Text

Emergency Plan Document Revision
	ML23319A058
Person / Time
Site:	FitzPatrick
Issue date:	11/15/2023
From:	David Gudger; Constellation Energy Generation
To:	; Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation, Document Control Desk
References
	JAFP-23-0064
	Download: ML23319A058 (1)
	v • d • e

200ExelonWay KennettSquare,PA19348 www.ConstellationEnergy.com 10 CFR 50.54(q)(5) 10 CFR 50.4 10 CFR 72.44(f)

JAFP-23-0064 November 15, 2023 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 Docket No. 50-333 James A. FitzPatrick Nuclear Power Plant Independent Spent Fuel Storage Installation General License No. SFGL-12 NRC Docket No.72-012

Subject:

Emergency Plan Document Revision In accordance with 10 CFR 50.4(b)(5), "Emergency Plan and related submissions,"

Constellation Energy Generation, LLC (CEG) is submitting the Emergency Plan document revision listed in the table below for the James A. FitzPatrick Nuclear Power Plant (JAF).

Procedure No.

Revision Title EP-AA-1014 5

Radiological Emergency Plan Annex for James A.

FitzPatrick Station The changes to the Emergency Plan Annex noted in the table above were evaluated under the requirements of 10 CFR 50.54(q) and were determined not to result in a reduction in the effectiveness of the Emergency Plan for JAF. This notification is being submitted within 30 days of implementation of the changes as required by 10 CFR 50.4(b)(5). The changes continue to meet the applicable planning standards established in 10 CFR 50.47(b) and 10 CFR 50, Appendix E.

U.S. Nuclear Regulatory Commission Emergency Plan Annex Revision NRC Docket Nos. 50-333 and 72-012 November 15, 2023 Page 2 In addition, as required by 10 CFR 50.54(q)(5), Attachment 1 of this submittal includes a summary analysis of the changes to the Emergency Plan Annex for JAF. This submittal also satisfies the reporting requirements associated with 10 CFR 72.44(f), which stipulates that within six months after any change is made to the Emergency Plan, the licensee shall submit a report containing a description of the changes to the Director, Division of Fuel Management, Office of Nuclear Material Safety and Safeguards.

A copy of the Emergency Plan Annex revision and supporting change summary analysis are included in the attachments to this letter.

There are no regulatory commitments in this submittal.

If you have any questions or require additional information, please contact Richard Gropp at 1-267-533-5642.

Respectfully, David T. Gudger Sr. Manager, Licensing Constellation Energy Generation, LLC Attachments:

1.

10 CFR 50.54(q)(5) Change Summary Analysis 2.

EP-AA-1014, Revision 5, Radiological Emergency Plan for James A. FitzPatrick Station cc:

w/ Attachment 1 only Regional Administrator - NRC Region I Director, NRC Division of Fuel Management, ONMSS NRC Project Manager, NRR - James A. FitzPatrick Nuclear Power Plant A. L. Peterson, NYSERDA B. Frymire, NYSPSC G. Machina, NYS Chief of Radiological Emergency Preparedness Program

ATTACHMENT 1 10 CFR 50.54(q)(5) Change Summary Analysis Change Summary Analysis Page 1 of 12 ATTACHMENT 1 10 CFR 50.54(q)(5) Change Summary Analysis I.

Document Title Constellation Energy Generation, LLC (CEG) has issued the following Emergency Plan Annex document revision for the James A. FitzPatrick Nuclear Power Plant (JAF):

EP-AA-1014, Revision 5, Radiological Emergency Plan for James A. FitzPatrick Station II.

Description of Procedure EP-AA-1014 serves as the Radiological Emergency Plan Annex for the JAF station and contains information and guidance that is unique to the station. This includes facility geography and location for a full understanding and representation of the stations emergency response capabilities. The Station Annex is subject to the same review and audit requirements as the Constellation Standardized Radiological Emergency Plan per EP-AA-120, "Emergency Plan Administration."

III.

Description of Changes

1. EP VHF System Radio Retirement Description of Changes The existing JAF Emergency Preparedness (EP) VHF Radio System, which supports Emergency Planning has become obsolete and difficult to maintain. The radio function is replaced in the Emergency Plan by Satellite and Cellular Phone technology for communication with the Field Survey Teams and the offsite Emergency Response Facilities (ERFs).

The following specific changes related to the JAF Radios are made to the JAF Emergency Plan.

Steps 2.3.1, 4.2.2, 5.3.3 and Figure 5-1 are revised to delete reference to radios and recognize the use of Satellite Phones for Oswego County Emergency Management Office (OCEMO) and radiological survey team communications. The Satellite Phones provide equivalent or more reliable means of maintaining the communication function. Figure 5-1 is revised to remove reference to Radios in the Emergency Operations Facility (EOF) and the Alternate Facilities.

Step 5.2.5 is revised to remove the referenced locations which will no longer have EP Radio Systems installed. The reference to Radio Consoles is removed since some consoles are removed and replaced with radio units. The radio units are fully functional with respect to EP use and do not result in degraded capabilities.

New Section 5.2.6 is added to the Emergency Plan to add a commitment to make available Satellite and Cellular Phones for communication with Offsite Emergency Change Summary Analysis Page 2 of 12 Facilities and Field Teams, and for inter-facility use. At JAF, there are abundant Satellite or Cellular-based phones installed at the ERFs, Field Survey Team Vehicles, and at the OCEMO to provide a backup means of communications as stipulated in NUREG-0654. The following Satellite and Cellular Phones are available during an Emergency Condition for use by the Emergency Response Organization (ERO):

o Main Control Room (1 installed Cellular Phone, 1 installed Satellite Phone) o Technical Support Center (TSC) (3 installed Cellular Phones) o Operations Support Center (OSC) (1 installed Cellular Phone) o EOF (1 installed Satellite Phone) o Field Survey Teams (2 installed Cellular Phones, 4 installed Satellite Phones) o Alternate Facilities (2 Handheld Satellite Phones)

Note, there are 25 additional Satellite phones installed to support FLEX objectives (and not credited under the Emergency Plan) that are available but may need additional time to set up or may have limited satellite access from inside the facility.

EP-AA-1014, Appendix N, Typical Federal Support Resources, Step 4, Radio Frequency Table is removed from the Emergency Plan. The deleted table contains a list of Radio systems and associated frequencies utilized at JAF. Under this revision, the JAF EP Radios are no longer utilized for Radiological Survey Teams and communications with OROs (see changes above for justification of this revision). The other Radio systems identified in this table have been provided for information only and not as commitments under the Emergency Plan. The Station Security and Law Enforcement Radio channels described in Step 4 fall under the JAF Security Plan. With the removal of the EP-related Radio systems, the future applicability of this list of Radio frequencies, which distinguish between Security and EP-related channels, is no longer needed or useful. As such, the informational table is removed from the Emergency Plan.

2. Radiological Emergency Communication System (RECS) Changes The RECS is a separate and independent telephone system from the local commercial telephone system. The RECS platform utilized Plain Old Telephone System (POTS) copper wire technology. The system is used at JAF to provide initial offsite notification of an emergency as well as providing continuing emergency information to New York State and Oswego County Authorities. The Emergency Plan is revised to credit the Emergency Management Network (EmNET) platform for RECS which utilizes Voice over Internet Protocol (VoIP) technology. Additionally, the list of installed RECS phones is updated to reflect the installed offsite locations.

The JAF Emergency Plan is revised to reflect the installation of the EmNET platform as the Radiological Emergency Communication System. Section 5.2.4.1 is revised to include EmNET in place of the POTS system. In addition, EmNET has been added to the Acronym and Definition sections of the Emergency Plan Annex as well as an editorial change to remove reference to Nine Mile Point Nuclear Station (NMPNS) from the Emergency Preparedness Implementing Procedure (EPIP) acronym.

Change Summary Analysis Page 3 of 12 Also, as part of this revision, the location of RECS phones discussed in Section 5.2.3 was reviewed. The RECS phones located at the New York State (NYS) Alternate Watch Center, Department of Health, New York State Office of Emergency Management (NYSOEM) Regional Office, and NYSOEM Technical Resources and the Joint Information Center are no longer necessary or desired. These extra extensions are beyond those required by regulatory guidance and were originally installed in coordination with the OROs. With the advancement of communications technology, the need to maintain these additional dedicated copper-based phone extensions is unnecessary. Note that RECS EmNET phones still remain offsite at Oswego County Warning Point (Oswego County 911 Center), Oswego County Emergency Operations Center, NYS Warning Point, and the NYS Emergency Operations Center.

The affected parties have been contacted and permission was obtained to remove the RECS line extensions considering the advancement of communications technology (VOIP, text messages, fiber optics, etc.).

3. Dedicated Phone Line Changes JAF utilizes dedicated POTS phone lines as a backup independent means to provide onsite inter-facility communications. As the old POTS lines are being retired per a federal mandate, the copper-based platform is replaced by fiber optic, cellular, and satellite technology in the JAF ERFs. Additionally, Dedicated Conference Bridges are utilized to provide and maintain direct facility-to-facility communication described in the Emergency Plan.

4. Addition of Non-Regulatory Commitments Non-regulatory commitments made to the State of New York in accordance with CEG procedures and processes were added as Appendix O for visibility.

5. Editorial Change In February 2022, a license transfer between Exelon Generation Company, LLC and Constellation Energy Generation, LLC (CEG) was completed such that CEG obtained ownership and operating authority of the JAF facility. Editorial changes to the Emergency Plan Annex were made to reflect CEG as appropriate.

6. Relocation of Training Requirements Training requirement information contained in Section 6 of the JAF Emergency Plan Annex, redundant to that found in Section O of EP-AA-1000, "Standardized Radiological Emergency Plan," is removed.

IV.

Description of How the Changes Still Comply with Regulations

1. EP VHF System Radio Retirement 10 CFR 50.47, Planning Standard (b)(6), requires that "Provisions exist for prompt communications among principal response organizations to emergency personnel and Change Summary Analysis Page 4 of 12 to the public." NUREG-0654, Program Element II.F.1, further requires that "Each organization shall establish reliable primary and backup means of communication for licensees, local, and State response organizations. Such systems should be selected to be compatible with one another. Each plan shall include: b. provision for communications with contiguous State/local governments within the Emergency Planning Zones;."

Per EP-AA-1014, the JAF Emergency Plan specifies that EP Radios are utilized to provide a backup means of communication between the OCEMO, as well as communication with the JAF Radiological Survey Teams and the JAF EOFs. As a result of the increased burden to maintain the JAF VHF EP Radio system, and the advancements in communications technology since the inception of the JAF Emergency Plan, the JAF VHF Radio System is being replaced by Satellite and Cellular Phones for these communication functions. Note that station Ultra High Frequency (UHF) radios are also utilized to communicate between JAF Security, Nine Mile Point Nuclear Security, and Local Law Enforcement Agencies (LLEAs), as well as being used for in-plant communications. These UHF radios systems are maintained and are not revised per this change.

Radios have been credited since the early inception of the NRC-approved JAF Emergency Plan. At the time of the initial Emergency Plan, available communication technology was limited to copper-wire based POTS and Radio systems. Since this time (i.e., early 1980s), communications technology has advanced to include more robust and diverse methods. Available technology today includes Cellular, Satellite, and VoIP systems, all of which are currently utilized in some capacity at JAF. These additional methods provide a more robust, reliable, and diverse means to support communications during a radiological emergency.

2. Radiological Emergency Communication System (RECS) Changes 10 CFR 50.47, Planning Standard (b)(5), requires that "Procedures have been established for notification, by the licensee, of State and local response organizations and for notification of emergency personnel by all organizations; the content of initial and follow-up messages to response organizations and the public has been established; and means to provide early notification and clear instruction to the populace within the plume exposure pathway Emergency Planning Zone have been established." NUREG-0654, Program Element II.E.1, further requires "Each organization shall establish procedures which describe mutually agreeable bases for notification of response organizations consistent with the emergency classification and action level scheme set forth in Appendix 1."

10 CFR 50.47, Planning Standard (b)(6), requires that "Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public." NUREG-0654, Program Element II.F.1, further requires that "Each organization shall establish reliable primary and backup means of communication for licensees, local, and State response organizations. Such systems should be selected to be compatible with one another. Each plan shall include:

a. provision for 24-hour per day notification to and activation of the State/local emergency response network; and at a minimum, a telephone link and alternate, Change Summary Analysis Page 5 of 12 including 24-hour per day manning of communications link that initiate emergency response actions.

b. provision for communications with contiguous State/local governments within the Emergency Planning Zones;

c. provision for communications as with the Federal emergency response organization.

Additionally, NUREG-0696, Functional Criteria for Emergency Response Facilities, requires that Licensees provide a "means for TSC [EOF] telephone access to commercial telephone common-carrier services that bypasses any onsite or local offsite telephone switching facilities that may be susceptible to loss of power during emergencies."

The JAF Emergency Plan Annex, EP-AA-1014, Section 5.2.4.1 states that "The Radiological Emergency Communications System is a dedicated telephone network to be used for communications pertaining to nuclear emergencies at JAFNPP."

The JAF RECS was initially installed as a separate and completely independent system from the local telephone system utilizing POTS technology. This system is used to provide initial notification of an emergency and continuing emergency information to New York State and Oswego County Authorities.

As of August 2, 2022, telephone networks are required to sunset all long-standing POTS phone line connections in the U.S. This mandate was released by the Federal Communications Commission in August 2019. POTS lines have been in use for over 100 years in the U.S. and were the primary means of communication before the advent of Cell phones, Satellite phones and VOIP systems.

JAF has upgraded their site communication systems to utilize EmNET platform for State/local communication capability. RECS EmNET phones are installed at the JAF Main Control Room (MCR), the Technical Support Center (TSC) and EOF, as well as offsite at Oswego County Warning Point (Oswego County 911 Center), Oswego County Emergency Operations Center, NYS Warning Point and the NYS Emergency Operations Center. The current RECS POTS lines will be retired.

EmNET is a VoIP-based communication system. EmNET is a national communications network designed to provide the operational functions listed below through flexible, redundant, and secure communications paths. The EmNET VoIP system at JAF is independent of the stations telephone system.

o Provide a standardized platform for emergency and routine (non-emergency) communications between thousands of network endpoints (Nuclear Power Plants, Emergency Response Facilities, Federal Emergency Management Agency, State and Local Emergency Operations Centers, Municipalities, Broadcast Partners, etc.).

o Provide a digital replacement for the RECS POTS network with more features, increased security, and redundant communications paths.

Change Summary Analysis Page 6 of 12 o Provide a digital aggregation, authentication, and delivery backbone for EP.

The network satisfies the nuclear EROs need for a secure voice and messaging system, redundant in nature, which can be used to rapidly communicate with multiple endpoints or disseminate a message to multiple stations simultaneously.

EmNET provides redundant communications paths using a hybrid system design. All remote stations are capable of communicating with the EmNET servers using multiple communications paths for the purposes of redundancy. The primary communication path for each remote station is terrestrial Internet.

EmNET is a managed network of servers and remote clients. Network operation is controlled at the Network Management Center (NMC). The status of all servers, critical clients, and transmission capabilities are monitored 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day, 365 days a year, and technicians are available to respond should any abnormalities, errors, or emergencies occur.

EmNET utilizes an "active/active" server architecture comprised of primary, alternate, and geo-recovery servers to ensure survivability and continuity of communications in the event that the primary server location becomes unavailable.

All network accounts, users privileges, and messaging data are mirrored between all servers real-time to allow alternate and geo-recovery servers to immediately take over all operations should the primary server become unavailable.

3. Dedicated Phone Line Changes 10 CFR 50.47, Planning Standard (b)(6), requires that "Provisions exist for prompt communications among principal response organizations to emergency personnel and to the public." NUREG-0654, Program Element II.F.1, further requires that "Each organization shall establish reliable primary and backup means of communication for licensees, local, and State response organizations."

JAF Emergency Plan Annex, EP-AA-1014, Section 5.2.4.2, Other Dedicated or Special Lines, states that in addition to the RECS system, dedicated telephone connections provide direct communication between the points shown below through use of bridge lines. Access to the bridge lines is available through redundant means from each facility (e.g., VOIP, Satellite). These bridge lines include conference between:

a. Control Room to:

NRC Technical Support Center NMPNS EOF OSC

b. Technical Support Center to:

Change Summary Analysis Page 7 of 12 NRC Control Room NMPNS Emergency Operations Facility Operations Support Center Backup Operational Support Center

c. Emergency Operations Facility to:

NRC Technical Support Center Operations Support Center JAFNPP Radiation Protection Manager Control Room The JAF Dedicated Telephone System is based on the POTS copper wire platform. As of August 2, 2022, telephone networks are required to sunset all long-standing POTS phone line connections in the U.S. This mandate was released by the Federal Communication Commission in August 2019. As a result of the mandate, JAF is revising their Dedicated Telephone System. As the old POTS lines are being retired, the copper-based platform is replaced by VoIP and Satellite technology in the JAF ERFs. The addition of these two diverse platforms maintains the independent methods (primary and backup) for interfacility communication. In addition to the installation of VoIP and Satellite phones in the ERFS, EP Conference Bridges have been implemented to provide the direct dedicated communication between ERFs described in the Emergency Plan.

The dedicated conference bridges described in the EPIPs can be accessed at any ERF.

Note that the NRC is removed from the list of participants as they are not required to participate in the company inter-facility communications. The function of these bridge lines is to facilitate inter-facility communications by JAF staff; however, the NRC staff can participate in the bridge conference lines should conditions warrant. Designated communication systems for the NRC staff are provided through the Emergency Notification System (ENS), the Health Physics Network (HPN) and commercial telephone lines.

4. Addition of Non-Regulatory Commitments The commitments meet the definition of a non-regulatory commitment per CEG procedure LS-AA-110, Commitment Management. Per LS-AA-110, a non-regulatory commitment is characterized as an explicit statement to take a specific action agreed to or volunteered by CEG and submitted in formal correspondence to an external organization (other than the NRC), authorized by a CEG officer, and specifically identified as a commitment.

Change Summary Analysis Page 8 of 12

5. Editorial Change Regulatory Guide 1.219, Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors, Section 5.1, states "The licensee should screen each proposed change separately and reserve the treatment of changes collectively for (2) editorial or typographical changes such as formatting, paragraph numbering, spelling, or punctuation that do not change intent, The licensee should document this screening if it concludes that a 10 CFR 50.54(q) evaluation is not necessary." No further evaluation is necessary for these editorial changes. The following editorial change is implemented in the JAF Emergency Plan Annex, EP-AA-1014:

Company Name Change In February 2022, a license transfer between Exelon Generation Company, LLC and CEG was completed such that CEG obtained ownership and operating authority of the JAF facility. As a result of this change, reference to Exelon and Exelon Nuclear was revised to reflect CEG throughout the JAF Emergency Plan.

6. Relocation of Training Requirements Section 6.2, Paragraphs 1 - 6, of the JAF Emergency Plan Annex were revised with most information identified to be redundant or comparable to the information contained in EP-AA-1000, Standardized Radiological Nuclear Emergency Plan (i.e., Standard Plan). The following sections evaluate each paragraph within Section 6.2, as well as each row of Figures 6.1 and 6.2.

Paragraph 1 of the JAF Station Annex states that personnel in the ERO receive training in accordance with their EP role. A comparable requirement exists in the Constellation Standard Emergency Plan EP-AA-1000, Section O, Emergency Response Training. Section O states "The E-Plan Training Program assures the training, qualification, and requalification of individuals who may be called on for assistance during an emergency." It also states, "Exelon personnel who are assigned an E-Plan position will receive retraining at a frequency of once per calendar year not to exceed 18 months between training sessions." The requirement to train ERO members for their EP role is maintained in the Standardized Emergency Plan and can be removed from the Station Annex without a reduction in effectiveness of the Emergency Plan.

Paragraph 2 of the JAF Station Annex states that the Training Department shall maintain records regarding EP Training including both classroom and drills/exercises. A comparable requirement exists in the Constellation Standard Emergency Plan EP-AA-1000, Section O, Emergency Response Training. Section O.5.a, states that Corporate ERO responsibilities include record keeping for training courses and ensuring the records are current. Additionally, Section P.3 of the Standard Emergency Plan states that Station EP Manager responsibilities include maintaining adequate documentation/files to support EP activities and overseeing Change Summary Analysis Page 9 of 12 the maintenance of the ERO training records. Training is defined to include both classroom and drills/exercises.

EPIP TQ-AA-113 implements the EP training records retention and is not revised as a result of this change. TQ-AA-113 states the following:

5.4. Training Records 5.3.1. EP training records are required to be maintained for 2 years (Exelon Nuclear [CEG] Standard Records Retention Schedule 3D.128). NOTE: EP Training performed in conjunction with INPO Accredited Training Programs may be subject to their program record retention requirements.

5.3.2. EP Manager or designee review of completed documentation may be required prior to sending records to Records Management.

5.3.3. All records for this Training Program are maintained in accordance TQ-AA-205, Training Records.

5.3.4. Ensure finalized documents are sent to records management for archiving in accordance with RM-AA-101, Records Management Program.

The requirement for maintaining training records is maintained by the Standardized Emergency Plan and can be removed from the Station Annex without a reduction in effectiveness of the Emergency Plan.

Paragraph 3 of the JAF Station Annex provides a curriculum to be completed by individuals on the station Authorized Access List. This curriculum provides instructions to those individuals who might be present in an emergency situation. A comparable requirement exists in the Constellation Standard Emergency Plan EP-AA-1000, Section O, Emergency Response Training. Section O.5.c states, "All personnel with unescorted station access are provided with initial orientation training on the notification and instruction methods used in the event of an emergency." The Standardized Emergency Plan provides for training of the required actions to be taken during an emergency including alarms, assembly, evacuation, as well as any other special precautions and limitations. The detail is contained in company Nuclear General Employee Training (NGET) materials and is not revised with this change.

The requirement to provide an EP curriculum to personnel with authorized access in the JAF Emergency Plan Annex (i.e., EP-AA-1014) is maintained by the Standardized Emergency Plan (i.e., EP-AA-1000) and can be removed from the JAF Emergency Plan Annex without a reduction in effectiveness of the Emergency Plan.

Change Summary Analysis Page 10 of 12 Paragraph 4 of the JAF Station Annex states that personnel with specific emergency preparedness duties and responsibilities shall receive specialized training. The types (categories) of training are listed. A comparable requirement exists in the Constellation Standard Emergency Plan EP-AA-1000, Section O, Emergency Response Training. Section O.4 states, "Exelon Nuclear ERO personnel who are responsible for implementing this plan receive specialized training. The training program for emergency response personnel is developed based on the requirements of 10 CFR 50, Appendix E and position specific responsibilities." The standardized Emergency Plan also lists the position types.

The requirement to provide specialized training for the ERO is maintained by the Standardized Emergency Plan and can be removed from the Station Annex without a reduction in effectiveness of the Emergency Plan. One specific training discussed in the Annex regards Severe Accident training. Severe Accident training is maintained at JAF, but the reference is removed from the Emergency Plan Annex. JAF initially maintained a station commitment to NEI 91-04, Severe Accident Issue Closure Guidelines, which tied Severe Accident training to Emergency Planning. As a result, many licensees included a discussion of Severe Accident Management Guidelines (SAMG) training as part of the Emergency Plans. Subsequently, on December 15, 2015, JAF sent a letter to the NRC to update the stations commitment for SAMGs. It supersedes the stations commitment to NEI 91-04. JAFs new commitment is to NEI 14-01, Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents, which removes the commitment to include SAMGs as part of the Emergency Plan. From NEI 14-01:

Each licensee should maintain Severe Accident Management Guidelines (SAMGs) and supporting guidelines which consider the generic technical guidance provided by the applicable technology Owners Group. This includes the development of any additional guidance necessary for responding to a beyond design basis event or severe accident affecting the cooling of irradiated fuel stored in a spent fuel pool. With respect to guidance issued by the Nuclear Energy Institute (NEI), the material in this document supersedes that provided in Section 5 of NEI 91-04, Severe Accident Issue Closure Guidelines, for the development, implementation and maintenance of severe accident management programs.

PROCEDURE INTEGRATION Each licensee should establish an overall framework for strategies that would be used to mitigate and manage the consequences of a beyond design basis event and severe accident. This framework should address the integrated use of emergency response procedures and guidelines such that they have been designed to work together to implement the best available strategy for preventing or mitigating fuel damage, and limiting radiological releases. The effective integration of procedures and guidelines is characterized by the attributes listed in Section 2.4, Integration of Procedure and Guideline Sets.

The station commitment made in 2015 states:

Change Summary Analysis Page 11 of 12 "ENO [Entergy - JAFs owner at the time] will update the site Severe Accident Management Guidelines (SAMGs) to future revisions of the Boiling Water Reactor Owners Group (BWROG) generic severe accident technical guidelines, and the SAMGs will be integrated with other emergency response guideline sets and symptom-based Emergency Operating Procedures, and validated, using the guidance in NEI 14-01, Emergency Response Procedures and Guidelines for Beyond Design Basis Events and Severe Accidents."

In effect, the new commitment removes the ties between the Emergency Plan and SAMGs. NEI recommends that SAMGs should be deleted from the Emergency Plans citing the revised change in commitments. There are no EP Regulatory requirements for SAMGs at this time, as SAMGs do not fall under 10 CFR 50.47 or 10 CFR 50, Appendix E. The FLEX Support Guidelines, SAMGs, and Extensive Damage Mitigation Guidelines (EDMGs) are a set of Beyond Design Basis (BDB) documents considered together that should stand alone apart from the Emergency Plan. The SAMG training requirements fall under the BDB program at the station. Note: SAMGs are still discussed in EPIPs.

TQ-AA-113 still recognizes SAMG training for certain ERO positions; however, it is inappropriate to include SAMG commitments under the EP program rather than the BDB program.

Paragraph 5 of the JAF Station Annex describes information contained in Figure 6.1.

Paragraph 5 also refers to the Standard Plan and TQ-AA-113 to describe the EP training program. This is retained in the proposed change to Section 6.2 which continues to refer to both EP-AA-1000 and TQ-AA-113. The requirement is maintained in the JAF Emergency Plan Annex Section 6.2.

Paragraph 6 of the JAF Station Annex states that training will include both classroom and practical training. A comparable requirement exists in the Constellation Standard Emergency Plan EP-AA-1000, Section O, Emergency Response Training.

Section O states "In addition to general and specialized classroom training, members of the Exelon Nuclear ERO receive periodic performance based emergency response training."

The requirement to include both classroom and practical training is maintained by the Standardized Emergency Plan and can be removed from the JAF Emergency Plan Annex without a reduction in effectiveness of the Emergency Plan.

Figure 6.1 - Emergency Response Training, presents a summary of the emergency response training program including type of training, personnel receiving training, frequency of training and retraining, applicable procedures, and objectives for the training. The Emergency Response Training program is also described in the Standard Plan EP-AA-1000. In addition, personnel assigned to ERO positions are described in the EPIP TQ-AA-113, ERO Training and Qualifications, Attachment 1 -

ERO Position Desired Prerequisites. The experience and/or qualifications to fill ERO positions are provided in detail in the Attachment 1 and are consistent with the information in EP-AA-1014, Figure 6.1.

Change Summary Analysis Page 12 of 12 Figure 6.2 - Schedule of Drill Performance, presents a summary of the emergency drill frequencies and drill objectives. Emergency Preparedness Drills and Exercises are also described in the Standard Plan EP-AA-1000, Section N.2.a. The drill frequencies and objectives discussed in the Standard Plan are consistent with the information in EP-AA-1014, Figure 6.1.

Summary Applicable regulatory commitments made to the NRC continue to be met. Existing requirements and capabilities under the Emergency Plan were not deleted or reduced and applicable regulatory requirements established in 10 CFR 50.47, 10 CFR 50, Appendix E, and the Program Element guidance of NUREG-0654 continue to be met.

V.

Description of Why the Changes are Not a Reduction in Effectiveness (RIE)

Based on the changes described in Sections III and IV above, the emergency response capabilities are maintained and are not adversely impacted. The revision to the Emergency Plan Annex discussed above does not change the meaning or intent of Emergency Plan requirements for JAF. Existing emergency planning requirements and capabilities have not been deleted or reduced as a result of these revisions. The changes do not alter the capability of the ERO to implement required Emergency Plan actions, and do not affect the timeliness or effectiveness of the performance of emergency planning functions. The changes described continue to satisfy applicable emergency planning standard requirements established in 10 CFR 50.47 and 10 CFR 50, Appendix E, as well as program elements described in the guidance of NUREG-0654. The changes described continue to maintain emergency planning commitments to the NRC. Therefore, the revision to the Emergency Plan Annex document described above does not constitute a reduction in effectiveness of the Emergency Plan for JAF.

ATTACHMENT 2 Radiological Emergency Plan Document Revision EP-AA-1014, Revision 5, Radiological Emergency Plan Annex for James A. FitzPatrick Station

EP-AA-1014 Revision 5 CONSTELLATION RADIOLOGICAL EMERGENCY PLAN ANNEX FOR JAMES A. FITZPATRICK STATION

FitzPatrick Annex Constellation October 2023 ii EP-AA-1014 (Revision 5)

REVISION HISTORY Revision 0: 03/18 Revision 1: 04/18 Revision 2: 05/19 Revision 3: 12/19 Revision 4: 12/19 Revision 5: 10/23

FitzPatrick Annex Constellation October 2023 JF 1-1 EP-AA-1014 (Revision 5)

RADIOLOGICAL EMERGENCY PLAN ANNEX FOR JAMES A. FITZPATRICK STATION TABLE OF CONTENTS PAGE Section 1: Introduction......................................................................... 1-5 1.1 Site Description.......................................................................... 1-5 1.2 Purpose...................................................................................... 1-6 1.3 Concept..................................................................................... 1-7 1.4 Emergency Planning Zones 1-10 1.5 Population...1-11 1.6 Figures, Forms, and Attachments1-11 Figure 1-1, JAFNPP Fenced Area Map............................................... 1-12 Figure 1-2, Plume Exposure Pathway Emergency Planning Zone....... 1-13 Figure 1-3, Ingestion Exposure Pathway Emergency Planning Zone... 1-14 Figure 1-4, Population Distribution by Emergency Response Planning Area.................................................................... 1-15 Figure 1-5, Combined NMPNS / JAFNPP Site Map............................ 1-17 Section 2: Organizational Control of Emergencies................................ 2-1 2.1 Normal Operating Organization................................................... 2-1 2.2 Onsite Emergency Organization................................................. 2-1 2.3 Augmented (Minimum Staffing) Emergency Organization......... 2-2 2.4 Offsite Support Organization....................................................... 2-2 2.5 Coordination with Participating Government Agencies............... 2-3 2.6 Administrative and Logistics Support.......................................... 2-6 2.7 Figures, Forms, and Attachments............................................... 2-6 Figure 2-1, Emergency Organization Interface..................................... 2-7 Figure 2-2, JAFNPP Emergency Staffing On Shift Response Organization....................................................................... 2-8 Table 2-1, Plant Personnel - Emergency Activity Assignments......... 2-9 Notes for Table 2-1................................................................................ 2-11 Section 3: Classification of Emergencies 3.1 Classification System................................................................. 3-1 3.2 Unusual Event............................................................................ 3-2 3.3 Alert........................................................................................... 3-2 3.4 Site Area Emergency................................................................. 3-3 3.5 General Emergency................................................................... 3-4 3.6 Spectrum of Postulated Accidents.3-4 3.7 Recovery3-6 3.8 Figures, Forms, and Attachments 3-7

FitzPatrick Annex Constellation October 2023 JF 1-2 EP-AA-1014 (Revision 5)

Figure 3-1, Recommended Protective Actions for the General Population and Emergency Workers..3-8 Figure 3-2, Maximum Estimated Doses from Design Basis Accidents.3-9 Section 4: Emergency Measures............................................................. 4-1 4.1 Activation of the Emergency Organization................................. 4-1 4.2 Assessment Actions................................................................... 4-4 4.3 Mitigative Actions..................................................................... 4-10 4.4 Protective Actions.................................................................. 4-10 4.5 Aid to Affected Personnel...................................................... 4-17 4.6 Figures, Forms, and Attachments.......................................... 4-19 Figure 4-1, Emergency Exposure Criteria......................................... 4-20 Figure 4-2, Ten Mile Emergency Planning Zone................................ 4-21 Figure 4-3, 2010 Population Estimates ERPAs................................ 4-22 Figure 4-4, Bus Routes and Pickup Point Map................................. 4-23 Figure 4-5, Offsite Survey Locations................................................ 4-24 Figure 4-6, Special Facilities............................................................ 4-25 Figure 4-7, Siren Locations.............................................................. 4-26 Figure 4-8, Off-Site Environmental Monitoring Station and TLD Locations....................................................................... 4-27 Figure 4-9, Primary Evacuation Routes............................................ 4-28 Section 5: Facilities and Equipment........................................................... 5-1 5.1 Emergency Response Facilities.................................................. 5-1 5.2 Communications Systems......................................................... 5-6 5.3 Assessment Facilities and Systems........................................... 5-10 5.4 Protective Facilities.................................................................. 5-20 5.5 Onsite First Aid and Medical Facilities..................................... 5-21 5.6 Decontamination Facilities for Emergency Personnel............. 5-21 5.7 Damage Control Equipment.................................................... 5-22 5.8 Control of Emergency Equipment............................................ 5-22 5.9 Federal Response Support...................................................... 5-22 5.10 Figures, Forms, and Attachments............................................ 5-22 Figure 5-1, Emergency Communications Network 5-23 Figure 5-2, Onsite Environmental Station and TLD/DLR Locations.5-24 Figure 5-3, Off-Ste Environmental Station and TLD/DLR Locations5-25 Figure 5-4, Siren Locations Map......................................................... 5-26 Figure 5-5, Offsite Survey Locations Map......................................... 5-28 Section 6: Maintaining Preparedness......................................................... 6-1 6.1 Responsibility for Maintaining Emergency Preparedness........... 6-1 6.2 Training of Emergency Personnel............................................. 6-2 6.3 Emergency Planning Staff Training............................................. 6-3 6.4 Drills and Exercises..................................................................... 6-3 6.5 Document Maintenance............................................................... 6-5 6.6 Maintenance and Inventory of Emergency Equipment and Supplies....................................................................................... 6-6

FitzPatrick Annex Constellation October 2023 JF 1-3 EP-AA-1014 (Revision 5) 6.7 Maintenance of Public and News and News Media Awareness. 6-7 Section 7: Definitions and Acronyms............................................................ 7-1 7.1 Definitions.................................................................................... 7-1 7.2 Acronyms................................................................................... 7-9 APPENDICES A. Emergency Plan Implementing Procedures B. Policy Statement C. Letters of Agreement D. New York State Plan and Procedures E. Oswego County Plan and Procedures F. Typical Support Companies H. Public Information Program I. Emergency Equipment Kits J. Supporting Documents L. NUREG-0654 Cross Reference N. Typical Federal Support Resources O. Non-Regulatory Commitments ADDENDUMS Addendum 1, James A. FitzPatrick Nuclear Power Plant On-Shift Staffing Analysis Report Addendum 2, James A. FitzPatrick Nuclear Power Plant Evacuation Time Estimates Addendum 3, James A. FitzPatrick Nuclear Power Plant Emergency Action Levels

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RADIOLOGICAL EMERGENCY PLAN ANNEX FOR JAMES A. FITZPATRICK STATION Section 1: Introduction As required in the conditions set forth by the Nuclear Regulatory Commission (NRC) for the operating licenses for the Constellation Stations, the management of Constellation recognizes its responsibility and authority to operate and maintain the nuclear power stations in such a manner as to provide for the safety of the general public.

The Constellation Emergency Preparedness Program consists of EP-AA-1000, Constellation Standardized Radiological Emergency Plan (henceforth known as the Standard Plan), Station Annexes, emergency plan implementing procedures, and associated program administrative documents. The Constellation Standardized Radiological Emergency Plan outlines the basis for response actions that would be implemented in an emergency. Planning efforts common to all Constellation stations are encompassed within the Emergency Plan.

This document serves as the Radiological Emergency Plan Annex for FitzPatrick Station and contains information and guidance that is unique to the station. This includes facility geography and location for a full understanding and representation of the stations emergency response capabilities. The Station Annex is subject to the same review and audit requirements as the Constellation Standardized Radiological Emergency Plan per EP-AA-120, Emergency Plan Administration.

1.1 Site Description The James A. FitzPatrick Nuclear Power Plant (JAFNPP) is a single-unit electric power generating plant equipped with a boiling water reactor rated at approximately 2536 megawatts thermal with a net electrical output of approximately 850 megawatts. The plant's principal components are a nuclear steam generating system, a turbine-generator unit, 345 kv and 115 kv switchyards, lake water pumping facilities complete with intake and discharge structures, and other auxiliary equipment.

The plant consists of five principal buildings interconnected to form one structure approximately 640 feet long and 250 feet wide. These buildings are the turbine building, the reactor building, the radwaste building, the pump house and screen well building, and the administrative building. There is a 385 foot high stack located approximately 400 feet south of the plant. The 345 kV and 115 kV switchyards are approximately 200 feet west of the plant. Figure 1.1 shows a map of the site. The plant buildings and switchyards use approximately one percent of the total site area. About 600 acres of the site has been left in its natural condition.

The plant site is on the shore of Lake Ontario in the town of Scriba, Oswego County, New York. The plant is located adjacent to and east of the Nine Mile Point Nuclear Station (NMPNS) which is operated by another Corporation.

Figure 1.5 shows a map of the combined NMPNS/JAFNPP Site. Exclusion

FitzPatrick Annex Constellation October 2023 JF 1-5 EP-AA-1014 (Revision 5) distances for the NMPNS/JAFNPP site are 3,000 feet to the east, over a mile to the west and approximately one and one-half miles to the southern site boundary.

Markers have been placed in Lake Ontario denoting an exclusion distance north of the plant site. These markers are removed prior to the onset of the winter season. For the purpose of off-site emergency planning, the NMPNS/JAFNPP sites are considered to be one exclusion area. This exclusion area may also be referred to as the site boundary or combined owner-controlled areas.

1.2 Purpose The Emergency Preparedness plan for the James A. FitzPatrick Nuclear Power Plant consists of the Constellation Standardized Radiological Emergency Plan, Fitzpatrick Station Annex, off-site radiological emergency plans, and procedures for protection of plant personnel and the general public. The JAFNPP Emergency Plan provides guidance for response to both onsite and off-site emergency situations. This JAFNPP Emergency Plan provides guidance for response to both onsite and off-site emergency situations. The plan provides responses to all levels of emergencies that have an actual or potential degradation of the level of safety at FitzPatrick, including hostile action. To this end, this plan has been prepared in general accordance with NUREG-0654/

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

This plan presents the organization and emergency response activities that will be performed to provide an organized response to an accident. Detailed actions are described in the Emergency Plan Implementing Procedures. Inter-relationships of this plan with procedures, other plans and emergency arrangements include:

A. Detailed actions to be taken by plant personnel in response to emergency conditions are described in Emergency Plan Implementing Procedures. A listing of JAFNPP Emergency Plan Implementing Procedures is contained in Appendix A.

B. Plant Operating Procedures are coordinated with the Emergency Plan and Implementing Procedures to ensure appropriate actions are taken on a timely basis.

C. The FitzPatrick Radiation Protection Procedures define such areas as radiological controls and precautions, personnel decontamination and instructions for health physics activities. These instructions are implemented on a routine basis and may be used during emergency situations as necessary.

Specific Implementing Procedures, such as those necessary for emergency radiological surveys, are included in the Emergency Plan Implementing Procedures.

D. The FitzPatrick Security and Safeguards Plans and Implementing Procedures and the Emergency Plan and Implementing Procedures are coordinated to

FitzPatrick Annex Constellation October 2023 JF 1-6 EP-AA-1014 (Revision 5) ensure compatibility.

The Oswego County Radiological Emergency Preparedness Plan and the New York State Radiological Emergency Plan, in conjunction with this Plan and Implementing Procedures, provide for early and redundant notification schemes, continual assessment and update, and the initiation of protective actions.

E. The concept of JAF emergency operations and its relationship to the Federal, State, County and private organizations is described in Section 5.0 and 6.0. A block diagram which illustrates these interrelationships is included in Figure 5.1.

1.3 Concept The JAFNPP Emergency Plan describes the emergency response organization that will be in place during an emergency and describes the interfaces with and responsibilities of the corporate, state, county, federal, and private organizations.

1.3.1 Emergency Plan (Standard Plan, Station Annex, and Addendums)

The Emergency Plan ensures that emergency situations, including those involving radiation or radioactive material, are handled properly and efficiently.

The Emergency Plan covers a spectrum of emergencies from minor localized emergencies to major emergencies involving off-site emergency response. The Emergency Plan provides for advance planning required to develop implementation methods. The Emergency Plan describes:

1. An emergency classification system used at the plant and emergency measures to be taken that are compatible with those used by Federal, State and county emergency response agencies and organizations.

2. Organizational control of emergencies by on-site, off-site, and augmentation organizations, including identification of normal and emergency operating organizations.

3. Identification of Federal, State, and County authorities and agencies and other outside organizations that are available for assistance, including plans and agreements pertaining to participating off-site organizations and agencies.

4. Requirements for ensuring a high degree of emergency preparedness and operational readiness such as through training, drills, reviews, and audits.

5. Information pertaining to on-site and off-site emergency facilities and equipment such as the Emergency Operations Facility, Technical Support Center, Operational Support Center, and Joint Information Center.

6. Figures and tables that display information and data such as organizations, maps, and population distributions.

FitzPatrick Annex Constellation October 2023 JF 1-7 EP-AA-1014 (Revision 5) 1.3.2 Emergency Plan Implementation Procedures Emergency Plan Implementation Procedures are used in conjunction with plant operating, chemistry, radiological control, security, and other technical procedures, as appropriate, to respond to emergency conditions and mitigate accident consequences.

These documents are made available to those individuals, facilities, and organizations where immediate use of such instructions would be required during an emergency.

These documents provide:

1. Specific instructions for emergency organizations including responsibilities, facilities, equipment, emergency classification, and seeking emergency assistance used to implement the Emergency Plan and support implementation of the State Radiological Emergency Response Plan.

2. Specific authorities and responsibilities for emergency response personnel responsible for assessing emergency conditions and providing steps to be taken to mitigate the consequences of an accident.

3. Specific instructions to ensure prompt actions, notifications, and communications.

4. A record of completed actions.

5. A mechanism for maintaining emergency preparedness.

Emergency Plan Implementation Procedures are developed to respond to a variety of accident scenarios. These include minor events up to core melt situations with unplanned radioactive material release to the environment. While the emergency level(s) listed in the procedures is sufficient to cause their implementation, it is not necessary to implement all Emergency Plan Implementation Procedures under these conditions. Specific procedures may not be used if the actual emergency does not call for their use. For example: a security threat may not result in plant damage and an unplanned release; therefore, radiological monitoring procedures may not be used.

The following types of documents include the Emergency Plan Implementation Procedures:

Fleet EP Procedures and T&RMs (Training and Reference Materials)

Station/Region EP procedures and T&RMs Position Specific Checklists and Forms 1.3.3 County, State and Federal agencies having lead responsibilities specifically related to this Emergency Plan are:

a.

New York State Department of Health (NYSDOH) - The lead State emergency response agency, responsible for requesting necessary monitoring and for activating assessment and evaluation of personnel, equipment and other resources.

FitzPatrick Annex Constellation October 2023 JF 1-8 EP-AA-1014 (Revision 5)

b.

New York State Office of Emergency Management (NYSOEM) -

Responsible for developing, implementing, and maintaining comprehensive emergency plans and procedures for prompt reactions to potential emergencies at nuclear power plants in New York or in bordering states and adjoining provinces.

c.

Oswego County Emergency Management Office (OCEMO) - Designated by local laws and executive orders to coordinate Oswego County's emergency response.

d.

U.S. Nuclear Regulatory Commission (NRC) - The cognizant Federal agency responsible for verifying appropriate emergency plans have been implemented and for conducting investigative activities associated with an emergency.

e.

U.S. Federal Emergency Management Agency (FEMA) - The Federal agency designated to serve as the contact point for State officials and to coordinate and manage all non-technical aspects of the Federal response.

f.

U.S. Department of Energy (DOE) - The Federal agency responsible for coordinating offsite monitoring, evaluation and assessment activities.

1.3.4 Emergency response is categorized by the following four functional areas:

a. Initiation Initiation of the emergency response occurs with the classification of a situation into one of the four emergency classes: Unusual Event (UE}, Alert, Site Area Emergency, and General Emergency. Based on the level of emergency, the appropriate plant staffing, emergency facility activation, and notification of offsite authorities occurs. Appropriate initial action to alleviate the situation is taken in accordance with plant operating procedures.

b. Assessment The emergency, and its potential or actual radiological consequences, is assessed by the plant operating and emergency staffs. Onsite plant instrumentation, both fixed and portable, and other parametric measurements provide data for projecting radiological exposures. Offsite, radiological survey teams sample air, effluent water, snow, rain, vegetation, and milk; measure ambient gamma and beta radiation levels; and otherwise evaluate actual environmental levels of radiation to provide radiological data. The most reliable assessment data available are utilized to make offsite and onsite protective action recommendations.

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c. Protective and Mitigative action Based on the assessment, onsite or offsite protective actions may be required.

The Shift Emergency Director or Station Emergency Director may implement the plant protective actions of protected area assembly or site evacuation.

Only the Shift Emergency or the Corporate Emergency Director may recommend to offsite authorities that the implementation of protective actions is appropriate. These actions may include sheltering or evacuation. It is the responsibility of offsite authorities to evaluate these recommendations and implement any protective actions in accordance with Oswego County Radiological Emergency Preparedness Plans and the New York State Radiological Emergency Preparedness Plan and their respective implementing procedures.

Mitigative actions will be implemented by onsite personnel to alleviate the emergency situation. Onsite personnel may be supported by local offsite organizations in implementing onsite mitigative actions.

d. Recovery Once the emergency situation has been controlled, recovery begins.

Recovery is defined as: restoration of the plant to its pre-emergency conditions. The onsite emergency organization will be supported with assistance from corporate, federal, and private organizations, as needed.

1.4 Emergency Planning Zones There are two Emergency Planning Zones (EPZ). The first is the Plume Exposure Pathway Emergency Planning Zone which is an area approximately 10 miles in radius around the JAFNPP (see Figure 1.2), for which detailed emergency planning consideration of the plume exposure pathway has been given to ensure prompt and effective protective actions for the public. The second is the Ingestion Exposure Pathway Emergency Planning Zone which is an area approximately 50 miles in radius around the JAFNPP (see Figure 1.3),

for which emergency planning consideration of the ingestion exposure pathway has been given to ensure effective protective measures for the public.

The area within 10 miles of the James A. FitzPatrick Nuclear Power Plant is located on Lake Ontario and in Oswego County. Oswego County is predominantly rural in nature with the majority of its total land acres consisting of woodland, wetlands and inactive agricultural land. Although active agricultural lands account for only a small part of the total land acres, agriculture is the major land use in the county. In recent years, there has been a trend toward fewer farms and increased residences in low density areas.

Available statistics indicate that the area surrounding the site is primarily woodland with some active agricultural land. The major agricultural activity in Oswego County is dairy, accounting for the greatest percentage of the value of all farm products produced in the county. The major harvested crops are hay, alfalfa, and corn. The major livestock animals are cattle.

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The industrial activities within 10 miles of the site are confined principally to the city of Oswego and the community of Scriba, with little industry in the outlying communities of Minetto, Volney, and Mexico. One facility in the immediate area is the NOVELIS manufacturing plant which is located approximately three miles southwest of the site on Route 1. An electrical generating facility has been constructed adjacent to the NOVELIS manufacturing plant.

The public institutions, aside from the schools and churches, within the 10-mile Plume Exposure EPZ of the site are a hospital and a college in the city of Oswego. There are no public institutions within five miles of the site.

A detailed listing of special facilities in Oswego County within the 10-mile Plume Exposure EPZ is presented in the "Oswego County Radiological Emergency Response Plan."

1.5 Population The total 2016 population of the plume exposure pathway EPZ is 41,049. (This data is from 2010 census data as updated in 2016 and is discussed in EP-AA-1014, Addendum 2, Evacuation Time Estimates.) The population density of the immediate area surrounding the site is quite low, with the exception of the city of Oswego whose population in 2015 was 17,787 and the Village of Mexico, located approximately nine miles from the site, which contains about 1,574 residents.

According to the 2011 Residence Census performed for the Radiological Environmental Monitoring Program, the nearest permanent resident is on Lake Road, about 0.7 miles east-southeast of the plant. The population distribution within 10 miles of the site is presented in Figure 1.4.

1.6 Figures, Forms and Attachments Figure 1.1 JAFNPP Fenced Area Map Figure 1.2 Plume Emergency Planning Zone (10 Mile Radius)

Figure 1.3 Ingestion Emergency Planning Zone (50 Mile Radius)

Figure 1.4 Population Distribution by Emergency Response Planning Area Figure 1.5 Combined NMPNS/JAFNPP Site Map

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Figure 1-1 JAFNPP Fenced Area Map

FitzPatrick Annex Constellation October 2023 JF 1-12 EP-AA-1014 (Revision 5)

Figure 1-2 Plume Exposure Pathway Emergency Planning Zone This page is a large map and can be viewed in the Electronic Data Management System (EDMS).

To search for the map, do the following in EDMS:

1.) Log onto EDMS 2.) Set the Object Type to: Exelon Record 3.) Set the facility to: Fitzpatrick 4.) Click the search button located at the bottom right 6.) Double click to view the record that displays in the search results screen 7.) The map will appear in Adobe Reader NOTE: Reference to locate Map in Emergency Planning Dept. efiles.

G:\\EPlan Procedures\\Emergency Plan Maps and Figures\\MAP 1-Rev Plume (Map Number 1) Ten-mile Emergency Planning Zone (Plume Exposure Pathway)

FitzPatrick Annex Constellation October 2023 JF 1-13 EP-AA-1014 (Revision 5)

Figure 1-3 Ingestion Exposure Pathway Emergency Planning Zone

FitzPatrick Annex Constellation October 2023 JF 1-14 EP-AA-1014 (Revision 5)

Figure 1-4 Population Distribution by Emergency Response Planning Area

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Figure 1-4 (Continued) 2016 PERMANENT RESIDENT POPULATION ESTIMATES EMERGENCY RESPONSE PLANNING AREAS Emergency Response Planning Area 2016 Permanent Resident Population Estimates 1

169 2

460 3

334 4

687 5

780 6

887 7

699 8

718 9

597 10 995 11 1,858 12 7,764 13 9,977 14 193 15 1,101 16 1,571 17 583 18 1,010 19 1,281 20 1,736 21 1,731 22 5,918 TOTAL 41,443 Source: 2010 census data.

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Figure 1-5 Combined NMPNS / JAFNPP Site Map

FitzPatrick Annex Constellation October 2023 JF 2-1 EP-AA-1014 (Revision 5)

Section 2: Organizational Control of Emergencies JAFNPP has established an emergency response organization to respond to hostile actions and radiological emergencies. That organization includes on-shift personnel, additional plant personnel who may be offsite, other JAFNPP personnel, local services support, and private organizations support. The interfaces among the various emergency organizations are shown in Figure 2-1. The following sections describe in detail the JAFNPP plant and corporate organization and identify the interaction of the Minimum Staff emergency response organization. Note that the Onsite and Minimum Staff Emergency Response Organization is defined in EP-AA-1000.

2.1 Normal Operating Organization The James A. FitzPatrick Nuclear Power Plant (JAFNPP) organization for normal operation is described in OP-AA-20, Conduct of Operations Process Description, which is consistent with the JAFNPP - specific On Shift Staffing Analysis. The typical minimum shift crew consists of:

1 Shift Manager (SRO) 1 Control Room Supervisor (SRO) 1 Field Support Supervisor (FSS)/Shift Technical Advisor (STA)*

3 Senior Nuclear Operator (RO) 6 Nuclear Plant Operators (NPO)-covers Fire Brigade member, AOP-43 and E-Plan Communicator requirements 1 Radiation Protection Technician (Health Physics) 1 Shift Dose Assessor Security Personnel in accordance with Security Plan

(STA responsibilities may lie with a different member of the Control Room staff.

The STA function is not required in modes 4 and 5.)

FitzPatrick Annex Constellation October 2023 JF 2-2 EP-AA-1014 (Revision 5) 2.2 Offsite Support Organizations 2.2.1 Local Services Support The nature of an emergency may require the augmentation of onsite response groups by local services, personnel and equipment. Support from the following local organizations may be obtained:

o Oswego Hospital o

Oswego County Sheriff o

University Hospital in Syracuse o

The City of Oswego (Fire Department) o Oswego County E-911 Center (Fire Department) o Specific methods for notification of these organizations are contained in Emergency Plan Implementing Procedures.

2.2.2 Private Organization Support JAFNPP may obtain emergency response support from various private organizations. These organizations and the support they may provide are:

A. Nine Mile Point Nuclear Station - Will provide use of laboratories, equipment and personnel for radiological monitoring, decontamination, backup communications, and personnel to assist in recovery operations.

B. R.E. Ginna Nuclear Power Plant - Will provide use of laboratories, equipment and personnel for radiological monitoring, backup communications, and personnel to assist in recovery operations.

C. General Electric-Will provide technical support and personnel.

2.3 Coordination with Participating Government Agencies 2.3.1 State and Local Agencies This section identifies the principal state and local government agencies having action responsibilities for radiological emergencies in the vicinity of the JAFNPP.

The radiological emergency response plans of these agencies describe their respective responsibilities, authorities, capabilities and emergency functions, and are included as part of this Plan. The following is a summary of the provisions for preparedness and response to radiological emergencies by each organization, as well as the primary and alternate methods of emergency notification.

A. State Office of Emergency Management (SOEM) The SOEM is the lead state agency for offsite coordination and response. SOEM coordinates the development of radiological emergency plans. The New York State Emergency Plan received Federal approval on February 1, 1985 and is titled "New York State Radiological Emergency Preparedness Plan." See Appendix D for the locations of plan copies.

FitzPatrick Annex Constellation October 2023 JF 2-3 EP-AA-1014 (Revision 5)

The New York State plan includes provisions for:

Planning and coordination with local, state, Canadian and federal authorities.

Initial response to notification by JAFNPP.

Alert and warning of local political subdivisions.

Evacuation and other protective measures for local populations.

Emergency services. Situation analysis.

Declaration of a "State of Emergency" and provision of state resources to support protective response actions.

B. Oswego County Emergency Management Office (OCEMO)

The OCEMO is the lead local government agency for coordination and response. The OCEMO emergency plan titled, "Oswego County Radiological Emergency Preparedness Plan" received Federal approval on February 1, 1985 and the locations of plan copies are contained in Appendix E.

The OCEMO plan contains provisions for: Notification and management to other emergency response personnel.

Public notification and dissemination of information concerning the incident.

Alert and warning of local officials. Implementation of protective response actions.

(The OCEMO Plan also contains the implementing procedures for an emergency response.)

The primary method of notification to the OCEMO is through Oswego County E-911 Center. The dispatcher is available for twenty-four hours per day communications. Backup satellite phone communications are also available.

2.3.2 Federal Agencies This section identifies the principal federal government agencies receiving notification of an emergency along with those that may be called on for assistance during an emergency. Typical resources available and additional information concerning Federal response is included in Appendix N "Typical Federal Support Resources."

A. U. S. Department of Energy (DOE)

The DOE, Brookhaven Area Office, will respond to requests from JAFNPP, Oswego County, and NYSDOH and provide assistance. This assistance consists of advice and emergency action essential for the control of the immediate hazards to public health and safety as specified in the letter of agreement. As part of this emergency action, DOE will supply personnel and equipment in accordance with the Federal Radiological Monitoring and Assistance Program (FRMAP).

FitzPatrick Annex Constellation October 2023 JF 2-4 EP-AA-1014 (Revision 5)

The primary method of notification to DOE is by telephone. Notification may also be made through the NRC. Upon notification, estimated arrival time of personnel is within four (4) hours.

B. U.S. Department Of Energy (REACTS)

DOE Radiation Emergency Assistance Center/Training Site (REAC/TS) is a deployable DOE National Nuclear Security Agency (NNSA) asset, on call 24/7 to offer its expertise on managing the medical component of a radiation incident.

REAC/TS has developed an interdisciplinary radiation emergency medical response approach that integrates medicine with health physics. This enables rapid dose assessment, radiological and medical triage, diagnosis, and medical management during a radiation emergency.

REAC/TS maintains specialized response teams to ensure readiness to respond. Each team consists of a physician, nurse/paramedic, and a health physicist, all cross-trained in the details of managing a radiation emergency.

Response teams are equipped with state-of-the* art medical equipment that can be transported to the site or used in their facility in Oak Ridge, Tenn.

Capabilities include:

medical and radiological triage

decontamination

diethylenetriaminepentaacetic acid (DTPA) and Prussian Blue therapy for specific radiological materials

diagnostic and prognostic assessments of radiation-induced injuries

biological and radiological dose estimates by methods that include cytogenetic analysis, bioassay, and in vivo counting C. Federal Emergency Management Agency (FEMA)

The Federal Emergency Management Agency has the lead responsibility for all offsite nuclear emergency planning and response. This agency is charged with establishing policy for and coordinating all civil emergency planning and assistance functions for executive agencies.

D. Nuclear Regulatory Commission (NRC)

The U.S. Nuclear Regulatory Commission is responsible for verifying that appropriate emergency plans have been implemented and for conducting investigative activities associated with a radiological emergency. An NRC Response Team will offer assistance during an emergency. Estimated time of arrival is within 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months . The Agency Procedures for the NRC Incident Response Plan (NUREG-0845) describes the functions of the NRC during an incident and the kinds of actions that comprise the NRC response.

FitzPatrick Annex Constellation October 2023 JF 2-5 EP-AA-1014 (Revision 5) 2.4 Administrative and Logistics Support During the response to a radiological emergency, it may be necessary to supplement the Company's resources and/or provide response personnel with necessary support.

Arrangements for this support which includes: the means and sources for obtaining food, lodging, sanitation, office supplies, temporary offices, communications equipment, and vehicles in support of an extended or augmented emergency response. This will be made by the Company Corporate Staff.

2.5 Figures, Forms, and Attachments FIGURE 2-1 Emergency Organization interface FIGURE 2-2 Emergency Staffing - On Shift Response Organization

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Figure 2-1 EMERGENCY ORGANIZATION INTERFACE

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Figure 2-2 JAFNPP EMERGENCY STAFFING ON SHIFT RESPONSE ORGANIZATION Radiation Protection &

Dose Assessor

FitzPatrick Annex Constellation October 2023 JF 3-1 EP-AA-1014 (Revision 5)

Section 3: Classification of Emergencies 3.1 Classification System This plan and its associated implementing procedures provide the means for responding to a wide range of emergency conditions.

NOTE: As used in the following paragraph, "plant operator" means any member of the plant staff, who by virtue of training and experience, is qualified to assess the indications or reports for validity and to compare the same to the EALs in the emergency classification scheme.

JAFNPP maintains the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and shall promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level.

These emergency conditions have been categorized into four emergency classes, which cover the spectrum of postulated accidents. The classification system used in this plan has been developed based on the guidance contained in NEI 99-01 Rev. 6, "Methodology for Development of Emergency Action Levels" and NRC Bulletin 2005-02 "Emergency Preparedness and Security Related Events" and is compatible with the systems used by county and state agencies.

Emergency conditions will be evaluated using the classification guidance in EP-AA-1014 Addendum 3, JAF Emergency Action Levels, and the Emergency Classification and Protective Action Recommendations procedure. That procedure contains event categories, initiating conditions, and emergency action levels for each of the four emergency classes.

The emergency action levels are specific plant conditions, instrument readings, alarms, or other conditions that indicate that an abnormal condition exists which warrants the declaration of an emergency and implementation of the emergency plan.

The purpose of the emergency classification system is to initiate a planned response to a given severity of accident. JAFNPP, county, and state plans and implementing procedures provide for specific emergency organization, notification, emergency facility activation, and preliminary actions to be taken based on the level of emergency that is declared.

As the emergency situation changes, the emergency class will be reviewed and revised in accordance with the classification guidance documents. This allows for the augmentation of emergency personnel and resources to respond to a more severe emergency and provides for an orderly close out of the emergency and entry into recovery operations once the situation has been controlled.

Facility activation may be modified by the Emergency Director if the safety of incoming personnel may be jeopardized by a security event or other event hazardous to incoming personnel.

FitzPatrick Annex Constellation October 2023 JF 3-2 EP-AA-1014 (Revision 5) 3.2 Unusual Event 3.2.1 Description This class applies to an unusual plant condition, which either has occurred or is impending. This plant condition could eventually lead to a potential degradation in overall safety or indicate a security threat to facility protection. Inherently, however, this is a situation in which sufficient time is available to take precautionary and constructive steps to prevent a more serious event or to mitigate any consequences that may occur.

The primary purpose for this class is to ensure that the plant operating staff recognizes initiating conditions, takes appropriate action such as assessment and verification, and comes to a state of readiness to respond if the condition becomes more severe. The Unusual Event class requires that off-site authorities be notified of the event.

No protective actions will be recommended to state and county authorities for an Unusual Event and no offsite agency response is required. The TSC, OSC, or other facilities may be activated as a precautionary measure, or to assist as needed.

.3.2.2 Emergency Action Levels Initiating conditions established as Emergency Action Levels for determining an Unusual Event classification are listed in EP-AA-1014, Addendum 3. An Unusual Event is declared any time that respective Emergency Action Levels are met or exceeded. All minor events are analyzed in light of their potential for degrading the level of plant safety.

3.3 Alert 3.3.1 Description An Alert emergency class is declared when events are in process or have occurred which involve an actual or potential substantial degradation of the level of plant safety or a security event that involves probable life-threatening risk to site personnel or damage to site equipment because of intentional malicious dedicated efforts of HOSTILE ACTIONS. Although the potential for limited releases of radioactivity in excess of technical specification limits may exist, the initial assessment leading to this class indicates that it is unlikely that a public hazard will be created. An Alert requires response by the plant emergency organization, augmentation of onsite emergency resources and constitutes the lowest level where emergency off site response may be required.

The declaration of an Alert results in the activation of the Technical Support Center (TSC), Emergency Operations Facility (EOF), Operational Support Center (OSC) and the Joint Information Center (JIC). The JIC may be declared operational prior to a Site Area Emergency at the discretion of the JIC Director, or designee. Also prompt initial and follow-up notification is provided to federal, state, and local authorities.

At the Alert classification, the JIC may be deactivated at the discretion of the

FitzPatrick Annex Constellation October 2023 JF 3-3 EP-AA-1014 (Revision 5)

Emergency Director if operation is not necessary based upon conditions or events.

(This decision should be discussed with State and County authorities prior to deactivation of the JIC.)

Although initial and follow-up notification to state and county authorities will include projected off site exposures, if applicable, no protective actions will be recommended to those authorities since the exposures possible during an Alert are below the Protective Action Guides (PAG).

3.3.2 Emergency Action Levels Initiating conditions established as Emergency Action Levels for determining an Alert emergency classification are listed in EP-AA-1014, Addendum 3. An Alert is declared any time that respective Emergency Action Levels are met or exceeded.

3.4 Site Area Emergency 3.4.1 Description The Site Area Emergency class is declared when events are in process or have occurred which involve actual or probable major failures of plant functions needed for protection of the public or security events that result in intentional damage because of intentional malicious dedicated efforts of HOSTILE ACTIONS; (1) towards site personnel or equipment that could lead to the likely failure of or; (2) prevents effective access to equipment needed for the protection of the public. Many events within this class constitute an actual or clear potential for significant releases of radioactive material to the environment. These releases, however, are not normally in excess of the PAGs.

The Technical Support Center (TSC), Operational Support Center (OSC), Emergency Operations Facility (EOF) and Joint Information Center will be activated for a Site Area Emergency.

The declaration of a Site Area Emergency requires the notification of federal, state, and county authorities so that they may activate their emergency operation centers and dispatch key emergency personnel.

3.4.2 Emergency Action Levels Initiating conditions established as Emergency Action Levels for determining Site Area Emergency classification are listed in EP-AA-1014, Addendum 3. A Site Area Emergency is declared any time that respective Emergency Action Levels are met or exceeded.

FitzPatrick Annex Constellation October 2023 JF 3-4 EP-AA-1014 (Revision 5) 3.5 General Emergency 3.5.1 Description The General Emergency class is declared when events are in process or have occurred which involve actual or imminent substantial core degradation or melting with the potential for loss of containment integrity and significant releases of radioactivity to the environment or security events that result in an actual loss of physical control of the facility.

The Technical Support Center (TSC), Operational Support Center (OSC), Emergency Operations Facility (EOF), and Joint Information Center will be activated for a General Emergency.

The declaration of a General Emergency requires the notification of federal, state, and county authorities so that they may activate their emergency operating centers and dispatch key emergency personnel.

A General Emergency involves the potential or actual release of airborne radioactivity which may result in off-site projected exposures that would exceed the limits specified in the USEPA Protective Action Guides. The Emergency Director will recommend protective actions to state and county authorities based on actual measurements, projections, or calculations.

It is the responsibility of state and county authorities to implement off site protective actions and to provide an independent determination of the type and extent of such actions.

3.5.2 Emergency Action Levels Initiating conditions established as Emergency Action Levels for determining General Emergency are listed in EP-AA-1014, Addendum 3. A General Emergency is declared any time that a respective Emergency Action Level is met or exceeded.

3.6 Spectrum of Postulated Accidents The Emergency Action Levels contained in EP-AA-1014 Addendum 3, JAF Emergency Action Levels, provide the ability for classifying approximately eighty discrete types and levels of events. However, to develop the maximum projected exposure information contained in Figure 3.2, it was necessary to evaluate several discrete accidents. The discrete accidents addressed in this section are those which are defined in the JAFNPP FSAR Update as "design basis accidents."

FitzPatrick Annex Constellation October 2023 JF 3-5 EP-AA-1014 (Revision 5) 3.6.1 Control Rod Drop Accident An accident that results in radioactive material release from the fuel with the Reactor Coolant Pressure Boundary, Primary Containment and Secondary Containment intact.

As an example, this accident is postulated to occur with the reactor in hot standby, critical condition, and is expected to result in the failure of about 330 fuel rods. With the elimination of the automatic closure of the Main Steam Isolation Valves (MSIVs) on high radiation fission products will be transported to the offgas system and subsequently out the stack. The whole body dose at the site boundary is detailed in the JAFNPP FSAR.

3.6.2 Refueling Accident An accident that results in radioactive material release directly to the Secondary Containment with the Primary Containment not intact.

As an example, this accident is postulated to occur with the reactor in shutdown condition with the vessel head removed. A fuel assembly is assumed to drop onto the top of the core, resulting in the failure of about 440 fuel rods. The refueling floor ventilation radiation monitoring system alarms, isolates the ventilation system, and starts operation of the Standby Gas Treatment System (SGTS), within about one minute.

Noble gases and radioiodines are released to the reactor coolant, migrate to the secondary containment, and are released to the environment through the SGTS.

3.6.3 Main Steam Line Break An accident that results in radioactive material releases outside the Secondary Containment.

As an example, this accident is postulated to occur with the reactor operating at rated conditions. The steam line break occurs outside the secondary containment and releases reactor coolant for a period no longer than 10.5 seconds, until complete closure of the MSIVs. Noble gases and radioiodines in the coolant are assumed to be released directly to the environment.

An estimate of the resultant exposures as shown in Figure 3.2 is for worst case conditions. Actual exposures are proportional to the fission product activity in the steam, as monitored by the off-gas release rate prior to the accident. The exposures in Figure 3.2 are based on the assumption that the off-gas release rate is at the upper limiting condition for operation.

FitzPatrick Annex Constellation October 2023 JF 3-6 EP-AA-1014 (Revision 5) 3.6.4 Loss of Coolant Accident (LOCA)

An accident that results in radioactive material release directly to the Primary Containment.

As an example, this accident is postulated to involve a complete circumferential break of a recirculating loop pipe inside the primary containment with the reactor operating at full power. The accident results in the release of a significant quantity of fission products into the primary containment, leakage into the secondary containment, and release to the environment through the SGTS.

3.6.5 Other Accident Types Additional accident types have been included for the purposes of dose assessment.

The types allow for the variability of isotopic mixtures and, by pre-establishing isotopic mixtures and developing a ratio of containment to atmosphere leakage, allow for simplified use. These include accidents "Containment Design Basis Accident" and "Severe Accident."

3.7 Recovery After the initial emergency response actions are concluded (i.e., the plant is in cold shutdown and under control), a decision to begin the recovery phase will be initiated. A number of considerations will enter into the decision to begin the recovery phase and dismantle the Emergency Response Organization. The decision to enter the recovery phase from an alert or higher will be made by the Corporate Emergency Director in consultation with Senior Station Managers, Corporate Management, and, after a formal discussion with regulatory, State and local authorities has been conducted to ensure coordination and agreement is met for termination. EP-AA-115, Termination and Recovery will be used by the organization to transition from a response organization to a recovery organization.

Federal, State and local authorities shall be advised of any decisions and resulting changes pertaining to the Emergency Organization status.

3.7.1 Recovery Actions:

Re-entry of the plant, decontamination, repair, and return to operation will be controlled by a general implementing procedure which provides for development of a flexible plan of actions and specifies particular evaluation and planning activities. A recovery organization to provide long term augmentation of the emergency organization has been established. A procedure to alert these people and put the EOF into operation is part of the station implementing procedures.

The Termination and Recovery procedure details the establishment of a Recovery organization.

The Corporate Emergency Director will notify all response organizations that recovery operations are underway.

In the recovery phase, all actions will be carefully planned by station supervisory personnel in conjunction with the Recovery Team, the Technical Support Center personnel and the station senior management. Planning for recovery will include evaluation of survey data, review of exposures incurred, projection of manpower and

FitzPatrick Annex Constellation October 2023 JF 3-7 EP-AA-1014 (Revision 5) equipment needs, and re-entry offsite monitoring team activities. Actions prescribed upon re-entry include a comprehensive survey of the plant to define radiological problem areas. Based on survey results, high radiation areas and areas of contamination will be isolated and posted and, if possible, portable shielding will be used, as appropriate.

Upon evaluation of plant conditions, further activities for making necessary repairs, decontamination and restoration to normal operations will be outlined by station senior management in accordance with standard Radiation Protection practices.

Personnel radiation exposure during the recovery stage of the incident shall be closely controlled and documented. Individual exposures shall be in accordance with 10CFR20 limits.

Corporate management and Emergency Response Organization personnel will augment the plant staff in long-term recovery operations.

a) Corporate groups such as Business Continuity may provide logistical support using corporate emergency plans, protocols and procedures.

b) Technical support may be provided by the Engineering Services Department and consultants under the direction of the Manager, Nuclear Services.

c) The station Vice President will provide management level interface with government authorities. He or she will be assisted by the Corporate Communications group.

d) Communicating with the President of the United States and the Governor of New York State is the responsibility of Company senior management.

3.8 Figures, Forms, and Attachments Figure 3.1 Recommended Protective Actions for the General Population and Emergency Workers Figure 3.2 Maximum Estimated Doses Resulting from Design Basis Accidents

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FIGURE 3-1 RECOMMENDED PROTECTIVE ACTIONS FOR THE GENERAL POPULATION AND EMERGENCY WORKERS PAGs for the Early Phase of a Nuclear Incident Protective Action PAG (projected dose)

Comments Evacuation (or shelteringa) 1 - 5 remb Evacuation (or, for some situations, shelteringa) should normally be initiated at 1 rem.

Administration of stable iodine 5 remc Per local and state upon declaration of a GE a Sheltering may be the preferred protective action when it will provide protection equal to or greater than evacuation, based on consideration of factors such as source term characteristics, and temporal or other site* specific conditions.

b The sum of the effective dose equivalent resulting from exposure to external sources and the committed effective dose equivalent incurred from all significant inhalation pathways during the early phase. Committed dose equivalents to the thyroid and to the skin may be 5 and 50 times larger, respectively.

Reference:

Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, EPA-400-R-02-001, May 1992.

c committed dose equivalent to the child thyroid from radioiodine, per "Implementation of the Use of Potassium Iodide (KI) as a Protective Agent for the Public", Rev. 1 January 2005.

Guidance on Dose Limits for Workers Performing Emergency Services Dose Limita (rem)

Activity Condition 5

All 10 Protecting valuable property Lower dose not practicable 25 Lifesaving or protection of large populations Lower dose not practicable

>25 Lifesaving or protection of large populations Only on a volunteer basis to persons fully aware of the risks involved aSum of external effective dose equivalent and committed effective dose equivalent to non-pregnant adults from exposure and intake during an emergency situation. Workers performing services during emergencies should limit dose to the lens of the eye to three times the listed value and doses to any other organ (including skin and body extremities) to ten times the listed value. These limits apply to all doses from an incident, except those received in unrestricted areas as members of the public during the intermediate phase of the incident.

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FIGURE 3-2 MAXIMUM ESTIMATED DOSES RESULTING FROM DESIGN BASIS ACCIDENTS Maximum Estimated Dose (rem)

Whole Thyroid Postulated Accident 0-2 Hours 3000 Feet 0-30 Days 3.4 Miles 0-2 Hours 3000 Feet 0-30 Days 3.4 Miles Control Rod Drop 0.0142 0.0049 0.201 0.137 Refueling 2.40 TEDE 0.270 TEDE Main Steam Line Break 0.0906 0.0111 7.14 0.799 Loss of Coolant 2.34 1.89 62.2 68.7 Estimated doses taken from Chapter 14 of the JAFNPP FSAR

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Section 4: Emergency Measures Emergency measures are actions taken to ensure that an emergency situation is assessed and that proper corrective and/or protective actions are taken. These actions include activation of the appropriate components of the emergency organizations, both onsite and offsite; assessment of plant systems status and radiological conditions; mitigative actions to ameliorate or terminate an emergency situation; protective actions to minimize the consequences of the emergency to plant personnel and to the general public in the plant environs; decontamination and medical treatment for plant personnel; and other supporting actions such as timely and accurate emergency news dissemination to the public media.

Emergency actions are initiated primarily in response to alarmed instrumentation but may be initiated through notification to the Control Room by the first individual at the JAFNPP to become aware of an apparent emergency situation.

The occurrence of an off-normal event will initiate the classification of that event via an established procedure into one of the four emergency classes. Once an emergency is classified and declared, the implementation of the JAFNPP Emergency Plan Implementing Procedures will begin.

This plan and procedures provide for the implementation of measures to respond to the emerge cy. The following sections provide a description of the emergency measures.

4.1 Activation of the Emergency Organization Prior to an emergency being declared, the normal plant operating organization is in place. The initial classification of an off-normal event occurs in the Control Room and is performed by the Shift Manager (see Section 4). Upon the classification and declaration of an emergency the Shift Manager assumes the role of Emergency Director and retains that role until the CED and SED can assume control. It is the primary responsibility of the Shift Manager, however, to act in accordance with any Emergency Operating Procedures (EOPs), and Abnormal Operating Procedures (AOPs) to verify the proper operation of engineered safety features prior to implementation of the emergency plan procedures.

The Emergency Director will, upon classification of the emergency, immediately initiate the appropriate series EP-AA-112 procedure. This procedure directs the initiation of notification and activation of the emergency organization and for the initiation of mitigative and protective actions appropriate for the emergency class.

4.1.1 Notification and Activation of the Onsite Emergency Organization The onsite emergency organization is activated by personnel notification or when the station alarm is sounded, and the emergency is announced over the public address system.

Initially, the emergency response organization will consist of the normal operating shift personnel who will function as the emergency team members. The normal operating staff will be augmented, as needed, by plant personnel and corporate headquarters personnel. Those personnel onsite will respond when the station alarm

FitzPatrick Annex Constellation October 2023 JF 4-2 EP-AA-1014 (Revision 5) is sounded, and the announcement is made or when individuals are notified by another means. Personnel not onsite during off-hours operations or located at the corporate headquarters will be notified. A designated on-staff plant employee shall perform notifications. The details of notifying all emergency operations personnel during normal and off-hours are contained in EP-AA-112-100-F-57, ERONS NOTIFICATION DETAILS.

4.1.2 Notification and Activation of the Offsite Emergency Organization The offsite organization will be notified as soon as possible after the declaration of an emergency. Offsite notifications will be made in accordance with the Emergency Notifications procedure. Notifications will be made to:

A. NRC B. State of New York, Nine Mile Point Nuclear Station and Oswego County C. Company headquarters The contents of the initial notification message are in a pre-arranged notification form that will be used by both the transmitting and receiving parties. The initial messages will transmit key information. Date, time, location of emergency, person reporting information and telephone number, the emergency class, whether a release is occurring, the potentially affected area (s), the protective actions recommended, and meteorological conditions are included on the form. No verification of message authenticity is required when the notification will be transmitted via a dedicated telephone line. The content of the notification message will be verified with the State of New York. It is the responsibility of the State to verify message content with other State and Local government agencies. The notification will be repeated for each change in emergency classification or on a periodic basis in accordance with the Notifications Procedure.

Once the initial notification is made, additional information will be transmitted from JAFNPP to offsite agencies. These follow-up messages will consist of the following information in addition to that transmitted during the initial notification (if known and appropriate):

A. General Release Information B. Atmospheric Release Information C. Waterborne Release or Surface Spill Information D. Dose/Dose Rate Calculations E. Field Measurements of Dose Rates or Surface Contamination The information will be transmitted and received in accordance with the Notifications Procedure.

FitzPatrick Annex Constellation October 2023 JF 4-3 EP-AA-1014 (Revision 5)

Additional follow-up information regarding plant parameters will be transmitted, if known and appropriate, in accordance with the Notifications Procedure. The following plant system information may be transmitted:

A. Primary coolant system information B. Safety coolant system information.

C. Radiation monitoring system information In addition to those organizations notified, other offsite agencies may be contacted as indicated in the Notifications Procedure. The Emergency Director will ensure that offsite emergency support groups are contacted to request the type and level of assistance, which may be necessary to deal with the emergency condition. The following organizations may be contacted for assistance, either through direct telephone contact or by message relay through the Oswego County Sheriff's Department or Oswego E-911 Center:

A. Local fire departments through agreement with the Oswego County Fire Coordinator B. Oswego Hospital C. University Hospital D. Oswego County Sheriff's Department E. Nine Mile Point Nuclear Station F. United States Department of Energy G. R.E. Ginna Nuclear Power Plant Letters of agreement are maintained with each of the offsite agencies, which specify the commitment of that organization to provide assistance to JAFNPP. A listing of Letters of Agreement is contained in Appendix C. The offsite agencies contacted will activate their organizations to the level required in accordance with their plans and procedures. See Appendix J of this Plan for a list of supporting documents.

In addition to the services provided by the above* mentioned organizations, support may be provided by other private organizations.

FitzPatrick Annex Constellation October 2023 JF 4-4 EP-AA-1014 (Revision 5) 4.2 Assessment Actions Provisions throughout are made for assessment and continuing reassessment the course of an emergency to ensure the effective coordination, direction and upgrading of emergency activities in a timely manner. The assessment actions are described in detail in the Emergency Plan Implementing Procedures. The assessment functions and the general methodology and techniques utilized are identified in this section.

Initially, the Shift Manager will assume the responsibility for the emergency response direction and coordination and will take charge of all assessment activities until these functions are turned over to the CED and SED. The Radiation Protection Organization (TSC) will direct on-site survey teams. The Radiation Protection Organization (EOF) will direct off-site survey teams and the dose assessment activities of JAFNPP, once responsibility is turned over and accepted.

4.2.1 Assessment Actions and General Discussion Unusual Event Continuous assessment of the status of plant systems radiological conditions is provided by plant instrumentation and is supplemented by routine surveillance function.

The occurrence of an Unusual Event will be recognized by instrument indications and / or alarms, surveillance results or other observations of an off-normal condition by an individual at the plant.

Many events within this classification involve exceeding the Limiting Conditions of Operation cases. Assessment and mitigative actions are described in detail in operating procedures. Supplementary assessment actions are described, where appropriate, in the Emergency Plan Implementing Procedures.

For events which require dispatching of emergency teams, such as a fire or damage control, the initial and continuing assessment will be performed by the team leader.

Through training and experience the team leader will be able to evaluate the condition, implement proper mitigative action and escalate the response as necessary.

Offsite dose projections will be performed if the event involves radiological effluents exceeding the Technical Specification limits or if such releases are projected. These dose projections are based on the rate and estimated duration of the releases and current meteorological parameters. The projections will be repeated throughout the duration of the emergency to reflect any significant changes. Methods for performing rapid dose projections including the use of computerized meteorological/dose assessment models are described in the Emergency Plan Implementing Procedures.

FitzPatrick Annex Constellation October 2023 JF 4-5 EP-AA-1014 (Revision 5)

Alert Assessment actions for an Alert include an upgrading of the functions performed for an Unusual Event as appropriate for the condition. Examples are:

Increased surveillance of in-plant instrumentation

Additional assistance from off-duty personnel and/or offsite support groups.

Possible radiological monitoring of offsite areas and increased dose projection activities.

Site Area Emergency Assessment actions for a Site Area Emergency will be in accordance failure of release of material with the increased probability of a major failure of plant safety functions and the potential release of significant quantities of radioactive Examples are:

Increased surveillance of instrumentation, which may provide information on the status of the core and reactor coolant system.

Increased offsite monitoring efforts including direct radiation measurements, sampling and analysis of air and other environmental media.

Dose projection results correlated with offsite monitoring data.

Coordinated offsite dose assessment activities with other emergency response organizations.

Increased reactor coolant sampling and analysis frequency.

General Emergency The emphasis of assessment actions for a General Emergency will be based on the likelihood of substantial core degradation, potential loss of containment integrity, and the release of large quantities of radioactive material. Surveillance of instrumentation relative to the core condition, reactor coolant system activity, containment pressure and radiation level and radioactive effluents will be increased. Dose projection and offsite monitoring efforts will be further intensified, and on-going communications will be maintained with the Oswego County Emergency Operations Center (OCEOC) and New York State Emergency Operations Center (NYSEOC) to ensure that offsite assessments are based on the best available information.

Specifically, post-accident assessment capability will include:

Post-accident sampling analysis of reactor coolant and containment atmosphere.

In-plant iodine instrumentation.

Plots showing containment radiation versus time.

Determination of the degree of reactor core damage.

FitzPatrick Annex Constellation October 2023 JF 4-6 EP-AA-1014 (Revision 5) 4.2.2 Field Radiological Assessment Field radiological data will be collected by onsite and offsite survey teams. There will be at least one onsite and one offsite survey team, when the ERO is fully staffed and radiological conditions warrant it. Each team should be comprised of at least two individuals. (In instances of a fast-breaking event, only a single technician may be available). The teams will be deployed for any emergencies, which involve actual releases of radioactive materials and at the discretion of the Emergency Director.

Survey teams will be formed following the request by the Emergency Director or his designee by direct communication or over the PA system. It is expected that the teams can be deployed in about 30 minutes during normal working hours and in about es during other hours. The survey teams will use emergency vehicles (or personal vehicles, if needed) for transportation and will maintain Cellular phone or Satellite phone contact with the Emergency Director or his designee while deployed.

An onsite survey kit and two offsite survey kits are maintained for emergency use by survey teams. Each kit contains portable instrumentation for direct radiation surveys, contamination surveys, and for collecting and analyzing airborne samples for gross and iodine radioactivity.

Rapid assessment of any radiological hazards resulting from the gaseous pathway will be made in the field by direct radiation surveys and by collecting airborne samples and then analyzing these samples for gross radioactivity and iodine radioactivity.

These data will be communicated to the Emergency Director or his designee as the information is obtained.

Rapid field assessment of liquid samples is not considered to be essential because the nearest drinking water supply is far enough away to provide ample time for warning the appropriate state and local authorities in the event protective measures are required. When field liquid samples are required, they will be taken and transported to an Environmental Lab for assessment.

4.2.2.1 In-plant Surveys In-plant survey teams will be dispatched during an emergency if annunciators, alarms, or other instrumentation indicate the possible or actual release of radioactivity to in-plant locations. The Shift Emergency Director, Station Emergency Director, or Radiation Protection Manager, or designee will notify, brief, and dispatch the survey teams. All dispatching and directing of survey teams and the performance of surveys will be accordance with the TSC Radiation Protection Manager Checklist.

The in-plant survey teams will be composed of a team leader and team member. The teams will report to and be dispatched from the Operational Support Center. Emergency survey kits are maintained for use by the in-plant survey teams.

These kits contain portable instrumentation for direct radiation surveys, contamination surveys,

FitzPatrick Annex Constellation October 2023 JF 4-7 EP-AA-1014 (Revision 5) the collection and analysis of airborne samples for gross and iodine radioactivity, and the collection of liquid samples.

Equipment is also provided for post-accident reactor water sampling.

For details of the specific type and quantities of equipment contained in each kit see EP inventory procedures.

4.2.2.2 Out-of-plant Surveys Out-of-plant survey teams may be dispatched if releases of radiation have occurred, or to verify that releases above technical specifications are not occurring. The Environmental Coordinator (EOF), or designee, will notify, brief, and dispatch the survey teams. The dispatching and direction of survey teams to designated locations (see Figures 4.5 and 4.8) and the performance of out-of-plant surveys will be performed in accordance with EP-AA-112-500, Emergency Environmental Monitoring.

Out-of-plant survey teams will (if possible), be composed of a team leader and team member. The teams will report to and be dispatched from the Technical Support Center or the Emergency Operations Facility. Emergency survey kits are maintained for use by the out-of-plant survey teams. JAF will share the Out-of-Plant Survey Responsibilities with the Nine Mile Point Nuclear Station. The Out-of-Plant teams are available and trained to respond to an event at either station.

The out-of-plant survey teams have the capability and equipment to collect environmental and emergency TLD/DLR (Dosimeter of Legal Record), filter media from the environmental air samplers, water, milk, soil, vegetation, and snow samples. The field teams can also take direct radiation surveys and collect and analyze in the field, airborne samples for gross and iodine radioactivity. For details of the specific type and amount of equipment contained in the out-of-plant survey kits see the EP Inventory Implementing Procedures.

The field assessment of airborne samples will be reported back to the EOF where the Dose Assessment Coordinator or RPM will use the data for dose assessment. Other environmental media will be transported to an Environmental Lab for analysis.

One type of radiological data which the onsite and offsite survey teams may be collecting to aid in dose assessment is airborne radioiodine concentrations. Monitoring is accomplished by the use of portable air sampling pumps equipped with a particulate filter and silver zeolite cartridge. The particulate filter and silver zeolite cartridge can be analyzed in a low background area using a count rate meter for determination of total radioiodine. The silver zeolite cartridges have an iodine retention in excess of 99% while retaining only traces of noble

FitzPatrick Annex Constellation October 2023 JF 4-8 EP-AA-1014 (Revision 5) gases. Particulates are removed using a pre-filter. Gamma spectrometry at an Environmental Lab will be used for analysis as time permits but is not necessarily required to make a rapid estimation of airborne radioiodine.

The count rates obtained from the filter and silver zeolite cartridges are multiplied by correction factors to determine the concentrations of particulates and airborne radioiodine.

With the use of silver zeolite cartridges, the interference from the presence of noble gases is not expected to impair the capability to detect less than lE-7 µCi/cc of radioiodine. Cartridges and filters also can be analyzed using gamma spectrometry in either the JAFNPP counting laboratory, an environmental laboratory, or the adjacent NMPNPS, Unit 1 laboratory.

4.2.2 Dose Assessment Methods and Techniques Three methods are available at JAFNPP to assess offsite doses following an accident. The first method utilizes EP-AA-112-201, On-Shift Dose Assessment, for Control Room Dose Assessment. The second method utilizes EP-AA-112-200, Dose Assessment, in conjunction with the Unified RASCAL Interface (URI) computer application. The third method uses measured activity in environmental samples collected by the Emergency Radiological Survey Teams. All of these methods estimate external doses from noble gases and thyroid doses from radioiodine. A summary of each method is described in the following paragraphs.

The computer applications used to provide dose calculations are evaluated against the EPA-400 plume exposure Protective Action Guides (PAGs) applicable for the early phase of an accident. These evaluations place an emphasis on determining the necessity for offsite protective action recommendations. Dose assessment actions will be performed in the following sequence:

4.2.3.1 The Dose Assessment and the Emergency Classification and Protective Action Recommendations Procedures will be utilized from the onset of a release to approximately 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months post-accident: Shift personnel will rely on a simplified computerized dose model (URI in "rapid mode")to assist them in developing offsite dose projections using real time data from effluent monitors and site meteorology.

4.2.3.2 The Dose Assessment and the Emergency Classification and Protective Action Recommendations Procedures will be utilized from approximately 1-hour post-accident to event termination. Estimates of off-site doses based on more sophisticated techniques are provided. Dedicated ERO personnel will analyze the offsite consequences of a release using the full capabilities of the URI model. These additional methods are able to analyze more offsite conditions than the simplified quick method, as well account for more specific source term considerations.

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The URI program utilizes the following features:

a. The system provides results of the sum of the effective dose equivalent from external radiation (both the plume and ground deposition) and the committed effective dose equivalent from inhalation of radioisotopes (this total is referred to as the TEDE),

committed dose equivalent to the thyroid (CDE-thyroid), as well as deposition rates and cumulative deposition at the ground.

b. URI uses both meteorological and source term data screens with editing capabilities, allowing both easy data-entry and the ability to review, edit, or update data entered for other time steps. User "help" functions are available on command, and upon entry of invalid data.

c. The URI meteorological data entry screen also allows for direct entry of data from the NMP-JAF Meteorological Monitoring System (MMS).

d. Program results for URI calculation routines include those for considering source term and plume decay, as well as the effects of wet and dry deposition of iodines and particulates.

e. The model also includes predefined Protective Action Guidelines for the plume and ingestion pathway EPZs to alert users of the program to any exceedances of pre-determined limits.

f. Multiple source term selection representing different isotopic mixtures can be entered or the default values changed to more accurately characterize an accident.

g. The URI model and JAF procedures integrate both JAF and Nine Mile Point dose assessment information.

4.2.3.2 Dose Estimates from Field Measurements The third method available to assess dose rate is based on activity measured in environmental media. Three techniques will be used to calculate doses from gross radioactivity measurements: Direct gamma dose by TLD/DLR, in mrem; direct beta-gamma dose rate by portable survey instruments, in mrem/hr; and dose from gross measurements following radioiodine sampling. The first two techniques yield direct dose information. The third technique for dose rate determinations, involve environmental sampling by the survey teams with later evaluation using the Dose Assessment Procedure to determine offsite doses. Dose rates will be measured using portable survey instruments. Selective sampling for radioiodine will be performed using a silver zeolite cartridge preceded by a particulate filter. Silver zeolite cartridges are iodine specific because they permit approximately 99% of the noble gases to pass through.

The particulate filters and the silver zeolite cartridges are analyzed in the field obtaining a gross count rate using a portable count rate meter.

Calculations of dose from the silver zeolite cartridge are based on the

FitzPatrick Annex Constellation October 2023 JF 4-10 EP-AA-1014 (Revision 5) assumption that any measured activity is totally attributable to I-131.

Gross measurements of particulate filters and silver zeolite cartridges will be performed in the field.

Because this method of analysis is less accurate than laboratory analysis, protective actions will not be taken based on these data unless protective actions are deemed necessary and laboratory analytical results are not available.

If it is determined that a release of radioactive liquid to Lake Ontario has occurred, the projected TEDE and CDE skin doses received while boating or swimming on the lake will be determined in accordance with site processes.

Survey teams will also collect environmental media such as milk, human food products, water, snow, and soil which will be analyzed in an environmental laboratory for radioiodine (I-131, 133) by gamma spectrometry. These results, along with the gross radioiodine measurements mentioned above, will be used in determining CDE thyroid dose estimates in accordance with the Dose Assessment Procedure and environmental surveillance procedures.

Dose rate and dose information will be provided to the Dose Assessment Coordinator (or Radiation Protection Manager) for use in determining recommended protective actions.

4.3 Mitigative actions Detailed operating procedures, emergency operating procedures, and Severe Accident Operating Guidelines (SAOGs) are utilized by the plant operating personnel to assist them in responding to potential or actual emergency events.

These procedures describe the mitigative actions necessary to place the plant in a safe condition. Long term mitigative actions will be taken as part of the Recovery phase (Section 3.7)

In addition, the Operational Support Center will be activated and serve during the emergency as the location for the assembly and dispatch of teams to respond to plant conditions. Specifically, damage control teams, fire brigades, and search and rescue teams will be directed in accordance with emergency implementing procedures. The appropriate Emergency Director will direct all mitigative actions through the appropriate emergency coordinators.

Some essential mitigative actions may involve the risk of higher than normal radiation exposure to emergency response personnel. Such actions could involve protecting valuable property, protection of large populations, or lifesaving actions. Figure 4.1 specifies the limits for such emergency radiation exposure and other relevant criteria to be considered.

FitzPatrick Annex Constellation October 2023 JF 4-11 EP-AA-1014 (Revision 5) 4.4 Protective Actions Protective actions are measures which are implemented to prevent or mitigate consequences to individuals during or after a radiological emergency. Protective actions within the JAFNPP site boundary are primarily the responsibility of the Shift Manager or SED but may include assistance by offsite organizations. Protective actions outside the JAFNPP site boundary are primarily the responsibility of State and local emergency organizations but may include coordination of activities and dissemination of appropriate data with JAFNPP, and recommendations by the JAFNPP Corporate Emergency Director.

4.4.1 Onsite Protective Actions The primary protective measure for onsite personnel in an emergency is prompt evacuation from areas which may be affected by radiation, concentrations of airborne radioactivity that exceeds normal limits for specific area or areas and cannot be readily controlled, or other hazardous conditions.

All personnel (including employees not having emergency assignments, visitors, and contractor and construction personnel) will be notified of an emergency situation by the sounding of the station alarm and an announcement over the public address system and by Security for the Wellness Center, etc.

A range of protective actions to protect onsite personnel during hostile action is provided to ensure the continued ability to safely shut down the reactor and perform the functions of the emergency plan.

4.4.1.1 Protected Area Assembly A Protected Area Assembly may be ordered by the Shift Manager or SED for all of the protected area based on initiating conditions such as; high radiation levels, fire, toxic gases, etc. Actions will be taken in accordance with the Personnel Protective Actions procedure.

When a Protected Area Assembly is ordered, personnel will be instructed to proceed to the nearest primary assembly area via a route that bypasses the hazardous area.

Once at the primary assembly areas, accountability will be conducted. The Shift Manager or SED will then decide whether to implement a Site Evacuation, order an early dismissal, or to allow personnel to return to their normal work stations.

4.4.1.2 Site Evacuation

FitzPatrick Annex Constellation October 2023 JF 4-12 EP-AA-1014 (Revision 5)

A Site Evacuation involves the movement of personnel from the site to a remote assembly area offsite or to their homes.

A site evacuation may be ordered by the Shift Manager or SED based on severe abnormal conditions such as high radiation levels, safety hazards, or declaration of a General Emergency. Initiating conditions and the implementation of a Site Evacuation are described in detail in the Personnel Protective Actions procedure.

When a Site Evacuation is ordered by the sounding of the evacuation alarm, all personnel without emergency assignments will proceed offsite to the remote assembly area or to their homes using their own vehicles.

A Staging/Muster area and an Alternative TSC and Alternative OSC are available if the site is under threat of or experiencing hostile action.

Augmented emergency response staff can be staged at these locations in a manner that provides rapid response to mitigate site damage as soon as the site is accessible, as well as continuity of TSC and OSC functions.

The remote assembly area is located at the Oswego County Airport on County Route 176 adjacent to the EOF and JIC in the Town of Volney. Should offsite radiological considerations exist, the Shift Manager or Station emergency director will direct the evacuating personnel to take alternate routes or designate an alternate remote assembly area, if necessary.

A Site Evacuation may be ordered with or without a Protected Area Assembly previously being ordered. If a Protected Area Assembly was ordered, accountability will have been accomplished previously. If no Protected Area Assembly was ordered, accountability will be accomplished when personnel exit the plant.

To minimize the spread of contamination, the Shift Manager or SED Manager will direct a team to evaluate contamination on cars and decontaminate them by onsite washing, if time permits. Personnel will be monitored and decontaminated at the remote assembly area by a radiation survey team dispatched from the plant if necessary.

4.4.1.3 Personnel Accountability The Shift Manager or SED will inform Security and direct them to begin personnel accountability. An accountability

FitzPatrick Annex Constellation October 2023 JF 4-13 EP-AA-1014 (Revision 5) supervisor is designated and is responsible for the implementation of personnel accountability and the reporting of results. All actions will be taken in accordance with the Personnel Protective Actions procedure.

Accountability compares the name and number of persons in the primary assembly areas with the name and number of persons badged into the protected area. The results of this comparison and any discrepancies are reported to the Shift Manager or SED.

Following any unsuccessful attempts to locate missing personnel through supervisors, co-workers, and PA announcements, the Shift Manager or SED will be notified and will initiate search and rescue actions.

4.4.1.4 Other Onsite Protective Actions

a. Contamination Control The JAFNPP Radiation Protection Department Procedures and Programs contain provisions governing the control of contamination including access control, use of protective clothing, contamination monitoring, and the release of potentially contaminated items from Radiologically Controlled Areas. The guidelines of this manual shall apply to contamination control during emergency conditions.

b. Food and water in Plant Drinking water at the JAFNPP is provided by the City of Oswego and distributed by the domestic water system, which is a closed system. As a result of this configuration, contamination of the drinking water is unlikely.

With the exception of food brought to the site by Plant personnel, or prepared in the cafeteria, all other food supplied to the site arrives sealed for vending machine sale.

These machines and the cafeteria are located in non-radiologically controlled areas. If these areas become contaminated, they will be considered as radiologically controlled areas, and eating will be prohibited as is normally the case for radiologically controlled areas. Normal radiologically controlled areas access controls will prevent the removal of contaminated food from these radiologically controlled areas and possible ingestion by unwary individuals.

FitzPatrick Annex Constellation October 2023 JF 4-14 EP-AA-1014 (Revision 5)

c. Exposure Control The exposure of Plant personnel during emergency operations shall be maintained as low as reasonably achievable, and should be maintained less than the administrative guides established in JAFNPP RP Procedures and Programs and/or less than the Federal radiation exposure standards established in 10 CFR 20. In order to accomplish this objective, administrative means used during normal operations to minimize personnel exposure, such as Radiation Work Permits, Authorization to Exceed Radiation Exposure Guides, and ALARA measures should remain in force to the extent consistent with timely implementation of emergency measures.

The Personnel Protective Actions Procedure shall be utilized to provide guidance where normal operations exposure control procedures are not sufficient.

Dosimetry equipment in the form of TLDs/DLRs, direct reading dosimeters and electronic dosimeters are provided at the plant, and such dosimetry will continue to be used during emergency situations.

Personnel will be available 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day during an emergency to issue and/or process dosimetry devices.

JAFNPP RP Procedures and Programs provide guidelines and procedures for issuing, using, and reading/processing dosimetry devices and provisions for exposure record keeping. During an emergency, the processing frequency will be based upon the exposure rates and/or the exposures received by emergency personnel.

Exposure control shall include accelerated or additional bioassays in the event there are individuals who are suspected of being exposed to elevated levels of airborne activity as a result of the emergency.

This bioassay consists primarily of whole body counts. This is supplemented by urinalysis when predetermined screening levels, or predetermined airborne activity exposure levels, are exceeded or suspected of being exceeded (with provisions for follow-up monitoring, medical treatment, and incident reporting).

Exposure control may also involve administration of radioprotective drugs in accordance with the Personnel Protective Actions Procedure.

FitzPatrick Annex Constellation October 2023 JF 4-15 EP-AA-1014 (Revision 5)

d. Respiratory Protection The JAFNPP RP Procedures and Programs contain provisions covering the use of respiratory protection equipment and the administration of the JAFNPP Respiratory Protection program. The provisions of this program shall apply to all usage of respiratory protection equipment during emergencies.

4.4.2 Offsite Protective Actions If an emergency exists at JAFNPP that involves the actual or potential release of airborne or waterborne radiation, the RPM or designee, will evaluate the doses projected to occur in the offsite area as described in section 4.2.3. Based on the projected dose, the RPM, will evaluate the need for protective actions for the public using the Emergency Classification and Protective Action Recommendations procedure. The projected doses will be compared to the EPA Protective Action Guides Figure 4-1 and a protective action recommended to the Corporate Emergency Director. The results of this evaluation and the recommended protective action information will be transmitted to the State of New York and Oswego County by the Corporate Emergency Director, or

designee, via the dedicated communication

system, or alternate communication method.

NOTE:

If a General Emergency has been declared, protective action recommendations will be based on the flowcharts contained in the Emergency Classification and Protective Action Recommendations Procedure. However, responsible offsite officials must decide the feasibility of implementing the protective actions at the time of the accident.

The responsibility for actions to protect offsite individuals rests with the State of New York Department of Health, as described in the New York State Radiological Emergency Preparedness Plan.

The Chairman of the Oswego County Legislature, possibly assisted by the Commissioner, State Department of Health is responsible for implementation of that plan and the ordering of actions to protect the public.

Oswego County and NYSDOH is responsible for evaluating information obtained from JAFNPP and/or other sources and recommending appropriate offsite protective actions to Oswego County. Such recommendations, based on all available data, local constraints and other consideration may include:

Shelter for affected populations.

Evacuation within designated area(s).

Control of drinking water, milk, and agricultural products.

FitzPatrick Annex Constellation October 2023 JF 4-16 EP-AA-1014 (Revision 5)

Since the 10-mile Emergency Planning Zone is located entirely in Oswego County (See Figure 1-2), the principal offsite local coordinating agency for providing response to radiological emergencies in the vicinity of the JAFNPP is the Oswego County Emergency Management Office. Upon notification by NYSDOH or by the JAFNPP SM/ED or CED of a situation which may require protective actions for offsite populations, the Oswego County Emergency Management Office will initiate appropriate actions, including notification (see Figure 4.7) and provision of prompt instructions to the people within the plume exposure EPZ, considering recommendations from the notifying party, and within the guidelines of the Oswego County Radiological Emergency Plan.

In order to facilitate the planning and implementation of protective actions, the 10-mile Emergency Planning Zone is further subdivided in Emergency Response Planning Areas (ERPAs), Figure 4-3. All recommendations from JAFNPP to the State and from the State to the County will be in terms of ERPAs. The Public Information Program, Appendix H, will ensure that the public is aware of the proper response to an emergency or protective action order.

4.4.2.1 Sheltering Sheltering may be ordered for the population within the 10-mile EPZ.

Sheltering involves the population going or remaining inside of their homes or place of business, to wait further information and instructions.

Sheltering is particularly useful to assure that a population is positioned so that if the need arises, communication with the population can be carried out expeditiously.

4.4.2.2 Evacuation Evacuation may be ordered for all or part of the population in the affected ERPAs.

The Oswego County Radiological Emergency Preparedness Plan contains a detailed evacuation plan, which includes specific county agency operating procedures and evacuation route maps (refer to Figures 4-4 and 4-9), as well as special facilities throughout the ten-mile EPZ (see Figure 4-6). In addition, a reception center and congregate care centers are designated in the Onondaga County Radiological Emergency Response Host Plan.

FitzPatrick Annex Constellation October 2023 JF 4-17 EP-AA-1014 (Revision 5) 4.4.2.3 Thyroid Prophylaxis Federal Guidance from the NRC and FDA has prompted New York State and Oswego County to include the prophylactic use of potassium iodide (KI) as an additional public protective action.

Implementation of this measure is in accordance with the NYS and Oswego County Plans.

4.4.2.4 Food, Water, and Milk Control Within the Ingestion Pathway Emergency Planning zone (approximate 50-mile radius), the State Commissioner of Health may order controls to minimize radiation doses to the public through ingestion of contaminated food, water and milk. When requested, JAFNPP will assist with radiological sampling of environmental media and the results reported to the NYSDOH.

In addition, other sources of sampling information will be used to evaluate the need for controls.

Ingestion Pathway protective actions can include the quarantine or destruction of contaminated water and foodstuffs and the substitution of uncontaminated supplies.

4.5 Aid to Affected Personnel Procedures are established which provide for the control of radiation exposure including emergency exposure, personnel contamination, and for assistance to injured personnel, including situations involving complications due to the presence of radiation or radioactive contamination.

4.5.1 Radiation Exposure Control The JAFNPP has an onsite dosimetry system. The system consists of DLRs, and/or direct-reading dosimeters or electronic dosimeters. A limited number of TLDs/DLRs and direct reading dosimeters are also available in emergency kits.

During an emergency, personnel are available 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day to issue and/or process dosimetry devices and to document and maintain the results.

Exposures will be controlled based on the guidance and recommendations contained in the Personnel Protective Actions Procedure. This procedure provides for expeditious decisions with consideration given for a known and reasonable balance of associated risks.

Reasonable measures will be taken to limit the radiation exposure of emergency personnel who provide rescue, first aid, decontamination and ambulance or medical treatment services to within applicable exposure limits specified in 10 CFR 20 unless higher exposures are deemed necessary by the Emergency Director or appropriate offsite authority. Figure 4-1 summarizes the emergency and lifesaving actions such as:

FitzPatrick Annex Constellation October 2023 JF 4-18 EP-AA-1014 (Revision 5)

Removal of injured persons

Undertaking mitigative actions

Performing assessment actions

Providing first aid

Performing personnel decontamination

Providing ambulance service

Providing medical treatment services 4.5.2 Decontamination and First Aid Personnel contamination in emergency situations will be controlled to the extent feasible by the normal methods of using protective clothing and surveying for contamination following the removal of such clothing.

Personnel decontamination areas, consisting of showers and sinks, which drain to the radwaste system, are available for either routine or emergency use at the JAFNPP.

Similar facilities are available at the NMPNPS. Plant employees are instructed in the proper methods of removal of minor contamination from skin surfaces.

Decontamination efforts involving significant amounts of contamination, particularly in the vicinity of facial openings, will normally be performed under the direction of Radiation Protection personnel. Detailed criteria and methods for personnel decontamination are described in the JAFNPP RP Procedures and Programs.

At least two persons who are knowledgeable in basic first aid methods are onsite at all times. Procedure FPP-1.4, Medical Emergencies, delineates steps for handling a contaminated medical injury. First aid to injured personnel can normally be performed in conjunction with any necessary decontamination methods. However, if immediate treatment of injury is vital, that treatment shall take precedence over decontamination.

The philosophy also extends to offsite emergency assistance involving radioactive contamination. For that purpose, measures are established to ensure timely offsite medical treatment, as described in Sections 4.5.3 and 4.5.4.

4.5.3 Medical Transportation Arrangements have been made for the transportation to a medical treatment facility of personnel who may have injuries complicated with radioactive contamination or who may have been involved in a radiation incident from the JAFNPP.

Agreements from this organization to provide emergency services are listed in Appendix C. Ambulance emergency supply kits are available for use.

A communication link can be established by radio between the County dispatcher and emergency vehicles. A communication link can be established by telephone between the JAFNPP and the dispatcher.

FitzPatrick Annex Constellation October 2023 JF 4-19 EP-AA-1014 (Revision 5) 4.5.4 Medical Treatment Arrangements have been made with the Oswego Hospital for the medical treatment of patients from the JAFNPP who may have injuries complicated by radioactive contamination.

Similar arrangements have been made with the University Hospital for medical treatment of contamination injuries and significant overexposure to radiation. Both facilities have developed detailed procedures for handling radioactively contaminated patients from the JAFNPP.

A listing of Letters of Agreement is contained in Appendix C.

A communication link can be established by telephone between the JAFNPP and any of these medical facilities, if necessary.

Medical treatment facilities and onsite personnel may also contact a radiation management expert who is contracted to provide radiological treatment advice upon request. This service is available to medical personnel 24-hours per day year-round. This contracted letter of agreement is contained in Appendix C.

4.6 Figures, Forms, and Attachments Figure 4-1 Emergency Exposure Criteria Figure 4-2 Ten-Mile EPZ Map Figure 4-3 2010 Population Estimates ERPAs Figure 4-4 Bus Routes and Pickup Point Map Figure 4-5 Offsite Survey Locations Figure 4-6 Special Facilities Figure 4-7 Siren Locations Figure 4-8 Offsite Environmental Stations and TLD Locations Figure 4-9 Primary Evacuation Routes

FitzPatrick Annex Constellation October 2023 JF 4-20 EP-AA-1014 (Revision 5)

FIGURE 4-1 Emergency Exposure Criteria Planned exposure to the whole body and/or specific organs shall not exceed the following recommendations of the Environmental Protection Aqencv in EPA-400-R 001 Guidance on Dose Limits for Workers Performing Emergency Services Dose Limita TEDE (rem)

Activity 5

All activities during the emergency 10 Protecting valuable property. Lower dose not practicable.

25 Lifesaving or protection of large populations. Lower dose not practicable.

>25 Lifesaving or protection of large populations, only if individual receiving exposure is a volunteer, and fully aware of risks involved a Workers performing services during emergencies should limit dose to the lens of the eye to three times the listed value and doses to any other organ (including skin and body extremities) to ten times the listed value. These limits apply to all doses from an incident, except those received in unrestricted areas as members of the public during the intermediate phase of the incident.

Additional General Criteria All reasonable means for keeping personnel emergency exposures as low as reasonably achievable and within 10 CFR 20 limits shall be expended before exposure exceeding 10 CFR 20 limits are permitted.

All reasonable measures shall be taken to minimize skin contamination and the uptake of radioactive material.

All personnel performing emergency activities involving exposures, which may or will exceed 10 CFR 20 limits, shall be volunteers and shall be briefed on potential exposure consequences prior to receiving such exposures.

Women of childbearing age shall not be permitted to receive emergency exposures, which exceed 10 CPR 20 limits.

Retrospective exposures shall be evaluated on an individual case basis.

FitzPatrick Annex Constellation October 2023 JF 4-21 EP-AA-1014 (Revision 5)

FIGURE 4-2 MAP NUMBER 1 TEN MILE EMERGENCY PLANNING ZONE (PLUME EXPOSURE PATHWAY)

This page is a large map and can be viewed in EDMS under:

Object Type - EXELON RECORD Doc Number - SECTION 6 Once EDMS Opens the List of Files The PDF Name is: Section 6, Sheet 1, 20030527, Figure 6-2 EMERGENCY MEASURES

FitzPatrick Annex Constellation October 2023 JF 4-22 EP-AA-1014 (Revision 5)

FIGURE 4-3 2010 POPULATION ESTIMATE ERPAS

FitzPatrick Annex Constellation October 2023 JF 4-23 EP-AA-1014 (Revision 5)

FIGURE 4-4 MAP NUMBER 3 BUS ROUTES AND PICKUP POINT MAP This page is a large map and can be viewed in EDMS under:

Object Type - EXELON RECORD Doc Number - SECTION 6 Once EDMS Opens the List of Files The PDF Name is: Section 6, Sheet 2, 20030176, Figure 6-4 EMERGENCY MEASURES

FitzPatrick Annex Constellation October 2023 JF 4-24 EP-AA-1014 (Revision 5)

FIGURE 4-5 MAP NUMBER 4 OFFSITE SURVEY LOCATIONS This page is a large map and can be viewed in EDMS under:

Object Type - EXELON RECORD Doc Number - SECTION 6 Once EDMS Opens the List of Files The PDF Name is: Section 6, Sheet 3, 20030176, Figure 6-5 EMERGENCY MEASURES

FitzPatrick Annex Constellation October 2023 JF 4-25 EP-AA-1014 (Revision 5)

FIGURE 4-6 MAP NUMBER 5 SPECIAL FACILITIES This page is a large map and can be viewed in EDMS under:

Object Type - EXELON RECORD Doc Number - SECTION 6 Once EDMS Opens the List of Files The PDF Name is: Section 6, Sheet 4, 20030176, Figure 6-6 EMERGENCY MEASURES

FitzPatrick Annex Constellation October 2023 JF 4-26 EP-AA-1014 (Revision 5)

FIGURE 4-7 MAP NUMBER 6 SIREN LOCATIONS This page is a large map and can be viewed in EDMS under:

Object Type - EXELON RECORD Doc Number - SECTION 6 Once EDMS Opens the List of Files The PDF Name is: Section 6, Sheet 5, 20030176, Figure 6-7 EMERGENCY MEASURES

FitzPatrick Annex Constellation October 2023 JF 4-27 EP-AA-1014 (Revision 5)

FIGURE 4-8 OFF-SITE ENVIRONMENTAL MONITORING STATION AND TLD LOCATIONS PAGE 1 OF 1 This page is a large map and can be viewed in EDMS under:

Category - GENERAL RECORDS Document Type - EMERGENCY PLANNING MAPS Document ID - SECTION 6

FitzPatrick Annex Constellation October 2023 JF 4-28 EP-AA-1014 (Revision 5)

FIGURE 4-9 MAP NUMBER 8 PRIMARY EVACUATION ROUTES This page is a large map and can be viewed in EDMS under:

Category - GENERAL RECORDS Document Type - EMERGENCY PLANNING MAPS Document ID - SECTION 6

FitzPatrick Annex Constellation October 2023 JF 5-1 EP-AA-1014 (Revision 5)

Section 5: Facilities and Equipment Identified and described in this section of the Plan are the emergency response facilities; communications systems; assessment, protective, first aid, and decontamination facilities; and equipment which is available for the Constellation response to an emergency at JAFNPP. (Facility activation may be modified by the Emergency Director if the safety of incoming personnel may be jeopardized by a security event or other event hazardous to incoming personnel).

5.1 Emergency Response Facilities The emergency response facilities are identified and described in this section.

5.1.1 Control Room The Control Room is the primary location in which plant conditions are monitored and controlled and mitigative actions are taken to mitigate emergency conditions. The room is equipped with instrumentation and controls for major plant systems. It is the facility in which initial accident assessment, emergency classification, and emergency response occurs.

Meteorological and radiological instrumentation provide data for dose calculations. Emergency communications systems for in-plant and out-of-plant communications are also provided.

Initially, the on-duty Shift Manager will assume the role of Emergency Director and the Control Room will be the primary location for assessment and coordination of corrective and protective actions for essentially all emergency conditions. The Control Room is staffed as specified in the JAFNPP Emergency Plan.

Emergency response functions which are initially conducted in the Control Room will be transferred to the Technical Support Center or the Emergency Operations Facility, as soon as it is feasible to do so, for events which constitute an Alert, Site Area Emergency or a General Emergency. This transfer of emergency response functions may also be implemented for less severe events, at the discretion of the Shift Manager.

The primary consideration is to ensure that the activities and the number of personnel involved with the emergency in and around the Control Room shall not impair the safe and orderly shutdown of the reactor or the operation of plant safety systems.

5.1.2 Technical Support Center (TSC)

Activation and the location of the TSC or OSC may be modified by the Shift Manager if the safety of incoming personnel is in question. Locations for consideration of ventilation include:

FitzPatrick Annex Constellation October 2023 JF 5-2 EP-AA-1014 (Revision 5)

1. The JAFNPP Training Building

2. The JAFNPP Technical Library

3. The Emergency Operations Facility

4. The Backup OSC.

Other locations may also be considered.

The TSC is a facility external to the Main Control Room from which plant management and technical support personnel may operate during emergency situations. It is also the facility from which technical support is provided during recovery operations. The TSC will be operational within approximately sixty minutes of the declaration of an ALERT, SITE AREA EMERGENCY, or GENERAL EMERGENCY. It may also be activated for an UNUSUAL EVENT at the discretion of the Shift Manager. The activation of the TSC is described in EP-AA-112-200, TSC Activation and Operation. The TSC is located in the old Administration Building on the second floor within a two-minute walk of the Main Control Room. The TSC is close to normal plant administrative offices which can provide additional documentation and equipment use in the TSC.

Assessment activities as well as coordination of corrective and protective actions for most emergency situations will be performed in this facility. These functions may include:

1. Providing guidance to the Control Room operating personnel.

2. Providing plant systems support for management personnel in the EOF during recovery operations.

3. Communication with other emergency response centers.

4. Providing direction to emergency coordinators.

5. Acting as the primary information source to the EOF and the NRC for plant operations.

This center provides an area outside of the Control Room in which to conduct the technical support functions necessary for the control of an emergency situation. These functions include:

1. Capability to display real-time plant status.

2. Capability to transmit plant status data.

3. Capability to communicate with the Control Room and the NRC.

4. Availability of plant systems drawings and other documents for decision making purposes.

The TSC is equipped with appropriate communications and other equipment to perform the above-mentioned functions.

5.1.3 Operations Support Center (OSC)

The OSC is located on the 272 elevation of the old Administration Building,

FitzPatrick Annex Constellation October 2023 JF 5-3 EP-AA-1014 (Revision 5) and is the staging and dispatch area for all:

1.

Maintenance and Instrument and Control technicians from which personnel will be selected and dispatched to emergency assignments.

2.

Radiation Protection and Chemistry technicians who will be dispatched to obtain in-plant radiation measurements and samples.

3.

Damage Control Teams.

4.

Search and Rescue Teams.

The OSC is located near a Health Physics checkpoint. The issuance of personnel dosimetry, as well as monitoring and decontamination of personnel, may be accomplished in the OSC. Some specialized equipment is available for use in the OSC and is listed in the inventory procedure. The Operational Support Center has communications equipment, with which to control OSC related activities, either installed or readily available.

The OSC will be activated upon the declaration of an ALERT, SITE AREA EMERGENCY, or GENERAL EMERGENCY. It may also be activated for an UNUSUAL EVENT at the discretion of the Shift Manager. Activation and operation of the OSC will be in accordance with EP-AA-112-300, OSC Activation and Operation.

5.1.4 Backup Operational Support Center (BOSC)

The BOSC is located in a work area adjacent to the JAFNPP Control Room.

If conditions warrant, and as directed by the JAFNPP Shift Manager or Station emergency director, OSC personnel shall move to and equip this facility. The BOSC is an area with same habitability design as the JAFNPP Control Room.

(The 300 ft elevation outside the Control Room and within the TSC ventilation boundary may also be used if habitability conditions warrant. This area has the same habitability design as the TSC). Additional locations may be established as directed by the Shift Manager or Station emergency director, if needed. This facility could further be used to provide a TSC work area.

5.1.5 Emergency Operation Facility (EOF)

The Emergency Operation Facility is located near the Oswego County Airport on Rt. 176. This location is outside of JAFNPP security fence and the 10 mile EPZ and is within 30 minutes ground travel time from the TSC.

The EOF will be the location where the following functions are to be performed.

1. Overall management of Constellation emergency response and recovery resources.

2. Evaluation, coordination, and communication of Constellation emergency response activities with Federal, State, and County emergency response organizations.

3. Determination/verification of the magnitude and effects of actual or

FitzPatrick Annex Constellation October 2023 JF 5-4 EP-AA-1014 (Revision 5) potential radioactive releases from JAFNPP, as initially calculated in the Control Room.

4. Receipt and coordination of field radiological survey data and sample media.

5. Making recommendations to offsite agencies regarding protective actions.

6. Initial communications with Public Information Personnel.

The EOF will be activated following the declaration of an ALERT, SITE AREA EMERGENCY or GENERAL EMERGENCY. The EOF will be activated and/or take Command and Control within approximately one hour. It may also be activated for an Unusual Event at the discretion of the Shift Manager. The activation of the EOF is described in EP-AA-112-400, Emergency Operations Facility Activation and Operation.

The Emergency Operations Facility also services for Recovery. This area has sufficient space available for personnel and equipment necessary for planning and arranging recovery activities. Systems are provided for communications with other centers.

An emergency diesel generator is available for use at the EOF.

5.1.6 Joint Information Center (JIC)

The Joint Information Center is located next to the Oswego County Airport on Co. Rt.

176 in the Town of Volney. This facility will serve as the central location for release of all information from Constellation, as well as from local and State agencies to the news media.

The JIC is equipped to accommodate the news media for large briefings and conferences. Recording capability for briefings is included. Telephones are provided for the use of reporters. Off-air radio and television monitoring and recording capability is provided to alert Constellation and other representatives to incorrect information or rumors which may be broadcast. This information will then be corrected during briefings.

Rumor control will also be provided using a group of telephones at the JIC. Responses to media telephone inquiries will be handled by additional telephones at the JIC.

The Joint Information Center will be activated at the declaration of an ALERT, a SITE AREA EMERGENCY or GENERAL EMERGENCY. It may also be activated at a lesser emergency classification at the discretion of the Shift Manager.

An emergency diesel generator is available for use at the JIC.

5.1.7 Oswego County Emergency Operations Center (OCEOC)

The Oswego County Emergency Operations Center is located in the Emergency

FitzPatrick Annex Constellation October 2023 JF 5-5 EP-AA-1014 (Revision 5)

Management Office, County Branch Building, Fulton, NY. The County Warning Point is located at the E-911 Center. Communication systems are manned 24-hours per day at this warning point. Upon activation by the Oswego County Emergency Management Office, communications, planning and coordination personnel will be available for emergency response.

A representative from JAFNPP will be dispatched to this facility to act as a liaison between the County and Constellation, when requested by County Officials.

5.1.8 State Emergency Operations Center The State Emergency Operations Center is in the substructure of the Public Security Building No. 22, State Office Building Campus, Albany, NY. State Warning Point communication systems and the New York State Emergency Management Office are also located in this center. Communications systems operate on the around-the-clock basis. Upon activation, planning and coordination personnel will be available for emergency response.

5.1.9 Staging/Muster Area A Staging/Muster Area with communication capabilities for contacting the Control Room and plant security is available to serve as a staging area for augmented emergency response staff if the site is under threat of or experiencing hostile action.

The Staging/Muster area is the Remote Assembly Area located at the Oswego County Airport in Fulton, NY, approximately 12 miles from the JAF site. The Remote Assembly Area is adjacent to both the EOF and the Alternative TSC and Alternative OSC. Augmented emergency response staff can be staged at the Remote Assembly Area in a manner that provides rapid response to mitigate site damage as soon as the site is accessible.

5.1.10 Alternative Facilities Should the primary TSC or OSC, or backup OSC not be available, an Alternative TSC (ATSC) and Alternative OSC (AOSC) are available. These two facilities are located in the EOF building and are positioned to take advantage of the EOF and Remote Assembly Area facilities which are in close proximity. The ATSC and AOSC have the following capabilities:

communication with the emergency operations facility, control room, and plant security

the capability to perform offsite notifications

emergency assessment activities damage control team planning and preparation The Alternative Facility maintains the capability for staging the TSC/OSC emergency response organization personnel in the event of a hostile action. The alternative facility has the capability for communications with the emergency operations facility, control room, and plant security and the capability for engineering assessment activities, including damage control team planning and preparation. Consistent with NRC EPFAQ No. 2013-005, the EOF will satisfy the offsite notification responsibilities for the Alternative Facility. The Alternative Facility is located at the Nine

FitzPatrick Annex Constellation October 2023 JF 5-6 EP-AA-1014 (Revision 5)

Mile/Fitzpatrick EOF on County Route 176, just outside Fulton, NY, adjacent to the Oswego County Airport.

5.2 Communications System The JAFNPP communication capabilities include multiple systems and redundancies, which ensure the performance of vital functions in transmitting and receiving information throughout the course of an emergency. Figure 5-1 shows the communication systems available and the primary communication links. As can be seen on the diagram, multiple communication modes and paths are available for emergency communications.

Following is a list of available communications systems along with a brief description of each:

5.2.1 Page/Party System (In-Plant)

- Control Room

- Technical Support Center

- Operational Support Center

- Office Area

- Other Plant Areas The page/party system (Gaitronics) is comprised of a page channel connected to loudspeakers throughout the plant and three channels. System functions allow multiple personnel to participate in a conversation on each of the channels. The page system is also used for announcements and plant alarms.

The alarm mode must be initialized from the Control Room, but the conversation features are available in all emergency response facilities onsite and throughout the plant.

5.2.2 Sound Powered Phone System (In-Plant)

Control Room Technical Support Center Other Plant Areas The sound-powered phone system allows point-to-point Communications as well as multi-point communication without interference from cross-talk. This system is normally used for maintenance and testing but can be used for conversations between individuals performing specialized tasks (e.g., an individual in the Control Room and a technical specialist in the Technical Support Center). This system is operational from the relay room accessible from the TSC and Control Room.

5.2.3 Telephone System Control Room Operational Support Center (Primary, Backup, and Alternative)

Technical Support Center (Primary and Alternative)

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Emergency Operations Facility Other Plant Areas Various Offsite Agencies The plant telephone systems can be used for in-plant as well as outside communications. The system can be used for point-to-point or multi-point communications. Normal telephone lines are available at each emergency center.

The phone systems include many automated or programmable features that improve notification and allow communications flexibility. Cellular or satellite phones are also available at various locations.

5.2.4 Dedicated Telephone Links 5.2.4.1 Radiological Emergency Communications system (RECS)

The Radiological Emergency Communications System is a dedicated telephone network to be used for communications pertaining to nuclear emergencies at JAFNPP. The RECS system is available 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day, 7 days per week and is tested by New York State periodically.

The system utilizes the Emergency Management Network (EmNET) which is a Voice over Internet Protocol (VoIP) system providing multi-party communication in a conferencing mode.

A phone is normally located at each of the following locations:

1.

New York State Emergency Operations Center

2.

New York State Watch Center

3.

Oswego County Emergency Operations Center

4.

Oswego County E-911 Center (Warning Point)

5.

Nine Mile Point Control Rooms

6.

Nine Mile Point TSC and EOF

7.

JAFNPP Control Room

8.

JAFNPP Technical Support Center

9.

JAFNPP Emergency Operations Facility/Alternative TSC

10. Joint Information Center 5.2.4.2 Other Dedicated or Special Lines In addition to the RECS system, dedicated telephone connections provide direct communication between the points shown below through use of bridge lines.

Access to the bridge lines is available through redundant means from each facility (e.g., VoIP, Satellite). These bridge lines include conference between:

a. Control Room to:

Technical Support Center NMPNS

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EOF OSC

b. Technical Support Center to:

Control Room NMPNS Emergency Operations Facility Operational Support Center Backup Operational Support Center

c. Emergency Operations Facility to:

Technical Support Center Operational Support Center JAFNPP Radiation Protection Manager Control Room 5.2.4.3 NRC Health Physics Network (HPN), FTS2001 Phones This telephone system is part of the FTS2001. It is used to transmit health physics (radiological) data or other data to the NRC during an emergency.

JAFNPP facilities at which these telephones are located include:

Technical Support Center Emergency Operations Facility Several FTS2001 telephones exist at the TSC and EOF 5.2.5 Radio System The JAFNPP radio system utilizes various frequencies at the following locations:

- Control Room

- Technical Support Center

- Security Force

- Portable Units These emergency facilities are equipped with radios that allow contacting radio-equipped personnel within the plant.

5.2.6 Satellite/Cellular Phone Systems JAF has Satellite or Cellular Phones available for use in the Emergency Response Facilities (MCR, TSC, OSC, EOF), as well as Offsite Emergency Facilities (OCEMC, NYSEMO). The emergency facilities are capable of establishing contact with personnel within the plant and offsite, including the Oswego County 911 Center and State/County emergency facilities.

FitzPatrick Annex Constellation October 2023 JF 5-9 EP-AA-1014 (Revision 5) 5.2.7 Data Links Plant Data System to:

- Technical Support Center

- Emergency Operations Facility

- Joint Information Center

- New York State

- NRC Operations Center 5.2.8 Hard Copy Transceivers (Telecopy)

- Oswego County Emergency Management Office

- Constellation Headquarters

- Technical Support Center (Primary and Alternative TSC)

- Emergency Operations Facility

- Joint Information Center

- New York State Office of Emergency Management

- Other Services as necessary 5.2.9 Alert and Notification System In order to provide prompt notification to the public of emergency conditions, an Alert and Notification System (ANS) has been installed in the plume exposure EPZ.

The ANS consists of:

The Alerting portion of the system, which consists of fixed sirens within the 10 mile EPZ. Figure 5-4 depicts the approximate locations of the fixed sirens within the 10 mile EPZ. As a backup to the siren portion of the alerting system, a 911-based mass notification system is available.

The Notification portion of the system utilizes the Emergency Alert System (EAS) which consists of pre-designated radio stations that will broadcast public protective actions and other emergency news. The 911-based mass notification system can also act as a backup to the EAS portion of the notification system.

The design objectives, construction, operation and maintenance of the ANS meets or exceeds all of the relevant criteria for ANS delineated in NUREG0654 and FEMAREP10. The above ANS attributes are described in Design Report, Nine Mile Point Nuclear Generating Station and James A. Fitzpatrick Nuclear Power Plant, Public Alert and Notification System, Revision 1, November 2015 which was approved by FEMA in February 2016.

In accordance with instructions provided during periodic public information programs (Section 6 of the Plan), the alerted population will turn to EAS radio stations for emergency information and instructions. Nine Mile Point Nuclear Station and James A. FitzPatrick shall provide the hardware for the ANS within the plume exposure pathway EPZ.

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The responsibility for activation of the public warning system rests with the Oswego County Emergency Management Office. This organization will activate the alert portion of the ANS and supply appropriate emergency messages to the EAS station serving the jurisdiction in accordance with the provisions of their emergency response plans.

Reportability criteria for the Alert and Notification System failure is consistent with NUREG-1022 and industry guidance.

5.3 Assessment Facilities and Systems 5.3.1 Onsite Assessment Facilities Initially following an emergency, the primary onsite emergency assessment facility is the Control Room. This assessment function is transferred to the TSC after that facility has been activated. These facilities are described in Section 5.1.

Post-accident radiological samples may be analyzed in the JAFNPP radiochemistry laboratory if background radiation levels permit. This in-plant laboratory has full computer/HPGe gamma spectral, gross beta and gross alpha analysis capabilities.

5.3.2 Offsite Assessment Facilities In addition to the in-plant radiochemistry laboratory, the services of an environmental laboratory are available, which can be used for post-accident radiological sample analysis. This environmental laboratory has full computer/HPGe gamma spectral and gross beta analysis capabilities. That service is listed as a Letter of Agreement in Appendix C.

Post-accident radiological samples can be sent to the Nine Mile Point Nuclear Power Station radiochemistry laboratory in the event that the JAFNPP in-plant and contracted environmental laboratories are unavailable for any reason, such as high background radiation levels, or operation at full capacity.

If the above facility cannot perform the analyses or cannot handle the number of analyses required, samples can be sent to the R.E. Ginna Nuclear Power Plant laboratory, located near Rochester, about an hour away by car.

5.3.3 Assessment System 5.3.3.1 Plant Radiation Monitoring Systems This system, consisting of process and area radiation monitors, provides for personnel protection and accident assessment by

FitzPatrick Annex Constellation October 2023 JF 5-11 EP-AA-1014 (Revision 5) measuring and recording radiation levels and radioactivity concentrations at strategically selected locations throughout the plant. The systems are described in the following paragraphs.

- Post Accident Sampling System (PASS)

The post-accident sampling system shall provide means of obtaining primary and secondary containment atmosphere samples for determination of gas composition by means of gas chromatography, and for performing radiochemical analysis of noble gas, iodine, and particulate activities. Liquid samples shall be taken from the suppression pool and from the reactor coolant system under design conditions of temperature and pressure.

The system is designed in accordance with the criteria set forth in NUREG-0578 with regard to post-accident sampling system performance and scope of radiochemical analysis.

An in-line conductivity cell is used as the primary indicator of liquid chemical concentrations and changing chemical conditions. For rapid characterization of samples, pH paper may be used to establish pH to within +/-0.5 pH units at high conductivities. The post-accident laboratory will have the ability to perform accurate chloride and pH determinations.

The use of an in-line conductivity cell adequately satisfies the immediate need for chemical information without detailed analysis and eliminates unnecessary personnel exposure and the risk of major laboratory contamination. The system has the capability to provide a 1 to 1000 dilution of liquid samples to permit handling using existing facilities. Specific provisions for boron analysis are not included in the system. The only time boron would be present in the reactor coolant system is when the injection of sodium pentaborate was manually initiated from the Control Room via the standby liquid control system. In this case, an increase in reactor coolant system conductivity would indicate injection of the sodium pentaborate solution.

Liquid samples may be drawn from the reactor coolant system via instrument lines in the reactor water recirculation system and the shutdown cooling configuration of the residual heat removal system. The suppression pool may be sampled from the core spray pumps or via the suppression pool cooling mode of the residual heat removal system.

Provisions have been made to obtain gas samples from the

FitzPatrick Annex Constellation October 2023 JF 5-12 EP-AA-1014 (Revision 5) drywell and suppression pool atmospheres and from the secondary containment (Reactor Building).

The gas sampling system is designed to operate at pressures from sub-atmospheric up to the design pressures of the primary and secondary containments. Heat-traced sample lines prevent precipitation and subsequent loss of iodine in the lines. Gas samples may be passed through a particulate filter and silver zeolite filter for the determination of particulate activity and total iodine by analysis of the samples in a gamma spectrometer system. The system provides for grab sampling to allow analysis of gaseous activity as well as the dilution of high activity samples.

Main Steam Line Radiation Monitoring System The objective of the main steam line monitoring system is to continuously monitor for the gross release of fission products from the fuel. Indication of such a failure will initiate an alarm condition. The monitoring system consists of four gamma sensitive ionization chambers, logarithmic radiation monitor and dual pen recorder.

Off-Gas Radiation Monitoring System The objective of the off-gas radiation monitoring system is to continuously monitor radioactive effluents from the main condenser to the environment via the off-gas treatment system. This radiation monitoring system initiates closure of the off-gas isolation valve after a time delay when off-gas radiation levels exceed a preset limit. This system consists of two identical channels each consisting of a gamma sensitive ionization chamber and logarithmic radiation monitor. Both channels provide input to a dual pen recorder. The off-gas system is also equipped with sampling sub-system to allow for periodic grab sampling for laboratory analysis.

- Main Stack (Off-Gas Vent Pipe) Radiation Monitor This subsystem monitors the release of radioactive material the environment via the main stack, which receives inputs from the off-gas system and the standby gas treatment system. Isokinetic probes in the stack provide a representative sample of the effluent to the detection system.

This system consists of a pair of gamma sensitive scintillation detectors. The output of these detectors is displayed in the Control Room on logarithmic radiation monitors and multipen recorders.

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The High Range Effluent Monitoring System consists of three noble gas monitoring units connected in line with existing effluent monitors. One unit each is connected upstream of the turbine building exhaust sampler, the radwaste building exhaust sampler, and main stack effluent monitor.

Each monitoring unit contains two redundant ion chamber detectors. Associated with each detector is a meter type readout module in the main Control Room panel 09-2, having a range of 1E-1 to 1E+7 mR/hr. In addition to meter readouts, these modules supply digital outputs for annunciation of failure, high radiation ("alert") and high-high radiation. They also supply analog outputs for trend recording and computer logging.

The monitoring units also supply analog and digital outputs to the plant process computer. Digital outputs indicate failure, high, or high-high radiation conditions.

- Service Water and Reactor Building Closed Loop Cooling Water System Monitors Each of these systems provides cooling water to various heat exchangers for the cooling of systems which may contain radioactive material. These continuous monitoring systems are used to detect leakage and prevent an inadvertent release of radioactive material to the environment. Each of these monitors consists of a gamma-sensitive scintillation detector in a shielded sampling chamber. Activity above a preset level is annunciated in the Control Room.

- Radioactive Waste Effluent Radiation Monitor This subsystem is used for the control of discharges of low activity liquids. It is similar in design to other water monitoring systems. In the event activity exceeds a predetermined level, the trip unit of this system sends an isolation signal to the discharge valve of the liquid radwaste system.

- Ventilation Monitoring Systems Ventilation monitoring systems are used to continuously monitor releases from building ventilation systems, provide alarms when releases approach preset levels, isolate ventilation systems to protect the environment, and maintain habitability of the Control Room. The monitors for the radwaste building, turbine building, and reactor building are

FitzPatrick Annex Constellation October 2023 JF 5-14 EP-AA-1014 (Revision 5) similar. They consist of a sampling pump, sample chamber, GM radiation detector, and logarithmic display. The monitors also contain in-line particulate and activated charcoal filters which are analyzed to provide a precise determination of releases to the environment. Alarms for high activity and inoperable detectors are provided in the Control Room. The reactor building ventilation monitors have two channels.

If effluent activity exceeds a preset level on either channel, the normal reactor building ventilation system is isolated and the standby gas treatment system is initiated.

The Control Room air inlet is continuously monitored by an in-line GM-type radiation detector. Indication is provided in the Control Room and an alarm is received if activity in the Control Room ventilation intake approaches preset levels.

- Drywell Continuous Airborne Radioactivity Monitors The drywell continuous airborne radioactivity monitor consists of two redundant systems. Each of these contains a sampling pump, sample chamber, gamma sensitive scintillation detector and filter chambers. Each system provides continuous indication of particulate and noble gas activity. The system also provides for sampling and analysis of halogens/iodine.

- Iodine Monitoring Routine monitoring of ventilation exhausts for iodine is accomplished by the use of in-line activated charcoal filters.

These filters are periodically changed and analyzed in a gamma spectrometer. Routine grab sampling is performed using portable sampling pumps fitted with particulate and activated charcoal filters and are similarly analyzed.

Continuous air monitors are also located in various areas of the plant and monitor gross airborne activity, as well as halogen activity.

Monitoring during off-normal conditions can be accomplished by the use of portable sampling pumps equipped with particulate filter and silver zeolite cartridge. The silver zeolite cartridge can be analyzed in a low background area using a count rate meter for immediate determination of total iodine.

Cartridges can be analyzed using gamma spectrometry in either the JAFNPP counting laboratory, an environmental laboratory, or the adjacent NMPNS laboratory. The silver zeolite cartridges have an iodine retention in excess of 99%

FitzPatrick Annex Constellation October 2023 JF 5-15 EP-AA-1014 (Revision 5) while retaining only traces of noble gases. Particulates are removed using a pre-filter. Thus, gamma spectrometry is not necessarily required to make a rapid estimation of airborne radioiodine. The count rate obtained using the silver zeolite cartridge is then multiplied by a correction factor to determine the concentration of airborne radioiodine. Using this method, it is possible to attain the required minimum detectable activity of 1E-7 µCi/cc.

- Containment Radiation Monitors Monitoring of radiation levels within the primary containment (drywell) is accomplished using two redundant high-range (1E+8 rem/hr) ionization chambers. These detectors are located in approximately opposite locations in the drywell.

Indications of radiation levels and alarms for high radiation conditions are provided in the Control Room.

The Core Damage Assessment procedure can be used to estimate core damage as an input to URI.

- Area Radiation Monitoring System The fixed area radiation monitoring system consists of thirty units located throughout the plant. Each unit consists of gamma-sensitive GM tube encased in a protective cylinder.

Indication of radiation levels is provided in the Control Room on logarithmic radiation monitors and multi-point recorder.

Local indication is provided at many locations. The most common ranges are 0.1 to 1000 mR/hr. Monitors in areas such as laboratories, offices and Control Room range from 0.01 to 100 mR/hr. A high range radiation monitor on the refueling floor ranges from 0.1 to 1000 R/hr.

- High Range Effluent Monitor (HREM)

Three HREM systems have been installed at JAF. The systems were installed to monitor unusually high-level stack, turbine building and radwaste building noble gas releases.

Each system consists of a large volume sample chamber and two independent gamma sensitive instrument channels. The instrument readouts and recorders are located on a back panel in the main control room. Computer and annunciator alarms alert plant operators of unusual noble gas releases. A detailed HREM interpretation is contained in SP-03.08 series of procedures.

FitzPatrick Annex Constellation October 2023 JF 5-16 EP-AA-1014 (Revision 5) 5.3.3.2 Fire Protection Systems Fire protection in the plant is provided by a complete network of fire suppression and extinguishing systems. These systems are associated with fire alarms and are activated by a variety of thermal and products of combustion fire detection devices located throughout the plant.

5.3.3.3 Geophysical Phenomena Monitoring System Monitors are provided for detecting and recording natural phenomena events which could result in plant damage due to ground motion or structural vibration and stress.

Backup information can be obtained from the NMPNPS which also has seismic detectors or a local National Weather Service Station.

Hydrologic conditions (e.g., floods, low water, hurricanes) would be observed by the shift operating crew and / or information would be provided by the U.S. Coast Guard, or a local National Weather Service Station.

5.3.3.4 Environmental Radiological Monitoring Systems There are 15 environmental radiological monitoring stations, as shown in Figure 5-2 and 5-3. The inner ring of monitoring stations, designated the onsite monitoring stations, surround the plant at a radius of approximately 2000 feet from the plant. The outer ring of monitoring stations, designated the offsite monitoring stations, surround the plant at a radius which varies from approximately 6 to 15 miles from the plant.

Each of the 15 monitoring stations continuously collects a particulate and iodine air sample. A continuously operating sample pump draws air through a two-inch diameter glass fiber filter followed in the flow path by a two-inch diameter by one inch thick charcoal cartridge.

`

The Technical Specification Environmental Monitoring Stations located at the site boundary, (R1, R2, R3 and R4),

and the offsite Environmental Station (R5) each have a direct radiation monitor. The radiation monitors are Eberline Model ERM-2 which consist of a GM detector with an associated power supply and provides a digital dose rate readout.

Historical (prior month) monitor readings may be obtained using a computer (PC) interface to access the monitors internal storage ROM. Each radiation monitor has an

FitzPatrick Annex Constellation October 2023 JF 5-17 EP-AA-1014 (Revision 5) operating range of 1 µR / hr to 100 mR / hr. The radiation monitors are used to detect and measure dose rates resulting from possible plume releases of radioactive material from the plant.

Each of the 15 monitoring stations has the capability for collecting precipitation samples, if required.

5.3.3.5 Environmental Dosimeter of Legal Record (TLD/DLR)

Monitoring Systems The environmental TLD/DLR monitoring system is comprised of TLD/DLR stations placed on and around the site as shown in Figures 5-2 and 5-3.

The first group of TLD/DLRs is located within the site boundary. This group consists of TLD/DLR stations ranging in distance from adjacent to the plant buildings to approximately 0.9 miles from the plant.

The second group of TLD/DLRs is located beyond the site boundary. This offsite set consists of TLD/DLR stations ranging in distance from approximately 0.6 to 12 miles from the plant.

The current placement of environmental TLD/DLRs is in accordance with the approved Technical Specifications for the site and conforms to the NRC Radiological Assessment Branch Technical Position.

Each environmental TLD/DLR station is comprised of TLD/DLRs sealed in a polyethylene package to ensure dosimeter integrity. The TLD/DLR packages are further protected by placement in plastic enclosures, or by tape sealing to supporting surfaces.

The TLD/DLRs are collected, replaced and evaluated quarterly.

5.3.3.6 Emergency TLD/DLR Monitoring System In addition to the environmental TLD/DLR monitoring system, a second group of TLD/DLRs called emergency TLD/DLRs has been placed in various locations around the site (as described in the Emergency Environmental Monitoring procedures. These TLD/DLRs are evaluated as necessary.

The TLD/DLR chips are renewed quarterly.

FitzPatrick Annex Constellation October 2023 JF 5-18 EP-AA-1014 (Revision 5) 5.3.3.7 Meteorological Measuring System Wind speed, wind direction and temperature sensors are installed on an isolated tower at elevations of approximately 30 feet, 100 feet and 200 feet above grade. The data collected by these sensors are telemetered to the JAFNPP Control Room and TSC and are continuously recorded on strip charts or digital recorders.

This data is also available in the CR, TSC and the EOF in digital form.

Joint frequency distributions of wind speed and direction by atmospheric stability class are maintained to aid in the evaluation of radiation doses which may result from the release of radioactive material from the plant.

As a backup to the primary meteorological measuring system, JAFNPP has an onsite atmospheric sensor with the ability to measure the wind speed and direction at the approximately 90-foot level. The recorders for the backup system are located on the same Control Room and TSC panel as the recorders for the primary system, thus permitting instantaneous, real time readings from two sources. A 30-foot inland tower is also an additional source of meteorological data. These sensors also have digital readouts in the CR, TSC and EOF.

Offsite backup for meteorological data is available from the National Weather Service by telephone.

An additional source of meteorological information is available through online information services. The information services collect weather information comprised of surface and upper air reports, satellite and radar information and other meteorological data on a continuous basis from sources around the world.

Access to this data is available by JAF personnel through an internet computer link.

5.3.3.8 Emergency Radiological Survey Teams Survey teams may be dispatched to provide immediate support for both onsite and offsite emergency condition assessment.

Teams will be provided survey kits composed of adequate portable instrumentation and instruction packages to permit the monitoring of airborne gamma and radioiodine levels and the acquisition of environmental media samples. A listing of available equipment for use by the survey teams is contained in equipment inventory procedure.

FitzPatrick Annex Constellation October 2023 JF 5-19 EP-AA-1014 (Revision 5)

The teams activities will be controlled by the Environmental Coordinator, or designee. Cellular phone and / or Satellite phone contact will be provided between the plant and survey teams.

Initial responsibilities for each team will include direct radiation measurements and the collection of airborne particulate and iodine samples. Following field evaluations, the collected samples will be individually packaged and identified to permit subsequent re-evaluation, if required. Monitoring locations for the initial surveys may be the locations identified in Figures 5.2, 5.3 and 5.5 and/or other locations as determined by the Emergency Directors and/or, Radiological Protection Managers, or designees.

The survey teams may participate in the collection of samples from the fixed assessment systems described in Sections 5.3.3.4, 5.3.3.5 and 5.3.3.6. The teams will also expand their sampling activities to include collection of environmental media as dictated by the Environmental Coordinator, or designee.

Representative media referenced in the Site Radiological Environmental Monitoring Program will be sampled on an increased frequency commensurate with prevailing conditions.

In addition to the airborne particulate samples, airborne iodine samples and the TLD/DLRs previously described, environmental media samples may include milk, soil, water and vegetation.

A full description of the radiological monitoring capabilities is described in Section 4, EMERGENCY MEASURES, 4.2.2 Field Radiological Assessment.

5.3.3.9 Process Monitors Plant parameters such as reactor coolant system level and pressure, containment pressure and temperature and various system flow rates are indicated in the Control Room.

Such parameters are also available in the TSC and EOF via the Safety Parameter Display System(SPDS).

5.4 Protective Facilities Facilities are provided which ensure adequate radiological protection for personnel assigned to emergency duties in the plant, and for the accommodation of other personnel evacuated from areas that may be affected by radiation and / or airborne radioactivity or other actions that may restrict access to the site.

FitzPatrick Annex Constellation October 2023 JF 5-20 EP-AA-1014 (Revision 5) 5.4.1 Plant Control Room In addition to serving as the initial control location for emergency situations, the plant Control Room has the following features which provide protection for personnel who may have emergency or operational duties throughout the course of any emergency:

1. Adequate shielding by concrete walls to permit continuous occupancy under severe accident conditions.

2. An independent emergency air supply system, equipped with absolute and activated charcoal filters.

3. Continuous monitoring of radiation levels in the Control Room and throughout the plant by the ARM system, with readout in the Control Room.

4. Emergency lighting and power supplied by a 125V dc system and battery packs.

5. Communications system, as described in Section 5.2.

Additional details regarding the design and inherent protective capabilities of the plant Control Room are discussed in the JAFNPP FSAR.

5.4.2 Technical Support Center (TSC)

The TSC serves as the long range emergency control facility. To allow for long-term human occupancy during an emergency situation, the following personnel protective features have been incorporated into design.

1. Adequate shielding by concrete walls to permit continuous long-term occupancy under severe accident conditions. (Certain areas of the TSC may not be used under certain radiological conditions).

2. An air handling system equipped with HEPA filters to provide proper breathing air during a severe radiological accident.

3. Communications systems as described in Section 5.2.

4. Emergency lighting supplied by a 125V dc system and battery packs.

Emergency power is supplied to some receptacles via a plant UPS.

5. Continuous monitoring of radiation and airborne activity levels in the TSC.

FitzPatrick Annex Constellation October 2023 JF 5-21 EP-AA-1014 (Revision 5) 5.4.3 Primary Assembly Areas Specific locations at the plant are designated for assembly of personnel in the event of a Protected Area Assembly. These areas provide space to accommodate personnel who may be at the plant. They are located on the basis of logical access routes and physical separation from likely areas of radiation and / or airborne radioactivity. The Assembly, Accountability, and Evacuation procedure lists the primary assembly areas.

5.4.4 Remote Assembly Area The Oswego County Airport is designated as a remote assembly area, which provides the function of a staging/muster area.

This facility is located approximately 12 miles from the site on County Route 176 in the Town of Volney (Fulton, N.Y.). It is adjacent to the EOF/JIC and is away from the prevailing downwind direction.

Employee vehicles shall be used to transport employees to the Remote Assembly Area. Backup bus transportation is available from the Oswego County Emergency Management Office upon the Emergency Directors request. Evacuated personnel and vehicles can be decontaminated at this site if necessary.

5.5 Onsite First Aid and Medical Facilities First aid treatment facilities, equipped with industrial first aid supplies, are located on the first floor of the Administration / Support Building.

5.6 Decontamination Facilities for Emergency Personnel The personnel decontamination facilities at the JAFNPP and/or the EOF will be the primary facilities for decontaminating emergency personnel. If those facilities are unavailable for any reason, emergency personnel may be decontaminated at the NMPNPS facility.

The liquid waste from each of these decontamination facilities would be disposed of in the respective plant or facility liquid radwaste system. Solid waste would be disposed of in containers provided for this purpose.

A typical listing of personnel decontamination equipment is contained in the Radiation Protection Procedures.

5.7 Damage Control Equipment Damage control equipment consists of normal and special purpose tools and devices used for maintenance functions throughout the plant. Personnel assigned to damage control teams are trained and participate in drills and exercises in

FitzPatrick Annex Constellation October 2023 JF 5-22 EP-AA-1014 (Revision 5) accordance with the Drill and Exercise Program procedure. Guidance for damage control teams is contained in the Operations Support Center Activation and Operation Procedure.

5.8 Control of Emergency Equipment A list of emergency equipment and kits is included in Appendix I, EMERGENCY EQUIPMENT KITS. The frequency of emergency equipment maintenance is specified in the inventory procedure.

5.9 Federal Response Support Information vital to Federal Response Support is contained in Appendix N, TYPICAL FEDERAL SUPPORT RESOURCES.

5.10 Figures, Forms, and Attachments Figure 5.1 Emergency Communications Network Figure 5.2 Onsite Environmental Station and TLD/DLR Locations Figure 5.3 Offsite Environmental Station and TLD/DLR Locations Figure 5.4 Siren Locations Map Figure 5.5 Offsite Survey Locations Map

FitzPatrick Annex Constellation October 2023 JF 5-23 EP-AA-1014 (Revision 5)

FIGURE 5-1 Emergency Communications Network

FitzPatrick Annex Constellation October 2023 JF 5-24 EP-AA-1014 (Revision 5)

Figure 5-2, Onsite Environmental Station and TLD/DLR Locations

FitzPatrick Annex Constellation October 2023 JF 5-25 EP-AA-1014 (Revision 5)

Figure 5-3, Off-Site Environmental Station and TLD/DLR Locations

FitzPatrick Annex Constellation October 2023 JF 5-26 EP-AA-1014 (Revision 5)

Figure 5-4, Siren Locations Map Page 1 of 2 Nine Mile Point/JA FitzPatrick ANS Sirens

FitzPatrick Annex Constellation October 2023 JF 5-27 EP-AA-1014 (Revision 5)

FIGURE 5.4 - SIREN LOCATIONS MAP NUMBER 6 Page 2 of 2 To search for the map do the following in EDMS:

1.)

Log onto EDMS Reference Library via the intranet 2.)

Type in your user name, pass word, and group is general 3.)

Click on general records 4.)

In the Document ID area type in Section 7 and hit search 5.)

Highlight the row that has title - "Figure 7-4 Emergency Facilities and Equipment" 6.)

Select view from top 7.)

Select preview 8.)

The map should appear, and you can resize it if you like 9.)

The document is MAP NUMBER 6 - SIREN LOCATIONS 10.)

Map may be printed on any size paper for expansion and ease of reading, depending on printer selected.

FitzPatrick Annex Constellation October 2023 JF 5-28 EP-AA-1014 (Revision 5)

Figure 5.5 Offsite Survey Locations Map Page 1 of 2

FitzPatrick Annex Constellation October 2023 JF 5-29 EP-AA-1014 (Revision 5)

FIGURE 5.5 - OFFSITE SURVEY LOCATIONS MAP NUMBER 4 Page 2 of 2 To search for the map, do the following in EDMS:

1.)

Log onto EDMS Reference Library via the intranet 2.)

Type in your user name, pass word, and group is general 3.)

Click on general records 4.)

In the Document ID area type in Section 7 and hit search 5.)

Highlight the row that has title - "Figure 7-6 Emergency Facilities and Equipment" 6.)

Select view from top 7.)

Select preview 8.)

The map should appear, and you can resize it if you like 9.)

The document is MAP NUMBER 4 - OFFSITE SURVEY LOCATIONS 10.)

Map may be printed on any size paper for expansion and ease of reading, depending on printer selected.

FitzPatrick Annex Constellation October 2023 JF 6-1 EP-AA-1014 (Revision 5)

Section 6: Maintaining Nuclear Emergency Preparedness Emergency preparedness is maintained at the JAFNPP through administrative controls designed to; (1) train and periodically retrain site personnel, and offsite emergency organization personnel, (2) evaluate onsite and offsite proficiency and provide hands on experience through drills and exercises, (3) ensure that plans and implementing procedures are in place and current through document control procedures, (4) maintain sufficient stores of functional emergency equipment and supplies through equipment inventory procedures, (5) and maintain public and news media awareness of emergency preparedness through annual information updates and meetings with members of the media.

6.1 Responsibility for Maintaining Emergency Preparedness The Plant Manager has overall authority and responsibility for radiological emergency response planning. The Emergency Preparedness Manager is delegated the overall authority and responsibility for radiological emergency response planning and has the responsibility for developing and updating emergency plans and implementing procedures.

Responsibilities for ERO training are contained in EP-AA-1000, Constellation Standardized Radiological Emergency Plan.

The Emergency Preparedness Manager shall be responsible for coordinating, scheduling and administrating news organization training.

The Oswego County Director of Emergency Management is responsible for planning and conducting emergency preparedness training for emergency response personnel in Oswego County.

The Director Emergency Programs is responsible for ensuring that corporate personnel who have emergency plan duties supporting JAFNPP receive the appropriate emergency preparedness training.

Individuals responsible for Emergency Planning are trained in accordance with paragraphs 6.2 - Training of Emergency Personnel and 6.3 - Emergency Planning Staff Training. In addition, the Emergency Planning Staff receives training by:

attendance at Emergency Planning Workshops conducted with other utilities and attendance at NRC, FEMA and other government sponsored Emergency Planning seminars and, participation in JAFNPP specific training programs related to emergency preparedness.

6.2 Training of Emergency Personnel Training is conducted in accordance with Section O.5 of EP-AA-1000, the Standardized Radiological Emergency Plan per TQ-AA-113, ERO Training and Qualification. Retraining is performed on an annual basis, which is defined as once per calendar year not to exceed 18 months between training sessions.

FitzPatrick Annex Constellation October 2023 JF 6-2 EP-AA-1014 (Revision 5) 6.2.1 Annual Review of Emergency Action Levels The Emergency Preparedness Manager, in accordance with 10 CFR 50, shall conduct an annual review of the JAFNPP Emergency Action Levels (or changes to those EALs from the prior review cycle) with appropriate representatives of New York State and Oswego County. Reviews will be documented by memorandum.

6.3 Emergency Planning Staff Training Personnel responsible for the Fitzpatrick emergency preparedness effort receive appropriate training to maintain their level of competency. On an annual basis, site Emergency Planning staff may participate in any one of the following. The Site Emergency Preparedness Manager and staff attend relevant seminars and meetings on emergency preparedness issues, such as those held by the NRC/FEMA and Nuclear Energy Institute. In addition, appropriate technical literature (such as that received from NEI, FEMA, NRC, etc.) is reviewed to assist in maintaining this competency. Training requirements for FitzPatrick personnel responsible for the emergency planning effort are described in the Standard Plan and in the Emergency Plan Administration procedure.

6.4 Drills and Exercises An exercise is an event that tests the integrated capability and a major portion of the basic elements existing within emergency preparedness plans and organizations.

Drills and Exercises are discussed in the Standard Plan and EP-AA-122-100, Drill and Exercise Planning and Scheduling. Drills and exercises provide the means to evaluate training effectiveness under simulated emergency conditions, skills developed during training, reinforce correct actions and identify and correct short-comings in training, equipment, or procedures.

6.4.1 Drills A drill is a supervised instruction period aimed at testing, developing and maintaining skills in a particular operation. A drill is often a component of an exercise. A drill may also be tabletop supervised instruction or role-playing.

The Emergency Preparedness Manager is responsible for the conduct of drills.

Drills shall be conducted using the following guidelines:

FitzPatrick Annex Constellation October 2023 JF 6-3 EP-AA-1014 (Revision 5)

a. Drills are planned in advance using formal scenarios (except communications drills which may be performed by a single individual).

b. Observers/evaluators, and/or controllers are designated and briefed in advance, as required.

c. Drill critiques are conducted as described in the Standard Plan and in accordance with the Drill and Exercise Evaluation procedure. The results of the critique along with observer, evaluator, controller and participant comments are utilized to evaluate and resolve any identified shortcomings.

d. Major elements of the JAFNPP Emergency Plan are tested within an eight-year period.

e. At least once per eight-year period a drill starts between 6:00 p.m. and 4:00 a.m.

f. Drills are conducted under various weather conditions.

6.4.2 Exercises The Emergency Preparedness Manager is responsible for the coordination and conduct of exercises. Exercises are conducted at least once every two years in accordance with NRC and FEMA rules. The conduct of exercises is described in the Standard Plan and the Drill and Exercise Program procedure. In summary, the following criteria apply to exercises conducted at JAFNPP.

Exercises will be conducted using the same criteria as applied to drills as summarized below:

a.

The JAFNPP Exercise should include simulated off-site radiological releases.

b.

Federal, State, and company observers/evaluators may be present.

c.

Exercises are planned in advance using formal scenarios.

d.

Scenarios shall be reviewed and approved in advance by the Emergency Preparedness Manager and a representative from the Plant Operations Safety Review Committee (PORC) or senior management reviewer. The reviewer should have plant experience and have participated in an SRO training program or have a current SRO license.

e.

Observers, evaluators and controllers are designated and briefed in advance.

f.

Unannounced exercises are controlled through input of initiating events by controllers.

g.

Observers, evaluators, controllers and participants comments from the

FitzPatrick Annex Constellation October 2023 JF 6-4 EP-AA-1014 (Revision 5) exercise documentation package.

h.

The NRC/FEMA critique is factored into the exercise documentation package (when applicable).

i.

The exercise documentation package is used as a basis to evaluate shortcomings and develop a plan to correct deficiencies through additional training or equipment or procedure revision.

j.

Drill/Exercise report generation is discussed in the Standard Plan and EP-AA-122, Drills and Exercise Program.

6.4.3 Drill and Exercise Scenario Preparation Responsibilities The development of drills and exercises for JAFNPP shall be coordinated by the JAFNPP Emergency Preparedness Manager. The JAFNPP Training Director shall have the responsibility for developing plant specific data. The JAFNPP Emergency Preparedness Manager shall have the responsibility for ensuring plant specific radiological data is provided. Exercise Scenario preparation shall be conducted by a committee and documented by the Emergency Preparedness Manager. Responsibilities are discussed in the Standard Plan and the Drill and Exercise Program procedure.

6.5 Document Maintenance 6.5.1 Plans and Procedures The JAFNPP Emergency Plan and Procedures will be maintained in the format and by the method specified in the EP-AA-120, Emergency Plan Administration, and Constellation fleet Document Control Administrative procedures.

6.5.2 Letters of Agreement The Emergency Preparedness Manager will ensure that letters of agreement from all participating organizations are reviewed and recertified.

Recertification may include a written recertification, purchase order documentation, memo form, or a memo of a telephone conversation. The Plant Manager JAF is the individual with the authority and responsibility to make agreements with utility and non-utility organizations.

FitzPatrick Annex Constellation October 2023 JF 6-5 EP-AA-1014 (Revision 5) 6.5.3 Reviews An independent review of the JAFNPP Emergency Preparedness Program shall be conducted by Nuclear Oversight. The independent review shall be conducted in accordance with 10CFR50.54(t) as follows:

At intervals not to exceed 12 months or, As necessary, based on an assessment by the licensee against performance indicators, and as soon as reasonably practicable after a change occurs in personnel, procedures, equipment, or facilities that potentially could adversely affect emergency preparedness, but no longer than 12 months after the change. In any case, all elements of the emergency preparedness program must be reviewed at least once every 24 months.

The review must include an evaluation for adequacy of interfaces with State and local governments and of licensee drills, exercises, capabilities, and procedures. The results of the review, along with recommendations for improvements, must be documented, reported to the licensee's corporate and plant management. The part of the review involving the evaluation for adequacy of interface with State and local governments must be available to the appropriate State and local government.

6.5.5 Supporting Documents A list of supporting documents is contained in Appendix J, Supporting Documents. Documents on this list will be maintained in the manner specified by the agency the supporting document is received from.

6.6 Maintenance and Inventory of Emergency Equipment and Supplies Periodic testing, calibration and inventory of emergency equipment and supplies are conducted in accordance with Emergency Plan Implementing Procedures. The Emergency Preparedness Manager or designated alternate shall conduct an annual review of this procedure to ensure the operational readiness of emergency equipment and supplies.

Emergency equipment and instrumentation shall be inventoried, inspected and operationally checked monthly, quarterly, or semiannually as indicated by the procedure and after each use. Sufficient reserves of equipment and instrumentation are stocked to replace emergency equipment and instrumentation removed from service for calibration and/or repair.

Appendix I, EMERGENCY EQUIPMENT KITS, presents a list of emergency equipment and instrumentation and emergency equipment kits.

Records detailing the testing, calibration and inventory of emergency equipment and supplies shall be maintained for two years.

FitzPatrick Annex Constellation October 2023 JF 6-6 EP-AA-1014 (Revision 5)

Communications checks and drills will be conducted in accordance with EP Implementing Procedures. This procedure specifies that certain emergency telephones and telephone numbers shall be verified at least quarterly.

6.7 Maintenance of Public and News Media Awareness 6.7.1 Public Awareness JAF, in conjunction with the Nine Mile Point Site, New York State EMO, and the Oswego County EMO, has established an information program for the permanent residents and transient population within the Plume Exposure EPZ. The information provided emphasizes the means of notification and subsequent actions to be taken in the event of an emergency at the JAFNPP (or NMPNPS), and includes information on contacts for additional information and protective measures. Refer to Appendix H, PUBLIC INFORMATION PROGRAM for detailed information.

Information is distributed to permanent residents by various methods, including mailings to their residence or placement in local telephone books.

Postings in public areas and places of business frequented by the transient population is the principal method for informing those individuals.

Public postings are updated as necessary and public distribution shall be conducted at least annually, or a frequency to coincide with telephone book distribution.

6.7.2 Residents Who May Require Special Care Information for residents who may require special care (e.g. handicapped, elderly) is included with the annual mailing sent to the resident population.

Along with this information is a card that is requested to be returned if an individual requires special care. A list of these individuals is maintained by the OCEMO for their use.

6.7.3 Rumor Control Rumor control is conducted by a telephone answering system that may include both mechanical or electronic devices as well as operators for the answering of calls from the public.

6.7.4 News Media Awareness News media awareness is completed by meeting with representatives annually in conjunction with Oswego County, Nine Mile Point, and New York State, or other means, as necessary. These meetings provide information concerning radiation, emergency planning, and the means established for the release of information to the news media during an emergency. In addition, media manuals are distributed to media organizations, as necessary.

FitzPatrick Annex Constellation October 2023 JF 7-1 EP-AA-1014 (Revision 5)

SECTION 7: DEFINITIONS AND ACRONYMS 7.1 Definitions This section contains the definition of terms for the James A. FitzPatrick Nuclear Power Plant.

Accountability - The process by which the onsite emergency organization determines the location of personnel in order to identify missing and/or injured personnel.

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

Alert - Events are in process or have occurred which involve a potential or actual 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 intentional malicious dedicated efforts of a hostile act. Any releases are expected to be limited to small fractions of the EPA Protective Action Guides exposure levels beyond the site boundary.

Alternate NY State Watch Center (Alternate SWC) - The Alternate NY SWC is located in the New York State Police Communications Center in Public Security Building No. 22, State Office Building Campus, Albany, New York. This facility is manned 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day to receive Radiological Emergency Communication System (RECS) or alternate notifications during off-hours.

Area Radiation Monitor (ARM) - Instruments (some of which are fixed) which typically measures gross gamma radiation levels in a local area and alarms when the radiation exposure rate reaches the preset alarm level.

Assessment Actions - Those actions taken during or after an accident to obtain and process information necessary to make decisions to implement specific emergency measures.

Augmented Dose Assessment - Dose Assessment from the Emergency Offsite Facility (EOF) or Technical Support Center (TSC) utilizing dose assessment staff.

Command and Control - This is the function where the current Emergency Director resides (Control Room, TSC, or EOF).

Committed Dose Equivalent (CDE) - The dose equivalent to organs or tissues of reference that will be received from an intake of radioactive material by an individual during the 50-year period following the intake (organ dose) (per EPA-400 definition).

Committed Effective Dose Equivalent (CEDE) - The sum of the products of the weighing factors applicable to each of the body organs or tissues that are irradiated and the committed dose equivalent to these organs or tissues.

Corporate Emergency Director (CED) - The designated individual who has the authority,

FitzPatrick Annex Constellation October 2023 JF 7-2 EP-AA-1014 (Revision 5) management ability, and technical knowledge to manage Constellation s Emergency Response Activities.

Mitigative actions - Those emergency measures taken to mitigate or terminate an emergency situation at or near the source of the problem in order to prevent an uncontrolled release of radioactive material or to reduce the magnitude of a release.

County Warning Point - The E-911 Center at the Oswego County Public Safety Building in Oswego. This serves as a notification point for messages from the utilities to appropriate officials in Oswego County.

Deep Dose Equivalent (DDE) - Applies to external whole-body exposure, is the dose equivalent at tissue depth of 1 cm (1,000 mg/cm2) [external whole-body dose].

Dose Equivalent (DE) - The product of the absorbed dose in tissue, quality factor, and all other necessary modifying factors at the location of interest; measured in rem or sievert.

Dose Projection - A calculated estimate of the potential dose to individuals at a given location, usually off site.

Emergency Actions - A collective term which encompasses the assessment, corrective and protective actions taken during the course of an emergency.

Emergency Action Levels (EAL) - Plant instrumentation readings, survey measurements or off normal plant conditions that are used to classify an emergency. (See Emergency Classification System.)

Emergency Action Procedure (EAP) - The procedures which provide a detailed list of responsibilities and actions to be implemented by personnel staffing emergency facilities.

Emergency Alert System (EAS) [formerly Emergency Broadcast System (EBS)] - A network of radio stations organized to permit designated government officials a means of timely and efficient issuance of emergency information and instructions to the public.

Emergency Classification System - A system that categorizes certain abnormal plant conditions into one of the following classes:

- Unusual Event

- Alert

- Site Area Emergency

- General Emergency Emergency Operations Center (EOC) - Designated state and county facilities used for the assessment of emergency information and coordination and control of local and state emergency response personnel.

Emergency Operations Facility (EOF) - The designated and equipped facility that is used to provide continuous coordination with local, state, and federal agencies, and provide evaluation of FitzPatrick activities during an emergency having or potentially having

FitzPatrick Annex Constellation October 2023 JF 7-3 EP-AA-1014 (Revision 5) environmental consequences. The EOF is located on County Route 176, approximately 12 miles south of the JAF plant.

Emergency Plan Implementing Procedures - The procedures, which detail the specific course of action for implementing the emergency plan at the JAF Facility.

Emergency Preparedness Manager - The individual responsible for the coordination of emergency planning efforts.

Emergency Plant Manager (EPM) - Individual normally assigned to the TSC who normally oversees the onsite and plant aspects of the emergency. The EPM reports to the Emergency Director.

Emergency Planning Zone (EPZ) - There are two Emergency Planning Zones. The first is an area, approximately 10 miles in radius around the JAFNPP, for which detailed emergency planning consideration of the Plume Exposure Pathway has been given to ensure prompt and effective protective actions for the public. The second is an area, approximately 50 miles in radius around the JAFNPP, for which emergency planning consideration of the Ingestion Exposure Pathway has been given to ensure effective preventative measures for the public.

Emergency and Plant Information Computer (EPIC) - Computer providing display of plant data to the Control Room, TSC, and EOF. EPIC includes Safety Parameter Display System (SPDS) information.

Emergency Response Data System (ERDS) - A computerized link between JAF EPIC data system and the NRC Operations Center.

Emergency Response Facility (ERF) - ERF is a generic term referring to a facility that is used for emergency purposes. These facilities include the Control Room, Technical Support Center, Emergency Operations Facility, Operational Support Center, Alternate Operational Support Center, Joint Information Center, Oswego County Emergency Operations Center.

Emergency Response Planning Area (ERPA) - Pre-designated sub-areas within the 10-Mile Emergency Planning Zone used to more specifically target the recommendation of off site protective actions.

Emergency Response/Recovery Organization - The organizational structure within the James A. FitzPatrick Nuclear Power Plant Emergency Response Organization, which is responsible for coordinating response and recovery from emergency conditions at the plant. The Termination and Recovery procedure specifies the Recovery Organization.

Emergency Telecommunications System (ETS) - Part of the Federal Telecommunications system used by the NRC for emergency communications.

Exclusion Area - The property of the James A. FitzPatrick Nuclear Power Plant and Nine Mile Point stations surrounding the Protected Area in which the licensee has the authority

FitzPatrick Annex Constellation October 2023 JF 7-4 EP-AA-1014 (Revision 5) to determine all activities including exclusion or removal of personnel and property from the area.

Federal Radiological Monitoring and Assessment Plan - An arrangement whereby the Department of Energy and other federal agencies provide teams to assist JAFNPP, Oswego County and New York State with an in-depth capability during a radiological emergency.

Final Safety Analysis Report (FSAR) - Multi-volume report describing a nuclear power plant's site, design features, safety features and the utility's intended methods of operation.

General Emergency - Events, which are in process or have occurred which involve imminent or actual substantial core degradation or melting with the potential for loss of containment integrity, or Security events that result in an actual loss of physical control of the facility.

Hostile Action - An act toward JAFNPP or its personnel that includes 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. 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 JAFNPP.

Ingestion Exposure Pathway - A pathway by which individuals can be exposed to radiation from ingestion of contaminated water or foods such as milk, fresh vegetables, and fish.

Initial Dose Assessment - Dose assessment using a pre-calculated dose assessment value tree, to be conducted before augmented dose assessment.

Joint Information Center - Located next to the Oswego County Airport on Co. Rt. 176 in the Town of Volney. The Joint Information Center provides a central facility for the release of information to the public. The facility includes participants from JAFNPP, Nine Mile Point, Oswego County, New York State, and Federal Agencies.

Joint Information Center Manager - ERO position whose primary responsibility is direction of all activities at the Joint Information Center and coordination of information.

Meteorological Monitoring System - A computer and software that accesses the main, backup and inland tower data. Data is accessible via designated computers.

National Warning System (NAWAS) - A nationwide warning system used to warn of actual or impending natural or man-made disasters. NAWAS warning points are strategically located and are manned on a 24-hour-a-day basis.

New York State Emergency Operations Center (NYSEOC) - The New York State EOC is located in the substructure of the Public Safety Building No. 22, State Office Building Campus, Albany, New York. It is the State Command Post from which emergency operations will be directed and coordinated.

FitzPatrick Annex Constellation October 2023 JF 7-5 EP-AA-1014 (Revision 5)

NSSS Supplier - Nuclear Steam Supply System Supplier, General Electric Company, San Jose, California.

Offsite - The area outside the Exclusion Area. Offsite surveys include the area inside the exclusion area, but outside the protected area.

Onsite - The area within the Exclusion Area.

Operational Support Center (OSC) - The area on the 272' level of the old administration building that serves as an onsite assembly and dispatch area for plant survey, fire, rescue, and maintenance teams.

Oswego County Emergency Management Office (OCEMO) - The lead local government agency responsible for offsite emergency response within the 10-mile EPZ surrounding the James A. FitzPatrick Nuclear Power Plant.

Oswego County Emergency Operations Center (OCEOC) -Located in the Emergency Management Office in the basement of the Oswego County Branch Building, Fulton, New York; serves as a command post from which emergency operations will be directed and coordinated.

Oswego County Warning Point (OCWP) - The dispatch center at Oswego E-911 Center in Oswego. This serves as a notification point for messages from the utilities to appropriate officials in the County.

Plant Data Acquisition System - A computer link making plant data available for onsite and offsite emergency facilities.

Plant Operator - Any member of the plant staff who, by virtue of training and experience, is qualified to assess the indications or reports for validity and to compare the same to the EALs in the licensees emergency classification scheme.

Plume Exposure Pathway - The principal exposure sources from this pathway are: a) external exposure to gamma radiation from the plume and from deposited material; and b) inhalation exposure from the passing radioactive plume. This pathway is commonly identified as the 10-mile EPZ.

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

Primary Assembly Areas - Specific locations at the plant designated for the assembly of personnel in the event of a Protected Area Assembly.

Projected Dose - The estimated radiation dose that would be received by individuals following a release of radiation.

Protected Area - The area within the plant security fence designated to implement the security requirements of 10 CFR 73.

FitzPatrick Annex Constellation October 2023 JF 7-6 EP-AA-1014 (Revision 5)

Protected Area Assembly - Assembly of individuals from the Protected Area at designated primary assembly areas.

Protective Actions - Actions taken in anticipation of / or after a release of radioactive material, for the purpose of preventing or minimizing radiological exposures to persons that would otherwise be likely to occur if the actions were not taken. Some of the protective actions are:

- Protected Area Assembly

- Site Evacuation

- Sheltering off site population

- Evacuation of the offsite population

- Isolation of ingestion pathways and sources Protective Action Guides (PAG) - Guidance developed by the Environmental Protection Agency regarding projected radiological dose or dose commitment values to individuals in the general population that warrant protective action following a release of radioactive material.

Radiologically Controlled Area (RCA) - Any area, access to which is limited for the purpose of protecting individuals against undue risks from exposure to radiation and radioactive materials. The RCA is posted with a sign bearing the radiation caution symbol in magenta, purple or black on a yellow background. Examples of radiologically controlled areas are:

- Reactor Building

- Turbine Building

- Radwaste Building

- Main Stack Examples of other postings within an RCA include:

- RADIOACTIVE MATERIALS

- CONTAMINATED AREA

- AIRBORNE RADIOACTIVITY AREA

- HIGHLY CONTAMINATED AREA

- RADIATION AREA

- HIGH RADIATION

- VERY HIGH RADIATION AREA Radiological Emergency Communications System (RECS) -System used to provide initial notification of an emergency, and continuing emergency information, to the State, Oswego County and Nine Mile Point Stations. RECS utilizes the EmNET platform to communicate between facilities.

Recovery Activities - Those actions taken after the emergency to restore the plant as nearly as possible to its pre-emergency condition.

Remote Assembly Area - Specific locations outside the JAFNPP exclusion area for the assembly of personnel in the event of a Site Evacuation. The primary Remote Assembly Area is the Oswego County Airport on Co. Rt. 176 in the Town of Volney.

FitzPatrick Annex Constellation October 2023 JF 7-7 EP-AA-1014 (Revision 5)

Restricted Area - An area, access to which is limited by the licensee, for the purpose of protecting individuals against undue risks from exposure to radiation and radioactive materials. Separate rooms or areas in any building may be set apart as a restricted area.

The restricted area is that area inside of the protected area fence and any other area within the site boundary that is appropriately identified and restricted from unauthorized entry.

Severe Accident Operating Guidelines (SAOGs) Guidelines to assist in dealing with a Severe Accident.

Safety Parameter Display System (SPDS) - System providing a display of plant data from which the safety status of plant operations may be assessed in the Control Room, Technical Support Center and Emergency Operations Facility.

Site Area Emergency - Events which are in process, or have occurred, which involve potential or actual major failure of plant functions needed for protection of the public, or Security events that result in intentional damage or because of intentional malicious dedicated efforts of hostile action: toward site personnel or equipment that could lead to the likely failure of, or: prevents effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guide exposure levels beyond the site boundary.

Site Evacuation - Evacuation of all people, except NMPNS personnel, from the exclusion area and evacuation of all nonessential personnel from the JAFNPP protected area via the security gate to the designated Remote Assembly Area or home.

Site Recovery Director - The Site Recovery Director is responsible for the management of recovery operations and other support functions. The Recovery Director is the senior company official who has the requisite authority, management ability and technical know-how to manage the nuclear power plant recovery operations. He has full authority to make required decisions regarding plant recovery without consulting higher management.

Spokesperson - ERO position whose primary responsibility is to act as the individual to coordinate all outgoing information to public officials, the news media and to the public.

State Emergency Operations Center - The New York State EOC is located in the substructure of the Public Safety Building No. 22, State Office Building Campus, Albany, New York. It is the State Command Post from which emergency operations will be directed and coordinated.

State Watch Center (SWC) - A center for receipt and dissemination of warnings of an attack upon the United States as well as for actual or impending natural or man-made disasters.

Station Emergency Director (SED) - The position designated in the emergency response organization that has the authority and responsibility to implement and administer the Emergency Plan at the station.

Technical Support Center (TSC) - The emergency facility activated and staffed by plant

FitzPatrick Annex Constellation October 2023 JF 7-8 EP-AA-1014 (Revision 5) management and other personnel during an emergency to utilize technical data and displays to provide direction for implementation of emergency procedures, and in-depth technical support to Control Room activities. Located on the second floor of the old administration building.

Technical Support Guidelines (TSGs) Guidelines providing information for use in implementing SAOGs.

Thyroid Dose and Thyroid Dose Rate - These terms have been replaced with Committed Dose Equivalent-Thyroid (CDE-Thyroid). CDE-Thyroid is defined as the internal dose that will be received by the thyroid over 50 years following an intake of radioactive materials plus the deep dose equivalent to the thyroid. For application offsite, dose to the child thyroid has been agreed upon by the New York State Dose Assessment Task Force. For application onsite to JAFNPP emergency workers, an adult thyroid dose is used.

Total Effective Dose Equivalent (TEDE) - The sum of the Deep Dose Equivalent (DDE) plus Committed Effective Dose Equivalent (CEDE) from inhalation components.

Unified Rascal Interface (URI) - Dose assessment software that is operated from a PC or the network that utilizes real-time met data inputs to project dose to members of the public for use in determining PARs. URI uses the NRCs RASCAL dose model and has a user plant specific front end and output format. URI has two modes - the first is a rapid assessment mode that is utilized by the Control Room, and the second is a detailed dose assessment mode that is utilized by the EOF.

Unrestricted Area - An area, access to which is neither limited nor controlled by the licensee.

Unusual Event (UE) - Events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection. No releases of radioactive material requiring offsite response or monitoring are expected, unless further degradation of safety systems occurs.

Web-based Emergency Operations Center (WebEOC) - A crisis information management software tool.

Whole Body Dose and Whole-Body Dose Rate - These terms have been replaced with Total Effective Dose Equivalent (TEDE). TEDE is defined as the sum of the deep dose equivalent (DDE) (external dose) and the inhalation components. The New York State Utilities Dose Assessment Task Force agrees with the recommendation of NUMARC in defining TEDE (previously external dose) as the DDE and any measurable thyroid CEDE components during the early phase of the emergency. The early phase is defined up to the first four days after an emergency. In this usage, the TEDE rate may be considered equivalent to a gamma dose rate reading on a fixed or portable survey instrument. Actual iodine, particulate and ground shine dose components should be factored in to the TEDE as soon as possible, although this is not required for initial TEDE determination. Default iodine to noble gas ratios may be used until actual data becomes available. Since the iodine contribution to TEDE is very small using the default ratio of approximately 1E-4, it can be omitted from the determination of TEDE.

FitzPatrick Annex Constellation October 2023 JF 7-9 EP-AA-1014 (Revision 5) 7.2 Acronyms AE Architect/Engineer ALARA As Low As Reasonably Achievable ANSI American National Standards Institute AOP Abnormal Operating Procedures ARM Area Radiation Monitor BRH New York State Bureau of Environmental Radiation Protection CDE Committed Dose Equivalent CEDE Committed Effective Dose Equivalent CWP County Warning Point DDE Deep Dose Equivalent DE Dose Equivalent DHS Department of Homeland Security DLR Dosimeter Legal Record DO Duty Officer DOE US Department of Energy EAL Emergency Action Level EAS Emergency Alert System ECCS Emergency Core Cooling System ED Emergency Director EmNET Emergency Management Network EMS Emergency Medical Service ENS Emergency Notification System EOC Emergency Operations Center EOF Emergency Operations Facility EOP Emergency Operating Procedures EP EOP Support Procedure EPA Environmental Protection Agency EPM Emergency Plant Manager EPIP Emergency Plan Implementing Procedure EPZ Emergency Planning Zone ERDS Emergency Response Data System

FitzPatrick Annex Constellation October 2023 JF 7-10 EP-AA-1014 (Revision 5)

ERON Emergency Response Organization Notification System ERPA Emergency Response Planning Area ETS Emergency Telecommunications System FEMA Federal Emergency Management Agency FRMAP Federal Radiological Monitoring and Assessment Program FSAR Final Safety Analysis Report IAP JAFFNPP Emergency Plan Immediate Action Procedure JAFNPP James A. FitzPatrick Nuclear Power Plant JIC Joint Information Center KI Potassium Iodide LCO Limiting Condition of Operation LOCA Loss of Coolant Accident MSIV Main Steam Isolation Valve NAWAS National Warning System NFPA Fire Prevention Association NFO Nuclear Facility Operator NMPNS Nine Mile Point Nuclear Station NRC Nuclear Regulatory Commission NSSS Nuclear Steam Supply System NWS National Weather Service NYSDOH New York State Department of Health NYSEOC New York State Emergency Operations Center NYSOEM New York State Office of Emergency Management NYSPIO New York State Public Information Officer NYSWC New York State Watch Center OCEMO Oswego County Emergency Management Office OCEOC Oswego County Emergency Operations Center OCNFLO Oswego County Nuclear Facility Liaison Officer OP Operating Procedures OSC Operational Support Center OSCR Onsite Safety Review Committee PA Public Address PAG Protective Action Guidelines

FitzPatrick Annex Constellation October 2023 JF 7-11 EP-AA-1014 (Revision 5)

PAR Protective Action Recommendation PASS Post Accident Sampling System PNS Prompt Notification System RCA Radiologically Controlled Area RECS Radiological Emergency Communications System RERP Radiological Emergency Response Plan SAOG Severe Accident Operating Guideline SBGT Standby Gas Treatment SEMO State Emergency Management Office SEOC State Emergency Operations Center SGTS Standby Gas Treatment System SM Shift Manager SOCA Security Owner Controlled Area SUNY State University of New York SWC State Watch Center TEDE Total Effective Dose Equivalent TLD Thermoluminscent Dosimeter TSC Technical Support Center TSG Technical Support Guidelines URI Unified Rascal Interface

FitzPatrick Annex Constellation APPENDIX A Emergency Plan Implementing Procedures October 2023 A1-1 EP-AA-1014 (Revision 5)

EMERGENCY PLAN IMPLEMENTING PROCEDURES PROCEDURE NUMBER PROCEDURE TITLE CORRESPONDING SECTION I APPENDIX EP-AA-114 EP-CE-114-100 Notifications Emergency Notifications 4.1.2 4.1. 2 FFP-1.4 Medical Emergencies 4.5.2 4.5.3 4.5.4 5.5 CC-AA-211 Fire Protection Program

5. 3. 3. 2 EP-AA-110-201 On Shift Dose Assessment

4. 2. 3.1 5.3.1 5.3.2 5.3. 3.1

5. 3. 3. 7 EP-AA-110-200 Dose Assessment 5.3.3

4. 2. 2. 2

4. 2. 3 4.4.2 5.3.1 5.3.2

5. 3. 3.1

5. 3. 3. 7 EP-AA-111 Emergency Classification and Protective Action Recommendations 5.3.3.9

4. 2. 3 4.4.2 EP-AA-114-F-08 JAF Release In Progress Determination Guidance 3.1 3.2

2. 3. 9

4. 2. 3 5.3.3.1

5. 3. 3. 7 EP-AA-112-500 Emergency Environmental Monitoring

4. 2. 2. 2

4. 2. 3. 3

5. 3. 3. 4

5. 3. 3. 5

5. 3. 3. 6

5. 3. 3. 7

5. 3. 3. 8 EP-AA-112-200-F-60 TSC Radiation Protection Manager Checklist

4. 2. 2.1 Appendix I EP-AA-113 Personnel Protective Actions 2.3.11 4.4.1.3 EP-AA-112-100-F-50 Shift Emergency Director Checklist 4.4.1.3 EP-AA-113 Personnel Protective Actions 3.2 6.4.1.1 6.4.1.2 7.4.3 EP-AA-113-F-06 JAF Assembly, Accountability, and Evacuation Guidelines 1.3.6 4.4.1.2 SP-01-05 Waste Water Sampling and Analysis

4. 2. 3. 3 EP-AA-112-300 Operations Support Center Activation and Operation 4.3 5.1. 3 5.7 EP-AA-113 Personnel Protective Actions 5.1. 4 5.4.1 5.4.2

FitzPatrick Annex Constellation APPENDIX A Emergency Plan Implementing Procedures October 2023 A1-2 EP-AA-1014 (Revision 5)

EMERGENCY PLAN IMPLEMENTING PROCEDURES PROCEDURE NUMBER PROCEDURE TITLE CORRESPONDING VOLUME 1 SECTION I APPENDIX EP-AA-113-F-33 JAF Assembly, Accountability, and Evacuation Guidelines Remote Assembly Area Activation Operations Checklist 5.4.4 EP-AA-112-700 Alternative Facility Operation 4.4.1.2 EP-AA-113 Personnel Protective Actions

2. 3.1 2.3.9 4.4.1.4

4. 5.1 Figure 4.1 EP-AA-112-600 Public Information Organization Activation and Operation 2.3.12 2.4.1 4.4.2 5.1. 2 5.1. 6 5.1. 7 5.1. 8 5.2.8 6.7 3.7.1 Appendix H EP-AA-112-600 Public Information Organization Activation and Operation 2.3.12 2.5.1 5.1. 6 6.7 3.7.1 3.7.2 3.7.3 Appendix H EP-AA-112-100F-57 ERONS Notification Details 2.2 2.3 Figure 2-2 Figure 3 -3 Table 2-1 4.1.1 EP-AA-113 Personnel Protective Actions

5. 3.1 4.4.1.4

4. 4. 2. 3 EP-AA-112-500 EP-AA-112-400-F-61 Emergency Environmental Monitoring Environmental Coordinator Checklist 4.2.1 4.2.2.1 5.3.1 5.3.2 5.3.3.1 EP-AA-112-200-F-61 Security Coordinator Checklist 2.3.11 4.4.1 5.9 6.2 EP-AA-112-400 EP-AA-112-400-F-58 Emergency Operations Facility Activation and Operation EOF Radiation Protection Manager Checklist

.4.1.2

. 5.2

.4.4

.6 EP-AA-115 EP-AA-112-400-F-58 Termination and Recovery EOF Radiation Protection Manager Checklist (CNG) 3.7

FitzPatrick Annex Constellation APPENDIX A Emergency Plan Implementing Procedures October 2023 A1-3 EP-AA-1014 (Revision 5)

EMERGENCY PLAN IMPLEMENTING PROCEDURES PROCEDURE NUMBER PROCEDURE TITLE CORRESPONDING VOLUME 1 SECTION I APPENDIX EP-AA-115 EP-AA-111-F-01 Termination and Recovery Event Termination Checklist 3.7 EP-AA-112-500 EP-AA-112-400-F-61 Emergency Environmental Monitoring During an Emergency Environmental Coordinator Checklist 5.1.5 5.3.2 EP-AA-112-400-F-58 RP-AA-210 EOF Radiation Protection Manager Checklist Dosimetry Issue, Usage, and Control 2.3.1 2.3.9 4.4.1.4 4.5.1 EP-AA-110-200 EP-AA-110-201 Dose Assessment On Shift Dose Assessment 5.3.3.7 EP-AA-110-301 Core Damage Assessment (BWR)

.1

.2

.2.1

.3.3.1 EP-AA-112 and T&RMs by facility Emergency Response Organization (ERO) Emergency Response Facility (ERF) Activation and Operation None Applicable EP-AA-122 Drills and Exercises 6.4 EP-AA-122 Drill and Exercise Program 6.4 EP-AA-112-100 Control Room Operations None Applicable EP-AA-112-400 Emergency Operations Facility (EOF) Operations 5.1. 5 EP-AA-112-200 Technical Support Center (TSC) Operations 5.1. 2 5.4.2 EP-AA-112-300 Operational Support Center (OSC) Operations 5.1. 3 EP-AA-112 Emergency Response Organization (ERO) Emergency Response Facility (ERF) Activation and Operation

2. 2 2.3

FitzPatrick Annex Constellation October 2023 B1-1 EP-AA-1014 (Revision 5)

Appendix B - JAFNPP Policy Statement Immediate response, assessment, and the implementation of protective and corrective measure pertaining to an emergency condition at the James A. FitzPatrick Nuclear Power Plant (JAFNPP) shall be the responsibility of the JAFNPP Emergency Director (SM/CED/SED). The individual who shall act in the capacity of Emergency Director is determined as follows:

Immediately upon the occurrence of an emergency, the Shift Manager on duty at the plant shall assume the role of Emergency Director. The Shift Manager shall continue to perform the functions of the Emergency Director as described in the Emergency Plan, until relieved of that responsibility by a designated Corporate and Station Emergency Director.

The Emergency Director (Shift Manager/ED, Corporate Emergency Director and Station Emergency Director) shall implement applicable portions of the Emergency Plan to prevent or mitigate the consequences of emergencies at the JAFNPP. T h e y shall have the authority to act on the behalf of the company in all matters concerning an emergency, at least until such time as the scope, severity and potential radiological consequences have been assessed, and the appropriate protective and mitigative actions have been implemented.

Following that critical period, but still with complete regard for health and safety, major decisions and commitments are the responsibility of corporate management.

Throughout the course of an emergency condition, all expertise and support available within the corporation shall be provided at the request of the JAFNPP Corporate Emergency Director

FitzPatrick Annex Constellation October 2023 C1-1 EP-AA-1014 (Revision 5)

Appendix C LETTERS OF AGREEMENT 1

SUNY Upstate Medical University University Hospital 750 East Adams Street Syracuse, NY 13210 on file in JAF EP Dept.

2 Oswego County Sheriff's Department 39 Churchill Road Oswego, NY 13126 on file in JAF EP Dept.

3 Oswego County Airport 40 Airport Drive Fulton, NY 13069 on file in JAF EP Dept.

5 EA Engineering, PC EA Science and Technology 6712 Brooklawn Parkway Suite 104 Syracuse, NY 13211 on file in JAF EP Dept.

6 Energy Solutions Suite 100, Center Point II 100 Center Point Dr.

Columbia, SC 29210 on file in JAF EP Dept.

7 Oswego Hospital 110 West 6th Street Oswego, NY 13126 on file in JAF EP Dept.

8 New York State Office of Emergency Management 1220 Washington Avenue Building 22, Suite 101 Albany, NY 12226-2251 on file in JAF EP Dept.

9 Framatome Inc.

3315 Old Forest Road P.O. Box 10935 Lynchburg, VA 24506-0935 24x7 AREVA NP Inc.

on file in JAF EP Dept.

FitzPatrick Annex Constellation October 2023 C1-2 EP-AA-1014 (Revision 5) 10 Oswego County Fire Coordinator 720 East Seneca Street Oswego, NY 13126 on file in JAF EP Dept.

11 Teledyne Brown Engineering (P.O.) for Bioassay Analysis and Radiochemical Analysis on file in JAF EP Dept.

12 Oswego County Emergency Management Office 200 North Second Street Fulton, NY 13069 on file in JAF EP Dept.

13 Department of Energy Oak Ridge Office P.O. Box 2008 Oak Ridge, Tennessee 37831 on file in JAF EP Dept.

14 Oswego County Ambulance Service 404 Ontario Street Fulton, New York 13069 on file in JAF EP Dept.

FitzPatrick Annex Constellation October 2023 D1-1 EP-AA-1014 (Revision 5)

APPENDIX D NEW YORK STATE PLAN AND PROCEDURES The New York State Plan and Procedures are maintained in the JAFNPP Emergency Planning Offices and the JAFNPP Emergency Operations Facility.

The New York State Emergency Preparedness Plan and Procedures received Federal approval on February 1, 1985. Attached is a FEMA Fact Sheet listing the chronology of events prior to approval.

FitzPatrick Annex Constellation October 2023 D1-2 EP-AA-1014 (Revision 5)

FEDERAL EMERGENCY MANAGEMENT AGENCY Region II I 26 Federal Plaza I New York, NY 10278 2/5/85 55-5 (For further information contact Marinne C. Jackson or Nancy Kelly (212) 264-8980)

FACT SHEET Off-Site Emergency Planning Chronology for Nine Mile Point Federal Emergency Management Agency - Region II Following the accident at Three Mile Island, the Federal Emergency Management Agency (FEMA) was assigned responsibility for reviewing and approving state and local emergency plans for nuclear power plants. Frank P. Petrone heads.FEMA Region II which covers New York, New Jersey, Puerto Rico and the Virgin Islands. Commercial nuclear power plants are operating in New York State at Ginna, Indian Point and Nine Mile Point.

The Nuclear Regulatory Commission (NRC), the licensing authority, reviews and approves the utilities' on-site emergency plans.

July 15, 1981: The State of New York submits off-site emergency plans for Nine Mile Point to the Director of FEMA Region II for review and approval. The plans consist of Oswego County's plan for the Emergency Planning Zone, (the area within a ten mile radius of the plant) and the state's site specific plan for assisting the county in the event of an accident. The Committee comprised of representatives from 8 federal agencies.

September 15, 1981: The first full scale radiological emergency exercise in New York State is conducted to assess the adequacy of the response plans for New York State and Oswego County. 22 federal observers evaluate the response of county and state personnel to a simulated accident at the plant. On September 30, FEMA issues a post exercise assessment of the exercise. The assessment identifies deficiencies which state and county officials target for improvement.

November 4, 1981: A public meeting is held in Oswego to answer questions about the off-site plans and receive recommendations for changes.

August 11, 1982: A 24 member federal observer team observes the second full scale exercise of off-site emergency response by New York State and Oswego County. On October 29, the post exercise assessment is issued for the exercise.

September 28, 1983: A 22 member off-site team observes a third full scale exercise. On October 12, federal observers evaluate a medical drill. The post exercise assessment evaluating both the full scale exercise and the medical drill is issued in December 1983.

(more)

September 28, 1984: FEMA Region II Director Petrone forwards the evaluation of the New York State and Oswego plans to FEMA National Office. The submission includes an

FitzPatrick Annex Constellation October 2023 D1-3 EP-AA-1014 (Revision 5) evaluation of the plans, the full-scale exercises and issues raised at the public meeting.

November 16, 1984: The alert and Notification System is activated and successfully tested.

February 1, 1985: Based on the evaluation by FEMA Region II Director Petrone and the review by FEMA headquarters staff, FEMA Associate Director Samuel W. Speck certifies to the Nuclear Regulatory Commission that the State and Oswego plans and preparedness and adequate to protect the health and safety of the public in the vicinity of Nine Mile Point.

This is both the first approval for radiological plans and the first approval of an alert and notification system in the New York State.

FitzPatrick Annex Constellation October 2023 E1-1 EP-AA-1014 (Revision 5)

APPENDIX E OSWEGO COUNTY PLANS AND PROCEDURES The Oswego County Plans and Procedures are maintained in the JAFNPP Emergency Planning Office and at the JAFNPP Emergency Operations Facility.

The Oswego County Radiological Emergency Preparedness Plan and Procedures received Federal approval on February 1, 1985. Attached is a FEMA Fact sheet listing the chronology of events prior to approval.

FitzPatrick Annex Constellation October 2023 E1-2 EP-AA-1014 (Revision 5)

FEDERAL EMERGENCY MANAGEMENT AGENCY Region II I 26 Federal Plaza I New York, NY 10278 2/5/85 55-5 For further information contact Marinne C. Jackson or Nancy Kelly (212) 264-8980)

FACT SHEET Off-Site Emergency Planning Chronology for Nine Mile Point Federal Emergency Management Agency - Region II Following the accident at Three Mile Island, the Federal Emergency Management Agency (FEMA) was assigned responsibility for reviewing and approving state and local emergency plans for nuclear power plants. Frank P. Petrone heads FEMA Region II which covers New York, New Jersey, Puerto Rico and the Virgin Islands. Commercial nuclear power plants are operating in New York State at Ginna, Indian Point and Nine Mile Point. The Nuclear Regulatory Commission (NRC), the licensing authority, reviews and approves the utilities' on-site emergency plans.

July 15, 1981: The State of New York submits off-site emergency plans for Nine Mile Point to the Director of FEMA Region II for review and approval. The plans consist of Oswego County's plan for the Emergency Planning Zone, (the area within a ten mile radius of the plant) and the state's site specific plan for assisting the county in the event of an accident. The Committee comprised of representatives from 8 federal agencies.

September 15, 1981: The first full scale radiological emergency exercise in New York State is conducted to assess the adequacy of the response plans for New York State and Oswego County.

22 federal observers evaluate the response of county and state personnel to a simulated accident at the plant. On September 30, FEMA issues a post exercise assessment of the exercise. The assessment identifies deficiencies which state and county officials target for improvement.

November 4, 1981: A public meeting is held in Oswego to answer questions about the off-site plans and receive recommendations for changes.

August 11, 1982: A 24-member federal observer team observes the second full scale exercise of off-site emergency response by New York State and Oswego County. On October 29, the post exercise assessment is issued for the exercise.

September 28, 1983: A 22 member off-site team observes a third full scale exercise. On October 12, federal observers evaluate a medical drill. The post exercise assessment evaluating both the full scale exercise and the medical drill is issued in December 1983.

(more)

FitzPatrick Annex Constellation October 2023 E1-3 EP-AA-1014 (Revision 5)

September 28, 1984: FEMA Region II Director Petrone forwards the evaluation of the New York State and Oswego plans to FEMA National Office. The submission includes an evaluation of the plans, the full-scale exercises and issues raised at the public meeting.

November 16, 1984:

The alert and Notification System is activated and successfully tested.

February 1, 1985: Based on the evaluation by FEMA Region II Director Petrone and the review by FEMA headquarters staff, FEMA Associate Director Samuel W. Speck certifies to the Nuclear Regulatory Commission that the State and Oswego plans and preparedness and adequate to protect the health and safety of the public in the vicinity of Nine Mile Point.

This is both the first approval for radiological plans and the first approval of an alert and notification system in the New York State.

FitzPatrick Annex Constellation October 2023 F1-1 EP-AA-1014 (Revision 5)

APPENDIX F TYPICAL SUPPORT COMPANIES AND ORGANIZATIONS NAME SERVICE DZ ATLANTIC Health Physics support personnel Energy Solutions Solidification of liquid waste, shipping cask rental, waste burial, tool and equipment decontamination Chicago Bridge & Iron (CB&I) A/E Engineering support General Electric Company Nuclear maintenance support EA Science and Technology Evaluation of environmental samples GEL Laboratories, LLC Liquid and gas sample analysis

FitzPatrick Annex Constellation October 2023 H1-1 EP-AA-1014 (Revision 5)

APPENDIX H PUBLIC INFORMATION PROGRAM

1. GENERAL In order to maintain the awareness of the public and the news media, JAFNPP has instituted a program of public information prior to and during an emergency.

2. PRE-EMERGENCY INFORMATION JAFNPP in conjunction with the NMPNS Staff, the NYSOEM, and OCEMO has established a public information program for the permanent and transient population within the plume exposure EPZ. Information is provided in several forms: brochure, signs, and telephone book insert.

a. Information Brochure/Calendar An information brochure/calendar containing radiological emergency response information and instructions has been prepared and mailed to all residents of the plume exposure EPZ. It presents the following information:

1. General Information

2. Radiological health

3. Public notification systems

4. Courses of action

5. General preparedness

6. Sheltering

7. General evacuation

8. Relocation to a public shelter or someone's home

9. Bus information (including pick-up points) for transit-dependent people

10. Obtaining special assistance

11. School evacuation

12. Maps describing ERPAs, evacuation routes, location of reception centers and bus pickup locations

13. Phone numbers for further information

14. KI Information Brochures/calendar shall be updated and mailed to all residences in the plume exposure EPZ annually.

FitzPatrick Annex Constellation October 2023 H1-2 EP-AA-1014 (Revision 5)

APPENDIX H PUBLIC INFORMATION PROGRAM

b. Signs In order to provide information to people visiting the area who may not have seen the public information brochure, emergency information signs have been prepared for posting in public places. Areas to be posted have been selected by the OCEMO. The signs present a summary of the key information contained in the brochure described above. These signs shall be updated annually.

c. Telephone Book Information Inserts Emergency information is also provided to the resident and transient population through inserts in telephone books covering the plume exposure EPZ. The information provided is the same as that provided on the sign and shall be updated annually, or as updated by the phone book publication. Inserts are provided in many of the local telephone books.

3. PUBLIC INFORMATION DURING EMERGENCIES During an emergency, the Spokesperson shall provide information to the news media and the public.

The designated location for the dissemination of coordinated information regarding JAFNPP, State and County emergency response to the news media is the Joint Information Center located on Co. Rt. 176 in the Town of Volney. It shall be activated during an Alert, a Site Area Emergency and General Emergency arid may be activated during an Unusual Event.

The Joint Information Center provides working space and communications for State, County, Federal, and company media relations staff and the news media. It is equipped for large briefings and has the capability for the recording of those briefings.

The Joint Information Center is also the location where public inquiry is provided through off-air monitoring of radio and television broadcasts and the use of staffed telephones which the public can call. Response to media inquiries shall be handled through telephones at the Joint Information Center.

FitzPatrick Annex Constellation October 2023 I1-1 EP-AA-1014 (Revision 5)

APPENDIX I EMERGENCY EQUIPMENT KITS TYPE DESCRIPTION NUMBER Fire Cabinet Fire Brigade equipment 4

Ambulance Kit Equipment for handling contaminated persons 1

Rescue Kit Rescue Equipment 1

Downwind Survey Kit (OSC)

Offsite radiological monitoring equipment 2

Emergency Operations Facility Survey/Reentry Kit Supplies for operation of EOF and offsite monitoring 1

JAF Decontamination Kit Supplies for personnel decontamination 1

OSC Emergency Kit Emergency Equipment 1

Emergency Survey Kit Offsite and onsite radiological monitoring equipment 1

Medical Trauma Kit First Aid Team supplies 5

Security Building Kit Protective equipment 1

Control Room Inventory Emergency plans and dose assessment material 1

Technical Support Center Inventory Supplies for operation of TSC 1

PASS Cabinet Entry equipment for obtaining PASS sample 1 Oswego Hospital Emergency Cabinet Equipment for handling contaminated persons 1

EOF Decontamination Kit Supplies for personnel decontamination 1

EOF Inventory Supplies for operation of EOF 1

FitzPatrick Annex Constellation October 2023 J1-1 EP-AA-1014 (Revision 5)

APPENDIX J SUPPORTING DOCUMENTS

1. James A. FitzPatrick Nuclear Power Plant

a. JAFNPP Emergency Plan and Implementing Procedures

b. JAFNPP Final Safety Analysis Report (FSAR)

c. Radiation Protection Department Procedures and Programs

d. Administrative Procedures

e. Fire Protection and Prevention Procedures

f. Security I Safeguards Implementing Procedures

g. Technical Specifications

h. Operating and Special Procedures

i. Chemistry Department Procedures

j. Nuclear Management Manual Policies & Procedures

2. State of New York

a. New York State Radiological Emergency Preparedness Plan and Procedures

3. Oswego County

a. Oswego County Radiological Emergency Preparedness Plan and Procedures

b. Oswego Hospital Plan: Decontamination and Treatment of the Radioactively Contaminated Patient at Oswego Hospital

4. Nine Mile Point Nuclear Station

a. Nine Mile Point Nuclear Station Emergency Plan and Procedures

b. Constellation Alert and Notification System Maintenance and Operations Procedures

5. Onondaga County

a. University Hospital Procedures

b. Onondaga County Radiological Emergency Response Host Plan

FitzPatrick Annex Constellation October 2023 L1-1 EP-AA-1014 (Revision 5)

APPENDIX L NUREG-0654 / FEMA-REP-1 CROSS REFERENCE PURPOSE: Appendix L provides a cross reference for locating NUREG-0654 planning standards within the James A. FitzPatrick Emergency Plan. This cross reference will facilitate timeliness in reviewing which sections of the JAF Emergency Plan satisfy applicable planning standards established in NUREG-0654.

NUREG-0654 Section Evaluation Criteria JAFNPP EMERGENCY PLAN A.1.a Overall response organization identification

- State, Local, Federal and Private Organizations Section 2.4.2 Section 2.4.3 Section 2.5.1 Section 2.5.2 Section 2.6 Appendix N A.1.b Organizational concept of operations Section 2.2 Section 2.3 Section 2.4 Section 2.5 Section 2.6 A.1.c Organizational interrelationships

- block diagram Figure 2-1 Figure 2-2 Figure 3-3 A.1.d Identification of individual in charge Section 2.3.1 Section 2.4.1 Appendix B A.1.e 24-hour response capability (including communications)

Section 2.1 Section 2.2 Section 2.3 Section 2.4.1 Section 4.5 Section 5.2.4 A.2.a Specification of functions and responsibilities of key individuals N/A*

A.2.b Legal basis for authority N/A*

N/A - Not applicable applies throughout Appendix L

FitzPatrick Annex Constellation October 2023 L1-2 EP-AA-1014 (Revision 5)

NUREG-0654 Section Evaluation Criteria JAFNPP EMERGENCY PLAN A.3 Written agreements referring to concept of operations Section 2.2 Section 4.1.2 Section 4.5.3 Section 4.5.4 Section 6.5.2 A.4 Provisions for 24-hour operations/continuity of resources EP-AA-1000, Section B Section 2.2 Section 2.4 B.1 Onsite Emergency Organization EP-AA-1000, Section B Appendix 5 B.2 Designation of Emergency Coordinator EP-AA-1000, Section B B.3 Emergency Coordinator - line of succession EP-AA-1000, Section B Section 3.7.1 Appendix D B.4 Functional responsibilities of Emergency Coordinator EP-AA-1000, Section B EP-AA-1000, Appendix 5 B.5 Titles and major tasks of emergency positions EP-AA-1000, Section B EP-AA-1000, Appendix 5 B.6 Interfaces between and among emergency organizations - block diagram Figure 2-1 B.7 Augmentation of plant staff EP-AA-1000, Section B EP-AA-1000, Appendix 5 B.7.a Logistics support Section 2.4 Section 3.7 B.7.b Technical support Section 3.7 Figure 3-3 B.7.c Management interface with governmental authorities Section 2.2 Section 2.3 B.7.d Release of information to news media EP-AA-1000, Section B Section 3.7 Appendix H

FitzPatrick Annex Constellation October 2023 L1-3 EP-AA-1014 (Revision 5)

NUREG-0654 Section Evaluation Criteria JAFNPP EMERGENCY PLAN B.8 Contractor and private organization assistance / staff augmentation Section 2.2.2 Section 2.3.3 Appendix C Appendix F B.9 Emergency services provided by local agencies Section 2.2.2 Section 4.5 Appendix C C.1.a Incorporation of Federal response capability into Plan - request for Section 2.3.2 Section 4.1.2 C.1.b Federal resources expected Section 2.3.2 Appendix C C.1.c Resources to support Federal response Appendix N C.2.a Offsite EOF representative N/A*

C.2.b Licensee representative at offsite locations EP-AA-1000, Section B C.3 Identification of radiological laboratories Section 2.2.3 Section 4.2.2.2 Section 5.3.1 Section 5.3.2 C.4 Identification of organizations to provide assistance Section 2.4.3 Appendix C Appendix F D.1 Establishment of emergency classification/emergency action Section 3.1 D.2 Initiating conditions for postulated accidents in FSAR Section 3.1 Section 3.2 D.3 State/local emergency l

ifi ti h

N/A*

D.4 Offsite procedures providing emergency actions N/A*

FitzPatrick Annex Constellation October 2023 L1-4 EP-AA-1014 (Revision 5)

NUREG-0654 Section Evaluation Criteria JAFNPP EMERGENCY PLAN E.1 Procedures to describe notification of response organizations Section 4.1 E.2 Establishment of personnel alerting, notifying, and mobilizing procedures Section 4.1.1 E.3 Contents of initial emergency messages from Licensee Section 4.1. 2 E.4.a-n Contents of follow-up messages from Licensee Section 4.1. 2 E.5 Off site system to disseminate message N/A E.6 Establishment o f means to notify public in EPZ Section 5.2.8 E.7 Provisions for written messages to notify the public Section 7.3.12 Appendix H F.1.a 24-hour primary and backup provision for notification and activation of local emergency network Section 5.2.3 Section 5.2.4.1 Section 5.2.5 F.1.b Primary and backup communications with contiguous State/local governments Section 4.1. 2 Section 5.2.3 Section 5.2.4.1 F.1.c Primary and backup communications with Federal organizations Section 4.1. 2 Section 5.2.3 Section 5.2.4.2 Section 5.2.4.3 F.1.d Primary and backup communications between nuclear facility, State/local EOCs and radiological monitoring teams Section 5.2.3 Section 5.2.4.1 Section 5.2.5 F.1.e Primary and backup alerting of emergency personnel Section 4.1.1 Section 4.1.2

FitzPatrick Annex Constellation October 2023 L1-5 EP-AA-1014 (Revision 5)

NUREG-0654 Section Evaluation Criteria JAFNPP EMERGENCY PLAN F.1.f Provision for communication by Licensee to NRC, EOF, and radiation monitoring team Section 4.1.2 Section 5.2.3 Section 5.2.4.2 Section 5.2.4.3 Section 5.2.5 F.2 Primary and backup communications link to medical support facilities Section 4.5.3 Section 4.5.4 Section 5.2.3 Section 5.2.5 F.3 Periodic testing of communications system Section 6.4 Section 6.6 G.l.a-d Coordinated periodic dissemination of information to the public Section 6.7.1 Section 6.7.2 Appendix H G.2 Provisions for public information program Section 6.7.1 Section 6.7.4 Appendix H G.3.a Physical location for use by news media Section 5.1.6 Appendix H G.3.b SUPP 1, G.3 Space for news media at EOF Section 5.1.6 G.4.a SUPP 1, G.4.a Designation of spokesperson Section 5.1.6 Section 3.7.1 G.4.b SUPP 1, G.4.b Exchange of information among spokespersons Section 5.1.6 Appendix H G.4.c SUPP 1, G.4.c Coordinated arrangements for dealing with rumors Section 7.1.6 Section 6.7.3 G. 5 SUPP 1, G.5 Annual coordinated programs for the news media Section 6.7.4 Appendix H H.1 Establishment of TSC and osc Section 5.1. 2 Section 5.1. 3 Section 5.1.4 Section 5.1.10 H.2 Establishment of EOF for Licensee Emergency activities Section 5.1. 5

FitzPatrick Annex Constellation October 2023 L1-6 EP-AA-1014 (Revision 5)

NUREG-0654 Section Evaluation Criteria JAFNPP EMERGENCY PLAN H.3 Establishment of EOC for response functions N/A*

H.4 Provisions for timely activation and staffing of facilities EP-AA-1000, Section B Section 4.1.1 Section 5.1 H.5.a Identification of geophysical phenomena monitors Section 5.3.3.3 Section 5.3.3.7 H.5.b Identification of radiological monitors Section 4.5.1 Section 4.5.2 Section 5. 3. 3.1 Section 5.3.3.8 H.5.c Identification of process monitors Section 5.3.3.9 H.5.d Identification of fire detectors Section 5.3.3.2 H.6.a Acquisition of data from geophysical phenomena monitors Section 5.3.3.3 Section 5.3.3.7 H.6.b Acquisition of data from radiological monitors Section 4.5.1 Section 5.3.3.1 Section 5.3.3.4 Section 5.3.3.5 Section 5.3.3.6 H.6.c Acquisition of data from laboratory facilities Section 5.3.1 Section 5.3.2 H.7 Provisions for off-site monitoring equipment Section 4.2.2.2 Section 5.3.3.8 H.8 Provisions for meteorological instrumentation and procedures Section 5.3.3.7 H.9 Provisions for onsite Operations Support Center Section 5.1. 3 H.10 Provisions to inspect, inventory, and operationally check equipment Section 6.6 H.11 Identification of emergency equipment Appendix I

FitzPatrick Annex Constellation October 2023 L1-7 EP-AA-1014 (Revision 5)

NUREG-0654 Section Evaluation Criteria JAFNPP EMERGENCY PLAN H.12 Establishment of central point for receipt/analysis of field monitoring data Section 5.1. 5 Section 5.3.2 I.1 Identification of plant system and effluent values characteristic of off-normal conditions Section 3.1 I. 2 Onsite capability to provide initial values and assessment throughout accident Section 5.3.3.1 I. 3.a Establishment of methods and techniques to determine source term of releases Section 5.3.3.1 I.3.b Establishment of methods and techniques to determine magnitude of releases Section 4.2.3 I.4 Establishment of relationship between effluent monitor readings and exposures Section 5.3.3.1 I. 5 Capability to acquire and evaluate meteorological information Section 5.3.3.7 I. 6 Methodology for determining release rate/projected doses Section 4.2.3 I. 7 Capability and resources for field monitoring within EPZ Section 4.2.2.2 Section 4.2.3.3 Section 5.3.3.4 Section 5.3.3.5 Section 5.3.3.6 Section 5.3.3.8 I. 8 Provisions for methods, equipment and expertise to make rapid assessments of radiological hazards Section 4.2.2 Section 4.2.3 Section 5.3.3.8 I. 9 Capability to detect and measure radioiodine concentration in EPZ as low as lE-7 µCi/cc Section 4.2.2.2

FitzPatrick Annex Constellation October 2023 L1-8 EP-AA-1014 (Revision 5)

NUREG-0654 Section Evaluation Criteria JAFNPP EMERGENCY PLAN I.10 Establishment of means for relating measured parameters to dose rates Section 4.2.3 I.11 Arrangements to track airborne plume using Federal and State N/A*

J.1. a-d Means to warn onsite individuals in controlled areas Section 4.4.1 J.2 Provisions for evacuation routes and transportation for onsite individuals Section 4.4.1.2 J.3 Provisions for radiological monitoring of people evacuated from site Section 4.4.1.2 Section 5.4.4 Section 5.6 J.4 Provisions for decontamination facility for onsite personnel Section 5.4.1.2 Section 5.4.4 Section 5.6 J.5 Provisions for onsite accountability Section 4.4.1.3 J.6.a Provisions for respiratory protection Section 4.4.1.4.d J.6.b Provisions for protective clothing Section 4.4.1.4.a J.6.c Provisions for radioprotective drugs Section 4.4.1.4.c Section 4.4.2.3 J.7 Mechanism for recommending protective actions to State and local authorities Section 3.1 Section 2.3.1 Section 4.4.2 Figure 3.1 J.8 Inclusion of evacuation time estimates in Licensee's plan Appendix K J.9 State/local capability for implementing protective measures N/A*

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NUREG-0654 Section Evaluation Criteria JAFNPP EMERGENCY PLAN J.10.a Inclusion of maps showing evacuation routes, monitoring locations, and relocation centers Figure 4.2 Figure 4.9 Figure 5.2 Figure 5.3 Figure 5.4 Figure 5.6 Appendix H J.10.b Inclusion of maps showing population distribution around the facility Figure 1.4 Figure 4.3 Appendix K J.10.c Means for notifying all segments of the population Section 5.2.8 Appendix H J.10.d-l State/local plans to implement various protective measures N/A*

J.10.m Basis for choice of recommended protective actions Section 4.4.2 J.11 State protective measures for ingestion pathway N/A*

J.12 State/local plans for registration and monitoring of evacuees N/A*

K.1.a-g Establishment of onsite exposure guidelines consistent Section 4.4.1 Section 4.5.1 Figure 4.1 K.2 Onsite radiation protection program to be implemented during emergencies EP-AA-1000, Section B Section 4.4.1.4 Section 4.5.1 K.3.a-b Provisions for 24-hour capability to determine emergency personnel doses Section 4.5.1 K.4 State/local decision chain for authorizing exposures in excess of EPA PAGs N/A*

K.5.a Specification of action levels for decontamination Section 4.5.2 K.5.b Means for radiological decontamination of emergency personnel Section 4.5.2 Section 5.6

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NUREG-0654 Section Evaluation Criteria JAFNPP EMERGENCY PLAN K.6.a Provisions for area access control Section 4.4.1 K.6.b Provisions for drinking water and food contamination control Section 4.4.1.4.a and b K.6.c Criteria for permitting return of areas to normal use Section 4.4.1.4.a K. 7 Provisions for decontaminating relocated onsite personnel Section 4.4.1.2 Section 5.4.4 Section 5.6 L.1 Arrangements for local and backup hospital and medical services Section 4.5.3 Section 4.5.4 Appendix C L.2 Provision for onsite first aid capability Section 5.5 L.3 State listing of medical support facilities N/A*

L.4 Arrangements for transport of victims of radiological accidents Section 4.5.3 M.1 Development of plans for reentry and recovery Section 3.7.4 M.2 Listing of individuals filling positions in recovery organization Section 3.7.1 Section 3.7.2 Figure 3-3 M.3 Means to inform organization that recovery is initiated Section 3.7 Section 3.7.1 M.4 Establishment of method to estimate total population exposure Section 3.7.2 N.1.a Provisions for periodic exercises Section 6.4 N.1.b Provisions for exercise critique/varied scenarios Section 6.4 N.2.a-e Provisions for drills Section 6.4

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NUREG-0654 Section Evaluation Criteria JAFNPP EMERGENCY PLAN N.3.a-f Description of components of drills and exercises Section 6.4 N.4 Provisions for observers/

critiques Section 6.4 N. 5 Provisions for exercise corrective actions Section 6.4 0.1.a Provisions for site specific training for offsite emergency organizations Section 6.2 0.1.b Provisions for training mutual aid organizations N/A*

0.2 Onsite training program/

practical drills Section 6.2 0.3 Training for Licensee first aid teams Section 6.2 0.4.a-j Training and retraining programs for personnel implementing response plan Section 6.2 0.5 Initial training and retraining of personnel Section 6.1 P.1 Training of individuals responsible for the planning effort Section 6.1 Section 6.2 Section 6.3 P.2 Identification of individual responsible for planning Section 6.1 P.3 Designation of Emergency Planning Coordinator Section 6.1 P.4 Annual update of plan and agreements Section 8.5.1 Section 6.5.2 P.5 Distribution of approved plans Section 6.5 P.6 Detailed listing of support plans Appendix J P.7 Procedures required to implement the plan Appendix A

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NUREG-0654 Section Evaluation Criteria JAFNPP EMERGENCY PLAN P.8 Plan table of contents/

cross reference Appendix L Table of Contents P.9 Annual independent review of emergency preparedness program Section 6.5.3 P.10 Quarterly update of telephone numbers Section 6.6 EALs were revised in accordance with NEI 99-01 Rev. 6, Methodology for Development of Emergency Action Levels. The EALs are not included in the NUREG-0654 Cross Reference.

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APPENDIX N TYPICAL FEDERAL SUPPORT RESOURCES

1.

AIRFIELDS

a. Greater Rochester International Airport 1200 Brooks Avenue Rochester, NY 14624 Tel. 585/753-7001

b. Oswego County Airport 40 Airport Drive Fulton, NY 13069 Tel. 315/591-9130

c. Griffiss International Airport 592 Hanger Road Suite 200 Rome, NY 13441 Tel. 315/736-4171

d. Syracuse Hancock International Airport 1000 Colonel Eileen Collins Boulevard Syracuse, NY 13212 Tel. 315/454-3263 (Commissioner of Aviation)

Tel. 315/455-3800 (Air Traffic Control)

e. Watertown International Airport 22564 Airport Drive Dexter, NY 13634 Tel. 315/786-6000 Fax: 315/639-3990

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2.

COMMAND POSTS

a. JAFNPP Emergency Operations Facility 2262 State Route 176 Fulton, NY 13069 Tel. 315/593-5700

b. JAFNPP Technical Support Center JAFNPP 268 Lake Road East Lycoming, NY 13093 Tel. 315/349-6710

c. Joint Information Center 10 Airport Drive Fulton, NY 13069 Tel. 315-592-3700

d. New York State Emergency Operations Center New York State Office of Emergency Management Public Security Building, State Campus Albany, NY 12226 Tel. 518/292-2200 FAX. 518/322-4982

e. Oswego County Emergency Operations Center Oswego County Office Building Annex 200 North Second Street Fulton, NY 13069 Tel. 315/591-9150

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3. TELEPHONE SYSTEMS IN PLANT VICINITY

a. WINDSTREAM COMMUNICATIONS Tel. 866/990-3282 (Repair) and EARTHLINK BUSINESS (JAF Intermediate Provider) Tel. 800/883-9177 (Repair)

b. VERIZON Tel. 800/837-4966 (Repair)

c. AT&T Tel 800/222-0400 (Repair) 800/222-3000 (Repair)

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APPENDIX O NON-REGULATORY COMMITMENTS

1. Commitment 1 Annual agency funding for the New York Nuclear Assets (i.e., nuclear facility) consistent with statutory obligations will be continued to address emergency management and response throughout the period of their respective operations. Constellation Energy Generation, LLC (formally Exelon Generation Company, LLC) agrees to maintain staffing at the emergency operations facilities in New York commensurate with the various stages of decommissioning until the fuel at the New York Nuclear Asset associated with that emergency operations facility has been removed from its pool to its ISFSI.

Source Document: NY State EP Agreement - Commitment FI-21-009 Date of Commitment: April 17, 2033 (This is a tentative date for tracking purposes and can be adjusted as needed.)

2. Commitment 2 In the event Constellation Energy Generation, LLC (formally Exelon Generation Company, LLC) should find more efficient alternatives to the existing emergency operations facilities that also ensure at least the same level of safety at the New York Nuclear Assets, Constellation Energy Generation, LLC agrees to meet and confer with the State and Local Governmental Entities with which these matters have previously been presented. At such meeting, Constellation Energy Generation, LLC will identify these alternatives for DPS Staff to consider for acceptance prior to their implementation.

Source Document: NY State EP Agreement - Commitment FI-21-009 Date of Commitment: April 17, 2033 (This is a tentative date for tracking purposes and can be adjusted as needed.)

3. Commitment 3 Following the permanent Cessation and Certification of operation of a New York Nuclear Asset, payments to address emergency preparedness will be made in accordance with applicable NY State law. In addition, emergency management and response efforts with State and Local Governmental Entities will be continued throughout the decommissioning process commensurate with the various stages of decommissioning. The structure of these efforts will be discussed with NYDHSES and coordinators in Oswego County for the Oswego sites (i.e., James A. FitzPatrick and Nine Mile Point) and Wayne and Monroe Counties for the Ginna site as the units near the End of Licensed Life. Upon review with these entities, areas to be considered upon the permanent Cessation and Certification of operation of each New York Nuclear Asset may include:

FitzPatrick Annex Constellation October 2023 O1-2 EP-AA-1014 (Revision 5) o Emergency Response Contacts o Access to Meteorological and Other Data o Meetings o Communications Hardware o Exercises o Public Alerts o Public Communications o Training o Fire Systems Source Document: NY State EP Agreement - Commitment FI-21-009 Date of Commitment: April 17, 2033 (This is a tentative date for tracking purposes and can be adjusted as needed.)

JAFP-23-0064, Emergency Plan Document Revision

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