LIC-19-0021, Independent Spent Fuel Storage Installation - Response to Request for Additional Information License Amendment for ISFSI-only EP and EAL Scheme

Independent Spent Fuel Storage Installation - Response to Request for Additional Information License Amendment for ISFSI-only EP and EAL Scheme

ML19325E256
Person / Time
Site:	Fort Calhoun
Issue date:	11/20/2019
From:	Fisher M Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
LIC-19-0021
Download: ML19325E256 (218)

Text

Omaha Public Power District LIC-19-0021 November 20, 2019 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 Fort Calhoun Station Independent Spent Fuel Storage Installation NRC Docket No.72-054

Subject:

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

- Request for Additional Information, OPPD Fort Calhoun License Amendment for ISFSI-only EP and EAL Scheme

References:

1. Letter from OPPD (M. Fisher) to USNRC (Document Control Desk), "License Amendment Request (LAR) 19-01: Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan and Emergency Action Level Scheme," dated February 28, 2019 (LIC-19-0001) (ML19064A758)

2. EMAIL from NRC (J. Parrot) to OPPD (C. Cameron), "Request for Additional Information, OPPD Fort Calhoun License Amendment for ISFSI-only EP and EAL Scheme", dated August 21, 2019 (ML19241A181)

By letter dated February 28, 2019 (Reference 1) (ML19064A758), Omaha Public Power District (OPPD) submitted a License Amendment Request (LAR) to replace the Permanently Defueled Emergency Plan (PDEP) and its associated Emergency Action Level (EAL) technical basis document with the Independent Spent Fuel Storage Installation Only Emergency Plan (IOEP) and its associated EAL technical basis document.

On August 21, 2019 (Reference 2), the NRC provided OPPD with Requests for Additional Information (RAI) regarding some administrative and technical aspects of the LAR. Attachment 1 of this letter provides the responses to the RAI's. Attachments 2 and 3 of this letter provides the necessary changes to Reference 1 resulting from the responses to the RAI. Attachment 4 contains a copy of "Removal of emergency notification to the State of Iowa".

444 SOUTH 16TH STREET MALL

• OMAHA, NE 68102-2247 EMPLOtMENfWITH EQUAL OPPORTUNITY

U. S. Nuclear Regulatory Commission LIC-19-0021 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) 533-6041.

Respec~ully, ._ / .

-n1~1l~

Mary J. Fisher Vice President Energy Production and Nuclear Decommissioning MJF/dmp Attachments: 1. Response to Request for Additional Information

2. Revised Enclosure 1 and Attachments, With Markups

3. Revised Enclosure 1 and Attachments Clean, Without Markups

4. Document- "Removal of emergency notification to the State of Iowa" c: S. A. Morris, NRC Regional Administrator, Region IV J. D. Parrott, NRC Senior Project Manager C. D. Steely, NRC Health Physicist, Region IV Director of Consumer Health Services, Department of Regulation and Licensure, Nebraska Health and Human Services, State of Nebraska

LIC-19-0021 Page 1 ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LICENCE AMENDMENT REQUEST OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION UNIT NO. 1 DOCKET NO. 50-285,72-054 By application dated February 28, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19064A758), Omaha Public Power District requested changes to the Fort Calhoun Station (FCS) Permanently Defueled Emergency Plan (PDEP) pursuant to 10 CFR 50.54(q). The proposed changes replace the FCS PDEP and associated Emergency Action Level (EAL) Technical Bases Document with the Independent Spent Fuel Storage Installation Only Emergency Plan (IOEP) and associated EAL scheme.

The NRC staff has reviewed the licensees application and determined that additional information is needed to enable the NRC staff to complete its technical review:

LIC-19-0021 Page 2

RAI-1

Section 3.1, Elimination of SFP [spent fuel pool] Initiation Conditions and EALS and Alert Classification, of Enclosure 1, Description of Proposed Changes, Technical and Regulatory Evaluation, Significant Hazards Determination, and Environmental Consideration, states, in part (page 6):

Even though a Hostile Action-Based program is not necessary for an ISFSI-only site, precedence from other utilities and regulatory guidance provides that consideration of actions by an adversary for EAL purposes is still applicable. Therefore, the use of the term "ADVERSARIAL ACTION" and the revised definition is included, to reflect those aspects associated with an ISFSI-only site and is utilized in the EALs.

The term adversarial action is not consistent with U.S. Nuclear Regulatory Commission (NRC)

EAL guidance, nor is it consistent with industry precedence. Please provide further technical justification for inconsistency NRC EAL guidance and industry precedence or revise to reflect the term HOSTILE ACTION.

Response

As stated in the LAR and previously approved exemptions, the Hostile Action-Based program is not necessary for an ISFSI-only site. The proposed term ADVERSARIAL, was introduced to minimize confusion for State and Local agencies when determining the type of event in progress. However, precedence from other utilitys Emergency Plans and as required by regulatory review, the consideration of a hostile action for EAL purposes is still applicable.

Therefore, the use of the term "HOSTILE ACTION" and the revised definition is added. The term and usage for HOSTILE replaces the previously requested verbiage ADVERSARIAL in the LAR enclosure 1, including Table 1, the EAL technical basis document Table A-1, classification basis, and definitions, affected EALs and basis, and Attachment 2, Emergency Classification Table. The proposed change is consistent with precedence, and is in Attachment 2 and 3.

LIC-19-0021 Page 3

RAI-2

Section 3.1 of Enclosure 1, (page 6) states, in part:

Judgement EALs are being eliminated as part of this submittal to align with Draft Regulatory Guide 1346. The draft does not include the Judgement EALs as part of the IOEP scheme.

Draft Regulatory Guide 1346 was made publicly available for stakeholder awareness concurrent with the Commissions review of SECY-18-0055, Proposed Rule: Regulatory Improvements for Production and Utilization Facilities Transitioning to Decommissioning (ADAMS Accession No. ML18012A019). As such, reference to this draft regulatory guide to justify changes to an EAL scheme is not justified, since guidance may be revised as part of overall rulemaking.

Please provide further technical justification, other than referencing Draft Regulatory Guide 1346, for inconsistency with existing NRC-endorsed EAL guidance and industry precedence or revise to include EAL declarations based on Emergency Director judgment.

Response

The NRC supported the use of the regulatory basis associated with the Draft Regulatory Guide 1346 during the development and submittal of the LAR. Subsequently, the NRC no longer supports the use basis to develop the IOEP. Therefore, the use of the basis of Draft Regulatory Guide 1346 and nomenclature is revised to that of NEI 99-01, Revision 6. The judgment EALs and basis is added to the LAR enclosure, including Table 1, the EAL technical basis document Table A-1, classification basis, and definitions, the affected EALs and basis, and Attachment 2, Emergency Classification Table. The proposed change is consistent with precedence, and is located in Attachment 2 and 3.

With the replacement of the reference to Draft Regulatory Guide 1346 with NEI 99-01 revision 6, other requirements including the numbering scheme, and other aspects and justifications within the LAR and attachments are also changed. NEI 99-01 Revision 6, provides select guidance for an emergency classification scheme applicable to a ISFSI only station. This provides consistency with precedence sites and align the IOEP documents with the present regulatory standard. The proposed inclusion of PD-HA3 will not include the hostile action portion of the judgment EAL, this portion of the EAL is duplicative to PD-HA1. The proposed change is in and 3.

LIC-19-0021 Page 4

RAI-3

Section 3.1 of Enclosure 1 (page 7) states, in part:

FCS is proposing to base this EAL on a change in radiation levels significant enough to warrant concern for exceeding the limit to dose to the general public as defined in 10 CFR 20.1301(a)(2) of 0.002 Rem (2 mRem) in any one hour. Establishing an EAL threshold of >2 mRem/hr within the ISFSI protected area or on a Horizontal Storage Module (HSM) concrete surface provides a level of margin to maintain protection of the public, while providing an easily identifiable set point for ISFSI personnel. This level of radiation is high enough to minimize instrument error and operational differences while still providing positive indication of an emergency condition.

The current NRC-endorsed EAL scheme indicates that two times (2X) the technical specification limit has dose rates of:

> 1600 mRem/hr on HSM front surface and > 400 mRem/hour on the HSM door centerline.

Based on these limits, it would appear to the staff that the proposed EAL of 2 mRem/hour on a HSM concrete surface would be exceeded normally. Please provide a technical justification for the use of a radiation reading of >2 mRem/hr (gamma) within the ISFSI Protected Area or on a HSM concrete surface.

Response

The two (2) mrem/hr limit on concrete surfaces would not be exceeded under normal conditions.

There is no present or expected incidence of exceeding this value on the NUHOMS HSMs.

The previously proposed value was presented to provide simpler criteria, while still providing a more realistic radiation level limit to distinguish an emergency from normal operation. However, FCS proposes the following change to comply with precedent and reviewer comments.

For FCS, there are three (3) 72-1004, Technical Specifications Amendments that presently govern the operation of the ISFSI. CoC 72-1004, Amendment 8 and Amendment 9 contain the same dose rate requirements and govern the one (1) through ten (10) HSMs. CoC 72-1004, Amendment 15 governs the dose rate requirements for HSM eleven (11) through forty two (42).

Applicable portions of the criterion is below:

Applicable sections of Technical Specifications for the Standardized NUHOMS Horizontal Modular Storage System CoC 72-1004, Renewed Amendment Number 9, Section 1.2.7a, HSM Dose Rates with a Loaded 32PT DSC Only:

1.2.7a Dose rates at the following locations shall be limited to levels which are less than or equal to:

a. 800 mrem/hr on the HSM front surface.

b. 200 mrem/hr on the HSM door centerline

c. 8 mrem/hr on the end shield wall exterior

LIC-19-0021 Page 5 Technical Specifications for the Standardized NUHOMS Horizontal Modular Storage System CoC 72-1004, Renewed Amendment Number 15, HSM or HSM-H Dose Rate Evaluation Program:

5.4.1 The licensee shall establish a set of HSM dose rate limits which are to be applied to DSCs used at the site to ensure the limits of 10 CFR Part 20 and 10 CFR 72.104 are met. Limits shall establish peak dose rates at the following three locations:

1) HSM front bird screen,

2) Outside HSM door, and 5.4.2 Notwithstanding the limits established in 5.4.1, the dose rate limits listed below for the Standardized HSM and HSM-H shall be met when a specific DSC model loaded with fuel is stored within a module: Dose Rate Limits for 32PT:

1) HSM front bird screen - 1000 mrem/hr

2) Outside HSM door - 250 mrem/hr

3) End shield wall exterior - 10 mrem/hr The site-specific accident dose limits are provided from FC08574, Fort Calhoun Data Specific Radiological Assessment, Appendix C, HSM-202 Technical Specification Limit calculated for all 42 HSMs. These values correspond to those required per Technical Specification 5.4.1:

1) Front Vent - 400 mrem/hr

2) Door - 10 mrem/hr

3) ESW - 5 mrem/hr In such, the use of the site-specific Technical Specification radiological limit under Section 5.4.1 will be utilized to determine the EAL entry conditions.

Using the methods described in NEI 99-01, Rev. 6, EAL E-HU1, Damage to a Loaded Cask CONFINEMENT BOUNDARY:

The Technical Specifications radiological limit for the HSM Bird Screen, Outside HSM Door, and outside End Shield Wall, and measurement methods is used for this EAL entry. This proposed limit utilizes the earliest Technical Specification limit to be reached in case of a confinement boundary failure. The EAL entry condition, using the methodology from NEI 99-01 Rev 6, of two (2) times 400 mrem/hr, two (2) times 10 mrem/hr, and two (2) times 5 mrem/hr (gamma +

neutron) from Technical Specifications 5.4.1, provides the proposed values for entry into the Notification of Unusual Event. The values are:

800 mrem/hr (gamma + neutron) at front of HSM Bird Screen or, 20 mrem/hr (gamma + neutron) on outside the HSM Door or, 10 mrem/hr (gamma + neutron) on End Shield Wall exterior These values align the entry conditions for EAL E-HU1 with the Technical Specifications, NEI 99-01, precedence sites, and will accommodate reviewers concern for early entry into the emergency action levels. It is noted that under provisions of 10 CFR 72.212, applying the changes authorized by an amendment CoC to a cask loaded under an earlier amended CoC may result in a corresponding change to the applicable cask specific technical specification allowable radiation levels, which would be subject to the change process of 10 CFR 50.54(q).

LIC-19-0021 Page 6 The propose change is added to the IOEP technical basis document, EAL table and attachment 2, and the EAL comparison matrix.

The proposed change is consistent with precedence, and is in Attachment 2 and 3.

LIC-19-0021 Page 7

RAI-4

Section 3.4, Removal of requirement to conduct accountability following declaration of an emergency, of Enclosure 1 states, in part:

The proposed IOEP for FCS does not contain an emergency classification higher than ALERT, and considering the factors specified previously, the requirement to conduct accountability following an emergency declaration is no longer warranted.

Paragraph 50.47(b)(10) of 10 CFR, as exempted for FCS, states:

A range of protective actions has been developed for the plume exposure pathway EPZ for emergency workers and the public. In developing this range of actions, consideration has been given to evacuation, sheltering, and, as a supplement to these, the prophylactic use of potassium iodide (KI), as appropriate. Evacuation time estimates have been developed by applicants and licensees. Licensees shall update the evacuation time estimates on a periodic basis. Guidelines for the choice of protective actions during an emergency, consistent with Federal guidance, are developed and in place, and protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been developed.

As such, licensee is still required to establish a range of protective actions for emergency workers and the public onsite. The exemptions to emergency planning (EP) requirements approved for a permanently defueled emergency plan where intended to align with the EP requirements for an ISFSI in 10 CFR 72.32.

Spent Fuel Project Office Interim Staff Guidance (ISG) - 16, Emergency Planning, (ADAMS Accession No. ML003724570) provides guidance related to the requirements for an ISFSI emergency plan and its contents as delineated in 10 CFR 72.32. Section 3.6.2, Onsite Protective Actions, in ISG-16 states that the emergency plan should include methods for onsite personnel evacuation and accountability. Please provide further justification for deviating for NRC guidance based on the requirements of 10 CFR 50.47(b)(10), as exempted, or revise to restore personnel accountability.

Response

The approval of the Stations exemptions was based on 10 CFR 50.12, 10 CFR 50.47, 10 CFR 50, Appendix E, and industry precedence. The requested exemptions and justification were based on, and consistent with, Interim Staff Guidance (ISG) NSIR/DPR-ISG-02, Emergency Planning Exemption Requests for Decommissioning Nuclear Power Plants, issued May 11, 2015.

As stated in NSIR/DPR-ISG-02, Section 2.0, Scope, The Office of Nuclear Materials Safeguards and Security Spent Fuel Project Office Interim Staff Guidance - 16, Emergency Planning, provides the appropriate guidance for fuel stored in a dry cask storage facility consistent with the EP requirements in 10 CFR 72.32, Emergency Plan. In accordance with Interim Staff Guidance - 16, which provides clarification on the use and content of Regulatory Guide 3.67 as included in NUREG-1567 (March 2000). The discussion in Section 3.6.2, Onsite Protective Actions, provides information on the use of site accountability, evacuation, and other personnel protective actions. However, not all provisions or requirements located in these documents are applicable to the 10 CFR 50.47 requirements utilized in the IOEP for the station. In such, some

LIC-19-0021 Page 8 aspects of these references are not applicable, as they have been removed under previous license amendments from the emergency plan and not used (e.g., Site Area Emergency).

Utilizing the applicable sections of the listed references, as well as NUREG-0654, the proposed guidance in the IOEP includes provisions to perform accountability. This provides consistency with the provisions in NUREG-0654, precedence sites, and address the reviewers comments.

The requirements for accountability, associated with the remaining provisions needed for an ISFSI is included in the IOEP in definitions, security, Table 6-1, and the accountability section, and in the technical basis document in definitions. The proposed change is consistent with precedence, and is in Attachment 2 and 3.

LIC-19-0021 Page 9

RAI-5

Section 3.5, Removal of emergency notification to the State of Iowa, of Enclosure 1, Removal of emergency notification to the State of Iowa, states, in part:

The State of Iowa Department of Homeland Security formally requested to be removed from any emergency notifications associated with FCS.

Please provide documentation from the State of Iowa supporting this request.

Response

The document is attached as Attachment 4.

LIC-19-0021 Page 1 ATTACHMENT 2 REVISED ENCLOSURE 1 AND ATTACHMENTS, WITH MARKUPS OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION. UNIT NO. 1 DOCKET NO. 50-285

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

DESCRIPTION OF PROPOSED CHANGES, TECHNICAL AND REGULATORY EVALUATION, SIGNIFICANT HAZARDS DETERMINATION, AND ENVIRONMENTAL CONSIDERATIONS

Subject:

Independent Spent Fuel Storage Installation Only Emergency Plan (IOEP) and Emergency Action Level (EAL) Scheme

3.0 PROPOSED CHANGE

S 3.1 Elimination of SFP Initiating Conditions and EALs 3.2 Emergency Response Organization Revision 3.3 Replacement of the Shift Manager with the ISFSI Shift Supervisor 3.4 Removal of emergency notification to the State of Iowa.

4.0 TECHNICAL EVALUATION

4.1 Radiological Consequences of Design Basis Events 4.2 Radiological Consequences of Postulated Events 4.3 ISFSI Only Emergency Plan 4.4 ISFSI Emergency Action Levels

5.0 REGULATORY EVALUATION

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

6.0 ENVIRONMENTAL CONSIDERATION

S

7.0 REFERENCES

Attachment 1, Supporting Evaluations and Calculations Attachment 2, Comparison Matrix For ISFSI EALs Based On The Proposed Regulatory Guide DG-1346 NEI 99-01, Rev 6 Development of Emergency Action Levels for Non-Passive ReactorsEmergency Planning For Decommissioning Nuclear Reactors To The Commented [PDM1]: RAI-2 Proposed FCS Emergency Classification System And ISFSI EALs Attachment 3, ISFSI Only Emergency Plan Attachment 4, ISFSI Emergency Action Level Technical Bases Document

LIC-19-0001 Page 2

1.0 INTRODUCTION

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

By letter dated August 25, 2016, OPPD informed the NRC that FCS will permanently cease power operations in accordance with 10 CFR 50.82(a)(1)(i), specifying a shutdown date of October 24, 2016 (Reference 7.1). By letter dated November 13, 2016, FCS submitted a certification of permanent cessation of power operations and permanent removal of fuel from the reactor vessel (Reference 7.2). Consequently, as specified in 10 CFR 50.82(a)(2), the stations 10 CFR Part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel.

The proposed IOEP continues to rely on previously requested exemptions from certain emergency planning requirements (Reference 7.3), as the basis for these exemptions has not changed and remains in effect. The proposed IOEP has been determined to represent changes in both the EAL scheme and the staffing level previously requested to implement the Permanently Defueled Emergency Plan (PDEP) (Reference 7.4) in accordance with the requirements of 10 CFR 50.54(q) and therefore, require NRC approval prior to implementation. Additional changes to the FCS PDEP and EAL Technical Bases Document are warranted to reflect the storage of all fuel in the Independent Spent Fuel Storage Installation (ISFSI) facility.

The Post-Shutdown Decommissioning Activities Report (PSDAR) (Reference 7.5) documented OPPDs expectation that all spent fuel would be completely transferred to the ISFSI by the end of 2022. OPPD awarded contracts in the first quarter of 2018 which expedited transferring all spent fuel to the ISFSI by the middle of 2020. To comport to the reduced scope of potential radiological accidents with spent fuel in dry cask storage within the ISFSI, OPPD determined that implementation of the IOEP and the ISFSI EAL Technical Bases Document will be warranted.

The proposed emergency plan is related to the operation of the ISFSI and would be implemented after all spent fuel has been removed from the spent fuel pool (SFP) and placed in dry storage within the ISFSI. Implementation of the IOEP would involve the establishment of administrative controls for radiological source term accumulation limits and methods to control the accidental dispersal of the radiological source.

The NRC approved AREVA TN Americas Amendment 14, to the standardized NUHOMS Certificate of Compliance (CoC) No. 1004 for Spent Fuel Storage Casks, on April 25, 2017 (Reference 7.6). This revision deleted the License Condition requiring a return to the SFP for inspection. With the approval of the CoC, there is no longer a requirement to return spent fuel to the SFP.

Consistent with the condition that the proposed emergency plan may be implemented ninety (90) days after all spent fuel has been certified to have been removed from the SFP, FCS has submitted a LAR to revise the FCS Facility Operating License to comport to the ISFSI-Only condition that there is no longer a requirement to return spent fuel to the SFP.

LIC-19-0001 Page 3

2.0 DESCRIPTION

The proposed amendment would modify the FCS license by replacing the existing FCS PDEP and the associated EAL scheme with the IOEP and the ISFSI EAL scheme to reflect the storage of all fuel in the ISFSI. The proposed changes reduce the scope of onsite emergency planning requirements to reflect the reduced scope of potential radiological accidents with all spent fuel in dry cask storage within the ISFSI. After all spent fuel is in dry cask storage within the ISFSI, the number and severity of potential radiological accidents possible at FCS are substantially lower.

There continues to be no need for offsite emergency response plans at FCS because no postulated design basis accident or reasonably conceivable beyond design basis accident can result in a radioactive release that exceeds Environmental Protection Agency (EPA) Protective Action Guides (PAGs) beyond the site boundary, as described in EPAs PAG Manual "Protective Action Guides and Planning Guidance for Radiological Incidents" dated January 2017 (EPA PAG Manual) (Reference 7.7).

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

The radioactive source term for an accidental release at the defueled reactor site is reduced by radioactive decay and transfer of spent fuel from the SFP to the ISFSI. Potential offsite doses were calculated at FCS to verify that the necessary administrative radiological source term accumulation limits would be adequate during decontamination and dismantling of radioactive systems, structures, and components contained in the non-operational nuclear unit. These administrative radiological source term accumulation limits ensure that if a radiological release were to occur, it would not exceed two times the Offsite Dose Calculation Manual (ODCM) limits (two (2) times 1500 millirem/year) at the site boundary for sixty (60) minutes (and therefore not result in doses to the public above EPA PAGs beyond the controlled area boundary). In addition to administrative limits on radioactive source term accumulation, administrative controls will be in place to limit the dispersal of radioactive material. These administrative limits and dispersal controls are in addition to the requirements already specified in the ODCM for control of effluent releases.

The PDEP EAL scheme used at FCS in is based on NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors, Revision 6 (Reference 7.8). The proposed IOEP EAL scheme format is based on NEI 99-01, Revision 6, as appropriate after the transfer of the spent fuel from the SFP to the ISFSI. The proposed revisions constitute a change in the emergency planning function commensurate with the ongoing and anticipated reduction in radiological source term at FCS.

LIC-19-0001 Page 4

3.0 PROPOSED CHANGE

S Replacement of the FCS PDEP and associated EAL Technical Bases Document with the IOEP and the ISFSI EAL Technical Bases Document involves the following major changes to the FCS PDEP:

1) Removal of the various emergency actions related to the SFP,

2) Removal of non-ISFSI-related emergency event types,

3) Removal of the judgment EALs Commented [PDM2]: RAI-2

43) Clarifying definitions for security EALs

45) Revision of the Emergency Response Organization (ERO), and

56) Identification of the ISFSI Shift Supervisor (ISS) title as the position that assumes the Emergency Director (ED) responsibilities following an emergency declaration

7) Removal of requirement to perform accountability after declaration of an emergency. Commented [PDM3]: RAI-4 The off-normal events and accidents addressed in the IOEP are related to the dry storage of spent nuclear fuel within the ISFSI and include only the off-normal, accident, natural phenomena, and hypothetical events and consequences presented in the Updated Final Safety Analysis Report (UFSAR), NUH-003, Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, for the AREVA TN Americas. After all fuel is removed from the FCS SFP, there will no longer be any potential for the accidents previously described in the FCS emergency plan that would increase risk to the health and safety of the public. These accidents included events specifically related to the storage of the spent fuel in the SFP. After the transfer of the spent fuel from the SFP to the ISFSI, the spent fuel storage and handling systems will be removed from operation.

The proposed revisions to the FCS emergency plan and associated EAL scheme are commensurate with the reduction in radiological hazards associated with the transfer of the spent fuel from the SFP to the ISFSI and will allow the facility to transition to an emergency plan and EAL scheme specifically related to the storage of the spent fuel in the ISFSI. The proposed changes are necessary to properly reflect the conditions of the facility and to maintain the effectiveness of the emergency plan.

3.1 Elimination of SFP Initiating Conditions and EALs and Alert Classification The Initiating Conditions (ICs) and EALs associated with emergency classification in the PDEP are based on NEI 99-01, Revision 6. Specifically, Appendix C of NEI 99-01 contains a set of ICs and EALs for permanently defueled nuclear power plants that had previously operated under a 10 CFR Part 50 license and have permanently ceased power operations.

After all spent fuel has been transferred from the SFP to dry storage within the ISFSI, the NEI 99-01, Appendix C ICs and EALs that are specifically associated with the SFP are no longer required to be in the emergency plan. Additionally, certain ICs and EALs, the primary function of which is not associated with the SFP, are also no longer required to be in the emergency plan when administrative controls are established to limit source term accumulation and the offsite consequences of uncontrolled effluent releases.

Therefore, the ICs listed in Table 1, below, are proposed for elimination and are not included in the IOEP and EAL scheme.

LIC-19-0001 Page 5 With respect to the aircraft-related EALs; Interim Compensatory Measures (ICM) Order EA-02-026, Section B.5.b mitigation strategies (dated February 25, 2002) (Reference 7.9) was issued and subsequent security-based ICs and EALs were provided to licensees in NRC Bulletin (BL) 2005-02, Emergency Preparedness and Response Actions for Security Based Events, dated July 18, 2005 (Reference 7.10). BL 2005-02 was addressed to all holders of operating licenses for nuclear power reactors, except those who had permanently ceased operation and had certified that fuel has been removed from the reactor vessel.

In 2009, the NRC amended its security regulations adding new security requirements pertaining to nuclear power reactors. This rulemaking established and updated generically applicable security requirements similar to those previously imposed by Commission orders issued after the terrorist attacks of September 11, 2001. In the Statements of Consideration (SOC) for the Final Rule for Power Reactor Security Requirements (74 Federal Register (FR) 13926; March 27, 2009), the Commission stated, in part:

Current reactor licensees comply with these requirements through the use of the following 14 strategies that have been required through an operating license condition. These strategies fall into the three general areas identified by

§§ 50.54(hh)(2)(i), (ii), and (iii). The firefighting response strategy reflected in

§ 50.54(hh)(2)(i) encompasses the following elements:.

7. Spent fuel pool mitigation measures As such, the staff maintained EALs for potential or actual aircraft threats for facilities transitioning into decommissioning with spent fuel stored in a SFP, in addition to maintaining the mitigative strategies license conditions required by NRC Order, EA-02-026, Interim Compensatory Measures (ICM) Order, issued February 25, 2002 (67 FR 9792; March 4, 2002).

The SOC further stated, in part:

The NRC believes that it is inappropriate that § 50.54(hh) should apply to a permanently shutdown defueled reactor where the fuel was removed from the site or moved to an ISFSI. The Commission notes that the § 50.54(hh) do not apply to any current decommissioning facilities that have already satisfied the § 50.82(a) requirements.

On November 28, 2011, the NRC issued a letter that rescinded Item B.5.b of the ICM Order EA-02-26 (Reference 7.18). The rulemaking codified generically applicable security requirements previously issued by orders and updated the existing power reactor security requirements.

Neither the ICM Order nor 10 CFR 50.54(hh) continue to apply to FCS. Therefore, the ICs deleted also include those associated with the mitigative strategies and response procedures for potential or actual aircraft attack procedures as the spent fuel has been removed from the SFP and is stored in the ISFSI.

10 CFR Part 50, Appendix E (IV)(A)(7) defines hostile action as an act directed toward a nuclear power plant or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end, as it applies to the capability of implementing the emergency plan during such events. However, in the

LIC-19-0001 Page 6 Statement of Considerations for the 2011 Emergency Plan Final Rule, the NRC excluded non-power reactors from the definition of hostile action because a non-power reactor as defined in 10 CFR 50.2, Definitions, is not a nuclear power plant, and presently a regulatory basis had not been developed to support the inclusion of non-power reactors in the definition of hostile action. The term is maintained to provide consistency with the site Security Plan and procedures. Commented [PDM4]: RAI-1 Even though FCS will continue to maintain a facility license under the auspices of 10 CFR 50, the FCS ISFSI is licensed in accordance with the requirements of 10 CFR 72.212, Conditions of General License Issued Under 10 CFR 72.210. As such, the radiological consequences to the public from the FCS ISFSI have been developed in accordance with the requirements of 10 CFR 72.104, Criteria for Radioactive Materials in Effluents and Direct Radiation from an ISFSI or MRS, and 10 CFR 72.106, Controlled Area of an ISFSI or MRS. The use of these regulations to develop the FCS ISFSI Technical Specifications provides corollary alignment for development of an ISFSI EAL scheme that meets the historical purpose of an Emergency Plan, protecting the public from radiological exposure in the event of a design basis accident, using the regulatory technical bases for ISFSI facilities. This technical basis also provides the foundation for development of a radiological EAL that is more in line with the standardized risk from an ISFSI.

FCS recognizes that the practice of using Emergency Planning requirements set forth under 10 CFR 50.47 for Independent Spent Storage Facilities located at operating Nuclear Power Reactors is prudent, and that prudency extends through the period that used fuel is stored in the Spent Fuel Pool for a facility that has submitted the certifications required under 10 CFR 50.82. During these periods, having an Emergency Plan and EAL scheme that is familiar to the Certified Fuel Handlers and operating staff allows for a manageable transition from power operations to removal of all fuel from the Spent Fuel Pool. Once all fuel is placed in dry storage in the ISFSI, the makeup of the facility staff can shift dramatically. This shift, concurrent with the significant reduction in risk to the public, predicates the use of an emergency plan that more closely aligns to that of an emergency plan developed under 10 CFR 72.32. The most significant difference between the proposed FCS EAL scheme and that of a decommissioning power reactor using a 10 CFR 72.32 Emergency Plan is the required use of the ALERT classification for 10 CFR 72.32 emergency plans. All other terminology is essentially the same.

This rationale justifies the exclusion of facilities with permanent removal of fuel from the reactor vessel from the definition for a hostile action and its related requirements (including conducting hostile action exercises) as they apply to the Emergency Plan.

Elements for security-based events should be maintained for facilities, including ISFSI-only facilities with a 10 CFR Part 50 license to help ensure assistance can be made available during these events. As such, the Alert security classification based on a hostile action is being redefined for the FCS IOEP.

Even though a Hostile Action-Based program is not necessary for an ISFSI-only site, precedence from other utilities and regulatory guidance provides that consideration of actions by an adversary for EAL purposes is still applicable. Therefore, the use of the term HOSTILEADVERSARIAL ACTION and the revised definition is included, to reflect those aspects associated with an ISFSI-only site and is utilized in the EALs. Commented [PDM5]: RAI-1 The proposed judgment EAL for Alert, removes the portion of the entry condition associated with hostile action. Hostile action is already controlled in an event specific EAL. The

LIC-19-0001 Page 7 duplication of the event in the EALs may lead to errors in implementation of the correct EAL. Therefore, the inclusion of the judgment EAL will not contain this entry provision.

NEI 99-01, Judgements EALs are being eliminated as part of this submittal to align with Draft Regulatory Guide 1346. The draft does not include the Judgement EALs as part of the IOEP scheme.

Draft Regulatory Guide 1346 also proposesprovides for an alternate EAL for determining the occurrence of damage to a loaded storage cask following an event that may cause damage to the loaded casks. This proposed methodology identifies any change in radiation Commented [PDM6]: RAI-2 levels above normal background as the initiating condition for the EAL. FCS is proposing to base this EAL on CoC 72-1004 Technical Specifications associated with off normal radiological conditions calculated for site specific values. The NEI methods provides multiplying the Technical Specifications for the dose rate limit times two. a change in radiation levels significant enough to warrant concern for exceeding the limit to dose to the general public as defined in 10 CFR 20.1301(a)(2) of 0.002 Rem (2 mRem) in any one hour. Establishing an EAL threshold of > 8002 mRem/hr, 20 mRem/hr, within the ISFSI protected area or or 10 mrem/hr as measured at on athe Horizontal Storage Module (HSM) concrete surface, provides a level of margin to maintain protection of the public, while providing an easily identifiable set point for ISFSI personnel. This level of radiation is high enough to minimize instrument error and operational differences while still providing positive indication of an emergency condition. Commented [PDM7]: RAI-3 The ICs listed in Table 1 are not included in the proposed ISFSI EAL scheme for FCS. The ICs in Table 1 are either associated only with SFP operation or are ICs for which administrative controls to limit possible effluent releases have been established.

LIC-19-0001 Page 8 Table 1 - Emergency Plan Initiating Conditions Being Deleted ALERT UNUSUAL EVENT PD-RA1 Release of gaseous or liquid PD-RU1 Release of gaseous or liquid radioactivity resulting in offsite dose greater radioactivity greater than 2 times the ODCM than 10 mRem TEDE or 50 mRem thyroid limits for 60 minutes or longer.(1)

CDE.(1)

PD-RA2 UNPLANNED rise in facility PD-RU2 UNPLANNED rise in facility radiation levels that impedes facility access radiation levels.(1) required to maintain spent fuel integrity.(1)

PD-HA1 HOSTILE ACTION within the PD-HU1[EU1] Confirmed SECURITY Formatted: Not Strikethrough OWNER CONTROLLED AREA or airborne CONDITION or threat.(2) Formatted: Not Strikethrough attack threat within 30 minutes. [EA1

1. A SECURITY CONDITION that does not Formatted: Not Strikethrough HOSTILEADVERSARIAL ACTION is involve a HOSTILE ACTION as reported Commented [PDM8]: RAI-1, RAI-2 occurring or has occurred.] (2) by [the security supervision force and

1. [An HOSTILEADVERSARIAL ACTION is impacting the ISFSI].

occurring or has occurred as reported by the security force.] A HOSTILE ACTION is 2. Notification of a credible security threat occurring or has occurred within the directed at the site [ISFSI].

OWNER CONTROLLED AREA as reported by security supervision. 3. A validated notification from the NRC providing information of an aircraft threat.

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

PD-HU2 Hazardous event affecting SAFETY SYSTEM equipment necessary for spent fuel cooling.(1)

PD-HA3 Other conditions exist which in the PD-HU3 Other considerations exist which in judgment of the Emergency Director warrant the judgment of the Emergency Director declaration of Alert. (1) warrant declaration of an Unusual Event. (1) Commented [PDM9]: RAI-2 PD-SU1 UNPLANNED spent fuel pool temperature rise.(1)

E-HU1 [EU2]: Damage to a loaded cask Formatted: Not Strikethrough CONFINEMENT BOUNDARY.

1. Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact [abnormal] radiation reading [of >2 mRem/hr (gamma) within the ISFSI Protected Area or on a Horizontal Storage Module (HSM) concrete surface.]

LIC-19-0001 Page 9

• 1600 mRem/hr (gamma + neutron) on Formatted: Not Strikethrough the Horizontal Storage Module (HSM) Formatted: Not Strikethrough front surface [800 mRem/hr (gamma +

neutron) at the front bird screen of the Hoizontal Storage Module (HSM)] Formatted: Not Strikethrough OR

• > 400 mRem/hr (gamma + neutron) on Formatted: Indent: Left: 0.23", Hanging: 0.1" the HSM door centerline [* 20 Formatted: Not Strikethrough mRem/hr (gamma + neutron) on the Outside HSM door](2) Commented [PDM10]: RAI-3 OR Formatted: Superscript

[* 10 mRem/hr (gamma + neutron) on Formatted: Not Strikethrough the End Shield Wall exterior](2) Formatted: Indent: Left: 0.23", Hanging: 0.1"

• > 16 mRem/hr (gamma + neutron) on the Commented [PDM11]: RAI-3 end shield wall exterior Formatted: Not Strikethrough

[NOTE: Radiation readings are taken at the Formatted: Not Strikethrough locations prescribed by the Technical Specifications for the Standardized NUHOMS Horizontal Storage System (Amendment Number 15 to CoC 1004)]

(1) Indicates the IC and the associated EALs are being deleted in their entirety.

(2)

Indicates only the portion of the IC or EAL shown in strikethrough text is being deleted. Text included with brackets [ ] will be added in the proposed ISFSI EAL Scheme.

The ICs being deleted include all ICs associated with the categories of abnormal radioactive release and system malfunction associated with the SFP as well as security conditions associated with aircraft. These categories apply only to SFP operation and are not appropriate given the minimized risk of having all spent fuel stored within the ISFSI.

The ICs listed in Table 2, below, are being retained. The ICs being retained in the ISFSI Only Emergency Plan are appropriate to address the condition of a facility in which all spent fuel is stored in the ISFSI.

Table 2 - ISFSI Emergency Plan Initiating Conditions Commented [PDM12]: RAI-1, RAI-2 UNUSUAL EVENT SECURITY EU1 (formally PD-HU1) Confirmed SECURITY CONDITION, or threat, at the independent spent storage installation (ISFSI).

Other Conditions PD-HU3 Judgment Independent Spent Fuel Storage Installation (ISFSI)

LIC-19-0001 Page 10 EU2 (formally E-HU1): Damage to a loaded cask CONFINEMENT BOUNDARY.

ALERT SECURITY EA1 (formally PD-HA1) HOSTILEADVERSARIAL ACTION is occurring or has occurred. Formatted: Font: Not Bold Other Conditions PD-HA3 Judgement Formatted: Font: Not Bold 3.2 Emergency Response Organization Revision The FCS PDEP provides for two (2) ERO augmented positions - a Technical Coordinator and a Radiation Protection Coordinator. The proposed FCS IOEP replaces these positions with a Resource Manager and an individual trained in radiological monitoring and assessment.

A Resource Manager is provided to assist in assessing the event and obtaining needed resources. The Resource Manager is required to be in contact with the Emergency Director (ED) within two (2) hours of declaration of an Unusual Event or an Alert. Entry into the IOEP would result from an extreme natural phenomenon (beyond design basis) or a security condition, either of which would negatively impact or restrict access to the site.

The Resource Manager augments the ED by assisting in assessing the emergency condition and coordinating the required resources, including serving as the public information interface. Services provided to the ED by the Resource Manager can be provided remotely and do not necessitate an onsite response by the Resource Manager.

By responding remotely, the actual response time is decreased with no negative impact to services and functional responsibilities provided by the Resource Manager. The Resource Managers functional responsibilities could be performed in a timely manner either by reporting to the site or performing the function remotely in the specified timeframe.

In addition, FCS proposes that, for a classified event involving radiological consequences, a minimum of one person trained in radiological monitoring and assessment will report to the ISFSI within four hours of the emergency declaration.

The proposed FCS IOEP also provides that additional personnel resources may be directed to report to FCS to provide additional support as needed to assess radiological conditions, support maintenance and repair activities, develop and implement corrective action plans, and assist with recovery actions. The augmentation personnel are available from FCS staff, OPPD, and from various contractors.

3.3 Replacement of the Shift Manager with the ISFSI Shift Supervisor The FCS PDEP assigns the authority and responsibility for control and mitigation of emergencies to the Shift Manager (SM). If an emergency condition develops, the SM

LIC-19-0001 Page 11 would assume the role of ED. The proposed FCS IOEP proposes replacing the SM position with an ISS within the IOEP.

The ISS will be at FCS on a continuous, 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day basis, and is the senior management position during off-hours. This position is responsible for monitoring ISFSI conditions and managing the activities at the FCS ISFSI. This position assumes overall command and control of the response as the ED and is responsible for monitoring conditions and approving all onsite activities. The IOEP identifies non-delegable responsibilities, along with other designated tasks. OPPD considers this an administrative change which will not impact the timing or performance of existing emergency response duties.

3.4 Removal of requirement to conduct accountability following declaration of an emergency.

The specification for accountability from section J.5 of revision 1 of NUREG-0654 (Reference 7.13) reads as follows.

Each licensee shall provide for a capability to account for all individuals onsite at the time of the emergency and ascertain the names of missing individuals within 30 minutes of the start of an emergency and account for all onsite individuals continuously thereafter.

The previously approved exemptions and PDEP for FCS removed the requirements for Site Area Emergencies and General Emergencies. Accountability of personnel is a process required for the Protected Area at most nuclear plants when a Site Area Emergency or General Emergency has been declared. Accountability is necessitated at these classifications due to the potential for significant radiological exposure or other health hazards to site personnel. As the facility transitions to an ISFSI only site, the need for accountability diminishes as a result of the following:

- significantly smaller staff (less than 5% of an operational facility)

-the facility only has one building

-entry into the Protected Area is intermittent, with no permanent occupation other than that required for the security plan

-the staff at the ISFSI will be in continuous communication with each other

-the entire facility is under video surveillance, and monitored 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day The proposed IOEP for FCS does not contain an emergency classification higher than ALERT, and considering the factors specified previously, the requirement to conduct accountability following an emergency declaration is provided only if determined to be necessaryno longer warranted.

3.45 Removal of emergency notification to the State of Iowa.

The State of Iowa Department of Homeland Security formally requested to be removed from any emergency notifications associated with FCS.

4.0 TECHNICAL EVALUATION

LIC-19-0001 Page 12 4.1 Radiological Consequences of Design Basis Events FCS is located midway between Fort Calhoun and Blair, Nebraska, on the west bank of the Missouri River. The site is located approximately 19 miles North of Omaha, Nebraska and four (4) miles South of Blair, Nebraska. The ISFSI is located within a Protected Area on the site. Except for the city of Blair and the villages of Fort Calhoun and Kennard, the area within a ten mile radius is predominantly rural and land use is primarily devoted to general farming. There are no private businesses or public recreational facilities on the plant property.

Chapter 14 of the FCS Final Safety Analysis Report, as Updated described the Abnormal Operational Transients and Design Basis Accident (DBA) scenarios applicable to FCS during power operations. However, after permanent cessation of power operations and transfer of all irradiated fuel from the SFP to dry storage within the ISFSI, the remaining accident scenarios postulated in the Defueled Safety Analysis Report (DSAR) are no longer possible. The ISFSI is a passive storage system that does not rely on electric power for heat transfer. After removal of the spent fuel from the SFP, there are no credible fuel-related accidents for which actions of a Certified Fuel Handler, SM, or Non-Certified Operator are required to prevent occurrence or to mitigate the consequences. There is no credible accident resulting in radioactive releases requiring offsite protective measures.

The robust design and construction of the spent fuel storage system selected for use at the ISFSI prevents the release of radioactivity in the event of an off-normal or accident event as described in the NUHOMS UFSAR. Leakage of fission products from a canister confinement boundary breach is not considered to be a credible event, given the high integrity nature of the canisters design and the additional protection afforded by the storage casks.

FCS PSDAR documents the decommissioning strategy selected for FCS. Systems that are not required to support the spent fuel, HVAC, Emergency Plan, or site security will be drained, de-energized, and secured and the plant will remain in a stable condition until final decontamination and dismantlement activities begin. The PSDAR documents the time period that OPPD expects to have all spent fuel transferred to the ISFSI. After the fuel transfer is completed, the SFP and associated systems will be drained and de-energized.

After all the spent fuel has been removed from the SFP, the estimated radiological inventory (non-fuel) that remains at the reactor facility is primarily attributable to activated reactor components and structural materials. There are no credible accident scenarios that can mobilize a significant portion of this inventory for release. As a result, the potential accidents that could occur during decommissioning of the reactor facility have negligible offsite and onsite radiological consequences.

With all spent nuclear fuel in dry storage within the ISFSI, the radiological status of the facility required for implementing this proposed IOEP is summarized as follows:

The remaining radiological source term at FCS will not create an unplanned/unanticipated increase in radiation or in liquid or airborne radioactivity levels that would result in doses to the public above EPA PAG limits at the site boundary.

Source term accumulation from activities during decontamination and dismantlement of radioactive systems, structures, and components are administratively controlled at a

LIC-19-0001 Page 13 level that would preclude declaring an Unusual Event.

Necessary radiological support personnel will be administratively required to be onsite during active decontamination and dismantlement of radioactive systems, structures, and components.

The IOEP, and certain ICs and EALs for which administrative controls to limit possible effluent releases will be established, do not apply to the decontamination and dismantlement of radioactive systems, structures, and components.

NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, (NUREG-0586) (Reference 7.11) supports this conclusion in the following statement:

The staff has reviewed activities associated with decommissioning and determined that many decommissioning activities not involving spent fuel that are likely to result in radiological accidents are similar to activities conducted during the period of reactor operations. The radiological releases from potential accidents associated with these activities may be detectible. However, work procedures are designed to minimize the likelihood of an accident and the consequences of an accident, should one occur, and procedures will remain in place to protect health and safety while the possibility of significant radiological accident exists.

NUREG-0586 also includes the following statement:

The staff has considered available information, including comments received on the draft of Supplement 1 of NUREG-0586, concerning the potential impacts of non-spent fuel related radiological accidents resulting from decommissioning. This information indicates, that with the mitigation procedures in place, the impacts of radiological accidents are neither detectible nor destabilizing. Therefore, the staff makes the generic conclusion that impacts of non-spent fuel related radiological accidents are SMALL. The staff has considered mitigation and concludes that no additional measures are likely to be sufficiently beneficial to be warranted.

Accordingly, administrative controls that are designed to minimize the likelihood and consequence of off-normal or accident events would be implemented when decontamination or dismantling activities involving radioactive systems, structures, or components are being performed.

Implementation of the IOEP would involve FCS establishing administrative controls for radiological source term accumulation limits and methods to control the accidental dispersal of the radiological source. Examples of radiological source term accumulation limits are based on:

Radioactive materials collected on filter media and resins (dose rate limit)

Contaminated materials collected in shipping containers (dose rate limit)

Surface or fixed contamination on work areas that may create airborne radioactive material (activity limits)

LIC-19-0001 Page 14 Radioactive liquid storage tank(s) (activity concentration limits)

An example of a method to control accidental dispersal of the radiological source term is limitation on dispersal mechanisms that may cause a fire (e.g., limits on combustible material loading, use of fire watch to preclude fire, etc.), or placement of a berm around a radioactive liquid storage tank. If the dispersal control fails, the limits on source term would preclude exceeding the site boundary source term limit.

As discussed in the previously requested exemptions from various emergency planning requirements contained in 10 CFR 50.47 and 10 CFR 50, Appendix E, an analysis of the potential radiological impact of a design basis accident at FCS in a permanently defueled condition indicates that any releases beyond the site boundary are below EPA PAG exposure levels. The basis for these exemptions has not changed and remains in effect for the proposed IOEP.

4.2 Radiological Consequences of Postulated Events Although the limited scope of postulated accidents that remain applicable to the FCS facility justifies a reduction in the necessary scope of emergency response capabilities, FCS also assessed beyond design basis events using past industry precedence, including information contained in Appendix I, Radiological Accidents, of NUREG-0586.

With spent fuel stored within the SFP, the most severe postulated beyond design basis event involved a highly unlikely sequence of events that causes heatup of the spent fuel, postulated to occur without any heat transfer, such that the zircaloy fuel cladding reaches ignition temperature (adiabatic heat up). The resultant zircaloy fire could lead to the release of large quantities of fission products to the atmosphere. However, after removal of the spent fuel from the SFP, the configuration of the spent fuel stored in dry storage precludes the possibility of such a scenario.

With this previously limiting beyond design basis scenario no longer possible, FCS assessed the following beyond design basis events associated with performance of decommissioning activities with all irradiated fuel stored in the ISFSI. A summary of the assessments is provided below:

1. Cask Drop Event (Fuel-Related Event)

FCS is the holder of a general license for the storage of spent fuel in an ISFSI at power sites in accordance with the provisions of 10 CFR 72.210 and 10 CFR 72.212. The generally licensed ISFSI at FCS is used for interim onsite dry storage of spent nuclear fuel assemblies in the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, (Certificate of Compliance (CoC) 1004).

As documented in the NUHOMS UFSAR, NUH-003, analysis of the normal events, including drop events, determined that canister drops can be sustained without breaching the confinement boundary, preventing removal of spent fuel assemblies, or creating a criticality accident. There are no evaluated normal conditions or off-normal or accident events that result in damage to the canister producing a breach in the confinement boundary. Neither normal conditions of operation or off-normal events preclude retrieval of the fuel for transport and ultimate disposal.

The dry spent fuel storage casks used at FCS are approved for storage of spent fuel per

LIC-19-0001 Page 15 10 CFR 72.214; and, as such, are in compliance with the requirements of 10 CFR 72.24 and 10 CFR 72.122 for off-normal and accident events to ensure that they will provide safe storage of spent fuel during all analyzed off-normal and accident events. Therefore, no radiological release beyond the site boundary would be expected to occur.

2. Radioactive Material Handling Accident (Non-Fuel-Related Event)

The limiting non-fuel related event involves the release of radioactive material from a concentrated source, such as filters, resins, and shipping containers (as discussed in NUREG-0586, Appendix 1). The initiator to these events could be a fire, explosion, or a handling event (cask drop). After all spent fuel has been moved to the ISFSI, there would be no concentrated source of radioactive material available to be released to the environment in an amount that could exceed two (2) times the ODCM limit at the site boundary (2 times 1500 millirem/year). During decontamination and dismantlement activities, administrative controls would limit the total amount of activity that could accumulate in a concentrated source. FCS Calculation FC08566 (Attachment 1) details an activity accumulation limit methodology for decontamination and dismantlement of irradiated stainless steel (e.g., reactor vessel internals) and irradiated concrete (e.g.,

reactor coolant loop bio-shield walls) based on isotopic mixtures from NUREG/CR-3474, Long-Lived Activation Products in Reactor Materials, (Reference 7.12) such that a release to the environment from concentrated sources of these radioactive materials would not exceed two times the ODCM at the site boundary.

It is expected that representative material samples will be taken and analyzed prior to actual decontamination/dismantlement work. Using the methodology consistent with this calculation, container/filter maximum radioactivity limits will be derived.

The results of the above assessment indicate that the projected radiological doses at the controlled area boundary are less than the EPA PAGs.

3. Accidents Initiated by External Events The effects of external events, such as fires, floods, wind (including tornados), earthquakes, lightning, and physical security breaches on the ISFSI remain unchanged from the effects that were considered under the proposed PDEP. Externally initiated events are addressed by the proposed ISFSI EALs.

In summary, there continues to be a low likelihood of any postulated event resulting in radiological releases requiring offsite protective measures, and there is no credible radioactive material event (non-fuel related) resulting in radiological releases requiring declaration of an emergency.

4.3 ISFSI ONLY EMERGENCY PLAN The FCS IOEP is provided in Enclosure 1, Attachment 3 to this submittal for NRC review and approval. This proposed emergency plan is associated with EALs for events related to the ISFSI. The IOEP addresses the applicable regulations stipulated in 10 CFR 50.47, Emergency Plans; 10 CFR 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities (considering the exemptions requested in Reference 7.3); and 10 CFR 72.32, Emergency Plan, and is consistent with the applicable guidelines established in NUREG-0654/FEMA-REP-1, Revision 1, Criteria for Preparation and

LIC-19-0001 Page 16 Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (Reference 7.13).

The IOEP describes FCSs plan for responding to emergencies while all spent fuel is in dry storage within an ISFSI. After all spent fuel at FCS is in dry storage within the ISFSI, the number and severity of potential radiological accidents is significantly less than when fuel is stored in the SFP.

The FCS IOEP conservatively provides that the emergency planning zone for the ISFSI is the area within the site boundary. At FCS, the site boundary completely encompasses the controlled area. The controlled area, as defined in 10 CFR 72.3, Definitions, means the area immediately surrounding an ISFSI for which FCS exercises authority over its use and within which ISFSI operations are performed.

The controlled area is established to limit dose to the public during normal operations and design basis accidents in accordance with the requirements of 10 CFR 72.104, Criteria for Radioactive Materials in Effluents and Direct Radiation from an ISFSI or MRS, and 10 CFR 72.106, Controlled Area of an ISFSI or MRS. FC08574, Fort Calhoun Data Specific Radiological Assessment, FCSs analysis of the radiological impact of potential accidents at the ISFSI concludes that any releases beyond the ISFSI controlled area are expected to be less than the EPA PAGs. The controlled area is completely enclosed within the site boundary. Thus, any radiological releases beyond the site boundary will also be less than the EPA PAGs.

Based on the reduced number and consequences of potential radiological events with all spent fuel in dry storage within the ISFSI, there will continue to be no need for offsite emergency response plans for the protection of the public beyond the site boundary.

Additionally, the scope of the onsite emergency preparedness organization and corresponding requirements in the emergency plan may be reduced without an undue risk to the public health and safety.

The analysis of the potential radiological impact of an accident in a condition with all irradiated fuel stored in the ISFSI indicates that any releases beyond the site boundary are below the EPA PAG exposure levels. Exposure levels, which warrant pre-planned response measures, are limited to onsite areas. For this reason, radiological emergency planning is focused onsite.

4.4 ISFSI Emergency Action Levels Enclosure 1, Attachment 4 of this submittal provides the FCS ISFSI EAL Technical Bases Document, which contains the proposed FCS ISFSI EAL scheme for NRC review and approval. The proposed ISFSI EAL scheme is to be implemented by the FCS ISFSI Emergency Plan (provided in Enclosure 1).

Deletions from the proposed Permanently Defueled EAL scheme are identified in Table 1, Emergency Plan Initiating Conditions Being Deleted, in Section 3.1, Elimination of SFPs Initiating Conditions and EALs, above.

Related Documents

LIC-19-0001 Page 17 Supporting evaluations/calculations for establishing appropriate radioactive material administrative control limits are provided in Attachment 1 to this submittal.

Operating Modes and Applicability The proposed ISFSI EALs are only applicable after the final spent nuclear fuel assembly has been transferred out of the SFP and placed in dry storage within the ISFSI.

State and Local Government Review of Proposed Changes State and local emergency management officials are advised of EAL changes that are implemented. Prior to implementation of the EAL scheme proposed in this License Amendment Request (LAR), FCS will provide an overview of the new classification scheme to State and local emergency management officials in accordance with 10 CFR 50, Appendix E, Section IV.B.1.

5.0 REGULATORY EVALUATION

The proposed emergency plan does not meet all standards of 10 CFR 50.47(b) and requirements of 10 CFR Part 50, Appendix E. However, FCS previously received exemptions from portions of 10 CFR 50.47(b), 10 CFR 50.47(c)(2), and 10 CFR 50, Appendix E, Section IV, by letter dated December 11, 2017 (Reference 7.3). The basis for these exemptions has not changed and remains in effect for the emergency plan changes requested in this document. Considering the previously approved exemptions, the emergency plan, as revised, will continue to meet the remaining applicable requirements in 10 CFR Part 50, Appendix E and the remaining applicable planning standards of 10 CFR 50.47(b).

5.1 No Significant Hazards Consideration In accordance with 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit, OPPD requests NRC approval of a reduction in effectiveness of the site Emergency Plan by the removal of several EALs and corresponding changes to the emergency plan, to be implemented after all spent fuel has been removed from the SFP and placed in dry storage within the ISFSI. The proposed IOEP and ISFSI EAL Technical Bases Document are commensurate with the reduction in radiological source term at FCS.

The PSDAR documents the time period that FCS expects to have all spent fuel transferred to the ISFSI. To comport to the reduced scope of potential radiological accidents with all spent fuel in dry cask storage within the ISFSI, FCS proposes a new emergency plan and corresponding EAL scheme.

Pursuant to 10 CFR 50.92, OPPD has reviewed the proposed changes and concludes that the changes do not involve a significant hazards consideration because the proposed changes satisfy the criteria in 10 CFR 50.92(c). These criteria require that operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

The proposed changes would revise the FCS emergency plan and EAL scheme commensurate with the hazards associated with a permanently shut down and defueled facility that has transferred all spent fuel from the SFP to dry cask storage within the ISFSI.

LIC-19-0001 Page 18 The discussion below addresses each of these criteria and demonstrates that the proposed amendment does not constitute a significant hazard.

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

Response: No.

The proposed amendment would modify the FCS facility operating license by revising the emergency plan and EAL scheme. FCS has permanently ceased power operations and is permanently defueled. The proposed amendment is conditioned on all spent nuclear fuel being removed from wet storage in the SFP and placed in dry storage within the ISFSI. Occurrence of postulated accidents associated with spent fuel stored in a SFP is no longer credible in a SFP devoid of such fuel. The proposed amendment has no effect on plant systems, structures, or components (SSC) and no effect on the capability of any plant SSC to perform its design function. The proposed amendment would not increase the likelihood of the malfunction of any plant SSC. The proposed amendment would have no effect on any of the previously evaluated accidents in the FCS DSAR.

Because FCS has permanently ceased power operations, the generation of fission products has ceased and the remaining source term continues to decay. This continues to significantly reduce the consequences of previously evaluated postulated accidents.

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

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

Response: No.

The proposed amendment constitutes a revision of the emergency planning function commensurate with the ongoing and anticipated reduction in radiological source term at FCS.

The proposed amendment does not involve a physical alteration of the plant. No new or different types of equipment will be installed and there are no physical modifications to existing equipment as a result of the proposed amendment. Similarly, the proposed amendment would not physically change any SSC involved in the mitigation of any postulated accidents. Thus, no new initiators or precursors of a new or different kind of accident are created. Furthermore, the proposed amendment does not create the possibility of a new failure mode associated with any equipment or personnel failures.

The credible events for the ISFSI remain unchanged.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

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

LIC-19-0001 Page 19 Response: No.

Because 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), the occurrence of postulated accidents associated with reactor operation is no longer credible. With all spent nuclear fuel transferred out of wet storage from the SFP and placed in dry storage within the ISFSI, a fuel handling accident is no longer credible. There are no credible events that would result in radiological releases beyond the site boundary exceeding the EPA PAG exposure levels, as detailed in the EPAs PAG Manual "Protective Action Guides and Planning Guidance for Radiological Incidents" dated January 2017 (EPA PAG Manual).

The proposed amendment does not involve a change in the plants design, configuration, or operation. The proposed amendment does not affect either the way in which the plant SSCs perform their safety function or their design margins. Because there is no change to the physical design of the plant, there is no change to these margins.

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

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

5.2 Applicable Regulatory Requirements/Criteria The regulatory requirements, considering the previously requested exemptions are discussed below.

Title 10 of the Code of Federal Regulations (10 CFR), Section 50.47, "Emergency Plans,"

set forth emergency plan requirements for nuclear power plant facilities. The regulations in 10 CFR 50.47(a)(1)(i) state, in part:

no initial operating license for a nuclear power reactor will be issued unless a finding is made by the NRC that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.

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

Planning Standard (1) of Section 50.47(b) states, in part: [E]ach principal response organization has staff to respond and to augment its initial response on a continuous basis.

Planning Standard (2) of Section 50.47(b) states, in part: On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available

LIC-19-0001 Page 20 Planning Standard (4) of Section 50.47(b) requires that a licensees emergency response plan contain the following: A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee.

Planning Standard (8) of Section 50.47(b) states, in part: Adequate emergency facilities and equipment to support the emergency response are provided and maintained.

10 CFR 50.54(q)(4) specifies the process for revising emergency plans where the change reduces the effectiveness of the plan. This regulation states the following:

The changes to a licensees emergency plan that reduce the effectiveness of the plan as defined in paragraph (q)(1)(iv) of this section may not be implemented without prior approval by the NRC.

Section IV.A of Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, to 10 CFR Part 50, states, in part: The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensees emergency organization Section IV.C.1 of Appendix E requires that each emergency plan define the emergency classification levels that determine the extent of participation of the emergency response organization.

Section IV.E of Appendix E states, in part: Adequate provisions shall be made and described for emergency facilities and equipment. As identified in 10 CFR 72.13, Applicability, the applicable emergency plan requirements for an ISFSI associated with a general license are specified in 10 CFR 72.32(c) and (d).

The proposed emergency plan continues to rely on previously requested exemptions from certain emergency planning requirements as the basis for these exemptions has not changed and remains in effect.

The proposed changes are conservatively being considered as a change to the EAL scheme development methodology. Pursuant to 10 CFR Part 50, Appendix E, Section IV.B.2, a revision to an entire EAL scheme must be approved by the NRC before implementation.

5.3 Precedent Similar changes to emergency plans and associated EAL schemes approved by the NRC for plants that have transitioned to ISFSI-only status include: 1) the La Crosse Boiling Water Reactor (LACBWR) facility on September 8, 2014 (Reference 7.15); 2) the Zion Facility on May 14, 2015 (Reference 7.16); 3) the Vermont Yankee Station (Reference 7.19); and 34)

Duke Energy Florida, Inc. for the Crystal River Unit 3 Nuclear Generating Station on August 12, 2016 (Reference 7.17).

5.4 Conclusion

LIC-19-0001 Page 21 Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

LIC-19-0001 Page 22

6.0 ENVIRONMENTAL CONSIDERATION

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

(i) The amendment involves no significant hazards consideration.

As described in Section 5.1 of this evaluation, the proposed changes involve no significant hazards consideration.

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

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

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

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

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

7.0 REFERENCES

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

(ADAMS Accession No. ML16242A127) 7.2 OPPD Letter (T. Burke) to USNRC (Document Control Desk) - Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel, dated November 13, 2016 (LIC-16-0074) (ADAMS Accession No. ML16319A254) 7.3 Letter USNRC (J. Kim) to OPPD (M. Fisher) - Fort Calhoun Station, Unit No. 1, Exemptions From Certain Emergency Planning Requirements and Related Safety Evaluation, dated December 11, 2017 (LIC-16-0109) (CAC No. MF9067)

(ML17263B198; ML17263B191; ML17278A178) 7.4 OPPD Letter (T. Burke) to USNRC (Document Control Desk) - License Amendment Request 16-05 to 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) (ADAMS Accession No. ML16351A464)

LIC-19-0001 Page 23 7.5 Letter USNRC (J. Kim) to OPPD (M. Fisher) - Fort Calhoun Station, Unit No. 1, Post-Shutdown Decommissioning Activities Report, dated March 23, 2017 (LIC 0033) (CAC No. 9536) (ML18011A687) 7.6 Nuclear Regulatory Commission to AREVA TN Americas CoC 1004, Amendment 14, CoC, dated March 31, 2017, effective April 25, 2017. (ADAMS Accession No. ML17191A236) 7.7 U.S. Environmental Protection Agency, Protective Action Guide and Planning Guidance for Radiological Incidents, dated January 2017 (PAG Manual) 7.8 Nuclear Energy Institute (NEI) 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, dated November 2012. (ADAMS Accession No. ML12326A805) 7.9 NRC Interim Compensatory Measures (ICM) Order EA-02-026, Section B.5.b mitigation strategies (dated February 25, 2002) (ADAMS Accession No. ML020510635) 7.10 NRC Bulletin (BL) 2005-02, Emergency Preparedness and Response Actions for Security Based Events, dated July 18, 2005 (ADAMS Accession No. ML051740058) 7.11 NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, Supplement 1, Volume 1, dated November 2002 7.12 NUREG/CR-3474, Long-Lived Activation Products in Reactor Materials, dated August 2000 7.13 NUREG-0654, FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, published November 1980 7.14 Letter, Mark Thaggard (USNRC) to Susan Perkins-Grew (NEI), U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 6, Dated November, 2012 (TAC No. D92368), dated March 28, 2013 (ADAMS Accession No. ML12346A463) 7.15 Letter from U.S. Nuclear Regulatory Commission to Dairyland Power Cooperative (La Crosse Boiling Water Reactor) Issuance of Amendment Relating to the Dairyland Power Cooperative La Crosse Boiling Water Reactor Request for Changes to the Emergency Planning Requirements, dated September 8, 2014 (ADAMS Accession No. ML14155A112) 7.16 Letter from U.S. Nuclear Regulatory Commission to Zion Solutions LLC (Zion Nuclear Power Station), Issuance of Amendments Relating to the Emergency Planning Requirements for Zion Nuclear Power Station, Units 1 and 2, dated May 14, 2015 (ADAMS Accession No. ML15092A423) 7.17 Memo, Office of Nuclear Security and Incident Response, Reactor Licensing Branch, Division of Preparedness and Response to Office of Nuclear Materials Safety and Safeguards, Division of Decommissioning, Uranium Recovery and Waste

LIC-19-0001 Page 24 Programs, Reactor Decommissioning Branch, Safety Evaluation Input for the Crystal River Unit 3 Independent Spent Fuel Storage Installation Only Emergency Plan (CAC No L53129), dated August 12, 2016 (ADAMS Accession No. ML16201A135) 7.18 Letter from U.S. Nuclear Regulatory Commission for Holders of Licenses for Operating Power Reactors Rescission or Partial Rescission of Certain Power Reactor Security Orders Applicable to Nuclear Power Plants, dated November 28, 2011 (ADAMS Accession No. ML111220447) 7.19 Letter from U.S. Nuclear Regulatory Commission to Vermont Yankee Nuclear Power Station - Issuance of Amendment to Change the Emergency Plan and Emergency Action Level Scheme to Reflect an ISFSI-Only Configuration (ML18053A112)

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION DOCKET NUMBER 50-285 / LICENSE NUMBER DPR-40 ATTACHMENT 1 SUPPORTING EVALUATIONS AND CALCULATIONS

FORT CALHOUN STATION DOCKET NUMBER 50-285 / LICENSE NUMBER DPR-40 ATTACHMENT 2 COMPARISON MATRIX FOR ISFSI EALS BASED ON NEI 99-01, Rev 6 DEVELOPMENT OF EMERGENCY ACTION LEVELS FOR NON-PASSIVE REACTORS THE PROPOSED REGULATORY GUIDE DG-1346 EMERGENCY PLANNING FOR DECOMMISSIONING NUCLEAR REACTORS TO THE PROPOSED FCS EMERGENCY CLASSIFICATION SYSTEM AND ISFSI EALS

LIC-19-0001 Attachment 2 Page 1 DG-1346, NEI 99-01 Rev 6, Formatted Table Proposed EAL Matrix for FCS Comparison Appendix CA ICs/EALs E-HU12 E-HU12 Removed Operating Mode applicability as it does not apply ECL: Unusual Event ECL: Unusual Event in a permanently defueled Initiating Condition: Damage to a condition loaded cask CONFINEMENT Initiating Condition: Damage to a BOUNDARY. loaded cask CONFINEMENT BOUNDARY.

Operating Mode Applicability: Not Applicable Example Emergency Action Levels: Emergency Action Levels: 1, 2, or 3 Provides FCS-specific radiation levels that conform to CoC 72-(1) Damage to a loaded cask 1. Damage to a loaded cask 1004 Technical Specification CONFINEMENT BOUNDARY as CONFINEMENT BOUNDARY as radiation limits indicated by an on-contact indicated by an abnormal radiation reading of 800 mrem/hr (gamma Included NOTE to identify that radiation reading greater than 2x

+neutron) at front Bird Screen of the radiation levels referenced in site specific cask technical the HSM. the EAL are taken at the specifications allowable radiation locations prescribed by the level on the surface of the spent 2. Damage to a loaded cask Technical Specifications for the fuel cask.Damage to a loaded CONFINEMENT BOUNDARY as Standardized NUHOM Horizontal cask CONFINEMENT indicated by an abnormal radiation Storage SystemProvided FCS-BOUNDARY as indicated by a reading of 20 mrem/hr (gamma specific radiation levels that

+neutron) on outer HSM Door. conform to 10 CFR 20.1301 radiation monitor reading greater than NORMAL background at or allowable levels based on Formatted: Indent: Left: 0.25", No bullets or

3. Damage to a loaded cask calculations.

near the cask. numbering CONFINEMENT BOUNDARY as indicated by an abnormal radiation reading of 10 mrem/hr (gamma

+neutron) on End Shield Wall exterior.

1. NOTE: Radiation readings are Formatted: Indent: Left: 0.25", No bullets or taken at the locations prescribed by numbering the Technical Specifications for the Standardized NUHOMS Horizontal Storage System (Amendment Number 15 to CoC 1004).Damage Formatted: Font: 9 pt to a loaded cask confinement BOUNDARY as indicated by an abnormal radiation reading of >2 mRem/hr. (gamma) within the ISFSI Protected Area or on a Horizontal Storage Module (HSM) concrete surface.

Basis: Basis: Added FCS specific basis This IC addresses an event that results This IC addresses an event that results information.

in damage to the CONFINEMENT in damage to the CONFINEMENT BOUNDARY of a storage cask BOUNDARY of a storage cask containing spent fuel. It applies to containing spent fuel. It applies to irradiated fuel that is licensed for dry irradiated fuel that is licensed for dry storage beginning at the point that the storage beginning at the point that the loaded storage cask is sealed. The loaded storage cask is sealed. The issues of concern are the creation of a issues of concern are the creation of a

LIC-19-0001 Attachment 2 Page 2 DG-1346, NEI 99-01 Rev 6, Formatted Table Proposed EAL Matrix for FCS Comparison Appendix CA ICs/EALs potential or actual release path to the potential or actual release path to the environment, degradation of one or environment, degradation of one or more fuel assemblies due to more fuel assemblies due to environmental factors, and environmental factors, and configuration configuration changes which could changes which could cause challenges cause challenges in removing the cask in removing the cask or fuel from or fuel from storage. storage.

The existence of damage is The existence of damage is determined by radiological survey. The determined by radiological survey. The technical specification multiple of 2 radiation limits listed in the EAL reflect times, which is also used in calculations based on the technical Recognition Category A IC AU1, is specification multiple of 2 times, is used here to distinguish between non- used here to distinguish between non-emergency and emergency conditions. emergency and emergency conditions.

The emphasis for this classification is The emphasis for this classification is the degradation in the level of safety of the degradation in the level of safety of the spent fuel cask and not the the spent fuel cask and not the magnitude of the associated dose or magnitude of the associated dose or dose rate. It is recognized that in the dose rate. It is recognized that in the case of extreme damage to a loaded case of extreme damage to a loaded cask, the IC may be determined based cask, the IC may be determined based on measurement of a dose rate at on measurement of a dose rate at some some distance from the cask. distance from the cask.10 CFR 20.1301(a)(2) radiation Security-related events for ISFSIs are dose limits to the public. In addition to covered under ICs EHU1 and EHA1. aligning with 10 CFR 20.1301 limits, the radiation levels chosen are a reasonable indication that actual cask confinement boundary has occurred due to the level being greater than calculated levels.

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

The Transnuclear Standardized NUHOMS System Technical Specifications Amendment 15 to CoC 1004, Section 5.4.1 (HSM or HSM-H Dose Rate Evaluation Program) contains site-specific radiation values for the cask that should not be exceeded. Keeping in line with NEl 99-01 guidance that an Unusual Event is warranted for radiation conditions at a level of twice the Technical Specification value, the values chosen for EAL E-HU1 represents these values.

The Note in the EAL provides guidance on where the radiation readings are to be taken when evaluating this EAL.

LIC-19-0001 Attachment 2 Page 3 DG-1346, NEI 99-01 Rev 6, Formatted Table Proposed EAL Matrix for FCS Comparison Appendix CA ICs/EALs EPD-HU1 EPD-HU1 Use of Unusual Event instead of Notification of Unusual Event ECL: Unusual Event ECL: Unusual event Use agrees in meaning and Initiating Condition: Confirmed intent with NEI 99-01, Rev 6.

SECURITY CONDITION, or threat. Initiating Condition: Confirmed SECURITY CONDITION, or threat, at Removed Operating Mode Formatted: Normal, Indent: Left: -0.01", Hanging:

Operating Mode Applicability: Not applicability as it does not apply the independent spent storage 0.19", Bulleted + Level: 1 + Aligned at: 0.25" + Indent Applicable in a permanently defueled installation (ISFSI).

condition at: 0.5" Example Emergency Action Levels: Emergency Action Levels: 1 or 2 Removed Example from (1 or 2 or 3) emergency action levels

1. A SECURITY CONDITION as (1) A SECURITY CONDITION that reported by the security force and Revised reporting person to does not involve a HOSTILE impacting the ISFSI. conform to security staffing ACTION as reported by the (site-specific security shift supervision) 2. Notification of a credible security Included distinction that the and impacting the ISFSI. threat directed at the ISFSI. threat impacts the ISFSI Removed the term HOSTILE (2) Notification of a credible security ACTION as it does not apply to threat directed at the siteISFSI. an ISFSI Only Facility (3) A validated notification from the Deleted EAL 3 related to aircraft NRC providing information of an threat aircraft threat.

Basis: Basis: Deleted reference to communicating with the Control This initiating condition (IC) addresses This IC addresses events that pose a Room and referenced events that pose a threat to plant threat to facility personnel or spent fuel, communicating with the ISFSI personnel and, thus, represents a and thus represent a potential Shift Supervisor/Emergency potential degradation in the level of degradation in the level of facility safety.

Director plant safety. Security events which do Security events which do not meet one not meet one of these emergency of these EALs are adequately Deleted wording associated with action levels (EALs) are adequately addressed by the requirements of aircraft threats addressed by the requirements of 10 CFR 73.71 or 10 CFR 50.72.

Section 73.71, Reporting of Security events assessed as HOSTILE Deleted wording regarding safeguards events, of Title 10 of the ACTION are classifiable under IC PD- security-sensitive information Code of Federal Regulations (10 CFR) HA1.

Part 73, Physical Protection of Plants and Materials, or Section 50.72, Timely and accurate communication Immediate notification requirements between the security force and the for operating nuclear power reactors, ISFSI Shift Supervisor/Emergency of 10 CFR Part 50, Domestic Director is essential for proper Licensing of Production and Utilization classification of a security-related event.

Facilities. Classification of these events will initiate appropriate threat-related notifications Timely and accurate communications to site personnel and Offsite Response between Security Shift Supervision Organizations (OROs).

and the Control Room is essential for proper classification of a security- Security plans and terminology are related event. Classification of these based on the guidance provided by NEI events will initiate appropriate threat- 03-12, Template for the Security Plan, related notifications to plant personnel Training and Qualification Plan,

LIC-19-0001 Attachment 2 Page 4 DG-1346, NEI 99-01 Rev 6, Formatted Table Proposed EAL Matrix for FCS Comparison Appendix CA ICs/EALs and offsite response organizations Safeguards Contingency Plan [and (OROs). Independent Spent Fuel Storage Installation Security Program].

Security plans and terminology are based on the guidance provided by EAL #1 references the security force NEI 03-12 Template for the Security because these are the individuals Plan, Training and Qualification Plan, trained to confirm that a security event Safeguards Contingency Plan [and is occurring or has occurred. Training Independent Spent Fuel Storage on security event confirmation and Installation Security Program]. classification is controlled due to the nature of Safeguards and 10 CFR 2.390 EAL #1 references (site-specific information.

security shift supervision) because these are the individuals trained to EAL #2 addresses the receipt of a confirm that a security event is credible security threat. The credibility occurring or has occurred. Training on of the threat is assessed in accordance security event confirmation and with Security procedures.

classification is controlled due to the nature of safeguards and Section Escalation of the emergency 2.390, Public inspections, exemptions, classification level would be via IC PD-and requests for withholding, of HA1.

10 CFR Part 2, Agency Rules of Practice and Procedure, information.

EAL #2 addresses the receipt of a credible security threat directed at the ISFSI. The credibility of the threat is assessed in accordance with (site-specific procedure).

EAL #3 addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may also be provided by North American Aerospace Defense Command (NORAD) through the NRC.

Validation of the threat is performed in accordance with (site-specific procedure).

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.

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

LIC-19-0001 Attachment 2 Page 5 DG-1346, NEI 99-01 Rev 6, Formatted Table Proposed EAL Matrix for FCS Comparison Appendix CA ICs/EALs PD-HA1 EPD-HA1 Changed Initiating Condition wording to delete the reference to ECL: Alert ECL: Alert the Owner Control Area Initiating Condition: HOSTILE Initiating Condition: ADVERSARIAL Changed Initiating Condition ACTION within the OWNER HOSTILE ACTION is occurring or has wording CONTROLLED AREA or airborne occurred.

attack threat within 30 minutes. Deleted reference to airborne Operating Mode Applicability: threat Formatted: Font:

IOEPNot Applicable Removed Operating Mode Formatted: List Paragraph, Indent: Left: -0.01",

applicability as it does not apply Hanging: 0.19", Bulleted + Level: 1 + Aligned at: 0.25" in a permanently defueled condition + Indent at: 0.5" Formatted: Font: 9 pt Example Emergency Action Levels: Emergency Action Levels: 1 Removed Example from Emergency Action Levels (1) A HOSTILE ACTION is occurring 1. An ADVERSARIALHOSTILE Formatted: Indent: Left: 0.02", Space Before: 6 pt, or has occurred within the ACTION is occurring or has Reworded to make EAL specific Numbered + Level: 1 + Numbering Style: 1, 2, 3, +

OWNER CONTROLLED occurred as reported by the to FCS ISFSI facility. The security force. Start at: 1 + Alignment: Left + Aligned at: 0.25" +

AREAISFSI as reported by the security force is trained on security events. The occurrence Indent at: 0.5" (site-specific security shift of a hostile action will be supervision). determined by security (2) A validated notification from NRC supervision in accordance with of an aircraft attack threat within security procedures 30 minutes of the site.

Deleted Example EAL 2 related to aircraft threat Basis: Basis: Changed wording to reflect FCS ISFSI EAL wording This IC addresses the occurrence of a This IC addresses the occurrence of an HOSTILE ACTION within the ISFSI or ADVERSARIALHOSTILE ACTION. Deleted wording associated with notification of an aircraft attack threat. aircraft threats This event will require rapid response Timely and accurate communication and assistance due to the possibility of between the security force and the Deleted reference to the attack compromising stored spent ISFSI Shift Supervisor/Emergency communicating with the Control fuel or damaging the storage casks, or Director is essential for proper Room and referenced the need to prepare the plant and staff classification of a security-related event. communicating with the ISFSI for a potential aircraft impact. Security plans and terminology are Shift Supervisor/Emergency based on the guidance provided by Director Timely and accurate communications between Security Shift Supervision NEI 03-12, Template for the Security Deleted information on aircraft and the Control Room is essential for Plan, Training and Qualification Plan, threat proper classification of a security- Safeguards Contingency Plan [and Independent Spent Fuel Storage Deleted wording regarding related event.

Installation Security Program]. security-sensitive information Security plans and terminology are based on the guidance provided by As time and conditions allow, these NEI 03-12. events require a heightened state of readiness by the facility staff and As time and conditions allow, these implementation of onsite protective events require a heightened state of measures (e.g., evacuation, dispersal or readiness by the plant staff and sheltering). The Alert declaration will implementation of possible onsite also heighten the awareness of Offsite protective measures (e.g., evacuation, Response Organizations (OROs),

LIC-19-0001 Attachment 2 Page 6 DG-1346, NEI 99-01 Rev 6, Formatted Table Proposed EAL Matrix for FCS Comparison Appendix CA ICs/EALs dispersal or sheltering). The Alert allowing them to be better prepared declaration will also heighten the should it be necessary to consider awareness of OROs, allowing them to further actions.

be better prepared should it be necessary to consider further actions. This IC does not apply to incidents that are accidental events, acts of civil This IC does not apply to incidents that disobedience, or otherwise are not a are accidental events, acts of civil HOSTILE ACTION perpetrated by a disobedience, or otherwise are not a hostile force. Examples include the HOSTILE ACTION perpetrated by a crash of a small aircraft, shots from HOSTILE FORCE. Examples include hunters, physical disputes between the crash of a small aircraft, shots from employees, etc. Reporting of these hunters, physical disputes between types of events is adequately employees, etc. Reporting of these addressed by other EALs, or the types of events is adequately requirements of 10 CFR 73.71 or addressed by other EALs, or the 10 CFR 50.72.

requirements of 10 CFR 73.71 or 10 CFR 50.72. This EAL is applicable for any HOSTILE ACTION directed against the ISFSI.

EAL #1 is applicable for any HOSTILE ACTION occurring, or that has occurred, in the ISFSI.

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

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

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

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This

LIC-19-0001 Attachment 2 Page 7 DG-1346, NEI 99-01 Rev 6, Formatted Table Proposed EAL Matrix for FCS Comparison Appendix CA ICs/EALs includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.

PD-HU3 PD-HU3 Use of Unusual Event instead Formatted Table of Notification of Unusual Event ECL: Notification of Unusual Event ECL: Unusual event Use agrees in meaning and Formatted: Right: -0.06" Initiating Condition: Other intent with NEI 99-01, Rev 6 Conditions exist which in the judgment Initiating Condition: Other Conditions exist which in the judgment of the Removed Operating Mode of the emergency director warrant emergency director warrant declaration applicability as it does not apply declaration of a NOUE.

of an Unusual Event. in a permanently defueled Operating Mode Applicability: Not condition Applicable Example Emergency Action Levels: Emergency Action Levels: 1 Removed Example from Formatted: Right: -0.06" emergency action levels (1) Other conditions exist which in the judgment of the Emergency 1. Other conditions exist which in the Reworded to make EAL specific Director indicate that events are in judgement of the Emergency to FCS ISFSI facility and align progress or have occurred which Director indicate that events are in with the systems utilized in the indicate a potential degradation of progress or have occurred which ISFSI the level of safety of the plant or indicate a potential degradation of indicate a security threat to facility the level of safety of the ISFSI or protection has been initiated. No indicate a security threat to facility releases of radioactive material protection has been initiated. No requiring offsite response or release of radioactive material monitoring are expected unless requiring offsite response or further degradation of safety monitoring are expected unless systems occurs. further degradation of systems important to safety occurs.

Basis: Basis: Use agrees in meaning and Formatted: Right: -0.06" intent with NEI 99-01, Rev. 6 This IC addresses unanticipated This IC addresses unanticipated conditions not addressed explicitly conditions not addressed explicitly elsewhere but that warrant declaration elsewhere but that warrant declaration of of an emergency because conditions an emergency because conditions exist exist which are believed by the which are believed by the Emergency Emergency Director to fall under the Director to fall under the emergency emergency classification level classification level description for an description for a NOUE. UNUSUAL EVENT.

PD-HA3 PD-HA3 Removed Operating Mode Formatted: Right: -0.06" applicability as it does not apply ECL: Alert ECL: Alert in a permanently defueled Initiating Condition: Other condition Conditions exist which in the judgment Initiating Condition: Other Conditions of the emergency director warrant exist which in the judgment of the declaration of an Alert.

LIC-19-0001 Attachment 2 Page 8 Operating Mode Applicability: Not emergency director warrant declaration Applicable of an ALERT.

Example Emergency Action Levels: Emergency Action Levels: 1 Removed Example from Formatted: Right: -0.06" emergency action levels (1) Other conditions exist which in the judgment of the Emergency 1. Other conditions exist which in the Reworded to make EAL specific Director indicate that events are judgement of the Emergency to FCS ISFSI facility and align in progress or have occurred Director indicate that events are in with the systems utilized in the which indicate a potential progress or have occurred which ISFSI substantial degradation of the involve an actual or potential level of safety of the plant or substantial degradation of the level Removed duplicate entry criterion Formatted: Indent: Left: -0.01", Hanging: 0.19" indicate a security threat that of safety of the ISFSI. Any releases for hostile action involves probable life threatening are expected to be limited to small risk to site personnel or damage fractions of the EPA Protective to equipment because of a Action Guideline exposure levels.

HOSTILE ACTION. Any releases are expected to be limited to a small fraction of the EPA Protective Action Guideline exposure levels.

Basis: Basis: No differences or deviations Formatted: Right: -0.06" This IC addresses unanticipated This IC addresses unanticipated conditions not addressed explicitly conditions not addressed explicitly elsewhere but that warrant declaration elsewhere but that warrant declaration of of an emergency because conditions an emergency because conditions exist exist which are believed by the which are believed by the Emergency Emergency Director to fall under the Director to fall under the emergency emergency classification level classification level description for an description for an Alert. ALERT.

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION DOCKET NUMBER 50-285 / LICENSE NUMBER DPR-40 ATTACHMENT 3 ISFSI ONLY EMERGENCY PLAN

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

ONLY EMERGENCY PLAN (Revision 0 when approved)

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION ISFSI ONLY EMERGENCY PLAN TABLE OF CONTENTS

1.0 INTRODUCTION

................................................................................................................ 1 1.1. Purpose ................................................................................................................... 1 1.2. Scope ...................................................................................................................... 1 2.0 DISCUSSION .................................................................................................................. 313 2.1. Overview of ISFSI Only Emergency Plan .......................................................... 313 2.2. Facility Description .............................................................................................. 414 2.3. Summary of Emergency Actions ........................................................................ 414 3.0 DEFINITIONS AND ACRONYMS .................................................................................. 515 3.1. Definitions ........................................................................................................... 515 3.2. Acronyms ............................................................................................................ 818

4.0 REFERENCES

............................................................................................................... 919 5.0 ASSIGNMENT OF RESPONSIBILITY ...................................................................... 11111 5.1. Emergency Response and Responsibility ...................................................... 11111 5.2. Offsite Response Organizations ..................................................................... 11111 6.0 EMERGENCY RESPONSE ORGANIZATION .......................................................... 13113 6.1. On-Shift Positions ........................................................................................... 13113 6.2. ERO Augmented Positions ............................................................................. 14114 6.3. Offsite Response Organizations ..................................................................... 15115 6.4. Functional Responsibilities ............................................................................. 15115 7.0 OFFSITE EMERGECY RESPONSE SUPPORT AND RESOURCES ...................... 16116 8.0 EMERGENCY CLASSIFICATION SYSTEM ............................................................. 17117 8.1. Emergency Classification System .................................................................. 17117 8.2. Emergency Action Levels and Postulated Accidents ..................................... 18118 9.0 NOTIFICATION METHODS AND PROCEDURES ................................................... 19119 9.1. Basis for Emergency Notification.................................................................... 19119 9.2. Emergency Messages .................................................................................... 19119 9.3. Means of Providing Emergency Notification .................................................. 20120

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 10.0 EMERGENCY COMMUNICATIONS ......................................................................... 22122 11.0 PUBLIC INFORMATION ............................................................................................ 23123 12.0 EMERGENCY FACILITY AND EQUIPMENT ............................................................ 24124 12.1. Emergency Response Facility ........................................................................ 24124 12.2. Emergency Equipment and Supplies ............................................................. 24124 12.3. First Aid Facilities ............................................................................................ 25125 13.0 ACCIDENT ASSESSMENT ....................................................................................... 26126 14.0 PROTECTIVE ACTIONS............................................................................................ 27127 14.1. Accountability ...................................................................................................... 271 14.2. ISFSI Egress Control Methods ....................................................................... 27127 15.0 RADIOLOGICAL EXPOSURE CONTROL ................................................................ 28128 15.1. Exposure Guidelines ....................................................................................... 28128 15.2. Radiation Protection Program ........................................................................ 28128 16.0 MEDICAL AND HEALTH SUPPORT ........................................................................ 31131 16.1. Onsite First Aid ............................................................................................... 31131 16.2. Medical Transportation ................................................................................... 31131 16.3. Offsite Medical Support .................................................................................. 31131 17.0 EMERGENCY TERMINATION AND RECOVERY .................................................... 32132 17.1. Emergency Termination and Notification ....................................................... 32132 17.2. Recovery Operations ...................................................................................... 32132 18.0 EXERCISES AND DRILLS ........................................................................................ 33133 18.1. Emergency Plan Exercises and Drills ............................................................ 33133 18.2. Equipment and Proficiency Drills/Tests .......................................................... 34134 18.3. Critiques and Evaluation ................................................................................. 35135 19.0 EMERGENCY RESPONSE TRAINING ..................................................................... 36136 19.1. Emergency Response Personnel Training ..................................................... 36136 19.2. Emergency Response Support Organizations ............................................... 37137 19.3. Annual Emergency Action Level Training ...................................................... 38138 20.0 RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW, AND DISTRIBUTION ................................................................................. 39139 20.1. Emergency Preparedness Responsibilities .................................................... 39139 20.2. Review and Updating of the IOEP .................................................................. 40140 20.3. Training ........................................................................................................... 40140 20.4. Maintenance and Inventory of Emergency Equipment and Supplies ............ 40140

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 APPENDICES Page Appendix A Emergency Equipment, Supplies and Reference Materials 4239 Appendix B Cross Reference IOEP Section to Planning Standards/Requirements/Criteria and EPIPs 4341 LIST OF TABLES Page Table 6-1 Emergency Response Organization Staffing and Responsibilities 1514 Table 10-1 Communications Systems 2221 Table 15-1 Response Worker Emergency Dose Limits 3029 Table B-1 Cross Reference IOEP Section to Planning Standards/Requirements/Criteria and EPIPs 4442

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 INTRODUCTION Fort Calhoun Station (FCS) permanently ceased power operations on October 24, 2016.

On November 13, 2016, by letter (LIC-16-0074), Omaha Public Power District (OPPD) provided certification to the U.S. Nuclear Regulatory Commission (NRC) required by 10 CFR 50.82(a)(1)(i) and (ii) that FCS had permanently ceased power operations and that all fuel had been permanently removed from the reactor vessel. Subsequently, all spent fuel has been transferred to the onsite Independent Spent Fuel Storage installation (ISFSI) facility.

The FCS ISFSI Only Emergency Plan (IOEP) describes the plan for responding to emergencies that may arise at the ISFSI. In this condition, no reactor operations can take place and all irradiated fuel has been removed from the Spent Fuel Pool. This IOEP adequately addresses the risks associated with FCSs current conditions.

The ISFSI Updated Final Safety Analysis Report (UFSAR) describes the Design Basis Accidents (DBAs) applicable to the FCS ISFSI along with the radiological dose calculation results. As provided in the ISFSI UFSAR, the analyses of the potential radiological impacts of postulated off-normal, natural phenomena, and accident events involving the ISFSI indicate that any releases would result in a dose to the public below those limits established in 10 CFR 72.106(b). Therefore, exposure levels, which warrant pre-planned response measures are limited to the ISFSI and immediate vicinity, and for this reason, radiological emergency planning is focused on this area.

1.1. Purpose The purpose of the IOEP is to ensure an adequate level of preparedness to cope with the spectrum of emergencies that could be postulated to occur. This plan integrates the necessary elements to provide effective emergency response considering cooperation and coordination of organizations expected to respond to potential emergencies.

1.2. Scope The IOEP has been developed to respond to potential radiological emergencies at the FCS ISFSI. Because there are no postulated off-normal, natural phenomena, or accident events that would result in dose consequences that are large enough to require offsite emergency planning, the overall scope of the IOEP details the actions necessary to safeguard onsite personnel. The concepts presented in the IOEP address the applicable regulations stipulated in 10 CFR 50.47, Emergency Plans, and Appendix E to 10 CFR 50, Emergency Planning and Preparedness for Production and Utilization Facilities. The IOEP is consistent with the applicable guidelines established in NUREG 0654/FEMA REP 1, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 Exemptions from selected portions of 10 CFR 50.47 and 10 CFR Part 50 Appendix E were approved by the NRC on December 11, 2017 (ADAMS Accession Number ML17263B198)

The IOEP, Revision 0 was approved per NRC Safety Evaluation on [insert date prior to issuing] (ADAMS Accession Number ML#########) [insert ADAMS Accession Number prior to issuing].

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 DISCUSSION 2.1. Overview of ISFSI Only Emergency Plan In the event of an emergency at the FCS ISFSI, actions are required to identify and assess the nature of the emergency and to bring it under control in a manner that protects the health and safety of the public and onsite personnel.

The IOEP describes the organization and responsibilities of FCS for implementing emergency measures and describes interfaces with offsite agencies (Federal, State, and local) and organizations that may be notified in the event of an emergency and may provide assistance.

Emergency fire/rescue, law enforcement, and medical response are provided by local public and private entities. Specifically, fire/rescue support services and transportation of injured and/or contaminated personnel are provided by the Blair Volunteer Fire Department; fixed medical services are provided by Blair Hospital providing 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; and law enforcement support services are provided by local, State, and Federal law enforcement authorities, as appropriate.

FCS is licensed under the requirements of 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities. Consistent with the requirements of 10 CFR Part 50, Section 50.47(b) and Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, with approved exemptions. Sections 5.0 through 20.0 of this IOEP address the standards outlined in 10 CFR 50.47(b)(1) through (16). In addition, the IOEP is also intended to meet appropriate State and U.S. NRC regulations in accordance with OPPDs Operating License (No. DPR-40). OPPD is licensed to store spent fuel in the FCS ISFSI under the General License provisions of 10 CFR 72.210 and 10 CFR 72.212.

Because the analyses of credible design basis events and consequences indicate there are no postulated events that would result in offsite dose consequences large enough to require offsite emergency planning, emergencies are divided into two classifications: 1) Notification of Unusual Event (Unusual Event) and 2) Alert.

OPPD is responsible for planning and implementing emergency measures associated with the FCS ISFSI. This IOEP is provided to meet this responsibility.

To carry out specific emergency measures discussed in the IOEP, detailed Emergency Plan Implementing Procedures (EPIPs) are established and maintained. Appendix B provides a listing of the EPIPs for the IOEP.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 In addition to the description of activities and steps that can be implemented during a potential emergency, the IOEP also provides a general description of the steps taken to recover from an emergency. It also describes the training, exercises and drills, planning, and coordination appropriate to maintain an adequate level of emergency preparedness.

2.2. Facility Description FCS is located midway between Fort Calhoun and Blair, Nebraska, on the west bank of the Missouri River. The site is located approximately 19 miles North of Omaha, Nebraska and 4 miles South of Blair. The ISFSI is located within the Protected Area of the site.

FCS is certified to have ceased power operations and is permanently defueled in accordance with 10 CFR 50.82(a)(1)(i) and (ii). All spent fuel has been transferred to the FCS ISFSI. The FCS ISFSI is a robust and high integrity facility for the spent fuel storage system. This facility is designed to prevent the release of radioactivity in the event of accidents, including environmental phenomena (e.g., earthquake and flooding).

2.3. Summary of Emergency Actions This plan is activated by the ISFSI Shift Supervisor (ISS) upon identification of an emergency situation based upon the Emergency Action Level (EAL) criteria.

The ISS assumes the position of the Emergency Director upon classification of an emergency. The emergency measures described in the subsequent sections and EPIPs are implemented in accordance with the classification and nature of the emergency, and at the direction of the Emergency Director. The Emergency Director has the authority and responsibility for control and mitigation of the emergency, including emergency response resources, and coordination of emergency response activities.

The following sections of this IOEP describe the detailed plans and actions of the FCS Emergency Response Organization (ERO), including interfaces with offsite support organizations.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 DEFINITIONS AND ACRONYMS This section provides definitions and acronyms used in this document. Terms capitalized in the text of the definitions indicate that they are defined elsewhere in this section.

3.1. Definitions Accountability - A discretionary protective action taken for all persons onsite Formatted: Font: Not Bold, No underline (within the ISFSI PROTECTED AREA) that involves the gathering of personnel into pre-designated areas and subsequent verification that the location of all personnel is known. Commented [PDM1]: RAI-4 Formatted: Font: Not Bold, No underline Adversary- An individual who has not been granted unescorted access to a sites protected area, or access to a sites critical systems, who attempts (or is actively engaged in planning for or attempting) to gain unauthorized entry to the ISFSI Protected Area, or access to critical systems for the purposes of committing an act of radiological sabotage. Commented [PDM2]: RAI-1 Adversarial Action: An attempted or unauthorized entry into the ISFSI Protected Area via the fence or barrier in an attempt to steal or damage nuclear fuel for the purposes of committing an act of radiological sabotage.

Unauthorized entry can be by air or land using guns, explosive, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Commented [PDM3]: RAI-1 Alert - Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the ISFSI. Any releases are expected to be limited to small fractions of the Environmental Protection Agency (EPA) Protective Action Guideline (PAG) exposure levels.

Annual - Once per calendar year, unless otherwise stated.

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

Corrective Action - Those emergency measures taken to mitigate or terminate an emergency situation at or near the source of the problem in order to prevent an uncontrolled release of radioactive material or to reduce the magnitude of a release (e.g., equipment shutdown, firefighting, equipment repair, and damage control).

Design Basis Accident (DBA) - Credible accident events as analyzed in the ISFSI Updated Final Safety Analysis Report.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 Emergency Action Level (EAL) - A pre-determined, site-specific, observable threshold for an INITIATING CONDITION (IC) that, when met or exceeded, places the ISFSI in a given emergency classification level.

Emergency Classification System - A system of classification in which emergency occurrences are categorized according to specific protective action levels. The two emergency classification levels, in ascending order of severity, are: NOTIFICATION OF UNUSUAL EVENT and ALERT.

Emergency Director - This position is the highest level of authority for the FCS Emergency Response Organization (ERO) and onsite emergency activities. This position is held by the ISFSI Shift Supervisor (ISS) or designated alternate.

Emergency Plan Implementing Procedure (EPIP) - Specific procedures describing actions taken by plant staff to activate and implement the IOEP.

Emergency Response Facility (ERF) - Facility containing the communications equipment necessary for emergency conditions. It is operated under the direction of the Emergency Director and serves as the primary location for classification of the emergency, notification of the emergency to offsite agencies, ASSESSMENT ACTIONS, and CORRECTIVE ACTION direction.

Emergency Response Organization (ERO) - Organization comprised of assigned individuals who would respond and assist during a classified emergency.

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

Hostile Action - An act toward the ISFSI or its personnel that includes the use Formatted: Font: Bold, Underline of violent force to destroy equipment, take hostages, and/or intimidate the Formatted: Indent: Left: 1.03" licensee to achieve an end. This includes, but is not necessarily limited to, attack by air, land, or water using guns, explosives, projectiles, vehicles or devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts are not part of a concerted attack on the ISFSI.

Violent acts between individuals in the owner controlled area do not meet this definition. Commented [PDM4]: RAI-1 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): - A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage and GTCC radioactive material.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 Initiating Condition (IC) - An event or condition that aligns with the definition of one of the two emergency classification levels by virtue of the potential or actual effects or consequences.

Monthly - Frequency of occurrence is met if performed within 1.25 times a 31 Formatted: No underline day interval as measured from the previous performance.

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

Protected Area (PA) - That area within the perimeter of the security fence.

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

Protective Action Guide (PAG) - The projected dose to an individual, resulting from a radiological incident at which specific protective actions to reduce or avoid that dose are warranted.

Radioactive Release - Any radioactive material beyond pre-emergency levels and not attributable to normal operations, either detected or suspected of migrating beyond the PROTECTED AREA, while in a classified emergency.

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

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

Security Condition - Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the ISFSI.

Site - That property of Fort Calhoun Station which is owned by the Licensee.

Site Boundary - The perimeter of the land owned by OPPD surrounding the ISFSI. The ISFSI Controlled Area, as defined by 10 CFR 72.3, is bounded within the Site Boundary.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 3.2. Acronyms ALARA As Low As Reasonably Achievable DBA Design Basis Accident EAL Emergency Action Level ENS Emergency Notification System EPA Environmental Protection Agency EPIP Emergency Plan Implementing Procedure ERF Emergency Response Facility ERO Emergency Response Organization FCS Fort Calhoun Station FTS Federal Telecommunication System IC Initiating Condition IOEP ISFSI Only Emergency Plan ISFSI Independent Spent Fuel Storage Installation ISS ISFSI Shift Supervisor LLEA Local Law Enforcement Agency NRC Nuclear Regulatory Commission OPPD Omaha Public Power District ORO Offsite Response Organization PAG Protective Action Guide RCA Radiological Control Area UFSAR Updated Final Safety Analysis Report 8

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 REFERENCES

1. 10 CFR 50.47, Emergency Plans

2. 10 CFR 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities

3. 10 CFR 20, Standards for Protection Against Radiation

4. NUREG-0578, "TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations" (July 1979)

5. NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Rev. 1

6. Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors"

7. FCS ISFSI Storage System, Certificates of Compliance, Updated Final Safety Analysis Report, and Technical Specifications

8. NRC Bulletin (BL) 2005-02, Emergency Preparedness and Response Actions for Security Based Events, dated July 18, 2005 (ADAMS Accession No. ML051740058)

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

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

11. EPAs Protective Action Guides and Planning Guidance for Radiological Incidents, EPA-400/R-17/001 dated January 2017

12. Letter, OPPD to USNRC, Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel, LIC-16-0074, dated November 13, 2016 (ADAMS Accession No. ML16319A254)

13. Fort Calhoun Station - Exemption from Certain Emergency Planning Requirements and Related Safety Evaluation, February 15, 2017(ADAMS Accession Number ML17041A238)

14. NUREG-0586, Generic Environmental Impact Statement of Decommissioning of Nuclear Facilities, Supplement 1, Volume 1, November 2002

15. NRC Information Notice No. 90-08: KR-85 Hazards from Decayed Fuel

16. 10 CFR 72.13, Applicability

17. 10 CFR 72.32, Emergency Plan

18. 10 CFR 72.44, License Conditions

19. 10 CFR 72.106, Controlled Area of an ISFSI or MRS

20. Fort Calhoun Station ISFSI Security Plan 9

FCS ISFSI ONLY EMERGENCY PLAN Revision 0

21. Fort Calhoun Station ISFSI EAL Technical Bases 10

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 ASSIGNMENT OF RESPONSIBILITY The FCS ISFSI Organization has 24-hour capability to perform the detection, classification, initial response, and notification functions required during an emergency.

Primary responsibilities for emergency response have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

5.1. Emergency Response and Responsibility OPPD is responsible for the safe storage of spent fuel in accordance with the State of Nebraska and NRC regulations. Responsibility for planning and implementing all emergency measures rests with OPPD.

FCS ISFSI Organization has an inherent emergency response/recovery function in its overall management and operation.

The ISFSI Shift Supervisor (ISS) is at FCS on a continuous, 24-hour per day basis, and is the senior management position during off-hours. This position is responsible for monitoring ISFSI conditions and managing the activities at the FCS ISFSI. The ISS has the responsibility and authority to declare an emergency and initiate appropriate actions in accordance with written procedures to mitigate the consequences. When an off-normal, natural phenomenon, or accident event becomes apparent, the ISS shall assess the condition and assume the position of Emergency Director once an emergency declaration has been made.

The Emergency Director is responsible for the direction of all activities at the ISFSI site during an emergency. Should evaluation indicate the need, the Emergency Director has the authority to direct any or all personnel to relocate from the ISFSI and surrounding area and to notify all applicable agencies of the ISFSI status. The Emergency Director ensures that appropriate actions are taken and management and applicable offsite supporting organizations and regulatory agencies are notified, as necessary.

The functions associated within the Emergency Directors scope of responsibilities are specified on Table 6-1.The Emergency Director does not have concurrent duties which conflict with the these responsibilities.

A Resource Manager assists in assessing the event and obtaining additional resources needed to respond to the event.

5.2. Offsite Response Organizations The Emergency Director coordinates the Offsite Response Organization (ORO) response (fire/rescue, ambulance, and local law enforcement agency (LLEA)),

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 access, and radiological controls with the onsite activities. The OROs are capable of 24-hour emergency response.

The response of the State of Nebraska and local government agencies are in accordance with each agency's plans and procedures, and are commensurate with the hazard posed by the emergency.

Letters of Agreement are in place for those local organizations that will respond.

State of Nebraska Notification of an emergency declaration or change in classification is provided to the State of Nebraska via the commercial telephone system.

The State of Nebraska is capable of receiving the notification on a 24-hour per day basis.

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.

Transportation of Injured and Contaminated Personnel 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. The Fort Calhoun Volunteer Fire Department has agreed to provide backup services.

Treatment of Radioactively Contaminated and Injured Personnel The Blair Hospital has agreed to provide medical support for work-related injuries. University of Nebraska Medical Center (UNMC) in Omaha, maintains a regional Radiation Health Center which provides services for the treatment of radiologically contaminated injuries and radiation exposure evaluation.

Law Enforcement Law enforcement support services are provided by local, State of Nebraska, and federal law enforcement authorities as appropriate, and response capabilities are documented in the Letters of Agreement maintained by Security.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 EMERGENCY RESPONSE ORGANIZATION Emergency Response Organization (ERO) responsibilities for emergency response are identified in Table 6-1, Emergency Response Organization Staffing and Responsibilities.

6.1. On-Shift Positions FCS maintains personnel on-shift at all times capable of providing the initial response to an off-normal, natural phenomenon, or accident event. Members of the on-shift organization are trained on their responsibilities and duties in the event of a classified emergency and are capable of performing all necessary response actions until any necessary augmenting staff arrives or the event is terminated. The on-shift staffing assignments include the roles and responsibilities for their emergency response functions.

ISFSI Shift Supervisor The ISS is at FCS 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day and is the senior management position during off-hours. When an off-normal, natural phenomenon, or accident event becomes apparent, the ISS shall assess the condition and assume the position of Emergency Director once an emergency classification has been made.

Emergency Director This position is responsible for monitoring conditions and approving all onsite activities and has the requisite authority, management ability, technical knowledge, and staff to manage the site emergency and recovery organization.

The Emergency Director is responsible for the direction of the total emergency response and has the company authority to accomplish this responsibility. The Emergency Director assumes overall command and control.

The Emergency Director cannot delegate the following responsibilities:

Classification of an event Approval of emergency notifications (although the task of making notifications may be delegated)

Authorization of radiation exposures in excess of 10 CFR Part 20 limits The Emergency Director is responsible for assuring that appropriate corrective and protective actions are taken to mobilize emergency response personnel and for notifying management, OROs, and regulatory 13

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 agencies, as necessary. Other responsibilities assumed by the Emergency Director associated with the functions listed in Table 6-1 include:

Notification of the emergency classification to the NRC and the State of Nebraska Management of available station resources Initiation of mitigative, corrective, and onsite protective actions Decision to call for LLEA, fire/rescue, or ambulance assistance Augmentation of the emergency staff, as deemed necessary Coordination of security activities Termination of the emergency condition when appropriate Performance of initial radiological assessment Maintaining a record of event activities Suspending security measures Security Security is administered by the ISFSI Physical Security Plan. Security will perform accountability as directed by the ISS or Emergency Director. Commented [PDM5]: RAI-4 6.2. ERO Augmented Positions FCS maintains the necessary personnel and resources to support the Emergency Director in responding to an emergency.

Resource Manager The Resource Manager will be in contact with the Emergency Director within two (2) hours of an emergency declaration. The Resource Manager will augment the Emergency Director by assisting in the assessment of the emergency condition and coordinating any required resources, including serving as the public information interface. The Resource Manager does not need to physically report to the ERF to perform the assigned responsibilities.

Radiological Assessment Personnel For a declared emergency involving radiological consequences, a minimum of one person trained in radiological monitoring and assessment will report to the ERF within four (4) hours of the emergency declaration.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 Additional Resources Additional personnel resources may be directed to report to FCS by the Emergency Director to provide additional support as needed to assess radiological conditions, support maintenance and repair activities, develop and implement corrective action plans, and assist with recovery actions. The augmentation personnel are available from FCS staff, OPPD, Nebraska Public Power Districts Cooper Nuclear Station, and can be requested from various contractors.

6.3. Offsite Response Organizations Additional support is available from OROs, as described in Section 5.2 of this Plan.

6.4. Functional Responsibilities Table 6-1 lists the functional responsibilities that fulfill emergency staffing capabilities.

TABLE 6-1 Emergency Response Organization Staffing and Responsibilities AUGMENTED FUNCTIONAL AREA LOCATION ON-SHIFT STAFF

RESPONSE

Assessment of Condition Emergency Response Emergency Director Resource Manager (Emergency Declaration) Facility Emergency Direction and Emergency Response Emergency Director ---

Control Facility Notifications / Emergency Response Emergency Director ---

Communications Facility Resource Manager Radiological Accident Emergency Response Radiological Assessment and Emergency Director Facility / On Scene Assessment Protective Actions Personnel**

Emergency Response Corrective Actions Emergency Director ---

Facility / On Scene Per Fire Protection Offsite Response Fire Fighting On Scene Program Plan Organization 15

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 Rescue and First Aid Offsite Response On Scene

• Treatment Organization Site Access Control and Per ISFSI Security Per ISFSI Security Accountability Procedureslan Procedureslan Commented [PDM6]: RAI-4

• Provided by on-shift personnel who may be assigned other functions

• • For a declared emergency involving radiological consequences, a minimum of one (1) person trained in radiological monitoring and assessment will report to the ERF within four (4) hours of the emergency declaration.

OFFSITE EMERGECY RESPONSE SUPPORT AND RESOURCES Arrangements for requesting and effectively using resources have been made and other organizations capable of augmenting the planned response have been identified. Letters of Agreement are in place for those local organizations (fire/rescue, ambulance, LLEA, and medical) that will respond to an emergency at the FCS ISFSI. The Letters of Agreement for each agency are maintained on file.

The Emergency Director coordinates the fire/rescue, ambulance, and LLEA response as previously discussed in Section 5.2 of this Plan.

The Emergency Director is authorized to request Federal assistance as needed. The NRC will act as the lead Federal agency providing coordination and support in response to an emergency at FCS.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 EMERGENCY CLASSIFICATION SYSTEM A standard emergency classification and emergency action level scheme is in use. This section describes emergency classifications, Initiating Conditions (ICs), Emergency Action Levels (EALs), and postulated emergency situations.

8.1. Emergency Classification System The emergency classification system covers the entire spectrum of possible radiological and non-radiological emergencies at the FCS ISFSI. The emergency classification system categorizes accidents and/or emergency situations into one of two emergency classification levels depending on emergency conditions at the time of the incident: Unusual Event and Alert. Each of these emergency classes requires notification to the Resource Manager, the State of Nebraska, and the NRC.

Once indications are available that an EAL is met, the event is assessed and classified, and the corresponding emergency classification level is promptly declared as soon as possible. Refer to the ISFSI Emergency Action Level Technical Bases for actual parameter values, and status used to classify emergencies.

Incidents may be initially classified as an Unusual Event and then escalated to an Alert if the situation deteriorates. The following Sections outline the actions at each classification level.

Unusual Event EVENTS ARE IN PROGRESS OR HAVE OCCURRED WHICH INDICATE A POTENTIAL DEGRADATION OF THE LEVEL OF SAFETY OF THE ISFSI OR INDICATE A SECURITY THREAT TO ISFSI PROTECTION HAS BEEN INITIATED. NO RELEASES OF RADIOACTIVE MATERIAL REQUIRING OFFSITE RESPONSE OR MONITORING ARE EXPECTED.

Upon classification of an Unusual Event, offsite authorities will be informed of the emergency classification and the necessary documentation will be completed as specified in the EPIPs.

The purpose of the Unusual Event declaration is to: 1) provide for an increased awareness of abnormal conditions; 2) provide for systematic handling of information and decision-making, and 3) augment on-shift personnel, if deemed necessary by the Resource Manager.

The classification shall be maintained until the emergency is terminated or the emergency escalates to an Alert. If an escalation to an Alert 17

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 occurs, offsite authorities will be informed within 60 minutes of the change in emergency classification.

ALERT EVENTS ARE IN PROGRESS OR HAVE OCCURRED WHICH INVOLVE AN ACTUAL OR POTENTIAL SUBSTANTIAL DEGRADATION OF THE LEVEL OF SAFETY OF THE ISFSI. ANY RELEASES ARE EXPECTED TO BE LIMITED TO SMALL FRACTIONS OF THE ENVIRONMENTAL PROTECTION AGENCY (EPA) PROTECTIVE ACTION GUIDELINE (PAG) EXPOSURE LEVELS.

Upon classification of an Alert, offsite authorities will be informed of the emergency classification and the necessary documentation will be completed as specified in the EPIPs.

The purpose of the Alert declaration is to: 1) perform event mitigation and radiation monitoring, if required, and 2) ensure that all necessary resources are being applied to accident mitigation.

Plant responses associated with this event classification ensure that sufficient emergency response personnel are mobilized and respond to event conditions. The Alert classification includes emergency situations which are not expected to threaten the public.

The classification shall be maintained until the emergency is terminated.

FCS may enter Recovery operations while in the Alert classification.

8.2. Emergency Action Levels and Postulated Accidents Both emergency classifications are characterized by EALs consisting of specific instrument readings and/or observations which indicate to the ISS that an IC has been met. These EALs are used to ensure that the initial classification of emergencies can be accomplished rapidly, allowing for the prompt identification of the necessary mitigating actions. EALs and ICs are provided under the following categories:

ISFSI Hazards and other ConditionsSecurity Commented [PDM7]: RAI-2 The ISFSI UFSAR describes the DBAs applicable to the FCS ISFSI and the radiological dose calculation results. Specific guidance for classifying emergencies is found in EPIPs and the ISFSI EAL Technical Bases Document.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 NOTIFICATION METHODS AND PROCEDURES Procedures are established for notification to the State of Nebraska and local organizations and for notification of FCS emergency personnel. FCS has established the means for notification and dissemination of emergency messages. The content of initial and follow-up messages to response organizations has been established.

9.1. Basis for Emergency Notification The notification of personnel and emergency response organizations is commensurate with the hazard posed by the emergency. The emergency classification system described in Section 8.0 is the primary bases for notification and has been mutually agreed upon by applicable State and Federal organizations.

9.2. Emergency Messages The Emergency Director is responsible for the notification of an emergency declaration to the State of Nebraska and the NRC within 60 minutes of the event classification or change in classification.

The format and contents of the initial message between FCS and the State of Nebraska are specified in notification procedures and have been established with the review and agreement of the responsible state authorities. The initial notification contains the following information, as available:

Identification of the facility Identification of the message sender Date and Time of the emergency declaration Emergency classification, including EAL Radiological conditions Follow up reports are provided as additional information describing the emergency situation becomes available, or as requested by the State of Nebraska, until such time that the emergency condition has been terminated.

The follow-up messages will contain the following information, as available:

Identification of the facility Identification of the message sender Date and Time of the emergency declaration Emergency classification, including EAL Radiological conditions, including an assessment of any radioactive release Emergency response actions underway Request for any needed support from offsite agencies Prognosis for worsening or termination of the event based on available information 19

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 9.3. Means of Providing Emergency Notification Various communications systems, as described in Section 10.0, are available to perform emergency notifications. The Emergency Director is the primary individual for initiating notifications. However, the Emergency Director may designate an individual to perform the notifications. EPIPs and emergency telephone directories identify organizations and individuals to be notified and contain appropriate listings of telephone numbers.

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

State of Nebraska Notification of an emergency declaration, and specific emergency information, is conveyed to the State of Nebraska using the commercial telephone system. This system is available in the ERF on a 24-hour per day basis.

Other commercial means, including the use of wireless communications, will serve as a backup to the commercial telephone system.

NRC Emergency Notification System The NRC utilizes the Federal Telecommunications System (FTS) telephone network. The FTS system provides a dedicated telephone network. The Emergency Notification System (ENS) utilizes an FTS line which exists between the NRC Operations Office in Rockville, Maryland and FCS. Emergency notification, facility status information, and radiological information are communicated via the ENS.

The NRC will be notified as soon as possible after State notification and within 60 minutes of event declaration or change in classification.

The commercial telephone system serves as a backup to the ENS.

ERO Notification The Resource Manager is notified of an emergency declaration by an onsite announcement, the commercial telephone system, or other means which may include land line and/or wireless devices. The Emergency Director is responsible for the notification to the Resource Manager. As described in Section 5.1 of this Plan, the on-shift staff positions are available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day and can perform all required IOEP actions.

The Resource Manager will be in contact with the Emergency Director within two (2) hours of an emergency declaration. At the direction of the 20

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 Emergency Director, additional personnel will be activated to augment the on-shift staff.

Notification of Offsite Response Organizations The ORO support services described in Section 5.2 of this Plan are primarily notified of the need for assistance via 911 utilizing the commercial telephone system. Requests for ORO support services are the responsibility of the Emergency Director.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 EMERGENCY COMMUNICATIONS Provisions exist for prompt communications between principal response organizations and emergency response personnel. The communications systems listed in Table 10-1 provide 24-hour onsite and offsite communications capability allowing for prompt notification and activation of emergency personnel. In the event of an emergency declaration, these communications systems provide the appropriate means for alerting or activating emergency personnel in each response organization and allow continued means for contact throughout the emergency.

Communications systems providing the capability for onsite and offsite communications are tested to verify proper operation at the frequencies specified in Table 10-1.

Communications systems that are listed with a testing frequency of Frequent Use indicates that the associated equipment is normally used at a sufficiently high regularity (e.g., multiple times each day), such that separate additional testing is not needed.

Functionality is verified through normal (frequent) use of the system.

TABLE 10-1 Communications Systems Communications System Testing Frequency Commercial Telephone System Monthly Portable Radios Frequent Use NRC ENS Monthly 22

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 PUBLIC INFORMATION As part of its normal corporate structure, OPPD maintains a corporate public affairs office that can be called upon, as necessary. The public affairs office will be notified of an emergency classification by the Emergency Director or Resource Manager.

Public affairs office personnel will monitor media activity and coordinate with senior management to address rumors and disseminate information to the public. News conferences can be conducted onsite or at other locations, as necessary. Senior FCS or OPPD management will be assigned as spokespersons.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 EMERGENCY FACILITY AND EQUIPMENT Adequate emergency facilities and equipment to support the emergency response are provided and maintained. This section of the IOEP identifies and describes the ERF, assessment equipment, the first aid and medical facilities, and protective equipment and supplies that can be utilized during an emergency.

12.1. Emergency Response Facility The emergency command and control functions are managed within the ERF.

From the ERF, the Emergency Director (or other personnel, as directed) can assess ISFSI conditions; evaluate the magnitude and potential consequences of abnormal conditions; initiate preventative and corrective actions; and perform emergency notifications.

The ERF is staffed in accordance with Section 6.0 of this Plan. The facility provides sufficient space to accommodate anticipated response personnel and provides 24-hour availability of the communications systems specified in Table 10-1.

Radiological conditions resulting from the design basis accidents specified in the ISFSI UFSAR do not inhibit staffing of the ERF.

12.2. Emergency Equipment and Supplies This section describes the monitoring instruments used to initiate emergency measures and provide continuing assessment of conditions throughout the course of an emergency.

Portable Radiation and Contamination Monitoring Instruments Portable radiation and contamination monitoring equipment necessary for monitoring the conditions of the FCS ISFSI are utilized and maintained by the Radiation Protection group, are available for emergency use.

Communications Systems Communications systems providing for 24-hour per day onsite and offsite communications capabilities are identified and tested as described in section 10.0 of this IOEP.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 Emergency Supplies Emergency equipment and supplies necessary to carry out the provisions of the IOEP and support procedures are maintained at the Emergency Response Facility. Appendix A, Emergency Equipment, Supplies and Reference Materials, lists required equipment, supplies and reference materials that are to be maintained in the ERF and other onsite locations.

Emergency equipment is inspected, inventoried and operationally checked at least quarterly and any time it is opened or used. Sufficient reserves are provided to replace items removed for calibration or repair.

Calibration of instruments is at intervals recommended by instrument suppliers or as required by Federal regulations.

12.3. First Aid Facilities First aid supplies and equipment are located at the ERF. Qualified personnel are available 24/7 to provide medical treatment referenced in Section 16.0.

Radiological wound monitoring onsite is performed using an appropriate instrument. If severity of the wound restricts decontamination by Radiation Protection personnel, the patient will be referred to offsite medical services or transported to an offsite medical facility for treatment and decontamination.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 ACCIDENT ASSESSMENT Effective response to a potential emergency situation requires assessment to determine the nature of the emergency and its actual and potential consequences. OPPD has established various methods to evaluate and monitor the effects of a potential emergency at the FCS ISFSI and has the appropriate means to ensure adequate assessment.

The assessment activities required to evaluate a particular emergency depend on the specific nature and classification of the emergency. The Emergency Director is responsible for the initial measurement of ISFSI dose rates after off-normal, natural phenomena, or accident events. The EALs identify the parameter value to determine the emergency condition. Classification of events is performed by the ISS/Emergency Director in accordance with the EAL scheme.

If the measured ISFSI dose rates exceed the EAL threshold, the Emergency Director ensures a radioactive release assessment in the vicinity of the affected storage module or cask is performed. After the assessment is complete, the Emergency Director contacts the Resource Manager to assist in interpreting the radioactive release assessment results.

Notification of the radiological release assessment is performed in accordance with Section 9.0.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 PROTECTIVE ACTIONS Protective actions for onsite personnel are provided for their health and safety.

Implementation guidelines for onsite protective actions are provided in EPIPs.

EPIPs provide for a range of protective actions to protect onsite personnel during security events.

14.1. Accountability Commented [PDM8]: RAI-4 The Emergency Director has the authority to initiate personnel accountability.

Accountability should be considered and used as a protective action whenever a Formatted: Indent: Left: 1" risk to health or safety exists, or at the discretion of the Emergency Director. If personnel accountability is required, at the direction of the Emergency Director, all individuals at the facility (including employees without emergency assignments; visitors; and contractor personnel) shall be notified of the emergency and provided with instructions.

Accountability of all personnel inside the ISFSI Protected Area should be accomplished within 60 minutes after event declaration and maintained thereafter at the discretion of the Emergency Director. If personnel are not accounted for, the Emergency Director is notified and Security will initiate sweeps to locate the missing individual(s).

Non-ERO personnel, supplemental personnel, and visitors located outside of the ISFSI Protected Area will be directed to report to an assembly area or exit the facility as appropriate. The Emergency Director is responsible for controlling access to the facility when the IOEP is activated.

Accountability may be modified or suspended if personnel safety could be jeopardized by a security event or other event hazardous to personnel health and safety.

Formatted: Normal, Indent: Left: 0.88" 14.1.14.2. ISFSI Egress Control Methods All visitors and unnecessary contractors are evacuated from the ISFSI 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.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 RADIOLOGICAL EXPOSURE CONTROL The means for controlling radiological exposures, during an emergency, are established for emergency workers. Controls for emergency radiological exposures shall include exposure guidelines consistent with the Environmental Protection Agencys (EPA)

Emergency Worker and Lifesaving Activity Protective Action Guides (PAGs).

15.1. Exposure Guidelines During an emergency, doses above normal occupational radiation exposure limits may be authorized by the Emergency Director for activities such as controlling further exposures, preservation of equipment, or saving a life.

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, or assessment actions within applicable limits specified in 10 CFR Part 20. The Emergency Director is responsible for authorizing emergency response personnel to receive doses in excess of 10 CFR Part 20 limits. This authority cannot be delegated.

Table 15-1 provides exposure guidelines for such onsite emergency activities.

15.2. Radiation Protection Program The purpose of the Radiation Protection Program is to ensure that radiation doses received by personnel are kept as low as reasonably achievable (ALARA) and do not exceed the prescribed limits for both normal and emergency conditions. The established measures to provide this assurance include access control, personnel exposure monitoring, and contamination control.

Access Control During a declared emergency, radiological surveys of the ISFSI pad area will be performed to determine the extent of the radiological concern. The Emergency Director will ensure Radiological Control Areas (RCAs) and access controls are established to prevent personnel from entering the area. Recovery and corrective actions will be planned and executed in a manner to minimize personnel exposure.

Personnel Exposure Monitoring Personnel dosimeters are utilized to monitor the exposure of personnel during normal or emergency conditions. Adequate supplies of dosimeters are maintained for use during an emergency. Procedures describe the types of personnel dosimeter devices, the manner in which they are utilized, who is to wear them, and how they are to be cared for.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 Emergency worker dose records are maintained in accordance with Radiation Protection procedures.

Contamination Control Various contamination control measures are used. These include control measures and means for the decontamination of personnel, areas, and equipment. These activities are addressed in ISFSI procedures and are briefly described below.

All personnel are monitored for radioactive contamination prior to leaving the ISFSI. During normal or emergency conditions, contamination should be removed from any part of a persons body prior to leaving the RCA. All personnel decontamination, even during an emergency, will be performed under supervision of Radiation Protection and in accordance with established procedures.

Portable contamination monitoring instruments are available to frisk personnel for potential contamination.

Documentation of surveys, contamination, and decontamination activities shall be maintained in accordance with Radiation Protection procedures.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 TABLE 15-1 Response Worker Emergency Dose Limits Guideline Activity Condition All reasonably achievable 5 rem All occupational exposures actions have been taken to minimize dose.

Exceeding 5 rem unavoidable and all appropriate actions Protecting valuable property 10 rem(a) taken to reduce dose.

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

Exceeding 5 rem unavoidable (b) Lifesaving or protection of and all actions taken to reduce 25 rem large populations dose. Monitoring available to project or measure dose.

(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.

NOTE: Table 15-1 contains the guidelines for emergency exposure criteria, which is consistent with Table 2-2, Response Worker Guidelines, of the EPAs Protective Action Guide and Planning Guidance for Radiological Incidents.

NOTE: Dose limits listed in Table 15-1 are in addition to prior annual occupational dose received.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 MEDICAL AND HEALTH SUPPORT Arrangements are made for medical services for injured individuals and/or contaminated injured individuals. If immediate professional medical help is required, arrangements exist with local fire/rescue and medical services to assist in the transport and treatment of injured personnel, as described in Section 5.2. Assistance is requested via 911 utilizing the commercial telephone system.

OPPD ensures that persons providing medical services are adequately prepared to handle contaminated injured individuals through training, drills, and exercises.

16.1. Onsite First Aid Arrangements are made to treat injured individuals and/or contaminated injured individuals. FCS maintains on-shift personnel and equipment to provide first-aid for personnel at the ISFSI. Medical emergency supplies are located in various locations.

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

When the situation allows, contaminated injured personnel transported offsite will be accompanied by a person trained in radiological monitoring and decontamination.

Preservation of life is paramount over contamination controls.

16.3. Offsite Medical Support Agreements are in place with the Blair Hospital and UNMC 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. Offsite medical assistance is requested via 911 utilizing the commercial telephone system.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 EMERGENCY TERMINATION AND RECOVERY General plans have been established that describe the termination and the recovery from declared emergencies at the FCS ISFSI.

17.1. Emergency Termination and Notification Termination of a declared emergency is the responsibility of the Emergency Director. The Emergency Director is also responsible for providing notification of the emergency termination and initiation of recovery operations to the NRC, State of Nebraska, local agencies, and the OPPD/FCS Emergency Response Organization.

At the discretion of the Emergency Director, FCS may enter recovery operations and the ISFSI could be returned to a stable condition before terminating the emergency.

17.2. Recovery Operations Upon termination of an emergency, or at the discretion of the Emergency Director, the ERF transitions into the recovery phase. The recovery organization will be based on the normal FCS ISFSI organization. The senior management position directs the recovery organization and is responsible for:

Ensuring FCS ISFSI is maintained in a safe condition; Managing onsite Recovery activities during the initial Recovery phase; Keeping OPPD support apprised of FCS ISFSI activities and requirements.

The remainder of the recovery is accomplished using the normal and emergency organizations as necessary to provide technical and radiological expertise in order to return to normal operations.

ISFSI recovery activities shall be in accordance with the ISFSI Technical Specifications and other licensee documents. During ISFSI recovery, the radiation exposure limits of 10 CFR Part 20 shall apply.

If, during recovery operations, an emergency situation occurs, recovery efforts will be suspended until the emergency condition is resolved. The Emergency Director will re-evaluate FCS ISFSI conditions prior to resuming recovery.

The Recovery operations will be terminated by the senior management position directing the recovery organization after the FCS ISFSI is returned to a stable condition.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 EXERCISES AND DRILLS Emergency Preparedness is maintained at FCS through the following:

Conducting and evaluating periodic drills and exercises Training and periodic retraining of personnel involved in emergency response Reviewing and updating plans and implementing procedures Maintaining emergency facilities and equipment Periodic exercises are conducted to evaluate major portions of FCSs emergency response capabilities. Periodic drills are conducted to develop and maintain key skills.

Deficiencies, as a result of exercises or drills, are identified and corrected.

An exercise tests the execution of the overall plant emergency preparedness and the integration of this preparedness. A drill is a supervised instruction period aimed at testing, developing, and maintaining skills in a particular response function. A summary of exercises and drills, including the associated elements for each, is outlined below.

18.1. Emergency Plan Exercises and Drills FCS ISFSI conducts a biennial exercise to test the adequacy of timing and content of implementing procedures and methods; to test emergency equipment and communication networks; and to ensure that emergency personnel are familiar with their duties. FCS offers the following offsite organizations the opportunity to participate to the extent assistance would be expected during an emergency declaration. However, participation is not required.

State of Nebraska Blair Volunteer Fire Department Fort Calhoun Volunteer Fire Department Blair Hospital University of Nebraska Medical Center (UNMC)

LLEAs At least one drill involving a combination of some of the principal functional areas of emergency response shall be conducted in the interval between biennial exercises for the purpose of testing, developing, and maintaining the proficiency of emergency responders.

Exercise and Drill scenarios will include, at a minimum, the following:

The basic objective(s) of the exercise/drill The date(s), time period, place(s), and participating organizations A time schedule of real and simulated initiating events A narrative summary describing the conduct of the drill 33

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 18.2. Equipment and Proficiency Drills/Tests Drills are conducted for the purpose of training, developing, and maintaining the proficiency of emergency responders. Additionally, drills may be used to test and evaluate the adequacy of the ERF, equipment, procedures, communication channels, actions of emergency response personnel, and coordination between OROs and the ISFSI.

Communications Drills/Tests To ensure that emergency communications systems described in Section 10.0 of this plan are operable, communications tests are conducted as outlined below.

1. To test the capability to notify the State of Nebraska utilizing the commercial telephone system, the capability is functionally tested monthly. This drill will include the aspect of the receiving party understanding the content of the message.

2. To test the capability to communicate with the NRC, ENS is functionally tested monthly.

3. Portable radios, as detailed in Section 10.0, are used on a frequent basis, therefore periodic testing of the radio system is not necessary:

Performance of the Communication Drills satisfies the testing requirements specified in Section 10.0.

Augmentation Capability Drills An unannounced, off-shift, Augmentation Capability Drill shall be conducted annually. These drills shall involve implementation of the ERO callout system procedure and documentation of the estimated response time for each responder. This drill shall serve to demonstrate the capability to augment the Emergency Director after an emergency declaration.

Radiological Monitoring Drills Radiological monitoring drills are conducted annually. These drills demonstrate the ability to perform radiological survey and assessment and can be performed separately or as part of an Emergency Plan exercise or drill.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 Medical Emergency Drills To evaluate the training of the ISFSIs medical response personnel, a medical drill is conducted annually involving a simulated contaminated injured individual and may also contain provisions for participation by ambulance services and hospitals. This drill can be performed separately or as part of an annual exercise or drill.

18.3. Critiques and Evaluation Critiques are used to evaluate the performance of participating personnel and the adequacy of the ERF, equipment, and procedures. The ability of emergency response personnel to self-evaluate weaknesses and identify areas for improvement is the key to successful exercise or drill conduct.

Exercise and drill performance objectives are evaluated against measurable demonstration criteria. As soon as possible following the conclusion of each exercise or drill, a critique, including participants and evaluators, is conducted to evaluate the ability of the ERO to implement the IOEP and associated procedures. Deficiencies identified during exercises or drills are entered into the corrective actions program.

A written report is prepared following an exercise or drill involving the evaluation of designated objectives. The report evaluates and documents the ability of the ERO to respond to a simulated emergency situation. The report will also contain reference to corrective action and recommendations resulting from the exercise or drill.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 EMERGENCY RESPONSE TRAINING Emergency response training is provided to those who may be called on to assist in an emergency at the FCS ISFSI. All personnel at the FCS ISFSI who fill required positions in the ERO will take part in a training program to ensure adequate preparedness to assist in an emergency situation. OROs that may be called upon for emergency assistance will also be invited to participate in appropriate training programs.

19.1. Emergency Response Personnel Training Requirements for emergency preparedness training are specified in the Emergency Response Training Program outlined in this section. This program identifies the level and the depth to which individuals are to be trained. The Emergency Response Training Program is based on position-specific responsibilities as defined in the IOEP. Emergency response personnel in the following categories receive initial training and annual retraining:

ISFSI Shift Supervisors/Emergency Directors and Resource Managers The ISS/Emergency Directors and Resource Managers shall have training conducted such that proficiency is maintained on the topics listed below. These subjects shall be covered as a minimum on an annual basis.

EAL classification Offsite notification procedures ERO activation Dose rate meter operation Radioactive release assessment Emergency exposure control Protective actions for onsite personnel ISFSI DBAs Review of applicable drill and exercise-identified deficiencies and Human Performance Concerns Personnel available during declared emergencies who may be called upon to perform emergency response activities as an extension of their normal duties receive duty-specific training. Additional emergency preparedness training is provided as part of annual access training.

Medical Response Personnel (On-Shift)

Personnel assigned the responsibility for responding to a medical emergency at FCS receive the American Red Cross Standard First Aid Training Program, or equivalent. To maintain qualifications in 36

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 accordance with the American Red Cross, CPR and First Aid Training are given once every two years.

Radiation Monitoring Personnel Initial and annual retraining for radiation monitoring personnel consists of the following topics:

Use of Radiation Protection procedures Use of emergency survey equipment Communications Field surveys Role of radiological assessment in an ISFSI emergency Monitoring of radioactive releases Protective actions for onsite personnel Review of drill and exercise-identified deficiencies and Human Performance concerns Personnel Badged for Unescorted Access Personnel who are badged for unescorted access receive access training annually. Information pertaining to their safety and the safety of visitors under escort during a classified emergency is included in this training.

Access training shall include the following emergency preparedness topics:

Basic Emergency Plan and implementing preparedness topics Emergency classification levels Call out of personnel during an emergency Personnel accountability procedures 19.2. Emergency Response Support Organizations Training is offered annually to OROs that may be requested to provide assistance in the event of an emergency at FCS (e.g., law enforcement, fire-fighting, rescue, medical services, transport of injured, etc.). The training shall be structured to meet the needs of that organization with respect to the nature of their support. Training topics such as event notification, site access procedures, basic radiation protection and interface activities between the ORO and FCS are included in the training.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 19.3. Annual Emergency Action Level Training Annually, the emergency classification system specified in Section 8.0 and the EALs are reviewed with the authorities of Nebraska.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW, AND DISTRIBUTION Responsibilities for IOEP development and review and for distribution of the IOEP are established and planners are properly trained.

20.1. Emergency Preparedness Responsibilities Overall Authority and Responsibility A member of FCS senior management has overall authority and responsibility for emergency response planning and implementation of the FCS IOEP. This responsibility includes ensuring that the emergency preparedness program is maintained and implemented as described in the IOEP, and applicable requirements and regulations are met.

Maintaining the IOEP A FCS ISFSI position will be designated the responsibility for maintaining an adequate knowledge of regulations, planning techniques, and the latest applications of emergency equipment and supplies. The position is responsible for the following tasks:

Maintaining and updating this IOEP and associated procedures Ensuring exercise and drill commitments stated in this IOEP are met Ensuring material readiness of the ERF Overseeing the Emergency Preparedness Training Program Maintaining Emergency Preparedness interfaces with OROs Performing and documenting appropriate evaluations of the Emergency Preparedness program and classified emergency events The individual assigned the duties of maintaining the IOEP shall maintain an adequate knowledge of regulations, planning techniques, and the latest applications of emergency equipment and supplies. Training for these individuals includes 10 CFR 50.54(q) and 72.44(f) Evaluation Qualification.

Audits Independent audits of the Emergency Preparedness program meeting the requirements of 10 CFR 50.54(t) will be performed. All aspects of emergency preparedness, including exercise documentation, capabilities, procedures, and interfaces with state and local governments are audited.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 20.2. Review and Updating of the IOEP The IOEP, the associated EPIPs, and the ISFSI EAL Technical Bases Manual are reviewed at least annually, and updated as needed. Any needed changes shall be incorporated in the IOEP, ISFSI EAL Technical Bases Manual, and appropriate EPIPs. Proposed activities that may impact the IOEP must be evaluated per 10 CFR 50.54(q). The review shall encompass the need for changes based upon the following:

Written critiques and evaluations of drills and exercises Changes in the organizational structure Changes in the functions and capabilities of supporting agencies Changes in Federal or State regulations Modifications to the ISFSI or surrounding site which would affect emergency planning Recommendations or agreement changes received from other organizations Emergency Telephone Directory Names and telephone numbers of the ERO and supporting offsite agencies shall be reviewed at least quarterly and updated as necessary.

Letters of Agreement Written agreements with outside support organizations and government agencies are evaluated biennially to determine if these agreements are still valid. If agreements are not valid, then they are updated and renewed with the applicable organization. This agreement review is documented.

20.3. Training The assigned Emergency Preparedness position shall assist management in coordinating and/or providing emergency planning -related training. The training described in Section 19.0 shall be properly coordinated to ensure adequate qualification, training, and retraining of personnel.

20.4. Maintenance and Inventory of Emergency Equipment and Supplies Specific emergency response equipment and reference materials are listed in Appendix A. The items listed in Appendix A are inspected, inventoried, and operationally checked quarterly and after each use. Sufficient reserves are maintained to replace those which are removed for calibration or repair.

Equipment in these inventories is checked and calibrated in accordance with approved procedures.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 APPENDIX A Formatted EMERGENCY EQUIPMENT, SUPPLIES, AND REFERENCE MATERIALS 0

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 Appendix A EMERGENCY EQUIPMENT, SUPPLIES AND REFERENCE MATERIALS EMERGENCY RESPONSE FACILITY Procedures / Reference Materials ISFSI Only Emergency Plan ISFSI EAL Technical Bases Document Emergency Telephone Directory EPIPs Equipment Portable radiation monitoring instrument Portable emergency lighting Medical emergency response kit ONSITE LOCATIONS Equipment / Supplies Portable radiation and contamination monitoring instruments Contamination control supplies Decontamination control supplies Protective clothing Dosimeters Radiological postings and barricades First Aid Kits 0

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 APPENDIX B Formatted CROSS-REFERENCE IOEP SECTION TO PLANNING STANDARDS/REQUIREMENTS/CRITERIA AND EPIPS 0

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 Appendix B TABLE B-1 CROSS-REFERENCE IOEP SECTION TO PLANNING STANDARDS/REQUIREMENTS/CRITERIA AND EPIPS Planning NUREG-0654, Implementing Planning FCS IOEP Standard Section II Procedure Requirement Section(s) (10 CFR Evaluation (Appendix E.IV)**

50.47)** Criteria 5.0 (b)(1) A.1, 2, 4, 7 A To Be Determined (TBD) 6.0 (b)(2) A.1, 2, 4; C.1 B TBD 7.0 (b)(3) A.6, 7 C TBD 8.0 (b)(4) B.1, 2; C.1, 2 D TBD A.6, 7; C.1; D.1, 3; TBD 9.0 (b)(5) E E

10.0 (b)(6) C.1; D.1, 3; E F TBD 11.0 (b)(7) Exempt G TBD 12.0 (b)(8) E; G H TBD 13.0 (b)(9) A.4; B.1; C.2; E I TBD 14.0 (b)(10) C.1; E J TBD 15.0 (b)(11) E K TBD 16.0 (b)(12) A.6, 7; E L TBD 17.0 (b)(13) H M TBD 18.0 (b)(14) E9; F N TBD 19.0 (b)(15) F O TBD 20.0 (b)(16) G P TBD

• • as exempted 0

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 Formatted

SUMMARY

OF CHANGES Page/Section Change Reason and References This is a major revision to the Emergency Plan which supports the transition to an Independent Spent Fuel Storage Installation (ISFSI) Only Transition to an ISFSI Emergency Plan (IOEP). The IOEP describes the Only Emergency Plan stations plan for responding to emergencies that may arise at the FCS ISFSI facility.

Major changes made throughout the Plan include the following:

• Removal of terms/definitions/abbreviations and references that are no longer applicable

• Adding new applicable references.

• Changed the organizational titles to reflect the ISFSI organization titles.

• Complete reorganization of the Emergency Response Organization including removal of the Technical Coordinator, Radiation Protection Coordinator, Radiation Protection Technician, and NCO positions.

Adding the Resource Manager position.

Revise moval of the requirement to perform accountability in the facility. Commented [PDM9]: RAI-4

• Deleted information that is no longer applicable based on the transfer of all spent fuel to the ISFSI facility.

0

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION DOCKET NUMBER 50-285 / LICENSE NUMBER DPR-40 ATTACHMENT 4 ISFSI EMERGENCY ACTION LEVEL TECHNICAL BASES DOCUMENT

Omaha Public Power District Fort Calhoun Station Independent Spent Fuel Storage Installation Emergency Action Level Technical Bases

TABLE OF CONTENTS Formatted: Font: Bold 1.0 PURPOSE............................................................................................................................ 1 Formatted: Font: Bold

2.0 REFERENCES

.................................................................................................................... 1 3.0 ACRONYMS & DEFINITIONS ............................................................................................ 2 4.0 ATTACHMENTS.................................................................................................................. 4 ATTACHMENTS Page ATTACHMENT 1 EMERGENCY ACTION LEVEL TECHNICAL BASES 45 Table A-1 Recognition Category Initiating Condition Matrix 6 PD-HEU1 Security (Unusual Event) 7 PD-HEA1 Security (Alert) 8 PD-HU3 Judgment (Unusual Event) 10 Formatted: Hyperlink PD-HA3 Judgment (Alert) 11 E-HU12 ISFSI Malfunction (Unusual Event) 149 ATTACHMENT 2 EMERGENCY CLASSIFICATION TABLE 1410 Fort Calhoun Station ISFSI EAL Technical Bases Page i

1.0 PURPOSE This document provides the detailed set of Emergency Action Levels (EALs) applicable to the Fort Calhoun Station (FCS) Independent Spent Fuel Storage Installation (ISFSI) and the associated technical bases. The EALs have been developed utilizing the structure of the EAL development methodology provided in NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 6 (NEI 99-01). All recommendations for changes to this document or associated implementing procedures are reviewed in accordance with the requirements of 10 CFR 50.54(q).

This information provided in this document should be used to facilitate review of the FCS EALs, provide historical documentation for future reference, and serve as a resource for training.

Personnel responsible for implementation of the ISFSI Only Emergency Plan and the ISFSI Emergency Action Level scheme may use the information provided in this document as a technical reference in support of EAL interpretation.

The expectation is that emergency classifications are to be made as soon as conditions are present and recognizable for the classification. Use of this document for assistance is not intended to delay the emergency classification.

2.0 REFERENCES

2.1 NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Formatted: Indent: Left: 0.19", Hanging: 0.44" Reactors Draft Regulatory Guide 1346 (Proposed new Regulatory Guide 1.235),

Emergency Planning for Decommissioning Nuclear Power Reactors 2.2 FCS-I-EP-1, ISFSI Only Emergency Plan 2.3 NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73 2.4 NUREG-1536, Standard Review Plan for Spent Fuel Dry Storage Systems at a General License Facility 2.5 NEI 03-12, Template for Security Plan, Training and Qualification, Safeguards Contingency Plan, and ISFSI Security Program Fort Calhoun Station ISFSI EAL Technical Bases Page 1

3.0 ACRONYMS & DEFINITIONS Acronyms CFR ..................................................................................................... Code of Federal Regulations EAL............................................................................................................. Emergency Action Level ECL .................................................................................................Emergency Classification Level EPA ............................................................................................. Environmental Protection Agency GTCC ............................................................................................................. Greater Than Class C ISFSI .......................................................................... Independent Spent Fuel Storage Installation IC ......................................................................................................................... Initiating Condition mRem ............................................................................................... milli-Roentgen Equivalent Man NEI ............................................................................................................. Nuclear Energy Institute NRC............................................................................................... Nuclear Regulatory Commission ORO ............................................................................................... Off-site Response Organization PAG ............................................................................................................. Protective Action Guide PD ................................................................................................................. Permanently Defueled rem .......................................................................................................... Roentgen Equivalent Man Definitions Selected terms used in Initiating Condition (IC) and EAL statements are set in all capital letters (e.g., ALL CAPS). These words are defined terms that have specific meanings as used in this document. The definitions of these terms are provided below.

ACCOUNTABILITY - A discretionary protective action taken for all persons onsite (within the ISFSI PROTECTED AREA) that involves the gathering of personnel into pre-designated areas and subsequent verification that the location of all personnel is known. Commented [PDM1]: RAI-4 ADVERSARIAL ACTION: An attempted or unauthorized entry into the ISFSI Protected Area via the fence or barrier in an attempt to steal or damage nuclear fuel for the purposes of committing an act of radiological sabotage. Unauthorized entry can be by air, land, water using guns, explosive, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Commented [PDM2]: RAI-1 ALERT: Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the ISFSI. Any releases are expected to be limited to small fractions of the Environmental Protection Agency (EPA) Protection Action Guideline (PAG) exposure levels.

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

CREDIBLE SECURITY THREAT - A threat to the ISFSI confirmed and validated by the security force per procedures or received over the Emergency Notification System (ENS) from the NRC.

Fort Calhoun Station ISFSI EAL Technical Bases Page 2

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

EMERGENCY CLASSIFICATION LEVEL (ECL): One of a set of names or titles established by the Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to (1) potential or actual effects or consequences, and (2) resulting onsite and offsite response actions. The ECLs, in ascending order of severity, are NOTIFICATION OF UNUSUAL EVENT (UNUSUAL EVENT) and ALERT.

HOSTILE ACTION - An act toward the ISFSI or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end.

This includes, but is not necessarily limited to, attack by air, land, or water using guns, explosives, projectiles, vehicles or devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts are not part of a concerted attack on the ISFSI. Violent acts between individuals in the owner controlled area do not meet this definition. Commented [PDM3]: RAI-1 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage and GTCC radioactive material.

INITIATING CONDITION (IC) - An event or condition that aligns with the definition of one of the two emergency classification levels by virtue of the potential or actual effects or consequences.

PROTECTED AREA: That area within the perimeter of the security fence.

SECURITY CONDITION: Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the ISFSI.

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

Fort Calhoun Station ISFSI EAL Technical Bases Page 3

4.0 ATTACHMENTS ATTACHMENT 1 EMERGENCY ACTION LEVEL TECHNICAL BASES ATTACHMENT 2 EMERGENCY CLASSIFICATION TABLES Fort Calhoun Station ISFSI EAL Technical Bases Page 4

Attachment 1 EMERGENCY ACTION LEVEL TECHNICAL BASES Fort Calhoun Station ISFSI EAL Technical Bases Page 5

Table A-1: Recognition Category E Initiating Condition Matrix UNUSUAL EVENT ALERT PD-HEU1 Confirmed SECURITY PD-HEA1 HOSTILEADVERSARIAL ACTION Commented [PDM4]: RAI-1 CONDITION, or threat, at the independent is occurring or has occurred.

spent fuel storage installation (ISFSI).

(Page 8)

(Page 7)

PD-HU3 Other conditions exist which in the PD-HA3 Other conditions exist which in the Formatted: Font: Not Bold judgment of the Emergency Director warrant judgment of the Emergency Director warrant Formatted: Font: Not Bold declaration of an Unusual Event. declaration of an Alert.

Formatted: Font: Not Bold (Page 9) (Page 10)

Formatted: Font: Not Bold E-HU12: Damage to a loaded cask Formatted: Font: Not Bold CONFINEMENT BOUNDARY.

Formatted: Font: Not Bold (Page 1191)

Commented [PDM5]: RAI-2 Formatted: Font: Italic Fort Calhoun Station ISFSI EAL Technical Bases Page 6

PD-HEU1 EMERGENCY CLASSIFICATION LEVEL:

UNUSUAL EVENT INITIATING CONDITION:

Confirmed SECURITY CONDITION, or threat, at the independent spent storage installation (ISFSI).

EMERGENCY ACTION LEVEL (EAL): (1 or 2)

1. A SECURITY CONDITION as reported by the security force and impacting the ISFSI.

2. Notification of a credible security threat directed at the ISFSI.

Basis:

This IC addresses events that pose a threat to facility personnel or spent fuel, and thus represent a potential degradation in the level of facility safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR 73.71 or 10 CFR 50.72.

Security events assessed as HOSTILE ADVERSARIAL ACTION are classifiable under IC PD-HEA1. Commented [PDM6]: RAI-1 Timely and accurate communication between the security force and the ISFSI Shift Supervisor/Emergency Director is essential for proper classification of a security-related event.

Classification of these events will initiate appropriate threat-related notifications to site personnel and Offsite Response Organizations (OROs).

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

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

EAL #2 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with Security procedures.

Fort Calhoun Station ISFSI EAL Technical Bases Page 7

SECURITY CONDITION: Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the ISFSI.

Escalation of the emergency classification level would be via IC PD-HEA1.

Basis

Reference:

1. FCS ISFSI Security Plan Fort Calhoun Station ISFSI EAL Technical Bases Page 8

PD-HEA1 EMERGENCY CLASSIFICATION LEVEL:

ALERT INITIATING CONDITION:

HOSTILEADVERSARIAL ACTION is occurring or has occurred. Commented [PDM7]: RAI-1 EMERGENCY ACTION LEVEL (EAL):

Formatted: Indent: Left: 0"

1. A HOSTILE n ADVERSARIAL ACTION is occurring or has occurred as reported by the security force.

Basis:

This IC addresses the occurrence of an HOSTILEADVERSARIAL ACTION.

Timely and accurate communication between the security force and the ISFSI Shift Supervisor/Emergency Director is essential for proper classification of a security-related event.

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

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

ADVERSARIAL HOSTILE ACTION: An act toward the ISFSI or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end. This includes, but is not necessarily limited to, attack by air, land, or water using guns, explosives, projectiles, vehicles or devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts are not part of a concerted attack on the ISFSI. Violent acts between individuals in the owner controlled area do not meet this definition. An attempted or unauthorized entry into the ISFSI Protected Area via the fence or barrier in an attempt to steal or damage nuclear fuel for the purposes of committing an act of radiological sabotage. Unauthorized entry can be by air, land, water using guns, explosive, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

Basis

Reference:

1. FCS ISFSI Security Plan Fort Calhoun Station ISFSI EAL Technical Bases Page 9

PD-HU3 EMERGENCY CLASSIFICATION LEVEL:

UNUSUAL EVENT Commented [PDM8]: RAI-2 INITIATING CONDITION:

Other conditions exist which in the judgment of the Emergency Director warrantwarrant declaration of an Unusual Event.

EMERGENCY ACTION LEVEL (EAL):

1. Other conditions exist which in the judgment of the Emergency Director indicate that events Formatted: Font: 11 pt, Font color: Black are in progress or have occurred which indicate a potential degradation of the level of safety Formatted: Font: 11 pt of the facility or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further Formatted: Indent: Left: 0", Numbered + Level: 1 +

degradation of systems needed to maintain spent fuel cooling occurs. Numbering Style: 1, 2, 3, + Start at: 1 + Alignment:

Left + Aligned at: 0.19" + Indent at: 0.44" Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant Formatted: Font: 11 pt declaration of an emergency because conditions exist which are believed by the Emergency Formatted: Left, Don't adjust space between Latin and Director to fall under the emergency classification level description for an Unusual Event.

Asian text, Don't adjust space between Asian text and numbers Basis

Reference:

1. NEI 99-01, Rev. 6, PD-HU3 Fort Calhoun Station ISFSI EAL Technical Bases Page 10

PD-HA3 EMERGENCY CLASSIFICATION LEVEL:

ALERT Commented [PDM9]: RAI-2 INITIATING CONDITION:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert.

EMERGENCY ACTION LEVEL (EAL):

1. Other conditions exist which, in the judgment of the Emergency Director, indicate that events Formatted: Font: Font color: Auto are in progress or have occurred which involve an actual or potential substantial degradation Formatted: Indent: Left: 0", Right: 0.05", Numbered +

of the level of safety of the facility. Any releases are expected to be limited to small fractions Level: 1 + Numbering Style: 1, 2, 3, + Start at: 1 +

of the EPA Protective Action Guideline exposure levels. Alignment: Left + Aligned at: 0.19" + Indent at: 0.44" Basis: Formatted: Font: Font color: Auto Formatted: Font: 8 pt, Font color: Auto This IC addresses unanticipated conditions not addressed explicitly elsewhere but that Formatted: Left, Don't adjust space between Latin and warrant declaration of an emergency because conditions exist which are believed by the Asian text, Don't adjust space between Asian text and Emergency Director to fall under the emergency classification level description for an numbers Alert.

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

Basis

Reference:

1. NEI 99-01, Rev. 6, PD-HA3 Fort Calhoun Station ISFSI EAL Technical Bases Page 11

E-HU21 EMERGENCY CLASSIFICATION LEVEL:

UNUSUAL EVENT INITIATING CONDITION Damage to a loaded cask CONFINEMENT BOUNDARY.

EMERGENCY ACTION LEVEL (EAL): (1, 2, or 3) Commented [PDM10]: RAI-3

1. Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an abnormal radiation reading of 800 mrem/hr (gamma + neutron) at front Bird Screen of the HSM

2. Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an abnormal radiation reading of 20 mrem/hr (gamma + neutron) on outer HSM Door. Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an abnormal radiation reading of

>2 mRem/hr. (gamma) within the ISFSI Protected Area or on a Horizontal Storage Module (HSM) concrete surface.

3. Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an abnormal radiation reading of 10 mrem/hr (gamma + neutron) on End Shield Wall exterior NOTE: Radiation readings are taken at the locations prescribed by the Technical Specifications for the Standardized NUHOMS Horizontal Storage System (Amendment Number 15 to COC 1004).

Basis:

This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage cask is sealed. The issues of concern are the creation of a potential or actual release path to the environment, degradation of one or more fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the cask or fuel from storage.

The existence of damage is determined by radiological survey. The radiation limits listed in the EAL reflect calculations based on NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, recommends using 2 times the site-specific cask specific technical specification radiation level as the EAL. The technical specification site specific radiation multiple of 2 times, is used here to distinguish between non-emergency and emergency conditions.

Fort Calhoun Station ISFSI EAL Technical Bases Page 12

The emphasis for this classification is the degradation in the level of safety of the spent fuel cask and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the IC may be determined based on measurement of a dose rate at some distance from the cask.

The existence of damage is determined by radiological survey. The radiation limits listed in the EAL reflect calculations based on 10 CFR 20.1301(a)(2) radiation dose limits to the public. In addition to aligning with 10 CFR 20.1301 limits, the radiation levels chosen are a reasonable indication that actual cask confinement boundary has occurred due to the level being greater than calculated levels.

Security-related events for ISFSIs are covered under ICs PD-HEU1 and PD-HEA1.

As provided in the Transnuclear Standardized NUHOMS System Technical Specifications Amendment 15 to CoC 1004, Section 5.4.1, HSM or HSM-H Dose Rate Evaluation Program, as calculated in FC08574, Fort Calhoun Data Specific Radiological Assessment, contain radiation dose levels for the DSC that should not be exceeded based while it is stored in the HSM. Keeping in line with NEl guidance that a UNUSAL EVENT warranted for radiation conditions at a level of twice the Technical Specification value, the values chosen for EAL E-HU1 represent these values.

The Note in the EAL provides guidance on where the radiation readings are to be taken when evaluating this EAL.

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

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

Basis

References:

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

2. Amendment 15 to CoC 1004 Technical Specifications for the Standardized NUHOMS Horizontal Storage Module System10 CFR 20.1301, Radiation Dose Limits for Individual Members of the Public

3. FC08574, Fort Calhoun Data Specific Radiological Assessment Fort Calhoun Station ISFSI EAL Technical Bases Page 13

Attachment 2 Emergency Classification Table ALERT UNUSUAL EVENT PD-HEA1 HOSTILEADVERSARIAL ACTION is occurring or has PD-HEU1 Confirmed SECURITY CONDITION, or threat, at the occurred. independent spent storage installation (ISFSI).

EMERGENCY ACTION LEVEL (EAL): EMERGENCY ACTION LEVEL (EAL): (1 or 2)

SECURITY 1. An HOSTILEADVERSARIAL ACTION is occurring or has occurred as reported by the security force.

1. A SECURITY CONDITION as reported by the security force and impacting the ISFSI.

1. OR Formatted: Numbered + Level: 1 + Numbering Style: 1,

2. Notification of a credible security threat directed at the ISFSI. 2, 3, + Start at: 1 + Alignment: Left + Aligned at: 0" +

Indent at: 0.25", Tab stops: Not at 1.5" PD-HA3 Other Conditions exist which in the judgment of the PD-HU3 Other Conditions exist which in the judgment of the emergency director warrant declaration of an Alert. emergency director warrant declaration of an Unusual Formatted: Centered, Indent: Left: 0", Hanging: 0.01",

Event. Tab stops: Not at 0.74" EMERGENCY ACTION LEVEL (EAL): EMERGENCY ACTION LEVEL (EAL): Formatted Table JUDGMENT 1. Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a

1. Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve an Formatted: Font: Not Bold, No underline potential degradation of the level of safety of the ISFSI or indicate a actual or potential substantial degradation of the level of safety of theFormatted: Font: 16 pt security threat to facility protection has been initiated. No release of ISFSI. Any releases are expected to be limited to small fractions of the radioactive material requiring offsite response or monitoring are expected EPA Protective Action Guideline exposure levels. Formatted: No Spacing, Numbered + Level: 1 +

unless further degradation of systems important to safety occurs.

Numbering Style: 1, 2, 3, + Start at: 1 + Alignment:

Left + Aligned at: 0" + Indent at: 0.25", Tab stops: Not None E-HU1 Damage to a loaded cask CONFINEMENT BOUNDARY.EU2 Damage to a loaded cask CONFINEMENT at 0.6" BOUNDARY. Formatted: Tab stops: 0.65", Left + Not at 0.8" EMERGENCY ACTION LEVEL (EAL): (1,2, or 3)

Damage to a loaded cask CONFINEMENT BOUNDARY as indicatedFormatted: Indent: Left: 0.25", Space Before: 3 pt, Line by an abnormal radiation reading of; spacing: single, No bullets or numbering, Tab stops:

ISFSI 1. 800 mrem/hr at front Bird Screen of the HSM 0.6", Left OR Formatted: Font: 8.5 pt, Bold

2. 20 mrem/hr on outer HSM Door.Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by a radiation reading of >2 mRem/hr. (gamma) within the ISFSI Protected Area or on a Horizontal Storage Module (HSM) concrete surface. Formatted: Font: 11 pt OR 1.3. 10 mrem/hr on End Shield Wall exterior Formatted: Font: Bold Fort Calhoun Station ISFSI EAL Technical Bases Page 14

Attachment 2 Emergency Classification Table Fort Calhoun Station IC/EAL Identifier Emergency Action Level Matrix EX##-###.# - Examples (E-HUA1.1) or (E-HU1.2)

Fort Calhoun Station ISFSI EAL Technical Bases Page 15

LIC-19-0021 Page 1 ATTACHMENT 3 REVISED ENCLOSURE 1 AND ATTACHMENTS CLEAN, WITHOUT MARKUPS OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION. UNIT NO. 1 DOCKET NO. 50-285

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

DESCRIPTION OF PROPOSED CHANGES, TECHNICAL AND REGULATORY EVALUATION, SIGNIFICANT HAZARDS DETERMINATION, AND ENVIRONMENTAL CONSIDERATIONS

Subject:

Independent Spent Fuel Storage Installation Only Emergency Plan (IOEP) and Emergency Action Level (EAL) Scheme

3.0 PROPOSED CHANGE

S 3.1 Elimination of SFP Initiating Conditions and EALs 3.2 Emergency Response Organization Revision 3.3 Replacement of the Shift Manager with the ISFSI Shift Supervisor 3.4 Removal of emergency notification to the State of Iowa.

4.0 TECHNICAL EVALUATION

4.1 Radiological Consequences of Design Basis Events 4.2 Radiological Consequences of Postulated Events 4.3 ISFSI Only Emergency Plan 4.4 ISFSI Emergency Action Levels

5.0 REGULATORY EVALUATION

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

6.0 ENVIRONMENTAL CONSIDERATION

S

7.0 REFERENCES

Attachment 1, Supporting Evaluations and Calculations Attachment 2, Comparison Matrix For ISFSI EALs Based On NEI 99-01, Rev 6 Development of Emergency Action Levels for Non-Passive Reactors To The Proposed FCS Emergency Classification System And ISFSI EALs Attachment 3, ISFSI Only Emergency Plan Attachment 4, ISFSI Emergency Action Level Technical Bases Document

LIC-19-0001 Page 2

1.0 INTRODUCTION

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

By letter dated August 25, 2016, OPPD informed the NRC that FCS will permanently cease power operations in accordance with 10 CFR 50.82(a)(1)(i), specifying a shutdown date of October 24, 2016 (Reference 7.1). By letter dated November 13, 2016, FCS submitted a certification of permanent cessation of power operations and permanent removal of fuel from the reactor vessel (Reference 7.2). Consequently, as specified in 10 CFR 50.82(a)(2), the stations 10 CFR Part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel.

The proposed IOEP continues to rely on previously requested exemptions from certain emergency planning requirements (Reference 7.3), as the basis for these exemptions has not changed and remains in effect. The proposed IOEP has been determined to represent changes in both the EAL scheme and the staffing level previously requested to implement the Permanently Defueled Emergency Plan (PDEP) (Reference 7.4) in accordance with the requirements of 10 CFR 50.54(q) and therefore, require NRC approval prior to implementation. Additional changes to the FCS PDEP and EAL Technical Bases Document are warranted to reflect the storage of all fuel in the Independent Spent Fuel Storage Installation (ISFSI) facility.

The Post-Shutdown Decommissioning Activities Report (PSDAR) (Reference 7.5) documented OPPDs expectation that all spent fuel would be completely transferred to the ISFSI by the end of 2022. OPPD awarded contracts in the first quarter of 2018 which expedited transferring all spent fuel to the ISFSI by the middle of 2020. To comport to the reduced scope of potential radiological accidents with spent fuel in dry cask storage within the ISFSI, OPPD determined that implementation of the IOEP and the ISFSI EAL Technical Bases Document will be warranted.

The proposed emergency plan is related to the operation of the ISFSI and would be implemented after all spent fuel has been removed from the spent fuel pool (SFP) and placed in dry storage within the ISFSI. Implementation of the IOEP would involve the establishment of administrative controls for radiological source term accumulation limits and methods to control the accidental dispersal of the radiological source.

The NRC approved AREVA TN Americas Amendment 14, to the standardized NUHOMS Certificate of Compliance (CoC) No. 1004 for Spent Fuel Storage Casks, on April 25, 2017 (Reference 7.6). This revision deleted the License Condition requiring a return to the SFP for inspection. With the approval of the CoC, there is no longer a requirement to return spent fuel to the SFP.

Consistent with the condition that the proposed emergency plan may be implemented ninety (90) days after all spent fuel has been certified to have been removed from the SFP, FCS has submitted a LAR to revise the FCS Facility Operating License to comport to the ISFSI-Only condition that there is no longer a requirement to return spent fuel to the SFP.

LIC-19-0001 Page 3

2.0 DESCRIPTION

The proposed amendment would modify the FCS license by replacing the existing FCS PDEP and the associated EAL scheme with the IOEP and the ISFSI EAL scheme to reflect the storage of all fuel in the ISFSI. The proposed changes reduce the scope of onsite emergency planning requirements to reflect the reduced scope of potential radiological accidents with all spent fuel in dry cask storage within the ISFSI. After all spent fuel is in dry cask storage within the ISFSI, the number and severity of potential radiological accidents possible at FCS are substantially lower.

There continues to be no need for offsite emergency response plans at FCS because no postulated design basis accident or reasonably conceivable beyond design basis accident can result in a radioactive release that exceeds Environmental Protection Agency (EPA) Protective Action Guides (PAGs) beyond the site boundary, as described in EPAs PAG Manual "Protective Action Guides and Planning Guidance for Radiological Incidents" dated January 2017 (EPA PAG Manual) (Reference 7.7).

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

The radioactive source term for an accidental release at the defueled reactor site is reduced by radioactive decay and transfer of spent fuel from the SFP to the ISFSI. Potential offsite doses were calculated at FCS to verify that the necessary administrative radiological source term accumulation limits would be adequate during decontamination and dismantling of radioactive systems, structures, and components contained in the non-operational nuclear unit. These administrative radiological source term accumulation limits ensure that if a radiological release were to occur, it would not exceed two times the Offsite Dose Calculation Manual (ODCM) limits (two (2) times 1500 millirem/year) at the site boundary for sixty (60) minutes (and therefore not result in doses to the public above EPA PAGs beyond the controlled area boundary). In addition to administrative limits on radioactive source term accumulation, administrative controls will be in place to limit the dispersal of radioactive material. These administrative limits and dispersal controls are in addition to the requirements already specified in the ODCM for control of effluent releases.

The PDEP EAL scheme used at FCS in is based on NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors, Revision 6 (Reference 7.8). The proposed IOEP EAL scheme format is based on NEI 99-01, Revision 6, as appropriate after the transfer of the spent fuel from the SFP to the ISFSI. The proposed revisions constitute a change in the emergency planning function commensurate with the ongoing and anticipated reduction in radiological source term at FCS.

LIC-19-0001 Page 4

3.0 PROPOSED CHANGE

S Replacement of the FCS PDEP and associated EAL Technical Bases Document with the IOEP and the ISFSI EAL Technical Bases Document involves the following major changes to the FCS PDEP:

1) Removal of the various emergency actions related to the SFP,

2) Removal of non-ISFSI-related emergency event types,

3) Clarifying definitions for security EALs

4) Revision of the Emergency Response Organization (ERO), and

5) Identification of the ISFSI Shift Supervisor (ISS) title as the position that assumes the Emergency Director (ED) responsibilities following an emergency declaration The off-normal events and accidents addressed in the IOEP are related to the dry storage of spent nuclear fuel within the ISFSI and include only the off-normal, accident, natural phenomena, and hypothetical events and consequences presented in the Updated Final Safety Analysis Report (UFSAR), NUH-003, Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, for the AREVA TN Americas. After all fuel is removed from the FCS SFP, there will no longer be any potential for the accidents previously described in the FCS emergency plan that would increase risk to the health and safety of the public. These accidents included events specifically related to the storage of the spent fuel in the SFP. After the transfer of the spent fuel from the SFP to the ISFSI, the spent fuel storage and handling systems will be removed from operation.

The proposed revisions to the FCS emergency plan and associated EAL scheme are commensurate with the reduction in radiological hazards associated with the transfer of the spent fuel from the SFP to the ISFSI and will allow the facility to transition to an emergency plan and EAL scheme specifically related to the storage of the spent fuel in the ISFSI. The proposed changes are necessary to properly reflect the conditions of the facility and to maintain the effectiveness of the emergency plan.

3.1 Elimination of SFP Initiating Conditions and EALs and Alert Classification The Initiating Conditions (ICs) and EALs associated with emergency classification in the PDEP are based on NEI 99-01, Revision 6. Specifically, Appendix C of NEI 99-01 contains a set of ICs and EALs for permanently defueled nuclear power plants that had previously operated under a 10 CFR Part 50 license and have permanently ceased power operations.

After all spent fuel has been transferred from the SFP to dry storage within the ISFSI, the NEI 99-01, Appendix C ICs and EALs that are specifically associated with the SFP are no longer required to be in the emergency plan. Additionally, certain ICs and EALs, the primary function of which is not associated with the SFP, are also no longer required to be in the emergency plan when administrative controls are established to limit source term accumulation and the offsite consequences of uncontrolled effluent releases.

Therefore, the ICs listed in Table 1, below, are proposed for elimination and are not included in the IOEP and EAL scheme.

With respect to the aircraft-related EALs; Interim Compensatory Measures (ICM) Order EA-02-026, Section B.5.b mitigation strategies (dated February 25, 2002) (Reference 7.9) was issued and subsequent security-based ICs and EALs were provided to licensees in NRC

LIC-19-0001 Page 5 Bulletin (BL) 2005-02, Emergency Preparedness and Response Actions for Security Based Events, dated July 18, 2005 (Reference 7.10). BL 2005-02 was addressed to all holders of operating licenses for nuclear power reactors, except those who had permanently ceased operation and had certified that fuel has been removed from the reactor vessel.

In 2009, the NRC amended its security regulations adding new security requirements pertaining to nuclear power reactors. This rulemaking established and updated generically applicable security requirements similar to those previously imposed by Commission orders issued after the terrorist attacks of September 11, 2001. In the Statements of Consideration (SOC) for the Final Rule for Power Reactor Security Requirements (74 Federal Register (FR) 13926; March 27, 2009), the Commission stated, in part:

Current reactor licensees comply with these requirements through the use of the following 14 strategies that have been required through an operating license condition. These strategies fall into the three general areas identified by

§§ 50.54(hh)(2)(i), (ii), and (iii). The firefighting response strategy reflected in

§ 50.54(hh)(2)(i) encompasses the following elements:.

7. Spent fuel pool mitigation measures As such, the staff maintained EALs for potential or actual aircraft threats for facilities transitioning into decommissioning with spent fuel stored in a SFP, in addition to maintaining the mitigative strategies license conditions required by NRC Order, EA-02-026, Interim Compensatory Measures (ICM) Order, issued February 25, 2002 (67 FR 9792; March 4, 2002).

The SOC further stated, in part:

The NRC believes that it is inappropriate that § 50.54(hh) should apply to a permanently shutdown defueled reactor where the fuel was removed from the site or moved to an ISFSI. The Commission notes that the § 50.54(hh) do not apply to any current decommissioning facilities that have already satisfied the § 50.82(a) requirements.

On November 28, 2011, the NRC issued a letter that rescinded Item B.5.b of the ICM Order EA-02-26 (Reference 7.18). The rulemaking codified generically applicable security requirements previously issued by orders and updated the existing power reactor security requirements.

Neither the ICM Order nor 10 CFR 50.54(hh) continue to apply to FCS. Therefore, the ICs deleted also include those associated with the mitigative strategies and response procedures for potential or actual aircraft attack procedures as the spent fuel has been removed from the SFP and is stored in the ISFSI.

10 CFR Part 50, Appendix E (IV)(A)(7) defines hostile action as an act directed toward a nuclear power plant or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end, as it applies to the capability of implementing the emergency plan during such events. However, in the Statement of Considerations for the 2011 Emergency Plan Final Rule, the NRC excluded non-power reactors from the definition of hostile action because a non-power reactor as defined in 10 CFR 50.2, Definitions, is not a nuclear power plant, and presently a

LIC-19-0001 Page 6 regulatory basis had not been developed to support the inclusion of non-power reactors in the definition of hostile action. The term is maintained to provide consistency with the site Security Plan and procedures.

Even though FCS will continue to maintain a facility license under the auspices of 10 CFR 50, the FCS ISFSI is licensed in accordance with the requirements of 10 CFR 72.212, Conditions of General License Issued Under 10 CFR 72.210. As such, the radiological consequences to the public from the FCS ISFSI have been developed in accordance with the requirements of 10 CFR 72.104, Criteria for Radioactive Materials in Effluents and Direct Radiation from an ISFSI or MRS, and 10 CFR 72.106, Controlled Area of an ISFSI or MRS. The use of these regulations to develop the FCS ISFSI Technical Specifications provides corollary alignment for development of an ISFSI EAL scheme that meets the historical purpose of an Emergency Plan, protecting the public from radiological exposure in the event of a design basis accident, using the regulatory technical bases for ISFSI facilities. This technical basis also provides the foundation for development of a radiological EAL that is more in line with the standardized risk from an ISFSI.

FCS recognizes that the practice of using Emergency Planning requirements set forth under 10 CFR 50.47 for Independent Spent Storage Facilities located at operating Nuclear Power Reactors is prudent, and that prudency extends through the period that used fuel is stored in the Spent Fuel Pool for a facility that has submitted the certifications required under 10 CFR 50.82. During these periods, having an Emergency Plan and EAL scheme that is familiar to the Certified Fuel Handlers and operating staff allows for a manageable transition from power operations to removal of all fuel from the Spent Fuel Pool. Once all fuel is placed in dry storage in the ISFSI, the makeup of the facility staff can shift dramatically. This shift, concurrent with the significant reduction in risk to the public, predicates the use of an emergency plan that more closely aligns to that of an emergency plan developed under 10 CFR 72.32. The most significant difference between the proposed FCS EAL scheme and that of a decommissioning power reactor using a 10 CFR 72.32 Emergency Plan is the required use of the ALERT classification for 10 CFR 72.32 emergency plans. All other terminology is essentially the same.

Elements for security-based events should be maintained for facilities, including ISFSI-only facilities with a 10 CFR Part 50 license to help ensure assistance can be made available during these events.

Even though a Hostile Action-Based program is not necessary for an ISFSI-only site, precedence from other utilities and regulatory guidance provides that consideration of actions by an adversary for EAL purposes is still applicable. Therefore, the use of the term HOSTILE ACTION and definition is included, to reflect those aspects associated with an ISFSI-only site and is utilized in the EALs.

The proposed judgment EAL for Alert, removes the portion of the entry condition associated with hostile action. Hostile action is already controlled in an event specific EAL. The duplication of the event in the EALs may lead to errors in implementation of the correct EAL. Therefore, the inclusion of the judgment EAL will not contain this entry provision.

NEI 99-01, provides for an EAL for determining the occurrence of damage to a loaded storage cask following an event that may cause damage to the loaded casks. FCS is proposing to base this EAL on CoC 72-1004 Technical Specifications associated with off normal radiological conditions calculated for site specific values. The NEI methods

LIC-19-0001 Page 7 provides multiplying the Technical Specifications for the dose rate limit times two.

Establishing an EAL threshold of 800 mRem/hr, 20 mRem/hr, or 10 mrem/hr as measured at the Horizontal Storage Module (HSM), provides a level of margin to maintain protection of the public, while providing an easily identifiable set point for ISFSI personnel.

This level of radiation is high enough to minimize instrument error and operational differences while still providing positive indication of an emergency condition.

The ICs listed in Table 1 are not included in the proposed ISFSI EAL scheme for FCS. The ICs in Table 1 are either associated only with SFP operation or are ICs for which administrative controls to limit possible effluent releases have been established.

LIC-19-0001 Page 8 Table 1 - Emergency Plan Initiating Conditions Being Deleted ALERT UNUSUAL EVENT PD-RA1 Release of gaseous or liquid PD-RU1 Release of gaseous or liquid radioactivity resulting in offsite dose greater radioactivity greater than 2 times the ODCM than 10 mRem TEDE or 50 mRem thyroid limits for 60 minutes or longer.(1)

CDE.(1)

PD-RA2 UNPLANNED rise in facility PD-RU2 UNPLANNED rise in facility radiation levels that impedes facility access radiation levels.(1) required to maintain spent fuel integrity.(1)

PD-HA1 HOSTILE ACTION within the PD-HU1 Confirmed SECURITY CONDITION OWNER CONTROLLED AREA or airborne or threat.(2) attack threat within 30 minutes. [HOSTILE

1. A SECURITY CONDITION that does not ACTION is occurring or has occurred.] (2) involve a HOSTILE ACTION as reported

1. [A HOSTILE ACTION is occurring or has by [the security supervision force and occurred as reported by the security impacting the ISFSI].

force.] A HOSTILE ACTION is occurring or has occurred within the OWNER 2. Notification of a credible security threat CONTROLLED AREA as reported by directed at the site [ISFSI].

security supervision.

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

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

PD-HU2 Hazardous event affecting SAFETY SYSTEM equipment necessary for spent fuel cooling.(1)

PD-SU1 UNPLANNED spent fuel pool temperature rise.(1)

E-HU1: Damage to a loaded cask CONFINEMENT BOUNDARY.

1. Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact

[abnormal] radiation reading

• 1600 mRem/hr (gamma + neutron) on the Horizontal Storage Module (HSM)[800 mRem/hr (gamma + neutron) at the front bird screen of the Hoizontal Storage Module (HSM)]

OR

• > 400 mRem/hr (gamma + neutron) on the HSM door centerline[* 20 mRem/hr

LIC-19-0001 Page 9 (gamma + neutron) on the Outside HSM door](2)

OR

[* 10 mRem/hr (gamma + neutron) on the End Shield Wall exterior](2)

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

[NOTE: Radiation readings are taken at the locations prescribed by the Technical Specifications for the Standardized NUHOMS Horizontal Storage System (Amendment Number 15 to CoC 1004)]

(1)

Indicates the IC and the associated EALs are being deleted in their entirety.

(2)

Indicates only the portion of the IC or EAL shown in strikethrough text is being deleted. Text included with brackets [ ] will be added in the proposed ISFSI EAL Scheme.

The ICs being deleted include all ICs associated with the categories of abnormal radioactive release and system malfunction associated with the SFP as well as security conditions associated with aircraft. These categories apply only to SFP operation and are not appropriate given the minimized risk of having all spent fuel stored within the ISFSI.

The ICs listed in Table 2, below, are being retained. The ICs being retained in the ISFSI Only Emergency Plan are appropriate to address the condition of a facility in which all spent fuel is stored in the ISFSI.

Table 2 - ISFSI Emergency Plan Initiating Conditions UNUSUAL EVENT SECURITY PD-HU1 Confirmed SECURITY CONDITION, or threat, at the independent spent storage installation (ISFSI).

Other Conditions PD-HU3 Judgment Independent Spent Fuel Storage Installation (ISFSI)

E-HU1: Damage to a loaded cask CONFINEMENT BOUNDARY.

ALERT SECURITY PD-HA1 HOSTILE ACTION is occurring or has occurred.

LIC-19-0001 Page 10 Other Conditions PD-HA3 Judgement 3.2 Emergency Response Organization Revision The FCS PDEP provides for two (2) ERO augmented positions - a Technical Coordinator and a Radiation Protection Coordinator. The proposed FCS IOEP replaces these positions with a Resource Manager and an individual trained in radiological monitoring and assessment.

A Resource Manager is provided to assist in assessing the event and obtaining needed resources. The Resource Manager is required to be in contact with the Emergency Director (ED) within two (2) hours of declaration of an Unusual Event or an Alert. Entry into the IOEP would result from an extreme natural phenomenon (beyond design basis) or a security condition, either of which would negatively impact or restrict access to the site.

The Resource Manager augments the ED by assisting in assessing the emergency condition and coordinating the required resources, including serving as the public information interface. Services provided to the ED by the Resource Manager can be provided remotely and do not necessitate an onsite response by the Resource Manager.

By responding remotely, the actual response time is decreased with no negative impact to services and functional responsibilities provided by the Resource Manager. The Resource Managers functional responsibilities could be performed in a timely manner either by reporting to the site or performing the function remotely in the specified timeframe.

In addition, FCS proposes that, for a classified event involving radiological consequences, a minimum of one person trained in radiological monitoring and assessment will report to the ISFSI within four hours of the emergency declaration.

The proposed FCS IOEP also provides that additional personnel resources may be directed to report to FCS to provide additional support as needed to assess radiological conditions, support maintenance and repair activities, develop and implement corrective action plans, and assist with recovery actions. The augmentation personnel are available from FCS staff, OPPD, and from various contractors.

3.3 Replacement of the Shift Manager with the ISFSI Shift Supervisor The FCS PDEP assigns the authority and responsibility for control and mitigation of emergencies to the Shift Manager (SM). If an emergency condition develops, the SM would assume the role of ED. The proposed FCS IOEP proposes replacing the SM position with an ISS within the IOEP.

The ISS will be at FCS on a continuous, 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day basis, and is the senior management position during off-hours. This position is responsible for monitoring ISFSI conditions and managing the activities at the FCS ISFSI. This position assumes overall command and control of the response as the ED and is responsible for monitoring conditions and approving all onsite activities. The IOEP identifies non-delegable responsibilities, along with other designated tasks. OPPD considers this an administrative

LIC-19-0001 Page 11 change which will not impact the timing or performance of existing emergency response duties.

3.4 Removal of emergency notification to the State of Iowa.

The State of Iowa Department of Homeland Security formally requested to be removed from any emergency notifications associated with FCS.

4.0 TECHNICAL EVALUATION

4.1 Radiological Consequences of Design Basis Events FCS is located midway between Fort Calhoun and Blair, Nebraska, on the west bank of the Missouri River. The site is located approximately 19 miles North of Omaha, Nebraska and four (4) miles South of Blair, Nebraska. The ISFSI is located within a Protected Area on the site. Except for the city of Blair and the villages of Fort Calhoun and Kennard, the area within a ten mile radius is predominantly rural and land use is primarily devoted to general farming. There are no private businesses or public recreational facilities on the plant property.

Chapter 14 of the FCS Final Safety Analysis Report, as Updated described the Abnormal Operational Transients and Design Basis Accident (DBA) scenarios applicable to FCS during power operations. However, after permanent cessation of power operations and transfer of all irradiated fuel from the SFP to dry storage within the ISFSI, the remaining accident scenarios postulated in the Defueled Safety Analysis Report (DSAR) are no longer possible. The ISFSI is a passive storage system that does not rely on electric power for heat transfer. After removal of the spent fuel from the SFP, there are no credible fuel-related accidents for which actions of a Certified Fuel Handler, SM, or Non-Certified Operator are required to prevent occurrence or to mitigate the consequences. There is no credible accident resulting in radioactive releases requiring offsite protective measures.

The robust design and construction of the spent fuel storage system selected for use at the ISFSI prevents the release of radioactivity in the event of an off-normal or accident event as described in the NUHOMS UFSAR. Leakage of fission products from a canister confinement boundary breach is not considered to be a credible event, given the high integrity nature of the canisters design and the additional protection afforded by the storage casks.

FCS PSDAR documents the decommissioning strategy selected for FCS. Systems that are not required to support the spent fuel, HVAC, Emergency Plan, or site security will be drained, de-energized, and secured and the plant will remain in a stable condition until final decontamination and dismantlement activities begin. The PSDAR documents the time period that OPPD expects to have all spent fuel transferred to the ISFSI. After the fuel transfer is completed, the SFP and associated systems will be drained and de-energized.

After all the spent fuel has been removed from the SFP, the estimated radiological inventory (non-fuel) that remains at the reactor facility is primarily attributable to activated reactor components and structural materials. There are no credible accident scenarios that can mobilize a significant portion of this inventory for release. As a result, the potential

LIC-19-0001 Page 12 accidents that could occur during decommissioning of the reactor facility have negligible offsite and onsite radiological consequences.

With all spent nuclear fuel in dry storage within the ISFSI, the radiological status of the facility required for implementing this proposed IOEP is summarized as follows:

The remaining radiological source term at FCS will not create an unplanned/unanticipated increase in radiation or in liquid or airborne radioactivity levels that would result in doses to the public above EPA PAG limits at the site boundary.

Source term accumulation from activities during decontamination and dismantlement of radioactive systems, structures, and components are administratively controlled at a level that would preclude declaring an Unusual Event.

Necessary radiological support personnel will be administratively required to be onsite during active decontamination and dismantlement of radioactive systems, structures, and components.

The IOEP, and certain ICs and EALs for which administrative controls to limit possible effluent releases will be established, do not apply to the decontamination and dismantlement of radioactive systems, structures, and components.

NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, (NUREG-0586) (Reference 7.11) supports this conclusion in the following statement:

The staff has reviewed activities associated with decommissioning and determined that many decommissioning activities not involving spent fuel that are likely to result in radiological accidents are similar to activities conducted during the period of reactor operations. The radiological releases from potential accidents associated with these activities may be detectible. However, work procedures are designed to minimize the likelihood of an accident and the consequences of an accident, should one occur, and procedures will remain in place to protect health and safety while the possibility of significant radiological accident exists.

NUREG-0586 also includes the following statement:

The staff has considered available information, including comments received on the draft of Supplement 1 of NUREG-0586, concerning the potential impacts of non-spent fuel related radiological accidents resulting from decommissioning. This information indicates, that with the mitigation procedures in place, the impacts of radiological accidents are neither detectible nor destabilizing. Therefore, the staff makes the generic conclusion that impacts of non-spent fuel related radiological accidents are SMALL. The staff has considered mitigation and concludes that no additional measures are likely to be sufficiently beneficial to be warranted.

Accordingly, administrative controls that are designed to minimize the likelihood and consequence of off-normal or accident events would be implemented when decontamination or dismantling activities involving radioactive systems, structures, or components are being performed.

LIC-19-0001 Page 13 Implementation of the IOEP would involve FCS establishing administrative controls for radiological source term accumulation limits and methods to control the accidental dispersal of the radiological source. Examples of radiological source term accumulation limits are based on:

Radioactive materials collected on filter media and resins (dose rate limit)

Contaminated materials collected in shipping containers (dose rate limit)

Surface or fixed contamination on work areas that may create airborne radioactive material (activity limits)

Radioactive liquid storage tank(s) (activity concentration limits)

An example of a method to control accidental dispersal of the radiological source term is limitation on dispersal mechanisms that may cause a fire (e.g., limits on combustible material loading, use of fire watch to preclude fire, etc.), or placement of a berm around a radioactive liquid storage tank. If the dispersal control fails, the limits on source term would preclude exceeding the site boundary source term limit.

As discussed in the previously requested exemptions from various emergency planning requirements contained in 10 CFR 50.47 and 10 CFR 50, Appendix E, an analysis of the potential radiological impact of a design basis accident at FCS in a permanently defueled condition indicates that any releases beyond the site boundary are below EPA PAG exposure levels. The basis for these exemptions has not changed and remains in effect for the proposed IOEP.

4.2 Radiological Consequences of Postulated Events Although the limited scope of postulated accidents that remain applicable to the FCS facility justifies a reduction in the necessary scope of emergency response capabilities, FCS also assessed beyond design basis events using past industry precedence, including information contained in Appendix I, Radiological Accidents, of NUREG-0586.

With spent fuel stored within the SFP, the most severe postulated beyond design basis event involved a highly unlikely sequence of events that causes heatup of the spent fuel, postulated to occur without any heat transfer, such that the zircaloy fuel cladding reaches ignition temperature (adiabatic heat up). The resultant zircaloy fire could lead to the release of large quantities of fission products to the atmosphere. However, after removal of the spent fuel from the SFP, the configuration of the spent fuel stored in dry storage precludes the possibility of such a scenario.

With this previously limiting beyond design basis scenario no longer possible, FCS assessed the following beyond design basis events associated with performance of decommissioning activities with all irradiated fuel stored in the ISFSI. A summary of the assessments is provided below:

1. Cask Drop Event (Fuel-Related Event)

FCS is the holder of a general license for the storage of spent fuel in an ISFSI at power sites in accordance with the provisions of 10 CFR 72.210 and 10 CFR 72.212. The generally licensed ISFSI at FCS is used for interim onsite dry storage of spent nuclear fuel

LIC-19-0001 Page 14 assemblies in the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, (Certificate of Compliance (CoC) 1004).

As documented in the NUHOMS UFSAR, NUH-003, analysis of the normal events, including drop events, determined that canister drops can be sustained without breaching the confinement boundary, preventing removal of spent fuel assemblies, or creating a criticality accident. There are no evaluated normal conditions or off-normal or accident events that result in damage to the canister producing a breach in the confinement boundary. Neither normal conditions of operation or off-normal events preclude retrieval of the fuel for transport and ultimate disposal.

The dry spent fuel storage casks used at FCS are approved for storage of spent fuel per 10 CFR 72.214; and, as such, are in compliance with the requirements of 10 CFR 72.24 and 10 CFR 72.122 for off-normal and accident events to ensure that they will provide safe storage of spent fuel during all analyzed off-normal and accident events. Therefore, no radiological release beyond the site boundary would be expected to occur.

2. Radioactive Material Handling Accident (Non-Fuel-Related Event)

The limiting non-fuel related event involves the release of radioactive material from a concentrated source, such as filters, resins, and shipping containers (as discussed in NUREG-0586, Appendix 1). The initiator to these events could be a fire, explosion, or a handling event (cask drop). After all spent fuel has been moved to the ISFSI, there would be no concentrated source of radioactive material available to be released to the environment in an amount that could exceed two (2) times the ODCM limit at the site boundary (2 times 1500 millirem/year). During decontamination and dismantlement activities, administrative controls would limit the total amount of activity that could accumulate in a concentrated source. FCS Calculation FC08566 (Attachment 1) details an activity accumulation limit methodology for decontamination and dismantlement of irradiated stainless steel (e.g., reactor vessel internals) and irradiated concrete (e.g.,

reactor coolant loop bio-shield walls) based on isotopic mixtures from NUREG/CR-3474, Long-Lived Activation Products in Reactor Materials, (Reference 7.12) such that a release to the environment from concentrated sources of these radioactive materials would not exceed two times the ODCM at the site boundary.

It is expected that representative material samples will be taken and analyzed prior to actual decontamination/dismantlement work. Using the methodology consistent with this calculation, container/filter maximum radioactivity limits will be derived.

The results of the above assessment indicate that the projected radiological doses at the controlled area boundary are less than the EPA PAGs.

3. Accidents Initiated by External Events The effects of external events, such as fires, floods, wind (including tornados), earthquakes, lightning, and physical security breaches on the ISFSI remain unchanged from the effects that were considered under the proposed PDEP. Externally initiated events are addressed by the proposed ISFSI EALs.

In summary, there continues to be a low likelihood of any postulated event resulting in radiological releases requiring offsite protective measures, and there is no credible

LIC-19-0001 Page 15 radioactive material event (non-fuel related) resulting in radiological releases requiring declaration of an emergency.

4.3 ISFSI ONLY EMERGENCY PLAN The FCS IOEP is provided in Enclosure 1, Attachment 3 to this submittal for NRC review and approval. This proposed emergency plan is associated with EALs for events related to the ISFSI. The IOEP addresses the applicable regulations stipulated in 10 CFR 50.47, Emergency Plans; 10 CFR 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities (considering the exemptions requested in Reference 7.3); and 10 CFR 72.32, Emergency Plan, and is consistent with the applicable guidelines established in NUREG-0654/FEMA-REP-1, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (Reference 7.13).

The IOEP describes FCSs plan for responding to emergencies while all spent fuel is in dry storage within an ISFSI. After all spent fuel at FCS is in dry storage within the ISFSI, the number and severity of potential radiological accidents is significantly less than when fuel is stored in the SFP.

The FCS IOEP conservatively provides that the emergency planning zone for the ISFSI is the area within the site boundary. At FCS, the site boundary completely encompasses the controlled area. The controlled area, as defined in 10 CFR 72.3, Definitions, means the area immediately surrounding an ISFSI for which FCS exercises authority over its use and within which ISFSI operations are performed.

The controlled area is established to limit dose to the public during normal operations and design basis accidents in accordance with the requirements of 10 CFR 72.104, Criteria for Radioactive Materials in Effluents and Direct Radiation from an ISFSI or MRS, and 10 CFR 72.106, Controlled Area of an ISFSI or MRS. FC08574, Fort Calhoun Data Specific Radiological Assessment, FCSs analysis of the radiological impact of potential accidents at the ISFSI concludes that any releases beyond the ISFSI controlled area are expected to be less than the EPA PAGs. The controlled area is completely enclosed within the site boundary. Thus, any radiological releases beyond the site boundary will also be less than the EPA PAGs.

Based on the reduced number and consequences of potential radiological events with all spent fuel in dry storage within the ISFSI, there will continue to be no need for offsite emergency response plans for the protection of the public beyond the site boundary.

Additionally, the scope of the onsite emergency preparedness organization and corresponding requirements in the emergency plan may be reduced without an undue risk to the public health and safety.

The analysis of the potential radiological impact of an accident in a condition with all irradiated fuel stored in the ISFSI indicates that any releases beyond the site boundary are below the EPA PAG exposure levels. Exposure levels, which warrant pre-planned response measures, are limited to onsite areas. For this reason, radiological emergency planning is focused onsite.

4.4 ISFSI Emergency Action Levels

LIC-19-0001 Page 16 Enclosure 1, Attachment 4 of this submittal provides the FCS ISFSI EAL Technical Bases Document, which contains the proposed FCS ISFSI EAL scheme for NRC review and approval. The proposed ISFSI EAL scheme is to be implemented by the FCS ISFSI Emergency Plan (provided in Enclosure 1).

Deletions from the proposed Permanently Defueled EAL scheme are identified in Table 1, Emergency Plan Initiating Conditions Being Deleted, in Section 3.1, Elimination of SFPs Initiating Conditions and EALs, above.

Related Documents Supporting evaluations/calculations for establishing appropriate radioactive material administrative control limits are provided in Attachment 1 to this submittal.

Operating Modes and Applicability The proposed ISFSI EALs are only applicable after the final spent nuclear fuel assembly has been transferred out of the SFP and placed in dry storage within the ISFSI.

State and Local Government Review of Proposed Changes State and local emergency management officials are advised of EAL changes that are implemented. Prior to implementation of the EAL scheme proposed in this License Amendment Request (LAR), FCS will provide an overview of the new classification scheme to State and local emergency management officials in accordance with 10 CFR 50, Appendix E, Section IV.B.1.

5.0 REGULATORY EVALUATION

The proposed emergency plan does not meet all standards of 10 CFR 50.47(b) and requirements of 10 CFR Part 50, Appendix E. However, FCS previously received exemptions from portions of 10 CFR 50.47(b), 10 CFR 50.47(c)(2), and 10 CFR 50, Appendix E, Section IV, by letter dated December 11, 2017 (Reference 7.3). The basis for these exemptions has not changed and remains in effect for the emergency plan changes requested in this document. Considering the previously approved exemptions, the emergency plan, as revised, will continue to meet the remaining applicable requirements in 10 CFR Part 50, Appendix E and the remaining applicable planning standards of 10 CFR 50.47(b).

5.1 No Significant Hazards Consideration In accordance with 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit, OPPD requests NRC approval of a reduction in effectiveness of the site Emergency Plan by the removal of several EALs and corresponding changes to the emergency plan, to be implemented after all spent fuel has been removed from the SFP and placed in dry storage within the ISFSI. The proposed IOEP and ISFSI EAL Technical Bases Document are commensurate with the reduction in radiological source term at FCS.

The PSDAR documents the time period that FCS expects to have all spent fuel transferred to the ISFSI. To comport to the reduced scope of potential radiological accidents with all spent fuel in dry cask storage within the ISFSI, FCS proposes a new emergency plan and corresponding EAL scheme.

LIC-19-0001 Page 17 Pursuant to 10 CFR 50.92, OPPD has reviewed the proposed changes and concludes that the changes do not involve a significant hazards consideration because the proposed changes satisfy the criteria in 10 CFR 50.92(c). These criteria require that operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

The proposed changes would revise the FCS emergency plan and EAL scheme commensurate with the hazards associated with a permanently shut down and defueled facility that has transferred all spent fuel from the SFP to dry cask storage within the ISFSI.

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

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

Response: No.

The proposed amendment would modify the FCS facility operating license by revising the emergency plan and EAL scheme. FCS has permanently ceased power operations and is permanently defueled. The proposed amendment is conditioned on all spent nuclear fuel being removed from wet storage in the SFP and placed in dry storage within the ISFSI. Occurrence of postulated accidents associated with spent fuel stored in a SFP is no longer credible in a SFP devoid of such fuel. The proposed amendment has no effect on plant systems, structures, or components (SSC) and no effect on the capability of any plant SSC to perform its design function. The proposed amendment would not increase the likelihood of the malfunction of any plant SSC. The proposed amendment would have no effect on any of the previously evaluated accidents in the FCS DSAR.

Because FCS has permanently ceased power operations, the generation of fission products has ceased and the remaining source term continues to decay. This continues to significantly reduce the consequences of previously evaluated postulated accidents.

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

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

Response: No.

The proposed amendment constitutes a revision of the emergency planning function commensurate with the ongoing and anticipated reduction in radiological source term at FCS.

The proposed amendment does not involve a physical alteration of the plant. No new or different types of equipment will be installed and there are no physical modifications

LIC-19-0001 Page 18 to existing equipment as a result of the proposed amendment. Similarly, the proposed amendment would not physically change any SSC involved in the mitigation of any postulated accidents. Thus, no new initiators or precursors of a new or different kind of accident are created. Furthermore, the proposed amendment does not create the possibility of a new failure mode associated with any equipment or personnel failures.

The credible events for the ISFSI remain unchanged.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

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

Response: No.

Because 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), the occurrence of postulated accidents associated with reactor operation is no longer credible. With all spent nuclear fuel transferred out of wet storage from the SFP and placed in dry storage within the ISFSI, a fuel handling accident is no longer credible. There are no credible events that would result in radiological releases beyond the site boundary exceeding the EPA PAG exposure levels, as detailed in the EPAs PAG Manual "Protective Action Guides and Planning Guidance for Radiological Incidents" dated January 2017 (EPA PAG Manual).

The proposed amendment does not involve a change in the plants design, configuration, or operation. The proposed amendment does not affect either the way in which the plant SSCs perform their safety function or their design margins. Because there is no change to the physical design of the plant, there is no change to these margins.

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

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

5.2 Applicable Regulatory Requirements/Criteria The regulatory requirements, considering the previously requested exemptions are discussed below.

Title 10 of the Code of Federal Regulations (10 CFR), Section 50.47, "Emergency Plans,"

set forth emergency plan requirements for nuclear power plant facilities. The regulations in 10 CFR 50.47(a)(1)(i) state, in part:

no initial operating license for a nuclear power reactor will be issued unless a finding is made by the NRC that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.

LIC-19-0001 Page 19 Section 50.47(b) establishes the standards that emergency response plans must meet for NRC staff to make a positive finding that there is reasonable assurance that the licensee can and will take adequate protective measures in the event of a radiological emergency.

Planning Standard (1) of Section 50.47(b) states, in part: [E]ach principal response organization has staff to respond and to augment its initial response on a continuous basis.

Planning Standard (2) of Section 50.47(b) states, in part: On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available Planning Standard (4) of Section 50.47(b) requires that a licensees emergency response plan contain the following: A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee.

Planning Standard (8) of Section 50.47(b) states, in part: Adequate emergency facilities and equipment to support the emergency response are provided and maintained.

10 CFR 50.54(q)(4) specifies the process for revising emergency plans where the change reduces the effectiveness of the plan. This regulation states the following:

The changes to a licensees emergency plan that reduce the effectiveness of the plan as defined in paragraph (q)(1)(iv) of this section may not be implemented without prior approval by the NRC.

Section IV.A of Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, to 10 CFR Part 50, states, in part: The organization for coping with radiological emergencies shall be described, including definition of authorities, responsibilities, and duties of individuals assigned to the licensees emergency organization Section IV.C.1 of Appendix E requires that each emergency plan define the emergency classification levels that determine the extent of participation of the emergency response organization.

Section IV.E of Appendix E states, in part: Adequate provisions shall be made and described for emergency facilities and equipment. As identified in 10 CFR 72.13, Applicability, the applicable emergency plan requirements for an ISFSI associated with a general license are specified in 10 CFR 72.32(c) and (d).

The proposed emergency plan continues to rely on previously requested exemptions from certain emergency planning requirements as the basis for these exemptions has not changed and remains in effect.

The proposed changes are conservatively being considered as a change to the EAL scheme development methodology. Pursuant to 10 CFR Part 50, Appendix E, Section IV.B.2, a revision to an entire EAL scheme must be approved by the NRC before implementation.

LIC-19-0001 Page 20 5.3 Precedent Similar changes to emergency plans and associated EAL schemes approved by the NRC for plants that have transitioned to ISFSI-only status include: 1) the La Crosse Boiling Water Reactor (LACBWR) facility on September 8, 2014 (Reference 7.15); 2) the Zion Facility on May 14, 2015 (Reference 7.16); 3) the Vermont Yankee Station (Reference 7.19); and 4)

Duke Energy Florida, Inc. for the Crystal River Unit 3 Nuclear Generating Station on August 12, 2016 (Reference 7.17).

5.4 Conclusion Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

LIC-19-0001 Page 21

6.0 ENVIRONMENTAL CONSIDERATION

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

(i) The amendment involves no significant hazards consideration.

As described in Section 5.1 of this evaluation, the proposed changes involve no significant hazards consideration.

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

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

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

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

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

7.0 REFERENCES

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

(ADAMS Accession No. ML16242A127) 7.2 OPPD Letter (T. Burke) to USNRC (Document Control Desk) - Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel, dated November 13, 2016 (LIC-16-0074) (ADAMS Accession No. ML16319A254) 7.3 Letter USNRC (J. Kim) to OPPD (M. Fisher) - Fort Calhoun Station, Unit No. 1, Exemptions From Certain Emergency Planning Requirements and Related Safety Evaluation, dated December 11, 2017 (LIC-16-0109) (CAC No. MF9067)

(ML17263B198; ML17263B191; ML17278A178) 7.4 OPPD Letter (T. Burke) to USNRC (Document Control Desk) - License Amendment Request 16-05 to 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) (ADAMS Accession No. ML16351A464)

LIC-19-0001 Page 22 7.5 Letter USNRC (J. Kim) to OPPD (M. Fisher) - Fort Calhoun Station, Unit No. 1, Post-Shutdown Decommissioning Activities Report, dated March 23, 2017 (LIC 0033) (CAC No. 9536) (ML18011A687) 7.6 Nuclear Regulatory Commission to AREVA TN Americas CoC 1004, Amendment 14, CoC, dated March 31, 2017, effective April 25, 2017. (ADAMS Accession No. ML17191A236) 7.7 U.S. Environmental Protection Agency, Protective Action Guide and Planning Guidance for Radiological Incidents, dated January 2017 (PAG Manual) 7.8 Nuclear Energy Institute (NEI) 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, dated November 2012. (ADAMS Accession No. ML12326A805) 7.9 NRC Interim Compensatory Measures (ICM) Order EA-02-026, Section B.5.b mitigation strategies (dated February 25, 2002) (ADAMS Accession No. ML020510635) 7.10 NRC Bulletin (BL) 2005-02, Emergency Preparedness and Response Actions for Security Based Events, dated July 18, 2005 (ADAMS Accession No. ML051740058) 7.11 NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, Supplement 1, Volume 1, dated November 2002 7.12 NUREG/CR-3474, Long-Lived Activation Products in Reactor Materials, dated August 2000 7.13 NUREG-0654, FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, published November 1980 7.14 Letter, Mark Thaggard (USNRC) to Susan Perkins-Grew (NEI), U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 6, Dated November, 2012 (TAC No. D92368), dated March 28, 2013 (ADAMS Accession No. ML12346A463) 7.15 Letter from U.S. Nuclear Regulatory Commission to Dairyland Power Cooperative (La Crosse Boiling Water Reactor) Issuance of Amendment Relating to the Dairyland Power Cooperative La Crosse Boiling Water Reactor Request for Changes to the Emergency Planning Requirements, dated September 8, 2014 (ADAMS Accession No. ML14155A112) 7.16 Letter from U.S. Nuclear Regulatory Commission to Zion Solutions LLC (Zion Nuclear Power Station), Issuance of Amendments Relating to the Emergency Planning Requirements for Zion Nuclear Power Station, Units 1 and 2, dated May 14, 2015 (ADAMS Accession No. ML15092A423) 7.17 Memo, Office of Nuclear Security and Incident Response, Reactor Licensing Branch, Division of Preparedness and Response to Office of Nuclear Materials Safety and Safeguards, Division of Decommissioning, Uranium Recovery and Waste

LIC-19-0001 Page 23 Programs, Reactor Decommissioning Branch, Safety Evaluation Input for the Crystal River Unit 3 Independent Spent Fuel Storage Installation Only Emergency Plan (CAC No L53129), dated August 12, 2016 (ADAMS Accession No. ML16201A135) 7.18 Letter from U.S. Nuclear Regulatory Commission for Holders of Licenses for Operating Power Reactors Rescission or Partial Rescission of Certain Power Reactor Security Orders Applicable to Nuclear Power Plants, dated November 28, 2011 (ADAMS Accession No. ML111220447) 7.19 Letter from U.S. Nuclear Regulatory Commission to Vermont Yankee Nuclear Power Station - Issuance of Amendment to Change the Emergency Plan and Emergency Action Level Scheme to Reflect an ISFSI-Only Configuration (ML18053A112)

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION DOCKET NUMBER 50-285 / LICENSE NUMBER DPR-40 ATTACHMENT 1 SUPPORTING EVALUATIONS AND CALCULATIONS

FORT CALHOUN STATION DOCKET NUMBER 50-285 / LICENSE NUMBER DPR-40 ATTACHMENT 2 COMPARISON MATRIX FOR ISFSI EALS BASED ON NEI 99-01, Rev 6 DEVELOPMENT OF EMERGENCY ACTION LEVELS FOR NON-PASSIVE REACTORS TO THE PROPOSED FCS EMERGENCY CLASSIFICATION SYSTEM AND ISFSI EALS

LIC-19-0001 Attachment 2 Page 1 NEI 99-01 Rev 6, Appendix C Proposed EAL Matrix for FCS Comparison ICs/EALs E-HU1 E-HU1 Removed Operating Mode applicability as it does not apply ECL: Unusual Event ECL: Unusual Event in a permanently defueled Initiating Condition: Damage to a Initiating Condition: Damage to a condition loaded cask CONFINEMENT loaded cask CONFINEMENT BOUNDARY. BOUNDARY.

Operating Mode Applicability: Not Applicable Example Emergency Action Levels: Emergency Action Levels: 1, 2, or 3 Provides FCS-specific radiation levels that conform to CoC 72-(1) Damage to a loaded cask 1. Damage to a loaded cask 1004 Technical Specification CONFINEMENT BOUNDARY as CONFINEMENT BOUNDARY as radiation limits indicated by an on-contact indicated by an abnormal radiation reading of 800 mrem/hr (gamma Included NOTE to identify that radiation reading greater than 2x

+ neutron) at front Bird Screen of the radiation levels referenced in site specific cask technical the HSM. the EAL are taken at the specifications allowable radiation locations prescribed by the level on the surface of the spent 2. Damage to a loaded cask Technical Specifications for the fuel cask. CONFINEMENT BOUNDARY as Standardized NUHOM Horizontal indicated by an abnormal radiation Storage System.

reading of 20 mrem/hr (gamma +

neutron) on outer HSM Door.

3. Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an abnormal radiation reading of 10 mrem/hr (gamma +

neutron) on End Shield Wall exterior.

NOTE: Radiation readings are taken at the locations prescribed by the Technical Specifications for the Standardized NUHOMS Horizontal Storage System (Amendment Number 15 to CoC 1004).

Basis: Basis: Added FCS specific basis This IC addresses an event that results This IC addresses an event that results information in damage to the CONFINEMENT in damage to the CONFINEMENT BOUNDARY of a storage cask BOUNDARY of a storage cask containing spent fuel. It applies to containing spent fuel. It applies to irradiated fuel that is licensed for dry irradiated fuel that is licensed for dry storage beginning at the point that the storage beginning at the point that the loaded storage cask is sealed. The loaded storage cask is sealed. The issues of concern are the creation of a issues of concern are the creation of a potential or actual release path to the potential or actual release path to the environment, degradation of one or environment, degradation of one or more fuel assemblies due to more fuel assemblies due to environmental factors, and environmental factors, and configuration configuration changes which could changes which could cause challenges

LIC-19-0001 Attachment 2 Page 2 NEI 99-01 Rev 6, Appendix C Proposed EAL Matrix for FCS Comparison ICs/EALs cause challenges in removing the cask in removing the cask or fuel from or fuel from storage. storage.

The existence of damage is The existence of damage is determined by radiological survey. The determined by radiological survey. The technical specification multiple of 2 radiation limits listed in the EAL reflect times, which is also used in calculations based on the technical Recognition Category A IC AU1, is specification multiple of 2 times, is used here to distinguish between non- used here to distinguish between non-emergency and emergency conditions. emergency and emergency conditions.

The emphasis for this classification is The emphasis for this classification is the degradation in the level of safety of the degradation in the level of safety of the spent fuel cask and not the the spent fuel cask and not the magnitude of the associated dose or magnitude of the associated dose or dose rate. It is recognized that in the dose rate. It is recognized that in the case of extreme damage to a loaded case of extreme damage to a loaded cask, the IC may be determined based cask, the IC may be determined based on measurement of a dose rate at on measurement of a dose rate at some some distance from the cask. distance from the cask.

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

The Transnuclear Standardized NUHOMS System Technical Specifications Amendment 15 to CoC 1004, Section 5.4.1 (HSM or HSM-H Dose Rate Evaluation Program) contains site-specific radiation values for the cask that should not be exceeded. Keeping in line with NEl 99-01 guidance that an Unusual Event is warranted for radiation conditions at a level of twice the Technical Specification value, the values chosen for EAL E-HU1 represents these values.

The Note in the EAL provides guidance on where the radiation readings are to be taken when evaluating this EAL.

PD-HU1 PD-HU1 Use of Unusual Event instead of Notification of Unusual Event ECL: Unusual Event ECL: Unusual event Use agrees in meaning and Initiating Condition: Confirmed Initiating Condition: Confirmed intent with NEI 99-01, Rev 6.

SECURITY CONDITION, or threat. SECURITY CONDITION, or threat, at Removed Operating Mode the independent spent storage Operating Mode Applicability: Not applicability as it does not apply installation (ISFSI).

Applicable in a permanently defueled condition Example Emergency Action Levels: Emergency Action Levels: 1 or 2 Removed Example from (1 or 2 or 3) emergency action levels

LIC-19-0001 Attachment 2 Page 3 NEI 99-01 Rev 6, Appendix C Proposed EAL Matrix for FCS Comparison ICs/EALs (1) A SECURITY CONDITION that 1. A SECURITY CONDITION as Revised reporting person to does not involve a HOSTILE reported by the security force and conform to security staffing ACTION as reported by the (site- impacting the ISFSI.

specific security shift supervision). Included distinction that the

2. Notification of a credible security threat impacts the ISFSI (2) Notification of a credible security threat directed at the ISFSI. Deleted EAL 3 related to aircraft threat directed at the site. threat (3) A validated notification from the NRC providing information of an aircraft threat.

Basis: Basis: Deleted reference to communicating with the Control This initiating condition (IC) addresses This IC addresses events that pose a Room and referenced events that pose a threat to plant threat to facility personnel or spent fuel, communicating with the ISFSI personnel and, thus, represents a and thus represent a potential Shift Supervisor/Emergency potential degradation in the level of degradation in the level of facility safety.

Director plant safety. Security events which do Security events which do not meet one not meet one of these emergency of these EALs are adequately Deleted wording associated with action levels (EALs) are adequately addressed by the requirements of aircraft threats addressed by the requirements of 10 CFR 73.71 or 10 CFR 50.72.

Section 73.71, Reporting of Security events assessed as HOSTILE Deleted wording regarding safeguards events, of Title 10 of the ACTION are classifiable under IC PD- security-sensitive information Code of Federal Regulations (10 CFR) HA1.

Part 73, Physical Protection of Plants and Materials, or Section 50.72, Timely and accurate communication Immediate notification requirements between the security force and the for operating nuclear power reactors, ISFSI Shift Supervisor/Emergency of 10 CFR Part 50, Domestic Director is essential for proper Licensing of Production and Utilization classification of a security-related event.

Facilities. Classification of these events will initiate appropriate threat-related notifications Timely and accurate communications to site personnel and Offsite Response between Security Shift Supervision Organizations (OROs).

and the Control Room is essential for proper classification of a security- Security plans and terminology are related event. Classification of these based on the guidance provided by NEI events will initiate appropriate threat- 03-12, Template for the Security Plan, related notifications to plant personnel Training and Qualification Plan, Safeguards Contingency Plan [and and offsite response organizations (OROs). Independent Spent Fuel Storage Installation Security Program].

Security plans and terminology are based on the guidance provided by EAL #1 references the security force NEI 03-12 Template for the Security because these are the individuals Plan, Training and Qualification Plan, trained to confirm that a security event Safeguards Contingency Plan [and is occurring or has occurred. Training Independent Spent Fuel Storage on security event confirmation and Installation Security Program]. classification is controlled due to the nature of Safeguards and 10 CFR 2.390 EAL #1 references (site-specific information.

security shift supervision) because these are the individuals trained to EAL #2 addresses the receipt of a confirm that a security event is credible security threat. The credibility occurring or has occurred. Training on of the threat is assessed in accordance security event confirmation and with Security procedures.

LIC-19-0001 Attachment 2 Page 4 NEI 99-01 Rev 6, Appendix C Proposed EAL Matrix for FCS Comparison ICs/EALs classification is controlled due to the Escalation of the emergency nature of safeguards and Section classification level would be via IC PD-2.390, Public inspections, exemptions, HA1.

and requests for withholding, of 10 CFR Part 2, Agency Rules of Practice and Procedure, information.

EAL #2 addresses the receipt of a credible security threat directed at the ISFSI. The credibility of the threat is assessed in accordance with (site-specific procedure).

EAL #3 addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may also be provided by North American Aerospace Defense Command (NORAD) through the NRC.

Validation of the threat is performed in accordance with (site-specific procedure).

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.

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

PD-HA1 PD-HA1 Changed Initiating Condition wording to delete the reference to ECL: Alert ECL: Alert the Owner Control Area Initiating Condition: HOSTILE Initiating Condition: HOSTILE Deleted reference to airborne ACTION within the OWNER ACTION is occurring or has occurred.

threat CONTROLLED AREA or airborne attack threat within 30 minutes. Removed Operating Mode Operating Mode Applicability: Not applicability as it does not apply Applicable in a permanently defueled condition Example Emergency Action Levels: Emergency Action Levels: 1 Removed Example from Emergency Action Levels

LIC-19-0001 Attachment 2 Page 5 NEI 99-01 Rev 6, Appendix C Proposed EAL Matrix for FCS Comparison ICs/EALs (1) A HOSTILE ACTION is occurring 1. A HOSTILE ACTION is occurring Reworded to make EAL specific or has occurred within the or has occurred as reported by the to FCS ISFSI facility. The OWNER CONTROLLED AREA security force. security force is trained on as reported by the (site-specific security events. The occurrence of a hostile action will be security shift supervision).

determined by security (2) A validated notification from NRC supervision in accordance with of an aircraft attack threat within security procedures 30 minutes of the site.

Deleted Example EAL 2 related to aircraft threat Basis: Basis: Changed wording to reflect FCS ISFSI EAL wording This IC addresses the occurrence of a This IC addresses the occurrence of an HOSTILE ACTION within the ISFSI or HOSTILE ACTION. Deleted wording associated with notification of an aircraft attack threat. aircraft threats This event will require rapid response Timely and accurate communication and assistance due to the possibility of between the security force and the Deleted reference to the attack compromising stored spent ISFSI Shift Supervisor/Emergency communicating with the Control fuel or damaging the storage casks, or Director is essential for proper Room and referenced the need to prepare the plant and staff classification of a security-related event. communicating with the ISFSI for a potential aircraft impact. Security plans and terminology are Shift Supervisor/Emergency based on the guidance provided by Director Timely and accurate communications between Security Shift Supervision NEI 03-12, Template for the Security Deleted information on aircraft and the Control Room is essential for Plan, Training and Qualification Plan, threat proper classification of a security- Safeguards Contingency Plan [and Independent Spent Fuel Storage Deleted wording regarding related event.

Installation Security Program]. security-sensitive information Security plans and terminology are based on the guidance provided by As time and conditions allow, these NEI 03-12. events require a heightened state of readiness by the facility staff and As time and conditions allow, these implementation of onsite protective events require a heightened state of measures (e.g., evacuation, dispersal or readiness by the plant staff and sheltering). The Alert declaration will implementation of possible onsite also heighten the awareness of Offsite protective measures (e.g., evacuation, Response Organizations (OROs),

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

be better prepared should it be necessary to consider further actions. This IC does not apply to incidents that are accidental events, acts of civil This IC does not apply to incidents that disobedience, or otherwise are not a are accidental events, acts of civil HOSTILE ACTION perpetrated by a disobedience, or otherwise are not a hostile force. Examples include the HOSTILE ACTION perpetrated by a crash of a small aircraft, shots from HOSTILE FORCE. Examples include hunters, physical disputes between the crash of a small aircraft, shots from employees, etc. Reporting of these hunters, physical disputes between types of events is adequately employees, etc. Reporting of these addressed by other EALs, or the types of events is adequately requirements of 10 CFR 73.71 or addressed by other EALs, or the 10 CFR 50.72.

requirements of 10 CFR 73.71 or 10 CFR 50.72. This EAL is applicable for any HOSTILE ACTION directed against the ISFSI.

LIC-19-0001 Attachment 2 Page 6 NEI 99-01 Rev 6, Appendix C Proposed EAL Matrix for FCS Comparison ICs/EALs EAL #1 is applicable for any HOSTILE ACTION occurring, or that has occurred, in the ISFSI.

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

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

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

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.

PD-HU3 PD-HU3 Use of Unusual Event instead of Notification of Unusual Event ECL: Notification of Unusual Event ECL: Unusual event Use agrees in meaning and Initiating Condition: Other Initiating Condition: Other Conditions intent with NEI 99-01, Rev 6 Conditions exist which in the judgment exist which in the judgment of the Removed Operating Mode of the emergency director warrant emergency director warrant declaration applicability as it does not apply declaration of a NOUE. of an Unusual Event.

in a permanently defueled condition

LIC-19-0001 Attachment 2 Page 7 Operating Mode Applicability: Not Applicable Example Emergency Action Levels: Emergency Action Levels: 1 Removed Example from emergency action levels (1) Other conditions exist which in the 1. Other conditions exist which in the judgment of the Emergency judgement of the Emergency Reworded to make EAL specific Director indicate that events are in Director indicate that events are in to FCS ISFSI facility and align progress or have occurred which progress or have occurred which with the systems utilized in the indicate a potential degradation of indicate a potential degradation of ISFSI the level of safety of the plant or the level of safety of the ISFSI or indicate a security threat to facility indicate a security threat to facility protection has been initiated. No protection has been initiated. No releases of radioactive material release of radioactive material requiring offsite response or requiring offsite response or monitoring are expected unless monitoring are expected unless further degradation of safety further degradation of systems systems occurs. important to safety occurs.

Basis: Basis: Use agrees in meaning and intent with NEI 99-01, Rev. 6 This IC addresses unanticipated This IC addresses unanticipated conditions not addressed explicitly conditions not addressed explicitly elsewhere but that warrant declaration elsewhere but that warrant declaration of of an emergency because conditions an emergency because conditions exist exist which are believed by the which are believed by the Emergency Emergency Director to fall under the Director to fall under the emergency emergency classification level classification level description for an description for a NOUE. UNUSUAL EVENT.

PD-HA3 PD-HA3 Removed Operating Mode applicability as it does not apply ECL: Alert ECL: Alert in a permanently defueled Initiating Condition: Other Initiating Condition: Other Conditions condition Conditions exist which in the judgment exist which in the judgment of the of the emergency director warrant emergency director warrant declaration declaration of an Alert. of an ALERT.

Operating Mode Applicability: Not Applicable Example Emergency Action Levels: Emergency Action Levels: 1 Removed Example from emergency action levels (1) Other conditions exist which in 1. Other conditions exist which in the the judgment of the Emergency judgement of the Emergency Reworded to make EAL specific Director indicate that events are Director indicate that events are in to FCS ISFSI facility and align in progress or have occurred progress or have occurred which with the systems utilized in the which indicate a potential involve an actual or potential ISFSI substantial degradation of the substantial degradation of the level level of safety of the plant or of safety of the ISFSI. Any Removed duplicate entry criterion indicate a security threat that releases are expected to be limited for hostile action involves probable life threatening to small fractions of the EPA risk to site personnel or damage Protective Action Guideline to equipment because of a exposure levels.

HOSTILE ACTION. Any releases are expected to be limited to a small fraction of the EPA

LIC-19-0001 Page 8 Protective Action Guideline exposure levels.

Basis: Basis: No differences or deviations This IC addresses unanticipated This IC addresses unanticipated conditions not addressed explicitly conditions not addressed explicitly elsewhere but that warrant declaration elsewhere but that warrant declaration of of an emergency because conditions an emergency because conditions exist exist which are believed by the which are believed by the Emergency Emergency Director to fall under the Director to fall under the emergency emergency classification level classification level description for an description for an Alert. ALERT.

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION DOCKET NUMBER 50-285 / LICENSE NUMBER DPR-40 ATTACHMENT 3 ISFSI ONLY EMERGENCY PLAN

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

ONLY EMERGENCY PLAN (Revision 0 when approved)

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION ISFSI ONLY EMERGENCY PLAN TABLE OF CONTENTS

1.0 INTRODUCTION

............................................................................................................. 1 1.1. Purpose ............................................................................................................... 1 1.2. Scope .................................................................................................................. 1 2.0 DISCUSSION .................................................................................................................. 3 2.1. Overview of ISFSI Only Emergency Plan ............................................................. 3 2.2. Facility Description ............................................................................................... 4 2.3. Summary of Emergency Actions .......................................................................... 4 3.0 DEFINITIONS AND ACRONYMS ................................................................................... 5 3.1. Definitions ............................................................................................................ 5 3.2. Acronyms ............................................................................................................. 8

4.0 REFERENCES

................................................................................................................ 9 5.0 ASSIGNMENT OF RESPONSIBILITY .......................................................................... 11 5.1. Emergency Response and Responsibility .......................................................... 11 5.2. Offsite Response Organizations......................................................................... 11 6.0 EMERGENCY RESPONSE ORGANIZATION .............................................................. 13 6.1. On-Shift Positions .............................................................................................. 13 6.2. ERO Augmented Positions ................................................................................ 14 6.3. Offsite Response Organizations......................................................................... 15 6.4. Functional Responsibilities................................................................................. 15 7.0 OFFSITE EMERGECY RESPONSE SUPPORT AND RESOURCES ........................... 16 8.0 EMERGENCY CLASSIFICATION SYSTEM ................................................................. 17 8.1. Emergency Classification System ...................................................................... 17 8.2. Emergency Action Levels and Postulated Accidents .......................................... 18 9.0 NOTIFICATION METHODS AND PROCEDURES ........................................................ 19 9.1. Basis for Emergency Notification ....................................................................... 19 9.2. Emergency Messages ....................................................................................... 19 9.3. Means of Providing Emergency Notification ....................................................... 20

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 10.0 EMERGENCY COMMUNICATIONS ............................................................................. 22 11.0 PUBLIC INFORMATION ............................................................................................... 23 12.0 EMERGENCY FACILITY AND EQUIPMENT ................................................................ 24 12.1. Emergency Response Facility ............................................................................ 24 12.2. Emergency Equipment and Supplies ................................................................. 24 12.3. First Aid Facilities ............................................................................................... 25 13.0 ACCIDENT ASSESSMENT .......................................................................................... 26 14.0 PROTECTIVE ACTIONS............................................................................................... 27 14.1. Accountability..................................................................................................... 27 14.2. ISFSI Egress Control Methods ........................................................................... 27 15.0 RADIOLOGICAL EXPOSURE CONTROL .................................................................... 28 15.1. Exposure Guidelines .......................................................................................... 28 15.2. Radiation Protection Program ............................................................................ 28 16.0 MEDICAL AND HEALTH SUPPORT ............................................................................ 31 16.1. Onsite First Aid .................................................................................................. 31 16.2. Medical Transportation....................................................................................... 31 16.3. Offsite Medical Support ...................................................................................... 31 17.0 EMERGENCY TERMINATION AND RECOVERY ........................................................ 32 17.1. Emergency Termination and Notification ............................................................ 32 17.2. Recovery Operations ......................................................................................... 32 18.0 EXERCISES AND DRILLS ........................................................................................... 33 18.1. Emergency Plan Exercises and Drills................................................................. 33 18.2. Equipment and Proficiency Drills/Tests .............................................................. 34 18.3. Critiques and Evaluation .................................................................................... 35 19.0 EMERGENCY RESPONSE TRAINING ......................................................................... 36 19.1. Emergency Response Personnel Training ......................................................... 36 19.2. Emergency Response Support Organizations .................................................... 37 19.3. Annual Emergency Action Level Training ........................................................... 38 20.0 RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW, AND DISTRIBUTION .................................................................................... 39 20.1. Emergency Preparedness Responsibilities ........................................................ 39 20.2. Review and Updating of the IOEP...................................................................... 40 20.3. Training .............................................................................................................. 40 20.4. Maintenance and Inventory of Emergency Equipment and Supplies .................. 40

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 APPENDICES Page Appendix A Emergency Equipment, Supplies and Reference Materials 42 Appendix B Cross Reference IOEP Section to Planning Standards/Requirements/Criteria and EPIPs 43 LIST OF TABLES Page Table 6-1 Emergency Response Organization Staffing and Responsibilities 15 Table 10-1 Communications Systems 22 Table 15-1 Response Worker Emergency Dose Limits 30 Table B-1 Cross Reference IOEP Section to Planning Standards/Requirements/Criteria and EPIPs 44

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 INTRODUCTION Fort Calhoun Station (FCS) permanently ceased power operations on October 24, 2016.

On November 13, 2016, by letter (LIC-16-0074), Omaha Public Power District (OPPD) provided certification to the U.S. Nuclear Regulatory Commission (NRC) required by 10 CFR 50.82(a)(1)(i) and (ii) that FCS had permanently ceased power operations and that all fuel had been permanently removed from the reactor vessel. Subsequently, all spent fuel has been transferred to the onsite Independent Spent Fuel Storage installation (ISFSI) facility.

The FCS ISFSI Only Emergency Plan (IOEP) describes the plan for responding to emergencies that may arise at the ISFSI. In this condition, no reactor operations can take place and all irradiated fuel has been removed from the Spent Fuel Pool. This IOEP adequately addresses the risks associated with FCSs current conditions.

The ISFSI Updated Final Safety Analysis Report (UFSAR) describes the Design Basis Accidents (DBAs) applicable to the FCS ISFSI along with the radiological dose calculation results. As provided in the ISFSI UFSAR, the analyses of the potential radiological impacts of postulated off-normal, natural phenomena, and accident events involving the ISFSI indicate that any releases would result in a dose to the public below those limits established in 10 CFR 72.106(b). Therefore, exposure levels, which warrant pre-planned response measures are limited to the ISFSI and immediate vicinity, and for this reason, radiological emergency planning is focused on this area.

1.1. Purpose The purpose of the IOEP is to ensure an adequate level of preparedness to cope with the spectrum of emergencies that could be postulated to occur. This plan integrates the necessary elements to provide effective emergency response considering cooperation and coordination of organizations expected to respond to potential emergencies.

1.2. Scope The IOEP has been developed to respond to potential radiological emergencies at the FCS ISFSI. Because there are no postulated off-normal, natural phenomena, or accident events that would result in dose consequences that are large enough to require offsite emergency planning, the overall scope of the IOEP details the actions necessary to safeguard onsite personnel. The concepts presented in the IOEP address the applicable regulations stipulated in 10 CFR 50.47, Emergency Plans, and Appendix E to 10 CFR 50, Emergency Planning and Preparedness for Production and Utilization Facilities. The IOEP is consistent with the applicable guidelines established in NUREG 0654/FEMA REP 1, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 Exemptions from selected portions of 10 CFR 50.47 and 10 CFR Part 50 Appendix E were approved by the NRC on December 11, 2017 (ADAMS Accession Number ML17263B198)

The IOEP, Revision 0 was approved per NRC Safety Evaluation on [insert date prior to issuing] (ADAMS Accession Number ML#########) [insert ADAMS Accession Number prior to issuing].

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 DISCUSSION 2.1. Overview of ISFSI Only Emergency Plan In the event of an emergency at the FCS ISFSI, actions are required to identify and assess the nature of the emergency and to bring it under control in a manner that protects the health and safety of the public and onsite personnel.

The IOEP describes the organization and responsibilities of FCS for implementing emergency measures and describes interfaces with offsite agencies (Federal, State, and local) and organizations that may be notified in the event of an emergency and may provide assistance.

Emergency fire/rescue, law enforcement, and medical response are provided by local public and private entities. Specifically, fire/rescue support services and transportation of injured and/or contaminated personnel are provided by the Blair Volunteer Fire Department; fixed medical services are provided by Blair Hospital providing 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; and law enforcement support services are provided by local, State, and Federal law enforcement authorities, as appropriate.

FCS is licensed under the requirements of 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities. Consistent with the requirements of 10 CFR Part 50, Section 50.47(b) and Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, with approved exemptions. Sections 5.0 through 20.0 of this IOEP address the standards outlined in 10 CFR 50.47(b)(1) through (16). In addition, the IOEP is also intended to meet appropriate State and U.S. NRC regulations in accordance with OPPDs Operating License (No. DPR-40). OPPD is licensed to store spent fuel in the FCS ISFSI under the General License provisions of 10 CFR 72.210 and 10 CFR 72.212.

Because the analyses of credible design basis events and consequences indicate there are no postulated events that would result in offsite dose consequences large enough to require offsite emergency planning, emergencies are divided into two classifications: 1) Notification of Unusual Event (Unusual Event) and 2) Alert.

OPPD is responsible for planning and implementing emergency measures associated with the FCS ISFSI. This IOEP is provided to meet this responsibility.

To carry out specific emergency measures discussed in the IOEP, detailed Emergency Plan Implementing Procedures (EPIPs) are established and maintained. Appendix B provides a listing of the EPIPs for the IOEP.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 In addition to the description of activities and steps that can be implemented during a potential emergency, the IOEP also provides a general description of the steps taken to recover from an emergency. It also describes the training, exercises and drills, planning, and coordination appropriate to maintain an adequate level of emergency preparedness.

2.2. Facility Description FCS is located midway between Fort Calhoun and Blair, Nebraska, on the west bank of the Missouri River. The site is located approximately 19 miles North of Omaha, Nebraska and 4 miles South of Blair. The ISFSI is located within the Protected Area of the site.

FCS is certified to have ceased power operations and is permanently defueled in accordance with 10 CFR 50.82(a)(1)(i) and (ii). All spent fuel has been transferred to the FCS ISFSI. The FCS ISFSI is a robust and high integrity facility for the spent fuel storage system. This facility is designed to prevent the release of radioactivity in the event of accidents, including environmental phenomena (e.g., earthquake and flooding).

2.3. Summary of Emergency Actions This plan is activated by the ISFSI Shift Supervisor (ISS) upon identification of an emergency situation based upon the Emergency Action Level (EAL) criteria.

The ISS assumes the position of the Emergency Director upon classification of an emergency. The emergency measures described in the subsequent sections and EPIPs are implemented in accordance with the classification and nature of the emergency, and at the direction of the Emergency Director. The Emergency Director has the authority and responsibility for control and mitigation of the emergency, including emergency response resources, and coordination of emergency response activities.

The following sections of this IOEP describe the detailed plans and actions of the FCS Emergency Response Organization (ERO), including interfaces with offsite support organizations.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 DEFINITIONS AND ACRONYMS This section provides definitions and acronyms used in this document. Terms capitalized in the text of the definitions indicate that they are defined elsewhere in this section.

3.1. Definitions Accountability - A discretionary protective action taken for all persons onsite (within the ISFSI PROTECTED AREA) that involves the gathering of personnel into pre-designated areas and subsequent verification that the location of all personnel is known.

Alert - Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the ISFSI. Any releases are expected to be limited to small fractions of the Environmental Protection Agency (EPA) Protective Action Guideline (PAG) exposure levels.

Annual - Once per calendar year, unless otherwise stated.

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

Corrective Action - Those emergency measures taken to mitigate or terminate an emergency situation at or near the source of the problem in order to prevent an uncontrolled release of radioactive material or to reduce the magnitude of a release (e.g., equipment shutdown, firefighting, equipment repair, and damage control).

Design Basis Accident (DBA) - Credible accident events as analyzed in the ISFSI Updated Final Safety Analysis Report.

Emergency Action Level (EAL) - A pre-determined, site-specific, observable threshold for an INITIATING CONDITION (IC) that, when met or exceeded, places the ISFSI in a given emergency classification level.

Emergency Classification System - A system of classification in which emergency occurrences are categorized according to specific protective action levels. The two emergency classification levels, in ascending order of severity, are: NOTIFICATION OF UNUSUAL EVENT and ALERT.

Emergency Director - This position is the highest level of authority for the FCS Emergency Response Organization (ERO) and onsite emergency activities. This position is held by the ISFSI Shift Supervisor (ISS) or designated alternate.

Emergency Plan Implementing Procedure (EPIP) - Specific procedures describing actions taken by plant staff to activate and implement the IOEP.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 Emergency Response Facility (ERF) - Facility containing the communications equipment necessary for emergency conditions. It is operated under the direction of the Emergency Director and serves as the primary location for classification of the emergency, notification of the emergency to offsite agencies, ASSESSMENT ACTIONS, and CORRECTIVE ACTION direction.

Emergency Response Organization (ERO) - Organization comprised of assigned individuals who would respond and assist during a classified emergency.

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

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

Violent acts between individuals in the owner controlled area do not meet this definition.

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

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

Monthly - Frequency of occurrence is met if performed within 1.25 times a 31 day interval as measured from the previous performance.

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

Protected Area (PA) - That area within the perimeter of the security fence.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 Protective Actions - Those measures taken in anticipation of, or after an uncontrolled release of radioactive material, for the purpose of preventing or minimizing radiological exposures to persons that would be likely to occur if the actions were not taken.

Protective Action Guide (PAG) - The projected dose to an individual, resulting from a radiological incident at which specific protective actions to reduce or avoid that dose are warranted.

Radioactive Release - Any radioactive material beyond pre-emergency levels and not attributable to normal operations, either detected or suspected of migrating beyond the PROTECTED AREA, while in a classified emergency.

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

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

Security Condition - Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the ISFSI.

Site - That property of Fort Calhoun Station which is owned by the Licensee.

Site Boundary - The perimeter of the land owned by OPPD surrounding the ISFSI. The ISFSI Controlled Area, as defined by 10 CFR 72.3, is bounded within the Site Boundary.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 3.2. Acronyms ALARA As Low As Reasonably Achievable DBA Design Basis Accident EAL Emergency Action Level ENS Emergency Notification System EPA Environmental Protection Agency EPIP Emergency Plan Implementing Procedure ERF Emergency Response Facility ERO Emergency Response Organization FCS Fort Calhoun Station FTS Federal Telecommunication System IC Initiating Condition IOEP ISFSI Only Emergency Plan ISFSI Independent Spent Fuel Storage Installation ISS ISFSI Shift Supervisor LLEA Local Law Enforcement Agency NRC Nuclear Regulatory Commission OPPD Omaha Public Power District ORO Offsite Response Organization PAG Protective Action Guide RCA Radiological Control Area UFSAR Updated Final Safety Analysis Report 8

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 REFERENCES

1. 10 CFR 50.47, Emergency Plans

2. 10 CFR 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities

3. 10 CFR 20, Standards for Protection Against Radiation

4. NUREG-0578, "TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations" (July 1979)

5. NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Rev. 1

6. Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors"

7. FCS ISFSI Storage System, Certificates of Compliance, Updated Final Safety Analysis Report, and Technical Specifications

8. NRC Bulletin (BL) 2005-02, Emergency Preparedness and Response Actions for Security Based Events, dated July 18, 2005 (ADAMS Accession No. ML051740058)

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

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

11. EPAs Protective Action Guides and Planning Guidance for Radiological Incidents, EPA-400/R-17/001 dated January 2017

12. Letter, OPPD to USNRC, Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel, LIC-16-0074, dated November 13, 2016 (ADAMS Accession No. ML16319A254)

13. Fort Calhoun Station - Exemption from Certain Emergency Planning Requirements and Related Safety Evaluation, February 15, 2017(ADAMS Accession Number ML17041A238)

14. NUREG-0586, Generic Environmental Impact Statement of Decommissioning of Nuclear Facilities, Supplement 1, Volume 1, November 2002

15. NRC Information Notice No. 90-08: KR-85 Hazards from Decayed Fuel

16. 10 CFR 72.13, Applicability

17. 10 CFR 72.32, Emergency Plan

18. 10 CFR 72.44, License Conditions

19. 10 CFR 72.106, Controlled Area of an ISFSI or MRS

20. Fort Calhoun Station ISFSI Security Plan 9

FCS ISFSI ONLY EMERGENCY PLAN Revision 0

21. Fort Calhoun Station ISFSI EAL Technical Bases 10

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 ASSIGNMENT OF RESPONSIBILITY The FCS ISFSI Organization has 24-hour capability to perform the detection, classification, initial response, and notification functions required during an emergency.

Primary responsibilities for emergency response have been assigned, the emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

5.1. Emergency Response and Responsibility OPPD is responsible for the safe storage of spent fuel in accordance with the State of Nebraska and NRC regulations. Responsibility for planning and implementing all emergency measures rests with OPPD.

FCS ISFSI Organization has an inherent emergency response/recovery function in its overall management and operation.

The ISFSI Shift Supervisor (ISS) is at FCS on a continuous, 24-hour per day basis, and is the senior management position during off-hours. This position is responsible for monitoring ISFSI conditions and managing the activities at the FCS ISFSI. The ISS has the responsibility and authority to declare an emergency and initiate appropriate actions in accordance with written procedures to mitigate the consequences. When an off-normal, natural phenomenon, or accident event becomes apparent, the ISS shall assess the condition and assume the position of Emergency Director once an emergency declaration has been made.

The Emergency Director is responsible for the direction of all activities at the ISFSI site during an emergency. Should evaluation indicate the need, the Emergency Director has the authority to direct any or all personnel to relocate from the ISFSI and surrounding area and to notify all applicable agencies of the ISFSI status. The Emergency Director ensures that appropriate actions are taken and management and applicable offsite supporting organizations and regulatory agencies are notified, as necessary.

The functions associated within the Emergency Directors scope of responsibilities are specified on Table 6-1.The Emergency Director does not have concurrent duties which conflict with the these responsibilities.

A Resource Manager assists in assessing the event and obtaining additional resources needed to respond to the event.

5.2. Offsite Response Organizations The Emergency Director coordinates the Offsite Response Organization (ORO) response (fire/rescue, ambulance, and local law enforcement agency (LLEA)),

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 access, and radiological controls with the onsite activities. The OROs are capable of 24-hour emergency response.

The response of the State of Nebraska and local government agencies are in accordance with each agency's plans and procedures, and are commensurate with the hazard posed by the emergency.

Letters of Agreement are in place for those local organizations that will respond.

State of Nebraska Notification of an emergency declaration or change in classification is provided to the State of Nebraska via the commercial telephone system.

The State of Nebraska is capable of receiving the notification on a 24-hour per day basis.

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.

Transportation of Injured and Contaminated Personnel 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. The Fort Calhoun Volunteer Fire Department has agreed to provide backup services.

Treatment of Radioactively Contaminated and Injured Personnel The Blair Hospital has agreed to provide medical support for work-related injuries. University of Nebraska Medical Center (UNMC) in Omaha, maintains a regional Radiation Health Center which provides services for the treatment of radiologically contaminated injuries and radiation exposure evaluation.

Law Enforcement Law enforcement support services are provided by local, State of Nebraska, and federal law enforcement authorities as appropriate, and response capabilities are documented in the Letters of Agreement maintained by Security.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 EMERGENCY RESPONSE ORGANIZATION Emergency Response Organization (ERO) responsibilities for emergency response are identified in Table 6-1, Emergency Response Organization Staffing and Responsibilities.

6.1. On-Shift Positions FCS maintains personnel on-shift at all times capable of providing the initial response to an off-normal, natural phenomenon, or accident event. Members of the on-shift organization are trained on their responsibilities and duties in the event of a classified emergency and are capable of performing all necessary response actions until any necessary augmenting staff arrives or the event is terminated. The on-shift staffing assignments include the roles and responsibilities for their emergency response functions.

ISFSI Shift Supervisor The ISS is at FCS 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day and is the senior management position during off-hours. When an off-normal, natural phenomenon, or accident event becomes apparent, the ISS shall assess the condition and assume the position of Emergency Director once an emergency classification has been made.

Emergency Director This position is responsible for monitoring conditions and approving all onsite activities and has the requisite authority, management ability, technical knowledge, and staff to manage the site emergency and recovery organization.

The Emergency Director is responsible for the direction of the total emergency response and has the company authority to accomplish this responsibility. The Emergency Director assumes overall command and control.

The Emergency Director cannot delegate the following responsibilities:

Classification of an event Approval of emergency notifications (although the task of making notifications may be delegated)

Authorization of radiation exposures in excess of 10 CFR Part 20 limits The Emergency Director is responsible for assuring that appropriate corrective and protective actions are taken to mobilize emergency response personnel and for notifying management, OROs, and regulatory 13

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 agencies, as necessary. Other responsibilities assumed by the Emergency Director associated with the functions listed in Table 6-1 include:

Notification of the emergency classification to the NRC and the State of Nebraska Management of available station resources Initiation of mitigative, corrective, and onsite protective actions Decision to call for LLEA, fire/rescue, or ambulance assistance Augmentation of the emergency staff, as deemed necessary Coordination of security activities Termination of the emergency condition when appropriate Performance of initial radiological assessment Maintaining a record of event activities Suspending security measures Security Security is administered by the ISFSI Physical Security Plan. Security will perform accountability as directed by the ISS or Emergency Director.

6.2. ERO Augmented Positions FCS maintains the necessary personnel and resources to support the Emergency Director in responding to an emergency.

Resource Manager The Resource Manager will be in contact with the Emergency Director within two (2) hours of an emergency declaration. The Resource Manager will augment the Emergency Director by assisting in the assessment of the emergency condition and coordinating any required resources, including serving as the public information interface. The Resource Manager does not need to physically report to the ERF to perform the assigned responsibilities.

Radiological Assessment Personnel For a declared emergency involving radiological consequences, a minimum of one person trained in radiological monitoring and assessment will report to the ERF within four (4) hours of the emergency declaration.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 Additional Resources Additional personnel resources may be directed to report to FCS by the Emergency Director to provide additional support as needed to assess radiological conditions, support maintenance and repair activities, develop and implement corrective action plans, and assist with recovery actions. The augmentation personnel are available from FCS staff, OPPD, Nebraska Public Power Districts Cooper Nuclear Station, and can be requested from various contractors.

6.3. Offsite Response Organizations Additional support is available from OROs, as described in Section 5.2 of this Plan.

6.4. Functional Responsibilities Table 6-1 lists the functional responsibilities that fulfill emergency staffing capabilities.

TABLE 6-1 Emergency Response Organization Staffing and Responsibilities AUGMENTED FUNCTIONAL AREA LOCATION ON-SHIFT STAFF

RESPONSE

Assessment of Condition Emergency Response Emergency Director Resource Manager (Emergency Declaration) Facility Emergency Direction and Emergency Response Emergency Director ---

Control Facility Notifications / Emergency Response Emergency Director ---

Communications Facility Resource Manager Radiological Accident Emergency Response Radiological Assessment and Emergency Director Facility / On Scene Assessment Protective Actions Personnel**

Emergency Response Corrective Actions Emergency Director ---

Facility / On Scene Per Fire Protection Offsite Response Fire Fighting On Scene Program Plan Organization 15

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 Rescue and First Aid Offsite Response On Scene

• Treatment Organization Site Access Control and Per ISFSI Security Per ISFSI Security Accountability Procedures Procedures

• Provided by on-shift personnel who may be assigned other functions

• • For a declared emergency involving radiological consequences, a minimum of one (1) person trained in radiological monitoring and assessment will report to the ERF within four (4) hours of the emergency declaration.

OFFSITE EMERGECY RESPONSE SUPPORT AND RESOURCES Arrangements for requesting and effectively using resources have been made and other organizations capable of augmenting the planned response have been identified. Letters of Agreement are in place for those local organizations (fire/rescue, ambulance, LLEA, and medical) that will respond to an emergency at the FCS ISFSI. The Letters of Agreement for each agency are maintained on file.

The Emergency Director coordinates the fire/rescue, ambulance, and LLEA response as previously discussed in Section 5.2 of this Plan.

The Emergency Director is authorized to request Federal assistance as needed. The NRC will act as the lead Federal agency providing coordination and support in response to an emergency at FCS.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 EMERGENCY CLASSIFICATION SYSTEM A standard emergency classification and emergency action level scheme is in use. This section describes emergency classifications, Initiating Conditions (ICs), Emergency Action Levels (EALs), and postulated emergency situations.

8.1. Emergency Classification System The emergency classification system covers the entire spectrum of possible radiological and non-radiological emergencies at the FCS ISFSI. The emergency classification system categorizes accidents and/or emergency situations into one of two emergency classification levels depending on emergency conditions at the time of the incident: Unusual Event and Alert. Each of these emergency classes requires notification to the Resource Manager, the State of Nebraska, and the NRC.

Once indications are available that an EAL is met, the event is assessed and classified, and the corresponding emergency classification level is promptly declared as soon as possible. Refer to the ISFSI Emergency Action Level Technical Bases for actual parameter values, and status used to classify emergencies.

Incidents may be initially classified as an Unusual Event and then escalated to an Alert if the situation deteriorates. The following Sections outline the actions at each classification level.

Unusual Event EVENTS ARE IN PROGRESS OR HAVE OCCURRED WHICH INDICATE A POTENTIAL DEGRADATION OF THE LEVEL OF SAFETY OF THE ISFSI OR INDICATE A SECURITY THREAT TO ISFSI PROTECTION HAS BEEN INITIATED. NO RELEASES OF RADIOACTIVE MATERIAL REQUIRING OFFSITE RESPONSE OR MONITORING ARE EXPECTED.

Upon classification of an Unusual Event, offsite authorities will be informed of the emergency classification and the necessary documentation will be completed as specified in the EPIPs.

The purpose of the Unusual Event declaration is to: 1) provide for an increased awareness of abnormal conditions; 2) provide for systematic handling of information and decision-making, and 3) augment on-shift personnel, if deemed necessary by the Resource Manager.

The classification shall be maintained until the emergency is terminated or the emergency escalates to an Alert. If an escalation to an Alert 17

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 occurs, offsite authorities will be informed within 60 minutes of the change in emergency classification.

ALERT EVENTS ARE IN PROGRESS OR HAVE OCCURRED WHICH INVOLVE AN ACTUAL OR POTENTIAL SUBSTANTIAL DEGRADATION OF THE LEVEL OF SAFETY OF THE ISFSI. ANY RELEASES ARE EXPECTED TO BE LIMITED TO SMALL FRACTIONS OF THE ENVIRONMENTAL PROTECTION AGENCY (EPA) PROTECTIVE ACTION GUIDELINE (PAG) EXPOSURE LEVELS.

Upon classification of an Alert, offsite authorities will be informed of the emergency classification and the necessary documentation will be completed as specified in the EPIPs.

The purpose of the Alert declaration is to: 1) perform event mitigation and radiation monitoring, if required, and 2) ensure that all necessary resources are being applied to accident mitigation.

Plant responses associated with this event classification ensure that sufficient emergency response personnel are mobilized and respond to event conditions. The Alert classification includes emergency situations which are not expected to threaten the public.

The classification shall be maintained until the emergency is terminated.

FCS may enter Recovery operations while in the Alert classification.

8.2. Emergency Action Levels and Postulated Accidents Both emergency classifications are characterized by EALs consisting of specific instrument readings and/or observations which indicate to the ISS that an IC has been met. These EALs are used to ensure that the initial classification of emergencies can be accomplished rapidly, allowing for the prompt identification of the necessary mitigating actions. EALs and ICs are provided under the following categories:

ISFSI Hazards and other Conditions The ISFSI UFSAR describes the DBAs applicable to the FCS ISFSI and the radiological dose calculation results. Specific guidance for classifying emergencies is found in EPIPs and the ISFSI EAL Technical Bases Document.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 NOTIFICATION METHODS AND PROCEDURES Procedures are established for notification to the State of Nebraska and local organizations and for notification of FCS emergency personnel. FCS has established the means for notification and dissemination of emergency messages. The content of initial and follow-up messages to response organizations has been established.

9.1. Basis for Emergency Notification The notification of personnel and emergency response organizations is commensurate with the hazard posed by the emergency. The emergency classification system described in Section 8.0 is the primary bases for notification and has been mutually agreed upon by applicable State and Federal organizations.

9.2. Emergency Messages The Emergency Director is responsible for the notification of an emergency declaration to the State of Nebraska and the NRC within 60 minutes of the event classification or change in classification.

The format and contents of the initial message between FCS and the State of Nebraska are specified in notification procedures and have been established with the review and agreement of the responsible state authorities. The initial notification contains the following information, as available:

Identification of the facility Identification of the message sender Date and Time of the emergency declaration Emergency classification, including EAL Radiological conditions Follow up reports are provided as additional information describing the emergency situation becomes available, or as requested by the State of Nebraska, until such time that the emergency condition has been terminated.

The follow-up messages will contain the following information, as available:

Identification of the facility Identification of the message sender Date and Time of the emergency declaration Emergency classification, including EAL Radiological conditions, including an assessment of any radioactive release Emergency response actions underway Request for any needed support from offsite agencies Prognosis for worsening or termination of the event based on available information 19

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 9.3. Means of Providing Emergency Notification Various communications systems, as described in Section 10.0, are available to perform emergency notifications. The Emergency Director is the primary individual for initiating notifications. However, the Emergency Director may designate an individual to perform the notifications. EPIPs and emergency telephone directories identify organizations and individuals to be notified and contain appropriate listings of telephone numbers.

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

State of Nebraska Notification of an emergency declaration, and specific emergency information, is conveyed to the State of Nebraska using the commercial telephone system. This system is available in the ERF on a 24-hour per day basis.

Other commercial means, including the use of wireless communications, will serve as a backup to the commercial telephone system.

NRC Emergency Notification System The NRC utilizes the Federal Telecommunications System (FTS) telephone network. The FTS system provides a dedicated telephone network. The Emergency Notification System (ENS) utilizes an FTS line which exists between the NRC Operations Office in Rockville, Maryland and FCS. Emergency notification, facility status information, and radiological information are communicated via the ENS.

The NRC will be notified as soon as possible after State notification and within 60 minutes of event declaration or change in classification.

The commercial telephone system serves as a backup to the ENS.

ERO Notification The Resource Manager is notified of an emergency declaration by an onsite announcement, the commercial telephone system, or other means which may include land line and/or wireless devices. The Emergency Director is responsible for the notification to the Resource Manager. As described in Section 5.1 of this Plan, the on-shift staff positions are available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day and can perform all required IOEP actions.

The Resource Manager will be in contact with the Emergency Director within two (2) hours of an emergency declaration. At the direction of the 20

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 Emergency Director, additional personnel will be activated to augment the on-shift staff.

Notification of Offsite Response Organizations The ORO support services described in Section 5.2 of this Plan are primarily notified of the need for assistance via 911 utilizing the commercial telephone system. Requests for ORO support services are the responsibility of the Emergency Director.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 EMERGENCY COMMUNICATIONS Provisions exist for prompt communications between principal response organizations and emergency response personnel. The communications systems listed in Table 10-1 provide 24-hour onsite and offsite communications capability allowing for prompt notification and activation of emergency personnel. In the event of an emergency declaration, these communications systems provide the appropriate means for alerting or activating emergency personnel in each response organization and allow continued means for contact throughout the emergency.

Communications systems providing the capability for onsite and offsite communications are tested to verify proper operation at the frequencies specified in Table 10-1.

Communications systems that are listed with a testing frequency of Frequent Use indicates that the associated equipment is normally used at a sufficiently high regularity (e.g., multiple times each day), such that separate additional testing is not needed.

Functionality is verified through normal (frequent) use of the system.

TABLE 10-1 Communications Systems Communications System Testing Frequency Commercial Telephone System Monthly Portable Radios Frequent Use NRC ENS Monthly 22

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 PUBLIC INFORMATION As part of its normal corporate structure, OPPD maintains a corporate public affairs office that can be called upon, as necessary. The public affairs office will be notified of an emergency classification by the Emergency Director or Resource Manager.

Public affairs office personnel will monitor media activity and coordinate with senior management to address rumors and disseminate information to the public. News conferences can be conducted onsite or at other locations, as necessary. Senior FCS or OPPD management will be assigned as spokespersons.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 EMERGENCY FACILITY AND EQUIPMENT Adequate emergency facilities and equipment to support the emergency response are provided and maintained. This section of the IOEP identifies and describes the ERF, assessment equipment, the first aid and medical facilities, and protective equipment and supplies that can be utilized during an emergency.

12.1. Emergency Response Facility The emergency command and control functions are managed within the ERF.

From the ERF, the Emergency Director (or other personnel, as directed) can assess ISFSI conditions; evaluate the magnitude and potential consequences of abnormal conditions; initiate preventative and corrective actions; and perform emergency notifications.

The ERF is staffed in accordance with Section 6.0 of this Plan. The facility provides sufficient space to accommodate anticipated response personnel and provides 24-hour availability of the communications systems specified in Table 10-1.

Radiological conditions resulting from the design basis accidents specified in the ISFSI UFSAR do not inhibit staffing of the ERF.

12.2. Emergency Equipment and Supplies This section describes the monitoring instruments used to initiate emergency measures and provide continuing assessment of conditions throughout the course of an emergency.

Portable Radiation and Contamination Monitoring Instruments Portable radiation and contamination monitoring equipment necessary for monitoring the conditions of the FCS ISFSI are utilized and maintained by the Radiation Protection group, are available for emergency use.

Communications Systems Communications systems providing for 24-hour per day onsite and offsite communications capabilities are identified and tested as described in section 10.0 of this IOEP.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 Emergency Supplies Emergency equipment and supplies necessary to carry out the provisions of the IOEP and support procedures are maintained at the Emergency Response Facility. Appendix A, Emergency Equipment, Supplies and Reference Materials, lists required equipment, supplies and reference materials that are to be maintained in the ERF and other onsite locations.

Emergency equipment is inspected, inventoried and operationally checked at least quarterly and any time it is opened or used. Sufficient reserves are provided to replace items removed for calibration or repair.

Calibration of instruments is at intervals recommended by instrument suppliers or as required by Federal regulations.

12.3. First Aid Facilities First aid supplies and equipment are located at the ERF. Qualified personnel are available 24/7 to provide medical treatment referenced in Section 16.0.

Radiological wound monitoring onsite is performed using an appropriate instrument. If severity of the wound restricts decontamination by Radiation Protection personnel, the patient will be referred to offsite medical services or transported to an offsite medical facility for treatment and decontamination.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 ACCIDENT ASSESSMENT Effective response to a potential emergency situation requires assessment to determine the nature of the emergency and its actual and potential consequences. OPPD has established various methods to evaluate and monitor the effects of a potential emergency at the FCS ISFSI and has the appropriate means to ensure adequate assessment.

The assessment activities required to evaluate a particular emergency depend on the specific nature and classification of the emergency. The Emergency Director is responsible for the initial measurement of ISFSI dose rates after off-normal, natural phenomena, or accident events. The EALs identify the parameter value to determine the emergency condition. Classification of events is performed by the ISS/Emergency Director in accordance with the EAL scheme.

If the measured ISFSI dose rates exceed the EAL threshold, the Emergency Director ensures a radioactive release assessment in the vicinity of the affected storage module or cask is performed. After the assessment is complete, the Emergency Director contacts the Resource Manager to assist in interpreting the radioactive release assessment results.

Notification of the radiological release assessment is performed in accordance with Section 9.0.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 PROTECTIVE ACTIONS Protective actions for onsite personnel are provided for their health and safety.

Implementation guidelines for onsite protective actions are provided in EPIPs.

EPIPs provide for a range of protective actions to protect onsite personnel during security events.

14.1. Accountability The Emergency Director has the authority to initiate personnel accountability.

Accountability should be considered and used as a protective action whenever a risk to health or safety exists, or at the discretion of the Emergency Director. If personnel accountability is required, at the direction of the Emergency Director, all individuals at the facility (including employees without emergency assignments; visitors; and contractor personnel) shall be notified of the emergency and provided with instructions.

Accountability of all personnel inside the ISFSI Protected Area should be accomplished within 60 minutes after event declaration and maintained thereafter at the discretion of the Emergency Director. If personnel are not accounted for, the Emergency Director is notified and Security will initiate sweeps to locate the missing individual(s).

Non-ERO personnel, supplemental personnel, and visitors located outside of the ISFSI Protected Area will be directed to report to an assembly area or exit the facility as appropriate. The Emergency Director is responsible for controlling access to the facility when the IOEP is activated.

Accountability may be modified or suspended if personnel safety could be jeopardized by a security event or other event hazardous to personnel health and safety.

14.2. ISFSI Egress Control Methods All visitors and unnecessary contractors are evacuated from the ISFSI 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.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 RADIOLOGICAL EXPOSURE CONTROL The means for controlling radiological exposures, during an emergency, are established for emergency workers. Controls for emergency radiological exposures shall include exposure guidelines consistent with the Environmental Protection Agencys (EPA)

Emergency Worker and Lifesaving Activity Protective Action Guides (PAGs).

15.1. Exposure Guidelines During an emergency, doses above normal occupational radiation exposure limits may be authorized by the Emergency Director for activities such as controlling further exposures, preservation of equipment, or saving a life.

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, or assessment actions within applicable limits specified in 10 CFR Part 20. The Emergency Director is responsible for authorizing emergency response personnel to receive doses in excess of 10 CFR Part 20 limits. This authority cannot be delegated.

Table 15-1 provides exposure guidelines for such onsite emergency activities.

15.2. Radiation Protection Program The purpose of the Radiation Protection Program is to ensure that radiation doses received by personnel are kept as low as reasonably achievable (ALARA) and do not exceed the prescribed limits for both normal and emergency conditions. The established measures to provide this assurance include access control, personnel exposure monitoring, and contamination control.

Access Control During a declared emergency, radiological surveys of the ISFSI pad area will be performed to determine the extent of the radiological concern. The Emergency Director will ensure Radiological Control Areas (RCAs) and access controls are established to prevent personnel from entering the area. Recovery and corrective actions will be planned and executed in a manner to minimize personnel exposure.

Personnel Exposure Monitoring Personnel dosimeters are utilized to monitor the exposure of personnel during normal or emergency conditions. Adequate supplies of dosimeters are maintained for use during an emergency. Procedures describe the types of personnel dosimeter devices, the manner in which they are utilized, who is to wear them, and how they are to be cared for.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 Emergency worker dose records are maintained in accordance with Radiation Protection procedures.

Contamination Control Various contamination control measures are used. These include control measures and means for the decontamination of personnel, areas, and equipment. These activities are addressed in ISFSI procedures and are briefly described below.

All personnel are monitored for radioactive contamination prior to leaving the ISFSI. During normal or emergency conditions, contamination should be removed from any part of a persons body prior to leaving the RCA. All personnel decontamination, even during an emergency, will be performed under supervision of Radiation Protection and in accordance with established procedures.

Portable contamination monitoring instruments are available to frisk personnel for potential contamination.

Documentation of surveys, contamination, and decontamination activities shall be maintained in accordance with Radiation Protection procedures.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 TABLE 15-1 Response Worker Emergency Dose Limits Guideline Activity Condition All reasonably achievable 5 rem All occupational exposures actions have been taken to minimize dose.

Exceeding 5 rem unavoidable and all appropriate actions Protecting valuable property 10 rem(a) taken to reduce dose.

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

Exceeding 5 rem unavoidable Lifesaving or protection of and all actions taken to reduce 25 rem(b) large populations dose. Monitoring available to project or measure dose.

(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.

NOTE: Table 15-1 contains the guidelines for emergency exposure criteria, which is consistent with Table 2-2, Response Worker Guidelines, of the EPAs Protective Action Guide and Planning Guidance for Radiological Incidents.

NOTE: Dose limits listed in Table 15-1 are in addition to prior annual occupational dose received.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 MEDICAL AND HEALTH SUPPORT Arrangements are made for medical services for injured individuals and/or contaminated injured individuals. If immediate professional medical help is required, arrangements exist with local fire/rescue and medical services to assist in the transport and treatment of injured personnel, as described in Section 5.2. Assistance is requested via 911 utilizing the commercial telephone system.

OPPD ensures that persons providing medical services are adequately prepared to handle contaminated injured individuals through training, drills, and exercises.

16.1. Onsite First Aid Arrangements are made to treat injured individuals and/or contaminated injured individuals. FCS maintains on-shift personnel and equipment to provide first-aid for personnel at the ISFSI. Medical emergency supplies are located in various locations.

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

When the situation allows, contaminated injured personnel transported offsite will be accompanied by a person trained in radiological monitoring and decontamination.

Preservation of life is paramount over contamination controls.

16.3. Offsite Medical Support Agreements are in place with the Blair Hospital and UNMC 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. Offsite medical assistance is requested via 911 utilizing the commercial telephone system.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 EMERGENCY TERMINATION AND RECOVERY General plans have been established that describe the termination and the recovery from declared emergencies at the FCS ISFSI.

17.1. Emergency Termination and Notification Termination of a declared emergency is the responsibility of the Emergency Director. The Emergency Director is also responsible for providing notification of the emergency termination and initiation of recovery operations to the NRC, State of Nebraska, local agencies, and the OPPD/FCS Emergency Response Organization.

At the discretion of the Emergency Director, FCS may enter recovery operations and the ISFSI could be returned to a stable condition before terminating the emergency.

17.2. Recovery Operations Upon termination of an emergency, or at the discretion of the Emergency Director, the ERF transitions into the recovery phase. The recovery organization will be based on the normal FCS ISFSI organization. The senior management position directs the recovery organization and is responsible for:

Ensuring FCS ISFSI is maintained in a safe condition; Managing onsite Recovery activities during the initial Recovery phase; Keeping OPPD support apprised of FCS ISFSI activities and requirements.

The remainder of the recovery is accomplished using the normal and emergency organizations as necessary to provide technical and radiological expertise in order to return to normal operations.

ISFSI recovery activities shall be in accordance with the ISFSI Technical Specifications and other licensee documents. During ISFSI recovery, the radiation exposure limits of 10 CFR Part 20 shall apply.

If, during recovery operations, an emergency situation occurs, recovery efforts will be suspended until the emergency condition is resolved. The Emergency Director will re-evaluate FCS ISFSI conditions prior to resuming recovery.

The Recovery operations will be terminated by the senior management position directing the recovery organization after the FCS ISFSI is returned to a stable condition.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 EXERCISES AND DRILLS Emergency Preparedness is maintained at FCS through the following:

Conducting and evaluating periodic drills and exercises Training and periodic retraining of personnel involved in emergency response Reviewing and updating plans and implementing procedures Maintaining emergency facilities and equipment Periodic exercises are conducted to evaluate major portions of FCSs emergency response capabilities. Periodic drills are conducted to develop and maintain key skills.

Deficiencies, as a result of exercises or drills, are identified and corrected.

An exercise tests the execution of the overall plant emergency preparedness and the integration of this preparedness. A drill is a supervised instruction period aimed at testing, developing, and maintaining skills in a particular response function. A summary of exercises and drills, including the associated elements for each, is outlined below.

18.1. Emergency Plan Exercises and Drills FCS ISFSI conducts a biennial exercise to test the adequacy of timing and content of implementing procedures and methods; to test emergency equipment and communication networks; and to ensure that emergency personnel are familiar with their duties. FCS offers the following offsite organizations the opportunity to participate to the extent assistance would be expected during an emergency declaration. However, participation is not required.

State of Nebraska Blair Volunteer Fire Department Fort Calhoun Volunteer Fire Department Blair Hospital University of Nebraska Medical Center (UNMC)

LLEAs At least one drill involving a combination of some of the principal functional areas of emergency response shall be conducted in the interval between biennial exercises for the purpose of testing, developing, and maintaining the proficiency of emergency responders.

Exercise and Drill scenarios will include, at a minimum, the following:

The basic objective(s) of the exercise/drill The date(s), time period, place(s), and participating organizations A time schedule of real and simulated initiating events A narrative summary describing the conduct of the drill 33

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 18.2. Equipment and Proficiency Drills/Tests Drills are conducted for the purpose of training, developing, and maintaining the proficiency of emergency responders. Additionally, drills may be used to test and evaluate the adequacy of the ERF, equipment, procedures, communication channels, actions of emergency response personnel, and coordination between OROs and the ISFSI.

Communications Drills/Tests To ensure that emergency communications systems described in Section 10.0 of this plan are operable, communications tests are conducted as outlined below.

1. To test the capability to notify the State of Nebraska utilizing the commercial telephone system, the capability is functionally tested monthly. This drill will include the aspect of the receiving party understanding the content of the message.

2. To test the capability to communicate with the NRC, ENS is functionally tested monthly.

3. Portable radios, as detailed in Section 10.0, are used on a frequent basis, therefore periodic testing of the radio system is not necessary:

Performance of the Communication Drills satisfies the testing requirements specified in Section 10.0.

Augmentation Capability Drills An unannounced, off-shift, Augmentation Capability Drill shall be conducted annually. These drills shall involve implementation of the ERO callout system procedure and documentation of the estimated response time for each responder. This drill shall serve to demonstrate the capability to augment the Emergency Director after an emergency declaration.

Radiological Monitoring Drills Radiological monitoring drills are conducted annually. These drills demonstrate the ability to perform radiological survey and assessment and can be performed separately or as part of an Emergency Plan exercise or drill.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 Medical Emergency Drills To evaluate the training of the ISFSIs medical response personnel, a medical drill is conducted annually involving a simulated contaminated injured individual and may also contain provisions for participation by ambulance services and hospitals. This drill can be performed separately or as part of an annual exercise or drill.

18.3. Critiques and Evaluation Critiques are used to evaluate the performance of participating personnel and the adequacy of the ERF, equipment, and procedures. The ability of emergency response personnel to self-evaluate weaknesses and identify areas for improvement is the key to successful exercise or drill conduct.

Exercise and drill performance objectives are evaluated against measurable demonstration criteria. As soon as possible following the conclusion of each exercise or drill, a critique, including participants and evaluators, is conducted to evaluate the ability of the ERO to implement the IOEP and associated procedures. Deficiencies identified during exercises or drills are entered into the corrective actions program.

A written report is prepared following an exercise or drill involving the evaluation of designated objectives. The report evaluates and documents the ability of the ERO to respond to a simulated emergency situation. The report will also contain reference to corrective action and recommendations resulting from the exercise or drill.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 EMERGENCY RESPONSE TRAINING Emergency response training is provided to those who may be called on to assist in an emergency at the FCS ISFSI. All personnel at the FCS ISFSI who fill required positions in the ERO will take part in a training program to ensure adequate preparedness to assist in an emergency situation. OROs that may be called upon for emergency assistance will also be invited to participate in appropriate training programs.

19.1. Emergency Response Personnel Training Requirements for emergency preparedness training are specified in the Emergency Response Training Program outlined in this section. This program identifies the level and the depth to which individuals are to be trained. The Emergency Response Training Program is based on position-specific responsibilities as defined in the IOEP. Emergency response personnel in the following categories receive initial training and annual retraining:

ISFSI Shift Supervisors/Emergency Directors and Resource Managers The ISS/Emergency Directors and Resource Managers shall have training conducted such that proficiency is maintained on the topics listed below. These subjects shall be covered as a minimum on an annual basis.

EAL classification Offsite notification procedures ERO activation Dose rate meter operation Radioactive release assessment Emergency exposure control Protective actions for onsite personnel ISFSI DBAs Review of applicable drill and exercise-identified deficiencies and Human Performance Concerns Personnel available during declared emergencies who may be called upon to perform emergency response activities as an extension of their normal duties receive duty-specific training. Additional emergency preparedness training is provided as part of annual access training.

Medical Response Personnel (On-Shift)

Personnel assigned the responsibility for responding to a medical emergency at FCS receive the American Red Cross Standard First Aid Training Program, or equivalent. To maintain qualifications in 36

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 accordance with the American Red Cross, CPR and First Aid Training are given once every two years.

Radiation Monitoring Personnel Initial and annual retraining for radiation monitoring personnel consists of the following topics:

Use of Radiation Protection procedures Use of emergency survey equipment Communications Field surveys Role of radiological assessment in an ISFSI emergency Monitoring of radioactive releases Protective actions for onsite personnel Review of drill and exercise-identified deficiencies and Human Performance concerns Personnel Badged for Unescorted Access Personnel who are badged for unescorted access receive access training annually. Information pertaining to their safety and the safety of visitors under escort during a classified emergency is included in this training.

Access training shall include the following emergency preparedness topics:

Basic Emergency Plan and implementing preparedness topics Emergency classification levels Call out of personnel during an emergency Personnel accountability procedures 19.2. Emergency Response Support Organizations Training is offered annually to OROs that may be requested to provide assistance in the event of an emergency at FCS (e.g., law enforcement, fire-fighting, rescue, medical services, transport of injured, etc.). The training shall be structured to meet the needs of that organization with respect to the nature of their support. Training topics such as event notification, site access procedures, basic radiation protection and interface activities between the ORO and FCS are included in the training.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 19.3. Annual Emergency Action Level Training Annually, the emergency classification system specified in Section 8.0 and the EALs are reviewed with the authorities of Nebraska.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW, AND DISTRIBUTION Responsibilities for IOEP development and review and for distribution of the IOEP are established and planners are properly trained.

20.1. Emergency Preparedness Responsibilities Overall Authority and Responsibility A member of FCS senior management has overall authority and responsibility for emergency response planning and implementation of the FCS IOEP. This responsibility includes ensuring that the emergency preparedness program is maintained and implemented as described in the IOEP, and applicable requirements and regulations are met.

Maintaining the IOEP A FCS ISFSI position will be designated the responsibility for maintaining an adequate knowledge of regulations, planning techniques, and the latest applications of emergency equipment and supplies. The position is responsible for the following tasks:

Maintaining and updating this IOEP and associated procedures Ensuring exercise and drill commitments stated in this IOEP are met Ensuring material readiness of the ERF Overseeing the Emergency Preparedness Training Program Maintaining Emergency Preparedness interfaces with OROs Performing and documenting appropriate evaluations of the Emergency Preparedness program and classified emergency events The individual assigned the duties of maintaining the IOEP shall maintain an adequate knowledge of regulations, planning techniques, and the latest applications of emergency equipment and supplies. Training for these individuals includes 10 CFR 50.54(q) and 72.44(f) Evaluation Qualification.

Audits Independent audits of the Emergency Preparedness program meeting the requirements of 10 CFR 50.54(t) will be performed. All aspects of emergency preparedness, including exercise documentation, capabilities, procedures, and interfaces with state and local governments are audited.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 20.2. Review and Updating of the IOEP The IOEP, the associated EPIPs, and the ISFSI EAL Technical Bases Manual are reviewed at least annually, and updated as needed. Any needed changes shall be incorporated in the IOEP, ISFSI EAL Technical Bases Manual, and appropriate EPIPs. Proposed activities that may impact the IOEP must be evaluated per 10 CFR 50.54(q). The review shall encompass the need for changes based upon the following:

Written critiques and evaluations of drills and exercises Changes in the organizational structure Changes in the functions and capabilities of supporting agencies Changes in Federal or State regulations Modifications to the ISFSI or surrounding site which would affect emergency planning Recommendations or agreement changes received from other organizations Emergency Telephone Directory Names and telephone numbers of the ERO and supporting offsite agencies shall be reviewed at least quarterly and updated as necessary.

Letters of Agreement Written agreements with outside support organizations and government agencies are evaluated biennially to determine if these agreements are still valid. If agreements are not valid, then they are updated and renewed with the applicable organization. This agreement review is documented.

20.3. Training The assigned Emergency Preparedness position shall assist management in coordinating and/or providing emergency planning -related training. The training described in Section 19.0 shall be properly coordinated to ensure adequate qualification, training, and retraining of personnel.

20.4. Maintenance and Inventory of Emergency Equipment and Supplies Specific emergency response equipment and reference materials are listed in Appendix A. The items listed in Appendix A are inspected, inventoried, and operationally checked quarterly and after each use. Sufficient reserves are maintained to replace those which are removed for calibration or repair.

Equipment in these inventories is checked and calibrated in accordance with approved procedures.

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FCS ISFSI ONLY EMERGENCY PLAN Revision 0 APPENDIX A EMERGENCY EQUIPMENT, SUPPLIES, AND REFERENCE MATERIALS 41

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 Appendix A EMERGENCY EQUIPMENT, SUPPLIES AND REFERENCE MATERIALS EMERGENCY RESPONSE FACILITY Procedures / Reference Materials ISFSI Only Emergency Plan ISFSI EAL Technical Bases Document Emergency Telephone Directory EPIPs Equipment Portable radiation monitoring instrument Portable emergency lighting Medical emergency response kit ONSITE LOCATIONS Equipment / Supplies Portable radiation and contamination monitoring instruments Contamination control supplies Decontamination control supplies Protective clothing Dosimeters Radiological postings and barricades First Aid Kits 42

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 APPENDIX B CROSS-REFERENCE IOEP SECTION TO PLANNING STANDARDS/REQUIREMENTS/CRITERIA AND EPIPS 43

FCS ISFSI ONLY EMERGENCY PLAN Revision 0 Appendix B TABLE B-1 CROSS-REFERENCE IOEP SECTION TO PLANNING STANDARDS/REQUIREMENTS/CRITERIA AND EPIPS Planning NUREG-0654, Implementing Planning FCS IOEP Standard Section II Procedure Requirement Section(s) (10 CFR Evaluation (Appendix E.IV)**

50.47)** Criteria 5.0 (b)(1) A.1, 2, 4, 7 A To Be Determined (TBD) 6.0 (b)(2) A.1, 2, 4; C.1 B TBD 7.0 (b)(3) A.6, 7 C TBD 8.0 (b)(4) B.1, 2; C.1, 2 D TBD A.6, 7; C.1; D.1, 3; TBD 9.0 (b)(5) E E

10.0 (b)(6) C.1; D.1, 3; E F TBD 11.0 (b)(7) Exempt G TBD 12.0 (b)(8) E; G H TBD 13.0 (b)(9) A.4; B.1; C.2; E I TBD 14.0 (b)(10) C.1; E J TBD 15.0 (b)(11) E K TBD 16.0 (b)(12) A.6, 7; E L TBD 17.0 (b)(13) H M TBD 18.0 (b)(14) E9; F N TBD 19.0 (b)(15) F O TBD 20.0 (b)(16) G P TBD

• • as exempted 44

FCS ISFSI ONLY EMERGENCY PLAN Revision 0

SUMMARY

OF CHANGES Page/Section Change Reason and References This is a major revision to the Emergency Plan which supports the transition to an Independent Spent Fuel Storage Installation (ISFSI) Only Transition to an ISFSI Emergency Plan (IOEP). The IOEP describes the Only Emergency Plan stations plan for responding to emergencies that may arise at the FCS ISFSI facility.

Major changes made throughout the Plan include the following:

• Removal of terms/definitions/abbreviations and references that are no longer applicable

• Adding new applicable references.

• Changed the organizational titles to reflect the ISFSI organization titles.

• Complete reorganization of the Emergency Response Organization including removal of the Technical Coordinator, Radiation Protection Coordinator, Radiation Protection Technician, and NCO positions.

Adding the Resource Manager position.

Revise the requirement to perform accountability in the facility.

• Deleted information that is no longer applicable based on the transfer of all spent fuel to the ISFSI facility.

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OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION DOCKET NUMBER 50-285 / LICENSE NUMBER DPR-40 ATTACHMENT 4 ISFSI EMERGENCY ACTION LEVEL TECHNICAL BASES DOCUMENT

Omaha Public Power District Fort Calhoun Station Independent Spent Fuel Storage Installation Emergency Action Level Technical Bases

TABLE OF CONTENTS 1.0 PURPOSE ....................................................................................................................... 1

2.0 REFERENCES

................................................................................................................ 1 3.0 ACRONYMS & DEFINITIONS ........................................................................................ 2 4.0 ATTACHMENTS ............................................................................................................. 4 ATTACHMENTS Page ATTACHMENT 1 EMERGENCY ACTION LEVEL TECHNICAL BASES 4 Table A-1 Recognition Category Initiating Condition Matrix 6 PD-HU1 Security (Unusual Event) 7 PD-HA1 Security (Alert) 8 PD-HU3 Judgment (Unusual Event) 9 PD-HA3 Judgment (Alert) 10 E-HU1 ISFSI Malfunction (Unusual Event) 13 ATTACHMENT 2 EMERGENCY CLASSIFICATION TABLE 13 Fort Calhoun Station ISFSI EAL Technical Bases Page i

1.0 PURPOSE This document provides the detailed set of Emergency Action Levels (EALs) applicable to the Fort Calhoun Station (FCS) Independent Spent Fuel Storage Installation (ISFSI) and the associated technical bases. The EALs have been developed utilizing the structure of the EAL development methodology provided in NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 6 (NEI 99-01). All recommendations for changes to this document or associated implementing procedures are reviewed in accordance with the requirements of 10 CFR 50.54(q).

This information provided in this document should be used to facilitate review of the FCS EALs, provide historical documentation for future reference, and serve as a resource for training.

Personnel responsible for implementation of the ISFSI Only Emergency Plan and the ISFSI Emergency Action Level scheme may use the information provided in this document as a technical reference in support of EAL interpretation.

The expectation is that emergency classifications are to be made as soon as conditions are present and recognizable for the classification. Use of this document for assistance is not intended to delay the emergency classification.

2.0 REFERENCES

2.1 NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors 2.2 FCS-I-EP-1, ISFSI Only Emergency Plan 2.3 NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73 2.4 NUREG-1536, Standard Review Plan for Spent Fuel Dry Storage Systems at a General License Facility 2.5 NEI 03-12, Template for Security Plan, Training and Qualification, Safeguards Contingency Plan, and ISFSI Security Program Fort Calhoun Station ISFSI EAL Technical Bases Page 1

3.0 ACRONYMS & DEFINITIONS Acronyms CFR ................................................................................................. Code of Federal Regulations EAL .........................................................................................................Emergency Action Level ECL..............................................................................................Emergency Classification Level EPA ......................................................................................... Environmental Protection Agency GTCC ........................................................................................................ Greater Than Class C ISFSI........................................................................ Independent Spent Fuel Storage Installation IC .....................................................................................................................Initiating Condition mRem ........................................................................................... milli-Roentgen Equivalent Man NEI.......................................................................................................... Nuclear Energy Institute NRC ........................................................................................... Nuclear Regulatory Commission ORO ........................................................................................... Off-site Response Organization PAG ......................................................................................................... Protective Action Guide PD.............................................................................................................. Permanently Defueled rem ...................................................................................................... Roentgen Equivalent Man Definitions Selected terms used in Initiating Condition (IC) and EAL statements are set in all capital letters (e.g., ALL CAPS). These words are defined terms that have specific meanings as used in this document. The definitions of these terms are provided below.

ACCOUNTABILITY - A discretionary protective action taken for all persons onsite (within the ISFSI PROTECTED AREA) that involves the gathering of personnel into pre-designated areas and subsequent verification that the location of all personnel is known.

ALERT: Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the ISFSI. Any releases are expected to be limited to small fractions of the Environmental Protection Agency (EPA) Protection Action Guideline (PAG) exposure levels.

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

CREDIBLE SECURITY THREAT - A threat to the ISFSI confirmed and validated by the security force per procedures or received over the Emergency Notification System (ENS) from the NRC.

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

EMERGENCY CLASSIFICATION LEVEL (ECL): One of a set of names or titles established by the Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to (1) potential or actual effects or consequences, and (2) resulting onsite and offsite Fort Calhoun Station ISFSI EAL Technical Bases Page 2

response actions. The ECLs, in ascending order of severity, are NOTIFICATION OF UNUSUAL EVENT (UNUSUAL EVENT) and ALERT.

HOSTILE ACTION - An act toward the ISFSI or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end.

This includes, but is not necessarily limited to, attack by air, land, or water using guns, explosives, projectiles, vehicles or devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts are not part of a concerted attack on the ISFSI. Violent acts between individuals in the owner controlled area do not meet this definition.

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

INITIATING CONDITION (IC) - An event or condition that aligns with the definition of one of the two emergency classification levels by virtue of the potential or actual effects or consequences.

PROTECTED AREA: That area within the perimeter of the security fence.

SECURITY CONDITION: Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the ISFSI.

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

Fort Calhoun Station ISFSI EAL Technical Bases Page 3

4.0 ATTACHMENTS ATTACHMENT 1 EMERGENCY ACTION LEVEL TECHNICAL BASES ATTACHMENT 2 EMERGENCY CLASSIFICATION TABLES Fort Calhoun Station ISFSI EAL Technical Bases Page 4

Attachment 1 EMERGENCY ACTION LEVEL TECHNICAL BASES Fort Calhoun Station ISFSI EAL Technical Bases Page 5

Table A-1: Recognition Category Initiating Condition Matrix UNUSUAL EVENT ALERT PD-HU1 Confirmed SECURITY CONDITION, PD-HA1 HOSTILE ACTION is occurring or or threat, at the independent spent fuel has occurred.

storage installation (ISFSI).

(Page 8)

(Page 7)

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

(Page 9) (Page 10)

E-HU1: Damage to a loaded cask CONFINEMENT BOUNDARY.

(Page 11)

Fort Calhoun Station ISFSI EAL Technical Bases Page 6

PD-HU1 EMERGENCY CLASSIFICATION LEVEL:

UNUSUAL EVENT INITIATING CONDITION:

Confirmed SECURITY CONDITION, or threat, at the independent spent storage installation (ISFSI).

EMERGENCY ACTION LEVEL (EAL): (1 or 2)

1. A SECURITY CONDITION as reported by the security force and impacting the ISFSI.

2. Notification of a credible security threat directed at the ISFSI.

Basis:

This IC addresses events that pose a threat to facility personnel or spent fuel, and thus represent a potential degradation in the level of facility safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR 73.71 or 10 CFR 50.72.

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

Timely and accurate communication between the security force and the ISFSI Shift Supervisor/Emergency Director is essential for proper classification of a security-related event.

Classification of these events will initiate appropriate threat-related notifications to site personnel and Offsite Response Organizations (OROs).

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

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

EAL #2 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with Security procedures.

SECURITY CONDITION: Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the ISFSI.

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

Basis

Reference:

1. FCS ISFSI Security Plan Fort Calhoun Station ISFSI EAL Technical Bases Page 7

PD-HA1 EMERGENCY CLASSIFICATION LEVEL:

ALERT INITIATING CONDITION:

HOSTILE ACTION is occurring or has occurred.

EMERGENCY ACTION LEVEL (EAL):

1. A HOSTILE ACTION is occurring or has occurred as reported by the security force.

Basis:

This IC addresses the occurrence of a HOSTILE ACTION.

Timely and accurate communication between the security force and the ISFSI Shift Supervisor/Emergency Director is essential for proper classification of a security-related event.

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

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

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

Basis

Reference:

1. FCS ISFSI Security Plan Fort Calhoun Station ISFSI EAL Technical Bases Page 8

PD-HU3 EMERGENCY CLASSIFICATION LEVEL:

UNUSUAL EVENT INITIATING CONDITION:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Unusual Event.

EMERGENCY ACTION LEVEL (EAL):

1. Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the facility or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of systems needed to maintain spent fuel cooling occurs.

Basis:

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

Basis

Reference:

1. NEI 99-01, Rev. 6, PD-HU3 Fort Calhoun Station ISFSI EAL Technical Bases Page 9

PD-HA3 EMERGENCY CLASSIFICATION LEVEL:

ALERT INITIATING CONDITION:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert.

EMERGENCY ACTION LEVEL (EAL):

1. Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the facility. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

Basis:

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

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

Basis

Reference:

1. NEI 99-01, Rev. 6, PD-HA3 Fort Calhoun Station ISFSI EAL Technical Bases Page 10

E-HU1 EMERGENCY CLASSIFICATION LEVEL:

UNUSUAL EVENT INITIATING CONDITION Damage to a loaded cask CONFINEMENT BOUNDARY.

EMERGENCY ACTION LEVEL (EAL): (1, 2, or 3)

1. Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an abnormal radiation reading of 800 mrem/hr (gamma + neutron) at front Bird Screen of the HSM

2. Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an abnormal radiation reading of 20 mrem/hr (gamma + neutron) on outer HSM Door.

3. Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an abnormal radiation reading of 10 mrem/hr (gamma + neutron) on End Shield Wall exterior NOTE: Radiation readings are taken at the locations prescribed by the Technical Specifications for the Standardized NUHOMS Horizontal Storage System (Amendment Number 15 to CoC 1004).

Basis:

This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage cask is sealed. The issues of concern are the creation of a potential or actual release path to the environment, degradation of one or more fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the cask or fuel from storage.

The existence of damage is determined by radiological survey. The radiation limits listed in the EAL reflect calculations based on NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, recommends using 2 times the site-specific cask specific technical specification radiation level as the EAL. The technical specification site specific radiation multiple of 2 times, is used here to distinguish between non-emergency and emergency conditions.

The emphasis for this classification is the degradation in the level of safety of the spent fuel cask and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the IC may be determined based on measurement of a dose rate at some distance from the cask.

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

As provided in the Transnuclear Standardized NUHOMS System Technical Specifications Amendment 15 to CoC 1004, Section 5.4.1, HSM or HSM-H Dose Rate Evaluation Program, as calculated in FC08574, Fort Calhoun Data Specific Radiological Assessment, contain radiation dose levels for the DSC that should not be exceeded based while it is stored in the HSM. Keeping in line with NEl guidance that a UNUSAL EVENT warranted for radiation conditions at a level of Fort Calhoun Station ISFSI EAL Technical Bases Page 11

twice the Technical Specification value, the values chosen for EAL E-HU1 represent these values.

The Note in the EAL provides guidance on where the radiation readings are to be taken when evaluating this EAL.

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

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

Basis

References:

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

2. Amendment 15 to CoC 1004 Technical Specifications for the Standardized NUHOMS Horizontal Storage Module System

3. FC08574, Fort Calhoun Data Specific Radiological Assessment Fort Calhoun Station ISFSI EAL Technical Bases Page 12

Attachment 2 Emergency Classification Table ALERT UNUSUAL EVENT PD-HA1 HOSTILE ACTION is occurring or has occurred. PD-HU1 Confirmed SECURITY CONDITION, or threat, at the independent spent storage installation (ISFSI).

EMERGENCY ACTION LEVEL (EAL): EMERGENCY ACTION LEVEL (EAL): (1 or 2)

SECURITY 1. A HOSTILE ACTION is occurring or has occurred as reported by the security force.

1. A SECURITY CONDITION as reported by the security force and impacting the ISFSI.

OR

2. Notification of a credible security threat directed at the ISFSI.

PD-HA3 Other Conditions exist which in the judgment of the PD-HU3 Other Conditions exist which in the judgment of the emergency director warrant declaration of an Alert. emergency director warrant declaration of an Unusual Event.

EMERGENCY ACTION LEVEL (EAL): EMERGENCY ACTION LEVEL (EAL):

JUDGMENT 1. Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a

1. Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve an potential degradation of the level of safety of the ISFSI or indicate a actual or potential substantial degradation of the level of safety of the security threat to facility protection has been initiated. No release of ISFSI. Any releases are expected to be limited to small fractions of the radioactive material requiring offsite response or monitoring are expected EPA Protective Action Guideline exposure levels.

unless further degradation of systems important to safety occurs.

E-HU1 Damage to a loaded cask CONFINEMENT BOUNDARY.

EMERGENCY ACTION LEVEL (EAL): (1,2, or 3)

Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an abnormal radiation reading of; ISFSI 1. 800 mrem/hr at front Bird Screen of the HSM OR

2. 20 mrem/hr on outer HSM Door.

OR

3. 10 mrem/hr on End Shield Wall exterior Fort Calhoun Station IC/EAL Identifier Emergency Action Level Matrix

1. 1. -###.# - Examples (E-HU1.1) or (E-HU1.2)

Fort Calhoun Station ISFSI EAL Technical Bases Page 13

LIC-19-0021 Page 1 ATTACHMENT 4 DOCUMENT - REMOVAL OF EMERGENCY NOTIFICATION TO THE STATE OF IOWA OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION. UNIT NO. 1 DOCKET NO. 50-285

Fields of Opportunities STATE OF IOWA KIM REYNOLDS IOWA DEPARTMENT OF HOMELAND SECURI1Y GOVERNOR AND EMERGENCY MANAGEMENT V. JOYCE FLINN, HOMELAND SECURITY ADVISOR ADAM GREGG AND EMERGENCY MANAGEMENT DIRECTOR LT. GOVERNOR January 14, 2019 Tim Uehling Senior Director FCS Decommissioning Omaha Public Power District 961 0 Power Lane Blair, NE 68008

Dear Mr. Uehling,

When Omaha Public Power District's (OPPD) Fort Calhoun Station (FCS) implemented its Permanently Defueled Emergency Plan (PDEP) in 2018, the need for offsite emergency response plans was significantly reduced because the offsite radiological consequences of postulated accidents at FCS became substantially lower.

In 2018, OPPD submitted a request to the Nuclear Regulatory Commission (NRC) fm approval of a prutial site release which will remove all prope1ty located in the State of Iowa from the FCS license.

In 2020, OPPD is expected to complete the movement of all its spent fuel to its Independent Spent Fuel Storage Installation (ISFSI) facility and implement an ISFSI-only Emergency Plan.

Once implemented, the FCS ISFSI-only Emergency Plan will not require a pre-planned emergency response from any jurisdictions located in Iowa. As a result, the State of Iowa will no longer have a need to be included in any planning activities or notifications for radiological emergencies associated with FCS and therefore request to be excluded from the FCS ISFSI-only Emergency Plan when it is submitted to the NRC for approval.

Should you have any questions concerning this request, please contact Jacob Nicholson of my staff at 515-323-4337 or jacob.nicholson@iowa.gov r~~ly, .~~

V Jo~rm Director 7900 HICKMAN ROAD I SUITE 500 I WINDSOR HEIGHTS, IOWA 50324/515-725-3231 h1tp://WNW .homelandsecurtty.iowa.gov