3F0815-01, License Amendment Request No. 318, Revision 0, Permanently Defueled Emergency Plan, Revision 2, and Permanently Defueled Emergency Action Level Bases Manual, Revision 1, for the Independent Spent Fuel Storage Installation

License Amendment Request No. 318, Revision 0, Permanently Defueled Emergency Plan, Revision 2, and Permanently Defueled Emergency Action Level Bases Manual, Revision 1, for the Independent Spent Fuel Storage Installation

ML15246A231
Person / Time
Site:	Crystal River
Issue date:	08/27/2015
From:	Reising R Duke Energy Florida
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
3F0815-01, TAC MF2981, TAC MF3415
Download: ML15246A231 (152)

Text

/_~ DUKE ENERGY~

August 27, 2015 3F0815-01 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Crystal River Nuclear Plant 15760 W. Power Line Street Crystal River, FL 34428 Docket 50-302 Operating License No. DPR-72 10 CFR 50.54(q) 10 CFR 50.47(b) 10 CFR 50, Appendix E 10 CFR 50.90 10 CFR 72.212(b)(10) 10 CFR 72.32(c)(2) 10 CFR 100

Subject:

Crystal River Unit 3 -

License Amendment Request #318, Revision 0, Permanently Defueled Emergency Plan, Revision 2, and Permanently Defueled Emergency Action Level Bases Manual, Revision 1, for the Independent Spent Fuel Storage Installation

References:

1. NRC to CR-3 letter dated March 31, 2015, "Crystal River Unit 3-Issuance of Amendment Regarding Changes to the Emergency Plan and Emergency Action Levels (TAC No. MF3415)" (ADAMS Accession No. ML15027A209)

Dear Sir:

2. NRC to CR-3 letter dated March 30, 2015, "Crystal River Unit 3 - Exemptions From Certain Emergency Planning Requirements and Related Safety Evaluation (TAC No. MF2981 )" (ADAMS Accession No. ML15058A906)

Pursuant to 10 CFR 50.54(q), 10 CFR 50.47(b), 10 CFR 50, Appendix E, and 10 CFR 50.90, Duke Energy Florida, Inc. (DEF) hereby requests approval of License Amendment Request (LAR) #318, Revision 0, where the Permanently Defueled Emergency Plan (PDEP) has been revised to reflect the planned use of an Independent Spent Fuel Storage Installation (ISFSI) located in the Crystal River Unit 3 Nuclear Plant (CR-3) Protected Area while the spent fuel pool contains spent fuel assemblies. CR-3 will begin to transfer spent fuel from the spent fuel pool once the ISFSI is ready to receive dry shielded canisters (DSCs).

As a result of the installation of an ISFSI within the Protected Area of the CR-3 site, DEF determined that changes to the PDEP and Permanently Defueled Emergency Action Level (PO EAL) Bases Manual were warranted.

Pursuant to 10 CFR 50.47, 10 CFR 72.32(c)(2) and 10 CFR 72.212(b)(10), DEF additionally requests approval of a revision to the Permanently Defueled Emergency Action Level (EAL)

Bases Manual based upon the installation of the ISFSI. 10 CFR 72.32(c)(2) states for an ISFSI located within the exclusion area boundary, as defined in 10 CFR Part 100, of a nuclear power reactor licensed for operation by the Commission, the emergency plan required by 1 0 CFR

U.S. Nuclear Regulatory Commission 3F0815-01 Page 2 of 4 50.47 shall be deemed to satisfy the requirements of this section. 10 CFR 72.212(b)(10) states all general licensees shall review the emergency plan to determine if their effectiveness is decreased, and if so, prepare the changes and seek and obtain the necessary approvals.

The PO EAL Bases Manual is now being revised to provide appropriate response measures for damage to a loaded spent fuel dry shielded canister CONFINEMENT BOUNDARY while in transit to the ISFSI facility, and once it is stored in the ISFSI facility. The declaration of an Unusual Event (UE) for a damaged spent fuel cask is based upon a Transfer Cask (TC) or Horizontal Storage Module (HSM) dose reading, depending upon whether the spent fuel Dry Shielded Canister (OSC) is in transit to the ISFSI facility, or stored within the Horizontal Storage Module (HSM) at the ISFSI facility. A separate EAL during transit to the ISFSI facility is consistent with the Hope Creek and Salem Nuclear Generating Stations EAL submittal dated July 19, 2011 (ADAMS Accession No. ML11215A179), and Dominion Energy Kewaunee Power Station PDEP and EAL Scheme submittal dated January 16, 2014 (ADAMS Accession No. ML14029A053).

This license amendment also requests the elimination of the augmented staff position, Emergency Response Organization (ERO) Communicator. This position was originally added to the Permanently Defueled ERO staff to assist the Emergency Coordinator (EC) and Emergency Support Center (ESC) staff in the development and delivery of Emergency Notification messages to the State and the NRC.

The position of Communicator was a position that was expected to alleviate the perceived burden to the EC and ESC to make timely notifications. However, during the course of the last several ERO integrated drills, it was determined this position is not needed. All notifications during the ERO integrated drills were delivered on time and accurately by the on-shift crew.

Additionally, since this is an augmented position, the majority of required communications would have already been completed prior to the individual serving this position's arrival. Removing the requirement to augment the ERO response with a Communicator will reduce an unnecessary ERO staffing position. The EC is responsible for Federal, State and local notifications but can delegate this activity to the Emergency Mitigation Coordinator, the Radiation Controls Coordinator, or Certified Fuel Handlers at any time in accordance with the CR-3 PDEP, Section 9.2. The use of the EC to develop and deliver Emergency Notification communications to Federal, State and local agencies is consistent with what was approved on October 31, 2014 (ADAMS Accession No. ML14279A482) for the Kewaunee Power Station (KPS) Permanently Defueled Emergency Plan where KPS utilizes the Shift Manager, Emergency Director, Technical Director or Radiation Protection Director to perform this function.

In References 1 and 2, the NRC approved the CR-3 PDEP, with exemptions, and the associated permanently defueled emergency action levels via License Amendment No. 246.

The PDEP established a new emergency preparedness baseline for the CR-3 permanently defueled condition that complies with approved exemptions to the applicable provisions of 1 0 CFR 50.47(b) and 10 CFR 50, Appendix E.

The proposed PDEP change has been reviewed considering the requirements of 10 CFR 50.54(q), the planning standards of 10 CFR 50.47(b) with approved exemptions, the requirements of 1 0 CFR 50, Appendix E, with approved exemptions, and the CR-3 PDEP.

These PDEP changes have been determined to represent changes in both the EAL scheme and the staffing level previously approved to implement the Emergency Plan in accordance with

U. S. Nuclear Regulatory Commission 3F0815-01 Page 3 of 4 the requirements of 10 CFR 50.54(q) and therefore, require NRC approval prior to implementation.

These changes are commensurate with the reduced radiological source term at the permanently defueled CR-3 since the Environmental Protection Agency (EPA) Protective Action Guides (PAGs) will not be exceeded at the exclusion area boundary for the remaining credible design basis accident (fuel handling). For the case of the unlikely beyond design basis accidents (loss of all modes of heat transfer to the spent fuel pool (SFP), or complete loss of SFP water inventory), there is considerable time (at least 19.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />), with multiple sources of inventory makeup water, to initiate appropriate mitigating actions to restore a means of heat removal to the SFP prior to any release. The NRC concurred with these conclusions in Reference 2.

The revised PDEP provides reasonable assurance that the public health and safety is protected and continues to satisfy the planning standards set forth in 10 CFR 50.47(b) (as exempted), 10 CFR 50, Appendix E (as exempted), and 10 CFR 72.32.

10 CFR 72.32(c)(2) states for an ISFSI located within the exclusion area boundary, as defined in 10 CFR Part 100, of a nuclear power reactor licensed for operation by the Commission, that the emergency plan required by 10 CFR 50.47 shall be deemed to satisfy the requirements of this section.

10 CFR 72.212(b)(10) states all general licensees shall review the emergency plan to determine if their effectiveness is decreased, and if so, prepare the changes and seek and obtain the necessary approvals.

As a result of the installation of an ISFSI within the Protected Area of the CR-3 site, DEF determined that changes to the PDEP and PO EAL were warranted.

LAR #318, Revision 0, contains PDEP, Revision 2 (Enclosure 2), and the Permanently Defueled Action Emergency Action Level (PO EAL) Bases Manual, Revision 1, revised scheme (Enclosure 3), and a comparison matrix of the Nuclear Energy Institute 99-01, "Development of Emergency Action Levels for Non-Passive Reactors, Revision 6," to the Proposed CR-3 Emergency Classification System and New Emergency Action Levels (Enclosure 4), reflecting the addition of the ISFSI, that has been reviewed and concurred upon with the State and local emergency management officials.

There are no new regulatory commitments made within this submittal.

The CR-3 Plant Nuclear Safety Committee has reviewed this LAR and recommended it for approval.

DEF requests approval of this PDEP LAR by August 31, 2016, with a 60-day implementation period, in order to facilitate ISFSI construction and fuel transfer to the facility.

U. S. Nuclear Regulatory Commission 3F0815-01 Page 4 of 4 If you have any questions regarding this submittal, please contact Mr. Phil Rose, Lead Engineer, Nuclear Regulatory Affairs, at (352) 563-4883.

I declare under penalty of perjury that the foregoing is true and correct. Executed on August 27, 2015.

Sincerely, t=£.~~Pre~ent Operations Support RRR!faw

Enclosures:

1. Description of Proposed License Amendment

Request, Proposed Changes, and Regulatory Analysis

2. Permanently Defueled Emergency Plan, Revision 2

3. Permanently Defueled Emergency Action Level Bases Manual, Revision 1

4. Comparison Matrix of Nuclear Energy Institute 99-01, "Development of Emergency Action Levels for Non-Passive Reactors, Revision 6," to the Proposed CR-3 Emergency Classification System and New Emergency Action Levels xc:

NRR Project Manager Regional Administrator, Region I

DUKE ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 LICENSE AMENDMENT REQUEST #318, REVISION 0, PERMANENTLY DEFUELED EMERGENCY PLAN, REVISION 2, AND PERMANENTLY DEFUELED EMERGENCY ACTION LEVEL BASES MANUAL, REVISION 1, FOR THE INDEPENDENT SPENT FUEL STORAGE INSTALLATION ENCLOSURE 1 DESCRIPTION OF PROPOSED LICENSE AMENDMENT REQUEST, PROPOSED CHANGES, AND REGULATORY ANALYSIS

U.S. Nuclear Regulatory Commission 3F0815-01 Page 1 of 16 LICENSE AMENDMENT REQUEST #318, REVISION 0- PERMANENTLY DEFUELED EMERGENCY PLAN, REVISION 2, AND PERMANENTLY DEFUELED EMERGENCY ACTION LEVEL BASES MANUAL, REVISION 1, FOR THE INDEPENDENT SPENT FUEL STORAGE INSTALLATION

1.0 INTRODUCTION

The U.S, Nuclear Regulatory Commission (NRC) issued License Amendment No. 246 to Facility Operating License No. DPR-72 for the Crystal River Unit 3 Nuclear Generating Plant (CR-3) by letter dated March 31, 2015 (Reference 1). Since the issuance of License Amendment No. 246, where the CR-3 Permanently Defueled Emergency Plan (PDEP) with exemptions and PD Emergency Action Levels (EALs) were approved, additional changes to the CR-3 PDEP and PD EAL Bases Manual are warranted to reflect the use of an Independent Spent Fuel Storage Installation (ISFSI) facility to store spent fuel. CR-3 spent nuclear fuel is to be stored near term in both the spent fuel pool and the ISFSI storage facility, and in the near future, the ISFSI only.

CR-3 is a permanently defueled station that has permanently ceased operations and is storing generated spent fuel onsite in the spent fuel pools. This license amendment request adds the ISFSI Initiating Condition/Emergency Action Level (IC/EAL) to the current Permanently Defueled ICs/EALs. The emergency classification levels applicable to an ISFSI are consistent with the requirements of 10 CFR 50 and the guidance in NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants. The initiating conditions germane to a 10 CFR 72.32 emergency plan, as described in NUREG-1567, Standard Review Plan for Spent Fuel Dry Storage Facilities, are subsumed within the classification scheme for a 10 CFR 50.47 emergency plan.

Adding the ISFSI IC/EAL, IC E-HU1 covers the spectrum of credible natural and man-made events included within the scope of an ISFSI design. In addition, appropriate aspects of IC HU1 and IC HA1 are being included in the EAL scheme to address a HOSTILE ACTION directed against an ISFSI.

The analysis of potential onsite and offsite consequences of accidental releases associated with the operation of an ISFSI is contained in NUREG-1140, A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees. NUREG-1140 concluded that the postulated worst-case accident involving an ISFSI has insignificant consequences to public health and safety. This evaluation shows that the maximum offsite dose to a member of the public due to an accidental release of radioactive materials would not exceed 1 rem Effective Dose Equivalent.

This license amendment also requests the elimination of the augmented staff position, Emergency Response Organization (ERO) Communicator. This position was originally added to the Permanently Defueled ERO staff to assist the Emergency Coordinator (EC) and Emergency Support Center (ESC) staff in the development and delivery of Emergency Notification messages to the State and the NRC. The position of Communicator was added to address a perceived burden to the EC and ESC to make timely notifications. However, during the course of the last several ERO integrated drills, the expected burden to the EC was never realized. All notifications during the ERO integrated drills were delivered on time and accurately by the on-shift crew. Additionally, as this is an augmented position, the majority of

U.S. Nuclear Regulatory Commission 3F0815-01 Page 2 of 16 required communications would be completed prior to the individual serving this positions arrival. Removing the requirement to augment the ERO response with a Communicator will reduce an unnecessary ERO staffing position. The EC is responsible for Federal, State and local notifications but can delegate this activity to the Emergency Mitigation Coordinator, the Radiation Controls Coordinator, or Certified Fuel Handlers at any time in accordance with the CR-3 PDEP, Section 9.2. The use of the EC to develop and deliver Emergency Notification communications to Federal, State and local agencies is consistent with what was approved on October 31, 2014 (ADAMS Accession No. ML14279A482) for the Kewaunee Power Station (KPS) Permanently Defueled Emergency Plan where KPS utilizes the Shift Manager, Emergency Director, Technical Director or Radiation Protection Director to perform this function.

2.0 DESCRIPTION

- PDEP REVISION The PDEP was developed to respond to emergency events that threatened or challenged the integrity of the spent nuclear fuel. The PDEP is written in accordance with the emergency planning standards set forth in 10 CFR 50.47(b), and the emergency planning requirements delineated in 10 CFR 50, Appendix E. Certain CR-3 exemptions, predominantly for offsite emergency response and planning to these regulations were requested and subsequently granted by the NRC on March 30, 2015 (Reference 6) based upon the permanently shut down and defueled condition of the plant. The CR-3 fuel was last irradiated on September 25, 2009.

The PDEP was fully implemented on April 7, 2015 in accordance with License Amendment No.

246 (Reference 1).

CR-3 includes a single, non-operational nuclear unit undergoing decommissioning. The current spent fuel storage configuration is in wet SAFSTOR. Because of the passive nature of the material being stored, the reduction in radiological source term, the lack of a significant dispersal mechanism, and the robust nature of the construction of the ISFSI storage system, the need for an offsite response (evacuation or sheltering) is not needed.

The radioactive source term for an accidental release at the defueled reactor site is reduced by radioactive decay and spent fuel removal from the pool to the ISFSI. Potential offsite doses were calculated to verify that the necessary controls are in place during D&D operations to ensure exposures due to an unanticipated event are less than the Environmental Protection Agency (EPA) 400, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, (Reference 2) protective action guide (PAG) limit of 1 rem at the exclusion area boundary.

The robust nature and high integrity of the spent fuel storage system selected for use at the ISFSI is designed to prevent the release of radioactivity in the event of an accident, including environmental phenomena (e.g., earthquake and flooding). As a result of the high integrity dry shielded canisters design and the substantial protection afforded the canisters by the horizontal storage modules (HSM), leakage of fission products from a canister is not considered to be a credible event.

The proposed revisions constitute a change in the emergency planning function commensurate with the ongoing and anticipated reduction in radiological source term at CR-3. These changes add the responsibilities for emergency planning functions of the ISFSI to the Shift Supervisor/Certified Fuel Handler (SS/CFH).

U.S. Nuclear Regulatory Commission 3F0815-01 Page 3 of 16 An Emergency Action Level (EAL) change has been incorporated into the PD EAL Bases Manual to provide appropriate emergency response measures for damage to the spent fuel once it is safely stored in the ISFSI facility. The EAL change also addresses emergency response actions while the dry shielded canisters containing spent fuel are in transit to the ISFSI facility. This change is discussed in the following sections.

3.0 PROPOSED CHANGE

S - PDEP REVISION License Amendment Request (LAR) #318, Revision 0, provides the following changes:

Organization Shift Supervisor/Certified Fuel Handler (SS/CFH)

The SS/CFH is the senior management position on-site that is outside of normal working hours, and is responsible for managing the activities of the plant, including the ISFSI facility. If the EAL threshold or initiating condition is met, the SS/CFH then assumes the position of EC and activates the emergency plan. Upon activation of the emergency plan the SS/CFH or EC becomes responsible for implementation of the following emergency plan actions:

Classification Notification to the site staff Notification to federal, state authorities Implementation of any required assessment of onsite protective measures Notification to advisory personnel Augmentation of the onsite emergency response organization (if required) with company resources to address long-term recovery actions EP Function Impacted:

In accordance with 10 CFR 50.47(b)(2), licensee responsibilities for the emergency response are unambiguously defined. This LAR added the ISFSI facility responsibility to the EC responsibilities for emergency response.

Reason for the Change:

The SS/CFH position is responsible for implementing the emergency plan, which will now include responsibility for any emergencies related to transferring spent fuel and storing spent fuel in the ISFSI facility.

On-Call Emergency Response Organization The on-shift staff can respond to most situations arising from implementation of the emergency plan without assistance from others. However, for an ALERT emergency classification, involving radiological consequences, the augmented ERO may be activated at the discretion of the EC, and/or advisory personnel can be contacted by phone, as available, to provide counsel and guidance.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 4 of 16 EP Function Impacted:

In accordance with 10 CFR 50.47(b)(2), the process for timely augmentation of the on-shift staff is established. The PDEP describes the augmented Communicator position, which is being eliminated.

Reason for the Change:

The augmented staff position of the Communicator was originally included in the PDEP to receive the delegated responsibility for communication to the State and the NRC and to ease the burden on the EC. The EC will retain the responsibility for the risk significant planning function to notify federal and state authorities, but can delegate this action as necessary.

Performance drill observations have shown that there were no time challenges for the EC to notify the State and the NRC. No conflicting EP functions were created to prevent the EC from completing EP notification requirements. There are no emergency tasks that could cause emergency personnel to not complete the required notification on time. The augmented Communicator additional resource is not needed.

Upon activation of the emergency plan, the EC becomes responsible for implementation of the following emergency plan actions:

Classification Notification to the site staff Notification to federal, state authorities Implementation of any required assessment of onsite protective measures The EC is responsible for Federal, State and local notifications but can delegate this activity to the Emergency Mitigation Coordinator, the Radiation Controls Coordinator, or Certified Fuel Handlers at any time in accordance with the CR-3 PDEP, Section 9.2. The use of the EC to develop and deliver Emergency Notification communications to Federal, State and local agencies is consistent with what was approved on October 31, 2014 (ADAMS Accession No. ML14279A482) for the Kewaunee Power Station (KPS) Permanently Defueled Emergency Plan where KPS utilizes the Shift Manager, Emergency Director, Technical Director or Radiation Protection Director to perform this function.

Addition of Spent Fuel Pool Initiating Event and Emergency Action Level The IC and EALs associated with the spent fuel pool emergency classification system are based on NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, (Reference 3). Specifically, Appendix C of NEI 99-01, Revision 6, contains a set of ICs/EALs for permanently defueled nuclear power plants that had previously operated under a 10 CFR Part 50 license and have permanently ceased operations.

Since spent fuel assemblies will be loaded into dry shielded canisters (DSCs) and placed in the ISFSI facility, the NEI 99-01, Revision 6, Table E-1: Recognition Category E Initiating Condition Matrix, IC/EAL is required to be added to the PD EAL Bases Manual.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 5 of 16 Specifically, the following Initiating Condition will be added to the emergency plan:

UNUSUAL EVENT (E-HU1)

Initiating Condition: Damage to a loaded dry shielded canister CONFINEMENT BOUNDARY Mode Applicability: All EP Function Impacted:

In accordance with 10 CFR 50.47 (b)(4), a standard scheme of emergency classification and action levels is in use. This scheme is affected by the addition of the EAL for spent fuel DSCs in transit or stored in the HSMs at the ISFSI facility.

Reason for the Change:

A permanently defueled station is essentially a spent fuel storage facility where the fuel is stored in a pool of water that serves as both a cooling medium (i.e., removal of decay heat) and shielding from direct radiation. NEI 99-01, Revision 6 includes EALs for potential radiological accidents associated with transferring spent fuel to the ISFSI, and during long-term storage.

Recognition Category PD provides a stand-alone set of ICs/EALs for a permanently defueled nuclear power plant where an ISFSI facility will ultimately house all the spent fuel from commercial operations. The Category E recognition EAL is required to be added to address transfer and ultimate storage of the DSCs in the HSMs at the ISFSI facility.

The proposed site emergency plan revision is commensurate with the ongoing and anticipated reduction in radiological source term at the CR-3 site, and reflects that all spent fuel assemblies will ultimately be transferred to the ISFSI facility. A subsequent licensing amendment request will be forthcoming to reflect the case when all spent fuel contained in the dry shielded canisters will be stored in the HSMs at the ISFSI facility.

4.0 TECHNICAL EVALUATION

- PDEP REVISION The proposed change has been reviewed considering the requirements of 10 CFR 50.54(q), the planning standards of 10 CFR 50.47(b), with approved exemptions, 10 CFR 50 Appendix E, with approved exemptions, and the PDEP. The changes associated with the elimination of the Communicator position and functional capabilities of the ERO staff have been determined to reduce the effectiveness of the PDEP, in accordance with the requirements of 10 CFR 50.54(q),

and require prior NRC approval. The reduction in effectiveness was determined due to a decrease in radiological response staff required, and a decrease in the functional capabilities of the emergency response organization. The change also reflects the addition of the ISFSI facility where all spent fuel will ultimately be in long-term storage.

The radiological conditions and equipment and personnel availability at the CR-3 site required for implementing this proposed revision to the CR-3 PDEP is summarized as follows:

Spent fuel assemblies will be removed from the CR-3 spent fuel pool and relocated to the ISFSI facility.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 6 of 16 Modular HEPA ventilation systems remain available in structures for localized ventilation control and worker protection, but there is insufficient radiological source term to generate airborne effluents exceeding the CR-3 offsite dose calculation manual (ODCM) specification limits.

Liquids are evaluated for low levels of radioactivity, and based on the concentration and the source of water (groundwater/storm water), may be collected and treated onsite or processed as groundwater/storm water and discharged to the CR-3 discharge canal in accordance with the CR-3 National Pollutant Discharge Elimination System (NPDES) permit FL0000159.

The remaining radiological source terms at the CR-3 site are not likely to create an unplanned/unanticipated increase in radiation or airborne radioactivity levels within the Protected Area or outside of the Protected Area that could not be mitigated or controlled by the presence of an on-call radiological emergency support organization. Necessary radiological support personnel are onsite during activities involving fuel handling, or activities with a potential to create a radioactive release.

Event scenarios involving D&D activities are controlled by procedures at a level that would preclude the declaration of an Unusual Event (UE).

5.0 PROPOSED CHANGE

- PERMANENTLY DEFUELED EMERGENCY ACTION LEVEL BASES MANUAL REVISION The Permanently Defueled Emergency Action Level (PD EAL) Bases Manual, Revision 1, reflects the addition of an ISFSI facility located in the CR-3 Protected Area.

The PD EAL changes have been incorporated into the PD EAL Bases Manual to provide appropriate response measures for damage to spent fuel dry shielded canisters once it is safely stored in the HSMs at the ISFSI facility. The PD EAL changes also reflect the emergency response actions for damage to spent fuel dry shielded canisters in the transfer casks during transit to the ISFSI facility. The PDEP revision and the PD EAL revised scheme have been reviewed and agreed upon with state and local emergency management officials.

6.0 TECHNICAL EVALUATION

- PD EAL BASES MANUAL REVISION Emergency Action Level Changes for the ISFSI Facility Addition The Initiating Condition for EAL PD-AU1 and PD-AA1 applies to gaseous or liquid releases from irradiated fuel or radioactively contaminated structure, system or component (SSC) for storage up to the point that the loaded dry shielded canister is sealed. Once the canister is sealed, damage to a loaded canister potentially causes a loss of CONFINEMENT BOUNDARY and is classified according to IC E-HU1. NEI 99-01, Revision 6, notes that the results of the ISFSI Updated Safety Analysis Report (SAR) that was developed in accordance with NUREG-1536, Standard Review Plan for Dry Cask Storage Systems, (Reference 4), or the SAR referenced in the cask Certificate of Compliance (COC) with the NRC-associated Safety Evaluation, can be used to identify the natural phenomena and accident conditions that could potentially affect the CONFINEMENT BOUNDARY. The E-HU1 EAL addresses damage to the TC or HSM from a range of identified natural or man-made events (e.g., a dropped or tipped cask, explosion, fire, earthquake). The allowable radiation level for the transfer cask (TC) or HSM can be found in the COC technical specification (Reference 7).

U.S. Nuclear Regulatory Commission 3F0815-01 Page 7 of 16 The UE classification is warranted on the basis of the occurrence of an event of sufficient magnitude such that a loaded TC or HSM is damaged, resulting in potential damage to a DSC CONFINEMENT BOUNDARY. This classification includes events involving the loss of a loaded fuel storage DSC CONFINEMENT BOUNDARY. Natural phenomena events and accident conditions in which a loaded horizontal cask is damaged are classified at the UE Level.

Canister seal integrity issues discovered during leakage testing during normal canister processing would be addressed in accordance with the ISFSI COC technical specifications or SAR required actions; therefore, classification is not solely made based on the loss of seal integrity. However, loss or potential loss of seal integrity coincident with an accident condition or natural phenomena event that clearly affects the canister would justify a UE classification.

Additionally, Duke Energy Florida (DEF) has added ISFSI to basis language for PD-HA1, HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes, based upon NEI 99-01, Revision 6.

Defueled Emergency Action Level - Differences and Deviations The Permanently Defueled Emergency Action Level Bases Manual, Revision 1, (Enclosure 3) is the site-specific technical basis document for each recognition category included in the proposed defueled EAL scheme. NEI 99-01, Revision 6, provides EAL guidance that is identified in the matrix contained in Enclosure 4, Comparison Matrix of Nuclear Energy Institute 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 6, and Generic Guidance to the Proposed CR-3 Emergency Classification System and New Emergency Action Levels. Differences and deviations for the new EALs are identified in in accordance with the guidance contained in NRC Regulatory Issue Summary (RIS) 2003-018, Use of NEI 99-01, Methodology for Development of Emergency Action Levels, Revision 4, dated January 2003, and Supplements (Reference 5).

As discussed in RIS 2003-018, Supplement 1, dated July 13, 2004, differences and deviations are defined as follows: A difference is an EAL change where the basis scheme guidance (NUREG, NUMARC, NEI) differs in wording but agrees in meaning and intent, such that classification of an event would be the same, whether using the basis scheme guidance or the site-specific proposed EAL. Examples of differences include the use of site-specific terminology or administrative reformatting of site-specific EALs.

A deviation is an EAL change where the basis scheme guidance differs in wording and is altered in meaning or intent, such that classification of the event could be different between the basis scheme guidance and the site-specific proposed EAL. Examples of deviations include the use of altered mode applicability, altering key words or time limits, or changing words of physical reference (protected area, safety-related equipment, etc.).

7.0 REGULATORY ANALYSIS

The PDEP changes include the addition of the SS/CFH responsibilities for emergency planning functions as a result of the ISFSI facility installation. The initiating condition, E-HU1, addresses an event that results in damage to the CONFINEMENT BOUNDARY of a loaded dry storage canister containing spent fuel. This EAL applies to irradiated fuel that is licensed for dry storage, beginning at the point that the loaded storage canister is sealed. The issues of concern are the creation of a potential or actual release path to the environment, degradation of

U.S. Nuclear Regulatory Commission 3F0815-01 Page 8 of 16 one or more storage canisters or spent fuel assemblies due to environmental factors, and configuration changes that could cause challenges in removing the canister or fuel from storage.

The existence of damage, either while in transit or during storage is determined by radiological survey where, as an example: the on-contact radiation reading is greater than two-times the site-specific ISFSI COC technical specification or SAR allowable radiation level, as discussed in NEI 99-01, Revision 6. The COC technical specification multiple of two-times, used also in Recognition Category IC AU1, distinguishes the difference between a non-emergency and emergency condition. The emphasis for this classification is the degradation in the dry canister safety level, and not the magnitude of the associated dose or dose rate. Recognizing that in the case of extreme damage to the loaded canister, the on-contact dose rate limit will be exceeded, and may be determined based upon the measured dose rate some distance from the canister.

No Significant Hazards Determination In accordance with 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit, DEF requests NRC approval of a reduction in effectiveness of the site PDEP by eliminating the Communicator emergency response staffing position, and the addition of a new PD EAL for the installation of the CR-3 ISFSI facility. The proposed site PDEP and PD EAL Bases Manual revisions are commensurate with the ongoing and anticipated reduction in radiological source term at the CR-3 site, and reflects the addition of spent fuel being transferred to the ISFSI facility. DEF has evaluated whether a significant hazards consideration is involved with the proposed amendment by focusing on the three conditions set forth in 10 CFR 50.92, Issuance of amendment, discussed below:

Criterion 1: Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed site PDEP and PD EAL Bases Manual revisions are commensurate with the ongoing and anticipated reduction in radiological source term at the CR-3 site and reflects the addition of spent fuel being transferred to the ISFSI facility. These changes add the responsibility for responding to ISFSI emergencies to the CR-3 PDEP Shift Supervisor/Certified Fuel Handler, and accompanying changes to the PD EAL Bases Manual due to the creation of a potential or actual release path to the environment, degradation of one or more storage canisters or fuel assemblies due to environmental factors, and configuration changes that could cause challenges in removing the canister or fuel from storage.

There are no longer design basis accidents or postulated beyond design basis accidents that could result in doses to the public and the environment beyond the exclusion area boundary that would exceed the EPA PAGs. CR-3 was shut down on September 26, 2009, and will not be restarted. With the reactor permanently defueled, the spent fuel pool and its support systems are dedicated to spent fuel storage only. With the spent fuel in wet storage for some time, the spectrum of postulated accidents is much smaller than for an operational plant, with the majority of design basis accidents no longer possible. The only remaining credible design basis accident is the fuel handling accident, which does not result in exceeding the EPA Protective Action Guidelines at the exclusion area boundary. Spent fuel located in the spent fuel pools will be transferred to the ISFSI facility. Emergency Planning Zones beyond the exclusion area

U.S. Nuclear Regulatory Commission 3F0815-01 Page 9 of 16 boundary and the associated protective actions are no longer required. No corporate personnel, personnel involved in offsite dose projections, or personnel with special qualifications are required to augment the ERO.

The credible events for the ISFSI facility remain unchanged. The indications of damage to a loaded Dry Shielded Canister CONFINEMENT BOUNDARY have been revised to be twice the design basis dose rate as described in Draft Amendment 14 to COC 1004 Technical Specifications for the Standardized NUHOMS Horizontal Modular Storage System, Sections 5.2.4 Radiation Protection Program and 5.4.2 HSM or HSM-H Dose Rate Evaluation Program (Reference 7), while in transit or HSM storage.

Damage to Dry Shielded Canister CONFINEMENT BOUNDARY as indicated by the following on-contact radiation readings at some prescribed distance from the transfer cask or HSM:

1300 mrem/hr (gamma + neutron) on the radial surface of the fuel transfer cask while in transit to the ISFSI horizontal storage module (HSM)

OR 1050 mrem/hr (gamma + neutron) - HSM Front Bird Screen 4 mrem/hr (gamma + neutron) - HSM Outside Door 40 mrem/hr (gamma + neutron) - HSM End Shield Wall Exterior while in HSM storage.

This change is consistent with industry practices previously approved by the NRC to distinguish whether a degraded containment barrier condition exists.

The probability of occurrence of previously evaluated accidents is not increased, since most previously analyzed accidents can no longer occur and the probability of the remaining credible design basis accident is unaffected by the proposed amendment.

The deletion of the Communicator position does not impact Emergency Notifications from the plant since the Emergency Coordinator has shown the capability to perform this function. This function is not involved in operations or evolutions that could cause an accident since it is not performed until after the emergency is declared, and has no effect on accident mitigation.

Therefore, the proposed changes do not affect any plant system, the operation and maintenance of CR-3 and the ISFSI facility, or increase the probability or consequences of an accident previously evaluated.

Criterion 2: Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed changes have no impact on facility structures, systems, or components (SSCs) affecting the safe storage of irradiated fuel, or on the methods of operation of such SSCs, or on the handling and storage of irradiated fuel itself. Additionally, the proposed changes have no impact on a Fuel Handling Accident, which is the remaining credible design basis accident evaluated. The CR-3 PDEP is applicable for the plants defueled condition. There is no impact on the prevention, diagnosis, or mitigation of reactor-related transients as there are no longer

U.S. Nuclear Regulatory Commission 3F0815-01 Page 10 of 16 any reactor-related accidents. Accidents cannot result in different or more adverse failure modes or accidents than previously evaluated because the reactor is permanently shut down and defueled, and CR-3 is no longer authorized to operate the reactor.

There are no longer credible events that would result in doses to the public beyond the exclusion area boundary that would exceed the EPA PAGs. Spent fuel waste will be transferred to the ISFSI facility. Emergency Planning Zones beyond the site boundary and the associated protective actions are no longer required. No corporate personnel, personnel involved in offsite dose projections, or personnel with special qualifications are required to augment the ERO.

The credible events for the ISFSI facility remain unchanged. The indications of damage to a loaded Dry Shielded Canister CONFINEMENT BOUNDARY have been revised to be twice the design basis dose rate as described in Draft Amendment 14 to COC 1004 Technical Specifications for the Standardized NUHOMS Horizontal Modular Storage System, Sections 5.2.4 Radiation Protection Program and 5.4.2 HSM or HSM-H Dose Rate Evaluation Program (Reference 7), while in transit or HSM storage.

Damage to Dry Shielded Canister CONFINEMENT BOUNDARY as indicated by the following on-contact radiation readings at some prescribed distance from the transfer cask or HSM:

1300 mrem/hr (gamma + neutron) on the radial surface of the fuel transfer cask while in transit to the ISFSI horizontal storage module (HSM)

OR 1050 mrem/hr (gamma + neutron) - HSM Front Bird Screen 4 mrem/hr (gamma + neutron) - HSM Outside Door 40 mrem/hr (gamma + neutron) - HSM End Shield Wall Exterior while in HSM storage.

This change is consistent with industry practices previously approved by the NRC to distinguish whether a degraded containment barrier condition exists. The proposed amendment does not introduce a new mode of plant operation or new accident precursors, does not involve any physical alterations to plant configurations, or make changes to plant system setpoints that initiate a new or different kind of accident.

The deletion of the Communicator position does not impact Emergency Notifications from the plant since the Emergency Coordinator has shown the capability to perform this function. This function is not involved in operations or evolutions that could cause or create new or different kinds of accidents since the communication of Emergency Notifications is not performed until after the emergency is declared and cannot affect an accident or event already in progress.

Therefore, the proposed changes have no direct effect on any plant system, the operation and maintenance of CR-3 or the ISFSI facility, or create the possibility of a new or different kind of accident.

Criterion 3: Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No

U.S. Nuclear Regulatory Commission 3F0815-01 Page 11 of 16 The proposed changes have no direct effect on any plant system, do not involve any physical plant limit or parameter, License Condition, Technical Specification Limiting Condition of Operability or operating philosophy, and therefore cannot affect any margin of safety. The margin of safety is maintained by conforming to the CR-3 Technical Specifications or the ISFSI Technical Specifications. The proposed CR-3 PDEP and PD EAL Bases Manual revisions are commensurate with the ongoing and anticipated reduction in radiological source term at the CR-3 site and reflect spent fuel being transferred to the ISFSI facility. These changes add the responsibility for implementing the emergency plan for the ISFSI facility to the Shift Supervisor/Certified Fuel Handler.

The only remaining credible accident for CR-3, while the SFP is operable and prior to the transference of all spent fuel to dry shielded canisters, is a fuel handling accident. The proposed amendment does not adversely affect the inputs or assumptions of any design basis analysis that impact the fuel handling accident. There are no longer credible events that would result in doses to the public beyond the exclusion area boundary that would exceed the EPA PAGs. Emergency Planning Zones beyond the exclusion area boundary and the associated protective actions are no longer required. No corporate personnel, personnel involved in offsite dose projections, or personnel with special qualifications are required to augment the ERO.

The credible events for the ISFSI facility remain unchanged. The indications of damage to a loaded dry shielded canister CONFINEMENT BOUNDARY have been revised to be twice the design basis dose rate as described in Draft Amendment 14 to COC 1004 Technical Specifications for the Standardized NUHOMS Horizontal Modular Storage System, Sections 5.2.4 Radiation Protection Program and 5.4.2 HSM or HSM-H Dose Rate Evaluation Program (Reference 7), while in transit or HSM storage.

Damage to Dry Shielded Canister CONFINEMENT BOUNDARY as indicated by the following on-contact radiation readings at some prescribed distance from the transfer cask or HSM:

1300 mrem/hr (gamma + neutron) on the radial surface of the fuel transfer cask while in transit to the ISFSI horizontal storage module (HSM)

OR 1050 mrem/hr (gamma + neutron) - HSM Front Bird Screen 4 mrem/hr (gamma + neutron) - HSM Outside Door 40 mrem/hr (gamma + neutron) - HSM End Shield Wall Exterior while in HSM storage.

This change is consistent with industry practices previously approved by the NRC to distinguish whether a degraded containment barrier condition exists. The proposed changes are limited to the CR-3 PDEP and PD EAL Bases Manual and do not impact the safe storage of irradiated fuel. The proposed revisions do not affect any requirements for SSCs credited in the remaining analyses of applicable postulated accidents, and as such, do not affect the margin of safety associated with these accident analyses.

The deletion of the Communicator position does not impact Emergency Notifications from the plant since the Emergency Coordinator has shown the capability to perform this function. This function is not involved in design basis analyses or operations that could cause any decrease in any previously analyzed safety margin.

Therefore, the proposed changes do not create the possibility of reduction in any safety margin.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 12 of 16 In conclusion, based on the considerations discussed above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner; (2) such activities will be conducted in compliance with the Commission's regulations; and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Therefore, the proposed changes do not involve a significant hazards consideration as set forth in 10 CFR 50.92(c).

Environmental Impact Evaluation 10 CFR 51.22(c)(9) provides criteria for and identification of licensing and regulatory actions that are eligible for categorical exclusion from performing an environmental assessment. A proposed amendment to an operating license for a facility requires no environmental assessment if the amendment changes a requirement with respect to use of a facility component within the restricted area provided that (i) the amendment involves no significant hazards consideration, (ii) there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite, and (iii) there is no significant increase in individual or cumulative occupational radiation exposure.

DEF has reviewed this LAR and has determined that it meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22, no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the proposed license amendment. The following is the basis for this determination:

(i)

The proposed license amendment does not involve a significant hazards consideration, as described in the significant hazards evaluation.

(ii)

As discussed in the Technical Justification for the Request and the No Significant Hazards Consideration, this change does not result in a significant change or significant increase in the release associated with any Design Basis Accident or any radiological event. There will be no significant change in the types or a significant increase in the amounts of any effluents released offsite during normal activities or evolutions. There will be no significant change in the types or increase in the amounts of any effluents that may be released offsite and does not involve irreversible environmental consequences beyond those already associated with the CR-3 Final Environmental Statement.

(iii)

The proposed LAR does not result in a significant increase to the individual or cumulative occupational radiation exposure. The changes made to the PDEP and PD EAL Bases Manual reflects the installation of the ISFSI facility where all the spent fuel assemblies will be ultimately stored. The potential radiological source term has been decreased and these changes do not interface with radiologically contaminated systems, and do not require operator or other actions that could increase occupational radiation exposure. Individual and cumulative occupational exposure will significantly decrease during the time the spent fuel dry shielded canisters are in the HSMs at the ISFSI facility as CR-3 remains in SAFSTOR. Administrative and procedural restrictions will be used to assure occupational dose remains As Low As Reasonably Achievable (ALARA) during dry shielded canister loading and transportation to ISFSI activities. Therefore, the

U.S. Nuclear Regulatory Commission 3F0815-01 Page 13 of 16 proposed LAR does not result in a significant increase to the individual or cumulative occupational radiation exposure.

This application and the accompanying CR-3 PDEP and PD EAL Bases Manual license amendments are exempt from environmental review because they fall within the categorical exclusion of 10 CFR 51.22, Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review, paragraph (c)(9).

Applicable Regulatory Requirements/Criteria - PDEP Revision 10 CFR 50.54(q), Conditions of Licenses, Emergency Plans, requires that a license amendment request be submitted to the NRC for approval prior to implementation of changes to the emergency plan, which are considered to constitute a "reduction in effectiveness."

10 CFR 50.47, Emergency plans, sets forth emergency plan requirements for nuclear power plant facilities. The regulations in 10 CFR 50.47(a)(1)(i) states in part: no initial operating license for a nuclear power reactor will be issued unless a finding is made by the NRC that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency. All sections with approved exemptions (Reference 6) apply to these proposed changes.

10 CFR 50.47(b) establishes standards that the onsite and offsite emergency response plans must meet for the NRC staff to make a positive finding that there is reasonable assurance that the licensee can and will take adequate measures in the event of a radiological emergency.

Planning Standard (4) of this section requires that a licensees emergency response plan contain the following:

A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility license, and State and local response plans call for reliance on information provided by facility licensees for determination of minimum initial offsite response measures.

10 CFR 50.54(q)(4) specifies the process for revising emergency plans where the changes reduce the effectiveness of the plan. The regulation states:

The changes to a licensees emergency plan that reduce the effectiveness of the plan as defined in paragraph (q)(1)(iv) of this section may not be implemented without prior approval by the NRC. A licensee desiring to make such a change after February 21, 2012 shall submit an application for an amendment to its license. In addition to the filling requirements of §§ 50.90 and 50.91, the request must include all emergency plan pages affected by that change and must be accompanied by a forwarding letter identifying the change, the reason for the change, and the basis for concluding that the licensees emergency plan, as revised, will continue to meet the requirements in appendix E to this part and, for nuclear power reactor licensees, the planning standards of § 50.47(b).

Section IV.B.1 of Appendix E to Part 50, Emergency Planning and Preparedness for Production and Utilization Facilities, states in part:

U.S. Nuclear Regulatory Commission 3F0815-01 Page 14 of 16 The means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of local and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring. By June 20, 2012, for nuclear power reactor licensees, these action levels must include hostile action that may adversely affect the nuclear power plant.

10 CFR 50, Appendix E, Section IV.C.1 requires each emergency plan to define the emergency classification levels that determine the extent of the participation of the emergency response organization. The emergency classification levels are: (1) Notification of unusual events; (2) alert; (3) site area emergency; and (4) general site emergency. EALs are used by plant personnel in determining the appropriate emergency classification level to declare. CR-3 License Amendment No. 246 approved certain exemptions to Appendix E where only two emergency classification levels exist at CR-3, Unusual Event and Alert.

10 CFR 72.32(c)(2), Emergency Plan, requires that any general licensed ISFSI that is located on the site or located within the exclusion area as defined in 10 CFR Part 100, of a nuclear power reactor licensed for operation by the Commission, the emergency plan required by 10 CFR 50.47 shall be deemed to satisfy the requirements of this section.

10 CFR 72.44(f), License conditions, requires that a submittal be made to the NRC for approval prior to implementation of changes to the emergency plan where the change constitutes a "reduction in effectiveness."

Because it is no longer possible for the radiological consequences of a postulated design basis accident or a beyond design basis accident to result in radioactive releases that exceed the EPA PAGs at the exclusion area boundary, the PD EAL developed was based upon NEI 99-01, Revision 6 guidance. The existing EAL PD-AU1 for IC gaseous or liquid releases from irradiated fuel for storage up to the point that the loaded storage canister is sealed, addresses damage to the cask from a range of identified natural or man-made events (e.g., a dropped or tipped cask, explosion, fire, earthquake). The proposed addition of EAL E-HU1 will address potential damage to the spent fuel dry shielded canister Containment Boundary during transport to the ISFSI pad, and during long-term storage in the horizontal storage module from natural phenomena or man-made events. The Unusual Event (UE) classification is warranted on the basis of the event occurrence being of sufficient magnitude such that a loaded horizontal concrete cask is severely damaged, resulting in potential damage to a dry shielded canister CONFINEMENT BOUNDARY.

The deletion of the Communicator position does not impact Emergency Notifications from the plant, even though it was determined to be a reduction in effectiveness from the current PDEP.

Since the Emergency Coordinator has shown the capability to make appropriate notifications to Federal, State and local agencies, there is no detrimental effect on emergency responses. This function is not involved in operations or evolutions that could cause or create new or different kinds of accidents since the communication of Emergency Notifications is not performed until after the emergency is declared and cannot affect an accident or event already in progress.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 15 of 16 The proposed changes to the emergency plan continue to implement the applicable requirements of the regulations as approved with NRC exemptions. Therefore, the revised emergency plan provides reasonable assurance that public health and safety is protected and continues to satisfy the planning standards set forth in 10 CFR 50.47(b) (as exempted), 10 CFR 50 Appendix E (as exempted), and 10 CFR 72.32.

Applicable Regulatory Requirements/Criteria - PD EAL Bases Manual Revision 10 CFR 50.47(b) establishes the standards that onsite and offsite emergency response plans must meet that allows the NRC Staff to make a positive finding that there is a reasonable assurance that the licensee can and will take adequate protective measures in the event of radiological emergency. Planning Standard (4) of this section requires that a licensees emergency response plan contain the following:

A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures.

10 CFR 50.54(q)(4) specifies the process for revising emergency plans where the changes reduce the effectiveness of the plan:

The changes to licensees emergency plan that reduce the effectiveness of the plan as defined in paragraph (q)(1)(iv) of this section may not be implemented without prior approval by the NRC. A licensee desiring to make such a change after February 21, 2012 shall submit an application for an amendment to its license. In addition to the filing requirements of §§ 50.90 and 50.91, the request must include all emergency plan pages affected by that change and must be accompanied by a forwarding letter identifying the change, the reason for the change, and the basis for concluding that the licensees emergency plan, as revised, will continue to meet the requirements in appendix E to this part and, for nuclear power reactor licensees, the planning standards of § 50.47(b).

Section IV.B.2 of Appendix E to Part 50 states: A licensee desiring to change its entire emergency action level scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change.

10 CFR 72.212 (b)(10) states: Review the reactor emergency planto determine if their effectiveness is decreased and, if so, prepare the necessary changes and seek and obtain the necessary approvals.

10 CFR 72.32(c)(2) states: For an ISFSI that is: located within the exclusion area as defined in 10 CFR part 100, of a nuclear power reactor licensed for operation by the Commission, the emergency plan by 10 CFR 50.47 shall be deemed to satisfy the requirements of this section.

The NRC endorsed the November 2012 NEI 99-01 Revision 6, on which this application is based. Because it is no longer possible for the radiological consequences of a postulated design basis accident or a beyond basis accident to result in radioactive releases that exceed the EPA PAGs at the exclusion area boundary, the PD EALs were based upon this guidance.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 16 of 16 The proposed amendment is being submitted to the NRC pursuant to 10 CFR 50.90, for the purpose of changing the CR-3 PD EAL Bases Manual for the installation of an ISFSI facility.

This is considered a significant change to the EAL scheme development methodology.

Pursuant to 10 CFR Part 50, Appendix E, Section IV.B.2, a revision to an entire EAL scheme must be approved by the NRC before implementation.

The proposed change does not alter any CR-3 Technical Specifications requirements, nor does it have any programmatic effect on the Quality Assurance Program description.

In conclusion, based on the considerations discussed above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by the change in the CR-3 EAL scheme; (2) the operation of CR-3 will continue to be conducted in compliance with the Commissions regulations; and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

8.0 REFERENCES

1. NRC to CR-3 letter, Issuance of Amendment Regarding Changes to the Emergency Plan and Emergency Action Levels, dated March 31, 2015. (ADAMS Accession No. ML15027A209)

2. Environmental Protection Agency (EPA) 400, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, Protective Action Guides and Planning Guidance for Radiological Incidents, Draft for Interim Use and Public Comment, dated March 2013.

3. Nuclear Energy Institute (NEI) 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, November 2012. (ADAMS Accession No. ML12326A805)

4. U.S. Nuclear Regulatory Commission, NUREG-1536, Revision 1, Standard Review Plan for Spent Fuel Dry Storage Systems at a General License Facility - Final Report, dated July 2010.

5. U.S. Nuclear Regulatory Commission, RIS 03-018, Use of NEI 99-01, Methodology for Development of Emergency Action Levels, Revision 4, dated January 2003, and Supplements 1 and 2 dated July 13, 2004 and December 12, 2005.

6. NRC to CR-3 letter, Crystal River Unit 3 - Exemptions From Certain Emergency Planning Requirements and Related Safety Evaluation (TAC No. MF2981) dated March 30, 2015. (ADAMS Accession No. ML15058A906)

7. Standardized NUHOMS System Technical Specifications, Draft Amendment 14 to Certificate of Compliance 1004, Sections 5.2 and 5.4.2 dated April 16, 2015.

DUKE ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302 / LICENSE NUMBER DPR-72 LICENSE AMENDMENT REQUEST #318, REVISION 0, PERMANENTLY DEFUELED EMERGENCY PLAN, REVISION 2, AND PERMANENTLY DEFUELED EMERGENCY ACTION LEVEL BASES MANUAL, REVISION 1 FOR THE INDEPENDENT SPENT FUEL STORAGE INSTALLATION ENCLOSURE 2 PERMANENTLY DEFUELED EMERGENCY PLAN, REVISION 2

U.S. Nuclear Regulatory Commission 3F0815-01 Page 1 of 87 PERMANENTLY DEFUELED EMERGENCY PLAN Revision 2 DUKE ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 James B. Ferguson Emergency Pia Terry Hobbs

'i*P-7. I~

Date

TABLE OF CONTENTS (Continued)

Section Page PDEP Rev. 2 Page i

1.0 INTRODUCTION

..................................................................................................................... 1-1 1.1 PURPOSE................................................................................................................... 1-2 1.2 SCOPE........................................................................................................................ 1-2 2.0 DISCUSSION.......................................................................................................................... 2-1 2.1 OVERVIEW OF PDEP................................................................................................. 2-1 2.2 FACILITY DESCRIPTION............................................................................................ 2-2 2.3

SUMMARY

OF EMERGENCY ACTIONS.................................................................... 2-3

3.0 REFERENCES

........................................................................................................................ 3-1 4.0 DEFINITIONS AND ABBREVIATIONS.................................................................................... 4-1 4.1 DEFINITIONS.............................................................................................................. 4-1 4.1 DEFINITIONS (Continued)........................................................................................... 4-2 4.1 DEFINITIONS (Continued)........................................................................................... 4-3 4.1 DEFINITIONS (Continued)........................................................................................... 4-4 4.2 ABBREVIATIONS........................................................................................................ 4-5 5.0 ASSIGNMENT OF RESPONSIBILITY (ORGANIZATION CONTROL).................................... 5-1 5.1 ORGANIZATIONAL PLANNING OBJECTIVE.............................................................. 5-1 5.2 SAFSTOR ORGANIZATION........................................................................................ 5-2 5.3 OVERALL EMERGENCY RESPONSE ORGANIZATIONS.......................................... 5-3 5.4 RESPONSE ORGANIZATIONS................................................................................... 5-3 5.5 INTERRELATIONSHIP OF KEY RESPONSE ORGANIZATIONS [R1]........................ 5-3 5.5.1 CR3 Emergency Response Organization......................................................... 5-3 5.5.2 State Watch Office-Tallahassee....................................................................... 5-4 5.5.3 Florida Division of Emergency Management.................................................... 5-5 5.5.4 Citrus County Sheriff's Office, Division of Emergency Management................. 5-5 5.5.5 Seven Rivers Regional Medical Center............................................................ 5-6 5.5.6 Local Emergency Medical Services.................................................................. 5-6 5.5.7 Nuclear Regulatory Commission...................................................................... 5-7 5.5.8 Federal Emergency Management Agency........................................................ 5-8 5.5.9 Local Fire Departments.................................................................................... 5-8 5.6 WRITTEN AGREEMENTS FOR EMERGENCY RESPONSE...................................... 5-8 6.0 ON-SITE EMERGENCY RESPONSE ORGANIZATION......................................................... 6-1 6.1 ON-SHIFT POSITIONS................................................................................................ 6-1 6.2 CR3 EMERGENCY RESPONSE ORGANIZATION..................................................... 6-2 6.2.1 On-Shift Organization....................................................................................... 6-3 6.2.2 Emergency Coordinator.................................................................................... 6-3 6.2.3 Augmented Staff............................................................................................... 6-4 6.2.4 Medical Response Personnel........................................................................... 6-6 6.2.5 Industrial Incipient Fire Brigade........................................................................ 6-6 6.3 AUGMENTATION OF CR3 EMERGENCY RESPONSE ORGANIZATION.................. 6-7 6.4 CORPORATE ORGANIZATION.................................................................................. 6-7 U.S. Nuclear Regulatory Commission 3F0815-01 Page 2 of 87

TABLE OF CONTENTS (Continued)

Section Page PDEP Rev. 2 Page ii 7.0 EMERGENCY RESPONSE SUPPORT AND RESOURCES................................................... 7-1 7.1 LICENSEE RESOURCES SUPPORTING FEDERAL RESPONSE [R1]...................... 7-1 7.2 RADIOLOGICAL LABORATORIES............................................................................. 7-1 7.3 NUCLEAR AND OTHER FACILITIES, ORGANIZATIONS, AND INDIVIDUALS PROVIDING EMERGENCY ASSISTANCE............................................ 7-1 8.0 EMERGENCY CLASSIFICATION SYSTEM............................................................................ 8-1 8.1 STANDARD CLASSIFICATION OF EMERGENCIES.................................................. 8-1 8.1.1 Unusual Event.................................................................................................. 8-1 8.1.2 Alert.................................................................................................................. 8-2 8.2 EMERGENCY ACTION LEVELS AND POSTULATED ACCIDENTS........................... 8-2 9.0 NOTIFICATION METHODS AND PROCEDURES.................................................................. 9-1 9.1 BASIS FOR NOTIFICATION........................................................................................ 9-1 9.2 MEANS OF NOTIFICATION........................................................................................ 9-1 9.2.1 CR3 Plant Staff................................................................................................. 9-2 9.2.2 CR1 & 2 and 4 & 5 Control Centers.................................................................. 9-2 9.2.3 Nuclear Regulatory Commission...................................................................... 9-2 9.2.4 State Watch Office-Tallahassee....................................................................... 9-3 9.2.5 Medical Support Organizations......................................................................... 9-3 9.3 EMERGENCY MESSAGES......................................................................................... 9-3 9.4 PUBLIC ALERT AND NOTIFICATION......................................................................... 9-3 10.0 EMERGENCY COMMUNICATIONS..................................................................................... 10-1 10.1 GENERAL GUIDELINES........................................................................................... 10-1 10.2 PAX SYSTEM............................................................................................................ 10-2 10.3 COMMERCIAL TELEPHONES.................................................................................. 10-2 10.4 PORTABLE UHF RADIOS......................................................................................... 10-2 10.5 MAINTENANCE TELEPHONES................................................................................ 10-2 10.6 EVACUATION AND FIRE ALARMS........................................................................... 10-3 10.7 STATE HOT RINGDOWN.......................................................................................... 10-3 10.8 EMERGENCY NOTIFICATION SYSTEM.................................................................. 10-3 10.9 SATELLITE TELEPHONES....................................................................................... 10-3 11.0 PUBLIC EDUCATION AND INFORMATION......................................................................... 11-1 12.0 EMERGENCY FACILITIES AND EQUIPMENT..................................................................... 12-1 12.1 EMERGENCY RESPONSE FACILITIES................................................................... 12-1 12.1.1 CR3 Control Room......................................................................................... 12-1 12.1.2 Emergency Support Center (ESC).................................................................. 12-2 12.1.3 Nuclear Security Operations Center............................................................... 12-2 12.1.4 Alternate ERO Augmentation Facility............................................................. 12-2

12.2 ASSESSMENT

SYSTEMS AND EQUIPMENT.......................................................... 12-3 12.2.1 Radiation Monitoring System.......................................................................... 12-3 12.2.2 Hydrologic Monitoring Systems...................................................................... 12-3 12.2.3 Meteorological Monitoring Systems................................................................ 12-4 U.S. Nuclear Regulatory Commission 3F0815-01 Page 3 of 87

TABLE OF CONTENTS (Continued)

Section Page PDEP Rev. 2 Page iii 12.2.4 Plant Process Monitoring Systems................................................................. 12-4 12.3 PROTECTIVE FACILITIES AND EQUIPMENT.......................................................... 12-5 12.3.1 Fire Protection System................................................................................... 12-5 12.4 EMERGENCY SUPPLIES......................................................................................... 12-5 12.5 FIRST AID FACILITIES.............................................................................................. 12-5 12.6 DAMAGE CONTROL EQUIPMENT........................................................................... 12-6 13.0 ACCIDENT ASSESSMENT................................................................................................... 13-1 13.1 RANGE OF ASSESSMENT ACTIVITIES................................................................... 13-1 13.2 ACCIDENT ASSESSMENT METHODS..................................................................... 13-2 13.2.1 Incident Determination.................................................................................... 13-2 13.2.2 Radiation Monitoring and Estimating Release Potential.................................. 13-2 13.2.3 Dose Assessment.......................................................................................... 13-3 14.0 PROTECTIVE RESPONSE [R2]........................................................................................... 14-1 14.1 ON-SITE PROTECTIVE MEASURES........................................................................ 14-1 14.1.1 Radiation Protection Program......................................................................... 14-1 14.1.2 Emergency Exposure Guidelines................................................................... 14-2 14.2 PERSONNEL ASSEMBLY, SHELTERING, OR EVACUATION................................. 14-2 14.3 OFF-SITE PROTECTIVE MEASURES...................................................................... 14-3 15.0 RADIOLOGICAL EXPOSURE CONTROL............................................................................. 15-1 15.1 EXPOSURE GUIDELINES........................................................................................ 15-1 15.2 RADIATION PROTECTION....................................................................................... 15-2 15.2.1 Access Control............................................................................................... 15-2 15.2.2 Personnel Exposure Monitoring...................................................................... 15-3 15.3 CONTAMINATION CONTROL................................................................................... 15-3 15.3.1 Personnel Decontamination............................................................................ 15-3 15.3.2 Area and Equipment Decontamination........................................................... 15-4 15.3.3 Control of Potable Water and Food................................................................ 15-4 16.0 MEDICAL AND PUBLIC HEALTH SUPPORT....................................................................... 16-1 16.1 ON-SITE FIRST AID.................................................................................................. 16-1 16.1.1 Medical Response Personnel......................................................................... 16-1 16.1.2 First Aid Kits................................................................................................... 16-1 16.1.3 On-Site Medical Emergency Communications................................................ 16-1 16.2 MEDICAL TRANSPORTATION................................................................................. 16-2 16.3 OFF-SITE MEDICAL SUPPORT................................................................................ 16-2 16.3.1 Seven Rivers Regional Medical Center.......................................................... 16-2 16.3.2 Off-Site Medical Support Plans....................................................................... 16-2 17.0 RECOVERY AND RE-ENTRY PLANNING AND POST-ACCIDENT OPERATIONS............. 17-1 17.1 RE-ENTRY PLANS.................................................................................................... 17-1 17.2 EMERGENCY TERMINATION AND NOTIFICATION................................................ 17-2 17.3 RECOVERY OPERATIONS...................................................................................... 17-2 U.S. Nuclear Regulatory Commission 3F0815-01 Page 4 of 87

TABLE OF CONTENTS (Continued)

Section Page PDEP Rev. 2 Page iv 17.3.1 Recovery Plan................................................................................................ 17-2 18.0 DRILLS AND EXERCISES.................................................................................................... 18-1 18.1 PLANNING DRILLS AND EXERCISES..................................................................... 18-1 18.2 SCENARIO DEVELOPMENT.................................................................................... 18-2 18.3 DRILL AND EXERCISE REQUIREMENTS................................................................ 18-3 18.3.1 Training Drills................................................................................................. 18-3 18.3.2 Biennial Exercises.......................................................................................... 18-4 18.4 CRITIQUES............................................................................................................... 18-5 19.0 EMERGENCY RESPONSE ORGANIZATION TRAINING..................................................... 19-1 19.1 EMERGENCY RESPONSE ORGANIZATION TRAINING PROGRAM...................... 19-2 19.1.1 Medical Response Personnel......................................................................... 19-2 19.1.2 Emergency Mitigation Coordinator.................................................................. 19-2 19.1.3 Emergency Mitigation Personnel.................................................................... 19-2 19.1.4 Radiation Controls Coordinator...................................................................... 19-2 19.1.5 Radiation Monitoring Personnel...................................................................... 19-2 19.1.6 Fire Brigade.................................................................................................... 19-3 19.1.7 Emergency Coordinators................................................................................ 19-3 19.1.8 Medical Support Personnel [R2]..................................................................... 19-3 20.0 RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION OF EMERGENCY PLANS................................................................ 20-1 20.1 EMERGENCY PLANNING COORDINATION............................................................ 20-1 20.2 PLAN/PROCEDURES REVIEW AND UPDATE......................................................... 20-1 20.3 TRAINING.................................................................................................................. 20-2 20.4 AUDITS..................................................................................................................... 20-2 U.S. Nuclear Regulatory Commission 3F0815-01 Page 5 of 87

TABLE OF CONTENTS (Continued)

PDEP Rev. 2 Page v Appendices Page APPENDIX A - Implementing Procedure Listing................................................................................ A-1 APPENDIX B - Agreements With Supporting Organizations............................................................. B-1 APPENDIX C - Cross-Reference To Regulatory Requirements........................................................ C-1 Tables 6.1 Shift and Emergency Staffing Capabilities.............................................................................. 6-8 12.1 Typical Emergency Equipment/Supplies And Locations....................................................... 12-7 14.1 Guidelines For Protective Action Recommendations For Non-Essential Energy Complex Personnel............................................................................................................................. 14-4 16.1 Summary Of Actions For Emergency Medical Treatment..................................................... 16-3 19.1 Emergency Response Organization Training Programs....................................................... 19-4 Figures 5.1 Functional Interrelationship of Key Emergency Organizations................................................ 5-9 6.1 CR3 Emergency Response Organization............................................................................... 6-9 Summary of Changes.................................................................................................................... SOC 1 Nuclear Operations Commitment System (NOCS) References

[R1] NOCS001122, Description of Licensee, State and Local Resources Available to Support the Federal Response

[R2] NOCS001130, Provisions for Controlling Exposure of Offsite Ambulance Drivers; Advance Approval of Emergency Level Doses and Assurance of Adequate Training U.S. Nuclear Regulatory Commission 3F0815-01 Page 6 of 87

PDEP Rev. 2 Page 1-1

1.0 INTRODUCTION

Crystal River Unit 3 Nuclear Plant (CR3) has been safely shutdown since September 26, 2009. On February 20, 2013, by letter 3F0213-07, Progress Energy Florida, a subsidiary of Duke Energy, provided certification to the U.S. Nuclear Regulatory Commission (NRC) required by 10 CFR 50.82(a)(1)(i) and (ii) that CR3 has permanently ceased operations and that all fuel has been permanently removed from the reactor vessel.

Commercial operation began on March 13, 1977. As of May 28, 2011, all fuel assemblies have been permanently removed from the reactor vessel and placed in the spent fuel (SF) pools for storage. By letter dated March 13, 2013, the NRC acknowledged certification of permanent cessation of power operation and permanent removal of fuel from the reactor vessel. Pursuant to 10 CFR 50.82(a)(2),

the 10 CFR Part 50 license for CR3 no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel. This Permanently Defueled Emergency Plan (PDEP) adequately addresses the risks associated with CR3s current conditions.

Analyses of the credible accident or beyond design basis events and consequences of an accident for CR3 in a permanently defueled condition are presented in the calculations provided as References 3.19 - 3.24. The analyses indicate that any releases beyond the EXCLUSION AREA BOUNDARY (EAB) are limited to small fractions of the Environmental Protection Agency (EPA) Protective Action Guide (PAG) exposure levels, as detailed in the EPAs Protective Action Guide and Planning Guidance for Radiological Incidents, Draft for Interim Use and Public Comment dated March 2013 (PAG Manual). Exposure levels warranting pre-planned emergency preparedness activities are limited to onsite areas. For this reason, this Plan addresses actions necessary to safeguard onsite personnel and minimize damage to property.

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PDEP Rev. 2 Page 1-2 1.1 PURPOSE The purpose of this Plan is to assure an adequate level of preparedness by which to cope with a spectrum of emergencies that could be postulated to occur, including means to minimize radiation exposure to Plant personnel. This Plan integrates the necessary elements to provide effective emergency response considering cooperation and coordination of organizations expected to respond to potential emergencies.

1.2 SCOPE Duke Energy Florida, Inc. (DEF) has developed this PDEP to respond to potential radiological emergencies at CR3 considering it's permanently shutdown and defueled status. Because the analyses of the credible design basis events and consequences indicate there are no postulated accidents that would result in off-site dose consequences that are large enough to require off-site emergency planning, the overall scope of this Plan delineates the actions necessary to safeguard onsite personnel and minimize damage to property.

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PDEP Rev. 2 Page 2-1 2.0 DISCUSSION 2.1 OVERVIEW OF PDEP In the event of an emergency at the CR3 Plant, actions are required to identify and assess the nature of the emergency and to bring it under control in a manner that protects the health and safety of Plant personnel.

This Plan describes the organization and responsibilities of DEF for implementing emergency measures. It describes interfaces with Federal, State of Florida, and Citrus County organizations, which may be notified in the event of an emergency, and may provide assistance. Emergency services are provided by local public and private entities. Fire, rescue and law enforcement services are provided by Citrus County. Ambulance service is provided by Nature Coast Emergency Medical Services. Medical services are provided by Seven Rivers Regional Medical Center (SRRMC).

CR3 is licensed under the requirements of 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities. Consistent with the requirements of 10 CFR Part 50, this Plan is based on the requirements of 10 CFR Part 50, Section 50.47(b) and Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, with approved exemptions that reflects CR3 in its permanently shutdown and defueled status. Sections 5.0 thru 20.0 of this Plan address the standards outlined in 10 CFR 50.47(b)(1) through (16). In addition, the Plan is also intended to meet appropriate State of Florida and U.S. NRC regulations in accordance with DEF's Operating License (No. DPR-72).

Because the analyses of the credible design basis events and consequences indicate there are no postulated accidents that would result in off-site dose consequences that are large enough to require off-site emergency planning, emergencies are divided into two classifications: 1) Notification of UNUSUAL EVENT (UNUSUAL EVENT) and 2) ALERT. This classification scheme has been discussed and agreed upon with responsible off-site organizations and is compatible with the State Plan. According to the EPA PAG Manual, Emergency Planning Zones (EPZs) are not necessary at those facilities where it is not possible for PAGs to be exceeded off-site.

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PDEP Rev. 2 Page 2-2 2.1 OVERVIEW OF PDEP (Continued)

DEF is responsible for planning and implementing emergency measures within the CR3 OWNER CONTROLLED AREA. This Plan is provided to meet that responsibility.

To carry out specific emergency measures discussed in this Plan, detailed implementing procedures are established and maintained. Appendix A provides a listing of the implementing procedures for this Plan. Those procedures necessary to maintain the emergency preparedness program are also addressed in Appendix A.

In addition to the description of activities and steps that can be implemented during a potential emergency, this Plan also provides a general description of the steps taken to recover from an emergency. It also describes the training, drills, exercises, planning, and coordination appropriate to maintain an adequate level of emergency preparedness.

2.2 FACILITY DESCRIPTION The CR3 Plant is located at Red Level, Florida in Citrus County, about 5 miles south of Levy County. The site is 7.5 miles northwest of Crystal River, Florida and 90 miles north of St. Petersburg, Florida. CR3 is situated on the Gulf of Mexico, within the Crystal River Energy Complex.

CR3 formerly consisted of a single unit nominal 911 MWe / 2609 MWth Nuclear Power Plant, utilizing a Babcock & Wilcox (B&W) Company (currently AREVA) pressurized water reactor (PWR). The unit is certified to have ceased power operations and is permanently defueled in accordance with 10 CFR 50.82(a)(1)(i) and (ii).

Spent fuel is stored in SF Pool A and SF Pool B, both of which feature high-density storage racks. Spent Fuel is also stored in the Independent Spent Fuel Storage Installation (ISFSI). The SF Pool storage racks are designed to Seismic Class I requirements. The fuel storage racks are designed to have a minimum of 23 feet of water shielding over stored assemblys fuel rods. A complete description of spent fuel storage is provided in Section 9.6 of the FSAR.

ISFSI is a robust and high integrity facility for the spent fuel storage system. This facility is designed to prevent the release of radioactivity in the event of accidents, including environmental phenomena (e.g., earthquake and flooding).

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PDEP Rev. 2 Page 2-3 2.3

SUMMARY

OF EMERGENCY ACTIONS This Plan is activated by the EMERGENCY COORDINATOR (EC) upon identification of an emergency situation at CR3. The emergency measures described in the subsequent sections and implementing procedures are implemented in accordance with the classification and nature of the emergency and directions from the EC.

Regulatory authorities and off-site support organizations are notified in accordance with this Plan. The EC has authority and responsibility for control and mitigation of the emergency, including emergency response resources, coordination of radiological ASSESSMENT ACTIVITIES, RECOVERY implementation, and coordination of emergency response activities.

The following sections of this Plan describe the detailed plans and actions of the CR3 Emergency Response Organization (ERO), including interfaces with off-site support organizations.

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PDEP Rev. 2 Page 3-1

3.0 REFERENCES

3.1 10 CFR 50.47, Emergency Plans 3.2 10 CFR Part 50, Appendix "E," "Emergency Planning and Preparedness for Production and Utilization Facilities" 3.3 10 CFR Part 20, "Standards for Protection Against Radiation" 3.4 NUREG-0578, "TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations" (July 1979) 3.5 NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" (November 1980) 3.6 Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors" 3.7 Environmental Protection Agency, Protective Action Guide and Planning Guidance for Radiological Incidents, Draft for Interim Use and Public Comment (March 2013) 3.8 "State of Florida Radiological Emergency Management Plan" (herein referred to as State Plan) 3.9 State of Florida Statutes, Chapter 170J-1, "Control of Radiation Hazards" 3.10 CR3 Final Safety Analysis Report (FSAR) 3.11 CR3 Technical Specifications 3.12 CR3 Plant Operating Manual (POM)

(See Appendix A for list of implementing procedures.)

3.13 Emergency Plan Implementing Procedures (See Appendix A for list.)

3.14 Seven Rivers Regional Medical Center "Radioactive Material Contamination Response Plan" 3.15 NRC Bulletin 2005-02, Emergency Preparedness and Response Actions for Security-Based Events 3.16 NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Rev. 6 3.17 CR3 Letter 3F0213-07 dated February 20, 2013. Crystal River Unit 3 - Certification of Permanent Cessation of Power Operations and that Fuel Has Been Permanently Removed from the Reactor. ML13056A005.

3.18 NRC Letter dated March 13, 2013. Crystal River Unit 3 Nuclear Generating Plant Certification of Permanent Cessation of Operation and Permanent Removal of Fuel From the Reactor.

3.19 Calculation N13-0001, "Fuel Handling Accident" 3.20 Calculation F13-0002, "Loss of Pool Inventory Air Cooled Heatup" 3.21 Calculation N13-0003, "Radioactive Waste Handling Accident" 3.22 Calculation F97-0014 and Engineering Change 92486, "Loss of Spent Fuel Pool Normal Cooling" 3.23 Calculation F13-0004, "Hottest Fuel Assembly Adiabatic Heatup" 3.24 Calculation N13-0002, "Loss of Pool Inventory Dose" 3.25 Time-Motion Study - B.5.b Actions for Catastrophic Loss of SF Pool Level U.S. Nuclear Regulatory Commission 3F0815-01 Page 12 of 87

PDEP Rev. 2 Page 4-1 4.0 DEFINITIONS AND ABBREVIATIONS 4.1 DEFINITIONS

1.

Annual: Once per calendar year unless otherwise specifically stated.

2.

Assessment Activities: Actions taken during or after an emergency for the purpose of obtaining and processing the information that will be used to make the decisions to implement specific emergency measures.

3.

Emergency Actions: Assessment, corrective, and protective actions designed to achieve a safe, stable Plant condition, and to immediately mitigate the effects of the emergency.

4.

Emergency Action Level (EAL): A pre-determined, observable threshold for Plant conditions that places the Plant in a given emergency classification.

5.

Emergency Classification System: A system of classification in which emergency occurrences are categorized according to specific protective action levels. The two emergency classifications in order of significance are UNUSUAL EVENT and ALERT. These classifications are defined by NEI 99-01, Rev. 6 as follows:

a.

Unusual Event: Events are in progress or have occurred which indicate a potential degradation of the level of safety of the Plant or indicate a security threat to facility protection has been initiated.

No releases of radioactive material requiring off-site response or monitoring are expected unless further degradation of safety systems occurs.

b.

Alert: Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the Plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA PAG exposure levels.

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PDEP Rev. 2 Page 4-2 4.1 DEFINITIONS (Continued)

6.

Emergency Coordinator (EC): This position is the highest level of authority for the CR3 ERO and on-site emergency activities. This position is held by the Shift Supervisor or designated alternate.

7.

Exclusion Area Boundary: The perimeter of the area that extends 4,400 feet or 0.83 miles in a circle around the Reactor Building, which includes the PROTECTED AREA.

8.

Fire: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.

9.

Frequency: That unit of time specified (monthly, quarterly, etc.) plus or minus 25 percent unless otherwise specifically stated. This definition does not apply to "annual" when it is related to the conduct of the Biennial Exercise (NRC Evaluated). Biennial Exercises are performed within the calendar year.

10.

Hostile Action: An act toward a Nuclear Power Plant or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the Nuclear Power Plant. Non-terrorism-based EALs should be used to address such activities, (e.g., violent acts between individuals in the OWNER CONTROLLED AREA). (NEI 99-01, Rev. 6)

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PDEP Rev. 2 Page 4-3 4.1 DEFINITIONS (Continued)

11.

Hostile Force: One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction. (NEI 99-01, Rev. 6)

12.

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

13.

Local Assembly Area: A pre-designated area personnel report for organization, roll-call, and supervision following an "ALERT" emergency classification.

14.

Normal Working Hours: The normal hours that most Plant personnel are on-site, usually between 7 a.m. and 5 p.m., Monday through Friday.

15.

Owner Controlled Area: The area of land (approximately 4738 acres) that is owned, leased, or otherwise controlled by DEF, situated between the mouths of the Withlacoochee and Crystal Rivers and bounded to the north by woodlands, to the east by Highway 19, to the south by medium to dense woodlands and to the west by marshlands and the Gulf of Mexico.

The OWNER CONTROLLED AREA is the area of land within the SITE BOUNDARY, as shown in Figure 2-3 of the FSAR. The PROTECTED AREA is located within the OWNER CONTROLLED AREA.

16.

Protected Area: All areas within the CR3 security perimeter fence that require badged authorization for entry.

17.

Protective Actions: Those emergency measures taken after an uncontrolled release of radioactive material has occurred for the purpose of preventing or minimizing radiological exposures to persons that would be likely to occur if the actions were not taken.

18.

Protective Action Guide (PAG): The projected dose to an individual, resulting from a radiological incident at which a specific PROTECTIVE ACTION to reduce or avoid that dose is warranted.

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PDEP Rev. 2 Page 4-4 4.1 DEFINITIONS (Continued)

19.

Recovery: The condition declared after the immediate hazards to life and safety due to the emergency have been removed and efforts are directed to returning affected areas to normal.

20.

Recovery Actions: Those actions taken after the emergency to restore CR3 as nearly as possible to its pre-emergency condition.

21.

Re-entry: Return of personnel into areas evacuated due to Plant conditions.

22.

Release: (Florida Nuclear Plant Emergency Notification Form) - Any of the following:

Exceeding the warning set-point in count rate on an effluent monitor that is a direct result of an event that has initiated an emergency declaration; OR Radioactivity detected by environmental monitoring; OR NOTE Suspected leakage should NOT be categorized as a release until confirmed by environmental monitoring or direct observation.

Radioactivity escaping unmonitored from the Plant.

23.

Site Boundary: That line beyond which the land is not owned, leased, or otherwise controlled by the licensee. This line establishes the perimeter of the Owner Controlled Area (OCA).

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PDEP Rev. 2 Page 4-5 4.2 ABBREVIATIONS CAS Central Alarm Station CCSO Citrus County Sheriff's Office CFH Certified Fuel Handler CR3 Crystal River Unit 3 Plant DEF Duke Energy Florida DEM State of Florida Department of Community Affairs, Division of Emergency Management DHBRC Department of Health, Bureau of Radiation Control (State of Florida)

DOE U.S. Department of Energy EAB Exclusion Area Boundary EAL Emergency Action Level EC Emergency Coordinator ENS Emergency Notification System EPA U.S. Environmental Protection Agency ERO Emergency Response Organization ESC Emergency Support Center FDLE Florida Department of Law Enforcement FRERP Federal Radiological Emergency Response Plan FSAR Final Safety Analysis Report ISFSI Independent Spent Fuel Storage Installation NRC U.S. Nuclear Regulatory Commission NSOC Nuclear Security Operations Center ORO Offsite Response Organization PA Public Address System PAG Protective Action Guide PAX Public Address Exchange System RCA Radiation Controlled Area PDEP Permanently Defueled Emergency Plan REAC/TS Radiation Emergency Assistance Center/Training Site RMS Radiation Monitoring System SAS Secondary Alarm Station SEOC State of Florida Emergency Operations Center (Tallahassee, FL)

SF Spent Fuel SHRD State Hot Ringdown SLERS State Law Enforcement Radio System SRRMC Seven Rivers Regional Medical Center SWOT State Watch Office-Tallahassee TLD Thermoluminescent Dosimeter U.S. Nuclear Regulatory Commission 3F0815-01 Page 17 of 87

PDEP Rev. 2 Page 5-1 5.0 ASSIGNMENT OF RESPONSIBILITY (ORGANIZATION CONTROL)

The SAFSTOR organization has complete capability at all times to perform the detection, classification, initial response, and notification functions required during an emergency. This Plan considers the capabilities and responsibilities of the on-shift staff; augmented by support from other utility personnel and support organizations, if necessary.

An extended emergency situation may require augmentation of the on-site ERO.

In addition, the personnel resources of off-site emergency support organizations can be mobilized to augment the on-site ERO, if conditions warrant.

This section of the Plan addresses the identification of: (a) the various emergency response organizations and sub-organizations; (b) their conduct of operations and interrelationships, and their plans to provide 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day response; and (c) reference to all written agreements between DEF and off-site emergency response organizations.

5.1 ORGANIZATIONAL PLANNING OBJECTIVE The organizational planning objective is to assure that primary emergency preparedness responsibilities of CR3 organizations responsible for emergency support have been established and assigned. Furthermore, the objective is to assure that response organizations are staffed to respond and are capable of augmenting initial response on a continuous basis.

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PDEP Rev. 2 Page 5-2 5.2 SAFSTOR ORGANIZATION DEF is responsible for the safe storage and handling of spent fuel and decommissioning of CR3 in accordance with the State of Florida and NRC regulations, and its NRC Operating License (No. DPR-72), as amended. Responsibility for planning and implementing all emergency measures within the OWNER CONTROLLED AREA rests with DEF.

The CR3 SAFSTOR ORGANIZATION has an inherent emergency response/RECOVERY function in its overall management and operation. This function can be delineated by reviewing management structure and responsibilities as follows:

1.

General Manager Decommissioning, Crystal River Nuclear Plant The General Manager Decommissioning is directly responsible for the decommissioning of CR3, reports to the Senior Vice President of Operations Support and has ultimate responsibility for the overall effectiveness of CR3s PDEP. In the event of an emergency at CR3, the General Manager Decommissioning assumes administrative authority and responsibility for the effective implementation of the PDEP.

2.

Operations and Maintenance Manager The Operations and Maintenance Manager reports to the General Manager Decommissioning and is responsible for the safe spent fuel handling and decommissioning activities of CR3 and for the supervision of persons assigned. During an emergency, the Operations and Maintenance Manager is responsible for the protection of Energy Complex personnel from radiation exposure and/or any other consequence of an accident at CR3. The Operations and Maintenance Manager is responsible for the accountability of all personnel within the confines of CR3.

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PDEP Rev. 2 Page 5-3 5.3 OVERALL EMERGENCY RESPONSE ORGANIZATIONS During an emergency, numerous response organizations and sub-organizations are available to provide assistance, if required. The analyses of the credible design basis events and consequences indicate that there are no postulated accidents that would result in off-site dose consequences that are large enough to require off-site emergency planning. Any assistance from off-site organizations is limited to law enforcement, fire or medical support. These emergency services are drawn from local government and the private sector and are listed for reference in an off-site support directory.

5.4 RESPONSE ORGANIZATIONS Response organizations are available on a continuous basis and interrelate to receive notifications and communications and provide medical and law enforcement support to CR3.

5.5 INTERRELATIONSHIP OF KEY RESPONSE ORGANIZATIONS [R1]

Figure 5.1 illustrates the functional interrelationship of the key response organizations.

5.5.1 CR3 Emergency Response Organization The CR3 Staff has the immediate and continuing responsibility for emergency response and control of emergency activities at CR3.

The CR3 ERO and its functions are predefined and personnel assignments are specified and updated on a continuous basis to provide for automatic, unambiguous staffing of the CR3 ERO to respond effectively and in a timely manner. The CR3 ERO is capable of functioning on a 24-hour basis.

5.5.1.1 Relationship to the Total Effort:

The CR3 ERO performs the emergency technical, radiological, warning, and health support response. This organization is supported directly and indirectly on a broad scale by off-site organizations in the governmental and private sector, as necessary.

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PDEP Rev. 2 Page 5-4 5.5.1.2 Concept of Operations:

The CR3 ERO evaluates the emergency and initiates the necessary actions to address it.

The Shift Supervisor has the responsibility and authority to declare an emergency and initiate appropriate actions in accordance with written procedures to mitigate the consequences. The Shift Supervisor also has the responsibility to notify the Operations and Maintenance Manager as soon as possible after an emergency classification has been determined. The Shift Supervisor serves as the EC.

The EC is responsible for the direction of all activities at the Plant site during an emergency. Should evaluation indicate the need, the EC has the authority to direct any or all personnel to evacuate CR3 and to notify all applicable agencies of the Plant status. The EC ensures that appropriate actions are taken to mobilize emergency teams and to notify management and applicable off-site supporting organizations and regulatory agencies as necessary.

5.5.2 State Watch Office-Tallahassee The State Watch Office-Tallahassee (SWOT) is the primary point of contact for the State of Florida for the purpose of notification of an emergency declaration.

Notification of an emergency will be made to the SWOT within 60 minutes after an emergency declaration or change in classification. The SWOT will notify the Division of Emergency Management (DEM) and Citrus County officials of an emergency at CR3.

5.5.2.1 Relationship to the Total Effort:

The SWOT is available on a 24-hour basis to receive emergency communications from CR3 and, in turn, contact State and local emergency response organizations, as appropriate.

5.5.2.2 Concept of Operations:

Emergency notification is received from the CR3 EC or designated alternate via the State Hot Ringdown Telephone System (SHRD), or other means necessary.

The Duty Officer notifies the Florida Division of Emergency Management (DEM) and Citrus County officials. The Duty Officer, with assistance from the DEM, then notifies appropriate State agencies.

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PDEP Rev. 2 Page 5-5 5.5.3 Florida Division of Emergency Management The State of Florida Department of Community Affairs' DEM is responsible for coordinating Federal, State and local radiological emergency response activities, and for preparing and maintaining the State Plan.

5.5.3.1 Relationship to the Total Effort:

The DEM provides guidance and assistance in preparation of local emergency response procedures. The DEM provides personnel and equipment to emergency response facilities, and provides needed supplies to State and local political subdivisions.

5.5.3.2 Concept of Operations:

The Director, DEM is responsible for coordinating DEM emergency response. The DEM receives notification of an emergency at CR3 via the SWOT; verifies the information contained in the notification messages; and alerts key State, local and Federal emergency response personnel, as appropriate.

5.5.4 Citrus County Sheriff's Office, Division of Emergency Management Citrus County Emergency Management is responsible for law enforcement and fire support at CR3.

5.5.4.1 Relationship to the Total Effort:

The CCSO is responsible for coordinating emergency operations at the local level and for keeping local officials advised of law enforcement actions involving CR3. During an emergency requiring CCSO response to CR3, communications with the CCSO are maintained through the Citrus County 911 Dispatch Center.

5.5.4.2 Concept of Operations:

The Citrus County EOC in Lecanto, Florida maintains 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day communications through the County's Fire Dispatch/EOC on the SHRD or commercial telephone.

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PDEP Rev. 2 Page 5-6 5.5.5 Seven Rivers Regional Medical Center SRRMC in Crystal River, Florida serves as the hospital to treat injuries resulting from any non-radiological or radiological emergency situation at CR3.

5.5.5.1 Relationship to the Total Effort:

The hospital will acknowledge and respond to all emergency medical requests from the emergency response organization and management at CR3. Treatment will be provided for non-radiological and radiological injuries. The hospital will maintain communications with CR3. The hospital will maintain communications with the Citrus County EOC on support needs or other agencies as appropriate.

5.5.5.2 Concept of Operations:

The hospital will furnish the services of physicians to injured persons. The hospital will accept all patients dispatched from CR3. If necessary, the hospital will utilize radiological support provided by CR3 Staff.

5.5.6 Local Emergency Medical Services Ambulance service is available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day to provide assistance in the event of an emergency at CR3.

5.5.6.1 Relationship to the Total Effort:

Upon request, local ambulance services will provide emergency medical services.

It will maintain communication with CR3, SRRMC and/or CCSO on support needs.

5.5.6.2 Concept of Operations:

Upon request from the CR3 EC or designee, ambulance service will be provided immediately, which includes emergency medical treatment and/or transportation to a designated hospital facility. The service shall accept all patients dispatched from CR3 and, where necessary, shall utilize the radiological support provided by CR3 Staff.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 23 of 87

PDEP Rev. 2 Page 5-7 5.5.7 Nuclear Regulatory Commission The NRC is the primary Federal agency providing coordination and support to the licensee in the event of an emergency at a CR3. NRC responsibilities are directed toward a coordination of Federal efforts to provide assistance to the licensee and State and local governments in their planning and implementation of emergency preparedness procedures.

5.5.7.1 Relationship to the Total Effort:

The NRC response must be regarded primarily as supportive of, and not a substitute for, responsible action by DEF and other key response organizations. The NRC must be continually informed of status and possible radiological consequences, and be frequently updated on plans for emergency and RECOVERY ACTIONS and needs for assistance.

5.5.7.2 Concept of Operations:

In the event of an emergency at CR3, the NRC Operations Center in Rockville, Maryland will be notified immediately after notification of the SWOT and not later than 60 minutes after declaration of an emergency classification or change in classification.

Classification information and radiological information are communicated to this office over a dedicated telephone line from CR3. Emergency notification, plant status information and radiological information is communicated via the Emergency Notification System (ENS). Other Plant information is communicated via normal telephone service.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 24 of 87

PDEP Rev. 2 Page 5-8 5.5.8 Federal Emergency Management Agency The U.S. Federal Emergency Management Agency (FEMA) is the primary Federal agency for coordination of Federal response activities at the national level and at the scene of the emergency in accordance with the Federal Radiological Emergency Response Plan (FRERP).

5.5.8.1 Relationship to the Total Effort:

FEMA has the lead responsibility for off-site emergency preparedness. To meet this role, FEMA establishes policy and provides leadership in the coordination of all Federal assistance and guidance to local and State governments for developing, reviewing, assessing, and testing the local and State radiological emergency response plans.

5.5.8.2 Concept of Operations:

In the event of an emergency at CR3, the primary role of FEMA is to assure that appropriate Federal assistance is available to State and local governments. This is accomplished through coordination with other Federal agencies as appropriate.

5.5.9 Local Fire Departments In the event of a large area FIRE at CR3, local fire departments will be called upon for assistance. Assistance will be requested from larger departments outside of the immediate area if conditions warrant.

5.6 WRITTEN AGREEMENTS FOR EMERGENCY RESPONSE Discussions have been held and agreements reached and confirmed, in writing, with State, County and private sector organizations having responsibilities for coping with radiological emergencies. Appendix B contains a list of these agreements. A copy of each agreement is maintained on file at CR3.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 25 of 87

PDEP Rev. 2 Page 5-9 FIGURE 5.1 FUNCTIONAL INTERRELATIONSHIP OF KEY EMERGENCY ORGANIZATIONS State Watch Office -

Tallahassee U.S. Nuclear Regulatory Commission 3F0815-01 Page 26 of 87

PDEP Rev. 2 Page 6-1 6.0 ON-SITE EMERGENCY RESPONSE ORGANIZATION General elements of the CR3 SAFSTOR organization are described in the preceding section. This section provides additional detail of the CR3 ERO. Within the normal SAFSTOR organization, the ERO and its augmented support from off-site organizations are described. Mobilization of the ERO, including action levels and contact points, are described in Section 9.0.

6.1 ON-SHIFT POSITIONS The personnel and resources of the CR3 SAFSTOR organization maintain the capabilities necessary to respond to an emergency. All site activities are conducted under the direction and control of the Operations and Maintenance Manager. To provide support in required areas, the SAFSTOR organization is broken down into functional areas headed by designated managers. As appropriate, these areas are further subdivided according to specific technical disciplines or support functions.

The CR3 organization is a key element for spent fuel handling, spent fuel storage activities and emergency response. The minimum on-shift positions are defined in the CR3 Technical Specifications.

Chemistry Technician positions are staffed during normal day-shift working hours.

In addition to this normal shift crew, the organizational complement of Maintenance, Technical Support, and Administrative personnel will be available during NORMAL WORKING HOURS.

The Shift Supervisor is at CR3 on a 24-hour basis. The Shift Supervisor is also a Certified Fuel Handler (CFH). This position is responsible for monitoring SF Pool conditions and managing the activities of the plant, including the ISFSI facility. When an abnormal condition warranting an emergency declaration is recognized, the Shift Supervisor makes the decision to classify the event and assumes the position of EC and associated responsibilities. The Shift Supervisor is authorized to change process controls as necessary to maintain SF Pool cooling, and for taking immediate actions required to maintain or bring CR3 to a safe condition during abnormal and/or emergency conditions. Two Fire Brigade members (excluding the Shift Operator) are utilized to perform mitigating strategies required for a catastrophic loss of spent fuel pool inventory.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 27 of 87

PDEP Rev. 2 Page 6-2 6.1 ON-SHIFT POSITIONS (Continued)

Reference 3.25 contains a timeline analysis for ERO functions that demonstrates sufficient personnel are available to respond to a catastrophic loss of SFP level with on-shift staff.

Fire Brigade staffing is maintained in accordance with the Fire Protection Plan.

Security staffing is maintained in accordance with the Security Plan.

6.2 CR3 EMERGENCY RESPONSE ORGANIZATION In the event of an emergency at CR3, a pre-established ERO is activated.

This organization is established to contain all the essential operational and technical capabilities of the normal organization, but is structured to expedite emergency response. The CR3 ERO is under the direction of the EC, and consists of operational and technical staff described below. Figure 6.1 illustrates the CR3 ERO.

Emergency duties and responsibilities are described in the series of Emergency Plan Implementing Procedures, listed in Appendix A. Personnel assignments will be in accordance with the emergency responsibilities. All personnel will be trained to fulfill their responsibilities as defined in Section 19.0. Mobilization of the emergency teams will be conducted under the direction of the EC, according to personnel assignments and telephone numbers maintained in various phone directories.

In addition to the emergency teams, DEF has designated specific personnel assignments for the functional areas of emergency activities. These assignments are made for all shifts and for Plant Staff members. Table 6.1, "Minimum Staffing Requirements for CR3 Emergencies," depicts these assignments.

The following sections address these assignments and identify and describe the ERO augmented positions.

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PDEP Rev. 2 Page 6-3 6.2.1 On-Shift Organization Under normal conditions, CR3 will be staffed by the on-shift organization described in Section 6.1. On-shift personnel are trained in emergency response procedures and have the knowledge and capability to institute measures to mitigate the effects of an emergency and to take appropriate actions for monitoring and controlling the emergency situation. Personnel required for long-term response or reliefs are available through notification of augmented staff.

6.2.2 Emergency Coordinator The Shift Supervisor has the responsibility and authority to declare an emergency and to initiate appropriate actions in accordance with written procedures to mitigate the consequences of the emergency. The Shift Supervisor will assume the position of EC upon declaration of an emergency and has the responsibility to notify the Operations and Maintenance Manager, or the designated alternate of an emergency at CR3.

The EC is responsible for the direction of all activities at CR3 during any emergency.

In accordance with site procedures, the EC shall evaluate the emergency and take necessary actions to mitigate the consequences. The EC has the authority to direct personnel to evacuate the CR3 site or to direct activities on the Energy Complex as necessary to ensure personnel safety.

The EC is responsible for assuring that appropriate corrective and PROTECTIVE ACTIONS are taken to mobilize emergency response personnel and for notifying management and off-site supporting organizations and regulatory agencies, as necessary.

The highest level of authority for on-site emergency activities will remain with the EC who may delegate responsibilities to other personnel as deemed necessary. The EC shall not delegate the responsibility to make emergency classifications or approval of emergency notifications. However, the task of making notifications to off-site organizations may be delegated.

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PDEP Rev. 2 Page 6-4 6.2.3 Augmented Staff The goal of the ERO is to augment the on-shift staff within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of an ALERT classification. Due to the slow rate of the postulated event scenarios in the accident analysis, the ERO augmentation goal of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is appropriate. The augmented staff provides the technical expertise required to assist the EC. The on-shift staff is augmented by station personnel that report as directed after receiving notification of an emergency requiring augmented staff. The minimum augmented staff consists of an Emergency Mitigation Coordinator and a Radiation Controls Coordinator. Technical support personnel will supplement the minimum augmented staff as necessary.

Augmented staff will be briefed and dispatched to assigned tasks.

The Emergency Support Center (ESC) serves as an assembly point for making available the technical expertise required to assist the EC, while at the same time minimizing the number of personnel in the Control Room to those absolutely necessary. Coordination of the ESC personnel is provided through procedure EM-501. The ESC is further described in Section 12.1.2.

6.2.3.1 Emergency Mitigation Coordinator The Emergency Mitigation Coordinator reports to the EC and is responsible for:

Evaluating technical data pertinent to Plant conditions Assessing the emergency situation Developing strategies for mitigation and corrective actions Developing strategies for search and rescue and firefighting Directing maintenance and equipment restoration Augmenting the ERO with additional technical support and emergency repair personnel as deemed necessary U.S. Nuclear Regulatory Commission 3F0815-01 Page 30 of 87

PDEP Rev. 2 Page 6-5 6.2.3.2 Radiation Controls Coordinator The Radiation Controls Coordinator reports to the EC and is responsible for:

Monitoring personnel accumulated dose Advising the EC concerning radiological conditions Establishing and monitoring Radiation Controlled Areas (RCAs)

On-Site Dose Assessment Augmenting the ERO with radiation monitoring personnel as deemed necessary 6.2.3.3 Technical Personnel Technical personnel operate under the direction of the EC, Emergency Mitigation Coordinator or Radiation Controls Coordinator, as identified above. Technical personnel are described as follows; Emergency mitigation personnel are responsible for providing assessment and repairs of equipment and facilities necessary to return CR3 to a safe condition. The emergency mitigation personnel operate under the direction of the Emergency Mitigation Coordinator.

Radiation monitoring personnel have the authority, through the EC, to prevent any or all personnel from crossing lines of controlled areas in the emergency area; the authority to require individuals to evacuate from the emergency area; and the authority to require decontamination of evacuated personnel. Radiation monitoring personnel are responsible for issuing protective equipment and monitoring devices to other personnel; performing radiological surveys in accordance with written and verbal instructions from the Radiation Controls Coordinator; establishing RCAs in accordance with surveys; providing qualified personnel for RE-ENTRY procedures; and supervising the survey and release of all personnel who evacuate on-site assembly areas. Within the OWNER CONTROLLED AREA, The radiation monitoring personnel perform area monitoring for the Energy Complex in the event of a radiological emergency.

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PDEP Rev. 2 Page 6-6 6.2.4 Medical Response Personnel LEADER: Any Emergency Response Coordinator.

RESPONSIBILITIES: The responsibilities of the medical response personnel are to provide basic life support to injured persons and request transportation for injured persons to a medical facility, as required.

AUTHORITY: The medical response personnel are authorized to release to medical personnel only the required pertinent information necessary to treat the injured, and to deliver the injured to the appropriate medical facility. Emergency Response Coordinators provide search and rescue support as well as medical response.

6.2.5 Industrial Incipient Fire Brigade LEADER: Any Emergency Response Coordinator that has completed training and qualifications as directed in the Fire Protection Plan. The leader is cognizant of the system interrelationships for maintaining spent fuel cooling and SF Pool inventory.

RESPONSIBILITIES: To provide direction within the CR3 PROTECTED AREA and perform functions as assigned by the EC during emergencies not involving a FIRE.

AUTHORITY: To maintain command and control of the FIRE scene.

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PDEP Rev. 2 Page 6-7 6.3 AUGMENTATION OF CR3 EMERGENCY RESPONSE ORGANIZATION In the event of an emergency at CR3 that requires personnel and other support resources beyond those available within the CR3 ERO, augmentation is available from other Duke Energy facilities and can be requested from various contractors.

Additional support to CR3 is available from off-site organizations, as previously discussed in Section 5.0 of this Plan.

6.4 CORPORATE ORGANIZATION The Operations and Maintenance Manager and the entire CR3 Staff are a part of the SAFSTOR organization, headed by the General Manager Decommissioning. The General Manager Decommissioning reports to the Senior Vice President of Operations Support who, in turn, reports to the Executive Vice President & President Generation and Transmission.

In addition to Duke Energy Nuclear, the organization consists of elements that provide administrative and technical support to assure continued safe spent fuel handling and decommissioning operations in compliance with applicable licensing requirements and regulations.

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PDEP Rev. 2 Page 6-8 TABLE 6.1 SHIFT AND EMERGENCY STAFFING CAPABILITIES

(*)

May be provided by shift personnel assigned other functions.

(**)

Provided by on-shift personnel that support the Fire Brigade. The Fire Brigade is composed of the Emergency Response Coordinator, Shift Operator, and an additional qualified personnel member. The on-shift Fire Brigade members (3 personnel) are the only required personnel to perform mitigating strategies required for a catastrophic loss of spent fuel pool inventory.

(***)

Security performs ERO Activation MAJOR FUNCTIONAL AREA MAJOR TASKS EMERGENCY POSITION, TITLE, OR EXPERTISE ON-SHIFT AUGMENTED STAFF CAPABILITY FOR RESPONSE IN 2 HOURS Plant Operations and Assessment of Operational Aspects Plant Operations Shift Supervisor Shift Operator 1

1(**)

Emergency Direction and Control Emergency Coordinator Shift Supervisor

(*)

Notification/Communication Notify State and Federal personnel and maintain communications Shift Supervisor

(*)

Radiological Accident Assessment and Support of Operational Accident Assessment Onsite Dose Assessment and Monitoring Health Physics Technician 1

Radiation Controls Coordinator 1

Protective Actions (In-Plant)

In-Plant Surveys Radiation Protection

a. Access Control

b. HP Coverage for Repair, Corrective Actions, Search and Rescue, First Aid, and Firefighting

c. Personnel Monitoring

d. Dosimetry Health Physics Technician

(*)

As necessary Plant Condition Evaluation, Engineering Support, Repair, and Corrective Actions Technical Direction Repair, Mitigation, and Corrective Action Shift Supervisor Emergency Response Coordinator Fire Brigade Member

(*)

(*)(**)

1(**)

1(**)

Emergency Mitigation Coordinator 1

Firefighting Firefighting Per the Fire Protection Plan Rescue Operations/ First Aid Rescue and First Aid Emergency Response Coordinator

(*)(**)

As necessary Security Security Per the Security Plan (***)

U.S. Nuclear Regulatory Commission 3F0815-01 Page 34 of 87

PDEP Rev. 2 Page 6-9 FIGURE 6.1 CR3 EMERGENCY RESPONSE ORGANIZATION U.S. Nuclear Regulatory Commission 3F0815-01 Page 35 of 87

PDEP Rev. 2 Page 7-1 7.0 EMERGENCY RESPONSE SUPPORT AND RESOURCES Response support organizations from the local, State, Federal, and private sectors available to assist in an emergency at CR3 are identified and described in Section 5.0.

This section addresses emergency support arrangements among local, State, and DEF facilities and individuals providing emergency services other than those already cited.

CR3 maintains agreements with organizations that can be relied upon in an emergency to provide assistance. The agreements are listed in Appendix B of this Plan.

7.1 LICENSEE RESOURCES SUPPORTING FEDERAL RESPONSE [R1]

Specific resources will be made available by DEF to support a Federal response to an emergency. DEF will provide for office space and telephone services for NRC use during an emergency, if requested. DEF personnel will be designated to assist NRC personnel during the emergency. Details of any Federal response deemed necessary are outlined in the FRERP.

7.2 RADIOLOGICAL LABORATORIES Duke maintains facilities capable of providing post-accident analytical services, particularly for high level radioactivity samples.

7.3 NUCLEAR AND OTHER FACILITIES, ORGANIZATIONS, AND INDIVIDUALS PROVIDING EMERGENCY ASSISTANCE Support available from the Department of Energy-Oak Ridge includes medical support from the Radiation Emergency Assistance Center/Training Site (REAC/TS).

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PDEP Rev. 2 Page 8-1 8.0 EMERGENCY CLASSIFICATION SYSTEM 8.1 STANDARD CLASSIFICATION OF EMERGENCIES DEF utilizes NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors Rev. 6, as its basis for classifying emergencies. Specifically, Appendix C of NEI 99-01, Rev. 6 contains a set of Initiating Conditions/EMERGENCY ACTION LEVELs (EALs) for permanently defueled nuclear power plants that had previously operated under a 10 CFR Part 50 license and have permanently ceased operations.

Section 8, Table E-1 of NEI 99-01, Rev. 6 contains the Initiating Conditions/EALs for the Independent Spent Fuel Storage Installation (ISFSI). The classification system referenced in NEI 99-01, Rev. 6 has been endorsed by the NRC and offers a standard method for classifying emergencies. EALs are addressed in site procedures and the Permanently Defueled EAL Basis Manual (PDEALBM).

This Plan addresses two (2) classifications of emergencies (UNUSUAL EVENT and ALERT), which represent a hierarchy of emergencies based on potential accidents that could occur at CR3. CR3 maintains the capability to assess, classify and declare an emergency condition within 30 minutes of information becoming available to Control Room personnel that conditions have reached an EAL threshold.

8.1.1 Unusual Event Events are in progress or have occurred which indicate a potential degradation of the level of safety of the Plant or indicate a security threat to facility protection has been initiated. No release of radioactive material requiring off-site response or monitoring are expected. The State of Florida and the NRC are notified of an UNUSUAL EVENT.

The purpose of the UNUSUAL EVENT classification is to bring the on-shift staff to a state of readiness and to provide for systematic handling of event information and its related decision making.

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PDEP Rev. 2 Page 8-2 8.1.2 Alert Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the Plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA PAG exposure levels.

As in the case of the UNUSUAL EVENT, the ALERT classification includes emergency situations which are not expected to threaten the public, but for which notification of the State of Florida and the NRC is required.

The purpose of the ALERT classification is to assure that the CR3 ERO is available to respond to perform event mitigation, radiation monitoring if required, and to provide the State of Florida and the NRC with current information on Plant status.

8.2 EMERGENCY ACTION LEVELS AND POSTULATED ACCIDENTS Both emergency classifications are characterized by EALs consisting of specific instrument readings, alarms, and observations which are used either in combination or singularly to tell the on-shift staff that an initiating condition has occurred, thus allowing the EC to declare the appropriate level of emergency. These EALs are used to assure that the initial classification of emergencies can be accomplished rapidly, allowing for the prompt identification of the nature of mitigating activities needed.

EALs and Initiating Conditions are provided under the following categories for permanently defueled stations:

Abnormal Radiation Levels / Radiological Effluent Hazards and Other Conditions Affecting Plant Safety System Malfunction EALs and Initiating Conditions are also provided for the ISFSI These conditions include accidents evaluated in the FSAR. Specific guidance for classifying emergencies is found in site procedures and the Permanently Defueled EAL Basis Manual (PDEALBM).

EALs shall be reviewed with State of Florida and Citrus County government authorities on an ANNUAL basis.

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PDEP Rev. 2 Page 9-1 9.0 NOTIFICATION METHODS AND PROCEDURES To provide prompt notification of affected personnel and emergency response organizations in the event of an emergency at CR3, DEF has established means for notification and dissemination of emergency messages. These means utilize both normal communications systems and those dedicated for emergency use.

Emergency message formats have been established to disseminate appropriate emergency information to affected personnel and organizations.

9.1 BASIS FOR NOTIFICATION The analyses of the credible design basis events and consequences indicate that there are no postulated accidents that would result in off-site dose consequences that are large enough to require off-site emergency planning. The notification of personnel and emergency response organizations is commensurate with the hazard posed by the emergency. The EMERGENCY CLASSIFICATION SYSTEM described in Section 8.0 is the primary bases for notification and has been mutually agreed upon by applicable State and Federal response organizations.

The EC is responsible for identifying the appropriate emergency classification, declaring the emergency and initiating emergency notifications.

9.2 MEANS OF NOTIFICATION Various communications systems, as described in Section 10.0 are available to perform emergency notifications. As noted above, the EC is the primary individual for initiating notifications; however, the EC may designate an individual to carry out appropriate notifications. Implementing procedures and various directories identify organizations and individuals to be notified and contain appropriate listings of telephone numbers.

The following sections describe the means of notifying, alerting, and mobilizing the various emergency response organizations or individuals.

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PDEP Rev. 2 Page 9-2 9.2.1 CR3 Plant Staff Following declaration of an emergency, the EC will notify the Station Duty Manager.

The Station Duty Manager will then notify the General Manager Decommissioning of an emergency condition. These notifications will be completed via the Plant phone system or a commercial telephone which may include land line and/or a wireless device capable of receiving text messages. Notification of other key personnel may be made by commercial telephone and include land lines and/or wireless devices capable of receiving text messages.

On-site staff is informed of an emergency condition through the use of both audible and visual alarms and the Public Address (PA) System. Separate, distinct, audible alarms are available to alert personnel of a FIRE, building evacuation and PROTECTED AREA evacuation. The EC or designee will use the CR3 PA System to inform personnel of specific emergency conditions or instructions, and to activate the CR3 ERO. In the event that personnel required to staff emergency positions are not on-site, they may be contacted through manual notification by commercial telephone and/or wireless devices capable of receiving text messages.

9.2.2 CR1 & 2 and 4 & 5 Control Centers Upon declaration of an emergency, the EC or a delegate will notify the CR1 & 2 and the 4 & 5 Control Centers by Plant phone or other available means, and an appropriate response will be initiated. The EC or a delegate will provide further instructions, as required.

9.2.3 Nuclear Regulatory Commission The NRC Operations Center will be notified of an emergency via the ENS, a designated phone line available in the CR3 Control Room. Upon contact with the NRC, a description of the emergency is provided, along with potential consequences.

Commercial phone lines will be used as a backup means of notification in the event of failure of the ENS.

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PDEP Rev. 2 Page 9-3 9.2.4 State Watch Office-Tallahassee The State Watch Office-Tallahassee (SWOT) will be notified of an emergency via the SHRD. The commercial telephone systems serves as back-up communications systems. Upon contact, the content of the Florida Nuclear Plant Emergency Notification Form will be provided. The SWOT will notify the Florida DEM and Citrus County officials of an emergency at CR3.

9.2.5 Medical Support Organizations If an emergency involves personnel injury, the EC can request assistance from off-site medical support organizations. Based on the type of injury and degree of possible contamination, the requirements for medical care will be determined, and the appropriate medical facility and personnel needed to accompany the injured personnel will be notified.

9.3 EMERGENCY MESSAGES Notification of an emergency is provided verbally to the SWOT based on the content of the Florida Nuclear Plant Emergency Notification Form. The form may also be transmitted electronically. The content of the initial notification and follow-up message form has been established in conjunction with the State of Florida and includes the date and time of the incident, the class of emergency, and the EAL. Appropriate identification of the caller and time of the notification are also provided.

As additional information describing the emergency situation and local conditions becomes available, supplemental messages containing additional detail are provided.

9.4 PUBLIC ALERT AND NOTIFICATION The analyses of the credible design basis events and consequences indicate there are no postulated accidents that would result in off-site dose consequences that are large enough to require off-site emergency planning. Prompt notification of the public, particularly to take PROTECTIVE ACTIONS such as sheltering or evacuation, is not necessary. However, Federal, State and local emergency response organizations maintain the capability to disseminate appropriate information regarding an emergency at CR3.

Also, DEF maintains the capability to interface with the media and disseminate information during an emergency, if necessary.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 41 of 87

PDEP Rev. 2 Page 10-1 10.0 EMERGENCY COMMUNICATIONS 10.1 GENERAL GUIDELINES Several modes of communication are available to transmit information within CR3; throughout the Crystal River Energy Complex; and to various locations off-site during normal and emergency conditions. In the event of an emergency at CR3, these communications systems provide the appropriate means for alerting or activating emergency personnel in each response organization and allow continued means for contact throughout the emergency.

The various communications systems provided for both on-site and off-site communications are used on a regular basis or tested periodically in accordance with Plant procedures. Periodic testing or frequent use of each system is conducted as follows:

System Use/Testing Public Address Exchange System Frequent Use Commercial Telephones Frequent Use Portable UHF Radios Frequent Use Maintenance Telephones Frequent Use Evacuation and Fire Alarms Tested Monthly SHRD Tested Monthly ENS Tested Daily Duke Intra-Company System Frequent Use Satellite Phones Tested Annually The communications systems available between on-site locations and personnel are described in Sections 10.2 thru 10.9. All systems are available in the CR3 Control Room on a 24-hour basis to allow prompt notification and activation of emergency response organizations.

During an emergency, use of all communications systems is limited to those necessary and appropriate contacts related to the emergency. Specific individuals are designated to provide notifications and communications. The Emergency Coordinator will assure effective use of communications systems and provide for timely, knowledgeable review and dissemination of messages and is responsible for overall awareness and coordinated dissemination to responsible ERO positions.

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PDEP Rev. 2 Page 10-2 10.2 PAX SYSTEM The Public Address Exchange (PAX) System consists of a network of phones and speakers strategically located throughout CR3. PAX is utilized for mass communications, paging, special instructions, and announcements. In addition, the PA system is utilized as an alarm system supported by strobe lights in high noise level areas.

10.3 COMMERCIAL TELEPHONES Commercial telephones are located throughout the CR3 site and serve as a means to communicate off-site.

10.4 PORTABLE UHF RADIOS Portable UHF radios are available for limited communication on the CR3 site.

During normal shift operations, key personnel have UHF radios available for communication. These radios are the primary communications link during a FIRE.

This system utilizes UHF repeaters and antennas located in the Plant and Energy Complex to aid in radio communications. Earphones are provided for use in high noise areas.

10.5 MAINTENANCE TELEPHONES These telephones are normally used for communication between the Control Room and personnel conducting maintenance operations.

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PDEP Rev. 2 Page 10-3 10.6 EVACUATION AND FIRE ALARMS The evacuation and FIRE alarms are actuated manually from the Control Room if conditions warrant.

10.7 STATE HOT RINGDOWN The SHRD serves as the primary means of communications between the CR3 Control Room and the SWOT. CR3 is capable of dialing all stations on the circuit or calling selected station(s). The network includes CR3, the SWOT, Citrus County EOC and the DHBRC. All stations on the network can call all or a selected number of other stations by utilizing a dial-up code.

10.8 EMERGENCY NOTIFICATION SYSTEM In the event of an emergency at CR3, the NRC Operations Center in Rockville, Maryland will be notified via the ENS. Emergency notification, plant status information and radiological information are communicated via the ENS.

10.9 SATELLITE TELEPHONES Satellite telephones are available in the Control Room and provide an additional back-up means of communication off-site.

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PDEP Rev. 2 Page 11-1 11.0 PUBLIC EDUCATION AND INFORMATION The EC will notify Duke Energy Corporate Communications following a CR-3 emergency event declaration. The Corporate Nuclear Communications emergency response plan requires that the Corporate Communications be notified at an ALERT classification. The Corporate Communications will be notified at the companys Charlotte headquarters and a near-site response team will be established for CR-3.

The near-site response team will be staffed with a company spokesperson and media communicators, who will provide local interaction with the media. If an event occurs at CR-3, information will be disseminated to the public in a timely manner.

Briefings with media organizations will be coordinated between Duke Energy Corporate Communications and the near-site response team per Corporate Communications protocols.

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PDEP Rev. 2 Page 12-1 12.0 EMERGENCY FACILITIES AND EQUIPMENT Facilities and equipment available to augment the CR3 ERO and effectively mitigate and control emergencies are identified in this section. Where adequate description is provided in the CR3 FSAR, such information is incorporated by reference.

The following paragraphs describe these emergency facilities. Subsequent sections describe the emergency equipment and other means of providing emergency support through these centers. Communications systems available at each center have been described in Section 10.0.

The State of Florida has facilities to carry out their emergency response activities and interface with DEF.

12.1 EMERGENCY RESPONSE FACILITIES The ability of Plant personnel to monitor Plant systems and equipment on a continuous basis is maintained in various locations at CR3 and allows the ERO to effectively control and support emergency response activities. Some of these locations (e.g., Control Room and 95' elevation) are staffed on a regular basis while others are staffed in the event of an emergency.

12.1.1 CR3 Control Room The principal emergency control center is the CR3 Control Room. The Control Room contains instrumentation and control systems necessary to identify and continuously monitor emergency conditions and for taking various corrective and on-site PROTECTIVE ACTIONS. Section 12.2 identifies the systems important for emergency response and detailed descriptions are provided in the FSAR. The Control Room has reliable voice and data communications capabilities with the SWOT and the NRC.

During an emergency, Control Room activities are conducted under the direct supervision of the Shift Supervisor, who can maintain contact with augmented staff located in the Emergency Support Center (ESC). The Control Room is staffed as described in Section 6.0 and additional support can be obtained from the augmenting staff responding to the ESC, as required.

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PDEP Rev. 2 Page 12-2 12.1.2 Emergency Support Center (ESC)

The ESC is provided as a point of assembly for augmented resources providing technical expertise to assist the EC and the Control Room in the assessment, mitigation and response to an emergency. It also supports the dispatch of emergency teams. The ESC is located in the Control Complex adjacent to the Control Room. The Control Complex contains communications equipment, emergency radiation monitoring equipment, emergency respiratory devices, and an emergency kit containing protective clothing and other supplies (see Table 12.1).

Augmented staff responding to the ESC and the Control Room have access to up-to-date technical documentation, including drawings, system information and procedures to enable mitigation planning and support of Control Room staff.

Communications systems available in the Control Complex are described in Section 10.0.

12.1.3 Nuclear Security Operations Center The Nuclear Security Operations Center (NSOC) provides appropriate accountability of individuals leaving the PROTECTED AREA and controls access to the facility.

This building serves as the key location for security activity and control in accordance with site procedures. The NSOC is equipped to implement all appropriate security measures and is the primary location for personnel accountability. Under certain meteorological conditions, evacuation of the NSOC may be necessary and personnel accountability can be conducted at an alternate location as directed by the EC.

12.1.4 Alternate ERO Augmentation Facility DEF maintains an off-site facility that would be available as a staging area for augmentation staff in the event that access to CR3 is impeded. The alternate facility is capable of:

Communicating with the Control Room and Plant Security Performing notifications to the SWOT Enabling emergency repair and damage control teams to begin planning actions to mitigate the consequences of an event Supporting a rapid response as soon as the site is deemed accessible The alternate facility is located at the Duke Energy Operations Center in Inverness.

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PDEP Rev. 2 Page 12-3

12.2 ASSESSMENT

SYSTEMS AND EQUIPMENT DEF maintains or has access to data from monitoring systems essential for initiating emergency measures and performing accident assessment. This includes monitoring systems for radiological conditions, hydrology, meteorology, and Plant processes.

12.2.1 Radiation Monitoring System DEF maintains the radiation monitors described in the Permanently Defueled EAL Basis Manual (PDEALBM) that monitor areas near the Spent Fuel Pool, the Control Room, and that monitor gaseous and liquid releases. Portable radiation monitoring instruments are maintained to support ISFSI operations including transfer operations of the Dry Shielded Canister (DSC) to the Horizontal Storage Module (HSM) and for monitoring of the spent fuel while in storage in the HSM. Additional detail regarding the Radiation Monitoring System is contained in the FSAR. Field radiation monitoring capabilities are described in Section 13.2.2 of the PDEP.

Installed and portable radiation monitoring and sampling equipment, including dedicated emergency response equipment are maintained.

12.2.2 Hydrologic Monitoring Systems Off-site hydrologic monitoring data is available to DEF from the Southwest Florida Water Management District which maintains monitoring wells throughout Citrus County. Additional hydrologic data could be obtained from the public water supplies identified in the FSAR.

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PDEP Rev. 2 Page 12-4 12.2.3 Meteorological Monitoring Systems DEF acquires meteorological data from a meteorological tower located on-site.

The following meteorological parameters are measured:

Wind Speed, 175 feet Wind Direction, 175 feet Wind Speed, 33 feet Wind Direction, 33 feet Ambient Temperature, 175 feet Ambient Temperature, 33 feet Delta Temperature (Stability Class)

Sigma Theta (Wind Range), 33 feet (Stability Class) (Local readout only)

Rainfall (near bottom of tower) (Local readout only)

Real time meteorological data is digitally displayed in the Control Room and computerized data acquisition is capable of collecting real time data.

DEF maintains the capability to obtain meteorological data from other sources if the meteorological tower data is unavailable.

12.2.4 Plant Process Monitoring Systems Annunciator and computer alarms are provided for a variety of parameters including the Spent Fuel Cooling System to indicate SF Pool level, temperature, and pump status.

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PDEP Rev. 2 Page 12-5 12.3 PROTECTIVE FACILITIES AND EQUIPMENT 12.3.1 Fire Protection System The Fire Protection Plan outlines FIRE protection, FIRE detection, and FIRE suppression activities at CR3. These systems are designed to detect and alert CR3 personnel of excess temperature or FIRE conditions in specified areas of the Plant and to automatically actuate fixed FIRE extinguishing systems in affected areas.

A variety of manual FIRE extinguishing equipment is also available to the Fire Brigade.

12.4 EMERGENCY SUPPLIES Emergency equipment and supplies to carry out the provisions of the Emergency Plan are specified in Plant procedures. Table 12.1 lists typical emergency equipment and supplies and their locations.

Emergency kit contents listed in Table 12.1 are inspected, inventoried, and operationally checked at least quarterly and anytime a kit is opened and used, in accordance with HPP-409, Inventory and Availability of Emergency Supplies /

Equipment." Sufficient reserves of instruments/equipment are provided to replace those which are removed from emergency kits for calibration or repair. Calibration of instruments has been established at intervals recommended by instrument suppliers, or as required by Federal regulations.

12.5 FIRST AID FACILITIES First aid supplies and equipment are located throughout CR3. Qualified personnel are available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day to provide medical treatment as referenced in Section 16.0.

Radiological wound monitoring on-site is performed using an appropriate high sensitivity detector (e.g., HP-210 probe). If the severity of the wound restricts decontamination efforts by radiation protection personnel, the injured personnel will be referred to off-site medical personnel or transported to an off-site medical facility for treatment and further decontamination.

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PDEP Rev. 2 Page 12-6 12.6 DAMAGE CONTROL EQUIPMENT Fire protection systems described in Section 12.3.1 are designed and maintained to mitigate the effects of FIRE.

The Plant elevation has been set at a level in excess of expected water surges, and the buildings have been designed for wind speeds in excess of probable maximum velocities.

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PDEP Rev. 2 Page 12-7 TABLE 12.1 TYPICAL EMERGENCY EQUIPMENT/SUPPLIES AND LOCATIONS Kit Contents Compass Pens, Pencils Protective Clothing Calculator Air Sampler Heads Plant Survey Map Tape, Barricade Area Map Thermoluminescent Dosimeter (TLD) Badges Tape, Masking Radiation Signs HP Probes Plastic Rain Gear Check Source Smears Area Monitor (or Electronic Dosimeters)

Air Filters, Particulate Batteries Charcoal Cartridges Flashlight Silver Zeolite Cartridges Felt Marker, Black Labeled Envelopes Shoe Covers SH-4 Sample Mount and Holder Gloves Bottle, for water samples Pad Paper Electronic Dosimeters Kit Locations CR3 Control Room Control Complex U.S. Nuclear Regulatory Commission 3F0815-01 Page 52 of 87

PDEP Rev. 2 Page 13-1 13.0 ACCIDENT ASSESSMENT Effective response to a potential emergency situation requires assessment to determine the nature of the emergency and its actual and potential consequences.

DEF has established various methods to evaluate and monitor the effects of a potential emergency at CR3 and has the appropriate means to assure adequate assessment.

13.1 RANGE OF ASSESSMENT ACTIVITIES The ASSESSMENT ACTIVITIES required to evaluate a particular emergency depend on the specific nature and classification of the emergency. Activities could range from increased surveillance of monitors in the Control Room to surveys of affected Plant areas During an UNUSUAL EVENT, ASSESSMENT ACTIVITIES required to fully identify the nature of the emergency are completed to determine the possibility of an escalation in the severity of the situation. At an ALERT classification, the ERO is activated to assist in assessment functions, such as performing confirmatory surveys or radiation monitoring, as required.

The EC determines the initial classification of the emergency based on systems and effluent parameter values or other observations as presented in the EALs. In order to provide effective coordination and direction of the CR3 ERO, the EC utilizes the minimum augmented staff, emergency teams, systems and equipment for continuing assessment of accident severity and means of control and potential impact on CR3 and Energy Complex personnel. The EC institutes ASSESSMENT ACTIVITIES prescribed by implementing procedures as needed to accurately classify each emergency and to maintain accurate classification throughout the emergency.

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PDEP Rev. 2 Page 13-2 13.2 ACCIDENT ASSESSMENT METHODS Accident ASSESSMENT ACTIVITIES carried out at CR3 are aimed at three (3) basic areas: (a) determining the nature of the emergency; (b) determining or estimating the nature and quantities of an actual or potential radioactive release; and (c) assessing the actual or potential dose to CR3 and Energy Complex personnel.

13.2.1 Incident Determination ASSESSMENT ACTIVITIES are necessary to determine the means to bring the emergency situation under control and to identify the specific affected areas, systems, and components. Based on this assessment, appropriate corrective actions can be identified and implemented.

The Control Room staff monitors instrumentation, including SF Pool parameters and process and radiation monitoring systems, and provides early identification of system status and potential for change. Augmented staff is provided appropriate data to assess the nature of the emergency and, in combination with the on-shift staff, recommend control actions to mitigate the emergency and potential effects.

Plant procedures provide instructions on identifying and responding to various types of abnormal and emergency situations involving Plant systems.

13.2.2 Radiation Monitoring and Estimating Release Potential Methods have been established to monitor radiation levels in the PROTECTED AREA and OWNER CONTROLLED AREA and to determine the nature of actual or potential radioactive releases. These activities range from radiation surveys to confirm the emergency classification to detailed measurement and analysis of liquid and gaseous samples to identify key isotopes or the nature of damage.

Control Room instrumentation is used by the operating staff to monitor SF Pool inventory and cooling capabilities and to obtain early indication of any release of radioactivity. The Plant process and effluent radiological monitoring systems and associated alarms described in Section 12.0 are utilized for this purpose.

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PDEP Rev. 2 Page 13-3 13.2.2 Radiation Monitoring and Estimating Release Potential (Continued)

In-Plant evaluations and radiological surveys are performed by radiation monitoring personnel. Upon activation of these personnel, the Radiation Controls Coordinator and EC determine area(s) to be surveyed. The radiation monitoring personnel conduct a general beta-gamma survey of the selected area(s), performs gross particulate air samples, conducts smear surveys, and establishes RCAs. Survey results are forwarded to the Radiation Controls Coordinator for evaluation and assessment. The Radiation Controls Coordinator will advise the EC of radiological status. The need for additional or continuing surveys is established by the EC.

Provisions have been established through implementing procedures to sample and analyze in-plant atmosphere and effluent releases for additional information.

Dose levels are determined at the EAB as soon as possible following an accidental release of radioactive material for EAL evaluation. Implementing procedures provide instructions for sampling plant effluents.

13.2.3 Dose Assessment Emergency workers are provided with dose measurement instrumentation.

Dose assessment capabilities are available on a 24-hour per day basis.

Implementing procedures provide a rapid method of determining the magnitude of a radioactive release from CR3 during an accident condition. A computerized and manual method can be used along with radiological data to generate dose projections for EAL evaluation. Meteorological data can be obtained from either off-site or CR Fossil units.

Radiological surveys and monitoring outside of the OWNER CONTROLLED AREA are not anticipated as any credible accident or beyond design basis accident can result in radioactive releases or direct radiation doses which exceed EPA PAGs beyond the EAB. However, in the event the State of Florida elects to conduct radiological surveys and monitoring, these activities would be coordinated by the State and conducted by the State Radiological Emergency Team.

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PDEP Rev. 2 Page 14-1 14.0 PROTECTIVE RESPONSE [R2]

The Radiation Protection Program assures that protective measures are provided for the purpose of safeguarding the health of all personnel working at the Energy Complex. DEF is responsible for the implementation of these protective measures. Implementation guidelines for PROTECTIVE ACTIONS are contained in implementing procedures.

14.1 ON-SITE PROTECTIVE MEASURES The protective measures serve as the basis for additional measures required during an emergency. Some of the standard and emergency measures are discussed in the following sections.

14.1.1 Radiation Protection Program A detailed description of the Radiation Protection Program is provided in Section 15.0 of this Plan. The Radiation Protection Program requires the use of protective equipment to minimize personnel exposure and to maintain exposure limits within 10 CFR 20. The external dosimetry program includes provisions and requirements for use of both permanent record and self-reading dosimeters (e.g., pocket or electronic dosimeters). Dosimeter ranges are sufficient to measure both planned routine and foreseeable accident doses. Implementing procedures associated with this Plan establish requirements for distributing dosimeters to emergency responders, including those individuals responding to CR3 from off-site locations. Internal doses are typically estimated through the use of whole body counting and/or in-vitro sampling and analysis routines. Implementing procedures associated with this Plan or the Radiation Protection Program establish requirements for determining internal doses based on in-vivo or in-vitro analyses results or by assessment of individual exposures to airborne radioactive materials.

Implementing procedures also establish guidance for wearers to periodically read their self-reading dosimeters to maintain compliance with emergency exposure guidelines.

DEF maintains individual dose records in accordance with the requirements of 10 CFR 20 and the Radiation Protection Program and its supporting procedures.

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PDEP Rev. 2 Page 14-2 14.1.2 Emergency Exposure Guidelines Protective measures of on-site personnel are detailed in implementing procedures for circumstances in which Plant personnel exposure may otherwise exceed allowable limits. These procedures address corrective and PROTECTIVE ACTIONS, use of protective equipment, and personnel evacuation and accountability.

Table 14.1 provides exposure guidelines for on-site emergency activities.

These measures are determined from considerations of personnel protection and not by emergency classification.

14.2 PERSONNEL ASSEMBLY, SHELTERING, OR EVACUATION The EC has the authority to initiate personnel assembly, sheltering, or evacuation of CR3. Personnel assembly can be used to facilitate communication, accountability, and supervision during an emergency. When assembly is requested, personnel will stop work, shut down potentially hazardous equipment, and proceed to the pre-designated LOCAL ASSEMBLY AREAS. LOCAL ASSEMBLY AREA accountability will take place and the results will be reported to the EC when requested. At a declaration of an ALERT or at any time deemed necessary, the EC will direct non-essential personnel to LOCAL ASSEMBLY AREAS.

Plant personnel are expected to report to LOCAL ASSEMBLY AREAS immediately following the Public Address System announcement. The Local Area Supervisor is required to notify Security at the Central Alarm Station (CAS) if an individuals location is not determined in approximately 30 minutes from the time assembly begins. Personnel will remain in the assembly areas until instructed to return to work, report to the Main Assembly Area, or leave the Crystal River Energy Complex.

Accountability of all personnel onsite will be accomplished during local assembly and the names of missing individuals will be determined within 60 minutes of the start of an emergency (at a declaration of an ALERT or at any time deemed necessary).

Onsite individuals will be accounted for continuously thereafter.

The EC will initiate evacuation of the PROTECTED AREA if deemed necessary to ensure personnel safety. Evacuation of the CR3 PROTECTED AREA will be coordinated by the Director Nuclear Plant Security, or a designated representative. In the event of an evacuation of the PROTECTED AREA, Plant personnel will report to the Main Assembly Area for organization and supervision.

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PDEP Rev. 2 Page 14-3 14.2 PERSONNEL ASSEMBLY, SHELTERING, OR EVACUATION (Continued)

An evacuation may affect the CR3 PROTECTED AREA or the Energy Complex.

The EC will determine the specific areas to be evacuated. Evacuation of all other portions of the Energy Complex will be coordinated by CR3 Security.

Procedural guidance has been established as an aid in implementing an evacuation.

Plant procedures contain instructions to evacuate specific work areas or buildings whenever emergency conditions create a localized radiological hazard.

14.3 OFF-SITE PROTECTIVE MEASURES The analyses of the credible design basis events and consequences indicate there are no postulated accidents that would result in off-site dose consequences that are large enough to require off-site protective measures.

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PDEP Rev. 2 Page 14-4 TABLE 14.1 GUIDELINES FOR PROTECTIVE ACTION RECOMMENDATIONS FOR NON-ESSENTIAL ENERGY COMPLEX PERSONNEL GUIDELINES FOR DEF EMERGENCY WORKER EXPOSURE ACTIVITY GUIDELINE CONDITION All occupational exposures 5 rem All reasonably achievable actions have been taken to minimize dose.

Protecting valuable property necessary for public welfare.

10 rem a Exceeding 5 rem unavoidable and all appropriate actions taken to reduce dose.

Monitoring available to project or measure dose.

Lifesaving or protection of large populations 25 rem b Exceeding 5 rem unavoidable and all appropriate actions taken to reduce dose.

Monitoring available to project or measure dose.

Notes: a For potential doses >5 rem, medical monitoring programs should be considered.

b In the case of a very large incident, consider need to raise property and lifesaving response worker guidelines.

NOTE: Reference for this table is Table 2-2 in the EPA PAG Manual.

NOTE: The dose limits listed above are in addition to any annual occupational dose already received.

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PDEP Rev. 2 Page 15-1 15.0 RADIOLOGICAL EXPOSURE CONTROL CR3 maintains a radiological exposure control program to assure that protection against radiological exposure, as set forth in 10 CFR Part 20 and Chapter 170J-1 of the State of Florida Statutes, is provided. This program is implemented through the "Radiological Protection Standard" which covers both normal and emergency radiation protection measures.

15.1 EXPOSURE GUIDELINES During an emergency operation, doses above normal occupational radiation exposure limits may be authorized by the EC for activities such as saving a life, preservation of valuable equipment, or controlling exposure. Table 14.1 provides exposure guidelines for on-site emergency activities.

Actions such as providing first aid or medical treatment, removal of injured personnel, personnel decontamination, or ambulance service could encounter the lifesaving guideline. Measures to reduce exposure should be considered as practical.

Personnel involved in lifesaving actions should be volunteers (healthy and above the age of 45) with the approval and authorization of the EC. If the situation allows, Health Physics personnel should provide recommended courses of action to minimize exposure.

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PDEP Rev. 2 Page 15-2 15.2 RADIATION PROTECTION The purpose of a Radiation Protection Program is to assure that radiation doses received by personnel are kept as low as reasonably achievable and do not exceed the prescribed limits for both normal and emergency conditions. The established measures to provide this assurance include access control, personnel monitoring, and contamination control.

15.2.1 Access Control Strict access control is a primary means to minimize radiation exposure.

Measures are initiated by the EC through the use of the radiation monitoring personnel as described in procedures.

In an emergency in which hazardous radiation levels might be encountered, the radiation monitoring personnel are dispatched. RCAs are established where elevated levels of radiation, contamination, and/or airborne radioactivity may exist.

Within the RCA, areas of varying hazards may be present; these are identified and controlled per Radiation Protection procedures.

During an emergency, a temporary RCA may be set up in other parts of the Plant, as directed by the EC, by barricades, ropes, etc., and be conspicuously posted with precautionary signs.

Radiations Work Permits (RWP)s are utilized to maintain control of personnel radiation exposures. For emergency, short-term, or special situations, an Emergency RWP can be initiated in accordance with procedures.

A Control Point is established, as appropriate, as the point of entrance to and exit from an RCA to ensure personnel are adequately attired with required protective clothing and have proper personnel monitoring devices, and to prevent the spread of radioactive contamination upon exiting.

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PDEP Rev. 2 Page 15-3 15.2.2 Personnel Exposure Monitoring Personal dosimeters are utilized to monitor the exposure of personnel during normal or emergency conditions. Adequate supplies of dosimeters are maintained for use during an emergency. Procedures describe in detail the types of personal dosimeter devices, the manner in which they are to be used, who is to wear them, and how they are to be cared for. Provisions have been established, both on-site and through service organizations, to provide 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day capability to read dosimeters to determine the doses received by emergency workers.

When it is suspected that radioactive materials may have entered the body, appropriate bioassay services and/or special tests shall be performed as stipulated in 10 CFR 20. The determination of the individual's exposure shall be based upon this evaluation.

The CR3 Radiation Protection Program requires that individual exposure records be documented and maintained in order to: (a) evaluate the effectiveness of the Radiation Protection Program; (b) demonstrate and facilitate compliance with procedural requirements and applicable governmental regulations; and (c) reconstruct for legal or medical purposes situations and conditions for analysis of radiation doses received.

15.3 CONTAMINATION CONTROL Various contamination control measures are utilized. These include the access control measures discussed above and means for the decontamination of personnel, areas, and equipment are addressed in Plant procedures and are briefly described below.

15.3.1 Personnel Decontamination During normal or emergency conditions, contamination should be removed from any part of a person's body prior to their leaving the RCA. All personnel decontamination, even during an emergency, will be performed under the supervision of the Health Physics Section and in accordance with Plant procedures.

CR3 maintains dedicated decontamination and clothing supplies on-site. The location of the decontamination supplies are listed in Plant procedures. Decontamination stations, which include a decontamination shower, are located in the Control Complex near the exit to the RCA and on the first floor of the Plant Administration Building.

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PDEP Rev. 2 Page 15-4 15.3.2 Area and Equipment Decontamination Areas and equipment are considered contaminated when there is loose, removable, contamination in excess of levels stipulated in Radiation Protection procedures.

Radioactive material may be shipped following an emergency in accordance with site procedures.

15.3.3 Control of Potable Water and Food Potable water and food supplies are protected from radioactive contamination on-site by the following measures:

a.

All potable water for the Plant site comes from wells located four (4) miles east of the Plant, through an open lime softener at Unit 1.

b.

No food is permitted in the RCA.

c.

Controlled use of hydration station when necessary.

In addition, selected water sources and vegetation around the Plant are routinely analyzed for radioactivity. Also, external radiation field measurements and ambient air samples are analyzed.

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PDEP Rev. 2 Page 16-1 16.0 MEDICAL AND PUBLIC HEALTH SUPPORT Medical assistance is available on-site and off-site for treatment of CR3 personnel.

Various means of transportation are also available to transport individuals for radiological and non-radiological injuries. The following sections describe the available medical support. Table 16.1 summarizes the types of medical treatment for various types of injuries.

The individuals and organizations providing emergency medical assistance as identified in this section either have the capability for evaluation of radiation exposure and uptake or they are provided this capability from DEF in the form of personnel and/or equipment. DEF assures that persons providing these services are adequately prepared to handle contaminated individuals through detailed training classes, drills and exercises. Letters of Agreement with off-site organizations and individuals for medical support are listed in Appendix B.

16.1 ON-SITE FIRST AID First aid assistance at CR3 is designed to handle a wide range of injuries. This task is accomplished by medical response personnel.

16.1.1 Medical Response Personnel The medical response personnel are on-site individuals trained in basic medical procedures and certified by the State of Florida Department of Health, Division of Medical as described in Section 19.0 of this Plan. Medical response personnel are trained to handle injured personnel, with or without radiological considerations.

16.1.2 First Aid Kits First aid kits are located throughout the Plant. The kits are maintained by plant staff personnel.

16.1.3 On-Site Medical Emergency Communications An emergency phone system is available for reporting medical emergencies.

This system enables an individual to report an emergency by dialing "555" on any PAX or 5555 on any conventional intra-Plant phone at CR3, which activates a dedicated emergency telephone in the Control Room. Other communications systems for medical emergencies are available as discussed in Section 10.0 of this Plan.

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PDEP Rev. 2 Page 16-2 16.2 MEDICAL TRANSPORTATION Transportation of injured personnel is available via local emergency medical services, other DEF vehicles, or private vehicles.

16.3 OFF-SITE MEDICAL SUPPORT The following sections identify medical facilities capable of handling various types of injuries.

16.3.1 Seven Rivers Regional Medical Center SRRMC is capable of treating patients with injuries of a non-radiological or radiological nature.

16.3.2 Off-Site Medical Support Plans SRRMC will provide for hospital treatment, medical examinations, and laboratory services for those DEF employees, and other persons designated by DEF.

When local facilities are considered inadequate because of the nature or severity of the injury sustained, the injured person may be referred to a trauma center in Florida or to Oak Ridge, Tennessee - REAC/TS for hospitalization. Oak Ridge Associated Universities (ORAU) operates a research hospital in Oak Ridge, Tennessee for the U.S. Department of Energy. Medical records, including bioassay records, will be maintained permanently by the hospital.

SRRMC has plans for emergency handling of patients from CR3. Agreements with the hospital include:

a.

Coordinating the medical disciplines, which are committed to support the treatment of injuries involving radiation exposure and/or radioactive contamination;

b.

Developing plans, procedures, and training programs for the reception, diagnosis, and treatment of injured personnel;

c.

Designating the physical facilities and equipment to be used for initial emergency care and subsequent definitive care and treatment; and

d.

Designating physicians and medical support personnel and alternates to handle radiation emergency patients.

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PDEP Rev. 2 Page 16-3 TABLE 16.1

SUMMARY

OF ACTIONS FOR EMERGENCY MEDICAL TREATMENT Type of Injury Minor Injury Not Requiring Doctor Minor Injury Requiring Medical Assistance Serious Injury Life or Death Situation Actions 1 Treat on-site.

Notify Control Room or transport off-site.

Notify Control Room, then transport to SRRMC.

Notify Control Room, then transport to SRRMC.

Note 1 Actions applicable to contaminated and non-contaminated injuries.

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PDEP Rev. 2 Page 17-1 17.0 RECOVERY AND RE-ENTRY PLANNING AND POST-ACCIDENT OPERATIONS DEF has established general plans described in the following sections to yield RECOVERY from potential emergencies at CR3.

17.1 RE-ENTRY PLANS RE-ENTRY into affected areas of CR3 may be required during the early stages of an emergency. Entry will be required for one or more of the following reasons:

a.

To search for personnel not accounted for;

b.

To perform operations or repairs to minimize or eliminate the source of the emergency;

c.

To determine more definite emergency RCA boundaries;

d.

To perform rescue operations; and

e.

To save property.

Personnel performing these activities will be approved by the EC. The team will be thoroughly briefed beforehand regarding their actions while in the evacuated area.

Efforts will be made to minimize exposure and all individuals will be briefed on emergency exposure and the risk involved with each mission.

Table 14.1 provides exposure guidelines for on-site emergency activities.

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PDEP Rev. 2 Page 17-2 17.2 EMERGENCY TERMINATION AND NOTIFICATION Termination of an emergency status is the responsibility of the EC. This decision will be based on the following considerations:

a.

Conditions no longer meet an EAL and it appears unlikely that conditions will deteriorate.

b.

Plant releases of radioactive materials to the environment are under control (within Tech Specs).

c.

In-plant radiation levels are stable or decreasing, and are acceptable given the Plant conditions.

d.

The operability and integrity of power supplies, electrical equipment and Plant instrumentation including radiation monitoring equipment is acceptable

e.

All required notifications have been made.

f.

Off-site conditions do not unreasonably limit access of outside support to the station and qualified personnel and support services are available.

g.

Radiological and Plant conditions permit resumption of normal occupational exposure limits to continue mitigation/repair activities.

The EC is also responsible for providing notification of the emergency termination and initiation of RECOVERY operations to the NRC, State of Florida (SWOT),

the CR3 ERO, and other organizations that may be providing on-site support.

17.3 RECOVERY OPERATIONS RECOVERY operations begin immediately following emergency termination.

17.3.1 Recovery Plan RECOVERY operations will address the specific emergency circumstances.

RECOVERY planning includes equipment to be repaired or replaced, licensing implications, special training requirements, offsite support, and determination of causes and consequences. Site procedures addressing RECOVERY operations provide an outline for a short term RECOVERY plan.

The General Manager Decommissioning shall be responsible for the development and implementation of the RECOVERY plan and shall provide for detailed monitoring of the implementation and status reporting. The General Manager Decommissioning also has the authority to revise or halt activities as circumstances dictate.

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PDEP Rev. 2 Page 18-1 18.0 DRILLS AND EXERCISES 18.1 PLANNING DRILLS AND EXERCISES Periodic drills and exercises are conducted to test the state of emergency preparedness of CR3 and response organizations. Drills and exercises shall be conducted to meet all or part of the following objectives:

a.

Assure that the participants are proficient in performing their respective duties and responsibilities;

b.

Evaluate the adequacy of the CR3 PDEP and the methods used in the Emergency Plan Implementing Procedures;

c.

Test communications networks and systems; and

d.

Check the availability and operability of emergency supplies and equipment The General Manager Decommissioning is responsible for oversight of the planning, scheduling, and coordination of all emergency preparedness-related drills and exercises and shall ensure that all or part of the following guidelines are utilized:

a.

Personnel are assigned to prepare a scenario;

b.

Efforts are coordinated with other participating emergency personnel, organizations, and agencies;

c.

A date is scheduled for drill/exercise execution and observers are assigned;

d.

A critique of the drill/exercise is conducted;

e.

Personnel are assigned to correct any deficiencies;

f.

Deficiencies are corrected; and

g.

Documentation is prepared for record retention of training conducted.

Scheduled drills and exercises will be held involving appropriate emergency personnel.

These drills and exercises shall be conducted, simulating as closely as possible actual emergency conditions, and may be scheduled such that one or more drills or exercises are held simultaneously. Drill and exercise scenarios can involve participation of several emergency teams and all or specific parts of the ERO, including varying degrees of participation by response organizations.

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PDEP Rev. 2 Page 18-2 18.2 SCENARIO DEVELOPMENT A scenario will be prepared for each drill and exercise. The scenario shall include, but not be limited to, the following:

a.

The basic objective(s) of the drill or exercise;

b.

The date(s), time period, location(s), and participating organizations;

c.

The simulated event;

d.

A time schedule of real and simulated initiating event; and

e.

A summary describing the conduct of the drill or exercise. Items which may be addressed include simulated casualties, off-site organization assistance, rescue of personnel, use of protective clothing, deployment of Radiological Monitoring Personnel; and

f.

Information describing conduct of the drill or exercise, such as ground rules, instructions for Controllers, etc.

Drill and exercise scenarios will be developed that incorporate a wide range of scenario elements.

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PDEP Rev. 2 Page 18-3 18.3 DRILL AND EXERCISE REQUIREMENTS 18.3.1 Training Drills Training drills serve as elements of training programs in which individuals demonstrate their ability to perform assigned emergency functions. During a training drill, on-the-spot correction of erroneous performance should be made and a demonstration of the proper performance should be offered. Problems should be noted for discussion as part of the training drill critique. Training drills shall be conducted at the frequencies indicated below:

a.

Communication Drills Monthly - Communication between CR3 and the State of Florida EOC shall be demonstrated.

These drills shall also include the aspect of understanding the content of messages.

b.

Medical Emergency Drills Annually - The drill will involve medical response personnel and include a simulated contaminated individual and may also allow provisions for participation by local support agencies (i.e., ambulance and off-site medical facilities). The off-site portions of the drill may be performed as part of the Biennial Exercise.

c.

Radiological Monitoring Annually - A drill involving radiation monitoring personnel will include monitoring of accessible areas within the Plant and include area radiation monitoring and air sampling techniques. The drill will also allow provisions for evaluating communications and recordkeeping performed by members of the emergency team.

Semi-Annually - Health Physics drills will involve response to, and analysis of, simulated elevated airborne samples and direct radiation measurements in the environment.

Annually - An analysis of liquid samples with actual elevated radiation levels will be included in a health physics drill.

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PDEP Rev. 2 Page 18-4 18.3.1 Training Drills (Continued)

d.

Fire Drills These drills shall be conducted at a FREQUENCY designated by, and in accordance with the Fire Protection Plan.

e.

Assembly and Accountability Drills Annually - An assembly and accountability drill shall be conducted.

The drill shall include identifying the locations of all individuals onsite.

Successful demonstration of assembly and accountability as a part of the Biennial Exercise shall serve as the successful completion of this drill requirement in that calendar year.

f.

Staff Augmentation Drills Annually - A staff augmentation drill involving the minimum ERO positions shall be conducted between 6 p.m. and 4 a.m. or on the weekend. The drill shall be unannounced and can be conducted via phone contact, staffing of the facility or as part of a training drill.

Drill requirements may be satisfied as part of the Biennial Exercise. A critique shall be conducted as soon as practical after each drill or exercise. The critique shall evaluate the ability of the organization to respond to a simulated emergency situation.

18.3.2 Biennial Exercises A Biennial Exercise is conducted every two (2) years and tests the capability and a major portion of the basic elements existing within emergency preparedness plans and organizations. The Biennial Exercise limits the on-the-spot-corrections used in training drills.

The Biennial Exercise is an event that tests the integrated capability and a major portion of the basic elements existing within emergency preparedness plans and organizations. If requested, the State of Florida, the Citrus County Sheriffs Office and local support organizations (firefighting, ambulance and medical services) will be invited to participate to verify this capability to respond to an emergency scenario requiring response. The exercise may satisfy the requirement for certain drills as required by Section 18.3.1.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 72 of 87

PDEP Rev. 2 Page 18-5 18.3.2 Biennial Exercises (Continued)

The scenario should be varied such that all major elements of the Plan are tested within an eight (8) year period. These elements include management and coordination of emergency response, accident assessment, and system repair and corrective action.

A remedial exercise will be conducted if it is determined that the emergency plan was not satisfactorily tested during the biennial exercise such that the NRC cannot find reasonable assurance that adequate protective measures can be taken in the event of a radiological emergency.

18.4 CRITIQUES Emergency Preparedness shall conduct a critique as soon as practicable after training drills and exercises to evaluate the ability of the participating organizations to respond as indicated in this Plan. Recommendations for revisions to the CR3 PDEP, the implementing procedures and/or the upgrading of emergency equipment and supplies as a result of the drill or exercise should be forwarded to the Emergency Planning Coordinator who shall review, coordinate, and assure that appropriate changes are implemented to correct any deficiencies.

A written evaluation shall result from the critique of the Biennial Exercise. The General Manager Decommissioning shall assure that deficiencies are corrected and implemented, and that documentation is prepared and submitted to the Operations and Maintenance Manager for upgrade of the appropriate training program.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 73 of 87

PDEP Rev. 2 Page 19-1 19.0 EMERGENCY RESPONSE ORGANIZATION TRAINING All personnel at CR3 who fill required positions in the ERO will take part in a training program to assure adequate preparedness to assist in an emergency situation.

Specific off-site support resources that may be called upon for emergency assistance will also be invited to participate in appropriate training programs. In general, these training programs provide for the indoctrination of DEF employees and off-site resources to familiarize each individual/organization with their responsibility during an emergency. The Training Program is used to assure all Plant employees, contractor personnel, and Plant visitors receive appropriate initial indoctrination, training, and requalification.

In conjunction with Plant indoctrination, which familiarizes personnel with Plant layout, structures, and systems, specific training programs are in effect for the medical response personnel, emergency mitigation personnel, radiation monitoring personnel, Fire Brigade, and Emergency Coordinators. Table 19.1 provides a summary of the required initial training topics for these personnel. Requalification training topics are based on student and drill feedback, audits, identified deficiencies from drills, and results of the program review by the Emergency Planning Coordinator.

Management is responsible for maintaining appropriate records of emergency preparedness training conducted for the on-site organizations.

Separate training programs will be utilized for non-DEF support resources and will include appropriate DEF interface. Records of this training will be maintained by DEF and the appropriate organization.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 74 of 87

PDEP Rev. 2 Page 19-2 19.1 EMERGENCY RESPONSE ORGANIZATION TRAINING PROGRAM 19.1.1 Medical Response Personnel All medical response personnel are, at a minimum, certified by the State of Florida as Emergency Medical Technicians. Training topics are established as per the State certification requirements.

19.1.2 Emergency Mitigation Coordinator The initial training for the Emergency Mitigation Coordinator consists of the emergency mitigation personnel topics listed in Table 19.1. Personnel will be retrained annually on topics that are determined as discussed in Section 19.0.

19.1.3 Emergency Mitigation Personnel The initial training for emergency mitigation personnel consists of topics listed in Table 19.1. Personnel will be retrained annually on topics that are determined as discussed in Section 19.0.

19.1.4 Radiation Controls Coordinator The initial training for the Radiation Controls Coordinator consists of the radiation monitoring personnel topics listed in Table 19.1. Personnel will be retrained annually on topics that are determined as discussed in Section 19.0.

19.1.5 Radiation Monitoring Personnel The initial training for radiation monitoring personnel consists of topics listed in Table 19.1. In addition, training is accomplished by performing tasks on a routine basis which involve dose assessments and radiation surveys. Personnel will be retrained annually on topics that are determined as discussed in Section 19.0.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 75 of 87

PDEP Rev. 2 Page 19-3 19.1.6 Fire Brigade The training for Fire Brigade members is directed by the Fire Protection Plan and includes initial training, continuing training and drill participation requirements.

19.1.7 Emergency Coordinators The initial training for ECs consists of topics listed in Table 19.1. The training is designed to give the EC the necessary information, experience, and training required to maintain overall control of EMERGENCY ACTIONS at the Energy Complex during an emergency at CR3. Most ECs will be provided training as part of the Certified Fuel Handler Training Program. Other ECs who are unable to attend the Certified Fuel Handler Continuing Training Program will receive training on an annual basis.

19.1.8 Medical Support Personnel [R2]

Medical Support training is provided in conjunction with SRRMC and local emergency medical services. The training for medical support personnel consists of topics listed in Table 19.1.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 76 of 87

PDEP Rev. 2 Page 19-4 TABLE 19.1 EMERGENCY RESPONSE ORGANIZATION TRAINING PROGRAMS I.

Medical Response Personnel A.

As required by State certification requirements II.

Emergency Mitigation Personnel (including Emergency Mitigation Coordinator)

A.

Respiratory Protection B.

Conduct of Emergency Repair C.

RE-ENTRY Procedures D.

Communications E.

Accident Assessment Guideline and Abnormal Procedure Training F.

Review of applicable drill-identified deficiencies and Human Performance Concerns III.

Radiation Monitoring Personnel (including Radiation Controls Coordinator**)

A.

Respiratory Protection/SCBA*

B.

Use of Radiation Protection Procedures C.

RE-ENTRY Procedures D.

Use of Emergency Survey Equipment E.

Communications F.

Field Surveys G.

The Role of Dose Assessment in an Emergency H.

Computerized and Initial Dose Assessment Methods I.

Coordinated Dose Assessment During an Emergency J.

Potential Sources of Radioactive Releases K.

Monitoring of Radioactive Releases L.

Review of applicable drill-identified deficiencies and Human Performance Concerns IV.

Fire Brigade See Fire Protection Plan V.

Emergency Coordinators A.

Introduction to Emergency Planning and Regulatory Perspectives B.

Role of Management During an Emergency C.

Communications D.

Review of applicable drill-identified deficiencies and Human Performance Concerns VI.

State and Local Support Services A.

Radiation Fundamentals B.

Fundamentals of Nuclear Fuel Storage C.

Fundamentals of Radiation Detection and Measurement D.

Management of Radiation Injuries E.

Radiation Protection and Decontamination F.

Warning and Communication Procedures

• Self-Contained Breathing Apparatus (SCBA) training is conducted independently.

• • Respiratory Protection/SCBA training is not necessary for the Radiation Controls Coordinator, since these positions provide direction only and do not implement any actions in the field.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 77 of 87

PDEP Rev. 2 Page 20-1 20.0 RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION OF EMERGENCY PLANS 20.1 EMERGENCY PLANNING COORDINATION The General Manager Decommissioning has overall authority and responsibility for emergency response planning. CR3 Emergency Preparedness develops and updates emergency plans and coordinates these plans with other response organizations.

In the event that licensing actions by the NRC or changes in the State agencies or other off-site resources impact this Plan, Emergency Preparedness is responsible for identifying the particular impact and necessary revisions to the Plan. The Emergency Planning Coordinator reports to the Operations and Maintenance Manager and is designated as having lead responsibility for these functions.

The Emergency Planning Coordinator training will consist of periodic reviews of federal Emergency Preparedness requirements and guidance documents and various site-specific documents related to Emergency Preparedness. Training is supplemented primarily by on-the-job activities and attendance of short courses, seminars, or executive conferences that relate specifically to emergency preparedness.

20.2 PLAN/PROCEDURES REVIEW AND UPDATE The PDEP should be reviewed and verified to be current on an annual basis by the Emergency Planning Coordinator. Revisions to the PDEP and implementing procedures identified in Appendix A will be reviewed in accordance with 10 CFR 50.54(q) requirements.

Procedures listed as implementing procedures in Appendix A shall be reviewed and verified to be current by the appropriate individual in accordance with procedures.

These procedures will be updated as appropriate and will consider improvements identified during drills and training. Comments for changes to these procedures, including observer and participant comments from drill critiques, will be solicited from those who have emergency responsibilities, or other parties involved in the program.

Significant changes should receive, as appropriate, an impact and/or technical review by affected departments.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 78 of 87

PDEP Rev. 2 Page 20-2 20.2 PLAN/PROCEDURES REVIEW AND UPDATE (Continued)

In addition, there shall be a quarterly review and update of the notification rosters used to activate and implement the Plan. These rosters are found in various phone directories.

Review of the PDEP and the plans of support organizations shall consider applicable emergency planning criteria and regulations promulgated by the NRC, as applicable to CR3.

In addition to the above reviews and updates, the Emergency Planning Coordinator shall review and update appropriate support agreements (see Appendix B) as required. Support plans for other groups such as the fossil plant, procurement, and SRRMC may also be reviewed periodically.

20.3 TRAINING The Emergency Planning Coordinator shall assist management in coordinating and/or providing emergency planning-related training. They shall assure that the training programs described in Section 19.0, are properly coordinated to assure adequate qualification, training, and retraining of personnel.

20.4 AUDITS Duke Energy maintains a Corporate Nuclear Oversight Section (NOS) that will support audits of the CR-3 PDEP according to Corporate NOS audit practices and instructions, which meet the requirements of 10 CFR 50.54(t). The audits will be completed by Corporate NOS personnel and will include the review of the CR-3 PDEP, its implementing procedures and practices, training, readiness testing, equipment, and interfaces with State and local governments. The audit will be conducted as soon as reasonably practicable after a change occurs in personnel, procedures, equipment, or facilities that could adversely affect emergency preparedness, but no longer than 12 months after the change.

All elements of the Emergency Preparedness program must be reviewed at least once every 24 months. The evaluation by Corporate NOS personnel ensures independence from the audited CR-3 organization.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 79 of 87

PDEP Rev. 2 Page A-1 PERMANENTLY DEFUELED EMERGENCY PLAN APPENDIX A IMPLEMENTING PROCEDURE LISTING U.S. Nuclear Regulatory Commission 3F0815-01 Page 80 of 87

PDEP Rev. 2 Page A-2 IMPLEMENTING PROCEDURES FOR THE PERMANENTLY DEFUELED EMERGENCY PLAN Implementing procedures specifically address elements of the PDEP that directly aid in the mitigation of, or lessen the impact of, an emergency. These procedures provide direction and information used during an actual emergency in areas such as: assessment of the significance of the emergency condition, augmented staffing, responsibilities and actions of emergency and non-essential personnel, emergency notifications, and assessment of radiological releases.

Procedure No.

Title PDEP* Cross-Reference PDEALBM Permanently Defueled Emergency Action Level Bases Manual EM-205 Personnel Emergency Responsibilities Regarding Discovery, Assembly, Evacuation, and Accountability Within the Protected Area 9.2.1, 14.2 EM-206 Emergency Plan Roster Notification 6.4 EM-211 Duties of the CR3 Nuclear Security Organization 12.1.3, 14.2 EM-501 Operation of the Emergency Support Center (ESC) 6.2.3 EM-502 Conduct of the Emergency Coordinator 6.3.2, 8.2, 9.1, 9.2, 10.1, 13.1, 14.1.2 EM-503 Conduct of the Emergency Mitigation Coordinator EM-504 Conduct of the Radiation Controls Coordinator 6.3.7, 6.3.10, 13.2.2, 15.2.1, Table 14.1 EM-911D Security Threat for Decommissioned Plant N/A HPP-334 Offsite Radiation Monitoring and Control N/A

• Section(s) of the PDEP implemented by or referencing each procedure.

Additional program maintenance procedures describe routine, ongoing actions and responsibilities which enhance and support DEF's state of readiness. These procedures are not referred to for guidance during declared emergencies and address areas such as: PDEP maintenance schedules, communications system descriptions, personnel conduct, selected training procedures and emergency supply inventories.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 81 of 87

PDEP Rev. 2 Page B-1 PERMANENTLY DEFUELED EMERGENCY PLAN APPENDIX B AGREEMENTS WITH SUPPORTING ORGANIZATIONS U.S. Nuclear Regulatory Commission 3F0815-01 Page 82 of 87

PDEP Rev. 2 Page B-2 AGREEMENTS WITH SUPPORTING ORGANIZATIONS The following agreements are reviewed annually and updated as necessary. The documents are kept on file at CR3 and maintained by the Emergency Planning Group.

1.

Citrus County Sheriff's Office

2.

Seven Rivers Regional Medical Center

3.

Nature Coast EMS U.S. Nuclear Regulatory Commission 3F0815-01 Page 83 of 87

PDEP Rev. 2 Page C-1 PERMANENTLY DEFUELED EMERGENCY PLAN APPENDIX C CROSS-REFERENCE TO REGULATORY REQUIREMENTS U.S. Nuclear Regulatory Commission 3F0815-01 Page 84 of 87

PDEP Rev. 2 Page C-2 CROSS-REFERENCE TO REGULATORY REQUIREMENTS The following table provides a cross-reference between this PDEP and applicable regulations.

Regulatory Requirement Corresponding PDEP Section(s) 10 CFR 50.47(b)(1) 5.0 10 CFR 50.47(b)(2) 6.0 10 CFR 50.47(b)(3) 5.0, 7.0, Appendix B 10 CFR 50.47(b)(4) 8.0 10 CFR 50.47(b)(5) 9.0 10 CFR 50.47(b)(6) 10.0 10 CFR 50.47(b)(7) 11.0 10 CFR 50.47(b)(8) 12.0 10 CFR 50.47(b)(9) 13.0 10 CFR 50.47(b)(10) 14.0 10 CFR 50.47(b)(11) 15.0 10 CFR 50.47(b)(12) 16.0 10 CFR 50.47(b)(13) 17.0 10 CFR 50.47(b)(14) 18.0 10 CFR 50.47(b)(15) 19.0 10 CFR 50.47(b)(16) 20.0 10 CFR 50.47(c)(2) 2.1 10 CFR Part 50, Appendix E IV 10 CFR Part 50, Appendix E IV.A 5.0, 6.0, 7.0 10 CFR Part 50, Appendix E IV.B 8.0, 13.0 10 CFR Part 50, Appendix E IV.C 8.0, 9.0 10 CFR Part 50, Appendix E IV.D 9.0, 10.0 10 CFR Part 50, Appendix E IV.E 12.0 10 CFR Part 50, Appendix E IV.F 18.0, 19.0 10 CFR Part 50, Appendix E IV.G 20.0 10 CFR Part 50, Appendix E IV.H 17.0 10 CFR Part 50, Appendix E IV.I 14.0 10 CFR Part 50, Appendix E V Appendix A 10 CFR Part 50, Appendix E VI Not Applicable U.S. Nuclear Regulatory Commission 3F0815-01 Page 85 of 87

SUMMARY

OF CHANGES PDEP Rev. 2 Page SOC 1 DRR 752017 Page / Section Change Reason/References Coversheet Changed Emergency Planning Coordinator name to current EPC Update staffing change Throughout Updated Decommissioning Director to new title, General Manager, Decommissioning SAFSTOR organization title change Throughout DTO or Decommissioned Transition Organization has been replace with the title SAFSTOR organization DTO is now called the SAFSTOR organization Throughout Replaced Plant Manager with Operations and Maintenance Manager SAFSTOR organization title change Throughout Change Emergency Preparedness Coordinator to Emergency Planning Coordinator Correct erroneous title.

Table of Contents Updated section title and page numbers Format update Table of Contents, page v Deleted reference to [R3] NOCS100477, The RERP and EALs Updated to Reflect Information Corresponding to NUMARC/NESP-007 Guidance in NRC Bulletin 2005-02, Attachment 2, Pages 6-7 Commitment Page 2-1, Section 2.1 Changed wording from "as applicable to CR3 in its permanently shutdown and defueled status" to "with approved exemptions that reflects CR3 in its permanently shutdown and defueled status".

Editorial. Reflects current PDEP.

Page 2-2 Add to the Facility Description the ISFSI facility description ISFSI added to PDEP Page 4-5, Section 4.2 Changed DEF acronym from Duke Energy Florida, Inc. to Duke Energy Florida.

Editorial Page 4-3 Added ISFSI definition ISFSI added to PDEP Page 4-5 Removed DTO and added ISFSI. Deleted EMnet.

DTO transitioned into SAFSTOR. ISFSI is a new facility.

EMnet removed from communications equipment Page 5-4, step 5.5.2.2 Page 5-5, step 5.5.4.2 Deleted EMnet Removed communications method Page 5-5 step 5.5.4.1 Retitled Citrus County Dispatch Center to be 911 dispatch center Update title Page 6-1, step 6.1 Added management of the ISFSI activities to the SS/CFH ISFSI facility added.

(LAR 318)

U.S. Nuclear Regulatory Commission 3F0815-01 Page 86 of 87

SUMMARY

OF CHANGES PDEP Rev. 2 Page SOC 2 Page / Section Change Reason/References Page 6-7, section 6.4 Corrected title of Dhiaa Jamil to Executive Vice President & President Generation and Transmission.

Update Title per Org. Chart Page 6-4 step 6.2.3.1 and re-numbered Removed Communicator position ERO position reduction (LAR 318)

Page 6-6 step 6.2.5 Re-titled Fire Brigade to Industrial Incipient Fire Brigade Update titles Page 6-7 and throughout Re-titled Vice President to present title of Senior Vice President of Operations Support Update titles Page 6-8, Table 6.1 Deleted reference to MCR Communicator ERO position reduction (LAR 318)

Page 6-9, Figure 6.1 Deleted reference to MCR Communicator ERO position reduction (LAR 318)

Page 8-1, step 8.1 Added NEI-99-01 reference for ISFSI EAL ISFSI EAL addition (LAR 318)

Page 8-2, step 8.2 Added ISFSI EAL category ISFSI EAL addition (LAR 318)

Page 9-3, Section 9.3 Added "notification" and removed "emergency incident" on the first paragraph, last sentence.

Time of notification is appropriate in lieu of time of emergency incident.

Page 10-1, step 10.1 Replace Communicator with Emergency Coordinator as being responsible for communications Deleted Communicator ERO position (LAR 318)

Page 10-4 Deleted EMnet Removed communications method Page 12-3, step 12.2.1 Added "Portable radiation monitoring instruments are maintained to support ISFSI operations including transfer operations of the Dry Shielded Canister (DSC) to the Horizontal Storage Module (HSM) and for monitoring of the spent fuel while in storage in the HSM."

Added instrumentation available to support ISFSI operations.

Page 15-4, step 15.3.3 Removed words "is affected" Editorial wording correction.

Page 18-5, step 18.4 and throughout Replaced EP Supervisor with Emergency Planning Coordinator SAFSTOR organization does not have a EP Supervisor Page 19-1, Section 19.0 Removed words "communications personnel" MCR Communicator being eliminated.

(LAR 318)

Page 19-3, step 19.1.7 Deleted training reference for MCR Communicator ERO position reduction (LAR 318)

Page 19-4, Table 19.1 Deleted training reference for MCR Communicator ERO position reduction (LAR 318)

U.S. Nuclear Regulatory Commission 3F0815-01 Page 87 of 87

DUKE ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302 / LICENSE NUMBER DPR-72 LICENSE AMENDMENT REQUEST #318, REVISION 0, PERMANENTLY DEFUELED EMERGENCY PLAN, REVISION 2, AND PERMANENTLY DEFUELED EMERGENCY ACTION LEVEL BASES MANUAL, REVISION 1 FOR THE INDEPENDENT SPENT FUEL STORAGE INSTALLATION ENCLOSURE 3 PERMANENTLY DEFUELED EMERGENCY ACTION LEVEL BASES MANUAL, REVISION 1

U.S. Nuclear Regulatory Commission 3F0815-01 Page 1 of 38 CRYSTAL RIVER UNIT 3 PERMANENTLY DE FUELED EMERGENCY ACTION LEVEL BASES MANUAL Revision 1 Terry Hobbs General Man

PD EAL Bases Manual Rev. 1 Page 2 of 38 TABLE OF CONTENTS 1.0 PURPOSE....................................................................................................................... 3

2.0 REFERENCES

................................................................................................................ 3 3.0 DEFINITIONS.................................................................................................................. 4 ATTACHMENT 1, EMERGENCY ACTION LEVEL TECHNICAL BASES.................................. 7 Table A-1, Recognition Category PD and E Initiating Condition Matrix...................... 8 PD-AU1, Radiological Effluents (Unusual Event)................................................... 9 PD-AA1, Radiological Effluents (Alert)................................................................. 12 PD-AU2, Spent Fuel Radiological Event (Unusual Event).................................... 14 PD-AA2, Spent Fuel Radiological Event (Alert).................................................... 16 PD-HU1, Security (Unusual)................................................................................ 18 PD-HA1, Security (Alert)...................................................................................... 20 PD-HU2, Natural or Technological Hazard (Unusual Event)................................ 22 PD-HU3, Other Conditions/EC Discretion (Unusual Event).................................. 24 PD-HA3, Other Conditions/EC Discretion (Alert).................................................. 25 PD-SU1, Unplanned Spent Fuel Pool Temperature Rise (Unusual Event)........... 26 E-HU1, Damage to a Dry Shielded Canister CONFINEMENT BOUNDARY (Unusual Event)....................................................................................... 27 ATTACHMENT 2, EMERGENCY CLASSIFICATION TABLES............................................... 29 Table Index.................................................................................................................. 30 Radiological Effluents (R).................................................................................... 31 Spent Fuel Radiological Event (R)....................................................................... 32 Security (H).......................................................................................................... 33 Natural or Technological Hazard (H).................................................................... 34 Other Conditions/Emergency Coordinator Discretion (H)..................................... 35 UNPLANNED Spent Fuel Pool Temperature Rise (S).......................................... 36 Damage to a Dry Shielded Canister CONFINEMENT BOUNDARY (E)............... 37 Summary of Changes............................................................................................................... 38 U.S. Nuclear Regulatory Commission 3F0815-01 Page 2 of 38

PD EAL Bases Manual Rev. 1 Page 3 of 38 1.0 PURPOSE This manual provides an explanation and rationale for each EMERGENCY ACTION LEVEL (EAL) included in the Permanently Defueled EAL scheme for CR3. The information provided should be used to facilitate reviews of the CR3 EALs and provide documentation for future reference.

Decision-makers with responsibility for implementation of EM-502 "Conduct of the Emergency Coordinator and the Emergency Action Level Table (Attachment 2) may use the information included in this document as a technical reference in support of an EAL interpretation. This information may assist the EMERGENCY COORDINATOR (EC) in making classifications, particularly those involving judgment or multiple events.

This manual is an Emergency Plan Implementing Procedure (EPIP). Any revisions must be carefully considered for Emergency Plan impact by evaluating changes in accordance with 10 CFR 50.54(q).

2.0 REFERENCES

2.1 NEI 99-01, Revision 6, November 2012, Development of Emergency Action Levels for Non-Passive Reactors, Appendix C, Permanently Defueled Station ICs/EALs and Section 8, Independent Spent Fuel Storage Installation (ISFSI)

ICs/EALs.

2.2 Permanently Defueled Emergency Plan (PDEP) 2.3 NUREG-1022, Event Reporting Guidelines: 10CFR50.72 and 50.73 2.4 NUREG-1536, Standard Review Plan for Spent Fuel Dry Storage Systems at a General License Facility 2.5 NSIR/DPR-ISG-01, Interim Staff Guidance, Emergency Planning for Nuclear Power Plants 2.6 NEI 03-12, Template for Security Plan, Training and Qualification, Safeguards Contingency Plan, and IFSI Security Program.

2.7 10 CFR § 2.390, Public inspections, exemptions, requests for withholding.

2.8 HPP-334, Offsite Radiation Monitoring and Controls 2.9 EM-502, Conduct of the Emergency Coordinator 2.10 SP-736L, Liquid Releases to Discharge Canal via RM-L2 2.11 SP-736M, Liquid Releases to Discharge Canal via RM-L7 U.S. Nuclear Regulatory Commission 3F0815-01 Page 3 of 38

PD EAL Bases Manual Rev. 1 Page 4 of 38 3.0 DEFINITIONS Selected terms used in Initiating Condition (IC) and EAL statements are set in all capital letters (e.g., ALL CAPS). These words are defined terms that have specific meanings as used in this document. The definitions of these terms are provided below.

1.

Alert: Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA PAG exposure levels.

2.

Committed Dose Equivalent (CDE): The dose to an organ that is due to the intake of radioactive materials. For emergency dose assessment, CR3 considers dose to the thyroid when calculating CDE (CDE dose = thyroid dose).

3.

Confinement Boundary: The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As applied to the CR3 ISFSI, the CONFINEMENT BOUNDARY is the Dry Shielded Canister (DSC) consisting of the DSC shell, the inner top and inner bottom cover plates, the siphon and vent block, the siphon and vent port cover plates, and the associated welds.

4.

Credible Security Threat: A threat to CR3 confirmed and validated by Security per procedures or received over the Emergency Notification System (ENS) from the NRC.

5.

Emergency Action Level (EAL): A pre-determined, observable threshold for plant conditions that places the plant in a given emergency classification.

6.

Emergency Classification Level (ECL): One of a set of names or titles established by the US Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to (1) potential or actual effects or consequences, and (2) resulting onsite and offsite response actions. The emergency classification levels, in ascending order of severity, are Notification of UNUSUAL EVENT (NOUE) and ALERT.

7.

Exclusion Area Boundary: The perimeter of the area that extends 4,400 feet or 0.83 miles in a circle around the Reactor Building, which includes the PROTECTED AREA.

8.

Explosion: A rapid, violent, unconfined combustion or catastrophic failure of pressurized equipment that imparts energy of sufficient force to potentially damage permanent structures, systems, or components.

9.

Fire: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES.

Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 4 of 38

PD EAL Bases Manual Rev. 1 Page 5 of 38 3.0 DEFINITIONS (Continued)

10.

Hostile Action: An act toward CR3 or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force.

Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on CR3. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).

11.

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

12.

Imminent: The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

13.

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

14.

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

15.

Owner Controlled Area (OCA): The area of land (approximately 4738 acres) that is owned, leased, or otherwise controlled by DEF, situated between the mouths of the Withlacoochee and Crystal Rivers and bounded to the north by woodlands, to the east by Highway 19, to the south by medium to dense woodlands and to the west by marshlands and the Gulf of Mexico. The OWNER CONTROLLED AREA is the area of land within the SITE BOUNDARY, as shown in Figure 2-3 of the FSAR. The PROTECTED AREA is located within the OWNER CONTROLLED AREA.

16.

Protected Area: All areas within the CR3 security perimeter fence that require badged authorization for entry

17.

Safety System: A system required for cooling the spent fuel pool of CR3 in the permanently defueled mode of operation.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 5 of 38

PD EAL Bases Manual Rev. 1 Page 6 of 38 3.0 DEFINITIONS (Continued)

18.

Security Condition: Any security event as listed in the approved CR3 Security Plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION.

19.

Site Boundary: That line beyond which the land is not owned, leased, or otherwise controlled by the licensee. This line establishes the perimeter of the Owner Controlled Area (OCA).

20.

Unusual Event: Events are in progress or have occurred which indicate a potential degradation of the level of safety of the Plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring off-site response or monitoring are expected unless further degradation of safety systems occur.

21.

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

22.

Valid: An indication, report, or condition, is considered to be VALID when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators function, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

23.

Visible Damage: Damage to equipment or structure that is readily observable without measurements, testing, or analyses. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected component or structure.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 6 of 38

PD EAL Bases Manual Rev. 1 Page 7 of 38 ATTACHMENT 1 EMERGENCY ACTION LEVEL TECHNICAL BASES U.S. Nuclear Regulatory Commission 3F0815-01 Page 7 of 38

PD EAL Bases Manual Rev. 1 Page 8 of 38 ATTACHMENT 1 Page 1 of 21 Table A-1: Recognition Category PD and E Initiating Condition Matrix UNUSUAL EVENT ALERT PD-AU1 Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer.

(Page 9)

PD-AA1 Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem CDE.

(Page 12)

PD-AU2 UNPLANNED rise in plant radiation levels.

(Page 14)

PD-AA2 UNPLANNED rise in plant radiation levels that impedes plant access required to maintain spent fuel integrity.

(Page 16)

PD-HU1 Confirmed SECURITY CONDITION or threat.

(Page 18)

PD-HA1 HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.

(Page 20)

PD-HU2 Hazardous event affecting SAFETY SYSTEM equipment necessary for spent fuel cooling.

(Page 22)

PD-HU3 Other conditions exists which in the judgment of the Emergency Coordinator warrant declaration of a UE.

(Page 24)

PD-HA3 Other conditions exists which in the judgment of the Emergency Coordinator warrant declaration of an ALERT.

(Page 25)

PD-SU1 UNPLANNED spent fuel pool temperature rise.

(Page 26)

E-HU1 Damage to a Dry Shielded Canister CONFINEMENT BOUNDARY (Page 27)

U.S. Nuclear Regulatory Commission 3F0815-01 Page 8 of 38

PD EAL Bases Manual Rev. 1 Page 9 of 38 ATTACHMENT 1 Page 2 of 21 Abnormal Rad Levels / Rad Effluent PD-AU1 ECL: Unusual Event Initiating Condition: Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer.

Emergency Action Levels: (1 or 2)

Note 1: The EMERGENCY COORDINATOR should declare the event promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes.

Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes.

VALID: An indication, report, or condition, is considered to be VALID when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators function, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

UNUSUAL EVENT

1. Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer.

1)

VALID reading on an effluent radiation monitor greater than the values shown for 60 minutes or longer.

Gaseous RM-A2 Accident Range: 0.01 µCi/cc Liquid RM-L2: 2 x liquid release setpoint RM-L7: 2 x liquid release setpoint OR

2)

Sample analysis for a

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

U.S. Nuclear Regulatory Commission 3F0815-01 Page 9 of 38

PD EAL Bases Manual Rev. 1 Page 10 of 38 ATTACHMENT 1 Page 3 of 21 Abnormal Rad Levels / Rad Effluent PD-AU1 Basis:

EAL #1:

The RM-A2 Accident Range value listed above and two times the liquid release setpoints for RM-L2 and RM-L7 listed on release permits all represent two times the ODCM setpoints.

EAL #2:

For conditions when RM-A2 Accident Range is unavailable, an evaluation of gaseous effluent radioactivity must be performed per CH-281 to determine entry conditions. For conditions when two times the liquid release setpoint is off-scale or other conditions where the liquid monitor reading is unavailable, an evaluation of liquid effluent radioactivity must be performed per SP-736L or SP-736M and compared against the ODCM release setpoint limit to determine entry conditions.

Generic This Initiating Condition addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release). It includes any gaseous or liquid radiological release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared.

Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.

Escalation of the emergency classification level would be via Initiating Condition PD-AA1.

Gaseous Releases The radioactive gaseous effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in gaseous effluents during actual or potential releases.

The alarm/trip setpoints for radioactive gaseous effluent instrumentation are calculated in accordance with the procedures in the Offsite Dose Calculation Manual (ODCM) to ensure that the alarm/trip will occur prior to exceeding a dose rate of 500 mrem/year to the total body at the SITE BOUNDARY. The SITE BOUNDARY equates to the EXCLUSION AREA BOUNDARY at the point where the distance between the center of the Reactor Building and the SITE BOUNDARY is at a minimum. This allows the projected doses at the EXCLUSION AREA BOUNDARY to bound projected doses at the SITE BOUNDARY.

5E3µCi/cc (high-high alarm) is the upper functional limit for RM-A2 Normal Range. The ODCM limit was chosen to assure the alarm trip function remained on the Normal Range. The UE threshold value is two times the ODCM limit.¹ Note 1: NEI 99-01 Rev. 6 recommends 2X the ODCM limit, however, application of the ODCM methodology using only Kr 85 yields a limit of 0.084 µCi/cc, which exceeds the Normal Range capacity. Since Auxiliary Building ventilation interlock functions are currently limited to the Normal Range, the ODCM limit will also remain on the Normal Range at 5E-3 µCi/cc. (Extending the interlock functions to the Accident Range would require a significant equipment modification.)

U.S. Nuclear Regulatory Commission 3F0815-01 Page 10 of 38

PD EAL Bases Manual Rev. 1 Page 11 of 38 ATTACHMENT 1 Page 4 of 21 Abnormal Rad Levels / Rad Effluent PD-AU1 Basis: (Continued)

Auxiliary Building & Fuel Handling Area Exhaust (RM-A2) the high alarm setpoint (normal range) ensures operators are aware that nuclide release concentrations exceed ODCM limits prior to reaching the UNUSUAL EVENT entry conditions.

Liquid Releases The radioactive liquid effluent instrumentation is provided to monitor and control, as applicable, the releases of radioactive materials in liquid effluents during actual or potential releases. The alarm/trip setpoints for these instruments shall be calculated in accordance with the procedures in the Offsite Dose Calculation Manual (ODCM) to ensure that the alarm/trip will occur prior to exceeding the 10 times limits of 10 CFR Part 20.

For liquid releases via the Plant Discharge Line (RM-L2) and the Secondary Drain Tank Liquid Effluent Line (RM-L7) the high alarm and isolation setpoints ensures release pathway isolation if nuclide concentrations exceed ODCM limits.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 11 of 38

PD EAL Bases Manual Rev. 1 Page 12 of 38 ATTACHMENT 1 Page 5 of 21 Abnormal Rad Levels / Rad Effluent PD-AA1 ECL: Alert Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE.

Emergency Action Levels: (1 or 2 or 3 or 4)

Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.

Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes.

Note 4: The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

24. EXCLUSION AREA BOUNDARY: The perimeter of the area that extends 4,400 feet or 0.83 miles in a circle around the Reactor Building, which includes the PROTECTED AREA.

VALID: An indication, report, or condition, is considered to be VALID when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators function, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

ALERT

1.

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

1)

VALID reading on RM-A2 Accident Range greater than 1.0 µCi/cc for 15 minutes or longer.

OR

2)

Dose assessment using actual meteorology indicates doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the EXCLUSION AREA BOUNDARY.

OR

3)

Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the EXCLUSION AREA BOUNDARY for one hour of exposure.

OR

4)

Field survey results indicate EITHER of the following at or beyond the EXCLUSION AREA BOUNDARY.

Closed window dose rates greater than 10 mR/hr expected to continue for

>60 minutes or longer.

Analyses of field survey samples indicate thyroid CDE >50 mrem for one hour of inhalation.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 12 of 38

PD EAL Bases Manual Rev. 1 Page 13 of 38 ATTACHMENT 1 Page 6 of 21 Abnormal Rad Levels / Rad Effluent PD-AA1 Basis:

EAL Example (1)

This concentration corresponds to 10 mrem TEDE at the SITE BOUNDARY (EXCLUSION AREA BOUNDARY) per calculation N13-0001. 10 mrem TEDE is the ALERT threshold recommended by NEI 99-01 Rev 6.

EAL Example (2)

Dose assessment may be performed by either manual Control Room or computer (RASCAL) based methods.

EAL Example (3)

Evaluation of liquid effluent radioactivity may be performed using RM-L2 per SP-736L, and RM-L7 per SP-736M. ODCM section 4.6 provides basis for the evaluating the samples and EAL impacts.

EAL Example (4)

Field monitoring based dose assessments are performed per HPP-334.

Generic This Initiating Condition addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone.

The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 13 of 38

PD EAL Bases Manual Rev. 1 Page 14 of 38 ATTACHMENT 1 Page 7 of 21 Abnormal Rad Levels / Rad Effluent PD-AU2 ECL: Unusual Event Initiating Condition: UNPLANNED rise in plant radiation levels.

Emergency Action Levels: (1a and 1b or 2)

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

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

UNUSUAL EVENT

1.

UNPLANNED rise in plant radiation levels.

1)

a.

UNPLANNED water level drop in the spent fuel pool (below -2.5 feet) as indicated by ANY of the following:

SF-1-LI1 SF-1-LI2 Visual Observation AND

b.

UNPLANNED rise in area radiation levels as indicated by warning alarms on ANY of the following radiation monitors.

RM-G15 Auxiliary Building Fuel Handling Bridge RM-G14 Fuel Storage Pools.

OR

2)

Area radiation monitor reading or survey result indicates an UNPLANNED rise of 25 mR/hr over NORMAL LEVELS.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 14 of 38

PD EAL Bases Manual Rev. 1 Page 15 of 38 ATTACHMENT 1 Page 8 of 21 Abnormal Rad Levels / Rad Effluent PD-AU2 Basis:

Plant-Specific The Spent Fuel Pool (SFP) is equipped with level indicators (SF-1-LI1 and SF-1-LI2) that indicate SFP level relative to normal zero at 158.5 feet plant datum. The top of the spent fuel seated in the SFP is at plant elevation 133 feet. The minimum level per Technical Specifications is 23 feet above the fuel seated in the SFP or - 2.5 feet indicated level (156 feet).

Area radiation monitor RM-G14 and RM-G15 are located in the proximity of where spent fuel may be located and has been selected to be indicative of a decrease in radiation shielding due to decreasing water level. While a radiation monitor could detect a rise in dose due to a drop in the water level, it might not be a reliable indication, in and of itself, of whether or not the fuel is uncovered.

For example, the reading on an area radiation monitor located on the refueling bridge may rise due to planned evolutions such as a fuel assembly being raised in the manipulator mast. For EAL #1, elevated radiation monitor indications or survey results will need to be combined with indication (or personnel report) of water loss.

Visual Observation can be by physical on site observation or by remote means available.

Generic This Initiating Condition addresses a decrease in water level above irradiated fuel sufficient to cause elevated radiation levels (EAL #1) or other UNPLANNED events sufficient to cause plant elevated radiation levels (EAL #2). Either condition could be a precursor to a more serious event and is also indicative of a minor loss in the ability to control radiation levels within the plant. It is therefore a potential degradation in the level of safety of the plant.

A water level decrease will primarily be determined by indications from available level instrumentation. Other sources of level indication may include reports from plant personnel or video camera observations (if available). A significant drop in the water level may also cause an increase in the radiation levels of adjacent or lower areas that may be detected by monitors in those locations. An unexplained rise in Auxiliary Building Sump level may help confirm the situation.

The effects of planned evolutions should be considered. For example, a refueling bridge area radiation monitor reading may increase due to planned evolutions such as movement of a fuel assembly. Note that EAL # 1 is applicable only in cases where the elevated reading is due to an UNPLANNED loss of water level. EAL #2 excludes radiation level increases that result from planned activities such as use of radiographic sources and movement or radioactive waste materials.

Escalation of the emergency classification level would be via Initiating Condition PD-AA1 or PD-AA2.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 15 of 38

PD EAL Bases Manual Rev. 1 Page 16 of 38 ATTACHMENT 1 Page 9 of 21 Abnormal Rad Levels / Rad Effluent PD-AA2 ECL: Alert Initiating Condition: UNPLANNED rise in plant radiation levels that impedes plant access required to maintain spent fuel integrity.

Emergency Action Levels: (1 or 2)

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

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

IMPEDE: Hindering or interfering, provided that the interference or delay is sufficient to significantly threaten necessary plant access.

ALERT

1.

UNPLANNED rise in plant radiation levels that IMPEDES plant access required to maintain spent fuel integrity.

1)

UNPLANNED dose rate greater than 15 mR/hr in ANY of the following areas requiring continuous occupancy to maintain control of radioactive material or operation of systems needed to maintain spent fuel integrity:

Main Control Room RM-G1 OR

2)

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

Spent Fuel Pump Area Spent Fuel Floor RM-G15 Seawater Room U.S. Nuclear Regulatory Commission 3F0815-01 Page 16 of 38

PD EAL Bases Manual Rev. 1 Page 17 of 38 ATTACHMENT 1 Page 10 of 21 Abnormal Rad Levels / Rad Effluent PD-AA2 Basis:

This Initiating Condition addresses increased radiation levels that impede necessary access to areas containing equipment that must be operated manually or that requires local monitoring, in order to maintain systems needed to maintain spent fuel integrity. As used here, impede includes hindering or interfering, provided that the interference or delay is sufficient to significantly threaten necessary plant access. It is this impaired access that results in the actual or potential substantial degradation of the level of safety of the plant.

The Emergency Coordinator should consider the cause of the increased radiation levels and determine if another Initiating Condition may be applicable.

Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., installing temporary shielding, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits).

An emergency declaration is NOT warranted if any of the following conditions apply:

The increased radiation levels are a result of a planned activity that includes compensatory measures, which address the temporary inaccessibility of a room or area (e.g., radiography, spent filter or resin transfer, etc.).

The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 17 of 38

PD EAL Bases Manual Rev. 1 Page 18 of 38 ATTACHMENT 1 Page 11 of 21 Hazards and Other Conditions Affecting Plant Safety PD-HU1 ECL: Unusual Event Initiating Condition: Confirmed SECURITY CONDITION or threat.

Emergency Action Levels: (1 or 2 or 3)

SECURITY CONDITION: Any security event as listed in the approved CR3 Security Plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION.

HOSTILE ACTION: An act toward CR3 or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on CR3. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).

UNUSUAL EVENT

1.

Confirmed SECURITY CONDITION or threat.

1)

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

OR

2)

Notification of a CREDIBLE SECURITY THREAT directed at the site.

OR

3)

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

U.S. Nuclear Regulatory Commission 3F0815-01 Page 18 of 38

PD EAL Bases Manual Rev. 1 Page 19 of 38 ATTACHMENT 1 Page 12 of 21 Hazards and Other Conditions Affecting Plant Safety PD-HU1 Basis:

This IC addresses events that pose a threat to plant personnel or the equipment necessary to maintain cooling of spent fuel, and thus represent a potential degradation in the level of plant safety.

Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under IC PD-HA1.

Timely and accurate communications between Security Shift Supervision and the Control Room are essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to plant personnel and Off Site Response Organizations.

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

EAL #1 references the Security Shift Supervisor because these are the individuals trained to confirm that a security event is occurring or has occurred. Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR § 2.39 information.

EAL #2 addresses the receipt of a CREDIBLE SECURITY THREAT. The credibility of the threat is assessed in accordance with SEC-92170, SECURITY EVENT PROCEDURES.

EAL #3 addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may also be provided by NORAD through the NRC. Validation of the threat is performed in accordance with SEC-92170, SECURITY EVENT PROCEDURES.

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.

Escalation of the emergency classification level would be via Initiating Condition PD-HA1.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 19 of 38

PD EAL Bases Manual Rev. 1 Page 20 of 38 ATTACHMENT 1 Page 13 of 21 Hazards and Other Conditions Affecting Plant Safety PD-HA1 ECL: Alert Initiating Condition: HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.

Emergency Action Levels: (1 or 2)

HOSTILE ACTION: An act toward CR3 or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on CR3. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).

OWNER CONTROLLED AREA:

The area of land (approximately 4738 acres) that is owned, leased, or otherwise controlled by DEF, situated between the mouths of the Withlacoochee and Crystal Rivers and bounded to the north by woodlands, to the east by Highway 19, to the south by medium to dense woodlands and to the west by marshlands and the Gulf of Mexico. The OWNER CONTROLLED AREA is the area of land within the SITE BOUNDARY, as shown in Figure 2-3 of the FSAR. The PROTECTED AREA is located within the OWNER CONTROLLED AREA.

ALERT

1.

HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.

1)

A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the Security Shift Supervisor OR

2)

A validated notification from NRC of an aircraft attack threat within 30 minutes of the site.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 20 of 38

PD EAL Bases Manual Rev. 1 Page 21 of 38 ATTACHMENT 1 Page 14 of 21 Hazards and Other Conditions Affecting Plant Safety PD-HA1 Basis:

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

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

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

This Initial Condition does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE.

Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.

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

EAL #2 addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that personnel are in a heightened state of readiness. This EAL is met when the threat-related information has been validated in accordance with SEC-92170, SECURITY EVENT PROCEDURES.

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

In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other Initial Conditions/EALs, should not be unduly delayed while awaiting notification by a Federal agency. If the intent is not clearly identified then declare the emergency.

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 21 of 38

PD EAL Bases Manual Rev. 1 Page 22 of 38 ATTACHMENT 1 Page 15 of 21 Hazards and Other Conditions Affecting Plant Safety PD-HU2 ECL: Unusual Event Initiating Condition: Hazardous event affecting SAFETY SYSTEM equipment necessary for spent fuel cooling.

Emergency Action Levels: (1 and 2 and 3)

SAFETY SYSTEM: A system required for cooling the spent fuel pool of CR3 in the permanently defueled mode of operation.

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

EXPLOSION: A rapid, violent, unconfined combustion or catastrophic failure of pressurized equipment that imparts energy of sufficient forced to potentially damage permanent structures, systems, or components.

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

Toxic/chemical hazard: Prevents occupancy or causes evacuation to the point of not being able to properly monitor SAFETY SYSTEM operation.

UNUSUAL EVENT

1. Hazardous event affecting SAFETY SYSTEM equipment necessary for spent fuel cooling.

1) The occurrence of ANY of the following hazardous events:

Seismic event (earthquake)

Internal or external flooding event High winds or tornado strike/ hurricane FIRE EXPLOSION Toxic/chemical hazard Other events with similar hazard characteristics as determined by the Shift Supervisor AND

2) The event has damaged at least one train of a SAFETY SYSTEM needed to maintain spent fuel in a safe condition.

AND

3) The damaged SAFETY SYSTEM train(s) cannot, or potentially cannot, perform its design function based on EITHER:

Indications of degraded performance VISIBLE DAMAGE U.S. Nuclear Regulatory Commission 3F0815-01 Page 22 of 38

PD EAL Bases Manual Rev. 1 Page 23 of 38 ATTACHMENT 1 Page 16 of 21 Hazards and Other Conditions Affecting Plant Safety PD-HU2 Basis:

This IC addresses a hazardous event that causes damage to at least one train of a SAFETY SYSTEM needed for spent fuel cooling. The damage must be of sufficient magnitude that the system(s) train cannot, or potentially cannot, perform its design function. This condition can be determined by indications or physical observation. All of these conditions must be present. This condition reduces the margin to a loss or potential loss of the fuel clad barrier, and therefore represents a potential degradation of the level of safety of the plant.

For Example EAL 3, the first bullet addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it will be readily available.

For Example EAL 3, the second bullet addresses damage to a SAFETY SYSTEM train that is not in service/operation or readily apparent through indications alone. Operators will make this determination based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.

Escalation of the emergency classification level could, depending upon the event, be based on any of the ALERT Initial Conditions; PD-AA1, PD-AA2, PD-HA1, PD-HA3.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 23 of 38

PD EAL Bases Manual Rev. 1 Page 24 of 38 ATTACHMENT 1 Page 17 of 21 Hazards and Other Conditions Affecting Plant Safety PD-HU3 ECL: Unusual Event Initiating Condition: Other conditions exist which in the judgment of the Emergency Coordinator warrant declaration of an UNUSUAL EVENT (UE).

Emergency Action Levels:

UNUSUAL EVENT

1) Other conditions exist which in the judgment of the Emergency Coordinator indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

Basis:

This Initial Condition addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Coordinator to fall under the emergency classification level description for a UE.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 24 of 38

PD EAL Bases Manual Rev. 1 Page 25 of 38 ATTACHMENT 1 Page 18 of 21 Hazards and Other Conditions Affecting Plant Safety PD-HA3 ECL: Alert Initiating Condition: Other conditions exist which in the judgment of the Emergency Coordinator warrant declaration of an ALERT.

Emergency Action Levels: (1)

ALERT

1) Other conditions exist which in the judgment of the Emergency Coordinator indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION.

Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

Basis:

This Initial Condition addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Coordinator to fall under the emergency classification level description for an ALERT.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 25 of 38

PD EAL Bases Manual Rev. 1 Page 26 of 38 ATTACHMENT 1 Page 19 of 21 System Malfunction PD-SU1 ECL: Unusual Event Initiating Condition: UNPLANNED spent fuel pool temperature rise.

Emergency Action Levels: (1)

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

Basis:

Site specific calculations (EE 92486) determined that the time to reach 212 on July 1, 2013 was 107.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />, and the total time form the loss of cooling to boil off inventory to 10 ft. above the fuel storage racks was 19.9 days.

Analysis results also indicate that surface temperature of the cladding in the spent fuel pools will not exceed the failure temperature for zirconium following a total loss of water from the pools on or after September 26, 2013, due to adequate natural circulation and heat rejection to the outside through the FHB walls and roof.

Since normal fuel pool temperature is below 100, a good indication that there is an issue with cooling the Spent Fuel Pools is considered to be 150 which still would allow an adequate amount of time to take action before any safety issues.

This Initial Condition addresses a condition that is a precursor increased radiation levels basically due to loss of the shielding component of the water.

Escalation of the emergency classification level would be via Initiating Condition PD-AA1 or PD-AA2.

UNUSUAL EVENT

1. UNPLANNED spent fuel pool temperature rise.

UNPLANNED spent fuel pool temperature rise to greater than 150 as per computer points X284 Pool A X285 Pool B U.S. Nuclear Regulatory Commission 3F0815-01 Page 26 of 38

PD EAL Bases Manual Rev. 1 Page 27 of 38 ATTACHMENT 1 Page 20 of 21 ISFSI Malfunction E-HU1 ECL: Unusual Event Initiating Condition: Damage to a Dry Shielded Canister CONFINEMENT BOUNDARY.

Emergency Action Levels: (1 or 2 or 3 or 4)

Mode Applicability: All CONFINEMENT BOUNDARY: The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As applied to the CR3 ISFSI, the CONFINEMENT BOUNDARY is the Dry Shielded Canister (DSC) consisting of the DSC shell, the inner top and inner bottom cover plates, the siphon and vent block, the siphon and vent port cover plates, and the associated welds.

UNUSUAL EVENT Damage to a Dry Shielded Canister CONFINEMENT BOUNDARY as indicated by radiation readings greater than or equal to the following:

1) 1300 mR/hr (gamma +neutron) on the radial surface of the fuel transfer cask while in transit to the ISFSI Horizontal Storage Module (HSM).

OR

2) 1050 mR/hr (gamma + neutron) on the HSM Front Bird Screen while stored in the HSM.

OR

3) 4 mR/hr (gamma + neutron) HSM Outside Door while stored in the HSM.

OR

4) 40 mR/hr (gamma + neutron) HSM End Shield Wall Exterior while stored in the HSM.

NOTE: Radiation readings are taken at the locations prescribed by the Technical Specifications for the Standardized NUHOMS Horizontal Storage System (Amendment Number 14 to COC 1004).

U.S. Nuclear Regulatory Commission 3F0815-01 Page 27 of 38

PD EAL Bases Manual Rev. 1 Page 28 of 38 ATTACHMENT 1 Page 21 of 21 ISFSI Malfunction E-HU1 Basis:

This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a dry shielded canister containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage canister is sealed. The issues of concern are the creation of a potential or actual release path to the environment, degradation of one or more fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the canister or fuel from storage.

The existence of damage is determined by radiological survey. NEI 99-01, Revision 6, November 2012, Development of Emergency Action Levels for Non-Passive Reactors, Section 8, Independent Spent Fuel Storage Installation (ISFSI) ICs/EALs recommend using 2 times the site-specific cask specific technical specification allowable radiation level as the EAL. The technical specification multiple of 2 times is used here to distinguish between non-emergency and emergency conditions.

The emphasis for this classification is the degradation in the level of safety of the spent fuel dry shielded canister and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded canister, the fact that the on-contact dose rate limit is exceeded may be determined based on measurement of a dose rate at some distance from the canister.

Security-related events for ISFSIs are covered under ICs PD-HU1 and PD-HA1.

An UNUSUAL EVENT in this EAL is categorized on the basis of the occurrence of an event of sufficient magnitude that a loaded Dry Shielded Canister (DSC) CONFINEMENT BOUNDARY is damaged or violated while in transit or storage.

This EAL applies to emergency conditions affecting a spent fuel DSC caused by an accident or natural phenomena. This EAL would be applicable at all times in all modes for a loaded DSC from the time the lid is installed, during transport to the INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) and while stored in the Horizontal Storage Module (HSM)..

The Transnuclear Standardized NUHOMS System Technical Specifications DRAFT Amendment 14 to COC 1004, Section 5.2.4 (Radiation Protection Program) and Section 5.4.2 (HSM or HSM-H Dose Rate Evaluation Program) contain radiation dose levels for the DSC that should not be exceeded based on whether the DSC is being transported inside the fuel transfer cask or while it is stored in the HSM. Keeping in line with NEl guidance that a Unusual Event is warranted for radiation conditions at a level of twice the Technical Specification value, the values chosen for EAL E-HU1 represent these values. The Note in the EAL provides guidance on where the radiation readings are to be taken when evaluating this EAL.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 28 of 38

PD EAL Bases Manual Rev. 1 Page 29 of 38 ATTACHMENT 2 EMERGENCY CLASSIFICATION TABLES U.S. Nuclear Regulatory Commission 3F0815-01 Page 29 of 38

PD EAL Bases Manual Rev. 1 Page 30 of 38 ATTACHMENT 2 Page 1 of 8 EMERGENCY CLASSIFICATION TABLE INDEX ABNORMAL RAD LEVELS/RAD EFFLUENT CATEGORY (A)

UNUSUAL EVENT (U)

ALERT (A)

(1) Radiological Effluents AU1 (Page 31)

AA1 (Page 31)

(2) Spent Fuel Radiological Event AU2 (Page 32)

AA2 (Page 32)

HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY CATEGORY (H)

UNUSUAL EVENT (U)

ALERT (A)

(1) SECURITY HU1 (Page 33)

HA1 (Page 33)

(2) Natural or Technological Hazard HU2 (Page 34)

(3) Other Conditions/Emergency Coordinator Discretion HU3 (Page 35)

HA3 (Page 35)

SYSTEM MALFUNCTION CATEGORY (S)

UNUSUAL EVENT (U)

ALERT (A)

(1) UNPLANNED Spent Fuel Pool Temperature Rise.

SU1 (Page 36)

ISFSI MALFUNCTION CATEGORY (E)

UNUSUAL EVENT (U)

ALERT (A)

(1) Damage to a Dry Shielded Canister CONFINEMENT BOUNDARY.

HU1 (Page 37)

U.S. Nuclear Regulatory Commission 3F0815-01 Page 30 of 38

PD EAL Bases Manual Rev. 1 Page 31 of 38 ATTACHMENT 2 Page 2 of 8 EMERGENCY CLASSIFICATION TABLE PERMANENTLY DEFUELED (PD)

CATEGORY UNUSUAL EVENT (AU1)

ALERT (AA1)

ABNORMAL RAD LEVELS /

RAD EFFLUENT (A)

1. Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer.

1)

VALID Reading on an effluent radiation monitor greater than the values shown for 60 minutes or longer.

Gaseous RM-A2 Accident Range: 0.01 µCi/cc Liquid RM-L2: 2 x liquid release setpoint RM-L7: 2 x liquid release setpoint OR

2)

Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times the ODCM limits for 60 minutes or longer Note 1: The EMERGENCY COORDINATOR should declare the UNUSUAL EVENT promptly upon determining that the 60 minutes has been exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes.

Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes.

1. Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE.

1)

VALID reading on RM-A2 Accident Range greater than 1.0 µCi/cc for 15 minutes or longer.

OR

2)

Dose assessment using actual meteorology indicates doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond EXCLUSION AREA BOUNDARY.

OR

3)

Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond EXCLUSION AREA BOUNDARY for one hour of exposure.

OR

4)

Field survey results indicate EITHER of the following at or beyond EXCLUSION AREA BOUNDARY.

Closed window dose rates greater than 10 mR/hr expected to continue for >60 minutes or longer.

Analyses of field survey samples indicate thyroid CDE >50 mrem for one hour of inhalation.

Note 1: The EMERGENCY COORDINATOR should declare the ALERT promptly upon determining that the 60 minutes has been exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.

Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes.

Note 4: The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 31 of 38

PD EAL Bases Manual Rev. 1 Page 32 of 38 ATTACHMENT 2 Page 3 of 8 EMERGENCY CLASSIFICATION TABLE PERMANENTLY DEFUELED (PD)

CATEGORY UNUSUAL EVENT (AU2)

ALERT (AA2)

ABNORMAL RAD LEVELS/

RAD EFFLUENT (A)

1. UNPLANNED rise in plant radiation levels.

1)

a.

UNPLANNED water level drop in the spent fuel pool (below -2.5 feet) as indicated by ANY of the following:

SF-1-LI1 SF-1-LI2 Visual Observation AND

b.

UNPLANNED rise in area radiation levels as indicated by warning alarms on ANY of the following radiation monitors.

RM-G15 Auxiliary Building Fuel Handling Bridge RM-G14 Fuel Storage Pools OR

2)

Area radiation monitor reading or survey result indicates an UNPLANNED rise of 25 mR/hr over NORMAL LEVELS.

1.

UNPLANNED rise in plant radiation levels that impedes plant access required to maintain spent fuel integrity.

1)

UNPLANNED dose rate greater than 15 mR/hr in ANY of the following areas requiring continuous occupancy to maintain control of radioactive material or operation of systems needed to maintain spent fuel integrity:

Main Control Room RM-G1 OR

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

Spent Fuel Pump Area Spent Fuel Floor RM-G15 Seawater Room U.S. Nuclear Regulatory Commission 3F0815-01 Page 32 of 38

PD EAL Bases Manual Rev. 1 Page 33 of 38 ATTACHMENT 2 Page 4 of 8 EMERGENCY CLASSIFICATION TABLE PERMANENTLY DEFUELED (PD)

CATEGORY UNUSUAL EVENT (HU1)

ALERT (HA1)

Hazards And Other Conditions Affecting Plant Safety (H)

1. Confirmed SECURITY CONDITION or threat.

1)

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

OR

2)

Notification of a CREDIBLE SECURITY THREAT directed at the site.

OR

3)

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

1. HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.

1)

A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the Shift Security Supervisor OR

2)

A validated notification from NRC of an aircraft attack threat within 30 minutes of the site.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 33 of 38

PD EAL Bases Manual Rev. 1 Page 34 of 38 ATTACHMENT 2 Page 5 of 8 EMERGENCY CLASSIFICATION TABLE MODE: PERMANENTLY DEFUELED (PD)

CATEGORY UNUSUAL EVENT (HU2)

ALERT (HA)

Hazards and other Conditions Affecting Plant Safety (H)

1.

Hazardous event affecting SAFETY SYSTEM equipment necessary for spent fuel cooling.

1) The occurrence of ANY of the following hazardous events:

Seismic event (earthquake)

Internal or external flooding event High winds or tornado strike/ hurricane FIRE EXPLOSION Toxic/chemical hazard Other events with similar hazard characteristics as determined by the Shift Supervisor AND

2) The event has damaged at least one train of a SAFETY SYSTEM needed to maintain spent fuel in a safe condition.

AND

3)

The damaged SAFETY SYSTEM train(s) cannot, or potentially cannot, perform its design function based on EITHER:

Indications of degraded performance VISIBLE DAMAGE U.S. Nuclear Regulatory Commission 3F0815-01 Page 34 of 38

PD EAL Bases Manual Rev. 1 Page 35 of 38 ATTACHMENT 2 Page 6 of 8 EMERGENCY CLASSIFICATION TABLE MODE: PERMANENTLY DEFUELED (PD)

CATEGORY UNUSUAL EVENT (HU3)

ALERT (HA3)

Hazards and other Conditions Affecting Plant Safety (H)

1.

Other conditions exist which in the judgment of the Emergency Coordinator warrant declaration of a UE.

1)

Other conditions exists which in the judgment of the Emergency Coordinator indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

1. Other conditions exist which in the judgment of the Emergency Coordinator warrant declaration of an ALERT.

1)

Other conditions exists which in the judgment of the Emergency Coordinator indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 35 of 38

PD EAL Bases Manual Rev. 1 Page 36 of 38 ATTACHMENT 2 Page 7 of 8 EMERGENCY CLASSIFICATION TABLE MODE: PERMANENTLY DEFUELED (PD)

CATEGORY UNUSUAL EVENT (SU1)

ALERT (SA)

SYSTEM MALFUNCTION (S)

1.

UNPLANNED spent fuel pool temperature rise.

1)

UNPLANNED spent fuel pool temperature rise to greater than 150°F as per computer points X284 Pool A X285 Pool B U.S. Nuclear Regulatory Commission 3F0815-01 Page 36 of 38

PD EAL Bases Manual Rev. 1 Page 37 of 38 ATTACHMENT 2 Page 8 of 8 EMERGENCY CLASSIFICATION TABLE INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

MODE: All (E)

CATEGORY UNUSUAL EVENT (HU1)

ALERT (HA1)

ISFSI MALFUNCTION (E)

Damage to a Dry Shielded Canister CONFINEMENT BOUNDARY as indicated by radiation readings greater than or equal to the following:

1300 mR/hr (gamma +neutron) on the radial surface of the fuel transfer cask while in transit to the ISFSI Horizontal Storage Module (HSM).

OR 1050 mR/hr (gamma + neutron) on the HSM Front Bird Screen while stored in the HSM.

OR 4 mR/hr (gamma + neutron) HSM Outside Door while stored in the HSM.

OR 40 mR/hr (gamma + neutron) HSM End Shield Wall Exterior while stored in the HSM.

NOTE: Radiation readings are taken at the locations prescribed by the Technical Specifications for the Standardized NUHOMS Horizontal Storage System (Amendment Number 14 to COC 1004).

Not Applicable U.S. Nuclear Regulatory Commission 3F0815-01 Page 37 of 38

SUMMARY

OF CHANGES PD EAL Bases Manual Rev. 1 Page 38 of 38 DRR 752063 PAGE /

SECTION CHANGE REASON &

REFERENCES Title Page Changed to Revision 1 Update names and titles to support the SAFSTOR Organization SAFSTOR Org Table of Contents Added E-HU1, Damage to a Dry Shielded Canister CONFINEMENT BOUNDARY New EAL for planned ISFSI facility. LAR 318.

Page 3 Sec. 2.0 Added Section 8 of NEI-99-01, Revision 6 to references.

Added reference NUREG 1536, Standard Review Plan for Spent Fuel Dry Storage Systems at a General License Facility Re-numbered Section 2.0 references Update references related to ISFSI EAL and governing Dry Storage Standards.

Page 4,5 Sec. 3.0 Added definition of Confinement Boundary Added definition of Independent Spent Fuel Storage Installation (ISFSI)

New definitions associated with ISFSI and associated EAL.

Page 8 Added Category E to Title of Table A-1.

EAL E-HU1 to Unusual Event New EAL for ISFSI per NEI 99-01, Rev. 6.

Page 20 EAL PD-HA1 Deleted duplicate paragraphs from Basis language.

Editorial only as the first two paragraphs of the Basis were duplicated.

Page 21 EAL PD-HA-1 Added verbiage in EAL#1 that this EAL is also applicable to threats against the ISFSI facility.

EAL will now apply to the planned ISFSI facility.

LAR 318.

Page 22 EAL PD-HU2 Changed wording for SAFETY SYSTEM to match those in the DEFINITIONS section.

Editorial only.

DRR 740016 Page 27 Added EAL E-HU1 ISFSI Malfunction New EAL for ISFSI per NEI 99-01, Rev. 6.

Page 28 Added Basis language for EAL E-HU1 New EAL for ISFSI per NEI 99-01, Rev. 6.

Page 30 Added Category E and EAL E-HU1 New EAL for ISFSI per NEI 99-01, Rev. 6.

Page 37 Added ISFSI EAL Table New EAL for ISFSI per NEI 99-01, Rev. 6.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 38 of 38

DUKE ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50-302 / LICENSE NUMBER DPR-72 LICENSE AMENDMENT REQUEST #318, REVISION 0, PERMANENTLY DEFUELED EMERGENCY PLAN, REVISION 2, AND PERMANENTLY DEFUELED EMERGENCY ACTION LEVEL BASES MANUAL, REVISION 1 FOR THE INDEPENDENT SPENT FUEL STORAGE INSTALLATION ENCLOSURE 4 COMPARISON MATRIX OF NUCLEAR ENERGY INSTITUTE 99-01, DEVELOPMENT OF EMERGENCY ACTION LEVELS FOR NON-PASSIVE REACTORS, REVISION 6, TO THE PROPOSED CR-3 EMERGENCY CLASSIFICATION SYSTEM AND NEW EMERGENCY ACTION LEVELS

NEI 99-01, Rev 6, Section 8 -ISFSI ICs/EALs Proposed EAL Matrix for CR-3 Comparison E-HU1 ECL: Notification of Unusual Event Initiating Condition: Damage to a loaded cask CONFINEMENT BOUNDARY.

Operating Mode Applicability: All E-HU1 ECL: Unusual Event Initiating Condition: Damage to a Dry Shielded Canister CONFINEMENT BOUNDARY.

Mode Applicability: All Use of Unusual Event instead of Notification of Unusual Event. Use is consistent with present EAL matrix and agrees in meaning and intent with NEI 99-01, Rev 6.

Used Dry Shielded Canister in place of loaded cask as this is the specific component name used for the CR3 ISFSI.

Removed reference to Operating Mode as it does not apply to a permanently defueled condition.

Example Emergency Action Levels:

(1) Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than (2 times the site-specific cask specific technical specification allowable radiation level) on the surface of the spent fuel cask.

Emergency Action Levels: (1 or 2 or 3 or 4)

Damage to a Dry Shielded Canister CONFINEMENT BOUNDARY as indicated by radiation readings greater than or equal to the following:

1) 1300 mR/hr (gamma +neutron) on the radial surface of the fuel transfer cask while in transit to the ISFSI Horizontal Storage Module (HSM).

OR

2) 1050 mR/hr (gamma + neutron) on the HSM Front Bird Screen while stored in the HSM.

OR

3) 4 mR/hr (gamma + neutron) HSM Outside Door while stored in the HSM.

OR

4) 40 mR/hr (gamma + neutron) HSM End Shield Wall Exterior while stored in the HSM.

NOTE: Radiation readings are taken at the locations prescribed by the Technical Specifications for the Standardized NUHOMS Horizontal Storage System (Amendment Number 14 to COC 1004).

Removed "Example" from Emergency Action Levels and added applicable numbered EALs.

Provided site-specific radiation levels which conform to the recommended 2 times the site-specific dry shielded canister technical specification allowable radiation level Included NOTE to identify that the radiation levels referenced in the EAL are taken at the locations prescribed by the Technical Specifications for the Standardized NUHOMS Horizontal Storage System.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 1 of 3

Basis:

This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage cask is sealed. The issues of concern are the creation of a potential or actual release path to the environment, degradation of one or more fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the cask or fuel from storage.

The existence of "damage" is determined by radiological survey. The technical specification multiple of "2 times", which is also used in Recognition Category A IC AU1, is used here to distinguish between non-emergency and emergency conditions. The emphasis for this classification is the degradation in the level of safety of the spent fuel cask and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the fact that the on-contact dose rate limit is exceeded may be determined based on measurement of a dose rate at some distance from the cask.

Security-related events for ISFSIs are covered under ICs HU1 and HA1.

Basis:

This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a dry shielded canister containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage canister is sealed. The issues of concern are the creation of a potential or actual release path to the environment, degradation of one or more fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the canister or fuel from storage.

The existence of damage is determined by radiological survey. NEI 99-01, Revision 6, November 2012, Development of Emergency Action Levels for Non-Passive Reactors, Section 8, Independent Spent Fuel Storage Installation (ISFSI)

ICs/EALs recommend using 2 times the site-specific cask specific technical specification allowable radiation level as the EAL. The technical specification multiple of 2 times is used here to distinguish between non-emergency and emergency conditions. The emphasis for this classification is the degradation in the level of safety of the spent fuel cask and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the fact that the on-contact dose rate limit is exceeded may be determined based on measurement of a dose rate at some distance from the cask. The radiation levels listed in the CR3 specific EAL represent the site-specific Technical Specification radiation levels and comply with this recommendation.

Security-related events for ISFSIs are covered under ICs PD-HU1 and PD-HA1.

Provided site-specific amplifying information related to the development of the radiation levels for the EAL.

Added information that the EAL is applicable when the DSC is in transit or storage.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 2 of 3

An UNUSUAL EVENT in this EAL is categorized on the basis of the occurrence of an event of sufficient magnitude that a loaded Dry Shielded Canister (DSC) CONFINEMENT BOUNDARY is damaged or violated while in transit or storage. *.

This EAL applies to emergency conditions affecting a spent fuel cask caused by an accident or natural phenomena. This EAL would be applicable at all times in all modes for a loaded spent fuel storage cask from the time the lid is installed, as the cask leaves the Spent Fuel Handling Building and during transport to the INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI).

The Transnuclear Standardized NUHOMS System Technical Specifications DRAFT Amendment 14 to COC 1004, Section 5.2.4 (Radiation Protection Program) and Section 5.4.2 (HSM or HSM-H Dose Rate Evaluation Program) contains radiation values for the cask that should not be exceeded. Keeping in line with NEl guidance that a Unusual Event is warranted for radiation conditions at a level of twice the Technical Specification value, the values chosen for EAL E-HU1 represents these values.

U.S. Nuclear Regulatory Commission 3F0815-01 Page 3 of 3