Text

EC 69954, Rev 0, Partial Site Release - Phase 1
	ML18215A221
Person / Time
Site:	Fort Calhoun
Issue date:	06/21/2018
From:	; Omaha Public Power District
To:	; Office of Nuclear Material Safety and Safeguards
References
	LIC-18-0023 EC 69954, Rev 0
	Download: ML18215A221 (103)
	v • d • e

{{#Wiki_filter:Engineering Change Company Name EC Number Status/Date Facility Type/Sub-type: OMAHA PUBLIC POWER DISTRICT 0000069954 000 APPROVED 06/21/2018 FC FORT CALHOUN DCR DSGN EC Title: PARTIAL SITE RELEASE -PHASE I Mod Nbr : Master EC Outage wo Required Adv Wk Appvd: Auto-Advance: Caveat Outst: Resp Engr Location Units Fac FC Unit 1 KWl: KW2: N Work Group N Alert Group: DEN MGR Image Addr 00091319 Alt Ref. PROJECT N Priority 2 Department CHURCH R Description FORT CALHOUN UNIT #1 KW3: 2444 L Print Date: 06/26/2018 .... ~,.,,,.,.,.lrid _....._....._......_._. Page: 1 KW4: KWS: Temporary N Aprd Reqd Date: Exp Insvc Date: Expires On Auto-Asbuild N Discipline

EC Number Status/Date Facility Type/Sub-type: Engineering Change 0000069954 000 APPROVED 06/21/2018 FC DCR DSGN Print Date: 06/26/2018 .. l llllll lllll lllll lllll lllll lllll lllll lllll lllll lllll lllll 111111111111111111 Page: 1 EC Title: PARTIAL SITE RELEASE -PHASE I Mod Nbr : Master EC Outage WO Required Adv Wk Appvd: Auto-Advance: Caveat Outst: N N N KWl: KW2: KW3: Work Group Alert Group: Image Addr Alt Ref. Priority Department DEN MGR 00091319 PROJECT 2444 2 Resp Engr Location CHURCH R Milestone Date Req By 110-PREPARE EC 0 6/14/2018 APPROVED PassPort: X9796 Name: CHURCH 120-REVIEW EC 06/21/2018 APPROVED PassPort: X7278 Name: DAVIS 240-ITPR-EPR 0 6/21/2018 APPROVED PassPort: X6038 Name: PHILLIPS 300-APPROVE EC 06/21/2018 APPROVED PassPo r t: X6182 Name: CATE 210-DEPT RVW-OP 06/20/2018 APPROVED PassPort: X9108 Name: LINDAU 800-ATTR CLOSED CLOSED PassPort: Name: 250-ALARA DSGN 06/20/2018 APPROVED PassPort: Xl3743 Name: BARKER 210-DEPT RVW-01 06/21/2018 APPROVED PassPort: X 6078 Name: GESCHWENDER Fire Protection Program Review 210-DEPT RVW-02 06/19/2018 APPROVED PassPort: Xll208 Name: FICKBOHM Emergency Planning 210-DEPT RVW-03 06/21/2018 APPROVED PassPort: X7928 Name: MARCELLUS Chemistry 210-DEPT RVW-04 0 6/21/2018 APPROVED PassPort: Xl0761 Name: CAMERON Reg A s surance 2 10-DE PT R VW-05 06/1 8/2 018 A P PROVED PassPort: Xl0131 Name: BERKEY Security 210-DEPT RVW-0 6 06/21/2018 APPROVED PassPo r t: Xl0170 Name: WASZA K KW4: KW5: Temporary Aprd Reqd Date: L R ERIC Exp Insvc Date: Expires On Auto-Asbuild Discipline WILLIAM JOHN BROCK ANDREA JAMES JASON MATTHEW COREY SAMUEL CAROL N N Engineering Change Print Date: 06/26/2018 EC Number Status/Date Facility Type/Sub-type: 0000069954 000 APPROVED 06/21/2018 FC DCR DSGN l llllll lllll lllll lllll lllll lllll lllll lllll lllll lllll lllll 111111111111111111 Units Fac FC Unit 1 Description FORT CALHOUN UNIT #1 Affected Documents List Fac FC !m! CALC !m! Document FC06802 Minor Rev: Major Rev: Sheet Page: 2 Ops Rvw y Updt Due: Pri Title: ENVIRONMENTAL RADIOACTIVITY RELEASE INVENTORIES FOLLOWING A WASTE GA FC CALC FC06808 y Minor Rev: Major Rev: 001 APPROVED Updt Due: Title: ATMOSPHERIC DISPERSION COEFFICIENTS (X/QS) AT THE EAB AND LPZ FOR IDEN FC CALC FC06816 y Minor Rev: Major Rev: 0 0 3 APPROVED Updt Due: Title: SITE BOUNDARY AND CONTROL ROOM DOSES FOLLOWING A FUEL HANDLING ACCIDE FC CALC FC06822 Minor Rev: Major Rev: y Updt Due: Title: SITE BOUNDARY AND CONTROL ROOM DOSES DUE TO AIRBORNE RELEASE FOL FC CALC FC08513 y Minor Rev: Major Rev: 001 APPROVED Updt Due: Title: EAB RADIATION SHINE DOSE 18 MONTHS POST SHUTDOWN WITH THE SFP DRAINED FC CALC FC08515 y Minor Rev: Major Rev: Updt Due: Title: PD-AA-1 1 GASEOUS RELEASE THRESHOLDS FC CALC FC08557 y Minor Rev: Major Rev: 002 APPROVED Updt Due: Title: FUEL HANDLING ACCIDENT IN THE SPENT FUEL POOL SITE BOUNDARY AND CONTRO FC CALC FC08790 y Minor Rev: Major Rev: 0 0 0 APPROVED Updt Due: Title: ATMOSPHERIC DISPERSION FACTORS (X/QS) AT THE DE COMMISSIONING EXCLUS FC CALC FC08791 y Minor Rev: Major Rev: 000 APPROVED Updt Due: Title: SITE BOUNDARY (EAB) DOSE FOLLOWING A FUEL HANDL ING ACCIDENT IN THE Ine y y y y y y y y y Engineering Change 0000069954 000 APPROVED 06/21/2018 FC Print Date: 06/26/2018 EC Number Status/Date Facility Type/Sub-type: DCR DSGN l llllll lllll lllll lllll lllll lllll lllll lllll lllll lllll lllll 111111111111111111 ~hlllkhWN/1/$/rkl ,', .................... _....~ , , Page: 3 ._ ___________ .. __ . FC CALC FC08792 Y Y Minor Rev: Major Rev: 000 APPROVED Updt Due: Title: SITE BOUNDARY (EAB) DOSE FOLLOWING A LIQUID WAS TE TANK RUPTURE ACCI FC DRAW USR 1.2-2 (36031) 0 01 y y Minor Rev: Major Rev: Updt Due: Title: RESTRICTED AREA (36031) FC DRAW USR 2.2-4(36045) 001 y y Minor Rev: Major Rev: Updt Due: Title: METES AND BOUNDS (36045) FC DRAW USR 8.2-2(36565) 001 y y Minor Rev: Major Rev: Updt Due: Title: TRANSMISSION LINE ROUTING (36565) FC EA EA17-010 y y Minor Rev: Major Rev: Updt Due: Title: DSAR 14.18 , SAFETY ANALYSIS -FUEL HANDLING ACCIDENT IN SPENT FUEL POO FC MANL DSR DSAR-1.2 y y Minor Rev: Major Rev: Updt Due: Title:

SUMMARY

PLANT DESCRIPTION FC MANL DSR DSAR-11.1 y y Minor Rev: Major Rev: Updt Due: Title: RADIOACTIVE WASTE DISPOSAL SYSTEM FC MANL DSR DSAR-14.1 y y Minor Rev: Major Rev: Updt Due: Title: GENERAL FC MANL DSR DSAR-14.18 y y Minor Rev: Major Rev: Updt Due: Title: FUEL HANDLING ACCIDENT (IN SPENT FUEL POOL AND CONTAINMENT) FC MANL DSR DSAR-14.20 y y Minor Rev: Major Rev: Updt Due: Title: WASTE LIQUID INCIDENT FC MANL DSR DSAR-2.2 y y Minor Rev: Major Rev: Updt Due: Title: GENERAL DESCRIPTION OF SITE AND ENVIRON Engineering Change Print Date: 06/26/2018 EC Number Status/Date Facility Type/Sub-type: FC MANL DSR Minor Rev: 0000069954 000 APPROVED 06/21/2018 FC DCR DSGN l llllll lllll lllll lllll lllll lllll lllll lllll lllll lllll lllll 111111111111111111 DSAR-2.5 Major Rev: Ti tle: METEOROLOGY FC PROC ODC CH-ODCM-0001 Minor Rev: Major Rev: Title: OFF-SITE DOSE CALCULATION MANUAL (ODCM) FC PROC STRM EP-FC-1001 ADDENDUM 3 Page: Updt Due: Updt Due: Minor Rev: Major Rev: Updt Due: Title: PERMANENTLY DEFUELED EMERGENCY ACTION LEVEL TECHINCAL BASES Cross References Ref. Sub-Number Number Description 4 y y y y y y WP 00627853 FCS PROJECT 2444 HAZARDOUS MATERIAL PARTIAL SI Engineering Change Comments Cornments Last Updated By: X9796 Last Updated Date: 06/07/2018 Engineering Change EC Number Facility Type/Sub-type: Topic From Panel 0000 069954 000 FC DCR DSGN 50. 59 REVIEW TIMElOO Last Opdated By Last Opdated Date: Text Status Print Date: 06/26/2018 ,,__. ~hWNl/$tr/d Page: 1 Engineering Change EC Number Facility Type/Sub-type: Topic From Panel 0000 069954 000 FC DCR DSGN DESIGN

SUMMARY

TIMElOO Last Updated By Last Updated Date: Text Status Page: 2 n Engineering Change EC Number Facility Type/Sub-type: Topic Frorn Panel 0000069954 000 FC DCR DSGN EC SCOPE TIMElOO Last Updated By Last Updated Date: Text Status Print Date: 06/26/2018 .... '-Ik,._, llstrld *;~_...., ....... _..,~ Page: 3

EC 69954 50.59 Documents attached 50.59 EC 69954 Partial Site Release -

1. Problem Definition/Scope EC 69954 , rev. 0 Partial 5ite Release -Phase 1 Page 1 of 15 The activity requests approval from the NRC to remove a portion of the Ft Calhoun site from the Part 50 license (License No. DPR-40}. 5pecifically , the activity will remove/release the non-impacted survey units from the Part 50 license in accordance with 10 CFR 50.83, "Release of Part of a Power Reactor Facility or Site for Unrestricted Use" subpart (b). The activity does not involve any tests or experiments.

Key aspects of this change include documenting the following:

Revision of calculations/analysis that support that the resultant dose to individual members of the public does not exceed the limits and standards of 10 CFR 20 , 5ubpart D.
That effluent releases remain within license conditions.
The early release of the subject property does not have any adverse effect on the environmental monitoring program and Offsite Dose Calculation Manual.
AII applicable statutory and regulatory requirements continue to be met.
lssuanc:e of the revised applicable station documents.

The change is part of the overall strategy to eventually release the site for un r estricted use. This activity is in support of Phase I of FC5 Project 2444 , Partial 5ite Release. The activity of the early release of the subject land supports the eventual overall license termination process on accordance with NRC regulations. 1.1 RESULTS OF HU-FC-1212 REVIEW: The Responsible Engineer has determined that the preparation of this EC/ECR/ECP involves only low Consequence Risk Factors or no Consequence Risk Factors (per HU-FC-1212 Attachment

2) and normai process controls apply. 2. Design Change Document Change Request (DCR) Basis The Engineering Change (EC) was screened via CC-FC-104 Rev. 0 reviewing criteria in section 4.2.1. This revision does not meet the requirements to be performed as an Administrative change due to the impact on the D5AR. The EC was further screened via CC-FC-103, Rev. 3, Attachments F and G. It was determined that the EC did NOT meet the screening criteria for Commercial Changes or the screening criteria for Equivalent Changes. Asa result, in accordance with CC-FC-104, section 4.2.2.C, the EC is to be processed asa Design Change DCR , per CC-FC-104 5ection 4.3. 2.1. Review Requirements (minimum)

A HU-FC-1212 review 15 required per CC-FC-104 5ection 4.3.4 as the DCR does NOT meet the necessary screening criteria to be processed as an Administrative Change DCR. A 10CFR50.59 review 15 required as per CC-FC-104 5ection 4.3.20. A 10CFR72.48 review 15 required as per CC-F C-104 Section 4.3.20. Reviews , as r equired under 50.54 (i.e., 5ecurity, EP). EC 69954, rev. 0 Partial Site Release -Phase 1 Page 2 of 15 An LS-FC-120-1001-F-01 review is required as per LS-FC-120-1001 Section IV, because the EC is a design change. 3. Proposed Document Changes EC 69954 addresses issuance of revisions to the following documents and nev,1 documents: Note: Proposed document revision and document change mark-ups are provided, except for those which include an RA number.

Existing Calculations/

Analysis revised by this EC: FC06802 -ENVIRONMENTAL RADIOACTIVITY RELEASE INVENTORIES FOLLOWING A WASTE GAS DECAY TANK RUPTURE AND LIQUID WASTE TANK RUPTURE This calculation will be revised to reflect the maximum isotopic activity inventory (Ci) in the Filtration lon Exchanger (FIX) available for release to the environment during decommissioning for the exclusion area boundary dose analysis for the Liquid Waste Tank Failu re Accident. RA 2018-0198. FC06808 -ATMOSPHERIC DISPERSION COEFFICIENTS (X/QS) ATTHE EAB AND LPZ FOR IDENTIFIED DESIGN BASIS ACCIDENTS' RELEASE POINTS Revise the calculation to remove the maximum calculated post-accident atmospheric dispersion factors (X/Qs) for the Exclusion Area Boundary (EAB). New Calculation FC08790 calculates the new maximum calculated post-accident atmospheric dispersion factors (X/Qs) for the EAB proposed for Fort Calhoun Station (FCS) decommissioning. Also removed the EAB and LPZ X/Qs for the MSSV / ADV Stacks, Room 81 Pressure Relief Domes, Auxiliary Feedwater Pump Turbine Exhaust, and Condenser Evacuation Discharge Stack as these X/Qs are no longer used because the accident analyses that they were used for are not applicable in the permanently defueled state. FC06816 -SITE BOUNDARY AND CONTROL ROOM DOSES FOLLOWING A FUEL HANDLING ACCIDENT IN THE FUEL POOL AREA USING ALTERNATE SOURCE TERMS This calculation was revised to make the doses calculated for the Fuel Handling Accident in the Spent Fuel Pool at the Exclusion Area Boundary (EAB) historical. New Calculation FC08791 was prepared to reflect the Partial Site Release Project 2444 reduction of the Exclusion Area for Fort Calhoun Station during its Decommission phase, and enable the plant to release portions of the site. FC08791 is the new analysis of record for the EAB doses due to Fuel Handling Accident in the Spent Fuel Pool. FC06822 -SITE BOUNDARY AND CONTROL ROOM DOSES DUE TO AIRBORNE RELEASE FOLLOWING A LIQUID WASTE TANK FAILURE EC 69954, rev. 0 Partial Site Release -Phase 1 Page 3 of 15 This calculation was revised to make the doses calculated for the Liquid Waste Tank Rupture Accident at the Exclusion Area Boundary (EAB) historical. New Calculation FC08792 was prepared to reflect the Partial Site Release Project 2444 reduction of the Exclusion Area for Fort Calhoun Station during its Decommission phase, and enable the plant to release portions of the site. FC08792 is the new analysis of record for the EAB doses due to The Liquid Waste Tank Rupture (LWTR). FC08513 -EAB RADIATION SHINE DOSE 18 MONTHS POST SHUTDOWN WITH THE SFP DRAINED Attachment H has been added as an entirely new Monte Carlo N-Particle Transport Code (MCNP) run to show what dose rates would be experienced with an Exclusion Area Boundary that is approximately 1525 ft from the centerline of the Auxiliary Building Stack. No geometry changes were required to the modei only the detector locations were modified in the MCNP modei. Sixteen detectors with a radius of approximately 1525 ft from the Auxiliary Building stack were put into the modei at 22.5 degrees apart in a circular pattern. AII pages were changed to Revision 1, cover sheet Drawing 11405-5-270 was added as it was in Revision O document but not on the cover sheet. TODI -185516-22-001 added as design input for 1525 ft radius distance from stack. 11405-A-263 is the design basis input for ground elevation at the plant of 1004'-6" and was added as reference. This is consistent with FCS-FRP-GEN-12-001 OPPD Letter to Electric Power Research lnstitute, EPRI Data Request for Site Amplification Calculations. FC08515 -PD-AA-1 GASEOUS RELEASE THRESHOLDS Revise EAB dose at the closest point to determine instrument values, as required. RA 2018-0200. FC08557 -FUEL HANDLING ACCIDENT IN THE SPENT FUEL POOL SITE BOUNDARY AND CONTROL ROOM DOSE This calculation was revised to make the 4-day EAB dose analysis performed for the Emergency Plan exemption historical. The EAB portion was redone for decommissioning with a reduced area. See calculation FC08791 for the 4-day EAB dose. EA17-010-DSAR 14.18, SAFETY ANALYSIS-FUEL HANDLING ACCIDENT IN SPENT FUEL POOL, DESIGN & LICENSING BASIS RECONSTITUTION REPORT This analysis is updated to change and revalidate the Statements of Fact based on the DSAR 14.18 changes due to the updated Fuel Handling Accident. RA 2018-0197.

New Calculations to be issued via the EC. FC08790-ATMOSPHERIC DISPERSION FACTORS (X/QS) AT THE DECOMMISSIONING EXCLUSION AREA BOUNDARY (EAB) FOR RADIOLOGICAL RELEASES FROM FORT CALHOUN STATION As part of its decommissioning strategy for FCS, OPPD is planning to reduce the owner controlled land. To that end, OPPD plans to reduce the size of the EAB. This analysis was EC 69954, rev. 0 Partial Site Release -Phase 1 Page 4 of 15 generated to calculate the atmospheric dispersion factors (i.e., X/Qs) for postulated accident radiological releases from the Fort Calhoun Station (FCS) Auxiliary Building Vent Stack and Radwaste Building Exhaust Nozzle applicable to the new EAB proposed for use during FCS Decommissioning.

These X/Q values apply to the 0-2 hours through 4-30 days period of the reieases. The input changes to this calculation include 1) reduced EAB, which is a 465 meter radius circle with the centerpoint of the Auxiliary Building Stack and 1075 foot from the Radwaste Building Nozzle to the closest EAB location, and 2) updated onsite meteorological data from January 1, 2013 to December 31, 2017. The met data provided is the same timeframe as the original analysis (i.e. 5 years) but is updated to reflect the mast recent averaged conditions onsite. (Wectec Vender calculation 1538351002) FC08791-SITE BOUNDARY (EAB) DOSE FOLLOWING A FUEL HANDLING ACCIDENT IN THE FUEL POOL AREA IN SUPPORT OF A REDUCED EAB DISTANCE DURING DECOMMISSIONING Partial Site Release Project 2444 was initiated by OPPD to reduce the Exclusion Area for Fort Calhoun Station (FCS) during its Decommission phase, and enable the plant to release land. The Fuel Handling Accident (FHA) in the Spent Fuel Pool (SFP) area dose at the Exclusion Area Boundary (EAB) is reanalyzed as part of the assessments being performed under the referenced Project. The aforementioned dose consequence reflects the dose due to inhalation and submersion in airborne activity, as well as due to groundshine, and remains below:

The FCS licensing basis commitment during "power operation" of < 6.3 rem TEDE over the worst 2-hour period (per 10CFR50.67; as augmented by Regulatory Guide 1.183, Revision O)
The FCS licensing basis commitment of < 1 rem when projected over 4 days (per NRC approval of an exemption from emergency planning during FCS decommissioning activities and in accordance with the guideline presented in Table 1-1 of the Environmental Protection Agency Protective Action Guidelines The input changes to this calculation are 1) The X/Qs based on the new EAB as calculated in FC08790, 2) updated FCS fuel gap fractions for non-LOCA accident to NUREG/CR-5009 as approved in License Amendment 243, 3) updated decontamination factor of 200 as required by License Amendment 201, and 4) longer decay time from 72 hours to 20 months due to permanent plant shut down. The methodology used in FC08791 to determine the gap fractions uses NUREG/CR-5009 specified methodology vs 2x Reg Guide 1.183 values used in the current AOR (FC06816).

This is acceptable because TS amendment 243 (NRC-06-0146) approved the change in methodology for future non-LOCA events. The decontamination factor was changed from 285 to 200, as specified in the TS amendment 201 where FCS made a commitment to the NRC to use an overall EC 69954, rev. 0 Partial Site Release -Phase 1 Page 5 of 15 decontamination factor of 200 in all future analyses. This was a condition of approval of the alternate source term analyses. Therefore, the change in element of an evaluation methodology has been approved by the NRC for use at FCS and therefore does not involve an adverse change to an element of a UFSAR described evaluation methodology, or use of an alternative evaiuation methodology. Ref. TS amendment 201. {Wectec Vender calculation 1538351002-C-M-00004) FC08792 -SITE BOUNDARY (EAB) DOSE FOLLOWING A LIQUID WASTE TANK RUPTURE ACCIDENT IN SUPPORT OF A REDUCED EAB DISTANCE DURING DECOMMISSIONING Partial Site Release Project 2444 was initiated by OPPD to reduce the Exclusion Area for Fort Calhoun Station {FCS) during its Decommission phase , and enable the plant to release land. The Liquid Waste Tank Rupture (LWTR) dose at the Exclusion Area Boundary (EAB) is reanalyzed as part of the assessments being performed under the referenced Project. The aforementioned dose consequence reflects the dose due to inhalation and submersion in airborne activity, as well as due to groundshine. The calculated dose remains below

The FCS licensing basis commitment of < 0.5 rem TEDE over the worst 2-hour period
The FCS licensing basis commitment of < 1 rem when projected over 4 days (per NRC approval of an exemption from emergency planning during FCS decommissioning activities and in accordance with the guideline presented in Table 1-1 of the Environmental Protection Agency {EPA) Protective Action Guidelines The input changes to this calculation are 1) The X/Qs based on the new EAB as calculated in FC08790 and 2) the isotopic inventory of the tank {OPPD has chosen to use the activity calculated for the operating plant's tank rupture, eliminating any isotopes with short half-lives that do not have the potential for becoming airborne, as the tank inventory release.)

{Wectec Vender calculation 1538351002-C-M-00003)

DSAR Sections The following DSAR Sections will be revised to reflect new site boundary and/or revised calculations following Phase I of Project 2444: DSAR 1.2, Summary Plant Description. RA 2018-0097.

DSAR 2.2, General Description of Site and Environs. DSAR 2.5, Meteorology. RA 2018-0098. DSAR 11.1, Radioactive Waste and Radiation Protection and Monitoring. RA 2018-0195. DSAR 14.1, Safety Analysis -General. DSAR 14.18, Fuel Handling Accident in Spent Fuel Pool. DSAR 14.20, Waste Liquid Incident. RA 2018-0196.

DSAR figures EC 69954, rev. 0 Partial Site Release -Phase 1 Page 6 of 15 Figures to be revised to reflect new site boundary following Phase I of Project 2444. Figure 1.2-2, RESTRICTED AREA (36031) Figure 2.2-4, METES AND BOUNDS (36045) Figure 8.2-2, TRANSMISSION LINE ROUTING (36565)
10 CFR 72 documents A review for potential impact on the 10 CFR 72 (ISFSI) documents was performed as part of this EC. This review determined that this change activity does not have any impact which would require revision of any 10 CFR 72 documents.

The review included, but was not limited to, calculation FC07140, RO, OPPD !SFSI Phase ! Site Dose and Occupational Dose Summary, and Fort Calhoun lndependent Spent Fuel Storage lnstallation Docket 72-054 10 CFR 72.212 Evaluation Report, R3. The review concludes that changes to the distance from the unrestricted area to the ISFSI in partial site release described in this EC does not impact the parameters used in dose calculation FC07140 that is referenced by the 72.212 Report. The controlled area around the ISFSI continues to be in compliance with 10 CFR 72.106.

Procedures/Manuals CH-ODCM-0001, Off-Site Dose Calculation Manual (ODCM). RA 2018-0199.

EP-FC-1001 Addendum 3, Permanently Defueled Emergency Action Level Technical Bases. RA 2018-0201. 3.1. Justification Physical description of area to be released: Part of Sections 17, 20, and 21, Township 18 North, Range 12 East of the 6th P.M. Washington County, Nebraska. A detailed Legal Description of these tracts can be found on Boundary Survey drawing, V_BNDY_73338 (attached to this EC). The area being released is that part of the owner controlled area as shown on the referenced Boundary Survey Drawing located in the East half of the Southwest quarter of Section 17, Township 18 North, Range 12 East and the East half of the Northeast EC 69954, rev. O Partial Site Release -Phase 1 Page 7 of 15 quarter of the Northwest quarter and East half of the Southeast quarter of the Northwest of Section 20, Township 18 North, Range 12 East. This area is general described as land on the northwest portion of the owner controlled area totaling approximately 120 acres from the Part 50 License. The Partial Site Release Project 2444 has performed calculations and revisions and physical sampling in order to reduce the Exclusion Area for the plant and enable the plant to release land. The new EAB was defined by the Project Team to use in the reanalysis in order to establish a new Exclusion Area Boundary (EAB). The new analysis will enable FCS to show that this EAB is acceptable for site doses and upon approval will become the new Design/Licensing Basis for the plant. ln accordance with subparts of 10 CFR 50.83, Release of Part of a Power Reactor Facility or Site for Unrestricted Use, this EC will document this following: Fort Calhoun Station evaluated the effects of releasing a portion of land on the northwest portion of the owner controlled area totaling approximately 120 acres from the Part 50 License in accordance with the criteria specified in 10 CFR S0.83(a)(l)(i)-(vi), (a)(2), and (a)(3): (a)(l} Evaluate the effects of releasing the property to ensure that: i. The dose to individual members of the public does not exceed the limits and standards of 10 CFR Part 20, Subpart D. The Omaha Public Power District's Fort Calhoun Station (FCS) controls and monitors effluents to ensure radioactivity release to the environment is maintained ALARA and does not exceed federal release limit criteria. Effluent controls include operation of radiation monitoring systems as well as an offsite environmental analysis program. The release of the northwest 120 acres of the owner controlled area does not change any controls used to comply with dose limits for individual members of the public and the conservatively estimated yearly dose to a member of the public is well below the 10 CFR Part 20, Subpart D limits and standards. A r eview of the Annual Effluent Report shows the TLD readings for the doses to members of the public are well below the regulatory limits set forth in both Environmental Protection Agency and Nuclear Regulato r y Commission dose limits. ii. There is no reduction in the effectiveness of emergency planning or physical security. No credit is taken for the subject land in the Emergency Plan. However, the release is being reviewed by Emergency Planning under the S0.54(q) and the Se c urity Pla n is being r e viewed under the S0.54(p) process. EC 69954, rev. 0 Partial Site Release -Phase 1 Page 8 of 15 Completed SY-FC-101-104-F-01, Screening Evaluation for Revisions to the Physical Security Plan (50.54p Screening) and EP-FC-2001-5054Q, Emergency Planning 10CFR50.54(Q) Review Program, is attached to this EC. iii. Effluent releases remain within license conditions. FCS programs to monitor and measure effluent releases within license conditions are still in effect and the early release of the subject land does not have an impact on these programs. Effluent monitoring conditions will remain in effect in accordance with license conditions. Environmental dose monitoring locations will not change asa result ofthis proposed land release. Therefore, the effluent releases from FCS will remain in accordance with license conditions. iv. The environmental monitoring program and offsite dose calculation manual (ODCM) are revised to account for the changes. Changes to the site boundary have the potential to affect concentrations in offsite dose pathways. The FCS ODCM is being evaluated and updated to address reduced distance to site boundary and potential land use in conjunction with implementation of partial site release request. Occupancy factors remain unchanged at this time. The Environmental lmpact Statement is not affected by the subject land release. There are no changes to the external appearance of the plant; changes to waste processing; changes in land or water usage; changes in water or air quality; changes in radiological impact; changes to historical or archeological areas. The socioeconomic impact of the release is balanced as the farmer who leases the land for row crops may be able to continue to do so after the release approval. lf any other development were to be undertaken in the future, the economic impact on the community could be improved. Any development would be subject to the construction and permitting for the laws of the state of Nebraska after the land release with the subje c t land being released from the provisions of the Part 50 license. v. The siting criteria for 10 CFR 100 continue to be met. The release of the subject property has been reviewed with respect to the siting criteria in 10 CFR 100 and it has been determined that the requirements of 10 CFR 100 are either not impacted or are not applicable. The radiological Exclusion Area Boundary (EAB) at FCS is being updated to approximately 464 meters per Engineering calculations. The dose at that distance from the Auxiliary Building effluent stack is well below the 10 CFR 100 criteria of 25 rem in two hours or 300 rem to the thyroid in that same time period at the 900 meter mark. The member of the public that is analyzed to receive the highest dose is postulated to receive 1 mrem total effective dose equivalent (TEDE) from an accident or event analysis, including a dropped fuel bundle, dropped used purification resin container, dry active waste container fire, fire within EC 69954, rev. 0 Partial Site Release -Phase 1 Page 9 of 15 the Radiologically Controlled Area, and boiling of the Spent Fuel Pool. FCS will continue to maintain the ability to remove members of the public from the exclusion area in the case of radiological emergency, which is approximately 436 meters closer to the plant than the subject land. vi. AII other applicable statutory and regulatory requirements continue to be met. Review by Regulatory Assurance for impact regarding 10 CFR 50.83(a){l)(vi) determined the following: -No impact to Technical Specifications. -DSAR will require a change to the site description (along with supporting documents). See document changes described in Section 3.0 of this EC. There are no changes to FCS palicies and procedures to ensure that statutory and regulatory requirements continue to be met asa result of this early release of the subject property. ln summary, the proposed release of the approximately 120 acres from the Part 50 License will not have any impact on Fort Calhoun Station's continued compliance with applicable NRC standards. (a)(2) Perform a historical site assessment of the part of the facility or site to be released. ln accordance with guidance provided in NUREG-1575, "Multi Agency Radiat i on Survey and Site lnvestigation Manual (MARSSIM)," section 3.0, a Historical Site Assessment (HSA) was performed for all areas outside of operational structures and documented in 2016 after permanently going offline for decommissioning. Historical information, including any 10 CFR 50.75 (g) files, employee interviews, radiological incident reports, pre-operational survey data, spill reports, special surveys, operational survey records, and Annual Radiological Operating Reports (including sampling of air, groundwater, milk, fish, and surface vegetation) were reviewed and compiled for this investigation. The HSA was a detailed investigation of all non-operational areas ofthe Owner Controlled Area to collect existing information for the site and its surroundings. The HSA focused on historical events and routine operational processes that could have resulted in contamination of onsite buildings outside of the Protected Area, surface, and subsurface soils with the Owner Controlled Area, as well as open land areas, subsurface soils outside of the Protected Area, but within the Owner Controlled Area. The information compiled by the HSA was used to establish initial area survey unit classification of the subject land. The scope of the HSA include potential contamination from radioactive materials, hazardous materials, and environmental contaminants. EC 69954, rev. 0 Partial Site Release -Phase 1 Page 10 of 15 The HSA investigation was designed to obtain sufficient information to provide initial classification of site land areas and structures as impacted or non-impacted. lmpacted areas have a potential for contamination (based on historical data) or contain known contamination (based on preliminary radiological surveillance). MARSSIM defines non-impacted areas as those areas where there is no reasonable possibility of residual contamination. Based on a review of the operating history of the facility, historical incidents, and operational radiological surveys as documented in the HSA, as well as subsequent characterization surveys discussed in the next section, the subject open land areas in the northwest corner of the Owner Controlled Area were deemed not impacted by licensed activities or materials. Therefore, it was determined that the "non-impacted" classification is appropriate. (a)(3) Perform surveys adequate to demonstrate compliance with the radiological criteria for unrestricted use specified in 10 CFR 20.1402 for impacted areas. The following activities were performed to support the response to 10 CFR 50.83 (a)(3): Radiological Analyses Supporting Partial Site Release FC-18-002 Potential Radionuclides of The purpose of this document is to compile an initial Concern During the suite of potential radionuclides of concern for the Decommissioning of Fort decommissioning of Fort Calhoun Station. Calhoun Station FC-18-003 Evaluation of Cs-137 Global This document provides a review of information from Fallout in Soils at Fort Calhoun published global fallout studies and Fort Calhoun Station Station (FCS) soil sample data. The document establish the technical basis for anticipated soil concentrations attributable to fallout and establishes criteria for investigating soil Cs-137 concentrations that are higher than those anticipated due to word-wide fallout. FC-18-004 Soil DCGLs for Fort Calhoun This analysis provides the Derived Concentration Station Outside the Protected Guideline Levels (DGCLs) required to support the partial Area ldentified for Partial Site site release of land areas outside of the Fort Calhoun Release Station (FCS) protected area. FC-18-005 Ha bits of the Real lndividual in This document provides the basis for decision making Vicinity of Fort Calhoun on what general radiation Ievels vs. labor hour that will Station, x/0, Direct Radiation give the threshold on when personnel require to Dose Calculation become trained as occupational radiation workers. FC-18-006 Soil Minimum Detectable The purpose of this document is to establish a standard Concentrations for 2x2 Nal methodology for determining the minimum detectable Probes concentration of radioactive contaminants in soil using a standard 2-inch by 2-inch Nal scintillation detector. FC-18-007 SURVEY PLAN -Non-lmpacted Document the methodology for surveying & assessing Open Land Survey Units the land selected for partial site release. FC-18-009 Use of ln-Situ Gamma Spectroscopy for Characterization FC-18-010 Partial Site Release Radiological Measurements EC 69954, rev. 0 Partial Site Release -Phase 1 Page 11 of 15 The purpose of this document is to describe the use of in situ gamma spectroscopy for performing scoping, characterization, and final status surveys in support of characterization and License Termination. The purpose of this document is to compile the results of the field measurements performed in support of the partial site release of Fort Calhoun Station property outside of the Protected Area. References Supporting support the response Partial Site Release 10 CFR 50.83 (a)(3} response: NUREG-1575 Multi-Agency Radiation and Site lnvestigation Manual (MARSSIM} NUREG-1757 Consolidated Decommissioning Guidance: Characterization, Survey and Volume 1 & 2 Determination of Radiological Criteria Fort Calhoun Nuclear Station Limited Site Radiological Characterization Survey Report (January 2017) Fort Calhoun Nuclear Station Limited Site Non-Radiological Characterization Survey Report (January 2017) FC-18-010, Partial Site Release Radiological Measurements concluded the following: The direct gamma seans using Nal detectors did not identify any locations that required further survey or examination. AII areas surveyed showed count rates consistent with the expected background count rates. The direct gamma spectroscopy and discrete soil sample measurements did not identify any FCS related radioactivity. They did identify low-levels of Cs-137 in low-points and relatively undisturbed locations (e.g. wooded areas) consistent with the expected residual Ievels from historical nuclear weapons testing. The results of the other analysis described in the table above support this conclusion. Other Analysis: The revisions to FC06808, FC06816, FC06822, and FC08513 as described in Section 3.0 of this EC do not involve any change in DSAR described evaluation methodology or use of an alternative evaluation methodology. These calculation revisions support an Exclusion Area Boundary with a radius of 1525' around the auxiliary Building Stack. Dose rates would be experienced with an Exclusion Area Boundary that is approximately 1525 ft from the centerline of the Auxiliary Building Stack do not impact the area of the site to be released. 3.2. Design Considerations EC 69954, rev. 0 Partial Site Release -Phase 1 Page 12 of 15 Per CC-FC-104 , Section 4.3.8.B, since the change is NOT administrative, CC-FC-102 was used to identify applicable design inputs and impacts. CC-FC-102, Attachment 1 , Design Attributes Review (DAR) was used. The evaluation of the applicable topies from the DAR is documented below. 3.2.1. Safety Classification (DAR 4.1.4.B) Safety Related (CQE) based on the classification of some of the calculations to be revised. 3.2.2. Codes and Standards (DAR 4.1.7) The activity will be performed in accordance 10 CFR 50.83 , Release Of Part Of A Power Reactor Facility Or Site For Unrestricted Use. The use of this 10 CFR invokes the use of other regulatory guidance, such as, but not limited to , 10 CFR 50.59, 10 CFR 50.54, etc. 3.2.3. Analysis/Calculation Changes (DAR 4.1.8) Changes to following calculation will be made as described in Section 3.0 of this EC: FC06802 -ENVIRONMENTAL RADIOACTIVITY RELEASE INVENTORIES FOLLOWING A WASTE GAS DECAY TANK RUPTURE AND LIQUID WASTE TANK RUPTURE FC06808 -ATMOSPHERIC DISPERSION COEFFICIENTS (X/QS) AT THE EAB AND LPZ FOR IDENTIFIED DESIGN BASIS ACCIDENTS' RELEASE POINTS FC06816 -SITE BOUNDARY AND CONTROL ROOM DOSES FOLLOWING A FUEL HANDLING ACCIDENT IN THE FUEL POOL AREA USING ALTERNATE SOURCE TERMS FC06822 -SITE BOUNDARY AND CONTROL ROOM DOSES DUE TO AIRBORNE RELEASE FOLLOWING A LIQUID WASTE TANK FAILU RE FC08513 -EAB RADIATION SHINE DOSE 18 MONTHS POST SHUTDOWN WITH THE SFP DRAINED. FC08513 -EAB RADIATION SHINE DOSE 18 MONTHS POST SHUTDOWN WITH THE SFP DRAINED FC08515 -PD-AA-1 GASEOUS RELEASE THRESHOLDS EC 69954, rev. 0 Partial Site Release -Phase 1 Page 13 of 15 FC08557 -FUEL HANDLING ACCIDENT IN THE SPENT FUEL POOL SITE BOUNDARY AND CONTROL ROOM DOSE EA17-010-DSAR 14.18, SAFETY ANALYSIS-FUEL HANDLING ACCIDENT IN SPENT FUEL POOL, DESIGN & LICENSING BASIS RECONSTITUTION REPORT New Calculations to be issued via the EC. FC08790-ATMOSPHERIC DISPERSION FACTORS (X/QS) AT THE DECOMMISSIONING EXCLUSION AREA BOUNDARY (EAB) FOR RADIOLOGICAL RELEASES FROM FORT CALHOUN STATION FC08791-SITE BOUNDARY (EAB) DOSE FOLLOWING A FUEL HANDLING ACCIDENT IN THE FUEL POOL AREA IN SUPPORT OF A REDUCED EAB DISTANCE DURING DECOMMISSIONING FC08792 -SITE BOUNDARY (EAB) DOSE FOLLOWING A LIQUID WASTE TANK RUPTURE ACCIDENT IN SUPPORT OF A REDUCED EAB DISTANCE DURING DECOMMISSIONING 3.2.4. Fire Protection lmpact (DAR 4.1.11) No impacts as described in the attached LS-FC-128 and CC-FC-209 reviews. 3.2.5. Environ. Condition Limits/ Restrictions / Changes (DAR 4.1.13) Verification that Release Does Not lmpact Environmental lmpact Statement performed. See 10 CFR 50.83 review in Section 3.1 of this EC. Project 2444 task no. 00627583 630-08. 3.2.6. Review of available Operating Experience (DAR 4.1.14) Review was performed of the Zion Station Request for Partial Site Release (doc # ZS-2105-0134) and the LACBWR Request for Partial Site Release (doc # LACBWR Correspondence LC-2016-21). lnsights into the implementation of 10 CFR50.83 as it relates to 10 CFR 50.59 and other aspects were gained from review of these documents. These insights are incorporated into this EC. 3.2.7. Procedure Changes (DAR 4.1.21) CH-ODCM-0001, Off-Site Dose Calculation Manual (ODCM). RA 2018-0199. EP-FC-1001 Addendum 3, Permanently Defueled Emergency Action Level Technical Bases. RA 2018-0201. Required document changes are summarized above in Section 3.0 of this EC. 3.2.8. Any radiation protection / ALARA concerns (DAR 4.1.25) EC 69954 , rev. 0 Partial Site Release -Phase 1 Page 14 of 15 These documents are supporting attachments of this EC. See 10 CFR 50.83 review in Section 3.1 of this EC for these reviews. Assessment Final Report (Attachment 1). Project 2444 task no. 00627583-01-630. Assessment as required by 10 CFR 50.83(a)(2) Perform a Historical Site Assessment of the Area to be Released. Project 2444 task no. 00627583-01 -630-07. Assessment as required by 10 CFR 50.83(a}(l) verify Siting Criteria for lOCFR Part 100 Continue to be Met. Project 2444 task no. 00627583-01-630-08. 3.2.9. Public health and safety req'ts new / changes (DAR 4.1.26) Verification as required by 10 CFR 50.83(a}(l)ii ensuring there is no reduction in Emergency. EP-FC-2001-5054Q, Emergency Planning 10CFR50.54(Q) Review Program, has been used to facilitate this screening and is attached to this EC. Project 2444 task no. 00627583-01-630 -01. 3.2.10. New or changed chemistry req'ts (DAR 4.1.31) See 10 CFR 50.83 review in Section 3.1 of this EC for these reviews. Verification as required by 10 CFR 50.83(a}(l)iii -Chemistry Evaluation ODCM Requirements and Effects for Effluent Releases. Project 2444 task no. 00627583 630-03. Verification as required by 10 CFR 50.83(a}(l)iii -Chemistry Evaluation ODCM Requirements and Effects for Environmental lmpact. Project 2444 task no. 00627583-01-630-04. 3.2.11. Changes to security requirements (DAR 4.1.34) Verification as required by 10 CFR 50.83(a}(l)ii -Security perform Evaluation Per 50.54(p) to Ensure There is no reduction in Security Effectiveness. SY-FC-101-104-F-01 has been used to facilitate this screening and is attached to this EC. Project 2444 task no. 00627583-01-630-02. 3.2.12. lnterfacing Department lmpact (DAR 4.1.39} EC 69954, rev. 0 Partial Site Release -Phase 1 Page 15 of 15 This EC impacts the following interfacing departments due to the required 10 CFR 50.83 assessments:

Radiation Protection
Emergency Preparedness
Chemistry
Regulatory Assurance
Security
Operations 3.2.13. Nuclear Electric lnsurance Limited (NEIL} Requirements (DAR 4.1.41} NEIL has been informed of this pending change by the FCS site NEIL liaison. 3.2.14. Program lmpact (DAR 4.5) 4. References This change impacts the Fire Protection Program. The Fire Protection Program impacts have been evaluated via CC-FC-209, Attachment 1 and LS-FC-128, Attachment

1. 4.1. 10 CFR 50.83, "Release of Part of a Power Reactor Facility or Site for Unrestricted Use" 4.2. Zion Station Request for Partial Site Release (doc # ZS-2105-0134) 4.3. LACBWR Request for Partial Site Release (doc # LACBWR Correspondence LC-2016-21). 4.4. Boundary Survey drawing, V _BNDY _73338. 5. Attachments 5.1. CC-FC-209, Attachment 1 , Approved Fire Protection Program Configuration Change lmpact Review. 5.2. LS-FC-128, Attachment 1, Fire Protection Change Regulatory Review (FPCRR). 5.3. 10 CFR 50.59 Review Documents 5.4. 10 CFR 72.48 Review Documents 5.5. EP-FC-2001-5054Q, Emergency Planning 10CFR50.54(Q)

Review Program. 5.6. LS-FC-120-1001 -F-01, 10 CFR 50.82 Screening. 5.7. SY-FC-101-104-F-Ol, Screening Evaluation For Revisions To The Physical Security Plan (50.54p Screening). EC Number Facility Type/Sub-type

Attributes Engineering Change 0000069954 000 FC DCR DSGN Attribute Sub-category:

DAR Attribute Name CC-FC-102 ATT 1, 7, 8 CC-FC-102 ATT lOA CC-FC-102 ATT lOF CC-FC-102 ATT lOF CC-FC-102 ATT lOF CC-FC-102 ATT lOF CC-FC-209 ATT 1 CC-FC-212-1001 ATT 1 Page: 1 Value PassPort Date DAR AND ATTACHMENTS X9796 06/14/2018 OPS ATT. lOA X9796 06/14/2018 CHEM X9796 06/14/2018 EP X9796 06/14/2018 REG ASSURANCE X9796 06/14/2018 SECURITY X9796 06/14/2018 FP X9796 06/20/2018 ALARA DESIGN REVIEW X9796 06/14/2018 ATTACHMENT 1 Design Attribute Review (DAR) Page 1 of 6 CC-FC-102 Revision 7 Page 1 of 8 IDENTIFY the applicability of the following to the Design Change. WHEN a topic is determined to be applicable, then PLACE the applicable topic information in the Design Change. lf the information is installation-related, then PLACE this information in the lnstaller lnstructions (Attachment C in CC-FC-103). lf not installation-related, then PLACE the topic information in a segregated design consideration section, or within the documentation required by the procedures governing a particular attribute. Optional fields "Tracking of Action" and "References" are available for notation by the Preparer if desired to assist the Preparer in manaaina the activitv. Section Design Change Attribute EC 69954 Applicab Tracking of References le Action 4.1.4.A. IDENTIFY Basie SSC Functions D 4.1.4.B. IDENTIFY Configuration Change safety lncluded in classification. DCS 4.1.4.C. IDENTIFY Seismic Classification of the D SSC. 4.1.5. PROVIDE the performance requirements .--, LJ and design conditions (including margin) of the SSC needed to evaluate the change from the existing to the modified systems, structures, or components. 4.1.6. DETERMINE the design requirements D necessary to facilitate periodic surveillance testing and acceptance testing that is necessary for the Configuration Change being considered. 4.1.7. DETERMINE the Codes, Standards, and lncluded in Regulatory Requirements applicable to the DCS Configuration Change. 4.1.8. DETERMINE changes required to existing D .,,. Design Analysis or new parameters that require new calculations or calculation revisions that are used to assess the acceptability of a system or a component function in meeting various physical req uirements. 4.1.9. lf Redundancy, Diversity and Separation D requirements are identified or affected, then REVIEW the original design basis as well as any subsequent modifications. 4.1.10. IDENTIFY any Failure Effects requirements. D (see Attachment

4)

Section 4.1.11. 4.1.12. 4.1.13. 4.1.14. 4.1.15. 4.1.16. 4.1.17. 4.1.18. 4.1.19. ATTACHMENT 1 Design Attribute Review (DAR} Page 2 of 6 Design Change Attribute Applica Tracking of ble action IDENTIFY Fire Protection and fire-induced radiological hazards requirements (reference 10 CFR 50.48(f)), by using the "Screening for Approved Fire Protection Program (AFPP) lmpact", Attachment

2. DETERMINE any Material requirements, D such as material grade, product form, compatibility with existing or other new materials, galvanic interaction between dissimilar metals, special welding material requirements, critical properties, performance characteristics, alternative materials as well as any Material Suitability requirements such as compatibility, electrical i nsulation properties, protective coating, corrosion resistance, mechanical insulation etc. necessary for the Configuration Change. Determine environmental conditions and 00627583-01-630-impacts. Also see EN-FC-103.

08 REVIEW the Operating Experience lncluded in databases available. DCS DOCUMENT program impact within the D section of the configuration change that discusses program impacts (Attachment 8). EVALUATE if System Operational D Requ i rements have changed. IDENTIFY any Human Factors D requirements. IDENTIFY procedure changes per direction lncluded in in Attachment

9. DCS IDENTIFY any changes or additional training D requirements for various departments, per direction in Attachment

9. CC-FC-102 Revision 7 Page 2 of 8 References Reviews performed per LS-FC-128 and CC-FC-209.

Section 4.1.20. 4.1.21. 4.1.22. 4.1.23. 4.1.24. 4.1.25. 4.1.26. ATTACHMENT 1 Design Attribute Review (DAR) Page 3 of 6 Design Change Attribute Applica ble CONSIDER the functional and physical system D interface requirements, including the effect of cumulative tolerances between the subject system or component and adjacent or related support systems, structures, and components that may have been affected by the Configuration Change. DETERMINE specialized layout and arrangement D requirements. DETERMINE if the Radiation Protection/ALARA programs are affected by review of changes that affect any of the following during normai or post accident conditions: Radiation sources; changes affecting controlled radiation areas; contaminated systems; radiation monitoring systems; HVAC Systems which could transport airborne contaminants; change or alter shielding. (see Attachment

5) DETERMINE the need for walkdowns to look at D accessibility to the work area( s) and any special installation considerations that need to be addressed during design development.

DETERMINE Accessibility for maintenance, repair D and ln-Service lnspection (ISI) and ln-Service Testing (1ST), and the conditions under which these activities will be performed. DETERMINE handling, storage, cleaning, and D shipping requirements, as well as transportability requirements for items which require special handling during transit from supplier to FCS, from FCS to vendor (for repair), or from FCS receiving to final placement in the plant. DETERMINE the effect of the Configuration Change on existing Emergency Plan or environmental and discharge monitoring that are used to prevent undue risk to public health and safety. Tracking of action 00627853 630, 00627583 630-05, 00627583 630-07 00627853 630-01 CC-FC-102 Revision 7 Page 3 of 8 References Section 4.1.27. 4.1.28. 4.1.29. 4.1.30. 4.1.31. 4.1.32. 4.1.33. 4.1.34. 4.1.35. ATTACHMENT 1 Design Attribute Review (DAR) Page 4 of 6 Design Change Attribute Applica ble DETERMINE lndustrial Safety requirements D such as restricting the use of dangerous materials, hazardous chemicals, escape provisions from enclosures, pertinent OSHA requirements, and grounding of electrical systems. DETERMINE impact on special nuclear D materials and accountability of nuclear materials as well as fuel stored in the spent fuel pool, by using Attachment

6. DETERMINE Load Path requirements for ,......, LJ installation, removal, and repair of equipment and replacement of major components.

IDENTIFY Mechanical System D Characteristics where design limits are placed on the mechanical properties of a system or components. IDENTIFY Chemistry requirements where limits are placed on the chemical properties of a system or component based upon safety, reliability, ALARA, economics, or other considerations. IDENTIFY Electrical requirements where D limits are placed on the electrical properties of a system or component. IDENTIFY Instrument and Control D requirements, including digital technology requirements. (Digital/CDA check using Attachment

3) IDENTIFY Security requirements such as FCS monitoring, alarm systems, vehicle barrier systems, security and security lighting.

IDENTIFY Civil/Structural requirements D where design limits are placed on the structural properties of a SSC such as equipment foundations and component /' supports. Tracking of action 00627853-01-630-03 00627853-01-630-04 00627853-01 -630-02 CC-FC-102 Revision 7 Page 4 of 8 References Section 4.1.36. 4.1.37. 4.1.38. 4.1.39. 4.1.40. 4.1.41. 4.1.42. ATTACHMENT 1 Design Attribute Review (DAR) Page 5 of 6 Design Change Attribute Applica ble lf the Configuration Change adds, relocates, D or alters Seismic Category I mechanical and/or electrical components then ENSURE that the Seismic Dynamic Qualification (SD/Q) of the components has been addressed per CC-FC-320-1003. DETERMINE Personnel Requirements and D Limitations such as the need for trade specialists and engineering experts as well as support personnel, such as Radiation Chemistry technicians, welding technicians with special expertise, use of specific contractor or station procedures for installation or the need for mock-ups for training, installation, or operation. LIST special procedures and installation D specifications that apply, but are not part of the normai installation procedural direction. DETERMINE lnterfacing Department impact of the Configuration Change, such as Operations, Systems Engineering, Training, Maintenance, Design Engineering Fuels, Radiation Protection, Business Technology (BT) and others. (see Attachments 10A through 10H) CONSIDER impact on License Renewal. D REVIEW the proposed changes for conformance with requirements of any applicable Nuclear Electric lnsurance Limited (NEIL) lnsurance Standard, or other appropriate insurance standards. DETERMINE the impact of the design D change on System Vulnerability. Tracking of action CC-FC-102 Revision 7 Page 5 of 8 References Section 4.1.43. 4.4. 4.5. ATTACHMENT 1 Design Attribute Review (DAR) Page 6 of 6 Design Change Attribute Applic able IDENTIFY changes to the plant, both D permanent and temporary, that potentially impact the switchyard or the interconnected transmission system. Communication and coordination of these plant changes with the applicable transmission entities is a requirement of the mandatory NERC Reliability Standards.(Attachment

11) Configuration Control Activities-Use of D Attachment 7 Determination of Program lmpact -Use of l6l Attachment 8 Tracking of action CC-FC-102 Revision 7 Page 6 of 8 References ATTACHMENT 7 Checklist of Configuration Activities Page 1 of 1 CC-FC-102 Revision 7 Page 7 of 8 "*" 1 d' h n 1cates t at 1t must b e complete d 1 'f h pnor to operat1on, but only I t e act1vitv is selected.

... Q) 0 &: ! n, Configuration Procedure(s) .!:? -oO 1 0 O"-Q) Activities " Update Tech Spec or license LS-FC-101 Yes* Update Tech Spec bases LS-FC-101-1000 D DSAR Change Notice NOD-QP-16 and As req'd by LS-FC-107 forms NOD-QP-16 Technical Requirement Manual Plant Specific D Design Bases Database Requirements NOD-QP-16 D Update Design Bases Topical Reports and System Documents NOD-QP-16 D Update of Cr i tical Control Room Drawings CC-FC-103 , CC-FC-112, D Yes* CC-FC-104, nuclear fuels Additional Walkdown (s) CC-FC-103-1001 D Affected Equipment or Component Record List Plant Specific D Update setpoint and calibration database (IISCP or other) Plant Specific D Electrical Load Monitoring Plant Specific D Cable Management Database (raceway and conduit) program Plant Specific D Update of Nuclear Fuels Analysis Attachment 1 OG D Yes* Plant Barriers Affected Plant Specific D Offsite Dose Calc Manual CY-FC-170-3100 D Yes* Update VETIP Manuals CC-FC-204 D Update Fire Protection Documentation Package CC-FC-209 D Update Use of Locks on Valves Operations D Yes* Equipment Tagging & Labeling Operations D Yes* Address Open Operability Determ i nations OP-FC-108-115 D Update or Create Equip Bill of Material SM-FC-300 D Deleted --D Functional Equip Group (FEG) Update ER-FC-200 D Clearance and Tagging Program (C/0 Models Updated) Operations D Equipment PMT Requirements Plant Specific D Other items D Emergency Response Data System Data Point Library Update (EP-FC-123) lf applicable , NRC is to be D informed within 30 days of the ch a ng e to the library files Update Cyber Security Assessment database CC-FC-6-AD-FCSG-48 -6 D List of equipment being replaced to FCS Supply Chain Manager SM-FC-4006 D Deleted --D " ATTACHMENT 8 Checklist for Programs lmpact Page 1 of 1 "*" lndicates that it must be completed prior to operation, but only if the activity is selected. Program Activities Procedure(s) Predefine / Surveillance Program SO-G-23 Performance Centered Maintenance (PCM) Program ER-FC-200 Create or Revise PCM Template ER-FC-200 Maintenance Rule Program ER-FC-310 Instrument Calibration as part of Predefine Surveillance Program SO-M-26 Deleted --Deleted --Deleted --Deleted --Deleted --Deleted -Boric Acid Corrosion Control (BACC) Program ER-FC-331 Deleted --Deleted --Deleted -Deleted --Deleted -Deleted -Deleted --Lead Shielding Program Plant Specific Deleted -Deleted --GL-89-13 Program for Heat Exchangers and Piping ER-FC-340 Environmental Review EN-FC-103 Deleted -Deleted --Deleted --Deleted -EmerQencv Preparedness (EP) Proarams EP-FC-120 Buried Pioina and Raw Water Corrosion Proaram ER-FC-5400 Cyber Security ProQram SO-G-120 Deleted --Control Room Envelope (CRE) Habitability Program Plant Soecific Deleted -Deleted --Cable Program ER-FC-300-150 CC-FC-102 Revision 7 Page 8 of 8 0 CI) .... ... 0 co *.::: .!:! D.. ,, C. *c-CI) 0::: "' C. 0 D Yes if Tech Spec D D D D D D D D D D D D D D D D D D D D D D D D D D D D D D D D D 1 " ' ATTACHMENT 1 OA CC-FC-102 Revision 7 Page 1 of 2 Operations Department (including Radwaste} Configuration Change Review Checklist Page 1 of 1 Configuration Change Document No.: This Attachment is a sam pie of a format that can be used to obtain lnterDepartmental approvals of a Configuration Change. The content of the Attachment is the required Ievel of questions that each department is expected to answer and provide concurrence before Engineering issues the Configuration Change. As long as the content of the Attachment is being addressed, there is no requirement to use this particular format. This review covers activities performed during the design phase of a Configuration Change, including initial meetings, walkdowns, detailed design development, and identification of impacts on other station programs and areas of resoonsibilitv. Review Reauirements 1 lnitial/Date

1. The impact on the station equipment, changes in equipment responses, and changes in operator response for different scenarios have been discussed.

As the representative of the BRL/6/16 Operations Department, 1 fully understand the impact, including training needs, upon my /18 department and concur that mv concerns have been adequatelv addressed.

2. 1 have confirmed the identified Programs, Procedures and Training requirements are complete, or initiated tracking for completion, for my department in accordance with CC-FC-102 attachments listed below:

Attachment 7 -Configuration Activities (List Tracking No . ) N/A
Attachment 8 -Programs (Tracking No . ) N/A
Attachment 9 -Procedures and Training (Tracking No . \ N/A I 3. Acceptance criteria for Post Maintenance Testing and any special tests required to adequately demonstrate system operability following implementation of a Configuration Change have been N/A specified.

4. ALARA for operation has been considered in the design. BRL/6/16 /18 5. Appropriate component labeling is used in the design package, including drawings.

N/A 6. The Configuration Change does not interfere with operation of existing nearby equipment. BRL/6/16 /18 7. There are no operating procedure changes required by this Configuration Change that introduce new susceptibility to water hammer or hydraulic transients that might result in impacting plant N/A operation.

8. The design can be implemented within constraints of plant operation/mode.

This includes an operation assessment of all affected systems and interfacing structures, systems and BRL/6/16 components during the mode(s) in which the design change is being implemented. /18 9. The configuration change has been reviewed and any new vulnerabilities and the impact of the BRL/6/16 design change on the identified existing vulnerabilities has been assessed. /18 10. lmpact of this configuration change on Operator Aids has been reviewed and appropriate actions BRL/6/16 have been or will be taken (refer to the Operator Aid Log) /18 11. The configuration change has been reviewed and impacts on margin are understood. The BRL/6/16 design summary adequately addresses known margin impacts. (refer to CC-FC-13) /18 12. Changes impacting the Clearance and Tagging Program have been identified and are being N/A tracked. 13. lmpact on configuration control and potential configuration control event precursors have been N/A identified and are being addressed.

14. lmpacts on B.5.b, SBO, flooding protection, fire protection, and other issues requiring operator BRL/6/16 manual actions have been identified and are beinq addressed.

/18 15. Changes to type of M&TE used and test methodology have been evaluated per MA-FC-716-040. N/A 16. lmpacts to and additions ofTCA's and TSA's have been processed per OP-FC-102-106. N/A My department has reviewed the Configuration Change Document ( or appropriate contents) and understands the impact regarding my department's operations , procedures, and programs. Ali Configuration Change support activities required ofmy department have been identified. __ Brock Lindau _______ _ Date: _6/20/2018 _ Operations Department Representative Return the completed form to the Configuration Change Preparer or Sign Electronically in Asset Suite CC-FC-102 Revision 7 Page 2 of 2 CC-FC-102 Revision 7 Page 1 of 1 ATTACHMENT 10F Configuration Change Review Checklist for Use by Other Departments Page 1 of 1 Department _Chemistry ___ _ CHANGE NO.: EC69954 This Attachment is a sample of a format that can be used to obtain lnter-Departmental approvals of a Configuration Change. The content of the Attachment is the required Ievel of questions that each department is expected to answer and provide concurrence before Engineering issues the Configuration Change. As long as the content of the Attachment is being addressed, there is no requirement to use this particular format. Th i s review covers activities performed during the design phase of a Configuration Change, including initial meetings, walkdowns , detailed design development, and identification of impacts on other station programs and areas of responsibility. R e view R eq u irements 1. My department has participated in the Configuration Change process (scope meetings , walkdowns, impact review, etc.) as required , and concurred with the proposed Configuration Change; and fully understands the Configuration Change i mplicat i ons for my department.

2. 1 have confirmed the identified Programs, Procedures and Training requirements are complete, or in i tiated tracking for completion , for my department in accordance with CC-FC-102 attachments listed below:

Attachment 8 -Programs (Tracking No._N/A __ _
Attachment 9 -Procedures and Training (Tracking No. __ N/A __ _ 3. Other Considerations required to be completed i n support of the Configuration Change: __ None ___________________________

_ 4. The configuration change has been reviewed and impacts on margin are understood. The design summary adequately addresses known margin impacts. (refer to CC-FC-13) ln i tial/Date mm/06/20/18 mm/06/20/18 mm/06/20/18 mm/06/20/18 mm/06/20/18 My department has reviewed the Configuration Change document (or applicable contents) and understands the impact regarding my department's operations, procedures, and programs. Ali Configuration Change support activities required of my department have been identified. Matthew Marcellus Date: 06/20/18 Affected Plant Departm e nt Representative (See EC Milestone for Dept Review signature authentication) Retum the completed form to the Configuration Change Preparer or Sign Electronically in Asset Suite CC-FC-102 Revision 7 Page 1 of 1 ATTACHMENT 10F Configuration Change Review Checklist for Use by Other Departments Page 1 of 1 Department __ EP ______ _ CONFIGURATION CHANGE DOCUMENT NO.: ______ _ This Attachment is a sam pie of a format that can be used to obtain lnter-Departmental approvals of a Configuration Change. The content of the Attachment is the required Ievel of questions that each department is expected to answer and provide concurrence before Engineering issues the Configuration Change. As long as the content of the Attachment is being addressed, there is no requirement to use this particular format. This review covers activities performed during the design phase of a Configuration Change, including initial meetings, walkdowns, detailed design development, and identification of impacts on other station programs and areas of responsibility. Review Requirements

1. My department has participated in the Configuration Change process (scope meetings, walkdowns, impact review, etc.) as required, and concurred with the proposed Configuration Change; and fully understands the Configuration Change implications for my department.

2. 1 have confirmed the identified Programs, Procedures and Training requirements are complete, or initiated tracking for completion, for my department in accordance with CC-FC-102 attachments listed below:

Attachment 8 -Programs (Tracking No .. _____ _
Attachment 9 -Procedures and Training (Tracking No. _____ _ 3. Other Considerations required to be completed in support of the Configuration Change: 4. The configuration change has been reviewed and impacts on margin are understood.

The design summary adequately addresses known margin impacts. (refer to CC-FC-13) lnitial/Date JEF/6/19/18 JEF/6/19/18 JEF/6/19/18 JEF/6/19/18 JEF/6/19/18 My department has reviewed the Configuration Change document (or applicable contents) and understands the impact regarding my department's operations, procedures, and programs. AII Configuration Change support activities required of my department have been identified. Jason Fickbohm Date: 6/19/18 Affected Plant Department Representative (See EC Milestone for Dept Review signature authentication) Retum the completed form to the Configuration Change Preparer or Sign Electronically in Asset Suite CC-FC-102 Rev i sion 7 Page 1 of 1 ATT ACHMENT 1 OF Configuration Change Review Checklist for Use by Other Departments Page 1 of 1 Department __ Regulatory Assurance _______ _ CONFIGURATION CHANGE DOCUMENT N0.: __ ----=-6""'"99 ___ 5'""'4'------- This Attachment is asam pie of a format that can be used to obtain lnter-Departmental approva l s of a Configuration Change. The content of the Attachment is the required Ievel of questions that each department is expected to answer and provide concurrence before Engineering issues the Configuration Change. As long as the content of the Attachment is being addressed, there is no requirement to use this particular format. This review covers activities performed during the design phase of a Configuration Change, including initial meetings, walkdowns, detailed design development, and identification of impacts on other station programs and areas of responsibil ity. Rev i ew Requ i rement s 1. My department has participated in the Configuration Change process (scope meetings, walkdowns, impact review, etc.) as required, and concurred with the proposed Configuration Change; and fully understands the Configuration Change implications for my department.

2. 1 have confirmed the identified Programs, Procedures and Training requirements are complete, or initiated tracking for completion, for my department in accordance with CC-FC-102 attachments listed below:

Attachment 8 -Programs (Tracking No. _____ _
Attachment 9 -Procedures and Training (Tracking N o. _____ _ 3. Other Considerations required to be completed in support of the Configuration Change: 4. The configuration change has been reviewed and impacts on marg i n are understood. The des i gn summary adequately addresses known marg i n impacts. (refer to CC-FC-13) lnitial/Date CAC 6/21/18 CAC 6/21/18 CAC 6/21/18 CAC 6/21/18 CAC 6/21/18 My department has reviewed the Configuration Change document (or applicable contents) and understands the impact regarding my department's operat i ons, procedures, and programs. AII Configuration Change support activ i ties required of my department have been identified. __ Corey A. Cameron ____________

_ Date: CAC 6/21 /18 __ _ Affected Plant Department Representative (See EC Milestone for Dept Rev i ew s i gnature authentication) Retum the completed form to the Configuration Change Preparer or Sign Electronically in Asset Suite CC-FC-102 Revision 7 Page 1 of 1 ATTACHMENT 10F Configuration Change Review Checklist for Use by Other Departments Page 1 of 1 Department __ 832 _____ _ CONFIGURATION CHANGE DOCUMENT N0.: ______ 6 __ 9 ___ 95 ___ 4 __ * -----This Attachment is a sample of a format that can be used to obtain lnter-Departmental approvals of a Configuration Change. The content of the Attachment is the required Ievel of questions that each department is expected to answer and provide concurrence before Engineering issues the Configuration Change. As long as the content of the Attachment is being addressed, there is no requirement to use this particular format. This review covers activities performed during the design phase of a Configuration Change, including initial meetings, walkdowns, detailed design development, and identification of impacts on other station programs and areas of responsibility. Review Requ i rements 1. My department has participated in the Configuration Change process (scope meetings, walkdowns, impact review, etc.} as required, and concurred with the proposed Configuration Change; and fully understands the Configuration Change implications for my department.

2. 1 have confirmed the identified Programs, Procedures and Training requirements are complete, or initiated tracking for completion, for my department in accordance with CC-FC-102 attachments listed below:

Attachment 8 -Programs (Tracking No. __ N/A. __ _
Attachment 9 -Procedures and Training (Tracking No. 2018-00578-01)

3. Other Considerations required to be completed in support of the Configuration Change: N/A ______________________________

_ 4. The configuration change has been reviewed and impacts on margin are understood. The design summary adequately addresses known margin impacts. (refer to CC-FC-13) lnitial/Date SRB/6/18/18 SRB/6/18/18 SRB/6/18/18 SRB/6/18/18 SRB/6/18/18 My department has reviewed the Configuration Change document (or applicable contents) and understands the impact regarding my department's operations, procedures, and programs. AII Configuration Change support activities required of my department have been identified. _Samuel Berkey _________ _ Date: 6/18/18 __ _ Affected Plant Department Representative (See EC Milestone for Dept Review signature authentication) Retum the completed form to the Configuration Change Preparer or Sign Electronically in Asset Suite Completed ALARA Design Review Attached AT1."AC..l:l~>>:r'iT 1 AI.ARA. Dasign Reviliw Page 1 of 1 C;C-foC-212* l 001 Rc-\0.ision 1 Pag,;: 1 of 1 Change Pookase Number: Y n11e: fuv 1Ya,\ ~\te &\,e:o..w.. F:lril\X ::C l. B~rics (S.1.1.l} App!i<:n";,lt:'! Yci; ~"'"' 2. Coboh RM.uction (5, 1.1.2) ,\pp)w,;~1,1,:? D 'ies l&J ~o }, C\1r.l><1:11iuaii.<>n Conccr~ (5.l .1.:!-l Applk;nbh,'.l 0 Yc~ ~.!o-1:' ... Ra.clli.ti.on Slt:icldi~ ().m-Jt,rns (~.1 .1 .4) ,\pp][cable? D Vo:, Ko 5. Sraj:fic Ai.ARA C cn.o;:ra,; {3, l.i ~) i,ITil.:;a*,..1~ D Y;:;; ['gj No .. lf ""*>* qu.eAfio11 ahovc i~ 8D!IWC!Cd ya;, tht:o m,,.,rd c;;mC.!1'11(!.)

ml d.lc COOJ~emtit'l!z 1hnl wiJ1 bt:: w-1:.t 11, maintai.B do1e ,\L'\RA (<1ll.'lru:.

~l..lr1luri*l r,!1.x:i.~, Lf ~cc:~~IIJ}'J. (R P Man:ager ar de.s111nee) Prinl _J Slgn CC-FC-209, Attachment 1 FP lmpact signed copy pdf attached. CC-FC-209 FP Impact signed copy / FCS CC-FC-209 Revision 1 Page 20 of 22 Leval 3 -lnforrnatlon Use Procedure A TT ACHMENT 1 FIRE PROTECTION PROGRAM CONFIGURATION CHANGE IMPACT REVIEW Page 1 of 3 EC Number: =69=9._.5_.4 ________ _ Revision: ..._O ___ _ Configuration Change

Description:

Partial Site Release -Phase 1 1. Configuration Change lmpact Review -Spent Fuel Pool (SFP) Cooling. Makeup or Support Systems and Equlpment -Fire-lnduced Radlological Hazards A. ls the scope/location of SFP cooling, makeup or support systems/components changed? D Yes 181 No B. ls the function of SFP cooling, makeup or support systems/component changed? C. ls a SFP cooling, makeup or support system/component cable add~/removed/changed/rerouted? D Yes D Yes 181 No No lf any questlon ls answered "Yes", then REVIEW the Updated Safety Analysis Report (USAR)/Fire Hazards Anelysls (FHA) and DETERMINE if they are affected by the proposed Configuration Change. lf "Yes", then LIST the affected sections, PROVIDE a brief description ofthe change, and INITIATE a change to the document(s} ln accordance with the goveming procedure or process. lf a change to the USAR/FHA is not required, then EXPLAIN why nol The area proposed for partial site release does not contain or lmpact SFP cooling, makeup and support systems and equipment.

2. Configuration Change lmpact Review -Contaminated Plant Areas and Radioactive Waste Storage -Fire-lnduced Radiologlcal Hazards A. ls the scope/location of contaminated plant areas changed? B. ls the scope/location of radioactive waste storage changed? C. ls there an tmpact on engineering controts used to prevent spread of radiation (e.g., floor drains/sumps, ventilation, flood baniers, doors, HEPA or charcoal filters, or monitoring related to plant vents or effluents in tanks)? D Yes D Yes D Yes 181 No l&I No 181 No FCS CC-FC-209 Revision 1 Page 21 of 22 Level 3 -lnformatlon Use Procedure

3. ATTACHMENT 1 APPROVED FIRE PROTECTION PROGRAM CONFIGURATION CHANGE IMPACT REVIEW Pa e 2 of 3 lf any questlon ls answered "Yes", then REVIEW the USAR/FHA and DETERMINE ifthey are affected by the proposed Configuration Change. lf *ves", then LIST the affected sectlons, PROVIDE a brlef description of the change, and ! INITIATE a change to the document(s}

in accordance with the goveming procedure or process. lf a change to the USAR/FHA ls !!21 required, then EXPLAIN why nol The area proposed for partial site release does not contain or impact contamlnated plant areas, radioactive , waste storage or plant engineering controls. Conflguration Change lm(;!§!ct Review -Fire Protection Design A. ls a fire suppression system configuration or function changed? 0 Yes 181 No B. ls a fire barrier configuration or function is changed? D Yes l8l No C. ls a fire detectlon/alarm device or system changed? D Yes l8l No D. ls a combustible loading analysis changed? D Yes l8l No E. ls the occupancy of a room belng changed? 0 Yes l8l No F. Are fire hazards associated with combustible/flammable liquid/gas changed? D Yes 181 No G. Are the emergency lighting system or components changed? 0 Yes 181 No lf any question is answered "Yes*, then REVIEW the USAR/FHA and determine if it is affected by the proposed change. lf "Yes*, then LIST the affected sections, PROVIDE a brief descriptlon of the change, and INITIA TE a change to the document(s} in accordance with the govemlng procedure or process. lf a change to the USAR/FHA is not requlrecl, 1 then EXPLAIN why not. 1 The area proposed for partial site release does not contain or impact fire protection systems or components. 1 1 FCS CC-FC-209 Revision 1 Page 22 of 22 Level 3 -lnformation Use Procedure ATTACHMENT 1 APPROVED FIRE PROTECTION PROGRAM CONFIGURATION CHANGE IMPACT REVIEW Page 3 of 3 4. Configuration Change lmpact Review On Other Documents lf a change to the USAR/FHA, calculatlon, analysls, procedure, pre-fire plan (SO-G-28),or SO-G-103 is necessary that has .!lS!l already been addressed in Sections 1 or 2 above, then LIST the affected documents, PROVIDE a brlef description of the change, and INITIATE a change to the document{s) in accordance wlth the govemlng procedure or process. The only aspect of the fire protection program that is related to this change is the quantification of offsite radlological consequences of postulated fires. Engineering Analysis EA17-002, Revision 1, "Fire Protection Radiological Consequences Analysis" quantifies offsite dose consequences of postulated fires using a X/Q value documented in Table 4 of the Off-Site Dose Calculation Manual (ODCM) Revision 28. The proposed partial site release does not impact the applicable ODCM X/Q value. Therefore the quantified radiological consequences of postulated fires is not impacted by the proposed partial site release. EA17-002 does NOT need to be changed to address the proposed partial site release. 5. lmpact on NEIL Property Loss Control Standards ls the Configuration Change required to be submitted in accordance with the NEIL Property Loss Control Standards? 0 Yes [81 No lf "Yes", then PROVIDE a brief descrlptlon ofthe change, and SUBMIT the Configuratlon Change package to NEIL for review in accordance with the NEIL Property Loss Control Standards and CC-FC-211-1002. Prepared by: ~8.s Gesc.t .... &a~ 1 L~ 1 6/t'f/tf I "/}:)-/ty Sig~ Dafe l ______ --'-N_a~~-------------' ~/A-[Evaluator] Print Reviewed by: [;A.;r, "'1 D,tv.rc.,, [FPPE or designee] Print Additional SME Review(s): N/A [if used] Print srgn Date EC 69954 Attachments: LS-FC-128: m a.;......a LS-FC-128 FP Reg Review EC 69954 ap 10 CFR 72.48 Review Documents: 72.48 review EC 69954 signed copy.~ 10 CFR 50.82 Screening 50.82 EC 69954 approved copy.pdf SY-FC-101-104-F-Ol, Screening Evaluation For Revisions To The Physical Security Plan (50.54p Screening). m~ SY-FC-101-104-F-Ol EC69954 approved c DSAR Figure Mark-ups: m~ DSAR figure mark ups EC 69954.pdf DSAR Section Mark-ups DSAR changes EC 69954.pdf Boundary Survey drawing, V _BNDY_73338. ~/ V _BNDY_73338-BND Yfinal (002).pdf EP-FC-2001-5054Q-Attachment 2, Emergency Planning 10CFR50.54(Q)(3) Screening J E P-FC-2001-5054Q EC66954 approved c 50.59 REVIEW COVERSHEET FOPJ\1 Statfon: __ F ___ C=S--------------- LS-FC-104-1001 Revision 0 Page 1 of2 Activity/Document Number: =E=C....,6=9.::..95"'"4.,___ _____________ _ Revision Number: _.O'------ Title: PARTIAL Sl"TE RELEASE -PHASE I NOTE: For 50.59 Evaluations, information on this form will provide the basis for preparing the biennial summary report submitted to the NRC in accordance with the requirements of 10 CFR 50.59(d)(2). Description of Activity: (Provide a brief, concise description ofwhat the proposed activity involves.) The proposed Activity requests approval from the :flj'R.C to remove a portion of the Ft Calhoun site from the Part 50 license (License No. DPR-40). Specifically, the activity will remove/release the non-impacted survey units from the Part 50 license in accordance with 10 CFR 50.83, "Release of Part of a Power Reactor Facility or Site for Unrestricted Use" subpart (b ). EC 69954 wi1I document the results of the assessment/reviews in support of this activity and issue any associated document revisions per 10 CFR 50.83 and applicable subparts of 10 CFR 50.54. EC 69954 documents that the activity does not include any tests or experi.ments or any changes to DSAR descnbed evaluation methodologies and use any altemate mythology. Key aspects of this proposed Activity include the following:

Revision of calculations/analysis that support that the resultant dose to individual members of the public does not exceed the limits and stand.ards of 10 CFR 20, Subpart D.
Documenting that effluent releases remain within license conditions.
Documenti.ng that the early release of the subject property does not have any adverse effect on the environmental monitoring program and Offsite Dose Calculation Manual.
Documenting all applicable statutory and regulatory requirements continue to be met.
Issuance of the revised applicable station documents.

The calculations revised as a result of this proposed Activity support a physical reducti.on of the site Exclusion Area Boundary (EAB}. The revised applicable station documents wi1I reflect the updated site EAB. Reason for Activity: (Discuss why the proposed activity is being performed.) The change is part of the overall strategy to eventually release the site for unrestricted use. This activity is in support of Phase I ofFCS Project 2444, Partial Site Release. The activity ofthe early release ofthe subject land supports the eventual overall license termination process in accordance with NRC regulations. Effect of Activity: (Discuss how the activity impacts plant operations, design bases, or safety analyses described in the UFSAR.) The information documented by EC 69954 will be used to support a 1'.'RC submittal to remove a porti.on of the Ft Calhoun site from the Part 50 license (License No. DPR-40} in accordance with 10 CFR S0.83, "Re]ease of Part of a Power Reactor Facility or S ite for Unrestricted U se" subpart (b ). Summary ofConclusion for the Activity's S0.59 Review: (Provide justification for the conclusion, including sufficient detail to recognize and understand the essential arguments leading to the conclusion. Provide more than a simple statement that a S0.59 Screening, 50.59 Evaluation , or a License Amendment Request, as applicable, is not requited.) To reduce duplication of effort, 10 CFR 50.59(c)(4) speci:fically excludes from the scope of 10 CFR 50.59 changes to the facility ot procedures that are controlled by more specific requirements and criteria that are established by other regulationsCll such as 10 CFR 50.54 and 10 CFR 50.83. EC 69954 performs assessments and review ofpotenti.al impacts to the applicable programs. EC 69954 will document the results ofthe assessment/reviews in support ofthis activity and issue any associated document revisions, as required, per 10 CFR 50.83 and applicable subparts of 10 CFR 50.54. Additionally, Specific Exemptions under 10CFR50.12 are a1so applicable per '!'lR~ 17-011 (MLl 7041A238}. The exemptions granted under ML 17041 A238 were considered in the Station: __ F_.C .... S _______ " _______ _ Aclh'i1y/iDucumen1

'\umhe1*; [:=(_' f-'-'1 9-'()"""~_,_4

_______________ _ Title: PARTIAL SITE RELEASE -PHASE I LS-FC-104-1001 RevisionO Page 2 of2 Revis[on Number: ~O ____ _

evaluated by FCS EP Department in the 50.54q screening as part ofEC 69954. This evaluation included a calcula ti on ofthe PAG value for the new EAB based on the FCS design basis fuel handling accident.

Tbe results of this evaluation dctennined that FCS will stil1 be in compliance with the referenced exemptions when the EAB is reduced. The information documented by EC 69954 will be used to support a NRC submittal to remove a portion of the Ft Calboun site from the Part 50 license (License No. DPR-40) in accordance with 10 CFR 50.83, "Release of Part of a Power Reactor Facility or Site for Unrestricted Use" subpart (b). The associated supporting asscssments documented by the EC are controlled by the applicable regulations and associated regulatory reviews. Once the partial site release is approved by the NRC per 10 CFR 50.83, sta.tion documents such as the DSAR arui other site documeots will be revised to reflect the approved change and new site boundary as Screened by this 50.59 review. Section 4.2.1 ofthe 50.59 Resource manual descnbing changes to other programs describes the 50.59 process is not applicable to changes to the ODCM as changes to the ODCM are covered under more specific requirements described in ODCM section 6.3. Thus the specific changes to the ODCM are not applicab1e to the 50.59 review process. The calculations revised in support of thjs proposed Activity support a physical reduction of the site Exclusion Area Boundary (EAB). The revised applicable station documents will reflect the updated site EAB. These proposed Activities are not specifically controlled by Other Programs. Review ofthese activities under 50.59, concluded that a 50.59 Screening was required using FC-104-1003. The result ofthis 50.59 Screening concluded that a 50.59 Evaluation is not required and priorNRC approval under 10 CFR 50.59 is not required. Refereoce

1) LS-FC-104-1000 , RO, 50.59 Resource. Attachments:

Attach ali 50.59 Review forms completed, as appropriate. Forms Attacbed: (Check ali that apply.) @ A pp J k.ab ilil~* R t-v ie 111 t?i C D ~(1.59 Sr n*c:-ning !'II.S fl F, 11hmtlon E,*aloation 5 0.5" Sl'rl'l'n i.ug N u. r n1luadu11 ~o. 50.~2 " ~o. 18-049 Rev. 0 -------Rev. Rev. See LS-FC-104, Section 5, Documcntation, for record retention requirements for this and ali other 50.59 fonns associated with the Activity. 50.59 APPLICABILITY REVIEW FORM LS-F C-104-100 2 RevisionO Page 1 of2 Activity/Document Number: EC 69954 Revision Number: !!. 1 Title: PARTIAL SITE RELEASE

PHASE I Address the questions below for all aspects of thc Activity.

Ifthc answer is yes for any portion ofthe Activity, apply the identified process(es) to that portion ofthc Activity. Notc that it is not unusual to have more than one process apply to a given Activity. See Scction 4 ofthe Resource Manual (RM) for additional guidance. I. Does the proposed Activity involve a change: l. Technical Specifications or Facility Operating License (lOCFRS0.90)? IZJNO OYES See Section 4.2.1.1 ofthe RM 2. Conditions ofLicense Quality Assurance program (10CFR50.54(a))? !ZiNO 0YES See Section 4.2.1.2 ofthe RM Security Plan (10CFR50.54(p))? ONO !Zi YES i Emergency Plan (10CFR50.54(q))? 0NO YES ! 3. Codes and Standards 1 1ST Program Plan (10CFR50.55a(f))? [gjNO OYES See Section 4.2.1.3 ofthe RM 1 ISI Program Plan (10CFR50.55a(g))? !ZiNO LJYES 1 4. ECCS Acceptance Criteria (lOCFRS0.46)? [giNO 0YES See Section 4.2.1.4 ofthe RM j 5. Specific Exemptions (lOCFRS0.12)? ONO ~YES See Section 4.2.1.5 ofthe RM l 6. Radiation Protection Program (10CFR20)? 0NO i&1 YES See Section 4.2.1.6 ofthe RM 1 7. Fire Protection Program (applicable UFSAR or operating license 0NO 12:J YES See Section 4.2.1.7 ofthe RM condition)?

8. Programs controlled by the Operating License or the Technical 0NO 12:J YES See Section 4.2.1.7 ofthe RM ' Specifications (such as the 0DCM). 9. Environmental Protection Program 0NO 12:J YES See Section 4.2.1.7 ofthe RM . ' ! 10. Other programs controlled by other regulations.

ONO 18) YES See Section 4.2.1 ofthe RM 11. Termination ofLicense: lOCFR 50.82(a)(6} and lOCFR 50.82(a)(7) 0NO 1:8:iYES See LS-FC-120-1001 1 II. Does the proposed Activity involve maintenance which restores SSCs to 1 ' their original condition or involve a temporary alteration supporting IZ]NO OYES See Section 4.2.2 ofthe RM maintenance that will be in effect during at-power operations for 90 days or less? III. Does the proposed Activity involve a change to the: 1. UFSAR (including documents incorporated by reference) that is limited to refonnatting, simplification, removing excessive detail, or minor IZ]NO OYEs See Section 4.2.3 ofthe RM editorial changes as discussed in NEI 96-07 or NEI 98-03? 1 1 2. Managerial or administrative procedures governing the conduct of ~NO OYES See Section 4.2.4 ofthe RM 1 facility operations (subject to the control of 10CFR50, Appendix B) i 3. Procedures for performing maintenance activities (subject to 10CFR50, ! 1 (g!NO OYES See Section 4.2.4 ofthe RM 1 Appendix B)? 4. Regulatory commitment as defined by NEI 99..()4 that is outside the ! scope of 10 CFR 50.59, i.e., the comm.itment does not involve the 1 1. facility or a procedure as described in the UFSAR pursuant to 10 CFR 18!NO 0YES See Section 4.2.3/4.2.4 ofthe RM 1 50.59, the commitment change does not meet the criteria for a change ! pursuant to 10 CFR 50.59, and the commitment is not otherwise 1 mandated by the NRC to require a 50.59 review? 1 N. Does the proposed Activity involve a change to the Independent Spent Fuel OYES See Section 4.2.6 ofthe RM Storage Installation (ISFSI) (subject to control by 10 CFR 72.48) ~~,,,__. ____ -t _, -~-~---~..---~~ 50.59 APPLICABILITY REVIEW FORI\1 Activity/Document Number: EC 69954 Revisioo Number: .!! Title: P ARTIJtL SITE RELEASE -PHASE I Check one of tbe following: LS-FC-104-1002 RevisionO Page 2 of2 D If all as;pects of tbe Activity are controlled by one or more of tbe above processes, theo a 50.59 Screening is not required Bnd the Activity may be implemented in accordance with its goveming procedure. If any portion of the Activity is not controlled by one or more of the above processes, then process a 50.59 Screening for the portion not covered by any of the above processes. The remaining portion of the activity should be implemented in accordance with its goveming procedure. Signoff: S!U9 SereeBeF/ /-J} 50.59 Evaluator: ______ __._R=.L=*-=C=hur=ch'°----- ~f~---~Date: 6 i?~!L_JJ (Circle One) (Print name) (Signature) See LS-FC-104, Section 5, Documentation, for record retention requirements for this and all other 50.59 forms associated with the Activity. 50.59 SCREENING FORM 50.59 Screening No . .=.:18::;...-=04=9'----- Rev. No ..... o __ _ Activity/Document Number: EC 69954 Revision Number: !! Title: P ARTIAI., SITE RELEASE -PHASE I LS-FC-104-1003 RevisionO Page 1 of4 I. 50.59 Screening Questions (Check correct response and provide separate written response providing the basis for the answer to each question)(See Section 5 of the Resource Manual (RM) for additional guidance):

1. Does the proposed Activity involve a change to an SSC that adversely affects an UFSAR descnbed design function? (See Section 5.2.2.1 ofthe R...\1) The proposed Activity (Ref. EC 69954) requests approval from the NRC to remove a portion of the Ft Calhoun site from the Part 50 license and the calculations revised asa result ofthis proposed Activity supporting a physical reduction ofthe site Exclusion Area Boundary (EAB). The revised applicable station documents will reflect the updated site EAB. Key aspects of this proposed Activity include the following:

Revision of calculations/analysis that support that the resultant dose to individual members ofthe public does not exceed the limits and standards ofiO CFR 20, SubpartD.
Documenting that effluent releases remain within license conditions.
Documenting that the early release of the subjoct property does not have any adverse effect on the environmental monitoring program and Offsite Dose Calculation Manual.
Documenting a1l applicable statutory and regulatory requirements continue to be met.
Issuance of the revised applicable station documents.

EC 69954 documents that the proposed release ofthe approximately 120 acres from the Part 50 License will not have any impact on Fort Calhoun Station's continued compliance with applicable NRC standards. The DSAR documents the regulatory requirements that the site complies with and their associated limits. EC 69954 documents that these regulatory requirements are not being cbanged and the results from the revised calculations show that these regulatory requirements continue to be met in ali cases, due to the changes in input parameters of the revised calculations which result in lower doses. These changed input parameter values reflect physical input changes due to the site being permanently defueled and the length of time that has passed since shutdown. As the proposed Activity documents no changes in existing regulatory requirements and that existing requirements continue to be met, the proposed Activity is not adverse. Therefore, the proposed Activity does not involve a change to an SSC that adversely affects an UFSAR described design function.

2. Does the proposed Activity involve a change to a procedure that adversely affects how UFSAR descnbed SSC design functions are performed or controlled?

{See Section 5.2.2.2 ofthe RM) The proposed Activity wil1 update station documents to reflect the revised site boundary and EAB (such as DSAR and procedure figures). These cbanges reflect the new physical boundary locations. The treatment of requirements for these boundaries are not changed by the proposed Activity. This is not an adverse change. Figures in the ODCM depictions of the physical site boundary. These figures will change with the parti.ai site release; however, specific changes to the ODCM are covered in ODCM section 6.3, the ODCM change process and are not applicable under 10 CFR 50.59. There are no changes to the X/Q values in the OCDM due to this proposed Activity. OYES 0YES ~NO 50.59 SCREENING FORM 50.59 Screening No . .:.18.._-.... 04..:..9..__ __ Rev. No. __ o __ Activlty/Document Number: EC 69954 Revision Number: !!. Title: P ARTIAL SITE RELEASE -PHASE I Additionally, the UFSAR described SSC design functions (i.e., the regulations being met) are not being changed. Therefore, there is no change in the performance or control of a design function. Therefore, the proposed Activity does not involve a change to a procedure that adversely affects how UFSAR described SSC design functions are perform.ed or controlled.

3. Does the proposed Activity involve an adverse change to an element of a UFSAR described evaluation methodology, or use of an altemative evaluation methodology, that is used in establishing the design bases or used in the safety analyses? (See Section 5.2.2.3 of the RM) The proposed Activity involves approval from the NRC to remove a portion of the Ft Calhoun site from the Part 50 license and the calculations revised asa result ofthis proposed Activity supporting a physical reduction of the site Exclusion Area Boundary (EAB). The calculations being revised are references in the DSAR. The calculation input parameters have changed, which has resulted in different output values. All the calculation revisions use the existing evaluation methodology from the previous approved revisions ofthese calculations (with the exception ofFC08791 as discussed in the next paragraph).

The fuel gap fractions and decontamination factor used in the Fuel Handling Accident (FHA) EAB dose performed in FC08791 were changed. The methodology used in FC08791 to determine the gap fractions uses NL"'REG/CR-5009 specified methodology vs 2x Reg Guide 1.183 values used in the current AOR (FC06816). This is acceptable because TS amendment 243 (NRC-06-0146) approved the change in methodology for future non-LOCA events. The decontamination factor was changed from 285 to 200, as specified in the TS amendment 201 where FCS made a commitment to the NRC to use an overall decontamination factor of 200 in all future analyses. This was a condition of approval of the alternate source term analyses. Therefore, the change in element of an evaluation methodology has been approved by the NRC for use at FCS and therefore does not involve an adverse change to an element of a UFSAR described evaluation methodology, or use of an altemative evaluation methodology. Ref. EC 69954 and TS amendment 201. The DSAR documents the regulatory requirements that the site complies with and their associated limits. EC 69954 documents that these regulatory requirements are not being changed and the results :from the revised calculations show that these regu]atory requirements continue to be met with additional margin in ali cases. The additional margin is a result ofthe change in input parameters, not as a result of a change to an element of an evaluation. These changed input para.meter values reflect physical input changes due to the site being permanently defueled and the length of time that has passed since shutdown. This type of input parameter change is not adverse and not consider a change to the element of a methodology per the 50.59 RM. Therefore, the proposed Activity does not involve an adverse change to an element of a l,rSAR descnbed evaluation methodology, or use of an alternative evaluation methodology, that is used in establishing the design bases or used in the safety analyses. LS-FC-104-1003 Revision 0 Page2 of4 0 YES 50.59 SCREENING FORM 50.59 Screening No . .;;;;.18.._-..._04..,.9'-- __ Rev. No. -=-0 __ Activity/Document Number: EC 69954 Revision Number: g_ Tltle: P ARTIAL SITE RELEASE -PHASE I 4. Does the proposed Activity involve a test or experiment not described in the UFSAR, where an SSC is utilized ar controlled in a manner that is outside the reference bounds ofthe design for that SSC or is inconsistent with analyses or dcscriptions in the UFSAR? (See Section 5.2.2.4 ofthe RM) The proposed Activity involves approval from the NRC to remove a portion ofthe Ft Calhoun site from the Part 50 license and the calculations revised asa result ofthis proposed Activity supporting a physical reduction of the site Exclusion Area Boundary (EAB). The proposed Activity does not include any test ar experiments. Tests ar Experiments involve utilizing an SSC in a manner previously not considered. Since there are no Tests or Experiments involved with proposed activity, there cannot be an impact on Tests or Experiments not descnbed in the USAR or how SSCs are utilized.

5. Does the proposed Activity require a change to the Technical Specifications or Facility Operating License? (See Section 5.2.2.5 ofthe RM) Technical Specifications refers to the site boundary in general , without specifics regarding the physical layout or dimensions.

This Technical Specification wording does not require any changes due to the proposed Activity. The applicable dose information and applicable regulations regarding the site boundary descnbed in Technical Specifications are not being changed by the proposed Activity. Therefore, Technical Specifications or Facility Operating License do not require any changes due to the proposed Activity. LS-FC-104-1003 RevisionO Page 3 of4 OYES l81NO 0YES ~NO Il. List the documents (e.g., UFSAR, Technical Specifications, other licensing basis, technical, commitments, etc.) reviewed, including sections numbers where relevant information was found (if not identified in the response to each question).

1) EC 69954, PARTIAL SITE RELEASE -PHASE I. 2) LS-FC-104-1000, RO, 50.59 Resource.

3) CH-ODCM-0001, Off-Site Dose Calculation Manual (ODC:M), R28. 4) DSAR-14.18, R2, Fuel Handling Accident in SpentFuel Pool. 5) DSAR-14.20, RO, Waste Liquid lnyident.

50.59 SCREENING FORM 50.59 Screening No * .._18.._-0 __ 4 __ 9 ___ Rev. No. __ o __ Activity/Document Number: EC 69954 Title: P ARTIAL SITE RELEASE -PHASE I m. Select the appropriate conditions: Revision Number: !! 181 If all questions are answered NO, then a 50.59 Evaluation is not required. LS-FC-104-1003 RevisionO Page4 of4 D If question 1, 2, 3, or 4 is answered YES for any portion of an Activity and question 5 is answered NO, then a 50.59 Evaluation shall be performed for the affected portion of the Activity. D If question 5 is answered YES for any portion of an Activity and questions 1 through 4 are answered NO for the remaining portions ofthe Activity, then a License Amendment is required prior to implementation of the portion ofthe Activity that requires the amendment; bowever, a 50.59 Evaluation is not required for the remaining portions of the Activity. D If question 5 is answered YES for any portion of an Activity and question 1, 2, 3, or 4 is answered YES for any of the

remainfog portions of the Activity, then a License Amendment is required prior to implementation of the portion of the Activity that requires the amendment and a 50.59 Evaluation is required for the remaining affected portions of the Activity.

IV. Screening Signoffs: 50.59 Screener: (Print name) 50.59 Reviewer: =E=.M=.(Print name) Date: G._/ !!.; 18 Date: ~/ 'Zf I IY See LS-FC-104, Section 5, Documentation, for record retention requirements for this and all other 50.59 forms associated with the Activity. Attachment 1 Fire Protection Change Regulatory Revlew (FPCRR) Page 1 of 2 1 Station / Unit: Fort Calhoun Station / Unit 1 Activity Document No: EC 69954 Rev. O 2. Descrlptlon: LS-FC-128 Revision 1 Page 10 of 15 Provide a brief description, including the reason, of the proposed change (or refer to change package that provides description ): Engineering Change EC 69954 addresses release of part of the Fort Calhoun Station <FCS) site for unrestricted use. Prior Nuclear Regulatory Commisslon (NRC) approval of the proposed partial site release will be reguested in accordance with 1 O CFR 50.83. The purpose of the change is to allow unrestricted use of a specific portion of the FCS site. 3. Screenlng: Considering the proposed change, answer the following questlons, including a reference to the applicable regulatory, licensing basis, or NFPA document(s), and a brief description of why the proposed change does or does not satisfy the referenced document(s). A. Does the proposed change satlsfy applicable fire protection regulatory requirements and/or guidance documents (e.g., 1 O CFR 50.48(f), Regulatory Guide 1.191, NFPA Codes, etc.)? IZ! Yes D No D N/A The proposed change would alter the site It would have no impact on fire protection eguipment. or on the effectiveness of fire protection. The only aspect of the fire protection program that is related to this change is the quantification of offsite radiological consequences of postulated fires. Analysis EA 17-002, Revision 1, "Fire Protection Radiological Consequences Analysis" guantifies offslte dose conseguences of postulated fires using a X/Q value documented in Table 4 of the Off-Site Dose Calculatlon Manual (ODCM) Revision 28. The proposed partial site release does not impact the applicable ODCM X/Q value. Therefore the guantified radiological conseguences of postulated fires Ci.e., EA17-002) is not impacted bythe proposed partial site release. Overall, the proposed partial slte release satisfies applicable fire protection regulatory requirements and guidance documents. B. Does the proposed change satisfy the fire protectlon licensing basis (e.g., alternate compliance, exemption, deviation, SER, docketed correspondence, NFPA Codes of Record, etc.)? (N/A if 3.A. is Yes) D Yes D No 181 N/A Not Applicable based on "Yes" response to Question 3.A above. Attachment 1 Flre Protection Change Regulatory Review (FPCRR) Page 2 of 2 C. ls either question above answered *ves*? 181 Yes D No LS-FC-128 Revision 1 Page 11 of 15 lf yes, then the proposed change does not reduce the effectiveness of fire protectlon for facilities, systems, and equipment that could result in a radiological hazard, and NRC approval is not required. Check N/A on Step 4 and proceed to Step 5. ff no, then complete Step 4 (See Enclosure 1 for additional guidance).

4. Evaluatlon:

Does the proposed change reduce the effectiveness of fire protection for facilities, systems, and equipment that could result in a radiological hazard, taking into account the decommissioning plant conditions and activities (attach evaluation, if necessary)? D Yes D No 181 N/A Not Applicable based on "Yes" response to Question 3.C above. lf yes, then the proposed change may not be implemented without prior NRC approval. lf no, then the proposed change does not reduce the effectiveness of fire protection for facilities, systems, and equipment that could result in a radiological hazard, taking into account the decommissioning plant conditions and activities, and NRC approval is not required. 5.

Conclusion:

[8)

Proposed change may be implemented without prior NRC approval.

D NRC approval is required prior to implementing the proposed change. 6. 1 have determined that the documentation is adequate Preparer: J;..,,.e,s GeJ!J.,w..J.1..,..,,.~~,=.~~~=-- Print Signat e Prmt Date: 6/t'fl/8

The conclusion above only indicates that there is no fire protection program change that would require prior NRC approval per 10 CFR 50.48(f).

EC 69954 DOES require NRC pre-approval per 10 CFR 50.83. FORT CALHOUN STATION (FCS) 72.48 REVIEW COVERSHEET FORM Station/Unit(s): Fort Calhoun Station Activity/Document No.: EC 69954 Partial Site Release Title: LS-FC-114-1001 Revision 1 Page 1 of2 Revision No.: _o"------NOTE: For 72.48 Evaluations prepared by FCS, information on this form will provide the basis for preparing the biennial summary report submitted to the NRC in accordance with the requirements of 10 CFR 72.48(d)(2). NOTE: For a 72.48 Review prepared by a CoC Holder, tbis form will document the FCS review concluding that the site's 72.212 Evaluation Report is not impacted by the CoC Holder-prepared 72.48 Review (i.e., by checking the box below titled "CoC-Holder 72.48 Impact Review) and documenting the basis for this conclusion in the "Effect of Activity/72.212 Non-Impact Basis" section ofthis specific 72.48 Review Coversheet Form. D CoC-Holder 72.48 lmpact Review (lf checked, only the "Impa.ct Reviewer Name/Date" and "Effect of Activity/72.212 Non-Impact Basis" sections need to be completed); lmpact ReviewerName/Date:

'/

______ _ De1cription of Actlvity: (Provide a brief, concise description ofwhat the proposed activity involves.) The activity requests approval from the NRC to remove a portion of the Ft Calhoun site from the Part 50 license (Liccnse No. DPR-40). Specifically, the activity wil1 rem.ove/release the non-impacted survey units from the Part 50 license in accordance with 10 CFR 50.83, "Release of Part ofa Power Reactor Facility or Site for Unrestricted Use" subpart (b). EC 699 54 wil1 document the results of the assessment/reviews in support of this activity and ismle any associated document revisions per 10 CFR 50.83 and applicable subparts of 10 CFR 50.54. This 72.48 Screening was performed to verify and document applicable calculations incorporated by reference by the 72.212 report are verified to be non-impacted by partial site release and to address specific ISFSI related 10 CFR 72 regulations regarding dose aru! controlled areas around the ISFSI. Reason for Activity: (Discuss why the proposed activity is being performed.) The change is part of thc overall strategy to eventually release the site for umestricted use. This activity is in support of Phase I ofFCS Project 2444. The activity of the early release ofthe subject 1and supports the eventual overall license termination process on accordance with NRC regulations. Effect of Activitynl.212 Non-lmpact Balis: (Discuss how the activity impacts ISFSI operations, design bases, or safety analyses described in the cask UFSAR [IFSSAR]. With respoct to a 72.48 Review prepared and provided by the CoC Holder, provide sufficient detail to conclude that the CoC Holder's 72.48 Review does not impact the site's 72.212 Evaluation Report.) This 72.48 review concludes that changes to the distance from the unrestricted area to the ISFSI in pe.rtial site release described in EC 69954 does not impact the parameters used in dose calculation FC07140 that is referenced by the 72.212 Report. The controlled area around the ISFSI continues to be in compliance with 10 CFR 72.106. Summary of Conclusion for tbe Activity's 72.48 Review: . (Provide justification for the conclusion, including sufficient detail to recognize and understand th.e essential arguments leading to the conclusion. Provide more than a simple statement that a 72.48 Screening, 72.48 Evaluation, or a Certificate of Compliance Amendment, as applicable, is not required.) To reduce duplication of effort, 10 CFR 72.48(c)(4) specifi.cally excludes from the scope of 10 CFR 72.48 activities that are controlled by more specific requirements and criteria established by other regulations. Activities that are controlled by more specific regulations may result in changes to the facility or procedures. These changes must also be reviewed to determine if 10 CFR 72.48 applies to those parts ofthe activity.1 1) LS-FC-114-1000 Fort Calhoun Station 72.48 Resource Manual 1 FORT CALHOUN STATION (FCS) 72.48 REVIEW COVERSHEET FOR.i""v.l LS-FC-114-1001 Revision 1 Page2 of2 The associated supporting assessments documented by the EC are controlled by applicable regulations and associated regulatory reviews. The portions ofthe 10 CFR 50.83 evaluations for partial site release from thc 10 CFR 50 license (Llcense No. DPR-40) coupled with this 10 CFR. 72.48 screening support permitting this activity. Attachments: Attach all 72.48 Review forms completed, as appropriate. Forms Attached: (Check all that apply.) Applicability Review 72.48 Screening 72.48 Evaluation 72.48 Screening No.:_~1=8~-0=0~8 _______ ....,Rev. 0 72.48 Evaluation No.: Rev. FORT CALHOU STATION 72.48 APPLICABILITY REVIEW FORM LS.Fe-114-1002 RevisionO Page 1 ofl Activity/Document No.: EC 69954 Parti.ai Site Release Revision No.:_o _____ _ L Address the questions below for ali aspects of the Activity. If the answer is yes for any portion of the Activity, apply the identified process(es) to that portion ofthe Activity. Note, more than one process may apply to a given Activity. (See Section 4 of the 72.48 Resource Manual for additional guidance.)

1. Does the proposed Activity involve a change to the: a) Certificate ofCompliance, including CoC Technical Specifications (10CFR72.244)?........

NO 181 YES D b) Does the Activity require a change to the 10CFR71 Transport CoC/SAR (10CFR71.3I)?. NO 181 YES 0 c) Conditions of License Quality Assurance program (10CFR.50.54(a)) / 10 CFR 72, Subpart G? ............*................ NO 181 YES 0 SecurityPlan (10CFR.50.54(p))? .......................................................................................... NO 181 YES D EmergencyPlan(IOCFR50.54(q))? ..................................................................................... NO 181 YES 0 d) Radiation Protection Program (10CFR20)? .......................................................................... NO 181 YES D e) Environmental Protection Program? ..................................................................................... NO 181 YES D f) Specific Exemptions (IOCFR72.7)? ..................................................................................... NO 181 YES D g) Other programs controlled by other regulations? ................................................................. NO D YES 181 2. Does the proposed Activity involve a change to the: a) Cask UFSAR [IFSSAR] (including documents incorporated by reference) that is excluded from the requirement to perform a 72.48 Review by NEI 96-07, Appendix B, and NEI 98-03? NO 181 YES D b) Managerial or administrative procedures governing the conduct of filcility operations (subject to the control of 10 CFR 72, Subpart G (quality assurance))? ................................ NO 181 YES D c) Regulatory commitment covered by another regulation based change process (see NEI 99-04)? ................................................................................................................... NO 181 YES D 3. Does the proposed Activity involve a cha.nge to SSCs or procedures subject to control by 10 CFR 50.59?...................................................................................................................... NO YES 0 II. Select the approprlate conditions: 0 H all aspects of the Activity are controlled by one or more of the above processes, then a 72.48 Screening is not required and the Activity may be implemented in accordance with its goveming procedure. 181 If any portion of the Activity is not controlled by one or more of the above processes, then process a 72.48 Screening or Evaluation for the portion not covered by any of the above processes. The remaining portion of the activity should be implemented in accordance with its governing procedure. D If any portion ofthe proposed Activity involves a change to the 10CFR71 Transport CoC/SAR, then the CoC holder shall be notified ofthe need to obtain an amendment ofthe 10CFR71 Transport CoC/SAR.. m Applicability Review Signoffs: 72.48 SeFeeBern2.48 Evaluator: R=.L"'". C=h=ur=c=h'------ 5'@~ (Circle One} (Printed name) (Signaturc) Date: C__;l'/it.!) FORT CALHOUN STATION 72.48 SCREENING FOIL'1 LS-FC-114-1003 RevisionO Page 1 of3 72.48 Screening No.: __ l,...8-0 ........ 0..,_8 __________ Revfslon No.: __ o __ _ Activity/Document No.: EC 69954 Partial Slte Release Revision No.: _ ___.o __ I. 72.48 Screening Questions (Check correct response and provide separate written response giving the basis for the answer to each question)(See Section 5 of the 72.48 Resource Manual [RM] for additional guidance.)

1. Does the proposed Activity involve a change to the ISFSI facility, an SSC or cask that adversely affects a UFSAR [IFSSAR] described SSC or cask design function? (See Section 5.1.1 ofthe RM.) 0 YES NO This activity involves a partial site release to the owner-controlled area in the furthest northwest section ofthe site. This will change the distance from the ISFSI to the nearest site boundary in the affected sectors. Dose calculation number FC07140 was reviewed and evaluated and was shown that there is no dose impact to a member of the public by change ofthis site boundary.

FC07140 uses a much more conservative distance of 137.2 meters as the distance to the nearest unrestricted area boundary. This distance is the distance from the ISFSI to the west bank of Missouri River to the East side of the ISFSI. Changing the site boundary to the north has no impact on this dose calculation. Therefore the proposed activity does not involve a a change to the ISFSI facility, an SSC or cask that adversely affects a UFSAR [IFSSAR] described SSC or cask design function.

2. Does the proposed Activity involve a change to a procedure that adversely affects how UFSAR [IFSSAR] described SSC or cask design functions are performed or controlled?

{See Section 5.1.2 ofthe RM.) This is a change to the physical description to the site boundary. The area around the ISFSI that is required to be controlled. According to lOCFR 72.106(b), "The minimum distance from the spent fuel, high-level radioactive waste, or reactor-related GTCC waste handling and storage facilities to the nearest boundary of the controlled area must be at least 100 meters." The area ofthe partial site release will not impact the requirement to maintain a controlled area of 100 m surrounding the ISFSI and this will not impact cask design functions and controls. Therefore tb.e proposed Activity does not involve a change to a procedure that adversely affects how UFSAR [IFSSAR] described SSC or cask design functions are performed or controlled.

3. Does the proposed Activity involve an adverse change to an element of a UFSAR [IFSSAR] described evaluation methodology, or use of an alternative evaluation methodology, that is used in establishing the design bases orused in the safety analyses?

{See Section 5.1.3 ofthe RM.) D YES l8I NO The proposed Activity does not involve a change in evaluation methodology. The evaluation methodology for ensuring tb.at the dose from the ISFSI complies with 1 OCFR 72.104 and 40CFR 190 limit of 25 mrem TEDE is not impacted by cbanging the site boundary. FC07140 uses tb.e distance of 137.2 meters (the distance from the ISFSI to the Missouri River) at an occupancy of 8760 hours per year as the parameters used to evaluate dose impact to a member oftb.e public. A partial site-release to the north section ofthe site does not impact tb.e distance from the ISFSI to the point at which the dose was calculated, tb.us this change dose not impact the method of compliance evaluation with lOCFR 72.104 nor40 CFR 190. Therefore, the proposed Activity does not involve an adverse change to an element of a UFSAR [IFSSAR] descnoed evaluation methodology, or use of an alternative evaluation methodology, that is used in establishing tb.e design bases or used in the safety analyses. FORT CALHOUN STAT!O!\ 72.48 SCREENI~G FORivl LS-FC-114-1003 RevisionO Page2 of3 1 7lAM St'Ttl.:Hing No.; _ _.1..,..8-'"""0...;,0 .... 8 ____ _ ---Rt',*hion :\o.: _o ___ _ At'.li,it~'/.l)ornmt'f11 No.: EC "94'54 Site Rt'leai.t' R('\*ision ~o.: --~"'-1 __ 4. **-------~-------Does the proposed Activity involve a test or e xperiment not descnbed in the UFSAR [I F SSAR], where an SSC or cask is used or controlled in a manner that is outside the reference bounds of tbe design for that SSC or cask, or is inconsistent with analyses or descriptions in the UFSAR [IFSSAR]? (See Section 5.1.4 oftheRM.) l:J Yf:S 181 NO This activity is nota test nor an cxperimenl Therefore there can be no adverse impacl Therefore, the proposed Activity does not involve a test or experiment not described in the UFSAR [IFSSAR], where an SSC or cask is used or controlled in a manner that is outside the reference bounds of the design for that SSC or cask, or is inconsistent with analyses or descriptions in the UFSAR [IFSSAR]. s. Does the proposed Activity involve a change to the Certificate of Compliance (including a change in the terms, conditions, or specifications incorporatecl. t.hereiD)? (See Section 5.1.5 ofthe RM.) D Y F S 181 NO This activity does not involve a change to the CoC. List doeuments reviewed (e.g., Certificate of Compliance/Technical Specifications sections reviewed, 1 OCFR7 l Transport SAR items/sections, UFSAR [IFSSAR] items/sections, 72.212 Report), including section numbers where relevant information was found (if not identified in the response to each question). Docket Number 72-054 Fort Calhoun Station ISFSI 10 CFR 72.212 Evaluation Report RP-1000 rev 1 -Radiation Protection Program EP-FC-1001 rev 4-OPPD Nuclear Pennanently Defueled EP 10 CFR 72.104 10 CFR 72.106 FC07140 rev 3-OPPD ISFSI Phase I Site Dose and Occupational Dose Summary Calculation. LS-FC-114-1000 rev 0-Fort Calhoun Station 72.48 Resomce Manual CoC No. 1004 Amend 9, Att. A Tech Specs TN NUHOMS Docket 72-1004 III. Select the appropriate conditlons: ' 181 If all questions are answered NO, then a 72.48 Evaluation is not required. D If qucstion 1, 2, 3, or 4 is answered YES for any portion of an Activity and question 5 is answered NO, tben a 72.48 Evaluation shall be performed for the affected portion of the Activity. D If question 5 is answered YES for any portion of an Activity and questions 1 through 4 are answ ere d NO for the remaining portions of the Activity, then a CoC amendment is required prior to implementation of the portion of the Activity that requires the amendment; however, a 72.48 Evaluation is not required for the remaining portions ofthe Activity.

---*---*-*-* ----~--J FORT CALHOlJ"N STATION 72.48 SCREENING FORM LS-Fc-114.1003 RevisionO Page3 of3 72.48 Screening No.: _ .... 1s;..-"""'oo

__ s"--_________ Reviston No.: --' ....... o __ Activity/Document No.: EC 69954 Partial Site Release Revision No.: ____ o __ D If question 5 is answered YES for any portion of an Activity and question 1, 2, 3, or 4 is answered YES for any of the remaining portions of tbe Activity, then a CoC amendment is required prior to implementation of the portion ofthe Activity that requires the amendment and a 72.48 Evaluation is required for the remaining affected portions of the Activity. IV. Screening Signoffs: 72.48 Screener: =R=.L~. (Printed Name) 72.48 Reviewer: Wc. /111. D (Printed Name) 1 ture DATE: r; ____.~!' # Sign: (Signature) DATE: Note: If this review is associated with a vendor approved 72.48 review, then. the signatures on tbis form signify review of and concurrence with the vendor 72.48 review. The vendor 72.48 review must be provided as an attachment to this document. LS-FC-120-1001-F-01 Revision 0 Page 1 of2 J. 50.82 Screening Questions (Check correct response and provide written response providing the basis for the answer to each question)

1. Does the proposed Activity result in foreclose the release of the site for possibJe unrestricted use? Provide Justi:fication:

1) Is it an activity that could preclude access to structures, systems or components for dismantlement?

No. There are no SSCs on or near the area to be released.

2) Is it an activity that could spread a significant amount of radioactive contamination preventing site remediation?

No. Calculations and analysis documented by EC 69954 confirm compliance with existing Radiation Protection requirements applicable for the site and the public. 3) Is it an activity that could result in preventing completion ofthe fina1 radiation survey? No. This activity encompasses the finaJ radiation survey for the portion of the site being released.

2. Does the proposed Activity result in significant environmental impacts not previously reviewed?

Provide Justification: Assessments required by 10 CFR 50.83, "Release Of Part Of A Power Reactor Facility Or Site For Unrestricted Use," documented by EC 69954 confirm there is no environmental impact for this activity.

3. Does the proposed Activity result in there no longer being reasonable assurance that adequate funds wil1 be available for decommissioning?

Providc Justi.fication: The activity is a budgeted project Project 2444, Partial Site Release. Release of site area for unrestricted use is within the scope of decommissioning activities. ~YES ONO 0YES DYES II. Review the answers to step I.1-3. Ifthe answer to any question is YES, then the activity CA.~OT be completed, without notification to the NRC. The EC 66954 activity is in support a submittal which requests approval from the NRC to remove a portion of the Ft Calhoun site from the Part 50 license (License No. DPR-40). Specifically, the activity will remove/release the non-impacted survey units from the Part 50 license in accordance with 10 CFR 50.83, "Release Of Part Of A Power Reactor Facility Or Site For Unrestricted Use" subpart (b). NOTE LS-FC-120-1001-F-01 RevisionO Page2 of2 In taking actions permitted under lO CFR 50.59 following submittal ofthe PSDAR, the licensee may perform activities inconsistent with the PSDAR. including signi:ficant schedule changes or significant cost increases, provided PRIOR written notification is made to the NRC, as well asa copy of the notification to the State ofNebraska. Ill Select the appropriate conditions:

1. 1s this activity inconsistent with those actions descn"bed in the Post-Shutdown Decommissioning Activities Report or cause a significant schedule change or cost increase?

IF the answer is YES, then notify the NRC and the State ofNebraska prior to perfonning the activity. IF the answer is NO, then proceed without notifications. Provide Justification The activity is a budgeted project. Project 2444, Partial Site Release. Release of site area for unrestricted use is within the scope of decommissioning activities. IV. Screenfng Signoffs: Based on this evaluation, I have determined that the proposed activity is not restricted by 10 CFR 50.82: ~:tf!-50.82 Screener: =R=L=*....:C=h=ur=c=h ________ _ (Print uame) The reviewer agrees that the proposed activity is not restricted by 10 CFR 50.82: 50.82-: IA/ j J I[,,.., f' Ml l 1.4S Sign: (Print name) ' (Signature

SQR qualification required.

OYES Date: / Document Revision Screening Evaluation SY-FC-101-104-F-01 Revision 2 Page 1 of 8 SCREENING EVALUATION FOR REVISIONS TO THE PHYSICAL SECURITY PLAN NEI 11-08, Guidance cn Submitting Security Plan Changes was utilized for applicability of to the Physical Security Plan (PSP). The review was used to analyze the effects of the changes in applicable sections of the Security Plan to ensure the Ievel of detail in the analysis is sufficient to allow submittal under the provisions of 10 CFR 50.54(p). Detailed below are the conclusions regarding how the change affects the safeguards effectiveness of the Plan, and how security measures continue to meet the requirements of 10 CFR 73.55. Physlcal Security Plan Revlslon #: N/A PSP Sectlon Affected PSP kctlcm Tltle Title Page Title Page 1.1 Page 6 Facility Physical Layout Purpose of the PSP chang&: To align the Security Plan with the partial release of land from Fort Calhoun Stations Owner Controlled Area license. NOTE: The revision # will be filled in upon NRC approval for the partial site release and prior to implementation of the Site Securlty Plan. This is a screening to support the submittal process for partial release of land from the Owner Controlled Area. Detaiiad descriptlon of document changes: See change summary SY-FC-101-104-F-03 10 CFR 50.54(p)(2) Screening Evaluation

Provide detailed description of how the Security Plan changes do not delete, contradict, or decrease the overall Ievel of security program perfonnance or effectiveness, to protect with reasonable assurance of success against the design basis threat of radiological sabotage as stated in § 73.1 (a).
Provide detailed descrlption of how the Security Plan changes continue to provide reasonable assurance through the effective lmplementation of the security plans to meet the requirements of § 73.55. f! Review the requirements in § 73.55 for each section being addressed below as the conclusion rationale is developed and provided.

10 CFR 73.55(b) General Performance Objectlves and Requlrements Does the rev1sion change/activity negatrvely 1mpact the capabilities to detect, assess, interdict, or neutralize threats up to and mcludlng the des1gn basis threat of radiological sabotage, or prov1de defense 1n depth through the rntegration of systems, technologies, programs, equ1pment, supportlng processes, and 1mplementing procedures needed to ensure the effectiveness of the phys1cal protectlon program? 12:1 Change does not decrease the safeguards effectiveness of any activity, system or component perfonnance meeting the requirements of 10 CFR 73.55. D Change decreasea the safeguards effectiveness of an obligation meeting the requirements of 10 CFR 73.55. D Not Applicable Conclusion Rationale: This change simply updates the Site description in the Physical Security Plan to align wlth the changes assoclated wlth partial site release. The area being released has no impact on the Protective Strategy or the ablllty of the Security organization to monitor the owner controlled area. Therefore it is determined that the revision does not negatlvety tmpact the capabllltles to detect, assess, interdict, or neutralize threats up to and including the design basis threat of radlotoglcal sabotage, or provide defense in depth through the integration of systems, technologies, programs, equtpment, supportlng processes, and implementing procedures needed to ensure the effectiveness of the physlcal protection program. Fort Calhoun Station stili maintains ali requirements per 10 CFR 73.55(b). 10 CFR 73.55(c) Securlty Plans and Procedures Does the revis1on change/actlvrty confllct, contrad1ct, or decrease an obllgatlon or text content meeting a § 73-55 requirement as stated within the Security Plan or a Security Plan lmplementing Procedure? Change does not decrease the safeguards effectiveness of any activity , system or oomponent performance meeting the requlrements of 10 CFR 73.55. D Change decreases the safeguards effectiveness of an obligation meetlng the requirements of 1 O CFR 73.55. D Not Applicable Conctuslon Rationale: Thls change simpty updates the Site description in the Physical Security Plan to align with the changes associated with partlal slte release. The area belng released has no impact on the Protective Strategy or the ability of the Securlty organlzation to monitor the owner controllecl area. Therefore it is determlned that the revision does not oonflict, contradlct, or decrease an obllgatlon or text content meeting a § 73.55 requirement as stated within the Securlty Plan or a Securtty Plan lmplementing Proceclure. There are no changes to any implementing procedures. 10 CFR 73.55(d) Securlty Organization Does the revrslon change/actiVity negatively 1mpact the organizat1onal respons1bihties, staffing, equ1pping, tra1ning or quallfication of Security personnel to 1mplement the phys1cal protecbon program as described m 10 CFR Part 73? 12:1 Change does not decrease the safeguards effectiveness of any activity, system or component performance meeting the requlrements of 1 o CFR 73.55. D Change decreases the safeguards effectiveness of an obligation meeting the requlrements of 10 CFR 73.55. D Not Applicable Conclusion Rationale: The revlslon does not negatively impact the organizational responsibilities, staffing, equipping, training or qualiflcatlon of Securlty personnel to implement the physical protection program as described in 10 CFR Part 73. This revision will onty contain a small reductlon to the OCA total acreage, therefore there is no impact to 10 CFR 73.55(d). 1 O CFR 73.56(e) Physlcal Barriers Does the revis1on change/actiVlty negatively impact the speatic use, type, function or placement of physlcal bamers needed to sattsfy the physlcal protection program design requirements of § 73.55(b)? 181 Change doaa not decrease the safeguards effectiveness of any activity, system or component performance meeting the requirements of 1 O CFR 73.55. D Change decreases the safeguards effectiveness of an obllgation meeting the requirements of 10 CFR 73.55. 0 Not Applicable Conclusion Rationale: The revision does not negatively impact ihe specific use, type, function or placement of physical barriers needed to satisfy the physical protection program design requirements of § 73.55(b). The reduction of land will not affect the existing physical barriers that are in place at Fort Calhoun Station. AII current baniers will remain in the current layout. 10 CFR 73.65(f) Target Sets Does the rev1sion change/act1vity negatively impact the site specific target sets, or the analysis and methodologies used to deterrmne the target set equ1pment or elements?

181 Change do88 not decrease the safeguards effectiveness of any activity, system or component performance i meeting the requirements of 1 O CFR 73.55. 1 D Change decreases the safeguards effectiveness of an obligation meeting the requirements of 10 CFR 73.55. D Not Applicable Conclusion Rationate:

The revision does not negatively impact the site specific target sets, or the analysis and methodologies used to determine the target set equipment or elements. Fort Calhoun Station maintains a Target Set Experi Panei. The panei still meets annually to review and update target sets as applicable. The release of the land from the license witl have no impact on Target Sets. 1 O CFR 73.SS(g) Access Controls Does the revis1on change/activrty negatively impact the control of personnel, veh1cles, or mater,al at access control points m accordance wrth the physical protect1on program des1gn requ1rements of § 73.55(b)? Change does not decrease the safeguards effectiveness of any activity, system or component performance meeting the requirements of 1 O CFR 73.55. 0 Change decreases the safeguards effectiveness of an obligation meeting the requirements of 10 CFR 73.55. D Not Applicable Conclusion Rationale: The revision does not negatively impact the control of personnel, vehicles, or materiat at access control points in accordance with the physical protection program design requirements of § 73.55(b). AII access control points at Fort Calhoun Station will remain the same as will the requirements to gain entry through the access points. The release of the land will have no impact to the control or personnel, vehicles, or material at access points. 10 CFR 73.55(h) Search Programs Does the rev1sion change/activity negatively impact any aspect of the search prograrn to detect, deter, and prevent the introduction of contraband or items to Security Controlled Areas could be used to commrt sabotage, cons,stent with the physical protection program design requirements of § 73.55(b)? Change does not decrease the safeguards effectiveness of any activity, system or component performance meeting the requirements of 1 O CFR 73.55. D Change decreases the safeguards effectiveness of an obligation meeting the requirements of 10 CFR 73.55. D Not Applicable Conclusion Rationale: The revision does not negatively impact any aspect of the search program to detect, deter, and prevent the introduction of contraband or prohibited items to Security Controlled Areas that could be used to commit radiological sabotage, consistent with the physical protectlon program design requirements of § 73.55(b). Ati search programs at Fort Calhoun Station will remain the same. The release of the land will have no impact on the ability to detect. deter, and prevent the introduction of contraband or prohibited items to Security Controlled Areas. This change simply updates the Site description in the Physical Security Plan to align with the changes associated with partial site release. 1 O CFR 73.55(1) Detectlon and Assessment Systems Ooes the revision change/actrvrty negatively 1mpact the abtlity to establish and malntaln intrusion detection and assessment systems that satisfy the des1gn requirements of § 73.55(b), and provlde at ali t1mes, the capability to detect and assess unauthorized persons and the effectlve rmplementation of the llcensee's protective strategy? l8I Change does not decrease the safeguards effectiveness of any activity, system or component performance meeting the requirements of 10 CFR 73.55. ! D Change decreases the safeguards effectiveness of an obligation meeting the requirements of 10 CFR 73.55. D Not Applicable Concluslon Rationale* The revision does not negatively impact the ability to establish and maintain intrusion detection and assessment systems that satisfy the design requirements of § 73.SS(b), and provide at all times, the , capability to detect and assess unauthorized persons and facilitate the effective implementation of the licensee's j protective strategy. The release of the land will shrink the Owner Controlled Area footprint and will assist with the assessment of these areas. Ali assessment systems and intrusion detection systems will remain the same at Fort Calhoun Station. The release of the land will have no impact to these systems. 10 CFR 73.550) Communication Requirements Does the revision change/actlvlty negatlvely impact the ablllty to establlsh and mamtaln contlnuous communlcatlon capabllity with onsite and offslte resouroes to ensure effective command and control dunng both normai and emergency situatlons? 181 Change does not decrease the safeguards effectiveness of any activity, system or component performance meeting the requirements of 1 O CFR 73.55. D Change decreases the safeguards effectiveness of an obiigaiion meeting the requirements of 1 O CFR 73.55. D Not Applicable Conclusion Rationale: The revision does not negatively impact the ability to establish and maintain continuous communication capability with onsite and offsite resources to ensure effective command and control during both normai and emergency situations. Fort Calhoun Station's communications requirements will not be affected with the release of the land from the Owner Controlled Area. Ali communications systems will remain the same as result of this revlslon. 10 CFR 73.55(k} Response Requirements Ooes the rev1s1on change/actlVity negatively lmpact the abtlity to establish and marntain, at all tlmes, proper1y trained, and equipped personnel requlred to 1nterd1ct and neutralize threats up to and 1nclud1ng the des1gn basrs threat of radrological sabotage as deflned 1n § 73.1, to prevent spent fuel sabotage? 181 Change does not decrease the safeguards effectiveness of any activity, system or component performance meeting the requirements of 10 CFR 73.55. D Change decreases the safeguards effectiveness of an obligation meeting the requirements of 1 o CFR 73.55. D Not Applicable Conclusion Rationale: The revision does not negatively impact the abillty to establish and maintaln, at all times, properly trained, qualified and equlpped personnel requlred to interdict and neutralize threats up to and including the deslgn basis threat of radiological sabotage as defined in § 73.1, to prevent spent fuel sabotage. The response requirements for Fort Calhoun Station will remain the same. The release of land will have no impact to the protective strategy. 10 CFR 73.55(m) Security Program Reviews Does the revision change/actlvlty negatively rmpact the abllity to rev1ew of each element of the phys1cal protectton program at least every 24 months or reviews conducted wrthm 12 months following initial 1mplementatlon of the phys1cal protection program or a change to personnel, procedures, equipmenl or facillties that potentially could adversely affect security? 12:1 Change does not decrease the safeguards effectiveness of any activity, system or component performance meeting the requirements of 10 CFR 73.55. D Change decreases the safeguards effectiveness of an obligation meeting the requirements of 1 O CFR 73.55. D Not Applicable Conclusion Rationale: The revision to the Physical Security Plan at Fort Calhoun Station does not change the reviewfrequency or inspections conducted in accordance with 10 CFR 73.55(m). 10 CFR 73.55(n) Malntenance, Testlng and C&llbratlon Does the revlslon change/acbvrty negatively 1mpact the to establish , maintain, and implement a ma1ntenance, and testing and callbratlon program to ensure that systems and equipment secondary and power supplies) are tested for operabilrty and performance at intervals predetermlned, matntained tn operable condillon, and are capable of performmg their mtended funct1ons? 1 181 Change does not decrease the safeguards effectiveness of any activity, system or component perfonnance meeting the requirements of 10 CFR 73.55. D Change decreases the safeguards effectiveness of an obligation meeting the requirements of 10 CFR 73.55. D Not Applicable i Conclusion Rationale: The revision does not negatively impact the ability to establish, maintain, and implement a 1 malntenance, and testing and calibration program to ensure that security systems and equipment (including secondary and uninterruptible power supplies) are tested for operability and performance at intervals predetermlned, malntainecl in operable condition, and are capable of perfonning their intended functions. The testing and calibration program at Fort Calhoun Statlon wlll remain the sama and will not be impacted by the release of land from the Owner Controlled Area. 10 CFR 73.55(0) Compensatory Measures Does the rev1s1on change/acbvlty negatively 1mpact the ablllty to provlde compensatory measures that are a Ievel of protecbon that is equivalent to the protectlon provlded by the degraded or moperable equipment, system, or component meeting the phys1Cal protectlon program des1gn requ1rements of § 73.55(b)? 1 Change does not decrease the safeguards effectiveness of any activity, system or component performance

rneeting the requirements of 1 O CFR 73.55. 1 D Change decreasas the safeguards effectiveness of an obligation meeting the requlrements of 1 O CFR 73.55. D Not Applicable Concluslon Ratlonale:

The revision does not negatively impact the ability to provide compensatory measures that are a Ievel of protection that is equlvalent to the protectlon provlded by the degraded or inoperable equipment, l system, or component meeting the physical protectlon program deslgn requlrements of § 73.55(b). Compensatory 1 measures at Fort Calhoun Station wlll remaln the sama and will not be lmpacted by the release of land from the Owner Controlled Area. 10 CFR 73.55(p) Suapension of Security Measures Does the revisron change/aclivrty negattvely lmpact the ablltty to suspend any securrty measures under this seclion in an emergency when this actlon 1s 1mmedlately needed to protect the publlc health or safety or the personai health and safety of securtty force personnel, and no action wlth Hcense condltions and technical specif1cabons that can prov1de adequate or equtvalent protecbon ls lmmed1ately apparent? 181 Change doas not decrease the safeguards effectiveness of any activity, system or component performance ' meeting the requirements of 10 CFR 73.55. D Change decreases the safeguards effectiveness of an obligation meeting the requlrements of 1 O CFR 73.55. D Not Applicable Conclusion Rationale: The revision does not negatively impact the ability to suspend any security measures under

this section in an emergency when this action is immediately needed to protect the public health or safety or the personai health and safety of security force personnel, and no action conslstent with license conditions and technlcal specifications that can provide adequate or equivalent protection is immediately apparent.

The suspension of Security Measures at Fort Calhoun Station will not be affected by the release of land from the Owner Controlled Area. 10 CFR 73.SS(q) Records Does the revis1on change/act1v1ty negatively 1mpact the abllity to mamtaln all records requlred to be kept by Commission regulatlons, orders, or llcense condltlons, and retam those records as requ1red by this section, unless otherwise spectfled by the Commlss1on? 181 Change does not decrease the safeguards effectiveness of any activity, system or component performance 1 meeting the requirements of 1 o CFR 73.55. D Change decreases the safeguards effectiveness of an obligation meeting the requirements of 10 CFR 73.55. D Not Applicable Conclusion Ratlonale: Fort Calhoun Station has not changed its records requirements. The revision of the Physical Security Plan does not alter or affect compliance with the requirements of 10 CFR 73.55(q) "Records". Records are maintained within regulation requirements. 10 CFR 73.65(r) Altematlve Measurea Does the rev1s1on change/actlVity negatively 1mpact a llcensee's demonstrated altemate measure for protection agamst radiolog1cal sabotage, other than one requ1red by § 73.55 that meets the same performance obJecbves and requ1rements specifled § 73.55(b)? D Change does not decrease the safeguards effectiveness of any activity, system or component performance meeting the requirements of 10 CFR 73.55. D Change decreases the safeguards effectiveness of an obligation meeting the requirements of 1 O CFR 73.55. 181 Not Applicable Conclusion Rationale: This section ls not applicable since there are no alternative measures to 73.55 in place at Fort Calhoun Station. 10 CFR 73, Appendlx B, Part VI -Tralnlng and Quallflcatlon for Nuclear Securlty Does the rev1s1on change/actiVlty negatively 1mpact, delete, or decrease the overall Ievel of secunty trainlng or quallftcation performance as descnbed m 10 CFR 73, Appendix B, Part VI, or decrease the effectlveness of the Training and Qualification Plan, or an implementing procedure that implements a traming or quallficabon requ1rement for the nuclear Security Change does not decrease the safeguards effectiveness of any activity , system or component perfonnance meeting the requirements of 10 CFR 73.55. D Change decreases the safeguards effectiveness of an obligation meeting the requirements of 1 O CFR 73.55. D Not Applicable Conclusion Rationale: The revlslon does not negatlvely impact, delete, contradlct, or decrease the overall Ievel of securlty training or quallflcatlon performance as descrlbed in 1 O CFR 73, Appendlx B, Part VI, or decrease the effectiveness of the Training and Qualification Plan, or an implementing procedure that implements a tralnlng or qualification requirement for the nuclear Security organization. Fort Calhoun Station Security training requirements have not changed or degraded with this revision of the Plan. AII members of the Security organization possess the knowledge, skills, and abilities required to effectively perform the assigned duties and responsibilities. 10 CFR 73, Appendlx C -Safeguards Contlngency Plans Does the revis1on change/activity negat1Vely 1mpact, delete, contradict, or decrease the effectiveness of the statlon's Defensive Strategy Plan, securtty force protectiVe actlons, or securlty systems performance as descnbed 1n 10 CFR 73, Append1x C, or decrease the effectlveness of the stabon's defens1ve strategy, or an 1mplementing procedure that implements a Safeguards Cont1ngency Plan requirement? 181 Change does not decrease the safeguards effectiveness of any activity, system or component performance meeting the requirements of 10 CFR 73.55. D Change decreases the safeguards effectiveness of an obligation meeting the requirements of 10 CFR 73.55. D Not Applicable Conclusion Rationale: The revision does not negatively impact, delete, contradict, or decrease the effectiveness of the station's Defensive Strategy Plan, security force protective actions, or security systems performance as described in 1 O CFR 73, Appendix C, or decrease the effectiveness of the station's defensive strategy, or an implementing procedure that implements a Safeguards Contingency Plan requirement. The Safeguards Contingency Plans will remain the same at Fort Calhoun Station. The Safeguards Contingency Plans at Fort Calhoun Station will not be affectecl by the release of land from the Owner Controlled Area. § 73.58 Safety/Security lntarface Requlrements for Nuclear Power Reactors Does the rev1s1on change/actlvrty negatively impact_. delete, contradict, or decrease the overall Ievel of securlty system performance, safety and security on plant equipment and operations, restrict or delay Operator access to vital equipment, negattvely lmpact emergency preparedness or security, or to 1mplement compensatory measures or mitigatlve actrons to mamtain safety and securlty m accordance wrth the llcense conditions 18] Change does not decrease the safeguards effectiveness of any activity, system or component performance meeting the requirements of 10 CFR 73.58. D Change decreases the safeguards effectiveness of an obligation meeting the requirements of 10 CFR 73.58. 1 D Not Applicable 1 Concluslon Ratlonale: The revision does not negatively impact, delete, contradict, or decrease the overall Ievel of security system performance, safety and security on plant equipment and operations, restrict or delay Operator access to equipment, negatlvely impact emergency preparedness or security, or to implement compensatory measures or mitigate actions to malntain safety and security in accordance with the license conditions. A project team was assembled to review the impacts on cross functlonal groups. The team consists of Security, Radiation Protection, Engineering, Chemistry, Regulatory Assurance, Emergency Plannlng, and Operations. The release of land from the Owner Controlled Area will not have an lmpact on the Safety/Security lnterface Requirements Fort Calhoun Station. § 73.54 Protectlon of Dlgltal Computer and Communication Systems and Networks Does the revis1on change/actiVlty negatively impact, delete, contradict, or decrease the overall Ievel of secunty system performance as described rn 10 CFR 73.54. D Change does not decrease the safeguards effecüveness of any activity, system or component performance meetlng the requirements of 1 O CFR 73.54. D Change the safeguards effectiveness of an obligation meeting the requirements of 1 O CFR 73.54. 181 Not Applicable Conclusion Rationale: The revision does not negatlvely impact, delete, contradict, or decrease the overall Ievel of security system performance as described in 10 CFR 73.54. Per Amendment No. 298 to Renewed Facility No. DPR-40, Fort Calhoun Station is no longer required to maintain a Cyber Security Plan. The release of land from the Owner Controlled Area has no effect on the protection of digital computers, communlcation systems, and networks. However, industry best practices are malntaln for cyber security related events. Document Revision Screening Evaluation Screenlng Evaluatlon Review: Concluslon: SY -FC-101*104-F-01 Revision 2 Page 8 of 8 This change to the Physical Security Plan continues to meet the general performance objectives and requirements, and describes in sufficient detail how requirements are implemented through the establishment and maintenance of a security organization, the use of security equipment and technology, the training and 1 qualification of securlty personnel, the implementation of predetermined response plans and strategies, and the protection of digital computer and communication systems and networks. Site-specifte conditions that affect how , the licensee implements Commission requirements have also been evaluated. This change does not decrease the Safeguards effectiveness of the Physical Security Plan based on the analysis of performance objectives defined in § 73.55 (a) through (r), § 73.54, and § 73.58. This change is* sultable for submittal under 1 o CFR 50.54(p ). 1 Screening Evaluation Prepared By: _Samuel Berkey Date: 6/12/18 0 Based on the rationale provided within this screening evaluation, 1 approve implementation of this document revlslon under the provisions of 10 CFR 50.54{p). Nate: Security Plan revisions not approved for implementation under the provisions of the 10 CFR 50.54(p) process SHALL BE sub itted to the NRC under the provisions of the 1 O CFR 50.90 approval process prior to implementatio t e Reviewed by (MSS): Date: "1/J;,h When Director, Site Security review and approval of the 10 CFR 50.54(p) screening evaluation is required by SY-FC-101-104, Attachment 1; obtain approval signature below prior to revision implementation. Reviewed and Approved _d / . / ,4 / / ,/ . / . / by:(Director Site Security): ~.$,; (.;/V'a~ /'1 Date: {Director, Slte Security) i/"'f~ t: -:z.,,, ~.,-.f A R-12-E WASHJNGTON COUNT~ NEBRASKA 1 IOWA *1i REV.SH. 25674 FILE 36045 OMAHA PUBLIC PQWER DISTRICT FORT CALHOUN STATION UNIT NO. I METES ANO BOUNDS N Figure 2.2-4 EC 69954 lnsert A: Drawing file 36045 EC 69954 revision lnsert A: This circle depicts the Exclusion Area Boundary (EAB) that is approximately 1525 ft from the centerline of the Auxiliary Bulldlng Stack. Ref. FC08790 -Atmospheric Dispersion Factors (X/QS) at the Decommissioning Exclusion Area Boundary (EAB) For Radiological Releases From Fort calhoun Station. This EAB depiction is INFOMRATION ONLY.

L ft1 fJv? 7,/-~ 6~ :,/.ek I ar -{,i,,. <1V( t/. .. __ 345KV LINE TO SIOUX CITY w .-OMAHA PUBLIC POWER DlffllCT FORT r.ALHOUN S1ATION UNIT N0.1 -\_NOTE 1 451<V LINKEO TO OMAHA Ik LlNCOI.N NOTE 1. THE MINIMUM SEPARATION BETWEEN THE 345 ICV LINES AND THE SHIELD WIRE FOR THE 161 ICV LVJE AT TIE CROSSOVER POINT IS 12.5 FT,; THIS MINIMUM SEPARATION WOULO UNOER 121'F SAO CONOITIONS. NOTE 2. THE MINIMUM SEPARATION BETWEEN THE 345 KV LINES MIJ THE SHIELD WIRE FOR THE 161 ICV LINE AT THE CROSSOVER POINT IS 32.0 FT I THIS MINIMUM SEPARATION WllLO OCCUR UNOER 120'F SAG CONDITIONS. USAR PIGURI 8.2-2 TRANSMISSION LINE ROUTING REVSH. FILE 36565 w ~z ..... --1-5"(::",y,~ 1>e~')A("'_.: rf.<'r li"~ f.e,,c. -f? /t<tr ?r'f< h11/1~~7. Crv5'fhe>..~ t::.r .e --fb e ,~ N1. c.1 v~ OIIAHA PUBLIC POWIIR DIITRICT FORT CALHOUN ITATION UNIT No.1 REV. SH. 23688 APVO REV C.T" tl 7 FILE 36031 SITE VICINITY PLAN Page 1 of 11 11 DSAR-2.2 11 Site and Environs General-Description of Site and Environs 1 Revi Safety Classification: Usage Level: 1 Safety 1 1 lnformation 1 Change No.: EC 69188 69954 Reason for Change: This section ls being updated to aligA ~\~1t1:1 PeFmaAeRtly l)ef11eled Teel:lnical &peeif.isatiens EPDTS). Due to EC 69954, Partlal Site Release -Phase 1. Changes on page 4, 10 and 11. Preparer: J. Delten R. L. Church Fort Calhoun Station DSAR-2.2 General Description of Site and Environs lnfonnation Use 2.2 General Description of Site and Environs Page 4 of 11 Rev.1 The post permanent shutdown site extent is was 660.46 acres; 564.96 acres of this area is was on the alluvial flood plain of the*Missouri River, and the remainder is part of the bluff system on the southwest side of the river. Phase l of Ref. 2.2-1 reduced the exclusion area by approximately 120 acres. An additional exclusion area of 582.18 acres is included on the northeast bank of the river directly opposite the plant buildings. This additional exclusion area is provided by means of perpetual easements which allows OPPD to restrict or prohibit access should evacuation be necessary. More specifically on October 28, 1969, and on October 24, 1973, the owners of property located across the Missouri River from OPPD's Fort Calhoun facility executed easements in perpetuity to the OPPD which consists of the following: ln consideration of the sum of One Dollar and other valuable consideration and of further agreements herein stated, the undersigned owners of real estate hereinafter described, their heirs, executors, administrators, successors and assigns. hereinafter called "Grantor" hereby grant and convey to the Omaha Public Power District, its successors and assigns, hereinafter called "District", a perpetual easement over, along and upon the following described accretion land to lowa real estate owned by the Grantor in Harrison County, lowa, and sometimes described as: October 28, 1969 Agreement: From the South 1/4 comer of Section 17, Township 18 North, Range 12 East of the 6th P.M., Washington County, Nebraska; thence North 00° 10'15" West along the % line a distance of 2,088.27 feet to the point of beginning, said point being on the right bank of the designed channel of the Missouri River, thence continuing North 00° 1 O' 15" West a distance of 57 4.52 feet to intersect the 1943 Nebraska-lowa compact line; thence along the compact line as follows: South 42°52' South 47°12' South 51°42' South 55°42' South 59°24' South 64°14' South 68°56'20" South 62°14' South 56°54' South 51 °30' South 46°48' South 41 °07' East a distance of East a distance of East a distance of East a distance of East a distance of East a distance of East a distance of East a distance of East a distance of East a distance of East a distance of East a distance of 277.91 feet; 476.86 feet; 477.30 feet; 479.83 feet; 478.09 feet; 481.84feet; 1,031.14 feet; 468.62 feet; 566.97 feet; 366.4 7 feet; 468.26 feet; 282 .40 feet; DSAR-2.2 General Description of Site and Environs lnfonnation Use Page 10 of 11 Rev.1 A tract of land in the North One-half of Section 31, Township 78 North, Ranga 45 West of the 5th P.M., Harrison County, lowa, being more particularly described as follows: Beginning at the point of intersection of the South line of the North One-half of Section 31-78-45 and the Nebraska-lowa compact line; thence N 30°05'35" W along the compact line a distance of 239.96 feet; thence N 28°04'05" W, a distance of 863.08 feet to the point of intersection of the Nebraska-lowa compact line and the design right bank of the Missouri River; thence S 71 °01 '48" E along said right bank a distance of 135.92 feet; thence S 73°37'43" E, a distance of 500.22 feet; thence S 75°11'38" E, a distance of 147.06 feet; thence S 76°21'54° E, a distance of 524.11 feet; thence S 78°41'38" E, a distance of 338.81 feet; thence S 79°35'38" E, a distance of 70.65 feet to a point of intersection of the design right bank and a line that is 2,970 feet East and parallel to the West line of said Section 31-78-45; thence S 02°40'52" E along said line a distance of 490.00 feet to the South line of the North One-half of said Section 31-78-45; thence S 87°19'10" W along said South line a distance of 1, 159.50 feet to the point of beginning. ln the opinion of counsel, paragraphs 3 and 5 of these agreements give OPPD ample legal authority to vacate said property in the event that an emergency should occur. Figure 2.2-1 is an aerial photograph of the site and immediately surrounding area. A majority of the sile is being fanned at the present time and it is planned that farming will continue. On-site farming consists primarily of grain. Approximately 445 acres of the totat 660.46 acres are under cultivation. The environmental monitoring program includes on-site crops as one of several vegetation samples. The sample is obtained and analyzed near the end of the growing season. The area adjacent to the sita is farm land and is sparsely populated. The nearest population area is the town of Blair. Nebraska, approximately 3.4 miles west northwest of the plant. Figures 2.2-2 and 2.2-3 show the geographical features within 60 and 30 miles, respectively, of the site center, Figure 2.2-4 defines the metes and bounds of the site. Both private and commercial traffic make use of U. S. Highway No. 75 which forms the southwest boundary of the site and of the Missouri River which forms the northeast boundary. The highway is located at least 3,200 feet away, therefore, it is unlikely that an accident on this route would affect the station. The river traffic handles few hazardous materials. The danger to the station from air traffic is considered minimal since the sita is not located near landing pattems or runways of any large commercial or military airport facility. The legal description of the area released under Phase I of Ref. 2.2-1 is as follows: Area located in the East half of the Southwest quarter of Section 17, Township 18 North, Range 12 East and the East half of the Northeast quarter of the Northwest quarter and East half of the Southeast quarter of the Northwest of Section 20, Township 18 North, Range 12 East. DSAR-2.2 General Description of Site and Environs DSAR 2.2 Specific

References:

lnformation Use 2.2-1: Project 2444, Partial Site Release. Page 11 of 11 Rev.1 11 Safety Classification: 1 Safety Change No.: Reason for Change: Preparer: Page 1 of 25 DSAR-14.1 Safety Analysis General Rev 23 -1 EC 6962569954 11 Updated per DLBR-findingsfor reduced EAB calculations C. Waszak Fort Calhoun Statlon 11 DSAR-14.1 Safety Analysis Infonnation Use List of Tables Page 3 of 25 Rev.2 Table 14.1-1 -Deleted .... .-........................................................................................................ 4 Table 14.1-2-Deleted ............................................................................................................. 5 Table 14.1-3 -Fort Calhoun Fuel Design Parameter Values for Representative Fuel ............. 5 Table 14.1-4 -Deleted ............................................................................................................. 5 Table 14.1-5-FCS Equilibrium Core lnventory (Power Level: 1530 MWt) ............................... 9 Table 14.1-6-Deleted ........................................................................................................... 14 Table 14.1-7-Deleted ............................................................................................................ 14 Table 14.1-8-Gap Fractions for non-LOCA Events ............................................................... 14 Table 14.1-9 -Fort Calhoun Site Boundary Atmospheric Dispersion Factors X/Q (sec/m 3) ... 16 Table 14.1-10 -Fort Calhoun Control Room Atmospheric Dispersion Factors X/Q (sec/m 3).19 Table 14.1-11 -Radiological Analysis Assumptions and Key ParameterValues-FCS Control Room ............................................................................................................. 20 Table 14.1-3

Fort Calhoun Fuel Design Parameter Values for Representative Fuel .............

5 Table 14.1-5= FCS Equilibrium Core lnventory (Power Level: 1530 MWt) ............................... 9 Table 14.1-8-Gap Fractions for non-LOCA Events ............................................................... 14 Table 14.1-9 -Fort Calhoun Site Boundary Atmospheric Dispersion Factors XIQ (sec/m 3) ........................................................................................................................................... 1749 Table 14.1-10 -Fort Calhoun Control Room Atmospheric Dispersion Factors X/Q (sec/m 3) ....................................................................................................................................... 2049 Table 14.1-11 -Radiological Analysis Assumptions and Key Parameter Values -FCS Control Room ........................................................................................................................... 212.Q DSAR-14.1 Safety Analysis lnformation Use Page 4of25 Rev. 2 14. SAFETY ANAL YSIS 14.1 General Earlier sections of this raport described and evaluated the reliability of major systems and components of the plant from a safety standpoint. For the Safety Analysis it is assumed that certain incidents may occur notwithstanding the precautions taken to prevent their occurrence. The potential consequences of such occurrences are then examined to determine their effect on the plant, to determine whether the plant design is adequate to minimize the consequences of such occurrences, and to provide assurance that the health and safety of the public is protected from the consequences of even the most severe of the hypothetical accidents analyzed. 14.1 .1 ldentification of Occurrences and Accidents A number of postulated accidents are considered which do not involve the reactor core or coolant system, but which could involve a release of radioactive material to the environment. They are discussed in Sections 14.18 ,and 14.20. Analysis of these incidents shows that safeguarcls incorporated in the plant design would limit any release of radioactive material to inconsequential amounts. 14.1.2 Deleted 14.1.3 Deleted Table 14.1.1 -Deleted 14.1.4 Radiation Monitoring During Accident Conditions Gaseous radioactivity is continuously sampled and monitored from the ventilation discharge duet (RM-062). A swing monitor (RM-052) can also monitor gaseous radioactivity and continuously sample particulates from either the containment building or the ventilation discharge duet. There is no longer any requirement to align RM-052 to containment. A multi-channel area monitoring system is provided to measure radiation Ievels in the containment and auxiliary building. Additiohally, the waste disposal system liquid effluent is continuously monitored. The radiation monitoring equipment, (described in detail in Section 11.2.3) in conjunction with installed process instruments and data from the on-site meteorological tower will be used to monitor, locate, quantify, control and plan releases of radioactivity from the plant during normai operation and following an accident. 14.1.5 Deleted Table 14.1.2-Deleted DSAR-14.1 Safety Analysis lnfonnation Use Page 5 of 25 Rev.2 Table 14.1-3 -Fort Calhoun Fuel Design Parameter Values for Representative Fuel Fuel Pellet diameter lnner cladding diameter Outer cladding diameter Active length Table 14.1-4 -Deleted 14.1.6 Radiological Consequences Methods 0.3805 inch 0.387 inch 0.440 inch 129.3 inch Fort Calhoun Station (FCS) voluntarily revised tne accident source tenn used in all of lts design basis site boundary and control room dose analyses by implementation ofthe Altemative Source tenn (AST) (Reference 14.1-13). The methodology used in the AST design basis accident analyses also reflects a design basis variflcationire-constitution effort that was initiated to support a total upgrade to the AST. lncluded in this verification process were site boundary (Exclusion Area Boundary-EAB and Low Population LPZ). and control room atmospheric dispersion factors. The site boundary and control room dose analyses for the design basis accidents were reanalyzed as part of Referance 14.1-13. A majority of the analyses which were reanalyzed for AST are no longer applicable in the permanently defueled state. The following analyses still applicable to FCS were re-evaluated using the AST (applicable DSAR section identified):

Section 14.18, Fuel Handling Accident (in Spent Fuel Pool ) (FHA)
Section 14.20, Waste Liquid Incident (LWTF) Note that LWTF was not impacted by implementation of the AST, as there is no accident initiated fuel damage associated with tAeSe-this event s. However, they-it to maintain consistency in design basis. FCS has completed a full implementation of the AST as defined in Reference 14.1-14. The worst 2 hour period dose at the EAB, and the dose at the LPZ for the duration of the ralease, is calculated for each of the events noted above based on postulated airbome radioactivity releases.

This represents the post accident dose to the public due to inhalation and submersion for each of these events. Offsite breathing rates used were as follows: 0-8 hr (3.47E-04 m 3/sec), 8-24 hr (1.75E-04 m 3/sec), 24-720 hr DSAR-14.1 Safety Analysis lnfonnation Use Page 6 of 25 Rev.2 (2.32E-04 m 3/sec). t'A:le-ta-distanoe/plant shieldin§, the dose oontributieR-at tAe EAB/LP-2 due to direot shine from oontained sources is sonsidered ~att the accidents.- The O to 30-day dose to an operator in the control room (CR) due to airbome radioactivity releases is developed for all of the DSAR Chapter 14 design basis accidents. This represents the post accident dose to the operator due to inhalation and submersion. 14.1.6.1 General Radiological Analysis Methodology Except as noted below, the updated FCS accident analyses follow the guidance provided in Regulatory Guide (RG) 1.183 (Reference 14.1-14): The site boundary and control room dose calculations used breathing rates noted in DG 1081 (Draft Guide to RG 1.183). The impact on dose analyses due to usage of these breathing rates instead of RG 1.183 rates is negligible. To account for fuel conditions outside the bounds of RG 1.183 (Table 3 footnote), conservative estimates of FCS specific fuel gap fractions are utilized for non-LOCA events. For all non-LOCA events analyze!) for NRC submittal in Reference 14.1-30 and any future revisions of non-LOCA events. FCS received permission to use the NUREG/CR*5009 gap fractions (Reference 14.1-32). RG 1.183 does not address the bw:f-RLWTF. The accident scenarios utilized for this analysis reflects other guidance and/or sita specific models. This accident is described in DSAR Section 14.20. Except as noted, assumptions regarding the occurrence and timing of a Loss of Offsite Power (LOOP) ara in accordance with RG 1.183 and are selected with the intent of maximizing doses. For the following reasons, a LOOP is not assumed with FHA and LWTF. Per lnforrnation Notice 93-17 the need to evaluate a design basis event assuming a simultaneous/subsequent LOOP is based on the cause/effect relationship between the two events. The accidents listed above {i.e. FHAs and LWTF) cannot cause a LOOP. Consequently, following the logic sequence discussed in lnformation Notice 93-17 relative to the LOCA/LOOP, these analyses do not address the potential of a LOOP. 14.1.6.2 Dose Acceptance Criteria DSAR-14.1 Safety Analysis lnformation Use 14.1 .6.6 Site Boundary Atmospheric Dispersion Factors Page 15 of 25 Rev. 2 Normalized atmospheric dispersion (X /Q) values were calculated for the FCS E:xclusion Area Boundary (EAB) ane-Low Population Zane (LPZ} for post accident gaseous releases from the Auxiliary Building Stack, Radwaste Processing Building Ventilation Discharge Nozzle, and Auxiliary Building Fresh Air lntake (Reference 14.1-23). Normalized atmospheric dispersion {X /Q) values were calculated for the FCS Exclusion Area Boundary (EAB} for post accident gaseous releases from the Auxiliary Building Stack and Radwaste Processing Building Ventilation Discharge Nozzle (Reference 14.1-25).Reference 14.1-16 methodology was used for calculation of atmospheric dispersion factors. Reference 14.1-13 provides information on howthe dispersion factors were developed and calculated. The following assumptions were made for derivation ofthe atmospheric dispersion faeton:;:

1. +oo~AB distaAGe&oo whlGMhe-A~xiliary BuHding Stack

J'.Q-values 1 1.1eFe-based aFe conservativel-y determined frorn the outer eage ef-tR-e-ContainmeRt Building:The plume centerline from each release is transported directly over the receptor ( conservative

}. 2-:--+he Auxiliary-8Hik:Jmg-Stack EAB x /Q value is applicab1e4e tho AuxUiafY,&ilding Fretm-Alf lntake-given the-f}foximity.ef ~-Gefttamment Building. AII releases are treateq as..Qoint sources (conservative).

3. As the radiological releases_are from the Spent Fuel Pool and liquid Waste Tank, no building wake effect is used in the calculation (conservative).

4. AII releases are treated as ground-l evel as there are no release conditions that are high enough to escape the aerodynamic effects of the plant buildings (conservative

). L_RG 1.111 "plain" terrain recirculation factors are used in the calculation of the annual average X/Q values (conservative). §.:_ The EAB relative to the Radwaste Building Exhaust Nozzle is a circle whose radius is based on the shortest distance from the nozzle to the Auxiliary Building Vent Stack EAB {..conservative) DSAR-14.1 Safety Analysis lnforrnation Use Page 17 of 25 Rev.2 Table 14.1-9-Fort Calhoun Site Boundary Atmospheric Dispersion FactorsX/Q (sec/m 3) Exclusion Area Boundary Release Point Aux. Bldg. Vent Stack Aw<. Bldg.-w-esA Air lmake Radwaste Processing Bldg. Ventilation Discharge Nozzle Averaging Period 0-2 hr 04 (E)9.82E-04 (NE) 2.46E 04 (ESE)1. 77E-03 (NE} NO+&+-fer oonservati-sm an E/\B X-/.Q...valtJe..9f...2.56E 04 seelm~twa~ release points: Low Population Zone Release Point AII Releases Averaging Period 8-24 hr 2.51E-05(NW} 7.29E-06{NW} 4.83E-06(NW) 24-96 hr 96-720 hr 1.98E-06{NW) 5.49E-07(NW) DSAR-14.1 Safety Analysis lnformation Use Page 20 of 25 Rev.2 Table 14.1-10-Fort Calhoun Control Room Atmospheric Dispersion FactorsX/Q (sec/m 3) Averaging Period Release/Receptor Combination 0-2 hr 2-8 hr 8-24 hr 24-96 hr 96-720 hr Aux. Bldg. Stack/CR Air lntake 3.16E-03 2.37E-03 1.16E-03 8.93E-04 7.15E-04 Aux. Bldg. Alr lntake/CR Air lntake 4.61E-04 3.12E-03 2.21E-03 9.58E-04 6.88E-04 Radwaste Nozzle/CR Air lntake 14.1.6.8 1.0SE-03 9.04E-04 4.02E-04 2.84E-04 2.27E-04 Radiological Consequences Control Room Modei For all FCS Radiological Consequence Calculations1 the control room (CR) is modeled asa single region (Reference 14.1-13). +l=le FCS oontrol room design functions (4JS-w.g-:-during bofu normai operation as well as aocident mode) were creditad--m-ü=\e rea nalysi&.-This DSAR section addresses the accident configuration and design basis for the CR. AII events analyzed for radiological consequences utilized the design basis configuration. A 10% margin is applied on all CR ventilation flows. Table 14.1-11 lists the key assumptions/parameters associated with FCS control room modei applied to design basis radiological consequences analyses from Reference 14.1-13. DSAR-14.1 Safety Analysis 14.1-11 DELETED 14.1-12 DELETED lnfonnation Use Page 24of 25 Rev.2 14.1-13 Application for Amendment of Operating License, (Altemate Source Tenn), LIC-01-0010, February 7, 2001, OPPD to USNRC Document Control Desk 14.1-14 Regulatory Guide 1.183, Revision 0, Altemative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors, July 2000 14.1-15 DELETED 14.1-16 Regulatory Guide 1.145, Revision 1, Atmospheric Dispersion Models for Potential Accident Consequence Assessments at Nuclear Power Plants 14.1-17 EPA-520/1-88-020, September 1988, Federal Guidance Report No. 11, Limiting Values of Radionuclide lntake and Air Concentration and Dose Conversion Factors for lnhalation, Submersion and lngestion 14.1-18 T1D~24190, Air Resources Laboratories, Meteorology and Atomic Energy, July 1968 14.1-19 OPPD Calculation FC06800, Revision 1, Bounding Composite Equilibrium Core lnventory with lnitial U-235 Enrichments of 3.5 w/o to 5.0 w/o 14.1-20 DELETED 14.1-21 OPPD Calculation FC06806, Revision 0, OPPD Meteorological Data Conversion to ARCON 96 and SWEC Fonnats. 14.1-22 OPPD Calculation FC06807, Revision 1, Atmospheric Dispersion Coefficients (X/Qs) at the Control Room and TSC Air lntakes for ldentified Design Basis Accidents' Release Points 14.1-23 OPPD Calculation FC06808, Revision 01 , Atmospheric Dispersion Coefficients (X/Qs) at the EAB and LPZ for ldentified Design Basis Accidents' Release Points 14.1-24 OPPD Calculation FC06811, Revision O, Estimate Gap Fractions Based on FCS Specific Fuel Characteristics DSAR-14.1 Safety Analysis lnformation Use Page 25 of 25 Rev. 2 14.1-25 OPPD Calculation FC08790, Revision 0, Dispersion Coefficients (X/Qs} at the Decommissioning Exclusion Area Boundary (EAB) for Radiological Releases from the Fort Calhoun Station~-+fil}. 14.1-26 DELETED 14.1-27 DELETED 14.1-28 DELETED 14.1-29 DELETED 14.1-30 OPPD Letter, LIC-05-107, October 31 , 2005, Application for Amendment of Operating License, Updated Safety Analysis Report Revision for Radiological Consequences Analysis for Replacement NSSS Components 14.1-31 NUREG/CR-5009, PNL-6258, Assessment ofthe Use of Extended Burnup Fuel in Light Water Power Reactors, February 1988 14.1-32 NRC Letter, NRC-06-0146, October27, 2006, Fort Calhoun Station, Unit No.1 -lssuance of Amendment RE: Changes to the Updated Safety Analysis Report Related to the Radiological Consequences of Events Affected by the Planned 2006 Replacement of the Steam Generators and Pressurizer (TAC NO. MC8857} 1 4.1-33 DELETED Page1 of 11 11 DSAR-14.18 11 Safety Analysis Fuel Handling Accident in Spent Fuel Pool Rev~ 1 Safety Classification: 11 Safety ' 1 ChanaeNo.: l Reason for Change: Preparer: r .. ':tonnation EC 69954 Updated te-refle&t-finding& frem the IKBRfor reanalvsis du& to reduced EAB C. Waszak Fort Calhoun Statlon 11 DSAR-14.18 lnformation Use Fuel Handling Accident in Spent Fuel Pool Page6of11 Rev.2 Loads may be canied over spent fuel positioned in a cask in the cask pit as allowed by the FCS Part 72 Llcensing Basis. 14.18.2 Method of Analysis The FHA was reanalyzed utilizlng altemative source tem (AST) methods in accordance with Regulatory Guide (RG) 1.183. Control Room and site boundary doses due to alrbome radloactivity releases following a FHA ln the fuel pool were calculated (References 14.18-5..al%! -_14.18-6 , and 14.18-11).1 T able 14.18-1 lists some of the key assumptions/parameters utilized to develop the radiological consequences followlng a FHA in the fuel pool (Referenoe 14.18-4). The analysis in Reference 14.18-5, whlch generates the ~'i3-~":J-LPZ dos~ assumes that the fuel handllng accldent occurs 72 hours after reactor shutdown. The analysls ln Referenoe 14.18-6 which generates the control room dose in Sectlon 14.18.3 is performed at a time of 100 days efter reactor shutdown .* The anal:tsis in R!}ference 14.18-11., which generates the EAB ___ , ____ .*. -{!!_ ... ~, -*-=-__ .J doses assumes that the fuel handling accident occurs 20 months after Not HlfllliQht ___ ---" reactor shutdown. It is postulated that the accident results ln damage to one fuel assembly thus releaslng all of the fuel gap activlty associated wlth that assembly. Referenoe 14.18-4 documents the methods used, the explicit calculatlons are documented in Reference 14.18-5 ,-Md--14.18"'6 , and 14.18-1 11. As discussed in Section 14.1 the gap fractlons utilized for non-1..0CA analyses at FCS are twice that recommended by RG 1.183 (Reference 14.16-4). The gap fractlons were reevaluated for the replacement steam generators and replacement pressurizer (Reference 14.18-10). This allowed use of non-LOCA gap fractions obtained from NUREG/CR-5009. The FHA forthe Control Room and Exc!usion Area Boundary werewas updated for 1 1 Oecommissloning and us es the gap fractions from NUREG/CR-5009. The FHA forthe EAB and-LPZ wem-was not updated andtherefore, contlnu~ to use FCS speclflc gap fractions developed in Reference 14.18-4. The activity (conslstlng of noble gases, halogens, and alkall metals) is released in a "puff" to the spent fuel pool, which has a minimum of 23 feet of water above the damaged fuel assembly. DSAR-14.18 lnformatlon Use Fuel Handling Accident in Spent Fuel Pool Page 7 of 11 Rev.2 The radioiodine released from the fuel gap is assumed to be 95% Csl, 4.85% elementa!, and 0.15% organic. Oue to the acidic nature of the water ln the spent fuel pool (pH less than 7), the Csl will immediately dlsassoclate, thus, changing the chemical fonn of lodine in the water to 99.85% elementa! and 0.15% organic. The chemical form of the lodlnes above the spent fuel pool is 57% elementa! and 43% organic. The current DSAR analysis used to generate the dose at the eAB--aAG-LPZ (Referenoe 14.18-5) is based on an __ overall effective decontaminatlon factor of 285 while Reference 14.18-6 for .--*{ Fannabll1 Not HIQh_'ii_lK _______ _ the control dose ,and 14.18-11 for the EAB

.. *r: Not H~hlg i. -* *=-=** ---room dose .. .... *-----* -* PclnMl:led:

Not Hlghl!Qlt _-______ _, Reference 14.1 besed on RG 1.183 guidelines shall utlllze an overall effectlve cleoontamination factor for lodine of 200. See Reference 14.18-7 for further details. This use of overall effective decontamlnation factor for lodine only applies to fuel handling accidents wlth 23 feet water depth per RG 1.183. Noble gas and unscrubbed iodines rise to the water surface where they are mixed ln the available air space. Ali of the alkali metals released from the gap are retalned ln the spent fuel pool water. The actlvlty is collected by the auxlllary bullding ventilation system and released, unfiltered, to the environment via the auxlliary buildlng vent stack. Since there ls no means of isolating the spent fuel pool area all of the alrbome activity resulting from the FHA is exhausted out of the auxlllary buildlng ln a period of two hours. The closest openlng ln the auxlliary build i ng to the oontrol room intake is the auxlliary bullding fresh air intake. However, the auxiliary buildlng vent stack X/Q's were used as they bound that of the auxiliary bulldlng fresh air intake. The event ls based on a two-hour release; the worst two-hour period for the Exclusion Area Boundary (EAB) l s the zero to two-hour pertod. The EAB , Low Populatlon Zona (LPZ), and oontrol room doses following a FHA in the spent fuel pool are presented in Sectlon 14.18.3. DSAR-14.18 lnformation Use Page8of 11 Rev.2 Fuel Handling Accident in Spent Fuel Pool Table 14.18-1 -Radiological Analysis Assumptions and Key Parameter Values-Fuel Handling Accident in Fuel Pool Area Powerlevel Number of Damaged Fuel Assemblles Total Number of Fuel Assemblies Decay Tlme Prlor to Fuel Movement Radial Peaklng Factor Fractlon of Core lnventory in gap Equlilbrium Core Activity lodine Form of gap release before scrubbing Scrubbing Deoontamlnation Factors Overall Effective Decontamination Factor for lodine Rate of Release from Fuel Environmental Release Rate Envlronmental Release Point Accident in Fuel Pool Area 1530MWt 1 133 72 hours/100 days liQ. mooths 1 1.8 1-131 (16% / 12%2) Kr-85 (20% / 30%2) Other Noble Gases (10%} Other Halides (10%) Alkall Metals (24% / 17%2) Table 14.1-5 99.85% Elementel 0.15% Organic Elementa! lodine (5004) Organic lodi ne (1} Noble Gas (1 } Partlculates ( -2853/2004 "pufl" Ali airbome activity in a 2-hour period Auxiliary building vent stack * !-ef.-100 dal'! is used for FHA dose to the controi room wlthout credit taken for radiolodine rernova! by control 1 room charcoal or HEPA filtera {Reference 14.18-6).si.OQ.1Q. months is used !or FHA a.1 the EAB with e ; reduced EAB 14.1!Hn. 1 2 The reanalysls performed ln Reference 14.18~ to detennine control room dose utlllzes updated gap fractlons &pprl)V8d ln TS Amendment 243 s For Mure revlslon to FHA ena!yaea an effec:1ive overall decontamination factor for lodlne of 200 s!lall be used (Reference 14.18-7). ~The reanalyaia performed in Reference 14.18~ and 14.18-11 to determlne control R>Om doae an_g_i;AB dos§ 1 ut!llzes a decontamlnatlon factor of 200. l'annlltled: Nct Hlghlght DSAR-14.18 lntormatlon Use Fuel Handllng Accident in Spent Fuel Pool 14.18.3 Results Page 9 of 11 Rev. 2 The total effectlve dose equivalent (TEDE) doses for the EAB, LPZ, and CR following a FHA in tha spent fuel pool are shown below. Location EAB LPZ Regulatory Limit Control Room Regulatory Limit TEDE Dose (rem) 4Ji.50 0.50 6.3 0.50 5.0 The maximum two-hour dose for the EAB 1s the zero to two hour time period. AII doses were rounded up to the nearest 0.5 rem. From Reference 14.18-8 the overall effectlve deoontamination factor (DF.11-) for a water pool (at least 23 feat deep) accounting for elemental5 and organic lodlne can be calculated using the following fonnula: DFBII' = 1 / [(% elementa! lodine / DF111emen1111) + (% organic lodine / DFargank>)] where DFe1ernenta1 = 500 (Reference 14.18-4) = 1 (Reference 14.18-4) fofI!\S of lodlne Credited for FHA Elementa! lodlne = 99.85% (95% Csl goes to elementa! form in water plus orlglnal 4.85% elementa! released (Reference 14.18-4, Page 39)) organic lodine = 0.15% (RG 1.183) The DFIIII' credited for analysis conducted in Reference 14.18-4 was calculated as follows: DFIIII' = 1 / [(0.9985 / 500) + (0.0015 / 1 }]

285 Thls is the DFllff based on assumptlons and parameters listed in Table 14.18-1. Forfuture analyses per Referenoe 14.18-7 a DFeff = 200 shall be utilized.

To achieve a lower DFe11 one can lower the credit for DFe1emen1a1 such as shown below: 5 Reference 14.18-8 def.nes the equatlon as and DF.1111.io. As noted ln Reference 14.18-8, decontamination factora for elementa! iodlne and hydrogen iodlde should be of comperabie magnillJde, and are not dlfferentlated. Therefore, llstlng th!s equetlon as DFo1 .... -1 lnstead of DF1nocgan10 hes the sama meanlng. DSAR*14.18 lnformation Use Fuel Handling Accident in Spent Fuel Pool DFelf = 200 = 1 / [(0.9985 / DF 8 1emen1a1} + (0.0015 / 1 )] Solvlng thls equatlon for DFe1err.en1:s1 yields DFe1emen1a1 = 285. Page 10 of 11 Rev.2 A DF81emen1:s1 of 285 ls equlvalent to stating that 99.65% of elementa! iodine is retalned ln the pool water. A DFe1emen1a1of5001s equlvalent to stating that 99.8% of elementa! iodine is retalned ln the pool water. Use of a DFe!! of 200 ln Mure FHA analysis for EAB dose ls conservative and wlll be ln accordance with oommitments contained in Reference 14.18-7. The reanalysis performed in Reference 14.18-6 utlllzed a DFerrof200. 14.18.4 Conclusions The potential radiological consequences of a fuel assembly drop in the spent fuel pool are presented above and the resultant doses are well within the requlrements of 10 CFR 50.67. It is, therefore, concluded that a dropped fuel assembly would not present any undue hazard to the health and safety of the public. 14.18.5 Speclflc References 14.18-1 Refueling System, Fort Calhoun Statlon, Unit 1, Updated Safety Analysls Report, Sectlon 9.5, Revision 7/89 14.18-2 Radiation Monitoring, Fort Calhoun Station, Unit 1, DSAR Sectlon 11.2.3, Revlslon O 14.18*3 P&ID Drawing, GHDR 11405-M-1 14.18*4 OPPD Letter, LIC-01--0010, February 7, 2001, Application for Amendrnent of Operatlng Llcense 14.18.S OPPD Calculatlon, FC06816, Revision 2 Site Boundaryand Control Room Doses following a Fuel Handling Accident ln the Fuel Pool Area using Altemate Source Terms 14.18-6 OPPD Calculation, FC08557, Revision 01 , Fuel Handling Accldef'J in the Spent Fuel Pool Site Boundary and Control Room Dose 14.1 S.7 NRC letter, December 5, 2001, Fort Calhoun Station, Unit No.1-lssuance of Amendment (TAC NO. MB1221}, Alan B. Wang (NRC) to Sudesh K. Gambhlr (OPPD) DSAR-14.18 lnformatlon Use Fuel Handling Accldent in Spent Fuel Pool Page11 of11 Rev.2 14.18-8 Burley, Evaluation of Flsslon Product Release and Transport for a Fuel Handllng Aocldent, USNRC, October 1, 1971(Attached to Reference 14.18-9) 14.18-9 OPPD Engineering Analysis, EA17-010, Revlslon Q1 DSAR 14.18, Safety Analysls-Fuel Handling Aocident in Spent Fuel Pool, Deslgn & Lloenslng Basie Reoonstitutlon Report 14.-1-918-10 OPPD Letter, LIC-05-107, October 31, 2005, Appllcatlon for Amendment of Operating Lioense, Updated Safety Analysis Raport Revision for Radiological Consequenoes Analysls for Replacement NSSS Components j4, i8::1L OPPD Calcu!ation,fG08791, Revi 2 ion 0. SJte _____ _ a Fuel Handling Accident in the Fuel Pool Aree in Support ot a Redy.9...ed distance during Decommissionino , l'OnUIIIIII: Nat Hlghlght NOSIJ\3~ 8~0C: ~B3N A"""'8~~ A>NOOO 001$NHSV M 1J]Ji ,1, i : =ns A>l't cN noe it h i fl -S!l.1.Vl:>O S SV 'NOSS10\0 \ z g

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EP-FC-2001-5054Q Revision 0 Page 24of36 ATTACHMENT 2 -10CFRS0.54(g)(3) SCREENING Procedure/ l\!u n1ber: EP-FC-1001 1 Revis f on: 5 Equimne n t/f acifüv/Othe r: N/A Title: Permanent!y Defueled Emergencv Plan for Fort Calhoun Station Part l:. Dell!,:;:ri1 )tkm ot: A ctivity Be ing R.e viewed {event or action, or series of actions that may result in a change to the emergency plan or affect the implementation of the emergency plan): The site description in the PDEP is being revised as part of the updated site release calculations that are being completed in accordance wlth NRC approved exemptions. , ,, art n. A eth.t~i\~ Poo v f lOlM Siy Revi ewetli? OYES [81 NO Is this activity fuily bounded by an NRC approved 10 CFR 50.90 S0.54(q)(3) I!) Evaluatlon is Contlnue to submittal? NOT required. next part Enter fi) If YES, identify bounding source document number/approvai justification reference and ensure t he basis for concluding the source below and document fully bounds the proposed change is documented complete Part be!ow: VI. N/A 0 Boundinq document attached (optional) Pa r t Ill. Applicabmty of O t h er Re g ul tory Change C ontro l Proce!ii s-e s Check if any other regulatory change processes control the proposed activity. r 1!0'1'5: For example, when a deslgn change is the proposed activity, consequentlal actions may lnclude changes t o o t her documents w hich have i:l different change control process and are NOT to be !ncluded ln thls 50.54(q)(3) Sc r eening. APPl.ICABIUl'Y CONCLU S ION D If there are no controlling change processes, continue the 50.54(q)(3) Screening. 181 One or more controlllng change processes are selected, however, some portion of the actlvity involves the emergency plan or affects the implementatlon of the emergency plan; contlnue the 50.54(q)(3) Screenlng for that portion of the actlvity. Identify the applicable controlling change processes below. D One or more controlling change processes are selected and fully bounds all aspects ofthe actlvlty. 50.54(q)(3) Evaluation is NOT required. Identify controlling change processes below a nc! complete Part VI. Ct)NTROU .* I~G CHANGE PR~Jt:~s s n:s 10 CFR 50.83 Reie a se of part o f a power r eactor facil!t y or s!te for un r est r ic t ed use 10 CFR 20 Subpa rt D 50.54(p) Effiuent releases remain w ithin l icense conditions and t he environmenta! moni t ori n g program and offsite dos e calculation manual are revised to account for the changes The siting criteria of 10 CFR Part 1 00 continue to be met Pa r t I V. OYES 1\10 Is this activit y an edito r ial or typographlcal change such 50.54(q)(3) formatting, paragraph numbering, spelling, or punctuation that does Evaluation is Contlnue to n ot change intent? NOT re q uired. next part Enter J 1 us ti fiCi-s tkm: j ustlflcation below and complete Part VI. --- Ef'-FC~2001-50S4Q Revision 0 Page 25 of 36 A TIA CHMEN T 2 -10CFR50.5 4 (q)(3) §tCR.EE NIN G ?rocedur e/Do c mnent Number: EP-FC-1001 Revislon: 5 f.:quipme n t/Fi!lcmty/Other: N/A ntEe: Permanently Defueled Emergency Plan for Fort Calhoun Station Part v. Emerg.: er&cy Phum1i!J'l:g Screen (Associated 10 CFR 50.47(b) planning standard function identlfied in brackets) Does this activity affect any of the following, including program elements from NUREG-0554/FEMA REP-1 Section II? *-1. Responsibility for emergency response is assigned. [1] D 2. The response organization has the staff to respond and to augment staff on a ! 0 contlnuir.g basis (24/7 staffing) in accordance with the emergency plan. [1] 1 3. The process ensures that on shift emergency response responsibilities are staffed D and assigned_:12]

4. The process for timely augmentation of onshift staff is established

~nd maintained. [2] D ,_. *--*, 5. Arrangements for requesting and using off site assistance have been made. [3] 0 6. A standard scheme of emergency classification and action Ievels is in use. [4] D 7. Proced.;res for ~tlon of State anci local governmental agencles are capable ::r= D a!erting them of the declared emergency within 60 minutes after of an emerge_ncy~nd provid!~ follow-up notif~tions. [5] --**-.--, 8. Systems are estab!ished for prompt communicatlon among principa! emergency LJ response organizations. [6] --*-----o* 9. Systems a r e established for prompt communlcation to emergency response personnel. [6] *--*TI-10. Coordina t eci d i ssemlnation of public information during emergencles is established. [7] *, ____ .. n=-11.Adequate fa~ilities are Taintained to support emergency response. [~_] __ ---~* 12. Adequate_.equipment is mainteined to support emergency response.~] i LJ 13. M ethods, systems, and eq u ipment for assessment ot' re , dioact!ve releases are in *o-use. [9] *. 14. A range of p r otective actions is available for plant emergency workers during LJ emergencies, induding those for hostile action events.[10] .,~-* --15. The resources for controlling radlological exposures for emergencv workers are LJ established. [11] '"'--., .... ----..._,___.., rr .. -1.6. A r rangements are made for medical servlces for contamina t ed, injured individuais. -~ [12] --"'""'---J* -* -* *-**--... --= 17. Plans for recovery and reentry are deve!oped. [13] -*--~ rr-18. A drill and exercise program (including radiological, medical, health physics and 1 other program areas) ls established. [14] .. --* *-c r-19. Dri!!s, e>c e r cises, and training evolutions that provicie performance opportur.ities to develop, m aintain, and dernons t rate key skills are assessed via a formai critique p r ocess in order t o identify weaknesses. [14] -*-,_. -~---*---r .. --i-20. !den t ified 1Neaknesses are co rre cted. [14] -...... *J ,.l ... ___ *~ 21. Training is provlded to emergency responders. [15] *--o--i 22. Responsibility for emergency plan deve l opment and review is established. [16] -TJ--l 23. P l anners responsible for emergency p!an deveioprnen t and maintenance are properly trained. [16] 1 EPFC-2001-5054Q Revision O Page 26 of 36 ATIACHMENI 2 -10CfRSQ.54(g)(3) SCREENING APPLICABIUTV CONCLUSION C8J lf no Part V criteria are checked, a 50.54(q)(3) Evaluation is NOT requlred; document the basls for conclusion below and complete Part VI and complete document revlsion process uslng Attachment 9 . . D lf any Part V criteria are checked, oomplete Part Vl and parform a 50.54{q)(3) Evaluation. 1 BASIS FOR CONCLUSION 1 The site descrlption in the PDEP is being revised as part of the updated site release calculations that are being l completed in accordance with NRC approved exemptions. Calculations FC08513 and FC06616 were performed 1 as part of the Partlal Site Release Project 2444, and were based on current facility conditions and support the changes to the site boundary. FC08557 was reevaluated and lncluded as part of the FC06816 calculatlons. Updating the PDEP to align with these changes in no way reduces the effectiveness of the PDEP. This 1 1 concludes lhe screening for changes to the slte area boundary. J i Part VI. Signatures:

* p ~a!..~ s~~n~at:t .. *t;..-* .. ---*---l Date: 6/13/18 t Na t hf.n P. DeVries f:..J "' -i Preparer Name (Print)}}

LIC-18-0023, EC 69954, Rev 0, Partial Site Release - Phase 1

Contents

Text

SUMMARY

SUMMARY

Description:

Conclusion:

References:

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