Text

Independent Spent Fuel Storage Installation - Emergency Plan Update
	ML18116A466
Person / Time
Site:	Fort Calhoun
Issue date:	04/18/2018
From:	; Omaha Public Power District
To:	; Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
	LIC-18-0018
	Download: ML18116A466 (109)
	v • d • e

Summary of Changes This summary of changes Is a synopsis of the NRC Requests for additional Information {RAI} and the FCS response to those requests. A detailed version of the response can be found in LIC-17-0047 that was submitted to the NRC on May 15, 2017. The NRC approved the Permanently Defueled Emergency Plan (PDEP) based on FCS response to the RAl's on December 12t11, 2017 by Amendment No. 295 effective April 7, 2018 and this amendment shall be Implemented within 90 days of the effective date. PORC approved the PDEP submitted to the NRC on December 16, 2016 and this summary only covers changes made since that time. NOTE: No changes were made to EP-FC-1001 Addendum 3 other that adding the procedure number to the top of each page. The content of EP-FC-1001 Addendum 3 remains the same as the initial submittal and was previously approved by PORC.

Editorial changes are also being made in addition to the RAl's. USAR was changed to DSAR in Section 4.2. Dosimeter chargers was removed from section 8.4.2, Dosimetry Kits, to align with dosimetry utilized on site.

RAI Summary:

(NRC) FCS-RAl One of the considerations for the granting of the exemptions is that FCS maintains the equipment, procedures and personnel for implementation ofSFP mitigation strategies in the unlikely event of a beyond design-basis-accident. Please provide a basis for this statement or revise the application to align.

FCS Response: FCS maintains procedures and strategies for the movement of any necessary portable equipment that will be relied upon for mitigating the loss of Spent Fuel Pool (SFP) water. These diverse strategies provide defense-in-depth and ample time to provide makeup water or spray to the SFP prior to the onset of zirconium cladding.

For clarity, the reference to "additional compensatory actions has been removed.

(NRC) FCS-RAl Please update the application accordlngly, to reflect current Federal guidance provided in EPA-400/R-17/001 (January 2017) (ADAMS Accession No. ML17044A073).

FCS Response: The proposed PDEP has been revised to address current Federal guidance provided in EPA-400/R-17/001.

(NRC) FCS-RAl Please provide any documentation of discussions with the State of Iowa and Harrison County indicating agreement that notification of an emergency declaration or change in classification is not required, as well as notification of whether a radiological release is taking place.

FCS Response: PDEP Sections 4, 5, and 16 were updated to add the State of Iowa to the notification.

Reviewer Note: References to notifying the counties was removed throughout the PDEP to align with FCS's response that the States of Nebraska and Iowa wlll provide notification to Washington County (Nebraska} and Harrison County (Iowa).

(NRC) FCS-RAl "Emergency action levels shall be reviewed with the State and local government authorities on an annual basis.>> Please provide additional clarification (see Exemption RAl-002).

FCS Response: FCS will continue to include the State of lowa,and Harrison County In the annual EAL review. Corresponding changes have been made to the proposed PDEP in section 16. Reviewer note:

The State of Iowa and Harrison County had were not included on the initial submittal.

(NRC) FCS-RAl-5 -There is no reference to any personnel specifically assigned to perform SFP inventory makeup strategies In the proposed PDEP. Please explain who performs SFP inventory makeup strategies.

FCS Response: Table 2.1, "On-Shift and Emergency Response Organization Staffing Requirements,"

includes an "*" next to the Non-Certified Operator (NCO), Shift Manager {SM), and the on-shift Radiation Protection Technician indicating these positions are on-shift personnel required to direct or perform site-specific mitigation strategies required for a catastrophic loss of SFP inventory.

(NRC) FCS-RAl Please clarify if Blair Hospital provides medical treatment of patients from FCS who have injuries complicated by radioactive contamination, and revise PDEP accordingly to reflect capability.

FCS Response: Sections 3.1.4 and 12.0 of the proposed PDEP have been revised to clarify that Blair Hospital does not provide medical treatment for radiologically contaminated Injuries and radiation exposure.

(NRC) FCS-RAl Please clarify why references to the letters of agreement, Identifying the specific organizations, are not included as an Appendix to the proposed PDEP, or revise accordingly.

FCS Response: Rather than include the listing in an appendix to the proposed PDEP, details of offslte response organization responsibilities are described in Section 3.0 of the proposed PDEP. Letters of Agreement between each organization and OPPD and maintained by the EP department.

(NRC)'FCS-RAl NUREG-0654 Criteria E.4, in Attachment 1 to NSIR/DPR-ISG-02, states: The licensee, in coordination with State and local organizations, shall establish the contents of the emergency messages to be sent from the nuclear facility. A detailed listing was not included.

FCS Response: Section 5 .1.2 of the proposed PDEP has been revised to include the information contained in Criteria E.4 of NUREG-0654.

(NRC) FCS-RAl:.9- No reference to NUREG-0654 Criterion K.3.a and b could be found in Section 11.0 FCS Response: Section 11.2 of the proposed PDEP has been revised to address the information contained in Criteria K.3.a and b of NUREG-0654

(NRC) FCS-RAl No reference to NUREG-0654 Criterion K.5.a and b could be found in Section 11.0 FCS Response: Section 11.3 of the proposed PDEP has been revised to address the Information contained in Criteria K.5.a and b of NUREG-0654 (NRC) FCS-RAl Please provide a description of the methods of communications to be used between FCS and Blair Hospital and the University of Nebraska Medical Center.

FCS Response: Section 12.0 ofthe proposed PDEP has been revised, and Section 6.3 (Communications with Medical Support Facilities) have been added to the proposed PDEP,~:

(NRC) FCS-RAl It appears that the PDEP does not address Blair Hospital as also being invited to .

participate In the annual exercise and/or scheduled drlll(s).

FCS Response: For.clarity, Section 14.2.1 of the proposed PDEP has been revised to state that the ambulance service is invited to participate in the annual exercise and/or scheduled drill.

(NRC) FCS-RAl "Training for individuals assigned to licensee first aid teams shall include courses equivalent to Red Cross First Aid, CPR, AED for Lay. Responders or equivalent.>> Please provide further information on who these personnel are on-shift (e.g., is duty performed as a collateral function), and what level and frequency of training they are given.

FCS Response: Table 2.1 of the proposed PDEP has been revised to Indicate that the first aid duties are assigned to on-shift personnel assigned other functions. Additionally, Section 15.0 of the proposed PDEP has been revised to include a section on first aid training (new Section 15.1.4). Reviewer Note: Updates in First Aid Training approved in Rev 3 of EP-FC-1001 were also incorporated into this procedure change and was previously approved by PORC.

(NRC) FCS-RAl Section 16.0, "Responsibility for the Planning Effort: Periodic Review and*

Distribution of Emergency Plans," of Enclosure 1 does not specifically address these criteria. Please explain why.

FCS Response: - Section 16 of the proposed PDEP has been revised to specifically refer to the Emergency Planning Manager as the position responsible for the development and updating of emergency plans and coordination of emergency planning activities with off-site response organizations.

References:

1. LIC-17-0047, FCS Response to Request for Additional Information (RAI)

2. NRC Docket No. 50-285 OPPD FCS Unit No. 1 EP Exemption (MLI 7263B198)

3. NRC Amendment No. 295 to License No. DRP-40 PDEP and EAL approval (MLI 7276B286)

4. Letter from OPPD (S. M: Marik) to USNRC (Document Control Desk), "License Amendment Request 16-07: Revise the Fort Calhoun Station Emergency Plan to the Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme" dated December 16, 2016 (LIC-16-0108) (ML16351A464)

(CAC MF8951)

5. OPPD Letter (S. Marik) to USNRC (Document Control Desk) - "Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR Part 50, Appendix E," dated December 16, 2016 {LIC-16-0109) (ML16356A578) (CAC MF9067)

6. Letter from OPPD {S. M. Marik) to USNRC (Document Control Desk), "License Amendment Request (LAR) 16-02: Revise the Fort Calhoun Station Emergency Plan to Address the Permanently Defueled Condition," dated September 2, 2016 (LIC-16-0076)

(ML16246A321) (CAC MF8326)

FCS EP-FC-1001 Revision 4 PERMANENTLY DEFUELED EMERGENCY PLAN OPPD NUCLEAR PERMANENTLY DEFUELED EMERGENCY PLAN FOR FORT CALHOUN STATION

FCS ...

EP-FC-1001 Revision 4 PERMANENTLY DEFUELED EMERGENCY PLAN OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION -

PERMANENTLY DEFUELED EMERGENCY PLAN TABLE OF CONTENTS

1.0 INTRODUCTION

........................................ ;...... :.* .......-.................. ;.*....... '. ........................ 1 1.1 Overview of the Permanently Defueled Emergency Plan ... : ........ /..... ,...... ; .... .', ............. 1 1.-1.1 Purpose ..................................................................................:.-...*........... *.- .......... .- ... 2 1.1.2 Scope ..................................... ;........................................ -............... -..................-.... 2 1.1.3 Objectives .......................................................................-...................................... 3 1.2 Site Description .................................. :........................... -.............. ;: .................... : .. .- ...... 4 2.0 ORGANIZATIONAL RESPONSIBILITY ......................................... ;.................. ;.:.......... 4 2.1 Facility On-Shift Organization ........................................................ ;............................. 5 2.1.1 Shift Manager/EmergencyDirector .......................................... ;.............. -, .........-.... 5 2.2 2.1.2 2.1.3 2.1.4 Non-Certified Operator .................................................. ~ ................ *................ ,...... 6 Radiation Protection Technician .................................... :.. :*.............. :............. :...... 6 Security Force ........................................ ,... .- ............ ;, ................ ,..... :*........ ;-.. .-:.:*i ...... 6 Emergency Response Organization ................................. t.* .. : .. : ... *... : .* : ..... ,.:/.. : .. *........... 6 2.2.1 Technical Coordinator .. ;..... :.... :.. '..)....... ::.: .......... ,.,.'. .. .- ... :.. :... :............ ~ ................... 6 2.2.2 Radiation Protection Coordinator.: .. ,........................ ,...................... .'.............. :...... 7 2.3 Offsite Organizations ........ :.......... :... :.. :.............. ,........................... ::...-; .... :.. :......... :...... 7 3.0 EMERGENCY RESPONSE SUPPOR_T AND RESOURCES:.;'. .............*........... :...... '. ... ~.10 3.1 Support Provided by Local Organizations ..................... :*............... :.:.................... :...... 10 3.1.1 Law Enforcement .............................................................'...... :-.... :, .............. :. .- ...... 10 3.1.2 Fire and Rescue Support ... ,.......................-...-.*... :............*................ :.: ............. ; ..... 10 3.1.3 Transportation of Injured and Contaminated Personnel .. -.~ ...... :., .. -................. :...... 1O 3.1.4 Treatment of Radioactively Contaminated and Injured PersonneL................. :..... 10 4.0 EMERGENCY CLASSIFICATION SYSTEM .. ;.........................;.. ;.. ;; ............................. 11 4.1 Classification of Emergencies ............................................... :: .. _.. -....... :........................ 11 I

4.1.1 Notification of Unusual Event. ............................ ,................................................. 11 4.1.2 Alert .......................*............................................................... ,......... :.-................... 12 4.2 Postulated Accidents .............................................. :.:-.. :................... ,.... *...................... 12 Page i

FCS EP-FC-1001 Revision 4 PERMANENTLY DEFUELED EMERGENCY PLAN 4.3 Emergency Classification System Review .. :... '. .............. :............................................ 12 5.0 NOTIFICATION METHODS AND PROCED.URES ........................................................ 12 5.1 Notification and Activation ...... ,.............. ,.. ,*... ,: ..................... :....................................... 12 5.1.1 Emergency Response Organization Activation .................................................... 13 5.1.2 State and Local Government No,tificatior, ............................................................. 13 5.1.3 . NRC Event Notification System ,................ ,........... ,... ,.................,.......... .a************* 14 6.0 EMERGENCY COMMUNICATIONS ..**................................ :................... :..................... 14 6.1 FCS Alarm System ..................................................................... :., ................. *............ 14 6.2 Communication Systems ...... ,........................... ,.................................... :.......... :......... 14.

6.2.1. FCS Paging Systems .............................. ,............................*........... : ....... , ............ 14 6.2.2 Telephone System ...................... ,............. ,........... ,................... ,.......................... 15 6.2.3 Federal Telecommunications System *........ : .............................. ,: .. :...... :.... :.......... 15 6.2.4 Portable Radios .......................................................:.,: .............................................. 15 6.3 Communications with Medical Support Facilities ..................... ;; .......... :....................... 16

6.3.1 Telephone System ................................................................;: ....... :*........ :.. :*......... 16 6.3.2 Portable Radios .................................. , .........;...................... : ........... :.................... 16 6.3.3 Non-OPPD Radio Systems ........................................... .'.......... :.... : ....................... 16

. 7.0 PUBLIC INFORMATION ................................... .-........... :.................................................. 16 8.0 EMERGENCY FACILITIES AND EQUIPMENT ....................................... ~ ............. .-...... 16

\ 8.1 Control Room ......................................... ,..**....................................... ,.............................. 17 8.2 . Laboratory Facilities .................... :.. ~, ...................................,, ................... ,**:**********:...... 17 8.~ Emergency Equipm.ent. .. ,................ ~.-.... ;, ................................... :........... ,... :... *............. ;.. 17 8.3.1 . Process Monitors .....................*.................. ,... *:*..........,... .-........... .-, ......... ,............... :: .. 17

. 8.3.2 Radiological Monitors ...............................................*,........*.*............................... 17

.8.3.3 Meteorological Monitoring ................. ,........*..... :.. ,........... , .................. :........ ~ ........... 18 8.3.4 Fire Detection and Suppressior;iEquipment ...................*...... ,...-;*............... :.. ,......... 18 8.4 Emergency Kits.::.........._. .......**..... *..................................... ,... i.'. ........... *: ...... : ............... '. ..... 18 8.4. t Radiological Emergency Kits ..... : .... :.. ::: ......... :.... .-....... :............ :.... :...... : .... ;........**.. 18 8.4.2 Dosimetry Kits ............................................................................. :.*....... :.........'...... 19 8.4.3 Medical. Kits ......................................... :......... ,.................... :................................ 19 9.0 ACCIDENT ASSESSMENT ..........................................................................................19

9.1 Radiological Assessment ........... ,........ ,..................................... .- .... :.. -.............................. 19 Page ii

FCS EP-FC-1001 Revision 4 PERMANENTLY DEFUELED EMERGENCY PLAN 9.1.1 Initial Assessment ....... ,............ '. .............................................'............................... 19 9.1.2 Initial Dose Assessment.. ..................................................................................... 19 9.2 Corrective Actions .................... :........................................................... .'. ..................... 20 9.3 Dose Assessment ......................................................-........................ :........................ 20

, 10.0 PROTECTIVE ACTIONS ....... :...................................... .'........................ -................ :....... 20 10.1 Accountability ........... :................. .-..... :................................... '........... '.'......... :: ............ 20 10.2 Site Egress Control Methods ...................................................................................21 11.0 RADIOLOGICAL EXPOSURE CONTROL. ..................................................... :... ,.:.;; .... 2_1 11.1 Radiological Control Areas .....................................................................................,.21 11.2 Exposure Control. ............. _.......................................................................................21 11.3 Contamination Control and Decontamination Capability .......................................... 22 12.0 MEDICAL AND HEALTH SUPPORT ............................................................................25

-13.0 RECOVERY ............................................ :........................... .-.........................................25 14.0 EXERCISES AND DRILLS ...........................................................................................26 14.1 14.2 14.2.1 14.2.2 Exercises .......................................... :......................................................................26 Drill$ ..................... ;....................... :...........*.......................... :........................ ;.; ....... :26 Medical Drills .......................................................................................................26 Accountability Drills ............................. : ............... :................................................ 27 14.2.3 Health Physics Drills ............................................................................................27 14.2.4 Augmentation Capability,Drills ... <.......... :.'..:.:.......................................................27 14.2.5 Fire and Security Drills ...... .'....... :.'..... :....... :...........'..... u.....................................'. ...27 14.2.6 Communication Tests ..........................................................................................27 14.3 Scenarios .......................................................................................... :..... .'.... ::: .. :..... i7 14.4 Critique/Evaluation .............................................................................................:.... 28 15.0 RADIOLOGICAL EMERGENCY RESPONSE TRAINING ............................................28 15.1 Emergency Response Training ...................................................................................28 15.1.1 Emergency Response Organization Training .......................................................29 15.1.2 General Employee Training .................................................................................29 15.1.3 Local Support Services Personnel Training .........................................................29 15.1.4 First Aid Training ..................................................................................................30 15.2 Documentation of Training ..........................................................................................30 Page iii

-FCS . ~. 'r EP-FC-1001 Revision 4 PERMANENTLY DEFUELED EMERGENCY PLAN

1s.o RESPONSIBILITY FOR THE PLANNING EFFORT: PERIODIC REVIEW AND DISTRIBUTION OF EMERGENCY PLANS ..................................................................30 16.1 Document Maintenance ..............................................................................................

. . 30 16.1.1 Review and Update of the PDEP and EPIPs ................. ~.... ,................. ,. ....... .- ..... 30 16.1.2

Emergency Planning Documents ......................................., .. *********::******:*************31 16.2 Inventory and Maintenance of Emergency Equipment ;................................... :........... 31 APPENDICES Page APPENDIXA. Emergency Plan Implementing Procedures 32 APPENDIX B Cross-Reference Between the PDEP, NUREG-0654/FEMA-REP-1, 10 CFR 50.47(b) Planning Standards, and Appendix E.IV Planning Requirements ~4 APPENDIXC Definitions and Acronyms... . 36

TABLE 2.1 TABLE 11.1 Requirements LIST OF TABLES On-Shift and Emergency Response Organization Staffing

Emergency Exposure Criteria 24 9

LIST OF FIGURES FIGURE 2.1 On-Shift and Emergency Response Organization 8 COMMITMENTS AR 67658

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FCS EP-FC-1001 Revision 4 PERMANENTLY DEFUELED EMERGENCY PLAN

1.0 INTRODUCTION

The Permanently Defueled Emergency Plan (PDEP) describes the plan for responding to emergencies that may arise at Fort Calhoun Station (FCS), while in a permanently shut down and defueled configuration. FCS has provided certification to the U.S. Nuclear Regulatory ,Commission (NRG) requir~d by 10 Code of Federal Regulation (CFR) 50.82(a)(1)(i) and (ii) that FCS has permanently ceased power operations and that all fuel. has been permanently removed from the reactor vessel. .In this configuration, all irradiated fuel is stored in the Independent Spent Fuel Storage lnstaHation (ISFSI) and in the Spent Fuel Pool (SFP). In this condition,* no reactor operations .can take place and the facility is prohibited from emplacement or retention of fuel in the reactor vessel. The PDEP adequately addresses the risks associated with FCS's current conditions .

. The analyses of the potential radiological impacts of postulated accidents in a permanently defueled condition indicates that any r~leases beyond the Site Boundary would be below the Environrnental Protection Agency (EPA) Prbtective Action Guide (PAG) exposure levels, as detailed in the EPA's "Protective Action Guides and Planning Guidance.for Radiological Incident~. EPA-400/R-17/001" dated January 2017 (EPA PAG Manual). No remaining postulated ac.cidents will.result in radiological releases requiring offsite protective actions*and the slow pmgressiori rate of beyond c;:!esign basis accident scenarios indicate sufficient time *is available to .initiate appropriate mitigating actions to

protect the health and safety of the public. Therefore, the PDEP adequately addresses the risk associated with FCS's.permanently defueled condition arid continues to provide adequate protection for plant personnel and the public. Exemptions from the applicable portions of 10 CFR 50.47(b), Appendix E to 10 CFR Part 50, and 10'CFR 50.47(c)(2) were previously approved by the NRC. * * * **

1.1 Overview of the Permanently Defueled Emergency Plan In the event of an emergency at FCS, actions are required to identify and assess the nature of the emergency and bring it under control in a manner that protects the health and safety of orisite person*nel.

This plan is aGtiv~ted pythe Shift Manager/Emergency Director upon identification

,of an emergency situation. ba.sed upon the Emergency Action Level (EAL) criteria.

The emergency mea.sures described in the subsequent.sections and associated Emergency Plan Implementing Proce.dures (EPIPs) are,in accordance with the classification and nature of the emergency at the direction of the Shift Manager/Emergency Director.

This plan describes the organization and responsibilities for implementing emergency measures. It describes interfaces with Federal, *state, and local organizations that may be notified in the event of an emergency and may provide assistance. Emergency fire, ambulance, and law enforcement services are provided by local public and private entitie's. Fixed medical services are provided Page 1

.FCS EP-.FC-1001 Revision 4 PERMANENTLY DE FUELED EMERGENCY PLAN .

by Blair Hospital to provide medical support for work related injuries, and University of Nebraska.Medical Center (UNMC) in Omaha, which maintains a regional Rac;liatjon Health Center that provides services for tt,e treatment <;>f radiologically contaminated injuries and radiation exposure e"'.aluat_ion. *

Because there are no postulated accidents that' would* result in offsite dose consequences that are large enough to require offsite emergency planning, emergencies are divided into two classifications: Notification of Unusual Event (NOUE)'and Alert. This classification scheme, developed in accordance with NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors",

Revision 6, November 2012, has been discussed and agreed upon with responsible offsite organizations and is compatible with their respective emergency plans. According to the EPA PAG Manu.al, the EPZ is based on the maximum

.. distance at which a PAG might be exc.eeded. If determined appropriate by governmentofficials, protective actions may be implemented to protect the public using the ex.isting all hazards emergency planning.

PCS is responsible for planning and implementing emergency measures within the

Site Boundary. This plan is provided to meet this responsibility.To carry out specific emergency measures discussed in this plan, detailed EPIPs are

established and maintained. A list of EPIPs is included in Appendix A.

In addition to the description _of a~tivi.ties and steps that can be implemented during

an emergency, this plan alsc;> provides a general description of steps taken to

- .. recover from an emergency situation. _It also describes the training, drills, planning, coordination, and program maintenance appropriate to mainta_in .an adequate level of emergency preparedness .

1.1.1 Purpose The purpose of the PDJ=P is to assure an adequate .level of preparedness to cope with the spectrum of postulated. emergencies, including the means to minimize radiation exposure to facility personnel. This plan integrates the necessary elements to provide effective emergency response considering cooperation and coordination of organizations

. *expected to respond to potential emergencies. All changes to the PDEP are reviewed in accordance with 10 CFR 50.54(q).

1.1.2 Scope The PDEP has been developed to respond to potential emergencies at FCS considering the permanently shut down and defueled condition.

Th~re are no postulated accidents that would r~sultin offsite dose

.c.onsequences that are large enough to require offsite emergency

. planning. Therefore,J~e overall scope of this plan delineates the actions

. n~cessary to safeguard onsite personnel and mini~ize damage to Page2

FCS EP-FC-1001 Revision 4 PERMANENTLY DEFUELED EMERGENCY PLAN property. If *determined appropriate by government officials, protective actions may be implemented to protect the public using an all hazards approach to emergency planning.

The concepts presented in this plan address the applicable regulations stipulated in 10 CFR 50'.4 7 "Emergency Plans" and* 1() CFR 50, I I Appendix E, "Emergency Planning and Preparedness for Production and Utilization Faciiities, as exempted. Exemptions to selected portions of 10 CFR 50.47(b); 10 CFR 50.47(c)(2); and 10 CFR 'so,' Appendix E were

. previously approved by the NRC. The plan is consistent with the remaining applicable guidelines established in NUREG-0654/FEMA-REP-1, Revision 1, "Criteriq for Preparation a,nd Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" (NUREG-0654). Appendix B contains a cross-reference to

. the applicable guidance in NUREG-0654.

Abbreviations C. . . and acronyms . used

. . in this

. Plan are..included in Appendix 1.1.3 Objectives The basic objectives of this plan are:

1) 2)

To establish a system for-identification arid classification 'of the emergency condition and initiation of response actions; ,*

To establish an organization for the-direction of ac~ivity within the facility to_ limit the consequences of the incident;

3) To establish an org~nization for control of assessment activities to determine the extent and significance of any un_controlled release of radioactive material;

4) .To identify faciHties,, equipment, and supplies available for

.,. emergency: use; .

5) *To establish an engineering support orga'nization to aid the facility personnel in limiting the consequences of and recovery from an event; .* ,, . . . . . ' ,.* . ,'

6) To generally d_escribe the elements of ~n emergency recovery program;

7) To specify a system for coordination with Federal, State, and local authorities and agencies offsite support organizations;

8) To develop a communications network between facility and offsite authorities to provide notification of emergency situations; and Page 3

FCS EP-FC-1001 Revision 4

. PERMANENTLY DEFUELED EMERGENCY PLAN 9). To develop a training and Emergency Plan drill and exercise program to. assure effectiveness of the plan is maintained.

1.2 Site Description FCS has ceased power operations and ha~ certified .that fuel has been permanently removed from the reactor vessel. The license for FCS, under 10 CFR 5.0, no lo~ger authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel, as specified in 10 CFR 50.82(a)(2).

. Fort Calhoun Station is located midway between Fort Calhoun and Blair, Nebraska, on the west bank of the Missouri River. The site consists of approximately 660.46 acres with an additional exclusion area of 582.18 acres on the northeast bank of the river directly opposite the plant buildings. The SFP is located in the Auxiliary Building, adjacent to the Containment Building. The Fort Calhoun Station includes the ISFSI, located within the Protected Area, approximately 200 meters north northwest of the Containment. Building. The distance from the reactor containment to the nearest site boundary is approximately 910 meters; and the distance to the nearest residence is beyond the site boundary.

2.0 ORGANIZATIONAL RESPONSIBILITY A predesignated group is assigned to va'ribus roles, during an event, to ensure capable emergency response and .mitigation at th'e FCS. These assignments are made to ensure that the adm,inistrative, manageria! and technical support needed for accident mitigation are met. A sufficient number of individuals are assigned to these positions to ensure around-the-clock and continued iong term support.

Responsibility for emergency response lies with the Shift Manager. The Shift Manager

assumes the Emergency Director position upon declaration of an emergency. The command and control position is responsible for ensuring the continuity of resources throughout an event.

The ERO augments the normal on-shift organization to respond to declared emergencies when activated. ERO personnel are trained and assigned to a position based on job qualifications or by being specifically trained to fill the positon. The ERO is activated at ttie Alert d~claration or at the discretion of the Shift Manager/Emergency Director. The designated on-shift and augmented ERO staff are capable of continuous (24-hour) operations for a protracted period .

.. The minimum staff required to conduct routine and immediate emergency mitigation is maintained at the station.

l

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FCS EP-FC-1001 Revision 4 PERMANENTLY DE FUELED EMERGENCY PLAN 2.1 Facility On-Shift Organization During normal conditions; the minimum staff on duty at .the facility during all shifts consists cif one*(1) Shift Manager, one (1) Non-Certified Operator (NCO), one (1)

. Radiation Protection Technician:Security personnel are maintained in accordance with the Security Plan. The minimum staff required to conduct routine and immediate emergency mitigation.is maintained on-shift 24. hours

~ .:

a day.

Figure 2.1 and Table 2.1 outline the minimum requirements.for the FCS on-shift and E*Ro staffing. ' ** * * * ** * * *

2.1.1 Shift Manager/Emergency Director

The Shift Manager position is staffed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day. This position is the senior management position at the facility during off-hours. This position i~ .responsible for monito'ring fadlity cond1~ioris and approving onsite activities. The position has the authority, management ability, and technical knowledge to classify and declare a facility emergency and assume the Emergency Director role.

The Emerg~ncy Director shall-assume command and control upon

. declaration of an event The. Emergency Director shall not delegate the

following responsibilities:

Classification of an eVent' ..

Emergency notification ap.proval (Task of *making the notifications

.. may be delegated)j .

Authorization of radiation exposures in excess of 10 CFR Part 20 limits.

Other Em.ergency Dir~ctor:,resppnsibilities:

Notification of the emergency classification to the NRC & States.

. Management of resources available to the facility

. Coordination of mitigative actions

coordination *of corrective actions

Coordination bf onsite protective actions

Decision tci Gall for ~ffsite assistance

Coordination of Sec_urity activities

Termination of the emergen_cy condition when appropriate

Performance of initial dose assessment

Maintenance of records of event activities Page 5

-.FCS EP-FC-1001

',. *.: '::,,:.' ' Revision 4 PERMANENTLY DEFUELED EMERGENCY PLAN

2.1.2 Non-Certified Operator

. The NCO, on shift 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day, performs system and component manipulations. The organizational relationship to the Shift

Manager/Emergency Director is. the same dµring normal situations and during situations where the PDEP has been implemented.

2.1.3 Radiation Protection*Technician The Radiation Protection Technician, on shift 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day, is available to monitor personnel exposure, determine radiological conditions, and provide survey results if necessary.

2.1.4 .Security *Force Security is adniinistered in accordance*with the Security Plan. The

.. Security Force will report to the Emergency Director when implementing the PDEP. '

2.2 Emergency Response Organization *

'The ERO shall be activated at the Alert classification: The ERO shall augment the on-shift staff within approximately 1'20 minutes of. an Alert declaration. However, the ERO may be activated, in part or in whole, at any time at the discretion of the Shift Manager/Emergency Director. : .. .

2.2.1 Tech_nical Coordinator The Technical Coordinator reports to the Emergency Director. The

responsibilities.of the Technical Coordinator when implementing the PDEP include:

evaluating technical data pertinent to facility conditions,

. * . *. augmenting the emergency staff as deemed necessary,

. designating engineering support, as necessary, to evaluate facility conqitions and proyide technical support,

recommending miti9ation .and corrective actions,

cqordinating search and re~cue,

coordinating majntenance.and eqµipment restoration,

establishing _a11d maintaining communications as desired by the Emergency Director, and

m'~intainirig a record of event activities .

Page 6

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- EP-FC-1001 Revision4

PERMANENTLY DEFUELED EMERGENCY PLAN -

2.2.2 Radiation Protection.Coordinator The Radiation Protection Coordinator reports fo the Emergency Director.

The responsibilities of the Radiation Protection Coordinator when implementing the PDEP include:

monitoring personnel accumulated dose,

advising the Emergency Director concerning Radiological EALs

_a1.Jgmenting the em_ergency staff _as deemed necessary,

directing radiological monitoring analysis,

performing dose assessment,

coordinating decontamination activities,

establishing and maintaining communications as desired by the Emergency Director, and

maintaining a record of event activities.

Table 2.1 provides a representation of the functional responsibilities of the on-shift 2.3 and ERO positions that fulfill the emergency staffing requirements.

Offsite Organizations Offsite organizations niay respond to a declared emergency at FCS. Each of these groups are capable of 24-hour response and operation. The details of their responsibilities are described in Section 3.0 of this Plan and are contained in their respective Letter of Agreement between

~ . .

each organization and OPPD.

'*,I Page 7 *

.FCS EP-FC-1001

' ,, ':* Revision 4 PERMANENTLY DEFUELED EMERGENCY PLAN FIGURE 2.1 On-Shift and Emergency Response Organization Shift Manager/

Emergency Director (1)

I I Security Force NCO (1) Radiation Protection Technician (1)

Emergency Response Organization I .....

I Technical Radiation Protection Coordinator (1)

' Coordinator (1)

I I

r---------------------r---------------.------1 I I I I I I I I I I I I Federal State/Local Local Services Agencies Agencies

(#) Denotes number of staff (either on-shift or designated ERO)

Page 8

FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELEQ EMERGENCY PLAN TABLE 2.1 On-Shift and Emergency Response Organization Staffing Requirements

ON- FCS AUGMENTED MAJOR FUNCTIONAL AREA LOCATION FCS STAFF SHIFT CAPABILITY (120 MIN.)

Operations and assessment of Control Non-Certified 11 -

Operational Aspects Room/On-Scene Operator*

Emergency Direction & Control Control Room Shift Manager* 11 -

Notification/Communication Control Room -

Radiological Accident Assessment As Directed by Radiation - 1 (may augment with and Support of Operational the Emergency Protection Radiation Monitoring Accident Assessment Director Coordinator personnel if necessary)

Protective Actions (hi-Facility) On-Scene Radiation 1 -

. Protection T~chnician*

Condition Evaluation, Repair,-and As Directed by Technical - 1 (may augment with Corrective Action the Emergency Coordinator technical support and Director emergency repair personnel if necessary)

Firefighting On-Scene Per the Fire Protection Offsite Response Procedures Organizations**

Rescue Operations/First Aid On-Scene ***

Site Access Control and Per the Security Security Per the - . ..

Accountability Plan Personnel Security Plan 1 Technical Specifications allow the Technical Specification-required on-shift positions to be vacant for not more than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ,

. in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

On-Shift personnel required to direct or perform site-specific mitigation strategies required for a catastrophic loss of SFP inventory.

- Response time is based on Fire Protection Procedures or response capability of the offsite response organization.

- - Provided by on-shift personnel assigned other functions.

Page 9

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PERMANENTLY DEFUELED EMERGENCY PLAN EP-FC-1001 Revision 4 3.0 EMERGENCY RESPONSE SUPPORT AND RESOURCES Radiological emergency preplanning is not required for the State of Nebraska, the State of Iowa, or the counties surrounding FCS (Washington County, Harrison County, and

. Pottawattamie County). State and County response:to an emergencywill be performed in accordance with each organization's plans and procedures and 'wi.11 be commensurate

. with the hazard posed by the emergency .

.*: Lett~rs of Agreement are in place for those loc;;al organizations that will provide ambulance services, treatment of contaminated and injured patients, fire support services, and law enforcement response as requested by FCS. These letters are maintained on file in the Emergency Planning Department at FCS ..

3. 1

Supp*ort Provided by Local Organizations 3:*1. 1 . Law Enforcement The Nebraska State Patrol and the Washington County Sheriffs Department have agreed to provide the primary law enforcement support to_ the FCS Security Department * * *

3. 1.2 Fir:e and Rescue Stipport

The Blair Volunteer F.ire Department has agreed to provide the primary fire support services-for FCS: The*Fort Calhoun Volunteer Fire Department has agreed to provide backup fire response .

. 3. 1.3 Transportation of Injured .and Contaminated Personn~I Omaha Public Power District (OPPD) vehicles. m~y transport non-injured potentially contaminated personnel.

The Blair Volunteer Fire Department has agreed to provide primary rescue and transportation support, for 'injured .and/or contaminated personnel.

Fort.Calhoun Volunteer Fire and R~scue has agreed to provide backup services.

3;1.4 Tre_atment of Radi<:>actively Contaminated and.Injured Personnel

UNMC, in Omaha, maintains a regional Radiation* Health Center Which

. provides services for the treatment of radiologically contaminated-.injuries

and radiation exposure evaluation. * *

Page 10

FCS PERMANENTLY DE FUELED EMERGENCY PLAN EP-FC-1001 Revision 4 4.0 *EMERGENCY CLASSIFICATION SYSTEM This section describes the emergency classification scheme adopted by the *OPPD for FCS.

4.1 *.classification of Emergencies The. emergency classification s'ysteril covers .the entire spectrum of possible radiological and' non-radiological emergencies at FCS. The *emergency classification system categorizes accidents and/or emergency situations into two

. emergency classification levels depending on emergency conditions at the time of the incident. The emergency classification levels applicabl~ to FCS, in order of increasing severity are NOUE and Alert. Each of these emergency classes requires notification of the responsible State of Nebraska and Iowa authorities, and the Nuclear Regulatory Commission (NRC). The Emergency Response Organization (ERO) will be notified at an Alert declaration.

FCS's**permanently defueled emergency classification system is developed consistent with NEl-99-'01, "Development of EALs for Non-Passive, Reactors,"

Revision 6. Appendix C of NEI 99.:.01, Rev. 6 contains a set of Initiating Conditions (ICs)/EALs for permanently defueled nuclear power plants that had previously

operated under a 10 CFR Par:t 50 licens_e and have permanently cea_sed .

operations. The classification system referenced in NEI 99~01, *Rev. 6 has been endorsed by the NRC and provides a standard method for classifying emergencies. ,* - t When indications are available to on-shift personnel that an EAL has been met, the event is assessed and the corresponding emergency classification level is

- deiclared. FCS maintains the capability to as~ess, classify.and declare an

. emergency condition within 30. minutes. after the availabflity ..of \ndicauon~ tllat an

. ,EAL. threshold has been reached *.

incidents niay be classified.in a lower emergency classification level first,' and then upgraded to the higher level if the situation deteriorates.

The following subsections outline the facility actions af each emergency

_ classification level. Refer tq the Permanently Defueled Emergency Action Level

.. Technical Bases for actual parameter values, annunciators, and equipment status

. used by FCS personnel to classify emergencies._

4.1:1 Notification of Unusual Event N.OUE conditions do not cause serious damage to the facility. The

*purpose.of the NOUE declaration is to: 1) bring*the ERO toa state of readiness; 2) make requirecr 1and 'needed notifications; 3) provide for Page 11

FCS

l Ji.:,.~-

PERMANENTLY DE FUELED EMERGENCY PLAN EP-FC-1001 Revision 4 systematic handling of information and decision-making; and 4) augment

.* shift:

personnel if necessary.

\ ** ..

4.1.2 Alert The purpose of the Alert declaration is to:* 1) activate *the ERO; 2) make required and needed initial notificatiqns as well as updates to event conditions; and 3) ensure all necessary res.ources are being applied to accident mitigation. * *. * * '

The Alert status shall be maintained until termination of the event occurs.

Recovery operations, may be entered without termination. Offsite authorities will be informed of the change in the emergency status and the necessary documentation shall be completed a*s specified in the EPIPs.

4.2 Postulated Accide.nts

The Defu.eled Safety Analysis Report (DSAR) de_scribes_the postulated accidents applicable to FCS. Methods for detecting and evaluating thes.e events include the use c;>finstalled systems, instrumentatiqn, alarms, approv.ed procedures, as well as fielq. observation. * * * *.

4.3

. Emergency Classification System Review The emergency, classification system and the EALs are reviewed with the States of Nebraska and Iowa, Washington County (Nebraska) and Harrison County (Iowa) on an annual basis.

5.0 NOTIFICATION METHODS AND PROCEDURES

The decision to make *notifications is based*on the emergency action levels and

.. ; corresponding emergency classifications described in Section 4.0 of this Plan. OPPD is capable of notifying and activating its Eme*rgency Response Organization 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day. It is also able to make notifications to the States of Nebraska and Iowa, and the NRG on a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day basis. ** ' * * * *

5.1 .Notification. and Activation

The Shift Manager is responsible for the initial emergency declaration and then assumes the duties of the Emergericy*Director. The authority*and responsibility for classifying arid declaring emergencies; initiating* notification to the States and Federal officials, and initiating cor.rective and mitigative actions resides with the Emergency Director position .

FCS personnel in the Protecte<;l Area are notified via the Emergency or Fire Alarm a

and public address sy5:~emrpe~~~ge. if required, pe,r~~nnel outside the Protected

Area are notified by public address systems installed in, the buildings outside the Page 12

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PERMANENTLY DEFUELED EMERGENCY PLAN EP-FC-1001 Revision 4 Protected Area. Site Security personnel may assist in the notification of all other

personnel on OPPD property.

5.1.1 . Emergency Response Organization Activation On-site staff are informed of an emergency condition through the use of the facility public address system, office telephone, and/or wireless devices capable of.receiving telephone calls anq text messages. In the event that personnel required to staff ERO positions are not on-site at the time an emergency is declared, they may be contacted by commercial telephone including land lines ahd/or wireless devices capable of receiving telephone calls and text messages. Mobilization of the ERO will be conducted under the direction of the Emergency Director, according to personnel assignments and telephone numbers maintained in various telephone directories.

5.1.2 State and Local Government Notification Notification to the responsible State authorities is required within 60 minutes of the emergency classification. The commercial telephone *.

network serves as the primary means to provide emergency notification to State agencies. It is. used to provide initial and updated notifications and for general information flow between these agencies.

OPPD, in coordination with the States of Nebraska and Iowa, have established the contents of the initial emergency messages to be sent from FCS in the event an emergency.is declared. These messages contain the following information if it is known an,d appropriate:

Location of the incident;

Name and telephone number (or communications channel identification) of caller;

Date and time of the 'incident;

Class *of emergency; *

Licensee emergency response actions underway;

Request for any needed onsite support by offsite organizations; and

Prognosis for worsening or termination of event based on facility information In the event the commercial telephone system is unavailable, wireless communications can be used to make emergency notifications. In addition, electronic means may be used to transmit the notification message.

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PERMANENTLY DEFUELED EMERGENCY PLAN .

EP-FC-1001 Revision 4 Follow-up emergency messages incorporate elements as determined necessary by the States of Nebraska and Iowa. These messages are transmitted by telephone or facsimile. Updated messages are sent at least every 60 minutes. The*frequency of updates may be modified during ongoing events if -requested by the States of Nebraska or Iowa and the status of the event h~s. no,t chang~d.

5.1.3 *NRC Event Notification Syste111

- - The NRG Event Notification System (ENS) is a dedicated telephone system used to notify the NRG Operations Center of an emergency. The NRG will be ,notified as soon as possible* after State notifications and within 60 minutes of event classification or change in classification. In the event that the ENS fails, commercial phone lines will be used to notify the NRG. Notification to the NRG is the responsibility of the Emergency Director.

6.0 EMERGENCY COMMUNICATIONS A number of communications systems a~e available for'.use among the principal

.. response organizations. Provisions .for ?4-hour per day notification to State. and local authorities is discussed in_,Section 5.0 of this plan. Provisions for activating OPPD ERO personnel are a_lso discussed. in sectior:i 5.0 of this plan. Provi~ions for periodic testing of the emergency communications system are described in Section 14.0 of this plan.

6.1 FCS Alarm System

Emergency or fire* alarms are sounded from the Control Room when an emergency

requiring* ERO activation or fire* is *deciared: Their function is to alert personnel within the Protected Area to an emergency condition.

6:2 Communication*systems **

Several modes of communication ar~ available tq facility staff to transmit information onsite and offsite during norn:,al and emergency situations.

6.2:1 . FCS Pa*ging Systems The Protected Area paging system (Gai-tronics) provides a means of intra-plant communiyations .. Stations on this sy,stem provide access to the paging system and to intercom lines. These stations and speakers are placed throughout the facility including the Control Room .

. . Bµildings outside of the Protected Area also have .public address announcing capabiliJi_es. Access to the_ public address system in both locations can be accomplished via the site's t~lephone system. This

system can be used to notify personnel of an emergency .

Page 14

FCS PERMANENTLY DEFUELED EMERGENCY PLAN EP-FC-1001 Revision 4 6.2.2 Telephone System

. The commercial telephone system (see Section 5:1.2)is the primary emergency notification system between FCS and State agencies and is used to provide initial and follow-up notifications and for general information flow between these agencies.

Additional methods of communication are available to facility staff to fransmit information onsite and offsite during normal and emergency situations.

The telephone system can be used for in-facility as well as outside communications. The telephone system is the primary means to activate the ERO upori declaration of an emergency, as directed by the Emergency Director. In the event that personn~I required to staff emergency positions are not on-site at the time an emergency is

. declared, they may be contacted by commercial telephone inclu~ing land lines and/or wireless devices capable of receiving telephone calls and text messages. Telephone numbers are maintained in various telephone

6.2.3 directories

The phone system includes many automated or programmable features

that improve *notification-and allow flexibility: Wireless communications serve as the backup means of communication. . .

Federal Telecommunications System The NRG ENS utilizes the Federal Telecommunications System (FTS) telephone network for emerg~ncy communications. The°FTS 'fine exists

'between the NR.C Operations Office in R9ckviile, Maryland ahd the FCS Control Room. Emergency notification, facility status information.and radiological information are communicated via the ENS.

6.2.4 Portable Radios*

Portable radios may be utilized by station personnel and ERO personnel during an emergency.

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PERMANENTLY DEFUELED EMERGENCY PLAN EP-FC-1001 Revision 4 6.3 Communications with Medical Support f'acilities Several modes of communication are available to facility staff to maintain communications with medical support facilities and mobile, rescue units during normal .and emergency situations.

6.3.1 Telephone System

FCS ERO personnel c~n communic_;ate with a1air Hospital, the UNMC, the Washington County E'mergency Co'mmunications Center, and mobile rescue units via the site telephone systems described earlier in this section.

6.3.2 Portable Radi'os When FCS personnel accompany a contaminated and/or injured employee* during transport, portable radios may be utilized by station personnel and ERO personnel to *communicate with the ambulance.

6.3.3 Non-OPPD Radio Systems

Non-OPPD radio systems provide communications between medical supportfacjlities and mobile rescue units as weU ~s inter-unit communications. T.hese radio systems have the capability to use the common medical emergency frequency.which ensures coordinated communications.

7.0 PUBLIC INFORMATION As part.of jts no_rmal corporate .structure: OPPD maintains a Corporate Communications

. Division that can be *called upon to pro*vide resources a~ necessary. The Corporate

. Crisi~ Communication Plan provides guidar:ice for the dissemination of information during emergencies. . . : ' .

The spokesperson function would typically be performed by QPPD Corporate Communications Division personnel. However, the' function could be performed by FCS or other corporate personnel. The spokesperson function participates in news conferences as appropriate with Federal, State, and local emergency response organizations. Principle points of contact with news media are also determined per the Corporate Crisis Communication Plan.

8.0 EMERGENCY FACILITIES AND EQUIPMENT Following the declaration of an emergency, the activities of the ERO are coordinated from the Control Room. Adequate emergency facilities and equipment to support emergency response are provided and maintained .

Page 16

FCS PERMANENTLY DE FUELED EMERGENCY PLAN EP-FC-1001 Revision 4

8.1 Control Room During a declared emergency, command and control is niaintained in the Control Room. Facility personnel assess conditions; evaluate the magnitude and potential consequences of abnormal conditions; initiate preventative, mitigating and corrective actions; and perform onsite and offsite notifications. When activated, the ERO .reports to the Control Room.

8.2 Laboratory Facilities A laboratory for radioisot9pic analysis and non*-radiological chemical analysis is available at FCS. A laboratory for non;-radiological chemical analysis is also available at OPPD's North Omaha Power Station.

The Nebraska Public Power DistricrCooper .Nuclear Station is capable of providing a ba.ckup facility in the event Fort Calhoun's ra'diocllemistry laboratory is not

.functional.. The Cooper Station's radiochemistry labqratory.is equipped to perform gross and isotopic dete~minations, on radionuclides in concentrations and counting geometries necessary for nuclear power plant operation and emergency monitoring. They will provide analysis.of liquid, air particulate, and cartridges on a

priority basis after receiving

. . the , ....

sample.

8:3 Emergency Equipment FCS maintains and operates on-site monitoring systems needed to provide data that is essential for initiating emergency measures and performing accident assessment, including dose* assessment and assessing the magnitude of a release. This includes monitoring *systems forfacility* processes, radiological conditions, meteorological conditions, and.fire* hazards.

Emergency kits are described in Section 8.4.

8~3.1 Process Monitors '

Annunciator and computer alarms are provided for a variety of

parameters including the SFP and the SFP systems to indicate SFP level

. and temperature. Th'e manner in which process monitors are used for accident recognition**and classification is detailed*in FCS's Permanently Defueled EALs.

8.3.2. Radiological Monitors Radiation monitors and monitoring systems proviqe continuous radiological surveillance. These monitors, which include Control Room readout and alarm functions, exist in order that appropriate action can be Page 17

FCS

PERMANENTLY DE FUELED EMERGENCY PLAN EP-FC-1001 Revision 4 initiated to limit fuel damage and/or contain radioactive material. The system performs the following basic functions:

Warns personnel of potential.radiological health hazards

Gives early* warning of certain equipment malfunctions that might lead* to a radiological hazard or facility damage

Prevents or minimizes the effects of inadvertent releases of radioactivity Plant instrumentation provides Control Room personnel with the following

.parameters necessary fo perform dose*assessmenf and determine the magnitude of ~potential release: ..

Gaseous and liqu.id effluent monitor readings ..

. . * . Area radiation leveis. . . .

In addition to installed monitoring systems, onsite portable radiation and cotita.mination monitoring equipment is available.

. 8.3.3 Meteorological Monitoring Meteorological data is.available in the Control Room. The*data are used to determine the projected radiological cons.equences in th~ event of an accidental release of radioactivity to the environment.

In addition, the National V\fec;1ther Service opefates on a twenty-four (24) hour.per <;lay basis. Upon request, this organization. can provide FCS with meteorological conditions incluc::ling.predicted temperature inversions, precipitation, wind patterns, ,;3nd velocity.

8.3.4 Fire Detection and Suppres~ion Equipment The fire protection system is detailed. in the .Station Fire Plan.

8.4 *. Emergency Kits Emergency kits. and equipme*nt are maintained to support an emergency response.

8.4.1* Radiological Emergency Kits*

Radiological Emergency kits include p*rotective equipment, radiological monitoring equipment and emergency supplies. Kits are located in the Control Room. The methods and frequencies for instrument calibration,

. repair, and replacement'are maintained in accordance with facility proce<;lures.* * ** * *

Page 18

FC*S PERMANENTLY DE FUELED EMERGENCY PLAN EP-FC-1001 Revision 4 8.4.2 Dosimetry Kits Dosimetry kits include dosimetry and appropriate paperwork. Kits are located in the Control Room:

8.4.3. Medical Kits First aid eq*uipment and supplies are located in the First Aid Room .

.Trauma and primary. response kits are available throughout the facility.

These kits are inspected arid maintained in accordance with approved facility procedures. .

Contaminated/injured person kits are located near the Radiation Protection Count Room and are maintained in accordance with facility procedures.

9.0 ACCIDENT ASSESSMENT The activatiQn of the PDEP and the continued assessment of accident conditions requires monitoring and assessment capabilities. FCS maintains and operates on-site monitoring systems needed to provide datathat is essential for initiating emergency

measures and performing accident assessment, including.dose assessm_ent.

9.1 Radiologic~! Assessment:

9; 1.1 *Initial Assessment Classification of an emergency is performed by the Emergency Director in accordance with the Permanently Defueled EAL Scheme. *

9.1.2 Initial Dose Assessm~nt Initial dose*assessment is performed by qualified on-shift personnel, under the direction of the Emergency Director. When the ERO is

~ugmented, the R~diation Protection Coordinator assumes* subsequent dose assessment responsibilities. . ..

Page 19

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PERMANENTLY DEFUELED EMERGENCY PLAN.

EP-FC-1001 Revision 4 9.2 Corrective Actions Station*procedures and EPIP,s provide preventative and/or corrective actions that mitigate the consequences of events. Instrumentation; control systems, and radiation monitoring systems provide indications related to the safe and orderly implementation of corrective actions. These systems provide indication of SFP storage inventory, temperature, cooling, and supp.o_rting systems .

.FCS maintains procedures and strategies for the movement of any necessary portable equipment that will be relied upon for mitigating the loss of SFP water.

These mitigative strategies are maintained in accordance with License Condition 3_.G of the FCS Renewed Facility Operating License and Technical Specifications.

These diverse strategies provide defense-in-depth and ample time to provide makeup water or spray to the SFP prior to the onset of zjrconium cladding ignition when considering very low probability beyond design basis events affecting the SFP. . ' . . .

9.3 *'oose Assessment

EPIPs utilize radiological instrumentation*readings and meteorological data to provide a rapid method .of determining the magnitude of a radioactive release during an emergency. FCS is capable of performing dose assessment 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day. Dose assessment is the responsibility of the Emergency Director. When augmented, the Radiation Protection Coordinator assumes the dose assessment responsibilities.

10.0 PROTECTIVE ACTl9NS Protective actions for personnel at the facility are provided for their health and safety.

Implementation guidelines for protective actions are pfovided in the EPIPs. Station

, procedures also provide protective actions to protect personnel during hostile actions.

. .Jt is the *policy of OPPD to keep personnel radiation exposure within federal regulations,

arid station limits and guidelines and.to keep exposures _ As Low As Reasonably Achievable (ALARA). Every effort will be made to keep exposures for those providing emergency functions within the limits of 10 CFR Part 20.

10.1 Accountability Accountability should be considered and used as a protective action whenever a site-wide risk to health and safety exists and prudence dictates. If personnel accountability is required, at the d_irection of the Emergency Director, all individuals at the site (including non-essential employees, visitors, and contractor personnel) shall be notified by sounding the facility alarm and making announcements over the Public Address System. Following announcement of an

emergency declaration, and when accountability has been requested, facility Page 20

FCS PERMANENTLY DEFUELED EMERGENCY PLAN.

EP-FC-1001 Revision 4 personnel are responsible for reporting* to designated areas and aiding Security in the accountability process .

. Accountability of all personnel on the site should be accomplished within 60 minutes -of the accountability announcement. If personnel ,are unaccounted for, teams shall be dispatched to locate the missing personnel. .

. Accountability may be modified or suspended if the safety of personnel may be jeopardized by a Security event or:other event hazardous to personnel.

.* 10.2 Site_ Egress Control Methods.

All visitors and unnecessary contractors are evacuated from the facility at the discretion of the Emergency Director. In the event of a suspected radiological release, personnel are monitored for radioactive contamination prior to leaving the Protected Area, Portable "radiation sµrvey meters are ayail~ble to monitor for potential contamination.

11.0 RADIOLOGICAL EXPOSURE CONTROL During ii plant emergency, abnorrtially high level~ of radiation and/or radioactivity may be encountered by plant personnel.*All.reasonable*measures shall be taken to control

the radiation exposure to emergency response personnel providing rescue, first aid, decontamination, emergency transportation, medical treatment services, or corrective or assessment actions within applicable limits specified in to CFR Part 20.

11.1 Radiological Control* Areas*

The Radiation Protection Coordinator:will ensure Radiological Control Areas (RCAs) are established in response to the event. The Radiation Protection Coordinator shall direct control of access to all RCAs unless immediate access control *is authorized by the Em~rgency Director t~ protect personnel or facilitate emergency repairs.

11.2 . Exposure Control

Individuals authorized to enter RCAs c)re required to have dosimetry capable of measuring a dose receivec::l from external sources ofionizing raqiation.

Emergency workers.are issued permanent reading dosimeters *ce.g., Dosimeter of Legal Record (DLR)) as a means of recording radiation exposure for permanent records prior to entering a RCA. Additionally, personnel are issued electronic alarming dosimetry capable of measuring dose and dose rate on a

.real-time basis. These dosimeters indicate dose on a digital display and are programmed to provide an-audible alarm at _a pre-determined dose or dose rate limit. Dose records are maintained in accordance with facility procedures. DLRs may be,processed with increased;periodicity during a response to an emergency .

Page 21

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- : ' : t ~;

PERMANENTLY DE FUELED EMERGENCY PLAN EP-FC-1001 Revision 4 The capability exists for the emergency processing of DLRs on a 24-hour per day basis.

All reasonable measures shall be taken to control the radiation exposure to emergency response personnel providing rescue*,Jirst aid, decontamination, emergency transportation, medical treatment services, corrective actions, and assessment actions within applicable limits specified in 10 CFR Part 20.

The Emergency Director is responsible for authorizing personnel to receive doses in excess of 10 CFR Part 20 limits, if necessary. This auth~rization is coordinated with the Radiation Protection Coordinator when available. Table 11.1 contains the guidelines for em~rgency exposure criteria, which is consistent with T~bl_e 3-1_, "Emergency Worker Guidelines," provided in the EPA PAG Manual.

Dosimeters and DLRs *are typically located in each of the em$rgency lockers in the co*ntrol Room. Additional dosimeters and DLRs are avail~ble.

11.3 Contamination Control and Decontamination Capability During emergency conditions, normal facility decont~mination and .contamination qontrol measures ar~_maintained as ciosely,as possible. However, the~!3 measures may be mod.ified, by the Emergency Director, should conditions

warrant. ** ' ' ' * * * -*

', j Contamination control measures are maintained to address access control, drinking water and food supplies, and the return of areas and items to normal use in accordance with proper radiation arid contamination control 'techniques.

Documentation surveys and decontamination activities shall be maintained in accordance with facility procedures.

FCS procedures establish requirements and specific action levels for decontamination of personnel, *equipment, areas, ,and for the release of the affected personnel, equipment, and areas from radiological Controls. If actual or potential contamination problems exist onsite, the Emergency Director may elect to establish contamination control and monitoring measures. These measures

. may consist of the establishment of contamination control boundaries to minimize

. , the spread of contamination and monitoring of personnel evacuating the affected area_ using installed monitors in the_ Security Building or personnel with portable equipment. : * * ' *

Contaminated areas* are isolated as restricted areas with appropriate radiological protection and access control. Personnel leaving contaminated areas are monitored to ensure both themselves-and their clothing are not contaminated.

Supplies, instruments, and equipment that are in contaminated areas or have been brought into contaniinated:areas will be monitored prior to removal. Items Page 22

FCS PERMANENTLY DE FUELED EMERGENCY PLAN EP-FC-1001 Revision 4 found to be contaminated, will be decontaminated using normal plant decontamination techniques and .facilities or may be disposed of as radioactive waste. Tools, equipment, and areas that become contaminated will be decontaminated as determined by Radiation Protection personneL

, If personnel decontamination becomes necessary, decontamination is performed under,.the direction of the Radiation Protection Coordinator. Contaminated personnel that are evacuated ~ill be. decontaminated as determined by Ra9iation Protection personnel. If the contaminated individual has an injury involving

contamination, efforts to decontaminate the injured person to reasonable levels are made prior to transfer to offsite medical facilities. If decontamination is not

.. practical,

.. the injured person is c_overed in such a manner

\

as to minimize the spread of co_ntamination untiJ either medical aid can be obtained or until the .*

injured person' can be transported to thia UNMC Radiation Health Center.

Additional decontamination facilities are available at the UNMC Radiation Health Center. Radioactive waste is controlled to ensure that the contents are monitored

and processed, if necessary.

Priorities for decontarriinating tools, equipment, and areas will be established by t~_e Eme;rgency Director, with top priority given to contamination within areas' that .

are or.will be inhabited by emergency workers. Decontamination of non-essential areas, tools, and equipment should be delayed to allow for natural decay of radioactive materials.

Protective clothing is maintained in the Control room. Additional sets are available. '

Monitoring and issue of respiratory protection equipment will be,conducted in accordance with facility procedures.

Page 23

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PERMANENTLY DEFUELED EMERGENCY PLAN EP-FC-1001 Revision 4 TABLE 11.1 EMERGENCY EXPOSURE CRITERIA

. (Refer to -Note 1)

Guideline Activity Condition

, . Ail ~eas*onably achievable 5 rem All occupational exposures actions have been taken to minimize dose.

.. Exceeding 5 rem is unavoidable and all Protecting critical 10 rem(al ' .appropriate actions have been infrastructure necessary for taken to reduce dose.

public welfare Monitc:>ring. available to project or measure dose.

Exceeding 5 r~m is unavoidable and all 25* rem(~l(cl Lifesaving or*Protedion of appropriate"actions have been Large Population* taken to reduce dose.

Monitoring available to project

.. *, : .. . ' or measure dose .

NOTES:*

1. Reference for this table is Table 3-1 of the EPA PAG Manual.

(a) For potential doses> 5 rem, medical monitoring programs should be considered.

(b) In the case-of a very large incident,*cons1der the need to raise the property and lifesaving Response Worker Guideline to prevent further loss.

(c) Only on a voluntary basis. Response actions that could cause exposures in excess of 25 rem should only be undertaken with an understanding of the potential acute effects of radiation to the exposed responder and only when the benefits of the action clearly exceed the associated risks .

Page 24

FCS PERMANENTLY DEFUELED EMERGENCY PLAN .

EP-FC-1001 Revision 4 12.0 MEDICAL AND HEALTH SUPPORT FCS maintains on-shift personnel and equipment to provide first aid for personnel working at.the site . .Medical supplies for emergency first aid treatment are provided on the site. at various locations.

If immediate professional medical help is nE:leded, local ambulance services are available to tran_sport seriously ill, injured, or radioactively cqntaminated injur~d personnel.. Patients can also be transported to the facility via medical ambula.nc!3 helicopters. FCS is capable of maintaining communications with medical support facilities and the local ambulance service while transporting a patient. The~e capabilities are described in Section 6.3.

An agreement is in place with UNMC in Omaha for medical treatment of patients from FCS who have 'injuries complicated by radioactive contamination. The hospital has trained personnel and detailed procedures for handling radioactively contaminated patients from FCS. *

13.0 RECOVERY The emergency.measures presented in this plan are actions designatedto mitigate the

consequences of the accident in a manner that affords the maximum. protection to plant personnel. Planning for the:recovery involves the development of general principles and

an organizational capability that can be adapted to any emergency situation. Upon termination of an emergency and transition to .recovery, phase, the Emergency Director assembles the recovery organization to address the specific emergency circumstances of the terminated event.

The Emergency Director directs the recovery organization and is responsible for:

- ** ' '. *' * * * '

J

Ensuring the facility is maintained.in .a safe condition;

Managing onsite recovery activities; and

Keeping corporate support apprised of recovery activities and requirements.

The remainder* of tile* re~overy is accomplished using t_he norm.al.facility and emergency organizations as necessary to provide radiological and technical expertise to the E_mergency Directqr in order to restore tile facility to normal corid_itions.

The recovery organization's responsibilities include:

Maintaining comprehensive radiological surveillance of the facility to assure continuous control and recognition of problems

Controlling access to the area and exposure to workers

Decontaminating affected areas and/or equipment Page 25

FCS

PERMANENTLY DEFUELED EMERGENCY PLAN EP-FC-1001 Revision 4

Conducting clean-up and restoration activities

. Isolating and repairing damaged systems

Documenting all proceedings of the event and reviewing the effectiveness of the emergency organization in reducing public hazard and plant damage *

When plant conditions allow a transition from the emergency phase to the recovery phase, the Emergency Director conducts a plant emergency man~gement meeting to discuss* the recovery organization. The actions taken by this organization concerning termination of the emergency proceeds in accordance with a recovery plan developed specifically for the accident conditions.

14.0 EXERCISES AND DRILLS Periodic exercises are conducted to evaluate major portions of emergency .response capabilities. Periodic drills are conducted to develop. and maintain key emergency response skills. Deficiencies as a result of exercises or drills are identified and corrected.

14.1 Exercises

Biennial exercises shall be 'conducted to test the timing and content of

implementing procedures and methods and to ensure that emergency personnel are familiar with their duties. Offsite organizations are offered the opportunity to participate to the extent assistance would be-expected during an emergency declaration. However, participation by offsite organizations is*not required, nor are. offsite response organizations evaluated.

14.2 Drills Communication checks with offsite agencies, fire drills, medical dri.lls, radiological monitoring drills and health physics drills are performed as indicated in the following sections.

14.2.1 Medical Drills A medical emergency drill shall be conducted annually. The drill involves a simulated contaminated injury. The local ambulance service and the UNMC Radiation Health Center are invited to partidpate in an annual

exercise and/or scheduled drill(s) to demonstrate and practice the receipt and treatment of contaminated patients. Involvement by hospital and medical transport services may be included as part of any drill or exercise,

Page 26

'FCS PERMANENTLY DEFUELED EMERGENCY PLAN EP-FC-1001 Revision 4 14.2.2 Accountability Drills An accountability drill shall be conducted annua,lly. This drill shall include identifying the locations of all personnel onsite. This drill can be performed as part of any drill or exercise.

14.2.3 Health Physics Drills Health Physics drills are conducted semi..:annually involving response to, and the analysis of, simulated elevated in,-facility airborne and liquid samples and direct radiation measurements in the environment. This drill can be performed as part of any drill or exercise.

14.2.4 Augmentation Capability Drills

, An off-hou_rs, unannounced augrnen.tatio~ drill shall be conducted semi-annually to estimate emergency response personnel response times. No actual travel is required. Participants provide:an estimate time of arrival to their designated ERO position.

14.2;5 Fire and Security Drills,' ,

Fire Drills and Security Drills are conducted in accordance with the

.respective FCS plans and procedures .

.14.2.6 Cprnmunica~ion *Te~ts A. The ENS -used to communicate with the NRC is tested monthly.

B. To ensure the reliability of the plant's call-in procedure, a semi-annual functional test of the ERO notification system is performed to test system performance. This can be performed' separately or during the Augmentation Capability Drill described in'Section 14.2.4.

C. The following communication system~. as d.e~ailed in Section 6.2, are used on a frequent basis. Therefore, periodic testing of these systemsis not necessary: ,.

a: , FCS Paging Sys~em *

b. *Commercial Telephone System

c. Portable Radios 1 14.3 Scenarios Ari Exercise/Drill Coordinator is ,r.espqn~ible for the overall development of the scenariO package. . . . ,. * *.....

Page 27

FCS

PERMANENTLY DEFUELED EMERGENCY PLAN .

EP-FC-1001 Revision 4 A scenario development team is assembled (if needed) by the Exercise/Drill Coordinator to create the various segments of the scenario which include, but are not limited to, the following: *

Objective(s)

Date, time period, place and participating organizations .*

. Simulation lists

Timeline of real and simulated events

An~rrative summary

List of controllers and parti?ipants The final scenario shall be approved by a designated member of senior facility management. Drill/Exercise confidenfiality must always be maintain_ed.

14.4 .* Critique/Evaluation Critiques will evaluate the participant's performance during a drill or exercise.

The ability of participants to self-evaluate weaknesses and identify areas of improvement is the key to successful exercise/drill conduct.

Exercise and drill performance objectives are evaluated against measurable demonstration criteria. As soon as possible following the conclusion of each drill/exercise, a critique, including participants, controllers,' and evaluators, is conducted to ~valuate the ability of the participants to meet the performance objectives. Deficiencies are identified and entered into the corrective action system.

Awritten report is prepared including \he evaluation of designated objectives.

The repprt evaluates and docum.e11ts. the participants' response to the emergency situation. The report will also contain reference to corrective action and recommendations resulting from the drill/exercise.

15.0 RADIOLOGICAL EMERGENCY RESPONSE T~INING Radiological emergency response training is provided to those who may be called on to assist in an emergency. FCS Management is responsible to ensure all members of the Emergency Response Organization receive the required initial training and continuing training.

15.1 Emergency Response Training The training prngram for ERO personnel is based <?n applicable requirements of Appendix E to 10 CFR Part 50 *and position-specific responsibilities as defined in

Page 28

FCS PERMANENTLY DEFUELED EMERGENCY PLAN EP-FC-1001 Revision 4 the PDEP. Emergency response J!)ersonnel in the following categories receive initial training and annual retraining .. i 15.1.1 Emergency Response Organization Training Shift Managers/Emergency Directors, Technical Coordinators, and Radiation Protection Coordinators,shall have training conducted such that proficiency is maintained on topics listed below. These topics should be covered as a minimum on an annual basis. *

Emergency Action Levei Classification

Dose Assessment

Federal, State, and local notification procedures

. ERO Augmentation

, Emergency Exposure* Control

Mitigating st~ategies fo~ 'a catastrophic loss of spent fuel pool inventory

Recovery FCS personnel available during emergencies to perform emergency response activities as an extension of their normal' duties receiv.e* duty specific training. This includes facility on-shift personnel, maintenance,

. radiation protection, and security*personnel. Personnel assigned to liaison

'with offsite fire departments are trained .in accordance* with the Fire Protection Program, including mitigating strategies *required for a .

catastrophic loss of SFP inventory. Personnel assigr::ied the responsibility 9f on~shift first 'aid Shall 'attend first aid training. .. ' .-

15.1.2 General Employee Training

An overview of the Emergency Pl,an is Qiven to all personnel allowed unescorted access into the Protected Area at Fort Calhoun Station.

Personnel receive this information *during initial training and are ..

requalified_ on an annual basis. This training includes identification of the to emergency alarm; the fire alarm *and the steps follow for a plant and site evacuation. ...

. 15.:1.3 _Loca1*support Seivi?es.Personnel Training

Training is offered annually to offsite organizations which may provide specialized services during an emergency at FCS (fire-fighting, medical services, transport of c:;ontamiiiated:and/or-injured personnel, etc.). The training shall be structured to meet the needs of that organization with Page 29

FCS

PERMANENTLY DE FUELED EMERGENCY PLAN EP-FC-1001 Revision 4 respect to the-nature of their support. Topics of event notification, site access, basic radiation protection and interfaqe activities are included in the training.

15.1.4 First Aid Training

. Personnel assigned the responsibility for responding to a medical

emergency at FCS receive the American Red Cross Standard First Aid Training Program, or: equivalent. To maintain qualifications in accordance with the American Red Cross, CPR and First Aid Training are given once every two years. The associated training records are maintained in accordance with Training Department procedures.

15.2 Documentation of Training FCS procedures outline the process to document training of the FCS Emergency Response Organization. An Emergency Planning procedure is used to verify training provided to offsite organizations.

16.0 RESPONSIBILITY FOR THE PLANNING EFFORT: PERIODIC REVIEW AND

DISTRIBUTION OF EMERGENCY PLANS

. Senior plant leadership is responsible for the implementation of actions required to

'periodically exercise the PDEP and the EPIPs and for maintaining an effective ERO staff. ** * * *

Senior plant leadership is responsible forthe final approval of PDEP and the EPIPs used

for emergency classification, and for-maintaining an effective emergency response capability at FCS.

Emergency Planning Manager is responsible for the development, administration and maintenance of the PDEP, EPIPs, review arid approval of ali EPIP changes (with the exception of the EPIP used for emergency classification),* planner training, the overall development and implementation of the FCS ERO Training and Qualification Program ahd cpordination of emergency planning activitie~ with off-site emergency organizations.

16.1

Document Maintenance 16.1.1 Review and Update ofthe PDEP anc;I EPIPs The FCS PDEP, Permanently Defueled EAL Technical Bases, and the EPIPs included in Appendix A are reviewed annually and updated as needed. All proposed changes will be reviewed in accordance with 10 CFR 50.54(q) to ensure that the change would.not compromise the effectiveness of any other EPIP or degrade the effectiveness of the PDEP. Emergency Planning Manager is responsible for forwarding

Page 30

FCS PERMANENTLY DEFUELED EMERGENCY PLAN EP-FC-1001 Revision 4 approved changes to the plan to appropriate organizations and individuals with responsibility for implementation of the plan.

16.1.2 Emergency Planning Documents Letters of Agreement with support agencies shall be reviewed annually.

Agreements will be revised or recertified. Recertification may include a recertification letter/memorandum, purchase order, email, documented telephone conversation or other correspondence. Designated FCS management has the authority to enter into these agreements with outside organizations.

The emergency classification system and the EALs are reviewed with the States of Nebraska and Iowa, Washington County (Nebraska) and Harrison County (Iowa) on an annual basis.

The FCS emergency telephone directory will be maintained in specified locations and updated quarterly.

16.2 Inventory and Maintenance 9f Emergency Equipment Periodic inventory, testing, and calibration of emergency equipment and supplies

are conducted in accordance with approved facility procedures. This equipment includes, but is not limited to:

-Portable radfation mon'itoring equipment * ** .

Emergency.medical re~pons~'.;equipm~nt

Dosimeters

Portable radios Emergency equipment and instrumentation shall be inventoried, inspected and operationally checked periodically 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.

Page 31

FCS PERMANENTLY DEFUELED EMERGENCY PLAN EP-FC-1001 Revision 4 AP:PENDIX A. *

EMERGENCY,PLAN .IMPLEMENTING PROCEDURES

Page 32

FCS PERMANENTLY DE FUELED EMERGENCY PLAN EP-FC-1001 Revision 4 APPENDIX A EMERGENCY PLAN IMPLEMENTING PROCEDURES Document Document Title EP-FC-1001 PERMANENTLY DE FUELED EMERGENCY ACTION LEVELS FORT Addendum 3 CALHOUN STATION EP-FC-110 ASSESSMENT OF EMERGENCIES EP-FC-111 EMERGENCY CLASSIFICATION EP-FC-112 EMERGENCY RESPONSE ORGANIZATION ACTIVATION AND

OPERATION EP-FC-112-100 CONTROL ROOM OPERATIONS EP-FC-113 PERSONNEL P~OTE~TIVI; ACTIONS EP-FC-114 NOTIFICATIONS EP-FC-115 TERMINATION AND RECOVERY Page 33

FCS

PERMANENTLY DEFUELED EMERGENCY PLAN .

EP-FC-1001 Revision 4 APPENDIX B .**

CROSS-REFERENCE BETWEEN THE PDEP, NUREG-0654/FEMA-REP-1, 10 CFR 50.47(b)

PLANNING STANDARDS, AND APPENDIX E.IV PLANNING REQUIREMENTS

Page 34

EP-FC-1001 Revision 4 PERMANENTLY DE FUELED EMERGENCY PLAN APPENDIX B CROSS-REFERENCE BETWEEN THE PDEP, NUREG-0654/FEMA-REP-1, the 10 CFR 50.47(b) PLANNING STANDARDS, AND APPENDIX E.IV PLANNING REQUIREMENTS NUREG- Planning Planning Requirement FCS 0654, Standard PDEP Section (Appendix E.IV)**

Section II (1 OCFR50.47)**

Evaluation Criteria A (b)(1) A.1,2,4,7 2.0 B (b)(2) A.1,2,4,9; C.1 2.0 C (b)(3) A.6,7 3.0 D (b)(4) B.1,2;C.1,2 4.0 l

E (b)(5) A.6, 7;C.1,2;D.1,3;E 5.0 F (b)(6) C.1;D,1,3;E 6.0 G

H I

(b)(7)

(b)(8)

(b)(9) ,

A.7;0.2 E;G A.4;8.1 ;C.2;E 7.0 8.0 9.0 J (b)(10) C.1;E;I 10.0 K (b)(11) E 11.0 L (b)(12) A.6,7;E 12.0 M (b)(13) H 13.0 N , (b)(14) E9;F 14.0 0 (b)(15) F 15.0 p (b)(16) G 16.0

- As Exempted

_/

Page 35

EP-FC-1001 Revision 4

PERMANENTLY DEFUELED EMERGENCY PLAN APPENDIX C

DE-FINITIONS AND ACRONYMS

Page 36

EP-FC-1001 Revision 4 PERMANENTLY DEFUELED EMERGENCY PLAN 1.0 DEFINITIONS Accountability - The process of determining the, loc~tion of onsite personnel in order to ide~tify missing and or injured personnel. :

Alert - Events are in progress or have occurred which involve a potential or actual substantial degradation of level of safety of the'facility, or a security event that involves probable life

threatening risk to site personnel or damage to site equipment because of hostile action. Any releases are expected to be limited to small fract1ons'of the EPA Protective Action Guideline*

exposure levels.

Annual - Frequency of occurrence equal to once per calendar year, January 1 to December 31, unless otherwise specified. * * *' * * *

Assessment Actions - Those action~ taken during or after an incident to obtain or process ..

information necessary for decisions in specific emergency measures'. * '*

Corrective Actions - Those emergency measures taken to mitigate or terminate .an emergency situation at cir near the source ~f the problem"in order.to' reduce the magnitude. ' :

Emergency Action Levels~ Predetermined, site specific, observable threshold for an Initiating Condition (IC) that,.when met or exceeded, places the facility 'in a given emeyg~qc::y . . . .

classification. * *

Emergency Classification - Narnes set forth by the Nuclear Regulatory Commission (NRC) for

grouping off-normal events or conditions according to potential effects or consequences: In" order of severity: Notification of Unusual Event (NOUE) and Alert. * * * *

Emergency Plan Implementing Procedures __: The procedures which detc:1iJ the specific course of action for implementing the emergency plan at FCS.

Emergency Response Organization - The organizational structure of assigned FCS personnel responsible for coordinating response and recovery from emergency conditions at the facility.

Exclusion Area - The property of FCS surrounding the Protected Area in which the licensee has the authority to determine all activities including exclusion or removal of personnel and property from the area.

Hostile Action - An act toward a facility or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end. This includes, but is not necessarily limited. to, attack by air, land, or water using guns, explosives, projectiles, vehicles or devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts are not part of a concerted attack on the facility. Violent acts between individuals in the owner controlled area do not meet this definition.

Independent Spent Fuel Storage Installation - A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.

Page 37

EP-FC-1001 Revision 4

PERMANENTLY DEFUELED EMERGENCY PLAN Initiating Condition - An event or condition that aligns with the definition of one of the two emergency classification levels by virtue of the potential or actual effects or consequences.

Monthly - Frequency of occurrence equal to once per calendar month.

Notification of Unusual Event - Events are in progress or have cc.curred which indicate a potential degradation of the level of safety of the facility or indicate a security threat to facility.

protection, has been initiated. No releases .of radioactive material requiring*offsite response or monitoring are expected unless further degradation of safety systems occurs.

Onsite - The area within the Exclusion Area Boundary.

Projected D~se -The estimated radiation dose that would be received by in9ividual.sJollowing a release of radiation. * '

Protected Area -* The area normally within the facility security fence designated to implement" the security requirements of 10 CFR 73. *

Protective Actions - .Measures taken to ~ffectively mitigate the consequen*ces *of an acddent by minimizing the radiological exposure that would likely occur ifsuch actions were not taken.

Radiological c*ontrol Area - An area in which. radioactive material is pres'ent and the* potenti~I:

exists for the* spread of radioactive contamination. The area will be posted for purposes of .

protecting individuals against undue risks from exposure to radiation and radioactive materials .

Recovery - Actions taken after the emergency has been controlled to resto.re the fadlity as .

nearly as.possible to ifs pte-emerg~ncy con~mio*n. ' * * *

Site Evacuation - Removal of all personnel, except essential FCS personnel from the Exclusion Area and FCS Protected Area: . . s . . * * * .

,r,

, ..

1,:r Page 38

EP-FC:-1001 Revision 4 PERMANENTLY DEFUELED EMERGENCY PLAN 2.0 CFR ACRONYMS Code of Federal Regulation DLR Dosimeter of Legal Record EAL Emergency Action Level ENS Emergency Notification System EPA Environmental Protection Agency EPIP Emergency Plan Implementing Procedure ERO Emergency Response Organization FCS Fort Calhoun Station FTS Federal Telecommunications System IC Initiating Condition ISFSI Independent Spent Fuel Storage Installation NCO Non-Certified Operator NOUE Notification of Unusual Event NRC U.S. Nuclear Regulatory Commission NWS National Weather Service OPPD Omaha Public Power District PAG Protective Action Guide PDEP Permanently Defueled EmergencyPlan.

RCA Radiological Control Area SFP Spent Fuel Pool Page 39

FCS EP-FC-1001 Addendum 3 Revision 4 OPPD NUCLEAR

PERMANENTLY DEFUELED EMERGENCY ACTION LEVEL TECHNICAL BASES

Fort Calhoun Station Permanently Defueled EAL Technical Bases

FCS EP-FC-1001 Addendum3 Revision 4 TABLE OF CONTENTS 1.0 PURPOSE ..................................... i .................................... : .................................. 1 2.0 DISCUSSION ........ :... :.... '. ...... *: ........... ;.. :..................... ~ .................................. ~; .. :... 1 2.1 Permanently Defueled Facility............................................................... :***** ....... 1 2.2 Independent Spent Fuel Storage Installation ................................ :, .................. : 2 3.0 KEY TERMINOLOGY USED ............*.............. : ......... : ........ : ............... ;........ :......... 2 3.1 Em~rgency Classification Levels ................... :.................................................... 3

. 3.2 Initiating Condition ......*..:., ............ .-........ :...................................... .- ....................... 4 3.3 Emergency Action Level .......... '. .................. :.: .......................... :.:: ...................... 4 4.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS .......... :...... :.......... 5 4.1 General Considerations ..................................................................................... 5 4.2 Classification Methodology ......... ,........................................................................ 6 4.3 Classification of Multiple Events and Conditions.: ..............*................................ 6 4.4 Classificatio~ *of Imminent C~nditions ............................*........ *.... :....... :.......... : .. :. 6 4.5 4.. 6 4.7 4.8 Emergency Classification Level Upgrading and Termination ............................. 7 Classification of Short-Lived Events ...... :............................. .' .... ~ ........ ,.. ~ .. ,.......... 7 Classification of Transient Conditions: ............... :........*.... :...........................*... ,.. .-?

After-the-Fact Discovery of an Emergency Event or Condition ........... : .......... :... 8 4.9 Retraction of an Emergency Declaration ............................. :: ............... :*.:: .......... 8

5.0 REFERENCES

.......... :................................... :...*........*...*...... :: .......*.. :.................. :.. ."8 I

5.1

Developmental ................................*.,...._............ :............ :............................... ,.... 8 5.2 lmpiementing .......... :................. *.*...... *.... :.. .- ................... :.......... :.......... *....... :*::.:.*:*.... 9 5.3 . Commitments." '

.-. .. :... :......................................... :.*....':*.. 9 6.0 ACRONYMS & DEFINITIONS .................................. .-................................. ,....... 10 6.1' Acronyms .................... ."... :.: ... *....... :.......... : ........... :.... ***:*:...... ;..... .-........... :.......... 1O 6.2 Definitions ..................................................................................... :................... 11 7.0 FCS-TO-NEI 99-01 EAL CROSS-REFERENCE ................................................. 13 8.0 ATTAC~MENTS .............................. ~ ................._. ......................... :... *..................... 1.4 Attachment *1 ......... :. .-...........................................................................;.... : ................... 15 ........... :..* ............ *.: ... ;*.......... :.*:.": ... : ..... : .........*..... : ..................... : ................. 37 Fort Calhoun Station Permanently Defueled EAL Technical Bases

FCS EP-FC-1001 Addendum 3 Revision 4 1.0 PURPOSE This document provides the detailed set of Emergency Action Levels (EALs) applicable to the Fort Calhoun Station (FCS) and the associated Technical Bases using the.EAL development methodology found in NEI ~i9-01, "Development of Emergency Action a

Levels for Non-Passive Reactors," Revision 6 (NEI 99-01, Rev. 6). As permanently

defueled facility, FCS will use the Recognition Category "PD", (Permanently Defueled) providing a stand-alone set of Initiating Conditions (ICs)/Ernergency Action Levels (EALs) for a permanently defueled facility to consider' for use in developing a site-specific emergency classification scheme and Recognition Category "E" ICs for the ISFSI. Permanently defueled ICs and EALs are addressed in Appendix C of NEI 99-01,

.Rev. 6. All recommendations for changes to this document or associated implementing procedures are reviewed in accorc,lance with 10 Code of Federal Regulations (CFR)

. 50.54(q). . ., ,.

This document should be used to facilitate review of the FCS Permahentl/Defueled*

EALs, provide historical documentation for future reference and serve as a resourcfffor training. Decision-makers responsible for implen,entation of the Permanently Defueled

. Emergency Plan (PDEP) may use this document as a techni9al reference in support of EAL interpretation. * * * * * ** * * *

. The expectation is that emergency classifications are to be made as soon as conditions are*present and recognizable for the classification, but'within 30 minutes or less in all cases of conditions present. Use of this document for assistance is.not intended to .

.delay th_e emergency classification ..

2.0 DISCUSSION 2.1 Permanently Defueled Facility

NEI 99-01 provides guidance for an emergency classification scheme applicable to a permanently defueled facility. This is a facility that generated spent fuel und~r a 10 CFR

.Part 50 license, has permanently ceased operations, and will store the spent fuel onsite for an extended period of time. The emergency classification levels (ECLs) applicable to this type of facility are consistent with the requirements of 10 CFR Part 50 and the

. guidance in NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nu~lear

Power Plants, Rev. 1" (NUREG-0654). '

. In order to relax the emergency plan requirements previously applica.ble.to an operating facility, the licensee must demonstrate that no credible event can result ih a significant radiological release beyond the site boundary. This verification confirms that the-sourc~

term and motive force available in the permanently defueled condition are insufficient to warrant classifications of a Site Area Emergen*cy or General Emergency. Therefore, the

Page 1

FCS EP-FC-1001 Addendum 3 Revision 4 generic ICs and EALs applicable to a permanently defueled facility may result in either a Notification of Unusual Eve_nt (Unusl:Jal Event) or an Alert ~lassification.

2.2 Independent Spent Fuel Storage Installation Selected guidance in NEI 99-01, Rev. 6 is applicable to licensees electing to use their 10 CFR Part,~0-emergency plan to fulfill the requirements of 10 CFR 72.32 for a stand-alone Independent Spent Fuel Storage Installation (ISFSI). The ECLs applicable to an ISFSI are consistent with the requirements of 10 CFR Part 50. The ICs germane to a 10

, CFR 72.32 eniergencyplan (as described in NUREG-1567)are subsumed within tl')e,,

classification scheme for a 10'CFR 50.47 emergency plan. *

The analysis of potential onsite and offsite consequences of accidental releases associated with the op,eration of an ISFSI is c~mtained in NUREG-1140, "A Regulatory Analysis on Emergency Preparedness for-Fuel Cycle and Other Radioactive Material Licensees", (N,UREG-1-140). NUREG,.1140 concluded that the postulated worst~case accident involving an ISFSI has insignificant consequences to public health and safety.

This evaluation shows that the maximum offsite dose to a member of the public due to an accidental release of radioactive materials would not exceed one (1) rem Tot~I Effective Dose Equivalent. * -- * ** *

Regarding the above information, the expectations for an offsite response to anAlert

classified under a 10 CFR 72.32 emergency plan are'generally consistentWith those for an Unusual Event in a 10 CFR 50.47 emergency plan (e.g., to provide assistance, if ..

requested). Also, the licensee's Emergency Response Organization (ERO) *required for

. a 10 CFR 72.32 emergency plan is different than that prescribed fora 10 CFR,50.47 emergency plan (e.g., no emergency technical support function).

3.0 KEY TERMINOLOGY USED There are several key terms that appear throughout the NEI 99-01, Rev. 6 methodology. These terms are introduced h-1 this section to support'uriderstanding of subsequent rnaterial.* As an aid to the reader, the following table is provided as an overview to illustrate the relationship of the terms to each other..

Page2

FCS EP-FC-1001 Addendum 3 Revision 4

Emerg~ncy Classification Level Unusual Event I Alert lnitiatin'g Condition Initiating Conditior( '

Permanentiy Defuele~. Emergency .* *

Permc1nently Defuele.d Emergency .*

Action Level1

Action Level1 ' . ' '

Notes

Notes

Basis* .. . Basis

1. When making an emergency classification; the Shift MariageriEmergency Director must conside'r all: information having a bearing on the proper assessr:nent of an .

Initiating Condition. This includes the PD and 6 EALs, Notes, a*nd the Basis information. * ; *'. '

3.1 Emergency Classification Levels

One of a set of name.s or titles established by.the .Nuclear Regulatory Commission

'(NRG) for grouping off-normal e~ents or' conditjons.according to ;(1) potential or actual effects *or.consequences, and (2) resulti_ng onsite ancl offsite response actions. The ECLs., in ascending or,der *of sever,ity, are: . . .

Unusual* Event'

Alert 3.1.1 Unusual Event Events are jn progress.or have occurred. which indica~e a potential .

degradation of the level of safety of the ,facility or indicate a security threat to

-'facility protection ha~ been Jnitiated. No re.leases of radioactive material ...

requiring offsite response or monitoring are expected unless further degradation of safety systems occurs. *

Purpose:

The purpose of this classification is to assure that the first step in future response has been carried out, to bring the operations staff to a state of readiness, and to provide systematic handling of unusual event information and decision-making .

Page 3

FCS EP-FC-1001 Addendum' 3 Revision 4 3.1.2 Alert Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the facility or a security event that in'volves probable life threatening risk to site personnel 'cir damage to site equipment b~cause of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the Environmental Protection

Agency (EPA) Protective.Action Guides (PAG) exposure levels .

.Purpose: The purpose of this classification is to assure that erner~ercy personnel are readily available to respond if the situation becomes. more serious or Jo perform confirmatory radiation monitoring if required, and

. :. provide offsite authorities current information on facility ~tatus.and *

. parameters.

3.2 ln.itiating Condition An event or condition that aligns with the definition of one of the two ECLs by virtue of the potential or actual effects or*consequences.

Discussion:, A~ lnitiati,ng C~mdition (IC) describes an event or condition, these.verity or consequences of which meets ,the definitipn of an EGL. An IC .can be expressed as a

continuous, measurable parameter (e.g., radiation monitor' readings) or an event (e.g.;

an earthquake).

Appendix 1 of NUREG-0654 does not contairi example EALs for each EGL, but rathe~ .

ICs (Le., conditio~s that indicate that a radiological eme.rgency, or events that could lead

. to a radiological emergency, hav~ occurred): NUREG-06~4 states that the 1c*s forni the basis for establishment by a licensee of the specifi.c facility instrumentation readings (as applicable) which, if exceeded, would initiate the emergency.classification. Thus,. ifis .

the specific instrument. readings th~t would be t~e E~Ls. . . . .. .

3.3 Emergency Action Level A pre-determined, site~specific; observable 'threshold for an IC that, when met or exceeded,-places the facility in a given EGL..

Discussion: EAL statements may utilize a variety of criteria including instrument .

., readings and status indications, ob.servab-le events, results of calculations and analyses, entry into particular procedures, and ttie' occurre,nce of natural phe.riomena. ' '

Page 4

FCS

I EP-FC-1001 Addendum 3 Revision 4 4.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS 4.1 General Considerations When making an emergency classification, the Emergency Director must consider all information having a bearing on the proper assess_ment of an IC. This includes the EAL plus Notes and the informing Basis information.

All emergency classification. assessments should be based upon valid indications, reports or conditions. A valid indication, report, or condition, is one that has been verified through appropriate means such that there is nd doubt regarding the indicator's oper~biljty, the condition's existence, or the report's accuracy. For example, validation could be accomplfshed through an instrument channel check, response on related or redundant indicators, or direct observation by personnel. The validation of indications should be completed in a manner that supports timely emergency declaration.

for ICs and EALs that have a stipulated time duration (e.g., 15 minutes, 60. minutes, etc.), the Emergency Director should not wait ~ntiLthe applicable, time has elapsed, but should declare the event as soon as it is detern:,ined thaJ the condition has e.xceeded, or will likely exceed, the applicable time. If an ongoing radiological release is detected and the release start time is unknown, it should be assumed that the release duration' .

specified in the IC/EAL has been exceeded, absent data to the contrary .

~

A planned work activity that results in an expected event or condition whicb meets or .

exceeds an EAL does not warrant an emergency declaration provided that 1) the activity proceeds as planned and' 2) the facili.ty remains within the limits imposed by the operatin*g license. Such activities' include *planned work to test, manipulate, repair, maintai*n; or modify a system or compcin.ent. In these cases, the controls associated with the planning, preparation, and exe'cutiori of the work will ensure that compliance is maintained with all asp'ects of the operating license provided that the actiyity proceeds and concludes as expected. Events or conditions of this type may be subject to the reporting requirements of 10 CFR 50.72.

The assessment of som~ EALs is based on the results of analyses thatare necessary to ascertain whether a specific EAL threshol_d has been exceeded (e.g., gaseous and liquid effluent sampling, etc.); the EAL and/or the associated basis discu~sion will identify the necessary analysis: In these cases*,-the declaration period starts with the

'availability of the analysis results that show the threshold to be exceeded (i.e., this is the time that the EAL* information is first available). * * *

While the EALs have been developed to address a full spectrum of possible events and conditions which may warrant emergency classification, a provision for classification based on operator/management experience and judgment is still necessary. The NEI 99-01 scheme provides the Emergency Director with the ability to classify events and Page 5

FCS 'i",:,i.

EP-FC-1001 Addendum 3 Revision 4 conditions based uponjudgmentusing EALs that are consistent with the ECL definitions (refer to PD-HU.3 and PD-HA3). The Emergency Director will need to determine if the effects or consequences of the event or condition reasonably meet or exceed a ;

particular ECL definition.

4.2 Classification Methodology To make an emergency classification, the user will compare an event or co~dition (i.e.,.

the relevant facility indications and reports) to an EAL(s) and determine if the EAL has been met or exceeded. The evaluation of an EAL(s) must be consistent with the Notes.

lfan EAL has been met or exceeded, then the IC is considered met and the associated ECL is declared in accordance with facility procedures ..

When assessing ~n EAL that specifies a time duration for the off-normal condition, the*.

EAL time duration runs concurrently with the emergency notification time duration. .

4.3 Classification of Multiple Events and Conditions When multiple emergency events or conditions are present, the user will idE;mtify all met or exceeded EALs.' The highest applicable ECL id~ritified during this review is deciared.

For example: . * * * ** * *

<If an Unusual Event EAL and an Alert EAL are met, an Alert should be declared.

There is no "additive" effect from multiple EALs meeting the same ECL. For example:

. If two Unu,sual Event EALs are met, ariUnu_sual Ever1t sho.uld b~ decl~red.

Related guidance concerning elassification of rapidly escalating events or conditions is provided iri Regulatory Issue Summary (RIS) 2001-02; "Clarificatibri of NRC Guidan'ce for Emergel)CY Notifications During Q_u_ickly Changing Even~s~"

4.4 Classification of Imminent' Conditions

Although EALs proyide specific thresho_lds, the Emergency D.irector must remain alert to events or conditions that could lead to meeting or exceeding an EAL within a relatively short period of time (i.e., a change in the ECL is IMMINENT). If, in the judgment of the Emergency Director, me*eting an EAL is IMMINENT, the emergency-classification should be* made as if the* EAL has been met While applicable to all ECLs, this approach is particularly important at the higher ECL since* it provides additional time for*

implementation bf protective measures.

Page*6

FCS EP-FC-1001 Addendum 3 Revision 4 4.5 Ernergency Classification Level Upgrading and Termination-An ECLmay be terminated when the event or condition that meets the IC and EAL no longer exists. } * * ** * *

As noted above, guidance concerning classification of rapidly escalating events or conditions is provided in RIS 2007-02. * **

4.6 Classification of Sh~rt-Lived Events Event-based ICs and EALs define a variety of specific occurrences that have potential or actual safety significance. By their nature, some of these events rnay be short-lived and, thus, over before the emergency classification assessment can be completed. If an event occurs that meets or exceeds an EAL, the associated ECL must be declared .

regardless of its continued presence at the time of declaration. **

4. 7 Classification of Transient Conditions Several of the ICs and/or EALs contained in this document employ time-based criteria.

These.criteria will require that the IC/EAL conc;litions be present for a defined period of time before an emergency declaration is warranted.* In cases where no time-based_

criterion is specified, it is recognized that some transient conditions may cause an EAL to be met for a brief period of time (e.g., a few seconds.to a few minutes). The*following guidance should be applied tothe classification of these conditions.

EAL momentarily met during expected facility response - In instances where an EAL is briefly met during an expected (normal) facilityrespdnse, an emergency declaration is not warranted provided that associated .systems, and components .are operating as expected, and operator actions are.performed-in accordance with procedures.

EAL momentarily met but the condition* is corrected prior to an* ernergency declaration -

If an operator takes prompt manual action _to: address a condition, an_d the action is successful in correcting the condition prior to the emergency declaration, then the applicabie EAL is' hot considered met and the associated emergency declaratio*n is hot required.* * **

It is import~nt to stress th_at the emergency classification assessment period is not a "grace period" durin_g which a _classification may be delayec:I to allow the perfo1111anQe of a corrective action that would obviate the need to_classify the event; emergency classification assessments must be deliberate and timely, with no undue delays .

Page 7

FCS, EP-FC-1001.Addendu~3 Revision 4 4.8 After-the-Fact Discovery of an Emergency Event or Condition In some cases, an EAL may be met but the emergency .classification was not made at the time of the event or condition. This situation can. occur when person11el discover that an event or condition existed which met an EAL, but no emergency was declared, and the event or condition no longer exists at the time of discovery. This may'be due to the event or condition not being recognized at the time or an error that was made in the emergency classification process.

In these cases, no emergency declaration is warranted; however, the guidance L

contained in NUREG-1022, "Event Report Guidelines 10 CFR 50.72 and 50.73," is applicable. Specifically, the event should be reported to the NRC in*accordance with 10 CFR § 50.72 within one hour of the discovery of the undeclared event or condition. The licensee should also notify_ appropriate State and local agencies in accordance with the agreed upon arrangement~.

4.9 Retraction of an Emergency Declaration Guidance on the retraction of an emergency declaration reported to the NRC is discussed in NUREG-1022.

5.0

5.1 REFERENCES

Developmental 5.1.1 NEI 99-01 Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, November 2012 5.1.2 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities 5.1.3 RIS 2007-02, Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events, February 2007 5.1.4 NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73 5.1.5 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors 5.1.6 NUREG-0654/FEMA-REP-1, Rev. 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants 5.1.7 10 CFR 72.32, Emergency Plan 5.1.8 NUREG-1567, Spent Fuel Dry Storage Facilities 5.1.9 10 CFR 50.4 7, Emergency Plans 5.1.10 NUREG-1140, A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees

Page 8

FCS EP-FC-1 oaf Addendum 3 Revision 4 5.2 Implementing

--5.2;1 Permaneritly Defueled Emergency Plan 5.2:2 EAL_ Comparaison Matrix 5.2.3 EAL Cla~sification Matrix 5.3 Commitments None

Page 9

FCS :** :

EP-FC-1001 Adderi'dum' 3 Revision 4 6.0 ACRONYMS & DEFINITIONS 6.1:- Acronyms .*

AOP .................................................................................. Abnormal Operating Procedure COE ....................................................................................... Committed Dose Equivalent CFR ..... :...... :: ............................................. ;.. :...*................. ,.. Code of Federal Regulations cpni .... :............ :............ :.... :. .'.... :: ........ :..... '. ...... .':......... :.... :..................... counts t>er Minute EAL .........................;........................................... :........................ Emergency Action Level

' '

I * *

ECL .................................................................. ;* ... ;........... Emergency Classification Level EPA ...................... :....................................................... Environmental Protectiqri Agency FAA*****,***********:****** ............................................... ,........... Federal Aviation Admi~istration FBl.*....... ,....... ;...: ...,.... ,................. ;................*.; ...*... ;., ..... ;... Federal Bureau of .lnvestig~tion FEMA ... ::.... :........................ :........... :........... :... Federal Emergency Management Agency HSM ........ :.*.... ::............... : .. :...................... :'. ..... ."....... ~ .............. .'. Horizontal Storage Module ISFSI ................. :.'. ..... :.; ................................ Independent Spent Fuel Storage Installation u: ...... lnitiatirig Condition

'; ' ~

IC ............................................. :.................................... :......... :....

mRem *

~:. ...........

J *;

... :' ... milli-Roentgen

~. . *

'EqUivaient Man MSL .................................................................... ;.................................... .Mean . *'* .

Sea Level NEI ************:********************************************************'.********:*********.:**:'.* .~ucl'3~r ErJergy l11stitute NORAD ............ ;....................................... North Am.erican Aerosp~ce D<3fense Command NRC .: .................... :...... ;.. '.: ............ ;....... i.:.::.: .. :..... :*... ;.:.:. Nuclear Regulatory Commission ODCM .............. :.............................. :......... :.........*.......... Off-site Do~e Calculation Manual ORO ...............................................................: ................ Off-site Response Organization PAG .............................................................................................. Protective Action Guide PD .................................................................................................. Permanently Defueled rem :.-..... :.................... '.......... :...... : ...:....... ;.: .. , .., ...................... :: .... Roentgen Equivalent Man TEDE .........'....... :................ :.: .... .'.. .'...........*..... :............ : ..... :Total Effective Dose Equi~alent USAR .; ..... :.*............................. :............ :...... ;.... ;' Final Safety Analysis Report as Updated

,.J

~- I' Page 10

EP-FC-1001,Addendum.3 Revision 4 6.2 Definitions The following definitions are taken from Title 10 CFR, and related regulatory* guidance documents .

. Alert

Events are *in progress or have occurred which involve an actual or potential substantial dE;!gradation of the level of safety of the facility or a security event that.

involves probable life threatening risk to site personnel or damage to site equipment

< because of HOSTILE ACTION. Any releases are expected to be limited to small* *

fractions *of the EPA PAG exposure levels.

Unusual Event* ..

.

Ev'ents are in progress or have occurred which indicate a potential degradation of

'* the level bf safety of the facility or indicate a security threat to facility protection has

~

b:een initiated. No releases .of radioactive material requiring offsite. response or monitoring are exp~cted unless further degradation of safety systems occurs .

.The following :key. terms are necessary for overaH understanding the NEI 99-01 em~rgency classification scheme .

Emergency Acti.on Level (EAL): A pre-determined, site-specific, observable threshold for an Initiating Condition that, when met' or exceeded, places the facil.ity in a given ECI'...

I . .

Emergency Classification Level*(ECL): One of a set of names or titles established

* *by' the Nuclear Regulatory Commission (NRG) for grouping off-normal events or *.

c;;onditions according to (1) potential or actual effects or consequences, and (2)

. . .~esulting onsite and offsite response actions. The ECLs, in ascending order of

. *~everity, are:* .

. Unusual Ev~nt

. Alert .

- Initiating Condition (IC): An event or condition that aligns with the definition of one of the? two ECLs by virtue of the potential or actual effects or consequences.

Selected terms used- in IC and EAL statements are.set.in all capital letters (e.g., ALL ..

CAPS). These words are defined terms that have specific meanings as used in this document. The definitions of these terms are provided below.

CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask barrier(s) between areas containing radioactive substances and the environment.

'Page 11

FCS EP-FC-1001 Addendum3 Revision 4 a

EXPLOSION: -A rapid, violent and* catastrophic failure of piece of equipment due to combustion, chemical reaction*or over pressurization. A release of steam (from high energy lines or components) or an electrical component failure (caus~d by short cjrcuits,* grou11ding; arqing, etc.) should not automatically be considered an ,.

explosion. Such events may require a-post-event inspection to determine if the attributes of an explosion are present.

FIRE: Combustion characterized by heat and light. Sources of smoke_ such as slipping' drive belt~ or overheated ~lectrical equipment do riot constitute FIRJ::S.

Observatbn of flame is preforred but is not required if large quantities of smoke and heat are observed. * **

HOSTAGE: A pe*r~on(s) held as leverageagainst the licensee to ensu~e thfit :

1 dem,ands will ~e met by the facility. *

HOSTILE ACTION: An act toward a facility or its personnel that includes the use of violent force to destroy equipment, t~ke HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used td deliver destructive force. Other acts that satisfy the *overall intent may be indluded'. HOSTILE ACTION should not be construed to include acts of civn'disobedierice or felonious acts .thalare not part of a

concerted attack on the facility. 'Non-terrodsm-based EALs should be used to address such activities, (i.e.; this may indude violent acts between individuals in the owner controlled area).

HOSTILE FORCE: One or more individuals who are engaged in a determined assault, overtly _or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

IMMINENT: The trajectory of events or conditions *is such tha.! an EAL will be. met within a relatively short period of time regardless of mitigation or-corrective actions.

INDEPENDENT SPENT FUEL STORAGE INSTALLATION .(ISFSI): A complex that is designed and constructed for the interim storage of spent n~clear fuel and other radioactive materials associated with sper,t fuel.storage.

NORMAL LEVELS: As applied to radiological IC/EALs, the highest reading in the past twenty-four hours excluding the current peak valu,e. '

OWNER CONTROLLED AREA (OCA): The property associated* with the facility and owned by the licensee. Access is normally limited to persons entering for official business.

PROJECTILE:* An- object *directed toward a facility that could cause concern for its continued operability, reliability, -or personnel safety. ' ' .

Page*12

EP-FC-1001 Addendum 3 Revision 4 PROTECTED AREA: The area normally within the facility security fence designated to impleme11t the security requirements of 10 CFR 73 ..

SECURITY CONDITION: Any Security Event as listed in the approved !:>ecurity contingency.plan that constitutes a threat/compromise to site security, threat/risk to site 'personnel, or a potential degradation to the levei of safety of the fadlity. A SECURITY CONDITION does not involve a*HOSTILE ACTION. . -

UNPLANNED: A parameter change or an event that _is* not: 1) the res.ult Qf an intended evolution; or 2) an expected facility response to a transient. The cause of the parameter change or 'event may be 'kno~n or unknown. ' .

VISIBLE DAMAGE: Damage to ~ component or structure that is readily observable without measurements, testing, or*analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected 9omponent or structure.

7.0 * . FCS-TO-NEI 99-01 EAL CROSS~REFERENCE

The following cross-reference tab.le

.. is provid~d

' . .. to.. facilitate association and location of a FCS EAL wi!hin the NEI 99_-01, Rev. 6 IC/EAL identification scheme. Further information reg~rding the development of the FCS EALs based on the NEI guidance can beJo_un:~ ,in ,the EAL Comparison. Matrix (Reference 5.2.2).

NEI 99-01, Rey. 6, AppendJx C .:...

FCS Permanently Defueled IC/EALs Permanently Defue"led Station ICs/EALs PD-Ru1* PD-AU1

* ,I.

PD-RA1 PD-M1 PD-RU2 PD-AU2 ,.

PD-RA2 PD-AA2

'PD-HU1 *

PD-HU1 PD-HA1 PD.,.HA1.

PD_-HU2 PD-HU2 *,

PD-HU3 ' * .PD-HU3 PD-HA3 PD-HA3 ...

PD-SU1 PD-SU1 -

NEI 99-01, Rev. 6, Section* 8 -

FCS ISFSI ICs/EAL ..

, . ;,i. ISFSI ICs/ EALs l* '.

E-HU1 ' E-HU1 Page 13

FCS EP-FC-1001 Addendurrf3 Revision 4 8.0 ATTACHMENTS 8.1 Attachment 1, Recognition Category PD EAL Bases 8.2 Attachment 2, Recognition Category E EAL Basis Page 14

EP-FC-1001 Addendum 3 Revision 4

Attachment 1 Recognition Category PD EAL Bases

Page 15

.FCS EP-FC-1001 Addenduni'.3 Revision 4 Recognition Category PD EAL Bases Recognition Category .PD (Permanently Defueled) provides a stand-alone*set of ICs/EALs for a permanently defueled facility to consider for use in developing a site-specific emergency classification scheme. For d_evelopment, it was assumed that the facility had operated under a 10 CFR Part 50 license and .that the licensee has permanently ceased power operations and removed fuel from the reactor vessel.

Further, the licensee intends*to store the spent fuel within the' perma~ently defueled facility for sorrie period of time.

When in a permanently defueled condition, the licensee typically ,receives approval from the NRG for exemptions from specific emergency planr:iing requirements*. These exemptions reflect the reduced radiological source term and risks associated with spent fuel pool storage relative to reactor at-pqwer operation. Source terms and accident analyses associated with plausible accidents are documented. in the facilities' Final,* '

Safety Analysis Report as Updated (USAR). As a result, FCS has developed facility-a

. specific emergency classification* scheme. using the NRG-approved exemptions, revised source terms, and revised accident analyses as documented in the.station's USAR.

Recognition* Category PD u~es the same ECLs as operating reactors; however, the

sourc;e term and accident analyses typically limit the ECLs to an Unusual Event and an Alert. The.Unusual Event ICs provide for an increa.sed awareness.of abnormal

conditions while the Alert ICs are specific to actual or po~entiaUmpacts to spent fuel.:.*:

The source terms and release motive forces associated with a permanently defueled ,

facility would not be sufficient to require declaration of a Site Area Emergency or ,. *..

General Emergency.

A permanently defueled station is essenJially a spent-fuel storage facility with th~ ~per.it fuel stored in a pool of water that serves as both a cooling medium (i.e.,; ren,qval of.:,.

decay heat) and shield fmm direct radiation. These primary functions of the spent fuel storage pool are the focus of the Recognition Category PD ICs and EALs; Radiological effluent ICs and EALs were included to provide a basis for classifying events that->

cannot be readily classified based on an observable events or facility conditions alone.

Appropriate ICs and EALs from Recognition Categories A, C, F, H, and S of NEI 99-01 were modified and included in Recognition Category PD to address a spectrum of the events that may affect a spent fuel pool. The Recognition Category PD ICs and EALs reflect the relevant guidance in NEI 99-01, Rev. 6 (e.g., the importance of avoiding both over-classification and under-classification). Nonetheless, FCS has developed its emergency classification scheme using the NRG-approved exemptions, and the source terms and accident analyses specific to FCS. Security-related events are also considered.

Attachment 1

l?age.16

FCS EP-FC-1001 Addendum 3 Revision 4 The following table, Table _PD-1: Recognition Category "PD" Initiating Condition Matrix, provides a summary of ICs associated with Recognition Category PD.

Table PD-1: Recognition Category "PD" hiltiating Condition Matrix UNUSUAL EVENT ;

ALERT PD-RU1 Release of gaseous or liquid PD-RA1 Release of gaseous or liquid

. radioactivity greater than 2 times the radioactivity resulting in offsite dose ODCM limits for 60 minutes or longer. greater than 10 mRem TEDE or 50

.. mRem thyroid COE ..

PD-RU2 UNPLANNED rise in. facility PD-RA2 UNPLANNED ril3e in facility .

radiation levels. ' radiation levels that impedes faqility access required to maintain spe.nt fuel integrity. * **

PD-HU1. Confirmed SECURITY PD-HA1 HOSTILE ACTION within the CONDITION or threat. OWNER CONTROL!-ED AREA or

airborne attack threat within 30 minutes PD-HU2 Hazardous event affecting equipme*nt necessary for* spent fuel cooling.* *. ",,

PD-HU3 Other conditions exist which in PD-HA3 Other conditions exist which in the judgment of the Emergency Dfrector

the judgment of the Emergency Director warrant'declaration of an Unusual Event. warrant declaration of an Alert.

PD-:-SU1 UNPLANNED spent fuel pool temperature rise. *

Attachment 1 Page 17

FCS ..

EP-FC-1001 Addendum,3 Revision 4 PD-RU1 Unusual Event Onitiaii'n9 Gonditio'n; ::*'

Release of gaseous or liquid radioactivity greater than 2 times the Offsite Dose Calculatio.n Manual (ODCM) limits f,or 60 minutes or longer.

Notes:

The Emergency Director. should declare the event promptly upon determining that the'applicabie time has been exceeded, or will likely be exceeded.

If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes.

If the effluent flow past an effluent n:ionitor. is known to have stopped oue to actions to isolate the release path, then the effluent monitor reading is no longer valid for

classification purposes.

1. Reading on ANY Table R1 effluent monitors greate,rthan 2 times the alarm setpoint established by a current radioactive release discharge*.,permit for 60 minutes. or.

longer. * *

. Table R1 Effluent Monit9r Thresholds * .,- "

., ** 1

. Effluent Monitor . ' Description Value \. ',

RM-052 (aligned to Aux. Building stack) AB Stack (gas) .. 2 X H(gh Alarm, RM-062 AB Stack*(gas) 2 X High Aiarm RM-055 (if discharge not isolated)

Liquid Discharge Header 2 X High Alarm'. -

OR

2. Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times the ODCM limits for 60 minutes or longer.

7. ~ - - ~ - - - - - -

.",. ~

, ' ,, t , ~. '*

This IC addresses a potential decrease in the level of safety of the facility as indicated by a low-level radiological release that exceeds regulatory commitments for an extended Attachment 1

. Page 18

FCS, EP-FC-1001 Addendum 3 Revision 4

,period of time (e.g., an uncontrolled release). It includes any gaseous or liquid radiological release, 'monitored or un-monitored, including those for which a radioactivity discharge permit is norm.ally prepared.

Fort Calhoun Station incorporates design features intended to control the release of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, *and to control and monitor intentional releases. The occurrence of an extended, uncontrolled radioactive release fo *the environment is indicative of degradation in these features and/or controls.

Radiolog'ical effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified* on the basis of facility conditions alone. The inclusion of both facility condition a11d radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due t6 actions to isolate the release path, then the effluent monitor reading is no longer valid fo(classification purposes. . . ' .

Releases should not be prorated or averaged> For example', a release exceeding 4 times

*release limits for 30 minutes does not meet the EAL.

EAL #1 addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This EAL will typically be associated *With planned

batch releases* from non-continuous* release pathways(e.g., radwaste*, waste gasJ; *

EAL #2 addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in riverwater systems, etc.).

Escalation of the emergency classification level would be via IC PD-RA 1.

[Basis :

Reference:

1. NEI 99-01 Rev. 6, PD-AU1 d *.. ,**, :*

Attachment 1 Page.19

FCS EP-FC-1001 Addendum*3 Revision 4 PD-RA1 IErriergencx Classification,_L_*e_v_e_l:'-~--------- J Alert'

[iiitiatihg Condiyo_11~:_*~-----*_-~_._*:~-",~**-~_*__ - ~ - - ~

Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mRem TEDE or 50 mRem thyroid COE.

Notes:

.* Th~ E'rnergen~y Director should dedare the event promptly upon determining that the applicaple, tirne has be,~n exceeded, or wiH likely be exceeded.

If an ongoing release is detected and the: release start time is unknown, assume that the release duration has exceeded 15 minutes. * *

;If the effluent flow pa.st an effluent monitor is known to have stopped due to actions

to isolate the release path, then th~ effluent monitor reading is no longer valid for

.classific~tion purposes.. . *,:*-

The pre-calculated effluent monitor values p'resented in EAL #.1 should be used for emergency classification assessments until the results from a dose assessment t using actual meteorology are available.* .*

1. A valid reading on ANY Table R2 effluent monitor greater than the value shown for 15 minutes cir longer:

Table R2 ~ Effluent Monitor Thresholds ...,, .

Effluent Monitor '.: ., Qescription . Value '* ,.

RM-052 (aligned to Aux Building stack) AB .Stack (gas) *

9 x 106 cpm ** *

RM-062 ,

AB Stack (gas) 9 x 106 cpm RM,055 (if discharge* not isolated) . :Liquid Discharge Header

9 x 106 cpm OR

2. Dose assessment using actual meteorology indicates doses greater than *10 mRem TEDE or 50 mRern thyroid COE at or beyond the site boundary.

OR ' . . .

3. Analysis of a liquid effluent sample indicates a *concentration or release rate that would result in doses greater than 10 mRerri TEDE or 50 mRem thymid COE at or*

Attachment'1 Page20

FCS ,,

EP-FC-1001 Addendum 3 Revision 4 beyond the site boundary for one hour of exposure.

OR

4. Field survey results indicate EITHER of the following at or beyond the site boundary:

Closed window dose rates greater than 10 mRem/hr expected to contjnue for 60 minutes or longer.

Analyses of field survey samples indicate thyroid COE greater than 50 mRem for one hour of inhalation: .

!Basis:* ,. * * * .* <* _*--"-* - _J This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnit1:1de represent an actual or potential*substantial 'degradation of the level of safety of the facility as indicated by a* radiological release that significantly exceeds regulatory limits (e.g., a significantuncohtrolledrelease); * *. * - **

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that -cannot be readily or appropriately classified on the basis of facility conditions alone. The inclusion of both facility condition and* radiological effluent EALs more fully addresses the spectrum of possible ac~ident events and conditions.*

The TEOE dose is set at 1% of the EPA PAG of 1000 -mRem while the 50 mRem thyroid COE was established in consideration of the 1:5 ratio of the EPA PAG for TEOE and thyroid .COE. . : }.

Classification* based on *effluent n:,onitor rea,ding~ aSSl/mes that a release path to the environment is established; If the effluent flow past an effluent monitor is known to have

~topped d_ue to actions to isolate*the 'telease path, then the effluent 'monitor reading is *no longer valid.for classification.purposes. *

The thr~shold value for RM-052 ~as.determined via Calculation FC08515. The RM-052 reading that corresponds to the 10 mRem TEOE (1.1 x 108 cpm) threshold exceeds the maximum count rate for the monitor (1 x 107 cpm). Based on the guidance presented in NEI 99-01, Rev. 6 the EAL threshold value is set at 90% of the maximum monitor reading, corresponding to 9 x 106 cprr,.

The threshold value for RM~062 wa~- determined via Calculation FC08515. The RM-Op2 reading that corresponds to the 10 mRem TEOE (9.3 x 107 cpm) threshold exceeds the maximum count rate for the monitor .( 1. ~, 1,07. cpm ). Based on the g.uidance presented in NEI 99-01, Rev. 6 the EAL threshold value is set at 90% of the maximum monitor: reading,

.* ' a*,> , * *' , ' '

Attachment 1 Page 21

FCS EP-FC-1001 Addendum'3 Revision 4 corresponding to 9 x 106 cpm.

The threshold value for RM-055 was determined via Calculation FC085,16. Tile RM-055 reading that corresponds to the 10 mRem TEDE threshold exceeds the maximum count

rate for the monitor ( 1 x 107 cpm ). Based on the guidance presented in NEI 99:-01, Rev.

6 the EAL threshold value is set at 90% of the maximum monitor reading, corresponding to 9 x 106 cpm.

--**,-1

~- ..

1. NEI 99-01 Rev. 6, PD-AA 1

2. Calculation FC08515

3. Calculation FC08516 Attachment 1 Page-22

EP-FC-1001 Addendum 3

~** ' '{,. '*. Revision 4 PD:..RU2 rr*--*-------------- ----- . - - --------.----. . - - . ****----------*-----------.,

JEmergency Classification Leyel: * --*-------------- ' ____ .

_ _ __ .__ .____ . ___J Un~~ual Event ij-***---- - -- ------------------------------*-----------------------------

lnifurting Condition:_ .____ . __ .______ . ______ *--------- *. . _______

_____ -_!

UNPLANNED rise in facility radiation levels.

r.-*---------------****---- - - - - - - - - - - .... ----*-**---- - - - - - * - - - - - - . - - . - - - --------*---------,

LEmergency Action Level(EAL)~(1 or*2)_____________

___* * . - - - - - 1

1. a. UNPLANNED water level drop to below the normal range in the spent fuel pool as indicated by the following:

LT-2846 (Spent Fuel Pool Level)

Ll-2846 (Local Indication)

AND

b. UNPLANNED rise in area radiation levels as indicated by a valid reading on ANY radiation monitor in Table R3.

Table R3 - Radiation Monitors RMS Area Monitored RM-80, 85, 87 Spent Fuel Storage Area Radiation Monitor Portable Area Auxiliary Building near fuel handling areas Rad Monitor OR

2. Area radiation monitor reading or survey result indicated an UNPLANNED rise of 25 mRem/hr over NORMAL LEVELS.

lBasis: _. -----*-------*-*---

__._________________ . __________________ - ______ --~ ---~-~--=--~~!

UNPLANNED: A parameter change or an event that is not: 1) the result of an intended evolution; or 2) an expected facility response to a transient. The cause of the parameter change or event may be known or unknown.

NORMAL LEVELS: As applied to radiological IC/EALs, the highest reading in the past twenty-four hours excluding the current peak value .

Attachment 1 Page 23

FCS EP-FC-1001 Addendum:,3 Revision 4 This IC addresses elevated radiation levels caused by a decrease in water level above irradiated (spent) fuel or other UNPLANNED events. The incre?l_sed .radiation levels are indicative of a minor loss in the ability to control radiation* levels within the *tacility or radioactive materials. Either condition is a potential degradation in the level of safety of the facility.

A water level decrease will be primarily determined by indications from available*'1evel instrumentation. Other sources of level indications may include reports from personnel or

video camera observations (if available). A significant drop in the water level may also cause a rise in the radiation levels of adjacent areas that can be detected by monitors in those lo9ations.

The effects of planned evolutions should be considered. Note that EAL #1. is applicable only in cases'where the elevated reading is due to' an .UNPLANNED water level drop.

EAL #2 excludes radiation level increases that result from planned activities* such as the use of radiographic sources and movement of radioactive waste materials.

Escalation of the emergency classification level would.be via. IC PD-RA1 or PD~RA2.

1. NE;I. 9*9-01 Rev. 6, PD-ALJ2

Attachment 1 Page,24

FCS EP-FC-1001 Addendum 3 Revision 4 PD-RA2

~_Emtirgen~Y-C_ iassificatfo[I_Leyek* _*

-~-=~--'--'--~~ -'-'-~ - " . ' ~ - - . ~' -.. ** :J Alert jlnitiatin_g Condition: .

UNP.LANN~D rise Jn facility radiation levels thpt impedes facility access required to

. maintain spent fuel ' .

integrity.

IEmergenc}! Action Level (.~AL)~Jt 0_(2)-

1 ... UNPLANN.ED dose rate greater th~n 15 hi Rem/hr in ANY of the. following areas requiring continuo.us occupancy to. maintain control of radioactive* material or operation of systems needed to.maintain spent fuel integrity. * ** *

Main Control Room .

.Central Alarm Station

OR

2. Area Radiation Monitor readings or survey results indicate an UNPLANNED rise by 100 mRem/hr over NORMAL LEVELS that impedes access to ANY of the following areas needed to maintain control of radioactive material or operation of systems needed to maintain spent fuel integrity.

Room 4

Room 5

Room 24

Room 25

Room 26

Room 69

[~asis:

NORMAL LEVELS: As applied to radiological IC/EALs, the highest reading in the past twenty-four hours excluding the current peak value.

UNPLANNED: A parameter change or an event that is not: 1) the result of an intended evolution; or 2) an expected facility response to a transient. The cause of the parameter change or event may be known or unknown.

This IC addresses increased radiation levels, as discussed in NEI 99-01, that impede necessary access to areas containing equipment that must be operated manually or that Attachment 1

-Page 25

/

FCS EP-FC-1001 Addendum*~3 Revision 4 requires local monitoring in order to maintain systems needed to maintain spent fuel integrity. As used here, "impede" includes hindering or interfering, provided that the interference or delay is sufficient to significantly threaten necessary facility access. It is this impaired access that results in the actual or potential substantial degradation of the level of safety of the facility.

This IC does not apply to anticipated temporary increases due to planned events ..

re:--------.-------------------- *-*-*- * - - - - - - - ----.-**- -*-* **---*-* ----- **--

,Basis.

Reference:

. * * . ** ** * * - . . * . *. * *i L------*------------.---------~--- . -~--~----------~

1. NEI 99-01 Rev. 6, PD-AA2 Attachment 1 Page26

FCS EP-FC-1001 Addendum 3 Revision 4 PD-HU1

~gene~ Classification Level: :. .,----.,-,---,._*-,--

.. _ - ~ . *l Unusual Event

[!!litiatiri~(Condition:. - * .*-. . I

,1\.

Confirmed SECURITY CONDITION or threat.

[Emerge hey A~t.ion Level (EAL)L(1_o_r_,2_o_r_3-)_-_ _ _ _ __

1. A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the Security Shift Supervisor.

OR

2. Notification of a credible security threat directed at the site.

OR

3. A validated notification from the NRC providing information of an aircraft threat.

---~--~-----.---~**J HOSTAGE: A person(s) held as leverage against the licensee to ensure that demands will be met by the facility.

HOSTILE ACTION: An act toward a facility or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the facility. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).

PROJECTILE An object directed toward a facility that could cause concern for its continued operability, reliability, or personnel safety.

SECURITY CONDITION: Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the facility. A SECURITY CONDITION does not involve a HOSTILE ACTION.

Attach.ment 1 Page27

FCS . ,;'_

EP-FC-1001 Addendum.3 Revision 4 This IC addresses events that pose a threat to facility personnel or equipment necessary to maintain spent fuel integrity, and thus represent a potential degradation in the level of facility safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR § 73. 71 or 1b CFR § 50. 72. s*ecurity events assessed as HOSTILE ACTIONS are classifiable under IC PD-HA 1..

Timely and accurate communication between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.. Classification of th~se events will initiate appropriate. threat-related notifications to. site personnel and Off-Site Response Organizations. * **

Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan; Safeguards Contingency Plan

'[and Independent Spent Fuel Storage Installation Security

. Program]. .

EAL #1 references Security Shift Supervisor because these are the individuals trained to confirm that a security event is occurring or has occurred. Training on security event confirmation and classification is controlled due to the nature of Safeguards ,and 10 CFR

§ 2.390 information. * * * * **

EAL #2 addresses the receipt of a credible security threat. The credibility of the threat is

assessed in accordance with 'SY-FC-101-132, Security Assessment and Response to Unusual Activities.

EAL #3 addresses the threat from the impact of an aircraft on th*e *facility.The NRC Headquarters Operations Officer (HOO) will co.mmunicate to the licensee if the t~reat involves an aircraft. The status and size of the.pla'ne may also be provided.by NORAD through the NRC. Validatfon of the threat is performed in accordance 'with Aop.:37, Security Event~. * ** * * * * * * '

Escalation; of. the emergency classification

. level would be via IC PD-HA.

1.

1. NEl_99-01 Rev. 6, PD-HU1 Attachment 1

.*Page 28 *

-FCS EP-FC-1001 Addendum 3

Revision 4 PD-HA1

-~

Alert r=-lln. . ,i:--:-:ti,-a-=ti_n_g_.. . ,c=-o_n_d-="i-ti_Q_n*~=----"-----,-----'-----'--~-'------------,-C--_

_ -------i

~-~~---~--'--'---'-,-I

'Host*ILE A.CTION within the OW°r~JER CONTROLLED AREA or airbor~e attack.threat within 30 minutes.

IEm'ergAACyfation Level(EAL)~(t' or 2)_.*_ _

1. A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED

.AREA . .

as :reported by the $ecurity

. . Shift Supervisor. .

OR.

2. *A validated notific~tion from NRC of an aircraft attack threat within 30 minutes 'of the site.

!Basis:*.*

will be n:1et by.t~e facility.

__ ;_*--:--*- - ~ - - - . - - ' - - - " - -

HOSTAGE: A person(s) held as leverage against the licensee to ensure that demands HOSTJ LE ACTION:. Ari act toward ~- facility or it~ personnel that include~ the u~e qf violent force Jo destroY, equipment,. take HOSTAGES, and/or iri_timidate the licensee to achieve an end. This includes attack by air,*1and, or wafer using guns, explosives, PROJECTIL_ES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be constru_ed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the facility. Non-terrorism-based EALs should be used to address such activities (i.e:, this may include violent acts between individuals in the owner controlled area):

HOSTILE FORCE: One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

OWNER CONTROLLED AREA (OCA): The property associated with the facility and owned by the licensee. Access is normally limited to persons entering for official business.

PROJECTILE: An object directed toward a facility that could cause concern for its continued operability, reliability, or personnel safety .

*f ttachment 1

Page 29

FCS EP-FC-1001 Addendum*':3 Revision 4 PROTECTED AREA: The area normally within the facility security fence designated to implement the security requirements of 10 CFR 73.

This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat.* This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the facility and staff for a potential aircraft impact.

Timely and accurate communication between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.

Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan {and Independent Spent Fuel Storage Installation Security Program].

As time and conditions allow, these events require a heightened state of readiness by the facility staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The Alert declaration will also heighten the awareness of Offsite Response Organizations (OROs), allowing them to be better prepared should it be necessary to consider further actions.

This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.

EAL #1 is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action directed against the ISFSI.

EAL #2 addresses the threat from the impact of an aircraft on the facility, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notification*s are made in a timely manner so that onsite personnel and OROs are in a heightened state of readiness. This EAL is met when the threat-related information has been validated in accordance with AOP-37, Security Events.

The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may be provided by NORAD through the NRC.

In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or

, Attachment 1 Page 30

FCS EP-FC-1001 Addendum 3 Revision 4 NRG. The emergency declaration, including one based on other ICs/EALs, should not be

unduly delayed while awaiting notification by a Federal agency.

~a~is

Reference:

___~---~------__ ______ _________________

_______ *~----- 1

1. NEI 99-01 Rev. 6, PD-HA 1

Attachment 1 Page*31

FCS EP-FC-1001' AddendulTI 3 Revision 4 PD-HU2

.lJnusual, Event.

[Ditiating: Co*ndition: .:. . *. _. . .*.. * * :_**_>_*.-*~*,--~-~-* ~i-,.-,:-\~-~*-*._*~*_ _ _ _ _ *. : ]

Hazardous event affecting equipment n~cessary for.spent fuel cooling.

~

~merg_~nc~ Action: Level (EA~}-;*-- -~. -"'---.c.._-,..-'-'-,,- ~~._..,---...:....,J

1. a .. The occurrence of ANY of thedollowing hazardous events: .

.* S.eismic event (earthquake)

Internal or external flooding event: .*

High winds or tornado strike

FIRE.,

- EXPLOSION . .

- Low; river lev~I as indicated by. less. than Q76 feet, 9 inches MSL elevation

Other events with similar hazard characteristics as determined by the. Shift Manager

AND

b. The event has,damaged at least.one train.of a ~ystem nee9ed for.spent,ft,Jel cooling. * ** * * * * ** *

AND

c. The damaged equipment cannot, or potentially cannot, p~rform its design .

function based on EITHER:

Indications of degraded performance

VISIBLE DAMAGE tEfasis:: .* * ..*.* *

~--~-* --- .~-~-- J EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or over pressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion. Such events may require a post-event inspection to determine if the attributes of an explosion are present.

Attachment 1

Page32

.,=cs EP-FC-1001 Adctendum 3

.;:. ~ -.. Revision 4 FIRE: .Combustion characterized by heat and light. Sources of smoke such as slipping drive belts 'or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.

VISIBLE DAMAGE: Damage to a component or structure that is readily ob~ervable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the af(ected compon.ent or structure. * * **

This IC addresses a hazardous event .that 6auses damage to at least one train, of equipment needed for spent fuel cooling. The damage must be of sufficient magnitude that the system(s) train cannot, or potentially cannot, perform its intended function. This condition reduces the margin to .a loss or. potential. loss of the fuel clad barrier, and therefore represents a potential degradation bfthe level ofsafety of the facility.

For EAL 1.c., the first bullet addresses damage to equipment that *is in service/operation since indications for it will be readily available. * '*

For EAL 1.c., the second bullet addresses damage to equipment that is not in service/operation or readily apparent through indications alone. Operators will make this

determination based on-the totality.of available event-and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.

Escalation of the emergency classification level could, depending upon the event, be based on any of tHe ALERT ICs: PD-HAf,'P[f.HA2, PD-HA1, or Pb-HA3

[Basis*

Reference:

1. NEI 99-01, Rev. 6, PD-HU2 .

.. Attachment, 1 Pag~33

.Fcs.

EP-FC-1001 Addendum 3 Revision 4 PD-HU3

.. ,---~--~--.-.~::~~-~-~.*=.\.--<---.~::~,J

~[filii'.ii~m~e-r-g-~-n-c~i*-::C-la-s~s~.i~fi_c_m-.io-n--_--l-_e~v-e-k-.~.~

Unusual Event

. -,--._- ~.

[initiatirig:Condition:.

Other conditions exist which in the judgment of the Emergency Director warrant -

declaration of an Unusual Event.

.1. Other.conditions exist which in the judgment of the Emergency Director indicate that events are, in progress or have occurred which indicate a potential degradation of the level of safety*of the facility or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or: monitoring are expected .unless further degradation of systems needed fo maintain spent fuel cooling occurs. * * **

~~.'.-':':~:._... -~-- ,- ~~_,*:*~ :L:~:::.*)G*:.*:3*. _ :,:~

,This* 1c addresses. unanticipated conditibns not addressed explicitly eise~here but that warrant declaration of an emergency because conditions exist which are-believed by the Emergency Director to fall -under the emergency dass_ification l~vel description for an Unusual Event. * ** * * *

1. NEI 99'-01, Rev. 6, PD-HU3

. Attachment 1 Page 34

FCS-, *,

EP-FC-1001 Addendum 3

,}-. . i .:: . , Revision 4 PD-HA3

~gene~ Classification Level: . *, :. *-.,..

'h ,:"

... *1-Alert

[inffiating

~---~ Condition:*.*.

~--~-~-----"*----~----

Other conditions* exist which in the judgment of the EmergencyDirector warrant

declaration of an Alert.

1. Other conditions exist which, in .the judgment of the Emergency Director, indicate that events are

in

progress or have occurred which involve

an actual or* potential substantial degradation of the level of safety of the facility or a security event that

. involves probable life threatening. risk to site personnel or damage.to*site equipment because. of HOSTILE ACT,ION. Any releases are expected to be limited to* small fractions of the EPA Protective Action Guideline exposure levels.

~asis:.,. *. ...:.:...,._____~ . : ,

' . .. ---*- ~~~-

HOSTAGE: A person(s) h.eld a,s leverage agai.nst the licens~e to ensure that.demands

. will Qe met by the facility: **. . . ' * * .. . . I .

HOSTILEACTION: An act toward a facility or*its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that, satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the facility. Non-terrorism-based EALs should be used to address such activities (i.e., this

may include violent acts between individuals in the owner controlled area).

PROJECTILE: An object directed toward a facility that could cause concern for its continued operability, reliability, or personnel safety.

This IC aqdresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an Alert.

1. NEI 99-01, Rev. 6, PD-HA3

. Attachment 1

Pag~35

FCS EP-FC-1001 Addendum 3 Revision 4 PD-SU1 fi::~*:.--: --

~gency Classification Level:

- - - > ~

.* *. *_j

> **---i Unusual Event

[ln]tiating~dition:. * *____ * ;-: ____ . _________ . - - ...

_* ___ . *. *. _____ *.

___ **: _____ ,____ _ i UNPLANNED spent fuel pool temperature rise.

((rnergen~y_Actiq_n~eveL{EAL)L *

____ * * *_*-'------~-~_;________________:_ *~---*_:

1. UNPLANNED spent fuel pool temperature rise to greater than 150 °F as indicated on T408A/B/C or locally by handheld instrument.

[Basis: -. _ * .-_ -.-_~.- ______ - ~ ._* .

__ *

_ ~----- * . _ * . __ : , _______ !

UNPLANNED: A parameter change or an event that is not: 1) the result of an intended evolution; or 2) an expected facility response to a transient. The cause of the parameter change or event may be known or unknown.

This IC addresses a condition that is a precursor to a rriore serious event and represents a potential degradation in the level of safety of the facility. If uncorrected, boiling in the pool will occur and result in a loss of pool level and increased radiation levels.

Escalation of the emergency classification level would be via IC PD-RA 1 or PD-RA2.

~asis

Reference:

- - - - ~ - - - - - - - - ~ -

~---------------

i

.J

1. NEI 99-01 Rev. 6, PD-SU1 Attachment 1 Page-36

FCS EP-FC-1001 Addendum3

,[~ ' ',l "".~* ' ' I * '

Revision 4 Attachment 2

-~ecogniti()n Category .E-EAL Basis.

, Page 37

Attachment 2 Recognition Category E EAL Bases

Recognition Category E EAL Basis

Recognition Category E provides a set of ICs/EALs for an ISFSI. An ISFSI is a_ complex that is designed and constructed for the interim storage of spent nuclear fuel and 0th.er radioactive materials associated with spent fuel storage. A significant am*ount of' the radioactive material contained within a cask must escape its packaging and enter the atmosphere for there to be a significant environmental effect resulting from an accident involving the dry storage of spent nuclear fuel. Formal offsite planning is not required because the postulated worst-case accident involving an ISFSI has . insignificant consequences to the public health and safety. *

An Unusual Event is declared on the basis of the occurrence of an event of.~uffici~nt magnitude that a loaded cask confinement boundary is damaged or violated. This includes classification based on a loaded fuel-storage cask confinement boundary loss leading to the degradation of the fuel during storage or posing an operational* safety problem with respect to its removal from storage.

Table E-1: Recognition Category "E" Initiating Condition Matrix UNUSUAL EVENT E-HU1 Damage to a loaded cask CONFINEMENT BOUNDARY.

i,

Attachinent2 Page*-38

Attachment 2 Recognition Category E EAL Bases

[Emerger:ic}! qassificatio_n 'Level:

UhusLial Event

E-HU1

=1 l

),,' .

Damage to a loaded cask CONFINEMENT BOUNDARY..

~n,e~gencyActiora Leve.I (EAL}: . ; .: .* * -~--:_*_--~~--~--'-----"~-~....:---.

1. Damage to a loaded cask.CONFINEMENTBOUNDARY as indicated by an on-contact

radiation.reading:

=:: 1600 mRem/hr (gamma + neutron) on the Horizontal Storage Module (HSM) front surface

OR

~ 400 mRem/hr (gamma + neutron)*

on the tiSM door centerline

OR

~ 16 mRem/hr (gamma + neutron) on the end* shield wall exterior

~=-.-- --. :_* :. ,. :-- _,.-.~-. *. _*__*.:._____~-~- ... ,-.:*-*-*1. J CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask barrier(s) between areas containing radioactive substances and the environment.

INDEPENDENT SPENT FUEL STORAGE INSTALLATION {ISFSI): A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.

This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage cask is sealed. The issues of concern are the creation of a potential or actual release path to the environment, degradation

of one or more fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the cask or fuel from storage.

The existence of "damage" is determined by radiological survey. The radiation limits listed in the EAL reflect 2 times the cask technical specification for radiation level. The technical

specification multiple of "2 times" is used here to distinguish between non-emergency and

Attachment 2 Page39

Attachment 2 Recognition Category E EAL Bases emergency co.nditions:The emphasis for this classification is the degfadation in the level

of safety of the spent fuel cask and not the magnitude of the associated dose or dose_.

rate .. It is recognized that iri the case of extreme damage to a loaded cask, the fact that the "on-contact" dose rate limit is exceeded may be determined based on measurernent of a dose rate at some' distance from the cask.

Amendment number 9 to COG 1004 Technical Specifications for the Standardized NUHOMS Horizontal Storage Module System contains radiation dose levels for the dry storage cask that should not be exceeded based on whether the dry _storage cask is being

transported inside the fuel transf~r cask or it is. stor~d in the horizontal storag~ module.

Based on the guidance contained in .NEI 99-:01, Rev. 6, an Unusual Event' is warranted for radiation levels of twice the Technical' Specification value; the values chosen for EAL E-HU1 represent these values.

Security-related events for ISFSls are covered under ICs PD-HU1 and PD-HA 1.

- - - - --~ -----*-*- --------*----***----------------*--

~Basis

References:

1. NEI 99-01, Rev. 6, E-HU1 . . , . . . . .

2. Amendment 9 to COG 1004 Technical Specifications for the Standardized NU HOMS

. Horizontal Storage Module. System

.( .

Attachment 2 Page 40

Summary of Changes for, EP-FC-1001 Addendu111 4 . ,

This\ummary of changes, is alisting of all the lndu'stry Decommissioning Cornmitments.(IDSs)° and Staff Decommissioning A~s~mptions (SDAs) Comparis~n,changesthathave

. . ' .. . ~ .

been made. ..since the .originai NRC submittal for PDEP. A cover page, table of conten~s, introduction, prqc~dure header, and page numbers were also added to the document. The NRC approved the Permanently Defueled Emergency Plan (PDEP) on December 12th,*2017 by Amendment No. 295. effective April 7, 2018 and this amendment shall be.

implemented within 90 days of the effective date. PORC app*roved the PDEP submitted to the NRC 'cm December 16, 2016 and this summary only covers changes made since that time. EP-FC-1001

a Addendum*4 is new procedur~ that is bein~* issue'd to ensure commitments related to the PDEP are not inadvertently deleted until the ISFS1only Emergency Plan is implemented.

Summary:

USAR was changed to DSAR.

EP-FC-112-100-F-01 title changed from "Command and Control Checklist- Control Room" to f'Shift Manager Checklist.

EP-FC-122 Drill .;ind Exercis~s cha~ged to EP-_FC-2001-DRILL.

Training requirements listed in EP-FC-10 were moved intoTQ.:.Dc:.:FC-113 ERO Training and Qualification and the ERO Training and Qualification procedure number changed from TQ-FC-113 to TQ-DC-FC-113 The title Non-Certified Fuel Handlers was changed to Non-Certified Operators OCAG-3 was deleted as RCS is no longer "intact" OP-AA-201-010-1001 was changed to OP-FC-201-010-1001 EP-FC-11 Operation Stations Emergency Preparedness Process Description was deleted and all relevant information was move to EP-FC-2001, Emergency Plan Administration HU-AA-104-101 was changed to HU-FC-104-101 The term Emergency Feedwater Storage Tank was removed as we no longer credit it.

The term General Emergency was removed and replaced with Alert 'as this is the highest classification that can be reached in the PDEP.

Updated SFP system walk down information to ensure operator logs are taken once per.

References:

1. LIC-17-0047, PCS Response to Request for Additional Information (RAI)

2. NRC Docket No. 50-285 OPPD PCS Unit No. 1 EP Exemption (MLl 7263Bl98)

3. NRC Amendment No. 295 to Lice,nse No. DRP-40 PDEP and EAL approval

(MLI 7276B286)

4. Letter from OPPD (S. M. Marik) to USNRC (Document Control Desk), "License Amendment Request 16-07: Revise the Fort Calhoun Station Emergency Plan to the Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme" dated December 16, 2016 (LIC-16-0108) (ML16351A464)

(CAC MF8951)

5. OPPD Letter (S. Marik) to USN RC (Document Control Desk) - "Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR Part 50, Appendix E," dated December 16, 2016 (LIC-16-0109) (ML16356A578) (CAC MF9067)

6. Letter from OPPD (S. M. Marik) to USN RC (Document C,ontrol Desk), "License Amendment Request (LAR) 16-02: Revise the Fort Calhoun Station Emergency Plan to Address the Permanently Defueled Condition," dated September 2, 2016 (LIC-16-0076)

(ML16246A321) (CAC MF8326) . , .

FCS

EP-FC-1001 Addendum 4 Revision 0 OPPD NUCLEAR PDEP Industry Decommissioning Commitments (IDCs) Comparison

Staff Decommissioning Assumptions {SDAs) Comparison

Page 1 of 17

FCS TABLE OF CONTENTS EP-FC-1001 Addendum 4 Revision 0 Introduction Page 3 Section 1 PDEP Industry Decommissioning Commitments (IDCs) Comparison Page4 Section 2 PDEP . Staff Decommissioning Commitments (SDAs) Comparison Page 13 Commitments:

AR 676SB*(Delete Commitment with the implementation of the approved ISFSI Only Emergency Plan)

Page 2 of 17

I FCS

EP-FC-1001 Addendum 4 Revision 0 INTRODUCTION NUREG-1738 identifies beyond design basis seismic events.as the dominant contributor to*

events that could result in a loss of SFP coolant that uncovers fuel for plants in the Central and Eastern United States. Additionally, NUREG-1738 'identifies a zirconium fire resulting from a substantial loss-of-water inventory from the SFP, as the only postulated scenario at a decommissioning plant that could result in a significant offsite radiological release.

The scenarios that lead to this condition have very low frequencies of occurrence (i.e., on th~*

order of one to tens of times in a million years) and are considered beyond design basis events because the SFP and attached systems are designed to prevent a substantial loss of coolant inventory under accident conditions. However, the consequences of such accidents could potentially lead to an offsite radiological dose in excess of the EPA PAGs at the EAB.

The risk associated with zirconium cladding fire events decreases as the spent fuel ages, decay

. time increases, decay heat decreases, and short-lived radionuclides decay away. As decay time increases, the overall risk of a zirconium cladding fire continues to decrease due to two factors:

1) the amount of time available for preventative actions increases, which reduces the probability

that the actions would not be successful; and

2) the increased likelihood that the fuel is able to be cooled by air, which decreases the reliance on actions to prevent a zirconium fire.

FCS has demonstrated that no credible accident will result in radiological releases requiring offsite protective actions. Additionally, there is sufficient time, resources and personnel available to initiate mitigative actions that will prevent an offsite release that exceeds EPA PAGs. Design and operation of the FCS SFP has been evaluated against the industry decommissioning commitments (IDCs) and staff decommissioning assumptions (SDAs) contained in NUREG-1738. This evaluation is contained in Section 1 and 2 .

Page 3 of 17

FCS EP-FC-1001 Addendum 4 Revision 0 SECTION 1 PDEP Industry Decommissioning Commltmen~s (IDCs) Comparison IDC Industry Commitments Response 1 Cask drop analyses will be performed DSAR 14.24:'The FCS auxiliary building crane with its rriain hook is used to move the spent fuel or single failure-proof cranes will be in casks into the spent fuel poQI. The capacity of the crane lifting system using the main hook is 106 use for handling of heavy loads (i.e., ton.s to accommodate the ISFSI spent fuel casks. The design of this lifting system is single failure phase II of NUREG-0612 will be proof. Theiefore, the likelihood of dropping the spent fuel casks into the spent fuel pool or in the implemented). -* auxiliary building is extremely low. The crane, main hook and lifting system meet the. .-

requirements of NUREG--0612, NUREG-0554, ANSl-30.2-1976, Regulatory Guide 1.104, CMAA-70 and ASM~ NOG-1-2004 as a single failure proof system.

GM-OI-HE-002, Attachment 13, Summary of HE-2 Licensing Basis asa Single Failure.Proof Crane: The licensing basis for the control of heavy loads associated with the Refuelin*g Area Cran,e,c9r:,sists of commitment to;NUREG .0~12 "Control of Heavy L,oads.at Nuclear-Power.

Rlants.. Phas!3 1 requir~ments. The Auxiiiary Bulldi119, Crane large hook. conforms-to.the design require1J1e.nts of !'JUREG 0,554 '_'Singl!3-Failure-Pr,0of Cranes for Nuclear _P_ower Plants", as demonstrated through conformance with the generic topical report for nuclear safety-related X SAM "crane EDR-1. The basis for FCS'* defense~ih-depth approach for the eontrol of heavy loads in the-spent fuelpbol area consists of preventin-g lbad drops due to crane failure, rigging failure, or human error through a combination ofthe use of the single-failure-proof crane and through compliance with the following guidelines from NUREG 0612.

1. Definition <;>f safe load paths

2. Development of*load handling p"rocei-dures *

3. Periodic

. . inspection an.d testing of

. .cranes

4. Qualifications, training and specified conduct ofoperators

5. s_pecial lifting devices should satisfy the gufdelines of ANSI N14:6

6. uttin 9 de~Ices that *are nofspecia11y designed shou1c1 be* i_nsta1ied and used in accordance with the guidelines of ANSI B30.9 *

7. Design of cranes to ANSI B30.2 or CMAA-70 -**-

1 *, * * * '

Page 4 of 17

FCS

EP-FC-1001 Addendum 4 Revision O IDC Industry Commitments Response Rigging,equiprnent.meeting guidelines no. 5 and 7 must b.~ used to maintain single failure proof status. The licensing basis with regard to these guidelines requires that off the shelf and specially

designed rigging equipment meet one of the following requirements:

1. Provide redundancy* cir duality such that a- single lift point failure will not result in uncontrolled lowering of the load; lift. points must have cl design factor of safety with respect to ultimate strength of five times the maximum load. The following is an example for meeting this

. requirement.Lifting a 10;000* lb !dad requires two sets of rigging, each rated for at least 10,000

. lbs (with a 5:1 fac~or of. safety). The total combined factor of safety would then be 10: 1.

OR

2. A non-redundant or non-dual lift point system must have a design safety factor of ten times the a

maximum load: This can be met by using one set of rigging 'rated at 20,000 lbs (with 5: 1 factor of safety) to Ifft a 10,000 lb load. The total combined factor of safety would then be 1O: 1.

Beqau~e th*e.a1,1xili~ry;b.uilding.crane is sing!e_-fallu.re proof.an accidental.load drop,is considered n<:>t.to be a.credible evenfsuch that condition 5J.2(1) of NU.REG-0612 is sa,tisfied.and analysis

of ca~k drop.ijccidents in accordance \Nith condition 5.1.2(4) of NUREG:0612. is not required.

Note that CR 2015-046.49 addresses concerns regarding the auxiliary building *crane. The ,,t',

calculations to support the crane usage for the next dry fuel storage will be updated to address concerns. .. .

2 Procedures and training of personnel FCS procedures are in place to ensure onsite and offsite resources can be brought to bear-,

will be in place to ensure that onsite during an event, including: .AOP-1, Acts.of Nature, AOP-6, Fire Emergency, AOP-37, Security and offsite resources can be brought to Event, AOP-31, 161kV Grid Malfunctions, AOP-38, Blair Water Main Trouble, and OCAG-1/2/4, be~r*dwing an event. Operational Contingency AcUon Guidelines. . * * ..

EP-FC-112-100-F-01, SHIFT MANAGER CHECKLIST, directs the Control Rdom to implement EP-FC-114-100, OFF-SITE NOTIFICATIONS. The Shift Manager or oth*er designated Control Room personnel activates the ERO Notification System, in accordance with EP-FC-112-100-F-06, ERO NOTIFICATION OR AUGMENTATION. This process ensures FCS emergency

'r ~ **

personnel report to_ their proper locaUC)~S. ," .

Periodic Emergency Plan- drills are conducted with opportunities for off-site response organization participation in accordance with EP-FC-2001-DRILL, DRILLS AND EXERCISES.

Training requirements are outlined in and executed per TQ-DC-FC-113, ERO TRAINING AND QUALIFICATION.

Page 5 of 17

FCS* EP-FC-1001 Addendum 4 Revision O IDC ... Industry Commitments Response The post-shutdown on-shift operations staff, including Certified Fuel Handlers (CFH) and Non -

Certified Operators (NCO) will be appropriately trained on these procedures: . . ** **

Finally, iri accordance with OP-FC-201.-010-1001, B.5.b MITIGl\TING STRATEGIES EQUIPMENT !=XPECTATIONS, the systematic approach to training is implemented to ensure Operations and other appropriate personnel receive initial and continuing.training onB.5.b event related. procedures and strategies_ credited in th~ Mitigation Strategy License Condition_ under 10 CFR 50.54 (hh)'(1), 10CFR 50.54 (hh)(2), and Attachment 2 to NRC order EA-06-137.

Additionally, ERO decision makers are to receive initial and continuing training in accordance wi~h TQ-DC~FC-113, ERO* TRAINING AND QUALIFICATION. Finally, training is to be provided a

on strategies and command and control aspects of 10 CFR 50.54 (hh)(1) and 10CFR50.54(hh)(2) B.5.b'event that includes the following: Initial operational response, Initial damage assessments; and Appropriate offsite notifications of ERO.

3 Procedures will be in place to establish FCS has.the following procedure to provide guidance for.establishing and maintaining, communication between onsite and communic:;ations J>_etwe13n offsite agencies and the pnsi!e E;:RO during severe weather and offsite organizations during severe seismic.events: .. . . , .

weather and seismic events.

. .* *1 .. EP~FC-2001', Emergency Plan Administration

. : ,2: ' EP~FC-11'1'; EMERGENCY CLASSIFICATION

. . 3*: : EP-FC-114'-1:oo; OFF-SITE NOTIFICATIONS ***

.4._, EP-F,C-11_4-100-F-01, FORT CALHOUN STATION-STATE/LOCAL EVENT NOTIFICATION FORM . *. . . **

~- EP-FC,-1.14~t007F-02, Notification/Update of States

. 6. AOP-.1, ACTS OF .NATURE . . . . . . .

7 .. OCAG-1,0PERATIONAL CONTINGENCY ACTION GUIDELINE ***10 CF:R 2.390*****

8. OCAG~2. OPERATIONAL CONTINGENCY ACTION GUIDELINEfOR PAM FAILURE OR PREDICTED F:LOOD GREATER THAN 1014 FEET MSL ***10 CFR 2.390***

9., OCAG-4, MITIGATING BEYOND DESIGN BASIS FLOODING GREATER THAN EL.

1036' WITH RCS OPEN ***10 CFR 2.390*****

4 An offsite resource plan will be T_he following pr6cedures pra'vide guidance 'for ac:cess to offsite r~sc,urces including a listing of devei'opeq whic.hwill include ;;iccess to providers, contact information and resources, as well as mitigation strategies Jor SFP damage.

portable pumps and emergency power . and water supply: . . - . . . . '

to supplement onsiteresources, The

1. OP-FC-201-010-1001, B.5.b MITIGATING STRATEGIES EQUIPMENT plan would principally identify EXPECTATIONS ,.,,.;; .

organizations or suppliers where offsite

2. OCAG-1, OPERATIONAL CONTINGENCY ACTION GUIDELINE ***10 CFR 2.390*****

Page 6 of 17

FCS

EP-FC-1001 Addendum.4.

Revision 0 IDC Industry Commitments . . Response resources could be:obtained ih.c! t_imely 3 ... OCAG~2. OPERATIONAL CONTINGENCY ACTION GUIDELINE FOR DAM FAILURE manner. .*. OR PREDICTED FLOOD GREATER THAN 1014 FEETMSL ***10 CFR 2.390***

. : 4:

OCAG-4, MITIGATINGBEYOND DESIGN BASIS FLOODING GREATER THAN EL.

1036' WffH RCS OPEN ***10 CFR 2.390***** .

External support resources are validated on an ann1,1al basis per OP-FC-201-010-1001.

5 SFP instrumentation will include The. FCS.design is consiste_nt .with tliis. IDC, which include multiple readouts and alarms for SFP readouts and alarms in the control temperature, water level, arid area radiation monitors. Addition.ally, FCS has procedure AOP-36, room (or where personnel are LOSS OF SPENT FUEL POOL COOLING, to guide the response in the event that cooling or stationed) for SFP temperature, water leve1 is lost in the SF_P. At FCS the control room ancf local operating panel (Al-100) is also alerl;ed level, and area radiation levels. by alarm *when a SFP cooling purnp is not running. This allows for prompt operation action prior to having an issue with cooling.

SFP temperature*indication in the Cohtrol Roorn and remote locations is monitored from a point in the SFP cdolintrpath on the outlet ofthe he.af:exchanger. Additionally, the Component Cooling water temperature through the heat exchan'gei" is also monitored. Both of these indications will cause.al;3rmsjn the Control Room on high temperature. Additionally, temperature indications from the 101 :3-, 1022- .and 1035-foot elevations of the SFP are displayed and recorded on the Emergency Response Facility computer (ERF) .. These indications have high, high-high, and rate of change alarms. . '

SFP water level is monitored shiftly as part ofrequired'Opei"ator rounds using an installed level indication and visual verification. This.level indication also drives a control room*alarm on both high and low level. There is: also a ruler rnounted indication 'in the SFP for monitoring level. lh the a

event of beyond design *basis flooding event, additional level indication is installed in the SFP as driven through OCAG-2/4. * * *

1

SFP area radiation levels a~e mqnitpred via area radiationmon.itors that provide.indication and alar.mam:,unciation in the Control Rqom. A local alarm to notify perscmr,el of high area radiation levels is also in place. . . .. - *

6 SFP seals that could cause leakage At FCS the design of th~, SFP and its cooling system and connections to the pool are such that leading to fuel uncovery in the event of the pool cannot tie drained below the level of the top of the* stored fuei* when in its storage rack.

seal failure shall be self limiting to Additionally; drainage grooves are provided behind the stainless steel liner to permit detection of leakage,9r otherwise.engineered so any liner leakage. On a quarterly basis, the liner leakage is evaluated per preventative that drainage cannot occur, maintenance. work instructions. Basically, the. hydraulic design of the Spent Fuel Pool Cooling Page 7 of 17

FCS EP-FC-1001 Addendum 4 Revision O IDC Industry Commitments ** Response System is such thafthe single failure of any line or other single component will not drain the spent fuel pool.

The top ~f the fuel assemblies in th~' rack is at elevation 1008'6", which is the same as the elevation ofthe bottom of the gate connecting the pool with the fuel transfer canal. A plate has been ins~c1lled across the bottom ofthe.gate to raise the mi_nimum pos~ible water level in the pool

_ to 1009'8.5". The gate is a.taper design that is 7'4" wide at the top and taper.s to 4'6" wide at the bottom. The gate is ccmstructed*of carbon steel wjth stainless steeLplate: The lower one-third is filled with concrete to withstand hydrostatic forces. The gate is sealed' using a rubber gasket at the gate-to-SFP liner interface. This design provides a passive seal (e.g., in comparison to the active seal of designs using inflatable bladders).

The spent fuel pool cooling system had two suction points. The upper suction line enters at elevation 1034'0" and*is the normal suction point. The lower suction line enters at elevation 1011 '4" which is above the top of the stored fuel. The lower suction normally has a closed valve, but if the valve is inadvertently left open, the upper cooling water suction line and strainer would serve as a vacuum breaker and prevent draining of the pool. A rupture of the suction line upstream' of the valve would only drain the poorto a level still above the spent fuel assemblies.

The ~pent f~el pool_cooling wat~r discharges to the pool at 1034'0" and ends at 103_1'7" (a 90 degree elbow, to*diredflow downward). The line is .provided 1,/Vith a 1/2'inch hole to act as a vacuum 'breaker iri the event that a discharge piping rupture occurs causing' the line to acf as a siphoh. * ** ** * * * * *

The transfer tube is .isolated except during refueling by a flange on the reactor side and by gate valve in the fuel transfer canal. The isolation valve is a 36~inch, double sliding stem gate valve, man~ally 9perated from the 1038-foot level of the spent fuel deck area.

7 Procedures or administrative controls to Administratjve.-.controls are in place.that drive procedure use and adherence and risk reduce the likelihood of rapid drain management:cSpecifically, HU~FC-104-101, Procedure Use and Adherence, establishes the down events will include (1) prohibitions expectations and requirements for procedure adherence and usage for all personnel performing on the use of pumps that lack adequate activities.- Additionally, all work activities are. subject to the work process controls a_nd Integrated siphon protection or (2) controls for Risk Management per\/YC-FC-100 where the activities c1r'e analyzed and managed for risk (e.g,,

pump suction and discharge points. address SFP activities). . . .. . ' . . .

< r : ~ : ' !

The functionality of anti-siphon devices AtFCS the SFP is designed to reduce the lik~lihood of rapid drain down events. Specifically, the will be periodically veri.fied ... , .

spent fuel pool cooling lower suction, which is still well above the top of stored fuel, has a manual valve thatis controlled/locked closed. If the valve were to be inadvertently left open, the upp_er, .

suction line and strainer would serve as a vacuum breaker and prevent draininQ of the pool. A *

~ ,; \ .' ..

Page 8 of 17

FCS

EP-FC-1001 Addendum 4

" 0 Revision IDC Industry Commitments Resp~nse rupture of the suction line upstream of the valve would only drain the pool to a level still above the.spent fuel assemblies. The spent fuel.cooling discharge line is provided with a 1/2 inch hole to a~t'as a vacuum breaker in the event that a discharge piping rµpture occurs causing the line.to act as a* siphon*. . * ** * *

FCS maintains an administrative requirement that the spent fuel pool be maintained at an elevation of 1033' .to 1037' 9" at all times. This corresponds to 37.5' and'42.3' on loc;al level

. indication. This administrative requirement is placed in procedures as a precaution/limitation.

Additionally,jhelSFSI equipment design is such that there are no SFP operations that have ttw potential to cau.se.a rapid drain down. Th_e ISFSl controlling procedures carefully-control water volume move in and.out-of the SFP during operations. ***

8 An onsite restoration plan will be in FCS practices align with this IPC._Thepnsite rest9ration plan for repair of the SFP cooling place to provide repair of the SFP system aod for makeup:water to the SFP are incorp*orated into procedures AOP.:.36, LOSS OF cooling systems or to provide access SPENT.FUEL 'POOL COOLIN<;3, and OCAG;;'f, OPERATIONAL CONTINGENCY.ACTION for makeup water to the SFP. The plan GUIDELfNE. (also *ocAG~!U4) .* . .

will provide for remote alignment of the AOP-36 establish~s multiple makeup source~ from onsite that include:

makeup source to the SFP without . . .'* . .,;_ .. - . *. . - ' ( .. ,' *' ' .

requiring entry to the refuel floor. 1.

Demineralized Water

* , - 2.

Blair Water (city water)

3.

Fire Water Storage Tank 4 .. Diesel Fire Pump (river water)

OCAG-1 establishes multiple makeup sources from onsite and offsite including:

1. Firehose*routec:! to edge o(SFP using Diesel Flr~ Pump . ' . .

2.

Firehose routed'to edge of SFP. using Fire Truck from hydrant * .** * ** *

3. Firehose routed near SFP. fo spray the pool using Fire Truck from hydrant .

.4.. Firehos.e routed near SFP)?'spr~y the pool using Fire Truc;k from_ river ... ,. . .

OCAG-2/4.establishes additional makeup sources from onsite in the event of major flooding:

1. Safety Injection Refueling Water Storage Ta'nk 2 .. Fire Protection System There are multiple ways to add niakeup water to the SFP with or without entry to the poof floor as

., "' depicted above. Additionally, OCAG-1 has guidance for repair of a SFP wall breach .

Page 9 of 17

FCS EP-FC-1001 Addendum 4 Revision O IDC Industry Commitments R:esponse 9 Procedures will be in place to control Administrative controls are in place that drive procedure use and adherence and risk SFP operations that have the potential management. Specifically, HU-FC-104-101, Procedure Use and Adherence, establishes the*

to rapidly decrease SFP inventory. e~pectations and requirements for procedure.adherence and usage for all personnel performing These administrative controls may activities. Additionally, all work activities are subject to the work process controls and Integrated require additional operations or Risk Managementper WC-FC-100. where the activities are aoalyzed and nianagedfor risk (e.g.,

management review, management address SFP activities). ,* . . . .- **

physical presence for designated FCS maintains an administrativlrequirement that the spent "fuel pool be maintain*ed at an -

operations or administrative limitations elevation of'1033' to 1037'*9"afall times. This corresponds to 37."5' a'nd 4i3' on local level .

such as restrictions on heavy load indication. This administrative requirement is placed in procedures as a precaution/limitation.'

movements. *-

Additionally, the ISFSI equipm*ent design is such that there are no SFP operations that nave the potential to cause a rapid drain down. The ISFSI controlling procedures carefully control. water volu~e move in_and,ciut of the SFP during operations. * * *

The* fuel handling procedures at FCS require additional personnel to verify fuel assemblies are correctly grappled prior to*movement. Additionally, the fuel handling tools are:designed with a J-Hook* that prevents a fuel. assembly from separating from the tool. - *'

The h~ayy loads and crane usage aroun~ the SFP are confrolledJhrough GM-OI-HE-002, Auxiliaty Building Cr,me HE;_2 Nqrmai Op-eratibn. Attachment 13 of this procedur~ summarizes the licensing basis for the auxiliary *building crane being single failure proof. FCS maintains a defense~in-depth approach to control heavy load*s in the SFP area. The basis for FCS' defense-in-9epth approach for the control of heavy loads in the spent fuel poql area consists of preventing load drops due to crane failure, rigging failure, or human error through a combination of the use of t~e single-failur_e'."proofcrane a_nd thrpugh compliance with the following guidelines from NURE;G 0612.. ** -* . . .

1. Definition of safe load paths .

2. Developfrtent ofload handling* procedures

3. Periodic inspection

~ '

and testing of. cranes

4. Qualifications, training and specified con9uct of operators

5. Special lifting devices should satisfy the guidelines of ANSI N14.6

~- ;; 6. Lifting devices that are not specially designed should be installed and used in accordance with the .guidelines of ANSI 830.9 .. -

F, Page 10 of 17

FCS

EP-FC-1001 Addendum 4 Revision O IDC Industry Commitments Response,

7. Design of cranes to ANSI 830.2 pr CMAA-70 Rigging equipment meeting guidelines no. 5 and ?must be .used to maintain single failure proof status. The licen_sing basi.s with regard to these guidelines requires that off the shelf and specially designed rigging equipment meet one of the following requirements:

1. Provid~ redundaricy cir duality such that a single lift point failure will not result in uncontrolled lowering of the load; .lift points must have a design factor of safety with respect to ultimate strength 9f five times the maximum load. The following is an example for meeting this retji.lfrement. Lifting a 10,000 lb load requires two sets of rigging, each rated for at least 10,000 lbs (with a 5:1"fatfor of safety). The total cc>'mbined factor of safetywould th~n be 10:1. __ ;.

OR .. * - ..

2: A rior'l-redundarit or nori-duai'lift p9int system must have adesign.safety factor 6ften times the niaxlfrlt:Jr,, lo~d: }his c~ri be met by using.one_ set of rigging' rated at 20,000 lbs (with a 5:'.1 factor of,safety~ tq lift a 1Q,OOQ I~ lo~d:Th~ tqtal combined factor of safety'would then*be _10':1. -****

10 Routine testing of the alternative fuel FCS:practices align with this IDC .. Fuel poolmakeup'.strategiesare outlined in AOP-36 and pool makeup system components will OCAG documents .as:previously outlined. One of the primary makeup strcitegies is from the Fire be performed and administrative Protection System. The Fire Protection System .has redundant pumping capability and *power controls for equipment out of service supplies to ensure alternate SFP makeup functions. The system is supplied by redundant will be implemented to provide added pum'ps, one diesel driven thafcan be "black started" and one electric motor driven, e.a.ch design assurance that the components would rated for 2000 gpm at 125 psig discharge pressure. Both pumps Jake suction from the p!ant be available, if needed. intake cooling water structure from the Missouri River. The fire protection header is normally .

a maintained at greater than 130 psig by jocl<ey pump. If pre'ssure decreases in th-e. system, the fire.pumps.are automatically started b,y their initiation logic to maintain the fire protection system

,, J.

header pressure. The electric *motor driven pump starts when system pressure decreases to 110 psig and tbe. diesel driven pump is started in 10 sec if the electric motor driven pump does not start or when-system pressure drops to 100 psig. The onsite Fire Truck can also take suction from the Miss.ouri River or a hydrantto provide an alternate source of makeup water to the SFP.

" The Fire Protection*System can also be,cross-connected with the Blair Water System (city .

water). The Fire Protection System provides .defense-in,:-depth, and is routinely tested to ensure

-* capability is maintained~ , , .. -

/, .

OCAG-t establishes multiple makeup sources from onsite and offsite as discussed previously.

OP-FC-201-010-1001 contains the maintenance, verification and testing requirements of B.5.b Equipment: * * * *

Page 11 of 17

FCS EP-FC-1001 Addendum 4 Revision 0 IDC Industry Commitments Response Administrative controls are in place that drive procedure use and adherence and risk management. Specifically, HU-FC~104-101, Procedure Use and Adherence, establishes the expectations and requirements for procedure adherence and usage for all personnel performing

,. activities. Additionally, all work activities are subject to the work process controls and Integrated

.. *, *. . , Risk Management per WC-FC-100 where the activities are analyzed and managed for risk (e.g.,

addressSFP activities). ... *'

Once all fuel is removed from containment, a large inven~o_ry of water above the fuel still exists to extend the time to boil or until fuel uncovered. The spent fuel cooling system h.as far fewer

.. interfaces than the RCS that could impact the ability of. the system to perform its function;

however, there are also less redundancy and makeup sources available which constitutes a higher risk. Therefore, S0-0-21, Shutdown Operations Protection Plan, has special requirements to adhere to or additional clarifying information when creditirig or considering available systems and equipment to fulfill Shutdown Condition - Reactor Defueled with all Fuel Assemblies Removed from Containment.

Page 12 of 17

FCS

EP-FC-1001 Addendum 4 Revision O SECTION 2 PDEP Staff Decommissioning Assumptions (SDAs) Comparison SDA Staff Assumptions Response 1 Licensee's SFP cooling design will be The FCS design is consistent with this SDA. The spent fuel pool cooling system was designed at least as capable as that assumed in and constructed to Seismic Class I standards. The spent fuel racks are Class I. This system is the risk assessment, including protected by a Nuclear Safety Design Class I structure.

instrumentation. Licensees will have at The SFP cooling system heat exchangers are ultimately cooled by the Missouri River (ultimate least one motor-driven and one diesel-heat sink) using redundant pumps that are supplied by redundant power sources. The pumps driven fire pump capable of delivering are normally powered from offsite power, but can be supplied from an alternate reliable power inventory to the SFP.

source. The makeup system is adequate to provide water at the required capacity.

The spent fuel pool makeup system can provide 500 gpm, and additional water is available from both the demineralized water system and the fire protection system using hoses. The station design includes a motor-driven fire pump and a diesel-driven fire pump, both of which will be maintained until all fuel is removed from the SFP. Each fire pump has the capability to deliver 200 to 500 gallons per minute (gpm) of makeup water to the SFP (ref. TDB-OCAG-1).

FCS also has a pumper type fire truck, which is able to provide 200 to 500 gpm* of makeup water to the SFP. .

2 Walk-downs of SFP systems will be FCS operators perform a walk down of the SFP system's once*per shift as *driven by op-~rator performed at least once per shift by the rounds: * ..

operators. Procedures will be The onsite restoration plan for repair of the SFP cooling system .and for makeup,water to the developed for and employed by the

,SFP are incorporated into,procedures AOP-36, LOSS OF.SPENT.FUELPOOL COOLING, and operators to provide guidance on the OCAG-1, OPERATIONAL CONTINGENCY ACTION-GUIDELINE. (also OCAG-2/4) capability and availability of onsite and offsite inventory makeup sources and AOP-36 estab_lishes multiple makeup sources from onsite that include:

time available to initiate these sources

1. Demineralized Water for various loss of cooling or inventory

2.

Blair Water (city water) events.

3.

Fire Water Storage Tank

4. Diesel*Fire Pump (river water)

OCAG-1 establishes multiple makeup sources from onsite and offsite including:

1. Firehose routed to edge of SFP using Diesel Fire Pump

2. Firehose routed to edge of SFP using Fire Truck from hydrant Page 13 of 17

FCS EP-FC-1001 Addendum 4 Revision 0 SDA Staff Assumptions ** Response

3. Firehose routed near SFPto.spray the pool using Fire Truck from hydrant

4. Firehose routed near SFP to spray the pool usir:,g Fire Truck from river OCAG72/4 establishes additional makeup ,sources from onsite in the .event of major flooding: .

1. Safety Injection Refueling Water Storage Tank

2. Fire Protection System- *

There are m~ltiple ways to add makeup water to the SFP with or with.out entry to the.pool floor as depicted above. Additionally, OCAG-1 has guidance for*repair ofa SFP wall brea.ch.

3 Control room instrumentation that The FCS design is* consistent with this SDC, which include multiple readouts and alarms for SFP monitors SFP temperature and water temperature, water level,-and area radiation monitors. Additionally, FCS has procedure AOP-36, level will directly measure the LOSS OF SPENT FUEL POOL COOLING, to guide the response in the event that cooling or parameters involved. Level level is lost in.the SFP. At FCS the control room is also alerted by alarm when a SFP cooling instrumentation will provide alarms at pump is not running. This allows for_ prompt operation action prior to having an issue with levels associated with calling in offsite cooling. .. .. . . ... ,.

resources and with declaring a general SFP temperature indication-in.the Control Room is monitored from a point in the SFP cooling emergency.

path on the outlet of the heat exchanger. Additionally, the component cooling water temperature through the*heat-exchanger is also monitored. Both of these indications will cause alarms in the control! room on *high temperature. Additionally, temperature indications from the. 1013~, 1022-and 1035-foot elevations* of.the SFP are displayed- and recorded on the plant computer. These indications have high, high-high, and rate of change alarms.

SFP water level is monitored shiftly as part of operator rounds using an installed level indication.

The level indication includes an alarm in the control room for both high and low SFP*level: This alarm will be changed to reflect the requirement of Emergency Plan limits. There is a field installed ruler type level indication mounted to.the SFP liner and can be used to manually monitor the SFP level. - - **

In the e~ent ~fa beyond de'sign basis flooding event, additional level indication is avaiiable for installation in the SFP as driven through OCAG-2/4.

FCS wili coriti~ue ~6 'us~ the approved NRC EAL scheme, based on NEI 99-01, Oevelopment of Emergency Action Levels for Non-Passive Reactors, Revision 6. FCS has implemented the Permanently Defueled EALs based on Appendix__C of NEI 99-01. Based on the current EAL scheme a declaration of Alert would be based on radiation levels from a fuel handling accide~!*

Page 14 of 17

FCS

EP-FC-1001 Addendum 4 Revision 0 SDA Staff Assumptions ~esponse. . _

4 Licen~ee determines that there are no FCS is n~t fully'compliant ;,,;ith the SDA due to having drain paths; that a/e mor~ than 15 feet drain paths in the SFP that could lower below the normal pool operating level. This response discusses the control for the lower drain the pool level (by draining, suction, or paths:

pumping) more than 15 feet below the The normal pool operating level is 1035' 6".'The SFP cooling system is normally supplied normal pool operating level and that through an ff' pipe at 1034' O". The SFP cooling system discharges through an 8" pipe. The licensee must initiate recovery using discharge pipe enters the S.FP at 1034' O" and ends at 1031' 7" (a 90 degree elbow to direct flow offsite sources.

downward): This discharge line is provided with a 1/2 inch hole to act as a vacuum breaker. A 4" purification line from the SFP cooling system directly discharges at 1034'0". This discharge line also includes the normal borated *makeup path for the SFP. **

The SFP cooling system has an additional lower suction point at an elevation of 1011' 4'\ which is more than *15 feet below the normal pool operating level, but above the top of the fuel assemblies, which are at an elevation of 1008" 6". The lower suction valve is locked closed and controlled closed; Additionally, FCS maintains an administrative requirement that the SFP be ..~*~

maintained at an elevation of 1033' to 1-037' *9" at all times. This ensures compliance With Technical Specifications, m~intaining greater than 23 feet of water above the top of the fuel.

The gate connecting the SFP to the fuel transfer canal is designed such that the minimum possible water level in the SFP is 1009' 8.5". The gate.is'a taper design that is 7'4" wide at the top and tapers to 4'6" wide atthe bottom. The gate is constructed of carbon *steel with stainless steel plate. The lower one-third is filled with .concrete to withstand hydrostatic forces. The gate is sealed using a rubber gasket at the gate-to-SFP liner interface. This design provides a passive seal (e.g., in comparison to the active seal of designs using inflatable bladders).

Jhe fuel transfer canal has two openings that are more than 15 fe~t below the normal pool operating level. These lower openings are only a credible drain path when the SFP gate is rerhove*d. The lowest entry poinf tci the fuel transfer canal when the gate is removed is at the 1009' 8.5" elevation (i.e., cannot drain below this elevation). The first opening is the fuel transfer tube, where the opening centerline* is.at 1001' 6" and the bottom of the transfer tube is at 1000'.

The transfer tube is isolated except during refueling by a flange on the reactor side and by a gate valve in the fuel transfer canal. The isolation valve is a 36 inch, double sliding stem gate valve, manually operated from the 1038' elevation.of the spent fuel deck area. The second opening is the drain at the bottom of the fuel transfer canal, which is at 995' 6". This opening has a locked closed isolation valve that is controlled closed except during specific operations (e.g., tra*nsfer to waste, draining transfer canal). Both of these openings cannot draining below an elevation of 1009' 8.5" since that is the bottom of the SFP gate opening.

Page 15 of 17

FCS EP-FC-1001 Addendum 4 Revision 0 SDA Staff Assumptions , . . . Response** .. . *,

FCS currently .has procedures and.guidelines in place to obtain offsifo assistance if necessary for mitigatiorfof events that resu'lflnsignificant loss of. SFP inventory. These mitigating strategies were implemented as part of B.5.b r¢quirements. * .. * * **

5 Load Drop consequence analyses will The FCS design is in alignment with this description: The heavy loads and crane. usage around pe performed for facilities with the SFP are controlled thro.ugh GM-Ol;.HE-002, Auxiliary Building Crane HE~2 Norrnal Operation.

nonsingle failure-proof systems.* The Attachment 13 of this procedure summarizes the licensing basis for the auxiliary building crane analyses and any mitigative actions being single failure proof.*FCS maintains a defense-in-depth approach to control heaving loads necessary to.preclude catastrophic in the SFP area. The basis forFCS' defense-in-depth approach for the control of heavy loads in damage to the SFP that would lead to a the spent fuel pool area con$ists of preventing load*drops due to crane failure, rigging failure, or rapid pool draining would be sufficient human error through a combination of the use of the single-failure-proof crane arid through to demonstrate that there is high compliance with the following guidelines from NUREG 0612.

cpnfidence in the facilities ability to.

1. Definition of safe load paths withstand a heavy load drop.

2. Developme.nt of load handling procedure$.*

3. PerfodJc*

ihspJction . and . *,*

testing of. cranes *.* *

4. Qualifications, training and specified conduct of operators s::\ipe6ial

. . ,' . .liffihg' d*evices sh6uld . -*

satisf/the guideiines of

'... .. ANSI N14.6.

.** :-- ! * ~ .;" ** 6. Lifting devices that are not specially designed Should be installed and used in accordance with the-guidelines of ANSI 830.9

.. 7.. Design

. of cranes to ANSI .

830.2' CMAA-70 dr . ..

Rigging equipment meeting guidelines no. 5 and 7 must be used to maintain single failure proof status, The licensing basis with regard to these guidelines requires that off the shelf and specially,designed rigging.equipment meet one of the following requirements:

a

1. Provid~ re*ciimdancy or duality *such that single lift point failure ~il(not result in uncontrolled lowering of the load; lift points must have a design factor of safety with. respect to ultimate ' . . '

strength of five times the maximum load. The following is an example for meeting this requirement. Lifting a 10,000 lb load requires two sets of rigging, each rated for at least 10,000 lbs* (with -a 5:1 factor of safety). The total combined factor of safety woul~ then be 10:1.

OR .

Page 16 of 17

FCS

EP-FC-1001 Addendum 4 Revision 0 SDA Staff Assumptions Response

2. A non-redundant or non-dual lift point system must have a design safety factor of ten times the maximum load. This can be met by using one sef-of rigging rated at20,000 lbs (with a 5:1 factor of safety) to.lift a 10,000 lb load. The total combined factorofsafety would then be 10:1.

Because the auxiliary bui,lcling cra~*e is_single-f.ailure, proof, an ~~cidental load drop is ,considered a

not to be credible event s*uch that condition 5.1.2(1) of NUREG-0612 is'satisfied and analysis ofcask drop accidents in accordance with condition 5.1 :2(4)' of NUREG-0612 is not required.

6 Each decommissioning plant will FCS conducted a seismic assessment iri response to the NRC Near-Temi* Task Force (NTTF) successfully complete the seismic request. The seismic assessment incl!,Jded c!II, structures including the SFP was prepared and checklist provided in Appendix 28 to submitted for NRC review. The OPPD submittal (LIC-14-0047) documents the seismic

this study [NUREG-1738]. If the evaluation in conformance with NTTF recommendation 2.1 including the HCLPF values'and the checklist cannot be successfully 1E-5 per year hazard level. The Staff review:of the NTTF submittal specifically for the Spent Fuel completed, the decommissioning plant Pool Evaluation associated with the reevaluate.d seismic hazard implementing NTTF 0

will perform a plant specific seismic risk rec':ommendation*2.1 (CAC No. MF3735) is docui'nented in NRC-16~0068 (ML16182A361). The assessment of the SFP and NRC staff concludes that the licensee's assessment was performed consistent with the NRG-demonstrate that SFP seismically endorsed SFP Evaluation ~uidance Report and has provided sufficient information including the induced structural failure and rapid loss SFP integrity evaluation tb meet the SFP Evaluation Guidance (Item 9 in Enclosure 1 of the of inventory is less than the generic NRC's.5-:54(f) letter), thus supporting.SDA No. 6 of NUREG-1738.

bounding estimates provided in this study (<1 x1 o-5 per year including non-seismic events):

7 Licensees will maintain a program to The FCS spent fuel racks utilize Bora! rather th~,m BorafleX-,as a neutron absorbing material:

provide surveillance and monitoring of There are two regions or types*of racks in the SFP that both contain Bora! as,described in DSAR Boraflex,in high~density spent fuel 9:5. The Bora! is attached as panels between each storage cell. The panels are protected with a racks .until such time as spent fuel is no stainless steel sheath. . -. * ** **

longer stored in these high~density The technical specifications descfibe*th~ surveillance te~t r~quire~ents, which* requires poison racks ..

sample coupons to be tested for dimensional change, weight, neutron attenuation change, and specific gravity change. This is requir~d 1, 2, 4, 7, and 10 years after installation, and every 5 years thereafter. The purpose of the coupon*sample program is to ensure that.the required amount of boron remains in the,neutr()n abi3orber material throughout the life .of the racks. These coupon samples are sent out for analysis to ari indeperident firm whose results are reviewed and

' . *,, ,{ accepted by FCS. The coupon test program is administered through RE-ST-RX-0004 and 0005.

Page 17 of 17

LIC-18-0018, Independent Spent Fuel Storage Installation - Emergency Plan Update

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LIC-18-0018, Independent Spent Fuel Storage Installation - Emergency Plan Update

Text

References:

1.0 INTRODUCTION

1.0 INTRODUCTION

6.2.3 directories

5.0 REFERENCES

Purpose:

5.1 REFERENCES

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