LIC-16-0108, License Amendment Request 16-07, Revise the Emergency Plan to the Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme

License Amendment Request 16-07, Revise the Emergency Plan to the Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme

ML16351A464
Person / Time
Site:	Fort Calhoun
Issue date:	12/16/2016
From:	Marik S Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-16-0108
Download: ML16351A464 (153)

Text

10 CFR 50.90 10 CFR 50.54(q)

LIC-16-0108 December 16, 2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285

Subject:

License Amendment Request 16-07; Revise the Fort Calhoun Station Emergency Plan to the Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme

References:

1. OPPD Letter (T. Burke) to USNRC (Document Control Desk) - Certification of Permanent Cessation of Power Operations, dated June 24, 2016 (LIC-16-0043) (ML16176A213)

2. OPPD Letter (T. Burke) to USNRC (Document Control Desk) - Certification of Permanent Cessation of Power Operations, dated August 25, 2016 (LIC-16-0067) (ML16242A127)

3. Letter from OPPD (T. Burke) to USNRC (Document Control Desk),

Certification of Permanent Removal of Fuel from the Reactor Vessel, dated November 13, 2016 (LIC-16-0074) (ML16319A254)

4. OPPD Letter (S. Marik) to USNRC (Document Control Desk) - License Amendment Request (LAR) 16-02 to Revise the Fort Calhoun Station Emergency Plan to Address the Permanently Defueled Condition, dated September 2, 2016 (LIC-16-0076)(ML16246A321)

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

Pursuant to 10 CFR 50.90, Omaha Public Power District (OPPD) requests an amendment to Renewed Facility Operating License Number DPR-40 for the Fort Calhoun Station (FCS). The proposed amendment would revise the FCS Emergency Plan and Emergency Action Level (EAL) scheme for the permanently defueled condition. The proposed changes are being submitted to the NRC for approval prior to implementation, as required under 10 CFR 50.54(q)(4) and 10 CFR Part 50, Appendix E, Section IV.B.2.

On June 24, 2016, OPPD certified that FCS would permanently cease power operations no later than December 31, 2016, in accordance with 10 CFR 50.82(a)(1)(i) (Reference 1). On August 25, 2016, OPPD certified that FCS would permanently cease power operations in accordance with 10 CFR 50.82(a)(1)(i) on October 24, 2016 (Reference 2).

444 South 16th Street Mall Omaha, NE 68102-2247

U.S. Nuclear Regulatory Commission LIC-16-0108 Page 2 On November 13, 2016 (Reference 3), pursuant to 10 CFR 50.82(a)(1)(ii), OPPD certified that the fuel has been permanently removed from the reactor vessel and placed in the spent fuel pool.

Therefore, pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for FCS no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel.

In Reference 4, OPPD submitted proposed changes to the FCS Emergency Plan to reduce the minimum required on-shift and Emergency Response Organization (ERO) staffing following the transition from an operating facility to a permanently defueled facility. In Reference 5, OPPD requested exemptions from portions of 10 CFR 50.47 and 10 CFR 50, Appendix E.

The proposed Permanently Defueled Emergency Plan (PDEP) and Permanently Defueled EAL scheme are commensurate with the significantly reduced spectrum of credible accidents that can occur in the permanently defueled condition and are necessary to properly reflect the conditions of the facility while continuing to preserve the effectiveness of the emergency plan. The proposed PDEP states FCS will maintain the ability to assess, classify, and declare an emergency within 30 minutes and that notification of an emergency declaration will be made to State and local authorities within 60 minutes of an emergency declaration or change in classification. Emergency declaration is required to be made as soon as conditions warranting classification are present and recognizable, but within 30 minutes in all cases of conditions being present.

Reference 5 included an analysis which shows that 530 days (1 year, 165 days) after permanent cessation of power operations, the spent fuel stored in the spent fuel pool will have decayed to the point where the requested exemptions (reference 5), PDEP, and Permanently Defueled EAL scheme may be implemented without additional compensatory actions. Following FCS shutdown, which occurred on October 24, 2016 (Reference 2), 530 days after permanent cessation of power operations will occur April 7, 2018.

The description, technical and regulatory evaluation, significant hazards determination, and environmental considerations evaluation for the proposed amendment are contained in . Attachment 2 provides a comparison of the proposed Permanently Defueled EAL Technical Bases Document to the corresponding information contained in NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 6. Enclosure 1 provides the proposed PDEP. Enclosure 2 provides the proposed Permanently Defueled EAL Technical Bases Document. Enclosure 3 provides the proposed Permanently Defueled EAL scheme.

The proposed changes have been evaluated in accordance with 10 CFR 50.91(a)(1) using criteria in 10 CFR 50.92(c), and FCS has determined that this change involves no significant hazards consideration. FCS has also determined that the proposed emergency plan changes satisfy the criteria for categorical exclusion in accordance with 10 CFR 51.22(c)(9) and do not require an environmental review. Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment is required.

In support of this license amendment and the associated exemption for the Permanently Defueled Emergency Plan, numerous discussions, both electronic and in person, have been held with the cognizant state (Nebraska and Iowa) and local response organizations. On October 13, 2016, FCS facilitated a presentation and discussion that included a line by line review of NSIR/DPR-ISG-02, Emergency Planning Exemption Requests for Decommissioning Nuclear Power Plants, which is the basis for the exemptions. Participants at this meeting include the States of Iowa and Nebraska, Washington and Douglas counties from Nebraska, and Regional leadership from the Federal Emergency Management Agency. Follow up conversations, via phone and email, have been made to address questions from that meeting.

U.S. Nuclear Regulatory Commission LIC-16-0108 Page 3 On December 8, 2016, FCS held the scheduled quarterly meeting with the States of Iowa and Nebraska, Douglas and Washington counties of Nebraska, Pottawattamie and Harrison Counties from Iowa, and Regional FEMA representatives. This meeting facilitated discussions on the process and plan changes that would be implemented at FCS as part of the Permanently Defueled Emergency Plan.

Pursuant to 10 CFR 50.91 , "Notice for public comment; State consultation," paragraph (b), OPPD is notifying the State of Nebraska of this application for license amendment by transmitting a copy of this letter and supporting attachments to the designated state official.

FCS requests review and approval of the proposed license amendment by December 30, 2017, with an effective date of April 7, 2018. Approval of these changes by December 30, 2017, will allow FCS adequate time to implement the changes to the emergency plan and EAL Scheme by the requested effective date.

The proposed changes have been reviewed and approved by the Fort Calhoun Station Plant Operations Review Committee (PORC) . This letter contains no new regulatory commitments.

If you should have any questions regarding this submittal , please contact Mr. Bradley H. Blome at (402) 533-7270.

I declare under penalty of perjury that the foregoing is true and correct. Executed on December 16, 2016.

Respectfully, Nf:JnP~

Shane M. Marik Fo,

Site Vice President and CNO Fort Calhoun Station Attachments: 1. Description of Proposed Changes, Technical and Regulatory Evaluation, Significant Hazards Determination, and Environmental Considerations

2. Comparison Matrix for Permanently Defueled EALs Based on NEI 99-01 ,

"Development of Emergency Action Levels for Non-Passive Reactors ,"

Revision 6

Enclosures:

1. Permanently Defueled Emergency Plan

2. Permanently Defueled Emergency Action Level Technical Bases Document

3. Permanently Defueled Emergency Action Level Scheme Matrix c:

K.M. Kennedy, NRC Regional Administrator, Region IV C.F. Lyon, NRC Senior Project Manager S.M. Schneider, NRC Senior Resident Inspector Director of Consumer Health Services, Department of Regulation and Licensure, Nebraska Health and Human Services, State of Nebraska

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION DOCKET NUMBER 50-285 / LICENSE NUMBER DPR-40 ATTACHMENT 1 DESCRIPTION OF PROPOSED CHANGES, TECHNICAL AND REGULATORY EVALUATION, SIGNIFICANT HAZARDS DETERMINATION, AND ENVIRONMENTAL CONSIDERATIONS

LIC-16-0108 Page 1 DESCRIPTION OF PROPOSED CHANGES, TECHNICAL AND REGULATORY EVALUATION, SIGNIFICANT HAZARDS DETERMINATION, AND ENVIRONMENTAL CONSIDERATIONS

Subject:

Revise the Fort Calhoun Station Emergency Plan and Emergency Action Level Scheme to Address the Permanently Defueled Condition 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION 2.1 Reason for the Proposed Changes 2.2 Background

3.0 TECHNICAL EVALUATION

3.1 Accident Analysis Overview 3.2 Consequences of a Design Basis Event 3.3 Consequences of a Beyond Design Basis Event 3.4 Consequences of Other Analyzed Events 3.5 Comparison to NUREG-1738 Industry Decommissioning Commitments and Staff Decommissioning Assumptions 3.6 Consequences of a Beyond Design Basis Earthquake 3.7 Permanently Defueled Emergency Plan 3.8 Permanently Defueled Emergency Action Levels 3.9 Conclusion

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements and Guidance 4.2 Precedent 4.3 No Significant Hazards Consideration Determination 4.4 Conclusion

5.0 ENVIRONMENTAL CONSIDERATION

S

6.0 REFERENCES

LIC-16-0108 Page 2 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend the Renewed Facility Operating License (OL)

DPR-40 for Fort Calhoun Station (FCS).

The proposed changes would revise the FCS Emergency Plan and Emergency Action Level (EAL) scheme to support the permanent cessation of power operations and permanent removal of fuel from the reactor vessel. This request contains the proposed FCS Permanently Defueled Emergency Plan (PDEP) and the Permanently Defueled Emergency Action Level (EAL) scheme for NRC review and approval.

The proposed PDEP and Permanently Defueled EAL scheme satisfy the applicable standards of 10 CFR 50.47(b) and the requirements of 10 CFR Part 50, Appendix E for a permanently defueled reactor, as exempted. OPPD has submitted a separate request for exemptions from portions of 10 CFR 50.47(b); 10 CFR 50.47(c)(2); and 10 CFR Part 50, Appendix E by letter dated December 16, 2016 (Reference 1). Reference 1 contained an analysis which demonstrated that 530 days (1 year, 165 days) after permanent cessation of power operations, the spent fuel stored in the spent fuel pool (SFP) will have decayed to the extent that the requested exemptions, PDEP, and Permanently Defueled EAL scheme may be implemented without any additional compensatory actions. FCS permanently shut down on October 24, 2016 (Reference 2), therefore, 530 days after permanent cessation of power operations will occur on April 7, 2018.

2.0 DETAILED DESCRIPTION The proposed amendment would modify the FCS license by revising the FCS Emergency Plan and the associated EAL scheme to reflect the permanent cessation of power operations and permanent defueling of the reactor. In the permanently defueled condition, the number and severity of potential radiological accidents is significantly less than when the facility was operating. Therefore, the offsite radiological consequences of postulated accidents at FCS are substantially lower. Because no postulated accident or reasonably conceivable beyond design basis event will be expected to result in radioactive releases that exceed Environmental Protection Agency (EPA) Protective Action Guides (PAGs) beyond the site boundary and the slow progression rate of postulated event scenarios indicate sufficient time is available to initiate appropriate mitigating actions to protect the health and safety of the public (Reference 1), the proposed PDEP states that FCS will maintain the ability to assess, classify, and declare an emergency within 30 minutes after the availability of indications to operators that an EAL threshold has been reached. Emergency declaration is required to be made as soon as conditions warranting classification are present and recognizable, but within 30 minutes in all cases of conditions being present. Notification of an emergency declaration will be made to State and County authorities within 60 minutes of an emergency declaration or change in classification. The proposed PDEP reduces the scope of onsite and offsite emergency planning activities commensurate with the spectrum of credible accidents that can occur in a permanently shutdown and defueled condition.

The proposed PDEP meets the applicable standards of 10 CFR 50.47(b) and requirements of 10 CFR Part 50, Appendix E, in view of the separately submitted request for exemptions (Reference 1).

LIC-16-0108 Page 3 The current EAL scheme is based on the guidance presented in NEI 99-01, Methodology for Development of Emergency Action Levels, Revision 6, (Reference 3) endorsed by the NRC in a letter dated March 28, 2013 (Reference 4). OPPD determined that a revision to implement the EAL scheme contained in Appendix C of NEI 99-01, Rev. 6 (Reference 3), Recognition Category PD (Permanently Defueled), is appropriate to address the permanently shutdown and defueled condition. This determination is supported by the analyses presented in Reference 1.

2.1 Reason for the Proposed Changes The proposed changes to the FCS Emergency Plan and EAL scheme are necessary to reflect the permanent cessation of power operations, permanent removal of fuel from the reactor, and the radiological conditions following 530 days of decay of the spent fuel in the SFP. FCS will submit a Post-Shutdown Decommissioning Activities Report (PSDAR) identifying the method FCS has selected for decommissioning. On November 13, 2016 (Reference 5), pursuant to 10 CFR 50.82(a)(1)(ii), OPPD certified that the fuel had been permanently removed from the reactor vessel and placed in the SFP. The irradiated fuel will be stored in the SFP and/or the Independent Spent Fuel Storage Installation (ISFSI) until it is removed by the Department of Energy (DOE).

The proposed revisions to the FCS Emergency Plan and EAL scheme are commensurate with the reduction in radiological hazards associated with the permanently shutdown and defueled condition and will allow the facility to transition to an emergency plan and EAL scheme required for a permanently defueled facility. The proposed changes are necessary to properly reflect the conditions of the facility 530 days following permanent cessation of power operations while continuing to maintain the effectiveness of the emergency plan and preserve the FCS Decommissioning Trust Fund.

2.2 Background FCS is located midway between Fort Calhoun and Blair, Nebraska, on the west bank of the Missouri River. The site consists of approximately 660.46 acres with an additional exclusion area of 582.18 acres on the northeast bank of the river directly opposite the plant buildings. FCS includes the ISFSI, located within the protected area, approximately 200 meters north-northwest of the Containment Building. The distance from the reactor containment to the nearest site boundary is approximately 910 meters; and the distance to the nearest residence is beyond the site boundary. Except for the city of Blair and the villages of Fort Calhoun and Kennard, the area within a ten-mile radius is predominantly rural. The land use within the ten-mile radius is primarily devoted to general farming. There are no private businesses or public recreational facilities on the plant property.

Chapter 14 of the FCS Final Safety Analysis Report as Updated (USAR) describes the accident scenarios that are applicable to FCS. Many of the accident scenarios postulated in the USAR for operating power reactors involve failures or malfunctions of systems, which could affect the fuel in the reactor vessel, which in the most severe postulated accidents, would involve the release of large quantities of fission products. With the termination of reactor operations and the permanent removal of fuel from the reactor vessel, such accidents are no longer possible.

Therefore, the postulated accidents involving failure or malfunction of the reactor, reactor cooling system, steam system, or turbine generator are no longer applicable.

LIC-16-0108 Page 4 On August 25, 2016, pursuant to 10 CFR 50.82(a)(1)(i) and 10 CFR 50.4(b)(8), OPPD certified to the NRC that FCS would permanently cease power operations on October 24, 2016 (Reference 2). On November 13, 2016 (Reference 5), pursuant to 10 CFR 50.82(a)(1)(ii), OPPD certified that the fuel has been permanently removed from the reactor vessel and placed in the SFP. Upon docketing of the certifications for permanent cessation of power operations (10 CFR 50.82(a)(1)(i)) and permanent removal of fuel from the reactor vessel (10 CFR 50.82(a)(1)(ii)), pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for FCS no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel. The irradiated fuel will be stored in the SFP and/or the ISFSI until it is removed by the DOE.

With the reactor permanently defueled, the SFP and its supporting systems will continue to be dedicated to the storage of spent fuel and other highly radioactive items. With the reactor permanently defueled, the reactor vessel assembly and supporting structures, systems, and components will no longer be in operation and will have no function related to the safe storage and management of irradiated fuel in the SFP. A SFP cooling and clean-up system is provided to remove decay heat from spent fuel stored in the SFP and to maintain a specified water temperature, purity, and clarity.

3.0 TECHNICAL EVALUATION

3.1 Accident Analysis Overview 10 CFR 50.82(a)(2) specifies that the 10 CFR Part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel after docketing the certifications for permanent cessation of power operations and permanent removal of fuel from the reactor vessel in accordance with 10 CFR 50.82(a)(1)(i) and (ii). Following the termination of power operations at FCS, and the permanent removal of the fuel from the reactor vessel, the postulated accidents involving failure or malfunction of the reactor and supporting structures, systems, and components are no longer applicable.

A summary of the postulated radiological accidents analyzed for the permanently shutdown and defueled condition is presented below. According to the EPA, Protective Action Guides and Planning Guidance for Radiological Incidents, Draft for Interim Use and Public Comment, dated March 2013 (Reference 6), Section 2.3.5, PAGs and Nuclear Facilities Emergency Planning Zones (EPZ), EPZs are not necessary at those facilities where it is not possible for PAGs to be exceeded offsite.

Section 5.0 of Interim Staff Guidance (ISG) - 02 (Reference 7) indicates that site-specific analyses should demonstrate that: (1) the radiological consequences of the remaining applicable postulated accidents would not exceed the limits of the EPA PAGs at the Exclusion Area Boundary (EAB); (2) in the event of a beyond design basis event resulting in the partial drain down of the SFP to the point that cooling is not effective, there is at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> (assuming an adiabatic heat up) from the time that the fuel is no longer being cooled until the hottest fuel assembly reaches 900 degrees Celsius (C); (3) adequate physical security is in place to assure implementation of security strategies that protect against spent fuel sabotage; and (4) in the unlikely event of a beyond design basis event resulting in a loss of all SFP cooling, there is sufficient time to implement pre-planned mitigation measures to provide makeup or spray to the SFP before the onset of a zirconium cladding ignition.

LIC-16-0108 Page 5 FCS described these analyses and provided each for NRC review in Reference 1. The specific analyses are summarized in the following sections.

3.2 Consequences of a Postulated Accident While spent fuel remains in the SFP, the only postulated accident that will remain applicable to FCS that could contribute to dose upon implementation of the requested exemptions is the fuel handling accident (FHA) in the Auxiliary Building, where the SFP is located. FCS maintains an analysis (Calculation FC08557, Fuel Handling Accident in the Spent Fuel Pool Site Boundary and Control Room Dose (Reference 31)) that has determined the Exclusion Area Boundary (EAB) dose due to a FHA occurring in the Auxiliary Building. The FHA analysis is performed using selective application of the Alternative Source Term (AST), the guidance in Regulatory Guide 1.183, Appendix B (Reference 8) and Total Effective Dose Equivalent (TEDE) dose criteria. The results of the analysis indicate that the EAB dose is within regulatory allowable limits for a FHA occurring in the Auxiliary Building within 10 days after shutdown.

The results of this analysis may be applied after November 13, 2016, the date that OPPD certified that all fuel has been permanently removed from the reactor vessel and placed in the SFP (Reference 5).

The analysis is also described in Reference 1.

3.3 Consequences of a Beyond Design Basis Event With respect to beyond design basis events, FCS analyzed a partial drain down of the SFP water that would effectively impede any decay heat removal (adiabatic heatup). The analysis (Calculation FC08104, Maximum Cladding Temperature Analysis for Adiabatic Heat-up of Spent Fuel Assembly (Reference 32) compares the conditions for the hottest fuel assembly stored in the FCS SFP to a criterion proposed in Commission Papers (SECY)-99-168 (Reference 9) applicable to offsite emergency response for a unit in the decommissioning process. This criterion considers the time for the hottest assembly to heat up from 30°C to 900°C adiabatically. If the heat up time is greater than 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> from the time spent fuel cooling is lost, then offsite emergency preplanning involving the facility is not necessary.

Based on the limiting fuel assembly decay heat and adiabatic heat up analysis, 530 days (1 year, 165 days) after permanent cessation of power operations is the time for the hottest fuel assembly to reach 900°C 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> after the assemblies have been uncovered. As stated in NUREG-1738, Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants, (February 2001) (Reference 10), 900°C is an acceptable temperature to use for assessing the onset of fission product release under transient conditions (to establish the critical decay time for determining availability of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to evacuate) if fuel and cladding oxidation occurs in air.

Because of the length of time it would take for adiabatic heat up to occur, there is ample time to respond to any partial drain down event that might cause such an occurrence by restoring SFP cooling or makeup, or providing spray. As a result, the likelihood that such a scenario would progress to a zirconium fire is not deemed credible. The analysis was submitted for NRC review in Reference 1.

LIC-16-0108 Page 6 3.4 Consequences of Other Analyzed Events FCS analyzed a drain down event of the SFP to determine a dose rate curve at the EAB and Control Room. NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, (Reference 11) Supplement 1, Section 4.3.9, identifies that a SFP drain down event is a beyond design basis event. Although Calculation FC08104, Maximum Cladding Temperature Analysis for Adiabatic Heat-up of Spent Fuel Assembly, demonstrated a significant release of radioactive material from the spent fuel is not possible in the absence of water cooling after 530 days (1 year, 165 days) following permanent cessation of power operations, the potential exists for radiation exposure to an offsite individual in the event that shielding of the fuel is lost. The SFP water and the concrete pool structure serve as radiation shielding. A loss of water shielding above the fuel could increase the offsite radiation levels because of the gamma rays streaming up out of the pool being scattered back to a receptor at the site boundary.

The offsite and Control Room radiological impacts of a postulated complete loss of SFP water were assessed in Calculation FC08513, EAB Radiation Shine Dose 18 Months Post Shutdown with the SFP Drained (Reference 33). It was determined that the gamma radiation dose rate at the EAB would be limited to small fractions of the EPA PAGs. The EPA PAGs were developed to respond to a mobile airborne plume that could transport and deposit radioactive material over a large area. In contrast, the radiation field formed by scatter from a drained SFP would be stationary rather than moving and would not cause transport or deposition of radioactive materials. The extended period required to exceed the EPA PAG limit of 1 Rem TEDE would allow sufficient time to develop and implement onsite mitigative actions and provide confidence that additional offsite measures could be taken without planning if efforts to reestablish shielding over the fuel are delayed.

Based on the data presented in Calculation FC08513, 530 days (1 year, 165 days) following permanent cessation of operations, the dose rate in the Control Room during an event involving a complete loss of SFP water will be below 2.32 x 10-3 mRem/hr, which is less than 15 mRem/hr.

The analysis was submitted for NRC review in Reference 1.

3.5 Comparison to NUREG-1738 Industry Decommissioning Commitments and Staff Decommissioning Assumptions Although the limited scope of the postulated accident and beyond design basis events that remain applicable to FCS justify a reduction in the necessary scope of emergency response capabilities, OPPD also evaluated the Industry Decommissioning Commitments (IDCs) and Staff Decommissioning Assumptions (SDAs) contained in NUREG-1738 (Reference 10).

LIC-16-0108 Page 7 NUREG-1738 contains the results of the NRC staffs evaluation of the potential accident risk in SFPs at decommissioning plants in the United States. The study was undertaken to support development of a risk-informed technical basis for reviewing regulatory exemption requests and a regulatory framework for integrated rulemaking. The NRC staff performed analyses and sensitivity studies on evacuation timing to assess the risk significance of relaxed offsite emergency preparedness requirements during decommissioning. The staff based its sensitivity assessment on the guidance in Regulatory Guide (RG) 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis (Reference 12). The staff's analyses and conclusions apply to decommissioning facilities with SFPs that meet the design and operational characteristics assumed in the risk analysis.

The study found that the risk of a potential SFP accident at decommissioning plants is low and well within the Commissions Safety Goals. The risk is low because of the very low likelihood of a zirconium fire (resulting from a postulated irrecoverable loss of SFP cooling water inventory) even though the consequences from a zirconium fire could be serious.

The study provided the following assessment:

The staff found that the event sequences important to risk at decommissioning plants are limited to large earthquakes and cask drop events. For emergency planning (EP) assessments, this is an important difference relative to operating plants where typically a large number of different sequences make significant contributions to risk. Relaxation of offsite EP a few months after shutdown resulted in only a "small change" in risk, consistent with the guidance of RG 1.174. Figures ES-1 and ES-2 [in NUREG-1738] illustrate this finding. The change in risk due to relaxation of offsite EP is small because the overall risk is low, and because even under current EP requirements, EP was judged to have marginal impact on evacuation effectiveness in the severe earthquakes that dominate SFP risk. All other sequences including cask drops (for which emergency planning is expected to be more effective) are too low in likelihood to have a significant impact on risk.

For comparison, at operating reactors, additional risk-significant accidents for which EP is expected to provide dose savings are on the order of 1x10-5 per year, while for decommissioning facilities, the largest contributor for which EP would provide dose savings is about two orders of magnitude lower (cask drop sequence at 2x10-7 per year).

The Executive Summary in NUREG-1738 states, in part, "the staff's analyses and conclusions apply to decommissioning facilities with SFPs that meet the design and operational characteristics assumed in the risk analysis. These characteristics are identified in the study as IDCs and SDAs. Provisions for confirmation of these characteristics would need to be an integral part of rulemaking." The IDCs and SDAs are listed in Tables 4.1-1 and 4.1-2, respectively, of NUREG-1738 (Reference 10). Tables 4 and 5 of Reference 1 identify how the FCS SFP meets or compares with each of these IDCs and SDAs.

LIC-16-0108 Page 8 3.6 Consequences of a Beyond Design Basis Earthquake NUREG-1738 (Reference 10) identifies beyond design basis seismic events as the dominant contributor to events that could result in a loss of SFP coolant that uncovers fuel for plants in the Central and Eastern United States. Additionally, NUREG-1738 identifies a zirconium fire resulting from a substantial loss-of-water inventory from the SFP, as the only postulated scenario at a decommissioning plant that could result in a significant offsite radiological release.

The scenarios that lead to this condition have very low frequencies of occurrence (i.e., on the order of one to tens of times in a million years) and are considered beyond design basis events because the SFP and attached systems are designed to prevent a substantial loss of coolant inventory under accident conditions. However, the consequences of such accidents could potentially lead to an offsite radiological dose in excess of the EPA PAGs (Reference 6) at the EAB.

However, the risk associated with zirconium cladding fire events decreases as the spent fuel ages, decay time increases, decay heat decreases, and short-lived radionuclides decay away.

As decay time increases, the overall risk of a zirconium cladding fire continues to decrease due to two factors: (1) the amount of time available for preventative actions increases, which reduces the probability that the actions would not be successful; and (2) the increased likelihood that the fuel is able to be cooled by air, which decreases the reliance on actions to prevent a zirconium fire. The results of research conducted for NUREG-1738 and NUREG-2161, Consequence Study of a Beyond-Design-Basis Earthquake Affecting the Spent Fuel Pool for a U.S. Mark I Boiling Water Reactor, dated September 2014 (Reference 13), suggest that, while other radiological consequences can be extensive, a postulated accident scenario leading to a SFP zirconium fire, where the fuel has had significant decay time, will have little potential to cause offsite early fatalities, regardless of the type of offsite response (i.e., formal offsite radiological emergency preparedness plan or Comprehensive Emergency Management Plan).

The purpose of NUREG-2161 (Reference 13) was to determine if accelerated transfer of older, colder spent fuel from the SFP at a reference plant to dry cask storage significantly reduces the risks to public health and safety. The study states that "this study's results are consistent with earlier research studies' conclusions that spent fuel pools are robust structures that are likely to withstand severe earthquakes without leaking cooling water and potentially uncovering the spent fuel. The study shows the likelihood of a radiological release from the spent fuel after the analyzed severe earthquake at the reference plant to be about one time in 10 million years or lower. If a leak and radiological release were to occur, this study shows that the individual cancer fatality risk for a member of the public is several orders of magnitude lower than the Commission's Quantitative Health Objective of two in one million (2 x 10-6/year). For such a radiological release, this study shows public and environmental effects are generally the same or smaller than earlier studies."

The reference plant for the study (a General Electric Type 4 BWR with a Mark I containment) generated approximately 3500 MWt and the SFP contained 2844 fuel assemblies. FCS is licensed to generate 1500 MWt, and the SFP has the capacity to hold 1083 fuel assemblies.

The SFP holds 944 fuel assemblies following permanent cessation of power operations and transfer of all fuel from the reactor vessel to the SFP. Based on these differences, the risk and the consequences of an event involving the SFP at FCS are lower than those in the NUREG-2161 study.

LIC-16-0108 Page 9 FCS conducted a seismic evaluation in response to a NRC request for information pursuant to 10 CFR 50.54(f) regarding Recommendation 2.1 of the Near-Term Task Force (NTTF) Review of Insights from the Fukushima Dai-ichi Accident. The seismic evaluation included all structures including the SFP, and was prepared and submitted for NRC review. The OPPD submittal (LIC-14-0047) (Reference 14) documents the seismic evaluation in conformance with NTTF Recommendation 2.1 including the high confidence of a low-probability of seismic failure (HCLPF) values and the 1 x 10-5 per year hazard level. The Staff review of the NTTF submittal, specifically for the SFP Evaluation associated with the reevaluated seismic hazard implementing NTTF Recommendation 2.1 (CAC No. MF3735) is documented in NRC-16-0068 (ML16182A361) (Reference 15). The NRC staff concluded that the assessment was performed consistent with the NRC-endorsed (ML15350A158) (Reference 16) SFP Evaluation Guidance Report (Reference 17) and provided sufficient information, including the SFP integrity evaluation, to meet the SFP Evaluation Guidance (Item 9 in Enclosure 1 of the NRCs 50.54(f) letter). The FCS response to other beyond design basis environmental events are also addressed in Tables 4 and 5 of Reference 1.

3.7 Permanently Defueled Emergency Plan The FCS PDEP is provided as Enclosure 1 of this submittal for NRC review and approval. The PDEP describes FCSs plan for responding to emergencies that may arise while in a permanently shutdown and defueled configuration. The PDEP was developed considering the guidance contained within Attachment 1 of ISG-02 (Reference 7).

The analyses of the potential radiological impact of accidents while the facility is in a permanently shutdown and defueled condition indicate that no postulated accident or reasonably conceivable beyond design basis event will be expected to result in radioactive releases that exceed EPA PAGs beyond the site boundary. The slow progression rate of postulated event scenarios indicate sufficient time is available to initiate appropriate mitigating actions to protect the health and safety of the public (Reference 1). Therefore, the proposed PDEP states that FCS will maintain the ability to assess, classify, and declare an emergency within 30 minutes after the availability of indications to operators that an EAL threshold has been reached. Emergency declaration is required to be made as soon as conditions warranting classification are present and recognizable, but within 30 minutes in all cases of conditions being present. Notification of an emergency declaration will be made to State and County authorities within 60 minutes of an emergency declaration or change in classification. Because of the geographic location of FCS, emergency planning and responsibilities have historically involved coordination with the States of Nebraska and Iowa. Decommissioning-related emergency plan submittals for FCS have been discussed with offsite response organizations since OPPD provided notification that it would permanently cease power operations. These discussions have addressed changes to onsite and offsite emergency preparedness throughout the decommissioning process, including the proposed 30-minute emergency declaration time and the 60-minute notification time to the State of Nebraska. Emergency management officials with both states have agreed that these proposed changes are appropriate.

LIC-16-0108 Page 10 Based on the results of accident analysis, the proposed emergency declaration and notification times and the reduced scope of onsite and offsite emergency response plans can be implemented without undue risk to public health and safety, commensurate with the reduced offsite radiological consequences associated with the permanently defueled and decommissioning status of the facility. As described in Enclosure 1, offsite notifications will be made via commercial telephone with wireless communications serving as the backup means of communication.

In the event of a large area fire, deliberate attack, or other rapidly developing beyond design basis events, the rapid deployment of offsite resources, including law enforcement, ambulance, and fire/rescue services may be requested by the station to assist with the onsite response.

These requests would be made via direct contact with local response agencies using established communications methods, including commercial telephones and the 9-1-1 system.

The PDEP addresses the applicable regulations contained in 10 CFR 50.47, Emergency Plans and 10 CFR Part 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities and is consistent with the applicable guidance established in ISG-02 (Reference 7) and NUREG-0654/FEMA-REP-1, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, (Reference 18) that remain applicable after the separately requested exemptions (Reference 1) are approved by the NRC.

3.8 Permanently Defueled Emergency Action Levels The current FCS EAL scheme was developed based on the guidance presented in NEI 99-01, Rev. 6 (Reference 3). provides the proposed Permanently Defueled EAL Technical Bases Document, containing the site-specific technical bases for the proposed Permanently Defueled EAL scheme. The EALs that comprise the proposed Permanently Defueled EAL scheme are also presented in the matrix provided in Enclosure 3.

3.8.1 Differences and Deviations provides a cross-reference between each generic EAL contained in NEI 99-01, Revision 6 (Reference 3) and the proposed Permanently Defueled EALs. Differences and deviations are identified in accordance with the guidance contained in NRC Regulatory Issue Summary (RIS) 2003-18, Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels, Revision 4, dated January 2003 (and Supplements)

(Reference 19). As discussed in RIS 2003-18, 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, and 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.

LIC-16-0108 Page 11 An explanation for each difference between the Permanently Defueled EALs and the guidance presented in NEI 99-01, Revision 6 is included in Attachment 2. The differences do not alter the meaning or intent of the Initiating Condition or EAL.

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.).

There are no deviations between the Permanently Defueled EALs and the guidance presented in NEI 99-01, Revision 6.

3.8.2 Operating Modes and Applicability The proposed Permanently Defueled EALs are only applicable in the permanently shutdown and defueled condition, with all fuel permanently removed from the reactor vessel and following 530 days of decay of the spent fuel.

3.8.3 State and Local Government Review of Proposed Changes State and local emergency management officials are advised of EAL changes that are implemented. Following NRC approval and prior to implementation, FCS will provide an overview of the new classification scheme to State and local emergency management officials in accordance with 10 CFR Part 50, Appendix E, Section IV.B.1.

3.9 Conclusion FCS has demonstrated that no postulated accident or reasonably conceivable beyond design basis event will result in radiological releases requiring offsite protective actions, or there is sufficient time, resources, and personnel available to initiate mitigative actions that will prevent an offsite release that exceeds EPA PAGs.

This proposed amendment would revise the FCS Emergency Plan and the EAL scheme to reflect the permanently shutdown and defueled condition following 530 days of decay of the spent fuel. The proposed PDEP and Permanently Defueled EAL scheme are being submitted to the NRC for approval prior to implementation, as required under 10 CFR 50.54(q)(4) and 10 CFR Part 50, Appendix E, Section IV.B.2.

4.0 REGULATORY EVALUATION

The proposed PDEP and Permanently Defueled EAL scheme implement the separately requested exemptions from portions of 10 CFR 50.47(b); 10 CFR 50.47(c)(2); and 10 CFR Part 50, Appendix E, Section IV, submitted in Reference 1.

LIC-16-0108 Page 12 4.1 Applicable Regulatory Requirements and Guidance 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) state, 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.

10 CFR 50.47(b) establishes the standards that the onsite and offsite emergency response plans must meet for NRC staff to make a positive finding that there is reasonable assurance that the licensee can and will take adequate protective measures in the event of a radiological emergency. Planning Standard (4) of this section (with exemption) (regulation requested for exemption in Reference 1 is included below in strikeout text) requires that a licensee's 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. This regulation states the following:

The changes to a licensee's 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 licensee's 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, "Emergency Planning and Preparedness for Production and Utilization Facilities," to 10 CFR Part 50, states, in part (with exemption):

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.

Section IV.B.2 of Appendix E states that: 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.

LIC-16-0108 Page 13 Section IV.C.1 of Appendix E requires (with exemption) 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 include: (1) notification of unusual events, (2) alert. EALs are used by facility personnel in determining the appropriate emergency classification level to declare.

In November 2012, NEI published NEI 99-01, Revision 6 (Reference 3). The EAL scheme being requested herein is based on Revision 6 to NEI 99-01. The NRC endorsed NEI 99-01, Revision 6, by letter dated March 28, 2013 (Reference 4). Because no postulated accident or reasonably conceivable beyond design basis event will be expected to result in radioactive releases that exceed EPA PAGs beyond the site boundary, or there is sufficient time to initiate appropriate mitigating actions to protect the health and safety of the public (Reference 1), the Permanently Defueled EALs, detailed in NEI 99-01, Revision 6, will be adopted, with certain differences. 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.

ISG-02 (Reference 7) contains guidance for NRC staff evaluation of decommissioning emergency plans.

The proposed amendment is being submitted to the NRC pursuant to 10 CFR 50.90, for the purpose of revising the FCS Emergency Plan in order to establish a plan appropriate for a permanently defueled facility and to implement a Permanently Defueled EAL scheme.

4.2 Precedent The changes to the FCS Emergency Plan and associated EAL scheme, including the change to assess, classify, and declare an emergency within 30 minutes, are consistent with changes to emergency plans and EALs for the transition to a permanently defueled condition that have recently been approved by the NRC for other nuclear power reactor facilities beginning decommissioning. Specifically, the NRC approved similar changes to: 1) Entergy Nuclear Operations, Inc. for the Vermont Yankee Nuclear Power Station on December 11, 2015, as identified in Reference 20; 2) Southern California Edison Company for the San Onofre Nuclear Generating Station, Units 1, 2, and 3 on June 5, 2015 (References 21 and 22); 3) Duke Energy Florida, Inc. for the Crystal River Unit 3 Nuclear Generating Station on March 31, 2015 (Reference 23); and Dominion Energy Kewaunee, Inc. for the Kewaunee Power Station on October 31, 2014 (Reference 24).

Similar changes to the emergency plan and the associated EAL scheme were approved by the NRC for the Zion station as it transitioned from an operating plant to a decommissioned facility, as described in References 25 and 26.

Increasing the notification time to responsible state and local governmental agencies to 60 minutes from emergency declaration was approved for the Haddam Neck Plant (Reference 27),

the La Crosse Boiling Water Reactor (LACBWR) facility (Reference 28), Maine Yankee (Reference 29) and Yankee Rowe (Reference 30).

LIC-16-0108 Page 14 4.3 No Significant Hazards Consideration Determination Pursuant to 10 CFR 50.92, OPPD has reviewed the proposed changes and concludes that the changes do not involve a significant hazards consideration because the proposed changes satisfy the criteria in 10 CFR 50.92(c). These criteria require that operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

The proposed changes would revise the FCS Emergency Plan and EAL scheme commensurate with the hazards associated with a permanently shutdown and defueled facility.

The discussion below addresses each of these criteria and demonstrates that the proposed amendment does not constitute a significant hazard.

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

Response: No.

The proposed changes to the FCS Emergency Plan and EAL scheme do not impact the function of facility structures, systems, or components. The proposed changes do not affect accident initiators or precursors, nor does it alter design assumptions. The proposed changes do not prevent the ability of the on-shift staff and emergency response organization to perform their intended functions to mitigate the consequences of any accident or event that will be credible in the permanently defueled condition.

The probability of occurrence of previously evaluated accidents is not increased, because most previously analyzed accidents can no longer occur and the probability of the few remaining credible accidents are unaffected by the proposed amendment.

Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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 reduce the scope of the FCS Emergency Plan and EAL scheme commensurate with the hazards associated with a permanently shutdown and defueled facility. The proposed changes do not involve installation of new equipment or modification of existing equipment, so that no new equipment failure modes are introduced. Also, the proposed changes do not result in a change to the way that the equipment or facility is operated resulting in new or different kinds of accident initiators or accident mitigation.

LIC-16-0108 Page 15 Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any previously evaluated.

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

Response: No.

Margin of safety is associated with confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public. The proposed changes are associated with the FCS Emergency Plan and EAL scheme and do not impact operation of the facility or its response to transients or accidents. The change does not affect the Technical Specifications. The proposed changes do not involve a change in the method of facility operation, and no accident analyses will be affected by the proposed changes. Safety analysis acceptance criteria are not affected by the proposed changes. The revised Emergency Plan will continue to provide the necessary response staff.

Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.

Based on the above, OPPD concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

4.4 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 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.

5.0 ENVIRONMENTAL CONSIDERATION

S This amendment request meets the eligibility criteria for categorical exclusion from environmental review set forth in 10 CFR 51.22(c)(9) as follows:

1. The amendment involves no significant hazards consideration.

As described in Section 4.3 of this evaluation, the proposed changes involve no significant hazards consideration.

2. There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

The proposed changes do not involve any physical alterations to the facility configuration or any changes to the operation of the facility that could lead to a change in the type or amount of effluent release offsite.

LIC-16-0108 Page 16

3. There is no significant increase in individual or cumulative occupational radiation exposure.

The proposed changes do not involve any physical alterations to the facility configuration or any changes to the operation of the facility that could lead to a significant increase in individual or cumulative occupational radiation exposure.

Based on the above, OPPD concludes that the proposed change meets the eligibility criteria for categorical exclusion as set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment is required to be prepared in connection with the issuance of this amendment.

LIC-16-0108 Page 17

6.0 REFERENCES

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

2. OPPD Letter (T. Burke) to USNRC (Document Control Desk) - Certification of Permanent Cessation of Power Operations, dated August 25, 2016 (LIC-16-0067)(ML16242A127)

3. Nuclear Energy Institute (NEI) 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, dated November 2012 (ML12326A805)

4. Letter, Mark Thaggard (USNRC) to Susan Perkins-Grew (NEI), U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 6, dated November, 2012 (TAC No. D92368), dated March 28, 2013 (ML12346A463)

5. OPPD Letter (T. Burke) to USNRC (Document Control Desk), Certification of Permanent Removal of Fuel from the Reactor Vessel, dated November 13, 2016 (LIC-16-0074)

(ML16319A254)

6. U.S. Environmental Protection Agency, Protective Action Guide and Planning Guidance for Radiological Incidents, Draft for Interim Use and Public Comment, dated March 2013 (PAG Manual)

7. NSIR/DPR-ISG-02, Interim Staff Guidance, Emergency Planning Exemption Requests for Decommissioning Nuclear Power Plants, dated May 11, 2015 (ML14302A490)

8. USNRC Regulatory Guide 1.183, Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors, July 2000

9. Commission Paper SECY-99-168, Improving Decommissioning Regulations for Nuclear Power Plants, dated June 30, 1999

10. NUREG-1738, Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants, dated February 2001 (ML010430066)

11. NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, dated October 2002

12. Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis

13. NUREG-2161, Consequence Study of a Beyond-Design-Basis Earthquake Affecting the Spent Fuel Pool for a U.S. Mark I Boiling Water Reactor, September 2014 (ML14255A365)

14. OPPD Letter (L. Cortopassi) to USNRC (Document Control Desk) - Omaha Public Power District (OPPD) Seismic Hazard and Screening Report (CEUS Sites), Response NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, dated March 31, 2014 (LIC-14-0047)(ML14097A087)

LIC-16-0108 Page 18

15. USNRC Letter to OPPD (S. Marik) - Fort Calhoun Station, Unit 1 - Staff Review of Spent Fuel Pool Evaluation Associated with Reevaluated Seismic Hazard Implementing Near-Term Task Force Recommendation 2.1 (CAC NO. MF3735), dated August 4, 2016 (ML16182A361)

16. Letter, Jack R. Davis (USNRC) to Joseph E. Pollock (NEI), Endorsement of Electric Power Research Institute Report 3002007148, Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation, dated March 17, 2016 (ML15350A158)

17. EPRI, Seismic Evaluation Guidance: Spent Fuel Pool Integrity Evaluation, Electric Power Research Institute Technical Update 3002007148, February, 2016 (ML16055A021)

18. NUREG-0654, FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, published November 1980

19. NRC Regulatory Issue Summary 2003-18, Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels, Revision 4, dated January 2003, and Supplements (ML032580518, ML041550395, and ML051450482)

20. Letter, USNRC to Entergy Nuclear Operations, Inc., Vermont Yankee Nuclear Power Station, Vermont Yankee Nuclear Power Station - Issuance of Amendment Re: Changes to the Emergency Plan and Emergency Action Levels (TAC No. MF4279), dated December 11, 2015 (ML15233A166)

21. Letter, USNRC to San Onofre Nuclear Generating Station, San Onofre Nuclear Generating Station, Units 1, 2, and 3 and the Independent Spent Fuel Storage Installation - Issuance of Amendments Re: Changes to the Emergency Action Level Scheme (TAC Nos. MF3838, MF3839, MF3840), dated June 5, 2015 (ML15105A349)

22. Letter, USNRC to San Onofre Nuclear Generating Station, San Onofre Nuclear Generating Station, Units 1, 2, and 3 and the Independent Spent Fuel Storage Installation - Issuance of Amendments Re: Changes to the Emergency Plan (TAC Nos. MF3841, MF3842, MF3843),

dated June 5, 2015 (ML15126A461)

23. Letter, USNRC to Crystal River Nuclear Plant (NA2C), Crystal River Unit 3 - Issuance of Amendment Regarding Changes to the Emergency Plan and Emergency Action Levels (TAC No. MF3415), dated March 31, 2015 (ML15027A209)

24. Letter, USNRC to Dominion Energy Kewaunee, Inc., Kewaunee Power Station - Issuance of Amendment for Changes to the Emergency Plan and Emergency Action Levels (TAC No.

MF3411), dated October 31, 2014 (ML14279A482)

25. Letter, USNRC to Zion Nuclear Power Station, Unit Nos. 1 and 2, Request For Approval of Defueled Station Emergency Plan and Exemption from Certain Requirements of 10 CFR 50.47, Emergency Plans- Zion Nuclear Power Station, Unit Nos. 1 and 2 (TAC NOs MA5253 and MA5254)," dated August 31, 1999 (ADAMS Legacy No. 9909070087)

LIC-16-0108 Page 19

26. Letter, USNRC to Zion Nuclear Power Station, Unit Nos. 1 and 2, Emergency Action Level Revisions for Zion Nuclear Power Station (TAC Nos. J00327 and J00328), dated February 25, 2008 (ML072680350)

27. Letter, USNRC to Connecticut Yankee Atomic Power Company, Response to Exemption Request for Portions of Title 10 of the Code of Federal Regulations Part 50 Appendix E, and Title 10 of the Code of Federal Regulations Part 50.47 for the Haddam Neck Plant (TAC No.

L24663), dated March 18, 2013 (ML13064A374)

28. Letter, USNRC to Dairyland Power Cooperative, La Crosse Boiling Water Reactor -

Issuance of Exemption From Certain Emergency Planning Requirements (TAC No.

J00438), dated July 31, 2013 (ML13008A565)

29. Letter, USNRC to Maine Yankee Atomic Electric Company, Response to Exemption Request for Portions of Title 10 of the Code of Federal Regulations Part 50 Appendix E, and Title 10 of the Code of Federal Regulations Part 50.47 for the Maine Yankee Atomic Power Station (TAC No. L24661), dated May 2, 2013 (ML13112A842)

30. Letter, USNRC to Yankee Rowe Plant ISFSI, Response to Exemption Request for Portions of Title 10 of the Code of Federal Regulations Part 50 Appendix E, and Title 10 of the Code of Federal Regulations Part 50.47 for the Yankee Rowe Plant (TAC No. L24662), dated May 7, 2013 (ML13121A560)

31. FCS Calculation FC08557, Fuel Handling Accident in the Spent Fuel Pool Site Boundary and Control Room Dose, (Proprietary)

32. FCS Calculation FC08104, Maximum Cladding Temperature Analysis for Adiabatic Heat-up of Spent Fuel Assembly

33. FCS Calculation FC08513, EAB Radiation Shine Dose 18 Months Post Shutdown with the SFP Drained (Proprietary)

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION DOCKET NUMBER 50-285 / LICENSE NUMBER DPR-40 ATTACHMENT 2 COMPARISON MATRIX FOR PERMANENTLY DEFUELED EALS BASED ON NEI 99-01, DEVELOPMENT OF EMERGENCY ACTION LEVELS FOR NON-PASSIVE REACTORS, REVISION 6

LIC-16-0108 Page 1 COMPARISON DOCUMENT FOR PERMANENTLY DEFUELED EALS BASED UPON NUCLEAR ENERGY INSTITUTE (NEI) 99-01, METHODOLOGY FOR DEVELOPMENT OF EMERGENCY ACTION LEVELS, REVISION 6

Subject:

Revise the Fort Calhoun Station Emergency Plan and Emergency Action Level Scheme to Address the Permanently Defueled Condition.

1.0 PURPOSE 2.0 DISCUSSION 3.0 KEY TERMINOLOGY USED 4.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS

5.0 REFERENCES

6.0 DEFINITIONS AND ACRONYMS 7.0 FCS TO NEI 99-01 EAL CROSS-REFERENCE 8.0 ATTACHMENTS 8.1 Attachment 1, Recognition Category PD EAL Bases 8.2 Attachment 2, Recognition Category E EAL Bases

LIC-16-0108 Page 2 Description of the Permanently Defueled EAL Technical Basis Document This document provide a description of each section in the proposed Fort Calhoun Station (FCS) Permanently Defueled (PD) Emergency Action Level (EAL) Technical Bases Document and describes the results of a comparison of the proposed FCS PD EAL scheme against the corresponding information contained in NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 6.

1.0 PURPOSE A comparison between this section and NEI 99-01 was not performed. The FCS PD EAL Technical Bases Document includes reference to the Recognition Category PD based on the facilitys permanently shut down and defueled condition, providing a stand-alone set of Initiating Conditions (ICs)/EALs for a permanently defueled nuclear power facility and Recognition Category E ICs for the Independent Spent Fuel Storage Installation (ISFSI).

2.0 DISCUSSION This section was developed based on information contained in NEI 99-01 Rev. 6, Section 1, Regulatory Background. Differences are discussed between the FCS PD EAL Technical Bases Document and NEI 99-01, Rev. 6. It also provides a description of a permanently defueled station (Section 2.1) and an Independent Spent Fuel Storage Installation (ISFSI)

(Section 2.2). It provides specific criteria for an ISFSI as it pertains to other regulations as well as guidance in NEI 99-01.

NEI 99-01, Section 1.1, Operating Reactors, was excluded as it pertains to operating reactors.

On November 13, 2016, pursuant to 10 CFR 50.82(a)(1)(ii), OPPD certified that the fuel has been permanently removed from the reactor vessel and placed in the spent fuel pool. Pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for FCS no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel. The EALs described in the FCS PD EAL Technical Bases Document will be implemented after FCS has permanently ceased power operations.

NEI 99-01, Section 1.5, Applicability to Advanced and Small Modular Reactor Designs, was excluded because it does not apply to FCS.

3.0 KEY TERMINOLOGY USED Differences between the FCS PD EALs Technical Bases Document and NEI 99-01, Rev. 6 are discussed below.

References to Site Area Emergency and General Emergency were removed throughout the section. EALs have been developed using Section 8 for the ISFSI and Appendix C for the permanently defueled station ICs/EALs. Emergency Classification Levels only include Notification of Unusual Event (Unusual Event) and Alert.

References to plant have been revised to facility to indicate that FCS is no longer an operating nuclear power plant.

LIC-16-0108 Page 3 References to company and owner have been revised to licensee to provide consistency throughout the document.

In Section 3.2, Initiating Condition (IC) (Section 2.2 of NEI 99-01, Rev. 6), references to RCS Leakage and fission product barriers were removed. Upon permanent cessation of operations, the RCS and Containment will no longer be considered fission product barriers because the reactor will be permanently defueled. In the permanently defueled condition, the fuel cladding is a fission product barrier. However, the Recognition Category F matrices containing EALs referred to as Fission Product Barrier Thresholds, are not applicable in the permanently defueled condition.

NEI 99-01, Section 2.4, Fission Product Barrier Threshold, was excluded for reasons previously identified related to fission product barriers.

4.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS This section was developed based on information contained in NEI 99-01, Section 5, Guidance on Making Emergency Classifications. Differences between the FCS Permanently Defueled EAL Technical Bases Document and NEI 99-01, Rev. 6 are discussed below.

In Section 4.1 (Section 5.1 of NEI 99-01), references to fission product barrier thresholds were removed as the RCS and Containment will no longer serve as fission product barriers upon permanent cessation of power operations and permanent removal of fuel from the reactor.

In Section 4.1 (Section 5.1 of NEI 99-01), the second paragraph of NEI 99-01 stating that, regulations require the licensee to establish and maintain the capability to assess, classify and declare an emergency condition within 15 minutes, was excluded. As detailed in NSIR/DPR-ISG-02, Interim Staff Guidance, Emergency Planning Exemption Requests for Decommissioning Plants, the staff concludes that a decommissioning power reactor is not required to assess, classify, and declare an emergency condition within 15 minutes. FCS will maintain the ability to assess, classify, and declare an emergency within 30 minutes. Emergency declaration is required to be made as soon as conditions warranting classification are present and recognizable, but within 30 minutes in all cases of conditions being present.

With respect to the notification of an emergency declaration to State and local authorities, no design basis accident or reasonably conceivable beyond design basis accident will be expected to result in radioactive releases that will exceed Environmental Protection Agency (EPA) Protective Action Guides (PAGs) beyond the site boundary. In the permanently defueled condition, the rapidly developing scenarios associated with events initiated during reactor power operation are no longer credible. The radiological consequences resulting from the only remaining events (e.g., fuel handling accident) develop over a significantly longer period. As such, a 15 minute notification requirement is unnecessarily restrictive. Sixty (60) minutes provides a reasonable amount of time to provide notification to state and local governmental authorities. This notification timeliness is also consistent with the notification requirement to the NRC Operations Center, contained in 10 CFR 50.72(a)(1)(i), for the declaration of an emergency class.

In Section 4.2 (Section 5.2 in NEI 99-01), reference to Operating Mode Applicability was removed because Operating Modes are not applicable to a permanently defueled facility.

LIC-16-0108 Page 4 In Section 4.3 (Section 5.3 of NEI 99-01), references to two units were removed because FCS is a single unit site.

Information provided in Section 5.4 of NEI 99-01 was excluded from the FCS PD EAL Technical Bases Document because mode changes during classification are not applicable to a permanently defueled facility.

In Section 4.4 (Section 5.5 of NEI 99-01), the word levels was changed to level because there is only one higher emergency classification level above an Unusual Event for a permanently defueled facility.

In Section 4.5 (Section 5.6 of NEI 99-01), references to Site Area Emergency and General Emergency were removed. Site Area Emergency and General Emergency are no longer credible emergency classifications at FCS. Also removed references to downgrading.

In Section 4.6 (Section 5.7 of NEI 99-01) references to an operating plant short-lived event (reactor trip) were removed and replaced with verbiage applicable to a permanently defueled facility.

In Section 4.7 (Section 5.8 of NEI 99-01) the example was removed because an emergency declaration associated with the auxiliary feedwater system is no longer credible at FCS. The reference to the 15 minute emergency classification was excluded for reasons presented above.

5.0 REFERENCES

This section was added to provide developmental and implementing references applicable to the FCS PD EAL Technical Bases Document. No corresponding section is included in NEI 99-01.

6.0 DEFINITIONS AND ACRONYMS This section was developed based on the information presented in Appendices A and B of NEI 99-01, Rev. 6. The list incorporates only those acronyms used in the FCS PD EAL Technical Bases Document.

The following definitions, included in NEI 99-01, Rev. 6, were excluded because they are not used in the FCS PD EAL Technical Bases Document:

General Emergency Site Area Emergency The following key term necessary for overall understanding of the NEI 99-01 emergency classification scheme was excluded because it was not used in the FCS PD EAL Technical Bases Document:

Fission Product Barrier Threshold The key term, Initiating Condition (IC), was revised to change four emergency classification levels to two emergency classification levels because Site Area Emergency and General Emergency are not used in the FCS PD EAL Technical Bases Document.

LIC-16-0108 Page 5 The key term, Emergency Classification Level, was revised to exclude reference to Site Area Emergency and General Emergency because they are not used in the FCS PD EAL Technical Bases Document.

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

These words are defined terms that have specific meanings as used in NEI 99-01, Rev. 6.

Definitions not used in the FCS PD EAL Technical Bases Document were excluded.

The term SAFETY SYSTEM was excluded because only those systems required to maintain spent fuel cooling are necessary in the permanently shut down and defueled condition. These systems are not, by definition, SAFETY SYSTEMS.

7.0 FCS TO NEI 99-01 EAL CROSS-REFERENCE There is no corresponding section included in NEI 99-01, Rev. 6. This section was added to facilitate association and location of a FCS PD EAL within the Appendix C NEI 99-01, Rev. 6 IC/EAL identification scheme. Further information regarding the development of the FCS PD EALs based on the NEI guidance can be found in the Recognition Category PD and ISFSI EAL Comparison Matrices in the Attachment 1 and 2 comparisons, respectively.

8.0 ATTACHMENTS 8.1 Attachment 1, Recognition Category PD EAL Bases Attachment 1 of the FCS PD EAL Technical Bases Document provides the PD IC/EALs and incorporates Appendix C of NEI 99-01, Rev. 6.

Reference to Section 3 of NEI 99-01, Rev. 6 was excluded.

References to Operating Modes were removed from Table PD-1.

The table included in Attachment 1, Comparison of FCS PD IC/EAL against NEI 99-01, Appendix C, Rev. 6 for Recognition Category PD, provides a comparison of the FCS PD EALs against the corresponding information contained in NEI 99-01, Rev. 6.

8.2 Attachment 2, Recognition Category E EAL Basis Attachment 2 of the FCS PD EAL Technical Bases provides the ISFSI IC/EALs and incorporates Section 8 of NEI 99-01, Rev. 6.

Reference to Operating Mode was removed from Table E-1.

The table included in the Attachment 2, "Comparison of FCS E IC/EAL against NEI 99-01, Rev. 6 for Recognition Category E, provides a comparison of the FCS ISFSI EALs against the corresponding information contained in NEI 99-01, Rev. 6.

LIC-16-0108 Page 6 NEI 99-01 Sections Not Included The following sections of NEI 99-01, Rev. 6 were not included and references made to these sections were also removed:

Section 3, Design of the NEI 99-01 Emergency Classification Scheme Section 4, Site-Specific Scheme Development Guidance The following sections of NEI 99-01, Rev. 6 were removed from the FCS Permanently Defueled EAL matrix as these do not apply to a permanently defueled facility:

Section 6, Abnormal Rad Levels/Radiological Effluent ICs/EALs, Section 7, Cold Shutdown/Refueling System Malfunction ICs/EALs, Section 9, Fission Product Barrier ICs/EALs, Section 10, Hazards and Other Conditions Affecting Plant Safety ICs/EALs, and Section 11, System Malfunction ICs/EALs.

LIC-16-0108 Page 7 Attachment 1 Comparison of FCS PD IC/EAL against NEI 99-01, Appendix C, Rev. 6 for Recognition Category PD

LIC-16-0108 Page 8 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station EAL for FCS ICs/EALs PD-AU1 PD-RU1 AU1 is replaced with RU1 to better signify a ECL: Notification of Unusual Event ECL: Unusual Event radiological event and to Initiating Condition: Release of gaseous Initiating Condition: Release of gaseous or liquid maintain continuity with the or liquid radioactivity greater than 2 times radioactivity greater than 2 times Offsite Dose Calculation previous FCS action level the (site-specific effluent release Manual (ODCM) limits for 60 minutes or longer. scheme.

controlling document) limits for 60 minutes or longer. Changed Notification of Unusual Event to Unusual Operating Mode Applicability: Not Event to maintain continuity Applicable with the previous FCS action Emergency Action Levels: (1 or 2) level scheme.

Example Emergency Action Levels: (1 or 2) Inserted Offsite Dose Notes: Notes: Calculation Monitor (ODCM) as the site specific effluent The Emergency Director should declare The Emergency Director should declare the Unusual Event release controlling the Unusual Event promptly upon promptly upon determining that 60 minutes has been document.

determining that 60 minutes has been exceeded, or will likely be exceeded.

exceeded, or will likely be exceeded. Removed Operating Mode If an ongoing release is detected and the release start time Applicability as it does not If an ongoing release is detected and is unknown, assume that the release duration has exceeded apply in a permanently the release start time is unknown, 60 minutes. defueled condition assume that the release duration has If the effluent flow past an effluent monitor is known to have Removed Example from exceeded 60 minutes.

stopped due to actions to isolate the release path, then the Emergency Action Levels as If the effluent flow past an effluent effluent monitor reading is no longer valid for classification they are no longer examples.

monitor is known to have stopped due purposes.

to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

LIC-16-0108 Page 9 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station EAL for FCS ICs/EALs (1) Reading on ANY effluent radiation 1. Reading on ANY Table R1 effluent monitors greater than 2 Removed radiation from monitor greater than 2 times the alarm times the alarm setpoint established by a current monitor notation. Pluralized setpoint established by a current radioactivity discharge permit for 60 minutes or longer. monitor.

radioactivity discharge permit for 60 minutes or longer. Included Table R1 to provide Table R1 - Effluent Monitor Thresholds effluent monitor description Effluent Monitor Description Value and threshold values.

RM-052 (aligned to AB Stack (gas) 2X High Alarm Replaced 2 times the alarm Aux Building stack) setpoint established by a RM-062 AB Stack (gas) 2X High Alarm current radioactivity RM-055 (if discharge Liquid Discharge 2X High Alarm discharge permit with 2 X not isolated) Header High Alarm.

OR Provided additional provisions for using sample

2. Sample analysis for a gaseous or liquid release indicates a analysis results of a gaseous concentration or release rate greater than 2 times the (2) Sample analysis for a gaseous or or liquid release as an action ODCM limits for 60 minutes.

liquid release indicates a concentration or level.

release rate greater than 2 times the (site-specific effluent release controlling document) limits for 60 minutes or longer.

NEI 99-01 Basis: Fort Calhoun Station Basis:

This IC addresses a potential decrease in This IC addresses a potential decrease in the level of safety of Added FCS specific basis the level of safety of the plant as indicated the facility as indicated by a low-level radiological release that information.

by a low-level radiological release that exceeds regulatory commitments for an extended period of time exceeds regulatory commitments for an (e.g., an uncontrolled release). It includes any gaseous or liquid Replaced plant with extended period of time (e.g., an radiological release, monitored or un-monitored, including those facility.

uncontrolled release). It includes any for which a radioactivity discharge permit is normally prepared. Split the explanation of the gaseous or liquid radiological release, two separate EAL criteria monitored or un-monitored, including those Fort Calhoun Station incorporates design features intended to thus providing additional control the release of radioactive effluents to the environment. provisions for using sample

LIC-16-0108 Page 10 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station EAL for FCS ICs/EALs for which a radioactivity discharge permit is Further, there are administrative controls established to prevent analysis results of a gaseous normally prepared. unintentional releases, and to control and monitor intentional or liquid release as an action releases. The occurrence of an extended, uncontrolled level.

Nuclear power plants incorporate design radioactive release to the environment is indicative of features intended to control the release of degradation in these features and/or controls.

radioactive effluents to the environment.

Further, there are administrative controls established to prevent unintentional Radiological effluent EALs are also included to provide a basis releases, and to control and monitor for classifying events and conditions that cannot be readily or intentional releases. The occurrence of an appropriately classified on the basis of facility conditions alone.

extended, uncontrolled radioactive release The inclusion of both facility condition and radiological effluent to the environment is indicative of EALs more fully addresses the spectrum of possible accident degradation in these features and/or events and conditions.

controls.

Classification based on effluent monitor readings assumes that Radiological effluent EALs are also a release path to the environment is established. If the effluent included to provide a basis for classifying flow past an effluent monitor is known to have stopped due to events and conditions that cannot be actions to isolate the release path, then the effluent monitor readily or appropriately classified on the reading is no longer valid for classification purposes.

basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully Releases should not be prorated or averaged. For example, a addresses the spectrum of possible release exceeding 4 times release limits for 30 minutes does accident events and conditions. not meet the EAL.

Classification based on effluent monitor EAL #1 addresses radioactivity releases that cause effluent readings assumes that a release path to the radiation monitor readings to exceed 2 times the limit environment is established. If the effluent established by a radioactivity discharge permit. This EAL will flow past an effluent monitor is known to typically be associated with planned batch releases from non-have stopped due to actions to isolate the continuous release pathways (e.g., radwaste, waste gas).

release path, then the effluent monitor reading is no longer valid for classification EAL #2 addresses uncontrolled gaseous or liquid releases that purposes.

are detected by sample analyses or environmental surveys, Releases should not be prorated or particularly on unmonitored pathways (e.g., spills of radioactive averaged. For example, a release

LIC-16-0108 Page 11 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station EAL for FCS ICs/EALs exceeding 4 times release limits for 30 liquids into storm drains, heat exchanger leakage in river water minutes does not meet the EAL. systems, etc.).

EAL #1 - This EAL addresses radioactivity releases that cause effluent radiation Escalation of the emergency classification level would be via IC monitor readings to exceed 2 times the limit PD-RA1.

established by a radioactivity discharge permit. This EAL will typically be associated Basis

Reference:

with planned batch releases from non-continuous release pathways (e.g., 1. NEI 99-01 Rev. 6, PD-AU1 radwaste, waste gas).

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

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

LIC-16-0108 Page 12 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station EAL for FCS ICs/EALs PD-AA1 PD-RA1 AA1 is replaced with RA1 ECL: Alert to better signify a ECL: Alert radiological event and to Initiating Condition: Release of gaseous Initiating Condition: Release of gaseous or liquid maintain continuity with the or liquid radioactivity resulting in offsite radioactivity resulting in offsite dose greater than 10 mRem previous FCS action level dose greater than 10 mRem TEDE or 50 TEDE or 50 mRem thyroid CDE. scheme.

mRem thyroid CDE.

Operating Mode Applicability: Not Removed Operating Mode Applicable Applicability as it does not Example Emergency Action Levels: (1 apply in a permanently Emergency Action Levels: (1 or 2 or 3 or 4) or 2 or 3 or 4) defueled condition Notes: Removed Example from Notes: Emergency Action Levels as The Emergency Director should they are no longer examples.

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

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

assume that the release duration has If the effluent flow past an effluent monitor is known to have exceeded 15 minutes. stopped due to actions to isolate the release path, then the If the effluent flow past an effluent effluent monitor reading is no longer valid for classification purposes.

monitor is known to have stopped due to actions to isolate the release path, The pre-calculated effluent monitor values presented in then the effluent monitor reading is no EAL #1 should be used for emergency classification longer valid for classification purposes. assessments until the results from a dose assessment The pre-calculated effluent monitor using actual meteorology are available.

values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

LIC-16-0108 Page 13 NEI 99-01 Rev 6 Appendix C - Proposed EAL Matrix for FCS Comparison Permanently Defueled Station ICs/EALs

1) Reading on ANY of the 1. A valid reading on ANY Table R2 effluent monitor greater than Added valid to better following radiation monitors the value shown for 15 minutes. enhance the identified greater than the reading information.

Table R2 - Effluent Monitor Thresholds shown for 15 minutes or longer: Effluent Monitor Description Value Removed ANY since RM-052 (aligned to AB Stack (gas) 9 x 106 cpm only one monitor is (site-specific monitor list and Aux Building Stack) listed.

threshold values)

RM-062 AB Stack (gas) 9 x 106 cpm Added site-specific

2) Dose assessment using actual RM-055 (if discharge Liquid Discharge 9 x 106 cpm monitor list and meteorology indicates doses not isolated) Header threshold values greater than 10 mRem TEDE or 50 mRem thyroid CDE at or OR Added site boundary beyond (site-specific dose 2. Dose assessment using actual meteorology indicates doses as the site specific dose receptor point). greater than 10 mRem TEDE or 50 mRem thyroid CDE at or receptor point.

3) Analysis of a liquid effluent beyond the site boundary. Calculation FC08515 sample indicates a OR was developed to concentration or release rate determine the RM-052 that would result in doses 3. Analysis of a liquid effluent sample indicates a concentration or and RM-062 monitor greater than 10 mRem TEDE release rate that would result in doses greater than 10 mRem threshold values.

or 50 mRem thyroid CDE at or TEDE or 50 mRem thyroid CDE at or beyond the site boundary beyond (site-specific dose for one hour of exposure. Calculation FC08516 receptor point) for one hour of was developed to exposure. OR determine the RM-055

4) Field survey results indicate 4. Field survey results indicate EITHER of the following at or monitor threshold value.

EITHER of the following at or beyond the site boundary:

beyond (site-specific dose Closed window dose rates greater than 10 mRem/hr receptor point): expected to continue for 60 minutes or longer.

Closed window dose rates Analyses of field survey samples indicate thyroid CDE greater than 10 mR/hr greater than 50 mRem for one hour of inhalation.

expected to continue for 60 minutes or longer.

Analyses of field survey samples indicate thyroid CDE

LIC-16-0108 Page 14 greater than 50 mRem for one hour of inhalation.

LIC-16-0108 Page 15 NEI 99-01 Rev 6 Appendix C - Proposed EAL Matrix for FCS Comparison Permanently Defueled Station ICs/EALs NEI 99-01 Basis: Fort Calhoun Station Basis: Replaced plant with facility.

This IC addresses a release of gaseous or This IC addresses a release of gaseous or liquid radioactivity that liquid radioactivity that results in projected results in projected or actual offsite doses greater than or equal to 1%

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

indicated by a radiological release that significantly exceeds regulatory limits (e.g., Radiological effluent EALs are also included to provide a basis for a significant uncontrolled release). classifying events and conditions that cannot be readily or appropriately classified on the basis of facility conditions alone. The Radiological effluent EALs are also inclusion of both facility condition and radiological effluent EALs more included to provide a basis for classifying fully addresses the spectrum of possible accident events and events and conditions that cannot be conditions.

readily or appropriately classified on the basis of plant conditions alone. The The TEDE dose is set at 1% of the EPA PAG of 1000 mRem while inclusion of both plant condition and the 50 mRem thyroid CDE was established in consideration of the 1:5 radiological effluent EALs more fully ratio of the EPA PAG for TEDE and thyroid CDE.

addresses the spectrum of possible accident events and conditions.

Classification based on effluent monitor readings assumes that a The TEDE dose is set at 1% of the EPA release path to the environment is established. If the effluent flow past PAG of 1,000 mRem while the 50 mRem an effluent monitor is known to have stopped due to actions to isolate thyroid CDE was established in the release path, then the effluent monitor reading is no longer valid consideration of the 1:5 ratio of the EPA for classification purposes.

PAG for TEDE and thyroid CDE.

The threshold value for RM-052 was determined via Calculation Classification based on effluent monitor FC08515. The RM-052 reading that corresponds to the 10 mRem readings assumes that a release path to TEDE (1.1 x 108 cpm) threshold exceeds the maximum count rate the environment is established. If the for the monitor (1 x 107 cpm). Based on the guidance presented in effluent flow past an effluent monitor is NEI 99-01, Rev. 6 the EAL threshold value is set at 90% of the known to have stopped due to actions to maximum monitor reading, corresponding to 9 x 106 cpm.

isolate the release path, then the effluent

LIC-16-0108 Page 16 monitor reading is no longer valid for The threshold value for RM-062 was determined via Calculation classification purposes. FC08515. The RM-062 reading that corresponds to the 10 mRem TEDE (9.3 x 107 cpm) threshold exceeds the maximum count rate for the monitor (1 x 107 cpm). Based on the guidance presented in NEI 99-01, Rev. 6 the EAL threshold value is set at 90% of the maximum monitor reading, corresponding to 9 x 106 cpm.

The threshold value for RM-055 was determined via Calculation FC08516. The RM-055 reading that corresponds to the 10 mRem TEDE threshold exceeds the maximum count rate for the monitor (1 x 107 cpm). Based on the guidance presented in NEI 99-01, Rev. 6 the EAL threshold value is set at 90% of the maximum monitor reading, corresponding to 9 x 106 cpm.

Basis

Reference:

1. NEI 99-01 Rev. 6, PD-AA1

2. FC08515

3. FC08516

LIC-16-0108 Page 17 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for FCS PD-AU2 PD-RU2 AU2 is replaced with RU2 to better signify a ECL: Notification of Unusual Event ECL: Unusual Event radiological event and Initiating Condition: UNPLANNED rise in Initiating Condition: UNPLANNED rise in facility radiation to maintain continuity plant radiation levels. levels. with the previous FCS action level scheme.

Operating Mode Applicability: Not Applicable Replaced plant with Example Emergency Action Levels: (1 or 2) Emergency Action Levels: (1 or 2) facility.

(1) a. UNPLANNED water level drop in the 1. a. UNPLANNED water level drop to below the normal spent fuel pool as indicated by ANY of the range in the spent fuel pool as indicated by the Changed Notification following: following: of Unusual Event to Unusual Event to LT-2846 (Spent Fuel Pool Level)

(Site specific level indications). maintain continuity with LI-2846 (Local Indication)

AND the previous FCS AND action level scheme.

b. UNPLANNED rise in area radiation levels as indicated by ANY of the following b. UNPLANNED rise in area radiation levels as indicated Removed Operating radiation monitors: by a valid reading on ANY radiation monitor in Table Mode Applicability as it R3 does not apply in a (Site specific level indications). permanently defueled Table R3 - Radiation Monitors (2) Area radiation monitor reading or survey RMS Area Monitored condition result indicates an UNPLANNED rise of 25 Removed Example RM-80, 85, 87 Spent Fuel Storage Area Radiation Monitor mR/hr over NORMAL LEVELS. from Emergency Action Portable Area Levels as they are no Auxiliary Building near fuel handling areas Rad Monitor longer examples.

OR Added to below the normal range to EAL

2. Area radiation monitor reading or survey result #1.a.

indicates an UNPLANNED rise of 25 mRem/hr over NORMAL LEVELS. Added a valid reading on to EAL #1.b.

Added site-specific monitor list and threshold values

LIC-16-0108 Page 18 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for FCS NEI 99-01 Basis: Fort Calhoun Station Basis: Added definitions for UNPLANNED: A parameter change or an event that is not: 1) UNPLANNED and This IC addresses elevated plant radiation the result of an intended evolution; or 2) an expected facility NORMAL LEVELS.

levels caused by a decrease in water level above irradiated (spent) fuel or other response to a transient. The cause of the parameter change Added FCS site-specific UNPLANNED events. The increased radiation or event may be known or unknown. basis information, levels are indicative of a minor loss in the ability NORMAL LEVELS: As applied to radiological IC/EALs, the instrumentation and to control radiation levels within the plant or highest reading in the past twenty-four hours excluding the documented references.

radioactive materials. Either condition is a current peak value. Replace plant with potential degradation in the level of safety of the facility.

This IC addresses elevated radiation levels caused by a plant. decrease in water level above irradiated (spent) fuel or other A water level decrease will be primarily UNPLANNED events. The increased radiation levels are determined by indications from available level indicative of a minor loss in the ability to control radiation instrumentation. Other sources of level levels within the facility or radioactive materials. Either indications may include reports from plant condition is a potential degradation in the level of safety of the personnel or video camera observations (if facility.

available). A significant drop in the water level A water level decrease will be primarily determined by may also cause an increase in the radiation indications from available level instrumentation. Other levels of adjacent areas that can be detected by sources of level indications may include reports from monitors in those locations. personnel or video camera observations (if available). A significant drop in the water level may also cause a rise in the The effects of planned evolutions should be radiation levels of adjacent areas that can be detected by considered. Note that EAL #1 is applicable only monitors in those locations.

in cases where the elevated reading is due to an UNPLANNED water level drop. EAL #2 The effects of planned evolutions should be considered. Note excludes radiation level increases that result that EAL #1 is applicable only in cases where the elevated from planned activities such as use of reading is due to an UNPLANNED water level drop. EAL #2 radiographic sources and movement of excludes radiation level increases that result from planned radioactive waste materials. activities such as the use of radiographic sources and movement of radioactive waste materials.

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

IC PD-RA1 or PD-RA2.

Basis

Reference:

1. NEI 99-01 Rev. 6, PD-AU1

LIC-16-0108 Page 19 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for FCS PD-AA2 PD-RA2 AA2 is replaced with RA2 to better signify a ECL: Alert ECL: Alert radiological event and to Initiating Condition: UNPLANNED rise in Initiating Condition: UNPLANNED rise in facility radiation maintain continuity with plant radiation levels that impedes plant access levels that impedes facility access required to maintain the previous FCS action required to maintain spent fuel integrity. spent fuel integrity. level scheme.

Operating Mode Applicability: Not Applicable Replaced plant with facility.

Example Emergency Action Levels: (1 or 2) Emergency Action Levels: (1 or 2)

(1) UNPLANNED dose rate greater than 1. UNPLANNED dose rate greater than 15 mRem/hr in Removed Operating Mode 15 mR/hr in ANY of the following areas ANY of the following areas requiring continuous Applicability as it does not requiring continuous occupancy to maintain occupancy to maintain control of radioactive material or apply in a permanently control of radioactive material or operation of operation of systems needed to maintain spent fuel defueled condition systems needed to maintain spent fuel integrity: integrity. Removed Example from Main Control Room Emergency Action Levels (site-specific area list)

Central Alarm Station as no longer example.

(2) UNPLANNED Area Radiation Monitor readings or survey results indicate a rise by 100 OR Replace mR/hr with mR/hr in ANY of the following areas needed to 2. Area Radiation Monitor readings or survey results mRem/hr maintain control of radioactive material or indicate an UNPLANNED rise by 100 mRem/hr over Reworded the EAL #2 to operation of systems needed to maintain spent NORMAL LEVELS that impedes access to ANY of the provide better guidance fuel integrity. following areas needed to maintain control of radioactive concerning access to (site specific area list) material or operation of systems needed to maintain areas.

spent fuel integrity.

Added site specific areas Room 4 Room 5 Room 24 Room 25 Room 26 Room 69

LIC-16-0108 Page 20 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for FCS Basis: Fort Calhoun Station Basis: Added definitions for NORMAL LEVELS and This IC addresses increased radiation levels NORMAL LEVELS: As applied to radiological IC/EALs, the UNPLANNED.

that impede necessary access to areas highest reading in the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> excluding the current containing equipment that must be operated peak value. Replace plant with manually or that requires local monitoring, in facility.

UNPLANNED: a parameter change or an event that is not 1) order to maintain systems needed to maintain the result of an intended evolution; or 2) an expected facility spent fuel integrity. As used here, impede response to a transient. The cause of the parameter change includes hindering or interfering, provided that or event may be known or unknown.

the interference or delay is sufficient to significantly threaten necessary plant access. It This IC addresses increased radiation levels, as discussed is this impaired access that results in the actual in NEI 99-01, that impede necessary access to areas or potential substantial degradation of the level containing equipment that must be operated manually or of safety of the plant. that requires local monitoring, in order to maintain systems needed to maintain spent fuel integrity. As used here, This IC does not apply to anticipated temporary impede includes hindering or interfering, provided that the increases due to planned events.

interference or delay is sufficient to significantly threaten necessary facility access. It is this impaired access that results in the actual or potential substantial degradation of the level of safety of the facility.

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

Basis

Reference:

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

LIC-16-0108 Page 21 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for FCS PD-HU1 PD-HU1 Changed Notification of Unusual Event to Unusual ECL: Notification of Unusual Event ECL: Unusual Event Event to maintain continuity Initiating Condition: Confirmed SECURITY Initiating Condition: Confirmed SECURITY with the previous FCS action CONDITION or threat. CONDITION or threat. level scheme.

Operating Mode Applicability: Not Applicable Removed Operating Mode Applicability as it does not Example Emergency Action Levels: (1 or 2 Emergency Action Levels: (1 or 2 or 3) apply in a permanently or 3) defueled condition.

1. A SECURITY CONDITION that does not

1. A SECURITY CONDITION that does not involve a Removed Example from involve a HOSTILE ACTION as reported by HOSTILE ACTION as reported by the Security Shift Emergency Action Levels as the (site-specific security shift supervision).

Supervisor. no longer example.

2. Notification of a credible security threat OR Security Force is provided as directed at the site. the site-specific security shift

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

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

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

LIC-16-0108 Page 22 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for FCS NEI 99-01 Basis: Fort Calhoun Station Basis: Added definitions for HOSTAGE, HOSTAGE This IC addresses events that pose a threat to HOSTAGE: A person(s) held as leverage against the ACTION, PROJECTILE, plant personnel or the equipment necessary to licensee to ensure that demands will be met by the facility.

and SECURITY maintain cooling of spent fuel, and thus HOSTILE ACTION: An act toward a facility or its personnel CONDITION.

represent a potential degradation in the level of that includes the use of violent force to destroy equipment, Replace plant with plant safety. Security events which do not meet take HOSTAGES, and/or intimidate the licensee to achieve facility.

one of these EALs are adequately addressed by an end. This includes attack by air, land, or water using the requirements of 10 CFR § 73.71 or 10 CFR guns, explosives, PROJECTILES, vehicles, or other

§ 50.72. Security events assessed as HOSTILE devices used to deliver destructive force. Other acts that ACTIONS are classifiable under IC PD-HA1.

satisfy the overall intent may be included. HOSTILE Timely and accurate communications between ACTION should not be construed to include acts of civil Security Shift Supervision and the Control disobedience or felonious acts that are not part of a Room is essential for proper classification of a concerted attack on the facility. Non-terrorism-based EALs security-related event. Classification of these should be used to address such activities (i.e., this may events will initiate appropriate threat-related include violent acts between individuals in the owner notifications to plant personnel and OROs. controlled area).

Security plans and terminology are based on PROJECTILE An object directed toward a facility that could the guidance provided by NEI 03-12, Template cause concern for its continued operability, reliability, or for the Security Plan, Training and Qualification personnel safety.

Plan, Safeguards Contingency Plan [and SECURITY CONDITION: Any Security Event as listed in Independent Spent Fuel Storage Installation the approved security contingency plan that constitutes a Security Program].

threat/compromise to site security, threat/risk to site This EAL references (site-specific security shift personnel, or a potential degradation to the level of safety supervision) because these are the individuals of the facility. A SECURITY CONDITION does not involve trained to confirm that a security event is a HOSTILE ACTION.

occurring or has occurred. Training on security This IC addresses events that pose a threat to facility event confirmation and classification is personnel or the equipment necessary to maintain spent controlled due to the nature of Safeguards and fuel integrity, and thus represent a potential degradation in 10 CFR § 2.390 information.

the level of facility safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.

Security events assessed as HOSTILE ACTIONS are classifiable under IC PD-HA1.

LIC-16-0108 Page 23 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for FCS Timely and accurate communications between Security Provided additional Shift Supervision and the Control Room is essential for information for each of the proper classification of a security-related event. 3 EALs Classification of these events will initiate appropriate threat-related notifications to facility personnel and Off-Site Response Organizations.

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

EAL #1 references Security Shift Supervisor because these are the individuals trained to confirm that a security event is occurring or has occurred. Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR § 2.390 information.

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

The credibility of the threat is assessed in accordance with SY-AA-101-132, Security Assessment and Response to Unusual Activities.

EAL #3 addresses the threat from the impact of an aircraft on the facility. 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 AOP-37, Security Events.

Escalation of the emergency classification level would be via IC PD-HA1.

Basis

Reference:

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

LIC-16-0108 Page 24 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for FCS PD-HA1 PD-HA1 Removed Operating Mode Applicability as it does not ECL: Alert ECL: Alert apply in a permanently Initiating Condition: HOSTILE ACTION within Initiating Condition: HOSTILE ACTION within the defueled condition.

the OWNER CONTROLLED AREA or airborne OWNER CONTROLLED AREA or airborne attack threat attack threat within 30 minutes. within 30 minutes. Removed Example from Emergency Action Levels as Operating Mode Applicability: Not Applicable no longer example.

Example Emergency Action Levels: (1 or 2) Emergency Action Levels: (1 or 2) Security Force is provided as (1) A HOSTILE ACTION is occurring or has 1. A HOSTILE ACTION is occurring or has occurred the site-specific security shift occurred within the OWNER within the OWNER CONTROLLED AREA as supervision.

CONTROLLED AREA as reported by reported by the Security Shift Supervisor.

the (site-specific security shift OR supervision).

2. A validated notification from NRC of an aircraft (2) A validated notification from NRC of an attack threat within 30 minutes of the site.

aircraft attack threat within 30 minutes of the site.

LIC-16-0108 Page 25 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for FCS NEI 99-01 Basis: Fort Calhoun Basis: Added the definitions for HOSTAGE, HOSTILE This IC addresses the occurrence of a HOSTILE HOSTAGE: A person(s) held as leverage against the ACTION, HOSTILE FORCE, ACTION within the OWNER CONTROLLED licensee to ensure that demands will be met by the facility.

OWNER CONTROLLED AREA. This event will require rapid response and AREA (OCA), PROJECTILE, assistance due to the possibility of the attack HOSTILE ACTION: An act toward a facility or its personnel and PROTECTED AREA.

progressing to the PROTECTED AREA. that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve Replaced plant with Timely and accurate communications between an end. This includes attack by air, land, or water using facility.

Security Shift Supervision and the Control Room guns, explosives, PROJECTILES, vehicles, or other is essential for proper classification of a security-devices used to deliver destructive force. Other acts that Provided additional related event. information for each of the 2 satisfy the overall intent may be included. HOSTILE Security plans and terminology are based on the ACTION should not be construed to include acts of civil EALs guidance provided by NEI 03-12, Template for disobedience or felonious acts that are not part of a the Security Plan, Training and Qualification concerted attack on the facility. Non-terrorism-based EALs Plan, Safeguards Contingency Plan [and should be used to address such activities (i.e., this may Independent Spent Fuel Storage Installation include violent acts between individuals in the owner Security Program]. controlled area).

As time and conditions allow, these events HOSTILE FORCE: One or more individuals who are require a heightened state of readiness by the engaged in a determined assault, overtly or by stealth and plant staff and implementation of onsite deception, equipped with suitable weapons capable of protective measures (e.g., evacuation, dispersal killing, maiming, or causing destruction.

or sheltering). The Alert declaration will also heighten the awareness of Offsite Response OWNER CONTROLLED AREA (OCA): The property Organizations, allowing them to be better associated with the facility and owned by the licensee.

prepared should it be necessary to consider Access is normally limited to persons entering for official further actions. business.

This IC does not apply to incidents that are accidental events, acts of civil disobedience, or PROJECTILE: An object directed toward a facility that otherwise are not a HOSTILE ACTION could cause concern for its continued operability, reliability, perpetrated by a HOSTILE FORCE. Examples or personnel safety.

include the crash of a small aircraft, shots from hunters, physical disputes between employees, PROTECTED AREA: The area normally within the facility etc. Reporting of these types of events is security fence designated to implement the security adequately addressed by other EALs, or the requirements of 10 CFR 73.

LIC-16-0108 Page 26 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for FCS requirements of 10 CFR § 73.71 or 10 CFR § This IC addresses the occurrence of a HOSTILE ACTION 50.72. within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the facility and staff for a potential aircraft impact.

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

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

As time and conditions allow, these events require a heightened state of readiness by the facility staff and implementation of onsite protective measures (e.g.,

evacuation, dispersal or sheltering). The Alert declaration will also heighten the awareness of Offsite Response Organizations (OROs), allowing them to be better prepared should it be necessary to consider further actions.

This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE.

Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc.

Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.

LIC-16-0108 Page 27 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for FCS EAL #1 is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA.

This includes any action directed against the ISFSI.

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

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

In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.

Basis

Reference:

1. NEI 99-01 Rev. 6, PD-HA1

LIC-16-0108 Page 28 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station EAL for FCS ICs/EALs PD-HU2 PD-HU2 Changed Notification of Unusual Event to Unusual Event to maintain continuity ECL: Notification of Unusual Event ECL: Unusual Event with the previous FCS action level Initiating Condition: Hazardous event Initiating Condition: Hazardous event affecting equipment scheme.

affecting SAFETY SYSTEM equipment necessary for spent fuel cooling.

necessary for spent fuel cooling. Removed Operating Mode Applicability as it does not apply in a permanently Operating Mode Applicability: Not defueled condition.

Applicable Removed Example from Emergency Example Emergency Action Levels: Emergency Action Levels: Action Levels as no longer example.

(1) a. The occurrence of ANY of the 1. a. The occurrence of ANY of the following hazardous events: Added low river level as site specific following hazardous events: hazard.

Seismic event (earthquake)

Seismic event (earthquake) Removed SAFETY SYSTEM as the Internal or external flooding event Internal or external flooding term is not applicable in the permanently event High winds or tornado strike shut down and defueled condition.

High winds or tornado strike FIRE FIRE EXPLOSION EXPLOSION Low river level as indicated by less than 976 feet, 9 inches MSL elevation (site-specific hazards)

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

b. The event has damaged at least one train of a system

b. The event has damaged at needed for spent fuel cooling.

least one train of a SAFETY SYSTEM needed for spent fuel AND cooling.

c. The damaged equipment cannot, or potentially cannot, AND perform its design function based on EITHER:

c. The damaged SAFETY SYSTEM train(s) cannot, or Indications of degraded performance potentially cannot, perform its VISIBLE DAMAGE

LIC-16-0108 Page 29 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station EAL for FCS ICs/EALs design function based on EITHER:

Indications of degraded performance VISIBLE DAMAGE NEI 99-01 Basis: Fort Calhoun Station Basis: Added definitions for EXPLOSION, FIRE, and VISIBLE DAMAGE.

This IC addresses a hazardous event that EXPLOSION: A rapid, violent and catastrophic failure of a piece of causes damage to at least one train of a equipment due to combustion, chemical reaction or over Replaced plant with facility.

SAFETY SYSTEM needed for spent fuel pressurization. A release of steam (from high energy lines or The designation AA is revised to RA cooling. The damage must be of sufficient components) or an electrical component failure (caused by short to better signify radioactivity and to magnitude that the system(s) train cannot, circuits, grounding, arcing, etc.) should not automatically be maintain continuity with the previous or potentially cannot, perform its design considered an explosion. Such events may require a post-event FCS action level scheme.

function. This condition reduces the margin inspection to determine if the attributes of an explosion are Replaced SAFETY SYSTEM with to a loss or potential loss of the fuel clad present. equipment.

barrier, and therefore represents a potential degradation of the level of safety FIRE: Combustion characterized by heat and light. Sources of of the plant. smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is For EAL 1.c, the first bullet addresses preferred but is NOT required if large quantities of smoke and heat damage to a SAFETY SYSTEM train that are observed.

is in service/operation since indications for it will be readily available.

VISIBLE DAMAGE: Damage to a component or structure that is For EAL 1.c, the second bullet addresses readily observable without measurements, testing, or analysis.

damage to a SAFETY SYSTEM train that The visual impact of the damage is sufficient to cause concern is not in service/operation or readily regarding the operability or reliability of the affected component or apparent through indications alone. structure.

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.

LIC-16-0108 Page 30 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station EAL for FCS ICs/EALs Escalation of the emergency classification This IC addresses a hazardous event that causes damage to at level could, depending upon the event, be least one train of equipment needed for spent fuel cooling. The based on any of the Alert ICs; PD-AA1, damage must be of sufficient magnitude that the system(s) train PD-AA2, PD-HA1 or PD-HA3. cannot, or potentially cannot, perform its intended function. This condition reduces the margin to a loss or potential loss of the fuel clad barrier, and therefore represents a potential degradation of the level of safety of the facility.

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

For EAL 1.c., the second bullet addresses damage to equipment that is not in service/operation or readily apparent through indications alone. Operators will make this determination based on the totality of available event and damage report information.

This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.

Escalation of the emergency classification level could, depending upon the event, be based on any of the ALERT ICs:

PD-RA1, PD-RA2, PD-HA1, or PD-HA3 Basis

Reference:

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

LIC-16-0108 Page 31 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station EAL for FCS ICs/EALs PD-HU3 PD-HU3 Changed Notification of Unusual Event to Unusual ECL: Notification of Unusual Event ECL: Unusual Event Event to maintain continuity Initiating Condition: Other conditions Initiating Condition: Other conditions exist which in the with the previous FCS action exist which in the judgment of the judgment of the Emergency Director warrant declaration of an level scheme.

Emergency Director warrant declaration of Unusual Event.

a (NO)UE. Removed Operating Mode Applicability as it does not Operating Mode Applicability: Not apply in a permanently Applicable defueled condition.

Example Emergency Action Levels: Emergency Action Levels: Removed Example from (1) Other conditions exist which in the 1. Other conditions exist which in the judgment of the Emergency Action Levels as judgment of the Emergency Emergency Director indicate that events are in no longer example.

Director indicate that events are in progress or have occurred which indicate a potential Replaced plant with progress or have occurred which degradation of the level of safety of the facility or facility.

indicate a potential degradation of indicate a security threat to facility protection has been the level of safety of the plant or initiated. No releases of radioactive material requiring Replaced SAFETY indicate a security threat to facility offsite response or monitoring are expected unless SYSTEMS with systems protection has been initiated. No further degradation of systems needed to maintain needed to maintain spent releases of radioactive material spent fuel cooling occurs. fuel cooling.

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

LIC-16-0108 Page 32 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station EAL for FCS ICs/EALs NEI 99-01 Basis: Fort Calhoun Station Basis:

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

under the emergency classification level description for an Unusual Event. Basis

Reference:

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

LIC-16-0108 Page 33 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station EAL for FCS ICs/EALs PD-HA3 PD-HA3 Removed Operating Mode ECL: Alert ECL: Alert Applicability as it does not apply in a permanently Initiating Condition: Other conditions Initiating Condition: Other conditions exist which in the defueled condition.

exist which in the judgment of the judgment of the Emergency Director warrant declaration of an Emergency Director warrant declaration of Alert. Removed Example from an Alert. Emergency Action Levels as no longer example.

Operating Mode Applicability: Not Applicable Replaced plant with Example Emergency Action Levels: Emergency Action Levels: facility.

1. Other conditions exist which in the 1. Other conditions exist which in the judgment of the judgment of the Emergency Emergency Director indicate that events are in Director indicate that events are in progress or have occurred which involve an actual or progress or have occurred which potential substantial degradation of the level of safety involve an actual or potential of the facility or a security event that involves probable substantial degradation of the level life threatening risk to site personnel or damage to site of safety of the plant or a security equipment because of HOSTILE ACTION. Any event that involves probable life releases are expected to be limited to small fractions of threatening risk to site personnel the EPA Protective Action Guideline exposure levels.

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.

LIC-16-0108 Page 34 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station EAL for FCS ICs/EALs NEI 99-01 Basis: Fort Calhoun Station Basis: Added definitions for HOSTAGE, HOSTILE This IC addresses unanticipated conditions HOSTAGE: A person(s) held as leverage against the licensee to ACTION, and not addressed explicitly elsewhere but that ensure that demands will be met by the facility.

PROJECTILE.

warrant declaration of an emergency because conditions exist which are HOSTILE ACTION: An act toward a facility or its personnel that believed by the Emergency Director to fall includes the use of violent force to destroy equipment, take under the emergency classification level HOSTAGES, and/or intimidate the licensee to achieve an end.

description for an Alert. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the facility. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).

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

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

Basis

Reference:

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

LIC-16-0108 Page 35 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station EAL for FCS ICs/EALs PD-SU1 PD-SU1 Changed Notification of Unusual Event to Unusual ECL: Notification of Unusual Event ECL: Unusual Event Event to maintain continuity Initiating Condition: UNPLANNED spent Initiating Condition: UNPLANNED spent fuel pool with the previous FCS action fuel pool temperature rise. temperature rise. level scheme.

Operating Mode Applicability: Not Removed Operating Mode Applicable Applicability as it does not apply in a permanently Example Emergency Action Levels: Emergency Action Levels:

defueled condition.

(1) UNPLANNED spent fuel pool 1. UNPLANNED spent fuel pool temperature rise to temperature rise to greater than greater than 150F as indicated on T408A/B/C or Removed Example from locally by handheld instrument. Emergency Action Levels as (site-specific F).

no longer example.

Site specific temperature and instrument.

NEI 99-01 Basis: Fort Calhoun Station Basis: Added the definition for UNPLANNED.

This IC addresses a condition that is a UNPLANNED: A parameter change or an event that is not: 1) precursor to a more serious event and the result of an intended evolution; or 2) an expected facility Replaced plant with represents a potential degradation in the response to a transient. The cause of the parameter change or facility.

level of safety of the plant. If uncorrected, event may be known or unknown.

boiling in the pool will occur, and result in a AA2 is replaced with This IC addresses a condition that is a precursor to a more RA2 to better signify a loss of pool level and increased radiation serious event and represents a potential degradation in the radiological event and to levels.

level of safety of the facility. If uncorrected, boiling in the pool maintain continuity with the Escalation of the emergency classification will occur and result in a loss of pool level and increased previous FCS action level level would be via IC PD-AA1 or PD-AA2. radiation levels. scheme.

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

Basis

Reference:

1. NEI 99-01 Rev. 6, PD-SU1

LIC-16-0108 Page 36 Attachment 2 Comparison of FCS E IC/EALs against NEI 99-01, rev. 6 for Recognition Category E

LIC-16-0108 Page 37 Fort Calhoun Station Proposed ISFSI ICs/EALs NEI 99-01 Rev 6, Section 8 Proposed Permanently Defueled Comparison ISFSI ICs/EALs EAL for FCS E-HU1 E-HU1 Changed Notification of Unusual Event to Unusual ECL: Notification of Unusual Event ECL: Unusual Event Event to maintain continuity Initiating Condition: Damage to a loaded Initiating Condition: Damage to a loaded cask with the previous FCS action cask CONFINEMENT BOUNDARY. CONFINEMENT BOUNDARY. level scheme.

Example Emergency Action Levels: Emergency Action Levels: Removed Operating Mode Applicability as it does not (1) Damage to a loaded cask

1. Damage to a loaded cask CONFINEMENT BOUNDARY as apply in a permanently CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading: defueled condition.

indicated by an on-contact radiation reading greater than (2 Removed Example from times the site-specific cask specific 1600 mRem/hr (gamma + neutron) on the Horizontal Emergency Action Levels as technical specification allowable Storage Module (HSM) front surface no longer example.

radiation level) on the surface of the spent fuel cask. Included the site-specific OR technical specification values

> 400 mRem/hr (gamma + neutron) on the HSM door centerline OR

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

LIC-16-0108 Page 38 NEI 99-01 Rev 6, Section 8 Proposed Permanently Defueled Comparison ISFSI ICs/EALs EAL for FCS Basis: Fort Calhoun Station Basis: Added definitions for CONFINEMENT This IC addresses an event that results in CONFINEMENT BOUNDARY: The irradiated fuel dry storage BOUNDARY and damage to the CONFINEMENT cask barrier(s) between areas containing radioactive INDEPENDENT SPENT BOUNDARY of a storage cask containing substances and the environment.

FUEL STORAGE spent fuel. It applies to irradiated fuel that INDEPENDENT SPENT FUEL STORAGE INSTALLATION INSTALLATION (ISFSI) is licensed for dry storage beginning at the (ISFSI): A complex that is designed and constructed for the point that the loaded storage cask is Added information to explain interim storage of spent nuclear fuel and other radioactive sealed. The issues of concern are the the values used as 2 times materials associated with spent fuel storage.

creation of a potential or actual release the technical specification path to the environment, degradation of This IC addresses an event that results in damage to the radiation reading.

one or more fuel assemblies due to CONFINEMENT BOUNDARY of a storage cask containing environmental factors, and configuration spent fuel. It applies to irradiated fuel that is licensed for dry Reworded the second and changes which could cause challenges in storage beginning at the point that the loaded storage cask is third sentence to better removing the cask or fuel from storage. sealed. The issues of concern are the creation of a potential or reflect specific FCS criteria.

actual release path to the environment, degradation of one or The existence of damage is determined more fuel assemblies due to environmental factors, and by radiological survey. The technical configuration changes which could cause challenges in specification multiple of 2 times, which is removing the cask or fuel from storage.

also used in Recognition Category A IC AU1, is used here to distinguish between The existence of damage is determined by radiological non-emergency and emergency survey. The radiation limits listed in the EAL reflect 2 times the conditions. The emphasis for this cask technical specification for radiation level. The technical classification is the degradation in the level specification multiple of 2 times is used here to distinguish of safety of the spent fuel cask and not the between non-emergency and emergency conditions. The magnitude of the associated dose or dose emphasis for this classification is the degradation in the level of rate. It is recognized that in the case of safety of the spent fuel cask and not the magnitude of the extreme damage to a loaded cask, the fact associated dose or dose rate. It is recognized that in the case that the on-contact dose rate limit is of extreme damage to a loaded cask, the fact that the on-exceeded may be determined based on contact dose rate limit is exceeded may be determined based measurement of a dose rate at some on measurement of a dose rate at some distance from the distance from the cask. cask.

Security-related events for ISFSIs are Amendment number 9 to COC 1004 Technical Specifications covered under ICs HU1 and HA1. for the Standardized NUHOMS Horizontal Storage Module System contains radiation dose levels for the dry storage cask that should not be exceeded based on whether the dry storage

LIC-16-0108 Page 39 NEI 99-01 Rev 6, Section 8 Proposed Permanently Defueled Comparison ISFSI ICs/EALs EAL for FCS cask is being transported inside the fuel transfer cask or it is stored in the horizontal storage module. Based on the guidance contained in NEI 99-01, Rev. 6, an Unusual Event is warranted for radiation levels of twice the Technical Specification value; the values chosen for EAL E-HU1 represent these values.

Security-related events for ISFSIs are covered under ICs PD-HU1 and PD-HA1.

Basis

References:

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

2. Amendment 9 to COC 1004 Technical Specifications for the Standardized NUHOMS Horizontal Storage Module System

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION DOCKET NUMBER 50-285 / LICENSE NUMBER DPR-40 ENCLOSURE 1 PERMANENTLY DEFUELED EMERGENCY PLAN

FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN OPPD NUCLEAR PERMANENTLY DEFUELED EMERGENCY PLAN FOR FORT CALHOUN STATION

FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION PERMANENTLY DEFUELED EMERGENCY PLAN TABLE OF CONTENTS

1.0 INTRODUCTION

............................................................................................................... 1 1.1 Overview of the Permanently Defueled Emergency Plan ............................................... 1 1.1.1 Purpose ................................................................................................................... 2 1.1.2 Scope ...................................................................................................................... 2 1.1.3 Objectives ................................................................................................................ 3 1.2 Site Description .............................................................................................................. 4 2.0 ORGANIZATIONAL RESPONSIBILITY ........................................................................... 4 2.1 Facility On-Shift Organization ......................................................................................... 5 2.1.1 Shift Manager/Emergency Director ......................................................................... 5 2.1.2 Non-Certified Operator ............................................................................................ 6 2.1.3 Radiation Protection Technician .............................................................................. 6 2.1.4 Security Force ......................................................................................................... 6 2.2 Emergency Response Organization ............................................................................... 6 2.2.1 Technical Coordinator ............................................................................................. 6 2.2.2 Radiation Protection Coordinator ............................................................................ 7 2.3 Offsite Organizations ...................................................................................................... 7 3.0 EMERGENCY RESPONSE SUPPORT AND RESOURCES ......................................... 10 3.1 Support Provided by Local Organizations .................................................................... 10 3.1.1 Law Enforcement .................................................................................................. 10 3.1.2 Fire and Rescue Support ...................................................................................... 10 3.1.3 Transportation of Injured and Contaminated Personnel ........................................ 10 3.1.4 Treatment of Radioactively Contaminated and Injured Personnel ........................ 10 4.0 EMERGENCY CLASSIFICATION SYSTEM .................................................................. 11 4.1 Classification of Emergencies ...................................................................................... 11 4.1.1 Notification of Unusual Event ................................................................................ 11 4.1.2 Alert ....................................................................................................................... 12 4.2 Postulated Accidents .................................................................................................... 12 Page i

FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN 4.3 Emergency Classification System Review ................................................................... 12 5.0 NOTIFICATION METHODS AND PROCEDURES......................................................... 12 5.1 Notification and Activation ............................................................................................ 12 5.1.1 Emergency Response Organization Activation ..................................................... 13 5.1.2 State and Local Government Notification .............................................................. 13 5.1.3 NRC Event Notification System ............................................................................. 14 6.0 EMERGENCY COMMUNICATIONS .............................................................................. 14 6.1 FCS Alarm System ....................................................................................................... 14 6.2 Communication Systems .............................................................................................. 14 6.2.1 FCS Paging Systems ............................................................................................ 14 6.2.2 Telephone System ................................................................................................ 14 6.2.3 Federal Telecommunications System ................................................................... 15 6.2.4 Portable Radios ..................................................................................................... 15 7.0 PUBLIC INFORMATION ................................................................................................ 15 8.0 EMERGENCY FACILITIES AND EQUIPMENT ............................................................. 16 8.1 Control Room ............................................................................................................... 16 8.2 Laboratory Facilities ..................................................................................................... 16 8.3 Emergency Equipment ................................................................................................. 16 8.3.1 Process Monitors ................................................................................................... 16 8.3.2 Radiological Monitors ............................................................................................ 17 8.3.3 Meteorological Monitoring ..................................................................................... 17 8.3.4 Fire Detection and Suppression Equipment .......................................................... 17 8.4 Emergency Kits ............................................................................................................ 17 8.4.1 Radiological Emergency Kits ................................................................................. 17 8.4.2 Dosimetry Kits ....................................................................................................... 18 8.4.3 Medical Kits ........................................................................................................... 18 9.0 ACCIDENT ASSESSMENT ............................................................................................ 18 9.1 Radiological Assessment ............................................................................................. 18 9.1.1 Initial Assessment ................................................................................................. 18 9.1.2 Initial Dose Assessment ........................................................................................ 18 9.2 Corrective Actions ........................................................................................................ 19 9.3 Dose Assessment ......................................................................................................... 19 Page ii

FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN 10.0 PROTECTIVE ACTIONS ................................................................................................ 19 10.1 Accountability ............................................................................................................ 19 10.2 Site Egress Control Methods .................................................................................... 20 11.0 RADIOLOGICAL EXPOSURE CONTROL ..................................................................... 20 11.1 Radiological Control Areas ....................................................................................... 20 11.2 Exposure Control ...................................................................................................... 20 11.3 Personnel Contamination Control ............................................................................. 21 12.0 MEDICAL AND HEALTH SUPPORT ............................................................................. 23 13.0 RECOVERY .................................................................................................................... 23 14.0 EXERCISES AND DRILLS ............................................................................................. 24 14.1 Exercises .................................................................................................................. 24 14.2 Drills .......................................................................................................................... 24 14.2.1 Medical Drills ......................................................................................................... 24 14.2.2 Accountability Drills ............................................................................................... 25 14.2.3 Health Physics Drills .............................................................................................. 25 14.2.4 Augmentation Capability Drills .............................................................................. 25 14.2.5 Fire and Security Drills .......................................................................................... 25 14.2.6 Communication Tests ............................................................................................ 25 14.3 Scenarios .................................................................................................................. 25 14.4 Critique/Evaluation .................................................................................................... 26 15.0 RADIOLOGICAL EMERGENCY RESPONSE TRAINING ............................................. 26 15.1 Emergency Response Training .................................................................................... 26 15.1.1 Emergency Response Organization Training ........................................................ 27 15.1.2 General Employee Training ................................................................................... 27 15.1.3 Local Support Services Personnel Training .......................................................... 27 15.2 Documentation of Training ........................................................................................... 28 16.0 RESPONSIBILITY FOR THE PLANNING EFFORT: PERIODIC REVIEW AND DISTRIBUTION OF EMERGENCY PLANS ................................................................... 28 16.1 Document Maintenance ................................................................................................ 28 16.1.1 Review and Update of the PDEP and EPIPs ........................................................ 28 16.1.2 Emergency Planning Documents .......................................................................... 28 16.2 Inventory and Maintenance of Emergency Equipment ................................................. 29 Page iii

FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN APPENDICES Page APPENDIX A Emergency Plan Implementing Procedures 30 APPENDIX B Cross-Reference Between the PDEP, NUREG-0654/FEMA-REP-1, 10 CFR 50.47(b) Planning Standards, and Appendix E.IV Planning Requirements 32 APPENDIX C Definitions and Acronyms 36 LIST OF TABLES TABLE 2.1 On-Shift and Emergency Response Organization Staffing Requirements 8 TABLE 11.1 Emergency Exposure Criteria 9 LIST OF FIGURES FIGURE 2.1 On-Shift and Emergency Response Organization 22 Page iv

FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN

1.0 INTRODUCTION

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

The analyses of the potential radiological impacts of postulated accidents in a permanently defueled condition indicates that any releases beyond the Site Boundary would be below 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 (EPA PAG Manual). No remaining postulated accidents will result in radiological releases requiring offsite protective actions and the slow progression rate of beyond design basis accident scenarios indicate sufficient time is available to initiate appropriate mitigating actions to protect the health and safety of the public. Therefore, the PDEP adequately addresses the risk associated with FCSs permanently defueled condition and continues to provide adequate protection for plant personnel and the public. Exemptions from the applicable portions of 10 CFR 50.47(b), Appendix E to 10 CFR Part 50, and 10 CFR 50.47(c)(2) were previously approved by the NRC.

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

This plan is activated by the Shift Manager/Emergency Director upon identification of an emergency situation based upon the Emergency Action Level (EAL) criteria.

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

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

FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN by Blair Hospital to provide medical support for work related injuries, and University of Nebraska Medical Center in Omaha, which maintains a regional Radiation Health Center that provides services for the treatment of radiologically contaminated injuries and radiation exposure evaluation.

Because there are no postulated accidents that would result in offsite dose consequences that are large enough to require offsite emergency planning, emergencies are divided into two classifications: Notification of Unusual Event (NOUE) and Alert. This classification scheme, developed in accordance with NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 6, November 2012, has been discussed and agreed upon with responsible offsite organizations and is compatible with their respective emergency plans. According to the EPA PAG Manual, Emergency Planning Zones are not necessary at those facilities where it is not possible for PAGs to be exceeded offsite. If determined appropriate by government officials, protective actions may be implemented to protect the public using the existing all hazards emergency planning.

FCS is responsible for planning and implementing emergency measures within the Site Boundary. This plan is provided to meet this responsibility. To carry out specific emergency measures discussed in this plan, detailed EPIPs are established and maintained. A list of EPIPs is included in Appendix A.

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

1.1.1 Purpose The purpose of the PDEP is to assure an adequate level of preparedness to cope with the spectrum of postulated emergencies, including the means to minimize radiation exposure to facility personnel. This plan integrates the necessary elements to provide effective emergency response considering cooperation and coordination of organizations expected to respond to potential emergencies. All changes to the PDEP are reviewed in accordance with 10 CFR 50.54(q).

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

There are no postulated accidents that would result in offsite dose consequences that are large enough to require offsite emergency planning. Therefore, the overall scope of this plan delineates the actions Page 2

FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN necessary to safeguard onsite personnel and minimize damage to property. If determined appropriate by government officials, protective actions may be implemented to protect the public using an all hazards approach to emergency planning.

The concepts presented in this plan address the applicable regulations stipulated in 10 CFR 50.47, Emergency Plans, and 10 CFR 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, as exempted. Exemptions to selected portions of 10 CFR 50.47(b); 10 CFR 50.47(c)(2); and 10 CFR 50, Appendix E were previously approved by the NRC. The plan is consistent with the remaining applicable guidelines established in NUREG-0654/FEMA-REP-1, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (NUREG-0654). Appendix B contains a cross-reference to the applicable guidance in NUREG-0654.

Abbreviations and acronyms used in this Plan are included in Appendix C.

1.1.3 Objectives The basic objectives of this plan are:

1) To establish a system for identification and classification of the emergency condition and initiation of response actions;

2) To establish an organization for the direction of activity within the facility to limit the consequences of the incident;

3) To establish an organization for control of assessment activities to determine the extent and significance of any uncontrolled release of radioactive material;

4) To identify facilities, equipment, and supplies available for emergency use;

5) To establish an engineering support organization to aid the facility personnel in limiting the consequences of and recovery from an event;

6) To generally describe the elements of an emergency recovery program;

7) To specify a system for coordination with federal, state, and local authorities and agencies offsite support organizations; Page 3

FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN

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

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

1.2 Site Description FCS has ceased power operations and has certified that fuel has been permanently removed from the reactor vessel. The license for FCS, under 10 CFR 50, no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel, as specified in 10 CFR 50.82(a)(2).

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

2.0 ORGANIZATIONAL RESPONSIBILITY A predesignated group is assigned to various roles, during an event, to ensure capable emergency response and mitigation at the FCS. These assignments are made to ensure that the administrative, managerial and technical support needed for accident mitigation are met. A sufficient number of individuals are assigned to these positions to ensure around-the-clock and continued long term support.

Responsibility for emergency response lies with the Shift Manager. The Shift Manager assumes the Emergency Director position upon declaration of an emergency. The command and control position is responsible for ensuring the continuity of resources throughout an event.

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

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

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FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN 2.1 Facility On-Shift Organization During normal conditions, the minimum staff on duty at the facility during all shifts consists of one (1) Shift Manager, one (1) Non-Certified Operator (NCO), one (1)

Radiation Protection Technician. Security personnel are maintained in accordance with the Security Plan. The minimum staff required to conduct routine and immediate emergency mitigation is maintained on-shift 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.

Figure 2.1 and Table 2.1 outline the minimum requirements for the FCS on-shift and ERO staffing.

2.1.1 Shift Manager/Emergency Director The Shift Manager position is staffed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. This position is the senior management position at the facility during off-hours. This position is responsible for monitoring facility conditions and approving onsite activities. The position has the authority, management ability, and technical knowledge to classify and declare a facility emergency and assume the Emergency Director role.

The Emergency Director shall assume command and control upon declaration of an event. The Emergency Director shall not delegate the following responsibilities:

Classification of an event Emergency notification approval (Task of making the notifications may be delegated)

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

Other Emergency Director responsibilities:

Notification of the emergency classification to the NRC, State, and County.

Management of resources available to the facility Coordination of mitigative actions Coordination of corrective actions Coordination of onsite protective actions Decision to call for offsite assistance Coordination of Security activities Termination of the emergency condition when appropriate Performance of initial dose assessment Page 5

FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN Maintenance of records of event activities 2.1.2 Non-Certified Operator The NCO, on shift 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, performs system and component manipulations. The organizational relationship to the Shift Manager/Emergency Director is the same during normal situations and during situations where the PDEP has been implemented.

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

2.1.4 Security Force Security is administered in accordance with the Security Plan. The Security Force will report to the Emergency Director when implementing the PDEP.

2.2 Emergency Response Organization The ERO shall be activated at the Alert classification. The ERO shall augment the on-shift staff within approximately 120 minutes of an Alert declaration. However, the ERO may be activated, in part or in whole, at any time at the discretion of the Shift Manager/Emergency Director.

2.2.1 Technical Coordinator The Technical Coordinator reports to the Emergency Director. The responsibilities of the Technical Coordinator when implementing the PDEP include:

evaluating technical data pertinent to facility conditions, augmenting the emergency staff as deemed necessary, designating engineering support, as necessary, to evaluate facility conditions and provide technical support, recommending mitigation and corrective actions, coordinating search and rescue, coordinating maintenance and equipment restoration, establishing and maintaining communications as desired by the Emergency Director, and maintaining a record of event activities.

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FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN 2.2.2 Radiation Protection Coordinator The Radiation Protection Coordinator reports to the Emergency Director.

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

monitoring personnel accumulated dose, advising the Emergency Director concerning Radiological EALs augmenting the emergency staff as deemed necessary, directing radiological monitoring analysis, performing dose assessment, coordinating decontamination activities, establishing and maintaining communications as desired by the Emergency Director, and maintaining a record of event activities.

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

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

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FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN FIGURE 2.1 On-Shift and Emergency Response Organization Shift Manager/

Emergency Director (1)

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

Emergency Response Organization Technical Radiation Protection Coordinator (1) Coordinator (1)

Federal State/Local Local Services Agencies Agencies

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

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

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

Operations and assessment of Control Non-Certified 11 -

Operational Aspects Room/On-Scene Operator*

Emergency Direction & Control Control Room Shift Manager* 11 -

Notification/Communication Control Room -

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

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

Protection Technician*

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

Firefighting On-Scene Per the Fire Protection Offsite Response Rescue Operations/First Aid On-Scene Procedures Organizations**

Site Access Control and Per the Security Security Per the -

Accountability Plan Personnel Security Plan 1

Technical Specifications allow the Technical Specification-required on-shift positions to be vacant for not more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, in order to provide for unexpected absence, provided immediate action is taken to fill the required position.

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

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

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FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN 3.0 EMERGENCY RESPONSE SUPPORT AND RESOURCES Radiological emergency preplanning is not required for the State of Nebraska, the State of Iowa, or the counties surrounding FCS (Washington County, Harrison County, and Pottawattamie County). State and County response to an emergency will be performed in accordance with each organizations plans and procedures and will be commensurate with the hazard posed by the emergency.

Letters of Agreement are in place for those local organizations that will provide ambulance services, treatment of contaminated and injured patients, fire support services, and law enforcement response as requested by FCS. These letters are maintained on file in the Emergency Planning Department at FCS.

3.1 Support Provided by Local Organizations 3.1.1 Law Enforcement The Nebraska State Patrol and the Washington County Sheriff's Department have agreed to provide the primary law enforcement support to the FCS Security Department.

3.1.2 Fire and Rescue Support The Blair Volunteer Fire Department has agreed to provide the primary fire support services for FCS. The Fort Calhoun Volunteer Fire Department has agreed to provide backup fire response.

3.1.3 Transportation of Injured and Contaminated Personnel Omaha Public Power District (OPPD) vehicles may transport non-injured potentially contaminated personnel.

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

Fort Calhoun Volunteer Fire and Rescue has agreed to provide backup services.

3.1.4 Treatment of Radioactively Contaminated and Injured Personnel The Blair Hospital has agreed to provide medical support for work related injuries.

University of Nebraska Medical Center, in Omaha, maintains a regional Radiation Health Center which provides services for the treatment of radiologically contaminated injuries and radiation exposure evaluation.

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FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN 4.0 EMERGENCY CLASSIFICATION SYSTEM This section describes the emergency classification scheme adopted by the OPPD for FCS.

4.1 Classification of Emergencies The emergency classification system covers the entire spectrum of possible radiological and non-radiological emergencies at FCS. The emergency classification system categorizes accidents and/or emergency situations into two emergency classification levels depending on emergency conditions at the time of the incident. The emergency classification levels applicable to FCS, in order of increasing severity are NOUE and Alert. Each of these emergency classes requires notification of the responsible State of Nebraska and Washington County authorities, and the Nuclear Regulatory Commission (NRC). The Emergency Response Organization (ERO) will be notified at an Alert declaration.

FCSs permanently defueled emergency classification system is developed consistent with NEI-99-01, Development of EALs for Non-Passive Reactors, Revision 6. Appendix C of NEI 99-01, Rev. 6 contains a set of Initiating Conditions (ICs)/EALs for permanently defueled nuclear power plants that had previously operated under a 10 CFR Part 50 license and have permanently ceased operations. The classification system referenced in NEI 99-01, Rev. 6 has been endorsed by the NRC and provides a standard method for classifying emergencies.

When indications are available to on-shift personnel that an EAL has been met, the event is assessed and the corresponding emergency classification level is declared. FCS maintains the capability to assess, classify, and declare an emergency condition within 30 minutes after the availability of indications that an EAL threshold has been reached.

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

The following subsections outline the facility actions at each emergency classification level. Refer to the Permanently Defueled Emergency Action Level Technical Bases for actual parameter values, annunciators, and equipment status used by FCS personnel to classify emergencies.

4.1.1 Notification of Unusual Event NOUE conditions do not cause serious damage to the facility. The purpose of the NOUE declaration is to: 1) bring the ERO to a state of readiness; 2) make required and needed notifications; 3) provide for Page 11

FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN systematic handling of information and decision-making; and 4) augment shift personnel if necessary.

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

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

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

4.2 Postulated Accidents The Final Safety Analysis Report as Updated (USAR) describes the postulated accidents applicable to FCS. Methods for detecting and evaluating these events include the use of installed systems, instrumentation, alarms, approved procedures, as well as field observation.

4.3 Emergency Classification System Review The emergency classification system and the EALs are reviewed with the State of Nebraska and Washington County on an annual basis.

5.0 NOTIFICATION METHODS AND PROCEDURES The decision to make notifications is based on the emergency action levels and corresponding emergency classifications described in Section D of this Plan. OPPD is capable of notifying and activating its Emergency Response Organization 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. It is also able to make notifications to the State of Nebraska and Washington County, and the NRC on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day basis.

5.1 Notification and Activation The Shift Manager is responsible for the initial emergency declaration and then assumes the duties of the Emergency Director. The authority and responsibility for classifying and declaring emergencies, initiating notification to the State, County, and Federal officials, and initiating corrective and mitigative actions resides with the Emergency Director position.

FCS personnel in the Protected Area are notified via the Emergency or Fire Alarm and a public address system message. If required, personnel outside the Protected Area are notified by public address systems installed in the buildings outside the Page 12

FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN Protected Area. Site Security personnel may assist in the notification of all other personnel on OPPD property.

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

5.1.2 State and Local Government Notification Notification to the responsible State and County authorities is required within 60 minutes of the emergency classification. The commercial telephone network serves as the primary means to provide emergency notification to State and County agencies. It is used to provide initial and updated notifications and for general information flow between these agencies.

OPPD, in coordination with the State of Nebraska, have established the contents of the initial emergency messages to be sent from FCS in the event an emergency is declared. These messages contain such information as the class of emergency and whether a release is taking place.

In the event the commercial telephone system is unavailable, wireless communications can be used to make emergency notifications. In addition, electronic means may be used to transmit the notification message.

Follow-up emergency messages incorporate elements as determined necessary by the State of Nebraska. These messages are transmitted by telephone or facsimile. Updated messages are sent at least every 60 minutes. The frequency of updates may be modified during ongoing events if requested by the State of Nebraska and the status of the event has not changed.

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FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN 5.1.3 NRC Event Notification System The NRC Event Notification System (ENS) is a dedicated telephone system used to notify the NRC Operations Center of an emergency. The NRC will be notified as soon as possible after State/County notifications and within 60 minutes of event classification or change in classification. In the event that the ENS fails, commercial phone lines will be used to notify the NRC. Notification to the NRC is the responsibility of the Emergency Director.

6.0 EMERGENCY COMMUNICATIONS A number of communications systems are available for use among the principal response organizations. Provisions for 24-hour per day notification to State and local authorities is discussed in Section 5.0 of this plan. Provisions for activating OPPD ERO personnel are also discussed in section 5.0 of this plan. Provisions for periodic testing of the emergency communications system are described in Section 14.0 of this plan.

6.1 FCS Alarm System Emergency or fire alarms are sounded from the Control Room when an emergency requiring ERO activation or fire is declared. Their function is to alert personnel within the Protected Area to an emergency condition.

6.2 Communication Systems Several modes of communication are available to facility staff to transmit information onsite and offsite during normal and emergency situations.

6.2.1 FCS Paging Systems The Protected Area paging system (Gai-tronics) provides a means of intra-plant communications. Stations on this system provide access to the paging system and to intercom lines. These stations and speakers are placed throughout the facility including the Control Room.

Buildings outside of the Protected Area also have public address announcing capabilities. Access to the public address system in both locations can be accomplished via the sites telephone system. This system can be used to notify personnel of an emergency.

6.2.2 Telephone System The commercial telephone system (see Section 5.1.2) is the primary emergency notification system between FCS, State, and county agencies and is used to provide initial and follow-up notifications and for general information flow between these agencies.

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FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN Additional methods of communication are available to facility staff to transmit information onsite and offsite during normal and emergency situations.

The telephone system can be used for in-facility as well as outside communications. The telephone system is the primary means to activate the ERO upon declaration of an emergency, as directed by the Emergency Director. In the event that personnel required to staff emergency positions are not on-site at the time an emergency is declared, they may be contacted by commercial telephone including land lines and/or wireless devices capable of receiving telephone calls and text messages. Telephone numbers are maintained in various telephone directories.

The phone system includes many automated or programmable features that improve notification and allow flexibility. Wireless communications serve as the backup means of communication.

6.2.3 Federal Telecommunications System The NRC ENS utilizes the Federal Telecommunications System (FTS) telephone network for emergency communications. The FTS line exists between the NRC Operations Office in Rockville, Maryland and the FCS Control Room. Emergency notification, facility status information, and radiological information are communicated via the ENS.

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

7.0 PUBLIC INFORMATION As part of its normal corporate structure, OPPD maintains a Corporate Communications Division that can be called upon to provide resources as necessary. The Corporate Crisis Communication Plan provides guidance for the dissemination of information during emergencies.

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

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FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN 8.0 EMERGENCY FACILITIES AND EQUIPMENT Following the declaration of an emergency, the activities of the ERO are coordinated from the Control Room. Adequate emergency facilities and equipment to support emergency response are provided and maintained.

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

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

The Nebraska Public Power District Cooper Nuclear Station is capable of providing a backup facility in the event Fort Calhoun's radiochemistry laboratory is not functional. The Cooper Station's radiochemistry laboratory is equipped to perform gross and isotopic determinations on radionuclides in concentrations and counting geometries necessary for nuclear power plant operation and emergency monitoring. They will provide analysis of liquid, air particulate, and cartridges on a priority basis after receiving the sample.

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

Emergency kits are described in Section 8.4.

8.3.1 Process Monitors Annunciator and computer alarms are provided for a variety of parameters including the SFP and the SFP systems to indicate SFP level and temperature. The manner in which process monitors are used for accident recognition and classification is detailed in FCSs Permanently Defueled EALs.

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FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN 8.3.2 Radiological Monitors Radiation monitors and monitoring systems provide continuous radiological surveillance. These monitors, which include Control Room readout and alarm functions, exist in order that appropriate action can be initiated to limit fuel damage and/or contain radioactive material. The system performs the following basic functions:

Warns personnel of potential radiological health hazards Gives early warning of certain equipment malfunctions that might lead to a radiological hazard or facility damage Prevents or minimizes the effects of inadvertent releases of radioactivity Plant instrumentation provides Control Room personnel with the following parameters necessary to perform dose assessment and determine the magnitude of a potential release:

Gaseous and liquid effluent monitor readings Area radiation levels In addition to installed monitoring systems, onsite portable radiation and contamination monitoring equipment is available.

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

In addition, the National Weather Service operates on a twenty-four (24) hour per day basis. Upon request, this organization can provide FCS with meteorological conditions including predicted temperature inversions, precipitation, wind patterns, and velocity.

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

8.4 Emergency Kits Emergency kits and equipment are maintained to support an emergency response.

8.4.1 Radiological Emergency Kits Radiological Emergency kits include protective equipment, radiological monitoring equipment and emergency supplies. Kits are located in the Page 17

FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN Control Room. The methods and frequencies for instrument calibration, repair, and replacement are maintained in accordance with facility procedures.

8.4.2 Dosimetry Kits Dosimetry kits include dosimetry, dosimeter chargers, and appropriate paperwork. Kits are located in the Control Room.

8.4.3 Medical Kits First aid equipment and supplies are located in the First Aid Room.

Trauma and primary response kits are available throughout the facility.

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

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

9.0 ACCIDENT ASSESSMENT The activation of the PDEP and the continued assessment of accident conditions requires monitoring and assessment capabilities. FCS maintains and operates on-site monitoring systems needed to provide data that is essential for initiating emergency measures and performing accident assessment, including dose assessment.

9.1 Radiological Assessment 9.1.1 Initial Assessment Classification of an emergency is performed by the Emergency Director in accordance with the Permanently Defueled EAL Scheme.

9.1.2 Initial Dose Assessment Initial dose assessment is performed by qualified on-shift personnel, under the direction of the Emergency Director. When the ERO is augmented, the Radiation Protection Coordinator assumes subsequent dose assessment responsibilities.

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FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN 9.2 Corrective Actions Station procedures and EPIPs provide preventative and/or corrective actions that mitigate the consequences of events. Instrumentation, control systems, and radiation monitoring systems provide indications related to the safe and orderly implementation of corrective actions. These systems provide indication of SFP storage inventory, temperature, cooling, and supporting systems.

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

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

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

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

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

Implementation guidelines for protective actions are provided in the EPIPs. Station procedures also provide protective actions to protect personnel during hostile actions.

It is the policy of OPPD to keep personnel radiation exposure within federal regulations, and station limits and guidelines and to keep exposures As Low As Reasonably Achievable (ALARA). Every effort will be made to keep exposures for those providing emergency functions within the limits of 10 CFR Part 20.

10.1 Accountability Accountability should be considered and used as a protective action whenever a site-wide risk to health and safety exists and prudence dictates. If personnel accountability is required, at the direction of the Emergency Director, all individuals at the site (including non-essential employees, visitors, and contractor personnel) shall be notified by sounding the facility alarm and making announcements over the Public Address System. Following announcement of an emergency declaration, and when accountability has been requested, facility Page 19

FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN personnel are responsible for reporting to designated areas and aiding Security in the accountability process.

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

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

10.2 Site Egress Control Methods All visitors and unnecessary contractors are evacuated from the facility at the discretion of the Emergency Director. In the event of a suspected radiological release, personnel are monitored for radioactive contamination prior to leaving the Protected Area. Portable radiation survey meters are available to monitor for potential contamination.

11.0 RADIOLOGICAL EXPOSURE CONTROL During a plant emergency, abnormally high levels of radiation and/or radioactivity may be encountered by plant personnel. All reasonable measures shall be taken to control the radiation exposure to emergency response personnel providing rescue, first aid, decontamination, emergency transportation, medical treatment services, or corrective or assessment actions within applicable limits specified in 10 CFR Part 20.

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

11.2 Exposure Control Individuals authorized to enter RCAs are required to have dosimetry capable of measuring a dose received from external sources of ionizing radiation.

Emergency workers are issued permanent reading dosimeters (e.g., Dosimeter of Legal Record (DLR)) as a means of recording radiation exposure for permanent records prior to entering a RCA. Additionally, personnel are issued electronic alarming dosimetry capable of measuring dose and dose rate on a real time basis. Dose records are maintained in accordance with facility procedures.

All reasonable measures shall be taken to control the radiation exposure to emergency response personnel providing rescue, first aid, decontamination, Page 20

FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN emergency transportation, medical treatment services, corrective actions, and assessment actions within applicable limits specified in 10 CFR Part 20.

The Emergency Director is responsible for authorizing personnel to receive doses in excess of 10 CFR Part 20 limits, if necessary. This authorization is coordinated with the Radiation Protection Coordinator when available. Table 11.1 contains the guidelines for emergency exposure criteria, which is consistent with Table 2-2, Response Worker Guidelines, provided in the EPA PAG Manual.

Dosimeters and DLRs are typically located in each of the emergency lockers in the Control Room. Additional dosimeters and DLRs are available.

11.3 Personnel Contamination Control During emergency conditions, normal facility decontamination and contamination control measures are maintained as closely as possible. However, these measures may be modified, by the Emergency Director, should conditions warrant.

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

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

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

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

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FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN TABLE 11.1 EMERGENCY EXPOSURE CRITERIA (Refer to Note 1)

Guideline Activity Condition All reasonably achievable 5 rem All occupational exposures actions have been taken to minimize dose.

Exceeding 5 rem is unavoidable and all Protecting Valuable Property appropriate actions have been 10 rem(a) necessary for public welfare taken to reduce dose.

Monitoring available to project or measure dose.

Exceeding 5 rem is unavoidable and all Lifesaving or Protection of appropriate actions have been 25 rem(b)(c)

Large Population taken to reduce dose.

Monitoring available to project or measure dose.

NOTES:

1. Reference for this table is Table 2-2 of the EPA PAG Manual.

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

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

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

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FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN 12.0 MEDICAL AND HEALTH SUPPORT FCS maintains on-shift personnel and equipment to provide first aid for personnel working at the site. Medical supplies for emergency first aid treatment are provided on the site at various locations.

If immediate professional medical help is needed, local ambulance services are available to transport seriously ill, injured, or radioactively contaminated injured personnel. Patients can also be transported to the facility via medical ambulance helicopters. FCS is capable of maintaining communications with the ambulance while transporting a patient.

Agreements are in place with Blair Hospital and University of Nebraska Medical Center in Omaha for medical treatment of patients from FCS who have injuries complicated by radioactive contamination. These hospitals have trained personnel and detailed procedures for handling radioactively contaminated patients from FCS.

13.0 RECOVERY The emergency measures presented in this plan are actions designated to mitigate the consequences of the accident in a manner that affords the maximum protection to plant personnel. Planning for the recovery involves the development of general principles and an organizational capability that can be adapted to any emergency situation. Upon termination of an emergency and transition to recovery phase, the Emergency Director assembles the recovery organization to address the specific emergency circumstances of the terminated event.

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

Ensuring the facility is maintained in a safe condition; Managing onsite recovery activities; and Keeping corporate support apprised of recovery activities and requirements.

The remainder of the recovery is accomplished using the normal facility and emergency organizations as necessary to provide radiological and technical expertise to the Emergency Director in order to restore the facility to normal conditions.

The recovery organizations responsibilities include:

Maintaining comprehensive radiological surveillance of the facility to assure continuous control and recognition of problems Controlling access to the area and exposure to workers Decontaminating affected areas and/or equipment Conducting clean-up and restoration activities Page 23

FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN Isolating and repairing damaged systems Documenting all proceedings of the event and reviewing the effectiveness of the emergency organization in reducing public hazard and plant damage When plant conditions allow a transition from the emergency phase to the recovery phase, the Emergency Director conducts a plant emergency management meeting to discuss the recovery organization. The actions taken by this organization concerning termination of the emergency proceeds in accordance with a recovery plan developed specifically for the accident conditions.

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

14.1 Exercises Biennial exercises shall be conducted to test the timing and content of implementing procedures and methods and to ensure that emergency personnel are familiar with their duties. Offsite organizations are offered the opportunity to participate to the extent assistance would be expected during an emergency declaration. However, participation by offsite organizations is not required, nor are offsite response organizations evaluated.

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

14.2.1 Medical Drills A medical emergency drill shall be conducted annually. The drill involves a simulated contaminated injury. The University of Nebraska Medical Center Radiation Health Center is invited to participate in an annual exercise and/or scheduled drill(s) to demonstrate and practice the receipt and treatment of contaminated patients. Involvement by hospital and medical transport services may be included as part of any drill or exercise.

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FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN 14.2.2 Accountability Drills An accountability drill shall be conducted annually. This drill shall include identifying the locations of all personnel onsite. This drill can be performed as part of any drill or exercise.

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

14.2.4 Augmentation Capability Drills An off-hours, unannounced augmentation drill shall be conducted semi-annually to estimate emergency response personnel response times. No actual travel is required. Participants provide an estimate time of arrival to their designated ERO position.

14.2.5 Fire and Security Drills Fire Drills and Security Drills are conducted in accordance with the respective FCS plans and procedures.

14.2.6 Communication Tests A. The ENS used to communicate with the NRC is tested monthly.

B. To ensure the reliability of the plant's call-in procedure, a semi-annual functional test of the ERO notification system is performed to test system performance. This can be performed separately or during the Augmentation Capability Drill described in Section 14.2.5.

C. The following communication systems, as detailed in Section 6.2, are used on a frequent basis. Therefore, periodic testing of these systems is not necessary:

a. FCS Paging System

b. Commercial Telephone System

c. Portable Radios 14.3 Scenarios An Exercise/Drill Coordinator is responsible for the overall development of the scenario package.

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FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN A scenario development team is assembled (if needed) by the Exercise/Drill Coordinator to create the various segments of the scenario which include, but are not limited to, the following:

Objective(s)

Date, time period, place and participating organizations Simulation lists Timeline of real and simulated events A narrative summary List of controllers and participants The final scenario shall be approved by a designated member of senior facility management. Drill/Exercise confidentiality must always be maintained.

14.4 Critique/Evaluation Critiques will evaluate the participants performance during a drill or exercise.

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

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

A written report is prepared including the evaluation of designated objectives.

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

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

15.1 Emergency Response Training The training program for ERO personnel is based on applicable requirements of Appendix E to 10 CFR Part 50 and position-specific responsibilities as defined in Page 26

FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN the PDEP. Emergency response personnel in the following categories receive initial training and annual retraining.

15.1.1 Emergency Response Organization Training Shift Managers/Emergency Directors, Technical Coordinators, and Radiation Protection Coordinators shall have training conducted such that proficiency is maintained on topics listed below. These topics should be covered as a minimum on an annual basis.

Emergency Action Level Classification Dose Assessment Federal, State, and local notification procedures ERO Augmentation Emergency Exposure Control Mitigating strategies for a catastrophic loss of spent fuel pool inventory Recovery FCS personnel available during emergencies to perform emergency response activities as an extension of their normal duties receive duty specific training. This includes facility on-shift personnel, maintenance, radiation protection, and security personnel. Personnel assigned to liaison with offsite fire departments are trained in accordance with the Fire Protection Program, including mitigating strategies required for a catastrophic loss of SFP inventory. Personnel assigned the responsibility of on-shift first aid shall attend first aid training.

15.1.2 General Employee Training An overview of the Emergency Plan is given to all personnel allowed unescorted access into the Protected Area at Fort Calhoun Station.

Personnel receive this information during initial training and are requalified on an annual basis. This training includes identification of the emergency alarm, the fire alarm and the steps to follow for a plant and site evacuation.

15.1.3 Local Support Services Personnel Training Training is offered annually to offsite organizations which may provide specialized services during an emergency at FCS (fire-fighting, medical services, transport of contaminated and/or injured personnel, etc.). The training shall be structured to meet the needs of that organization with Page 27

FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN respect to the nature of their support. Topics of event notification, site access, basic radiation protection and interface activities are included in the training.

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

16.0 RESPONSIBILITY FOR THE PLANNING EFFORT: PERIODIC REVIEW AND DISTRIBUTION OF EMERGENCY PLANS Senior plant leadership is responsible for the implementation of actions required to periodically exercise the PDEP and the EPIPs and for maintaining an effective ERO staff.

Senior plant leadership is responsible for the final approval of PDEP and the EPIPs used for emergency classification, and for maintaining an effective emergency response capability at FCS.

Emergency Planning is responsible for the development, administration and maintenance of the PDEP, EPIPs, review and approval of all EPIP changes (with the exception of the EPIP used for emergency classification), planner training, the overall development and implementation of the FCS ERO Training and Qualification Program and coordination of off-site emergency organization activities.

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

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

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

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FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN The emergency classification system and the EALs are reviewed with the State of Nebraska and Washington County on an annual basis.

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

16.2 Inventory and Maintenance of Emergency Equipment Periodic inventory, testing, and calibration of emergency equipment and supplies are conducted in accordance with approved facility procedures. This equipment includes, but is not limited to:

Portable radiation monitoring equipment Emergency medical response equipment Dosimeters Portable radios Emergency equipment and instrumentation shall be inventoried, inspected and operationally checked periodically as indicated by the procedure and after each use. Sufficient reserves of equipment and instrumentation are stocked to replace emergency equipment and instrumentation removed from service for calibration and/or repair.

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FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN APPENDIX A EMERGENCY PLAN IMPLEMENTING PROCEDURES Page 30

FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN APPENDIX A EMERGENCY PLAN IMPLEMENTING PROCEDURES Document Document Title EP-FC-1001 PERMANENTLY DEFUELED EMERGENCY ACTION LEVELS FORT Addendum 3 CALHOUN STATION EP-FC-110 ASSESSMENT OF EMERGENCIES EP-FC-111 EMERGENCY CLASSIFICATION EP-FC-112 EMERGENCY RESPONSE ORGANIZATION ACTIVATION AND OPERATION EP-FC-112-100 CONTROL ROOM OPERATIONS EP-FC-113 PERSONNEL PROTECTIVE ACTIONS EP-FC-114 NOTIFICATIONS EP-FC-115 TERMINATION AND RECOVERY Page 31

FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN APPENDIX B CROSS-REFERENCE BETWEEN THE PDEP, NUREG-0654/FEMA-REP-1, 10 CFR 50.47(b)

PLANNING STANDARDS, AND APPENDIX E.IV PLANNING REQUIREMENTS Page 32

APPENDIX B CROSS-REFERENCE BETWEEN THE PDEP, NUREG-0654/FEMA-REP-1, the 10 CFR 50.47(b) PLANNING STANDARDS, AND APPENDIX E.IV PLANNING REQUIREMENTS NUREG- Planning Planning Requirement FCS 0654, Standard PDEP Section (Appendix E.IV)**

Section II (10CFR50.47)**

Evaluation Criteria A (b)(1) A.1,2,4,7 2.0 B (b)(2) A.1,2,4,9; C.1 2.0 C (b)(3) A.6,7 3.0 D (b)(4) B.1,2;C.1,2 4.0 E (b)(5) A.6,7;C.1,2;D.1,3;E 5.0 F (b)(6) C.1;D.1,3;E 6.0 G (b)(7) A.7;D.2 7.0 H (b)(8) E;G 8.0 I (b)(9) A.4;B.1;C.2;E 9.0 J (b)(10) C.1;E;I 10.0 K (b)(11) E 11.0 L (b)(12) A.6,7;E 12.0 M (b)(13) H 13.0 N (b)(14) E9;F 14.0 O (b)(15) F 15.0 P (b)(16) G 16.0

• • As Exempted Page 33

APPENDIX C DEFINITIONS AND ACRONYMS Page 34

1.0 DEFINITIONS Accountability - The process of determining the location of onsite personnel in order to identify missing and or injured personnel.

Alert - Events are in progress or have occurred which involve a potential or actual substantial degradation of level of safety of the facility, or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of hostile action. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

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

Assessment Actions - Those actions taken during or after an incident to obtain or process information necessary for decisions in specific emergency measures.

Corrective Actions - Those emergency measures taken to mitigate or terminate an emergency situation at or near the source of the problem in order to reduce the magnitude.

Emergency Action Levels - Predetermined, site specific, observable threshold for an Initiating Condition (IC) that, when met or exceeded, places the facility in a given emergency classification.

Emergency Classification - Names set forth by the Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to potential effects or consequences. In order of severity: Notification of Unusual Event (NOUE) and Alert.

Emergency Plan Implementing Procedures - The procedures which detail the specific course of action for implementing the emergency plan at FCS.

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

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

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

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

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

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

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

Onsite - The area within the Exclusion Area Boundary.

Projected Dose - The estimated radiation dose that would be received by individuals following a release of radiation.

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

Protective Actions - Measures taken to effectively mitigate the consequences of an accident by minimizing the radiological exposure that would likely occur if such actions were not taken.

Radiological Control Area - An area in which radioactive material is present and the potential exists for the spread of radioactive contamination. The area will be posted for purposes of protecting individuals against undue risks from exposure to radiation and radioactive materials.

Recovery - Actions taken after the emergency has been controlled to restore the facility as nearly as possible to its pre-emergency condition.

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

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2.0 ACRONYMS CFR Code of Federal Regulation DLR Dosimeter of Legal Record EAL Emergency Action Level ENS Emergency Notification System EPA Environmental Protection Agency EPIP Emergency Plan Implementing Procedure ERO Emergency Response Organization FCS Fort Calhoun Station FTS Federal Telecommunications System IC Initiating Condition ISFSI Independent Spent Fuel Storage Installation NCO Non-Certified Operator NOUE Notification of Unusual Event NRC U.S. Nuclear Regulatory Commission NWS National Weather Service OPPD Omaha Public Power District PAG Protective Action Guide PDEP Permanently Defueled Emergency Plan RCA Radiological Control Area SFP Spent Fuel Pool Page 37

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION DOCKET NUMBER 50-285 / LICENSE NUMBER DPR-40 ENCLOSURE 2 PERMANENTLY DEFUELED EMERGENCY ACTION LEVEL TECHNICAL BASES DOCUMENT

OPPD NUCLEAR PERMANENTLY DEFUELED EMERGENCY ACTION LEVEL TECHNICAL BASES Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0

TABLE OF CONTENTS 1.0 PURPOSE ............................................................................................................. 1 2.0 DISCUSSION ........................................................................................................ 1 2.1 Permanently Defueled Facility............................................................................ 1 2.2 Independent Spent Fuel Storage Installation ..................................................... 2 3.0 KEY TERMINOLOGY USED ................................................................................ 2 3.1 Emergency Classification Levels ........................................................................ 3 3.2 Initiating Condition.............................................................................................. 3 3.3 Emergency Action Level .................................................................................... 4 4.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS ............................ 4 4.1 General Considerations ..................................................................................... 4 4.2 Classification Methodology................................................................................. 5 4.3 Classification of Multiple Events and Conditions ................................................ 5 4.4 Classification of Imminent Conditions ................................................................ 6 4.5 Emergency Classification Level Upgrading and Termination ............................. 6 4.6 Classification of Short-Lived Events ................................................................... 6 4.7 Classification of Transient Conditions ................................................................ 6 4.8 After-the-Fact Discovery of an Emergency Event or Condition .......................... 7 4.9 Retraction of an Emergency Declaration ............................................................ 7

5.0 REFERENCES

...................................................................................................... 7 5.1 Developmental ................................................................................................... 7 5.2 Implementing...................................................................................................... 8 5.3 Commitments ..................................................................................................... 8 6.0 ACRONYMS & DEFINITIONS .............................................................................. 9 6.1 Acronyms ........................................................................................................... 9 6.2 Definitions ........................................................................................................ 10 7.0 FCS-TO-NEI 99-01 EAL CROSS-REFERENCE ................................................. 12 8.0 ATTACHMENTS ................................................................................................. 13 ............................................................................................................... 14 ............................................................................................................... 37 Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0

1.0 PURPOSE This document provides the detailed set of Emergency Action Levels (EALs) applicable to the Fort Calhoun Station (FCS) and the associated Technical Bases using the EAL development methodology found in NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 6 (NEI 99-01, Rev. 6). As a permanently defueled facility, FCS will use the Recognition Category PD (Permanently Defueled) providing a stand-alone set of Initiating Conditions (ICs)/Emergency Action Levels (EALs) for a permanently defueled facility to consider for use in developing a site-specific emergency classification scheme and Recognition Category E ICs for the ISFSI. Permanently defueled ICs and EALs are addressed in Appendix C of NEI 99-01, Rev. 6. All recommendations for changes to this document or associated implementing procedures are reviewed in accordance with 10 Code of Federal Regulations (CFR) 50.54(q).

This document should be used to facilitate review of the FCS Permanently Defueled EALs, provide historical documentation for future reference and serve as a resource for training. Decision-makers responsible for implementation of the Permanently Defueled Emergency Plan (PDEP) may use this document as a technical reference in support of EAL interpretation.

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

2.0 DISCUSSION 2.1 Permanently Defueled Facility NEI 99-01 provides guidance for an emergency classification scheme applicable to a permanently defueled facility. This is a facility that generated spent fuel under a 10 CFR Part 50 license, has permanently ceased operations, and will store the spent fuel onsite for an extended period of time. The emergency classification levels (ECLs) applicable to this type of facility are consistent with the requirements of 10 CFR Part 50 and the guidance in NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Rev. 1 (NUREG-0654).

In order to relax the emergency plan requirements previously applicable to an operating facility, the licensee must demonstrate that no credible event can result in a significant radiological release beyond the site boundary. This verification confirms that the source term and motive force available in the permanently defueled condition are insufficient to warrant classifications of a Site Area Emergency or General Emergency. Therefore, the generic ICs and EALs applicable to a permanently defueled facility may result in either a Notification of Unusual Event (Unusual Event) or an Alert classification.

Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 1

2.2 Independent Spent Fuel Storage Installation Selected guidance in NEI 99-01, Rev. 6 is applicable to licensees electing to use their 10 CFR Part 50 emergency plan to fulfill the requirements of 10 CFR 72.32 for a stand-alone Independent Spent Fuel Storage Installation (ISFSI). The ECLs applicable to an ISFSI are consistent with the requirements of 10 CFR Part 50. The ICs germane to a 10 CFR 72.32 emergency plan (as described in NUREG-1567) are subsumed within the classification scheme for a 10 CFR 50.47 emergency plan.

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). NUREG-1140 concluded that the postulated worst-case accident involving an ISFSI has insignificant consequences to public health and safety.

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

Regarding the above information, the expectations for an offsite response to an Alert classified under a 10 CFR 72.32 emergency plan are generally consistent with those for an Unusual Event in a 10 CFR 50.47 emergency plan (e.g., to provide assistance, if requested). Also, the licensees Emergency Response Organization (ERO) required for a 10 CFR 72.32 emergency plan is different than that prescribed for a 10 CFR 50.47 emergency plan (e.g., no emergency technical support function).

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

Emergency Classification Level Unusual Event Alert Initiating Condition Initiating Condition Permanently Defueled Emergency Permanently Defueled Emergency Action Level1 Action Level1 Notes Notes Basis Basis 1

When making an emergency classification, the Shift Manager/Emergency Director must consider all information having a bearing on the proper assessment of an Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 2

Initiating Condition. This includes the PD and E EALs, Notes, and the Basis information.

3.1 Emergency Classification Levels One of a set of names or titles established by the 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 ECLs, in ascending order of severity, are:

Unusual Event Alert 3.1.1 Unusual Event Events are in progress or have occurred which indicate a potential degradation of the level of safety of the facility or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

Purpose:

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

3.1.2 Alert Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the facility or a security event that 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 Environmental Protection Agency (EPA) Protective Action Guides (PAG) exposure levels.

Purpose:

The purpose of this classification is to assure that emergency personnel are readily available to respond if the situation becomes more serious or to perform confirmatory radiation monitoring if required, and provide offsite authorities current information on facility status and parameters.

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

Discussion: An Initiating Condition (IC) describes an event or condition, the severity or consequences of which meets the definition of an ECL. An IC can be expressed as a Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 3

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

an earthquake).

Appendix 1 of NUREG-0654 does not contain example EALs for each ECL, but rather ICs (i.e., conditions that indicate that a radiological emergency, or events that could lead to a radiological emergency, have occurred). NUREG-0654 states that the ICs form the basis for establishment by a licensee of the specific facility instrumentation readings (as applicable) which, if exceeded, would initiate the emergency classification. Thus, it is the specific instrument readings that would be the EALs.

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

Discussion: EAL statements may utilize a variety of criteria including instrument readings and status indications, observable events, results of calculations and analyses, entry into particular procedures, and the occurrence of natural phenomena.

4.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS 4.1 General Considerations When making an emergency classification, the Emergency Director must consider all information having a bearing on the proper assessment of an IC. This includes the EAL plus Notes and the informing Basis information.

All emergency classification assessments should be based upon valid indications, reports or conditions. A valid indication, report, or condition, is one that has been verified through appropriate means such that there is no doubt regarding the indicators operability, the conditions existence, or the reports accuracy. For example, validation could be accomplished through an instrument channel check, response on related or redundant indicators, or direct observation by personnel. The validation of indications should be completed in a manner that supports timely emergency declaration.

For ICs and EALs that have a stipulated time duration (e.g., 15 minutes, 60 minutes, etc.), the Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time. If an ongoing radiological release is detected and the release start time is unknown, it should be assumed that the release duration specified in the IC/EAL has been exceeded, absent data to the contrary.

A planned work activity that results in an expected event or condition which meets or exceeds an EAL does not warrant an emergency declaration provided that 1) the activity proceeds as planned and 2) the facility remains within the limits imposed by the operating license. Such activities include planned work to test, manipulate, repair, maintain, or modify a system or component. In these cases, the controls associated with Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 4

the planning, preparation, and execution of the work will ensure that compliance is maintained with all aspects of the operating license provided that the activity proceeds and concludes as expected. Events or conditions of this type may be subject to the reporting requirements of 10 CFR 50.72.

The assessment of some EALs is based on the results of analyses that are necessary to ascertain whether a specific EAL threshold has been exceeded (e.g., gaseous and liquid effluent sampling, etc.); the EAL and/or the associated basis discussion will identify the necessary analysis. In these cases, the declaration period starts with the availability of the analysis results that show the threshold to be exceeded (i.e., this is the time that the EAL information is first available).

While the EALs have been developed to address a full spectrum of possible events and conditions which may warrant emergency classification, a provision for classification based on operator/management experience and judgment is still necessary. The NEI 99-01 scheme provides the Emergency Director with the ability to classify events and conditions based upon judgment using EALs that are consistent with the ECL definitions (refer to PD-HU3 and PD-HA3). The Emergency Director will need to determine if the effects or consequences of the event or condition reasonably meet or exceed a particular ECL definition.

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

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

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

When assessing an EAL that specifies a time duration for the off-normal condition, the EAL time duration runs concurrently with the emergency notification time duration.

4.3 Classification of Multiple Events and Conditions When multiple emergency events or conditions are present, the user will identify all met or exceeded EALs. The highest applicable ECL identified during this review is declared.

For example:

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

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

If two Unusual Event EALs are met, an Unusual Event should be declared.

Related guidance concerning classification of rapidly escalating events or conditions is provided in Regulatory Issue Summary (RIS) 2007-02, Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events.

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4.4 Classification of Imminent Conditions Although EALs provide specific thresholds, the Emergency Director must remain alert to events or conditions that could lead to meeting or exceeding an EAL within a relatively short period of time (i.e., a change in the ECL is IMMINENT). If, in the judgment of the Emergency Director, meeting an EAL is IMMINENT, the emergency classification should be made as if the EAL has been met. While applicable to all ECLs, this approach is particularly important at the higher ECL since it provides additional time for implementation of protective measures.

4.5 Emergency Classification Level Upgrading and Termination An ECL may be terminated when the event or condition that meets the IC and EAL no longer exists.

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

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

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

These criteria will require that the IC/EAL conditions be present for a defined period of time before an emergency declaration is warranted. In cases where no time-based criterion is specified, it is recognized that some transient conditions may cause an EAL to be met for a brief period of time (e.g., a few seconds to a few minutes). The following guidance should be applied to the classification of these conditions.

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

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

If an operator takes prompt manual action to address a condition, and the action is successful in correcting the condition prior to the emergency declaration, then the applicable EAL is not considered met and the associated emergency declaration is not required.

It is important to stress that the emergency classification assessment period is not a grace period during which a classification may be delayed to allow the performance of Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 6

a corrective action that would obviate the need to classify the event; emergency classification assessments must be deliberate and timely, with no undue delays.

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

In these cases, no emergency declaration is warranted; however, the guidance contained in NUREG-1022, Event Report Guidelines 10 CFR 50.72 and 50.73, is applicable. Specifically, the event should be reported to the NRC in accordance with 10 CFR § 50.72 within one hour of the discovery of the undeclared event or condition. The licensee should also notify appropriate State and local agencies in accordance with the agreed upon arrangements.

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

5.0 REFERENCES

5.1 Developmental 5.1.1 NEI 99-01 Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, November 2012 5.1.2 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities 5.1.3 RIS 2007-02, Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events, February 2007 5.1.4 NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73 5.1.5 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors 5.1.6 NUREG-0654/FEMA-REP-1, Rev. 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants 5.1.7 10 CFR 72.32, Emergency Plan 5.1.8 NUREG-1567, Spent Fuel Dry Storage Facilities 5.1.9 10 CFR 50.47, Emergency Plans Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 7

5.1.10 NUREG-1140, A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees 5.2 Implementing 5.2.1 Permanently Defueled Emergency Plan 5.2.2 EAL Comparison Matrix 5.2.3 EAL Classification Matrix 5.3 Commitments None Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 8

6.0 ACRONYMS & DEFINITIONS 6.1 Acronyms AOP.................................................................................. Abnormal Operating Procedure CDE....................................................................................... Committed Dose Equivalent CFR ...................................................................................... Code of Federal Regulations cpm ...................................................................................................... Counts per Minute EAL ............................................................................................. Emergency Action Level ECL .................................................................................. Emergency Classification Level EPA .............................................................................. Environmental Protection Agency FAA .................................................................................. Federal Aviation Administration FBI....................................................................................Federal Bureau of Investigation FEMA .............................................................. Federal Emergency Management Agency HSM ........................................................................................ Horizontal Storage Module ISFSI ............................................................Independent Spent Fuel Storage Installation IC.......................................................................................................... Initiating Condition mRem................................................................................ milli-Roentgen Equivalent Man MSL ......................................................................................................... Mean Sea Level NEI .............................................................................................. Nuclear Energy Institute NORAD ...................................................North American Aerospace Defense Command NRC ............................................................................... Nuclear Regulatory Commission ODCM ........................................................................... Off-site Dose Calculation Manual ORO ................................................................................ Off-site Response Organization PAG.............................................................................................. Protective Action Guide PD .................................................................................................. Permanently Defueled rem ........................................................................................... Roentgen Equivalent Man TEDE................................................................................Total Effective Dose Equivalent USAR ................................................................ Final Safety Analysis Report as Updated Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 9

6.2 Definitions The following definitions are taken from Title 10 CFR, and related regulatory guidance documents.

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

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

The following key terms are necessary for overall understanding the NEI 99-01 emergency classification scheme.

Emergency Action Level (EAL): A pre-determined, site-specific, observable threshold for an Initiating Condition that, when met or exceeded, places the facility in a given ECL.

Emergency Classification Level (ECL): One of a set of names or titles established by the 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 ECLs, in ascending order of severity, are:

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

Selected terms used in IC and EAL statements are set in all capital letters (e.g., ALL CAPS). These words are defined terms that have specific meanings as used in this document. The definitions of these terms are provided below.

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

EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or over pressurization. A release of steam (from high Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 10

energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion. Such events may require a post-event inspection to determine if the attributes of an explosion are present.

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.

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

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

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

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

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

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

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

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

PROTECTED AREA: The area normally within the facility security fence designated to implement the security requirements of 10 CFR 73.

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

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

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

7.0 FCS-TO-NEI 99-01 EAL CROSS-REFERENCE The following cross-reference table is provided to facilitate association and location of a FCS EAL within the NEI 99-01, Rev. 6 IC/EAL identification scheme. Further information regarding the development of the FCS EALs based on the NEI guidance can be found in the EAL Comparison Matrix (Reference 5.2.2).

NEI 99-01, Rev. 6, Appendix C -

FCS Permanently Defueled IC/EALs Permanently Defueled Station ICs/EALs PD-RU1 PD-AU1 PD-RA1 PD-AA1 PD-RU2 PD-AU2 PD-RA2 PD-AA2 PD-HU1 PD-HU1 PD-HA1 PD-HA1 PD-HU2 PD-HU2 PD-HU3 PD-HU3 PD-HA3 PD-HA3 PD-SU1 PD-SU1 NEI 99-01, Rev. 6, Section 8 -

FCS ISFSI ICs/EAL ISFSI ICs/ EALs E-HU1 E-HU1 Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 12

8.0 ATTACHMENTS 8.1 Attachment 1, Recognition Category PD EAL Bases 8.2 Attachment 2, Recognition Category E EAL Basis Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 13

Attachment 1 Recognition Category PD EAL Bases Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 14

Attachment 1 Recognition Category PD EAL Bases Recognition Category PD EAL Bases Recognition Category PD (Permanently Defueled) provides a stand-alone set of ICs/EALs for a permanently defueled facility to consider for use in developing a site-specific emergency classification scheme. For development, it was assumed that the facility had operated under a 10 CFR Part 50 license and that the licensee has permanently ceased power operations and removed fuel from the reactor vessel.

Further, the licensee intends to store the spent fuel within the permanently defueled facility for some period of time.

When in a permanently defueled condition, the licensee typically receives approval from the NRC for exemptions from specific emergency planning requirements. These exemptions reflect the reduced radiological source term and risks associated with spent fuel pool storage relative to reactor at-power operation. Source terms and accident analyses associated with plausible accidents are documented in the facilities Final Safety Analysis Report as Updated (USAR). As a result, FCS has developed a facility-specific emergency classification scheme using the NRC-approved exemptions, revised source terms, and revised accident analyses as documented in the stations USAR.

Recognition Category PD uses the same ECLs as operating reactors; however, the source term and accident analyses typically limit the ECLs to an Unusual Event and an Alert. The Unusual Event ICs provide for an increased awareness of abnormal conditions while the Alert ICs are specific to actual or potential impacts to spent fuel.

The source terms and release motive forces associated with a permanently defueled facility would not be sufficient to require declaration of a Site Area Emergency or General Emergency.

A permanently defueled station is essentially a spent fuel storage facility with the spent fuel stored in a pool of water that serves as both a cooling medium (i.e., removal of decay heat) and shield from direct radiation. These primary functions of the spent fuel storage pool are the focus of the Recognition Category PD ICs and EALs. Radiological effluent ICs and EALs were included to provide a basis for classifying events that cannot be readily classified based on an observable events or facility conditions alone.

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

The following table, Table PD-1: Recognition Category PD Initiating Condition Matrix, provides a summary of ICs associated with Recognition Category PD.

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Attachment 1 Recognition Category PD EAL Bases Table PD-1: Recognition Category PD Initiating Condition Matrix UNUSUAL EVENT ALERT PD-RU1 Release of gaseous or liquid PD-RA1 Release of gaseous or liquid radioactivity greater than 2 times the radioactivity resulting in offsite dose ODCM limits for 60 minutes or longer. greater than 10 mRem TEDE or 50 mRem thyroid CDE.

PD-RU2 UNPLANNED rise in facility PD-RA2 UNPLANNED rise in facility radiation levels. radiation levels that impedes facility access required to maintain spent fuel integrity.

PD-HU1 Confirmed SECURITY PD-HA1 HOSTILE ACTION within the CONDITION or threat. OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.

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

PD-HU3 Other conditions exist which in PD-HA3 Other conditions exist which in the judgment of the Emergency Director the judgment of the Emergency Director warrant declaration of an Unusual Event. warrant declaration of an Alert.

PD-SU1 UNPLANNED spent fuel pool temperature rise.

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Attachment 1 Recognition Category PD EAL Bases PD-RU1 Emergency Classification Level:

Unusual Event Initiating Condition:

Release of gaseous or liquid radioactivity greater than 2 times the Offsite Dose Calculation Manual (ODCM) limits for 60 minutes or longer.

Emergency Action Level (EAL): (1 or 2)

Notes:

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

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

If the effluent flow past an effluent 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. Reading on ANY Table R1 effluent monitors greater than 2 times the alarm setpoint established by a current radioactive release discharge permit for 60 minutes or longer.

Table R1 Effluent Monitor Thresholds Effluent Monitor Description Value RM-052 (aligned to Aux Building stack) AB Stack (gas) 2 X High Alarm RM-062 AB Stack (gas) 2 X High Alarm RM-055 (if discharge not isolated)

Liquid Discharge Header 2 X High Alarm OR

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

Basis:

This IC addresses a potential decrease in the level of safety of the facility as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release). It includes any gaseous or liquid radiological Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 17

Attachment 1 Recognition Category PD EAL Bases release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared.

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

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

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

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

EAL #1 addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This EAL will typically be associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas).

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

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

Basis

Reference:

1. NEI 99-01 Rev. 6, PD-AU1 Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 18

Attachment 1 Recognition Category PD EAL Bases PD-RA1 Emergency Classification Level:

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 Level (EAL): (1 or 2 or 3 or 4)

Notes:

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

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

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.

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.

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

Table R2 - Effluent Monitor Thresholds Effluent Monitor Description Value RM-052 (aligned to Aux Building stack) AB Stack (gas) 9 x 106 cpm RM-062 AB Stack (gas) 9 x 106 cpm RM-055 (if discharge not isolated) Liquid Discharge Header 9 x 106 cpm OR

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

OR

3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than 10 mRem TEDE or 50 mRem thyroid CDE at or beyond the site boundary for one hour of exposure.

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Attachment 1 Recognition Category PD EAL Bases OR

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

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

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

Basis:

This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the facility as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a 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 facility conditions alone. The inclusion of both facility 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 1000 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.

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

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

The threshold value for RM-062 was determined via Calculation FC08515. The RM-062 reading that corresponds to the 10 mRem TEDE (9.3 x 107 cpm) threshold exceeds the maximum count rate for the monitor (1 x 107 cpm). Based on the guidance presented in NEI 99-01, Rev. 6 the EAL threshold value is set at 90% of the maximum monitor reading, corresponding to 9 x 106 cpm.

The threshold value for RM-055 was determined via Calculation FC08516. The RM-055 Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 20

Attachment 1 Recognition Category PD EAL Bases reading that corresponds to the 10 mRem TEDE threshold exceeds the maximum count rate for the monitor (1 x 107 cpm). Based on the guidance presented in NEI 99-01, Rev.

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

Basis

Reference:

1. NEI 99-01 Rev. 6, PD-AA1

2. Calculation FC08515

3. Calculation FC08516 Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 21

Attachment 1 Recognition Category PD EAL Bases PD-RU2 Emergency Classification Level:

Unusual Event Initiating Condition:

UNPLANNED rise in facility radiation levels.

Emergency Action Level (EAL): (1 or 2)

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

LT-2846 (Spent Fuel Pool Level)

LI-2846 (Local Indication)

AND

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

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

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

Basis:

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

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

Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 22

Attachment 1 Recognition Category PD EAL Bases This IC addresses elevated radiation levels caused by a decrease in water level above irradiated (spent) fuel or other UNPLANNED events. The increased radiation levels are indicative of a minor loss in the ability to control radiation levels within the facility or radioactive materials. Either condition is a potential degradation in the level of safety of the facility.

A water level decrease will be primarily determined by indications from available level instrumentation. Other sources of level indications may include reports from personnel or video camera observations (if available). A significant drop in the water level may also cause a rise in the radiation levels of adjacent areas that can be detected by monitors in those locations.

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

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

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

Basis

Reference:

1. NEI 99-01 Rev. 6, PD-AU2 Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 23

Attachment 1 Recognition Category PD EAL Bases PD-RA2 Emergency Classification Level:

Alert Initiating Condition:

UNPLANNED rise in facility radiation levels that impedes facility access required to maintain spent fuel integrity.

Emergency Action Level (EAL): (1 or 2)

1. UNPLANNED dose rate greater than 15 mRem/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 Central Alarm Station OR

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

Room 4 Room 5 Room 24 Room 25 Room 26 Room 69 Basis:

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

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

This IC addresses increased radiation levels, as discussed in NEI 99-01, that impede necessary access to areas containing equipment that must be operated manually or that 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 Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 24

Attachment 1 Recognition Category PD EAL Bases interference or delay is sufficient to significantly threaten necessary facility access. It is this impaired access that results in the actual or potential substantial degradation of the level of safety of the facility.

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

Basis

Reference:

1. NEI 99-01 Rev. 6, PD-AA2 Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 25

Attachment 1 Recognition Category PD EAL Bases PD-HU1 Emergency Classification Level:

Unusual Event Initiating Condition:

Confirmed SECURITY CONDITION or threat.

Emergency Action Level (EAL): (1 or 2 or 3)

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

OR

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

OR

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

Basis:

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

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

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

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

This IC addresses events that pose a threat to facility personnel or equipment necessary to maintain spent fuel integrity, and thus represent a potential degradation in the level of facility safety. Security events which do not meet one of these EALs are adequately Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 26

Attachment 1 Recognition Category PD EAL Bases 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 communication between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to site personnel and Off-Site Response Organizations.

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

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

§ 2.390 information.

EAL #2 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with SY-AA-101-132, Security Assessment and Response to Unusual Activities.

EAL #3 addresses the threat from the impact of an aircraft on the facility. 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 AOP-37, Security Events.

Escalation of the emergency classification level would be via IC PD-HA1.

Basis

Reference:

1. NEI 99-01 Rev. 6, PD-HU1 Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 27

Attachment 1 Recognition Category PD EAL Bases PD-HA1 Emergency Classification Level:

Alert Initiating Condition:

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

Emergency Action Level (EAL): (1 or 2)

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.

Basis:

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

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

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

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

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

Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 28

Attachment 1 Recognition Category PD EAL Bases PROTECTED AREA: The area normally within the facility security fence designated to implement the security requirements of 10 CFR 73.

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

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

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

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

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

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

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

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

In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 29

Attachment 1 Recognition Category PD EAL Bases NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.

Basis

Reference:

1. NEI 99-01 Rev. 6, PD-HA1 Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 30

Attachment 1 Recognition Category PD EAL Bases PD-HU2 Emergency Classification Level:

Unusual Event Initiating Condition:

Hazardous event affecting equipment necessary for spent fuel cooling.

Emergency Action Level (EAL):

1. a. The occurrence of ANY of the following hazardous events:

Seismic event (earthquake)

Internal or external flooding event High winds or tornado strike FIRE EXPLOSION Low river level as indicated by less than 976 feet, 9 inches MSL elevation Other events with similar hazard characteristics as determined by the Shift Manager AND

b. The event has damaged at least one train of a system needed for spent fuel cooling.

AND

c. The damaged equipment cannot, or potentially cannot, perform its design function based on EITHER:

Indications of degraded performance VISIBLE DAMAGE Basis:

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

Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 31

Attachment 1 Recognition Category PD EAL Bases FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.

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

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

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

For EAL 1.c., the second bullet addresses damage to equipment that is not in service/operation or readily apparent through indications alone. Operators will make this determination based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.

Escalation of the emergency classification level could, depending upon the event, be based on any of the ALERT ICs: PD-RA1, PD-RA2, PD-HA1, or PD-HA3 Basis

Reference:

1. NEI 99-01, Rev. 6, PD-HU2 Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 32

Attachment 1 Recognition Category PD EAL Bases PD-HU3 Emergency Classification Level:

Unusual Event Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Unusual Event.

Emergency Action Level (EAL):

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

Basis:

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

Basis

Reference:

1. NEI 99-01, Rev. 6, PD-HU3 Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 33

Attachment 1 Recognition Category PD EAL Bases PD-HA3 Emergency Classification Level:

Alert Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert.

Emergency Action Level (EAL):

1. Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the facility or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

Basis:

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

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

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

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

Basis

Reference:

1. NEI 99-01, Rev. 6, PD-HA3 Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 34

Attachment 1 Recognition Category PD EAL Bases Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 35

Attachment 1 Recognition Category PD EAL Bases PD-SU1 Emergency Classification Level:

Unusual Event Initiating Condition:

UNPLANNED spent fuel pool temperature rise.

Emergency Action Level (EAL):

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

Basis:

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

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

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

Basis

Reference:

1. NEI 99-01 Rev. 6, PD-SU1 Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 36

Attachment 2 Recognition Category E EAL Basis Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 37

Attachment 2 Recognition Category E EAL Bases Recognition Category E EAL Basis Recognition Category E provides a set of ICs/EALs for an ISFSI. An ISFSI is a complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage. A significant amount of the radioactive material contained within a cask must escape its packaging and enter the atmosphere for there to be a significant environmental effect resulting from an accident involving the dry storage of spent nuclear fuel. Formal offsite planning is not required because the postulated worst-case accident involving an ISFSI has insignificant consequences to the public health and safety.

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

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

Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 38

Attachment 2 Recognition Category E EAL Bases E-HU1 Emergency Classification Level:

Unusual Event Initiating Condition Damage to a loaded cask CONFINEMENT BOUNDARY.

Emergency Action Level (EAL):

1. Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading:

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

> 400 mRem/hr (gamma + neutron) on the HSM door centerline OR

> 16 mRem/hr (gamma + neutron) on the end shield wall exterior Basis:

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

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

This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage cask is sealed. The issues of concern are the creation of a potential or actual release path to the environment, degradation of one or more fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the cask or fuel from storage.

The existence of damage is determined by radiological survey. The radiation limits listed in the EAL reflect 2 times the cask technical specification for radiation level. The technical Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 39

Attachment 2 Recognition Category E EAL Bases 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.

Amendment number 9 to COC 1004 Technical Specifications for the Standardized NUHOMS Horizontal Storage Module System contains radiation dose levels for the dry storage cask that should not be exceeded based on whether the dry storage cask is being transported inside the fuel transfer cask or it is stored in the horizontal storage module.

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

Security-related events for ISFSIs are covered under ICs PD-HU1 and PD-HA1.

Basis

References:

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

2. Amendment 9 to COC 1004 Technical Specifications for the Standardized NUHOMS Horizontal Storage Module System Fort Calhoun Station Permanently Defueled EAL Technical Bases Rev. 0 40

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION DOCKET NUMBER 50-285 / LICENSE NUMBER DPR-40 ENCLOSURE 3 PERMANENTLY DEFUELED EMERGENCY ACTION LEVEL SCHEME MATRIX

ALERT UNUSUAL EVENT PD-RA1 Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 PD-RU1 Release of gaseous or liquid radioactivity greater than 2 times the Offsite Dose mRem TEDE or 50 mRem thyroid CDE. calculation Manual (ODCM) limits for 60 minutes or longer.

EMERGENCY ACTION LEVEL (EAL): (1 or 2 or 3 or 4) EMERGENCY ACTION LEVEL (EAL): (1 or 2)

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

If an ongoing release is detected and the release start time is unknown, assume that the If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes. release duration has exceeded 60 minutes.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate If the effluent flow past an effluent monitor is known to have stopped due to actions to the release path, then the effluent monitor reading is no longer valid for classification purposes. isolate the release path, then the effluent monitor reading is no longer valid for classification The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency purposes.

classification assessments until the results from a dose assessment using actual meteorology 1. Reading on ANY Table R1 effluent monitors greater than 2 times the alarm setpoint established are available. by a current radioactive release discharge permit for 60 minutes or longer.

1. A valid reading on ANY Table R2 effluent monitor greater than the value shown for 15 minutes or Table R1 - Effluent Monitor Thresholds longer: Effluent Monitor Description Value Table R2 - Effluent Monitor Thresholds RM-052 (aligned to Aux AB Stack (gas) 2X High Alarm R 1 Effluent Monitor Description Value Building stack)

Effluent RM-052 (aligned to Aux Building AB Stack (gas) 9 x 106 cpm RM-062 AB Stack (gas) 2X High Alarm Abnormal Rad Radiation stack) RM-055 (if discharge not Liquid Discharge Header 2X High Alarm Levels / Rad RM-062 AB Stack (gas) 9 x 106 cpm isolated)

Effluent RM-055 (if discharge not isolated) Liquid Discharge Header 9 x 106 cpm OR OR

2. Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater

2. Dose assessment using actual meteorology indicates doses greater than 10 mRem TEDE or 50 than 2 times the ODCM limits for 60 minutes or longer.

mRem thyroid CDE at or beyond the site boundary.

OR

3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than 10 mRem TEDE or 50 mRem thyroid CDE at or beyond the site boundary for one hour of exposure.

OR

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

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

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

PD-RA2 UNPLANNED rise in facility radiation levels that impedes facility access required to PD-RU2 UNPLANNED rise in facility radiation levels.

maintain spent fuel integrity.

EMERGENCY ACTION LEVEL (EAL): (1 or 2) EMERGENCY ACTION LEVEL (EAL): (1 or 2)

1. UNPLANNED dose rate greater than 15 mR/hr in ANY of the following areas requiring continuous 1. a. UNPLANNED water level drop to below the normal range in the spent fuel pool as indicated occupancy to maintain control of radioactive material or operation of systems needed to maintain by the following:

spent fuel integrity. LT-2846 (Spent Fuel Pool Level)

Main Control Room LI-2846 (Local Indication)

Central Alarm Station AND OR b. UNPLANNED rise in area radiation levels as indicated by a valid reading on ANY radiation 2 2. Area Radiation Monitor readings or survey results indicate an UNPLANNED rise by 100 mRem/hr monitor in Table R3.

over NORMAL LEVELS that impedes access to ANY of the following areas needed to maintain Table R3 - Radiation Monitors Plant Rad control of radioactive material or operation of systems needed to maintain spent fuel integrity.

Levels Room 4 RMS Areas Monitored Room 5 RM-80, 85, 87 Spent Fuel Storage Area Radiation Monitor Room 24 Portable Area Rad Monitor Auxiliary Building near fuel handling areas Room 25 OR Room 26 Room 69 2.Area radiation monitor readings or survey results indicated an UNPLANNED rise of 25 mRem/hr over NORMAL LEVELS.

PD-HA1 HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat PD-HU1 Confirmed SECURITY CONDITION or threat.

within 30 minutes.

EMERGENCY ACTION LEVEL (EAL): (1 or 2) EMERGENCY ACTION LEVEL (EAL): (1 or 2 or 3)

1. A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as 1. A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the 1 reported by the Security Shift Supervisor. Security Shift Supervisor.

OR OR Security

2. A validated notification from NRC of an aircraft attack threat within 30 minutes of the site. 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.

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

EMERGENCY ACTION LEVEL (EAL):

H 1. a. The occurrence of ANY of the following hazardous events:

Hazards Seismic event (earthquake)

Internal or external flooding event High winds or tornado strike FIRE 2 None EXPLOSION Natural & Low river level as indicated by less than 976 feet, 9 inches MSL elevation Destructive Other events with similar hazard characteristics as determined by the Shift Manager Phenomena AND

b. The event has damaged at least one train of a system needed for spent fuel cooling.

AND

c. The damaged equipment cannot, or potentially cannot, perform its design function based on EITHER:

Indications of degraded performance VISIBLE DAMAGE

PD-HA3 Other conditions exist which in the judgment of the Emergency Director warrant PD-HU3 Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert. declaration of an Unusual Event.

EMERGENCY ACTION LEVEL (EAL): EMERGENCY ACTION LEVEL (EAL):

3 1. Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in 1. Other conditions exist which, in the judgement of the Emergency Director, indicate that events progress or have occurred which involve an actual or potential substantial degradation of the level of are in progress or have occurred which indicate a potential degradation of the level of safety of Judgment safety of the facility or a security event that involves probable life threatening risk to site personnel or the facility or indicate a security threat to facility protection has been initiated. No releases of damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited radioactive material requiring offsite response or monitoring are expected unless further to small fractions of the EPA Protective Action Guideline exposure levels. degradation of systems needed to maintain spent fuel cooling occurs.

PD-SU1 UNPLANNED spent fuel pool temperature rise.

EMERGENCY ACTION LEVEL (EAL):

S None

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

E-HU1 Damage to a loaded cask CONFINEMENT BOUNDARY.

EMERGENCY ACTION LEVEL (EAL):

1. Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading:

1600 mRem/hr (gamma + neutron) on the Horizontal Storage Module (HSM) front E None surface ISFSI OR

> 400 mRem/hr (gamma + neutron) on the HSM door centerline OR

> 16 mRem/hr (gamma + neutron) on the end shield wall exterior PERMANENTLY DEFUELED CONDITIONS Fort Calhoun Station IC/EAL Identifier Emergency Action Level Matrix PD or E-XX#.# - Example (PD-HA1.2)

Category (R, H, S, E) Sequential number within subcategory/classification Emergency Classification (A, U) Subcategory number (1 if no subcategory)