responding Company. The Responding Company shall furnish -the Requesting Company with a detailed statement of all costs and expenses paid or incurred by the Responding Company in connection with the furnishing of assistance to the Requesting Company, which statement shall be paid by Requesting Company within thirty (30) days after receipt.
- 7. The Requesting Company shall reimburse Responding Company for all direct and Indirect costs and expenses, not including a profit, incurred by Responding Company in giving assistance pursuant to this Agreement, including but not limited to costs and expenses related to or resulting from compliance with governmental requirements such as Title 10 of the Code of Federal Regulations, Part 20. Such costs and expenses shall be computed in accordance with Responding Company's standard rates and accounting practices including such overheads as are determined by Responding Company to be applicable to such direct and indirect costs and expenses incurred by Responding Company.
6-7 Appendix B Revision 32
Page 172 of 221 Requesting Company shall have the right to audit the records of Responding Company relative to work performed pursuant to this Agreement.
- 8. (a) In addition, and subject to the provisions of paragraph 8(b) hereof, Requesting Company shall Indemnify and hold Responding Company, its officers, directors, and employees, jointly and severally, harmless from and against any and all lability or loss, damage, cost, or expense which any of them may Incur by reason of bodily Injury, Including but not limited to death, to any person or persons, or by reason of damage to or destruction of any property, including but not limited to the loss of the use thereof, which results from furnishing assistance pursuant to this Agreement, whether due In whole or In part to any act, omission, or negligence of Responding Company, Its officers, directors, or employees.
(b) Where payments are made by Responding Company or its insurers to Responding Company's officers, directors, or employees or their beneficiaries for bodily injury or death resulting from furnishing assistance pursuant to this Agreement, including but not limited to workers' compensation, disability, pension plan, medical and hospitalization, or other such payments, Requesting Company shall make reimbursement to Responding Company to the extent such payments increase the Responding Company's employee-related costs, whether such Increase in costs occurs in the form of an Increase In premiums or contributions, a reduction In dividends or premium refunds, or otherwise. Requesting Company shall also reimburse Responding Company for any deductible amounts or for any amounts paid by Responding Company as a self-insurer. Responding Company will request Its Insurer to waive any right of subrogation it may have against Requesting Company as a result of any payment described in this paragraph 8(b) which such insurer may make on behalf of Responding Company because of Responding Company's furnishing of assistance pursuant to this Agreement.
(c) In the event any claim or demand Is made or suit, action, or proceeding is filed against Responding Company, Its officers, directors, or employees, jointly or severally, alleging liability for which Requesting Company 6-8 Appendix B Revision 32
Page 173 of 221 shall indemnify and hold harmless Responding Company, its officers, directors and employees under paragraph 8(a) hereof, Responding Company shlall promptly notify Requesting Company thereof, and Requesting Company, at its sole cost and expense, shall settle, compromise, or defend the same in such manner as it in its sole discretion deems necessary or prudent. Responding Company shall cooperate with Requesting Company in the resolution of any such matter.
(d) Each party to this Agreement agrees to carry financial protection required by the Atomic Energy Act of 1954, as amended, and self-Insurance or comprehensive liability Insurance, Including contractual liability coverage covering the Indemnification and defense obligations set forth herein, subject to such types and amounts of self-insurance, retentions, or deductibles as are consistent with good business practice in the industry.
(e) In the event a Responding Company provides assistance pursuant to this Agreement through an affiliate or subsidiary, the Indemnification provided in this paragraph 8 to the officers, directors, and employees of that Responding Company shall apply with equal force to the officers, directors, and employees of that affiliate or subsidiary.
- 9. Each Party shall provide the Institute of Nuclear Power Operations (hereinafter "INPO*) with an executed counterpart signature page to this Agreement and to any amendments heretoý This Agreement shall become effective when counterpart signature pages executed by at least two Parties shall have been received by INPO. This Agreement shall remain In effect as to any Party until such Party has withdrawn from the Agreement as provided below. Any electric utility involved in the transportation of nuclear materials may become a Party upon execution of the Agreement.
- 10. (a) INPO may provide certain administrative and emergency response support services in furtherance of this Agreement, such as maintaining and distributing to the Parties a roster of the signatories to this Agreement; providing copies of the Agreement and any amendments thereto to all Parties; and 6-9 Appendix B Revision 32
Page 174 of 221 preparing and distributing to the Parties other documents, such as a list of sources of emergency manpower and equipment. INPO may provide such other services as may be requested of INPO from time to time by the Parties. The Parties recognize that INPO shall not be responsible for implementing, enforcing, or interpreting this Agreement.
(b) The Parties shall defend, indemnify, and hold harmless INPO, its officers, directors, and employees, jointly and severally, from and against any and all liability or loss, damage, cost, or expense which results from performance of INPO functions described In paragraph 10(a) of this Agreement, except as may result from the sole negligence or willful misconduct of INPO, its officers, directors, or employees. Each Party hereby expressly waives any right it may have to assert any claim against INPO, Its officers, directors, or employees arising out of its or their performance of the duties described In paragraph 10(a),
except as may result from the sole negligence or willful misconduct of INPO, its officers, directors, or employees.
(c) Following the occurrence of an emergency involving the transportation of nuclear materials INPO may, if asked to do so by a Requesting Company, help to locate sources of emergency manpower and equipment with which the Requesting Company may contract for assistance. If INPO does furnish such assistance and, unless otherwise agreed by INPO and the Requesting Company, the Requesting Company and INPO shall have the same rights and obligations as if INPO were a Responding Company (including but not limited to the Requesting Company's obligations to INPO, its officers, directors, and employees under paragraph 8 hereof), except that paragraphs 6 and 7 shall not apply either to Requesting Company or INPO and paragraph 8(d) shall not apply to INPO.
- 11. This Agreement will not create any rights or defenses in favor of an entity or person not a signatory to this Agreement except to the extent provided in this paragraph and in paragraphs 8 and 10 of this Agreement. This Agreement shall be binding upon and inure to the benefit of each signatory to this Agreement and the subsidiaries and affiliates of each such signatory.
6-10 Appendix B Revision 32
Page 175 of 221
- 12. Except as otherwise provided in paragraph 13, any Party may withdraw from this Agreement upon at least thirty (30) days' prior written notice to INPO with a copy to all of the other Parties. Notice of withdrawal shall not affect any obligations which may have been incurred hereunder prior to the effective date of such notice or which may arise out of events occurring prior to that date. No party may withdraw from this Agreement while it is receiving assistance pursuant to this Agreement.
- 13. This Agreement may be amended by agreement of a majority of the Parties hereto. Such amendment shall be effective and binding upon all Parties thirty (30) days after INPO has received counterpart signature pages for the amendment executed by at least a majority of the Parties to the Agreement. INPO shall notify all Parties when at least a majority of the Parties have executed an amendment to the Agreement. No amendment shall affect any obligation which may have been Incurred hereunder prior to the effective date of such amendment or which arises out of events occurring prior to that date. Notwithstanding the first sentence of paragraph 12, any Party may withdraw from this Agreement by submitting written notice to INPO at any time during the thirty (30) day period prior to the effective date of such amendment with a copy to all of the other Parties.
- 14. If any provision of this Agreement is determined to be Invalid or unenforceable as to any Party or otherwise, such determination shall not affect the validity or enforceability of the other provisions of this Agreement as to that Party or otherwise.
6-11 Appendix B Revision 32
Page 176 of 221 6.1 Signatories to the Voluntary Assistance Agreement By and Amono Electric Utilities Involved In Transportation of Nuclear Materials The following organizations have signed the Voluntary Assistance Agreement By and Among Electric Utilities Involved in Transportation of Nuclear Materials.
AmerenUE (Union Electric Company)
AmerGen Energy Company, LLC Arizona Public Service Company Constellation Energy Group Dominion Generation Duke Energy Corporation Energy Northwest Entergy Nuclear Exelon Corporation FirstEnergy Nuclear Operating Company FPL Group, Inc.
Indiana Michigan Power Company Nebraska Public Power District Nuclear Management Company, LLC Omaha Public Power District Pacific Gas and Electric Company PPL Susquehanna, LLC Progress Energy, Inc.
PSEG Nuclear LLC Rochester Gas and Electric Corporation South Carolina Electric & Gas Company 6-3 Appendix B Revision 32
Page 177 of 221 6.1 Siginatories to the Voluntary Assistance Actreement By and Amona Electric Utilities Involved in Transportation of Nuclear Materials (continued)
Southern California Edison Company Southern Nuclear Operating Company STP Nuclear Operating Company Tennessee Valley Authority The Detroit Edison Company TXU Energy Wolf Creek Nuclear Operating Corporation 6-4 Appendix B Revision 32
Page 178 of 221 Nuclear Power Plant Emergency Response Voluntary Assistance Agreement 10 pages 6.3 Sicinatories to the Nuclear Power Plant Emergency Response Voluntary Assistance Agreement The following organizations have signed the Nuclear Power Plant Voluntary Assistance Agreement.
AmerenUE (Union Electric Company)
AmerGen Energy Company, LLC Arizona Public Service Company Constellation Energy Group Dominion Generation Duke Energy Corporation Energy Northwest Entergy Nuclear Exelon Corporation FirstEnergy Nuclear Operating Company FPL Group, Inc.
Indiana Michigan Power Company Nebraska Public Power District Nuclear Management Company, LLC Omaha Public Power District Pacific Gas and Electric Company PPL Susquehanna, LLC Progress Energy, Inc.
PSEG Nuclear LLC Rochester Gasand Electric Corporation South Carolina Electric & Gas Company 6-15 Appendix B Revision 32
Page 179 of 221 6.3 Signatories to the-Nuclear Power Plant Emergency Response Voluntary Assistance Agreement (continued)
Southern California Edison Company Southern Nuclear Operating Company STP Nuclear Operating Company Tennessee Valley Authority The Detroit Edison Company TXU Energy Wolf Greek Nuclear Operating Corporation 6-16 Appendix B Revision 32
Page 180 of 221 6.4 Nuclear Power Plant Emergency Response Voluntary Assistance Apreement This Nuclear Power Plant Emergency Response Voluntary Assistance Agreement (hereinafter "Agreement") has been entered into by and among electric utilities which have responsibility for the construction or operation of commercial nuclear power plants under a license issued by the U.S. Nuclear Regulatory Commission pursuant to Title 10 of the Code of Federal Regulations (hereinafter "nuclear power plants') and which have subscribed counterpart signature pages In the form attached hereto (hereinafter "Parties").
The Parties wish to set forth herein their understanding and agreement
.with respect to their mutual undertaking to each other in the situation wherein an emergency occurs at a nuclear power plant under the control of or operated on behalf of a Party and a request for assistance Is issued to another Party hereto in respect to such emergency and such assistance is provided. This Agreement is intended only to define the terms and conditions under which such assistance, If
- volunteered, will be rendered and received. ItIs understood that this Agreement does not impose any obligation on any Party to render or continue to render any such assistance, but this Agreement does record the understanding of the Parties with respect to the rights and obligations which will be incurred In responding to requests for assistance.
NOW, THEREFORE, it is agreed, that
- 1. Assistance rendered by a Party as described hereunder shall be entirely voluntary and, when given in response to a request by any Party for help following an emergency arising at a nuclear power plant, shall be rendered in accordance with the terms and conditions herein.
- 2. The Party that requests assistance shall be known as the "Requesting Company" and the Party furnishing assistance shall be known as the "Responding Company." Attachment A is a suggested letter confirming an agreement whereby assistancewill be furnished pursuant to this Agreement.
6-17 Appendix B Revision 32
Page 181 of 221
- 3. (a) Requesting Company shall notify Responding Company of the type of assistance requested and the anticipated duration during which such assistance is desired. Responding Company shall furnish such assistance as It may decide. Except as such companies may agree otherwise, Requesting Company shall be responsible for determining the procedures to be followed relative to the furnishing of such assistance, directing the work, and making any reports to governmental authorities and the news media regarding the emergency or the furnishing of assistance pursuant to this Agreement. Requesting Company shall notify Responding Company when Its assistance is no longer needed.
(b) The furnishing of assistance hereunder shall be deemed to have commenced when personnel of the Responding Company are assigned to other than normal duties or transportation of equipment commences pursuant to a determination by the Responding Company to provide assistance to a Requesting Company under this Agreement and shall be deemed to have terminated when the transportation of such personnel or equipment back to their working base, or home (for personnel returning at other than regular working hours), Is completed.
(c) The Responding Company shall make all arrangements for the transportation of its personnel and equipment from and to.their working base or home.
- 4. (a) Employees of Responding Company shall at all times continue to be employees of the Responding Company and shall at no time and for no purpose be deemed to be servants, agents, employees, or representatives of the Requesting Company.
(b) Wages, hours, and other terms and conditions of employment applicable to personnel of the Responding Company shall be those of the Responding Company.
Work procedures, security, and safety rules for such personnel shall be those of the Requesting Company.
6-18 Appendix B Revision 32
Page 182 of 221 c) Unless otherwise agreed, all personnel of the Responding Company shall be equipped by the Responding Company with such normal working and protective equipment as shall be compatible with the circumstances under which said personnel shall function hereunder, Requesting Company shall inform Responding Company of any specific equipment which may be required in a particular situation.
- 5. (a) Responding Company shall fumish the requested personnel and equipment to the extent that the Responding Company may determine to do so In its sole judgment and discretion.
(b) Any Information which Responding Company may provide to Requesting Company (including drawings, reports, and analyses) or which Requesting Company provides to Responding Company, which either the Responding Company or the Requesting Company considers proprietary or confidential, shall be so designated.
Such proprietary information shall be held in confidence and shall be used exclusively in connection with the emergency at the nuclear power plant at which the emergency has occurred (including necessary disclosures on a proprietary basis to others in that connection) and shall not be published or otherwise disclosed to others, except as may be required by law.
(c) Responding Company shall have the right, at any time and in its sole judgment and discretion, to withdraw personnel and equipment furnished to the Requesting Company and return such personnel and equipment to its working base.
Without limiting Responding Company's rights under the preceding sentence, Responding Company shall attempt to schedule any such withdrawal of its personnel or equipment to accommodate the needs of Requesting Company. Responding Company shall give written notice at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in advance to Requesting Company of the permanent withdrawal of personnel or equipment furnished. Responding Company's withdrawal of personnel or equipment shall not affect any obligations which may have been incurred hereunder prior to such withdrawal or which may arise out of events occurring prior to such withdrawal.
- 6. All time sheets and work records pertaining to Responding Company personnel and equipment shall be kept by the Responding Company. The Responding 6-19 Appendix B Revision 32
Page 183 of 221 Company shall furnish the Requesting Company with a detailed statement of all costs and expenses paid or incurred by the Responding Company In connection with the furnishing of assistance to the Requesting Company, which statement shall be paid by Requesting Company within thirty (30) days after receipt.
- 7. The Requesting Company shall reimburse Responding Company for all direct and indirect costs and expenses, not including a profit, incurred by Responding Company In giving assistance pursuant to this Agreement, Including but not limited to costs and expenses related to or resulting from compliance with governmental requirements such as Title 10 of the Code of Federal Regulations Part 20. Such costs and expenses shall be computed In accordance with Responding Company's standard rates and accounting practices Including such overheads as are determined by Responding Company to be applicable to such direct and Indirect costs and expenses incurred by Responding Company. Requesting Company shall have the right to audit the records of Responding Company relative to work performed pursuant to this Agreement.
- 8. (a) In addition, and subject to the provisions of paragraph 8(b) hereof, Requesting Company shall Indemnify and hold Responding Company, its officers, directors, and employees, jointly and severally, harmless from and against any and all liability or loss, damage, cost or expense which any of them may incur by reason of bodily injury, including but not limited to death, to any person or persons, or by reason of damage to or destruction of any property, Including but not limited to any property located at the site of the Requesting Company's nuclear power plant or the loss of use.
of any property, which results from furnishing assistance pursuant to this Agreement, whether due In whole or in part to any act, omission, or negligence of Responding Company, its officers, directors, or employees.
(b) Where payments are made by Responding Company or its insurers to Responding Company's officers, directors, or employees or their beneficiaries for bodily injury or death resulting from furnishing assistance pursuant to this Agreement, including but not limited to workers' compensation, disability, pension plan, medical and hospitalization, or other such payments, Requesting Company shall make reimbursement to Responding Company to the extent such payments increase the 6-20 Appendix B Revision 32
Page 184 of 221 Responding Company's employee-related costs, whether such Increase In costs occur in the form of an Increase in premiums or contributions, a reduction in dividends or premium refunds, or otherwise. Requesting Company shall also reimburse Responding Company for any deductible amounts or for any amounts paid by Responding Company as a self-insurer. Responding Company will request its Insurer to waive any right of subrogation it may have against Requesting Company as a result of any payment described in this paragraph 8(b) which such insurer may make on behalf of Responding Company because of Responding Company's furnishing of assistance pursuant to this Agreement (c) Responding Company makes no warranty with respect to any goods or services provided to Requesting Company and NO WARRANTY, EITHER EXPRESS OR IMPLIED, ORAL OR WRITTEN, SHALL APPLY TO THE GOODS OR SERVICES PROVIDED, INCLUDING, WITHOUT LIMITATION, THE WARRANTIES OF MERCHANTABILITY AND OF FITNESS FOR SPECIFIED OR INTENpED PURPOSE.
All equipment and services furnished by Responding Company pursuant to this Agreement are furnished as Is.
(d) In the event any claim or demand is made or suit, action, or proceeding is filed against Responding Company, its officers, directors, or employees, jointly or severally, alleging liability for which Requesting Company shall indemnify and hold harmless Responding Company, its officers, directors, and employees under this paragraph 8 hereof, Responding Company shall promptly notify Requesting Company thereof, and Requesting Company, at its sole cost and expense, shall settle, compromise, or defend the same in such manner.as it in its sole discretion deems necessary or prudent. Responding Company shall cooperate with Requesting Company in the resolution of any such matter.
(e) Each Party to this Agreement agrees to carry the amount of financial protection required by the Atomic Energy Act of 1954, as amended, and self-insurance or comprehensive liability insurance, including contractual liability coverage, covering the indemnification and defense obligations set forth herein,.subject to such types and amounts of self-insurance, retentions, or deductibles as are consistent with good business practice In the Industry.
6-21 Appendix B Revision 32
Page 185 of 221 (f) In the event a Responding Company provides assistance pursuant to this Agreement through an affiliate or subsidiary, the indemnification provided In this paragraph 8 to the officers, directors, and employees of that Responding Company shall apply with equal force to the officers, directors, and employees of that affiliate or subsidiary.
- 9. Each Party shall provide the Institute of Nuclear Power Operations (hereinafter "INPO') with an executed counterpart signature page to this Agreement and to any amendments hereto. This Agreement shall become effective when counterpart signature pages executed by at least two Parties shall have been received by INPO.
This Agreement shall remain In effect as to any Party until such Party has withdrawn from the Agreement as provided below. Any electric utility with responsibilities for the construction or operation of a nuclear power plant may become a Party upon execution of the Agreement.
- 10. (a) INPO may provide certain administrative and emergency response support services in furtherance of this Agreement, such as maintaining and distributing to the Parties a roster of the signatories to this Agreement; providing copies of the Agreement and any amendments thereto to all Parties; and preparing and distributing to the Parties other documents, such as a list of sources of emergency manpower and equipment. INPO may provide such other services as may be requested of INPO from time to time by the Parties. The Parties recognize that INPO shall not be responsible for implementing, enforcing, or Interpreting this Agreement.
(b) The Parties shall defend, Indemnify, and hold harmless INPO, its officers, directors, and employees, jointly and severally, from and against any and all liability or loss, damage, cost, or expense which results from performance of INPO's functions described in paragraph 10(a) of this Agreement, except as may result from the sole negligence or willful misconduct of INPO, its officers, directors, or employees. Each Party hereby expressly waives any right it may have to assert any claim against INPO, its officers, directors, or employees arising out of its or their performance of INPO's functions described in paragraph 10(a), except as may result from the sole negligence or willful misconduct of INPO, its officers, directors, or employees.
6-22 Appendix B Revision 32
Page 186 of 221 (c) Following an emergency at a nuclear power plant, INPO may, Ifasked to do so by a Requesting Company, help to locate sources of emergency manpower and equipment with which the Requesting Company may contract for assistance. The.
Requesting Company may ask INPO to furnish personnel or equipment followingan emergency arising at a nuclear power plant. If INPO does furnish such assistance and unless otherwise agreed by INPO and the Requesting Company, the Requesting Company and INPO shall have the same rights and obligations as if INPO were a Responding Company (including but not limited to the Requesting Company's.
obligations to INPO, its officers, directors, and employees under paragraph 8 hereof),
except that paragraphs 6 and 7 shall not apply either to Requesting Company or INPO and paragraph 8(e) shall not apply to INPO.
- 11. This Agreement will not create any rights or defenses in favor of any entity or person not a signatory to this Agreement except to the extent provided in this paragraph and In paragraphs 8 and 10 of this Agreement. This agreement shall be binding upon and inure to the benefit of each signatory to this Agreement and the subsidiaries and affiliates of each such signatory.
- 12. Except as otherwise provided in paragraph 13, any Party may withdraw from this Agreement upon at least thirty (30) days prior written notice to INPO with a copy to all of the other Parties. Notice of withdrawal shall not affect any obligations which may have been incurred hereunder priorto the effective date of such notice or which may arise out of events occurring prior to the date. No Party may withdraw from this Agreement while it is receiving assistance pursuant to this Agreement.
6-23 Appendix B Revision 32
Page 187 of 221
- 13. This Agreement may be amended by the agreement of a majority of the Parties hereto. Such amendment shall be effective and binding upon all Parties thirty (30) days after INPO has received counterpart signature pages for the amendment executed by at least a majority of the Parties to the Agreement. INPO shall notify all Parties when at least a majority of the Parties have executed an amendment to the Agreement. No amendment shall affect any obligation which may have been incurred hereunder prior to the effective date of such amendment or which may arise out of events occurring prior to that date. Notwithstanding the first sentence of paragraph 12, any Party may withdraw from this Agreement by submitting written notice to INPO at any time during the thirty (30) day period prior to the effective date of such amendment with a copy to all of the other Parties.
- 14. If any provision of this Agreement is determined to be invalid or unenforceable as to any Party or otherwise, such determination shall not affect the validity or enforceability of the other provisions of this Agreement as to that Party or otherwise.
- 15. In the event (i) an emergency occurs at a nuclear power plant under the control of or operated on behalf of a Party; (ii) a request for assistance is issued to another Party hereto In respect to such emergency; and (iii) such assistance Is provided, this Agreement shall be construed in accordance with the law of the State In which the nuclear power plant is located with respect to all, rights and obligations arising out of such emergency.
6-24 Appendix B Revision 32
Page 188 of 221 FEMA Letter describing Backup ANS U.S. Departnent ofHomeland Security Region V 536 South Clark Stee, Floor 6 Chicago, IL 60605 FEMA December 10, 2012 Thomas Higinbotham, Manager Radiological Emergency Preparedness Unit Emergency Management and Homeland Security 4000 Collins Road Lansing, Michigan 48910
Dear Mr. Higinbotharn:
This letter is to confirm the status of provisions for Backup Alert and Notification (ANS) for the D.C.
Cook Nuclear Power Plant Emergoncy Planning Zone (EPZ).
Backup ANS for this EPZ is achieved through Route Alerting, which is contained within the Radiological Emergency Response Plans and procedures for the State of Michigan and the County of Berrien. These plans and procedures have been approved by the Federal Emergency Management Agency (FEMA) in accordance with Tide 44 of the Code of Federal Regulations (CFR) §§350.12 and 14.
These plans, procedures and associated equipment and facilities are the responsibility of State and local Offsite Response Organizations, are not under the control of the U.S. Nuclear Regulatory Commission licensee and are subject to regular FEM4A review and evaluation. As of this date no deficiencies with the backup ANS for D.C. Cook exist. Deficiencies found at any time are subject to the provisions of 44 CFR
§350.13.
Licensees are required per Appendix E.IV.D.3 ofPart 50 of Tide 10 of the Code of Federal Regulations to demonstrate that the appropriate governmental authorities have the administrative and physical means for a backup method of public alerting and notification. Further, in 10 CFR Part 50, Appendix E, Section IV.D.4 requires that if FEMA has approved a design report, to include the backup ANS capability, as of December 23, 2011, then the backup ANS requirements in Section IV.D.3 must be implemented by December 24, 2012. This letter identifies that such an approval existed on December 23, 2011, and that the approved backup ANS incorporated in State and local plans, procedures, and associated equipment and facilities be incorporated into the D.C. Cook ANS design report. A copy of this letter should be appended to the design report.
If you should have any questions, please call me at 3 12-408-5575 or contact Dwaine Warren at 312-408-5342.
Sincerely, - -
William E. King, Chairman Regional Assistance Committee www.fema.gov Appendix B Revision 32
Page 189 of 221 APPENDIX C EMERGENCY KITS AND EQUIPMENT LOCATION Appendix C Revision 32
Page 190 of 221 Emergency Kits and Equipment Location KIT LOCATION Radiation Protection Emergency Kit Operations Support Center (OSC)
Emergency Operations Facility (EOF)
Survey Vehicles (1 in each of the 2 dedicated Survey Vehicles)
First Aid - Decon Equipment Radiation Protection Access Control (RPAC)
Anti-C Equipment for Ambulance Security Control Center In-Plant/On-Site Driver to Hospital Vehicle Search Portal Emergency Anti-C Equipment Technical Support Center (TSC)
Operations Support Center Area Training Center Emergency Operations Facility (EOF)
Both Control Rooms Control Room Emergency Cabinet Survey Vehicle Hospital Emergency Cabinet Lakeland Regional Medical Center, St. Joseph Niles Community Hospital, Niles Shift Supervisor Office Radiation Protection 633' Turbine Deck at TSC stairs Emergency Locker Appendix C Revision 32
Page 191 of 221 SCBAs 17 Auxiliary Building 10 RPAC 10 Basement Assembly Area (OSC) 10 633' Turbine Deck by TSC 2 Each Control Room 10 609' Turbine Bldg. - for Turbine Building use only Stretcher Lockers 10 Locations in Plant Appendix C Revision 32.
Page 192 of 221 APPENDIX D EMERGENCY PREPAREDNESS BROCHURE Appendix D Revision 32
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Read this now and then display it for easy access.
0 CALL IF YOU HAVE QUESTIONS OR REQUESTS Please call or write either of the offices below if you:
" Have questions or comments about the calendar.
" Need more information about emergency planning.
" Need more copies of the calendar.
" Would like to schedule a guest speaker to discuss the Berrien County Emergency Plan with your organization, company or service club.
Cook Energy Information Center Division of Berrien County Sheriff's Office
Dear Berrien County Resident:
800-548-2555 Berrien County Emergency Management One Cook Place 269-983-7141 Ext. 4916 If there is a serious emergency in Berrien County, this calendar tells you exactly what to do. That's why it is so important for you to read it now Bridgman, MI 49106 2100 E. Empire Ave.
so you are prepared. It is written especially for people who live, work or go Benton Harbor, MI 49022 to school within 10 miles of the Cook Nuclear Plant in Bridgman. It is also for use by boaters, campers and all visitors to the area. 0 TABLE OF CONTENTS Read this emergency information now. Then display it where you can Upfront with Larry Weber ..................................... 2 find it.
This calendar explains exactly what you should do if there is a nuclear What you should do if you hear sirens .................. 16 accident, chemical spill or an emergency weather condition such as a What you should do if you are told to seek shelter ..... 16 tornado or another dangerous condition.
Area radio and television stations ......................... 16 The best way to be safe in an emergency is to know what to do and how to help others. Please share this information with your family. Make sure they Functional Needs information and card ................... 16 know what to do if an emergency occurs. Talk over the information with What you should do if you are told to evacuate ......... 17 people at your work. Discuss it with your neighbors and friends. Find out Things you will want to bring with you .................. 17 if anyone will need special help in an emergency. Inform your neighbors if you will need special help. If you know people who are blind or have Cook Nuclear Plant Emergency Planning Zone .......... 17 difficulty reading, please read this information to them. Make sure they Nuclear emergency terms ................................... 18 understand it. We want everyone in our communities to be prepared to handle emergencies calmly and safely. Facts about radiation ........................................... 18 Sincerely, Notice to farmers, food processors and distributors ... 19 Indiana Michigan Power KI tablet voucher ............................................. 21 Berrien County Emergency Caring for our community ...................................... 22 Management Office Tribute to Don Ames .......................................... 22 Michigan State Police Emergency Management and Start preparing now/Important phone numbers ......... 22 Homeland Security Division Cook calendar photo contest ...................... back cover
UPFRONT WITH LARRY WE One of the hallmarks of Cook Nuclear Plant is its transparency.
In its nearly 40 years of operation, it has never taken an out-of-sight, out-of-mind approachto informing you or your neighbors about its operation. This calendar is an opportunity for Senior Vice Presidentand Chief Nuclear Officer Larry Weber to provide an update on Cook and the nuclear industry.You'll find his interview To continue operatingsafely and reliably over its extended on this and the next page. license life, Cook Plant is replacingmajor components, such as these turbines.
In 2012 Inin Mihia Powe anone tha Coo Plant is begII Imining aL5U six-year Lif Cyclej Maaemn Ii ~I [
I Project.I Wha is it an ho wil it beei hoewern IF YOU EVER HAVE QUESTIONS in Bere Couty OR CONCERNS ABOUT bsinse COOK PLANT, or wish to host a speaker to talk Larry: All nuclear plants were licensed $1.2 billion project. While this is a about nuclear power or energy initially to operate for 40 years. Many large investment in the plant, the Life topics at a club, organization or plants, including Cook Nuclear Plant's Cycle Management costs are 0 employee meeting, please contact: two units, have been relicensed for an significantly less than building a new Cook Energy Center additional 20 years. Cook's Unit 1 is plant with Cook's generation capacity.
P.O. Box 850 licensed until 2034 and Unit 2 to 2037. Our plan is to replace major Bridgman, MI 49106 Many of the structures and components components and systems during z 800-548-2555 at the plant, however, were engineered normal refueling outages over the next cookinfo@aep.com and manufactured on the basis of the six years. We will contract with many Z Facebook.com/CookN uclear 40-year service life. To ensure that the local workers, trades people and 0 plant continues to operate safely and vendors, as well as use local z
reliably for the extended licensed life, warehousing. Workers who come in Cook must monitor and manage the from out of town will stay in local aging of these components. hotels, eat at local restaurants and boost The Life Cycle Management program the regional economy. It's an investment 2 will help us accomplish this. This is a in the plant and in the community.
0
Yo metoe tha the dry cas strg failt i ig l cas. hyw asathreaee seue 00a ha Coo Larry: We recently had 14 Larry: The federal government has an Larry: The Berrien County Sheriff's employees complete an 18-month obligation to the nation to take used Department is the only sheriff initial license training class at Cook.
Larry: Vote for members of Congress nuclear fuel and store it safely offsite. department in the nation that is badged This is the fourth consecutive class The federal government has not met that see the need for a strong energy to enter a nuclear power plant. They with 100 percent pass rate on an policy that includes nuclear fuel that obligation. After two expansions, train with our security force inside our extremely challenging Nuclear storage or reprocessing. If we our spent fuel pool is nearly full, so we facility on a regular basis. We also have Regulatory Commission written introduced nuclear used nuclear fuel had to create new storage or we would drilled with the FBI and State of exam. This not only speaks well of reprocessing, as they do in Europe, have to stop operation in 2015. We Michigan's tactical response units. Our our reactor operators, but of our have built a two-acre concrete pad we could reduce our waste by 99 already strong security saw Operations Training Department for near the center of our 650-acre percent. We need forward-thinking considerable upgrades after 9/11, developing and presenting training property where we are currently storing people in office. including increases in staffing, training, that results in exceptional success.
12 licensed casks each loaded with 32 weapons, detection equipment and used nuclear fuel assemblies from our barriers. We completed another spent fuel pool. The dry cask storage is multi-million dollar upgrade in late in a highly secure area and is strictly 2012 in response to the latest threat regulated by the federal government. intelligence. I believe this maintains our position as one of the leading nuclear scurity forces in the industry.
Fuel is moved underwaterinto a cask (above). In order to continue operation, Cook will load an additional11 casks every three years.
Cook enlisted special equipment to move the dry casks loaded with used nuclear fuel to a highly secure storage site in a remote area on Cook's campus (right).
COOK PLANT'S SAFETY CULTURE GAINS INTERNATIONAL ATTENTION AT ASIAN SYMPOSIUM IN JAPAN.
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In Oct. 201Z the Japanesegovernment asked Cook's Senior V.P and Chief Nuclear Officer Larry Weber to meet in Japan.
He talked with them about how Cook successfully compels personnel to be I i 0i ýt accountablefor plantsafety.
'I sliuM In July 2012 Japa relase its ineedn invstgaio How cn .S.
repor rearin th Fuum aciet How wil Cook plantsincmlu-ding'ook, Plan an other U.S. nula plnt use thesoslere 0el th 0aans nuclear fro Fuum to imrv thi stutrs procedur0 indstr 0s it mvs an0aey Larry: The biggest lesson learned seismic and flooding mitigation. We Larry: I went with a team, including our Larry: In our industry it is critical to z from Fukushima is the importance of have process and procedure upgrades plant manager and radiation protection thoroughly understand the root causes.
setting high standards and having a for expanded emergency conditions manager, to Japan in October 2012. We are dealing with nuclear safety, so strong nuclear safety culture. Cook similar to Fukushima. Other The Japanese nuclear safety regulators we need to know how the "fix" will Z
-H meets our original safety design basis enhancements to our Emergency invited us for eight days to talk with impact other equipment and systems Z but we continue to do more. We're Preparedness plans will help us plant owners and regulators about our at the plant. Just as when the airline adding portable generators and fire- protect the public in the unlikely nuclear safety culture. The Japanese industry has issues, it conducts an 3
z truck-sized diesel pumps in addition event of an emergency. recognize that they are advanced engineering analysis to make sure the to performing extensive analyses on technically, but are not as strong at the solution doesn't result in a different m
human performance level. We talked hazard, we have to do the same z
about how our nuclear safety culture analysis. This does take time. We have would have helped reduce the impact to make sure an improvement does not 3 of the events at Fukushima. adversely affect other equipment.
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