ML18162A103

To IP-EP-420, Use of Potassium Iodide by Indian Point Personnel During and Emegency

ML18162A103
Person / Time
Site:	Indian Point
Issue date:	05/23/2018
From:	Karsten C Entergy Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
IP-EP-420, Rev 6
Download: ML18162A103 (27)

Text

IPEC EMERGENCY PLAN DISTRIBUTION LIST IP3 CONTROL ROOM IP3 SHIFT MANAGER IP2 CONTROL ROOM IPEC TSC IP2 SIMULATOR IP2 SIMULATOR - CLASSROOM 4 IP2 SIMULATOR-CLASSROOM 5 NRG RESIDENT INSPECTOR DOC CONTROL DESK NRG _.....,----*--1 r-**-*rr r.:: ("'"',-r ! \\ / C F'" r i I,, L.

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~RC MAY 30 20*;8 I

NEW YORK STATE OEM WESTCHESTER COUNTY OEM ROCKLAND COUNTY FIRE AND EMERGENCY SERVICES ORANGE COUNTY EMERGENCY SERVICES CENTER PUTNAMCOUNJ.:Y.BUBEAU.OF

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Page 1 of 2 DELIVERED BY DOCUMENTS DELIVERED BY DOCUMENTS DELIVERED BY DOCUMENTS DELIVERED BY DOCUMENTS

. DELIVERED BY DOCUMENTS DELIVERED BY DOCUMENTS DELIVERED BY DOCUMENTS NRG NRG - ROCKVILLE, MD ADDRESS JAMES DANNA DEPUTY DIRECTOR TED FISCH DENNIS DELBORGO NICHOLAS LONGO SHANNON FISHER KEN CLAIR IP3 53FT. CCR '

IP3 53FT. ELEVATION IP2 53FT. CCR IP2 53FT. ELEVATION IP2 SIMULATOR BLDG.

IP2 SIMULATOR BLDG.

IP2 SIMULATOR BLDG.

IP2 88FT. ELEVATION OFFSITE OFFSITE OFFSITE OFFSITE OFFSITE OFFSITE OFFSITE 1 COPY OF ALL EP'S 1 COPY OF ALL EP'S 1 COPY OF ALL EP'S 1 COPY OF ALL EP'S 1 COPY OF ALL EP'S 1 COPY OF ALL EP'S 3 COPIES OF ALL EP'S EXCEPT E-PLAN 1 COPY OF ALL EP'S 1 COPY OF ALL EP'S AND GENERAL RECORDS EXCEPT IP-EP-115 1 COPY OF ALL EP'S AND GENERAL RECORDS EXCEPT IP-EP-115 1 COPY OF ALL EP'S AND GENERAL RECORDS EXCEPT IP-EP-115 1 COPYOFTHE FOLLOWING:

E-PLAN, IP-EP-115, 120, 210,220,230,250,310, 320,340,360,410,420, 430, 620 & IP-1055 1 COPY OF E-PLAN, IP-EP-310 & 340 1 COPY OF E-PLAN, IP-EP-310 & 340 1 COPY OF E-PLAN, IP-EP-310 & 340 1 COPY OF E-PLAN, IP-EP-310 & 340 Mitf JJH]1f.EOLLOWING LOCATIONS ARE *ELECTRONIC DISTRIBUTIONS*

-::::=-Entergy Indian Point Energy Center Document Control 450 Broadway Buchanan, NY 10511 TO:

DISTRIBUTION CONTROLLED DOCUMENT TRANSMITTAL FROM: IPEC DOCUMENT CONTROL** 3RD FLOOR ADMIN BLDG DATE: May 23, 2018 PHONE#: 914-254-6835 TRANSMITTAL#: EP-18-0016 The Document(s) identified below are forwarded for use. Please review to verify receipt, incorporate the document(s) into your controlled document file, properly disposition superseded, voided, or inactive document(s).

Sign and return the receipt acknowledgement below within ten (10) working days.

AFFECTED DOCUMENT: IPEC EMERGENCY PLAN PROCEDURES DOC#

REV#

TITLE INSTRUCTIONS THE FOLLOWING PROCEDURE(S), DRA WING(S), GRAPHS ARE BEING REVISED, PLEASE REMOVE YOUR CURRENT COPY AND REPLACE WITH ATTACHED UPDATED ONE:

IP-EP-420 REV.6

• L EFFECT.I\\IE MAY 30 2018

[)ATE RECEIPT OF THE ABOVE LISTED DOCUMENT(S) IS HEREBY ACKNOWLEDGED. I CERTIFY THAT ALL SUPERSEDED, VOID, OR INACTIVE COPIES OF THE ABOVE LISTED DOCUMENT(S) IN MY POSSESSION HAVE BEEN REMOVED FROM USE AND ALL UPDATES HAVE BEEN PERFORMED IN ACCORDANCE WITH EFFECTIVE DATE(S)

(IF APPLICABLE) AS SHOWN ON THE DOCUMENT(S).

Ol NAME (PRINT)

SIGNATURE DATE COPY LOCATION

ATTACHMENT 9.1 10 CFR 50.54(Q)(2) REVIEW SHEET1 OF2 Procedure/Document Numb.er: IP-EP-420 I Revision: 6 Equipment/Facility/Other: Indian Point Energy Center (IPEC)

Title:

Use of Potassium Iodide by Indian Point Personnel During an Emergency Part I. Description of Activity Being Reviewed (event or action, or series of actions that have the potential to affect the emergency plan or have the potential to affect the implementation of the emergency plan):

See attached revision matrix.

Part II. Emergency Plan Sections Reviewed (List all emergency plan sections that were reviewed for this activity by number and title. IF THE ACTIVITY IN ITS ENTIRETY IS AN EMERGENCY PLAN CHANGE OR EAL OR EAL BASIS CHANGE, ENTER THE SCREENING PROCESS. NO 10 CFR 50.54(q)(2) DOCUMENTATION IS REQUIRED.

Part 2 Section H:

Part 2 Section J:

Part 2 Section K:

Emergency Facilities and Equipment

• Protective Response Radiological Exposure Control Part Ill. Ability to Maintain the Emergency Plan (Answer the following questions related to impact on the ability to maintain the emergency plan):

1.

Do a~ elements of the activity change information contained in the emergency plan (procedure section 3.0[6))?

YES D NO l8l IF YES, enter screening processifor that element

2.

Do any elements of the activity change an emergency classification Initiating Condition, Emergency Action Level (EAL), associated EAL note or associated EAL basis information or their underlying calculations or assumptions?

YES D NO l8l IF YES, enter screening process for that element

3.

Do any elements of the activity change the process or capability for alerting and notifying the public as described in the FEMA-approved Alert and Notification System design report?

YES D NO 1:81 IF YES, enter screening process for that element

4.

Do any elements of the activity change the Evacuation Time Estimate results or documentation?

YES D NO l8l IF YES, enter screening process for that element

5.

Do a~ elements of the activity change the Onshift Staffing Analysis results or documentation?

YES D NO l8l IF YES, enter screening process for that element

/

EN-EP-305 REV 4

ATTACHMENT9.1 10 CFR 50.54(Q)(2) REVIEW SHEET20F2 Procedure/Document Number: IP*EP-420 I Revision: 6 Equipment/Facility/Other: Indian Point Energy Center (IPEC)

Title:

Use of Potassium Iodide by Indian Point Personnel During an Emergency Part IV. Maintaining the Emergency Plan Conclusion The questions in Part II do not represent the sum total of all conditions that may cause a change to or impact the ability to maintain the emergency plan. Originator and reviewer signatures in Part IV document that a review of all elements of the proposed change have been considered for their impact on the ability to maintain the emergency plan and their potential to change the emergency plan.

1.

Provide a brief conclusion that describes how the conditions as described in the emergency plan are maintained with this activity.

2.

Check the box below when the 1 O CFR 50.54{q)(2} review completes all actions for all elements of the actiVity - no 10 CFR 50.54(q)(3) screening or evaluation is required for any element. Otherwise, leave the checkbox blank.

1811 have completed a review of this activity in accordance with 1 O CFR 50.54(q}(2) and determined that the effectiveness of the emergency plan is maintained. This activity does not make any changes to the emergency plan.

No further actions are required to screen or evaluate this activity under 1 O CFR 50.54(q)(3).

The proposed changes to IP-EP-420, Use of Potassium Iodide by Indian Point Personnel During an Emergency, update attachment 9.3 to be consistent with the current revision of the NYS OOH "Potassium Iodide (Kl) and Radiation Emergencies Fact Sheet" A review of this activity in accordance with 10 CFR 50.54(q)(2) has been completed and determined that the effectiveness of the emergency plan Is maintained. This activity does not make any changes to the requirements for performing dose assessment or offsite notifications. The changes made to IP*EP-420 do not require a change to the Emergency Action Level scheme, On shift staffing study, or the IPEC Emergency Plan. No further actions are required to screen or evaluate this activity under 10 CFR 50.54(q)(3).

Part V. Signatures:

Preparer Name (Print)

Casey Karsten Sr. Emergency Planner (Optional) Reviewer Name (Print)

Reviewer Name (Print)

Timothy F. Garvey Nuclear EP Project Manager Reviewer Name (Print)

Frank J. Mitchell Manager, Emergency Planning or designee Preparer Signature Date:

r/,s,a Reviewer Signature Date:

Reviewer Signature e""';'_

I """"-

EN-EP-305 REV 4

Revision Matrix IP-EP-420 "Use of Potassium Iodide by Indian Point Personnel During an Emergency" Revision 6 Number Location Existing Condition Proposed Condition

1.

Page4 of4 The Assembly Area Coordinators SHALL issue Kl to The Assembly Area Coordinators SHALL issue Kl to Section 5.6.1 personnel in the GSB and EEC.

personnel in the GSB/EEC..3 This fact sheet is about a new policy for people, This fact sheet is about the NYS policy for people,

2.

Sheet 1 of2 especially those who live within ten miles of a nuclear especially those who live within ten miles of a nuclear Opening power plant, who may be exposed to radiation from a power plant, who may be exposed to radiation from a statement nuclear plant emergency.

nuclear plant emergency..3

3.

Sheet 1 of2 How does potassium iodide work?

How does Kl work?

Question#2 The table below shows the smallest Kl dose that The table on the next page shows the smallest Kl different age groups can take which will protect the dose that different age groups can take which will protect the thyroid. Kl comes in liquid, 65-mg tablets thyroid. At the moment, the pill only comes in a 130 and 130-mg tablets. Since it is hard to cut many pills, mg tablet. Since it is hard to cut many pills the State the State Health Commissioner says that, in an.3 Health Commissioner says that, in an emergency, it is emergency, it is safe for children at school or day

4.

-Sheet 1 of 2 safe for children at school or day care centers to take care centers to take the whole pill. It's better for Question # 10 the whole pill. For children or babies who cannot take children under 12 years old to take the 65-mg pill, but pills, parents and caregivers can cut or crush the pill to it is safe to take the 130-mg pill if that is the only one make lower doses. For example, if 130 mg pill were you have. For children or babies who cannot take dissolved in 8 ounces of juice or other liquid, on ounce pills, parents and caregivers can cl,lt or crush the pill would contain 16 mg of Kl.

to make lower doses, or give the liquid form of Kl..3 Deleted the old table and inserted a new table

5.

Sheet2 of2 Old Table consistent with the NYS Fact Sheet Question # 1 O.3 Kl is helpful for about 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. You should keep Kl is helpful for about 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. You should keep

6.

Sheet2 of 2 taking it until the health department says to stop or you taking it once a day until the health department says Question # 11 are out of the emergency area.

to stop, or you are out of the emergencv area..3 Kl can come as a pill or a liquid, but right now it is only Kl can come as a pill or a liquid. Pills are available in

7.

Sheet2 of2 available as a pill. It may also be available as a liquid 65-mg or 130-mg doses. Kl is also available as a Question # 12 soon.

liquid.

. *--*---.. *---------*-*--*----------**--******--*--*---***--------*****------*-******-*--*-***-**** Page 1

Revision Matrix IP-EP-420 "Use of Potassium Iodide by Indian Point Personnel During an Erner ency" Revision 6.3 The manufacturers say Kl stays 'fresh' for 3 - 5 years.

The manufacturers say Kl stays "fresh" for 5-7 years.

8.

Sheet2 of2 If you keep it in a dry dark and cool place, it should last If you keep it in a dry, dark and cool place, it sho_uld Question # 13 for manv vears.

last for manv vears.

Yes, though it may not widely available in drugstores near you. Since it is not a prescription drug, you can It is not widely available in drugstores yet, but since it is buy it over the Internet. As with other drugs, make.3 not a prescription drug, you can buy it over the internet.

sure the Kl you buy has been approved by the FDA.

9.

Sheet2 of 2 We hope to give a supply of Kl to people who live A supply of Kl has been made available to people Question # 15 within 10 miles of a nuclear power plant in New York who live within 10 miles of a nuclear power plant in State.

New York State. If you live within 10 miles of a nuclear power plant and did not receive Kl, contact your local Office of Emergency Management.

For additional information contact:

For additional information contact:

New York State Department of Health lnfoline at 1-800-458-1158, extension 2-7550 New York State Department of Health info line 1-800-or e-mail BERP@health.ny.gov Other sources of information:

458-1158, exten~ion 2-7550 or hllJ;!s://www.fda.gov/downloads/drugs/guidancecomnlianc BERP@health.state.ny.us eregulatoQ'.information/guidances/ucm080542.Qdf Other sources of information:

hl!Qs://www.fda.gov/drugs/emergencmrenaredness/bioterr

10.

orismanddruggrenaredness/ucm072265.htm www.1da.gov/oder/guidance/4825fnl.htm hllJ;!s://www.fda.gov/drugs/emergencmregaredness/bioterr orismanddrugnregaredness/ucm07226 l.htm www./int/environmental information information resou hllJ;!s://emergency.cdc.gov/radiation/ki.as12 rces.documents/iodine/guide.~gf httn://www.who.int/ionizing radiation/Rub meet/tech brie www.health.state.us/nysdoh/consumer/environ/homeen fings/notassium iodide/en/

vi.htm I

hllJ;!://www.health.ny.gov/environmental/radiological/Qota ssium iodide/

• • • • • • • • • • -***-***************-** ***-*-***********.. -**** **********-********--*-*-****-*****--*-*****-*--***-**-********** --***-*** * *-*** Page 2

Knudsen, Lenore From:

mtrott@entergy.com t:

Subject:

Tuesday, May 22, 201810:13 AM ERO Duty Change; Trott, Matthew ERO DUTY CHANGE Please update the web with this EP Swap Request. Thank you.

Reliever_FirstName - Richard Motko Reliever_ Title - TSC Reactor Engineer Reliever_ Organization - A Reliever_ WorkPhone - 914 254 6865 Reliever_Email - rmotko@,entergy.com Contact_FullName - Matthew Keegan Trott Contact_Title -TSC Reactor Engineer Contact_ Organization - B Contact_ WorkPhone-9142546868 Contact_Email-mtrott@entcrgy.com Relief_start - 05/26/18 relief end - 5/28/18 1

Knudsen, Lenore From:

aking2@entergy.com nt:

o:

Subject:

Tuesday, May 22, 2018 1:34 PM ERO Duty Change; King, Anthony P ERO DUTY CHANGE Please update the web with this EP Swap Request. Thank you.

Reliever FirstName -Adam Kaczmarek Reliever_ Title - Putnam County Liason Reliever_ Organization - Bravo Reliever_ WorkPhone - 914-254-7670 Reliever_Email - akaczma@entergy.com Contact_FullName - Anthony King Contact_Title - Putnam County Liason Contact_ Organization - Charlie Contact_ WorkPhone-914-254-7477 Contact_Email - aking2@entergy.com Relief_start - 06/01/18 relief end - 06/03/18 1

Knudsen, Lenore mvasely@entergy.com From:

~nt:

.iro:

Subject:

Tuesday, May 22, 2018 4:13 PM ERO Duty Change; Vasely, Michael J ERO DUTY CHANGE Please update the web with this EP Swap Request. Thank you.

Reliever_FirstName - Vincent Andreozzi Reliever_ Title - TSC Manager Reliever_ Organization - Delta Reliever_ WorkPhone - 914-254-6816 Reliever _Email - vandreo@entergy.com Contact_FullName - Michael Vasely Contact_ Title - TSC Manager Contact_ Organization - Bravo Contact_ Work:Phone - 914-254-6887 Contact_Email - mvasely@entergy.com Relief start - 05/24/18 relief end - 05/28/18 1

Knudsen, Lenore From:

Vasely, Michael J nt:

o:

Tuesday, May 22, 2018 4:15 PM ERO Duty Change

Subject:

RE: ERO DUTY CHANGE Disregard this one. Another form is being sent with all the fields filled in.

From: mvasely@entergy.com [1]

Sent: Tuesday, May 22, 2018 4:11 PM To: ERO Duty Change; Vasely, Michael J

Subject:

ERO DUTY CHANGE Please update the web with this EP Swap Request. Thank you.

Reliever_FirstNrune - Vincent Andreozzi Reliever_ Title - TSC Manager Reliever_ Organization - Delta Reliever WorkPhone - 914-254-6816 Reliever_Email - vandrco@entergy.com Contact_FullName - Michael Vasely Contac(_ Title - TSC Manager Contact_ Organization -

Contact WorkPhone -

ontact=Email -

elief_ start -

relief end -

1

Knudsen. Lenore From:

wscholt@entergy.com nt:

o:

Subject:

Wednesday, May 23, 2018 1:12 PM ERO Duty Change; Schoitens, WilJiam ERO DUTY CHANGE Please update the web with this EP Swap Request. Thank you.

Reliever_FirstName - Wesley 0Brien Reliever_Title - JIC Rad Advisor Reliever_ Organization "'. A Reliever_ Work.Phone - 2637 Reliever_Email - wobrien@entergy.com Contact FullName - William Scholtens Contact_Title - JIC Rad Advisor Contact_ Organization - D Contact_ WorkPhone-5405 Contact_Email - wscholt@entergy.com Relief_start- 06/04/18 relief_end - 06/08/18 1

A IPEC NON-QUALITY RELATED IP-EP-AD2 Revision 10 EMERGENCY PLAN PROCEDURE

-=-Entergy ADMINISTRATIVE PROCEDURES REFERENCE Use Page 1

of 1. 1 Emergency Planning Document Change Checklist Form (All sections must be completed, NIA or place a check on the line where applicable)

Section 1 Doc/Procedure Type:

AdministrativeO Implementing ~

EPLAN 0 N/AO Doc/Procedure No:

IP-EP-420 Doc/Procedure

Title:

Use of Potassium Iodide by Indian Point Personnel During an Emergency Corrective Action:

Yes~

NoO N/A O CR#:CR-IP2-2018-02682 CA-2 Section 2 Change Description

1. Ensure the following are completed, or are not applicable and are so marked:

a.

50.54q

[8J N/A D

b.

EN-FAP-OM-023

[8J NIA 0

c.

IP-SMM-AD-102

[8J N/AO

d.

OSRC O

NIA~

2. Transmittals are completed: D N/A D Date: __

3.

Ensure the proper revision is active in Merlin: D NIA D

4.

Approved doc/procedure delivered to Doc. Control for distribution: D NIA O Date:

5.

Position Binders updated: D N/A D Date: __

6.

Copy of EPDCC placed in EP file: D NIA D Date: __

7.

Supporting documentation is submitted as a general record in MERLIN: D N/A O Date: __

8. Word files are moved from working drafts folder to current revision folder in the EP drive:

D NIA D Date: __

Sheet 1 of 1

I P-SMM-AD-102 Rev:15 IPEC IMPLEMENTING PROCEDURE PREPARATION, REVIEW, AND APPROVAL Page 35 of 43 ATTACHMENT 10.2 IPEC PROCEDURE REVIEW AND APPROVAL Procedure

Title:

Use of Potassium Iodide by Indian Point Personnel During an Emergency Procedure No.

IP-EP-420 Existing Rev:

5 New Rev:

6 ORN/EC No:

DRN-18-00630 Procedure Activitli!

0 Converted To IPEC, Replaces:

Tempora!l! Procedure Change (MARK Applicable)

(MARK Applicable) 0 NEW PROCEDURE Unit 1 Procedure No.

0 EDITORIAL Temporary Procedure Change l8l GENERAL REVISION 0 PARTIAL REVISION 0

ADVANCE Temporary Procedure Change 0 EDITORIAL REVISION Unit 2 Procedure No:

D CONDITIONAL Temporary Procedure Change 0 VOID PROCEDURE Terminating Condition:

0 SUPERSEDED Unit 3 Procedure No:

0 RAPID REVISION Document in Microsoft Word:

0 VOID DRNffPC No(s):

00 Yes 0 No Revision Summary See 50.54q revision matrix.

Implementation Requirements Implementation Plan? 00 Yes D No Formal Training? D Yes 18!No Special Handling? D Yes OONo RPO Dept:

Emergency Planning Writer: (Print Name/Ext/Sign): Casey Karsten / 7789 / G

C?> 5§ Review and Approval (Per Attachment 10.1, IPEC Review And val Requirements)

1. 00 Technical Reviewer:

Michael York/

s-':.t3 Jf

2. 0

3. (ID

4. 0 Cross-Disciplinary Reviewers:

Dept:

Reviewer:

Print Name/ Signature/ Date)

Dept:

Reviewer: fl Pr~_}8)'1~"ature/ Date)

RPO-Responsibilities/Checklist:

Frank Mitchell/ ~

~~....lo...56 3/t~

(Print Name/ Signature/ Date)

D PAD required and is complete (PAD Approver and Reviewer qualifications have been verified) 00 Previous exclusion from further Ll-100 Review is still valid 0 PAD not required due to type of change as defined in 4.6 Non-Intent Determination Complete: --------------------------

NO change of purpose or scope NO reduction in the level of nuclear safety NO voiding or canceling of a procedure, unless requirements are incorporated into another procedure or the need for the procedure was eliminated (Print Name/ Signature/ Date)

NO change to less restrictive acceptance criteria NO change to steps previously identified as commitment steps NO deviation from the Quality Assurance Program Manual NO change that may result in deviations from Technical Specifications, FSAR, plant design requirements,

5. 0 On-Shift Shift Manager/CRS: -----------------------------

6. D User Validation:

User:

7. D Special Handling Requirements Understood:

(

(Print Name/ Signature/ Date)

Validator:

(Print Name/ Signature/ Date)

CONTROLLED

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• .. :\\,

• .:'/;.

a.

IPEC NON-QUALITY RELATED IP-EP-420 Revision 6

-~--. 1~ / ?f.O

..;Tl f oYt, EMERGENCY PLAN PROCEDURE IMPLEMENTING PROCEDURES REFERENCE USE Page 1

of 14 Use of Potassium Iodide by Indian Point Personnel During an Emergency Prepared by:

Casey Karsten

~ -

• s-:f13c~a Pnnt Name

/)'~,?~

Approval:

Frank J. Mitchell

/.,A,,.

Pnnt Name Effective Date: May 30, 2018 T'his procndure excluc!od frorn further u.. *1 00 r'E:view IP-EP-420 (Kl) R6.doc

)

-Entergy0 IPEC NON-QUALITY RELATED IP-EP-420 Revision 6 EMERGENCY PLAN PROCEDURE IMPLEMENTING PROCEDURES REFERENCE USE Page

_g of 14 Table of Contents 1.0 PURPOSE...................................... ;..................................................................... 3

2.0 REFERENCES

..................................................................................................... 3 3.0 DEFINITIONS....................................................................................................... 3 4.0 RESPONSIBILITIES............................................................................................. 3 5.0

• DETAILS............................................................................................................... 4 6.0 INTERFACES....................................................................................................... 5 7.0 RECORDS............................................................................................................ 5 8.0 REQUIREMENTS AND COMMITMENT CROSS-REFERENCE.......................... 5 9.0 ATTACHMENTS................................................................................................... 5 9.1 Patient Package Insert for Thyro-Block Potassioum Iodide...................................... 6 9.2 Locations of Potassium Iodide.................................................................................. 7 9.3 DOH: USE OF Kl DURING RADIOLOGICAL EMERGENCIES INFORMATION FOR THE PUBLIC.. 8 9.4 New York State Policy on Potassium Iodide (Update June 2009)...................... 10

Q IPEC NON-QUALITY RELATED IP-EP-420 Revision 6

~E t2 n ergy0 EMERGENCY PLAN PROCEDURE IMPLEMENTING I

PROCEDURES REFERENCE USE Page

~

of 14 I

Use of Potassium Iodide by Indian Point Personnel During an Emergency 1.0 PURPOSE The purpose of this procedure is to provide instructions for the use of thyroid blocking Potassium Iodide (Kl) by Indian Point Energy Center personnel during an emergency.

2.0 REFERENCES

2.1 New York State Implementation of the use of Potassium Iodide (Kl) as a Protective Action for the Public.

2.2 EPA-400-R-92-001, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents.

3.0 DEFINITIONS 3.1 EOF is the Emergency Operations Facility 3.2 TSC is the Technical Support Center 3.3 OSC is the Operations Support Center 3.4 CDE is Committed Dose Equivalent 3.5 TEDE is Total Effective Dose Equivalent 3.6 Kl is Potassium Iodide 4.0 RESPONSIBILITIES 4.1 Emergency Plant Manager is to approve issuing Potassium Iodide to Entergy workers within the Protected Area.

4.2 Emergency Director is to approve issuing Potassium Iodide to Entergy personnel outside the Protected Area.

4.3 Radiological Assessment Coordinator is responsible to supply Emergency Director dose assessment calculations to determine issuing of Potassium Iodide to personnel outside the protected area.

4.4 TSC Radiological Coordinator is responsible to supply the Emergency Plant Manager dose assessment calculations to determine issuing of Potassium Iodide within the Protected Area.

4.5 Emergency Planning is to maintain a stock of Potassium Iodide at each identified location to assure enough is available to ensure the distribution of Kl for every employee, contractor and visitor for a single adult dose of 130 milligrams and additional supplies exist for ERO members for up to 4 days usage at a dosage of 130 milligrams per 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period or 2800 single adult doses, whichever is greater.

\\

-Enlergy0 IPEC NON-QUALITY RELATED IP-EP-420 Revision 6 EMERGENCY PLAN PROCEDURE IMPLEMENTING PROCEDURES REFERENCE USE Page

.4 of 14 5.0 DETAILS 5.1 5.2 5.3 5.4 5.5 5.6 Activation of the IPEC Emergency Response Organization has occurred and a release of radioactivity has occurred.

Emergency Facilities are staffed as outlined in the IPEC Emergency Plan.

There are two (2) conditions where Kl may be issued: a declared General Emergency and/or abnormal radiological conditions.

The TSC Radiological Coordinator and the Radiological Assessment Coordinator SHALL maintain an awareness of onsite and offsite radiological conditions respectively.

IF a General Emergency is declared, THEN all personnel in the Protected Area are authorized for voluntary use of Kl by the Emergency Plant Manager via a Site announcement.

5.5.1 The TSC Radiological Coordinator SHALL ensure that Kl is issued to all personnel within the Protected Area. This SHALL include Security personnel and personnel at the Emergency Response Facilities.

During a declared General Emergency, the Radiological Assessment Coordinator SHALL ensure that Kl is issued to Entergy workers outside the Protected Area. This SHALL include the Offsite Monitoring Teams, EOF personnel, Security, ICP, State Police and National Guard personnel. Kl tablets are available at the EOF. If necessary assign a member of Dose Assessment to distribute the Kl.

5.6.1 The Assembly Area Coordinators SHALL issue Kl to personnel in the GSB/EEC.

5.6.2 Consider distribution of Kl during accountability process if radiological conditions warrant.

5. 7 The following areas, other than the Assembly Areas, are outside the Protected Area where personnel may be located. In the event that Kl is to be issued the Assembly Coordinator will contact those personnel in the Material and Services Building, IPEC Warehouse, the Maintenance Training Center, the Unit 2 Simulator to relocate to one of the Assembly Areas.

5.8 If abnormal radiological conditions exist either onsite or offsite:

5.8.1 Determine the projected child thyroid dose to personnel as outlined in IP-EP-310, Dose Assessment.

~ Entergy?,

IPEC NON-QUALITY RELATED IP-EP-420 Revision 6 EMERGENCY PLAN PROCEDURE IMPLEMENTING PROCEDURES REFERENCE USE Page

.§ of 14 5.8.2 If the projected child thyroid dose exceeds 5 REM COE child thyroid to any personnel, then obtain authorization to issue Kl to those personnel for use on a voluntary basis.

NOTE:

For those individuals known to be allergic to Kl consider use of alternative personnel prior to issuing Kl 6.0 5.9 To all personnel who are issued Kl, issue one (1) 130 mg Kl tablet and if requested, provide a copy of Attachment 9.1, Insert for Thyro-Block Potassium Iodide and Attachment 9.3, Use of Kl During Radiological Emergencies-Information for the Public. Kl tablets are available in the Control Rooms, Technical Support Center/Operations Support Center, EOF, Assembly Area in the Generation Support Building/Energy Education Center, and Assembly Area in the IPEC Training Building.

5.10 Continue to issue one (1) 130 mg Kl tablet and a copy of Attachment 9.1 once per day as long as the personnel are expected to receive >5 Rem COE child thyroid.

5.11 After the initial issuance of Kl, consideration may be given to discontinue ongoing issuance if a release is no longer occurring or is unlikely. Receive concurrence from Emergency Director and Emergency Plant Manager.

INTERFACES 6.1 IP-EP-410, Protective Action Recommendations 6.2 IP-EP-250, Emergency Operations Facility 6.3 IP-EP-230, Operations Support Center 6.4 IP-EP-310, Dose Assessment 7.0 RECORDS NONE 8.0 REQUIREMENTS AND COMMITMENT CROSS-REFERENCE NONE 9.0 ATTACHMENTS 9.1 Insert for Thyroid Block Potassium Iodide

-- E'ntergy0 IPEC NON-QUALITY RELATED IP-EP-420 Revision 6 EMERGENCY PLAN PROCEDURE IMPLEMENTING PROCEDURES REFERENCE USE Page

§ of 14 9.2 Locations of Potassium Iodide 9.3 DOH: Use of Kl during Radiological Emergencies-Information for the Public 9.4 New York State Policy on Potassium Iodide (updated June 2009)

- Entergy,,

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of 14.1 PATIENT PACKAGE INSERT FOR THVRO-BLOCK POTASSIUM IODIDE Sheet 1 of 1 iosat' Tablets (Potassium Iodide Tablets, U.S.P.)

Pronounced poe-TASS-e-um EYE-oh-dyed)

(Abbreviated Kl)

TAKE POTASSIUM IODIDE ONLY WHEN PUBLIC HEALTH OFFICIALS TELL YOU. IN A RADIATION EMERGENCY RADIOACTIVE IODINE COULD BE RELEASED INTO THE AIR POTASSIUM IODIDE (A FORM OF IODINE) CAN HELP PROTECT YOU.

IF YOU ARE TOLD TO TAKE THIS MEDICINE. TAKE IT ONE TIME EVERY 24 HOURS. DO NOT TAKE IT MORE OFTEN. MORE WILL NOT HELP YOU AND MAY INCREASE THE RISK OF SIDE EFFECTS DO NOT TAKE THIS DRUG IF YOU KNOW YOU ARE ALLERGIC TO IODIDE (SEE SIDE EFFECTS BELOW).

INDICATIONS THYROID BLOCKING IN A RADIATION EMERGENCY ONLY DIRECTIONS FOR USE Use only as directed by State or local public health authorities in the event of a radiation emergency.

DOSE ADULTS AND CHILDREN ONE YEAR OF AGE OR OLDER One (1) tablet once a day. Crush for small children.

BABIES UNDER ONE YEAR OF AGE One-half (1/2) tablet once a day.

Crush first DOSAGE: Take for 10 days unless directed otherwise by State or local public health authorities. Store at controlled room temperature between 15° and 30° C (59° and 86° F). Keep package dry and foil packets intact.

WARNING POTASSIUM IODIDE SHOULD NOT BE USED BY PEOPLE ALLERGIC TO IODIDE. Keep out of the reach of children. In case of overdose or allergic reaction, contact a physician or public health authority.

DESCRIPTION Each IOSAT' Tablet contains 130 mg of potassium iodide.

HOW POTASSIUM IODIDE WORKS Certain forms of iodine help your thyroid gland work right. Most people get the iodine they need from foods like iodized salt or fish. The thyroid can "store" or hold only a certain amount of iodine.

In a radiation emergency, radioactive iodine may be released in the air.

This material may be breathed or swallowed. It may enter the thyroid gland and damage it. Children are most likely to have thyroid damage.

If you take potassium iodide, it will fill up your thyroid gland. This lessens the chance that harmful radioactive iodine will enter the thyroid gland.

WHO SHOULD NOT TAKE POTASSIUM IODIDE The only people who should not take potassium iodide are people who know they are allergic to iodide. You may take potassium iodide even if you are taking medicines for a thyroid problem (for example a thyroid hormone or antithyroid drug). Pregnant and nursing women and babies and children may also take this drug.

HOW AND WHEN TO TAKE POTASSIUM IODIDE Potassium iodide should be taken as soon as possible after public health officials tell you. You should take one dose every 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. More will not help you because the thyroid can "hold" only limited amounts of iodine. Larger doses will increase the risk of side effects. You will probably be told not to take the drug for more than 1 O days.

SIDE EFFECTS Usually side effects of potassium iodide happen when people take higher doses for a long time. You should be careful not to take more than the recommended dose or take it for longer than you are told. ~ide effects are unlikely because of the low dose and the short time you will be taking the drug.

/J Possible side effects include skin rashes, swelling of the salivary glands, and "iodism" (metallic taste burning mouth and throat, sore teeth and gums symptoms of a head cold, and sometimes stomach upset and diarrhea).

Taking iodide may rarely cause overactivity of the thyroid gland, underactivity of the thyroid gland, or enlargement of the thyroid gland (goiter).

WHAT TO DO IF SIDE EFFECTS OCCUR If the side effects are severe or if you have an allergic reaction, stop taking potassium iodide. Then, if possible, call a doctor or public health authority for instructions.

HOW SUPPLIED IOSAT' Tablets (Potassium Iodide Tablets, U.S.P.) packages of 14 tablets (NDC51803-001-01) Each white round scored tablet contains 130 mg potassium iodide.

Distributed by ANBEX, INC 1 O East 401h Street New York, NY 10016 www.anbex.com

- Entergy IPEC NON-QUALITY RELATED IP-EP-420 EMERGENCY PLAN PROCEDURE IMPLEMENTING PROCEDURES REFERENCE USE Page.2 LOCATIONS OF POTASSIUM IODIDE Sheet 1 of 1 Revision 6

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of 14 Potassium Iodide is to be stored in the following locations for issuance during a declared emergency.

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Unit 2 Central Control Room Unit 3 Central Control Room

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Technical Support Center/Operations Support Center Assembly Area in the Generation Support Building/Energy Education Center Assembly Area in the IPEC Training Building Emergency Operations Facility

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of 14.3 DOH: USE OF Kl DURING RADIOLOGICAL EMERGENCIES INFORMATION FOR THE PUBLIC Sheet 1 of 2 Use of Potassium Iodide (Kl) During Radiological Emergencies Information for the Public This fact sheet is about the NYS policy for people, especially those who live within ten miles of a nuclear power plant, who may be exposed to radiation from a nuclear plant emergency. In December 2001, the Federal Food and Drug Administration (FDA) said if there was a radiological emergency people should take a drug that would help protect them from thyroid cancer.

This drug is called potassium iodide (Kl). The New York State Health Department agrees."

The questions and answers below will give you more information.

1. What is potassium iodide (Kl) and what is it used for?

If there is a radiological emergency from a nuclear plant, large amounts of something called radioiodine could be put into the air and this could hurt your thyroid gland, or even cause thyroid cancer later on. You could breathe in the radioiodine or eat food that has some radioiodine in it.

When you take the Kl pill, it protects your thyroid gland from being harmed.

2. How does Kl work?

I When you take' the Kl pill, it fills your thyroid with a kind of iodine that prevents your thyroid gland from taking in any of the radioactive kind of iodine.

3. What age group has the highest risk from exposure to.radioiodine?

Young children have the highest risk. We have learned this from looking at children in Russia and other areas who were exposed to the radioiodine from the Chernobyl nuclear power plant accident.

4. When should Kl be taken?

You need to take Kl before or just after you are exposed to radioiodine. You can also take it 3 or 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> later, but it will not be as helpful.

5. How will I know if I should take Kl?

If there is an emergency, you will hear an announcement from your local or state health officials. Your local health department will tell you when you should start taking Kl and they will also tell you when you can stop taking it.

6. Does Kl work in all radiation emergencies?

Kl will only protect you from radioactive iodine. It does not protect you from other kinds of radioactive material. Kl works very well to protect your thyroid gland. However, it protects only your thyroid, not other parts of your body.

7. What will happen in an emergency?

You will be told what if any actions you should take to protect yourself. This might include leaving the area, staying inside with your windows closed and/or taking Kl.

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8. Can people have reactions to Kl?

In general, most people who have taken Kl have not had any reactions (side effects) if people did have a reaction it did not last very long. In a few cases, babies had a reaction in their thyroids. Adults who had reactions had stomach problems or a rash. The Federal Government thinks the benefits of taking Kl are much greater than the risks.

9. Are there some people who should not take Kl?

Most people can take Kl, but you should talk to your doctor before taking it. Talk to your doctor before an emergency occurs. It is not a good idea to take it if you have certain medical conditions or problems. Babies need to be

• watched carefully if they take Kl.

10. How much Kl do I take?

The table on the next page shows the smallest Kl dose that different age groups can take which will protect the thyroid.

Kl comes in liquid, 65-mg tablets and 130-mg tablets. Since it is hard to cut many pills, the State Health Commissioner says that, in an emergency, it is safe for children at school or day care centers to take the whole pill. It's better for children under 12 years old to take the 65-mg pill, but it is safe to take the 130-mg pill if that is the only one you have.

For children or babies who cannot take pills, parents and caregivers can cut or crush the pill to make lower doses, or give the liquid form of Kl.

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EMERGENCY PLAN PROCEDURE IMPLEMENTING PROCEDURES REFERENCE USE Page 10 of 14.3 DOH: USE OF Kl DURING RADIOLOGICAL EMERGENCIES INFORMATION FOR THE PUBLIC Sheet 2 of 2 Use of Potassium Iodide {Kl) During Radiological Emergencies Information for the Public Recommended Doses of KI for Different A~e Groups Age Group KI Dosage Number of ml liquid Number of Number of (65 m2'ml)

Adults over 18 years 130 mg

• Over 12 -18 years and 130mg over 150 pounds Over 12 -18 years and less 65mg than 150 pounds Over 3 -12 years 65mg Over 1 month to 3 years 32mg Birth -1 month 16mg

11. How often should Kl be taken?

Kl is helpful for about 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. You should,keep taking it once a day until the health department says to stop, or you are out of the emergency area.

12. Does Kl come in liquid or pill form?

Kl can come as a pill or a liquid. Pills are available in 65-mg or 130-mg doses. Kl is also available as a liquid.

13. If Kl has been stored for a while, is it still OK to use?

The manufacturers say Kl stays "fresh" for 5-7 years. If you keep it in a dry, dark and cool place, it should last for many years.

For additional information contact:

2 2

1 1

0.5 0.25 65-me tablets 130-me tablets 2

1 2

1 1

1/2 1

1/2 1/2 1/4 1/4 1/8

14. Do you need a prescription to get Kl?

No. You are allowed to get it over the counter.

15. Can Kl be purchased at local pharmacies?

Yes, though it may not widely available in drugstores near you. Since it is not a prescription drug, you can buy it over the Internet. As with other drugs, make sure the Kl you buy has been approved by the FDA. A supply of Kl has been made available to people who live within 10 miles of a*nuclear power plant in New York State. If you live within 1 O miles of a nuclear power plant and did not receive Kl, contact your local Office of Emergency Management.

New York State Department of Health lnfoline at 1-800-458-1158, extension 2-7550 or e-mail BERP@health.ny.gov Other sources of information:

https://www.fda.gov/down!oads/drugs/guidancecomplianceregulatoryinformation/guidances/ucm080542.pdf https://www.fda.gov/drugs/emergencypreparedness/bioterrorismanddrugpreparedness/ucm072265.htm https://www.fda.gov/drugs/emergencypreparedness/bioterrorismanddrugpreparedness/ucm072261.htm https://emergency.cdc.gov/radiation/ki:asp http://www.who.int/ionizing radiation/pub meet/tech briefings/potassium,iodide/en/

http://www.health.ny.gov/envlronmental/radiological/potassium iodide/

Rev. 3-A ril 2017

-~- J:.i1,tergy Introduction IPEC NON-QUALITY RELATED IP-EP-420 EMERGENCY PLAN PROCEDURE IMPLEMENTING PROCEDURES REFERENCE USE Page.4 New York State Policy on Potassium Iodide (Updated June 2009)

Page 1 of 5 Revision 6 11 of 14 This Policy updates the 1982 New York State Policy on the use of potassium iodide (Kl) for the general public to reduce the risk of thyroid cancer in radiation emergencies involving the release of radioactive iodine. The recommendations in this policy address Kl dosage and the projected radiation exposure at which the drug should be used.

These recommendations are based on guidance provided by the United States Food and Drug Administration (FDA), "Guidance on Potassium Iodide as a Thyroid Blocking Agent in Radiation Emergencies", in December of 2001.

Background

The FDA has provided guidance previously on the use of Kl as a thyroid blocking agent.

First, in 1978, the FDA announced its conclusion that Kl is a safe and effective means by which to block uptake of radioiodines by the thyroid gland in a radiation emergency under certain specified conditions of use. In 1982 FDA announced final recommendation on the administration of Kl to the general public in a general emergency. Those recommendations were formulated after reviewing studies relating the radiation dose to thyroid disease risk that relied the radiation dose to thyroid disease risk that relied on estimates of external thyroid irradiation after the nuclear detonation at Hiroshima and Nagasaki and analogous studies among children who received therapeutic radiation to the head and neck. The former New York State Policy on Kl was based on previous FDA recommendations for administering Kl to emergency workers and selected captive populations. This former policy which stated: "The FDA recommends that potassium iodide in doses of 130 mg per day per adult and children above one year, and 65 mg per day for children b.elow one year of age, be considered for thyroid blocking in radiation emergencies in those persons who are likely to receive a projected radiation dose of 25 rem or greater to the thyroid gland from radioiodines released to the environment. The decision to administer Kl will be made with the concurrence of local and State Health officials."

The policy that follows revises New York State's 1982 policy recommendation on the use of Kl for thyroid cancer prophylaxis based on the recent FDA's recent comprehensive review of the data relating radioiodine exposure to thyroid cancer risk, accumulated in the aftermath of the 1986 Chernobyl reactor accident.

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Page 2 of 5 Rationale for Revising the Existing Kl Policy Revision 6 12 of 14 The New York State Department of Health (NYSDOH) has reviewed the new guidance for prophylactic use of Kl prepared by the FDA and is hereby recommending that the New York State Policy on Kl distribution to the general public be revised. The rationale for the revision is given below.

Studies conducted after the Chernobyl accident in 1986 have provided the most reliable information available to date on the relationship between internal thyroid radioactive dose and cancer risk. These studies suggest that the risk of thyroid cancer is inversely related to age, and that, especially in young children, it may accrue at very low level of. radioiodine exposure. The FDA relied on Chernobyl data to formulate its specific recommendations.

The effectiveness of Kl s a specific.blocker of thyroid radioiodine uptake is well established, as are the doses necessary for blocking uptake. As such, it is reasonable to conclude that Kl will likewise be effective in reducing the risk of thyroid cancer in individuals or populations at risk for inhalation or ingestion of radioiodines.

Short-term administration of Kl at thyroid blocking doses is safe and, in general, more so in children than adults. The risks of stable iodine administration are detailed in the FDA guidance document (FDA01 ).

The NYSDOH, in consultation with its Radiological Health Advisory Committee, concluded that there was no medical reason not to make Kl available to the general public during a radiological emergency where a large release of radioiodines had taken place. In August 1998, the NYSDOH Commissioner (Dr. DeBuono) made that recommendation to Mr. Edward Jacoby, then Chairman of the Disaster Preparedness Commission (DPC).

The present NYSDOH Commissioner, Dr. Novello, reiterated that recommendation when the FDA released its final guidance on the use of Kl for the general public in December, 2001.

Based on information available to date, New York State has decided to revise its Kl policy to reflect current FDA recommendations.

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~Entergy New Policy IPEC NON-QUALITY RELATED IP-EP-420 EMERGENCY PLAN PROCEDURE IMPLEMENTING PROCEDURES REFERENCE USE Page.4 New York State Policy on Potassium Iodide (Updated June 2009)

Page 3 of 5 Revision 6 13 of 14 The New York State Plan endorses the 2001 FDA recommendation regarding Kl. The revised New York State Policy on Kl is revised as follows:

"The New York State Department of Health states that Kl is a safe and effective means by which to prevent radioiodine uptake by the thyroid gland, under certain specified conditions of use, and thereby reduce the risk of thyroid cancer in the event of a radiation emergency. The Department will follow the FDA's lower radioactive exposure thresholds for Kl prophylaxis as well as lower doses of Kl for neonates, infants, and children than those previously recommended in 1982 (see Table 1 ). The recommendation to take Kl by the general public will be issued by the Local or State Commissioner of Health, or his/her designee, during a radiological emergency where the potential to exceed the new FDA dose limits may be exceeded by the general public. This recommendation will be based on a projected thyroid dose to one-year old child of 5 Rem.

The NYSDOH continues to recommend that the radiation emergency response plans include:

• Provisions (in the event of a radiation emergency) for informing the public about the magnitude of the radiation hazard;

• The manner of use of Kl and its potential benefits and risks; and

• Medical contact, reporting, and assistance systems.

The NYSDOH recognizes FDA recommendations on availability as well as administration of Kl in advance of exposure to radioiodine. The NYSDOH stresses that Kl provides protection only for the thyroid from radioiodines. It has no impact on the impact on the uptake by the body of other radioactive materials and provides no protection against external irradiation of any kind.

The NYSDOH emphasizes that the use of Kl should be as an adjunct to recommended protective actions such as evacuation (itself not always feasible), sheltering, and control of foodstuffs."

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Page 4 of 5 Dosing Guidelines Revision 6 14 of 14 In addition to 130 mg tablets, Kl is now FDA-approved and available in 65 mg tablets and liquid (65 mg/ml).

The FDA guidance contains a number of age dependent doses (see Table 1 ). These recommendations are the lowest effective dose. Emergency planners and others should understand that absolute precision in dosing is generally not critical to safety or efficacy.

Higher doses (e.g., up to 130 mg) would be equally effective and, particularly among school-age children, extremely safe.

Table 1 Threshold Thyroid Radioactive Exposures and Recommended Doses of Kl for Different Risk Groups Kl dose

1. ml liquid

1. of 65 mg

1. of 130 (mn)

(65 mg/ml) tablets mg tablets Adults over 40 yrs 130 2

2 1

• Adults over 18 through 40 yrs

Pregnant or lactating women Adolescents over 12 through 18 130 2

2 1

yrs who weigh at least 150 pounds Adolescents over 12 through 18 65 1

yrs 1

1/2 who weigh less than 150 pounds Children over 3 through 12 yrs 65 1

1 1/2 Over 1 month through 3 years 32 1/2 1/2 1/4

'Birth through 1 month 16 1/4 1/4 1/8