LIC-17-0020, Response to Request for Additional Information, Final Request for Additional Information Concerning Post-Shutdown Eplan Amendment

Response to Request for Additional Information, Final Request for Additional Information Concerning Post-Shutdown Eplan Amendment

ML17062A887
Person / Time
Site:	Fort Calhoun
Issue date:	03/03/2017
From:	Fisher M Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF8326, LIC-17-0020
Download: ML17062A887 (55)

Text

Omaha Public Power District LIC-17-0020 March 3, 2017 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station (FCS), Unit 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285

Subject:

Response to Request for Additional Information, Fort Calhoun Station, Unit No.1

- Final Request for Additional Information Concerning Post-Shutdown EPian Amendment (CAC MF8326)

References:

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

(ML16246A321)

2. EMAIL from NRC (J. Kim) to OPPD (E. P. Matzke), "Fort Calhoun Station- Final Request for Additional Information Concerning Post-Shutdown EPian Amendment (CAC MF8326)", dated February 2, 2017 (ML17033A969)

By letter dated September 2, 2016 (Reference 1), the Omaha Public Power District (OPPD) proposed an amendment to Renewed Facility Operating License No. DPR-40 for the Fort Calhoun Station (FCS). The proposed amendment would revise the FCS Emergency Plan for the permanently defueled condition. Specifically, the proposed changes would revise the on-shift staffing and Emergency Response Organization (ERO) staffing levels.

On February 2, 2017 (Reference 2), the NRC provided OPPD with Requests for Additional Information (RAI) regarding the proposed emergency plan changes. Attachment 1 of this letter provides the responses to the RAI. Attachment 2 of this letter provides the necessary changes to Reference 1 resulting from the responses to the RAI.

444 SOUTH 16TH STREET MALL

• OMAHA, NE 68102-2247 EMPLOIMENT WITH EQUA~ OI'PORTUNITY

U. S. Nuclear Regulatory Commission LIC-17-0020 Page 2 This letter contains no regulatory commitments.

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

Respectfully, *

~t'/~

Senior Director Decommissioning Fort Calhoun Station MJF/epm Attachments: 1. Response to Request for Additional Information

2. License Amendment Request 16-02 Attachment 1, Revision 1

3. Supplemental Page Revisions c: K. M. Kennedy, NRC Regional Administrator, Region IV J. Kim, NRC 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

LIC-17-0020 Page 1 ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING ADMENDMENT REQUEST FOR EMERGENCY PLAN CHANGE OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION. UNIT NO. 1 DOCKET NO. 50-285 By letter dated September 2, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16246A321), Omaha Public Power District (OPPD, the licensee), requested prior U.S. Nuclear Regulatory Commission (NRC) approval of an amendment to the Fort Calhoun Station (FCS) Radiological Emergency Response Plan (RERP) in support of OPPDs intent to permanently cease power operations at FCS no later than December 31, 2016. The proposed amendment to the FCS RERP would revise the FCS Emergency Response Organization (ERO) on-shift and augmented staffing, based on NRC approval, based on the certifications for permanent cessation of power operations and permanent removal of fuel from the reactor vessel to the NRC in accordance with §50.82(a)(1)(i) and (ii) to Title 10 of the Code of Federal Regulations (10 CFR), which will no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel.

The standards in §50.47 to Title 10 of the Code of Federal Regulations (10 CFR 50.47),

Emergency plans, and the requirements of Appendix E to 10 CFR Part 50, Emergency Planning and Preparedness for Production and Utilization and Production Facilities, on which the staff based its review, are as follows:

10 CFR 50.47(b)(1), states, in part: ... each principal response organization has staff to respond and to augment its initial response on a continuous basis; 10 CFR 50.47(b)(2) states, in part: ... adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available...;

10 CFR Part 50, Appendix E, Section IV.A, states, in part: The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensees emergency organization; and 10 CFR Part 50, Appendix E, Section IV.C.1, states, in part: The emergency classes defined shall include (1) Notification of unusual events, (2) alert, (3) site area emergency, and (4) general emergency.

The evaluation criteria, as applicable based on the permanently shutdown and defueled condition of the facility, contained in Section II.B (Onsite Emergency Organization) of NUREG-0654/FEMA-REP-1, Revision 1, Criteria for Preparedness and Evaluation of Radiological Emergency Response Plans and Nuclear Power Plants, were used in evaluating proposed ERO staffing changes. The staffs technical review also takes into consideration that prior to the Commissions approval of requested exemptions to the standards in 10 CFR 50.47 and the requirements of Appendix E to 10 CFR Part 50, the proposed FCS RERP must continue to provide adequate on-shift and augmented ERO staffing to effectively respond to a radiological release escalating to a General Emergency classification and requiring consideration of offsite protective actions by State and local officials.

LIC-17-0020 Page 2 The requests for additional information (RAI) listed below are necessary to facilitate the technical review being conducted by the Office of Nuclear Security and Incident Response/ Division of Preparedness and Response, Reactor Licensing Branch (NSIR/DPR/RLB). A timely and thorough response to these RAIs is requested in order to meet the proposed deadline requested by the licensee.

RAI-FCS-1 Page 19 of Attachment 1, Description and Evaluation of the Proposed Changes, identifies only one Radiation Protection (RP) Technician in the Operational Support Center (OSC) for elimination. However, pages 27 and 28 of Attachment 2, Tabular Summary of Proposed Changes to the FCS RERP, identifies the following:

Before (Rev.1) After (Pending Reason for Change Revision Number) 2 RP Technicians Deleted These positions have no defined tasks in procedures.

All offsite survey tasks are currently performed by the Field Team Technicians, which are maintained.

2 RP Technicians 1 RP Technician The spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The duties and coverage required for the position is reduced.

2 RP Technicians 1 RP Technician The spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The duties and coverage required for the position is reduced.

a) With respect to the proposed 2 RP Technicians being deleted above, what tasks do these RP Technicians actually perform in the current RERP and how would they be utilized for an event classified as a General Emergency with a radiological release requiring an offsite protective action recommendation (PAR) to be issued?

Please provide further justification for their elimination based on their current tasks.

Response a The two Radiation Protection Technician positions currently listed in the Radiological Accident Assessment and Support of Operational Accident Assessment Major Functional Area of Attachment 1 - Table B.1 of Section B of the Fort Calhoun Station (FCS)

Radiological Emergency Response Plan (RERP), proposed for elimination in License Amendment Request (LAR) 16-02, dated September 2, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16246A321) (Reference 1),

do not have defined tasks in procedures. Currently, EPIPs direct the Protective Measures Coordinator (position maintained in the Post-Shutdown ERO) to dispatch Radiation Protection personnel to the Remote Assembly Area(s)/Relocation Area(s) to evaluate habitability and, if required, perform surveys of vehicles and evacuees in the event of a site evacuation, if sufficient Radiation Protection staff is present onsite at the time the site evacuation is ordered.

LIC-17-0020 Page 3 Historically, the Radiation Protection Technician positions proposed for elimination served as the Radiation Protection personnel that would mobilize to the Remote Assembly Area(s)/Relocation Area(s) to perform these actions. However, these actions need not be performed by Radiation Protection Technicians. Procedures direct the Protective Measures Coordinator to initiate callouts, or contact the EOF Protective Measures Manager (position maintained in the Post-Shutdown ERO) for additional resources.

FCS is eliminating these positions from Attachment 1 - Table B.1 because the time necessary to establish the offsite locations to which Radiation Protection personnel would respond precludes the need for these positions to be augmenting positions and because EPIPs direct the Protective Measures Coordinator to dispatch Radiation Protection personnel, not Radiation Protection Technicians, to perform the necessary actions. FCS maintains the necessary staffing to provide personnel trained in radiation protection to respond and perform the required actions, if necessary, in the post-shutdown condition.

Activities related to the conduct of surveys or radiological assessment of the area surrounding FCS will be performed by the four Field Team Technicians identified in the Radiological Accident Assessment and Support of Operational Accident Assessment Major Functional Area of Attachment 1 - Table B.1 of Section B of the FCS RERP, independent of the augmenting Radiation Protection Technician positions. Offsite surveys in support of dose assessment are currently performed by the four Field Team Technicians, which are maintained in the Post-Shutdown Emergency Plan (PSEP).

FCS is no longer an operating nuclear power plant. In accordance with 10 CFR 50.82(a)(1),

pursuant to 10 CFR 50.82(a)(2), the Part 50 license no longer authorizes operation of the FCS reactor or emplacement or retention of fuel in the reactor vessel. With irradiated fuel being stored in the Spent Fuel Pool (SFP) and the Independent Spent Fuel Storage Installation (ISFSI), the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The risk in the permanently defueled condition is significantly reduced because many of the potential initiating conditions that would lead to an emergency declaration will no longer be possible and the elimination of credible accidents involving an operating reactor provides additional time to plan and execute assessment and mitigation actions.

b) FCS is proposing to reduce the number of augmenting RP Technicians from six to two within 60 minutes. Please provide further justification that the proposed two augmenting RP Technicians can perform all required tasks for a radiological release escalating to a General Emergency classification and requiring consideration of offsite protective actions by State and local officials.

Response b The response to RAI-FCS-1.a, above, provides the justification for the elimination of the two Radiation Protection Technicians listed in the Radiological Accident Assessment and Support of Operational Accident Assessment Major Functional Area of Attachment 1 -

Table B.1 of Section B of the FCS RERP.

LIC-17-0020 Page 4 In Reference 1, FCS proposes reducing the number of Radiation Protection Technicians listed in the Major Task of Onsite (Out of plant) survey in the Radiological Accident Assessment and Support of Operational Accident Assessment Major Functional Area of Attachment 1 - Table B.1 of Section B of the FCS RERP from two to one. As described in Reference 1, the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The risk in the permanently defueled condition is significantly reduced because many of the potential initiating conditions that would lead to an emergency declaration will no longer be possible and the elimination of credible accidents involving an operating reactor provides additional time to plan and execute assessment and mitigation actions. Currently, EPIPs describe actions for Radiation Protection Technicians that could be performed by adequately trained station personnel.

Additionally, procedures direct the Protective Measures Coordinator to initiate callouts, or contact the EOF Protective Measures Manager (position maintained in the Post-Shutdown ERO) for additional resources. FCS maintains the necessary staffing to provide sufficient personnel trained in radiation protection to respond and perform the required actions, if necessary, in the post-shutdown condition.

In Reference 1, FCS also proposes reducing the number of Radiation Protection Technicians listed in the Protective Actions (Plant) Major Functional Area of Attachment 1 -

Table B.1 of Section B of the FCS RERP from two to one. The primary function of the Radiation Protection Technicians augmenting the ERO is to provide radiation protection oversight of the on-shift complement and augmented personnel who are expected to respond to emergency events for damage repair, corrective actions, search and rescue, first aid, firefighting, and personnel monitoring. As described in Reference 1, the elimination of credible accidents involving an operating reactor provides additional time to plan and execute assessment and mitigation actions, which precludes the need for these positions to be augmenting positions. Additionally, the duties and coverage required for the position is reduced. The reduced spectrum of possible accidents limits the necessity to take measures requiring multiple damage control or survey teams in the Protected Area. During the initial stages of an accident, not all areas of the plant would be affected by releases of radioactive materials. Therefore, radiation protection coverage would not be required for all areas.

Because entry is expected to be limited to those areas where maintenance necessary to maintain SFP cooling is required and the areas potentially affected by an accident involving the SFP are limited, there is a significant decrease in areas potentially requiring radiation protection coverage in a permanently shut down and defueled condition. If radiation protection coverage is deemed necessary, multiple emergency teams can be covered by the on-shift Radiation Protection Technician. If radiation protection coverage is not provided (for entry into areas with low radiological risk or known radiological status), worker protection is ensured because emergency workers are required to wear electronic dosimeters (which will alarm at preset dose and dose rate setpoints) and because of the installed Area Radiation Monitors (ARMs) (which alarm locally and remotely at preset dose rates) located throughout the plant. Section 4.2.7 of Reference 1 provides further justification related to the reduction of the Radiation Protection Technician positions in the Protective Actions (Plant) Major Functional Area.

LIC-17-0020 Page 5 Activities related to the conduct of surveys or radiological assessment of the area surrounding FCS will be performed by the four Field Team Technicians identified in the Radiological Accident Assessment and Support of Operational Accident Assessment Major Functional Area of Attachment 1 - Table B.1 of Section B of the FCS RERP, independent of the augmenting Radiation Protection Technician positions. Offsite surveys in support of dose assessment are currently performed by the four Field Team Technicians, which are maintained in the PSEP.

RAI-FCS-2 Page 23 of Attachment 1 states, Attachment 5 [Emergency Response Organization Task Analysis] contains an analysis of all ERO positions being eliminated and evaluates the transfer of tasks to remaining ERO positions following permanent cessation of power operations. Please describe by what process this was validated and documented for the staffing proposed in the Emergency Operations Facility (EOF), Technical Support Center (TSC), OSC and Joint Information Center (JIC).

Response

During the development of the proposed changes to the ERO staffing, documented in of Reference 1, FCS initiated a multi-disciplined team review of every aspect of the ERO staffing changes that were submitted for approval. This team included participants from Operations, Training, Engineering, Chemistry, Radiation Protection, Emergency Planning, Licensing, Plant Management, and Omaha Public Power District (OPPD) Corporate Communications. Membership covered all levels of ERO qualifications, incorporating shift technicians, licensed operators, reactor engineers, OSC Directors, and Emergency Directors.

Each proposed change in task alignment was discussed and vetted by this group.

To further validate the staffing and assignment of tasks as identified in Attachment 5 of Reference 1, FCS Emergency Planning has drafted revisions to the existing Emergency Plan Implementing Procedures (EPIPs) and position checklists to align with the task assignments proposed in Attachment 5 of Reference 1. These procedures will be used to support training of post-shutdown ERO staff and the conduct of drills that will be used to validate the staffing and assignment of tasks. FCS has held training and review sessions of these draft changes in each Emergency Response Facility, using the personnel who currently hold the proposed ERO positions. A total of four training sessions were held to orient the ERO members to the revised EPIPs. Additionally, as described in the LAR, a training drill will be conducted as a final validation of the proposed changes.

The training drill addressed above will provide the opportunity for NRC and FEMA observation, to confirm the ability of the proposed post-shutdown ERO to perform the necessary functions of each Emergency Response Facility, and to utilize the post-shutdown procedures developed to reflect the proposed revised assignment of duties.

LIC-17-0020 Page 6 RAI-FCS-3 During the staffs review, the inconsistencies below were identified in the submittal.

Please revise accordingly to accurately resolve or provide further justification for apparent misalignment.

a. Page 9 of Attachment 1 states, The proposed changes to the FCS RERP will also eliminate the following minimum staffing positions for activation of ERFs currently identified inthe FCS ERP: OSC Radiation Coordinator. However, Page 19 of Attachment 1 states, The proposed staffing changes do not eliminate any ERO positions in the OSC described in FCS EPIPs as minimum staff positions.

Response

Table 1 of Reference 1 and Part 4.3.3 of Section B of the FCS RERP both identify the OSC Director, the Radiation Protection Coordinator or the Radiation Protection Technician, and one other person as being necessary minimum staffing for activation of the OSC. Additionally, Attachment 2 - Figure B-2 of Section B of the FCS RERP states that minimum staffing for the OSC is an OSC Director, one Radiation Protection Technician or the Radiation Protection Coordinator, and one other person to form a team.

Additionally, Part 4.7.1 of Section B of the FCS RERP states that minimum staffing positions for the OSC are the OSC Director, a Radiation Protection Technician, and one other person to form a team.

Because either the Radiation Protection Coordinator or the Radiation Protection Technician is required for activation of the OSC, but not both, and the Radiation Protection Technician position is being retained in the post-shutdown ERO, the intent of the statement on Page 19 of Reference 1 was to indicate that the proposed post-shutdown ERO was being maintained at a level that allowed for minimum staffing of the OSC to be accomplished consistent with the current requirements in the RERP (Part 4.7.1 of Section B). The statement on Page 19 of Reference 1 has been clarified to state that the proposed staffing changes do not impact the ability of FCS to activate the OSC using minimum staff positions currently described in the RERP. The revisions to Reference 1 are included in Attachment 2 of this response. The revision appears on Page 17 of Attachment 2 of this response.

LIC-17-0020 Page 7

b. Page 19 of Attachment 1 states, Following permanent cessation of power operations, the following OSC positions are proposed for elimination: one RP Technician, RP Coordinator, Maintenance Coordinator, Chemistry Coordinator, Medical Response Coordinator, OSC Operations Liaison, Dosimetry Technician, ERMS Operator, Radio Operator, Storekeeper, and Accountability Clerk.

However, Page 22 of Attachment 1 states, Therefore, the RP Coordinator, Maintenance Coordinator, Chemistry Coordinator, Medical Response Coordinator, OSC Operations Liaison, Dosimetry Technician, ERMS Operator, Radio Operator, Storekeeper, and Accountability Clerk positions can be eliminated without placing an undue burden on the remaining ERO positions in the OSC and without increasing the risk to public health and safety.

Response

The intent of the statement on Page 20 (Page 22 sic) of Reference 1 was to indicate those OSC positions that were being eliminated in their entirety, rather than to describe a reduction in number. The statement on Page 19 of Reference 1 has been be clarified.

The revisions to Reference 1 are included in Attachment 2 of this response. The revision appears on Page 17 of Attachment 2 of this response.

The reduction in the number of Radiation Protection Technicians was previously addressed in the responses to RAI-FCS-1.

c. Page 29 of Attachment 1 provides an evaluation for the elimination of the on-shift Chemistry Technician and the on-shift Habitability Technician. However, there is no evaluation for, nor identification of, the proposed change to the current staffing requirement for the four RP Technicians augmenting within 60 minutes under the Major Task area of Offsite Dose Assessment; Onsite and In-plant surveys; Offsite surveys; Chemistry/Radiochemistry.

Response

The evaluation of the proposed change to the current staffing requirement for the four Radiation Protection Technicians augmenting within 60 minutes under the Major Task area of Offsite Dose Assessment; Onsite and In-plant surveys; Offsite surveys; Chemistry/Radiochemistry is addressed in the response to RAI-FCS-1.a, above.

Section 4.2.5 of Reference 1 has been revised to address the proposed change to the current staffing requirement for the four Radiation Protection Technicians augmenting within 60 minutes as described in the responses to RAI-FCS-1. The revisions to Reference 1 are included in Attachment 2 of this response. The revisions appear on Pages 28 and 29 of Attachment 2 of this response.

LIC-17-0020 Page 8

d. Section 4.2.7, Major Tasks: Protective Actions (Plant), on page 31 of Attachment 1, includes the following sentence that appears to be out of place,

[t]he fire brigade will continue to perform the tasks of search and rescue, first aid, and firefighting in the permanently shut down and defueled condition. It appears to be more appropriate information to be included in Section 4.2.8.1, Major Tasks: Combat Fires.

Response

The intent of the sentence in question was to indicate that personnel performing the tasks of search and rescue, first aid, and firefighting maintain the requisite training and knowledge to perform the tasks. However, the sentence can be moved to Section 4.2.8.1 without impacting the analysis. The revisions to Reference 1 are included in Attachment 2 of this response. The revisions appear on Pages 30, 31 and 32 of Attachment 2 of this response.

e. In Section 4.2.7.1, Major Tasks: Radiation Protection Access Control, on page 31 of Attachment 1, the evaluation does not include a Current Staffing Requirement nor proposed staffing, as was done for the other Major Tasks in Attachment 1.

Additionally, this section does not provide any conclusion for this Major Task that supports the proposed changes to the FCS RERP.

Response

The format of Section 4.2.7 has been revised for consistency with the other Major Tasks in Attachment 1 of Reference 1 to include Current Staffing Requirements and proposed staffing and Section 4.2.7.1 has been revised to provide a conclusion. The revisions to Reference 1 are included in Attachment 2 of this response. The revision appears on Page 31 of Attachment 2 of this response. The analysis of the proposed staffing changes is subsequently addressed in Sections 4.2.7.1 through 4.2.7.3 of Reference 1.

f. Section 4.2.8.1, Major Tasks: Combat Fires, on page 33 of Attachment 1, includes the following sentence that appears to be out of place, [t]he analysis of proposed post-shutdown on-shift staffing concluded that during an event requiring a Control Room evacuation in a permanently defueled condition, the Shift Manager and CRO (or NCO) can perform all required FCS RERP actions in a timely manner. There are no collateral duties that would prevent the timely performance of emergency plan functions. It appears to be more appropriate information to be included in Section 4.3, Conclusion.

Response

The sentences in question have been moved to Section 4.3. The revisions to Reference 1 are included in Attachment 2 of this response. The revisions appear on Pages 32 and 33 of Attachment 2 of this response.

LIC-17-0020 Page 9

g. Attachment 2, page 20, states, [t]he oncall technician positions will not exist in the postshutdown ERO. Technicians will be called in on an as needed basis.

This appears to contradict Table B-1 (in Attachment 3, page 26 - clean copy of OPPD Nuclear Post-Shutdown RERP for FCS), where the Electrical Maintenance Technician is referenced as a 60 minute augmenting responder.

Response

Attachment 3 of Reference 1 accurately states that FCS will maintain one Electrical Maintenance Technician as a 60-minute augmenting responder. Attachment 2 of Reference 1 has been revised accordingly. The revisions to Reference 1 are included in Attachment 3 of this response.

h. Attachment 2, page 21, states, [t]he augmenting Radiation Protection Technician positions will be reduced from five to three in the postshutdown ERO. This appears to contradict Table B-1, OPPD Emergency Response Organization (ERO)

Functions and Shift Staff Augmentation Plan (in Attachment 3, Proposed Revision to the FCS RERP, on page 30 of 170), which provides two RP Technicians augmenting in 60 minutes.

Response

The statement in question refers to a proposed change to Section 4.8.2.G of Section B of the current FCS RERP which details the duties of the augmenting Radiation Protection Technicians (currently 5 positions) in the OSC. These positions are in addition to the one Radiation Protection Technician identified in Section 4.7.1 of Section B of the current FCS RERP as necessary minimum staffing, for a total of six Radiation Protection Technicians augmenting within 60 minutes.

As previously detailed in the responses to RAI-FCS-1, FCS is proposing the elimination of four Radiation Protection Technicians currently listed in Attachment 1 - Table B.1 of Section B of the FCS RERP, resulting in two Radiation Protection Technicians augmenting in 60 minutes. One of these augmenting Radiation Protection Technicians is the position needed to satisfy the OSC minimum staffing requirements in Section 4.7.1 of Section B of the FCS RERP. The second is the Radiation Protection Technician addressed in Section 4.8.2.G of Section B of the current FCS RERP. Page 21 of Attachment 2 of Reference 1 and the proposed revision to Section 4.8.2.G of Section B of the current FCS RERP have been revised for consistency with the proposed augmenting positions listed in Attachment 1 - Table B.1 of Section B of the FCS RERP.

Attachment 2 of Reference 1 has been revised accordingly. The revisions to Reference 1 are included in Attachment 3 of this response.

LIC-17-0020 Page 10

i. Attachment 4, Analysis of Proposed Post-Shutdown On-Shift Staffing, page 20, states, [a]dditional plant personnel, including Operations, Chemistry, and RP Technician, would be on-site during fuel assembly movement. The presence of additional plant personnel would free the on-shift RP Technician to perform dose assessment. This is not consistent with the assumptions made for the on-shift staffing analysis in recent precedence for a radiological release escalating to a General Emergency classification and requiring consideration of offsite protective actions by State and local officials, where credit was not given for the additional personnel supporting initial response actions. (Refer to: ADAMS Accession No. ML14085A257, Proposed Changes to the. Vermont Yankee Emergency Plan Vermont Yankee Nuclear Power Station and ADAMS Accession No. ML16043A424, License Amendment Request to Revise the James A. FitzPatrick Emergency Plan to Address the Permanently Defueled Condition).

Response

As stated in Section 4.2.1.2 of Reference 1, the primary events of concern in the immediate post-shutdown and defueled condition will be a Fuel Handling Accident (FHA) and a loss of SFP cooling and/or water inventory. During fuel handling activities there will be extra personnel on site that will, were a FHA to occur, be able to respond to the event. Based on this assumption, the dose assessment responsibilities in Accident Analysis number 2 (Fuel Handling Accident with General Emergency and PAR) in Attachment 4 of Reference 1 were assigned to the On-Shift Radiation Protection Technician. The analysis also states that the tasks will be performed as directed by the Shift Manager.

The table in Section II.A of Attachment 4 of Reference 1 also indicates that the Equipment Operator/Non-Certified Operator (NCO) can perform the function of dose assessment and Footnote 2 to the table indicates that the NCO can be assigned dose assessment responsibilities in the FHA analyses, including Analyses number 2, as directed by the Shift Manager. FCS has implemented the NCO Training Program that includes the ability to perform dose assessment activities.

LIC-17-0020 Page 1 ATTACHMENT 2 LICENSE AMENDMENT REQUEST 16-02 ATTACHMENT 1 Revision 1 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION. UNIT NO. 1 DOCKET NO. 50-285

LIC-16-0076 Revision 1 Page 1 License Amendment Request 16-02: Revise the Fort Calhoun Station Emergency Plan to Address the Permanently Defueled Condition DESCRIPTION AND EVALUATION OF PROPOSED CHANGES 1.0

SUMMARY

DESCRIPTION

2.0 BACKGROUND

3.0 DETAILED DESCRIPTION

4.0 TECHNICAL EVALUATION

4.1 Accident Analysis 4.2 Analysis of Proposed Changes 4.3 Conclusion

5.0 REGULATORY EVALUATION

5.1 Applicable Regulatory Requirements/Criteria 5.2 Precedent 5.3 No Significant Hazards Consideration 5.4 Conclusion

7.0 REFERENCES

LIC-16-0076 Revision 1 Page 2 1.0

SUMMARY

DESCRIPTION This evaluation supports a request to amend the Renewed Facility Operating License (OL) DPR-40 for the Fort Calhoun Station (FCS).

The proposed changes would revise the OPPD Nuclear Radiological Emergency Response Plan for Fort Calhoun Station (FCS RERP), on-shift staffing, and Emergency Response Organization (ERO) staffing to support the planned permanent cessation of power operations and permanent defueling of the FCS reactor (Reference 1).

An analysis of proposed post-shutdown on-shift staffing was performed to provide the basis for the proposed changes to the on-shift staffing. On-shift staffing at FCS currently consists of:

1 Shift Manager (Senior Reactor Operator (SRO))

1 Unit Supervisor (SRO) 1 Shift Technical Advisor (STA) 2 Reactor Operators (RO) 2 Equipment Operators 1 Control Room Communicator 1 Radiation Protection Technician 1 Chemistry Technician 1 Habitability Technician The Fire Brigade currently consists of a minimum of five (5) responders, including a Fire Brigade Leader and a minimum of four (4) trained and qualified Fire Brigade Members.

The analysis of proposed post-shutdown on-shift staffing demonstrated that an on-shift complement of four (4) personnel along with the Fire Brigade is able to cope with the spectrum of analyzed events in the permanently defueled condition because the consequences of credible events will be reduced when compared to the events that can occur with an operating reactor.

The credited post-shutdown on-shift complement will consist of:

1 Shift Manager (SRO/Certified Fuel Handler (CFH))

1 Control Room Operator (SRO or RO/CFH) 1 Equipment Operator/Non-Certified Operator (NCO) 1 Radiation Protection Technician The number of on-shift and ERO staff at FCS following permanent cessation of power operations and defueling will be reduced from current normal operating levels, but are commensurate with the need to safely store spent fuel at the facility in a manner that is protective of public health and safety. The Fire Brigade complement will continue to consist of a minimum of five (5) responders, including a Fire Brigade Leader and a minimum of four (4) trained and qualified Fire Brigade Members in compliance with National Fire Protection Association (NFPA) 805 implementation at FCS.

OPPD has reviewed the proposed changes against the planning standards in 10 CFR 50.47(b) and the requirements in 10 CFR Part 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, and has concluded that the standards and requirements will continue to be met. Therefore, no exemption from 10 CFR 50.47 or 10 CFR 50, Appendix E is requested.

LIC-16-0076 Revision 1 Page 3

2.0 BACKGROUND

The proposed changes are intended to reflect the pending permanent cessation of power operations and permanent defueling of the FCS reactor, which will occur no later than December 31, 2016 (Reference 1). After the reactor is shut down, all fuel assemblies will be removed from the reactor vessel and placed in the spent fuel pool (SFP). The irradiated fuel will be stored in the SFP and in the Independent Spent Fuel Storage Installation (ISFSI) until it is removed by the Department of Energy (DOE). 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 will no longer authorize power operations of the reactor or emplacement or retention of fuel into the reactor vessel.

The proposed revisions to the FCS RERP are commensurate with the reduction in hazards associated with the permanently defueled condition and will allow FCS to transition from a staffing level necessary for an operating facility to that necessary for a permanently shut down and defueled facility. The proposed changes are necessary to properly reflect the conditions of the facility while continuing to preserve the FCS Decommissioning Trust Fund and the effectiveness of the FCS RERP.

On-Shift Staffing The on-site emergency response plan regulations in 10 CFR 50.47(b)(2) state, in part, that on-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, [and] timely augmentation of response capabilities is available.

NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, (Reference 2),Section II.B, Onsite Emergency Organization, presents guidance for meeting the planning standards and requirements of 10 CFR 50.47(b) and 10 CFR 50, Appendix E, Section IV.A. The guidance describes the onsite emergency organization, including the staffing requirements found in Table B-1, Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies.

This table specifies a minimum of ten on-shift responders in four Major Functional Areas. It also specifies seven on-shift response functions where the duties may be performed by shift personnel who are assigned other functions (i.e., there are no dedicated responders to perform these functions). Table B-1 specifies two Major Functional Areas (i.e., firefighting and site access control/personnel accountability) which must be staffed on a site-specific basis.

The on-shift staff must be able to cope with a spectrum of events until augmenting ERO personnel arrive in accordance with the sites emergency plan commitments. The augmenting ERO responders assume managerial, engineering, and administrative duties from the on-shift personnel, allowing on-shift personnel to focus on their assigned functions.

On November 23, 2011, the NRC published a final rule in the Federal Register amending certain emergency preparedness (EP) requirements in its regulations that govern domestic licensing of production and utilization facilities (Reference 3). This final rule amended 10 CFR Part 50, Appendix E, Section IV.A, Organization, to address the assignment of tasks or responsibilities to on-shift ERO personnel that could potentially overburden them and prevent the timely performance of their emergency plan functions. Specifically,Section IV.A.9 states that licensees shall perform a detailed analysis demonstrating that on-shift personnel assigned emergency plan

LIC-16-0076 Revision 1 Page 4 implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan.

Coincident with the rule change in 10 CFR Part 50, Appendix E, Section IV.A.9, the NRC issued NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants (ISG-01) (Reference 4). This Interim Staff Guidance (ISG) provides information relevant to performing the on-shift staffing analysis. The ISG states that the NEI developed NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, (Reference 5) to establish a standard methodology for a licensee to perform the required staffing analysis, and that the NRC reviewed NEI 10-05 and found it to be an acceptable methodology for this purpose. The ISG also indicates that the completed staffing analyses are required to be part of the emergency plan and the results documented and submitted to the NRC in accordance with 10 CFR 50.54(q)(5).

In October 2014, an On-Shift Staffing Analysis was performed in accordance with the NEI 10-05 guidance to satisfy the requirements of 10 CFR 50, Appendix E Section IV.A.9. This analysis examined the capability of the minimum staff listed in Section B, Attachment 1, Table B-1 of the FCS RERP to perform the key emergency response actions for events described in ISG-01 until augmenting ERO staff arrive. The analysis was conducted by a cross disciplinary team of personnel and station personnel from the Operations, Training, Radiation Protection, Chemistry, Licensing, and Emergency Preparedness departments. Additionally, members of the Security staff provided input to the analysis.

Each scenario was reviewed to determine what plant actions and emergency plan implementation actions were required based on plant procedures prior to staff augmentation. These actions were then compared to the minimum staffing for emergency response implementation as described in Section B, Attachment 1, Table B-1, ensuring that no actions were assigned to staff members that conflicted with either their dedicated emergency response role or their dedicated operational role, as appropriate. In cases where multiple tasks were assigned to an individual, the team evaluated the timing of the tasks to ensure that they could be performed by the individual in series within any specified time requirements. The accident scenarios considered in the analysis were the main steam line break (MSLB) accident, steam generator tube rupture (SGTR) accident, loss of coolant accident (LOCA), fuel handling accident (FHA) in the SFP, gas decay tank rupture, design basis threat, aircraft probable threat, Control Room fire leading to evacuation and remote shutdown, and station blackout.

The analysis concluded that an on-shift staff of eleven (11) is required to respond to the most limiting accident scenario reviewed.

FCS RERP Section B, Attachment 1, Table B-1 specifies the minimum staffing requirements for the FCS on-shift staff, defines the positions initially responsible for satisfying key ERO functions, and specifies positions that will augment the on-shift staff.

Emergency Response Organization Staffing The FCS RERP defines four classes of emergency events: Notification of Unusual Event (NOUE),

Alert, Site Area Emergency (SAE) and General Emergency (GE). Because on-shift personnel can normally address an emergency response to NOUEs without additional support, staff augmentation may not be activated for an NOUE declaration. The Operations Shift Manager maintains responsibility during NOUEs, unless the Emergency Operations Facility (EOF) has been activated. An Alert declaration results in the activation of the EOF, Technical Support Center (TSC), and Operations Support Center (OSC). The Joint Information Center (JIC) is activated following a SAE and GE classification, and can be activated at an earlier classification based on

LIC-16-0076 Revision 1 Page 5 the decisions of the Corporate Communications Division. Overall responsibility for the event is assumed by the Emergency Director (ED) in the EOF when the EOF is declared operational.

When the ERO is activated, notification is sent to those required to respond to their assigned Emergency Response Facility (ERF).

FCS RERP Section A.2, OPPD Concept of Emergency Operations, describes how the normal plant operating organization transitions into an ERO to effectively deal with any incident at FCS.

The FCS Onsite Emergency Organization is described in Section B, Organizational Control of Emergencies, and is depicted in Section B, Attachment 2, Figure B-2 of the FCS RERP. If initiating conditions exist that result in the declaration of an emergency, responsibility for emergency response initially lies with the Shift Manager. Currently, the Shift Manager may be relieved of the task of implementing the FCS RERP by the Control Room Coordinator.

The current Control Room Coordinator position is intended to provide a prompt transition of Command and Control functions from the Shift Manager within the Control Room complex. If the TSC is activated, command and control may be transferred to the Site Director. The Emergency Director in the EOF may assume command and control if that facility is activated. The command and control position is responsible for ensuring the continuity of resources throughout an event.

The normal operating organization will also assume their pre-assigned emergency response roles.

This is considered to be a short-term response organization that will be augmented within approximately one hour after call-out by additional plant personnel.

If an Alert, SAE, or GE is declared, or if the minimum shift crew requires assistance during an NOUE, the onsite emergency organization will be augmented by additional plant personnel as described in Section B of the FCS RERP, Organizational Control of Emergencies and shown in Section B, Attachment 1, Table B-1 and Section B, Attachment 2 Figure B-2. The FCS RERP describes the augmented emergency organization that will staff and operate the EOF, TSC, OSC, and JIC as needed within approximately one hour of the request for activation.

Plans and procedures have been put into place to ensure the timely activation of ERFs. FCS RERP Section B, Attachment 2, Figure B-3 identifies the interrelationships among the various emergency organizations.

3.0 DETAILED DESCRIPTION The proposed changes would revise the FCS RERP to reflect the permanently shut down and defueled condition. Specifically, the proposed changes would eliminate the on-shift positions not needed for the safe storage of spent fuel in the SFP during the initial decommissioning period and eliminate the ERO positions not necessary to effectively respond to credible accidents. of this submittal provides a tabular summary of the proposed changes to the FCS RERP. Attachment 3 of this submittal provides the revised pages of the FCS RERP with the proposed changes shown in strikethrough and underline format. The changes shown in Attachments 2 and 3 include additional changes beyond those involving a reduction in on-shift and ERO staffing. NRC approval of these additional changes is not being requested. These additional changes are included for clarification purposes.

Additional changes, not requiring prior NRC approval, will be made to the FCS RERP and will be dispositioned prior to implementation in accordance with the requirements in 10 CFR 50.54(q),

Conditions of Licenses, related to emergency preparedness, and specifically to making changes to emergency response plans.

LIC-16-0076 Revision 1 Page 6 On-Shift Staffing Currently, FCS RERP Section B, Attachment 1, Table B-1, OPPD Emergency Response Organization (ERO) Functions and Shift Staff Augmentation Plan, specifies the on-shift and augmented staffing for certain positions in the following Major Functional Areas:

Plant Operations and Assessment of Operational Aspects Emergency Command and Control (Emergency Coordinator)

Notification/Communication Radiological Accident Assessment and Support of Operational Accident Assessment Plant Systems Engineering, Repair and Corrective Actions Protective Actions (Plant)

Firefighting Rescue Operations and First Aid Site Access Control and Personnel Accountability The proposed changes to the FCS RERP will eliminate the following on-shift positions currently identified in Section 4.1.1 of the FCS RERP:

2 Reactor Operators 1 Equipment Operator 1 Control Room Communicator 1 Chemistry Technician 1 Habitability Technician 1 STA The post-shutdown on-shift complement will consist of:

1 Shift Manager (SRO/CFH) 1 Control Room Operator (SRO or RO/CFH) 1 Equipment Operator/NCO 1 Radiation Protection Technician Title changes for Licensed personnel and Equipment Operators to CFHs and NCOs, respectively, are dependent upon NRC approval of proposed changes to the FCS Technical Specifications that revise the minimum shift staffing requirements in the FCS Technical Specifications by replacing references to licensed and non-licensed operators with references to CFHs and NCOs.

Implementation of the FCS RERP, as proposed for revision in this submittal, is not dependent on prior NRC approval of the proposed changes to the FCS Technical Specifications.

These staffing levels have been evaluated in the FCS analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition. The analysis is provided in Attachment 4 of this submittal.

The term NCO is used to differentiate from CFH. CFHs will supervise fuel handling operations in the permanently defueled condition. Both Control Room Operators (CROs) and Shift Managers will be qualified as CFHs. However, the Shift Manager requires additional qualification beyond the CFH training. Therefore, any reference to the CFH position throughout this submittal is considered to be equivalent to the CRO position. NCOs will perform duties typically associated with those performed by Equipment Operators, such as manipulation and monitoring of plant equipment.

LIC-16-0076 Revision 1 Page 7 Reference 6 submitted a CFH training program for NRC approval. Senior Reactor Operators and Reactor Operators will not be utilized in the permanently defueled condition.

The NCO training program will be developed in accordance with 10 CFR 50.120. The Equipment Operator/NCO position will combine the post-shutdown duties of the licensed Reactor Operator and the non-licensed Equipment Operator. The specific training requirements of the Equipment Operator/NCO position will be drafted by the FCS Training Department and will be reviewed and approved by Operations Management. The training requirements will include classroom training in theory and systems topics, administrative procedures, off-normal and transient procedures/mitigation strategies, and refuel platform operations. The training program will be designed with an emphasis on dose assessment, systems/processes important to maintaining SFP cooling and monitoring and controlling SFP parameters, such as SFP water level and temperature.

Consequently, the Equipment Operators/NCOs will be trained on pertinent Control Room indications and controls that will be monitored and operated to maintain SFP cooling and SFP water level, in addition to plant radiological conditions. The NCO training program will also include training on applicable aspects of the FCS RERP-related NCO duties.

Personnel assigned to fill the NCO positions during the post-shutdown period, prior to implementation of the Permanently Defueled Emergency Plan (PDEP), will include both previously licensed and non-licensed operators. The majority of the required training for the NCO position will already have been completed by the licensed operators because they have previously been trained and qualified as Reactor Operators to support power operations. The current Equipment Operators have been trained and qualified as non-licensed operators only. Therefore, it is expected they will require additional training related to Control Room operations.

Once the specific training requirements for the NCO position have been identified using a systematic approach to training, as required by 10 CFR 50.120, a formal gap analysis will be completed for all operators identified to fill the NCO position. Individualized training plans will be developed and completed to address specific knowledge and skill areas for the selected NCO candidates. This will include training the currently qualified Equipment Operators on Control Room indications, controls, procedures, and Emergency Plan requirements. The initial training for any new NCOs will include all training requirements for the NCO position to ensure the personnel are equipped with the required skills and knowledge to perform their required job functions.

The proposed changes to the on-shift organization are identified in the FCS Post Shutdown RERP Section B, Attachment 1, Table B-1, OPPD Emergency Response Organization (ERO) Functions and Shift Staff Augmentation Plan, and Section B, Attachment 2, Figure B-2, Fort Calhoun Station Emergency Response Organization, Attachment 3.

Emergency Response Organization Staffing The proposed changes to the FCS RERP will eliminate ERO positions currently identified in Part 4 of Section B of the FCS RERP and Emergency Plan Implementing Procedures (EPIPs) for the augmentation of the Control Room staff and the activation and operation of the TSC, EOF, OSC, and JIC. Several of these positions are described in FCS EPIPs as positions required to meet the augmentation requirements of the emergency plan and positions needed to declare the ERFs operational. The proposed changes to the FCS RERP will also eliminate non-minimum (i.e., not required for augmentation or facility activation) ERO positions currently identified in EPIPs as support personnel. Specific ERO positions identified for elimination are listed in Table 1 of this attachment. Table 1 also identifies whether each position is currently required to meet the augmentation requirements of the FCS RERP.

LIC-16-0076 Revision 1 Page 8 Currently, FCS RERP Section B, Attachment 1, Table B-1 specifies the on-shift and augmented staffing for certain positions in the Major Functional Areas identified above. The proposed changes to the FCS RERP will eliminate the following augmenting positions identified in Table B-1:

Control Room Coordinator Control Room ENS Communicator Communicator in TSC Four (4) Radiation Protection (RP) Technicians Electrical and I&C Engineer Primary Systems Engineer Radiation Protection Coordinator Dosimetry Technician The proposed changes to the FCS RERP will also eliminate the following minimum staffing ERO positions for activation of ERFs currently identified in Parts 4.3.3, 4.3.4, and 4.3.5 of Section B of the FCS RERP:

OSC Radiation Protection Coordinator (Table B-1 position identified above as Radiation Protection Coordinator)

TSC COP Communicator (Table B-1 position identified above as Communicator in TSC)

EOF Dose Assessment Coordinator After permanent cessation of power operations and certification of permanent removal of fuel from the reactor vessel, in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license will no longer authorize reactor operation or emplacement or retention of fuel in the reactor vessel. As a result, the title of the Reactor Safety Coordinator position identified in Part 4.3.4 and Attachment 1, Table B-1 of Section B of the FCS RERP is not descriptive of the functions performed by the position. The current Reactor Safety Coordinator position will be retitled to the Engineering Coordinator. The Engineering Coordinator position will be tasked with performing an engineering assessment of plant conditions and/or actions needed to mitigate damage to the plant.

4.0 TECHNICAL EVALUATION

4.1 Accident Analysis Chapter 14 of the FCS Final Safety Analysis Report as Updated (USAR) describes the Abnormal Operational Transients and Design Basis Accident (DBA) scenarios that are applicable during plant operations. Fire events are addressed throughout the USAR. Upon docketing of the certifications required by 10 CFR 50.82(a)(1)(i) and (ii), the 10 CFR Part 50 license for FCS will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel, as specified in 10 CFR 50.82(a)(2). Therefore, most of the accident scenarios postulated in the USAR will no longer be applicable once FCS is in the permanently defueled condition.

One of the Chapter 14 accidents that will remain applicable to FCS in its permanently shut down and defueled condition is the FHA in the SFP. USAR Chapter 14 will be revised to eliminate the DBAs that will not be applicable in the permanently defueled condition.

The Station Blackout (SBO) event was not considered in the analysis of proposed post-shutdown on-shift staffing. Once the certifications required by 10 CFR 50.82(a)(1)(i) and (ii) are docketed,

LIC-16-0076 Revision 1 Page 9 FCS will no longer be licensed to operate, therefore the provisions of 10 CFR 50.63 (Loss of all alternating current power) will no longer be applicable pursuant to 10 CFR 50.63(a)(1).

A comparison of the accident scenarios included in the current On-Shift Staffing Analysis (EP-FC-1001, Addendum 1) (Reference 7) and the analysis of proposed post-shutdown on-shift staffing is provided in the following section.

A specific analysis was conducted to determine if sufficient on-shift staffing would be available to implement emergency response actions in response to potential aircraft impacts in reflected in 10 CFR 50.54(hh)(1). In the permanently shut down and defueled condition, the Fire Brigade will relocate and prepare for reentry. The task of maintaining communications during this event are transferred to an Equipment Operator/NCO trained and qualified to perform this function.

Therefore, sufficient staffing is available to promptly implement response actions required under 10 CFR 50.54(hh)(1) without impacting the performance of designated emergency plan functions.

A specific analysis to determine if sufficient on-shift staffing would be available to promptly implement SFP inventory makeup strategies was not necessary. The FCS 5-person Fire Brigade is currently responsible for implementing the SFP inventory makeup strategies required under 10 CFR 50.54(hh)(2). In the permanently shut down and defueled condition, FCS will continue to maintain a trained and qualified 5-person Fire Brigade responsible for implementation of the SFP inventory makeup strategies. The Fire Brigade personnel responsibilities identified in the post-shutdown RERP are separate and distinct from those for implementing the major elements of the emergency plan including emergency classification (Shift Manager), offsite notifications (Control Room Operator (or NCO during events requiring Fire Brigade response), and dose assessment/protective action recommendation development (Radiation Protection Specialist or NCO). Therefore, sufficient staffing is available to promptly implement SFP inventory makeup strategies required under 10 CFR 50.54(hh)(2) without impacting the performance of designated emergency plan functions.

As described in Section 4.2.1.2, events involving a loss of SFP cooling and/or water inventory can be addressed by implementation of SFP inventory makeup strategies required under 10 CFR 50.54(hh)(2). These strategies will continue to be maintained to satisfy applicable portions of Condition G of the FCS Renewed Facility Operating License.

4.2 Analysis of Proposed Changes 4.2.1 ERO Staffing Prior to an emergency declaration, the normal plant operating organization is in place. The initial classification of an off-normal event occurs in the Control Room. Classification and declaration are performed by the Shift Manager. Upon the classification and declaration of an emergency, the Shift Manager assumes the Command and Control role and retains that role until another designated Command and Control position (currently, the Control Room Coordinator, Site Director in the TSC, or Emergency Director in the EOF) can assume control. The onsite emergency organization is activated by personnel notification or when the station alarm is sounded and the emergency is announced over the public address system. Initially, the ERO consists of the normal operating shift personnel who function as the emergency team members. The normal operating staff is augmented, as needed, by plant personnel. Those personnel onsite respond when the station alarm is sounded and the announcement is made or when individuals are notified by another means. Personnel not onsite during off-hours operations will be notified via an ERO notification system. A designated on-shift plant employee shall perform notifications. The details

LIC-16-0076 Revision 1 Page 10 of notifying all emergency operations personnel during normal and off-hours are contained in EPIPs.

In the permanently defueled condition, FCS will maintain ERO teams, with one team being on duty and on-call at any given time. When the Shift Manager directs the activation of the ERO call out system, all ERO members are notified to ensure adequate coverage of all ERO positions at all ERFs. ERO members not on-call are expected to respond unless they are unavailable.

FCS requires ERO personnel to act promptly in reporting to their assigned ERF even when not on duty. During duty periods, procedures further require that team members respond within the required response time for their ERF and that they remain fit for duty throughout the duty assignment. Individuals are trained to respond to their ERF even if they are not on duty. Excess personnel that respond may be assigned support responsibilities or be designated as a relief shift.

This conservative policy ensures timely activation because some off duty personnel may respond sooner than the on duty personnel.

The proposed revisions to the FCS RERP will not change the requirements described above.

OPPD managements continued expectation is that all duty and support ERO members report to their respective ERF as quickly as possible.

FCS currently has designated ERO members who staff positions that augment the Control Room staff. These Control Room augmenting positions are described in Section 4.5.2 of Part B of the FCS RERP. With the exception of the Control Room Operations Liaison position, the Control Room augmenting positions will not exist in the post-shutdown ERO because the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The set of plant equipment required in the permanently defueled condition is also greatly reduced, which reduces the assessment and mitigation activities the Control Room must perform prior to the TSC and EOF being declared operational.

The retention of the tasks necessary to implement the RERP by the on-shift Control Room staff prior to ERO augmentation, including the ability of the Shift Manager to maintain Command and Control responsibilities, has been evaluated in the FCS analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.

FCS has designated ERO members who staff positions required to meet minimum staffing to activate the TSC, OSC, EOF, and JIC. EPIPs identify ERO positions assigned to each facility and the minimum staffing required before each facility can be declared operational. All ERO personnel are expected to respond when notified by the ERO notification system.

Current ERO positions are identified, and the associated duties are captured, in the ERO Task Analysis provided in Attachment 5. The duties of the ERO positions were reviewed against OPPD procedures and the FCS RERP. Each of the eliminated positions was analyzed to identify the key duties associated with the position and the duties were then evaluated against the planning standards in NUREG-0654.

The Table provided in Attachment 5 contains columns with headings "Implementing Actions" and "Task Assigned To?". These columns provide the details for disposition of each task. Procedures and training materials depicting the changes presented in Attachment 5 will be developed. Some of the tasks are identified as being eliminated because they become unnecessary following permanent cessation of power operations and permanent removal of fuel from the reactor vessel.

LIC-16-0076 Revision 1 Page 11 Other tasks are identified as eliminated because the tasks are performed by other positions in the ERO and will continue to be performed by these positions in the post-shutdown ERO.

The proposed changes to the FCS RERP, including the changes made to develop the post-shutdown ERO, have been evaluated for impacts on the ERO and for the ability of offsite response organizations to implement their Federal Emergency Management Agency (FEMA) approved Radiological Emergency Preparedness (REP) Plans. Potential impacts on the ability of the State and local response organizations to effectively implement their FEMA-approved REP Plans do not exist because no tasks that require interfacing with State and local response organizations are proposed for elimination. FCS has appropriately addressed elimination of ERO positions that interface with offsite representatives by transferring the necessary tasks to remaining post-shutdown ERO positions. In addition, the FCS ERO will continue to include technical support staff that have dedicated responsibilities for interfacing with State and local representatives.

To validate the results of the analysis, one or more drills will be developed and conducted prior to implementation of the changes described within this LAR. The drills will be conducted to confirm the ability of the post-shutdown ERO to perform the necessary functions of each ERF. The drills will be used to train and qualify post-shutdown ERO members, evaluate and validate the ability to accomplish the stated mission of each ERF, and ensure that the planning standard functions are preserved with no degradation in time sensitive activities or in the ability to communicate with offsite response organizations. The drills will also validate that the post-shutdown ERO continues to address the risks to public health and safety and comply with the FCS RERP, site commitments, and applicable regulations. Implementing procedures will be revised to address the permanently shut down and defueled conditions. The revised procedures will be used to support training of ERO staff and the conduct of drills described above.

Training and procedures will be developed and in place prior to performing post-shutdown ERO drills. The drill scenarios will include SFP events and will be designed to test the major elements of the FCS post shutdown RERP. Major elements to be tested will include communications and coordination with offsite response organizations, including the JIC. State, Local, and Federal response organizations will be provided the opportunity to participate in or observe the drills. New regulatory commitments for scenario elements and communication with offsite agencies are included in Attachment 6.

FCS has not yet finalized a schedule of drills that will be conducted. FCS will provide the schedule to the NRC and FEMA with appropriate advanced notice, thereby providing the NRC and FEMA an opportunity to observe each drill. A new regulatory commitment to provide the schedule to the NRC is included in Attachment 6.

LIC-16-0076 Attachment 1 Revision 1 Page 12 Table 1 - Emergency Response Organization Positions Current FCS Proposed Positions in the RERP Procedure(s) Current Positions Post-Shutdown Emergency Augmentation Plan1 Requirements Technical Support Center EP-FC-112-200 Site Director Site Director Yes EP-FC-112-200 TSC COP Communicator -- Yes EP-FC-112-200 TSC Protective Measures TSC Protective Measures Yes Coordinator Coordinator EP-FC-112-200 TSC Reactor Safety Coordinator TSC Engineering Coordinator Yes EP-FC-112-200 TSC Elec/I&C Engineer -- No EP-FC-112-200 TSC Primary Systems Engineer -- No EP-FC-112-200 TSC Field Team Technicians TSC Field Team Technicians No EP-FC-112-200 TSC Ops Liaison TSC Ops Liaison No EP-FC-112-200 Admin Logistics Coordinator Admin Logistics Coordinator No EP-FC-112-200 TSC Director -- No EP-FC-112-200 Reactor Engineer -- No EP-FC-112-200 TSC Secondary Systems -- No Engineer EP-FC-112-200 Security Coordinator Security Coordinator No EP-FC-112-200 TSC CHP Communicator -- No EP-FC-112-200 Admin Assistant -- No EP-FC-112-200 Site Director Secretary -- No EP-FC-112-200 TSC Status Board Keeper -- No Operations Support Center EP-FC-112-300 OSC Director OSC Director Yes EP-FC-112-300 RP Coordinator -- Yes or RP Tech EP-FC-112-300 Technicians (Electrical, I&C, Technicians (Electrical, I&C, Yes Mechanical Maintenance, RP/HP, Mechanical Maintenance, Chemistry) RP/HP, Chemistry)

EP-FC-112-300 Dosimetry Technician -- No EP-FC-112-300 Operations Liaison -- No EP-FC-112-300 Chemistry Coordinator -- No EP-FC-112-300 ERMS Operator -- No Operations Support Center (cont.)

EP-FC-112-300 Maintenance Coordinator -- No EP-FC-112-300 Maintenance Planner -- No EP-FC-112-300 Medical Response Coordinator -- No

LIC-16-0076 Attachment 1 Revision 1 Page 13 Current FCS Proposed Positions in the RERP Procedure(s) Current Positions Post-Shutdown Emergency Augmentation Plan1 Requirements EP-FC-112-300 Radio Operator -- No EP-FC-112-300 Store Keeper -- No EP-FC-112-300 Accountability Clerk -- No Emergency Operations Facility EP-FC-112-400 Emergency Director Emergency Director Yes EP-FC-112-400 EOF COP Communicator EOF COP Communicator Yes EP-FC-112-400 EOF Protective Measures Manager EOF Protective Measures Yes or DAC Manager EP-FC-112-400 EOF Dose Assessment Specialist EOF Dose Assessment Yes Specialist EP-FC-112-400 EOF Dose Assessment -- Yes or PMM Coordinator EP-FC-112-400 EOF Admin Logistics Manager EOF Admin Logistics Manager No EP-FC-112-400 EOF Information Specialist EOF Information Specialist No EP-FC-112-400 EOF Ops Liaison EOF Ops Liaison No EP-FC-112-400 EOF Field team EOF Field Team No EP-FC-112-400 Field Team Specialist Field Team Specialist No EP-FC-112-400 EOF Technical Liaison EOF Technical Liaison Yes EP-FC-112-400 EOF Clerical Assistant -- No EP-FC-112-400 Emergency Director Secretary -- No EP-FC-112-400 Des Moines Site Representative Des Moines Site Representative No EP-FC-112-400 IT Specialist -- No EP-FC-112-400 EOF CHP Communicator -- No EP-FC-112-400 Communications Specialist -- No EP-FC-112-400 Emergency Response Coordinator -- No EP-FC-112-400 EOF Secretary -- No EP-FC-112-400 EOF Dose Assessment Assistant -- No EP-FC-112-400 EOF Status Board Keeper -- No

LIC-16-0076 Attachment 1 Revision 1 Page 14 Current FCS Proposed Positions in the RERP Procedure(s) Current Positions Post-Shutdown Emergency Augmentation Plan1 Requirements Joint Information Center Crisis Company Spokesperson Company Spokesperson Yes Communication Plan Crisis JIC Manager JIC Manager Yes Communication Plan Crisis Executive Liaison -- No Communication Plan Crisis Internal information Liaison -- No Communication (Spokesperson)

Plan Crisis JIC Media Information Specialist JIC Media Information Specialist Yes Communication Plan Crisis JIC Technical Liaison JIC Technical Liaison Yes Communication Plan Crisis Public Inquiry Supervisor -- No Communication Plan Crisis Public Inquiry Specialist (10) Public Inquiry Specialist (5) No Communication Plan Crisis JIC Clerical Supervisor JIC Clerical Supervisor Yes Communication Plan 1-- Indicates the position is proposed for elimination upon implementation of the Post-Shutdown Emergency Plan.

The intent of Table 1 is to compare the current ERO positions against the proposed post-shutdown ERO positions. Table 1 also identifies whether each position is currently required to meet the augmentation requirements of the FCS RERP according to the EPIPs. As an example, the TSC Reactor Engineer is a position that is proposed for elimination in the post-shutdown ERO, because in a permanently shut down and defueled condition, responsibilities associated with a reactor core no longer need to be maintained. Also, Table 1 identifies the TSC COP Communicator as a current minimum staff position. The position is not included as a proposed position in the post-shutdown ERO upon implementation of the changes identified herein. The proposed elimination of the ERO minimum staff positions is described in the following sections.

LIC-16-0076 Revision 1 Page 15 4.2.1.1 Technical Support Center The TSC has been designed to meet the intent of the guidance in NUREG-0696, Functional Criteria for Emergency Response Facilities, and the clarification in NUREG-0737, Supplement 1, Clarification of TMI Action Plan Requirements, as applicable. Following permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the TSC will continue to be located on the north side of the Auxiliary Building. The proposed changes to the FCS RERP do not involve any physical modifications to, or layout/configuration changes in, the TSC.

The current FCS RERP and ERO staffing is intended to address the risks to public health and safety inherent in an operating reactor. The risk in the permanently defueled condition is significantly reduced because many of the potential initiating conditions that would lead to an emergency declaration will no longer be possible.

The spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The set of plant equipment required in the permanently defueled condition is also greatly reduced, which reduces the assessment and mitigation activities the TSC must perform.

Therefore, the TSC COP Communicator, TSC Elec/I&C Engineer, TSC Primary Systems Engineer, TSC Reactor Engineer, TSC Director, TSC Secondary Systems Engineer, Admin Assistant, Site Director Secretary, TSC Status Board Keeper, and TSC CHP Communicator positions can be eliminated without placing an undue burden on the remaining ERO positions in the TSC and without increasing the risk to public health and safety. Attachment 5 contains an analysis of all ERO positions being eliminated and evaluates the transfer of tasks to remaining ERO positions following permanent cessation of power operations. The proposed ERO staffing reductions continue to address the risks to public health and safety, comply with the FCS RERP, site commitments, and applicable regulations.

As previously described, to validate the results of the analysis, one or more drills will be developed and conducted prior to implementation of the changes described within. The drills will be conducted to confirm the ability of the post-shutdown ERO to perform the necessary functions of each ERF. The drills will be used to train and qualify post-shutdown ERO members, evaluate and validate the ability to accomplish the stated mission of each ERF, and ensure that the planning standard functions are preserved with no degradation in time sensitive activities or in the ability to communicate with offsite response organizations. The drills will also validate that the post-shutdown ERO continues to address the risks to public health and safety and comply with the FCS RERP, site commitments, and applicable regulations. Implementing procedures will be revised to address the permanently shut down and defueled conditions. The revised procedures will be used to support training of ERO staff and the conduct of drills described above.

Training and procedures will be developed and in place prior to performing post-shutdown ERO drills. The drill scenarios will include SFP events and be designed to test the major elements of the FCS post shutdown RERP. Major elements to be tested will include communications and coordination with offsite response organizations, including the JIC. State, local, and Federal response organizations will be provided the opportunity to participate in or observe the drills. New regulatory commitments for scenario elements and communication with offsite agencies are included in Attachment 6.

The ERF procedures describing activation and operation of each facility will continue to assign responsibilities to ERO responders for the purposes of removing the responsibilities of coordinating with offsite responders and delivering information to the public from the Control Room staff,

LIC-16-0076 Revision 1 Page 16 thereby allowing operations personnel to perform their assigned functions. ERO duties have been reviewed and duties for those positions proposed for elimination will be transferred appropriately.

The proposed staffing changes eliminate one ERO position in the TSC described in FCS EPIPs as a minimum staff position, the TSC COP Communicator.

TSC COP Communicator The TSC COP Communicator position is described in Section B.4.6.1.D of the FCS RERP and further detailed in EP-FC-112-200-F-05, TSC COP Communicator Checklist. According to Section B.4.6.1.D of the FCS RERP, the TSC COP Communicator performs notifications as directed by the Command and Control position. The EOF COP Communicator has redundant duties. Because both positions have the same response time, the TSC COP Communicator duties can be transferred to the EOF COP Communicator with no loss of efficiency. contains an analysis of all ERO positions being eliminated and evaluates the transfer of tasks to remaining ERO positions following permanent cessation of power operations and permanent removal of fuel from the reactor vessel. The proposed ERO staffing reductions continue to address the risks to public health and safety, comply with the FCS RERP, site commitments, and applicable regulations.

In addition to the TSC COP Communicator, the following TSC positions are proposed for elimination following permanent cessation of power operations:

TSC Reactor Engineer TSC Elec/I&C Engineer TSC Primary Systems Engineer TSC Secondary Systems Engineer TSC Director Admin Assistant Site Director Secretary TSC Status Board Keeper TSC CHP Communicator TSC Reactor Engineer While not a minimum staff position in the TSC, the primary duty of the TSC Reactor Engineer is to perform core damage assessments. In a permanently shut down and defueled condition, responsibilities associated with a reactor core no longer need to be maintained. FCS RERP Section B, Attachment 1, Table B-1 indicates that the TSC Reactor Safety Coordinator (retitled the TSC Engineering Coordinator in the Post-Shutdown RERP) is responsible for the core/thermal hydraulics task. Elimination of the TSC Reactor Engineer position will have no effect on emergency response in a permanently defueled condition because the position is not required to assess the condition of fuel in the SFP during an emergency. The TSC Reactor Engineer position can be eliminated without increasing the risk to public health and safety because the major task of evaluating core/thermal hydraulics is not necessary or possible in a permanently shut down and defueled condition.

TSC Engineers (Elec/I&C, Primary Systems, Secondary Systems)

The primary duties of the TSC Engineer positions include: providing engineering analysis and troubleshooting, evaluating the implementation of Severe Accident Management Guidelines, and assisting in the assessment and development of repair plans. These duties, described in

LIC-16-0076 Revision 1 Page 17 implementing procedures, are either no longer necessary in a permanently shut down and defueled condition or will be performed by other members of the post-shutdown ERO.

The TSC Reactor Safety Coordinator (retitled the TSC Engineering Coordinator in the post-shutdown RERP) is tasked with performing an engineering assessment of plant conditions and/or actions needed to mitigate damage to the plant. FCS EPIPs will continue to direct the Engineering to continuously evaluate the need for engineering resources and coordinate with the EOF Admin Logistics Manager to call in additional engineering assistance, as needed. These individuals may be tasked with activities to be completed at engineering offices external to the TSC, called to report to the TSC, or directed to other facilities as needed.

FCS EPIPs will continue to identify engineering resources as augmented positions with specific training and qualification requirements for assigned personnel in accordance with the site training program. The required training courses and requalification frequencies will be unchanged in the post-shutdown condition. However, these positions will no longer be identified as on-call positions.

The elimination of the TSC Engineer positions is justified because the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The set of plant equipment required in the permanently defueled condition is also greatly reduced, which reduces the assessment and mitigation activities the TSC must perform.

Other Positions The elimination of the TSC Director, Admin Assistant, Site Director Secretary, TSC Status Board Keeper, and TSC CHP Communicator positions does not impact the capabilities of the on-shift staffing or augmented response. The TSC will continue to be activated at an Alert or higher declaration. Functional responsibilities of the positions eliminated as a result of the changes will be reassigned to remaining positions as illustrated in Attachment 5. The proposed ERO staffing reductions continue to address the risks to public health and safety, comply with the FCS RERP, site commitments, and applicable regulations.

4.2.1.2 Operations Support Center The OSC has been designed to meet the intent of the guidance in NUREG-0696, Functional Criteria for Emergency Response Facilities, and the clarification in NUREG-0737, Supplement 1, Clarification of TMI Action Plan Requirements, as applicable. Following permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the OSC will continue to be located in the TSC Building. The proposed changes to the FCS RERP do not involve any physical modifications to, or layout/configuration changes in, the OSC.

Because either the Radiation Protection Coordinator or the Radiation Protection Technician is currently required for activation of the OSC, but not both, and the OSC minimum staffing Radiation Protection Technician position is being retained in the post-shutdown ERO, the proposed staffing changes do not impact the ability of FCS to activate the OSC using the minimum staff positions currently described in the FCS RERP. Following permanent cessation of power operations, the following OSC positions are proposed for elimination: RP Coordinator, Maintenance Coordinator, Chemistry Coordinator, Medical Response Coordinator, OSC Operations Liaison, Dosimetry Technician, ERMS Operator, Radio Operator, Storekeeper, and Accountability Clerk. Attachment 5 contains an analysis of all ERO positions being eliminated and evaluates the transfer of tasks to remaining ERO positions following permanent cessation of power operations and permanent removal of fuel from the reactor vessel. The proposed ERO staffing reductions continue to

LIC-16-0076 Revision 1 Page 18 address the risks to public health and safety, comply with the FCS RERP, site commitments, and applicable regulations.

As previously described, to validate the results of the analysis, one or more drills will be developed and conducted prior to implementation of the changes described within. The drills will be conducted to confirm the ability of the post-shutdown ERO to perform the necessary functions of each ERF and will utilize the post-shutdown procedures that will be developed depicting the revised assignment of duties. The drills will be used to train and qualify post-shutdown ERO members, evaluate and validate the ability to accomplish the stated mission of each ERF, and ensure that the planning standard functions are preserved with no degradation in time sensitive activities or in the ability to communicate with offsite response organizations. The drills will also validate that the post-shutdown ERO continues to address the risks to public health and safety and comply with the FCS RERP, site commitments, and applicable regulations. Implementing procedures will be revised to address the permanently shut down and defueled conditions. The revised procedures will be used to support training of ERO staff and the conduct of drills described above.

Training and procedures will be developed and in place prior to performing post-shutdown ERO drills. The drill scenarios will include SFP events and be designed to test the major elements of the FCS post shutdown RERP. Major elements to be tested will include communications and coordination with offsite response organizations, including the JIC. State, Local, and Federal response organizations will be provided the opportunity to participate in or observe the drills. New regulatory commitments for scenario elements and communication with offsite agencies are included in Attachment 6.

In the permanently shut down and defueled condition, the primary functions of the OSC will remain dispatching of, and accounting for, Repair and Corrective Action Teams and dispatching of Site Boundary Teams. The OSC Director is responsible for ensuring adequate staffing of the OSC to support the emergency; working with the Site Director to set priorities for the OSC; and directing the activities of the OSC to support the emergency response. If at any time the OSC Director determines additional manpower is necessary to accomplish the mission of the OSC, the OSC Director will contact the TSC Admin Logistics Coordinator to arrange for augmentation by additional personnel to support the emergency response functions of the OSC.

In the permanently shut down and defueled condition, the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The primary events of concern in the immediate post-shutdown and defueled condition will be a FHA and a loss of SFP cooling and/or water inventory. During fuel handling activities there will be extra personnel on site that will, were a FHA to occur, be able to respond to the event. Events involving a loss of SFP cooling and/or water inventory will continue to be addressed by implementation of SFP inventory makeup strategies in plant procedures and as required under 10 CFR 50.54(hh)(2).). These strategies will continue to be maintained as a license condition. OSC staff is not relied upon to implement SFP inventory makeup.

Restoration of equipment supporting SFP cooling and inventory will be the primary focus of emergency mitigation actions for the TSC and OSC in a permanently shut down and defueled condition. Although ERO activation/response time requirements will be unchanged, the elimination of credible accidents involving an operating reactor provides additional time to plan and execute assessment and mitigation actions. The proposed changes do not impact the capability to assess and monitor actual or potential offsite consequences of a radiological emergency or provide information to offsite authorities in a timely manner. Therefore, the RP Coordinator, Maintenance

LIC-16-0076 Revision 1 Page 19 Coordinator, Chemistry Coordinator, Medical Response Coordinator, OSC Operations Liaison, Dosimetry Technician, ERMS Operator, Radio Operator, Storekeeper, and Accountability Clerk positions can be eliminated without placing an undue burden on the remaining ERO positions in the OSC and without increasing the risk to public health and safety.

4.2.1.3 Emergency Operations Facility As described in Section H.2 of the FCS RERP, the EOF functions to maintain overall management of emergency response and recovery resources; evaluate, coordinate, and communicate emergency response activities with Federal, State, and local emergency response organizations; evaluate offsite accident conditions; and make recommendations to offsite agencies regarding protective actions. Nebraska and Iowa representatives are provided space and communications at the EOF and staff this facility at an Alert or higher classification.

The EOF has been designed to meet the intent of the guidance in NUREG-0696, Functional Criteria for Emergency Response Facilities, and the clarification in NUREG-0737, Supplement 1, Clarification of TMI Action Plan Requirements, as applicable. Following permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the EOF will continue to be located at North Omaha Power Station, approximately 17 miles from the plant site. The proposed changes to the FCS RERP do not involve any physical modifications to, or layout/configuration changes in, the EOF.

The EOF maintains extensive communications capability with all ERFs and direct links are established between the EOF, the Control Room, the State and County Emergency Operations Centers (EOCs), and the JIC to provide up-to-date emergency status reports. The proposed changes to the FCS RERP do not involve changes to the ability of offsite authorities to report to the EOF or the JIC, and as a result, do not impact the ability of the offsite authorities to mobilize to, or operate from, the EOF and JIC.

When activated, the Emergency Director reports to the EOF and directs the activities of the ERO throughout the emergency and until the recovery activities have been terminated. The Emergency Director, or a designated alternate, is notified of all emergency conditions occurring at the plant and issues periodic status reports of the event to the responding offsite representatives. As described in Section B.4.10 of the FCS RERP, the EOF serves as the primary interface with the various offsite support agencies. FCS RERP, Section B, Attachment 2, Figure B-3, Organizational Interrelationships illustrates the interface of the EOF with federal, state, and local support agencies. The proposed changes to the FCS RERP do not reduce the ability of FCS to provide the necessary information regarding the status and progression of an event or in the frequency at which event information updates are provided. Nor do the changes impact the ability to dispatch additional technical support to the EOCs. As a result, the proposed changes do not impact the ability of FCS to communicate with the offsite response organizations.

Centralized coordination of the offsite radiological assessment effort with all organizations interested in, and/or performing, assessments is necessary to ensure that the data and its interpretation are reviewed by FCS and offsite response organizations with monitoring and assessment responsibilities. The number and type of organizations performing this effort vary with time and following emergency declarations and offsite notification. Initially, plant emergency response personnel are the only organization performing this function and they are directed from, and their results evaluated, at the EOF. State authorities join the EOF monitoring and assessment activities. Federal response agencies would augment plant and State radiological assessment efforts upon their arrival. Plant and State monitoring efforts are coordinated at the EOF. The proposed changes to the FCS RERP do not involve changes to offsite radiological assessment

LIC-16-0076 Revision 1 Page 20 capabilities or coordination of these efforts with offsite response organizations, and as a result, do not impact the ability of offsite agencies to effectively implement their emergency plans.

FCS will continue to maintain the capability to display plant and meteorological data in the EOF, maintain offsite monitoring equipment at the EOF and maintain the current dose assessment capabilities at the EOF. Additionally, FCS will maintain a goal of approximately sixty (60) minutes after declaration of an emergency to activate the EOF.

The proposed staffing changes would eliminate one ERO position in the EOF described in FCS EPIPs as a minimum staff position. FCS EPIPs identify the Dose Assessment Coordinator or the Protective Measures Manager as required minimum staff position. The Protective Measures Manager position is retained in the post-shutdown ERO.

The following EOF positions are proposed for elimination following permanent cessation of power operations and permanent removal of fuel from the reactor vessel:

Emergency Response Coordinator EOF Secretary EOF Dose Assessment Assistant EOF Status Board Keeper Dose Assessment Coordinator EOF Clerical Assistant Emergency Director Secretary IT Specialist EOF CHP Communicator Communications Specialist The proposed EOF staffing changes described above do not impact the capabilities of the on-shift staffing or augmented response. The positions can be eliminated without placing an undue burden on the remaining ERO positions in the EOF and without increasing the risk to public health and safety. Attachment 5 contains an analysis of all ERO positions being eliminated and evaluates the transfer of tasks to remaining ERO positions following permanent cessation of power operations and permanent removal of fuel from the reactor vessel. The EOF will continue to be activated at an Alert or higher declaration. Functional responsibilities of the positions eliminated as a result of the changes will be reassigned to remaining positions. The proposed ERO staffing reductions continue to address the risks to public health and safety, comply with the FCS RERP, site commitments, and applicable regulations.

As previously described, to validate the results of the analysis, one or more drills will be developed and conducted prior to implementation of the changes described within. The drills will be conducted to confirm the ability of the post-shutdown ERO to perform the necessary functions of each ERF. The drills will be used to train and qualify post-shutdown ERO members, evaluate and validate the ability to accomplish the stated mission of each ERF, and ensure that the planning standard functions are preserved with no degradation in time sensitive activities or in the ability to communicate with offsite response organizations. The drills will also validate that the post-shutdown ERO continues to address the risks to public health and safety and comply with the FCS RERP, site commitments, and applicable regulations. Implementing procedures will be revised to address the permanently shut down and defueled conditions. The revised procedures will be used to support training of ERO staff and the conduct of drills described above.

LIC-16-0076 Revision 1 Page 21 Training and procedures will be developed and in place prior to performing post-shutdown ERO drills. The drill scenarios will include SFP events and be designed to test the major elements of the FCS post shutdown RERP. Major elements to be tested will include communications and coordination with offsite response organizations, including the JIC. State, local and Federal response organizations will be provided the opportunity to participate in or observe the drills. New regulatory commitments for scenario elements and communication with offsite agencies are included in Attachment 6.

4.2.1.4 Joint Information Center The FCS JIC is located at the OPPD Energy Plaza, 444 South 16th Street Mall, in Omaha, Nebraska. As described in Section G of the FCS RERP, the JIC provides a location for the news media to receive information from all involved agencies and companies during an emergency and provide it to the general public. The JIC is equipped to accommodate the news media for large briefings and conferences and contains extensive communications systems. Media monitoring and rumor control is also accomplished at the JIC, allowing FCS and State representatives to address incorrect information or rumors. Responses to media telephone inquiries are also addressed at the JIC.

The JIC meets the intent of the guidance in Planning Standard G of NUREG-0654. Following permanent cessation of power operations, the JIC will continue to be located at the OPPD Energy Plaza in Omaha. The proposed changes to the FCS RERP do not involve any physical modifications to, or layout/configuration changes in, the JIC.

The proposed staffing changes do not eliminate any ERO position in the JIC described in FCS EPIPs as a minimum staff position.

The proposed staffing changes eliminate the following ERO positions in the JIC:

Executive Liaison Internal Information Liaison (Spokesperson)

Public Inquiry Supervisor Five (5) Public Inquiry Specialists In the permanently shut down and defueled condition, media briefings and rumor control will continue to be conducted regularly during an emergency to provide accurate and timely information to the public. The proposed JIC staffing changes described above do not impact the capabilities of the on-shift staffing or augmented response. The positions can be eliminated without placing an undue burden on the remaining ERO positions in the JIC and without increasing the risk to public health and safety. Attachment 5 contains an analysis of all ERO positions being eliminated and evaluates the transfer of tasks to remaining ERO positions following permanent cessation of power operations and permanent removal of fuel from the reactor vessel. The JIC will continue to be activated at Site Area Emergency or higher declaration. Functional responsibilities of the positions eliminated as a result of the changes will be reassigned to remaining positions.

The proposed ERO staffing reductions continue to address the risks to public health and safety, comply with the FCS RERP, site commitments, and applicable regulations.

As previously described, to validate the results of the analysis, drills will be developed and conducted prior to implementation of the changes described within. The drills will be conducted to confirm the ability of the post-shutdown ERO to perform the necessary functions of each ERF.

The drills will be used to train and qualify post-shutdown ERO members, evaluate and validate the ability to accomplish the stated mission of each ERF, and ensure that the planning standard functions are preserved with no degradation in time sensitive activities or in the ability to

LIC-16-0076 Revision 1 Page 22 communicate with offsite response organizations. The drills will also validate that the post-shutdown ERO continues to address the risks to public health and safety and comply with the FCS RERP, site commitments, and applicable regulations. Implementing procedures will be revised to address the permanently shut down and defueled conditions. The revised procedures will be used to support training of ERO staff and conduct of drills.

Training and procedures will be developed and in place prior to performing post-shutdown ERO drills. The drill scenarios will include SFP events and be designed to test the major elements of the FCS post shutdown RERP. Major elements to be tested will include communications and coordination with offsite response organizations, including the JIC. State, local, and Federal response organizations will be provided the opportunity to participate in or observe the drills. New regulatory commitments for scenario elements and communication with offsite agencies are included in Attachment 6.

4.2.1.5 Impact on Off-Site Response Organizations Because of the geographic location of FCS, the planning and responsibilities at the State and local level involve coordination with the State of Nebraska, State of Iowa, Washington County (Nebraska), Harrison County (Iowa), and Pottawattamie County (Iowa). Section F of the FCS RERP describes the extensive communications network maintained between FCS, the States, and local agencies as a means of promptly notifying and maintaining communications with appropriate authorities. As illustrated in Section F, Figure F-2 of the FCS RERP, the coordination effort with offsite authorities is initiated by notifying the States of Nebraska and, State of Iowa, and Washington, Harrison, and Pottawattamie counties and providing each with information using a pre-arranged notification form that provides key information regarding an emergency. The proposed changes to the FCS RERP do not involve changes to this communications network, and as a result, do not impact the ability of FCS to promptly notify and initiate coordination with the offsite authorities.

Formal offsite REP plans, approved by FEMA in accordance with 44 CFR 350, are required to be maintained in effect until such time as the NRC approves an exemption to formal offsite emergency preparedness requirements. Because the changes proposed by FCS, specifically in regards to ERO staffing of the EOF and JIC, have the potential to adversely impact the effective implementation of the State and local REP plans, the proposed changes to the FCS RERP were evaluated for impacts on the ability of the State and local response organizations to effectively implement their FEMA-approved REP Plans. No specific change recommendations were identified; however, FCS will provide the offsite response organizations with the proposed post shutdown ERO positions so that they may revise their procedures as necessary. contains an analysis of all ERO positions being eliminated and evaluates the transfer of tasks to remaining ERO positions following permanent cessation of power operations. The discussion provided previously in this section addresses the potential impacts the proposed changes to the FCS RERP have on the EOF and the JIC and the potential impacts on the ability of the offsite response organizations to implement their FEMA-approved REP Plans.

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 (Reference 1). These discussions have addressed future changes to onsite and offsite emergency preparedness throughout the decommissioning process.

As previously described, State, local, and Federal response organizations will be provided the opportunity to participate in or observe drills prior to implementation of the post-shutdown RERP.

LIC-16-0076 Revision 1 Page 23 New regulatory commitments for scenario elements and communication with offsite agencies are included in Attachment 6.

4.2.2 On-Shift Staffing To support reduced staffing following permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the proposed post-shutdown on-shift staffing was evaluated in conjunction with the postulated accidents previously submitted to the NRC using methodology presented in NEI 10-05 (Attachment 4). The analysis of proposed post-shutdown on-shift staffing considered the FHA as the DBA. The analysis of proposed post-shutdown on-shift staffing concluded that in a permanently shut down and defueled condition the Shift Manager, one CRO/CFH, one Equipment Operator/NCO, and one Radiation Protection Technician can perform all required Emergency Plan actions in a timely manner and there are no collateral duties that would prevent the timely performance of emergency plan functions. The Fire Brigade complement considered in the analysis of proposed post-shutdown on-shift staffing was consistent with the requirements from the Fire Hazard Analysis.

For the analysis performed in October 2014, the following accident scenarios were evaluated:

Main Steam Line Break Accident This event results in radioactive material releases outside secondary containment and was due to a complete severance of a 16-inch line leading to the turbine bypass steam chest.

Steam Generator Tube Rupture (SGTR) Accident The steam generator tube rupture accident is a penetration of the barrier between the reactor coolant system and the main steam system.

Loss of Coolant Accident A loss-of-coolant accident (LOCA) is defined as a breach of the reactor coolant system boundary, which results in interruption of the normal mechanism for removing heat from the reactor core.

Fuel Handling and Fuel Loading Incidents (in Spent Fuel Pool and Containment)

A fuel handling accident is defined as dropping of a spent fuel assembly resulting in the rupture of the fuel cladding of a fuel assembly.

Gas Decay Tank Rupture The accident is defined as the uncontrolled or unanticipated release of the radioactive noble gases stored in a gas decay tank as a result of a failure of a tank or associated piping.

Design Basis Threat The event evaluated for this analysis assumes a land based threat that is neutralized immediately when inside the protected area fence, no significant damage to equipment or systems that require corrective actions before the ERO is staffed, no radiological release, and no fire that requires firefighting response before the ERO is staffed.

LIC-16-0076 Revision 1 Page 24 Aircraft Potential Threat (50.54(hh))

Notification is received from the NRC that a potential aircraft threat exists.

Fire requiring evacuation of the Control Room and plant shutdown from remote location A fire occurs in the main control room requiring the evacuation of the control room and procedures implemented to remotely shutdown the reactor.

Station Blackout A loss of all offsite AC power occurs and the failure of the emergency diesel generators to load. The SM determines power cannot be restored and declares a Site Area Emergency due to the loss of offsite power.

The following accident scenarios were included in the analysis of proposed post-shutdown on-shift staffing:

Design Basis Threat The event consists of notification to the Shift Manager from the Security Shift Supervisor that a hostile action is occurring at or inside the Protected Area. A hostile force will breach the Protected Area fence but is not sufficient to interrupt SFP cooling or cause a radiological release and is neutralized with no adverse consequences to plant safety.

Damage inflicted on plant systems, structures and components is not sufficient to cause a radiological release. There is no fire significant enough to warrant firefighting efforts prior to the arrival of offsite resources and/or the augmented ERO.

Fuel Handling Accident (FHA) with General Emergency and PAR One postulated DBA that will remain applicable to FCS in its permanently shut down and defueled condition is the FHA in the Auxiliary Building where the SFP is located. This event assumes a dose that exceeds the Environmental Protection Agencys (EPA)

Protective Action Guides (PAGs) beyond the site boundary, and thus necessitates promulgation of a Protective Action Recommendation (PAR).

Aircraft Potential Threat (50.54(hh)(1))

This event includes emergency response actions in response to potential aircraft impacts in accordance with 10 CFR 50.54(hh)(1).

Event Requiring Control Room Evacuation and Maintain SFP Cooling An event occurs requiring the evacuation of the Control Room and actions implemented to control auxiliary cooling water pumps from a remote location.

The analysis of the proposed post-shutdown on-shift staffing indicates that the proposed on-shift personnel can satisfactorily implement all emergency plan functions as required by regulation without augmented ERO personnel for at least 60 minutes following an emergency declaration.

LIC-16-0076 Revision 1 Page 25 Currently, the Chemistry Technician is an on-shift position per FCS RERP Section B, Attachment 1, Table B-1 so that a technician is always available to immediately collect and analyze a liquid sample if the applicable radiation monitor is not available during a release, or as directed by the Shift Manager. When the on-shift Chemistry Technician position is eliminated, the on-shift Radiation Protection Technician will be able to perform sampling and analysis, if necessary, so as to not delay information potentially needed by the Shift Manager to determine if an emergency declaration is required. For gaseous releases, the only credible scenario for releasing gas would be to mechanically damage spent fuel during handling or by impact of a heavy object. Activities that could cause mechanical damage will require that a Chemistry Technician be on-site or the radiation monitor listed in gaseous effluent EALs to be in service, thereby alleviating any reliance on a potentially delayed sample analysis to determine EAL applicability. A new regulatory commitment to revise applicable fuel handling procedures to incorporate this prerequisite is included in Attachment 6.

A gap analysis will be performed to determine any differences between current Radiation Protection Technician training requirements and any new specific knowledge requirements associated with emergency plan sampling and analysis. Such specific knowledge requirements would include how to obtain specific liquid samples.

Once the specific training requirements for the Radiation Protection Technician position have been identified using a systematic approach to training, as required by 10 CFR 50.120, a formal gap analysis will be completed for all personnel identified to fill the Radiation Protection Technician position. Individualized training plans will be developed and completed to address specific knowledge and skill areas for each of the selected Radiation Protection Technician candidates.

The initial training for all incumbent Radiation Protection Technicians will include all training requirements to perform liquid sampling and analysis to support an emergency declaration.

The initial training requirements for any new Radiation Protection Technician will include all training modules to ensure they are equipped with the required skills and knowledge to perform the required liquid sampling and analysis. These training modules will be specifically identified in the training program description for the Radiation Protection Technician position. This document will be developed in accordance with the requirements of 10 CFR 50.120.

Based on the above, the proposed change in on-shift operations staffing and elimination of the on-shift Chemistry Technician are appropriate given the permanent cessation of power operations and permanent removal of fuel from the reactor vessel.

Because of the reduced number of possible events requiring mitigating actions in the permanently defueled condition and the limited number of actions to be performed by the Control Room positions in a permanently defueled condition, no Licensed Reactor Operators or STA job tasks were noted as being required for any of the events analyzed in the analysis of proposed post-shutdown on-shift staffing. Therefore, the Licensed Reactor Operators and STA positions can be eliminated without reducing the effectiveness of the post-shutdown FCS RERP.

The proposed on-shift staffing changes do not impact the capabilities of the on-shift staff to respond to an emergency and continue to comply with the FCS RERP, site commitments, and applicable regulations.

Additional analysis for each of the staffing changes associated with FCS RERP Section B, , Table B-1 is provided in the following section.

LIC-16-0076 Revision 1 Page 26 4.2.3 Major Functional Area: Plant Operations & Assessment of Operational Aspects Current Staffing Requirement During normal operations, the minimum staff on duty at the plant during all shifts to satisfy this Major Functional Area consists of:

1 Shift Manager (SRO) 1 Unit Supervisor (SRO) 1 STA 2 Reactor Operators 2 Equipment Operators 1 Control Room Communicator 1 Radiation Protection Technician 1 Chemistry Technician 1 Habitability Technician Proposed Change The proposed changes to the FCS RERP will eliminate the following on-shift positions:

2 Reactor Operators 1 Equipment Operator 1 Control Room Communicator 1 Chemistry Technician 1 Habitability Technician 1 STA Credited on-shift personnel will consist of one Shift Manager (CFH), one CRO (CFH), and one Equipment Operator/NCO. Title changes for Licensed personnel and Equipment Operators to CFHs and NCOs, respectively, are dependent upon NRC approval of proposed changes to the FCS Technical Specifications that revise the minimum shift staffing requirements in the FCS Technical Specifications by replacing references to licensed and non-licensed operators with references to CFHs and NCOs. Implementation of the FCS RERP, as proposed for revision in this submittal, is not dependent on prior NRC approval of the proposed changes to the FCS Technical Specifications.

Analysis The regulatory standard for minimum staffing requirements for NRC licensees is documented in NUREG-0654. The total minimum on-shift staffing expressed in NUREG-0654, Table B-1, is ten personnel. Plant Operations shift staffing, as implemented previously, was based on an operating philosophy that provided defense in depth. The analysis of proposed post-shutdown on-shift staffing concluded that in a permanently shut down and defueled condition, the Shift Manager, CRO, and one Equipment Operator/NCO can perform all required FCS RERP actions in a timely manner and there are no collateral duties that would prevent the timely performance of emergency plan functions. Therefore, this deviation from the guidance presented in NUREG-0654, Table B-1 is acceptable.

LIC-16-0076 Revision 1 Page 27 4.2.4 Major Functional Area: Notification/Communication Major Tasks: Notify Licensee, State, Local, and Federal personnel and maintain communication.

Current Staffing Requirement The Control Room Communicator performs the function of on-shift notification/communication.

Proposed Change Replace the Control Room Communicator with the CRO/CFH (or NCO).

Analysis This function is currently performed by an on-shift staff position performing emergency plan Communicator requirements. This function is currently augmented by TSC and EOF designated communications positions when those facilities assume communications responsibilities.

Initial notification to offsite authorities are required to occur within 15 minutes of declaration of an emergency and initial NRC notification is required to occur immediately after notification of the appropriate State or Local agencies and not later than 60 minutes after the time of the emergency declaration, for non-security related events. Subsequent notifications are made should the event escalate and for informational updates. The resource commitment to support the communication function is not full time so there is time to support performance of collateral duties during the first 60 minutes until staff augmentation can occur. The on-shift and offsite communicators have advanced communications capabilities available such as the Conference Operations (COP) Network.

Communications with the NRC take place over dedicated telephone lines provided for and maintained by the NRC (Emergency Notification System (ENS)). For purposes of the analysis of proposed post-shutdown on-shift staffing, NRC notifications were treated as a continuous action in accordance with 10 CFR 50.72(c)(3), meaning that once the initial NRC communications are established, it was assumed that the NRC will request an open line to be continuously maintained with the NRC Operations Center. The use of dedicated phone circuits and headsets enables these notifications to be performed by the same on-shift communicator who performs the State and Local notifications.

The Shift Manager initially approves the content of the communication with the State and Federal agencies until relieved of this function by the EOF. The FCS RERP goal is to activate the EOF within approximately 60 minutes. The EOF assumes the communication responsibility concurrent with activation. Therefore, the current communication protocol may remain within the Control Room for the first 60 minutes, regardless of the presence of any prior ERO augmentation.

In the post-shutdown condition, the task of notifying and communicating with offsite authorities will be transferred to the CRO/CFH (or NCO). This change is acceptable because the analysis of proposed post-shutdown on-shift staffing concluded that in a permanently defueled condition, the designated on-shift staff can perform this required FCS RERP action in a timely manner and there are no collateral duties that would prevent the timely performance of this emergency plan function.

LIC-16-0076 Revision 1 Page 28 4.2.5 Major Functional Area: Radiological Accident Assessment and Support of Operational Accident Assessment Major Tasks: Offsite Dose Assessment; Onsite and In-plant surveys; Offsite surveys; Chemistry/Radiochemistry Current Staffing Requirement On-shift Radiation Protection Technician, Habitability Technician, and Chemistry Technician perform the in-plant radiation protective actions.

Augmentation of the on-shift Radiation Protection Technician capability by four Radiation Protection Technicians occurs within approximately 60 minutes.

Augmentation of the on-shift Chemistry Technician capability by one Chemistry Technician occurs within approximately 60 minutes.

Proposed Change Eliminate the on-shift Chemistry Technician position.

Eliminate the on-shift Habitability Technician position.

Eliminate three augmenting Radiation Protection Technician positions Analysis During a toxic gas event, tasks would be assigned to the Chemistry Technician in the first 60 minutes. These tasks will be reassigned to a trained and qualified on-shift Radiation Protection Technician with no conflicting duties. Therefore, the Chemistry Technician position does not need to be maintained on-shift.

The proposed change in on-shift staffing and elimination of the on-shift Habitability Technician are appropriate given the permanent cessation of power operations and permanent removal of fuel from the reactor vessel. The spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The set of plant equipment required in the permanently defueled condition is also greatly reduced, which reduces the assessment and mitigation activities in the Control Room. Habitability concerns in a permanently shut down and defueled condition do not require a dedicated on-shift position.

The two Radiation Protection Technician positions currently listed in the Radiological Accident Assessment and Support of Operational Accident Assessment Major Functional Area of Attachment 1 - Table B.1 of Section B of the FCS Radiological Emergency Response Plan (RERP), proposed for elimination, do not have defined tasks in procedures.

Currently, EPIPs direct the Protective Measures Coordinator (position maintained in the Post-Shutdown ERO) to dispatch Radiation Protection personnel to the Remote Assembly Area(s)/relocation area(s) to evaluate habitability and, if required, perform surveys of vehicles and evacuees in the event of a site evacuation, if sufficient Radiation Protection staff is present onsite at the time the site evacuation is ordered. Historically, the Radiation

LIC-16-0076 Revision 1 Page 29 Protection Technician positions proposed for elimination served as the Radiation Protection personnel that would mobilize to the Remote Assembly Area(s)/Relocation Area(s) and perform these actions. However, these actions need not be performed by Radiation Protection Technicians. Procedures direct the Protective Measures Coordinator to initiate callouts, or contact the EOF Protective Measures Manager (position maintained in the Post-Shutdown ERO) for additional resources.

FCS is eliminating these positions from Attachment 1 - Table B.1 because the time necessary to establish the offsite locations to which Radiation Protection personnel would respond precludes the need for these positions to be augmenting positions and because EPIPs direct the Protective Measures Coordinator to dispatch Radiation Protection personnel, not Radiation Protection Technicians, to perform the necessary actions. FCS maintains the necessary staffing to provide personnel trained in radiation protection to respond and perform the required actions, if necessary, in the post-shutdown condition.

Activities related to the conduct of surveys or radiological assessment of the area surrounding FCS will be performed by the four Field Team Technicians identified in the Radiological Accident Assessment and Support of Operational Accident Assessment Major Functional Area of Attachment 1 - Table B.1 of Section B of the FCS RERP, independent of the augmenting Radiation Protection Technician positions. Offsite surveys in support of dose assessment are currently performed by the four Field Team Technicians, which are maintained in the Post-Shutdown Emergency Plan (PSEP).

FCS proposes reducing the number of Radiation Protection Technicians listed in the Major Task of Onsite (Out of plant) survey in the Radiological Accident Assessment and Support of Operational Accident Assessment Major Functional Area of Attachment 1 - Table B.1 of Section B of the FCS RERP from two to one. As previously described, the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The risk in the permanently defueled condition is significantly reduced because many of the potential initiating conditions that would lead to an emergency declaration will no longer be possible and the elimination of credible accidents involving an operating reactor provides additional time to plan and execute assessment and mitigation actions. Currently, EPIPs describe actions for Radiation Protection Technicians that could be performed by adequately trained station personnel. Additionally, procedures direct the Protective Measures Coordinator to initiate callouts, or contact the EOF Protective Measures Manager (position maintained in the Post-Shutdown ERO) for additional resources. FCS maintains the necessary staffing to provide sufficient personnel trained in radiation protection to respond and perform the required actions, if necessary, in the post-shutdown condition.

4.2.6 Major Functional Area: Plant Systems Engineering, Repair and Corrective Actions 4.2.6.1 Major Task: Technical Support (STA)

Current Staffing Requirement The on-shift STA performs the major task of Technical Support.

Proposed Change Eliminate the on-shift STA position.

LIC-16-0076 Revision 1 Page 30 Analysis The STA performs independent assessments of plant operating concerns, technical support, appropriate corrective actions, analysis of events and their effects, effectiveness of response(s) to emergent conditions, assistance in classifications of emergencies, protection of the public, and any other actions related to critical safety functions and plant safety during abnormal and emergency situations. The STA also supports operations during normal plant conditions. By routine monitoring of equipment and plant operations, the STA can focus on preventative actions in order to mitigate the consequences of an accident.

Because of the permanent cessation of power operations and removal of fuel from the reactor vessel, the STA position is no longer necessary for technical and analytical assistance. The spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The set of plant equipment required in the permanently defueled condition is also greatly reduced, which reduces the assessment and mitigation activities in the Control Room. The Technical Support function will be assumed by the remaining Control Room personnel.

The analysis of proposed post-shutdown on-shift staffing concluded that the Shift Manager and CRO/CFH (or NCO during events requiring Fire Brigade response) can perform any required technical analysis, until augmented by the TSC Engineering Coordinator and necessary engineering staff, in a timely manner and there are no collateral duties that would prevent the timely performance of this task.

4.2.7 Major Functional Area: Protective Actions (Plant)

Current Staffing Requirement Two on-shift Radiation Protection Technicians perform the in-plant protective actions. As indicated in the RERP, these tasks can be performed by personnel assigned other functions.

Augmentation of the on-shift Radiation Protection Technicians by two Radiation Protection Technicians, the Radiation Protection Coordinator, and one Dosimetry Technician within 60 minutes.

Proposed Change Eliminate the on-shift Habitability Technician position (serving as the 2nd RP Technician)

Eliminate one augmenting Radiation Protection Technician Eliminate the Radiation Protection Coordinator Eliminate the Dosimetry Technician

LIC-16-0076 Revision 1 Page 31 Analysis The function of these additional resources is to provide radiation protection oversight of the on-shift complement of personnel and augmented personnel who are expected to respond to emergency events for damage repair, corrective actions, search and rescue, first aid, firefighting and personnel monitoring. They can also be expected to provide for access control and the issuance of dosimetry. Analysis of the proposed change for each of these tasks is discussed below.

4.2.7.1 Major Tasks: Radiation Protection Access Control Originally, radiological access control was a labor intensive task. Dedicated Radiation Protection Technicians were required to check dose margins, training qualifications, and to ensure workers had read and understood their radiation work permit. Worker access control is now partially automated because many of the Radiation Protection work processes have been computerized. Radiation Work Permit (RWP) access control and electronic dosimeter computer systems work together to provide a fully integrated system allowing workers to sign-in on their RWP and to self-issue electronic dosimeters. During a declared emergency however, RWPs and dose setpoints will change depending on the emergency situation and plant conditions. Both systems have been used by plant workers for several years. Worker dose margins and training qualifications are also automatically verified when the RWP access control system is used. If a worker's dose margin is inadequate or training is expired, the workers access would be precluded and the access control system would not allow issuance of an electronic dosimeter. In an emergency situation, approval to exceed dose margins is required. During the log-in process, workers acknowledge their electronic dosimeter alarm setpoints and that they have read and understand their RWP. The electronic dosimeter provides the worker with a continuous status of dose received and work area dose rates, and will alarm at preset dose and dose rate alarms. Worker use of electronic dosimeters facilitates more efficient use of Radiation Protection Technicians to provide Radiation Protection coverage while preserving the ALARA concept. Access control is maintained because the worker must obtain an electronic dosimeter and enter a RWP number into the access control computer system prior to being allowed access into the Radiologically Controlled Area (RCA). No setup is required for the RWP access control computers, which allows Radiation Protection Technicians to be used for more critical tasks during emergency response. Personnel are required to self-monitor for radioactive contamination whenever they exit the RCA. No Radiation Protection involvement is necessary for this contamination monitoring activity because workers are trained to perform this task without supervision or oversight.

However, contaminated personnel exiting the RCA will require Radiation Protection oversight.

The post-shutdown OSA concluded that in a permanently defueled condition, Equipment Operators/NCOs can perform this required action in a timely manner and there are no collateral duties that would prevent the timely performance of this task.

4.2.7.2 Major Task: RP Coverage and Personnel Monitoring Radiation Protection (RP) coverage will only be performed if the radiological status of a room is unknown and there is a definitive need for emergency workers to enter the room to perform a task. The decision to provide RP coverage may be based on plant radiological conditions as indicated by installed area radiation monitors (ARMs) or event mitigation requirements.

LIC-16-0076 Revision 1 Page 32 During the initial stages of an accident, not all areas of the plant would be affected by releases of radioactive materials. Therefore, RP coverage would not be required for all areas. Because entry is expected to be limited to those areas where maintenance necessary to maintain SFP cooling is required and the areas potentially affected by an accident involving the SFP are limited, there is a significant decrease in areas potentially requiring RP coverage in a permanently shut down and defueled condition. If RP coverage is deemed necessary, multiple emergency teams can be covered by the on-shift Radiation Protection Technician. If RP coverage is not provided (for entry into areas with low radiological risk or known radiological status), worker protection is ensured because emergency workers are required to wear electronic dosimeters (which will alarm at preset dose and dose rate setpoints) and because of the installed ARMs (which alarm locally and remotely at preset dose rates) located throughout the plant.

4.2.7.3 Major Task: Dosimetry Originally, dosimetry issuance was a manual process requiring Radiation Protection Technicians to zero and issue dosimeters, verify worker training, and verify and track radiation dose margins. As addressed in the Access Control/Personnel Monitoring Sections above, access control computers are now used for issue of electronic dosimetry with alarming capability. Battery-powered electronic dosimeters are available as a backup.

Worker self-issuance of electronic dosimeters has eliminated the need for Radiation Protection Technicians to physically issue dosimetry, with the exception of any tasks that require specialized dosimetry and/or special body placement of the dosimetry. These types of tasks are not expected in the initial stages of an event, but during the recovery phase.

Prior to self-issuance of dosimetry, workers are assigned a RWP, setpoints are adjusted, and, when required, briefings are conducted by Radiation Protection.

The analysis of proposed post-shutdown on-shift staffing determined there are no time critical Radiation Protection or chemistry tasks, and that task performance is directed and prioritized by the Shift Manager for the 60-minute time frame used in the analysis. There are no overlapping Radiation Protection or chemistry tasks. Radiation Protection tasks were able to be performed without augmented personnel in the 60-minute time frame used in the analysis.

4.2.8 Major Functional Areas: Fire Fighting/Rescue Operations and First Aid 4.2.8.1 Major Task: Combat Fires Current Staffing Requirement The FCS Fire Brigade complement is one (1) Fire Brigade Leader or advisor with commensurate Licensed Operator knowledge, two (2) Fire Brigade trained Equipment Operators-Nuclear Auxiliary (EONA) non-license training with commensurate knowledge and two (2) other Fire Brigade qualified on-shift personnel. If use of a Fire Brigade Advisor (commensurate Licensed Operator knowledge) is chosen, the Fire Brigade Leader will be qualified the equivalent of EONA.

All Fire Brigade training and qualification requirements will be maintained utilizing the Fire Hazards Analysis requirements. The Fire Brigade will continue to perform the tasks of search and rescue, first aid, and firefighting in the permanently defueled condition. The Fire Brigade will be available to promptly implement SFP inventory makeup strategies required under 10 CFR 50.54(hh)(2) without impacting the performance of designated emergency plan functions.

LIC-16-0076 Revision 1 Page 33 4.3 Conclusion OPPD completed an evaluation of the proposed reduction in on-shift and ERO staffing and completed an analysis of proposed post-shutdown on-shift staffing to analyze the ability of the proposed defueled on-shift and ERO organization to respond to an emergency.

The analysis of proposed post-shutdown on-shift staffing was conducted assuming an on-shift complement of one Shift Manager, one CRO/CFH, one Equipment Operator/NCO, and one Radiation Protection Technician. The results of the analysis indicate that the proposed on-shift personnel can satisfactorily implement all regulatory required emergency plan functions without augmented ERO personnel for at least 60 minutes following an emergency declaration. During a toxic gas event, tasks would be assigned to the Chemistry Technician in the first 60 minutes.

These tasks will be reassigned to a trained and qualified on-shift Radiation Protection Technician with no conflicting duties. Compensatory measures will be implemented to ensure that the ability to assess and declare an emergency during fuel handling activities is maintained. Based on the above, the proposed change in on-shift operations staffing and elimination of the on-shift Chemistry Technician are appropriate for the permanently defueled condition.

The analysis of proposed post-shutdown on-shift staffing concluded that during an event requiring a Control Room evacuation in a permanently defueled condition, the Shift Manager and CRO (or NCO) can perform all required FCS RERP actions in a timely manner. There are no collateral duties that would prevent the timely performance of emergency plan functions.

Specific training requirements for the Radiation Protection Technician and NCO positions will be identified using a systematic approach to training, as required by 10 CFR 50.120, and formal gap analyses will be completed for all personnel identified to fill these positions. Individualized training plans will be developed and completed to address specific knowledge and skills areas for each of the selected candidates.

The proposed ERO staffing changes do not impact the capabilities of the on-shift staffing or augmented response. The ERFs will continue to be activated within approximately 60 minutes of an Alert or higher declaration. The remaining post-shutdown functional responsibilities of the positions eliminated as a result of the changes described within are being reassigned to remaining positions. The proposed ERO staffing reductions continue to address the risks to public health and safety and comply with the FCS RERP, site commitments, and applicable regulations.

The risk of a major event resulting in radioactive materials being released to the environment is significantly reduced in the permanently defueled condition. All required radiation protection functions are accommodated within the requisite time frames using the proposed on-shift resources. Any anticipated tasks can be handled by the proposed on-shift resources detailed in the post-shutdown on-shift staffing analysis.

LIC-16-0076 Revision 1 Page 34

5.0 REGULATORY EVALUATION

5.1 Applicable Regulatory Requirements/Criteria On-Shift and ERO Staffing The specific standards for establishing an onsite emergency organization to respond to emergency events appears in 10 CFR 50.47(b) and 10 CFR 50, Appendix E, Section IV.A. Specifically:

• 10 CFR 50.47(b)(1): Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

• 10 CFR 50.47(b)(2): On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified.

• 10 CFR 50, Appendix E Section IV.A.1: [E-Plans must contain] A description of the normal plant operating organization.

• 10 CFR 50, Appendix E Section IV.A.2: [E-Plans must contain] A description of the onsite emergency response organization with a detailed discussion of:

o Authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency; o Plant staff emergency assignments; o Authorities, responsibilities, and duties on an onsite emergency coordinator who shall be in charge of the exchange of information with offsite authorities responsible for coordinating and implementing offsite emergency measures; NUREG-0654 (Reference 2),Section II.B, Onsite Emergency Organization, presents guidance for meeting these requirements. The guidance describes the onsite emergency organization, including the staffing requirements found in Table B-1, Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies.

10 CFR Part 50, Appendix E, Section IV.A.9 states that licensees shall perform a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan.

NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants (Reference 4) provides information relevant to performing the on-shift staffing analysis. The ISG states that NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, is an acceptable methodology for performing the staffing analysis. The ISG also indicates that the completed staffing analyses are required to be part of the emergency plan and the results documented and submitted to the NRC in accordance with 10 CFR 50.54(q)(5).

NRC Regulatory Guide 1.101, (Reference 8), Section C, states in part "The criteria and recommendations in Revision 1 of NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear

LIC-16-0076 Revision 1 Page 35 Power Plants (November 1980), are methods acceptable to the NRC staff for complying with the standards in 10 CFR 50.47 that must be met in onsite and offsite emergency response plans.

These criteria provide a basis for NRC licensees and State and local governments to develop acceptable radiological emergency plans and improve emergency preparedness."

Regulatory Guide 1.219, Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors, July 2016 (Reference 9), describes a method that the NRC considers to be acceptable to implement the requirements in 10 CFR 50.54(q). In Section 2.a., the NRC encourages licensees to arrange a conference call with the NRC staff to clarify 10 CFR 50.54(q) requirements and guidance within this regulatory guide for EP changes that increase the activation time of emergency response facilities.

Regulatory Issue Summary 2005-02, "Clarifying the Process for Making Emergency Plan Changes," Revision 1 (Reference 10) was issued by the NRC to clarify the meaning of "decrease in effectiveness" and the process for making changes to emergency plans, and to provide some examples of changes that are considered to be a decrease in effectiveness.

5.2 Precedent The requested changes to the on-shift staffing and ERO staffing are consistent with the post-shutdown changes approved by the NRC and implemented by Vermont Yankee Nuclear Power Station (Reference 11).

5.3 No Significant Hazards Consideration 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 RERP to reduce the number of on-shift and ERO positions commensurate with the hazards associated with a permanently shut down 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 RERP do not impact the function of plant structures, systems, or components (SSCs). 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 ERO to perform their intended functions to mitigate the consequences of any accident or event that will be credible in the permanently defueled condition. The proposed changes only remove positions that will no longer be credited in the FCS RERP.

LIC-16-0076 Revision 1 Page 36 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 number of on-shift and ERO positions commensurate with the hazards associated with a permanently shut down 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 so that no new accident initiators are created.

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 RERP staffing and do not impact operation of the plant 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 plant 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 FCS RRP will continue to provide the necessary response staff with the proposed changes.

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

5.4 Conclusion 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.

LIC-16-0076 Revision 1 Page 37

6.0 ENVIRONMENTAL CONSIDERATION

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

(i) The amendment involves no significant hazards consideration.

As described in Section 5.3 of this evaluation, the proposed changes involve no significant hazards consideration.

(ii) There is no significant change in the types or significant increase in the amounts of any effluent that may be released offsite.

The proposed changes do not involve any physical alterations to the plant 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.

(iii) There is no significant increase in individual or cumulative occupational radiation exposure.

The proposed changes do not involve any physical alterations to the plant 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 need be prepared in connection with the issuance of this amendment.

LIC-16-0076 Revision 1 Page 38

7.0 REFERENCES

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

2. 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.

3. Federal Register Volume 76, Number 226, Wednesday, November 23, 2011, Rules and Regulations, Enhancements to Emergency Preparedness Regulations; Final Rule.

4. NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants, Revision 0, November 2011 (ML113010523)

5. NEI 10-05, Rev. 0, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities.

6. Letter, OPPD to USNRC Request for Approval of a Certified Fuel Handler Training Program, dated July 7, 2016 (LIC-16-0049) (ML16190A208)

7. EP-FC-1001, Addendum 1, Fort Calhoun Station On-Shift Staffing Technical Basis, Revision 0, dated October 2014.

8. NRC Regulatory Guide 1.101, Emergency Response Planning and Preparedness for Nuclear Power Reactors, Revision 4, July 2003

9. Regulatory Guide 1.219, Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors, Revision 1, July 2016

10. Regulatory Issue Summary 2005-02, "Clarifying the Process for Making Emergency Plan Changes," Revision 1, April 19, 2011

11. Letter, USNRC to Entergy Nuclear Operations, Inc., Vermont Yankee Nuclear Power Station - Issuance of Amendment to Renewed Facility Operating License Re: Changes to the Emergency Plan (TAC No. MF3668), dated February 4, 2015 (ML14346A065)

LIC-17-0020 Page 1 ATTACHMENT 3 SUPPLEMENTAL PAGE REVISIONS OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION. UNIT NO. 1 DOCKET NO. 50-285

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 1) Reason for Change Number)

Section B, 4.7.2.C Electrical Maintenance Technicians Electrical Maintenance Technician The spectrum of credible accidents (two positions) duties include duties include providing repairs and and operational events, and the providing repairs and corrective corrective actions for plant electrical quantity and complexity of activities actions for plant electrical equipment as directed. required for the safe storage of equipment as directed. spent nuclear fuel is reduced as compared to an operating plant. The duties and coverage required for the position is reduced.

Section B, 4.7.2, F Operations Liaison duties include Deleted The OSC Operations Liaison position obtaining plant status/Control Room will not exist in the postshutdown information from the Control Room ERO, as previously described. The Operations Liaison and transmitting TSC Ops Liaison will perform the this information to the OSC staff as functions as needed.

needed. [AR 11390]

The proposed elimination of the Operations Liaison position has been evaluated in the FCS analysis of proposed postshutdown ERO staffing.

Relettered subsequent steps.

21

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section Before (Rev. 1) Reason for Change Number)

Section B, 4.7.2.G Radiation Protection Technicians Radiation Protection Technician The augmenting Radiation (five positions) duties include duties include providing radiological Protection Technician positions will providing radiological surveys and surveys and job coverage to repair be reduced from five to one in the job coverage to repair and corrective and corrective action teams as postshutdown ERO (in addition to action teams as directed. directed. the OSC minimum staff Radiation Protection Technician). The spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The duties and coverage required for the position is reduced.

Section B, 4.7.2.H H. The Radiation Protection H. The Protective Measures The Radiation Protection Coordinator duties include: Coordinator duties include Coordinator position will not exist in coordinating all radiation protection the postshutdown ERO, as

1. Forming and preparing emergency activities onsite. previously described. The OSC response teams as directed by the Director, RP Technicians, and the OSC Director.

TSC Protective Measures

2. Coordinating all radiation Coordinator will perform the protection activities onsite. functions as needed. The proposed elimination of the Radiation

3. Keeping the OSC Director and TSC Protection Coordinator position has Protective Measures Coordinator been evaluated in the FCS analysis of informed of the status of all proposed postshutdown ERO radiation protection activities onsite.

staffing. Duties and responsibilities

4. Fulfilling the minimum staffing will be transferred to remaining ERO position of Radiation Protection positions.

Technician, if required.

22

EP-FC-1001 Section B FCS Revision TBD Page 21 of 156 ORGANIZATIONAL CONTROL OF EMERGENCIES plant instruments as directed.

D. Machinist or Steam Fitter Mechanic duties include providing repairs and corrective actions to plant mechanical equipment as directed.

E. Radiation Protection Technician duties include providing radiological surveys and job coverage to repair and corrective action teams as directed.

F. The Protective Measures Coordinator duties include coordinating all radiation protection activities onsite.