James A. FitzPatrick NPP 315-342-3840 James D. JonesTel 315-342-3840 James D. Jones Emergency Preparedness Manager ... NIA Commitments Due Date Responsible Dept. Note: When fleet letters

JAFP-16-0086 May 20, 2016

United States Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555

Subject: Transmittal of Emergency Plan Updates

James A. FitzPatrick Nuclear Power Plant Docket No.50-333 License No. DPR-059

Dear Sir or Madam:

Entergy Nuclear Northeast Entergy Nuclear Operations, Inc.

James A. FitzPatrick NPP P.O. Box 110 Lycoming, NY 13093 Tel 315-342-3840

James D. Jones Emergency Preparedness Manager

The documents enclosed with this letter are changes to the James A. FitzPatrick Nuclear Power Plant's (JAF) Emergency Plan made pursuant to 10 CFR 50.54(q). This transmittal fulfills the requirements of 10 CFR 50.54(q), 10 CFR 50 Appendix E Section V, 10 CFR 70.32(i), and 10 CFR 72.44(f) to inform the commission of changes that have been made which do not decrease the effectiveness of the Emergency Plan.

The following documents (including change documentation and screening) are attached: • Appendix A, Revision 30

The following documents (including change documentation, screening and evaluation) are attached:

• Appendix K, Revision 10 • Section 8, Revision 34

This letter contains no new regulatory commitments.

If you should have any questions, plea.se contact Mr. James D. Jones at (315) 349-6030.

SEV James D. Jones Emergency Preparedness Manager

JDJ:cfv

Enclosure( s ):

Including change documentation and screening: • Appendix A, Revision 30

Including change documentation, evaluation and screening: • Appendix K, Revision 10 • Section 8, Revision 34

cc w/o procedure documentation, evaluation and screening:

USNRC (l&E) Regional Administrator, Region I - Controlled - 2 Copies NRC Resident Inspector - Controlled - 1 Copy NRC Director NMSS - Uncontrolled - 1 Copy

JAFP-16-0086 . Page 2 of 2

NRC Director Division of Spent Fuel Storage and Transportation - Uncontrolled - 1 Copy NRC Director, Division of Security Policy - Uncontrolled - 1 Copy NYSEMO - Controlled - 1 Copy OCEMO - Controlled - 1 Copy

JAFP-16-0086

Enclosures

Including change documentation and screening:

• Appendix A, Revision 30

l_ncluding change documentation, evaluation. and screening:

• Appendix K, Revision 10 • Section 8, Revision 34

.;..

.)•

~ NUCLEAR QUALITY RELATED EN-Ll-106 I REV.14 ._.... ~Entergy MANAGEMENT

MANUAL INFORMATIONAL USE

NRC Correspondence

ATTACHMENT 9.4 NRC SUBMITTAL REVIEW Sheet 1of2

:"~~~-~r.ff(~~~f'jJ~-~qa~ / ::·--.- __ . ..-- ~.~~~_p<i~5,~-~~-~~= ~l.~1/?o~--~- ~ -:~ __ :. ·sM~j~·~i{ f r~ci~tni(tal ~f Ern~t~Elncy Pl?_[!· Up~:ate§ . < .. -o~t~ iss.u~~ f~r R~vieW: .~/f9/~_016 ... ' ' .. :,

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. - .. ~ ~ ...:. - : ' .: ' . --

Section I Letter Concurrence and Agreement to Perform Actions • ~. • t -- - _.. • - • .;:~-. • ~ - •• -_

:· .. - . - .. Acti~:rf< · -. ~:. - • · _ _ · . ~ _: . -$igf1C!t.llte -_" - · - -. .. _ _-:-: ' .- (concur+.enc~;:·c!3rtifi~~ti9n. ~tc.> ·: . t~i9n. ·irWrqffi«~ mernq,:~ry;~ii, one1€f~o1Jif

·· .. - . .--:~~-~- ,__.:.':-._.::-:~._··.- ·::.:.: . .:- .... ' ',:_-_ -- .

Emergency Planning Dept. Preparer/Reviewer Cathee Vickery~~~

Licensing Department Concurrence Mark Hawes I 4 ~ / Emergency Preparedness Manager

Approver James D. Jones I ~~ ~ / :• (: \ 1y

.. ·'.

- . ~ . -- _. - . ! ·- •'" . :: • ~ • : ' .• . ~ • , >. - ..,

Appendix A, Revision 30 Appendix K, Revision 10 Section 8, Revision 34

S t" II ec1on c d orrespon ence Does this letter contain commitments? If "yes," identify the commitments with due dates in the submittal and in Section Ill. When fleet letters contain commitments, a PCRS LO (e.g., LO-LAR, LO-WT) should be initiated with a CA assigned to each applicable site to enter the commitments into the site's commitment management svstem. Does this letter contain any information or analyses of new safety issues performed at NRC request or to satisfy a regulatory requirement? If "yes," reflect requir.ement to update the UFSAR in Section Ill. Does this letter require any document changes (e.g., procedures, DBDs, FSAR, TS Bases, etc.), if approved? If "yes," indicate in Section Ill an action for the responsible department to determine the affected documents. (The Correspondence Preparer may indicate the specific documents requiring revision, if known or may initiate an action for review.) Does this letter contain information certified accurate? If "yes," identify the information and document certification in an attachment. (Attachment 9.5 must be used.)

s creenmg Yes 0181 No

Yes 0181 No

Yes 0181 No

Yes 0181 No

EN-Ll-106 REV 14

~ NUCLEAR QUALITY RELATED EN-Ll-106 I REV.14 -~Entergy MANAGEMENT MANUAL INFORMATIONAL Use

NRC Correspondence

ATTACHMENT 9.4 NRC SUBMITTAL REVIEW

Sheet 2 of 2

Section Ill Actions and Commitments Required Actions Due Date Responsible Dept. Note: Actions needed upon approval should be captured in the

appropriate action trackina system

NIA

Commitments Due Date Responsible Dept. Note: When fleet letters contain commitments, a PCRS LO

should be initiated with a CA assigned to each applicable site to enter the commitments into the site's commitment management system.

N/A

Section IV ;:· Final Document Signoff for Submittal .,

Correspondence Preparer c th v· k I a ee 1c ery

Final Submittal Review (optionfll) NIA

Responsible Department Head James D. Jones I

EN-Ll-106 REV 14

TO: DEPT.:

EP Admin Emergency Planning

LOCATION: USNRC Document Control Center, Washington DC/RockvilleMD

SPECIAL NOTES: JAFP Memo&: EN-LI-106~form required. Include 10CFR50.54(q) Screen and Evaluation (EN-EP-305 Attach 9.1 &: 9.2)

CONTROL MANUAL NUMBER 34

FROM: DEPT.: LOCATION: DATE:

KELLY SAWYER ADMINISTRATIVE SERVICES JAF May 18, 2016

APPLICABLE MANUAL: EPLAN PROCEDURES

UPDATE LIST

APPENDIX A

EMERGENCY PLAN I VOLUME 1

EMERGENCY PLAN (VOLUMES 2 AND 3) IMPLEMENTING PROCEDURES

EVACUATION TRAVEL TIME ESTIMATES AND APPENDIX I POPULATION DISTRIBUTION FOR THE

K JAF/NINE MILE POINT EMERGENCY PLANNING ZONE

SECTION 8 MAINTAINING EMERGENCY PREPAREDNESS

--\< b ~d C.b ifi Op~ lZ_ *

INSTRUCTIONS:

N/A\ 5/20/2016

30 I 5/20/2016

10 5/20/2016

34 I 5/20/2016

1. Insert the attached revised documents, and withdraw any noted WITHDRAWN documents from your controlled copy. 2. DISCARD ALL SUPERCEDED DOCUMENTS, as applicable. DISCARD THIS TRANSMITTAL.

NOTE Failure to incorporate these documents into your controlled manual

will result in cancellation of the subject controlled documents.

EMERGENCYPLAN/VOLUMEl UPDATE LIST

Date of Issue: ---=5'--'-'/2=0:..:....:/2=0'-'-l-=-6 ___ _

.. '.

~. .. . .,;..· :

..... " .

·' ..... '

N/A TABLE OF CONTENTS - VOLUME 1 I SECTlON 1 DEFINITIONS/ ACRONYMS I SECTION 2 SCOPE AND APPLlCABILITY I SECTION 3 SUMMARY OF THE JAFNPP EMERGENCY PLAN I SECTION 4 EMERGENCY CONDITIONS

SECTION 5 ORGANIZATlON

SECTION 6 EMERGENCY MEASURES

SECTION 7 EMERGENCY FACILITIES AND EQUIPMENT

SECTlON 8 MAINTAINING EMERGENCY PREPAREDNESS

SECTION 9 RECOVERY !

APPENDIX A EMERGENCY PLAN IMPLEMENTING PROCEDURES

APPENDIX B JAFNPP POLICY STATEMENT

APPENDIX C LETTERS OF AGREEMENT ! I

APPENDIX D NEW YORK STATE PLAN AND PROCEDURES I APPENDIX E OSWEGO COUNTY PLANS AND PROCEDURES

APPENDIX F TYPICAL SUPPORT COMPANIES AND ORGANIZATIONS

APPENDIX G DELETED (2/98)

APPENDIX H PUBLIC INFORMATION PROGRAM

APPENDIX I EMERGENCY EQUIPMENT KITS

APPENDIXJ SUPPORTlNG DOCUMENTS

APPENDIXK EVACUATION TRA YEL TIME ESTIMATES AND POPULATlON DISTRlBUTlON FOR THE JAF/NlNE MILE POINT EMERGENCY PLANNING ZONE

APPENDIX L NUREG-0654/FEMA-REP-1 CROSS REFERENCE

APPENDIX M DELETED (5/84)

APPENDIXN TYPICAL FEDERAL SUPPORT RESOURCES

Page 1of1

-------------------------

Revision Date of Last Number_.·. Review

REY. 31 07/15

REY. 28 01/16

REV. 27 01/16

REV. 15 04/16

REV. 27 01116

REV. 50 02/16

REV. 36 03/16

REY. 35 03/16

REV. 34 05116

REY. 23 07/15

REV. 30 05116

REV. 09 02/16

REY. 37 08/15

REY. 09 07/15

REY. 10 07/15

REY. 19 07/15

REV. 37 02/\6

REY. 12 04/16

REV. 13 03/16

REY. 10 5116

REY. 18 09/15

REV. 21 07/15

- - ·--·- ·----------- - - ------- ---

ENTERGY NUCLEAR O?ERATIONS, I NC. JAMES A. FITZPATRICK NUCLEAR POWER PLANT

EMERGENCY PLAN VOLUME 1

EMERGENCY PLAN (VOLUMES 2 & 3) IMPLEMENTING PROCEDURES

APPENDIX A

EFFECTIVE DATE:

****************************** ******************************

* * *

* INFORMATIONAL USE *

* ******************************

******************************

* * * ADMINISTRATIVE * * * ******************************

* * *

QUALITY RELATED * * *

******************************

CONTROLL .. r

PERIODIC REVIEW DUE DATE: MARCH 2017

Rev. No. 30

REVISION SUMMARY PAGE

REV. NO. CHANGE AND REASON FOR CHANGE

30 LIMITED REVISION

Rev. No.

1. Supplemental Action Procedures (SAP) Remove SAP-7. Reason: EN-EP-310 replaces SAP-7

2. Emergency Plan Implementing Procedures (EAP) Remove EAP-37 and EAP-43. Reason: Update to reflec t current procedure listings

3. Supplemental Action Procedures (SAP)- Add SAP-24, Loss of Emergency Preparedness Capabilities. Reason: Update to reflect current procedure listings

4. Add EN-EP-310, Emergency Response Organization Notification System. Reason: SAP-7 no longer exists, EN-EP-310 will replace SAP-7

5. Update cover page

30 Page A-i

APPENDIX A

EMERGENCY PLAN (VOLUMES 2 & 3) IMPLEMENTING PROCEDURES

IMMEDIATE ACTION PROCEDURES (IAP)

IAP-1 IAP-2

Emergency Plan Implementation Checklist Classification of Emergency Conditions Figure 2.1 EAL Classification Matrix Attachment 1 EAL Bases Category A - Abnormal Rad Release/Rad Effluent Category C - Cold Shutdown/Refueling System Malfunction Category E - Events Related to ISFSI Category H - Hazards Category S - System Malfunction Category F - Fission Product Barrier Degradation Attachment 2 Fission Product Barrier Loss I Potential Loss

Matrix and Bases

SUPPLEMENTAL ACTION PROCEDURES (SAP)

SAP-1 Maintaining Emergency Preparedness SAP-2 Emergency Equipment Inventory SAP-3 Emergency Communication Testing SAP-8 Prompt Notification System Failure I Siren System False

Activation SAP-10 Meteorological Monitoring System Surveillance SAP-17 Emergency Response Data System (ERDS) Quarterly Testing SAP-20 Emergency Plan Training SAP-23 Equipment Important to Emergency Preparedness SAP-24 Loss of Emergency Preparedness Capabilities

Rev. No. 30 Page A-1

EMERGENCY PLAN IMPLEMENTING PROCEDURES (EAP)

PROCEDURE CORRESPONDING

NUMBER PROCEDURE TITLE VOLUME 1 SECTION I APPENDIX

EAP-1.1 Offsite Notifications 6 .1. 2 EAP- 2 Personnel Inj ury 6.5.2

6.5.3 6.5 . 4

7 .5 EAP - 3 Fire 7.3.3.2

EAP-4A On s hift Dose Assessment 6. 2 .3 .1 7.3.1 7.3 . 2

7. 3. 3 .1 7. 3. 3 . 7

EAP-4B Detailed Dose Assessment 5.3.9B 6. 2. 2 .2 6.2.3 6 .4.2 7. 3 . 1 7 . 3 . 2

7. 3. 3 . 1 7 . 3. 3. 7

EAP- 4C Protective Action Recommendations 5.3.9B 6.2.3 6.4.2

EAP- 4 .l Release Rate Determination 4.1 4.2

5. 3. 9 6.2.3

7 .3.3.1 7. 3. 3. 7

EAP- 5.3 Onsite/Offsite Downwind Surveys a nd 6 . 2. 2 . 2 Environmental Moni toring 6.2.3.3

7. 3. 3 . 4 7.3.3.5 7.3.3.6 7.3.3.7 7. 3. 3. 8

EAP-6 In- Plant Emergency Survey/Entry 6.2.2.1 Aooendix I

EAP- 8 Personnel Accountabi lity 5. 3 . 11 6.4.1.3

EAP-9 Search and Rescue Operations 6.4.1.3 EAP-10 Protected Area Evacuat i on 3.2

6. 4. 1.1 6.4.1.2

7. 4. 3 EAP-11 Site Evacuation 3 . 2

6.4.1.2 EAP- 12 Dose Estimated from an Accidental 6.2.3.3

, Release ·'Jf Ra di ·-:oac t i ve !'.-1aterial to Lake Ontario

EAP-13 Damage Control 6.3 7 .1. 3

7 . 7 EAP - 14 . 6 Habitabili t y of the Emergency 7 .1. 4

Facilities 7 . 4 . 1

Rev . No. 30 Page A-2

.............. _____________________________________ _


PROCEDURE CORRESPONDING

NUMBER PROCEDURE TITLE VOLUME 1 SECTION I APPENDIX

7.4.2 EAP- 14.7 Remote Assembly Area Activation 7.4.5 EAP- 14.8 Alternate TSC/OSC Activation and 6.4.1.2

Operation EAP-15 Emergency Radiation Exposure Criteria 5 . 3 .1

and Control 5.3.9 6.4.1.4

6. 5 .1 Fiqure 6.1

EAP-16 Public Information Procedure 5.3.12 5. 4 .1 6.4.2 7 .1. 2 7 .1. 6 7 .1. 7 7 .1. 8 7 .2.8

8.7 9 .2

Appendix H EAP-16.2 Joint Information Center Operation 5.3.12

5. 5 .1 7 .1. 6

8.7 9.1 9.2 9.3

Appendix H EAP-17 Emergency Organization Staffing 5.2

5 . 3 Figure 5- 2 Figure 5-3 Table 5- 1

6 .1.1 EAP- 19 Emergency Use of Potassium Iodide (KI) 5. 3 .1

6.4 .1. 4 6. 4. 2. 3

EAP-20 Post Accident Sample, Offsite Shipment 6. 2 .1 and Analysis 6 .2 .2 .1

7 .3 .1 7.3.2

7 . 3. 3 .1 Figure 8 . 2

EAP-23 Emergency Access Control 5.3.11 6.4.1 7.9 8.2

EAP- 24 EOF Vehicle and Personnel 6 . 4 . 1.2 , Decontaminatj on 6 . "i . 2

7.4 .4 7 .6

EAP- 27 Estimation of Population Dose Within 9.1 10 Mile Emergency Planning zone

Rev . No. 30 Page A-3


PROCEDURE CORRESPONDING PROCEDURE TITLE VOLUME 1 NUMBER SECTION I APPENDIX

EAP-29 EOF Ventilation Isolation During an None Applicable Emergency

EAP-30 Emergency Termination and Transition 9.0 to Recovery

EAP-34 Acceptance of Environmental Samples at 7 .1. 5 the EOF/EL During an Emergency 7 . 3.2

EAP-35 EOF TLD Issuance During an Emergency 5.3.1 5.3 . 9

6.4.1.4 6.5.1

EAP-36 Environmental Laboratory Use During an 7 . 1. 5 Emergency 7.3.2

EAP-42 Obtaining Meteorological Data 7. 3. 3. 7

EAP-44 Core Damage Estimation 4.1 4.2

6.2.1 6.2.3

7.3.3.1 EAP-45 Emergency Response Data System (ERDS) 7.2.6

Sys t em Configuration Control Program

EAP- 46 Supplemental ERO Actions None Applicable

EN- EP-306 Drills and Exercises 8.4

EN-EP-308 Emergency Planning Critiques 8.4

EN-EP- 3 10 Emergency Response Organi zation None Applicable Notification System

EN-EP-609 Emergency Operations Facility(EOF) 7 .1. 5 Operations

EN- EP-610 Technical Support Center(TSC) 7 .1. 2, 7 .4. 2 Operations

EN-EP-611 Operational Support Center (OSC) Operations 7 .1. 3

EN-EP-801 Emergency Response Organization 5.2, 5.3 . EN- EP-900 Emergency Preparedness Forms None Applicable

Rev. No. 30 Page A-4

ATTACHMENT 9.1 SHEET1 OF4

10CFR50.54(q) SCREENING

Procedure/Document Number: Emergency Plan Revision: 30 Appendix A

EquipmenUFacility/Other: James A. Fitzpatrick (JAF)

Title: Emergency Plan Volume 1 Appendix A

Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change . to the emergency plan or affect the implementation of the emergency plan):

1. Supplemental Action Procedures (SAP)

Remove SAP-7. Reason: EN-EP-310 replaces SAP-7

2. Emergency Plan Implementing Procedures (EAP)

Remove EAP-37 and EAP-43. Reason: Update to reflect

current procedure listings

3. Supplemental Action Procedures (SAP)- Add SAP-

24,Loss of Emergency Preparedness Capabilities.

Reason: Update to reflect current procedure listings

4. Add EN-EP-310, Emergency Response Organization Notification System. Reason: SAP-7 no longer exists, EN-EP-310 will replace SAP-7

5. Update to cover page - removed signature and OSRC meeting number from the cover page, in order to comply with AP-02.04 requirements. The signature and OSRC information are contained in the PIRF.

EN-EP-305 REV 3

ATTACHMENT9.1 SHEET2 OF 4



Equipment/Facility/Other: James A. Fitzpatrick


Part II. Activity Previously Reviewed? ·ovEs t8J NO Is this activity fully bounded by an NRC approved 10 CFR 50.90 submittal or 50.54(q)(3) Continue to

Alert and Notification System Design Report? Evaluation is next part NOT required. Enter

If YES, identify bounding source document number/approval reference and justification ensure the basis for concluding the source document fully bounds the below and

proposed change is documented below: complete Part VI.

Justification:

0 Bounding document attached (optional)

Part Ill. Applicability of Other Regulatory Change Control Processes

Check if any other regulatory change processes control the proposed activity.(Refer to EN-Ll-100)

NOTE: For example, when a design change is the proposed activity, consequential actions may include changes to other documents which have a different change control process and are NOT to be included in this 50.54(q)(3) Screenino. APPLICABILITY CONCLUSION [8] If there are no controlling change processes, continue the 50.54(q)(3) Screening. D One or more controlling change processes are selected, however, some portion of the activity involves the emergency plan or affects the implementation of the emergency plan; continue the 50.54(q)(3) Screening for that portion of the activity. Identify the applicable controlling change processes below. 0 One or more controlling change processes are selected and fully bounds all aspects of the activity. 50.54(q)(3) Evaluation is NOT required. ldentifv controllinq chanae processes below and complete Part VI. CONTROLLING CHANGE PROCESSES

10 CFR 50.54(q)

Part IV. Editorial Change DYES [8J NO 50.54( q)(3) Continue to ne.xt

Is this activity an editorial or typographical change such as formatting, paragraph Evaluation is part numbering, spelling, or punctuation that does not change intent? NOT required.

Justification: Enter justification and

Change 5: Update to cover page - removed signature and OSRC meeting number from complete Part the cover page, in order to comply with AP-02.04 requirements. The signature and VI.

OSRC information are contained in the PIAF. Part v. Emergency Planning Element/Function Screen (Associated 10 CFR 50.47(b) planning standard function identified in brackets) Does this activity affect any of the following, including program elements from NU REG-0654/FEMA REP-1 Section II?

1. Responsibility for emergency response is assigned. [1] D 2. The response organization has the staff to respond and to augment staff on a continuing basis (24/7 D

staffing) in accordance with the emergency plan. [1]

3. The process ensures that on shift emergency response responsibilities are staffed and assigned. [2] D 4. The process for timely augmentation of onshift staff is established and maintained. [2] D 5. Arrangements for requesting and using off site assistance have been made. [3] D 6. State and local staff can be accommodated at the EOF in accordance with the emergency plan. [3] D

EN-EP-305 REV 3

,

ATTACHMENT9.1 5HEET3 OF4





7. A standard scheme of emergency classification and action levels is in use. [4] D 8. Procedures for notification of State and local governmental agencies are capable of alerting them of D

the declared emergency within 15 minutes after declaration of an emergency and providing follow-up notifications. [5]

9. Administrative and physical means have been established for alerting and providing prompt 0 instructions to the public within the plume exposure pathway. [5]

10. The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and 0 Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. [5]

11. Systems are established for prompt communication among principal emergency response D organizations. [6]

12. Systems are established for prompt communication to emergency response personnel. [6] D 13. Emergency preparedness information is made available to the public on a periodic basis within the 0

plume exposure pathway emergency planning zone (EPZ). [7]

14. Coordinated dissemination ofpublic information during emergencies is established. [7] D 15. Adequate facilities are maintained to support emergency response. [8] D 16. Adequate equipment is maintained to support emergency response. [8] D 17. Methods, systems, and equipment for assessment of radioactive releases are in use. [9] D 18. A range of public PARs is available for implementation during emergencies. [1 O] D 19. Evacuation time estimates for the population located in the plume exposure pathway EPZ are D

available to support the formulation of PARs and have been provided to State and local governmental authorities. [1 OJ

20. A range of protective actions is available for plant emergency workers during emergencies, including D those for hostile action events.[1 O]

21. The resources for controlling radiological exposures for emergency workers are established. [11] D 22. Arrangements are made for medical services for contaminated, injured individuals. [12] 0 23. Plans for recovery and reentry are developed. [13] D 24. A drill and exercise program (including radiological, medical, health physics and other program D

areas) is established. [14]

25. Drills, exercises, and training evolutions that provide performance opportunities to develop, D maintain, and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses. [14]

26. Identified weaknesses are corrected. [14] D 27. Training is provided to emergency responders. [15] D 28. Responsibility for emergency plan development and review is established. [16] D 29. Planners responsible for emergency plan development and maintenance are properly trained. [16) 0

EN-EP-305 REV 3



Procedure/Document Number: Emergency Plan j Revision: 30 Appendix A



APPLICABILITY CONCLUSION ./ If no Part V criteria are checked, a 50.54(q)(3) Evaluation is NOT required; document the basis for conclusion below

and complete Part VI O If any Part V criteria are checked, complete Part VI and perform a 50.54(q)(3) Evaluation.

BASIS FOR CONCLUSION

Change 1 - This procedure is a one for one replacement. EN-EP-310 replaces SAP-7. SAP-7 was deleted and no longer needs to be listed in this procedure. The deletion of SAP-7 was previously reviewed under 1 OCFR50.54(q). Therefore no further evaluation is needed.

Change 2 - These procedures have already been removed from the Emergency Plan and other Implementing Procedures. The list in Appendix A is being updated to reflect the changes. The deletion of EAP-37 and EAP-43 were previously reviewed under 10CFR50.54(q). Therefore. no further evaluation is needed.

Change 3 - Added new procedure, SAP-24 to the list. This procedure describes the emergency responsibilities where loss or emergency preparedness capabilities are encountered The addition of the new procedure was reviewed under 10CFR50.54(q). Therefore, no further evaluation is needed

Changes 4 -The implementation of EN-EP-310 for application at JAF has been reviewed under 1 OCFR50.54(q). The procedure revisions have been processed. Therefore, no further evaluation 1s needed

Part VI. Sitt natures: Preparer Name (Print) Preparer Signature Date

<Y\G ~s1_ 3/22/2016 Mellonie Christman I '<Y 'O...f\ (Optional) Reviewer Name (Print) N~ viewer Signature Date:

\ R~viewer~ame ~ ..d) ~:::__o

Date: J..,.o-'-' • I<'.. I ~ ...-""'"\ $.J>-<- 5/z.z/U Nuclear EP Project Manager

Approver Name (Print) A~re Date:

J.\)~~ b --..2'-I · Jtll.11 EP manaaer or esignee vu

EN-EP-305 REV 3

ENTERGY NUCLEAR OPERATIONS, INC . JAMES A. FITZPATRICK NUCLEAR POWER PLANT


EVACUATION TRAVEL TIME ESTIMATES AND POPULATION DISTRIBUTION FOR THE JAF / NINE MILE POINT EMERGENCY PLANNING ZONE

APPENDIX K

EFFECTIVE DATE :

********************************** *********************************

* * * * * INFORMATIONAL USE * * QUALITY RELATED * * * * * ********************************** *********************************

**********************************

* * * ADMINISTRATIVE * * * **********************************

PERIODIC REVIEW DUE DATE:~~~~~~~A~p_r_i_l~2_0_1_7~~~~~~~~~

Rev. No. 10

REV.NO.

10

REVISION SUMMARY PAGE

CHANGE AND REASON FOR CHANGE

FULL REVISION

1. Revised the NMP/JAF Evacuation Time Estimates t o implement the use of standard cardinal wind directions in the development and application of affected ERPAs in the ETEs for NMP and JAF. This aligns the sectors in the Nine Mile Point and Fitzpatrick ETE with the sectors suggested in the industry guidance, NUREG/CR 7002, Criteria for Development of Evacuation Time Estimate Studies.

2. Removed Table of Contents, List of Appendices, List of Figures, previous CD version of ETE and referenced electronic ETE document location in MERLIN.

APPENDIX K EVACUATION TRAVEL TIME ESTIMATES AND POPULATION DISTRIBUTION FOR THE

JAF/NINE MILE POINT EMERGENCY PLA../\JNING ZONE

Evacuation Time Estimates (ETEs)

The evacuation time estimates (ETE) were developed in accordance with NUREG/CR-7002, Criteria for Development of Evacuation Time Estimate Studies. Section IV of Appendix E to 10CFR50 requires that an analysis of the time required to evacuate be provided for various sectors and distances within the plume exposure pathway EPZ for transient and permanent residents. The evacuation time estimate (ETE) is a calculation of the time to evacuate the plume exposure pathway emergency planning zone (EPZ), which is an area with a radius of about 10 miles around the station.

This document is prepared by KLD Engineering, PC, of Hauppauge, NY for the Nine Mile Point/James A. FitzPatrick Nuclear Facility. The information is in pdf format and can be viewed in MERLIN.

Rev . No. 10 Page K - l

,,.

ATTACHMENT 9.1 SHEET 1OF3


··-·

Procedure/Document Number: JAF Emergency Plan Appendix K I Revision: 10

Equipment/Facility/Other: JAF

Title: NMP/JAF Evacuation Time Estimates 2016

Change#1

Revised the NMP/JAF Evacuation Time Estimates to implement the use of standard cardinal wind directions in the development and application of affected ERPAs in the ETEs for NMP and JAF. This aligns the sectors in the Nine Mile Point and Fitzpatrick ETE with the sectors suggested in the industry guidance, NUREG/CR 7002, Criteria for Development of Evacuation Time Estimate Studies.

Change#2

Removed Table of Contents, List of Appendices, List of Figures, previous CD version of ETE and referenced electronic ETE document location in MERLIN.

Part II. Activity Previously Reviewed? DYES 0NO Is this activity fully bounded by an NRG approved 1 O CFR 50.90 submittal or 50.54(q)(3) Continue to

Alert and Notification System Design Report? Evaluation is next part NOT required. Enter

If YES, identify bounding source document number/approval reference and justification ensure the basis for concluding the source document fully bounds the below and

proposed change is documented below: complete Part VI.

Justification:

D Bounding document attached (optional)


Check if any other regulatory change processes control the proposed activity.(Refer to EN-Ll-100)

NOTE: For example, when a design change is the proposed activity, consequential actions may include changes to other documents which have a different change control process and are NOT to be included in this 50.54(q)(3) Screeninq. APPLICABILITY CONCLUSION 0 If there are no controlling change processes, continue the 50.54(q)(3) Screening. D One or more controlling change processes are selected, however, some portion of the activity involves the emergency plan or affects the implementation of the emergency plan; continue the 50.54(q)(3) Screening for that portion of the activity. Identify the applicable controlling change processes below. D One or more controlling change processes are selected and fully bounds all aspects of the activity. 50.54(q)(3)

Evaluation is NOT reauired. ldentifv controllinq chanae processes below and complete Part VI. CONTROLLING CHANGE PROCESSES

1 OCFR50.54(q)

Part IV. Editorial Change DYES r8J NO 50.54(q)(3) Continue to next

ls this activity an editorial or typographical change such as formatting, paragraph Evaluation is part numbering, spelling, or punctuation that does not change intent? NOT required.

Justification: Enter justification and complete Part VI.

EN-EP-305 REV 3

., -· -··-·---···--·--·--·······--·-····--·········-··-·-··-----------------------

ATTACHMENT 9.1 SHEET 2 OF 3

1 OCFR50.54(q) SCREENING



Title: Evacuation Travel Time Estimates and Population Distribution for the JAF/Nine Mile Point Emergency Planning Zone

Part V. Emergency Planning ElementJFunction Screen (Associated 10 CFR 50.47(b) planning standard function identified in brackets) Does this activity affect any of the following, including program elements from NU REG-06541FEMA REP-1 Section II?

1. Responsibility for emergency response is assigned. [1J D 2. The response organization has the staff to respond and to augment staff on a continuing basis (24/7 D


3. The process ensures that on shift emergency response responsibilities are staffed and assigned. [2] D 4. The process for timely augmentation of onshift staff is established and maintained. [2] D 5. Arrangements for requesting and using off site assistance have been made. [3] D 6. State and local staff can be accommodated at the EOF in accordance with the emergency plan. [3J D 7. A standard scheme of emergency classification and action levels is in use. [4] D 8, Procedures for notification of State and local governmental agencies are capable of alerting them of D


9. Administrative and physical means have been established for alerting and providing prompt D instructions to the public within the plume exposure pathway. [5J

10. The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and D Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. [5J

11. Systems are established for prompt communication among principal emergency response D organizations. [6J

12. Systems are established for prompt communication to emergency response personnel. [6J D 13. Emergency preparedness information is made available to the public on a periodic basis within the D


14. Coordinated dissemination of public information during emergencies is established. [7] D 15. Adequate facilities are maintained to support emergency response. [BJ D 16. Adequate equipment is maintained to support emergency response. [8] D 17. Methods, systems, and equipment for assessment of radioactive releases are in use. [9] D 18. A range of public PARs is available for implementation during emergencies. [1 OJ D 19. Evacuation time estimates for the population located in the plume exposure pathway EPZ are [gJ

available to support the formulation of PARs and have been provided to State and local governmental authorities. (1 OJ

20. A range of protective actions is available for plant emergency workers during emergencies, including D those for hostile action events. [1 OJ

EN-EP-305 REV 3

--- -- - - --·-----

AnACHMENT 9.1 SHEET3 OF3





21. The resources for controlling radiological exposures for emergency workers are established. [11] u 22. Arrangements are made for medical services for contaminated, injured individuals. [12] LJ 23. Plans for recovery and reentry are developed. [13] u 24. A drill and exercise program (including radiological, medical, health physics and other program u

areas) Is established. [141

25. Drills, exercises, and training evolutions that provide performance opportunities to develop, u maintain, and demonstrate key skills are assessed via a formal critique process in order to Identify weaknesses. [14]

26. Identified weaknesses are corrected. (14] u 27. Training is provided to emergency responders. [15) u 28. Responsibility for emergency plan development and review is established. (16) u 29. Planners responsible for emergency plan development and maintenance are properly trained. (16] LJ APPLICABILITY CONCLUSION CJ If no Part V criteria are checked, a 50.54(q)(3) Evaluation is NOT required; document the basis for conclusion below

and complete Part VI. !El If any Part V criteria are checked, complete Part VI and perfonn a 50.54(q)(3) Evaluation.

BASIS FOR CONCLUSION Change #1: The proposed changes potentially affect emergency planning elemenVfunction 10. A 10CFR50.54(q) evaluation is required.

Change #2 revises editorial detail associated with how the current ETEs are represented in Appendix K. This detail is being removed. The removal of this detail does not change the intent or content of the proposed ETE's. No evaluation will be performed.

/ Part VI. Signatures: l. / Preparer Name (Print)· if ai Pn:iparer s1Qatui.-.k. t v Date: Debra J. Heagerty l./J1Lt; • ttc-vi k Aprll 12, 2016

(Optional) Reviewer Name (Print) Reviewer Stgnature IJ () - Date:

,//A-Reviewer ~me (Pr~ ~

. Date: Reviewer Signature

-uiµ!) . t<- c 6>~ ~-t t{ ;,~!th Nuclear EP Project Manager

Approver ~ame (Print) APP"""' S~ot"" Date: James D. Jones ~A•.-A.~ ~ 4 -1 &- '10lll EP manager or deslgnee

IT'" v ... .,. ... _

- \.

EN-EP-305 REV 3

'"

ATTACHMENT 9.2 SHEET 1OF8

Procedure/Document Number: JAF Emergency Plan Appendix K

Equipment/Facility/Other: James A. FitzPatrick Nuclear Power Plant

10CFR50.54(q) EVALUATION

I Revision: 10

Title: Evacuation Travel Time Estimates and Population Distribution for the JAF/Nine Mile Point Emergency Planning Zone . ·-- ·

Part I. Description of Proposed Change:

Change #1

Revised the James A. FitzPatrick (JAF) and Nine Mile Point (NMP) Evacuation Time Estimates to implement the use of standard cardinal wind directions in the development and application of affected ERPAs in the ETEs for NMP and JAF. This aligns the sectors in the Nine Mile Point and Fitzpatrick ETE with the sectors suggested in the industry guidance, NUREG/CR 7002, Criteria for Development of Evacuation Time Estimate Studies. This change effectively replaces the 201 o ETE study in Appendix K rev 9 with the 2016 ETE study in the proposed rev 10. This evaluation is performed only for the JAF Emergency Plan. The ETE study is applicable to JAF and NMP.

Reason for Revision

The JAF/NMP Emergency Plan Evacuation Time Estimates (ETEs) are being revised to implement the use of standard cardinal wind directions in the development and application of affected ERPAs in the ETEs for Nine Mile Station. This aligns the sectors in the JAF and NMP ETE with the sectors suggested in the industry guidance, NU REG/CR 7002, Criteria for Development of Evacuation Time Estimate Studies. Specifically, the ETEs should be based on the 16 secondary-intercardinal directions (e.g., NNE, ENE). Note that the ETE covers both the JAF and NMP emergency plans.

In September 2015, JAF/NMP received a question from Oswego County regarding ETE Table 6-1 of the KLD ETE report TR-521, (dated November 2012) for the "Evacuate 2-Mile Radius and Downwind to 10 Miles" Regions- Regions R15 through R36. Specifically, Oswego County questioned why Emergency Response Planning Areas (ERPAs) 7, 14 and 15 would evacuate for Evacuation Region 16 (wind from 234° to 240°) when they are generally the same direction relative to the plant as ERPA 4, but ERPA 4 is closer to the plant and it does not evacuate.

Figure 1. Mapping the Wind Range from 234° to 240°

Wind From 234 to 240 l·Sector Approach

LtCt"M

"(:r """~'"'' 0111ra

~l···""•l:ll I..-; ~.!t l-O,,.•lllfl'1i

·-··-····-----··-···-······- ·····-···-·-·--··········-··--··---------------

ATTACHMENT 9.2 10CFR50.54(q) EVALUATION SHEET 2 OF 8




Note that an ERPA is defined as local areas within the Emergency Planning Zone for which emergency response information is provided. These areas are typically defined by geographic or political boundaries to support emergency response planning and may not conform to a precise 10-mile radius from the Plant. An Evacuation Region consists of groupings of ERPAs to be evacuated based on wind direction and wind speed.

Table 1 identifies the groupings of ERPA within each wind range that were identified in the NMP Protective Action Recommendation (PAR) procedure provided to KLD for use in development of 2012 ETE TR-521. The NMP PAR procedure is identical to that used by JAF (EAP-4C).

Table 1. JAF/NMP PARs used to Develop ETE in KLD TR-521

~l-~ft~~-i~;lla!~l 214 to 222 1,2,3,26,27 223 to 233 1,2,3,26,27 4,7 234 to 240 1,2,3, 7,26,27 4 241to254 1,2,3,4,7,26,27 9 255 to 262 1,2,3,4,7,26,27 9 263 to 278 1,2,3,4, 7 ,9,26,27 5 279 to 292 1,2,3,4,5,7,9,26,27 10 293 to 305 1,2,3,4,5,7,9, 10,26,27 306 to 311 1,2,3,4,5,7,9, 10,26,27 312 to 332 1,2,3,4,5,7,9, 10,26,27 6, 11 333 to 340 1,2,3,4,5,9, 10, 11,26,27 6,7,12 341 to 349 1,2,3,4,5,9, 10, 11,26,27 6,7,12 350 to 356 1,2,3,5,6,9, 10, 11,26,27 4,7 357 to 12 1,2,3,5,6,9, 10, 11,26,27 4 13 to 20 1,2,3,5,6, 10, 11,26,27 4,9 21 to 51 1,2,3,5,6, 10, 11,26,27 9 52 to 56 1,2,3,5,6, 11,26,27 10 57 to 61 1,2,3,5,6, 11,26,27 10 62 to 70 1,2,3,6, 11,26,27 10 71 to 89 1,2, 3,6,26,27 11 90 to 95 1,2,3,6,26,27 5, 11, 12 96 to 114 1,2,3,26,27 6, 12 115 to 146 1,2,3,26,27 147 to 213 1,2,3,26,27

Exelon, Entergy and KLD did a comprehensive review of all the Evacuation Regions in response to the question from Oswego County. This review included mapping each of the wind ranges and hatching those ERPA that are within the projected plume.

ATTACHMENT 9.2 SHEET30F8

Procedure/Document Number: -·- . ··-

JAF Emergency Plan Appendix K



--- . ·-- -·····- ·---·-·-··-· - . . ··- --

I Revision: 10


In order to map the plume, KLP first mapped the wind range "from" direction. KLD then projected the vyind range from to wind range toward by adding 180°. Then, the midpoint of the range was mapped. Finally, a 67.5° (3 consecutive 22.5° sectors) keyhole plume was constructed around the midpoint of the range by adding and subtracting 33. 75° on each side of the midpoint.

Figure 1 is an example of the map created for wind from 234° to 240° (Region R 16 in KLD TR-521 ). The wind range maps to 54° to 60° when adding 180° to map the wind range toward. The midpoint of this is 57°. Then, the plume was built around the midpoint as 23.25° (57° - 33.75°) and 90.75° (57° + 33.75°). Finally, the ERPA that intersect the plume were hatched.

Note that ERPAs 1, 2, 3, 26 and 27 are included in all Regions as they are within the 2-mile radius.

In response to the Oswego County question, and as shown in

Figure 1, ERPA 7 does intersect the plume, whereas ERPA 4 does not. The major evacuation route for ERPA 4 is Route 104 eastbound which goes through ERPAs 7 and 15. So, ERPA 4, which is not evacuating, is essentially surrounded by ERPA that are evacuating. It is concluded that this is not good practice. It would be better for ERPA 4 to be included even though it is not within the keyhole.

During the review of the Regions identified in the legacy JAF/NMP PAR, additional issues similar to Region R16 were identified.

Based on discussions with Oswego County, these anomalous Regions are believed to be a result of using narrow wind ranges. As shown in Table 1 above, the wind range is as narrow as 4° for Evacuation Region (wind direction from 52° to 56°).

The decision was made jointly by Oswego County, JAF and NMP to switch to using the standard 16 secondary-intercardinal wind directions (north, north-northeast, northeast, etc.) which are each 22.5° wide as the wind ranges. This is consistent with the guidance provided in Tables 1-4 and 1-5 of NUREG/CR-7002.



Equipment/Facility/Other: James A FitzPatrick Nuclear Power Plant


I Revision: 10


Part 11. Description and Review of Licensing Basis Affected by the Proposed Change:

Reviewed JAF FSAR, Tech Specs, TRM using the following keywords:

• Evacuation • Population estimates

The UFSAR, TS, TS Bases and TRM were searched using Merlin Reference Library. Keywords used were "population estimates" ( 0 hits TS, 0 hits TS Bases, O hits TRM, 4 hits UFSAR; some hits relevant however no changes required; only historical population estimates and projections during FSAR development and revision). Keyword "evacuation" used (0 hits TS, 1 hit TS Bases, not relevant, 0 hits TRM, 4 hits UFSAR not relevant).

The proposed changes do not affect, invalidate or render incorrect, nor have the potential to affect, invalidate or render incorrect, information contained in any LBD with the exception of the JAF Emergency Plan as described below. The proposed changes do not affect any design function, method of controlling, or any method of evaluation that demonstrates the design functions of an SSC as described in the FSAR.

In addition to those reviewed for the PAD, each of the following documents I relevant sections was reviewed:

• Reviewed current JAF Emergency Plan Appendix K. Reviewed sections 1, 2, 3, 4, 5, 6. 7, 8, 9, Appendix A, B, C, D, E, F, H, I, J, K, L, and N of the Emergency Plan. No Emergency Plan sections are affected by these changes other than Appendix K. Sections 2 and 6 do reference population estimates and ERPA's however there are no changes required.

• The original Plan (1982) was reviewed manually with no differences noted.

Part Ill. Describe How the Proposed Change Complies with Relevant Emergency Preparedness Regulation(s) and Previous Commitment(s) Made to the NRC:

Emergency Preparedness Regulation

10 CFR 50.47(b)(10)

A range of protective actions has been developed for the plume exposure pathway EPZ for emergency workers and the public. In developing this range of actions, consideration has been given to evacuation, sheltering, and, as a supplement to these, the prophylactic use of potassium iodide (Kl), as appropriate. Evacuation time estimates have been developed by applicants and licensees. Licensees shall update the evacuation time estimates on a periodic basis. Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed

--------------------

ATTACHMENT 9.2 SHEET 5 OF B

Procedure/Document Number: JAf Emergency Plan Appendix K

Equipment/Facility/other: James P.. FitzPatrick Nuclear Power Plant


I Revision: 10

Title: Evacuation Travel Time Estim< tes and Population Distribution for the JAF/Nine Mile Point Emergency Planning Zone

Site Compliance

10 CFR 50.4 7(b)(10) requires that Ev 3cuation Time Estimates are developed in accordance with the federal guidance (i.e., NUREG/CR-7002). N JREG-0654, section 11.J further requires that JAFs Emergency Plan contain time estimates for evacuation within the plume exposure EPZ. Additionally, the time estimates for evacuation of various sectors and dis ances shall be based on a dynamic analysis (time-motion study under various conditions) for the plume exp1 sure pathway emergency planning zone. 10 CFR Part 50, App E requires that the ETE analysis of the ime required to evacuate various sectors and distances within the plume exposure pathway EPZ for trar sient and permanent populations are performed using the most recent U.S. Census Bureau data as of the d< te the applicant submits its application to the NRC. Further guidance is provided by NUREG/CR-7002 and NUREG 0654 Appendix 4.

These requirements are satisfied witr KLD's revision 1 to the Nine Mile Point ETEs and have been demonstrated in part by the satisfactc ry performance of NUREG/CR-7002, Table 8-1 ETE Review Criteria Checklist. It is concluded that the JAl/NMP ETE are in compliance with the Regulatory Guidance of 10 CFR 50.47(b)(10) as well as Part 50, AppTdix IV

Appendix E: Section IV.2-6 of Appendix E to 10CFR50: .

2. This nuclear power reactor licenf applicant shall also provide an analysis of the time required to evacuate various sectors and dis ances within the plume exposure pathway EPZ for transient and permanent populations, using th most recent U.S. Census Bureau data as of the date the applicant submits its application to the NR .

3. Nuclear power reactor licensees shall use NRG approved evacuation time estimates (ETEs) and updates to the ETEs in the formu ation of protective action recommendations and shall provide the ETEs and ETE updates to State and lo< al governmental authorities for use in developing offsite protective action strategies.

4. Within 365 days of the later of the date of the availability of the most recent decennial census data from the U.S. Census Bureau or Dece:nber 23, 2011, nuclear power reactor licensees shall develop an ETE analysis using this decennial date and submit it under§ 50.4 to the NRG. These licensees shall submit this ETE analysis to the NRG at I 0ast 180 days before using it to form protective action recommendations and providing ~t to State and local governmental authorities for use in developing offsite protective action strategies.

5. During the years between deceni~ial censuses, nuclear power reactor licensees shall estimate EPZ permanent resident population c anges once a year, but no later than 365 days from the date of the previous estimate, using the mos recent U.S. Census Bureau annual resident population estimate and State/local government population data, if available. These licensees shall maintain these estimates so that they are available for NRC inspection during the period between decennial censuses and shall submit these estimates to the NRC with any updated ETE analysis.

6. If at any time during the decennic: I period, the EPZ permanent resident population increases such that it causes the longest ETE value for the 2-mile zone or 5-mile zone, including all affected Emergency Response Planning Areas, or for the entire 10-mile EPZ to increase by 25 percent or 30 minutes, whichever is less. from the nucle 3r power reactor licensee's currently NRG approved or updated ETE, the licensee shall update the ETE analysis to reflect the impact of that population increase. The licensee shall submit the updated ETE an 3lysis to the NRC under§ 50.4 no later than 365 days after the licensee's determination that the criteria for updating the ETE have been met and at least 180 days before using it to form protective action recommendations and providing it to State and local governmental authorities for use n developing offsite protective action strategies.

ATTACHMENT 9.2 SHEETS OF 8


Equipment/Facility/Other: James Ai FitzPatrick Nuclear Power Plant

-----· ----------


I Revision: 10

Title: Evacuation Travel Time Estim<1tes and Population Distribution for the JAF/Nine Mile Point Emergency

Planning Zone

Site Compliance

10 CFR 50.47(b)( 10) requires that Ev 3cuation Time Estimates are developed in accordance with the federal guidance (i.e., NUREG/CR-7002). NI REG-0654, section 11.J further requires that JAFs Emergency Plan contain time estimates for evacuation within the plume exposure EPZ. Additionally, the time estimates for evacuation of various sectors and dis ances shall be based on a dynamic analysis (time-motion study under various conditions) for the plume exp 'sure pathway emergency planning zone. 10 CFR Part 50, App E requires that the ETE analysis of the ime required to evacuate various sectors and distances within the plume exposure pathway EPZ for trar sient and permanent populations are performed using the most recent U.S. Census Bureau data as of the date the applicant submits its application to the NRG. Further guidance is provided by NUREG/CR-7002 and NU REG 0654 Appendix 4.

These requirements are satisfied with KLD's revision 1 to the JAF ETEs and have been demonstrated in part by the satisfactory performance of NL REG/CR-7002, Table B-1 ETE Review Criteria Checklist. It is concluded that the JAF/NMP ETE are in compliance with the Regulatory Guidance of 10 CFR 50.47(b)(10) as well as Part 50, Appendix IV

Previous NRC Commitments

The licensing Commitment Management System and NRC commitment sections of EP implementing Procedures were reviewed for poten~al NRC commitment changes as a result of this procedure revision. There were no identified conflicts wit this procedure and the current listing of NRC commitments associated with emergency plan implementing p ocedures or the emergency plan. All current NRC commitments that relate to the ETEs continue to be maintained and fulfilled under this procedure.

Part IV. Description of Emergency 1:>1an Planning Standards, Functions and Program Elements Affected by the Proposed Change:

10 CFR 50.47(b)(10)- Emergency Protective Actions

• A range of public PARs is availat le for implementation during emergencies. • Evacuation time estimates for the population located in the plume exposure pathway EPZ are available

to support the formulation of PARs and have been provided to State and local governmental authorities. • A range of protective actions is allailable for plant emergency workers during emergencies, including

those for hostile action events.

Appendix E to 10 CFR 50 does not c:mtain any support requirements. Informing criteria appear in NUREG-0654 in Sections ll.J.1-8, Section 11.J.10, and Supplement 3 and in the licensee's emergency plan.

Part V. Description of Impact of th1~ Proposed Change on the Effectiveness of Emergency Plan Functions:

The change to using cardinal wind di ections in the revised ETE report does not constitute a reduction in effectiveness of emergency planning for the JAF site. As discussed above, all of the Evacuation Regions suggested in NUREG/CR-7002 have been considered in the revised ETE report. Furthermore, the critical ETE values for PAR development ou lined in NUREG-0654/FEMA-REP-1, Supplement 3 have not significantly changed.

ATTACHMENT 9.2 SHEET7 OF 8

Procedure/Document Number: JA~ Emergency Plan Appendix K

Equipment/Facility/Other: James P.i. FitzPatrick Nuclear Power Plant


I Revision: 10

Title: Evacuation Travel Time Estim< tes and Population Distribution for the JAF/Nine Mile Point Emergency Planning Zone

It is noted that both Rev. 1 and Rev. 0 ETEs utilized the same industry methodology from NUREG/CR-7002, Criteria for Development of Evacuati~o'n Time Estimate Studies. This has been validated and documented through the completion of the NURE /CR-7002 ETE Criteria Checklist provided in Section N of the ETE Report.

It is understood that ETEs are used a an information tools, and no minimum evacuation time must be achieved per the regulatory guidance The change in the Rev. 1 ETE time estimates from Rev. 0 does not infer a reduction in effectiveness of thle ETE. The nominal changes identified with this revision do not impact conclusions made regarding Shelteri g or Staging of Evacuees in the Protective Action process.

The proposed changes to the JAF E f ergency Plan Appendix K continue to meet the planning standards outlined in 10 CFR 50.47(b)(10). Thi revision does not represent a reduction in the effectiveness to the emergency plan and can be incorpor ted without prior NRC approval.

ATTACHMENT 9.2 SHEETS OF 8

Procedure/Document Number: J~F Emergency Plan Appendix K

Equipment/Facility/Other: Jame~ A. FitzPatrick Nuclear Power Plant

1 OCFR50,54(q) EVALUATION

-I Revision: 10

Title: Evacuation Travel Time Esti$iates and Population Distribution for the JAF/Nine Mile Point Emergency Planning Zone J

Part VI. Evaluation Concluslo 1

Answer the following questio s about the proposed change.

I. Does the proposed change omply with 10 CFR 50.47(b) and 10 CFR 50 Appendix E?

2. Does the proposed change aintc:iin the effectiveness of the emergency plan (i.e., no reduction in effectiveness)?

t8JYES D NO

t81YES 0 NO

3. Does the proposed change , onstitute an emergency action level scheme change? DYES 181 NO

If questions 1 or 2 are answered NO, or question 3 answered YES, reject the proposed change, modify the proposed change and perform a new evaluation or obtain prior NRG approval under provisions of 10 CFR 50.90. If questions 1 and 2 are nswered YES, and question 3 answered NO, implement applicable change process(es). Refer to step 5.6(8 .

Part VII. Signatures

Preparer Name (Print)

Debra J. Heagerty

(Optional) Reviewer Name (Print)

Reviewer N1'_me (Print)

-:u~,CJ K-~~ Nuclear EP Project Manager

Approver Name (Print)

James D. Jones

EP Manager or designee

Date:

April 12, 2016.

Date·

Reviewer Signature

~~ Date:

Approver Signatu/

ENTERGY NUCLEAR OPERATIONS, INC. JAMES A. FITZPATRICK NUCLEAR POWER PLANT


MAINTAINING EMERGENCY PREPAREDNESS

SECTION 8

EFFECTIVE DATE : 1--/?la~ / . .....r; . .::-,) c I <'e ~~~~!--'~/~-=-->~'---~~

****************************** ******************************

* * * INFORMATIONAL USE * * * ****************************** ******************************

* * * ADMINISTRATIVE * * * ******************************

* * *

QUALITY RELATED * * *

******************************

c

PERIODIC REVIEW DUE DATE:~~J_ANU~_A_R_Y~2_0_1_7~~~-

Rev . No. 34

REVISION SUMMARY SHEET

REV. NO. FULL REVISION

34

Change 1: Add reference to EN-EP-307(Hostile Action Based Drills & Exercis es) to Sections 8.4(second paragraph), 8.4.2.j and 8.4.3

Change 2: Revise Section to align with 8 year cycle for Drills and exercises, 8.4.l.d, 8.4.1.e and 8.4.1.f

Change 3: Figure 8.1 - Remove ED training for ERO positions: EPM, Lead Offsite Liaison, TSC Manager, Engineering Coordinator and Offsite Liaison

Change 4: Removed signatures and OSRC information from cover sheet

Rev. No. 34 Page 8-i

TABLE.OF CONTENTS

SECTION PAGE

8.0 MAINTAINING EMERGENCY PREPAREDNESS••••••••••••••••••••• 1

8.1 Responsibility for Maintaining Emergency Preparedness •• 1

8.2 Training of Emergency Personnel ••••• ~ •••••••••••••••••• 2

8.3 Emergency Planning Staff Training ••.•.•••••••••••••••.• 4

8.4 Drills and Exercises ............•...................... 5

8.5 Document Maintenance ..•.........•......•...•........... 8

8.6 Maintenance and Inventory of Emergertcy Equipment and Supplies .............................................. 10

8.7 Maintenance of Public and News Media Awareness •••••••• 11

8 .8 Figures, Forms and Attachments •••••••••••••••••••••••• 12

) FIGURE 8.1 - EMERGENCY RESPONSE TRAINING•••••••••••••••••••••• 13 /

FIGURE 8.2 SCHEDULE OF DRILL PERFORMANCE ••••••••••••••••••••• 19

Rev. No. 34 Page 8-ii

8.0 MAINTAINING EMERGENCY PREPAREDNESS

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

8.1 Responsibility for Maintaining Emergency Preparedness

The General Manager Plant Operations (GMPO) has overall authority and responsibility for radiological emergency response planning. The Emergency Preparedness Manager is delegated the overall authority and responsibility for radiological emergency response planning and has the responsibility for developing and updating emergency plans and implementing procedures.

Primary duties of ·the Emergency Preparedness Manager or Emergency Planners include coordination of training with the Training Manager for JAF personnel and with offsit.e organizations, scheduling and coordination of drills and exercises, maintenance of plans and implementing procedures, and maintenance and inventory of emergency equipment. The Emergency Preparedness Manager usually delegates the responsibilities for maintenance and inventory of emergency equipment to the Emergency Planners.

The JAFNPP Training Manager is responsible for ensuring that all personnel who have emergency plan duties at the JAFNPP receive the appropriate emergency preparedness training.

The Training Manager shall coordinate the scheduling of training of onsite personnel and provide for the training of all offsite fire support personnel.

Rev. No. 34 Page 8-1

_/

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

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

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

Individuals responsible for Emergency Planning are trained in accordance with paragraphs 8.2 - Training Of Emergency Personnel and 8.3 - Emergency Planning Staff Training. In addition, the Emergency Planning Staff receives training by: attendance at Emergency Planning Workshops conducted with other utilities and attendance at NRC, FEMA and other government sponsored Emergency Planning seminars and, participation in JAFNPP specific training programs related to emergency preparedness.

8.2 Training of Emergency Personnel

Plant personnel, participating corporate personnel, and offsite response organization personnel that respond to onsite requests for assistance receive emergency response training in accordance with their roles in an emergency.

The JAFNPP Training Department shall maintain a centralized records program concerning Emergency Plan Training Documentation. Records will include classroom training for plant personnel, and records documenting drills and exercise participation.

The following curriculum shall be completed by individuals on the Authorized Access List.

a. Overview of the Emergency Plan, include planning objectives, emergency organizations and facilities, the existence of coordinated procedures and the ability of the Emergency Response Organization {ERO) to mitigate the consequences of emergencies.

b. Site alarms and general responses.

Rev. No. 34 Page 8-2 ~~~-

c. Onsite and offsite evacuation routes, assembly areas, and decontamination of personnel and vehicles.

d. Reporting of fires, injuries, spills and other emergency conditions.

e. Accountability procedures.

f. Emergency classifications.

g. Rumor control.

Personnel assigned to the JAFNPP with specific emergency preparedness duties and responsibilities shall receive specialized training for their respective assignments. The types of training given in conjunction with Emergency Preparedness are:

a. Training for directors, coordinators, and personnel responsible for accident assessment

b. Emergency Communications training

c. Training for Radiological Monitoring Teams and Radiological Assessment personnel

d. Emergency access control, evacuation and accountability

e. Search and rescue/first aid response

f. Emergency repair/corrective actions

g. Training for onsite fire fighting personnel

h. Medical support personnel

i. Offsite fire fighting personnel

j. Severe Accident Management training


Figure 8.1 - Emergency Response Training presents a summary of the emergency response training program including type of training, personnel receiving training, frequency of training and retraining, applicable procedures, and objectives of the training. Details of the emergency planning training program can be found in EN-TQ-110, EMERGENCY RESPONSE ORGANIZATION TRAINING and SAP-20, Emergency Plan Training.

Training will include classroom training and where applicable practical training.

8.2.1 Annual Review of Emergency Action Levels

The Emergency Preparedness Manager, in accordance with 10 CFR 50, shall conduct an annual review of the JAFNPP Emergency Action Levels (or changes to those EALs from the prior review cycle) with appropriate representatives of New York State and Oswego County. Reviews will be documented by memorandum.

8.3 Emergency Planning Staff Training

Emergency Planning Staff Members receive on-going training and experiences to maintain or improve their knowledge related to emergency planning. At least once each calendar year members of the Emergency Preparedness staff are involved in one of the following activities:

• Training courses specific to emergency preparedness.

• Training courses related to emergency preparedness management, such as problem solving, stress management or confrontation/media relations; courses.

• Observation of or participation in drills and/or exercises at other utilities or stations.

• Participation in industry review and evaluation programs.

• Participation in regional or national emergency preparedness seminars, committees, workshops or forums.

• JAF training courses in related areas, such as systems, operations, or radiological protection training.


8.4 Drills and Exercises

An exercise is an event that tests the integrated capability and a major portion of the basic elements existing with1n emergency preparedness plans and organizations.

Drills and Exercises are discussed in detail in EN-EP-306, DRILLS AND EXERCISES, EN-EP-307, HOSTILE ACTION BASED DRILLS & EXERCISES and EN-EP-308, EMERGENCY PLANNING CRITIQUES.

Drills and exercises provide the means to evaluate training effectiveness under simulated emergency conditions, skills developed during training, reinforce correct actions and identify and correct short-comings in training, equipment, or procedures.

8.4.1

Rev. No. 34

Drills

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

The Emergency Preparedness Manager is responsible for the conduct of drills listed in Figure 8.2 - Schedule Of Drill Performance (except for Fire Fighting drills which are the responsibility of the Training Manager).

Drills shall be conducted using the following guidelines:

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

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

c. Drill critiques are conducted per EN-EP-308-EMERGENCY PLANNING CRITIQUES and the results of the critique along with observer, evaluator, controller and participant comments are utilized to evaluate and resolve any identified shortcomings.

Page __ 8_-_5_

8.4.2

Rev. No. 34

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

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

f. Drills are conducted under various weather conditions.

Exercises

The Emergency Preparedness Manager is responsible for the coordination and conduct of exercises. Exercises are conducted at least once every two years in accordance with NRC and FEMA rules. Detailed guidance for the conduct of exercises is contained in procedure SAP-1, MAINTAINING EMERGENCY PREPAREDNESS, EN-EP-306, DRILLS AND EXERCISES, EN-EP-308, EMERGENCY PLAN CRITIQUES. In summary the following criteria apply to exercises conducted at JAFNPP.

Exercises will be conducted using the same criteria as applied to drills and in accordance with the Figure 8.2 - Schedule of Drill Performance as summarized below:

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

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

c. Exercises are planned in advance using formal scenarios.

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

e.

f .

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

Unannounced exercises are controlled through

Page 8-6

8.4.3

Rev. No. 34

input of initiating events by controllers.

g. Observers, evaluators, controllers and participants comments form the exercise documentation package.

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

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

j. Drill/Exercise report generation is in accordance with EN-EP-306 - DRILLS AND EXERCISES, EN-EP-307 - HOSTILE ACTION BASED DRILLS AND EXERCISES and EN-EP-308 -EMERGENCY PLANNING CRITIQUES.

Drill and Exercise Scenario Preparation Responsibilities

The development of drills and exercises for JAFNPP .shall be coordinated by the JAFNPP Emergency Preparedness Manager. The JAFNPP Training Manager shall have the responsibility for developing plant specific data. The JAFNPP Emergency Preparedness Manager shall have the responsibility for ensuring plant specific radiological data is provided. Exercise Scenario preparation shall be conducted by a committee and documented by the Emergency Preparedness Manager

Responsibilities are discussed in detail in EN-EP-306 - DRILLS AND EXERCISES and EN-EP-307 -HOSTILE ACTION BASED DRILLS AND EXERCISES.

Page 8-7

)

8.5 Document Maintenance

8.5.1

8.5.2

Rev. No. 34

Plans and Procedures

The JAFNPP Emergency Plan and Procedures will be maintained in the format and by the method specified in JAFNPP Administrative Procedure AP-02.03, EMERGENCY PREPAREDNESS. This procedure delineates the following:

a. Responsibilities (for Emergency Plan Maintenance)

b. Format

c. Review and approval

This procedure documents that review and updating of the JAFNPP Emergency Plan and Implementing Procedures are primarily the responsibility of the Emergency Preparedness Manager. The Plan shall be updated periodically, based on recommendations resulting from exercises, drills, changes in operating procedures or conditions, or changes in regulatory or other requirements.

Technical Support Guidelines for Severe Accident Management are free form reference guides that do not have the same format, review and approval as listed above.

Letters of Agreement

The Emergency Preparedness Manager will ensure that letters of agreement from all participating organizations are reviewed and recertified. Recertification may include a written recertification, purchase order documentation, memo form, or a memo of a telephone conversation. The General Manager of Plant Operations (GMPO) JAF is the individual with the authority and responsibility to make agreements with utility and non-utility organizations.

Page 8-8

8.5.3

8.5.4

8.5.5

Rev. No. 34

Reviews

An independent review of the JAFNPP Emergency Preparedness Program shall be conducted by the Entergy Quality Assurance Department. The independent review shall be conducted in accordance with 10CFR50.54(t) as follows:

• At intervals not to exceed 12 months or,

• As necessary, based on an assessment by the licensee against performance indicators, and as soon as reasonably practicable after a change occurs in personnel, procedures, equipment, or facilities that potentially could adversely affect emergency preparedness, but no longer than 12 months after the change. In any case, all elements of the emergency preparedness program must be reviewed at least once every 24 months.

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

Supporting Documents

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

Page 8-9

8.6 Maintenance and Inventory of Emergency Equipment and Supplies

Periodic testing, calibration and inventory of emergency equipment and supplies are conducted in accordance with Emergency Plan Implementing Procedure SAP-2, EMERGENCY EQUIPMENT INVENTORY. The Emergency Preparedness Manager or designated alternate shall conduct an annual review of this procedure to ensure the operational readiness of emergency equipment and supplies.

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

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

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

Communications checks and drills will be conducted in accordance with SAP-3, EMERGENCY COMMUNICATIONS TESTING. This procedure specifies that certain emergency telephones and telephone numbers shall be verified at least quarterly.

Rev. No. 34 Page __ 8_-_1_0_

8.7 Maintenance of Public and News Media Awareness

8.7.1

8.7.2

Rev. No. 34

Public Awareness

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

Information is distributed to permanent residents by various methods, including mailings to their residence or placement in local telephone books. Postings in public areas and places of business frequented by the transient population is the principal method for informing those individuals.

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

Residents Who May Require Special Care

Information for residents who may require special care (e.g. handicapped, elderly) is included with the annual mailing sent to the resident population. Along with this information is a card that is requested to be returned if an individual requires special care. A list of these individuals is maintained by the OCEMO for their use.

Page 8-11

8.7.3

8.7.4

Rumor Control

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

News Media Awareness

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

8.8 Figures, Forms and Attachments

Figure 8.1 - Emergency Response Training

Figure 8.2 - Schedule of Drill Performance


TITLE/FUNCTION

Emergency Plan Indoctrination for Non-Essential Personnel

Emergency Plan Indoctrination for Essential Personnel

34

FIGURE 8.1 EMERGENCY RESPONSE TRAINING

ASSIGNED PERSONNEL

Personnel requiring regular access to the site.

Essential personnel who may be assigned to specific response functions in JAFNPP Emergency Plan.

FREQUENCY

Per General Employee Training, EN-TQ-107, Requirements

Before assuming position, annually thereafter.

TRAINING OBJECTIVE

Ensure Ability to: a. Report emergency conditions

correctly and expeditiously. b. Recognize and recal 1 the

significance of site alarms. c. Evacuate affected areas and the

site. d. Locate and assemble in designated

assembly areas. e. Facilitate personnel

accountability process. f . Rumor Control . g. Overview of JAFNPP Emergency Plan.

The objective of Emergency Plan Indoctrination for Essential Personnel shall be to provide Emergency Response Personnel a more detailed knowledge of the plant Emergency Plan and Procedures to ensure these personnel are familiar with their scope, applicability, and implementation.

8-13

i J

TITLE/FUNCTION

Emergency Plan Training for directors, coordinators, and personnel responsible for accident assessment

*Licensed Operator training may be substituted for Emergency Director training.

Emergency Plan Training for Licensed Operators and Shift Technical Advisors

Rev. No. 34

ASSIGNED PERSONNEL

Designated Primary and Alternates

a. Emergency Director b. EOF Manager c. Operations

Coordinator*

Any personnel not listed above who are assigned to a position that requires a valid USNRC Operator License, or who are designated as STAs.

FI'2.-..~-<'~ 8 .1 EMERGENCY RESPONSE TRAINING

(continued)

FREQUENCY

Before assuming position

Annually thereafter


Annually thereafter

TRAINING OBJECTIVE

The objective of training for Emergency Directors/Coordinators shall be to ensure the capability for immediate response, assessment and the implementation of measures to prevent or mitigate the consequences of emergencies through effective management of the Emergency Organization.

The objective of Emergency Plan training for Licensed Operators and STAs shall be to ensure the capability for immediate response, assessment, and the implementation of measures to prevent or mitigate the consequences of emergencies.

Page 8-14

TITLE/FUNCTION

Severe Accident Management Training

Emergency Plan Training for NonLicensed Operators

Emergency Corrununications

34

ASSIGNED PERSONNEL

Designated Staff

Non-Licensed Operators

Designated Primary and Alternates:

a. ENS Communicator b. Offsite

Communicators (EOF)

c. EOF Communicators


(continued)

FREQUENCY


Once every two years thereafter training or drill


Annually thereafter


Annually thereafter

TRAINING OBJECTIVE

The objective of SAM training shall be to ensure the capabilities for coordination, and assumption of responsibilities of actions associated with Severe Accident Operations Guidelines.

The objective of Emergency Plan training for Non-Licensed Operators shall be to ensure the capability for immediate response by conducting measures to prevent or mitigate accident conditions.

The objective of training for emergency communicators shall be to develop and maintain a group of Emergency Communicators qualified to operate emergency communication systems and effectively transmit emergency information and data to the applicable personnel and/or agencies.

8-15

TITLE/FUNCTION

Radiological Assessment

Radiological Controls and Surveys during Emergencies

Emergency Access Control, Evacuation and Accountability

Rev. No. 34

ASSIGNED PERSONNEL


a. Radiological Assessment Coordinator (EOF)

b. Offsite Team Coordinator (EOF)

c. Dose Assessor (EOF)

d. Dose Assessor Support (EOF)


a) In-Plant Radiological Controls and Downwind Survey Teams

b) RP Technicians c) Chemistry

Technicians d) Radiation

Protection I Chemistry Coordinator

e) Offsi te Mani toring Team

Designated Primary and Alternates

Fil1,~~--b 8 .1 EMERGENCY RESPONSE TRAINING

(continued)

FREQUENCY


Annually thereafter


Annually thereafter


TRAINING OBJECTIVE

The objective of training for radiological assessment personnel shall be to develop and maintain a group of personnel qualified to assess real or potential radiological hazards during emergencies in order to provide the Emergency Director with the necessary information and advice to make offsite protective action reconunendations and mitigate radiological consequences.

The objective of training for radiological controls personnel shall be to develop and maintain a group of personnel qualified to measure real or assess potential radiological conditions during emergencies in order to provide radiological assessment personnel with the necessary information to assess or project radiological hazards both on and offsite.

The objective of training in Emergency Access Control/ Evacuation and Accountability is to develop and

Page 8-16

TITLE/FUNCTION

Search and Rescue/First Aid Response

Emergency Repair/ Corrective Actions Training

Onsite

Reu. No. 34

ASSIGNED PERSONNEL

a. Plant Security Force

b. Security Coordinator

c. Security Shift Supervisor

d. Nuclear Security Guards.

Plant Fire Brigade members.


a. TSC Maintenance Coord.

b. OSC Manager c. Mechanics d. Electricians e. Instrument and

Control Technicians

f. Electrical/I & C Coordinator

g. Mechanical Coordinator

a. Fire Brigade


(continued)

FREQUENCY

Annually thereafter


Annually thereafter


Annually thereafter

Annually

TRAINING OBJECTIVE

maintain the station security force's ability to maintain personnel accountability, and ensure effective coordination of personnel movements, onsite, and during an emergency.

The objective of training fire brigade members in Search and Rescue/First Aid Response is to assure that prompt medical attention is provided to contaminated, injured or ill personnel and to provide effective search and rescue capabilities for missing, trapped or injured personnel in an emergency situation. The objective of Emergency Repair/ Corrective Action is to develop and maintain a group of personnel capable of assessing and performing emergency repair or corrective action operations in-plant in an emergency situation.

Develop well-trained fire brigade whose

8-17

TITLE/FUNCTION

Fire Fighting Personnel

Medical Support Personnel

Offsite Fire Fighting Personnel

Rev. No. 34

ASSIGNED PERSONNEL

members and Supervisors as specified in the Fire Protection Procedures Manual

a. Oswego Hospital Personnel

b. Ambulance Drivers and Attendants

c. University Hospital Personnel

Designated personnel from those fire agencies which will most likely respond to a request for aid through Oswego County E-911.

FI1~~-_J 8. 1 EMERGENCY RESPONSE TRAINING

(continued)

FREQUENCY

Annually

Annually

TRAINING OBJECTIVE

actions minimize injuries, property loss and damage and lost generation time.

Ensure a high state of emergency preparedness and medical awareness of handling of contaminated injuries that may occur at a nuclear facility.

The objective of training for fire fighting personnel is to ensure that offsite individuals who may be called upon in an emergency to access the JAFNPP will be knowledgeable in applicable procedures and intended roles.

Page 8-18

TITLE/FUNCTION

Communication

Communication

Communication

Fire Fighting

34

FIGURE 8.2 SCHEDULE OF DRILL PERFORMANCE

ASSIGNED PERSONNEL

Function of Corrununications link to State and Local Governments

Function of Corrununications link to Federal Emergency Response Organization

Function of Corrununications network out to field assessment personnel

Fire Brigade Response

FREQUENCY

Monthly

Monthly

Annually

Ref er to FPPs

ORGANIZATION(S) /PERSONNEL

Plant NY State Oswego Co.

Plant ENS HPN NRC

Plant NY State Oswego Co. Plant Field Monitoring Teams

Plant -Operations Fire Brigade Misc. Personnel Offsite -Scriba FD (Mutual Aid)

TRAINING OBJECTIVE

Test in Accordance with SAP-3, EN-EP-306

Test in Accordance with SAP-3, EN-EP-306

Test in Accordance with annual exercise and EN-EP-306

In Accordance with Fire Protection Procedures, AP-14.01 and EN-TQ-125

8-19

TITLE/FUNCTION

Medical Emergency

Radiological Monitoring

Rev. No. 34

FIGURE 8.2 SCHEDULE OF DRILL PERFORMANCE

(continued)

ASSIGNED PERSONNEL

Treatment of Contaminated, injured person

Dispatching and directing survey teams to perform radiation surveys and collect environmental samples (air, soil, water, etc.).

FREQUENCY

Annually

Annually

ORGANIZATION(S) /PERSONNEL

Plant -Operations First Aid Team Misc. Personnel Offsite -Ambulance Personnel Hospital Personnel

Plant ...:.. Radiological Assessment Coordinator Radiological Coordinator Radiological Monitors Other Support personnel

TRAINING OBJECTIVE

In Accordance with written scenario per SAP-1, EN-EP-306, EN-EP-308

In accordance with written scenario per SAP-1, EN-EP-306, EN-EP-308

Page 8-20

-·

ATTACHMENT 9.1 5HEET1 OF4

Procedure/Document Number: JAF Emergency Plan I Revision: 34

Equipment/Faclllty/Other: JAF

Title: Section 8: Maintaining Emergency Preparedness

1 OCFR50.54(q) SCREENING

Part I. Description of Activity Being Reviewed (event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan):

Annual review and revision of the JAF Emergency Plan Section 8 to include the following:

Change 1: Add reference to EN-EP-307(Hostile Action Based Drills & Exercises) to Sections 8.4(second paragraph), 8.4.2.j and 8.4.3

Change 2: Revise Section to align with 8 year cycle for Drills and exercises, 8.4.1 .d, 8.4.1.e and 8 .4.1. f

Change 3: Figure 8.1 - Remove ED training for ERO positions: EPM, Lead Offsite Liaison, TSC Manager, Engineering Coordinator and Offsite Liaison

Change 4: Removed signatures and OSRC Information from cover ~heet

Part II. Activity Previously Reviewed? ls this activity fully bounded by an NRC approved 10 CFR 50.90 submittal or Alert and Notification System Design Report?

If YES, Identify bounding source document number/approval reference and ensure the basis for concluding the source document fully bounds the proposed change is documented below: Justification:

D Bounding document attached (optional)


DYES 50.54(q)(3) Evaluation is NOT required. Enter justification below and complete Part VI.

181 NO Continue to next part

Check if any other regulatory change.processes control the proposed activity.(Refer to EN-Ll-100) NOTE: For example, when a design change is the proposed activity, consequential actions may include changes to other documents which have a different change control process and are NOT to be included in this 50.54(q)(3) Screenina. APPLICABILITY CONCLUSION 181 If there are no controlling change processes, continue the 50.54(q)(3) Screening. D One or more controlling change processes are selected, however, some portion of the activity involves the emergency plan or affects the implementation of the emergency plan; continue the 50.54(q)(3) Screening for that portion of the activity. Identify the applicable controlling change processes below. D One or more controlling change processes are selected and fully bounds all aspects of the activity. S0.54(q)(3) Evaluation is NOT required. Identify controlling change processes below and complete Part VI.

CONTROLLING CHANGE PROCESSES

1 OCFR50.54(q)

EN-EP-305 REV 3

··········-······-·········--········-···-·----------------------



Procedure/Document Number: Emergency Plan I Revision: 34

EquipmenUFacility/Other: JAF


Part IV. Editorial Change DYES rB;J NO ls this activity an editorial or typographical change such as formatting, paragraph S0.54(q)(3) Continue to nex

numbering, spelling, or punctuation that does not change intent? Evaluation is part

Justification: NOT required. Enter justification and complete Part VI.

Part V. Emergency Planning ElemenUFunction Screen (Associated 10 CFR 50.47(b) planning standard function identified in brackets) Does this activity affect any of the following, including program elements from NU REG-0654/FEMA REP-1 Section II?

1. Responsibility for emergency response is assigned. [1] 0 2. The response organization has the staff to respond and to augment staff on a continuing basis (24/7 0


3. The process ensures that on shift emergency response responsibilities are staffed and assigned. [2] 0 4. The process for timely augmentation of onshift staff is e_stablished and maintained. [2] D 5. Arrangements for requesting and using off site assistance have been made. [3] 0 6. State and local staff can be accommodated at the EOF in accordance with the emergency plan. [3] 0 7. A standard scheme of emergency classification and action levels is in use. [4] 0 8. Procedures for notification of State and local governmental agencies are capable of alerting them of D


9. Administrative and physical means have been established for alerting and providing prompt D instructions to the public within the plume exposure pathway. [5]

10. The public ANS meets the design requirements of FEMA-REP-10, Guide for Evaluation of Alert and D Notification Systems for Nuclear Power Plants, or complies with the licensee's FEMA-approved ANS design report and supporting FEMA approval letter. [5]

11. Systems are established for prompt communication among principal emergency response 0 organizations. [6]

12. Systems are established for prompt communication to emergency response personnel. [6] D 13. Emergency preparedness information is made available to the public on a periodic basis within the D


14. Coordinated dissemination of public information during emergencies is established. [7] D 15. Adequate facilities are maintained to support emergency response. [8] D 16. Adequate equipment is maintained to support emergency response. [BJ D 17. Methods, systems, and equipment for assessment of radioactive releases are in use. [9] D 18. A range of public PARs is available for implementation during emergencies. [10] D

EN-EP-305 REV 3

..

ATTACHMENT 9.1 1 OCFR50.54(q) SCREENING 5HEET30F4


Equipment/Facility/Other:· JAF


19. Evacuation time estimates for the population located in the plume exposure pathway EPZ are D available to support the formulation of PARs and have been provided to State and local governmental authorities. [1 O]

20. A range of protective actions is available for plant emergency workers during emergencies, including u those for hostile action events.[10)

21. The resources for controlling radiological exposures for emergency workers are established. [11] D 22. Arrangements are made for medical services for contaminated, injured individuals. [12] D 23. Plans for recovery and reentry are developed. [13] D 24. A drill and exercise program (including radiological, medical, health physics and other program 18]

areas) is established. [14]

25. Drills, exercises, and training evolutions that provide performance opportunities to develop, D maintain, and demonstrate key skills are assessed via a formal critique process in order to identify weaknesses. [14]

26. Identified weaknesses are corrected. [14] D 27. Training is provided to emergency responders. [15] u 28. Responsibility for emergency plan development and review is established. [16] D 29. Planners responsible for emergency plan development and maintenance are properly trained. [16] D APPLICABILITY CONCLUSION

0 If no Part V criteria are checked, a 50.54(q)(3) Evaluation is NOT required; document the basis for conclusion below and complete Part VI.

!El If any Part V criteria are checked, complete Part VI and perform a 50.54(q)(3) Evaluation.

BASIS FOR CONCLUSION Change 1: Add reference to EN-EP-307(Hostile Action Based Drills & Exercises) to Sections 8.4(second paragraph), 8.4.2.j and 8.4.3. Previously this procedure only referenced EN-EP-306 and was not updated to include the reference to EN-EP-307 for hostile action based drills and exercises. Drills continue to be performed. There are no applicable Emergency Planning Element/Functions affected by this change. The change does not add, delete or modify a process, meaning or intent of a description, or change facilities or equipment. No further evaluation is required.

Change 2: Revise Section to align with 8 year cycle for Drills and exercises, 8.4.1.d and 8.4.1.e. Drills continue to be performed. This change was made to align with 8 year cycle described in EN-EP-306. The change to revise the drill frequency could potentially affect 10CFR50.47 (b) Planning Standard 14 (Emergency Planning Element 24 in the screening - Attachment 9.1) and will be evaluated.

Change 3: Figure 8.1 - Remove ED training for ERO positions: EPM, Lead Offsite Liaison, TSC Manager, Engineering Coordinator and Offsite Liaison. These positions are not responsible for performing classifications and PARS and therefore the training associated with the performance of those functions was removed from Figure 8-1. This change was previously evaluated under 10CFR50.54(q) for SAP-20 revision 36. There are no applicable Emergency Planning ElemenVFunctions affected by this change. The change does not add, delete or

EN-EP-305 REV 3

·-·-·------------------------------------,

-· ATTACHMENT 9.1 1 OCFR50.54(q) SCREENING SHEET40F4

·-


Equipment!Facility/Other: JAF

Title: Section 8 Maintaining Emergency Preparedness

modify a process. meaning or intent of a description, or change facilities or equipment. No further evaluation is required.

Change 4: Removed signatures and OSRC information from cover sheet. There are no applicable Emergency Planning Element/Functions affected by this change. The change does not add, delete or modify a process, meaning or intent of a description, or change facilities or equipment. No further evaluation is required.

Part VI. Signatures:

Preparer Name (Print) ~C\rr~t~Y Date: Mellonie Christman 3-09-2016

(Optional) Reviewer Name (Print) Revie~r Signature Date:

NII\ Reviewer Name (Print) Reviewer Signature Date:

",Dov.cJ!. K,.~ v..l\.~.9. ~. Q 3-fO-lfa Nuclear EP Project Manager

Approver Name (Print) Stf7'"" Date: James D. Jones 3-lO~ ~l>I~ EP manager or designee

EN-EP-305 REV 3

.P





Part I. Description of Proposed Change:

1 OCFR50.54( q) EVALUATION

Note: Changes 1, 3 and 4 screened out. Only changes 2 requires an evaluation.

The proposed change is the annual review and revision of the JAF Emergency Plan Section 8 to include the following change:

Change 2: Revise Sections 8.4.1.d, 8.4.1.e and 8.4.1.f to align with 8 year cycle for Drills and exercises.

Part II. Description and Review of Licensing Basis Affected by the Proposed Change:

The changes to JAF Emergency Plan Section 8 affect emergency preparedness processes only. They represent no changes to the plant facility or systems, structures or components. These changes do not represent a change in any tests or experiments. These changes do not represent any modification to the plant's design or design functions.

A commitments search was performed using JAF LRS. With the exception of the JAF Emergency Plan section 8 noted, no current commitment impacts were identified.

Part Ill. Describe How the Proposed Change Complies with Relevant Emergency Preparedness Regulation(s) and Previous Commitment(s) Made to the NRC:

Changes 1

10 CFR 50.47(b)(14) - Drill and Exercise Program - A drill and exercise program (including radiological, medical, health physics, and other program areas) is established.

Site Compliance: This procedure establishes a frequency to conduct Off-Hours Unannounced drills to standardize the drill and exercise program and processes to promote excellence in practices to manage emergencies. Guidance is provided for the preparation and conduct of Off-Hours Unannounced drills. This change implements the regulatory changes for an eight year exercise cycle in the year the site performs a hostile action based exercise. Through implementation of this procedure revision, a drill and exercise program is established and maintained and this procedure as revised continues to comply with the planning standard.

Previous NRC Commitments

The Licensing Commitment Management System and NRC commitment sections of the emergency plan and applicable EP Implementing Procedure were reviewed for potential NRC commitment changes as a result of this procedure revision. There were no identified conflicts with this procedure revision and the current listing of NRC commitments associated with the EPIPs or Emergency Plan.

EN-EP-305 REV 3

ATIACHMENT 9.2 SHEET20F3

Procedure/Document Number: JAF Emergency Plan




I Revision: 34

Part IV. Description of Emergency Plan Planning Standards, Functions and Program Elements Affected by the Proposed Change:

10 CFR 50.47(b)(14) - Drill and Exercise Program

• A drill and exercise program (including radiological, medical, health physics, and other program areas) is established.

• Drills, exercises, and training evolutions that provide performance opportunities to develop, maintain, and demonstrate key skills, are assessed via a formal critique process in order to identify weaknesses.

• Identified weaknesses are corrected.

Sections IV.F.1-2 of Appendix E to 10 CFR 50 provide supporting requirements. Informing criteria appear in Section 11.N of NUREG-0654 and the licensee's emergency plan.

Part V. Description of Impact of the Proposed Change on the Effectiveness of Emergency Plan Functions:

• Change 2 assessment:

Revise Sections 8.4.1.d, 8.4.1.e and 8.4.1.f to align with 8 year cycle for Drills and exercises

Revised Off hours Unannounced Drill frequency to match EN-EP-306. The frequency of the Off hours Unannounced Drill was changed from "Once per 3 years" to "In accordance with EN-EP-306". EN-EP-306 defines the Off hours Unannounced Drill frequency as "3 years or twice per 8 year cycle (Typically 3 to 5 years apart)". NRC rule, Enhancements to Emergency Preparedness Regulations effective 12123/11, changes the six year requirements to an eight year exercise cycle beginning in the calendar year in which the site conducts the first hostile action based exercise. Since this procedure covers plants having their first HAS exercise in two different years, the procedure must contain both the 6 year and 8 year exercise cycle requirements. This change supports both the plants required to follow the 6 year schedule and the plants required to implement the 8 year exercise cycle in the year the plant conducts its first HAB exercise. The 8 year exercise cycle also applies to the objectives that are on the 6 year frequency. This change continues to comply with the requirements of planning standard 1 OCFR50.47(b)(14) and does not represent a reduction in effectiveness to the Emergency Plan because this change conforms to the EP rulemaking changes to 1 O CFR Part 50, Appendix E, Section IV.F.2.i and j. NSIR/DPR-ISG-01, Interim Staff Guidance Emergency Planning for Nuclear Power Plants, Revision 0 (November 2011) provides additional clarity and guidance on the 8 year exercise cycle and exercises required in the 8 year cycle.

The proposed changes to Plan Section 8 continue to meet the planning standards outlined in 1 O CFR 50.47 (b) (14). The effectiveness of the emergency plan is not reduced. The emergency plan changes can be incorporated without prior NRC approval.

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. - ·- -· - - . -·· -·- --· ·-- ... ···-·· ----ATTACHMENT 9.2 10CFR50.54(q) EVALUATION SHEET 3 OF 3



Title: Section 8: Maintaining Emergency Preparedness ' Part VI. Evaluation Conclusion

\

Answer tho following questions about the proposed change.

I. Does the proposed change comply with 10 CFR 50.47(b) and 10 CFR 50 Appendix E? [8JYES D NO

2. Does the proposed change maintain the effectiveness of the emergency plan (i.e., no [8JYES D NO

reduction in effectiveness)?

3. Does the proposed change constitute an emergency action level scheme change? DYES~ NO

If questions 1 or 2 are answered NO, or question 3 answered YES, reject the proposed change, modify the proposed change and perform a new evaluation or obtain prior NRC approval under provisions of 10 CFR 50.90. If questions 1 and 2 are answered YES, and question 3 answered NO, implement applicable change process( es). Refer to step 5.6[8].

Part VII. Signatures

Preparer Name (Print) Preparer Signature y Date:

Mellonie Christman rra~~ 3/09/2016

(Optional) Reviewer Name (Print) N JI\ \Reviewer Signature v Date:

Reviewer Name (Print)

~~ Date:

~.Q ll-lo~~ 5 ~lo - l<.o Nuclear EP Project Manager

Approver Name (Print) Approver Signature Date: James D. Jones

~~ ~ ~-1o~Jo1u EP Manager or designee

\J

EN-EP-305 REV 3