LIC-17-0047, Final Request for Additional Information Concerning License Amendment Request 16-07: Revise the Emergency Plan to the Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme

Final Request for Additional Information Concerning License Amendment Request 16-07: Revise the Emergency Plan to the Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme

ML17135A390
Person / Time
Site:	Fort Calhoun
Issue date:	05/15/2017
From:	Fisher M Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LAR 16-07, LIC-17-0047
Download: ML17135A390 (39)

Text

Omaha Public PowerDistrict LIC-17-0047 May 15, 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 License Amendment Request 16-07: Revise the Fort Calhoun Station Emergency Plan to the Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme

References:

1.

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

dated December 16, 2016 (LIC-16-0108)

(ML16351A464)

(CAC MF8951)

2.

EMAIL from NRC (J. S. Kim) to OPPD (E. P. Matzke), "Fort Calhoun Station - Final Request for Additional Information Concerning License Amendment Request 16-07:

Revise the Fort Calhoun Station Emergency Plan to the Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme," dated April20, 2017 (ML17112A036) (CAC MF8951)

By letter (Reference 1) dated December 16, 2016 (ADAMS Accession No. ML16351A464), Omaha Public Power District (OPPD) requested an amendment to Renewed Facility Operating License Number DPR-40 for the FCS. The proposed amendment would revise the FCS Emergency Plan, referred to hereafter as the Permanently Defueled Emergency Plan (PDEP), and Emergency Action Level (EAL) scheme for the permanently defueled condition.

On April20, 2017 (Reference 2), the NRC provided OPPD with Requests for Additional Information (RAI) regarding the requested amendment. 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

U. S. Nuclear Regulatory Commission LIC-17-0047 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, Director - Licensing and Regulatory Assurance, at (402) 533-7270.

Respec~~~~. A -

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Mary J. Fisher Senior Director - Decommissioning Fort Calhoun Station MJF/epm Attachments: 1.

2.

3.

Response to Request for Additional Information Revised Pages of License Amendment Request 16-07 Revised Pages of the Proposed Permanently Defueled Emergency Plan c:

K. M. Kennedy, NRC Regional Administrator, Region IV J. S. Kim, NRC Senior Project Manager R. S. Browder, NRC Senior Health Physicist, Region IV Director of Consumer Health Services, Department of Regulation and Licensure, Nebraska Health and Human Services, State of Nebraska

LIC-17 -004 7 Page 1 ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION RE:

LICENSE AMENDMENT REQUEST 16-07: REVISE THE FORT CALHOUN STATION EMERGENCY PLAN TO THE PERMANENTLY DEFUELED EMERGENCY PLAN AND PERMANENTLY DEFUELED EMERGENCY ACTION LEVEL SCHEME OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION. UNIT NO. 1 DOCKET NO. 50-285 By letter dated June 24, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16176A213), supplemented by letter dated August 25, 2016 (ADAMS Accession No. ML16242A127), Omaha Public Power District (OPPD) submitted certification to the U.S. Nuclear Regulatory Commission (NRC) indicating its intention to permanently cease power operations at the Fort Calhoun Station, Unit No. 1 (FCS) facility on October 24, 2016, pursuant to1 0 CFR 50.82(a)(1 )(i). By letter dated November 13, 2016 (ADAMS Accession No. ML16319A254), OPPD submitted a certification to the NRC of the removal of fuel from the reactor vessel, pursuant to 10 CFR 50.82(a)(1 )(ii). Upon docketing of the certifications, the 10 CFR Part 50 license for FCS no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2).

By letter dated December 16,2016 (ADAMS Accession No. ML16351A464), OPPD requested an amendment to Renewed Facility Operating License Number DPR-40 for the FCS. The proposed amendment would revise the FCS Emergency Plan, referred to hereafter as the Permanently Defueled Emergency Plan (PDEP), and Emergency Action Level (EAL) scheme for the permanently defueled condition.

In reviewing the license amendment request (LAR), the NRC staff used the guidance from recent emergency preparedness (EP)-related decommissioning exemption reviews provided in Interim Staff Guidance (ISG) document-NSIR/DPR-ISG-02, "Emergency Planning Exemption Requests For Decommissioning Nuclear Power Plants,", "Staff Guidance for Evaluating Permanently Defueled Emergency Plans" (ADAMS Accession No. ML14106A057). The staff also informed its review of the EAL scheme utilizing the guidance provided in the Nuclear Energy Institute (NEI) document, NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors," dated November 2012 (ADAMS Accession No. ML12326A805).

Based on the NRC staffs initial review of OPPD's LAR, the following requests for additional information (RAis) are required to facilitate completion of the staffs technical review:

FCS-RAI-1 Section 1.0, "Summary Description," in Attachment 1 provides the following, in part:

... the spent fuel stored in the spent fuel pool (SFP) will have decayed to the extent that the requested exemptions, PDEP, and Permanently Defueled EAL scheme may be implemented without any additional compensatory actions. (emphasis added)

LIC-17-0047 Page 2 One of the considerations for the granting of the exemptions is that FCS maintains the equipment, procedures and personnel for implementation of SFP mitigation strategies in the unlikely event of a beyond design-basis-accident. This is also maintained as a condition to the operating license.

Please provide a basis for this statement or revise the application to align with continued license commitment under proposed EP exemption to maintain SFP mitigation strategies.

Response

The "additional compensatory actions" being referred to in Reference 1 refer to those actions that would no longer be required upon NRC approval of the regulatory exemptions from portions of Part 50 of Title 10 of the Code of Federal Regulations (1 0 CFR 50) to reflect the risk associated with the permanent cessation of power operations and permanent removal of fuel from the reactor vessel. OPPD requested regulatory exemptions by letter dated December 16, 2016 (Reference 2).

As described in Reference 2 and the proposed PDEP included in Enclosure 1 of Reference 1,

FCS maintains procedures and strategies for the movement of any necessary portable equipment that will be relied upon for mitigating the loss of Spent Fuel Pool (SFP) water. These mitigative strategies are maintained in accordance with License Condition 3.G of the FCS Renewed Facility Operating License. These diverse strategies provide defense-in-depth and ample time to provide makeup water or spray to the SFP prior to the onset of zirconium cladding ignition when considering the very low probability beyond design basis events affecting the SFP.

For clarity, the reference to "additional compensatory actions" has been removed from Reference 1. The revisions to Reference 1 are included in Attachment 2 of this response.

Section 3.1, "Accident Analysis Overview," in Attachment 1 provides the following, in part:

According to the EPA, "Protective Action Guides and Planning Guidance for Radiological Incidents, Draft for Interim Use and Public Comment," dated March 2013 (Reference 6), Section 2.3.5, "PAGs and Nuclear Facilities Emergency Planning Zones (EPZ)," EPZs are not necessary at those facilities where it is not possible for PAGs to be exceeded offsite.

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

LIC-17 -004 7 Page 3

Response

As noted in the Request for Additional Information (RAI), the U.S. Environmental Protection Agency (EPA) issued a revision to the EPA Protective Action Guides (PAGs) following submittal of Fort Calhoun Station's (FCS) letter, License Amendment Request 16-07: Revise the Fort Calhoun Station Emergency Plan to the Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme," dated December 16, 2016 (LIC-16-0108) (ML16351A464) (Reference 1). In January 2017, EPA's "Protective Action Guides and Planning Guidance for Radiological Incidents, EPA-400/R-17/001,"(ADAMS Accession No. ML17044A073) (EPA PAG Manual) was issued.

Revised Federal guidance provided in EPA-400/R-17/001 states that the Emergency Planning Zone (EPZ) is based on the maximum distance at which a PAG might be exceeded. FCS has developed an analysis indicating that 530 days (1 year, 165 days) after permanent cessation of power operations, no credible accident at FCS will result in radiological releases requiring offsite protective actions. The analysis of the potential radiological impact of the postulated accident for FCS in a permanently defueled condition indicates that any releases beyond the site boundary are limited to small fractions of the EPA PAG exposure levels. The revisions to Reference 1 are included in Attachment 2 of this response.

In addition to the citation in Section 3.1 of Reference 1, the draft EPA PAG Manual is also referenced in Section 1.0, Section 1.1, Section 11.2, and Table 11.1 of the proposed PDEP included as Enclosure 1 in Reference 1. The proposed PDEP has been revised to address current Federal guidance provided in EPA-400/R-17/001 and these revisions are included in of this response.

RAI-FCS-3 Section 3.7, "Permanently Defueled Emergency Plan," in Attachment 1 provides the following, in part:

Notification of an emergency declaration will be made to State and County authorities within 60 minutes of an emergency declaration or change in classification. Because of the geographic location of FCS, emergency planning and responsibilities have historically involved coordination with the States of Nebraska and Iowa.

Decommissioning-related emergency plan submittals for FCS have been discussed with offsite response organizations since OPPD provided notification that it would permanently cease power operations. These discussions have addressed changes to onsite and offsite emergency preparedness throughout the decommissioning process, including the proposed 30-minute emergency declaration time and the 60-minute notification time to the State of Nebraska. Emergency management officials with both states have agreed that these proposed changes are appropriate.

(emphasis added)

Please provide any documentation of discussions with the State of Iowa and Harrison County indicating agreement that notification of an emergency declaration or change in classification is not required, as well as notification of whether a radiological release is taking place. [NOTE: A criteria in the NRC's approval of EP exemption per NSIR/DPR-ISG-02, is that in the likely event of a SFP accident where licensee mitigation strategies may not preclude a significant radiological release, adequate time would exist for offsite officials to implement protective measures for the public if warranted.]

LIC-17-0047 Page4

Response

FCS will provide notifications of an emergency declaration to the States of Nebraska and Iowa within 60 minutes after an emergency declaration or a change in classification. The States of Nebraska and Iowa will provide notification of an emergency declaration to Washington County (Nebraska) and Harrison County (Iowa). The revisions to Reference 1 are included in of this response. Corresponding changes have been made to the proposed PDEP to document the notification to the States of Nebraska and Iowa and are included in Attachment 3 of this response.

Cognizant officials with the States of Nebraska and Iowa, Washington County (Nebraska), and Harrison County (Iowa) have reviewed the proposed communications, as described, and concurrence is documented in letters maintained on file at FCS.

RAI-FCS-4 Section 3.8.3, "State and Local Government Review of Proposed Changes," in states:

State and local emergency management officials are advised of EAL [emergency action levels] changes that are implemented.

Section IV.B.1 of Appendix E to 10 CFR Part 50 states, in part that "emergency action levels shall be reviewed with the State and local government authorities on an annual basis." Please provide additional clarification (see Exemption RAI-002).

Response

FCS will continue to include the State of Iowa and Harrison County in the annual EAL review.

The revisions to Reference 1 are included in Attachment 2 of this response. Corresponding changes have been made to the proposed PDEP to document the annual review with Iowa and Harrison County and are included in Attachment 3 of this response.

RAI-FCS-5 Section 2.1, "Facility On-Shift Organization," in Enclosure 1 provides the following, in part:

The minimum staff required to conduct routine and immediate emergency mitigation is maintained on-shift 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.

Section 15.1.1, "Emergency Response Organization Training," in Enclosure 1 provides the following, in part:

Personnel assigned to liaison with offsite fire departments are trained in accordance with the Fire Protection Program, including mitigating strategies required for a catastrophic loss of SFP inventory.

LIC-17-0047 Page 5 Page 33 of Attachment 1 to the application dated September 2, 2016, "License Amendment Request (LAR) 16-02: Revise the Fort Calhoun Station Emergency Plan to Address the Permanently Defueled Condition," (ADAMS Accession No. ML16246A321) provides the following:

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.

However, there is no reference to any personnel specifically assigned to perform SFP inventory makeup strategies in the proposed PDEP. Please explain who performs SFP inventory makeup strategies in the proposed on-shift staffing and verify that the strategies can be implemented by the on-shift personnel within two hours, without interfering with other designated PDEP actions. Additionally, if the personnel are in addition to the identified on-shift staffing, this need to be identified in the PDEP on in Table 2.1, "On-Shift and Emergency Response Organization Staffing Requirements."

Response

The application dated September 2, 2016, "License Amendment Request (LAR) 16-02: Revise the Fort Calhoun Station Emergency Plan to Address the Permanently Defueled Condition,"

(Reference 3) referred to in the RAI addresses proposed changes to the FCS emergency plan to address the post-shutdown condition. The emergency plan included in that submittal would be replaced by the proposed PDEP included as Enclosure 1 of Reference 1 after spent fuel stored in the SFP will have decayed to the point where the requested exemptions, PDEP, and Permanently Defueled EAL scheme may be implemented.

Section 9.2 (Corrective Actions) of the proposed PDEP included as Enclosure 1 of Reference 1 refers to License Condition 3.G in the following manner:

FCS maintains procedures and strategies for the movement of any necessary portable equipment that will be relied upon for mitigating the loss of SFP water. These mitigative strategies are maintained in accordance with License Condition 3. G of the FCS Renewed Facility Operating License and Technical Specifications. These diverse strategies provide defense-in-depth and ample time to provide makeup water or spray to the SFP prior to the onset of zirconium cladding ignition when considering very low probability beyond design basis events affecting the SFP.

Table 2.1, "On-Shift and Emergency Response Organization Staffing Requirements," includes an "*" next to the Non-Certified Operator (NCO), Shift Manager (SM), and the on-shift Radiation Protection Technician indicating these positions are on-shift personnel required to direct or perform site-specific mitigation strategies required for a catastrophic loss of SFP inventory.

The mitigative strategies maintained in accordance with License Condition 3.G(b)7 of the FCS Renewed Facility Operating License specific to implementation of NEI 06-12, "B.5.b Phase 2 and 3 Submittal Guideline, Rev 2, December 2006," (ADAMS Accession Number ML070090060) table A.2-2 can be performed by the proposed on-shift crew within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> without impacting the performance of designated emergency plan functions. The ability to perform the required actions within the specified time is documented and retained at the station for review utilizing the FCS Operator Response Time Program.

LIC-17-0047 Page 6 RAI-FCS-6 NUREG-0654 Criteria L.1, in Attachment 1 to NSIR/DPR-ISG-02, states:

Each licensee shall arrange for hospital and medical services having the capability for evaluation of radiation exposure and uptake, including assurance that persons providing these services are adequately prepared to handle contaminated individuals.

Section 1.1, "Overview of the Permanently Defueled Emergency Plan," of Enclosure 1 states:

Fixed medical services are provided by Blair Hospital to provide medical support for work related injuries, and University of Nebraska Medical Center in Omaha, which maintains a regional Radiation Health Center that provides services for the treatment of radiologically contaminated injuries and radiation exposure evaluation.

Section 12.0, "Medical and Health Support," of Enclosure 1 states:

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

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

Response

Blair Hospital has agreed to provide medical support for work-related injuries. However, for the treatment of radiologically contaminated injuries and radiation exposure evaluations, FCS maintains an agreement with the University of Nebraska Medical Center (UNMC). Sections 3.1.4 and 12.0 of the proposed PDEP have been revised to clarify that Blair Hospital does not provide medical treatment for radiologically contaminated injuries and radiation exposure. The revisions to the proposed PDEP are included in Attachment 3 of this response.

RAI-FCS-7 NUREG-0654 Criterion 8.9, in Attachment 1 to NSIR/DPR-ISG-02, states:

Reference to the arrangements and agreements reached with contractor, private, and local support agencies shall be appended to the plan.

Section 3.0, "Emergency Response Support and Resources," of Enclosure 1 states:

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

LIC-17 -0047 Page 7 Please clarify why references to the letters of agreement, identifying the specific organizations, are not included as an Appendix to the proposed PDEP, or revise accordingly.

Response

The practice of maintaining Letters of Agreement on file in the Emergency Planning Department at FCS, rather than including them in an Appendix to the emergency plan, is consistent with the current practices at FCS. The current Radiological Emergency Response Plan for Fort Calhoun Station includes a listing of written agreements establishing the concept of operations developed between FCS and offsite support organizations having an emergency response role in an Appendix. However, the appendix contains a note stating that copies of the current Letters of Agreement are on file in the Emergency Planning Department. Rather than include the listing in an appendix to the proposed PDEP, details of offsite response organization responsibilities are described in Section 3.0 of the proposed PDEP and are contained in their respective Letters of Agreement between each organization and OPPD.

RAI-FCS-8 NUREG-0654 Criteria E.4, in Attachment 1 to NSIR/DPR-ISG-02, states:

The licensee, in coordination with State and local organizations, shall establish the contents of the emergency messages to be sent from the nuclear facility. These messages shall contain the following information if it is known and appropriate:

a. location of incident and name and telephone number (or communications channel identification) of caller;

b. date/time of incident;

c. class of emergency;

k. licensee emergency response actions underway;

m. request for any needed onsite support by offsite organizations; and

n. prognosis for worsening or termination of event based on facility information Section 5.1.2, "State and Local Government Notification," of Enclosure 1 states:

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

Please explain why remaining criteria is not addressed in the proposed PDEP, or provide documentation of agreement by applicable State and local organizations to proposed initial message content.

Response

The emergency notification will include the information identified in the RAI. Section 5.1.2 of the proposed PDEP has been revised to include the information contained in Criteria E.4 of NUREG-0654 included in Attachment 1 to NSIR/DPR-ISG-02, "Interim Staff Guidance, Emergency Planning Exemption Requests for Decommissioning Nuclear Power Plants," dated May 11, 2015 (ML14302A490). The revisions to the proposed PDEP are included in of this response.

LIC-17-0047 Page8 RAI-FCS-9 NUREG-0654 Criterion K.3.a and b, in Attachment 1 to NSIR/DPR-ISG-02, state:

a. Each licensee shall make provision for 24-hour-per-day capability to determine the doses received by emergency personnel involved in any nuclear accident, including volunteers. Each licensee shall make provisions for distribution of dosimeters.

b. Each licensee shall ensure that dosimeters are read at appropriate frequencies and provide for maintaining dose records for emergency workers involved in any nuclear accident.

No reference to these statements could be found in Section 11.0, "Radiological Exposure Control," of Enclosure 1. Please explain why these criteria are not addressed in the proposed PDEP, or revise accordingly to address.

Response

Section 11.2 of the proposed PDEP addresses exposure control and issuance of Dosimeters of Legal Record (DLR) as a means of recording radiation exposure for permanent records. Dose records are maintained in accordance with facility procedures. FCS maintains the capability for emergency processing of DLRs on a 24-hour per day basis. DLRs may be processed with increased periodicity during an emergency response. Additionally, personnel are issued electronic alarming dosimetry capable of measuring dose and dose rate on a real-time basis.

These dosimeters indicate dose on a digital display and are programmed to provide an audible alarm at a pre-determined dose or dose rate limit, thereby alleviating the need for the user to read dosimetry at a defined frequency.

Section 11.2 of the proposed PDEP has been revised to address the information contained in Criteria K.3.a and b of NUREG-0654 included in Attachment 1 to NSIR/DPR-ISG-02. The revisions to the proposed PDEP are included in Attachment 3 of this response.

RAI-FCS-10 NUREG-0654 Criterion K.5.a and b, in Attachment 1 to NSIR/DPR-ISG-02, state:

a. Each licensee, as appropriate, shall specify action levels for determining the need for decontamination.

b. Each licensee, as appropriate, shall establish the means for radiological decontamination of emergency personnel wounds, supplies, instruments and equipment, and for waste disposal.

No reference to these statements could be found in Section 11.0 of Enclosure 1. Please explain why these criteria are not addressed in the proposed PDEP, or revise accordingly to address.

Ll C-17 -004 7 Page 9

Response

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

These measures may consist of the establishment of contamination control boundaries to minimize the spread of contamination and monitoring of personnel evacuating the affected area using installed monitors in the Security Building or personnel with portable equipment.

Contaminated areas are isolated as restricted areas with appropriate radiological protection and access control. Personnel leaving contaminated areas are monitored to ensure both themselves and their clothing are not contaminated. Supplies, instruments, and equipment that are in contaminated areas or have been brought into contaminated areas will be monitored prior to removal. Items found to be contaminated will be decontaminated using normal plant decontamination techniques and facilities or may be disposed of as radioactive waste in accordance with Radiation Protection Manual requirements.

If personnel decontamination becomes necessary, decontamination is performed under the direction of the Radiation Protection Coordinator. Contaminated personnel that are evacuated will be decontaminated as determined by Radiation Protection personnel. If the contaminated individual has an injury involving contamination, efforts to decontaminate the injured person to reasonable levels are made prior to transfer to offsite medical facilities. If decontamination is not practical, the injured person is covered in such a manner as to minimize the spread of contamination until either medical aid can be obtained or until the injured person can be transported to the UNMC Radiation Health Center. Additional decontamination facilities are available at the UNMC Radiation Health Center. Radioactive waste is controlled to ensure that the contents are monitored and processed, if necessary.

Priorities for decontaminating tools, equipment, and areas will be established by the Emergency Director, with top priority given to contamination within areas that are or will be inhabited by emergency workers. Decontamination of non-essential areas, tools, and equipment should be delayed to allow for natural decay of radioactive materials.

Section 11.3 of the proposed PDEP has been revised to address the information contained in Criteria K.5.a and b of NUREG-0654 included in Attachment 1 to NSIR/DPR-ISG-02. The revisions to the proposed PDEP are included in Attachment 3 of this response.

RAI-FCS-11 NUREG-0654 Criteria F.2, in Attachment 1 to NSIR/DPR-ISG-02, states:

Each licensee shall ensure that a coordinated communication link for medical support exists.

Section 12.0, "Medical and Health Support," of Enclosure 1 states:

FCS is capable of maintaining communications with the ambulance while transporting a patient.

LIC-17-0047 Page 10 The proposed PDEP provides no specifics on the method of communications, nor is there any reference to communication methods with the Blair Hospital and the University of Nebraska Medical Center in Omaha.

Please provide a description of the methods of communications to be used between FCS and Blair Hospital and the University of Nebraska Medical Center.

Response

FCS ERO personnel can communicate with Blair Hospital, the UNMC, the Washington County Emergency Communications Center, and mobile rescue units via the site telephone system described in Section 6.2.2 of the proposed PDEP. Wireless communications serve as the backup means of communication. When FCS personnel accompany a contaminated and/or injured employee during transport, portable radios identified in Section 6.2.4 of the proposed PDEP may be utilized by station personnel and ERO personnel to communicate with the ambulance. In addition, non-OPPD radio systems provide communications between medical support facilities and mobile rescue units as well as inter-unit communications. These radio systems have the capability to use the common medical emergency frequency which ensures coordinated communications.

Section 12.0 of the proposed PDEP has been revised, and Section 6.3 (Communications with Medical Support Facilities) has been added to the proposed PDEP to address the information contained in Criteria F.2 of NUREG-0654 included in Attachment 1 to NSIR/DPR-ISG-02. The revisions to the proposed PDEP are included in Attachment 3 of this response.

RAI-FCS-12 NUREG-0654 Criteria N.3.c, in Attachment 1 to NSIR/DPR-ISG-02, states:

A medical emergency drill involving a simulated contaminated individual which contains provisions for participation by the local support services agencies (i.e., ambulance and offsite medical treatment facility) shall be conducted annually.

Section 12.0, "Medical and Health Support," of Enclosure 1 states:

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

However, Section 14.2.1, "Medical Drills," of Enclosure 1 states:

The University of Nebraska Medical Center Radiation Health Center is invited to participate in an annual exercise and/or scheduled drill(s) to demonstrate and practice the receipt and treatment of contaminated patients.

It appears that the PDEP does not address Blair Hospital as also being invited to participate in the annual exercise and/or scheduled drill(s). Additionally, there is no provision for participation of the Emergency Medical Service (EMS) organizations (i.e., victim/patient transport) in the annual exercise and/or scheduled drill(s).

LIC-17-0047 Page 11 Please explain why these areas are not addressed in the proposed PDEP, or revise accordingly to address.

Response

As described in the response to RAI-FCS-6, Blair Hospital provides medical support for work-related injuries. However, for the treatment of radiologically contaminated injuries and radiation exposure evaluations, FCS maintains an agreement with the UNMC. Sections 3.1.4 and 12.0 of the proposed PDEP have been revised to clarify that Blair Hospital does not provide medical treatment for radiologically contaminated injuries and radiation exposure.

Section 14.2.1 of the proposed PDEP states that involvement by medical transport services in the annual medical emergency drill may be included as part of any drill or exercise. However, for clarity, Section 14.2.1 of the proposed PDEP has been revised to state that the ambulance service is invited to participate in the annual exercise and/or scheduled drill to address the information contained in Criteria N.3.c of NUREG-0654 included in Attachment 1 to NSIR/DPR-ISG-02. The revisions to the proposed PDEP are included in Attachment 3 of this response.

RAI-FCS-13 NUREG-0654 Criteria 0.3, in Attachment 1 to NSIR/DPR-ISG-02, states:

"Training for individuals assigned to licensee first aid teams shall include courses equivalent to Red Cross First Aid, CPR, AED for Lay Responders or equivalent."

Section 12.0, "Medical and Health Support," of the proposed PDEP states:

FCS maintains on shift personnel and equipment to provide first aid for personnel working at the site.

Please provide further information on who these personnel are on-shift (e.g., is duty performed as a collateral function), and what level and frequency of training they are given.

Response

Personnel assigned the responsibility for responding to a medical emergency at FCS receive the American Red Cross Standard First Aid Training Program, or equivalent. These personnel typically consist of on-shift personnel included in Table 2.1 of the proposed PDEP and perform the function as a collateral duty. To maintain qualifications in accordance with the American Red Cross, CPR is conducted annually and First Aid Training is provided biannually. The associated training records are maintained in accordance with Training Department procedures.

Table 2.1 of the proposed PDEP has been revised to indicate that the first aid duties are assigned to on-shift personnel assigned other functions. Additionally, Section 15.0 of the proposed PDEP has been revised to include a section on first aid training (new Section 15.1.4) as described in this response to address the information contained in Criteria 0.3 of NUREG-0654 included in Attachment 1 to NSIR/DPR-ISG-02. The revisions to the proposed PDEP are included in Attachment 3 of this response.

LIC-17-0047 Page 12 RAI-FCS-14 NUREG-0654 Criterion P.3 and P.5, in Attachment 1 to NSIR/DPR-ISG-02, states:

3. Each licensee shall designate an Emergency Planning Coordinator with responsibility for the development and updating of emergency plans and coordination of these plans with other response organizations

5. The emergency response plans and approved changes to the plans shall be forwarded to all organizations and appropriate individuals with responsibility for implementation of the plans. Revised pages shall be dated and marked to show where changes have been made."

Section 16.0, "Responsibility for the Planning Effort: Periodic Review and Distribution of Emergency Plans," of Enclosure 1 does not specifically address these criteria. Please explain why these criteria are addressed in the proposed PDEP, or revise accordingly to address.

Response

To specifically address the guidance provided in Criteria 0.3 of NUREG-0654 included in to NSIR/DPR-ISG-02, Section 16.0 of the proposed PDEP has been revised to specifically refer to the Manager-Emergency Planning as the position responsible for the development and updating of emergency plans and coordination of emergency planning activities with off-site response organizations. Section 16.1 of the proposed PDEP has been revised to indicate that the Manager-Emergency Planning is responsible for providing approved changes to the organizations and individuals responsible for implementing the emergency plan. The revisions to the proposed PDEP are included in Attachment 3 of this response.

References:

1.

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

(CAC MF8951)

2.

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

3.

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 (UC-16-0076)

(ML16246A321) (CAC MF8326)

LIC-17 -004 7 Page 1 ATTACHMENT 2 REVISED PAGES OF LICENSE AMENDMENT REQUEST 16-07 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION. UNIT NO.1 DOCKET NO. 50-285

U.S. Nuclear Regulatory Commission LIC-16-01 08 Page 2 On November 13, 2016 (Reference 3), pursuant to 10 CFR 50.82(a)(1)(ii), OPPD certified that the fuel has been permanently removed from the reactor vessel and placed in the spent fuel pool.

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

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

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

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

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

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

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

LIC-16-0108 Page4 On August 25,2016, pursuant to 10 CFR 50.82(a)(1)(i) and 10 CFR 50.4(b)(8), OPPD certified to the NRC that FCS would permanently cease power operations on October 24, 2016 (Reference 2). On November 13, 2016 (Reference 5), pursuant to 10 CFR 50.82(a)(1 )(ii), OPPD certified that the fuel has been permanently removed from the reactor vessel and placed in the SFP. Upon docketing of the certifications for permanent cessation of power operations (1 0 CFR 50.82(a)(1 )(i)) and permanent removal of fuel from the reactor vessel (1 0 CFR 50.82(a)(1 )(ii)), pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for FCS no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel. The irradiated fuel will be stored in the SFP and/or the ISFSI until it is removed by the DOE.

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

3.0 TECHNICAL EVALUATION

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

A summary of the postulated radiological accidents analyzed for the permanently shutdown and defueled condition is presented below. According toCurrent Federal guidance provided in the EPA, "Protective Action Guides and Planning Guidance for Radiological Incidents, Draft for Interim Use and Public CommentEPA-400/R-17/001," dated March 2013Januarv 2017 (Reference 6), states that the EPZ is based on the maximum distance at which a PAG might be exceededSection 2.3.5, "PAGs and Nuclear Facilities Emergency Planning Zones (EPZ)," EPZs are not necessary at those facilities 'A'here it is not possible for PAGs to be exceeded offsite.

Section 5.0 of Interim Staff Guidance (ISG)- 02 (Reference 7) indicates that site-specific analyses should demonstrate that: (1) the radiological consequences of the remaining applicable postulated accidents would not exceed the limits of the EPA PAGs at the Exclusion Area Boundary (EAB); (2) in the event of a beyond design basis event resulting in the partial drain down of the SFP to the point that cooling is not effective, there is at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> (assuming an adiabatic heat up) from the time that the fuel is no longer being cooled until the hottest fuel assembly reaches 900 degrees Celsius (

0 C); (3) adequate physical security is in place to assure implementation of security strategies that protect against spent fuel sabotage; and (4) in the unlikely event of a beyond design basis event resulting in a loss of all SFP cooling, there is sufficient time to implement pre-planned mitigation measures to provide makeup or spray to the SFP before the onset of a zirconium cladding ignition.

LIC-16-01 08 Page9 FCS conducted a seismic evaluation in response to a NRC request for information pursuant to 10 CFR 50.54(f) regarding Recommendation 2.1 of the Near-Term Task Force (NTTF) Review of Insights from the Fukushima Dai-ichi Accident. The seismic evaluation included all structures including the SFP, and was prepared and submitted for NRC review. The OPPD submittal (LIC-14-0047) (Reference 14) documents the seismic evaluation in conformance with NTTF Recommendation 2.1 including the high confidence of a low-probability of seismic failure (HCLPF) values and the 1 x 1 o-5 per year hazard level. The Staff review of the NTTF submittal, specifically for the SFP Evaluation associated with the reevaluated seismic hazard implementing NTTF Recommendation 2.1 (CAC No. MF3735) is documented in NRC-16-0068 (ML16182A361) (Reference 15). The NRC staff concluded that the assessment was performed consistent with the NRC-endorsed (ML15350A158) (Reference 16) SFP Evaluation Guidance Report (Reference 17) and provided sufficient information, including the SFP integrity evaluation, to meet the SFP Evaluation Guidance (Item 9 in Enclosure 1 of the NRC's 50.54(f) letter). The FCS response to other beyond design basis environmental events are also addressed in Tables 4 and 5 of Reference 1.

3. 7 Permanently Defueled Emergency Plan The FCS PDEP is provided as Enclosure 1 of this submittal for NRC review and approval. The PDEP describes FCS's plan for responding to emergencies that may arise while in a permanently shutdown and defueled configuration. The PDEP was developed considering the guidance contained within Attachment 1 of ISG-02 (Reference 7).

The analyses of the potential radiological impact of accidents while the facility is in a permanently shutdown and defueled condition indicate that no postulated accident or reasonably conceivable beyond design basis event will be expected to result in radioactive releases that exceed EPA PAGs beyond the site boundary. The slow progression rate of postulated event scenarios indicate sufficient time is available to initiate appropriate mitigating actions to protect the health and safety of the public (Reference 1 ). Therefore, the proposed PDEP states that FCS will maintain the ability to assess, classify, and declare an emergency within 30 minutes after the availability of indications to operators that an EAL threshold has been reached. Emergency declaration is required to be made as soon as conditions warranting classification are present and recognizable, but within 30 minutes in all cases of conditions being present. Notification of an emergency declaration will be made to States and Countyof Nebraska and Iowa authorities within 60 minutes of an emergency declaration or change in classification. Because of the geographic location of FCS, emergency planning and responsibilities have historically involved coordination with the States of Nebraska and Iowa.

Decommissioning-related emergency plan submittals for FCS have been discussed with offsite response organizations since OPPD provided notification that it would permanently cease power operations. These discussions have addressed changes to onsite and offsite emergency preparedness throughout the decommissioning process, including the proposed 30-minute emergency declaration time and the 60-minute notification time to the State of Nebraska. The States of Nebraska and Iowa will provide notification of an emergency declaration to Washington County (Nebraska) and Harrison County (Iowa). Emergency management officials with both states. Washington County (Nebraska), and Harrison County (Iowa) have agreed that these proposed changes are appropriate.

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

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

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

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

3.8.3 State and Local Government Review of Proposed Changes State and loeal emergency management offieials are advised of EAL ehanges that are implemented. Following NRC approval and prior to implementation, FCS will provide an overview of the new classification scheme to State and local emergency management officials in accordance with 10 CFR Part 50, Appendix E, Section IV.B.1. FCS will continue to review EALs with the States of Nebraska and Iowa, Washington County (Nebraska), and Harrison County (Iowa) on an annual basis.

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

This proposed amendment would revise the FCS Emergency Plan and the EAL scheme to reflect the permanently shutdown and defueled condition following 530 days of decay of the spent fuel. The proposed PDEP and Permanently Defueled EAL scheme are being submitted to the NRC for approval prior to implementation, as required under 10 CFR 50.54(q)(4) and 1 0 CFR Part 50, Appendix E,Section IV.B.2.

4.0 REGULATORY EVALUATION

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

LIC-16-0108 Page 17

6.0 REFERENCES

1. OPPD Letter (S. Marik) to US NRC (Document Control Desk)- "Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR Part 50, Appendix E," dated December 16, 2016 (LIC-16-01 09)

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

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

4. Letter, Mark Thaggard (USNRC) to Susan Perkins-Grew (NEI), "U.S. Nuclear Regulatory Commission Review and Endorsement of NEI99-01," Revision 6, dated November, 2012 (TAC No. D92368), dated March 28, 2013 (ML12346A463)

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

(ML16319A254)

6. U.S. Environmental Protection Agency, "Protective Action Guide and Planning Guidance for Radiological Incidents, EPA-400/R-17/001 " Draft for Interim Use and Public Comment, dated Marsh 2013January 2017 (EPA PAG Manual)

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

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

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

10. NUREG-1738, "Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants," dated February 2001 (ML010430066) 11. NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities," dated October 2002

12. Regulatory Guide 1.17 4, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis"

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

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

LIC-17 -004 7 Page 1 ATTACHMENT 3 REVISED PAGES OF THE PROPOSED PERMANENTLY DEFUELED EMERGENCY PLAN OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION. UNIT N0.1 DOCKET NO. 50-285

FCS PERMANENTLY DEFUELED EMERGENCY PLAN

1.0 INTRODUCTION

EP-FC-1001 Revision 0 The Permanently Defueled Emergency Plan (PDEP) describes the plan for responding to emergencies that may arise at Fort Calhoun Station (FCS), while in a permanently shut down and defueled configuration. FCS has provided certification to the U.S. Nuclear Regulatory Commission (NRC) required by 10 Code of Federal Regulation (CFR) 50.82(a)(1 )(i) and (ii) that FCS has permanently ceased power operations and that all fuel has been permanently removed from the reactor vessel. In this configuration, all irradiated fuel is stored in the Independent Spent Fuel Storage Installation (ISFSI) and in the Spent Fuel Pool (SFP). In this condition, no reactor operations can take place and the facility is prohibited from emplacement or retention of fuel in the reactor vessel. The PDEP adequately addresses the risks associated with FCS's current conditions.

The analyses of the potential radiological impacts of postulated accidents in a permanently defueled condition indicates that any releases beyond the Site Boundary would be below the Environmental Protection Agency (EPA) Protective Action Guide (PAG) exposure levels, as detailed in the EPA's "Protective Action Guide and Planning Guidance for Radiological Incidents, EPA-400/R-17-001 " Draft for Interim Use and Public Comment dated March 2013January 2017 (EPA PAG Manual). No remaining postulated accidents will result in radiological releases requiring offsite protective actions and the slow progression rate of beyond design basis accident scenarios indicate sufficient time is available to initiate appropriate mitigating actions to protect the health and safety of the public. Therefore, the PDEP adequately addresses the risk associated with FCS's permanently defueled condition and continues to provide adequate protection for plant personnel and the public. Exemptions from the applicable portions of 10 CFR 50.47(b), Appendix E to 10 CFR Part 50, and 10 CFR 50.47(c)(2) were previously approved by the NRC.

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

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

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

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

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

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

Revision 6, November 2012, has been discussed and agreed upon with responsible offsite organizations and is compatible with their respective emergency plans. According to the EPA PAG Manual, the EPZ is based on the maximum distance at which a PAG might be exceeded."Emergency Planning Zones are not necessary at those facilities where it is not possible for PAGs to be exceeded o:ffsite." If determined appropriate by government officials, protective actions may be implemented to protect the public using the existing all hazards emergency planning.

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

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

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

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

There are no postulated accidents that would result in offsite dose Page2

FCS PERMANENTLY DEFUELED EMERGENCY PLAN 2.1 Facility On-5hift Organization EP-FC-1001 Revision 0 During normal conditions, the minimum staff on duty at the facility during all shifts consists of one (1) Shift Manager, one (1) Non-Certified Operator (NCO), one (1)

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

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

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

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

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

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

Other Emergency Director responsibilities:

Notification of the emergency classification to the NRC, State§,

and County.

Management of resources available to the facility Coordination of mitigative actions Coordination of corrective actions Coordination of onsite protective actions Decision to call for offsite assistance Coordination of Security activities Termination of the emergency condition when appropriate Performance of initial dose assessment Page 6

FCS PERMANENTLY DEFUELED EMERGENCY PLAN On-Shift and E TABLE 2.1 0

Staffina R

1. ON-FCS AUGMENTED EP-FC-1001 Revision 0 MAJOR FUNCTIONAL AREA LOCATION FCS STAFF SHIFT CAPABILITY (120 MIN.)

Operations and assessment of Control Non-Certified 11 Operational Aspects Room/On-Scene Operator*

Emergency Direction & Control Control Room Shift Manager*

11 Notification/Communication Control Room Radiological Accident Assessment As Directed by Radiation 1 (may augment with and Support of Operational the Emergency Protection Radiation Monitoring Accident Assessment Director Coordinator personnel if necessary)

Protective Actions (In-Facility)

On-Scene Radiation 1

Protection Technician*

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

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

Rescue Operations/First Aid On-Scene Site Access Control and Per the Security Security Per the Accountability Plan Personnel Security Plan

~ -

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

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

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

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

Page 10

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

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

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

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

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

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

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

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

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

Page 11

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

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

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

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

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

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

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

4.1.1 Notification of Unusual Event NOUE conditions do not cause serious damage to the facility. The purpose of the NOUE declaration is to: 1) bring the ERO to a state of readiness; 2) make required and needed notifications; 3) provide for Page 12

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

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

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

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

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

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

5.0 NOTIFICATION METHODS AND PROCEDURES The decision to make notifications is based on the emergency action levels and corresponding emergency classifications described in Section Q-4.0 of this Plan. OPPD is capable of notifying and activating its Emergency Response Organization 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. It is also able to make notifications to the State§ of Nebraska and Washington Countylowa, and the NRC on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day basis.

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

FCS personnel in the Protected Area are notified via the Emergency or Fire Alarm and a public address system message. If required, personnel outside the Protected Area are notified by public address systems installed in the buildings outside the Page 13

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

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

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

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

Location of the incident; Name and telephone number (or communications channel identification) of caller; Date and time of the incident; Class of emergency; Licensee emergency response actions underway; Reguest for any needed onsite support by offsite organizations; and Prognosis for worsening or termination of event based on facility information Page 14

FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN In the event the commercial telephone system is unavailable, wireless communications can be used to make emergency notifications. In addition, electronic means may be used to transmit the notification message.

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

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

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

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

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

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

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FCS PERMANENTLY DEFUELED EMERGENCY PLAN 6.3 Communications with Medical Support Facilities EP-FC-1001 Revision 0 Several modes of communication are available to facility staff to maintain communications with medical support facilities and mobile rescue units during normal and emergency situations.

6.3.1 Telephone System FCS ERO personnel can communicate with Blair Hospital, the UNMC. the Washington County Emergency Communications Center. and mobile rescue units via the site telephone systems described earlier in this section.

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

6.3.3 Non-OPPD Radio Systems Non-OPPD radio systems provide communications between medical support facilities and mobile rescue units as well as inter-unit communications. These radio systems have the capability to use the common medical emergency frequency which ensures coordinated communications.

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

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

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

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

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

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

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

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

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

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

Emergency workers are issued permanent reading dosimeters (e.g., Dosimeter of Legal Record (DLR)) as a means of recording radiation exposure for permanent records prior to entering a RCA. Additionally, personnel are issued electronic alarming dosimetry capable of measuring dose and dose rate on a real:-time basis. These dosimeters indicate dose on a digital display and are programmed to provide an audible alarm at a pre-determined dose or dose rate limit. Dose records are maintained in accordance with facility procedures. DLRs may be processed with increased periodicity during a response to an emergency.

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FCS PERMANENTLY DEFUELED EMERGENCY PLAN EP-FC-1001 Revision 0 The capability exists for the emergency processing of DLRs on a 24-hour per day basis.

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

The Emergency Director is responsible for authorizing personnel to receive doses in excess of 10 CFR Part 20 limits, if necessary. This authorization is coordinated with the Radiation Protection Coordinator when available. Table 11.1 contains the guidelines for emergency exposure criteria, which is consistent with Table ~3-1

, "Response Emergency Worker Guidelines," provided in the EPA PAG Manual.

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

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

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

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

FCS procedures establish requirements and specific action levels for decontamination of personnel, equipment. and areas. and for the release of the affected personnel, equipment, and areas from radiological controls. If actual1 or potential contamination problems exist onsite. the Emergency Director may elect to establish contamination control and monitoring measures. These measures may consist of the establishment of contamination control boundari:es to minimi,ze the spread of contamination and monitoring of personnel evacuating the affected area using irnstalled monitors in the Security Building or personnel with portable equipment.

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

Supplies. instruments. and equipment that are in contaminated areas or have Page 23

FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN been brought into contaminated areas will be monitored prior to removal. Items found to be contaminated. will be decontaminated using normal plant decontamination techniques and facilities or may be disposed of as radioactive waste. Tools. equipment. and areas that become contaminated will be decontaminated as determined by Radiation Protection personnel.

If personnel decontamination becomes necessary, decontamination is performed under the direction of the Radiation Protection Coordinator. Contaminated personnel that are evacuated will be decontaminated as determined by Radiation Protection personnel. If the contaminated individual has an injury involving contamination. efforts to decontaminate the injured person to reasonable levels are made prior to transfer to offsite medical facilities. If decontamination is not practical. the injured person is covered in such a manner as to minimize the spread of contamination until either medical aid can be obtained or until the injured person can be transported to the UNMC Radiation Health Center.

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

Priorities for decontaminating tools. equipment. and areas will be established by the Emergency Director. with top priority given to contamination within areas that are or will be inhabited by emergency workers. Decontamination of non-essential areas. tools. and equipment should be delayed to allow for natural decay of radioactive materials.

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

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

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FCS EP-FC-1001 Revision 0 PERMANENTLY DEFUELED EMERGENCY PLAN Guideline 5 rem 10 rem(a) 25 rem(b)(cJ NOTES:

TABLE 11.1 EMERGENCY EXPOSURE CRITERIA (Refer to Note 1)

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

Exceeding 5 rem is Protecting Valuable unavoidable and all Propertycritical infrastructure appropriate actions have been taken to reduce dose.

necessary for public welfare Monitoring available to project or measure dose.

Exceeding 5 rem is unavoidable and all Lifesaving or Protection of appropriate actions have been Large Population taken to reduce dose.

Monitoring available to project or measure dose.

1.

Reference for this table is Table 2--23-1 of the EPA PAG Manual.

(a)

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

(b)

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

(c)

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

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

If immediate professional medical help is needed, local ambulance services are available to transport seriously ill, injured, or radioactively contaminated injured personnel. Patients can also be transported to the facility via medical ambulance helicopters. FCS is capable of maintaining communications with #le--medical support facilities and the local ambulance service while transporting a patient. These capabilities are described in Section 6.3.

An agreementjs afe--in place with Blair Hospital and University of Nebraska Medioal CenterUNMC in Omaha for medical treatment of patients from FCS who have injuries complicated by radioactive contamination. These hospitals ha§ve trained personnel and detailed procedures for handling radioactively contaminated patients from FCS.

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

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

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

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

The recovery organization's responsibilities include:

Maintaining comprehensive radiological surveillance of the facility to assure continuous control and recognition of problems Controlling access to the area and exposure to workers Decontaminating affected areas and/or equipment Page 26

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

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

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

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

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

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

15.1.4 First Aid Training Personnel assigned the responsibility for responding to a medi'cal emergency at FCS receive the American Red Cross Standard First Aid Training Program. or equivalent. To maintain qualifications in accordance with the American Red Cross, CPR is conducted annually and First Aid Training is provided biannually. The associated training records are maintained in accordance with Training Department procedures.

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

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

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

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

16.1 Document Maintenance 16.1.1 Review and Update of the PDEP and EPIPs The FCS PDEP, Permanently Defueled EAL Technical Bases, and the EPIPs included in Appendix A are reviewed annually and updated as needed. All proposed changes will be reviewed in accordance with 10 CFR 50.54(q) to ensure that the change would not compromise the effectiveness of any other EPIP or degrade the effectiveness of the PDEP. The Manager-Emergency Planning is responsible for forwarding Page 31

FCS PERMANENTLY DEFUELED EMERGENCY PLAN EP-FC-1001 Revision 0 approved changes to the plan to appropriate organizations and individuals with responsibility for implementation of the plan.

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

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

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

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

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

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

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