NEI 99-01, Kewaunee, Attachment 2 to 13-495A - Comparison Matrix for Permanently Defueled Eals, Based Upon Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels, Revision 6

Kewaunee, Attachment 2 to 13-495A - Comparison Matrix for Permanently Defueled Eals, Based Upon Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels, Revision 6

ML14029A055
Person / Time
Site:	Kewaunee
Issue date:	01/16/2014
From:	Dominion Energy Kewaunee
To:	Office of Nuclear Reactor Regulation
References
13-495A, NEI 99-01, Rev 6
Download: ML14029A055 (33)

Text

Serial No. 13-495A ATTACHMENT 2 LICENSE AMENDMENT REQUEST 257: PERMANENTLY DEFUELED EMERGENCY PLAN AND EMERGENCY ACTION LEVEL SCHEME COMPARISON MATRIX FOR PERMANENTLY DEFUELED EALS BASED UPON NUCLEAR ENERGY INSTITUTE (NEI) 99-01,"METHODOLOGY FOR DEVELOPMENT OF EMERGENCY ACTION LEVELS," REVISION 6 KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No. 13-495A Attachment 2 Page 1 of 32 COMPARISON MATRIX FOR PERMANENTLY DEFUELED EALS BASED UPON NUCLEAR ENERGY INSTITUTE (NEI) 99-01,"METHODOLOGY FOR DEVELOPMENT OF EMERGENCY ACTION LEVELS," REVISION 6 The discussion below provides a description of the Kewaunee Power Station (KPS)Permanently Defueled Emergency Action Level (EAL) Technical Basis Document (provided as Enclosure 3 to this submittal) and provides a comparison of the EAL matrix against the corresponding information contained in NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors," Revision 6.Description of KPS Permanently Defueled EAL Technical Basis Document 1. Purpose The purpose section was taken from Emergency Action Level Technical Bases Document, Revision 10. Differences between the proposed permanently defueled EALs and those in NEI 99-01 Revision 6 are discussed below." The reference to NEI 99-01 was changed from Rev 4 to Rev 6., Information was added to include the Recognition Category "PD" due to KPS becoming a permanently defueled facility.2. Discussion This section was developed from NEI 99-01, Revision 6, Section 1, "Regulatory Background." Differences between the proposed EAL Technical Basis Document and NEI 99-01 are discussed below." NEI 99-01, Section 1.1, "Operating Reactors," was excluded as it pertains to operating reactors.

KPS has permanently ceased operation." NEI 99-01, Section 1.4, "NRC Order EA-12-051," was excluded.

KPS is a permanently defueled facility and has therefore requested rescission of NRC Order EA-12-051 by letter dated August 23, 2013." NEI 99-01, Section 1.5, "Applicability to Advanced and Small Modular Reactor Designs," was excluded as this section does not apply to KPS." Added statement of applicability that only certain EAL/ICs will be required after all the fuel stored in the spent fuel pool is transferred to the ISFSI.

Serial No. 13-495A Attachment 2 Page 2 of 32 3. Key Terminology Used This section was developed from NEI 99-01, Section 2, "Key Terminology Used in NEI 99-01." Differences in this section are discussed below.* Removed references to Site Area Emergency and General Emergency throughout the section. EALs have been developed using NEI 99-01, Section 8, for ISFSI and Appendix C for Permanently Defueled Station ICs/EALs.Emergency classification levels only include NOUE and Alert.* In NEI 99-01, Section 2.2, "Initiating Condition (IC)," removed the references to RCS leakage and fission product barriers.

KPS has permanently ceased operation.

The RCS and Containment have been abandoned and are not considered fission product barriers.* Removed NEI 99-01, Section 2.4, "Fission Product Barrier Threshold," for reasons mentioned previously.

4. Guidance on Making Emergency Classification This section was developed from NEI 99-01, Section 5, "Guidance on Making Emergency Classifications".

Differences in this section are discussed below." In Section 4.1 (NEI 99-01, Section 5.1), reference to fission product barrier thresholds were removed as the RCS and Containment have been abandoned and no longer serve as fission product barriers.* In Section 4.1 (NEI 99-01, Section 5.1), the second paragraph of NEI 99-01 was removed that referenced declaring an emergency within 15 minutes. It is no longer possible for the radiological consequences of design basis accidents or other credible events at KPS to exceed the limits of the EPA Protective Action Guidelines at the exclusion area boundary (EAB). Therefore, offsite emergency response plans and public notification are no longer necessary.

DEK will continue to make notifications to the State of Wisconsin and to the local county (Kewaunee).

The timeliness goal will be to make notification to the State and county within 60 minutes of declaration of an event. The radiological consequences resulting from the only remaining events (e.g., fuel handling accident) are below the Environmental Protection Agency (EPA) Protective Action Guides (PAGs) exposure levels at the site boundary, as detailed in the EPA's "Protective Action Guide and Planning Guidance for Radiological Incidents," Draft for Interim Use and Public Comment dated March 2013 (PAG Manual). As such, a 15 minute notification requirement is unnecessarily restrictive.

Sixty minutes provides a reasonable amount of time to provide notification to state and local governmental agencies since there is no need for the State to implement any protective actions. This notification timeliness is also consistent with the notification requirement to the NRC Operations Center, contained in 10 CFR 50.72(a)(1)(i), for the declaration of an emergency class.

Serial No. 13-495A Attachment 2 Page 3 of 32" In Section 4.2 (NEI 99-01, Section 5.2), reference to Operating Mode Applicability was removed because Operating Modes are not applicable to a permanently defueled facility.* Since Operating Modes no longer apply to a permanently defueled facility, NEI 99-01, Section 5.4 was not added to the KPS document." In Section 4.3, removed references to two units as KPS is a single unit site.* In Section 4.4 (NEI 99-01, Section 5.5), the word "levels" in the last sentence was changed to "level" as there is only one higher emergency classification level above a UE." In Section 4.5 (NEI 99-01, Section 5.6), references to SAE and GE were removed. Since it is no longer possible for the radiological consequences of design basis accidents or other credible events at KPS to exceed the limits of the EPA Protective Action Guidelines at the EAB, Site Area Emergency and General Emergency are no longer credible emergency classifications.

• In Section 4.6 (NEI 99-01, Section 5.7) removed references to an operating plant type of short lived event (reactor trip) and replaced with verbiage applicable to a permanently defueled plant." In Section 4.7 (NEI 99-01, Section 5.8) removed the illustrative example as the auxiliary feedwater system example is no longer a credible example at KPS. The reference to the 15 minute classification was also removed as discussed above.5. References

• This section was added. No corresponding section is provided in NEI 99-01.NEI 99-01 Sections Not Included The following sections of NEI 99-01, Revision 6 (which contain EAL development guidance), were not included and references made to these sections were also removed: " Section 3, "Design of the NEI 99-01 Emergency Classification Scheme"" Section 4, "Site-Specific Scheme Development Guidance" The following NEI 99-01 sections were completely removed from the KPS EAL matrix as these do not apply to a permanently defueled facility:* Section 6, "Abnormal Rad Levels/Radiological Effluent ICs/EALs"* Section 7, "Cold Shutdown/Refueling System Malfunction ICs/EALs"" Section 9, "Fission Product Barrier ICs/EALs"* Section 10, "Hazards and Other Conditions Affecting Plant Safety ICs/EALs"" Section 11, "System Malfunction ICs/EALs."

Serial No. 13-495A Attachment 2 Page 4 of 32 Appendix A, "Independent Spent Fuel Storage Installation"* Appendix A of the KPS EAL Technical Basis Document incorporates Section 8 of NEI 99-01. Changes to E-HU1 are provided in the table below.Appendix B, "Hazards and Other Conditions Affecting Plant Safety"" Appendix B provides the Permanently Defueled Station ICs/EALs and incorporates Appendix C of NEI 99-01." References to Operating Modes were removed from Table PD-1.Appendix C, "Definitions"" Appendix C, incorporates NEI 99-01, Appendix B." References to SAE, GE, and fission product barrier were removed as discussed above." The terms containment closure, faulted, and unisolable were removed from the list of definitions as they are not used in the permanently defueled ICs/EALs." Added specific definitions for Owner Controlled Area (OCA) and Protected Area." Revised NORMAL LEVELS by adding "or since the last survey" to the definition." Added definition for Vehicle Barrier System (VBS) which is applicable for Initiating Conditions PD-HU1 and PD-HAl.Appendix D, "Acronyms and Definitions"" Appendix D incorporates NEI 99-01, Appendix A." The list incorporates only those acronyms used in the KPS EAL Technical Basis Document.

Serial No. 13-495A Attachment 2 Page 5 of 32 NEI 99-01, Rev 6, Section 8- ISFSI ICs/EALs Proposed EAL Matrix for KPS Comparison E-HU1 E-HU1

• Use of Unusual Event (UE) instead of Notification of Unusual Event (NOUE) -use is consistent with ECL: Notification of Unusual Event ECL: Unusual Event present EAL matrix and agrees in meaning and intent with NEI 99-01, Rev 6.Initiating Condition:

Damage to a loaded cask Initiating Condition:

Damage to a loaded cask

• Removed reference to Operating Mode as they do CONFINEMENT BOUNDARY.

CONFINEMENT BOUNDARY.

not apply in a permanently defueled condition.

Operating Mode Applicability:

All Example Emergency Action Levels: Emergency Action Levels: E-HU1.1

• Removed "Example" from Emergency Action Levels and changed numbering of the EALs.(1) Damage to a loaded cask E-HU1.1 Damage to a loaded cask

• Removed "on the surface of the spent fuel cask".CONFINEMENT BOUNDARY as indicated CONFINEMENT BOUNDARY as Surveys are performed on the transfer cask and the by an on-contact radiation reading greater indicated by a radiation reading greater Horizontal Storage Module (HSM) and not directly than (2 times the site-specific cask specific than two times the ISFSI Technical on the spent fuel cask itself. Also, acceptance technical specification allowable radiation Specifications allowable levels, criteria for transfer cask readings are obtained at a level) on the surface of the spent fuel distance of three feet.cask.Basis: Basis: 9 Added an IC/EAL applicability statement to account for the end state of the plant.This IC addresses an event that results in damage This IC addresses an event that results in damage

• Removed reference to 'on contact' due to surveys to the CONFINEMENT BOUNDARY of a storage to the CONFINEMENT BOUNDARY of a storage not being on contact readings.cask containing spent fuel. It applies to irradiated cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at fuel that is licensed for dry storage beginning at the the point that the loaded storage cask is sealed. point that the loaded storage cask is sealed. The The issues of concern are the creation of a issues of concern are the creation of a potential or potential or actual release path to the environment, actual release path to the environment, degradation degradation of one or more fuel assemblies due to of one or more fuel assemblies due to environmental environmental factors, and configuration changes factors, and configuration changes which could which could cause challenges in removing the cause challenges in removing the cask or fuel from cask or fuel from storage. storage.The existence of "damage" is determined by The existence of "damage" is determined by radiological survey. The technical specification radiological survey. The technical specification multiple of "2 times", which is also used in multiple of "2 times" is used here to distinguish Serial No. 13-495A Attachment 2 Page 6 of 32 NEI 99-01, Rev 6, Section 8 -ISFSI ICs/EALs I Proposed EAL Matrix for KPS I Comparison Recognition Category A IC AU1, is used here to distinguish between non-emergency and emergency conditions.

The emphasis for this classification is the degradation in the level of safety of the spent fuel cask and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the fact that the "on-contact" dose rate limit is exceeded may be determined based on measurement of a dose rate at some distance from the cask.Security-related events for ISFSIs are covered under ICs HU1 and HAl.between non-emergency and emergency conditions.

The emphasis for this classification is the degradation in the level of safety of the spent fuel cask and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the fact that the dose rate limit is exceeded may be determined based on measurement of a dose rate at some distance from the cask.This IC/EAL applies while irradiated fuel is stored in the Spent Fuel Pool or loaded into dry storage casks.Security-related events for ISFSIs are covered under ICs PD-HU1 and PD-HAl.

Serial No. 13-495A Attachment 2 Page 7 of 32 NEI 99-01, Rev 6, Appendix C -Permanently Proposed EAL Matrix for KPS Comparison Defueled Station ICs/EALs PD-AU1 ECL: Notification of Unusual Event Initiating Condition:

Release of gaseous or liquid radioactivity greater than 2 times the (site-specific effluent release controlling document) limits for 60 minutes or longer.Operating Mode Applicability:

Not Applicable PD-AU1 ECL: Unusual Event Initiating Condition:

An uncontrolled release of gaseous or liquid radioactivity for 60 minutes or longer." Use of Unusual Event (UE) instead of Notification of Unusual Event (NOUE) -use is consistent with present EAL matrix and agrees in meaning and intent with NEI 99-01, Rev 6." Removed reference to Operating Mode as they do not apply in a permanently defueled condition." The IC is changed to 'An uncontrolled release of gaseous or liquid radioactivity for 60 minutes or longer'. KPS no longer has the source term or motive force from credible accidents that could cause a gaseous release that would exceed 2 x ODCM limits. Therefore this IC does not directly apply to KPS as written in the NEI guidance for gaseous releases.

The only remaining potential unplanned gaseous release of consequence would be caused by damage to spent fuel in the Spent Fuel Pool (SFP), and the subsequent release of the noble gas radionuclide Kr-85. Any releases associated with fuel damage caused by credible fuel handling accidents would be monitored by R-13 and R-14, the Auxiliary Building Ventilation stack radiation monitors, or could be detected using manual grab sampling as a backup. The offsite dose consequence due to a gaseous release caused by a credible fuel handling accident is negligible.

Therefore, using the NEI guidance of 2 x ODCM limits for unplanned gaseous releases is not practicable for this IC at KPS. Using an IC worded to reflect the condition of an uncontrolled release of gaseous or liquid radioactivity for 60 minutes or longer more accurately implements the NEI guidance for an Unusual Event at KPS and is indicative of a potential degradation of the level of safety of the plant.

Serial No. 13-495A Attachment 2 Page 8 of 32 NEI 99-01, Rev 6, Appendix C -Permanently Proposed EAL Matrix for KPS Comparison Defueled Station ICs/EALs Example Emergency Action Levels: (1 or 2)Notes:* The Emergency Director should declare the Unusual Event promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes.* If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.(1) Reading on ANY effluent radiation monitor greater than 2 times the alarm setpoint established by a current radioactivity discharge permit for 60 minutes or longer.(2) Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times the (site-specific effluent release controlling document) limits for 60 minutes or longer.Emergency Action Levels: PD-AU 1.1 or PD-AU 1.2 or PD-AU1.3 NOTE: The Emergency Director should declare the Unusual Event promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded.NOTE: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes.NOTE: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.PD-AU1.1 Reading on ANY effluent radiation monitor that is greater than the reading shown for 60 minutes or longer: " Removed "Example" from Emergency Action Levels and changed numbering of the EALs." EAL #1 (PD-AU1.1) is changed to "Reading on ANY effluent radiation monitor that is greater than the reading shown for 60 minutes or longer." KPS no longer has the source term or motive force to perform any planned gaseous batch releases from a non-continuous release pathway, or that is established by a gaseous radioactivity discharge permit, and could exceed ODCM limits.Therefore, this part of the EAL does not directly apply to KPS for planned gaseous releases.

The only remaining potential unplanned gaseous release of consequence would be caused by damage to spent fuel in the Spent Fuel Pool (SFP) and the subsequent release of the noble gas radionuclide Kr-85. Any releases associated with fuel damage caused by credible fuel handling accidents would be monitored by R-13 and R-14, the Auxiliary Building Ventilation stack radiation monitors.

The offsite dose consequence due to a gaseous release caused by a credible fuel handling accident is negligible.

Therefore, using a discharge permit or ODCM setpoint as the basis for the gaseous effluent radiation monitor readings is not practicable for this part of the EAL at KPS. Using RMS monitor readings based on an uncontrolled gaseous release for 60 minutes or longer and a credible fuel handling accident more accurately implements the NEI guidance for the gaseous release part of this EAL at KPS. This example EAL does still apply to liquid batch releases monitored by R-18 and continuous liquid releases monitored by R-20, therefore the NEI guidance will be used.EAL#2 (PD-AU1.2 and PD-AU1.3) was divided into two EALs, one for gaseous releases (PD-Auxiliary Building R-13 Aux. Bldg. Vent Exhaust R-14 Aux. Bldg. Vent Exhaust Liquid Radwaste R-18 WD System Liquid R-20 Aux Bldg SW Return Action Value 4.OE+05 cpm 4.OE+05 cpm 2 x Discharge Permit Limit 2.OE+03 cpm PD-AU1.2 Confirmed sample analysis for a gaseous release indicates a concentration greater than 5.4E-03 VCi/cc for 60 minutes or longer PD-AU1.3 Confirmed analysis for a liquid effluent sample indicates a concentration or release rate greater than 2 times the j _________________________________________________ -I-Serial No. 13-495A Attachment 2 Page 9 of 32 NEI 99-01, Rev 6, Appendix C -Permanently Proposed EAL Matrix for KPS Comparison Defueled Station ICs/EALs ODCM limits for 60 minutes or longer. A1.2) and one for liquid releases (PD-AU1.3).

For PD-AU1.2, KPS no longer has the source term or motive force from a credible accident that could create a gaseous release that could exceed ODCM limits. Therefore, this part of the EAL does not directly apply to KPS. The only remaining potential gaseous release of consequence would be caused by damage to spent fuel in the Spent Fuel Pool (SFP) and the subsequent release of the noble gas radionuclide Kr-85. Any releases associated with fuel damage caused by credible fuel handling accidents could be detected by noble gas grab sampling and analysis.

The offsite dose consequence due to a gaseous release caused by a credible fuel handling accident is negligible.

Therefore, using ODCM limits for unplanned gaseous releases is not practicable for this part of the EAL at KPS.Using gas sample analysis results and a gaseous effluent release rate based on an uncontrolled gaseous release for 60 minutes or longer and a credible fuel handling accident more accurately implements the NEI guidance for the gaseous release part of this EAL at KPS. For PD-AU1.3, this EAL does still apply to the KPS source term and motive force for radioactive liquid releases therefore the NEI guidance will be used.Basis: Basis: The basis for PD-AU1 was changed to reflect the fact that KPS no longer has the source term or This IC addresses a potential decrease in the level This IC addresses a potential or actual decrease in motive force to perform any planned gaseous of safety of the plant as indicated by a low-level the level of safety of the plant as indicated by an batch releases from a non-continuous release radiological release that exceeds regulatory uncontrolled, low level radiological release for an pathway, or that is established by a gaseous commitments for an extended period of time (e.g., extended period of time. It includes any gaseous or radioactivity discharge permit, and could exceed an uncontrolled release).

It includes any gaseous or liquid radiological release, monitored or un- ODCM limits. Therefore, this part of the EAL liquid radiological release, monitored or un- monitored, including those for which a radioactivity does not directly apply to KPS for planned monitored, including those for which a radioactivity discharge permit is normally prepared.

gaseous releases.

The only remaining potential discharge permit is normally prepared.

unplanned gaseous release of consequence Serial No. 13-495A Attachment 2 Page 10 of 32 NEI 99-01, Rev 6, Appendix C -Permanently Proposed EAL Matrix for KPS Comparison Defueled Station ICs/EALs P Nuclear power plants incorporate design features intended to control the release of radioactive effluents to the environment.

Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases.

The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.Releases should not be prorated or averaged.

For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.EAL #1 -This EAL addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This EAL will typically be associated with planned batch releases from non-continuous release pathways (e.g., radwaste, With the station being permanently shut down for more than 100 days, the only radionuclide of any significance available to be released in gaseous form is the noble gas Kr-85. Kr-85 decays emitting a beta particle and low abundance gamma, and is therefore not a significant contributor to Total Effective Dose Equivalent (TEDE). The gaseous release portion of this IC (detected by either an effluent monitor or by sample analysis) is not based on any particular ODCM values of dose or dose rate but rather the radiological release that results from damage to, and uncontrolled release from, a fuel assembly.

The liquid release portion of this IC is based on an uncontrolled release that exceeds two times the radiation monitor discharge permit limit (R-18) or ODCM default setpoint value (R-20).KPS incorporates design features intended to control the release of radioactive effluents to the environment.

The occurrence of extended, uncontrolled radioactive releases to the environment is indicative of degradation in these features and/or controls.

For gaseous and liquid releases, these controls are located in the ODCM. Further, there are administrative controls established to prevent unintentional releases.Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Classification based on effluent monitor readings assumes that a release path to the environment is would be caused by damage to spent fuel in the Spent Fuel Pool (SFP) and the subsequent release of the noble gas radionuclide Kr-85. Any releases associated with fuel damage caused by credible fuel handling accidents would be monitored.

The offsite dose consequence due to a gaseous release caused by a credible fuel handling accident is negligible.

Therefore, using a discharge permit or ODCM setpoint as the basis for the gaseous effluent radiation monitor readings is not practicable for this part of the EAL at KPS. Using RMS monitor readings based on an uncontrolled gaseous release for 60 minutes or longer and a credible fuel handling accident more accurately implements the NEI guidance for the gaseous release part of this EAL at KPS. The proposed KPS IC and EALS meet the NEI 99-01 stated attribute for a NOUE: "A minor loss of control of radioactive materials or the ability to control radiation levels within the plant." The emphasis for this classification is that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant and that no releases of radioactive material requiring offsite response are expected unless further degradation of safety systems occurs.Added an IC/EAL applicability statement to account for the end state of the plant.

Serial No. 13-495A Attachment 2 Page 11 of 32 NEI 99-01, Rev 6, Appendix C -Permanently Proposed EAL Matrix for KPS Comparison Defueled Station ICs/EALs waste gas).EAL #2 -This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).Escalation of the emergency classification level would be via IC PD-AA1.established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.PD-AU1.2 and PD-AU1.3 addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys.Releases should not be prorated or averaged.

For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.Recording equipment can be used to determine the start of a release This IC/EAL applies only while irradiated fuel is stored in the Spent Fuel Pool or there is sufficient volume of radioactive liquid that, if released, could exceed two times the ODCM limits.Escalation of the emergency classification level would be via IC PD-AA1.

Serial No. 13-495A Attachment 2 Page 12 of 32 NEI 99-01, Rev 6, Appendix C -Permanently Proposed EAL Matrix for KPS Comparison Defueled Station ICs/EALs PD-AA1 PD-AA1

• Removed reference to Operating Mode as they do not apply in a permanently defueled condition.

ECL: Alert ECL: Alert

• Changed the IC to 'An uncontrolled release of gaseous or liquid radioactivity resulting in Initiating Condition:

Release of gaseous or liquid Initiating Condition:

An uncontrolled release of detectable levels at the site boundary'.

KPS no radioactivity resulting in offsite dose greater than 10 gaseous or liquid radioactivity resulting in detectable longer has the source term or motive force from a mrem TEDE or 50 mrem thyroid CDE. levels at the site boundary.

credible accident to create a gaseous release resulting in offsite dose greater than 10 mrem Operating Mode Applicability:

Not Applicable TEDE or 50 mrem thyroid CDE. Therefore, this IC does not directly apply to KPS as written in the NEI guidance for gaseous releases.

The only remaining potential gaseous release of consequence would be caused by damage to spent fuel in the Spent Fuel Pool (SFP) and the subsequent release of the noble gas radionuclide Kr-85. Any releases associated with fuel damage caused by credible fuel handling accidents would be monitored by R-13 and R-14, the Auxiliary Building Ventilation stack radiation monitors.

The offsite dose consequence due to a gaseous release caused by a credible fuel handling accident is negligible.

Therefore, using the IC dose values of 10 mrem TEDE and 50 mrem thyroid CDE is not practicable at KPS. Using an IC worded to reflect the condition of an uncontrolled release of gaseous or liquid radioactivity that results in detectable levels at the site boundary more accurately implements the NEI guidance for an Alert at KPS.Example Emergency Action Levels: (1 or 2 or 3 Emergency Action Levels: PD-AA1.1 or PD-AA1.2 9 Removed "Example" from Emergency Action or 4) or PD-AA1.3 Levels and changed numbering of the EALs.* For EAL#1 related to gaseous radiation monitors, Notes: NOTE: The Emergency Director should declare the KPS no longer has the source term or motive Alert promptly upon determining that the applicable force from a credible accident to create a gaseous* The Emergency Director should declare the time has been exceeded, or will likely be exceeded.

release resulting in offsite dose greater than 10 Alert promptly upon determining that the NOTE: If an ongoing release is detected and the mrem TEDE or 50 mrem thyroid CDE. Therefore, applicable time has been exceeded, or will likely release start time is unknown, assume that the this part of the EAL does not directly apply to be exceeded.

release duration has exceeded 15 minutes. KPS. The only remaining potential gaseous* If an ongoing release is detected and the NOTE: If the effluent flow past an effluent monitor is release of consequence would be caused by Serial No. 13-495A Attachment 2 Page 13 of 32 NEI 99-01, Rev 6, Appendix C -Permanently Proposed EAL Matrix for KPS Comparison Defueled Station ICs/EALs P release start time is unknown, assume that the release duration has exceeded 15 minutes.* If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.* The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

(1) Reading on ANY of the following radiation monitors greater than the reading shown for 15 minutes or longer: (site-specific monitor list and threshold values)(2) Dose assessment using actual meteorology indicates doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond (site-specific dose receptor point).(3) Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond (site-specific dose receptor point) for one hour of exposure.(4) Field survey results indicate EITHER of the following at or beyond (site-specific dose receptor point):* Closed window dose rates greater than 10 mR/hr expected to continue for 60 minutes or longer.known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.PD-AA1.1 Reading on ANY effluent radiation monitor that is greater than the reading shown for 15 minutes or longer: Auxiliary Buildinq Action Value R-13 Aux Building Vent Exhaust 4.OE+06 cpm R-14 Aux Building Vent Exhaust 4.OE+06 cpm Liquid Radwaste R-18 WD System Liquid R-20 Aux Bldg SW Return 50 x Discharge Permit Limit 5.OE+04 cpm PD-AA1.2 Confirmed sample analysis for a gaseous release indicates a concentration greater than 5.4E-2 pCi/cc for 15 minutes or longer.damage to spent fuel in the Spent Fuel Pool (SFP) and the subsequent release of the noble gas radionuclide Kr-85. Any releases associated with fuel damage caused by credible fuel handling accidents would be monitored by R-13 and R-14, the Auxiliary Building Ventilation stack radiation monitors.

The offsite dose consequence due to a gaseous release caused by a credible fuel handling accident is negligible.

Therefore, using the IC dose values of 10 mrem TEDE and 50 mrem thyroid CDE as the basis for the gaseous effluent radiation monitor readings is not practicable at KPS. Using RMS monitor readings based on an uncontrolled gaseous release caused by a credible fuel handling accident that results in detectable levels at the site boundary more accurately implements the NEI guidance for the gaseous release part of this EAL at KPS, and provides an appropriate escalation from PD-AU1." For EAL#1 related to liquid effluent radiation monitors, KPS does not have the source term from a credible event to create a liquid release resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE. Therefore, this part of the EAL does not directly apply to KPS.The current source term considered for liquid radioactive releases is comparable to what was previously used for this EAL (pre-defueling/

decommissioning).

Therefore, using RMS monitor readings that are 50x the ODCM limits more accurately implements the NEI guidance for the liquid release part of this EAL at KPS, and provides an appropriate escalation from PD-AU1." For EAL#2, KPS no longer has the source term or motive force from a credible accident to create a gaseous release resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE.Therefore, this EAL does not apply to KPS. The only remaining potential gaseous release of PD-AA1.3 Confirmed analysis of a liquid effluent sample indicates a concentration or release rate greater than 50 times the ODCM limit for 15 minutes or longer.

Serial No. 13-495A Attachment 2 Page 14 of 32 NEI 99-01, Rev 6, Appendix C -Permanently Proposed EAL Matrix for KPS Comparison Defueled Station ICs/EALs e Analyses of field survey samples indicate thyroid CDE greater than 50 mrem for one hour of inhalation.

consequence would be caused by damage to spent fuel in the Spent Fuel Pool (SFP) and the subsequent release of the noble gas radionuclide Kr-85. Kr-85 decays by emitting a beta particle and low abundance gamma, thus the TEDE and thyroid CDE at or beyond the site boundary produced from a credible accident is negligible.

Since the offsite dose consequence due to a gaseous release caused by a credible accident is negligible, using this example EAL is not practicable at KPS." For EAL#3, KPS does not have the source term from a credible event to create a liquid release resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE. Therefore, this part of the EAL does not directly apply to KPS.The current source term considered for liquid radioactive releases is comparable to what was previously used for this EAL (pre-defueling/

decommissioning).

Therefore, using liquid sample analysis results that are 50x the ODCM limits for 15 minutes or longer more accurately implements the NEI guidance for the liquid release part of this EAL at KPS, and provides an appropriate escalation from PD-AU1." For EAL#4, KPS no longer has the source term or motive force from a credible accident to create a gaseous effluent release resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE. Therefore, this EAL does not directly apply to KPS. The only remaining potential gaseous release of consequence would be caused by damage to spent fuel in the Spent Fuel Pool (SFP) and the subsequent release of the noble gas radionuclide Kr-85. Kr-85 decays by emitting a beta particle and low abundance gamma.Therefore, using the EAL field survey values of 10 mR/hr closed window dose rate for 60 minutes or longer and 50 mrem thyroid CDE for one hour of Serial No. 13-495A Attachment 2 Page 15 of 32 NEI 99-01, Rev 6, Appendix C -Permanently Proposed EAL Matrix for KPS Comparison Defueled Station ICs/EALs inhalation at or beyond the site boundary is not practicable at KPS. Using gas sample analysis results and a gaseous effluent release rate caused by a credible fuel handling accident that results in detectable levels at the site boundary for 15 minutes or longer more accurately implements the NEI guidance for the gaseous release part of this EAL at KPS, and provides an appropriate escalation from PD-AU1.Basis: Basis:

• The proposed KPS IC and EALS meet the NEI 99-01 stated attribute for an ALERT, as modified This IC addresses a release of gaseous or liquid This IC addresses a release of gaseous or liquid herein: "A significant loss of control of radioactivity that results in projected or actual offsite radioactivity that results in detectable levels offsite radioactive materials resulting in an inability to doses greater than or equal to 1% of the EPA that are below 1% of the EPA Protective Action control radiation levels within the plant, or a Protective Action Guides (PAGs). It includes both Guides (PAGs). It includes both monitored and release of radioactive materials to the monitored and un-monitored releases.

Releases of unmonitored releases.

Releases of this magnitude environment that could result in doses that are a this magnitude represent an actual or potential represent an actual or potential substantial small fraction of an EPA PAG at or beyond the substantial degradation of the level of safety of the degradation of the level of safety of the plant as site boundary." The emphasis for this plant as indicated by a radiological release that indicated by a radiological release that could classification is that events are in progress or significantly exceeds regulatory limits (e.g., a potentially exceed regulatory limits (e.g., a significant have occurred which involve an actual or potential significant uncontrolled release).

uncontrolled release).

substantial degradation of the level of safety of the plant and that any releases of radioactive Radiological effluent EALs are also included to With the station being permanently shut down for material are expected to be limited to small provide a basis for classifying events and conditions more than 100 days, the only radionuclide of any fractions of the EPA PAGs.that cannot be readily or appropriately classified on significance available to be released in gaseous form ° Added an IC/EAL applicability statement to the basis of plant conditions alone. The inclusion of is the noble gas Kr-85. Kr-85 decays emitting a low account for the end state of the plant.both plant condition and radiological effluent EALs abundance gamma, and is therefore not a significant more fully addresses the spectrum of possible contributor to Total Effective Dose Equivalent accident events and conditions. (TEDE). The gaseous release portion of this IC (detected by either an effluent monitor or by sample The TEDE dose is set at 1% of the EPA PAG of analysis) is not based on any particular ODCM 1,000 mrem while the 50 mrem thyroid CDE was values of dose or dose rate but rather the established in consideration of the 1:5 ratio of the radiological release that results from damage to, and EPA PAG for TEDE and thyroid CDE. uncontrolled release from, multiple fuel assemblies.

The liquid release- portion of this IC is based on an Classification based on effluent monitor readings uncontrolled release that exceeds fifty times the assumes that a release path to the environment is radiation monitor discharge permit limit (R-18) or established.

If the effluent flow past an effluent ODCM default setpoint value (R-20).monitor is known to have stopped due to actions to Serial No. 13-495A Attachment 2 Page 16 of 32 NEI 99-01, Rev 6, Appendix C -Permanently Proposed EAL Matrix for KPS Comparison Defueled Station ICs/EALs I P isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.KPS incorporates design features intended to control the release of radioactive effluents to the environment.

The occurrence of extended, uncontrolled radioactive releases to the environment is indicative of degradation in these features and/or controls.

For gaseous and liquid releases, these controls are located in the ODCM. Further, there are administrative controls established to prevent unintentional releases.Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.PD-AA1.2 and PD-AA1.3 addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys.Recording equipment can be used to determine the start time of a release.This IC/EAL applies only while irradiated fuel is stored in the Spent Fuel Pool or there is sufficient volume of radioactive liquid that, if released, could exceed fifty times the ODCM limits.

Serial No. 13-495A Attachment 2 Page 17 of 32 NEI 99-01, Rev 6, Appendix C -Permanently Proposed EAL Matrix for KPS Comparison Defueled Station ICs/EALs PD-AU2 PD-AU2

• Use of Unusual Event (UE) instead of Notification of Unusual Event (NOUE) -use is consistent with ECL: Notification of Unusual Event ECL: Unusual Event present EAL matrix and agrees in meaning and intent with NEI 99-01, Rev 6.Initiating Condition:

UNPLANNED rise in plant Initiating Condition:

UNPLANNED rise in plant 9 Removed reference to Operating Mode as they radiation levels, radiation levels. do not apply in a permanently defueled condition.

Operating Mode Applicability:

Not Applicable Example Emergency Action Levels: (1 or 2) Emergency Action Levels: PD-AU2.1 or

• Removed "Example" from Emergency Action PD-AU2.2 Levels and changed numbering of the EALs.(1) a. UNPLANNED water level drop in the spent

• Added plant specific radiation monitors and SFP fuel pool as indicated by ANY of the PD-AU2.1 a. UNPLANNED water level drop in the level alarms.following:

spent fuel pool as indicated by EITHER of the following: (site-specific level indications).

• Spent Fuel Pool low water level alarm setpoint (3 ft. 4 in. below floor)AND

• Visual observation

b. UNPLANNED rise in area radiation levels AND as indicated by ANY of the following radiation monitors.

b. UNPLANNED rise in area radiation levels as indicated by EITHER of the (site-specific list of area radiation following radiation monitors.monitors).

• R-5 Fuel Handling Area ALERT Alarm (2) Area radiation monitor reading or survey result 9 R-10 New Fuel Pit Area ALERT indicates an UNPLANNED rise of 25 mR/hr Alarm over NORMAL LEVELS.PD-AU2.2 Area radiation monitor reading or survey result indicates an UNPLANNED rise of 25 mR/hr over NORMAL LEVELS.

Serial No. 13-495A Attachment 2 Page 18 of 32 NEI 99-01, Rev 6, Appendix C -Permanently Proposed EAL Matrix for KPS Comparison Defueled Station ICs/EALs P Basis: Basis:* Added an IC/EAL applicability statement to account for the end state of the plant.This IC addresses elevated plant radiation levels caused by a decrease in water level above irradiated (spent) fuel or other UNPLANNED events.The increased radiation levels are indicative of a minor loss in the ability to control radiation levels within the plant or radioactive materials.

Either condition is a potential degradation in the level of safety of the plant.A water level decrease will be primarily determined by indications from available level instrumentation.

Other sources of level indications may include reports from plant personnel or video camera observations (if available).

A significant drop in the water level may also cause an increase in the radiation levels of adjacent areas that can be detected by monitors in those locations.

The effects of planned evolutions should be considered.

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

Escalation of the emergency classification level would be via IC PD-AA1 or PD-AA2.This IC addresses elevated plant radiation levels caused by a decrease in water level above irradiated (spent) fuel or other UNPLANNED events. The increased radiation levels are indicative of a minor loss in the ability to control radiation levels within the plant or radioactive materials.

Either condition is a potential degradation in the level of safety of the plant.A water level decrease will be primarily determined by indications from available level instrumentation.

Other sources of level indications may include reports from plant personnel or video camera observations (if available).

A significant drop in the water level may also cause an increase in the radiation levels of adjacent areas that can be detected by monitors in those locations.

The effects of planned evolutions should be considered.

Note that PD-AU2.1 is applicable only in cases where the elevated reading is due to an UNPLANNED water level drop. PD-AU2.2 excludes radiation level increases that result from planned activities such as use of radiographic sources and movement of radioactive waste materials.

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

Serial No. 13-495A Attachment 2 Page 19 of 32 NEI 99-01, Rev 6, Appendix C -Permanently Proposed EAL Matrix for KPS Comparison Defueled Station ICs/EALs PD-AA2 PD-AA2

• Removed reference to Operating Mode as they do not apply in a permanently defueled condition.

ECL: Alert ECL: Alert Initiating Condition:

UNPLANNED rise in plant Initiating Condition:

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

Operating Mode Applicability:

Not Applicable Example Emergency Action Levels: (1 or 2) Emergency Action Levels: PD-AA2.1 or PD-AA2.2

• Removed "Example" from Emergency Action Levels and changed numbering of the EALs.(1) UNPLANNED dose rate greater than 15 PD-AA2.1 UNPLANNED dose rate greater than 15

• EAL 2 was reworded to ensure the connection of mR/hr in ANY of the following areas mrem/hr in ANY of the following areas UNPLANNED was to the word "rise" and not to requiring continuous occupancy to maintain requiring continuous occupancy to the phrase "Area Radiation Monitor or survey control of radioactive material or operation maintain control of radioactive material results".of systems needed to maintain spent fuel or operation of systems needed to

• For PD-AA2.2, removed reference to "Area integrity:

maintain spent fuel integrity:

Radiation Monitor readings".

At KPS there are no area radiation monitors in the Spent Fuel Pool (site-specific area list)

• R-1 Control Room Area Pump area and this is the area that contains equipment that must be operated manually to (2) UNPLANNED Area Radiation Monitor PD-AA2.2 Survey results that indicate an maintain spent fuel integrity.

readings or survey results indicate a rise by UNPLANNED rise of 100 mrem/hr over 100 mR/hr over NORMAL LEVELS that NORMAL LEVELS that impedes access impedes access to ANY of the following to ANY of the following areas needed to areas needed to maintain control of maintain control of radioactive material radioactive material or operation of systems or operation of systems needed to needed to maintain spent fuel integrity, maintain spent fuel integrity.(site-specific area list)

• Spent Fuel Pool Pump Area (survey)Basis: Basis:

• Added an IC/EAL applicability statement to account for the end state of the plant.This IC addresses increased radiation levels that This IC addresses increased radiation levels that impede necessary access to areas containing impede necessary access to areas containing equipment that must be operated manually or that equipment that must be operated manually or that Serial No. 13-495A Attachment 2 Page 20 of 32 NEI 99-01, Rev 6, Appendix C -Permanently Proposed EAL Matrix for KPS Comparison Defueled Station ICs/EALs requires local monitoring, in order to maintain systems needed to maintain spent fuel integrity.

As used here, 'impede' includes hindering or interfering, provided that the interference or delay is sufficient to significantly threaten necessary plant access. It is this impaired access that results in the actual or potential substantial degradation of the level of safety of the plant.This IC does not apply to anticipated temporary increases due to planned events.requires local monitoring, in order to maintain systems needed to maintain spent fuel integrity.

As used here, 'impede' includes hindering or interfering, provided that the interference or delay is sufficient to significantly threaten necessary plant access. It is this impaired access that results in the actual or potential substantial degradation of the level of safety of the plant.This IC/EAL applies only while irradiated fuel is stored in the Spent Fuel Pool.This IC does not apply to anticipated temporary increases due to planned events.

Serial No. 13-495A Attachment 2 Page 21 of 32 NEI 99-01, Rev 6, Appendix C -Permanently Proposed EAL Matrix for KPS Comparison Defueled Station ICs/EALs PD-SU1 PD-SU1

• Use of Unusual Event (UE) instead of Notification of Unusual Event (NOUE) -use is consistent with ECL: Notification of Unusual Event ECL: Unusual Event present EAL matrix and agrees in meaning and intent with NEI 99-01, Rev 6.Initiating Condition:

UNPLANNED spent fuel pool Initiating Condition:

UNPLANNED spent fuel pool

• Removed reference to Operating Mode as they temperature rise. temperature rise. do not apply in a permanently defueled condition.

Operating Mode Applicability:

Not Applicable Example Emergency Action Levels: Emergency Action Levels:

• Removed "Example" from Emergency Action Levels and changed numbering of the EALs.(1) UNPLANNED spent fuel pool temperature PD-SU1.1 UNPLANNED spent fuel pool e Added specific temperature information.

rise to greater than (site-specific OF). temperature rise to greater than 150 0 F.Basis: Basis: 9 Added an IC/EAL applicability statement to account for the end state of the plant.This IC addresses a condition that is a precursor to This IC addresses a condition that is a precursor to a a more serious event and represents a potential more serious event and represents a potential degradation in the level of safety of the plant. If degradation in the level of safety of the plant. If uncorrected, boiling in the pool will occur, and result uncorrected, boiling in the pool will occur, and result in a loss of pool level and increased radiation levels, in a loss of pool level and increased radiation levels.Escalation of the emergency classification level Escalation of the emergency classification level would be via IC PD-AA1 or PD-AA2. would be via IC PD-AA1 or PD-AA2.This IC/EAL applies only while irradiated fuel is stored in the Spent Fuel Pool.

Serial No. 13-495A Attachment 2 Page 22 of 32 NEI 99-01, Rev 6, Appendix C -Permanently Proposed EAL Matrix for KPS Comparison Defueled Station ICs/EALs PD-HU1 PD-HU1

• Use of Unusual Event (UE) instead of Notification of Unusual Event (NOUE) -use is consistent with ECL: Notification of Unusual Event ECL: Unusual Event present EAL matrix and agrees in meaning and intent with NEI 99-01, Rev 6.Initiating Condition:

Confirmed SECURITY Initiating Condition:

Confirmed SECURITY 9 Removed reference to Operating Mode as they CONDITION or threat. CONDITION or threat. do not apply in a permanently defueled condition.

Operating Mode Applicability:

Not Applicable Example Emergency Action Levels: (1 or 2 or 3) Emergency Action Levels: PD-HU1.1 or PD- Removed "Example" from Emergency Action HU1.2 or PD-HU1.3 Levels and changed numbering of the EALs.(1) A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by PD-HUI.1 A SECURITY CONDITION that does not the (site-specific security shift supervision), involve a HOSTILE ACTION as reported by Security Supervision.

(2) Notification of a credible security threat directed at the site. PD-HU1.2 Notification of a credible security threat directed at the site.(3) A validated notification from the NRC providing information of an aircraft threat. PD-HU1.3 A validated notification from the NRC providing information of an aircraft threat.Basis: Basis: e Added an IC/EAL applicability statement to account for the end state of the plant.This IC addresses events that pose a threat to plant This IC addresses events that pose a threat to plant e Reference to VBS boundary added to correspond personnel or the equipment necessary to maintain personnel or the equipment necessary to maintain to PD-HAI. Per NEI 99-01 rev 6: cooling of spent fuel, and thus represent a potential cooling of spent fuel, and thus represent a potential OWNER CONTROLLED AREA: Developer Note degradation in the level of plant safety. Security degradation in the level of plant safety. Security -This term is typically taken to mean the site events which do not meet one of these EALs are events which do not meet one of these EALs are property owned by, or otherwise under the control adequately addressed by the requirements of 10 adequately addressed by the requirements of 10 of, the licensee.

In some cases, it may be CFR § 73.71 or 10 CFR § 50.72. Security events CFR § 73.71 or 10 CFR § 50.72. Security events appropriate for a licensee to define a smaller area assessed as HOSTILE ACTIONS are classifiable within the VEHICLE BARRIER SYSTEM (VBS) with a perimeter closer to the plant Protected Area under IC PD-HAI. boundary that are assessed as HOSTILE ACTIONS perimeter.

are classifiable under IC PD-HAl.

• Based upon the reduced risk to the plant with KPS Timely and accurate communications between being in a permanently defueled condition, the Security Shift Supervision and the Control Room is Timely and accurate communications between VBS perimeter is the appropriate boundary.

Serial No. 13-495A Attachment 2 Page 23 of 32 NEI 99-01, Rev 6, Appendix C -Permanently Proposed EAL Matrix for KPS Comparison Defueled Station ICs/EALs essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to plant personnel and Offsite Response Organizations.

Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].EAL #1 references (site-specific security shift supervision) because these are the individuals trained to confirm that a security event is occurring or has occurred.

Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR § 2.39 information.

EAL #2 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with (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 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 Security Supervision and the Control Room is essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to plant personnel and Offsite Response Organizations.

Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].PD-HU1.1 references Security Supervision because these are the individuals trained to confirm that a security event is occurring or has occurred.

Training on security event confirmation and classification is controlled due to the nature of information that is controlled by Safeguards and 10 CFR § 2.390 (withholding from public disclosure) requirements.

PD-HU1.2 addresses the receipt of a credible security threat. The procedure to determine the credibility of a threat is considered security-sensitive information and therefore withheld from the EAL.Credible security threat includes a HOSTILE ACTION within the OWNER CONTROLLED AREA outside of the VBS boundary.PD-HU1.3 addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft.

The status and size of the plane may also be provided by NORAD through the NRC. The procedure to validate the threat is considered security-sensitive information and therefore withheld from the EAL.This IC/EAL applies while irradiated fuel is stored in Serial No. 13-495A Attachment 2 Page 24 of 32 NEI 99-01, Rev 6, Appendix C -Permanently Proposed EAL Matrix for KPS Comparison Defueled Station ICs/EALs concerning a specific threat or threat location, the Spent Fuel Pool or loaded into dry storage Security-sensitive information should be contained casks.in non-public documents such as the Security Plan.Escalation of the emergency classification level Escalation of the emergency classification level would be via IC PD-HAI.would be via IC PD-HAl.

Serial No. 13-495A Attachment 2 Page 25 of 32 NEI 99-01, Rev 6, Appendix C -Permanently Proposed EAL Matrix for KPS Comparison Defueled Station ICs/EALs PD-HA1 PD-HA1

• Removed reference to Operating Mode as they do not apply in a permanently defueled condition.

ECL: Alert ECL: Alert

• Changed "OWNER CONTROLLED AREA" to"VBS boundary".

Per NEI 99-01 rev 6: Initiating Condition:

HOSTILE ACTION within the Initiating Condition:

HOSTILE ACTION within the OWNER CONTROLLED AREA: Developer Note OWNER CONTROLLED AREA or airborne attack VBS boundary or airborne attack threat within 30 -This term is typically taken to mean the site threat within 30 minutes. minutes. property owned by, or otherwise under the control of, the licensee.

In some cases, it may be Operating Mode Applicability:

Not Applicable appropriate for a licensee to define a smaller area with a perimeter closer to the plant Protected Area perimeter.

Based upon the reduced risk to the plant with KPS being in a permanently defueled condition, the VBS perimeter is the appropriate boundary.Example Emergency Action Levels: (1 or 2) Emergency Action Levels: PD-HAI.1 or PD-

• Removed "Example" from Emergency Action HA1.2 Levels and changed numbering of the EALs.(1) A HOSTILE ACTION is occurring or has

• Changed "OWNER CONTROLLED AREA" to occurred within the OWNER CONTROLLED PD-HAI.1 A HOSTILE ACTION is occurring or has "VBS boundary" (per NEI 99-01 rev 6: AREA as reported by the (site-specific occurred within the VBS boundary as OWNER CONTROLLED AREA: Developer security shift supervision), reported by Security Supervision.

Note).Based upon the reduced risk to the plant with (2) A validated notification from NRC of an aircraft PD-HA1.2 A validated notification from NRC of an KPS being in a permanently defueled condition, attack threat within 30 minutes of the site. aircraft attack threat within 30 minutes of the VBS perimeter is the appropriate boundary.the site.Basis: Basis:

• Added an IC/EAL applicability statement to account for the end state of the plant.This IC addresses the occurrence of a HOSTILE This IC addresses the occurrence of a HOSTILE

• Changed the Initiating Condition and EAL ACTION within the OWNER CONTROLLED AREA ACTION within the VEHICLE BARRIER SYSTEM applicability from "OWNER CONTROLLED or notification of an aircraft attack threat. This event (VBS) boundary or notification of an aircraft attack AREA" to "VBS boundary".

Per NEI 99-01 rev 6: will require rapid response and assistance due to the threat. This event will require rapid response and OWNER CONTROLLED AREA: Developer Note possibility of the attack progressing to the assistance due to the possibility of the attack -This term is typically taken to mean the site PROTECTED AREA, or the need to prepare the progressing to the PROTECTED AREA, or the need property owned by, or otherwise under the control plant and staff for a potential aircraft impact. to prepare the plant and staff for a potential aircraft of, the licensee.

In some cases, it may be impact. appropriate for a licensee to define a smaller area Serial No. 13-495A Attachment 2 Page 26 of 32 NEI 99-01, Rev 6, Appendix C- Permanently Proposed EAL Matrix for KPS Comparison Defueled Station ICs/EALs Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness by the plant 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, allowing them to be better prepared should it be necessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.EAL #1 is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action directed against an ISFSI that is located within the OWNER CONTROLLED AREA.Timely and accurate communications between Security Supervision and the Control Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness by the plant 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, allowing them to be better prepared should it be necessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.PD-HA1.1 is applicable for any HOSTILE ACTION occurring, or that has occurred, in the VBS boundary.

This includes any action directed against an ISFSI that is located within the VBS boundary.

A HOSTILE ACTION within the OWNER with a perimeter closer to the plant Protected Area perimeter.

Based upon the reduced risk to the plant with KPS being in a permanently defueled condition, the VBS perimeter is the appropriate boundary.

Serial No. 13-495A Attachment 2 Page 27 of 32 NEI 99-01, Rev 6, Appendix C -Permanently Defueled Station ICs/EALs Proposed EAL Matrix for KPS Comparison 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 Headquarters Operations Officer (HOO)will communicate to the licensee if the threat involves an aircraft.

The status and size of the plane may be provided by NORAD through the NRC.In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC.The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.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.CONTROLLED AREA outside of the VBS boundary is considered a credible security threat and should be evaluated under EAL PD-HU1.2.PD-HA1.2 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 Offsite Response Organizations are in a heightened state of readiness.

The procedure to validate threat-related information is considered security-sensitive information and therefore is withheld from this IC.The NRC Headquarters Operations Officer (HOO)will communicate to the licensee if the threat involves an aircraft.

The status and size of the plane may be provided by NORAD through the NRC.In some cases, it may not be readily apparent if an aircraft impact within the VBS boundary was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.This IC/EAL applies while irradiated fuel is stored in the Spent Fuel Pool or loaded into dry storage casks.

Serial No. 13-495A Attachment 2 Page 28 of 32 NEI 99-01, Rev 6, Appendix C -Permanently Proposed EAL Matrix for KPS Comparison Defueled Station ICs/EALs PD-HU2 PD-HU2

• Use of Unusual Event (UE) instead of Notification of Unusual Event (NOUE) -use is consistent with ECL: Notification of Unusual Event ECL: Unusual Event present EAL matrix and agrees in meaning and intent with NEI 99-01, Rev 6.Initiating Condition:

Hazardous event affecting Initiating Condition:

Hazardous event affecting Removed reference to Operating Mode as they do SAFETY SYSTEM equipment necessary for spent SAFETY SYSTEM equipment necessary for spent not apply in a permanently defueled condition.

fuel cooling, fuel cooling.Operating Mode Applicability:

Not Applicable Example Emergency Action Levels: Emergency Action Levels: Removed "Example" from Emergency Action Levels and changed numbering of the EALs.(1) a. The occurrence of ANY of the PD-HU2.1 a. The occurrence of ANY of the Added Low Lake Level to the list of hazardous following hazardous events: following hazardous events: events. Low lake level is an IC that exists e Seismic event (earthquake) presently in the KPS EAL matrix and should* Seismic event (earthquake)

• Internal or external flooding event continue to be considered." Internal or external flooding event

• Low lake level According to NEI 99-01, Rev 6, developer notes" High winds or tornado strike e High winds or tornado strike for PD-HU2," nuclear power plant SAFETY" FIRE

• FIRE SYSTEMS are comprised of two or more separate" EXPLOSION e EXPLOSION and redundant trains of equipment in accordance" (site-specific hazards)

• Other events with similar hazard with site specific design criteria".

At KPS, the site" Other events with similar hazard characteristics as determined by specific design criteria for Spent Fuel Pool characteristics as determined by the the Shift Manager Cooling only specify a single train. Service Water Shift Manager System and Spent Fuel Pool Cooling are the AND systems necessary for cooling the spent fuel pool.AND The Spent Fuel Pool Cooling System consists of b. The event has damaged a SAFETY two half-capacity pumps, a heat exchanger, two b. The event has damaged at least one SYSTEM needed for spent fuel half-capacity filters, a demineralizer with pre- and train of a SAFETY SYSTEM needed for cooling, post-filters, and associated piping, valves, and spent fuel cooling, instrumentation.

The Service Water System AND consists of four pumps that supply water to the AND Spent Fuel Pool Cooling System through a ring c. The damaged SAFETY SYSTEM header formed by cross-connecting Train A and c. The damaged SAFETY SYSTEM train(s) cannot, or potentially cannot, perform Train B in the Aux Building and the Screenhouse.

cannot, or potentially cannot, perform its its design function based on EITHER: Although both systems contain redundant components, neither is considered to have Serial No. 13-495A Attachment 2 Page 29 of 32 NEI 99-01, Rev 6, Appendix C -Permanently Proposed EAL Matrix for KPS Comparison Defueled Station ICs/EALs design function based on EITHER:

• Indications of degraded separate and redundant trains. Therefore, the performance term "train" in PD-HU2.1b and PD-HU2.1c does" Indications of degraded performance e VISIBLE DAMAGE not apply." VISIBLE DAMAGE Basis: This IC addresses a hazardous event that causes damage to at least one train of a SAFETY SYSTEM needed for spent fuel cooling. The damage must be of sufficient magnitude that the system(s) train cannot, or potentially cannot, perform its design function.

This condition reduces the margin to a loss or potential loss of the fuel clad barrier, and therefore represents a potential degradation of the level of safety of the plant.For EAL 1 .c, the first bullet addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it will be readily available.

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

This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level could, depending upon the event, be based on any of the Alert ICs; PD-AA1, PD-AA2, PD-HA1 or PD-HA3.Basis: This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM needed for spent fuel cooling. At KPS, Service Water System and Spent Fuel Pool Cooling are the systems necessary for cooling the spent fuel pool. The damage must be of sufficient magnitude that the system(s) cannot, or potentially cannot, perform its design function.

This condition reduces the margin to a loss or potential loss of the fuel clad barrier, and therefore represents a potential degradation of the level of safety of the plant.For PD-HU2.1a, the "other' bullet is not intended to address component failures within the SAFETY SYSTEM such as pump bearing failures, electrical grounds or shorts in a pump, failure of valves, etc.Declaration of an event due to the failure of a SAFETY SYSTEM component would be based on PD-SU1.1.For PD-HU2.1c, the first bullet addresses damage to a SAFETY SYSTEM that is in service/operation since indications for it will be readily available.

For PD-HU2.1c, the second bullet addresses damage to a SAFETY SYSTEM that is not in service/operation or readily apparent through indications alone. Operators will make this determination based on the totality of available event and damage report information.

This is intended to* According to NEI 99-01, Rev 6, developer notes for PD-HU2," nuclear power plant SAFETY SYSTEMS are comprised of two or more separate and redundant trains of equipment in accordance with site specific design criteria".

At KPS, the site specific design criteria for Spent Fuel Pool Cooling only specify a single train. Service Water System and Spent Fuel Pool Cooling are the systems necessary for cooling the spent fuel pool.The Spent Fuel Pool Cooling System consists of two half-capacity pumps, a heat exchanger, two half-capacity filters, a demineralizer with pre- and post-filters, and associated piping, valves, and instrumentation.

The Service Water System consists of four pumps that supply water to the Spent Fuel Pool Cooling System through a ring header formed by cross-connecting Train A and Train B in the Aux Building and the Screenhouse.

Although both systems contain redundant components, neither is considered to have separate and redundant trains. Therefore the term "train" in PD-HU2.1b and PD-HU2.1c does not apply.* The intent of the last bullet in PD-HU2.1a is to consider similar hazards that may cause damage to a SAFETY SYSTEM and not intended to include component failures in a system. If a component fails, Spent Fuel Pool temperature will be effected and the SM/ED should consider declaration per PD-SU1 if it rises above 150'F." Added an IC/EAL applicability statement to account for the end state of the plant.

Serial No. 13-495A Attachment 2 Page 30 of 32 NEI 99-01, Rev 6, Appendix C -Permanently Proposed EAL Matrix for KPS Comparison Defueled Station ICs/EALs be a brief assessment not requiring lengthy analysis or quantification of the damage.This IC/EAL applies only while irradiated fuel is stored in the Spent Fuel Pool.Escalation of the emergency classification level could, depending upon the event, be based on any of the Alert ICs; PD-AA1, PD-AA2, PD-HA1 or PD-HA3.

Serial No. 13-495A Attachment 2 Page 31 of 32 NEI 99-01, Rev 6, Appendix C -Permanently Proposed EAL Matrix for KPS Comparison Defueled Station ICs/EALs PD-HU3 PD-HU3 = Use of Unusual Event (UE) instead of Notification of Unusual Event (NOUE) -use is consistent with ECL: Notification of Unusual Event ECL: Unusual Event present EAL matrix and agrees in meaning and intent with NEI 99-01, Rev 6.Initiating Condition:

Other conditions exist which Initiating Condition:

Other conditions exist which 9 Removed reference to Operating Mode as they in the judgment of the Emergency Director warrant in the judgment of the Emergency Director warrant do not apply in a permanently defueled condition.

declaration of a (NO)UE. declaration of a UE.Operating Mode Applicability:

Not Applicable Example Emergency Action Levels: Emergency Action Levels: e Removed "Example" from Emergency Action Levels and changed numbering of the EALs.(1) Other conditions exist which in the judgment PD-HU3.1 Other conditions exist which in the of the Emergency Director indicate that judgment of the Emergency Director events are in progress or have occurred indicate that events are in progress or which indicate a potential degradation of the have occurred which indicate a potential level of safety of the plant or indicate a degradation of the level of safety of the security threat to facility protection has been plant or indicate a security threat to initiated.

No releases of radioactive material facility protection has been initiated.

No requiring offsite response or monitoring are releases of radioactive material requiring expected unless further degradation of offsite response or monitoring are safety systems occurs. expected unless further degradation of safety systems occurs.Basis: Basis:

• Added an IC/EAL applicability statement to account for the end state of the plant.This IC addresses unanticipated conditions not This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant addressed explicitly elsewhere but that warrant declaration of an emergency because conditions declaration of an emergency because conditions exist which are believed by the Emergency Director exist which are believed by the Emergency Director to fall under the emergency classification level to fall under the emergency classification level description for a NOUE description for a UE This IC/EAL applies while irradiated fuel is stored in the Spent Fuel Pool or loaded into dry storage casks.

Serial No. 13-495A Attachment 2 Page 32 of 32 NEI 99-01, rev 6, Appendix C -Permanently Proposed EAL Matrix for KPS Comparison Defueled Station ICs/EALs PD-HA3 PD-HA3 ° Removed reference to Operating Mode as they do not apply in a permanently defueled condition.

ECL: Alert ECL: Alert Initiating Condition:

Other conditions exist which Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant in the judgment of the Emergency Director warrant declaration of an Alert. declaration of an Alert.Operating Mode Applicability:

Not Applicable Example Emergency Action Levels: Emergency Action Levels: Removed "Example" from Emergency Action Levels and changed numbering of the EALs.(1) Other conditions exist which in the judgment PD-HA3.1 Other conditions exist which in the of the Emergency Director indicate that judgment of the Emergency Director events are in progress or have occurred indicate that events are in progress or which involve an actual or potential have occurred which involve an actual or substantial degradation of the level of safety potential substantial degradation of the of the plant or a security event that involves level of safety of the plant or a security probable life threatening risk to site event that involves probable life personnel or damage to site equipment threatening risk to site personnel or because of HOSTILE ACTION. Any damage to site equipment because of releases are expected to be limited to small HOSTILE ACTION. Any releases are fractions of the EPA Protective Action expected to be limited to small fractions Guideline exposure levels, of the EPA Protective Action Guideline exposure levels.Basis: Basis: Added an IC/EAL applicability statement to account for the end state of the plant.This IC addresses unanticipated conditions not This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant addressed explicitly elsewhere but that warrant declaration of an emergency because conditions declaration of an emergency because conditions exist which are believed by the Emergency Director exist which are believed by the Emergency Director to fall under the emergency classification level to fall under the emergency classification level description for an Alert. description for an Alert.This IC/EAL applies while irradiated fuel is stored in the Spent Fuel Pool or loaded into dry storage casks