ML050610029

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Enclosure 1 - Emergency Planning - Early Site Permit (ESP) Application Options
ML050610029
Person / Time
Site: Nuclear Energy Institute
Issue date: 03/01/2005
From: Beckner W
Division of Regulatory Improvement Programs
To: Heymer A
Nuclear Energy Institute
SCOTT M L, NRR/DRIP/RNRP, 301-415-1421
Shared Package
ML050610023 List:
References
NUREG-0654
Download: ML050610029 (55)


Text

1 ENCLOSURE 1 E M E R G E N C Y P L A N N I N G Early Site Permit (ESP) Application Options DRAFT (03/01/05)

ESP-Options-030105.doc Complete & Integrated Plans (NUREG-0654/FEMA-REP-1)

ESP Major Features (Supplement 2 to NUREG-0654)

ESP Complete & Integrated Plans (COL Action Items)

COL Application (EP ITAAC)

A. Assignment of Resp. - Organiza-tion Control - 10 CFR 50.47(b)(1)

A.1.a Each plan shall identify the State, local, Federal and private sector organizations (including utilities), that are intended to be part of the overall response organization for Emergency Planning Zones. (See Appendix 5)

A.1 Each application shall identify the State, local, Federal and private sector organizations (including utilities) that are intended to be part of the overall response organization for EPZ.

A.1.b Each organization and suborganization having an operational role shall specify its concept of operations, and its relationship to the total effort.

A.1.c Each plan shall illustrate these interrelationships in a block diagram.

A.1.d Each organization shall identify a specific individual by title who shall be in charge of the emergency response.

A.1.e Each organization shall provide for 24-hour per day emergency response, including 24-hour per day manning of communications links.

A.1.e The licensee has provided for 24-hour per day emergency response, including 24-hour per day staffing of communication links. [Licensee Specific (LS)]

  • A.1.e The licensee has confirmed that the State and local organizations have provided for 24-hour per day emergency response, including 24-hour per day staffing of communication links. [Site Specific (SS)] [* = offsite]

2 Complete & Integrated Plans (NUREG-0654/FEMA-REP-1)

ESP Major Features (Supplement 2 to NUREG-0654)

ESP Complete & Integrated Plans (COL Action Items)

COL Application (EP ITAAC)

A.2.a Each organization shall specify the functions and responsibilities for major elements and key individuals by title, of emergency response, including the following: Command and Control, Alerting and Notification, Communications, Public Information, Accident Assessment, Public Health and Sanitation, Social Services, Fire and Rescue, Traffic Control, Emergency Medical Services, Law Enforcement, Transportation, Protective Response (including authority to request Federal assistance and to initiate other protective actions), and Radiological Exposure Control. The description of these functions shall include a clear and concise summary such as a table of primary and support responsibilities using the agency as one axis, and the function as the other. (See Section B for licensee)

A.2.a Each organization shall identify the functions and responsibilities for major elements of emergency response, such as Command and Control, Alerting and Notification, Communications, Public Information, Accident Assessment, Public Health and Sanitation, Social Services, Fire and Rescue, Traffic Control, Emergency Medical Services, Law Enforcement, Transportation, Protective Response, and Radiological Exposure Control. The description of these functions may be shown in a table of primary and support responsibilities.

A.2.b Each plan shall contain (by reference to specific acts, codes or statutes) the legal basis for such authorities.

A.2.b Each application shall contain (by reference to specific acts, codes or statutes) the legal basis for such authorities.

A.3 Each plan shall include written agreements referring to the concept of operations developed between Federal, State, and local agencies and other support organizations having an emergency response role within the Emergency Planning Zone. The agreements shall identify the emergency measures to be provided and the mutually acceptable criteria for their implementation, and specify the arrangements for exchange of A.3 Each application shall include a description of contacts and arrangements pertaining to the concept of operations developed between Federal, State, and local agencies and other support organizations having an emergency response role within the EPZs. Any written letters of agreement should be included. As signature page in the application may be appropriate for some organizations to signify their agreement.

3 Complete & Integrated Plans (NUREG-0654/FEMA-REP-1)

ESP Major Features (Supplement 2 to NUREG-0654)

ESP Complete & Integrated Plans (COL Action Items)

COL Application (EP ITAAC) information. These agreements may be provided in an appendix to the plan or the plan itself may contain descriptions of these matters and a signature page in the plan may serve to verify the agreements. The signature page format is appropriate for organizations where response functions are covered by laws, regulations or executive orders where separate written agreements are not necessary.

A.4 Each principal organization shall be capable of continuous (24-hour) operations for a protracted period.

The individual in the principal organization who will be responsible for assuring continuity of resources (technical, administrative, and material) shall be specified by title.

A.4 The licensee is capable of continuous (24-hour) operations for a protracted period. [LS]

  • A.4 The licensee has confirmed that the State and local organizations are capable of continuous (24-hour) operations for a protracted period. [SS]

B. Onsite Emergency Organization 10 CFR 50.47(b)(2)

B.1 Each licensee shall specify the onsite emergency organization of plant staff personnel for all shifts and its relation to the responsibilities and duties of the normal staff complement.

B.2 Each licensee shall designate an individual as emergency coordinator who shall be on shift at all times and who shall have the authority and responsibility to immediately and unilaterally initiate any emergency actions, including providing protective action recommendations to authorities responsible for implementing offsite emergency measures.

4 Complete & Integrated Plans (NUREG-0654/FEMA-REP-1)

ESP Major Features (Supplement 2 to NUREG-0654)

ESP Complete & Integrated Plans (COL Action Items)

COL Application (EP ITAAC)

B.3 Each licensee shall identify a line of succession for the emergency coordinator position and identify the specific conditions for higher level utility officials assuming this function.

B.4 Each licensee shall establish the functional responsibilities assigned to the emergency coordinator and shall clearly specify which responsibilities may not be delegated to other elements of the emergency organization. Among the responsibilities which may not be delegated shall be the decision to notify and to recommend protective actions to authorities responsible for offsite emergency measures.

B.5 Each licensee shall specify the positions or title and major tasks to be performed by the persons to be assigned to the functional areas of emergency activity. For emergency situations, specific assignments shall be made for all shifts and for plant staff members, both onsite and away from the site. These assignments shall cover the emergency functions in Table B-1 entitled, Minimum Staffing Requirements for Nuclear Power Plant Emergencies. The minimum on-shift staffing levels shall be as indicated in Table B-1. The licensee must be able to augment on-shift capabilities within a short period after declaration of an emergency.

This capability shall be as indicated in Table B-1.

B.5 The licensees minimum on-shift staffing levels are as indicted in Table B-1 of NUREG-0654/FEMA-REP-REP-1 (or equivalent). The licensee is able to augment on-shift capabilities within a short period after declaring an emergency, as shown in Table B-1.

[Unit Specific (US)]

5 Complete & Integrated Plans (NUREG-0654/FEMA-REP-1)

ESP Major Features (Supplement 2 to NUREG-0654)

ESP Complete & Integrated Plans (COL Action Items)

COL Application (EP ITAAC)

B.6 Each licensee shall specify the interfaces between and among the onsite functional areas of emergency activity, licensee headquarters support, local services support, and State and local government response organization. This shall be illustrated in a block diagram and shall include the onsite technical support center and operational support (assembly) center and the licensees near-site Emergency Operations Facility (EOF).

B.1 Each applicant shall identify the interfaces between and among the onsite functional areas of emergency activity, local services support, and State and local government response organization. This may be illustrated in a block diagram.

B.7 Each licensee shall specify the corporate management, administrative, and technical support personnel who will augment the plant staff as specified in the table entitled Minimum Staffing Requirements for Nuclear Power Plant Emergencies, (Table B-1) and in the following areas:

a. logistics support for emergency personnel, e.g., transportation, communications, temporary quarters, food and water, sanitary facilities in the field, and special equipment and supplies procurement;
b. technical support for planning and reentry/recovery operations;
c. management level interface with government authorities; and
d. release of information to news media during an emergency (coordinated with governmental authorities).

B.7 The licensee is able to augment plant staff, as specified in Table B-1 of NUREG-0654/FEMA-REP-1 (or equivalent), with corporate management, administrative, and technical support personnel. [LS]

6 Complete & Integrated Plans (NUREG-0654/FEMA-REP-1)

ESP Major Features (Supplement 2 to NUREG-0654)

ESP Complete & Integrated Plans (COL Action Items)

COL Application (EP ITAAC)

B.8 Each licensee shall specify the contractor and private organizations who may be requested to provide technical assistance to and augmentation of the emergency organization.

B.9 Each licensee shall identify the services to be provided by local agencies for handling emergencies, e.g., police, ambulance, medical, hospital, and fire-fighting organizations shall be specified. The licensee shall provide for transportation and treatment of injured personnel who may also be contaminated. Copies of the arrangements and agreements reached with contractor, private, and local support agencies shall be appended to the plan. The agreements shall delineate the authorities, responsibilities, and limits on the actions of the contractor, private organization, and local services support groups.

B.2 Each applicant shall identify the services to be provided by local agencies for handling emergencies (e.g., police, ambulance, medical, hospital, and fire-fighting organizations). A description of the arrangements involving these services shall be included in the plan. Any written letters of agreement should also be included.

C. Emergency Response Support and Resources - 10 CFR 50.47(b)(3)

C.1 The Federal government maintains in-depth capability to assist licensees, States and local governments through the Federal Radiological Emergency Response Plan (FRERP). Each State and licensee shall make provisions for incorporating the Federal response capability into its operation plan, including the following:

C.1 The Federal Government maintains in-depth capability to assist licensees, States and local governments through the Federal Radiological Emergency Response Plan [FRERP].

Each State and ESP applicant shall make provision for requesting Federal assistance.

7 Complete & Integrated Plans (NUREG-0654/FEMA-REP-1)

ESP Major Features (Supplement 2 to NUREG-0654)

ESP Complete & Integrated Plans (COL Action Items)

COL Application (EP ITAAC)

a. specific persons by title authorized to request Federal assistance; see A.1.d., A.2.a.
b. specific Federal resources expected, including expected times of arrival at specific nuclear facility sites; and
c. specific licensee, State and local resources available to support the Federal response, e.g., air fields, command posts, telephone lines, radio frequencies and telecommunications centers.

C.1.c The licensee has made provisions for incorporating the Federal response capability into its operation plan, including specific licensee, State and local resources available to support the Federal response; e.g., air fields, command posts, telephone lines, radio frequencies, and telecommunications centers. [LS]

  • C.1.c The licensee has confirmed that the State has made provisions for incorporating the Federal response capability into its operation plan, including specific licensee, State and local resources available to support the Federal response; e.g., air fields, command posts, telephone lines, radio frequencies, and telecommunications centers. [SS]

C.2.a Each principal offsite organiza-tion may dispatch representatives to the licensees near-site Emergency Operations Facility. (State technical analysis representatives at the nearsite EOF are preferred.)

C.2.b The licensee shall prepare for the dispatch of a representative to principal offsite governmental emergency operations centers.

8 Complete & Integrated Plans (NUREG-0654/FEMA-REP-1)

ESP Major Features (Supplement 2 to NUREG-0654)

ESP Complete & Integrated Plans (COL Action Items)

COL Application (EP ITAAC)

C.3 Each organization shall identify radiological laboratories and their general capabilities and expected availability to provide radiological monitoring and analyses services which can be used in an emergency.

C.2 Each organization shall identify radiological laboratories and their general capabilities and expected availability to provide radiological monitoring and analyses services during an emergency.

C.4 Each organization shall identify nuclear and other facilities, organizations or individuals which can be relied upon in an emergency to provide assistance. Such assistance shall be identified and supported by appropriate letters of agreement.

C.3 Each organization shall identify nuclear and other facilities and organizations that can be relied on to provide assistance in an emergency.

C.4 Each applicant shall include a description of the contacts and arrangements made with the response organizations identified above.

D. Emergency Classification System 10 CFR 50.47(b)(4)

D.1 An emergency classification and emergency action level scheme as set forth in Appendix 1 must be established by the licensee. The specific instruments, parameters or equipment status shall be shown for establishing each emergency class, in the in-plant emergency procedures.

The plan shall identify the parameter values and equipment status for each emergency class.

D.1 An emergency classification scheme, as set forth in Appendix 1 of NUREG-0654/FEMA-REP-1 or Regulatory Guide 1.101, must be established by the ESP applicant, but need not include plant-specific initiating conditions.

D.1 The licensee has established an emergency classification and emergency action level scheme, as set forth in Appendix 1 to NUREG-0654/FEMA-REP-1 or NEI 99-01 (as allowed by Regulatory Guide 1.101).

The emergency action levels (EALs) have been discussed and agreed on by the applicant and State and local government authorities. The specific instruments, parameters or equipment status is shown for establishing each emergency class, in the in-plant emergency procedures. The plan identifies the parameter values and equipment status for each emergency class. [10 CFR Part 50, App. E, IV.B, IV.C] [US]

D.1 A standard emergency classification and emergency action level (EAL) scheme exists, and identifies facility system and effluent parameters constituting the bases for the classification scheme.

D.2 The initiating conditions shall include the example conditions found in Appendix 1 and all postulated accidents in the Final Safety Analysis

9 Complete & Integrated Plans (NUREG-0654/FEMA-REP-1)

ESP Major Features (Supplement 2 to NUREG-0654)

ESP Complete & Integrated Plans (COL Action Items)

COL Application (EP ITAAC)

Report (FSAR) for the nuclear facility.

D.3 Each State and local organization shall establish an emergency classification and emergency action level scheme consistent with that established by the facility licensee.

D.2 Each State and local organization shall establish an emergency classification level scheme consistent with that established by the ESP applicant.

D.4 Each State and local organization should have procedures in place that provide for emergency actions to be taken which are consistent with the emergency actions recommended by the nuclear facility licensee, taking into account local offsite conditions that exist at the time of the emergency.

  • D.4 The licensee has confirmed that each State and local organization has procedures in place that provide for emergency actions to be taken, which are consistent with the emergency actions recommended by the licensee, taking into account local offsite conditions that exist at the time of the emergency. [SS]

E. Notification Methods and Procedures - 10 CFR 50.47(b)(5)

E.1 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. These procedures shall include means for verification of messages. The specific details of verification need not be included in the plan.

E.1 Each organization shall describe mutually agreeable bases for notification of response organizations consistent with the emergency classification scheme set forth in Appendix 1 of NUREG-0654/FEMA-REP-1.

E.1 The means exists to notify responsible State and local organizations within 15 minutes after the licensee declares an emergency.

E.2 Each organization shall establish procedures for alerting, notifying, and mobilizing emergency response personnel.

E.2 Each organization shall describe a method for alerting, notifying, and mobilizing emergency response personnel.

  • E.2 The licensee has confirmed that the State and local organizations have established procedures for alerting, notifying, and mobilizing emergency response personnel. [SS]

E.2 The means exists to notify emergency response personnel.

E.3 The licensee in conjunction with State and local organizations shall establish the contents of the initial emergency messages to be sent from

10 Complete & Integrated Plans (NUREG-0654/FEMA-REP-1)

ESP Major Features (Supplement 2 to NUREG-0654)

ESP Complete & Integrated Plans (COL Action Items)

COL Application (EP ITAAC) the plant. These [messages] shall contain information about the class of emergency, whether a release is taking place, potentially affected population and areas, and whether protective measures may be necessary.

E.4 Each licensee shall make provisions for followup messages from the facility to offsite authorities which shall contain the following information if it is known and appropriate:

a. location of incident and name and telephone number (or communications channel identification) of caller;
b. date/time of incident;
c. class of emergency;
d. type of actual or projected release (airborne, waterborne, surface spill),

and estimated duration/impact times;

e. estimate of quantity of radioactive material released or being released and the points and height of releases;
f. chemical and physical form of released material, including estimates of the relative quantities and concentration of noble gases, iodines and particulates;
g. meteorological conditions at appropriate levels (wind speed, direction (to and from), indicator of stability, precipitation, if any);

11 Complete & Integrated Plans (NUREG-0654/FEMA-REP-1)

ESP Major Features (Supplement 2 to NUREG-0654)

ESP Complete & Integrated Plans (COL Action Items)

COL Application (EP ITAAC)

h. actual or projected dose rates at site boundary; projected integrated dose at site boundary;
i. projected dose rates and integrated dose at the projected peak and at 2, 5 and 10 miles, including sector(s) affected;
j. estimate of any surface radioactive contamination inplant, onsite or offsite;
k. licensee emergency response actions underway;
l. recommended emergency actions, including protective measures;
m. request for any needed onsite support by offsite organizations; and
n. prognosis for worsening or termination of event based on plant information.

E.5 State and local government organizations shall establish a system for disseminating to the public appropriate information contained in initial and followup messages received from the licensee including the appropriate notification to appropriate broadcast media, e.g., the Emergency Alert System (EAS).

12 Complete & Integrated Plans (NUREG-0654/FEMA-REP-1)

ESP Major Features (Supplement 2 to NUREG-0654)

ESP Complete & Integrated Plans (COL Action Items)

COL Application (EP ITAAC)

E.6 Each organization shall establish administrative and physical means, and the time required for notifying and providing prompt instructions to the public within the plume exposure pathway Emergency Planning Zone.

(See Appendix 3.) It shall be the licensees responsibility to demonstrate that such means exist, regardless of who implements this requirement. It shall be the responsibility of the Stat and local governments to activate such a system.

E.3 Each organization shall describe the administrative and physical means for notifying and promptly instructing the public within the plume exposure pathway EPZ.

E.6 The licensee has demonstrated that administrative and physical means have been established for alerting and providing prompt instructions to the public within the plume exposure pathway EPZ. [10 CFR Part 50, App.

E, IV.D.3] [SS]

  • E.6 The licensee has confirmed that the State and local officials have the capability to make a public notification decision promptly on being informed by the licensee of an emergency condition. [10 CFR Part 50, App. E, IV.D.3] [SS]
  • E.6 The licensee has confirmed that the State and local organizations have established the administrative and physical means for alerting and providing prompt instructions to the public within the plume exposure pathway EPZ, and have the capability to essentially complete the initial notification within about 15 minutes.

[10 CFR Part 50, App. E, IV.D.3[ [SS]

E.6 The means exists to notify and provide instructions to the populace within the plume exposure EPZ.

E.7 Each organization shall provide written messages intended for the public, consistent with the licensees classification scheme. In particular, draft messages to the public giving instructions with regard to specific protective actions to be taken by occupants of affected areas shall be prepared and included as part of the State and local plans. Such messages should include the appropriate aspects of sheltering, ad hoc respiratory protection, e.g., handkerchief over

13 Complete & Integrated Plans (NUREG-0654/FEMA-REP-1)

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COL Application (EP ITAAC) mouth, thyroid blocking or evacuation.

The role of the licensee is to provide supporting information for the messages. For ad hoc respiratory protection see Respiratory Protective Devices Manual American Industrial Hygiene Association, 1963 pp. 123-126.

F. Emergency Communications 10 CFR 50.47(b)(6)

F.1 The communication plans for emergencies shall include organizational titles and alternates for both ends of the communication links.

Each organization shall establish reliable primary and backup means of communication for licenses, 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, including 24-hour per day manning of communications links that initiate emergency response actions.

F.1 The communication plans for emergencies shall describe:

a. provision for communications with contiguous State/local governments within the EPZ F.1 The licensee has provided for at least one onsite and one offsite communication system, including reliable primary and backup means of communication, a backup power source for each system, and the systems are compatible with one another. [10 CFR Part 50, App. E, IV.E.9] [LS]
  • F.1 The licensee has confirmed that the State and local response organizations have established reliable primary and backup means of communication, and the systems are compatible with one another. [SS]

F.1.a The licensee has provided, at a minimum, a telephone link and alter-nate, including 24-hour per day staffing of communication links that initiate emergency response actions. [LS]

  • F.1.a The licensee has confirmed that the State and local organizations have provided, at a minimum, a telephone link and alternate, including 24-hour per day staffing of communication links that initiate emergency response actions. [SS]

14 Complete & Integrated Plans (NUREG-0654/FEMA-REP-1)

ESP Major Features (Supplement 2 to NUREG-0654)

ESP Complete & Integrated Plans (COL Action Items)

COL Application (EP ITAAC)

b. provision for communications with contiguous State/local governments within the Emergency Planning Zones;
c. provision for communications as needed with Federal emergency response organizations;
d. provision for communications between the nuclear facility and the licensees near-site Emergency Operations Facility, State and local emergency operations centers, and radiological monitoring teams;
b. provision for communications as needed with Federal emergency response organizations
c. provision for alerting and activating emergency personnel in each response organization F.1.b The licensee has provided for communications with contiguous State/local governments within the emergency planning zones (EPZs). [10 CFR Part 50, App. E, IV.E.9.a] [LS]
  • F.1.b The licensee has confirmed that the State and local response organizations have provided for communications with contiguous State/local governments within the emergency planning zones (EPZs). [10 CFR Part 50, App. E, IV.E.9.a] [SS]

F.1.c The licensee has provided for communications, as needed, with Federal emergency response organizations. [10 CFR Part 50, App.

E, IV.E.9.b] [LS]

  • F.1.c The licensee has confirmed that the State and local response organizations have provided for communications, as needed, with Federal emergency response organizations. [10 CFR Part 50, App.

E, IV.E.9.b] [SS]

F.1.d The licensee has provided for communications among the control room, TSC, EOF, principal State and local emergency operations centers (EOCs), and radiological monitoring/field assessment teams. [10 CFR Part 50, App. E, IV.E.9.c] [US]

F.1.d The means exists for communications among the control room, TSC, EOF, principal State and local emergency operations centers (EOCs), and radiological field assessment teams.

15 Complete & Integrated Plans (NUREG-0654/FEMA-REP-1)

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e. provision for alerting or activating emergency personnel in each response organization; and
f. provision for communication by the licensee with NRC headquarters and NRC Regional Office Emergency Operations Centers and the licensees near-site Emergency Operations Facility and radiological monitoring team assembly area.
  • F.1.d The licensee has confirmed that the State and local response organizations have provided for communications among the control room, TSC, EOF, principal State and local emergency operations centers (EOCs), and radiological monitoring/field assessment teams. [10 CFR Part 50, App. E, IV.E.9.c] [SS]

F.1.e The licensee has made provisions for alerting or activating emergency personnel in each response organization. [LS]

  • F.1.e The licensee has confirmed that the State and local response organiza-tions have provided for alerting or activating emergency personnel in each response organization. [SS]

F.1.f The licensee has made provisions for communications - from the control room, TSE and EOF - to the NRC headquarters and regional office EOCs (including establishment of the Emergency Response Data System (ERDS) between the onsite computer system and the NRC Operations Center). [10 CFR Part 50, App. E, IV.E.9.d, IV.1] [US]

F.1.f The means exists for communications from the control room, TSC, and EOF to the NRC headquarters and regional office EOCs (including establishment of the Emergency Response Data System (ERDS) between the onsite computer system and the NRC Operations Center.)

F.2 Each organization shall ensure that a coordinated communication link for fixed and mobile medical support facilities exists.

F.2 The communication arrangement for fixed and mobile medical support facilities shall be described.

F.2 A licensee coordinated communi-cation link for fixed and mobile medical support facilities exists. [LS]

  • F.2 The licensee has confirmed that coordinated State and local communi-cation links for fixed and mobile medical support facilities exists. [SS]

16 Complete & Integrated Plans (NUREG-0654/FEMA-REP-1)

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COL Application (EP ITAAC)

F.3 Each organization shall conduct periodic testing of the entire emergency communications system (see evaluation criteria H.10, N.2.a and Appendix 3).

F.3 The licensee has implemented a periodic test program for its entire emergency communications system.

[10CFRPart50, App.E, IV.E.9.a-d][US]

  • F.3 The licensee has confirmed that the State and local organizations have implemented a periodic test program for their entire emergency communications systems. [10 CFR Part 50, App. E, IV.E.9.a-c] [SS]

G. Public Education and Information - 10 CFR 50.47(b)(7)

G.1 Each organization shall provide a coordinated periodic (at least annually) dissemination of information to the public regarding how they will be notified and what their actions should be in an emergency. This information shall include, but not necessarily be limited to:

a. educational information on radiation;
b. contact for additional information;
c. protective measures, e.g.,

evacuation routes and relocation centers, sheltering, respiratory protection, radioprotective drugs; and

d. special needs of the handicapped.

Means for accomplishing this dissemination may include, but are not necessarily limited to: information in the telephone book; periodic information in utility bills; posting in public areas; and publications distributed on an annual basis.

G.1 Each organization shall describe a program to provide a coordinated dissemination of information to the public on a periodic basis (at least annually) regarding how they will be notified and what their actions should be in an emergency. This program should include information on:

a. educational information on radiation;
b. contact for additional information
c. protective measures, e.g., evacuation routes and relocation centers, sheltering, respiratory protection, radioprotective drugs;
d. special needs of the handicapped and the transient population.

Means for accomplishing this dissemination may include, but are not necessarily limited to: information in the telephone book, periodic information in utility bills, posting in public areas, and publications distributed on an annual basis.

G.1 The licensee has provided for a coordinated, periodic (at least annually) dissemination of information to the public regarding how they will be notified and what their actions should be in an emergency. This information includes, but is not necessarily limited to: [SS]

a. education information on radiation;
b. contact for additional information;
c. protective measures, e.g., evacuation routes and relocation centers, sheltering, respiratory protection, radioprotective drugs; and
d. special needs of the handicapped.

17 Complete & Integrated Plans (NUREG-0654/FEMA-REP-1)

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COL Application (EP ITAAC)

  • G.1 The licensee has confirmed that the State and local organizations have provided for a coordinated, periodic (at least annually) dissemination of information to the public regarding how they will be notified and what their actions should be in an emergency. This information includes, but is not necessarily limited to: [SS]
a. education information on radiation;
b. contact for additional information;
c. protective measures, e.g., evacuation routes and relocation centers, sheltering, respiratory protection, radioprotective drugs; and
d. special needs of the handicapped.

G.2 The public information program shall provide the permanent and transient adult population within the plume exposure EPZ an adequate opportunity to become aware of the information annually. The programs should include provision for written material that is likely to be available in a residence during an emergency.

Updated information shall be disseminated at least annually. Signs or other measures (e.g., decals, posted notices or other means, placed in hotels, motels, gasoline stations and phone booths) shall also be used to disseminate to any transient population within the plume exposure pathway EPZ appropriate information that would be helpful if an emergency or accident occurs. Such notices should refer the transient to the telephone directory or other source of G.2 The public information program provides the permanent and transient adult population within the plume exposure EPZ an adequate opportunity to become aware of the information.

[SS]

  • G.2 The licensee has confirmed that the public information program provides the permanent and transient adult population within the plume exposure EPZ an adequate opportunity to become aware of the information.

[SS]

18 Complete & Integrated Plans (NUREG-0654/FEMA-REP-1)

ESP Major Features (Supplement 2 to NUREG-0654)

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COL Application (EP ITAAC) local emergency information and guide the visitor to appropriate radio and television frequencies.

G.3.a Each principal organization shall designate the points of contact and physical locations for use by news media during an emergency.

G.3.b Each licensee shall provide space which may be used for a limited number of the news media at the nearsite Emergency Operations Facility.

G.3.b The licensee has provided space, which may be used for a limited number of the news media. [LS]

G.3.b The licensee has provided space which may be used for a limited number of the news media at the EOF.

G.4.a Each principal organization shall designate a spokesperson who should have access to all necessary information.

G.4.b Each organization shall establish arrangements for timely exchange of information among designated spokespersons.

G.4.c Each organization shall establish coordinated arrangements for dealing with rumors.

G.5 Each organization shall conduct coordinated programs at least annually to acquaint news media with the emergency plans, information concerning radiation, and points of contact for release of public information in an emergency.

G.2 Each organization shall describe a program for acquainting news media on a periodic basis (at least annually) with the emergency plans, information concerning radiation, and points of contact for release of public information in an emergency.

G.5 The licensee has conducted coordinated programs to acquaint news media with emergency plans, information concerning radiation, and points of contact for release of public information in an emergency. [LS]

  • G.5 The licensee has confirmed that the State and local organizations have conducted coordinated programs to acquaint news media with emergency plans, information concerning radiation, and points of contact for release of public information in an emergency. [SS]

19 Complete & Integrated Plans (NUREG-0654/FEMA-REP-1)

ESP Major Features (Supplement 2 to NUREG-0654)

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COL Application (EP ITAAC)

H. Emergency Facilities and Equipment - 10 CFR 50.47(b)(8)

H.1 Each licensee shall establish a Technical Support Center and an onsite operations support center (assembly area) in accordance with NUREG-0696.

H.1 Each applicant shall describe a technical support center and an onsite operations support center in accordance with NUREG-0696.

H.1 The licensee has established a Technical Support Center (TSC), in accordance with NUREG-0696 (or equivalent). [10 CFR Part 50, App. E, IV.E.8] [LS]

H.1 The licensee has established an onsite Operations Support Center (OSC) (assembly area), in accordance with NUREG-0696 (or equivalent).

[LS]

H.1 The licensee has established a technical support center (TSC) and onsite operations support center (OSC).

H.2 Each licensee shall establish an Emergency Operations Facility from which evaluation and coordination of all licensee activities related to an emergency is to be carried out and from which the licensee shall provide information to Federal, State and local authorities responding to radiological emergencies in accordance with NUREG-0696.

H.2 Each applicant shall describe an emergency operations facility from which evaluation and coordination of all licensee activities related to an emergency is to be carried out and from which the licensee shall provide information to Federal, State and local authorities responding to radiological emergencies in accordance with NUREG-0696.

H.2 The licensee has established an Emergency Operations Facility (EOF),

in accordance with NUREG-0696 (or equivalent). [LS]

H.2 The licensee has established an emergency operations facility (EOF).

H.3 Each organization shall establish an emergency operations center for use in directing and controlling response functions.

H.3 Each offsite organization shall describe an emergency operations center for use in directing and controlling response functions.

  • H.3 The licensee has confirmed that the State and local organizations have established an emergency operations center (EOC) for use in directing and controlling response functions. [SS]

H.4 Each organization shall provide for timely activation and staffing of the facilities and centers described in the plan.

H.4 The licensee has provided for timely activation and staffing of the facilities and centers described in the plan. [LS]

  • H.4 The licensee has confirmed that the State and local organizations have provided for timely activation and staffing of the facilities and centers described in the plan. [SS]

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H.5 Each licensee shall identify and establish onsite monitoring systems that are to be used to initiate emergency measures in accordance with Appendix 1, as well as those to be used for conducting assessment.

The equipment shall include:

a. geophysical phenomena monitors (e.g., meteorological, hydrologic, seismic);
b. radiological monitors (e.g., process, area, emergency, effluent, wound and portable monitors and sampling equipment);
c. process monitors (e.g., reactor coolant system pressure and temperature, containment pressure and temperature, liquid levels, flow rates, status or lineup of equipment components); and
d. fire and combustion products detectors.

H.5 The licensee has identified and established monitoring systems that are to be used to initiate emergency measures, in accordance with Appendix 1 of NUREG-0654/FEMA-REP-1 (or equivalent), as well as those to be used for conducting assessment of the emergency. The equipment includes:

[US]

a. geophysical phenomena monitors (e.g., meteorological, hydrologic, seismic);
b. radiological monitors (e.g., process, area, emergency, effluent, wound and portable monitors and sampling equipment);
c. process monitors (e.g., reactor coolant system pressure and temperature, containment pressure and temperature, liquid levels, flow rates, status or lineup of equipment components); and
d. fire and combustion products detectors.

H.6 Each licensee shall make provision to acquire data from or for emergency access to offsite monitor-ing and analysis equipment including:

a. geophysical phenomena monitors (e.g., meteorological, hydrologic, seismic);
b. radiological monitors including ratemeters and sampling devices.

Dosimetry shall be provided and shall H.6 The licensee has made provisions to acquire data from, or for emergency access to, offsite monitoring and analysis equipment, including: [LS]

a. geophysical phenomena monitors (e.g., meteorological, hydrologic, seismic);
b. radiological monitors, including ratemeters and sampling devices.

Dosimetry shall be provided and shall

21 Complete & Integrated Plans (NUREG-0654/FEMA-REP-1)

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COL Application (EP ITAAC) meet, as a minimum, the NRC Radiological Assessment Branch Technical Position [BTP] for the Environmental Radiological Monitoring Program; and c laboratory facilities, fixed or mobile.

meet, as a minimum, the NRC Radiological Assessment BTP for the Environmental Radiological Monitoring Program (or equivalent);

and

c. laboratory facilities (fixed and mobile).

H.7 Each organization, where appropriate, shall provide for offsite radiological monitoring equipment in the vicinity of the nuclear facility.

H.7 The licensee, where appropriate, has provided offsite radiological monitoring equipment in the vicinity of the nuclear facility. [LS]

  • H.7 The licensee has confirmed that the State and local organizations, where appropriate, have provided offsite radiological monitoring equipment in the vicinity of the nuclear facility. [SS]

H.8 Each licensee shall provide meteorological instrumentation and procedures which satisfy the criteria in Appendix 2, and provisions to obtain representative current meteorological information from other sources.

H.8 The licensee has provided meteorological instrumentation and procedures, which satisfy the criteria in Appendix 2 of NUREG-0654/FEMA-REP-1 (or equivalent), and provisions to obtain representative current meteorological information from other sources. [LS]

H.9 Each licensee shall provide for an onsite operations support center (assembly area) which shall have adequate capacity, and supplies, including, for example, respiratory protection, protective clothing, portable lighting, portable radiation monitoring equipment, cameras and communications equipment for personnel present in the assembly area.

H.9 The licensee has provided for an onsite Operations Support Center (OSC) (assembly area), which has adequate capacity and supplies, including (for example) respiratory protection, protective clothing, portable lighting, portable radiation monitoring equipment, cameras and communications equipment for personnel present in the assembly area.

[10 CFR Part 50, App. E,IV.E.1] [LS]

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H.10 Each organization shall make provisions to inspect, inventory and operationally check emergency equipment/instruments at least once each calendar quarter and after each use. There shall be sufficient reserves of instruments/equipment to replace those which are removed from emergency kits for calibration or repair. Calibration of equipment shall be at intervals recommended by the supplier of the equipment.

H.10 The licensee has made provisions to inspect, inventory and operationally check emergency equipment/

instruments at least once each calendar quarter and after each use. There are reserves of instruments/equipment sufficient to replace those which are removed from emergency kits for calibration or repair. Calibration of equipment is at intervals recommended by the supplier of the equipment. [10 CFR Part 50, App. E, IV.E.1] [LS]

  • H.10 The licensee has confirmed that the State and local organizations have made provisions to inspect, inventory and operationally check emergency equipment/instruments at least once each calendar quarter and after each use. There are reserves of instruments/equipment sufficient to replace those which are removed from emergency kits for calibration or repair.

Calibration of equipment is at intervals recommended by the supplier of the equipment. [SS]

H.11 Each plan shall, in an appendix, include identification of emergency kits by general category (protective equipment, communications equipment, radiological monitoring equipment and emergency supplies).

H.12 Each organization shall establish a central point (preferably associated with the licensees near-site Emergency Operations Facility), for the receipt and analysis of all field monitoring data and coordination of sample media.

H.12 The licensee has established a central point (preferably associated with the licensees near-site EOF) for the receipt and analysis of all field monitoring data and coordination of sample media. [LS]

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  • H.12 The licensee has confirmed that the State and local organizations have established a central point (preferably associated with the licensees near-site EOF) for the receipt and analysis of all field monitoring data and coordination of sample media. [SS]

I. Accident Assessment 10 CFR 50.47(b)(9)

I.1 Each licensee shall identify plant system and effluent parameter values characteristic of a spectrum of off-normal conditions and accidents, and shall identify the plant parameter values or other information which correspond to the example initiating conditions of Appendix 1. Such parameter values and the corresponding emergency class shall be included in the appropriate facility emergency procedures. Facility emergency procedures shall specify the kinds of instruments being used and their capabilities.

I.1 The plant system and effluent parameter values characteristic of a spectrum of off-normal conditions and accidents, plant parameter values or other information that corresponds to the example initiating conditions of Appendix 1 of NUREG-0654/FEMA-REP-1 (or equivalent) set at the COL stage, and the corresponding emergency class have been included in the appropriate facility emergency procedures, which specify the kinds of instruments being used and their capabilities. [US]

I.2 Onsite capability and resources to provide initial values and continuing assessment throughout the course of an accident shall include post-accident sampling capability, radiation and effluent monitors, in-plant iodine instrumentation, and containment radiation monitoring (in accordance with NUREG-0737 and Supplement 1 to NUREG-0737).

I.2 Onsite capability and resources, to provide initial values and continuing assessment throughout the course of an accident, include post-accident sampling capability or sampling contingency plans, radiation and effluent monitors, in-plant iodine instrumentation, and containment radiation monitoring, in accordance with NUREG-0737 and Supplement 1 to NUREG-0737 (or equivalents). [10 CFR Part 50, App. E, IV.E.2; Model Safety Evaluation] [US]

I.2 The means exists to provide initial and continuing radiological assessment throughout the course of an accident.

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I.3 Each licensee shall establish methods and techniques to be used for determining:

a. the source term of releases of radioactive material within plant systems. An example is the relationship between the containment radiation monitor(s) reading(s) and radioactive material available for release from containment.
b. the magnitude of the release of radioactive materials based on plant system parameters and effluent monitors.

I.3.a-b The licensee has established methods and techniques to be used for determining the source term of releases of radioactive material within plant systems, and the magnitude of the release of radioactive materials based on plant system parameters and effluent monitors. [10 CFR part 50, App. E, IV.E.2; Model Safety Evaluation] [US]

I.3 The means exists to determine the source term of releases of radioactive material within plant systems, and the magnitude of the release of radioactive materials based on plant system parameters and effluent monitors.

I.4 Each licensee shall establish the relationship between effluent monitor readings and onsite and offsite exposures and contamination for various meteorological conditions.

I.4 The licensee has established the relationship between effluent monitor readings, and onsite and offsite exposures and contamination for various meteorological conditions; and has provided for equipment to continuously assess the impact of the release of radioactive materials to the environment. [10 CFR Part 50, App. E, IV.E.2] [US]

I.4 The means exists to continuously assess the impact of the release of radioactive materials to the environment, accounting for the relationship between effluent monitor readings, and onsite and offsite exposures and contamination for various meteorological conditions.

I.5 Each licensee shall have the capability of acquiring and evaluating meteorological information sufficient to meet the criteria of Appendix 2.

There shall be provisions for access to meteorological information by at least the nearsite Emergency Operations Facility, the Technical Support Center, the Control Room and an offsite NRC center. The licensee shall make available to the State suitable meteorological data processing interconnections which will permit I.1 Each applicant shall provide a description of the contacts and arrangements made with offsite organizations for acquiring and evaluating meteorological information.

The applicant shall describe how suitable meteorological data will be made available to the State.

I.5 The licensee has the capability of acquiring and evaluating meteorological information, sufficient to meet the criteria of Appendix 2 of NUREG-0654/FEMA-REP-1 (or equivalent). There are provisions for access to this information by at least the nearsite EOF, the TSC, the control room and an offsite NRC center. The licensee has made available to the State suitable meteorological data processing interconnections, which will permit independent analysis by the State, of I.5 The means exists to acquire and evaluate meteorological information.

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COL Application (EP ITAAC) independent analysis by the State, of facility generated data in those States with the resources to effectively use this information.

facility generated data in those States with the resources to effectively use this information. [LS]

I.6 Each licensee shall establish the methodology for determining the release rate/projected doses if the instrumentation used for assessment are offscale or inoperable.

I.6 The licensee has implemented the methodology for determining the release rate and projected doses if the instrumentation used for assessment is off-scale or inoperable. [US]

I.7 Each organization shall describe the capability and resources for field monitoring within the plume exposure Emergency Planning Zone which are an intrinsic part of the concept of operations for the facility.

I.2 Each organization shall describe the [capability and resources] for field monitoring within the plume exposure EPZ.

I.7 The licensee has described the capability and resources for field monitoring within the plume exposure EPZ, which are an intrinsic part of the concept of operations for the facility.

[LS]

  • I.7 The licensee has confirmed that the State and local organizations have described the capability and resources for field monitoring within the plume exposure EPZ, which are an intrinsic part of the concept of operations for the facility. [SS]

I.8 Each organization, where appropriate, shall provide methods, equipment and expertise to make rapid assessments of the actual or potential magnitude and location s of any radiological hazards thorough liquid or gaseous release pathways. This shall include activation, notification means, field team composition, transportation, communication, monitoring equipment and estimated deployment times.

I.8 The licensee, where appropriate, has provided methods, equipment and expertise to make rapid assessments of the actual or potential magnitude and locations of any radiological hazards through liquid or gaseous release pathways. This includes activation, notification means, field team composition, transportation, communication, monitoring equipment and estimated deployment times. [US]

  • I.8 The licensee has confirmed that the State and local organizations, where appropriate, have provided methods, equipment and expertise to make rapid I.8 The means exists to make rapid assessments of actual or potential magnitude and locations of any radiological hazards through liquid or gaseous release pathways, including activation, notification means, field team composition, transportation, communication, monitoring equipment, and estimated deployment times.

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COL Application (EP ITAAC) assessments of the actual or potential magnitude and locations of any radiological hazards through gaseous release pathways. This includes activation, notification means, field team composition, transportation, communication, monitoring equipment and estimated deployment times. [SS]

I.9 Each organization shall have a capability to detect and measure radioiodine concentrations in air in the plume exposure EPZ as low as 10-7

µCi/cc (microcuries per cubic centimeter) under field conditions.

Interference from the presence of noble gas and background radiation shall not decrease the stated minimum detectable activity.

I.9 The licensee has a capability to detect and measure radioiodine concentrations in air in the plume exposure EPZ, as low as 10-7 µCi/cc (microcuries per cubic centimeter) under field conditions. Interference from the presence of noble gas and background radiation does not decrease the stated minimum detectable activity.

[LS]

  • I.9 The licensee has confirmed that the State or local organizations have a capability to detect and measure radioiodine concentrations in air in the plume exposure EPZ, as low as 10-7

µCi/cc (microcuries per cubic centimeter) under field conditions.

Interference from the presence of noble gas and background radiation does not decrease the stated minimum detectable activity. [SS]

I.9 The capability exists to detect and measure radioiodine concentrations in air in the plume exposure EPZ, as low as 10-7 µCi/cc (microcuries per cubic centimeter) under field conditions.

I.10 Each organization shall establish means for relating the various measured parameters (e.g.,

contamination levels, water and air activity levels) to dose rates for key isotopes (i.e., those given in Table 3, page 18) and gross radioactivity measurements. Provisions shall be made for estimating integrated dose I.10 The licensee has established means for relating the various measured parameters (e.g.,

contamination levels, water/air activity levels) to dose rates for key isotopes (i.e., those given in Table 3 of NUREG-0654/FEMA-REP-1) (or equivalent) and gross radioactivity measurements. Provisions have been I.10 The means exists to estimate integrated dose from the projected and actual dose rates, and for comparing these estimates with the EPA protective actions guides (PAGs).

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COL Application (EP ITAAC) from the projected and actual dose rates and for comparing these estimates with the protective action guides. The detailed provisions shall be described in separate procedures.

made for estimating integrated dose from the projected and actual dose rates, and for comparing these estimates with the protective action guides (PAGs). The detailed provisions are described in separate procedures. [US]

  • I.10 The licensee has confirmed that the State or local organizations have established means for relating the various measured parameters (e.g.,

contamination levels, water and air activity levels) to dose rates for key isotopes (i.e., those given in Table 3 of NUREG-0654/FEMA-REP-1) (or equivalent) and gross radioactivity measurements. Provisions have been made for estimating integrated dose from the projected and actual dose rates, and for comparing these estimates with the protective action guides (PAGs). The detailed provisions are described in separate procedures. [SS]

I.11 Arrangements to locate and track the airborne radioactive plume shall be made, using either or both Federal and State resources.

I.3 Contacts and arrangements to locate and track the airborne radioactive plume, using either or both Federal and State resources, shall be described.

  • I.11 The licensee has confirmed that the State or local organizations have made arrangements to locate and track the airborne radioactive plume, using any or all Federal, State, and local resources. [SS]

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J. Protective Response 10 CFR 50.47(b)(10)

J.1 Each licensee shall establish the means and time required to warn or advise onsite individuals and individuals who may be in areas controlled by the operator, including:

a. Employees not having emergency assignments;
b. Visitors;
c. Contractor and construction personnel; and
d. Other persons who may be in the public access on or passing through the site or within the owner controlled area.

J.1 The licensee has established the means and time required to warn or advise onsite individuals, including those in areas controlled by the operator, including: [US]

a. employees not having emergency assignments;
b. visitors;
c. contractor and construction personnel; and
d. other persons who may be in the public access areas on or passing through the site or within the owner controlled area.

J.1 The means exists to warn and advise onsite individuals of an emergency, including those in areas controlled by the operator, including:

a. employees not having emergency assignments;
b. visitors;
c. contractor and construction personnel; and
d. other persons who may be in the public access areas, on or passing through the site, or within the owner controlled area.

J.2 Each licensee shall make provisions for evacuation routes and transportation for onsite individuals to some suitable offsite location, including alternatives for inclement weather, high traffic density and specific radiological conditions.

J.1 Each applicant shall describe the evacuation routes and transportation for onsite individuals to some suitable offsite location, including alternatives for inclement weather, high traffic density, and specific radiological conditions.

J.3 Each licensee shall provide for radiological monitoring of people evacuated from the site.

J.3 The licensee has provided fro radiological monitoring of people evacuated from the site. [LS]

J.4 Each licensee shall provide for the evacuation of onsite non-essential personnel in the event of a Site or General Emergency and shall provide a decontamination capability at or near the monitoring point specified in J.3.

J.4 The licensee has provided for the evacuation of onsite non-essential personnel in the event of a Site or General Emergency, and has provided a decontamination capability at, or near, the monitoring point for people evacuated from the site. [LS]

J.5 Each licensee shall provide for a capability to account for all individuals onsite at the time of the emergency and ascertain the names of missing individuals within 30 minutes J.5 The licensee has provided a capability to account for all individuals onsite at the time of an emergency, and ascertain the names of missing persons within 30 minutes of the start of an

29 Complete & Integrated Plans (NUREG-0654/FEMA-REP-1)

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COL Application (EP ITAAC) of the start of an emergency and account for all onsite individuals continuously thereafter.

emergency, and can account for all onsite individuals continuously thereafter. [LS]

J.6 Each licensee shall, for individual remaining or arriving onsite during the emergency, make provisions for:

a. Individual respiratory protection;
b. Use of protective clothing; and
c. Use of radioprotective drugs (e.g.,

individual thyroid protection).

J.6 For individuals remaining or arriving onsite during an emergency, the licensee has made provisions for individual respiratory protection, use of protective clothing, and use of radioprotective drugs (e.g., individual thyroid protection). [LS]

J.7 Each licensee shall establish a mechanism for recommending protective actions to the appropriate State and local authorities. These shall include Emergency Action Levels corresponding to projected dose to the population-at-risk, in accordance with Appendix 1 and with the recommendations set forth in Table 2.1 and 2.2 of the Manual of Protective Action Guides and Protective Actions for Nuclear Incidents ([EPA-520/1-75-001]). As specified in Appendix 1, prompt notification shall be made directly to the offsite authorities responsible for implementing protective measures within the plume exposure pathway Emergency Planning Zone.

J.2 Each applicant shall describe a mechanism for recommending protective actions to the appropriate State and local authorities in accordance with the Manual of Protective Action Guides and Protective Actions for Nuclear Incidents (EPA 400-R-92-001).

J.8 Each licensees plan shall contain time estimates for evacuation within the plume exposure EPZ. These shall be in accordance with Appendix 4.

J.3 Each applicant must prepare time estimates for evacuation within the plume exposure EPZ (see Section II of this document). These shall be in accordance with Appendix 4 of NUREG-0654/FEMA-REP-1.

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J.9 Each State and local organization shall establish a capability for implementing protective measures based upon protective action guides and other criteria. This shall be consistent with the recommendations of EPA regarding exposure resulting from passage of radioactive airborne plumes.

  • J.9 The licensee has confirmed that the State and local organizations have established a capability for implementing protective measures based upon protective guides and other criteria, and consistent with the Environmental Protection Agency (EPA) recommendations (or equivalent) regarding exposure resulting from the passage of radioactive airborne plumes. [SS]

J.10 The organizations plans to implement protective measures for the plume exposure pathway shall include:

a. Maps showing evacuation routes, evacuation areas, preselected radiological sampling and monitoring points, relocation centers in hose areas, and shelter areas (identification of radiological sampling and monitoring points shall include the designators in Table J-1 or an equivalent uniform system described in the plan);
b. Maps showing population distribution around the nuclear facility.

This shall be by evacuation areas (licensees shall also present the information in a sector format);

J.4 Each organizations concept for implementing protective measures for the plume exposure pathway shall be described including items such as those listed below, if available. Where appropriate, a description of contacts and arrangements made with offsite agencies with emergency planning responsibilities must be included.

a. maps showing evacuation routes, evacuation areas, shelter areas, and relocation centers in host areas.
b. maps showing population distribution around the site. This shall be by evacuation areas. (Each applicant shall also present the information in a sector format.)

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c. Means for notifying all segments of the transient and resident population;
d. Means for protecting those persons whose mobility may be impaired due to such factors as institutional or other confinement;
e. Provisions for the use of radioprotective drugs, particularly for emergency workers and institution-alized persons within the plume exposure EPZ whose immediate evacuation may be infeasible or very difficult, including quantities, storage, and means of distribution;
f. State and local organizations plans should include the method by which decisions by the State Health Dept. for administering radioprotective drugs to the general population are made during an emergency and the predetermined conditions under which such drugs may be used by offsite emergency workers;
c. proposed means for notifying all segments of the transient and resident population.
d. proposed means for protecting those persons whose mobility may be impaired (e.g., institution or other confinement).
e. proposed means for the use of radioprotective drugs for emergency workers and institutionalized persons within the plume exposure EPZ whose immediate evacuation may be infeasible or very difficult.

J.10.c The licensees plans to imple-ment protective measures for the plume exposure pathway (EPZ) include the means for notifying all segments of the transient and resident populations. [SS]

  • J.10 The licensee has confirmed that the State and local organizations have the means to implement protective measures for the plume exposure pathway (EPZ) including: [SS]
a. means for notifying all segments of the transient and resident population;
b. means for protecting those persons whose mobility may be impaired due to such factors as institutional or other confinement;
c. provisions for the use of radioprotective drugs, particularly for emergency workers and institutionalized persons within the plume exposure EPZ whose immediate evacuation may be infeasible or very difficult, including quantities, storage, and means of distribution;

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g. Means of relocation;
h. Relocation centers in host areas which are at least 5 miles, and preferably 10 miles, beyond the boundaries of the plume exposure emergency planning zone (see J.12);
i. Projected traffic capacities of evacuation routes under emergency conditions;
j. Control of access to evacuated areas and organization responsibilities for such control;
k. Identification of and means for dealing with potential impediments (e.g., seasonal impassability of roads) to use of evacuation routes, and contingency measures;
l. Time estimates for evacuation of various sectors and distances based on a dynamic analysis (time-motion study under various conditions) for the plume exposure pathway emergency planning zone (see Appendix 4); and
m. The bases for the choice of recommended protective actions from the plume exposure pathway during emergency conditions. This shall include expected local protection afforded in residential units or other shelter for direct and inhalation exposure, as well as evacuation time estimates.
f. proposed means of relocation.
g. potential relocation centers in host areas which are at least 5 miles, and preferably 10 miles, beyond the boundaries of the plume exposure emregncy planning zone
h. projected traffic capacities of evacuation routes under emergency conditions
i. control of access to evacuated areas and organization responsibilities for such control
j. identification of and means for dealing with potential impediments (e.g., seasonal impassability of roads) to use of evacuation routes and contingency measures
k. time estimates for evacuation of various sectors and distances based on a dynamic analysis (time-motion study under various conditions) for the plume exposure pathway EPZ (see Appendix 4 of NUREG-0654/FEMA-REP-1, and Section II of this document)
l. the bases for the choice of recommended protective actions from the plume exposure pathway during emergency conditions. This shall include expected local protection afforded in residential units or other shelter for direct and inhalation exposure, as well as evacuation time estimates
h. relocation centers in host areas which are at least 5 miles, and preferably 10 miles, beyond the boundaries of the plume exposure EPZ; and
k. identification and availability of means for dealing with potential impediments (e.g., seasonal impassability of roads) to use of evacuation routes, and contingency measures.

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J.11 Each State shall specify the protective measures to be used for the ingestion pathway, including the methods for protecting the public from consumption of contaminated foodstuffs. This shall include criteria for deciding whether dairy animals should be put on stored feed. The plan shall identify procedures for detecting contamination, for estimating the dose commitment consequences of uncontrolled ingestion, and for imposing protection procedures such as impoundment, decontamination, processing, decay, product diversion, and preservation. Maps for recording survey and monitoring data, key land use data (e.g., farming), dairies, food processing plants, water sheds, water supply intake and treatment plants and reservoirs shall be maintained.

Provisions for maps showing detailed crop information may be by including reference to their availability and location and a plan for their use. The maps shall start at the facility and include all of the 50-mile ingestion pathway EPZ. Up-to-date lists of the name and location of all facilities which regularly process milk products and other large amounts of food or agricultural products originating in the ingestion pathway Emergency Planning Zone, but located elsewhere, shall be maintained.

  • J.11 The licensee has confirmed that the State or local organizations maintain maps for recording survey and monitoring data, key land use data (e.g., farming), dairies, food processing plants, water sheds, water supply intake and treatment plants and reservoirs.

Provisions for maps showing detailed crop information may be by including reference to their availability and location and a plan for their use. The maps start at the facility and include all of the 50-mile ingestion pathway EPZ.

Up-to-date lists are maintained of the name and location of all facilities that regularly process milk products and other large amounts of food or agricultural products originating in the ingestion pathway EPZ, but located elsewhere. [SS]

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J.12 Each organization shall describe the means for registering and monitoring of evacuees at relocation centers in host areas. The personnel and equipment available should be capable of monitoring within about a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period all residents and transients in the plume exposure EPZ arriving at relocation centers.

J.5 Each organization shall describe the means for registering and monitoring evacuees at reception centers in host areas.

  • J.12 The licensee has confirmed that the State or local organizations have the means for registering and monitoring evacuees at reception centers. The resources available (i.e., trained personnel and equipment) are capable of monitoring, within about a 12-hour period, 20% of that portion of the plume EPZ allocated to the reception center. [FEMA-REP-14] [SS]

K. Radiological Exposure Control 10 CFR 50.47(b)(11)

K.1 Each licensee shall establish onsite exposure guidelines consistent with EPA 400-R-92-001 for:

a. removal of injured persons;
b. undertaking corrective actions;
c. performing assessment actions;
d. providing first aid;
e. performing personnel decontamination;
f. providing ambulance service; and
g. providing medical treatment services.

K.1 Each applicant shall describe guidelines on dose limits for

a. removal of injured persons
b. undertaking corrective actions
c. performing assessment actions
d. performing field radiological measurements in the plume EPZ
e. providing first aid
f. performing personnel decontamination
g. providing ambulance service
h. providing medical treatment services K.2 Each licensee shall provide an onsite radiation protection program to be implemented during emergencies, including methods to implement exposure guidelines. The plan shall identify individual(s), by position or title, who can authorize emergency workers to receive doses in excess of 10 CFR Part 20 limits. Procedures shall be worked out in advance for permitting onsite volunteers to receive radiation exposures in the course of carrying out lifesaving and other K.2 Each applicant shall describe an onsite radiation protection program to be implemented during emergencies, including methods to implement dose limits. General guidance on dose limits for workers performing emergency services can be found in EPA 400-R-92-001.

K.2 The licensee has provided an onsite radiation protection program to be implemented during emergencies, and has included methods to implement exposure guidelines. [LS]

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K.3.a Each organization shall make provision for 24-hour-per-day capability to determine the doses received by emergency personnel involved in any nuclear accident, including volunteers. Each organization shall make provisions for distribution of dosimeters, both self-reading and permanent record devices.

K.3.a Each organization shall describe how they would determine the doses received by emergency personnel involved in any nuclear accident, including volunteers.

K.3.b Each organization shall describe how they would acquire and distribute dosimeters, both direct-reading and permanent record devices.

K.3.a The licensee has made provisions for 24-hour-per-day capability to determine the doses received by emergency personnel involved in any nuclear accident, including volunteers. The licensee has made provisions for equipment at the site for personnel monitoring, including distribution of dosimeters (both self-reading and permanent record devices).

[10 CFR Part 50, App. E, IV.E.1] [LS]

  • K.3.a The licensee has confirmed that the State or local organizations have made provisions for 24-hour-per-day capability to determine the doses received by emergency personnel involved in any nuclear accident, including volunteers. The State or local organizations have made provisions for distribution of dosimeters, both self-reading and permanent record devices. [SS]

K.3.b Each organization shall ensure that dosimeters are read at appropriate frequencies and provide for maintaining dose records for emergency workers involved in any nuclear accident.

K.3.b The licensee has ensured that dosimeters are read at appropriate frequencies, and has provided for maintaining dose records for emergency workers involved in any nuclear accident. [LS]

  • K.3.b The licensee has confirmed that the State or local organizations have ensured that dosimeters are read at appropriate frequencies, and have provided for maintaining dose records

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K.4 Each State and local organization shall establish the decision chain for authorizing emergency workers to incur exposures in excess of the EPA General Public Protective Action Guides (i.e., EPA PAGs for emergen-cy workers and lifesaving activities).

K.4 Each organization shall describe a decision chain for authorizing emergency workers to incur exposures in excess of the EPA dose limits for workers performing emergency services.

K.5.a Each organization, as appropriate, shall specify action levels for determining the need for decontamination.

K.5.a Each organization, as appropriate, shall specify action levels for determining the need for decontamination of emergency workers, equipment and vehicles, and the general public an their possessions.

K.5.b Each organization, as appropriate, shall establish the means for radiological decontamination of emergency personnel wounds, supplies, instruments and equipment, and for waste disposal.

K.5.b Each organization, as appropriate, shall describe a means for radiological decontamination of emergency personnel wounds, supplies, instruments, and equipment.

K.5.b The licensee has established (as appropriate) the means for radiological decontamination of emergency personnel and wounds - including facilities, equipment, instruments and supplies - and for waste disposal. [10 CFR Part 50, App. E, IV.E.3] [LS]

  • K.5.b The licensee has confirmed that the State or local organizations have established (as appropriate) the means for radiological decontamination of emergency personnel and wounds -

including facilities, equipment, instruments and supplies - and for waste disposal. [SS]

K.6 Each licensee shall provide onsite contamination control measures including:

a. area access control;
b. drinking water and food supplies;
c. criteria for permitting return of areas and items to normal use (see EPA 400-R-92-001 guidance).

K.6 The licensee has provided onsite contamination control measures, including area access control, and drinking water and food supplies. [LS]

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K.7 Each licensee shall provide the capability for decontaminating relocated onsite personnel, including provisions for extra clothing and decontaminants suitable for the type of contamination expected, with particular attention given to radioiodine contamination of the skin.

K.7 The licensee has provided the capability for decontaminating relocated onsite personnel, including providing for extra clothing and decontaminants suitable for the type of contamination expected, with particular attention given to radioiodine contamination of the skin. [LS]

L. Medical and Public Health Support - 10 CFR 50.47(b)(12)

L.1 Each organization shall arrange for local and backup hospital and medical services having the capability for evaluation of radiation exposure and uptake, including assurance that persons providing these services are adequately prepared to handle contaminated individuals.

L.1 Each organization shall describe the contacts and arrangements made for local and backup hospital and medical services having the capability for evaluation of radiation exposure and uptake.

L.1 The licensee has arranged for local and backup hospital and medical services having the capability for evaluation of radiation exposure and uptake, including assurance that persons providing these services are adequately prepared to handle radiation emergencies, including contaminated persons. [10 CFR Part 50, App. E, IV.E.5, IV.E.7] [LS]

  • L.1 The licensee has confirmed that the State or local organizations have arranged for local and backup hospital and medical services having the capability for evaluation of radiation exposure and uptake, including assurance that persons providing these services are adequately prepared to handle radiation emergencies, including contaminated individuals. [10 CFR Part 50, App. E, IV.E.5, IV.E.7] [SS]

L.2 Each licensee shall provide for onsite first aid capability.

L.2 The licensee has provided for onsite first aid capability, including facilities and medical supplies. [10 CFR Part 50, App. E, IV.E.4] [LS]

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L.3 Each State shall develop lists indicating the location of public, private and military hospitals and other emergency medical services facilities within the State or contiguous States considered capable of providing medical support for any contaminated injured individual. The listing shall include the name, location, type of facility and capacity and any special radiological capabilities. These emergency medical services should be able to radiologically monitor contamination personnel, and have facilities and trained personnel able to care for contaminated injured persons.

L.2 Each State shall develop lists indicating the location of public, private, and military hospitals and other emergency medical services facilities within the State or contiguous States considered capable of providing medical support for any contaminated injured individual. The listing shall include the name, location, type of facility and capacity, and any special radiological capabilities. Contacts and arrangements made in developing this list should be described.

L.4 Each organization shall arrange for transporting victims of radiological accidents to medical support facilities.

L.4 The licensee has arranged for transporting victims of radiological accidents, including contaminated injured individuals, from the site to offsite medical support facilities. [10 CFR Part 50, App. E, IV.E.6] [LS]

  • L.4 The licensee has confirmed that the State or local organizations have arranged for transporting victims of radiological accidents to medical support facilities. [SS]

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M. Recovery and Reentry Planning

- 10 CFR 50.47(b)(13)

(Not Applicable to ESPs)

(Not Applicable to ESPs)

M.1 Each organization, as appropriate, shall develop general plans and procedures for reentry and recovery and describe the means by which decisions to relax protective measures (e.g., allow reentry into an evacuated area) are reached. This process should consider both existing and potential conditions.

M.2 Each licensee plan shall contain the position/title, authority and responsibilities of individuals who will fill key positions in the facility recovery organization. This organization shall include technical personnel with responsibilities to develop, evaluate and direct recovery and reentry operations. (See NUREG-0696 and Supplement 1 to NUREG-0737.)

M.3 Each licensee and State plan shall specify means for informing members of the response organizations that a recovery operation is to be initiated, and of any changes in the organizational structure that may occur.

M.4 Each plan shall establish a method for periodically estimating total population exposure.

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N. Exercises and Drills -

10 CFR 50.47(b)(14)

(Not Applicable to ESPs)

N.1.a 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.

The emergency preparedness exercise shall simulate an emergency that results in offsite radiological releases which would require response by offsite authorities. Exercises shall be conducted as set forth in NRC and FEMA rules.

N.1.a The exercise was conducted as set forth in NRC rules, and tested the integrated capability of the emergency preparedness plans and organizations.

The exercise simulated an emergency onsite that resulted in offsite radiological releases, necessitating response by offsite authorities. [10 CFR Part 50, App. E, IV.F.2.a] [US]

  • N.1.a The licensee has confirmed that the exercise was conducted as set forth in FEMA rules, and tested the integrated capability of the emergency preparedness plans and organizations.

The exercise simulated an emergency onsite that resulted in offsite radiological releases, necessitating response by offsite authorities. [10 CFR Part 50, App. E, IV.F.2.a] [US]

N.1 Licensee conducts a full-participation exercise to evaluate major portions of emergency response capabilities, which includes participation by each State and local agency within the plume exposure EPZ, and each State within the ingestion control EPZ.

N.1.b An exercise shall include mobilization of State and local personnel and resources adequate to verify the capability to respond to an accident scenario requiring response.

The organization shall provide for a critique of the annual exercise by Federal and State observers/

evaluators. The scenario should be varied from year to year such that all major elements of the plans and preparedness organizations are tested within a five-year period. Each organization should make provisions to start an exercise between 6:00 p.m.

and midnight, and another between midnight and 6:00 a.m. once every six N.1.b The exercise included mobilization of State and local personnel and resources, adequate to verify the capability to respond to an accident scenario necessitating response. The licensee provided for a critique of the exercise by Federal and State observers/evaluators. [10 CFR Part 50, App. E, IV.F.2.a, g] [US]

  • N.1.b The licensee has confirmed that the exercise included mobilization of State and local personnel and resources, adequate to verify the capability to respond to an accident scenario necessitating response. The State and local organizations provided for a

41 Complete & Integrated Plans (NUREG-0654/FEMA-REP-1)

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Some exercises should be unannounced.

critique of the exercise by Federal and State observers/evaluators. [10 CFR Part 50, App. E, IV.F.2.a, g] [US]

N.2 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 shall be supervised and evaluated by a qualified drill instructor. Each organization shall conduct drills, in addition to the annual exercise at the frequencies indicated below:

a. Communication Drills -

Communications with State and local governments within the exposure pathway Emergency Planning Zone shall be tested monthly.

Communications with Federal emergency response organizations and States within the ingestion pathway shall be tested quarterly.

Communications between the nuclear facility, State and local emergency operations centers, and field assessment teams shall be tested annually. Communication drills shall also include the aspect of understanding the content of messages.

b. Fire Drills - Fire drills shall be conducted in accordance with the plant (nuclear facility) technical specifications.

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c. Medical Emergency Drills - A medical drill involving a simulated contaminated individual which contains provisions for participation by the local support services agencies (i.e., ambulance and offsite medical treatment facility) shall be conducted annually. The offsite portions of the medical drill may be performed as part of the required annual exercise.
d. Radiological Monitoring Drills -

Plant environs and radiological monitoring drills (onsite and offsite) shall be conducted annually. These drills shall include collection and analysis f all ample eia (e.g., water, vegetation, soil and air), and provisions for communications and record keeping. The State drills need not be at each site. Where appropriate, local organizations shall participate.

e. Health Physics Drills - (1) Health Physics drills shall be conducted semi-annually which involve response to, and analysis of, simulated elevated airborne and liquid samples and direct radiation measurements in the environment. The State drills need not be at each site.

(2) Analysis of inplant liquid samples with actual elevated radiation levels including use of the post-accident sampling system shall be included in Health Physics drills by licensees annually.

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N.3 Each organization shall describe how exercises and drills are to be carried out to allow free play for decisionmaking and to meet the following objectives. Pending the development of exercise scenarios and exercise evaluation guidance by NRC and FEMA, the scenarios for use in exercises and drills shall include, but not be limited to, the following:

a. The basic objective(s) of each drill and exercise and appropriate evaluation criteria;
b. The date(s), time period, place(s) and participating organizations;
c. The simulated events;
d. A time schedule of real and simulated initiating events;
e. A narrative summary describing the conduct of the exercises or drills to include such things as simulated casualties, offsite fire department assistance, rescue of personnel, use of protective clothing, deployment of radiological monitoring teams, and public information activities; and
f. A description of the arrangements for and advance materials to be provided to official observers.

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N.4 Official observers from Federal, State or local governments will observe, evaluate, and critique the required exercises. A critique shall be scheduled at the conclusion of the exercise to evaluate the ability of organizations to respond as called for in the plan. The critique shall be conducted as soon as practicable after the exercise, and a formal evaluation should result from the critique.

N.5 Each organization shall establish means for evaluating observer and participant comments on areas needing improvement, including emergency plan procedural changes, and for assigning responsibility for implanting corrective actions. Each organization shall establish management control used to ensure that corrective actions are implemented.

N.5 The licensee established means for evaluating observer and participant comments on areas needing improvement, including emergency plan procedural changes, and for assigning responsibility for implementing corrective actions. The licensee established management control used to ensure that corrective actions are implemented. [10 CFR Part 50, App. E, IV.F.2.g] [LS]

  • N.5 The licensee has confirmed that the State and local organizations established means for evaluating observer and participant comments on areas needing improvement, including emergency plan procedural changes, and for assigning responsibility for implementing corrective actions. The State and local organizations established management control used to ensure that corrective actions are implemented. [10 CFR Part 50, App. E, IV.F.2.g] [SS]

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O. Radiological Emergency Resp.

Training - 10 CFR 50.47(b)(15)

O.1 Each organization shall assure the training of appropriate individual.

O.1 The licensee has assured the training of appropriate individuals. [10 CFR Part 50, App. E, IV.F.1] [LS]

  • O.1 The licensee has confirmed that the State and local organizations have assured the training of appropriate individuals. [SS]

O.1.a Each facility to which the plant applies shall provide site specific emergency response training for those offsite emergency organizations who may be called upon to provide assistance in the event of an emergency.

O.1.a The licensee has provided an opportunity for site specific emergency response training for those offsite emergency organizations that may be called upon to provide assistance in the event of an emergency. [10 CFR Part 50, App. E, IV.F.1] [US]

O.1.b Each offsite response organization shall participate in and receive training. Where mutual aid agreements exist between local agencies such as fire, police and ambulance/rescue, the training shall also be offered to the other departments who are members of the mutual aid district.

  • O.1.b The licensee has confirmed that the State and local organizations have participated in, and received, training.

Where mutual aid agreements exist between local agencies such as fire, police and ambulance/rescue, the training was offered to the other departments that are members of the mutual aid district. [SS]

O.2 The training program for members of the onsite emergency organization shall, besides classroom training, include practical drills in which each individual demonstrates ability to perform his assigned emergency function. During the practical drills, on-the-spot correction of erroneous performance shall be made and a demonstration of the proper performance offered by the instructor.

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O.3 Training for individuals assigned to licensee first aid teams shall include courses equivalent to Red Cross Multi-Media.

O.3 Training for individuals assigned to licensees first aid teams included courses equivalent to Red Cross Multi-Media. [10 CFR Part 50, App. E, IV.F.1.vi] [LS]

O.4 Each organization shall establish a training program for instructing and qualifying personnel who will implement radiological emergency response plans. The specialized initial training and periodic retraining programs (including the scope, nature and frequency) shall be provided in the following categories:

a. Directors or coordinators of the response organizations;
b. Personnel responsible for accident assessment;
c. Radiological monitoring teams and radiological analysis personnel;
d. Police, security and fire fighting personnel;
e. Repair and damage control/correctional action teams (onsite);
f. First aid and rescue personnel;
g. Local support services personnel including Civil Defense/Emergency Service personnel;
h. Medical support personnel;
i. Licensees headquarters support personnel;
j. Personnel responsible for transmission of emergency information and instructions.

O.1 Each organization shall describe a training program for instructing and qualifying personnel who will implement radiological emergency response plans. Specialized initial training and periodic retraining shall be provided in the following categories:

a. directors or coordinators of the response organizations
b. personnel responsible for accident assessment
c. radiological monitoring teams and radiological analysis personnel
d. police, security and fire fighting personnel
f. first aid and rescue personnel
g. local support services personnel, including civil defense/emergency service personnel
h. medical support personnel
i. personnel responsible for transmission of emergency information and instructions O.5 Each organization shall provide for the initial and annual retraining of personnel with emergency response responsibilities.

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P. Responsibility for Planning Effort

- 10 CFR 50.47(b)(16)

P.1 Each organization shall provide for the training of individuals responsible for the planning effort.

P.1 Each organization shall [describe]

for the training of individuals responsible for the planning effort.

P.2 Each organization shall identify by title the individual with the overall authority and responsibility for radiological emergency response planning.

P.2 Each organization shall identify by title the individual with the overall authority and responsibility for radiological emergency response planning.

P.3 Each organization shall designate an Emergency Planning Coordinator with responsibility for the develop-ment and updating of emergency plans and coordination of these plans with other response organizations.

P.3 Each organization shall designate an Emergency Planning Coordinator with responsibility for the development and updating of emergency plans and coordination of these plans with other response organizations.

P.4 Each organization shall update its plan and agreements as needed, review and certify it to be current on an annual basis. The update shall take into account changes identified by drills and exercises.

P.4 Each organization shall update its plan and agreements as needed.

P.4 The licensee has certified its plan and agreements as current. [LS]

  • P.4 The licensee has confirmed that the State and local organizations have certified their plans and agreements as current. [SS]

P.5 The emergency response plans and approved changes to the plans shall be forwarded to all organizations and appropriate individuals with responsibility for implementation of the plans. Revised pages shall be dated and marked to show where changes have been made.

P.5 The emergency response plans and approved changes to the plans shall be forwarded to all organizations and appropriate individuals with responsibility for implementation of the plans. Revised pages shall be dated and marked to show where changes have been made.

P.5 The licensee has forwarded its emergency response plans to all organizations and appropriate individuals with responsibility for implementation of the plans [LS]

  • P.5 The licensee has confirmed that the State and local organizations have forwarded their emergency response plans to all organizations and appropriate individual with responsibility for implementation of the plans. [SS]

P.6 Each plan shall contain a detailed listing of supporting plans and their source.

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P.7. Each plan shall contain as an appendix listing, by title, procedures required to implement the plan. The listing shall include the sections(s) of the plan to be implemented by each procedure.

P.8 Each plan shall contain a specific table of contents. Plans submitted for review should be cross-referenced to these criteria.

P.6 Each plan shall contain a specific table of contents. Plans submitted for review should be cross-referenced to the criteria in this supplement.

P.9 Each licensee shall arrange for and conduct independent reviews of the emergency preparedness program at least every 12 months. The review shall include the emergency plan, its implementing procedures and practices, training, readiness testing, equipment, and interfaces with State and local governments. Management controls shall be implemented for evaluation and correction of review findings. The result of the review, along with recommendations for improvements, shall be documented, reported to appropriate licensee corporate and plant management, and involved Federal, State and local organizations, and retained for a period of five years.

P.10 Each organization shall provide for updating telephone numbers in emergency procedures at least quarterly.

9.1 The licensee has submitted detailed implementing procedures for its emergency plan no less than 180 days prior to fuel load.

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