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PNPS NON-QUALITYEPA-lSEMERGENCY RELATED Revision 7

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EMERGENCY PREPAREDNESS ORGANIZATION AND RESPONSIBILITIES

Emergency Preparedness Organizationand Responsibilities

Change Statement

*Update titles and department references for Human Capital Managementreorganization. Pages 3-5,7-9

*Change EN-EP-307 title from "Threat Based Drills" to "Hostile Action Based Drills &Exercises". Pages 4,5,10

* Change "Nuclear Training" to "PNPS Training". Page 5

,, Add EN-EP-801 title "Emergency Response Organization". Page 5

* Add EP-AD-1 22 title "Maintenance of the Emergency Telephone Directory". Pages6,10

* Change "EN-EP-201, 'Performance Indicators" to "EN-FAP-EP-005, 'EmergencyPreparedness Performance Indicators". Pages 6,10

* Change "Emergency Organization" to "Emergency Response Organization". Page 7

* Add Alternate Joint Information Center acronym "(AJIC)". Page 8

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Table of ContentsSection Title

Paae

1.0 PURPOSE ............................................................................ 32.0 ,REFERENCES ....................................................................... 33.0 DEFINITIONS...................................................•....................... 34.0 RESPONSIBILITIES ................................................................. 35.0 DETAILS.............................................................................. 45.1 PRECAUTIONS AND LIMITATIONS............................................... 45.2 PROCEDURE ......................................................................... 45.2.1 Nuclear Safety Assurance Director.................................................. 45.2.2 Emergency Preparedness Manager ................................................ 55.2.3 Emergency Preparedness Staff ..................................................... 75.2.4 Budget ................................................................................. 95.2.5 Professional Development And Training ............................................. 95.2.6 Industry Issues ........................................................................ 96.0 INTERFACES ........................................................................ 107.0 RECORDS............................................................................ 108.0 REQUIREMENTS AND COMMITMENTS ........................................ 119.0 ATTACHMENTS..................................................................... 11ATT-ACHMENT 9.1 DOCUMENT CROSS-REFERENCES ......................................... 12

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1.0 PURPOSE

This Procedure describes the overall organization and responsibilities for maintaining thePNPS Emergency Preparedness Program.

2.0 REFERENCES

[1] EP-PP.-01, "PNPS Emergency Plan"

[2] NOP88A4, "Assignment of Responsibilities in Support of the PNPS EmergencyPreparedness Pro gram"

3.0 DEFINITIONS

[1] Corporate Organization - As used herein, all organizations and departments that do notreport to the Site Vice President.

[2] EPOC - Emergency Planning Oversight Committee.

[3] ERO - Emergency Response Organization.

[4] Offsite - The geographical area outside the Owner Controlled Area.

[5] Onsite - The land on which PNPS is located and the property immediately contiguous toPNPS which is owned by Entergy. This includes both the Protected Area and theOwner Controlled Area.

[6] Reportable - Occurrences (e.g., equipment or system malfunctions) that have beendetermined to warrant:

(a) Notification to the NRC under the requirements of I0CFR50.72 or I0CFR50.73.

(b) Notification of Emergency Planning Management.

4.0 RESPONSIBILITIES

[1] The Regulatory & Performance Improvement Director is responsible for ensuring theoverall maintenance of the PNPS Emergency Preparedness Program. This includescoordinating with the Emergency Planning Manager to provide management oversightand to provide support through the Emergency Planning Oversight Committee (EPOC)and necessary plant resources to maintain both the adequacy of onsite and offsiteEmergency Preparedness Programs at PNPS.

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[7] The Emergency Planning Oversight Committee (EPOC) is established andmaintained in accordance with EN-FAP-EP-002, "Emergency Planning OversightCommittee ".

5.2.2 EMERGENCY PLANNING MANAGER

The Emergency Planning Manager is responsible for managing the PNPS EmergencyPreparedness Program. Specifically, this may include but is not limited to the followingresponsibilities:

[1] Overseeing the development and maintenance of the PNPS Emergency Plan and itsImplementing Procedures while ensuring that regulatory guidance and industrystandards are met.

[2] Reviewing the Emergency Preparedness Training Program, including review of lessonplans.

(a) Interfacing with PNPS Training to ensure that an adequate number of personnelare trained and qualified to respond to an emergency at PNPS in accordancewith EN-TQ-212, "Conduct of Training and Qualification".

[3] Developing and conducting drills and exercises to maintain the state of readiness of thePNPS Emergency Preparedness Program in accordance with EN-EP-306, "Drills andExercises", EN-EP-307, "Hostile Action Based Drills & Exercises", and EN-EP-308,"Emergency Planning Critiques".

[4] Developing and maintaining administrative Procedures and manuals required to assurethe maintenance of the PNPS Emergency Preparedness Program.

[5] Ensuring the resolution of Emergency Preparedness deficiencies discovered throughdrills, audits, and training.

[6] Ensuring updates to the ERO staff are performed on a continuous basis, as needed, sothat sufficient numbers of personnel are qualified and available to staff the ERO on a24-hour/day basis in accordance with EN-EP-801, "Emergency ResponseOrganization ".

(a) Communicating the need for additional assignments to management orsupervisors and recommending personnel to be selected for ERO assignmentsas appropriate.

(b) Additions and deletions are communicated and forwarded to PNPS Training forincorporation into the applicable Training database.

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(c) Providing Security a list of personnel who are assigned to the EOF in accordancewith EP-AD-1 22, 'Maintenance of the Emergency Telephone Directory" so thatthey can ensure they are included in the FED Program. Verification of inclusionin the FED pool should be completed prior to entry of EOF personnel into aqualified status within the Training database.

NOTE

Requalification for ERO purposes does not apply to the annual requalification associated withGET and ERO qualification conducted once per year by Training. The notification processapplies to those positions that require requalification for training modules that are not normallypresented during the annual requalification process.

(d) Notifying applicable managers or supervisors of individuals who have failed toqualify or requalify.

[7] On a quarterly basis, ensuring that a position-by-position review of the ERO On-CallRoster is completed to determine whether any corrective action is needed inaccordance with EP-AD-122, "Maintenance of the Emergency Telephone Directory".

(a) Maintain ERO Readiness - ERO Defense in Depth Performance Indicator (PI) offour deep for Control Room, TSC, OSC, ICP, EOF, and JIC positions inaccordance with EN-FAP-EP-005, "Emergency Preparedness PerformanceIndicators".

(b) For positions falling below four deep, advise management or supervisors asappropriate of the need for individuals to be assigned to fill ERO positions to theirarea of expertise within the Emergency Plan. Otherwise, select an individualbased on EN-EP-801, "Emergency Response Organization".

(c) Inform PNPS Training of personnel to be qualified or requalified for thesepositions in accordance with EN-TQ-2 12, "Conduct of Training and Qualification"

(d) Provide Security a list of personnel who are assigned to the EOF so that they canensure they are included in the FED Program.

[8] Coordinating the development and annual distribution of the public informationpublication.

[9] Maintaining the PNPS Emergency Telephone Directory.

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(d) Coordinates the development and maintenance of administrative Procedures andmanuals required to assure the maintenance of the Station's EmergencyPreparedness Program.

(e) Ensures the operation and maintenance of Pilgrim Nuclear Power Station'semergency communications equipment.

(f) Ensures the operational readiness of PNPS emergency response facilities [i.e.,Emergency Operations Facility (EOF), Operational Support Center (OSC),Technical Sup~port Center (TSC), Joint Information Center (JIC), AlternateEmergency Operations Facility (AEOF), and Alternate Joint Information Center(AJIC)].

(g) Ensures the resolution of the Emergency Preparedness activity tracking throughStation corrective action systems, as appropriate.

(h) Ensures the maintenance and readiness of Station Prompt Alert NotificationSystem (sirens).

(i) Develops and conducts the Station Drill and Exercise Program.

[3] The offsite operational readiness activities may include, but are not limited to, thefollowing:

(a) Ensures that the Pilgrim Nuclear Power Station Emergency Plan and Proceduresare maintained and consistent with related Commonwealth and local EmergencyResponse Plans and Procedures.

(b) Ensures that the Emergency Public Information Program is developed andmaintained to achieve consistency and compatibility with the Pilgrim NuclearPower Station program.

(c) Provides assistance to local and Commonwealth officials in their emergency plandevelopment and revision efforts.

(d) Ensures local and Commonwealth training program development,implementation, and revision.

(e) Establishes and maintains liaison with elected and appointed local andCommonwealth officials by representing the PNPS Emergency PlanningDepartment at meetings and functions.

(f) Ensures that the Emergency Planning Manager is aware of trends andrelationships in community activities and actions. I

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(g) Participates in the development and implementation of strategies associated withoffsite Emergency Preparedness programs that are responsive to currentEmergency Preparedness regulations.

(h) Develops and maintains with the state of Rhode Island Emergency ManagementAgency Radiological Emergency Plans and Procedures for the IngestionPathway.

5.2.4 BUDGET

[1] The Emergency Planning Manager coordinates with the Regulatory & PerformanceImprovement Director to implement the following:

(a) Develop the annual budget request;

(b) Present and justify that request to management; and

(c) Manage Emergency Preparedness activities so as to remain within theconstraints of the approved budget.

[2] The Emergency Planning Manager will administer the approved budget.

5.2.5 PROFESSIONAL DEVELOPMENT AND TRAINING

All professionals assigned to Emergency Planning should participate, on at least an annualbasis, in programs designed to improve their Emergency Preparedness knowledge, technicalabilities, or management skills. These programs may include classroom training, workshops,seminars, participation in drills or exercises at other utilities, or industry review and evaluationprograms. Entergy cooperates with other agencies and institutions to provide college leveland/or continuing education courses for employees. Emergency Planning personnel areencouraged to consult with their manager regarding the availability of these courses andparticipate to the extent possible.

5.2.6 INDUSTRY ISSUES

The Emergency Planning Manager shall have the responsibility to remain informed on thestatus of Emergency Preparedness issues throughout the industry. Significant developmentsshould be brought to the attention of Emergency Planning personnel as appropriate.

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6.0 INTERFACES

[1] EN-EP-306, "Drills and Exercises"

[2] EN-EP-307, "Hostile Action Based Drills & Exercises"

[3] EN-EP-308, "Emergency Planning Critiques"

[4] EN-EP-801, "Emergency Response Organization"

[5] EN-FAP-EP-002,. "Emergency Planning Oversight Committee"

[6] EN-FAP-.EP-005, "Emergency Planning Performance Indicators"

[7] EN-TQ-2 12, "Conduct of Training and Qualification"

[8] EP-AD-1 22, "Maintenance of the Emergency Telephone Directory"

7.0 RECORDS

[1] This Procedure generates the list of personnel who are assigned to the EOF andprovided to Security which is not a QA record.

[2] The ERO On-Call Roster is updated using current information from the EmergencyTelephone Director (ETD) and applicable Training ERO database.

[3] Electronic communications between the EP Manager and managers, supervisors, andSecurity have no retention requirements.

[4] The Emergency Telephone Director (ETD) quarterly update documents theperformance of the quarterly ERO review and is maintained in accordance withEP-AD-1 22, "Maintenance of the Emergency Telephone Directory".

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8.0 REQUIREMENTS AND COMMITMENTS

This section lists those external commitments (NRC commitments, QA audit findings, andINPO inspection items) implemented in this Procedure.

Reference Commitment AffectedDocument _________________ Section(s)/Step(s)

Self-Assessment of EP MSTP - Rep Task S000245: Inactive. This activityProgram Commitments Quarterly review of program has been tracked for

commitments as relating to more than 2 yearsorganizational structure. and is embedded

within establishedprocess.

9.0 ATTACHMENTS

9.1 DOCUMENT CROSS-REFERENCES

PNPS

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F EMERGENCY PREPAREDNESS ORGANIZATION AND RESPONSIBILITIESATTACHMENT 9.1 DOCUMENT CROSS-REFERENCESSheet 1 of 1

This Attachment lists those documents which may be affected by changes to this Procedure.

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Equipment Important To Emergency Response (EITER)


RTYPE H8.24

Chanaqe Statement* Add "Allowed Outage Time" definition to Definitions section. Page 5

* Change comPensatory measure for Sea Water Bay Level instrumentation loss to"Operations to evaluate Sea Water Bay Water Level per PNPS 5.3.8." Page 25

* Change "LI-263-73A" and LI-263-73B" to "LIS-263-73A" and LIS-263-73B"respectively. Page 29

* Change "Emergency Response Organization Notification (ERON) System" to"Emergency Response Organization Notification (ERON) / Everbridge System".Page 35

* Change EITER Tracking sheet example equipment IDs to ones listed in thisprocedure. Page 58

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m Equipment Important To Emergency Response (EITER)

TABLE OF CONTENTS

Section Title Paae

1.0 PURPOSE............................................................................ 4

2.0 REFERENCES ........................................................................ 4

3.0 DEFINITIONS ................................ :......................................... 5

4.0 RESPONSIBILITIES .................................................................. 8

5.0 DETAILS ...................... :. ....................................................... 9

5.1 PRECAUTIONS AND LIMITATIONS................................................ 9

5.2 PROCEDURE ........................................................................ 10

5.2.1 General Guidelines .................................................................. 10

5.2.2 PNPS Emergency Plan EAL Instrumentation ..................................... 10

5.2.3 Emergency Operations Facility (EOF) ............................................. 11

5.2.4 Technical Support Center (TSC).................................................... 12

5.2.5 Operations Support Center (OSC) ........................................... :.......13

5.2.6 Joint Information Center (JIC)....................................................... 14

5.2.7 Main Control Room .................................................................. 15

5.2.8 Alternative Facility.................................................................... 16

5.2.90Offsite Response Organizations EITER and Public Notification Systems ..... 17

5.2.10 Discovery of Degraded or Non Functional EITER ................................ 18

5.2.11 Removing EITER from Service for Planned Maintenance ....................... 19

6.0 INTERFACES ........................................................................ 20

7.0 RECORDS ................................................. .......................... 21

8.0 REQUIREMENTS AND COMMITMENTS......................................... 21

9.0 ATTACHMENTS ..................................................................... 21

ATTACHMENT 9.1 - EQUIPMENT IMPORTANT TO EMERGENCY RESPONSE

AND COMPENSATORY MEASURES ............................ 22

ATTACHMENT 9.2 - UNPLANNED LOSS OF EQUIPMENT IMPORTANT TOEMERGENCY RESPONSE ....................................... 56

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ATTACHMENT 9.3 - PLANNED OUT OF SERVICE CONDITION OF EQUIPMENTIMPORTANT TO EMERGENCY RESPONSE ................... 57

ATTACHMENT 9.4 - EQUIPMENT IMPORTANT TO EMERGENCY RESPONSETRACKING SHEET (EXAMPLE) .................................. 58

ATTACHMENT 9.5 - DOCUMENT CROSS-REFERENCE.............................. 59

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Equipment Important To Emergency Response (EITER)1.0 PURPOSE

The purpose of this procedure is to ensure that when Equipment Important to EmergencyResponse (ElTER) is removed from service for maintenance or is in a degraded or failedcondition, the correct restoration priority is assigned, compensatory measures areimplemented, and the equipment is restored to a functional condition promptly. Thisprocedure provides the Pilgrim Nuclear Power Station (PNPS) listing of EITER andcompensatory measures.

In order to protect the health and safety of the public, licensees are required to follow andmaintain in effect, emergency plans that meet the standards of 10 CFR 50.47(b) and10 CFR 50 Appendix E. Equipment required to meet these regulations must be capable offunctioning at all times, or if there is a loss of function, compensatory measures must beavailable and taken to restore the function until the equipment is repaired. A loss ofemergency response function may occur from planned maintenance or unplanned equipmentfailures.

In some cases, installed redundant equipment provides adequate compensatory measures.In other cases, the Technical Specifications (TS) or Administrative Controls (AC) providesadequate compensatory actions. The PNPS Emergency Plan is designed as a last line ofdefense to address design basis accident events at PNPS, including the capability ofprotecting public health and safety during and following an accident. Therefore, regulationsthat govern EITER may require more timely restoration than Technical Specifications or otheradministrative controls. Actions site personnel take to return degraded or out-of-serviceEITER to service should be commensurate with the significance of the associated emergencyresponse function.

2.0 REFERENCES

[1] EN-EP-202, "Equipment Important to Emergency Preparedness"

[2] EN-WM-1 00, "Work Request (WR) Generation, Screening and Classification".

[3] EP-IP-1 00.1, "Emergency Action Levels (EALs)"

[4] USNRC Information Notice 2005-19, Effect of Plant Configuration Changes on theEmergency Plan, dated July 18, 2005

[5] INPO 10-007, Equipment Important to Emergency Response

[6] NUREG 1022, Revision 3, Event Reporting Guidelines 10 CFR 50.72 and 50.73: FinalReport

[7] NUREG 1022, Revision 3, Supplement 1, Event Report Guidelines10 CFR 50.72(b)(3)(xiii) - Final Report, September 2014

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Equipment Important To Emergency Response (EITER)[81 NEI 13-01, Reportable Action Levels for Loss of Emergency Preparedness

Capabilities, Revision 0, July 2014

3.0 DEFINITIONS

[1] Allowed Outage Time: Time limits reverse engineered based on time limits provided inthe NRC EP Significance Determination Process (SDP) criteria found in ManualChapter 609, Appendix B. The time limit used is that which corresponds to no finding,which constitutes the lowest risk for the out of service condition.

[2] Alternate Indication: A backup means of monitoring a parameter or condition whichshould approximate the primary indication it is replacing.

[3] Cateaorv A(1) Equipment: Equipment that provides the sole indication or very littleredundancy for a parameter used to assess an emergency action level (EAL)threshold.

[4] Cateaory A(2) Equipment: Equipment that provides the sole means of fulfilling anemergency response function

[5] Categqory B Equipment: Equipment that has redundant components or trains that fulfillan emergency response function or redundant indications for a parameter used toassess an EAL threshold,.

[6] Compensatory Measure: A temporary means to mitigate the degradation or loss ofemergency response function or of maintaining the emergency response function untilthe equipment is restored to a fully functional condition.

(a) A compensatory measure is the best available means to maintain theemergency preparedness function. Compensatory measures may include, butare not limited to, redundant equipment.

(b) Compensatory measures are put in place prior to scheduled equipment outagesand design modifications and immediately following equipment loss or facilityfunctional failures, to prevent or mitigate any loss of function that could resultfrom the removal of the equipment from service.

(c) Each compensatory measure is evaluated against the PNPS Emergency Planrequirements. This is to determine the capability of the compensatorymeasure's function and should state the allowed duration of the interimcompensatory measure. This duration may be different than the time allowedby Technical Specifications or equipment control guidelines. (This is dueprimarily to NRC SDP finding significance evaluation criteria). The review isdocumented and includes an analysis, conclusion, and approval of thecompensatory measure. This documentation may be in the form of anapproved, specific procedure which identifies compensatory measures inadvance, for specific EITER.

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Equipment Important To Emergency Response (EITER)(d) Compensatory measures are incorporated into the emergency preparedness

and work management processes. The work prioritization matrix appropriatelyaddresses EITER and adjusts/raises priority when the compensatory measureput in place exceeds the time allowed in the evaluation or procedure, or whenthe compensatory measure itself fails.

(e) Compensatory measures that rely on periodic monitoring also have an event-based trigger that prompts immediate and more frequent monitoring. Forexample, periodic sampling (such as once a shift) may be used to compensatefor a nonfunctional vent radiation monitor. However any increase in elevatedarea or airborne radiation levels in the affected buildings after the compensatorymeasure is put in place should trigger immediate and more frequent sampling.

(f) A formal tracking method is implemented to ensure compensatory measuresare in place and are completed on time.

[7] Emeraency Action Level (EAL): A condition or set of conditions that require entry intothe PNPS Emergency Plan at a specified emergency classification level (UnusualEvent, Alert, Site Area Emergency or General Emergency).

[8] Equipment Important to Emercqency Response (EITER): Includes systems, structures,and components, including essential tools and equipment, necessary to ensure theability of the station to implement the PNPS Emergency Plan. The level of detail usedin tracking these items should be sufficient to allow the user to identify any loss ordegradation of function that supports the PNPS Emergency Plan.

(a) Essential tools and equipment include, but are not limited to, such items as, facility computer links to the plant computer, dedicated telephone lines, hand-

held radiation survey meters, air samplers, and specially-equipped radiationmonitoring team vehicles. Loss or degradation of these items would result inthe loss of an emergency response function, as identified in the PNPSEmergency Plan.

(b) In contrast, nonessential tools and equipment are those items which, althoughuseful, would not result in a loss of function or diminish the emergencyresponse capability and are not considered equipment important to emergencyresponse.

[9] Emeraency Response Facility (ERF): Facilities, buildings, and structures, identified inthe PNPS Emergency Plan and which include systems and equipment identified in theplan that are used for emergency response during declared PNPS Emergency Planevents.

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Equipment Important To Emergency Response (EITER)[10] Functional Readiness: The availability of emergency response facilities and

Equipment Important to Emergency Response (EITER), maintained to ensure thehighest degree of reliability and a constant state of readiness. Consult the documentslisted in the References section for regulatory guidance related to "unavailable time"and restoration timeliness.

[11] Loss of Function: The inability of a facility, system or component, including essentialtools and equipment, to fulfill its emergency response purpose.

[12] Maintenance: Scheduled maintenance, periodic testing, or emergent equipmentfailures that can result in a loss of emergency response function. For the purposes ofstation work management, certain Equipment Important to Emergency Response(EITER) is considered "plant equipment" because it is required to be maintained byfederal or state regulatory compliance as defined in EN-WM-1 00, "Work Request (WR)Generation, Screening and Classification ". Maintenance encompasses the followingactivities (which are further subdivided into categories per EN-WM-1 00).

(a) Corrective maintenance (CM) represents a level of degradation of plantequipment that has failed or is significantly deficient such that failure isimminent (within its operating cycle/preventive maintenance interval) and it nolonger conforms to or cannot perform its design function.

(b) Deficient maintenance (DM) is any work on a plant component where there ispotential or actual degradation that does not threaten the component's designfunction or performance criteria.

(c) Other maintenance (OM) is work that does not reflect a material conditiondeficiency on plant equipment.

(d) Toolpouch Maintenance is a methodology by which work is accomplished thatdoes not require work documents to be initiated.

(e) Contingency Maintenance is work to be performed if a component is found tobe in a degraded state during other repairs or inspections.

[13) Timely Restoration: The PNPS Emergency Plan is designed as a last line of defenseto address design basis accident events at Pilgrim Nuclear Power Station, includingthe capability of protecting public health and safety during and following the accident.Therefore, regulations that govern Equipment Important to Emergency Response(EITER) may require more timely restoration than Technical Specifications or otheradministrative controls. Actions site personnel take to return degraded or out-of-service EITER to service should be commensurate with the significance of theassociated emergency response function.

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Equipment Important To Emergency Response (EITER)4.0 RESPONSIBILITIES

[1] The Performance Improvement Manager is responsibie for ensuring that the correctiveaction program supports tracking and trending of deficiencies related to EITER.

[2] The Design & Program Engineering Manager and Systems & Components Managerare responsible for ensuring that engineering support is provided as required, in theplanning and execution of work on EITER, and for assuring that configuration controlprocesses account for impact on emergency preparedness functions and equipment.

[3] The Emergency Planning Manager is responsible for maintaining oversight of EPfacilities and equipment, as well as ensuring that work and change-related processesinclude appropriate screening requirements to identify impacts to the EP program.The Emergency Planning Manager also has the overall responsibility for assuring themaintenance of this procedure, which contains a current list of equipment required forassessing EAL initiating conditions and for performing ERF functions, and for providingguidance on applicable compensatory actions for indicators and equipment notavailable for use.

[4] The Operations Shift Manager is responsible for ensuring that appropriate actions,including identification, tracking, and compensatory measures, are taken when EITERor emergency response facilities are degraded or removed from service. TheOperations Shift Manager is responsible for determining NRC reportability whenEITER is found degraded or out of service.

[5] The Operations Shift Manager/Emergency Director has the responsibility to utilize theinformation in this procedure in making EAL classifications.

[6] The Regulatory Assurance Manager or designee is responsible for providing guidanceon compliance with the station licensing basis and to assist the Operations ShiftManager when determining NRC reportability if EITER is found degraded or out ofservice.

[7] The Sr. Production Manager is responsible for ensuring that work on ElTER within thescope of the work management program is appropriately prioritized and scheduled.

[8] Operations Manager/Shift Manager or Sr. Production Manager has the responsibilityfor reviewing plant equipment that is out of service and its impact on EALdeterminations and emergency response facility availability. In addition he/she has theresponsibility to utilize the information in this procedure as a reference to establishcontingencies and take actions for planned instrument or equipment outages or duringthe recovery from an unplanned outage for the ERF equipment or instrumentsproviding indication for EAL determinations. Operations Support is responsible forproviding Operations information to the OSC Teams and the OSC Supervisor andensuring the Shift Manager is informed of OSC staffing utilization and activities.

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Equipment Important To Emergency Response (EITER)5.0 DETAILS

5.1 PRECAUTIONS AND LIMITATIONS

[1] NRC enforcement actions proceed from the assumption that licensees are required tofollow and maintain in effect, emergency plans that meet the standards of10 CFR 50.47(b) and 10 CFR 50 Appendix E. The NRC has interpreted this to meanthat equipment required to meet these regulations must be capable of functioning at alltimes, or if there is a loss of function, that compensatory measures must be taken torestore the function until the equipment is repaired.

[21 Specific reportability requirements in 10 CFR 50.72 exist for the loss of function ofEITER. 10 CFR 50.72(B)(3)(xiii) addresses the NRC 8 hour report requirement for amajor loss of emergency assessment capability, offsite response capability, or offsitecommunications capability. NEI 13-01 provides guidance for determining when a"major loss" of EP capability has occurred. If there is a loss of function of EITER, theOperations Shift Manager, must make the reportability determination. The RegulatoryAssurance manager or designee and the EP Manager or designee should becontacted to assist when making the reportability determination. The requirements ofEN-LI-I108, "Event Notification and Reporting", and PNPS 1.3.12, Notification andRecall of Personnel, must be followed.

[3] Category A(1) and A(2) equipment must be restored promptly or evaluated withIOCFR 50.54(q) and must be tracked on the daily plant status report until resolved.Compensatory measures must be initiated immediately.

[4] Category B equipment must be restored using normal work management processes. Ifalternate equipment is out of service, equipment must be restored promptly orevaluated with 10CFR 50.54(q) and must be tracked on the daily plant status reportuntil resolved. If alternate equipment is out of service, compensatory measures mustbe initiated immediately.

[5] If the ERO member callout systems have no redundancy or diversity, thencompensate or immediately restore to service. While compensating for the system,restore it to service within 24 hours.

[6] Maintain unavailability for any indivdual siren less than 4 continuous months.

[7] Maintain availability of any individual siren at >70% in any 12 month period, withcompensatory measures in place to assure that alerting takes place in less than 45minutes.

[8] If backup power for at least one onsite and one offsite communication system is out ofservice, restore within 3 days from time of discovery.

[ PNPS NON-QUALITY% -e yrPAEMERGENCY PRC~RRELATED EP-AD-270 Revision 1Entergy ADMINISTRATIVE POEDR


Equipment Important To Emergency Response (EITER)[9] If significant communications equipment is out of service, restore it within one day

and/or complete compensatory and repair methods.

[10] If the function of the JIC is impaired to the point where it cannot activate and performwithin the committed time frame, then compensatory measures should be establishedwithin 24 hours and the issue corrected within 7 days.

[11] Restore a non-functional TSC/OSC or EOF facility to functionality within 24 hours.Provide compensatory measures immediately.

[12] Maintain dose assessment equipment and systems such that any unavailability is lessthan 24 hours from time of discovery.

[13] Maintain field monitoring equipment and systems such that any unavailability is lessthan 72 hours from time of discovery.

[14] Maintain respirator equipment such that a minimum Control Room complement is ableto perform its function, and compensate within 4 hours if not met.

[15] Maintain out of service plant paging/announcement systems at less thanl0%unavailable speakers for a period no longer than 90 days.

5.2 PROCEDURE

5.2.1 General Guidelines

[1] Compensating actions need not be based on an exact replication of the monitoredparameter; a reasonable approximation can suffice in the case where only oneinstrument is installed and the parameter is not otherwise controlled.

[2] Timeliness of restoration actions should be commensurate with the significance of thedegraded emergency response function.

5.2.2 PNPS Emergency Plan EAL Instrumentation

[1] If an EAL entry condition is determined by a single (Category A) instrument which hasno Technical Specification (TS) or Administrative Control (AC) required compensatoryaction, then preplanned, documented compensatory actions should be provided toaddress the alternate means of making the EAL entry determination when theinstrument is inoperable. This preplanned action must be implemented immediatelyupon removal of the instrument from service (or discoveryrthat it is out of service).

[2] If an EAL entry condition is determined by a single instrument which has a TS or ACrequired compensatory action, then that compensating action may be used as thealternative action for EAL entry provided that the compensatory action can beaccomplished in a reasonably short time frame.

PNPS NON-QUALITY-~EMERGENCY RELATED EP-AD-270 Revision 1

~Enter~gy ADMINISTRATIVE PRCDEPROCEDURES REFERENCE USE Page 11 of 59

Equipment Important To Emergency Response (EITER)[3] If an EAL entry condition is part of a statement with multiple OR clauses, each of

which is directed at the same parameter, then each clause in the OR statement can beconsidered as compensatory action for the others, assuming the subject clause canitself be met (e.g. does not rely on the out of service instrument also).

[4] If an EAL entry condition contains several different process monitoring instrumentswhich are monitoring separate processes or parameters, but are grouped in the EALso that any of them can initiate entry into the EAL, then they do not serve ascompensating action for one another.

[5] If an EAL entry condition is monitored by multiple instruments (at least two), then nopreplanned compensation is required, provided a TS or AC action exists (such assampling) to address the loss of both instruments.

[6] If multiple different parameters are being monitored in a single instrument, orredundant instruments, then each of the parameters must have its own compensatingaction (e.g. different actions for the particulate, iodine and noble gas channels).

[7] The radiation monitoring' EALs make use of multiple non-redundant instruments tomonitor similar parameters in ventilation or local areas. Many of these are not coveredin the TS or AC. The monitors are located throughout the plant and may be thought ofas providing overlapping coverage for any event involving loss of control of radioactivematerial. However, it is necessary to have a plan in place to indicate which and howthe instruments/methods will be used as compensation.

[8] Some EALs use parameters which are indicated by multiple alarms and indications,some of which require brief diagnostic efforts by the shift crew, or which may bedetermined by actions which are obvious. These do not require preplanneddocumented contingencies, unless all means of determination are lost.

5.2.3 Emergency Operations Facility (EOF)

[1] The general functions of the EOF are:

(a) Coordination of overall response with Federal, Commonwealth and localagencies

(b) Coordinate radiological and environmental assessments

(c) Determine Protective Action Recommendations (PARs)

(d) Evaluate plant conditions to support radiological release assessment

(e) Support TSC and Control Room with offsite resources

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Equipment Important To Emergency Response (EITER)[2] The EOF EITER list and compensatory measures were developed based on the

following guidance:

(a) Safety Parameter Display System (SPDS) for plant data

(b) Meteorological Data display

(c) Radiological Data display

(d) Dose assessment hardware and software for determination of Protective ActionRecommendations

(e) Radiation monitoring equipment for personnel in EOF for exposure and airborneradioactivity with radioiodine detection down to 1 E-07 microcuries/cc

(f) Radios for communication with Offsite Monitoring Teams (OMTs)

(g) Charcoal filtration system with protection factor >=5

(h) Voice communications with TSC, Main Control Room, NRC andCommonwealth and local operations centers ,

(i) Communication with any facility outside the EOE that may supply supplementalsupport

(j) Fax capability between EOF, TSC and NRC Operations Center

(k) Some phone connections must bypass local switches and connect directly tocommercial phone systems that do not lose power during outages

(I) Plant information must be available or deliverable to the EOF. Any equipmentused to facilitate this availability must be identified and maintained operable

5.2.4 Technical Support Center (TSC)

[1] The general functions of the TSC are:

(a) Provides plant management and technical support to operations duringemergency conditions

(b) Relieve the reactor operators of peripheral duties and communications notdirectly related to reactor system manipulations

(c) Prevent congestion in the Main Control Room

... •PNPS NON-QUALITY• EMERGENCY RELATED EP-AD-270 Revision 1

Entergy ADMINISTRATIVE PRCDEPROCEDURES REFERENCE USE Page 13 of 59

Equipment Important To Emergency Response (EITER)[2] The TSC EITER list and compensatory measures were developed based on the

following guidance:

(a), Safety Parameter Display System (SPDS) for plant data



(d) Radiation monitoring equipment for personnel in TSC for exposure and airborneradioactivity with radioiodine detection dlown to 1 E-07 microcuries/cc

(e) Radiological protection gear to facilitate travel to Main Control Room (PC's,respirators, etc.)

(f) Ventilation system to produce habitability the same as the Main Control Roomwith HEPA and charcoal filtration (not seismic, redundant, automatic orinstrumented in Main Control Room)

(g) Voice communications with OSO, Main Control Room, EOE, NRC andCommonwealth and local operations centers

(h) Radios for communication with Offsite Monitoring Teams (OMTs)

(i) Fax capability between EOF, TSC and NRC Operations Center

(j) Some phone connections must bypass local switches and connect directly tocommercial phone systems that do not lose power during outages

(k) Plant information must be available or deliverable to the TSC. Any equipmentused to facilitate this availability must be identified and maintained operable

5.2.5 Operations Support Center (OSC)

[I] The general functions of the OSC are:

(a) Provide a location where plant logistical support can be provided during anemergency

(b) Coordination, dispatch and tracking of field teams necessary to respond to anemergency event

oPNPS NON-QUALITY• _EMERGENCY' RELATED EP-AD-270 Revision I

~zEI~er~y ADMINISTRATIVE PRCDR ________________


Equipment Important To Emergency Response (EITER)[2] The OSC EITER list and compensatory measures were developed based on the

following guidance:

(a) An alternate on site location must be provided in the event the OSC isevacuated, such that support can continue as required

(b) Direct communications with the TSC and the Main Control Room so that dutiescan be assigned in support of emergency response activities

(c) Radiological assessment capabilities to determine habitability of the facility

5.2.6 Joint Information Center (JIC)

[1] The general functions of the JIC are:

(a) Provide a location for the news media and Entergy points of contact toexchange information during an event

(b) Provide a space and equipment to support the spokesperson that will provideinformation on the event to the news media

(c) Provide a means of exchanging information among all the parties'spokespersons

(d) Provide a means of dealing with rumors related to the event

[2] The JIC EITER list and comPensatory measures were developed based on thefollowing guidance for equipment required for exchange of information:

(a) Equipment for communications with the EOF/TSC (phones, faxes, web, etc.) toacquire accurate information related to the event

(b) Equipment required to provide copies of the information to the press, such ascopiers, printers, computers or word processors, etc.

(c) Equiprnient to facilitate the function of the spokesperson, such as public addresssystems, overhead projectors, drawings, etc.

(d) Equipment required to provide information among the Offsite ResponseOrganizations' (OROs') spokespersons.

(e) Equipment required to communicate with the EOF so that rumors can beaddressed with accurate information and equipment (phones, web sites, etc.) tocommunicate with the public to receive questions and provide accurateinformation regarding rumors.

SPNPS INON-QUALITYSEMERGENCY RELATED EP-AD-270 Revision 1SEnter~gy. PADiNISRTEjPROCEDURE


Equipment Important To Emergency Response (EITER)5.2.7 Main Control Room

[1] The general functions of the Main Control Room for emergency response are toperform the functions of the Emergency Response Organization (ERO) until the EROhas been notified and the Emergency Response Facilities (ERFs) have been declaredoperational, as follows:

(a) Assess and classify the event

(b) Perform offsite dose assessment

(c) Determine any protective actions required

(d) Notify the ERO to activateER~s

(e) Notify the Offsite Response Organizations (OROs) of the event classificationand any Protective Action Recommendations (PARs) required (immediatenotification requirement)

(f) Activate the Emergency Notification System (ENS) to notify the NRC of theevent classification

(g) Report the event per 10 CFR 50.72 as required

(h) Continue to assess the plant status and take initial corrective actions to addressthe event

(i) Direct plant personnel to evacuate, as required, or to perform corrective actionsto address the event

[2] The Main Control Room EITER list and compensatory measures were developedbased on the following guidance:

(a) Plant alarms and indications required for EAL classification

(b) Safety Parameter Display System (SPDS) for plant data

(c) Meteorological Data display

(d) Radiological Data display

(e) Dose assessment hardware and software for determination of Protective ActionRecommendations (PARs)

* (f) Equipment required to notify members of the ERO to report to their facilities andmake them operational (ERON, Paging system, and all equipment required tomake it function)

(g) Offsite notification system as required by regulation. This is any and allequipment used to notify offsite agencies of the classification of the event and

• PNPS INON-QUALITYEMERGENCY RELATED EP-AD-270 Revision 1

Entcr~y.ADMINISTRATIVE PRCDRPROCEDURES REFERENCE USE Page 16 of 59

Equipment Important To Emergency Response (E=ITER)any protective actions to be taken. Includes DNN, BE=CONS, phones, otherradios, faxes, and all supporting equipment

(h) Radiation monitoring equipment for personnel in the Main Control Room forexposure and airborne radioactivity with radioiodine detection down to I1E-07microcuries/cc

(i) Ventilation system to produce habitability as required for the Main ControlRoom, i.e., redundant, backup power, seismic, etc.

(j) Voice communications with 0S0, EQEF, NRC and Commonwealth and localoperations centers

(k) Radios for communication with Ofisite Monitoring Teams (OMTs)

(I) Plant public address systems or in plant radio systems used to communicatewith plant personnel for evacuation announcements, directions to performcorrective actions, or initial announcements to activate E=RFs

5.2.8 Alternative Facility

[1] The function of the Alternative Facility for Emergency Response is to provide a stagingarea for TSCIOSC Responders in the event of a Hostile Action towards the plant or abeyond design basis external event. The Alternate Facility is to maintain the followingcapabilities:

(a) Provides plant management and technical support to operations duringemergency conditions

(b) Relieves the reactor operators of peripheral duties and communications notdirectly related to reactor system manipulations

(c) Provides a location where plant logistical support can be provided during anemergency

(d) Coordination, dispatch and tracking of field teams necessary to respond to anemergency event

t•PNPS NON-QUALITYEMERGENCY RELATED EP-AD-270 Revision 1

Eutergy ADMINISTRATIVE PREDEPROCEDURES REFERENCE USE Page 17 of 59

Equipment Important To Emergency Response (EITER)[2] The Alternative Facility EITER list and compensatory measures were developed based

on the following guidance:

(a) Safety Parameter Display System (SPDS) for plant data



(d) Voice communications with Main Control Room, EQE, NRC andCommonwealth and local operations centers

(e) Fax capability between EOF and NRC Operations Center

(f) Plant information must be available or deliverable to the TSC. Any equipmentused to facilitate this availability must be identified and maintained operable

5.2.9 Offsite Response Organizations EITER and Public Notification Systems

[1] Offsite Response Organization EITER, Public Notification Systems and compensatorymeasures are included in the Communications section of Attachment 9.1, EquipmentImportant To Emergency Response and Compensatory Measures

[2] The Offsite Response Organizations EITER and Public Notification Systems EITERlist and compensatory measures were developed based on the following guidance:

(a) Voice communications equipment such as phones and radios must be provided

(b) Initial notification equipment must be provided

(c) Radiological monitoring equipment

F ¶

SP NPS NON-QUALITY...... EMERGENCY RELATED EP-AD-270 Revision 1SEntergy PADMNISRTIE PROCEDURE


Equipment Important To Emergency Response (EITER)5.2.9 Discovery of Degraded or Non Functional EITER

[1] Refer to Attachment 9.1, Equipment Important to Emergency Response andCompensatory Measures, to identify EITER.

[2] Implement compensatory measures for Category A(1 ) and A(2) EITER as described inAttachment 9.1.

[3] EITER identified as Category B may be out of service without designatingcompensatory measures, provided the redundant equipment is available. Implementcompensatory measures for Category B EITER, as required.\

[4] Document the degraded or non-functional EITER in the Corrective Action Program.

[5] Assess reportability of the out of service condition in accordance with 10 CFR50.72(b)(3)(xiii) and the guidance in NUREG 1022, Rev 3, Supplement 1 and NE!13-01, Rev 0, July 2014.

[6] Contact the on-call Offsite EP Community Representative designated on the ERODuty Roster to assist in informing the Emergency Response Organization of the statusof out of service EITER and any associated compensatory measures.

[7] Notify PS&O to add the out of service condition on the Daily Plant Status Report.(Required only for category A(1 ) or A(2) equipment or category B equipment for whichthe redundant equipment is not available).

[8] Ensure that work documents receive the appropriate priority.

[9] Emergency Planning will track out of service EITER equipment on an EquipmentImportant to Emergency Response Tracking Sheet. Refer to Attachment 9.4 for anexam pie.

[10] Restore the out of service equipment within the time allowed in the Comments sectionof the equipment matrix in Attachment 9.1, Equipment Important to EmergencyResponse and Compensatory Measures.

[11] Refer to Attachment 9.2, Unplanned Loss of EP Equipment, flow chart for guidance.

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-~ Energy ADMINISTRATIVE PRCDEPROCEDURES REFERENCE USE Page 19 of 59

Equipment Important To Emergency Response (EITER)5.2.10 Removing EITER from Service for Planned Maintenance

[1] Refer to Attachment 9.1, Equipment Important to Emergency Response andCompensatory Measures, to identify EITER.

[2] If category A(1 ) or A(2) equipment is to be taken out of service, include provisions inthe work document for implementing the compensatory measures in the equipmentmatrix in Attachment 9.1 and notifying the Emergency Response Organization asnecessary.

(a) Category A(1 ) and A(2) EITER may be removed from service for maintenanceor testing without compensatory measures in place provided:

(1) Personnel removing the equipment from service remain in the immediatearea

S AND

(2) The EITER can be restored to service promptly.

(b) EITER identified as Category "B" may be out of service without designatingcompensatory measures, provided the redundant equipment is available.

(c) If the conditions of Steps 5.2.10[2](a) & (b) cannot be met, then the appropriatecompensatory measures as described in Attachment 9.1 need to beimplemented prior to removing the equipment from service for maintenance ortesting.

[3] Notify PS&O to add the out of service condition on the Daily Plant Status Report.(Required only for category A(1 ) or A(2) equipment or category B equipment for whichthe redundant equipment is not available).

[4] Prior to the start of work, contact the on-call Offsite EP Community Representativedesignated on the ERO Duty Roster to assist in informing the Emergency ResponseOrganization of the status of out of service EITER and any associated compensatorymeasures.

[5] Emergency Planning will track out of service EITER equipment on an EquipmentImportant to Emergency Response Tracking Sheet. Refer to Attachment 9.4 for anexample.

[6] If redundancy is lost for category B equipment and/or equipment cannot be restoredwithin the time required, then assess the reportability of the condition in accordancewith the guidance in NUREG 1022 and NEI 13-01.

[7] Refer to Attachment 9.3, Planned Out of Service Condition of EP Equipment, flowchart for guidance.

6.0 INTERFACES

[1 ] 2.1.6, "Reactor Scram"

[2] 5.2.1, "Earthquake"

[3] 5.3.8, "Loss of Instrument Air"

[4] 5.3.37, "Loss of Spent Fuel Cooling Event"

[5] 5.7.3.3, "Sampling, Transport, and Analyses of Effluent lodines and Particulates fromthe Main Stack Under Emergency Conditions"

[6] 5.7.3.4, "Emergency Reactor Building Vent Sample Collection"

[7] 5.7.3.5, "Sampling, Transport, and Analyses of Effluent Iodines and Particulates fromthe Turbine Building under Emergency Conditions"

[8] 5.7.4.1.12, "Post Accident Sampling System 14mL Gas Sample from Drywel/"

[9] 5.7.4.1.13, "Post Accident Sampling System l4mL Gas Sample from Torus"

[10] 6.3-064, "Routine Radiological Surveillance Program"

[11] 7.3.25, "Particulate and Iodine Monitoring at the Main Stack and the Reactor BuildingVent"

[12] 7.3.48, 'Airborne Effluent Monitoring of the Turbine Deck and Reactor Feed PumpBay"

[13] 7.9.12, "Liquid Effluent Releases with RETDA S"

[14] 8. B.14, "Fire Protection Technical Requirements"

[15] EN-EP-305, "Emergency Planning IOCFR5O.54(q) Review Program"

[16] EN-LI-I100, "Process Applicability Determination Process"

[17] EN-LI-I102, "Corrective Action Process"

[18] EN-LI-I108, "Event Notification and Reporting"

[19] EN-WM-1 00, "Work Request (WR) Generation, Screening and Classification"

[20] EN-WM-1 01, "Online Work Management Process"

[21] EN-WM-109, "Scheduling"

[22] EP-IP-I100, "Emergency Classification and Notification"

[23] EP-IP-21 0, "Control Room Augmentation"

PNPS NON-QUALITYX EMERGENCY RELATED EP-AD-270 Revision 1

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Equipment Important To Emergency Response (EITER)J

[24] EP-IP-261, "Technical Support Center.(TSC) Operations"

[25] EP-IP-262, "Operations Support Center (OSC) Operations"

[26] EP-PI-1 80, "Relocation of the Media Center"

7.0 RECORDS

None

8.0 REQUIREMENTS AND COMMITMENTS

Reference Commitment Affected StandardDocument Sections/Steps and Procedure

Former Procedure

9.0 ATTACHMENTS

ATTACHMENT 9.1 - EQUIPMENT IMPORTANT TO EMERGENCY RESPONSE ANDCOMPENSATORY MEASURES

ATTACHMENT 9.2 - UNPLANNED LOSS OF EQUIPMENT IMPORTANT TO EMERGENCYRESPONSE

ATTACHMENT 9.3 - PLANNED OUT OF SERVICE CONDITION OF EQUIPMENTIMPORTANT TO, EMERGENCY RESPONSE

ATTACHMENT 9.4 - EQUIPMENT IMPORTANT TO EMERGENCY RESPONSE TRACKINGSHEET (EXAMPLE)

ATTACHMENT 9.5 - DOCUMENT CROSS-REFERENCE

• ,,PNPS NON-QUALITY• E~e~•PAEMERGENCY PRC~RRELATED EP-AD-270 Revision 1

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ATTACHMENT 9.1 EQUIPMENT IMPORTANT TO EMERGENCY RESPONSE AND COMPENSATORY MEASURES

PLANT EQUIPMENT

Asset Asset Description Cat Compensatory Measures IC/EAL Comments

AG1.1

A11 Main Stack High Range

RI-i1001-608 Main Stack High Range Effluent A()Chemistry samples taken at Main Stack AG1.2 Effluent Monitor reading isPanel C170 Monitor per) PNS7A.5oSNP1..33G.1 indication of an offsite

H61 release.

HA6.1

RM-1705-1 8A AAI.1RM-1705-1 8B AGI.2 Main Stack Process

Panel C910 Main Stack Effluent Process B Chemistry samples taken at Main Stack AS1.2 Radiation Monitor readingsRadiation Monitors per PNPS 7.3.25 or PNPS 5.7.3.3. H61 are indication of offsite

RR-1705-19 HG6.1 release.Panel C902 HA6.1

AGI1.1AS 1.1AAI.1

FR-9368 Oeaintomnalcacltfow AUI.1StchueMain Stack Flow A(1)pe eainpP .. 4t°mnal aclt lw AG1.2

Stachous pe PNP 8.C34.AS 1.2

HG6.1HS6.1HA6.1

0 0

0PNPS NON-QUALITY

SEMERGENCY RELATED EP-AD-270 Revision 1' En/eigy/ PLAN PROCEDURE




PLANT EQUIPMENT


RM-1 705-32A AA1.1RM-1 705-32B AUI.1Panel C910 Reactor Building Vent Exhaust B Chemistry samples taken at vent AG1 .2 Provides indication of a

(BEMoiossample location per PNPS 7.3.25 or AS1.2 potential releaseRRBVE)7onitorsPNPS 5.7.3.4. HG6.1

Panel C902 HS6.1HA6. 1

AAI.1AUI1.1

FI-8116SA AG1.2FI-81 16B Reactor Building Vent Exhaust B Operations to manually calculate flow AS1.2Panel C7 Flow per PNPS 8.C.34. HG6.1

HS6.1HA6.1

AG 1.2AS 1.2

RT-1001-610 Turbine Building Vent High A(2) No compensatory measures required. HG6.1Panel 910 Range Radiation Monitor HS6.1

HA6.1

RM-1705-30 Provides indication of liquidPanel C910 RdstDicagEfletCeitysmlstkntsmpeAA1.2 radiological release.

RR-wate9Dic(Red EPen)nt A(1) Ceitys plsakntsmpeAU1.2 Samples analyzed andR-72(ePe) Radiation Monitor location per PNPS 7.9.12. release rate independently

Pane C20planned.

•-•PNPS NON-QUALITY• ,•EMERGENCY 'RELATED EP-AD-270 Revision 1

~Ei'degy IMPLEMENTING PRCURPROCEDURES REFERENCE USE Page 24 of 59



PLANT EQUIPMENT


Area Radiation Monitor: RP survey per PNPS 8.3-064 or Main A31 Poie niainoRIS-1815-2A Main Control Room A(1) Control Room Intake (RM-1705-16) can A22 eeae aito eesPanel C91 1 provide additional information.

Area Radiation Monitors:RIS-1815-3A Condensate Pump StairwayRIS-1 8156-8A Feedwater Heaters StairwayRIS-1815-8B Turbine Front StandardRIS-1815-3B Radwaste CorridorRIS-1815-8C Radwaste Sump Area Poie niainoRIS-1815-8D Chem Waste Rcvr Tank Inlet A(1) RP survey per PNPS 6.3-064. AU2.2 Poie niainoRIS-1815-2B Outside TIP RoomRIS-1815-2C Radwaste Truck Lock AreaRIS-1815-2D Rx Building SE Access AreaRIS- 1815-3C New Fuel Storage AreaPanel C91 1

Area Radiation Monitors:RIS-1815-3D New Fuel Vault AA2.1 Provides indication of fuelRIS-1815-3E Refuel Floor Shield Plug Area A(1) RP survey per PNPS 6.3-064. AU2.1 damage in the Spent FuelRIS-1815-3F Spent Fuel Pool Area AU2.2 Pool AreaPanel C911

AA2.1RR-1815-6 -AA3.1 Provides indication ofPanel C902 Area Radiation Recorder B RP survey per PNPS 6,3-064. AU2.1 elevated radiation levels.

AU2.2RR-105-1 RfuelFlor Vnt RdiaionProvides indication of fuel

PanelC0-21 RefulFoodr VetRdainB RP survey per PNPS 6.3-064. AA2.1 damage in the Spent FuelPane C90 RecrderPool Area

0 0PNPS NON-QUALITY

......... •EMERGENCY RELATED EP-AD-270 Revision 1En•: I/' e~ro-. PLAN PROCEDURE




PLANT EQUIPMENT


RIS-1 705-SARIS-1 705-8B Provides indication of fuel

RIS-1705-8C Refuel Floor Vent Exhaust A21 dmg nteSetFeRIS-1705-8C Process Radiation Monitors B RP survey per PNPS 6.3-064. A21 dmg nteSetFeRIS-1705-8D Pool AreaPanel C910

AG1.2Turbine Building Turbine Building Gaseous A()Chemistry samples per PNPS 7.3.48 AHG6.2

PaElMCS 0 Effluent Monitoring System A()and PNPS 5.7.3.5.

HA6.1

AG1.2Reacor eedPum saplesperPNP 7..48 AS1.2

GeMSo Fe Pm Reactor Feed Pump Gaseous A()Chemistry smlsprP S7.48 HG6.1PaElMS00 Effluent Monitoring System A()and PNPS 5.7.3.5.H6.

HA6.1I

ECU-370 Seismic MonitorPanel C911I Seismic Workstation (SWS)

A(1) Operations to refer to PNPS 5.2.1, HAl.1 Provides indication of aAnnunciator: "Earthquake". HUI.1 seismic event.

(C903R-B1) Seismic Recorder Operating ________________

LI-3831ALI-3831 B Sea Water Bay Water Level B Operations to evaluate Sea Water Bay HA1 .6Panel Cl Water Level per PNPS 5.3.8. HU1 .5

o,...PNPS NON-QUALITY• EMERGENCY RELATED EP-AD-270 Revision 1

~En~eiy. lIMPLEMENTING- POCDRPROCEDURES REFERENCE USE page 26of 5



PLANT EQUIPMENT


Fire DetectionEquipment for SafeShutdown Areas:1. Reactor Building2. Control Room3. Cable Spreading

Room4. 4160 Switchgear

Rooms5. Diesel Generator Oeain oesr htcmestr

Rooms Oprtost nueta opnaoy HA2.1 Provides indication of fire in6. Salt Service Water Fire Detection Equipment B measures are established per PNPS HU2.1 the plant

Bays 8..B.14.7. Rx Closed Cooling

Water SystemAuxiliary Bays

8. Standby GasTreatment Area, 51'Turbine Bldg9. CondensateStorage Tank

0

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ATTACHMENT 9.1 EQUIPMENT .IMPORTANT TO EMERGENCY RESPONSE AND COMPENSATORY MEASURES

PLANT EQUIPMENT


Bus A5 SG1.1Bus 6 Eergncy use B o cmpenatoy masurs rquied. SS 1.1

Panel C3SU.

EDG A (X-107A) SGI.1

EDG B (X-1 07B) Onsite AC Power Sources: B ocmestr esrsrqie. SAI.1SBO Diesel Power to Buses A5 and A6 BCocmestr eaue eurd A1.1

CU1.1

Startup Transformer(SUT) (X4)

Shutdown Transformer SGI1.1SS1.1(SDT) Offsite AC Sources: SAI .1

UntAxlayPower to Buses A5 and A6 B No compensatory measures required. SUI.1

Transformer (UAT) CU 1.1

Main Transformer(Backscuttle) _______________

Bus D16 SS7.1Bus D17 Essential 125 VDC Buses A(1) No compensatory measures required. CU6.1

PNPS NON-QUALITY•.EMERGENCY RELATED EP-AD-270 Revision 1

PNPS NON-QUALITYSEMERGENCY RELATED EP-AD-270 Revision 1

• •Er,/er#Olv, PLAN PROCEDURE0' IMPLEMENTING




PLANT EQUIPMENT


RPV Level: AA2.2

AU2.1LI-263-100GA C905 Narrow Range SG2.1LI-263-10GOB C905 Narrow Range FGI.1LI-263-1O1 C904 Shutdown Range FSI.1LI-1001-650A C170 Fuel Zone Range FAI.1LI-1001-650B C171 Fuel Zone Range CG2.1LI-263-106A C903 Fuel Zone Range CS2.1 Provides indication of aLI-263-106B 0903 Fuel Zone Range B No compensatory measures required. CA2.1 challenge to core coolingLIS-263-73A C2233A 2/3 Core Coverage CU2.1LIS-263-73B C2233B 2/3 Core Coverage CG2.2LR-640-28 C905 Fuel Zone Range CS2.2LR-1 001 -604A 0170 LI-i1001-650A (Green) CS2.3

LI-263-100GA (Blue) CU2.2LR-1001-604B 0171 LI-1001-650B (Green) CU2.3

LI-263-100OB (Blue) CU3.2

RPV Pressure:S21 Provides indication for Heat

PR/F-640-28 C905 Narro Range FG1.1 Capacity Temperature Limit.PRIF-640-25A C905 Wide Range B No compensatory measures required. FA1.1 Also provides indication ofPI-640-25A C905 Wide RangeFU.

PI-263-49A 0170 Wide Range CA3.1 CotimnBarelse.PI-263-49B C171 WideRange _____________________________________

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PLANT EQUIPMENT


RCS Temperature:

TR-263-1 05 (red pen) Reactor Vessel shell adjacentPanel C3904 to Reactor Vessel FlangeTR-263-1 04 Pt. 2 Reactor Vessel shell adjacent C3A3.1IPanel C921 to Reactor Vessel FlangeTR-263-104 Pt. 9 Reactor Vessel bottom head B No compensatory measures required. C3U3.1Panel C3921 temperature C3U3.2TR-260-151A Reactor Recirc Pump Loop APanel C904TR-260-151B Reactor Recirc Pump Loop BPanel C3904

SU6.1RC3S Leakage: FGl.1

FSI.1P305A / P305B Drywell Floor Sump Pumps FA1 .1 Indication of potential RCSP3O1A / P301 B Drywell Equip Sump Pumps B No compensatory measures available. CG2.2 Leakage

C3S2.3C3A2.1IC3U2.3 ___________

TI-5021-2A C903TI-5021-1A C903TI-5022-2B C3903 SG2.1 Provides indication for HeatTI-5022-1B C903 FGI .1 Capacity Temperature Limit.RU52-1(P5) Torus Water Temperature B No compensatory measures required. FS1. 1 Also indicates challenge to

Panl C70FUI..1 containment integrity.TRU-5022-O1B (Pt 5)Panel C3171_____________ ___________________

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Equipment Important To Emergency Response (EJTER)


PLANT EQUIPMENT


PID-5067BPae 94Torus Pressure A(2) No compensatory measures required. N/A

P-I-1001-69A

P1i016BTorus Bottom Pressure B No compensatory measures required. FUI.1PR-I100 1-69Panel C903 _________________LR-5049 C7 CG2.2LR-5038 C903 CS2.3 For determining RPVLl-1001-604A C170 Torus Water Level B No compensatory measures required. CA. Leakage and challenges to

LI-1001-604B C171 CU2.3 cr olnPrimary Containment Pressure:

PI-9046B C903TRU-9044 (blue) C903TRU-9045 (blue) C903FG.PI-1001-601A C170 Drywell Low FGI.1PI-i100i-601B C171 Drywell LowFS.

PI-i1001-600A C170 Drywell High B No compensatory measures required. FAI,1PI-1001-600B Ci7i Drywell High CG21.1PID-5067A C904 CG2.2PID-5067B C904CG2PI-1001-69A C903PI-1001-69B C903PR-i1001-69 C903 _____________

FGI.1TRU-9044FSI.1

TRU-90454ou/rwllPesr n B No Compensatory measures required. FUI.1

Panel C903 TemperatureFU.CG2.1

____ ____ ____ __ _ ____ ___ ____ ____ __ _ ___ ___ ____ ____ ____ ____ ___ CG2.2 _ _ _ _ _ _ _ _ _ _ _

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PLANT EQUIPMENT


Primary Containment Radiation:

RIT-1"001-606A C170 Drywell High Range Area

Radiaion GI.1 For determining challengesRIT-1001-606B C171 Drywell High Range Area B RsuvyprP S6.-6.FSI.1 t otimnfe n

Radiation RsueyprPP6.-4.FA1.1 t otimnfe n

RIT-1001-607A C170 Torus High Range Area FUI. RS1arirRadiation

RIT-1001-607B 0171 Torus High Range AreaRadiation

Plant AnnunciatorSystem on Panels:C903C904 SS4.1C905 Safety System Annunciators A(1) No Compensatory measures available. SA4.1 Alarm capabilitiesC1 SU4.10301700171

H2/O2 SystemFG.Panels 0172, 0173, FGI.10174 & 0175 Primary Containment H2 and Chemistry PASS sampling per PNPS FSI.1 Primary Containment

02 concentration B 5.7.4.1.12 and PN PS 5.7.4.1.13. C21 deflagration concentrationAR-1001-612A 0170 CG2.1AR-1001-612B 0171CG.

SPNPS NON-QUALITY

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PLANT EQUIPMENT


AI-5065-51 84A C1 74 FGI.1

Al 5065-5184B C175 Drywell or Torus Percent H2 or B Chemistry PASS sampling per PNPS FUI.1 Primary ContainmentAI-5065-5085A C174 02 Indication B 5.7.4.1.12 and PNPS 5.7.4.1.13. delartUncocetatoAI-5065-5085B C1 75 CG2.1 dfarto ocnrto

CG2.2Steam Leak Detection &Secondary Containment Temp:

TE-1291-60A RWCU Filter AreaTE-1291-60B RWCU Backwash Tank AreaTE-1291-60C RWCU Holding Pump AreaTE-1291-60D RWCU Pump A RoomTE-1291-60E RWCU Pump B RoomTE-1291-60F RWCU Heat Exchanger RmFG.TE-1360-23A RCIC Piping Area-Torus Com p FGS1.1TE-1360-23B RCIC Turbine Area - Stairwell FAI. 1TE-2374A HPCI Piping Area-Torus Comp A1 Nocmestrmaueseqid. FAI.1TE-2374B HPCI Turbine Area A()NHApnstr2esrs eurd U.1TE-1291-60H RWCU Piping Area HA2.1TE-1360-23C RCIC TIP RoomHU.TE-2374C HPCI Piping Area - 23' HU2.2TE-261-22A Main Steam TunnelTE-1001-92A RHR B&D Pp Area- StairwellTE-1001-92B RHR A&C Pp Area -6'TE-1001-92F RHR & RWCU Valve RoomTE-1001-92G RHR A&C Pp Area - PipewellTE-1001-92H RHR Fuel Pool Heat Exc RmPanel C921

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Equipment Important To Emergency Response (ELTER)


PLANT EQUIPMENT


Secondary ContainmentTemperature:

TI-H-34 RHR A Quad (SE) H&V CoolerTI-H-35 RHR B Quad (NW) H&V CoolerTI-H-36 RHR A Quad (SE) H&V CoolerFG.TI-H-37 RHR B Quad (NW) H&V CoolerFG.

TI-H-38 HPCI Comp H&V Cooler B No compensatory measures required. FAI .1TI-H-39 HPCl Comp H&V Cooler FAI.1TI-H-40 RClC Quad (SW) H&V CoolerFU.

TI-H-41 RClC Quad (SW) H&V CoolerT-H-42 CRD Quad (NE) H&V CoolerTI-H-43 CRD Quad (NE) H&V CoolerPanels C61AI/ C61B

LI-5008 Primary Containment Water A(2) No compensatory measures available. N/APanel C903 Level Indicator

RM-1705-3A Air Ejector Off-Gas Radiation B No compensatory measures required. SU5.1 Frincaonffulcd

Panel C910 Monitors degradation.

SCBA Compressor

Plymuth ire ir Cmpresorsfor illig B RP to have tanks filled at alternateN/DPlrtmenthFr SCBA tanks location.

Compressor

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COMMUNICATIONS


Offsite notification program that BECONS, commercial telephone,Deiae oiiain utilizes the internet to send B satellite phone (cell phone available in N/A

Network (DNN) offsite notifications Main Control Room)Notiicaion ystm acup adi sysem or ofsie B Commercial telephone, satellite phone

Community Offsite Bacu raiytmfrofie(cell phone available in Main Control N/A(BCNoiiainSyse notificationsRom

TheEEergecy ReponsOh mrganzainNtfcatiesonse lent Eebig oieAtvto

Emergency ResponseiSytewill beoativiatedion th1. PNPerbackptelEephdeone ActalltresRsoeoosrienihn2Omrganizati son s eenSyte oflb a dcliared emrgnc Bh usin commercalku telephones N/Alhours.NOtgaifiation (ERO) ento mobiiz th dela.e eaegch ERtrteviewthn2Everbidgetio SysN tem mmobewillz bhe cOntEact ih Referin tommprociaedueEphonsPNA hurs

emergency information and Rfrt rcdr PI-0instructions for responding.Computer with softwareprogram that receives ERON PNsin bckupria telephonecltres Restore to service within 24

Pager Relay Computer notifications and forwards them B ungcmeiatlphesN/A hours.to pager vendor for group pageRertopcdueE-P10to the ERO Refer______to____procedure________EP-_____P-100___The ERO pagers work PNPS backup telephone call treesindependent from the uigcmeca eehnsRsoet evc ihn2

ERO Pagers Emergency Response B uigcmeiatlphnsN/A Rsoet evc ihn2Organization Notification ReertopoedrrEsP.0System. Ree-opoedr PI-0

Emergency NRC Federal Telephone Commercial telephone, cell phone, SU4.2

Notification satllietpon(ENS) Telephones Systm_(FS)_tlephnestellteponeU4.

Heathor (Phyic NRC Federal Telephone B Commercial telephone, cell phone,Neetworks (P)System (FTS) telephone satellite phone N/A

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COMMUNICATIONS


NRC Federal TelephoneReactor Safety System (FTS) telephones usedComriltepncllhnNACounterpart Link by the NRC to conduct internal B CsatelliatelpoepoecelhneN/(RSCL) Telephones discussions on plant andsaeltpon

equipment conditions __________________NRC Federal Telephone

Protective Measures System (FTS) telephones usedConepr ik by the NRC to conduct internal B Commercial telephone, cell phone, N/A

PCoutrpr Lik discussions on radiological satellite phone(PMCL)releases and meteorological

conditions.NRC Federal TelephoneSystem (FTS) telephone used

Management by the NRC to conduct internaldiscussions between theCounterpart Link Eeuiem brsadte B Commercial telephone, satellite phone N/A

(MCL)NRC Director of SiteOperations or top level licenseemanagement at the site.NRC Federal Telephone

- System (FTS) telephone usedLocal Area Network by the base and site teams for

access to any of the products or B Commercial telephone, satellite phone N/A(LAN) Telephone services provided on the NRC

Emergency Operations__________________Center's local area network. ______________________

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COMMUNICATIONS

Asset Asset Description Cat Compensatory Measures IClEAL Comments

MEMA Headquarters is the PrimaryPrompt Alert and Control Points are used to CnrlPit ahTw a h

(PNS)fcontrol Points activate the sirens. B capability to activate the sirens in their N/A(PAN) Cntro Pontstown as a backup.

Promp Aler andRoute alerting is performed byPrmtAetad Alert and Notification System B applicable town(s) for inoperable sirens NA See Precautions and

Notification System Sirens without adequate overlap coverage of NA Limitations(PANS) Sirens operable sirens.

PrmtAetad Alert and Notification System Have Commonwealth of MA notify thePrmtAetad repeaters receive and EPZ towns that they will need toN/NtfctoSytm retransmit PANS radio B activate the sirens in their towns, ifN/

(PANS) Repeaters communications activation is required. _____________

Phone line connection from theLine Pine Hills Tower Facility to

PANS MEMA Lie MEMA HQ for transmission of B PANS Radio system. N/A

PANS information.Cell phone, satellite phone, Gaitronics,radios

Provides onsite and offsiteCommercial comuncatonTelephone System Plant Telephone System B Verify at least one plant telephone CU4.12 omniain

system is available. Voice over Internet C41 capabilities.Protocol (VolP) phones may also beused.

Plant Wireless Plant Wireless Telephone B Commercial telephone, satellite phone, SU4.2Telephone System System Gaitronics, radios CU4.1VOIP Phones VOIP Phones B Commercial telephone, cell phone, N/A

__________________ ________________________ _____ satellite phone, Gaitronics, radios______ _____________

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COMMUNICATIONS


Located in CAS, SAS, Main B Commercial telephone, satellite phone, N/ACellular Telephones Control Room, TSC and OSC B Gaitronics, radio

Saelit Pons atlltePhne B Commercial telephone, cell phone, SU4.2radio CU4.1

The State Police Auto RingDown circuit is part of the Commercial telephone (cell phones and

State Police Auto Ring commercial telephone system State Police radio available in MainDown Telephone used to connect the Main B Control Room, CAS and SAS; BECONS N/ACircuit Control Room, CAS, SAS, PAP and satellite phones available in Main

and/or EOF with State Police Control Room and EOF)Middleboro barracks.

The Plymouth Police Auto Ring Commercial telephone (Plymouth PoliceDown circuit is part of the rdoaalbei A n A;cl

Plymouth Police Auto commercial telephone system radone available in CASaindAS cetrllRoRingDownTelehone usedto cnnec theMainCAS and SAS; BECONS and satelliteN/

Circuit Control Room, CAS, SAS, PAPphnsailbenMinCtrlRoand/or EOF with the Plymouth ahnds E vialeOF)i otrlRoPolice. adEF

The Plymouth Fire Auto RingDown circuit is part of the Commercial telephone (Plymouth Fire

Plymouth Fire Auto commercial telephone system radio available in CAS and SAS; cellRing Down Telephone used to connect the Main B phones available in Main Control Room, N/ACircuit Control Room, CAS, SAS CAS and SAS; BECONS and satellite

and/or PAP with the Plymouth phone available in Main Control Room)Fire Department.____________________________________

S 0 0

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COMMUNICATIONS


Commercial telephone, cell phone,radio, VOiP phone

1. Supervisors should maintain a log ofwhere workers are working in the plant.2. VOIP cell phones should be used tocontact workers in the event of an Provides onsiteemergency once Everbridge has made communications

Plant Gaitronics the initial notification. SU4.2 capabilities.System Plant Intercom system A(2) 3. Control Room should call CAS/SAS CU4.1

in the event of an emergency so that Maintain such that < 10% ofSecurity radios can be used as a means speakers are unavailable forof notification of an emergency. > 90 days.4. Use of public address in ESB shouldbe used in the event of an emergency.5. Site accountability should beperformed immediately at an ALERTlevel or higher.

Pln lrsEmergency Alert and A()Same as Plant Gaitronics System SU4.2 Plant alarms are part of thePln lrsEmergency Evacuation Alarms A() above. CU4.1 Plant Gaitronics System.

Emergency Conferencing This EmergencySystem (ECS) line that provides Commercial telephone, cell phone, Conferencing System bridge

Mitigation Line conferencing capability for B satellite phone, VOIP phone N/A is integrated into the PNPSOperations and Engineeringpersonnel Telephone System.

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ATTACHMENT 9.1 EQUIPMENT IMPORTANT To EMERGENCY RESPONSE AND COMPENSATORY MEASURES

COMMUNICATIONS


Emergency ConferencingSystem (ECS) line that provides This Emergency

Plant Data Phone conferencing capability for B Commercial telephone, cell phone, N/A Conferencing System bridge(PDP) transmitting Station data for satellite phone, VOIP phone is integrated into the PNPS

status boards located in each of Telephone System.the emergency facilities

Emergency Conferencing This EmergencySystem (ECS) line that provides Commercial telephone, cell phone, Conferencing System bridge

Rad Data Line conferencing capability to BN/A isntgaeitohePPtransmit radiological information satellite phone, VOIP phoneisntgaeitoheP Sbetween the facilities Telephone System.

Emergency ConferencingSystem (ECS) line that provides This Emergency

Emergency conferencing capability for B Commercial telephone, cell phone, N/A Conferencing System bridgeConference Line (ECL) management and technical satellite phone, VOIP phone is integrated into the PNPS

personnel located in each of the Telephone System.facilities__________ ____

Main Control Room Operations Radio, Security B Land lines, cell phones, Gaitronics, SU4.2 crommusnsicti/onfsitPilgrim Radio System Radio, OMT Radio VOIP phones CU4.1 capabilities.

S 0

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Equipment Important To Emergency Response (FITER)

ATTACHMENT 9.1 EQUIPMENT IMPORTANT To EMERGENCY RESPONSE AND COMPENSATORY MEASURESCOMMUNICATIONS


Backup communications linkbetween the Main Control

Pilgrim Alert / State Room, the TSC/OSC, the EOF, Portable radios, commercialPolice Radio the AEOF, the PAP, the CAS, B telephones, wireless phones, cellular N/A

the SAS, and the State Police phones, satellite phones

in Middleborough.

For ommnicaingwiththePortable radios, commercialSecurity Base Radio Fo omnctn ihteB telephones, wireless phones, cellular N/ASecurity forces phones, satellite phones, Gaitronics

Fire Brigade Base For communicating with the B Portable radios, commercialRadio Fire Brigade B telephones, wireless phones, cellular N/A

phones, satellite phones, Gaitronics

The Radio Amateur CivilEmergency Services radio

RACES Base Radio serves as a backup B Commercial telephones, satellite N/Acommunications link to the phonesCommonwealth and local offsite

__________________agencies.

MDPH Nuclear IncidentNIAT Base Radio Advisory Team radio for B Commercial telephones, satellite N/A

communicating between the phonesEOF and NIAT vehicles. _______________________________________

,-%P N PS NoN -Q UALITYSEMERGENCY RELATED EP-AD-270 Revision IEit'deri .y APLEMN TN PROCEDURE



ATTACHMENT 9.1 EQUIPMENT IMPORTANT To EMERGENCY RESPONSE AND COMPENSATORY MEASURES

COMMUNICATIONS


For monitoring ship-to-shipand/or ship-to-shore None for monitoring ship-to-ship and/or

Marine Base Radio communications during an B ship-to-shore communications. UseN/emergency. Radio also has alternate method for obtaining weather N/channel for receiving weather reports (Weather Channel, etc.)reports.

Alternate Shutdown Commercial telephones, wireless SU4.2ASC Portable Radios CmucainrdosB telephones, cellular phones, satellite CU4.1

Commniction raiosphones

AG1.2AG1.3

Offsite Monitoring Radio for OMT Coordinator to Commercial telephones, wireless ASi1.2Team (OMT) Base communicate with OMTs. B telephones, cellular phones, satellite AS1 .3Radio phones HG6.1

HS6.1HA6.1

OMT vehicle mounted radiosAG.for communicating with the AG1.2EOF or other OMTs. TheseAG3

Offsit Monioring radios also communicate with OTpral ai rvhcecl S.Team (OMT) Vehicle B OM otberdoo

i document title: ~o~i'~7)7~ copy num~vber: / …exercises". pages 4,5,10 * change "nuclear...

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