NG-20-0093, Supplement to License Amendment Request (TSCR-187): Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme

Supplement to License Amendment Request (TSCR-187): Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme

ML20303A073
Person / Time
Site:	Duane Arnold
Issue date:	10/29/2020
From:	Dean Curtland NextEra Energy Duane Arnold
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NG-20-0093
Download: ML20303A073 (35)

Text

NEXTeraM ENERGY~

DUANE ARNOLD October 29, 2020 NG-20-0093 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Duane Arnold Energy Center Docket No. 50-331 Renewed Facility Operating License No. DPR-49

Reference:

D. Curtland (NextEra Energy Duane Arnold, LLC) to USNRC, "License Amendment Request (TSCR-187): Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme," NG-20-0028, dated May 15, 2020 (ML20136A438)

Supplement to License Amendment Request (TSCR-187) : Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme In the referenced letter, NextEra Energy Duane Arnold, LLC (NEDA) submitted a request for an amendment to the license for the Duane Arnold Energy Center (DAEC).

The proposed amendment would revise the DAEC Emergency Plan and Emergency Action Level (EAL) scheme for the permanently defueled condition.

This supplement revises Section B, "Emergency Response Organization," of the Permanently Defueled Emergency Plan (PDEP), which was originally submitted as Attachment 1 of the Enclosure to the referenced letter. Specifically, the on-shift staffing of Non-Certified Operators is changed from one (1) to two (2) throughout. The enclosure to this letter replaces, in its entirety, Attachment 1 of the referenced letter.

In accordance with 10 CFR 50.91, a copy of this application with enclosure is being provided to the designated State of Iowa official.

This supplement does not impact the 10 CFR 50.92 evaluation of "No Significant Hazards Consideration" previously provided in the referenced application.

This letter contains no new or revised regulatory commitments.

If you have any questions or require additional information, please contact Michael Davis, Licensing Manager, at 319-851-7032.

NextEra Energy Duane Arnol d, LLC, 3277 DAEC Road, Palo , IA 52324

Document Control Desk NG-20-0093 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on October 29, 2020.

s~ddY Dean Curtland Site Director NextEra Energy Duane Arnold, LLC Enclosure cc: Regional Administrator, USNRC, Region Ill, Project Manager, USNRC, Duane Arnold Energy Center Resident Inspector, USNRC, Duane Arnold Energy Center State of Iowa

NEXTERA ENERGY DUANE ARNOLD, LLC DUANE ARNOLD ENERGY CENTER LICENSE AMENDMENT REQUEST (TSCR-187)

ATTACHMENT 1 PERMANENTLY DEFUELED EMERGENCY PLAN 32 pages follow

Table of Contents Introduction .............................................................................................................................................. 3 1.1 Overview of the Permanently Defueled Emergency Plan ..................................................... 3 1.2 Site Description ............................................................................................................................ 5 Section A Organizational Responsibility ....................................................................................... 5 Section B Emergency Response Organization ............................................................................ 6 1.1 Facility On-Shift Organization .................................................................................................... 6 1.2 Emergency Response Organization Augmentation ............................................................... 7 1.3. Offsite Organizations ................................................................................................................. 8 Section C Emergency Response Support and Resources ...................................................... 11 1.1 Support Provided by Local Organizations ............................................................................. 11 Section D Emergency Classification System ............................................................................. 11 1.1 Classification of Emergencies .................................................................................................. 11 1.2 Postulated Accidents ................................................................................................................. 12 1.3 Emergency Classification System Review ............................................................................. 13 Section E Notification Methods and Procedures ....................................................................... 13 1.1 Notification and Activation ........................................................................................................ 13 Section F Emergency Communications ...................................................................................... 14 1.1 DAEC Alarm System ................................................................................................................. 14 1.2 Communication Systems .......................................................................................................... 14 Section G Public lnformation ......................................................................................................... 15 Section H Emergency Facilities and Equipment... ..................................................................... 15 1.1 Control Room ............................................................................................................................. 16 1.2 Laboratory Facilities .................................................................................................................. 16 1.3 Emergency Equipment. ............................................................................................................. 16 1.4 Emergency Kits .......................................................................................................................... 17 Section I Accident Assessment .................................................................................................. 17 1.1 Radiological Assessment ......................................................................................................... 18 1.2 Corrective Actions ..................................................................................................................... 18 1.3 Dose Assessment. ..................................................................................................................... 18 Section J Protective Actions ......................................................................................................... 18 1.1 Accountability ........................................................................................................................ 18 1

1.2 Site Egress Control Methods .............................................................................................. 19 Section K Radiological Exposure Control ................................................................................... 19 1.1 Radiological Control Areas ................................................................................................. 19 1.2 Exposure Control .................................................................................................................. 19 1.3 Personnel Contamination Control ...................................................................................... 20 Section L Medical and Health Support ....................................................................................... 21 Section M Recovery ........................................................................................................................ 21 Section N Exercises and Drills ...................................................................................................... 22 1.1 Exercises ............................................................................................................................... 22 1.2 Drills ........................................................................................................................................ 22 1.3 Scenarios ............................................................................................................................... 23 1.4 Critique/Evaluation ............................................................................................................... 24 Section 0 Radiological Emergency Response Training ........................................................... 24 1.1 Emergency Response Training .......................................................................................... 24 1.2 Documentation of Training .................................................................................................. 25 Section P Responsibility for the Planning/Review and Distribution of Emergency Plans ... 25 1.1 Document Maintenance ...................................................................................................... 25 1.2 Inventory and Maintenance of Emergency Equipment................................................... 26 Appendix 1 - Cross Reference Table ............................................................................................... 27 Appendix 2 - Letters of Agreement ................................................................................................... 28 Appendix 3 - Permanently Defueled Emergency Plan Implementing Procedures .................... 29 Appendix 4 - Definitions and Acronyms ........................................................................................... 30 1.0 Definitions .............................................................................................................................. 30 2.0 Acronyms ............................................................................................................................... 31 2

Introduction The Permanently Defueled Emergency Plan (PDEP) describes the plan for responding to emergencies that may arise at The Duane Arnold Energy Center (DAEC), while in a permanently shut down and defueled configuration. DAEC has provided certification to the U.S.

Nuclear Regulatory Commission (NRC) required by 10 Code of Federal Regulation (CFR) 50.82(a)(1)(i) and (ii) that DAEC has permanently ceased power operations and that all fuel has been permanently removed from the reactor vessel. In this configuration, all irradiated fuel is stored in the Independent Spent Fuel Storage Installation (ISFSI) and in the Spent Fuel Pool (SFP). In this condition, no reactor operations can take place and the facility is prohibited from emplacement or retention of fuel in the reactor vessel. The PDEP adequately addresses the risks associated with DAEC's current conditions.

The analyses of the potential radiological impacts of postulated accidents in a permanently defueled condition indicates that any releases beyond the Site Boundary would be below the Environmental Protection Agency (EPA) Protective Action Guide (PAG) exposure levels, as detailed in the EPA's "Protective Action Guide and Planning Guidance for Radiological Incidents, "EPA-400/R-17/001 dated January 2017" (EPA PAG Manual). No remaining postulated accidents will result in radiological releases requiring offsite protective actions and the slow progression rate of beyond design basis accident scenarios indicate sufficient time is available to initiate appropriate mitigating actions to protect the health and safety of the public.

Therefore, the PDEP adequately addresses the risk associated with DAEC's permanently defueled condition and continues to provide adequate protection for plant personnel and the public. Exemptions from the applicable portions of 10 CFR 50.47(b), Appendix E to 10 CFR Part 50, and 10 CFR 50.4 7( c)(2) were previously approved by the NRC.

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

This plan is activated by the Shift Manager upon identification of an emergency situation based upon the Emergency Action Level (EAL) criteria. The SM acts as the Emergency Director and is responsible for the emergency. The emergency measures described in the subsequent sections and associated Emergency Plan Implementing Procedures (EPIPs) are in accordance with the classification and nature of the emergency at the direction of the EC.

This plan describes the organization and responsibilities for implementing emergency measures. It describes interfaces with Federal, State, and local organizations that may be notified in the event of an emergency and may provide assistance. Emergency fire, ambulance, and law enforcement services are provided by local public and private entities. Fixed medical services are provided by Mercy Medical Center to provide medical support for work related injuries, and to provide services for the treatment of radiologically contaminated injuries and radiation exposure evaluation.

Because there are no postulated accidents that would result in offsite dose consequences that are large enough to require offsite emergency planning, emergencies are divided into two classifications: Notification of Unusual Event (NOUE) and Alert. This classification scheme, is developed in accordance with NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors", Revision 6, November 2012. In the Statement of Considerations for the 3

Final rule - 10 CFR Part 72, "Emergency Planning Licensing Requirements for Independent Spent Fuel Storage Facilities (ISFSI) and Monitored Retrievable Storage Facilities (MRS),"

(Reference 3), the Commission responded to comments concerning offsite emergency planning for an ISFSI or an MRS and concluded that, "the offsite consequences of potential accidents at an ISFSI or a MRS installation would not warrant establishing Emergency Planning Zones."

DAEC is responsible for planning and implementing emergency measures within the Site Boundary. This plan is provided to meet this responsibility. To carry out specific emergency measures discussed in this plan, detailed EPIPs are established and maintained. A list of EPIPs is included in Appendix 3.

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

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

1.1.2 Scope The PDEP has been developed to respond to potential emergencies at DAEC considering the permanently shut down and defueled condition. There are no postulated accidents that would result in offsite dose consequences that are large enough to require offsite emergency planning.

Therefore, the overall scope of this plan delineates the actions necessary to safeguard onsite personnel and minimize damage to property. If determined appropriate by government officials, protective actions may be implemented to protect the public using an all hazards approach to emergency planning.

The concepts presented in this plan address the applicable regulations stipulated in 10 CFR 50.47, "Emergency Plans", and 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," as exempted. Exemptions to selected portions of 10 CFR 50.47(b); 10 CFR 50.47(c)(2); and 10 CFR 50, Appendix E were previously approved by the NRC. The plan is consistent with the remaining applicable guidelines established in NUREG-0654/FEMA-REP1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" (NUREG-0654). Appendix 1 contains a cross-reference to the applicable guidance in NUREG-0654. Definitions and acronyms used in this Plan are included in Appendix 4.

1.1.3 Objectives The basic objectives of this plan are:

1) To establish a system for identification and classification of the emergency condition and initiation of response actions; 4

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

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

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

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

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

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

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

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

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

The Duane Arnold Energy Center is located in Linn County, Iowa, approximately eight miles from the City of Cedar Rapids, and 2.5 miles northeast of the town of Palo, Iowa. The site containing approximately 500 acres is entirely owned by NextEra Energy Duane Arnold, LLC and constitutes the Exclusion Area Boundary (EAB or "Site Boundary"). Distance from the reactor centerline to the nearest site boundary is approximately 2000 ft.; and distance to the nearest resident is beyond the site boundary. A paved county road provides access to the site.

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

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

The ERO augments the normal on-shift organization to respond to declared emergencies when activated. ERO personnel are trained and assigned to a position based on job qualifications or by being specifically trained to fill the positon. The ERO is activated at the Alert declaration or at 5

the discretion of the EC. The designated on-shift and augmented ERO staff are capable of continuous (24-hour) operations for a protracted period. The minimum staff required to conduct routine and immediate emergency mitigation is maintained at the station.

Figure B.1 and Table B.1 outline the minimum requirements for the DAEC on-shift and ERO staffing.

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

1.1 Facility On-Shift Organization During normal conditions, the minimum staff on duty at the facility during all shifts consists of one (1) Shift Manager, two (2) Non-Certified Operators (NCOs), one (1) Health Physics (HP)

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

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

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

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

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

Other Emergency Director responsibilities are outlined below:

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

Management of resources available to the facility Coordination of mitigation actions Coordination of corrective actions Coordination of onsite protective actions Decision to call for offsite assistance 6

Coordination of Security activities Termination of the emergency condition when appropriate Performance of initial dose assessment Maintenance of records of event activities 1.1.2 Non-Certified Operators (NCOs)

The NCOs, on shift 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, perform system and component manipulations. The organizational relationship to the Shift Manager/Emergency Director is the same during normal situations and during situations where the PDEP has been implemented.

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

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

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

1.2.1 Technical and Engineering (Tech. & Engineering) Supervisor The Tech. & Engineering Supervisor reports to the Emergency Director. The responsibilities of the Tech. & Engineering Supervisor when implementing the PDEP include:

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

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1.2.2. Site Radiation Protection Coordinator (SRPC)

The SRPC reports to the Emergency Director. The responsibilities of the SRPC when implementing the PDEP include:

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

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

1.3. Offsite Organizations Offsite organizations may respond to a declared emergency at DAEC. Each of these groups are capable of 24-hour response and operation. The details of their responsibilities are described in Section C Emergency Response Support and Resources of this Plan and are contained in their respective Letter of Agreement between each organization and DAEC.

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Figure B.1 Emergency Response Organization (On-Shift and Augmented Staffing)

Shift Manager (1)

Emergency Director 1

I I I Security Force NCOs (2) HP Technician (1)

Augmented Staffing Tech. & Engineering Site Rad Protection Supervisor (1) Coordinator {1}

I I

I I I Federal State/Local Fire/EMS/

Agencies Agencies LE Agencies

(#) Denotes number of staff (either on-shift or augmented staff) 9

Table B.1 On-Shift and Staff Augmentation Assignments MAJOR FUNCTIONAL AREA LOCATION DAEC STAFF #ON- DAEC AUGMENTED SHIFT CAPABILITY (120 MIN.)

Operations and Assessment of Control Room Non-Certified 21 -

Operational Aspects On-Scene Operators*

Emergency Direction & Control Control Room Shift Manager 1

Notification/Communication Control Room Shift Manager 1

Radiological Accident Assessment As directed by SRPC (May augment with and Support of Operational Accident the Emergency

- Radiation Monitoring Assessment Director personnel if necessary)

Protective Actions (In-Facility) On-scene HP 1 -

Technician*

1 Condition Evaluation, Repair, and As directed by Tech. & {May augment with Corrective Action the Emergency Engineering

- technical support and Director Supervisor emergency repair personnel if necessary)

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

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

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

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

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

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Section C Emergency Response Support and Resources Radiological emergency preplanning is not required for the State of Iowa or the surrounding Linn County. State and County response to an emergency will be performed in accordance with each organization's plans and procedures and will be commensurate with the hazard posed by the emergency.

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

1.1 Support Provided by Local Organizations 1.1.1 Law Enforcement The Linn County Sheriffs Office provides law enforcement support to the DAEC Security Department. A Letter of Agreement for this support is maintained in the DAEC Security Department.

1.1.2 Fire Response The Palo Volunteer Fire Department provides fire support services for DAEC and through mutual aid can call in other area fire departments for additional support.

1.1.3 Emergency Medical Rescue and Transport DAEC vehicles may transport non-injured potentially contaminated personnel. The Hiawatha Fire and Rescue Department provides emergency rescue and transportation services for injured and/or contaminated personnel.

1.1.4 Treatment of Radioactively Contaminated and Injured Personnel Mercy Medical Center, in Cedar Rapids, provides medical support for work related injuries and for the treatment of radiologically contaminated injuries and radiation exposure evaluation.

Mercy Medical Center uses the Radiation Emergency Assistance Center/Training Site (REAC/TS), a world-renowned, U.S. Department of Energy (DOE) asset and a leader in emergency medical response to radiological/nuclear incidents for support. Subject matter experts at REAC/TS are on-call and ready to deploy (as well as available for phone advice and consultation) 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day, seven days a week.

Section D Emergency Classification System This section describes the emergency classification scheme adopted by DAEC.

1.1 Classification of Emergencies The emergency classification system covers the entire spectrum of possible radiological and non-radiological emergencies at DAEC. The emergency classification system categorizes accidents and/or emergency situations into two emergency classification levels depending on emergency conditions at the time of the incident. The emergency classification levels applicable 11

to DAEC, in order of increasing severity are NOUE and Alert. Each of these emergency classes requires notification of the responsible State of Iowa and Linn County authorities, and the Nuclear Regulatory Commission (NRC). The Emergency Response Organization (ERO) will be notified at an Alert declaration.

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

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

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

The following subsections outline the facility actions at each emergency classification level.

Refer to the Permanently Defueled Emergency Action Level Technical Bases for actual parameter values, annunciators, and equipment status used by DAEC personnel to classify emergencies.

1.1.1 Notification of Unusual Event NOUE conditions do not cause serious damage to the facility. The purpose of the NOUE declaration is to: 1) bring the ERO to a state of readiness; 2) make required and needed notifications; 3) provide for systematic handling of information and decision-making; and 4) augment shift personnel if necessary.

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

The Alert status shall be maintained until termination of the event occurs. Recovery operations may be entered without termination. Offsite authorities will be informed of the change in the emergency status and the necessary documentation shall be completed as specified in the EPIPs. '

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

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1.3 Emergency Classification System Review The emergency classification system and the EALs are reviewed with the State of Iowa and Linn County on an annual basis.

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

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

DAEC personnel in the Protected Area are notified via the Emergency or Fire Alarm and a public address system message. If required, personnel outside the Protected Area are notified by public address systems installed in the buildings outside the Protected Area. Site Security personnel may assist in the notification of all other personnel on DAEC property.

1.1.1 Emergency Response Organization Activation On-site staff are informed of an emergency condition through the use of the facility public address system, office telephone, and/or wireless devices capable of receiving telephone calls and text messages. In the event that personnel required to staff ERO positions are not on-site at the time an emergency is declared, they may be contacted by commercial telephone including land lines and/or wireless devices capable of receiving telephone calls and text messages.

Mobilization of the ERO will be conducted under the direction of the Emergency Director, according to personnel assignments and telephone numbers maintained in various telephone directories.

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

DAEC, in coordination with the State of Iowa and Linn County, have established the contents of the initial emergency messages to be sent from DAEC in the event an emergency is declared.

These messages contain such information as the class of emergency and whether a release is taking place.

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

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

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

Section F Emergency Communications A number of communications systems are available for use among the principal response organizations. Provisions for 24-hour per day notification to State and local authorities is discussed in Section D of this plan. Provisions for activating DAEC ERO personnel are also discussed in Section D of this plan. Provisions for periodic testing of the emergency communications system are described in Section M of this plan.

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

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

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

Buildings outside of the Protected Area also have public address announcing capabilities.

Access to the public address system in both locations can be accomplished via the site's telephone system. This system can be used to notify personnel of an emergency.

1.2.2 Telephone System The commercial telephone system (see Section 4.1.2) is the primary emergency notification system between DAEC, State, and county agencies and is used to provide initial and follow-up notifications and for general information flow between these agencies.

Additional methods of communication are available to facility staff to transmit information onsite and offsite during normal and emergency situations.

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

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

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

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

Section G Public Information Any emergency generates a continuous and intensive demand for up-to-date information. The spokesperson function would typically be performed by Communications personnel.

Communication personnel will be notified of an emergency declaration and would serve as a spokesperson. However, the function could also be performed by plant or corporate management. Upon receiving notification of an emergency declaration, the spokesperson contacts the Control Room and receives a brief description of the event.

The spokesperson monitors media activity and coordinates with senior management to address rumors and disseminate information to the public. The spokesperson will participate in news conferences as appropriate with Federal, State and local emergency response organizations conducted from the site or at other locations, as necessary. The spokesperson is available for media inquiries and the positional duties include maintaining liaison with local media and coordinating with Federal, State and local emergency response organizations to disseminate appropriate information regarding an emergency at DAEC.

As part of its normal corporate structure, DAEC maintains a corporate communications office that can be called to provide additional resources, as necessary.

Section H Emergency Facilities and Equipment Following the declaration of an emergency, the activities of the ERO are coordinated from the Control Room. Adequate emergency facilities and equipment to support emergency response are provided and maintained.

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

1.2 Laboratory Facilities A laboratory for radioisotopic analysis and non-radiological chemical analysis is available at DAEC. A laboratory for radiological and non-radiological chemical analysis is also available at NextEra Energy Point Beach Nuclear Plant.

The DAEC and Point Beach radiochemistry laboratories are equipped to perform gross and isotopic determinations on radionuclides in concentrations and counting geometries necessary for nuclear power plant operation and emergency monitoring. They will provide analysis of liquid, air particulate, and cartridges on a priority basis after receiving the sample.

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

Emergency kits are described in Section H.

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

1.3.2 Radiological Monitors Radiation monitors and monitoring systems provide continuous radiological surveillance. These monitors, which include Control Room readout and alarm functions, exist in order that appropriate action can be initiated to limit fuel damage and/or contain radioactive material. The system performs the following basic functions:

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

Gaseous and liquid effluent monitor readings 16

Area radiation levels In addition to installed monitoring systems, onsite portable radiation and contamination monitoring equipment is available.

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

In addition, the National Weather Service operates on a twenty-four (24) hour per day basis.

Upon request, this organization can provide DAEC with meteorological conditions including predicted temperature inversions, precipitation, wind patterns, and velocity.

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

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

1.4.1 Radiological Emergency Kits Radiological Emergency kits include protective equipment, radiological monitoring equipment and emergency supplies. Kits are located in the Control Room. The methods and frequencies for instrument calibration, repair, and replacement are maintained in accordance with facility procedures.

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

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

Trauma and primary response kits are available throughout the facility. These kits are inspected and maintained in accordance with approved facility procedures.

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

Section I Accident Assessment The activation of the PDEP and the continued assessment of accident conditions requires monitoring and assessment capabilities. DAEC maintains and operates on-site monitoring systems needed to provide data that is essential for initiating emergency measures and performing accident assessment, including dose assessment.

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1.1 Radiological Assessment 1.1.1 Initial Assessment Classification of an emergency is performed by the Emergency Director in accordance with the Permanently Defueled EAL Scheme.

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

1.2 Corrective Actions Station procedures and EPIPs provide preventative and/or corrective actions that mitigate the consequences of events. Instrumentation, control systems, and radiation monitoring systems provide indications related to the safe and orderly implementation of corrective actions. These systems provide indication of SFP storage inventory, temperature, cooling, and supporting systems.

DAEC maintains procedures and strategies for the movement of any necessary portable equipment that will be relied upon for mitigating the loss of SFP water. These diverse strategies provide defense-in-depth and ample time to provide makeup water or spray to the SFP prior to the onset of zirconium cladding ignition when considering very low probability beyond design basis events affecting the SFP.

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

Section J Protective Actions Protective actions for personnel at the facility are provided for their health and safety.

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

It is the policy of DAEC to keep personnel radiation exposure within federal regulations, and station limits and guidelines and to keep exposures "As Low As Reasonably Achievable. "

(ALARA). Every effort will be made to keep exposures for those providing emergency functions within the limits of 10 CFR Part 20.

1.1 Accountability Accountability should be considered and used as a protective action whenever a site-wide risk to health and safety exists and prudence dictates. If personnel accountability is required, at the direction of the Emergency Director, all individuals at the site (including non-essential 18

employees, visitors, and contractor personnel) shall be notified by sounding the facility alarm and making announcements over the Public Address System. Following announcement of an emergency declaration, and when accountability has been requested, facility personnel are responsible for reporting to designated areas and aiding Security in the accountability process.

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

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

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

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

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

1.2 Exposure Control Individuals authorized to enter RCAs are required to have dosimetry capable of measuring a dose received from external sources of ionizing radiation. Emergency workers are issued permanent reading dosimeters (e.g., Dosimeter of Legal Record (DLR)) as a means of recording radiation exposure for permanent records prior to entering a RCA. Additionally, personnel are issued electronic alarming dosimetry capable of measuring dose and dose rate on a real time basis. Dose records are maintained in accordance with facility procedures.

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

The Emergency Director is responsible for authorizing personnel to receive doses in excess of 10 CFR Part 20 limits, if necessary. This authorization is coordinated with the Site Radiation Protection Coordinator when available. Table K-1 contains the guidelines for emergency 19

exposure criteria, which is consistent with the, "Response Worker Guidelines," provided in the EPA PAG Manual.

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

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

Contamination control measures are maintained to address access control, drinking water and food supplies, and the return of areas and items to normal use in accordance with proper radiation and contamination control techniques. Documentation surveys and decontamination activities shall be maintained in accordance with facility procedures.

Protective clothing is maintained in the Control room. Additional sets are available. Monitoring and issue of respiratory protection equipment will be conducted in accordance with facility procedures.

Table K.1 Emergency Exposure Criteria (Refer to Note 11)

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

10 Rem 2 Protecting valuable property Exceeding 5 rem is necessary for public welfare unavoidable and all appropriate actions have been taken to reduce dose.

25 Rem 3 , 4 Lifesaving or protection of Exceeding 5 rem is large Population unavoidable and all appropriate actions have been taken to reduce dose.

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

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

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

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

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Section L Medical and Health Support DAEC maintains on-shift personnel and equipment to provide first aid for personnel working at the site. Medical supplies for emergency first aid treatment are provided on the site at various locations.

If immediate professional medical help is needed, local ambulance services are available to transport seriously ill, injured, or radioactively contaminated injured personnel. Patients can also be transported to the facility via medical ambulance helicopters.

Agreements are in place with Mercy Medical Center in Cedar Rapids for medical treatment of patients from DAEC who have injuries complicated by radioactive contamination. Mercy Medical Center has trained personnel and detailed procedures for handling radioactively contaminated patients from DAEC.

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

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

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

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

The recovery organization's responsibilities include:

Maintaining comprehensive radiological surveillance of the facility to assure continuous control and recognition of problems Controlling access to the area and exposure to workers Decontaminating affected areas and/or equipment Conducting clean-up and restoration activities 21

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

Section N Exercises and Drills Periodic exercises are conducted to evaluate major portions of emergency response capabilities. Periodic drills are conducted to develop and maintain key emergency response skills. Deficiencies as a result of exercises or drills are identified and corrected.

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

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

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

1.2.2 Accountability Drills An accountability drill shall be conducted annually. This drill shall include identifying the locations of all personnel onsite. This drill can be performed as part of any drill or exercise.

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

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1.2.4 Augmentation Capability Drills An off-hour, unannounced augmentation drill, will be conducted semiannually to estimate emergency response personnel response times. No actual travel is required. Participants provide an estimate time of arrival to their designated ERO position.

1.2.5 Fire and Security Drills Fire Drills and Security Drills are conducted in accordance with the respective DAEC plans and procedures.

1.2.6 Communication Tests

a. The ENS, used to communicate with the NRC, is tested monthly.

b. To ensure the reliability of the plant's call-in procedure, a semi-annual functional test of the ERO notification system is performed to test system performance. This can be performed separately or during the Augmentation Capability Drill described in Section N.1.2.4.

c. The following communication systems, as detailed in Section F.1.2. are used on a frequent basis. Therefore, periodic testing of these systems is not necessary:

i. DAEC Paging System ii. Commercial Telephone System iii. Portable Radios 1.3 Scenarios An Exercise/EP Coordinator is responsible for the overall development of the scenario package.

A scenario development team is assembled (if needed) by the Exercise/EP Coordinator to create the various segments of the scenario which include, but are not limited to, the following:

Objective(s)

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

Drill/Exercise confidentiality must be maintained.

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1.4 Critique/Evaluation Critiques will evaluate the participant's performance during a drill or exercise. The ability of participants to self-evaluate weaknesses and identify areas of improvement is the key to successful exercise/drill conduct.

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

A written report is prepared including the evaluation of designated objectives. The report evaluates and documents the participants' response to the emergency situation. The report will also contain reference to corrective action and recommendations resulting from the drill/exercise.

Section 0 Radiological Emergency Response Training Radiological emergency response training is provided to those who may be called on to assist in an emergency. DAEC Management is responsible to ensure all members of the Emergency Response Organization receive the required initial training and continuing training.

1.1 Emergency Response Training The training program for ERO personnel is based on applicable requirements of Appendix E to 10 CFR Part 50 and position-specific responsibilities as defined in the PDEP. Emergency response personnel in the following categories receive initial training and annual retraining.

1.1.1 Emergency Response Organization Training Shift Managers/Emergency Directors, Tech. & Engineering Supervisors, and Site Radiation Protection Coordinators will have training conducted such that proficiency is maintained on topics listed below. These topics should be covered as a minimum on an annual basis.

Emergency Action Level Classification Dose Assessment Federal, State, and local notification procedures ERO Augmentation Emergency Exposure Control Mitigating strategies for a catastrophic loss of spent fuel pool inventory Recovery DAEC personnel available during emergencies to perform emergency response activities as an extension of their normal duties receive duty specific training. This includes facility on-shift personnel, maintenance, radiation protection, and security personnel. Personnel assigned to 24

liaison with offsite fire departments are trained in accordance with the Fire Protection Program, including mitigating strategies required for a catastrophic loss of SFP inventory. Personnel assigned the responsibility of on-shift first aid shall attend first aid training.

1.1.2 General Employee Training An overview of the Emergency Plan is given to all personnel allowed unescorted access into the Protected Area at the Duane Arnold Energy Center. Personnel receive this information during initial training and are requalified on an annual basis. This training includes identification of the emergency alarm, the fire alarm and the steps to follow for a plant and site evacuation.

1.1.3 Local Support Services Personnel Training Training is offered annually to offsite organizations which may provide specialized services during an emergency at DAEC (fire-fighting, medical services, transport of contaminated and/or injured personnel, etc.). The training shall be structured to meet the needs of that organization with respect to the nature of their support. Topics of event notification, site access, basic radiation protection and interface activities are included in the training.

1.2 Documentation of Training DAEC procedures outline the process to document training of the DAEC Emergency Response Organization. Annually, Offsite organization's training offers and training taken will be documented.

Section P Responsibility for the Planning: Periodic Review and Distribution of Emergency Plans Senior plant leadership is responsible for the implementation of actions required to periodically exercise the PDEP and the EPIPs and for maintaining an effective ERO staff. Senior plant leadership is responsible for the final approval of PDEP and the EPIPs used for emergency classification, and for maintaining an effective emergency response capability at DAEC.

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

1.1 Document Maintenance 1.1.1 Review and Update of the PDEP and EPIPs The DAEC PDEP, Permanently Defueled EAL Technical Bases, and the EPIPs included in Appendix 3 are reviewed on a semi-annual basis and updated as needed. All proposed changes will be reviewed in accordance with 10 CFR 50.54(q) to ensure that the change would not compromise the effectiveness of any other EPIP or degrade the effectiveness of the PDEP.

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1.1.2 Emergency Planning Documents Letters of Agreement with support agencies shall be reviewed annually. Agreements will be revised or recertified as appropriate. Recertification may include a recertification letter/memorandum, purchase order, email, documented telephone conversation or other correspondence. Designated DAEC management has the authority to enter into these agreements with outside organizations.

The emergency classification system and the EALs are reviewed with the State of Iowa and Linn County on an annual basis.

The DAEC emergency telephone directory will be maintained and updated quarterly.

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

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

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Appendix 1 - Cross Reference Table Cross-Reference Between the PDEP, NUREG-0654/FEMA-REP-1, 10 CFR 50.47(b)

Planning Standards, and Appendix E.IV Planning Requirements NUREG-0654/FEMA-REP-1, 10 CFR 50.47(b)

NUREG-0654, Planning Section II Planning Standard DAEC Requirement Evaluation (10CFR50.47)* PDEP Section (Appendix E.IV)*

Criteria A (b )( 1) A.1 ,2,4,7 A B (b)(2) A.1 ,2,4,9; C.1 B c (b)(3) A.6,7 c D (b)(4) B.1 ,2;C.1 ,2 D E (b)(5) A.6,7;C.1 ,2;D.1,3;E E F (b)(6) C.1 ;D.1 ,3;E F G (b)(7) A.7;0.2 G H (b)(8) E;G H I (b)(9) A.4;8.1 ;C.2;E I J (b)(10) C.1;E;I J K (b)(11) E K L (b)(12) A.6,7;E L M (b)(13) H M N (b)(14) E9;F N 0 (b)(15) F 0 p (b)(16) G p

• As Exempted 27

Appendix 2 - Letters of Agreement NextEra Energy Duane Arnold has agreements established with the agencies listed below that support implementation of the Permanently Defueled Emergency Plan.

Palo Fire Department Linn County Sheriff's Office (agreement is kept in the Safeguard Area, contact Security for review)

Mercy Medical Center Hiawatha Fire and Rescue 28

Appendix 3 - Permanently Defueled Emergency Plan Implementing Procedures EPIP 1.1 Determination of Emergency Action Level EPIP 1.2 Notifications EPIP 1.3 Plant Assembly and Site Evacuation EPIP 2.3 Operation of the FTS-2001 Phone Network EPIP 2.5 Control Room Emergency Response Operation EPIP 2.8 Security Threat EPIP 3.1 In Plant Radiological Monitoring EPIP 3.3 Dose Assessment and Protective Action EPIP 4.3 Rescue and Emergency Repair Work EPIP 5.2 Termination and Recovery EPIP 6.1 Drill and Exercise Program EPIP 6.2 Maintenance of Emergency Response Facilities and Equipment EPIP Form PDEAL-01 Permanently Defueled Emergency Action Levels - DAEC 29

Appendix 4 - Definitions and Acronyms 1.0 Definitions Accountability - The process of determining the location of onsite personnel in order to identify missing and or injured personnel.

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

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

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

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

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

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

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

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

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

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

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

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

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

Notification of Unusual Event - Events are in progress or have occurred which indicate a potential degradation of the level of safety of the facility or indicate a security threat to facility 30

protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

Onsite - The area within the Exclusion Area Boundary.

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

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

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

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

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

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

2.0 Acronyms CFR Code of Federal Regulation DLR Dosimeter of Legal Record EAL Emergency Action Level ENS Emergency Notification System EPA Environmental Protection Agency EPIP Emergency Plan Implementing Procedure ERO Emergency Response Organization DAEC The Duane Arnold Energy Center FTS Federal Telecommur:iications System IC Initiating Condition ISFSI Independent Spent Fuel Storage Installation NCO Non-Certified Operator NOUE Notification of Unusual Event NRC U.S. Nuclear Regulatory Commission NWS National Weather Service 31

DAEC NextEra Energy Duane Arnold Energy Center PAG Protective Action Guide PDEP Permanently Defueled Emergency Plan RCA Radiological Control Area SFP Spent Fuel Pool 32