PNP 2022-016, License Amendment Request: Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme

License Amendment Request: Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme

ML22193A090
Person / Time
Site:	Palisades
Issue date:	07/12/2022
From:	Fleming J Holtec
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
HDI PNP 2022-016
Download: ML22193A090 (165)

Text

Krishna P. Singh Technology Campus, 1 Holtec Blvd., Camden, NJ 08104 Telephone (856) 797-0900 Fax (856) 797-0909 10 CFR 50.90 10 CFR 50.54(q)

HDI PNP 2022-016 July 12, 2022 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

License Amendment Request: Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme Palisades Nuclear Plant NRC Docket No. 50-255 Renewed Facility Operating License No DPR-20

References:

1. Letter from Entergy Nuclear Operations, Inc. to U.S. Nuclear Regulatory Commission, "Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel," dated June 13, 2022 (ADAMS Accession No. ML22164A067)

2. U.S. Nuclear Regulatory Commission letter to Entergy Nuclear Operations, Inc., "Palisades Nuclear Plant - Issuance of Amendment Re: Changes to the Emergency Plan for Permanently Defueled Condition (CAC No. MG0198; EPID L-2017-LLA-0305)," dated September 24, 2018 (ADAMS Accession No. ML18170A219)

3. Letter from Holtec Decommissioning International, LLC to U.S. Nuclear Regulatory Commission, "Request for Exemptions from Certain Emergency Planning Requirements of 10 CFR 50.47; 10 CFR 50.47(c)(2); and 10 CFR Part 50, Appendix E," dated July 11, 2022 (ADAMS Accession No. ML22192A134)

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.90, Application for amendment of license, construction permit, or early site permit, Holtec Decommissioning International, LLC (HDI), on behalf of Holtec Palisades, LLC, hereby requests an amendment to the PNP license. The proposed amendment would revise the PNP Post-Shutdown Emergency Plan (PSEP) and Emergency Action Level (EAL) scheme for the permanently defueled condition. The proposed changes are being submitted to the U.S. Nuclear Regulatory Commission (NRC) for approval prior to implementation, as required by 10 CFR 50.54, Conditions of licenses, paragraph (q)(4) and 10 CFR Part 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities,Section IV, Content of Emergency Plans, paragraph B.2.

HDI PNP 2022-016 Page 2 of 4 By letter dated June 13, 2022, Entergy certified to the NRC that power operations ceased at PNP on May 20, 2022, and that the fuel was permanently removed from the reactor vessel and placed in the PNP spent fuel pool (SFP) on June 10, 2022, in accordance with 10 CFR 50.82, Termination of License, paragraphs (a)(1)(i) and (a)(1)(ii) (Reference 1). It is understood and acknowledged that upon the NRC's docketing of these certifications, in accordance with 10 CFR 50.82(a)(2), the license for PNP no longer authorizes operation of the reactor, nor emplacement or retention of fuel into the reactor vessel. The irradiated fuel will be stored in the SFP and in dry cask storage at an onsite independent spent fuel storage installation (ISFSI) until it is shipped offsite.

To address the transition from an operating facility to a permanently defueled facility, by letter dated September 24, 2018, the NRC issued Amendment No. 267 (PSEP) (Reference 2),

approving changes to the PNP Emergency Plan to support the planned permanent cessation of operations and permanent removal of fuel from the reactor vessel. Upon implementation of the PSEP, on June 15, 2022, the PNP emergency response organization (ERO) on-shift and augmented staffing were revised commensurate with the reduced spectrum of credible accidents for a permanently shutdown and defueled nuclear power reactor facility.

In Reference 3, Holtec requested exemptions from portions of 10 CFR 50.47(b); 10 CFR 50.47(c)(2); and 10 CFR Part 50, Appendix E. The Permanently Defueled Emergency Plan (PDEP) and Permanently Defueled Emergency Action Level (EAL) scheme, proposed within this amendment request, are predicated on the NRC granting approval of the requests for exemptions submitted in Reference 3. The proposed PDEP reduces the scope of offsite and onsite emergency planning commensurate with the permanently defueled condition, following sufficient decay of the spent fuel. However, the proposed PDEP and Permanently Defueled EAL scheme satisfy the applicable standards of 10 CFR 50.47(b) and the requirements of 10 CFR Part 50, Appendix E, for a permanently defueled reactor, as modified by the requested exemptions.

The proposed PDEP and Permanently Defueled EAL scheme are commensurate with the significantly reduced risk associated with the spent fuel stored in the PNP spent fuel pool (SFP) after it has sufficiently decayed such that the radiological impact of accidents is not expected to result in radioactive releases that exceed U.S. Environmental Protection Agency (EPA)

Protective Action Guidelines (PAGs) beyond the site boundary. The proposed changes are necessary to properly reflect the conditions of the facility while continuing to preserve the PNP Decommissioning Trust Funds and the effectiveness of the emergency plan.

The analyses provided to the NRC in Reference 3 demonstrate that approximately 12 months following shutdown of the PNP reactor, the spent fuel stored in the PNP SFP will have decayed to the point where the PDEP and Permanently Defueled EAL scheme may be implemented.

The analyses demonstrate that approximately 12 months after permanent cessation of power operations of the PNP reactor, there is sufficient time to mitigate events that could lead to a zirconium fire.

The Enclosure to this letter provides a description, technical and regulatory evaluation, significant hazards determination, and environmental considerations evaluation for the proposed license amendment. to the Enclosure contains the proposed PDEP.

HDI PNP 2022-016 Page 3 of 4 to the Enclosure contains the Permanently Defueled EAL Technical Bases Document. to the Enclosure contains a comparison of the proposed PNP Permanently Defueled EAL Technical Bases to the corresponding information contained in Nuclear Energy Institute (NEI) 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 6.

In support of the proposed changes to the PSEP, PNP personnel have had discussions with cognizant state and local response organizations regarding the regulatory exemption requests to be submitted to the NRC. PNP personnel will continue to meet with representatives from the State of Michigan; local emergency preparedness personnel with Berrien County, Allegan County, and Van Buren County; and regional leadership from the U.S. Federal Emergency Management Agency. to this Enclosure contains documentation of Offsite Response Organization (ORO) concurrence with the proposed transition to the PDEP.

HDI requests review and approval of the proposed license amendment by April 29, 2023, with an effective date of May 31, 2023 (i.e., approximately 12 months following the permanent shutdown of PNP). The license amendment will not be implemented until the certifications required by 10 CFR 50.82(a)(1)(i) and (ii) have been docketed in accordance with 10 CFR 50.82(a)(2) and the decay time requirement established in Reference 3 has been met.

This letter contains no new regulatory commitments or updates to existing commitments.

In accordance with 10 CFR 50.91, Notice for public comment; State consultation, paragraph (b),

a copy of this license amendment request, with enclosure, is being provided to the designated State Officials.

If you have any questions regarding this submittal, please contact Jim Miksa, Regulatory Assurance Engineer, at (269) 764-2945.

I declare under penalty of perjury that the foregoing is true and correct. Executed on July 12, 2022.

Respectfully, Jean A. Digitally signed by Jean A. Fleming Fleming Date: 2022.07.12 08:54:46 -04'00' Jean A. Fleming Vice President, of Licensing, Regulatory Affairs & PSA Holtec International, LLC

Enclosure:

Description and Evaluation of Proposed Changes Attachments to

Enclosure:

1. Permanently Defueled Emergency Plan

HDI PNP 2022-016 Page 4 of 4

1. Permanently Defueled Emergency Plan

2. Permanently Defueled Emergency Action Level Technical Bases

3. Comparison Matrix for Permanently Defueled Emergency Action Levels Based on NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors," Revision 6

4. Offsite Response Organization Acknowledgment and Concurrence cc:

U.S. NRC Regional Administrator (Region III)

NRC Senior Resident Inspector - PNP NRC Project Manager - PNP Designated Michigan State Official

Enclosure HDI PNP 2022-016 Description and Evaluation of Proposed Changes

Enclosure HDI PNP 2022-016 Page 1 of 17 TABLE OF CONTENTS 1.0

SUMMARY

DESCRIPTION ............................................................................................. 2 2.0 DETAILED DESCRIPTION AND BASIS FOR THE CHANGE ......................................... 2

3.0 TECHNICAL EVALUATION

............................................................................................. 4 3.1 Accident Analysis Overview ......................................................................................... 4 3.2 Consequences of Design Basis Events........................................................................ 4 3.2.1 Fuel Handling Accident ......................................................................................... 4 3.2.2 Liquid Waste Incident............................................................................................ 5 3.2.3 Waste Gas Incident............................................................................................... 5 3.2.4 Postulated Cask Drop Accident............................................................................. 5 3.3 Consequences of a Beyond Design Basis Event ......................................................... 6 3.3.1 Hottest Fuel Assembly Adiabatic Heatup .............................................................. 6 3.3.2 Spent Fuel Pool Drain Down Event ....................................................................... 6 3.4 Design and Operational Characteristics of the Spent Fuel Pool ................................... 7 3.5 Consequences of a Beyond Design Basis Earthquake ................................................ 7 4.0 EMERGENCY PLAN AND EMERGENCY ACTION LEVEL SCHEME ............................ 7 4.1 Permanently Defueled Emergency Plan....................................................................... 7 4.1.1 On-Shift and Emergency Response Organization Staffing .................................... 8 4.1.2 Emergency Communications ................................................................................ 9 4.1.3 Letters of Agreement ............................................................................................ 9 4.2 Permanently Defueled Emergency Action Level Scheme............................................. 9 4.2.1 Operating Modes and Applicability .......................................................................10 4.2.2 Differences and Deviations ..................................................................................10 4.3 Coordination with State and Local Governments ........................................................10

5.0 REGULATORY EVALUATION

.......................................................................................11 5.1 Applicable Regulatory Requirements and Criteria .......................................................11 5.2 No Significant Hazards Consideration Determination ..................................................13 5.3 Precedent ...................................................................................................................15 5.4 Conclusion ..................................................................................................................15

6.0 ENVIRONMENTAL CONSIDERATION

S ........................................................................15

7.0 REFERENCES

...............................................................................................................16

Enclosure Page 2 of 17 Description and Evaluation of Proposed Changes 1.0

SUMMARY

DESCRIPTION In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.90, Application for amendment of license, construction permit, or early site permit, Holtec Decommissioning International, LLC. (HDI), on behalf of Holtec Palisades, LLC, requests U.S. Nuclear Regulatory Commission (NRC) review and approval of a revision to the Palisades Nuclear Plant (PNP)

Post-Shutdown Emergency Plan (PSEP). The proposed changes would revise the PNP PSEP and Emergency Action Level (EAL) scheme to support the permanently defueled condition following a sufficient decay of the spent fuel, such that the risk of an offsite radiological release is significantly lower, and the types of possible accidents are significantly fewer.

HDI has submitted a separate request for exemptions from portions of 10 CFR 50.47, Emergency Plans, paragraphs (b) and (c)(2); and 10 CFR Part 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, by letter dated July 11, 2022 (Reference 1). The proposed PDEP and Permanently Defueled EAL scheme satisfy the applicable standards of 10 CFR 50.47(b) and the requirements of 10 CFR Part 50, Appendix E, for the permanently defueled condition, as modified by the exemptions requested in Reference

1. The exemption request contains an analysis for the PNP spent fuel pool (SFP) for beyond design basis events, which demonstrates that approximately 12 months after permanent cessation of power operations of the PNP reactor, the spent fuel stored in the SFP will have decayed to the extent that the requested exemptions are appropriate, and the PDEP and the Permanently Defueled EAL scheme may be implemented. The analysis demonstrates that approximately 12 months after permanent cessation of power operations of the PNP reactor, a minimum of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> is available to mitigate events that could lead to a zirconium fire.

Implementation of the PDEP and Permanently Defueled EAL scheme is based on this approximate 12-month decay period. Based on the shutdown date of May 20, 2022, approximately 12 months following permanent cessation of power operations of PNP would occur on May 31, 2023.

2.0 DETAILED DESCRIPTION AND BASIS FOR THE CHANGE This license amendment request would modify the PNP license by revising the PSEP and the associated EAL scheme to reflect the permanently shutdown and defueled condition of the PNP reactor, and the anticipated conditions following approximately 12 months of decay of the spent fuel in the PNP SFP.

By letter dated June 13, 2022, Entergy certified to the NRC that power operations ceased at PNP on May 20, 2022, and that the fuel was permanently removed from the reactor vessel and placed in the PNP SFP on June 10, 2022, in accordance with 10 CFR 50.82, Termination of License, paragraphs (a)(1)(i) and (a)(1)(ii) (Reference 2). Upon the NRC's docketing of these certifications, in accordance with 10 CFR 50.82(a)(2), the license for PNP no longer authorizes operation of the reactor, or emplacement or retention of fuel into the reactor vessel. The irradiated fuel will be stored in the SFP and in dry cask storage at an onsite independent spent fuel storage installation (ISFSI) until it is shipped offsite.

To address the transition from an operating plant to a permanently defueled facility, by letter dated September 24, 2018, the NRC issued Amendment No. 267 (PSEP) (Reference 3),

approving changes to the PNP emergency plan to support the planned permanent cessation of operations and permanent removal of fuel from the reactor vessel. Upon implementation of the PSEP on June 15, 2022, the PNP emergency response organization (ERO) on-shift and

Enclosure Page 3 of 17 augmented staffing were revised commensurate with the reduced spectrum of credible accidents for a permanently shutdown and defueled nuclear power reactor facility.

When PNP was licensed for power operations, Chapter 14 of the PNP Updated Final Safety Analysis Report (UFSAR) describes accident analyses for postulated design basis accidents (DBAs) and transient scenarios under which PNP is licensed. The most severe postulated DBA involves damage to the nuclear reactor core and the release of large quantities of fission products. Many of these accident scenarios involve failures or malfunctions of systems, which could affect the fuel in the reactor vessel. With the termination of reactor operations and the permanent removal of fuel from the reactor vessel, such accidents are no longer possible.

Therefore, the postulated accidents involving failure or malfunction of the reactor, reactor coolant system, steam system, or turbine generator, are no longer applicable. The only remaining DBAs will be the Fuel Handling Accident (FHA) in the SFP, the liquid waste incident, the waste gas incident, and the postulated cask drop accident. Because PNP is permanently shut down and the reactor is defueled, an FHA in the reactor cavity is no longer applicable because all irradiated spent fuel is stored in the SFP or an ISFSI. Therefore, because an FHA can only occur during movement of spent fuel in the SFP, the FHA event will be limited to the SFP.

The offsite radiological consequences of accidents possible at PNP, described in Reference 1, will be substantially lower than during plant operation. The analyses of the potential radiological impact of accidents while the facility is in a permanently defueled condition indicate that no DBA or reasonably conceivable beyond design basis accident would result in radioactive releases that exceed U.S. Environmental Protection Agency (EPA) Protective Action Guidelines (PAGs)

(Reference 4) beyond the exclusion area boundary (EAB).

The slow progression rate of postulated event scenarios indicate sufficient time is available to initiate appropriate mitigating actions to protect the health and safety of the public. Therefore, the proposed PDEP states that HDI will maintain the ability to assess, classify, and declare an emergency within 30 minutes after the availability of indications that an EAL threshold has been reached. Emergency classifications are to be made as soon as conditions warranting classification are present and recognizable for the classification in accordance with the applicable EALs, but within 30 minutes after the availability of indications that an EAL has been reached. The proposed PDEP also states that notification of an emergency declaration will be made to appropriate State of Michigan and Van Buren County authorities within 60 minutes of an emergency declaration or change in classification. The proposed PDEP reduces the scope of onsite and offsite emergency planning activities commensurate with the reduced spectrum of credible accidents that can occur in a permanently shutdown and defueled condition and continues to meet the applicable standards of 10 CFR 50.47(b) and requirements of 10 CFR Part 50, Appendix E, as modified by the exemptions requested in Reference 1.

The current PNP EAL scheme is based on the guidance presented in Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels, Revision 5 (Reference 5). A revision to the PNP EAL scheme to implement the EAL scheme contained in guidance presented in Appendix C of NEI 99-01, Revision 6 (Reference 6), Recognition Category "PD" (Permanently Defueled), is appropriate for the permanently shutdown and defueled condition of the PNP reactor. This determination is based on the analyses presented in Reference 1. Additionally, the guidance associated with the ISFSI Recognition Category "E,"

presented in Section 8 of NEI 99-01, Revision 6, is included because it will remain applicable.

NEI 99-01, Revision 6, was endorsed by the NRC in a letter dated March 28, 2013 (Reference 7).

Enclosure Page 4 of 17

3.0 TECHNICAL EVALUATION

3.1 Accident Analysis Overview 10 CFR 50.82(a)(2) specifies that the 10 CFR Part 50 license no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel after docketing the certifications for permanent cessation of power operations and permanent removal of fuel from the reactor vessel, in accordance with 10 CFR 50.82(a)(1). Following the termination of reactor operations at PNP, and the permanent removal of the fuel from the reactor vessel, the postulated accidents involving failure or malfunction of the reactor and supporting structures, systems, and components (SSCs) are no longer applicable. Summaries of the radiological accidents analyzed for the permanently shutdown and defueled condition, and supporting this license amendment request, are presented below.

Section 5.0 of Interim Staff Guidance (ISG) NSIR/DPR-ISG-02, Emergency Planning Exemption Requests for Decommissioning Nuclear Power Plants, issued May 11, 2015 (Reference 8) indicates that site-specific analyses should demonstrate that: (1) the radiological consequences of remaining applicable DBAs would not exceed the limits of the EPA PAGs at the EAB; (2) in the event of a beyond design basis event resulting in the partial drain down of the SFP to the point that cooling is not effective, there is at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> (assuming an adiabatic heat up) from the time that the fuel is no longer being cooled until the hottest fuel assembly reaches 900°C; (3) adequate physical security is in place to assure implementation of security strategies that protect against spent fuel sabotage; and (4) in the unlikely event of a beyond design basis event resulting in a loss of all SFP cooling, there is sufficient time to implement pre-planned mitigation measures to provide makeup or spray to the SFP before the onset of a zirconium cladding ignition.

These analyses are described in Reference 1. Specific analyses are summarized in the following sections.

3.2 Consequences of Design Basis Events As described in Amendment No. 272, issued by the NRC on May 13, 2022 (PNP - Issuance of Amendment No. 272 Re: Permanently Defueled Technical Specifications), the applicable remaining DBAs are (1) the FHA in the SFP, (2) the Liquid Waste Incident, (3) a Waste Gas Incident, and (4) a Postulated Cask Drop Accident (Reference 9).

The DBAs that remain applicable to PNP are discussed in the following paragraphs.

3.2.1 Fuel Handling Accident Following permanent cessation of power operations and permanent removal of fuel from the PNP reactor, an FHA in the reactor cavity is no longer applicable because all irradiated spent fuel will either be stored in the PNP SFP or an ISFSI. Therefore, because an FHA can only occur during movement of spent fuel in the SFP, the FHA event is limited to the SFP.

The FHA analysis assumed 22.5 feet of water above the stored fuel, which resulted in an effective decontamination factor of 183.07 and an overall decontamination factor for elemental iodine of 252 (Reference 10). The FHA utilizes the Alternate Source Term (AST) methodology described in Regulatory Guide 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors (Reference 11).

Enclosure Page 5 of 17 The analysis demonstrates that after a decay time of 60 days following permanent cessation of power operations of the PNP reactor, with no credit taken for the operability of mitigating structures, systems, or components (SSCs), the FHA in the SFP results in a dose of 0.014 rem TEDE at the EAB (Reference 12). This is less than the EPA PAG criterion of 1 rem TEDE and below the 10% EPA PAG threshold for declaration of a Site Area Emergency (SAE), based on the NRC guidance provided in NEI 99-01, Rev.6 (Reference 6).

3.2.2 Liquid Waste Incident A liquid tank failure remains a viable accident following the reactor being permanently defueled since liquid tanks may continue to store radioactive liquid. The accidents discussed in the DSAR include an accidental discharge to the circulating water discharge canal, or failure of the primary system makeup storage tank or the utility water storage tank. The primary makeup storage tank and the utility water storage tank have administrative controls that maintain tank activity concentration such that 10 CFR Part 20, Standards for Protection Against Radiation, dose limits would not be exceeded in the event of a tank failure. These concentration limits will be maintained in the permanently defueled condition.

HDI has concluded that the PNP design and administrative controls ensure that radioactive liquid leakage or spillage will be retained within the facility or within 10 CFR Part 20 dose limits.

Also, administrative controls and automatic interlocks, together with the fail-safe design of the instrumentation and control devices, provide assurance against any discharge of liquid wastes to the environs in excess of 10 CFR Part 20 limits and would not approach the EPA PAG criteria of 1 rem TEDE after a 90-day fuel decay period.

3.2.3 Waste Gas Incident The PNP DSAR evaluates the accidental release of waste gas. The atmospheric dispersion coefficients and the source term for the FHA, discussed in Section 5.2.1 of this Enclosure, bound those of the design basis gas decay tank rupture (GDTR).

The volume control tank rupture accident is no longer applicable in the permanently defueled condition because primary coolant letdown will no longer be required to support primary coolant system operation. In addition, inputs into the volume control tank rupture accident discussed in UFSAR Section 14.21.2, such as letdown flow and dose equivalent iodine-131 requirements will no longer be applicable in the permanently defueled condition. In the event that the volume control tank continues to hold reactor coolant fluid in the permanently defueled condition, the source term would be lower than during normal operation due to radioactive decay. In addition, the primary coolant iodine and noble gas concentrations released to the atmosphere from the volume control tank after 17 days of decay would be significantly less than the source term from the FHA with 17 days of decay and the CR doses from the FHA.

Therefore, it can be concluded that the dose consequences of the FHA bound the dose consequences of the GDTR with the same decay period.

3.2.4 Postulated Cask Drop Accident The PNP DSAR evaluates the postulated cask drop accidents. The analysis included a scenario in which a cask is dropped onto spent fuel which has decayed for 90 days. The scenario assumes the Fuel Handling Building (FHB) charcoal filter is not operating and all

Enclosure Page 6 of 17 radiation is released unfiltered from the FHB. The accident results in a dose of 0.08 rem at the EAB 90 days following permanent cessation of power operations of the PNP reactor. This is less than the EPA PAG criterion of 1 rem TEDE and below the 10% EPA PAG threshold for declaration of a SAE, based on the NRC guidance provided in NEI 99-01, Rev.6 (Reference 6).

3.3 Consequences of a Beyond Design Basis Event 3.3.1 Hottest Fuel Assembly Adiabatic Heatup An adiabatic heatup analysis was performed comparing the heat load limits for the hottest fuel assembly and for a 2X2 group of assemblies stored in the PNP SFP to a criterion proposed in Commission Paper SECY-99-168, Improving Decommissioning Regulations for Nuclear Power Plants," (Reference 13) that is applicable to offsite emergency response for nuclear power reactors in the decommissioning process. This criterion considers the time for the hottest assembly to heat up from 30°C to 900°C adiabatically. A heat up time of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> from the time the spent fuel is uncovered, was determined to be sufficient time to take mitigating actions and, if necessary, offsite protective measures without offsite emergency preplanning addressing the facility.

The analysis for the PNP SFP for beyond design basis events demonstrates that approximately 12 months after shutdown, a minimum of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> is available before the fuel cladding temperature of the hottest fuel assembly in the SFP reaches 900°C with a complete loss of SFP water inventory. As stated in NUREG-1738 (Reference 14), 900°C is an acceptable temperature to use for assessing the onset of fission product release under transient conditions (to establish the critical decay time for determining availability of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to evacuate) if fuel and cladding oxidation occurs in air. Based on the results of the analysis, in the unlikely event of a beyond design basis event, 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> is available to initiate appropriate mitigating actions to restore a means of heat removal to the spent fuel and, if governmental officials deem warranted, for authorities to implement offsite protective actions using a comprehensive approach to emergency planning to protect the health and safety of the public before the hottest fuel assembly reaches the rapid oxidation temperature.

Because of the time it would take for the adiabatic heat up to occur, there is ample time to respond to any partial drain down event that might cause such an occurrence by restoring cooling or makeup, or providing spray. As a result, the likelihood that such a scenario would progress to a zirconium fire is not deemed credible.

These analyses were provided to the NRC in Reference 1.

3.3.2 Spent Fuel Pool Drain Down Event NUREG-0586, Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities, (Reference 15) Supplement 1, Section 4.3.9.2, identifies that a SFP drain down event is a beyond design basis event. The analyses provided in Reference 1 demonstrated that, under adiabatic conditions, a significant release of radioactive material from the spent fuel is not possible within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> from the time the spent fuel is uncovered after approximately 12 months following the permanent cessation of power operation. However, the potential exists for radiation exposure if shielding of the spent fuel in the PNP SFP is lost.

The SFP water and the concrete SFP structure serve as radiation shielding. Therefore, a loss of water shielding above the fuel could increase the offsite radiation levels because of the

Enclosure Page 7 of 17 gamma rays streaming up out of the pool being scattered back to a receptor at the site boundary.

In preparation for the originally planned October 2018 shutdown of the PNP reactor, the radiological consequences of a postulated complete loss of SFP water at the EAB and Control Room were analyzed. It was determined that the gamma radiation dose rate at the EAB would be limited to small fractions of the EPA PAG exposure levels. Based on the analysis, the dose rate to a receptor at the EAB and the limiting dose rate in the PNP Control Room one year after shutdown are less than 0.20 mrem/hour (hr) and 2.5 mrem/hr, respectively. It was determined that this analysis is applicable to the May 2022 shutdown of the PNP reactor (Reference 16).

The EPA PAGs were developed to respond to a mobile airborne plume that could transport and deposit radioactive material over a large area. In contrast, the radiation field formed by scatter from a drained SFP would be stationary rather than moving and would not cause transport or deposition of radioactive materials. The extended period required to exceed the integrated EPA PAG limit of 1 rem TEDE would allow sufficient time to develop and implement onsite mitigative actions and provide confidence that additional offsite measures could be taken without planning if efforts to reestablish shielding over the fuel are delayed.

3.4 Design and Operational Characteristics of the Spent Fuel Pool Although the limited scope of DBAs and the associated dose consequences, and the significant time available to complete actions necessary to mitigate a beyond design basis accident that remain applicable to PNP justify a reduction in the necessary scope of emergency response capabilities, the Industry Decommissioning Commitments (IDCs) and Staff Decommissioning Assumptions (SDAs) contained in NUREG-1738 (Reference 14) were also evaluated.

The IDCs and SDAs are listed in Tables 4.1-1 and 4.1-2, respectively, of NUREG-1738. Tables 4 and 5 of Reference 1 identify how the PNP SFP meets or compares with each of these IDCs and SDAs.

3.5 Consequences of a Beyond Design Basis Earthquake In addition to an evaluation of each IDC and SDA, an analysis demonstrating that there is a High Confidence of Low Probability of Failure (HCLPF) of the PNP SFP was also performed.

Based on this analysis, the probability of seismically induced structural failure of the SFP and rapid loss of inventory is less than the generic bounding value of 1 x 10-5 per year. This analysis was provided to the NRC as Attachment 4 to Reference 1.

4.0 EMERGENCY PLAN AND EMERGENCY ACTION LEVEL SCHEME 4.1 Permanently Defueled Emergency Plan The PDEP, describing HDIs plan for responding to emergencies that may arise while in a permanently shutdown and defueled configuration, is provided as Attachment 1 to this Enclosure. The PDEP was developed considering the guidance contained within Attachment 1 of ISG-02 (Reference 8).

The analyses of the potential radiological impact of accidents while the facility is in a permanently defueled condition indicate that no DBA or reasonably conceivable beyond design basis accident would result in radioactive releases that exceed EPA PAGs (Reference 4)

Enclosure Page 8 of 17 beyond the site boundary or 10% of the EPA PAG, presented as guidance in NEI 99-01, Revision 6, as the threshold to declare a SAE.

The slow progression rate of postulated event scenarios indicate sufficient time is available to initiate appropriate mitigating actions to protect the health and safety of the public. Therefore, the proposed PDEP states that HDI will maintain the ability to assess, classify, and declare an emergency within 30 minutes after the availability of indications that an EAL threshold has been reached. Emergency classifications are required to be made as soon as conditions warranting classification are present and recognizable for the classification in accordance with the applicable EALs, but within 30 minutes after the availability that an EAL has been reached. The proposed PDEP also states that notification of an emergency declaration will be made to appropriate State of Michigan and Van Buren County authorities within 60 minutes of an emergency declaration or change in classification.

Based on the results of the accident analyses described in Reference 1 and Section 3.0 of this Enclosure, the proposed changes to the emergency declaration and notification times and the reduced scope of onsite and offsite emergency response plans can be implemented without undue risk to public health and safety, commensurate with the reduced offsite radiological consequences associated with the permanently defueled and decommissioning status of the facility.

The PDEP addresses the applicable regulations contained in 10 CFR 50.47 and 10 CFR Part 50, Appendix E that remain applicable after modified by the requested exemptions (Reference 1) and is consistent with the applicable guidance established in ISG-02 (Reference 8).

4.1.1 On-Shift and Emergency Response Organization Staffing The PDEP modifies the PNP Post-Shutdown Emergency Plan (PSEP) on-shift and augmenting ERO positions previously approved by the NRC in Reference 3. The proposed on-shift staffing for the PDEP consists of one (1) Shift Manager, one (1) Non-Certified Operator (NCO), and one (1) Radiation Protection Technician. Security personnel are maintained in accordance with the Security Plan. The minimum staff required to conduct routine and immediate emergency mitigation is maintained on-shift on a continuous, 24-hour-per-day basis. The on-shift organization is described in Part 2, Section B, of Attachment 1 to this Enclosure.

In the PDEP, the on-shift organization continues to provide the initial response to an emergency. The Shift Manager declares the initial emergency classification and assumes the role of Emergency Director. The Emergency Director is responsible for directing and coordinating the integrated emergency response effort during the emergency. The PDEP also specifies the non-delegable and delegable responsibilities of the Emergency Director. Members of the on-shift organization are trained on their responsibilities and duties in the event of an emergency and can perform necessary response actions until augmenting personnel arrive or the event is terminated. The on-shift staffing assignments include the roles and responsibilities for their emergency response functions. The relationship between normal and emergency response positions for the on-shift personnel is unchanged when an event occurs. The on-shift staff can perform all required response actions until the augmenting ERO staff arrives.

The PNP ERO is activated at the Alert classification and will augment the on-shift staff within approximately 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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. The minimum

Enclosure Page 9 of 17 augmenting ERO positions consist of a Radiation Protection (RP) Coordinator and a Technical Coordinator.

The staffing proposed in the PDEP is commensurate with the reduced spectrum of credible accidents for a permanently shutdown and defueled facility.

The PDEP further provides that in the event of an emergency at PNP requiring additional personnel and other support resources, the ERO can be augmented with personnel and equipment support from additional facility personnel and offsite organizations. Arrangements will be in place through letters of agreement for ambulance services, treatment of contaminated and injured patients, fire support services, and law enforcement response, as requested by PNP.

4.1.2 Emergency Communications While PNP must maintain the capability to notify offsite government agencies within a specified period, previous exemptions have allowed for extending the time to notify the State and local government agencies to 60 minutes, based on the site-specific justification. HDI proposes to complete emergency notification to the contiguous jurisdictions of the State of Michigan and Van Buren County within 60 minutes after an emergency declaration or a change in classification.

This timeframe is appropriate because there is no need for State or local response organizations to implement pre-planned protective actions. Therefore, commercial communication methods (public/private telephone service and wireless communications) are adequate primary and back-up methods of providing offsite notifications.

As described in the proposed PDEP, offsite notifications will be made via commercial telephone, with wireless communications serving as the backup means of communications with State of Michigan and Van Buren County authorities.

For beyond design basis events, the deployment of offsite resources, including law enforcement, ambulance, and fire/rescue services may be requested by PNP to assist with the onsite response. These requests would be made via direct contact with local response agencies using established communications methods, including the 911 system.

4.1.3 Letters of Agreement Criterion B.9 in Attachment 1 to ISG-02 (Reference 8) states that reference to the arrangements and agreements with support agencies be appended to the plan. As such, Appendix 1 to the proposed PDEP identifies offsite response organizations (ORO) with which HDI will enter into agreements. Details of ORO responsibilities are described in Part 2, Section C of the proposed PDEP, provided as Attachment 1 to this Enclosure. These agreements will identify the emergency measures to be provided, the mutually accepted criteria for implementation, and the arrangements for exchange of information. The agreement between these organizations and HDI will be maintained on file in the PNP Emergency Planning Department.

4.2 Permanently Defueled Emergency Action Level Scheme The current PNP EAL scheme was developed based on the guidance presented in NEI 99-01, Rev. 5 (Reference 5). Attachment 2 to this Enclosure provides the proposed Permanently Defueled EAL Technical Bases Document, containing the site-specific EALs and technical

Enclosure Page 10 of 17 bases for the proposed Permanently Defueled EAL scheme based on guidance provided in NEI 99-01, Rev. 6 (Reference 6).

4.2.1 Operating Modes and Applicability The proposed Permanently Defueled EALs are only applicable in the permanently shutdown and defueled condition, with all irradiated fuel permanently removed from the reactor vessel (and placed in the SFP and ISFSI) and after approximately 12 months having elapsed following the permanent shutdown of the PNP reactor.

4.2.2 Differences and Deviations to this Enclosure provides a cross-reference between each generic EAL contained in NEI 99-01, Revision 6 (Reference 6), and the proposed PNP Permanently Defueled EALs.

Differences are identified in accordance with the guidance provided in NRC Regulatory Issue Summary (RIS) 2003-18, Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels, Revision 4, dated January 2003, (and Supplements 1 and 2) (Reference 17).

RIS 2003-18, Supplement 1 defines differences as follows:

A difference is an EAL change where the basis scheme guidance (NUREG, NUMARC, and NEI) differs in wording but agrees in meaning and intent, such that classification of an event would be the same, whether using the basis scheme guidance or the site-specific proposed EAL. Examples of differences include the use of site-specific terminology or administrative reformatting of site-specific EALs.

An explanation for each difference between the Permanently Defueled EALs and the guidance presented in NEI 99-01, Revision 6, is included in Attachment 3 to this Enclosure. The differences do not alter the meaning or intent of the Initiating Conditions or EALs.

RIS 2003-18, Supplement 1, defines deviations as follows:

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

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

4.3 Coordination with State and Local Governments Because of the geographic location of PNP, emergency planning and responsibilities have historically involved coordination with the State of Michigan; Van Buren, Berrien, and Allegan Counties; and the Covert Township. Decommissioning-related Emergency Plan submittals for PNP have been discussed with cognizant officials from these organizations. These meetings have included discussions of the proposed changes to the PNP PSEP described in this submittal. These discussions have addressed changes to onsite and offsite emergency

Enclosure Page 11 of 17 preparedness throughout the decommissioning process, including the proposed changes pertaining to those agencies that are provided emergency notifications, the proposed 30-minute emergency declaration time, the proposed 60-minute notification time, those agencies participating in the annual review of EALs, and those agencies that would be invited to participate in drills and exercises. The proposed changes to the declaration and notification times were presented to the cognizant officials from the OROs, and no objections to the proposed changes were received. to this Enclosure contains documentation of ORO concurrence with the proposed changes to the PNP PSEP.

Following NRC approval, and prior to implementation of the proposed Permanently Defueled EAL scheme, HDI personnel will provide a review of the emergency classification scheme to State and local government authorities in accordance with 10 CFR Part 50, Appendix E, Section IV.B.1.

5.0 REGULATORY EVALUATION

The proposed PDEP and Permanently Defueled EAL scheme are predicated on the NRC granting approval of requests for exemptions from portions of 10 CFR 50.47(b);

10 CFR 50.47(c)(2); and 10 CFR Part 50, Appendix E, Section IV, submitted in Reference 1, and as such, they do not meet all of the standards of 10 CFR 50.47(b) and the requirements of 10 CFR Part 50, Appendix E. Upon approval of the exemptions requested in Reference 1, the PNP PDEP and Permanently Defueled EAL scheme will meet the remaining applicable planning standards of 10 CFR 50.47(b) and the requirements of 10 CFR Part 50, Appendix E.

5.1 Applicable Regulatory Requirements and Criteria HDI intends to meet the applicable regulatory requirements, discussed below, with the exemptions previously requested in Reference 1. The exemptions requested in Reference 1 are identified using "strikeout" text in the following discussion.

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

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

In 10 CFR 50.47(b), the standards are established that the onsite and offsite emergency response plans must meet for the NRC to make a positive finding that there is reasonable assurance that the licensee can and will take adequate protective measures in the event of a radiological emergency. Planning Standard (4) of this Section (e.g., 10 CFR 50.47(b)(4))

requires that a licensee's emergency response plan contain the following (with exemption):

"A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures."

Enclosure Page 12 of 17 The process for revising Emergency Plans where the changes reduce the effectiveness of the plan is specified in 10 CFR 50.54, Conditions of licenses, paragraph (q)(4). This regulation states the following:

"The changes to a licensee's emergency plan that reduce the effectiveness of the plan as defined in paragraph (q)(1)(iv) of this section may not be implemented without prior approval by the NRC. A licensee desiring to make such a change after February 21, 2012 shall submit an application for an amendment to its license. In addition to the filing requirements of §§ 50.90 and 50.91, the request must include all emergency plan pages affected by that change and must be accompanied by a forwarding letter identifying the change, the reason for the change, and the basis for concluding that the licensee's emergency plan, as revised, will continue to meet the requirements in appendix E to this part and, for nuclear power reactor licensees, the planning standards of § 50.47(b)."

Section IV.B.1 of Appendix E to 10 CFR Part 50 states, in part (with exemption):

"The means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of local and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite [and offsite] monitoring.

By June 20, 2012, for nuclear power reactor licensees, these action levels must include hostile action that may adversely affect the nuclear power plant. The initial emergency action levels shall be discussed and agreed on by the applicant or licensee and state and local governmental authorities, and approved by the NRC. Thereafter, emergency action levels shall be reviewed with the State and local governmental authorities on an annual basis."

Section IV.B.2 of Appendix E states that:

"A licensee desiring to change its entire emergency action level scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change."

Section IV.C.1 of Appendix E (with exemption) requires each Emergency Plan to define the emergency classification levels that determine the extent of the participation of the emergency response organization. EALs are used by plant personnel in determining the appropriate emergency classification level to declare. This Section states, in part (with exemption):

"Emergency action levels (based not only on onsite and offsite radiation monitoring information but also on readings from a number of sensors that indicate a potential emergency, such as the pressure in containment and the response of the Emergency Core Cooling System) for notification of offsite agencies shall be described. The existence, but not the details, of a message authentication scheme shall be noted for such agencies. The emergency classes defined shall include: (1) Notification of unusual events, (2) alert, (3) site area emergency, and (4) general emergency."

Enclosure Page 13 of 17 In November 2012, NEI published NEI 99-01, Revision 6 (Reference 6). The EAL scheme changes requested herein are based on the guidance presented in Revision 6 to NEI 99-01.

The NRC endorsed NEI 99-01, Revision 6, by letter dated March 28, 2013 (Reference 7). The analyses of the potential radiological impact of accidents with PNP in a permanently shutdown and defueled condition indicate that no DBA or reasonably conceivable beyond design basis accident would result in radioactive releases that exceed EPA PAGs beyond the site boundary.

The slow progression rate of postulated event scenarios indicates sufficient time is available to initiate appropriate mitigating actions to protect the health and safety of the public. Therefore, the Permanently Defueled EALs, detailed in NEI 99-01, Revision 6, will be adopted, with certain differences and deviations. Pursuant to 10 CFR Part 50, Appendix E, Section IV.B.2, a revision to an entire EAL scheme must be approved by the NRC prior to implementation.

ISG-02 (Reference 8) contains guidance for NRC staff evaluation of decommissioning Emergency Plans.

The proposed license amendment for PNP is being submitted to the NRC pursuant to 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit, for the purpose of revising the PNP PSEP to establish an Emergency Plan appropriate for a permanently shutdown and defueled facility and to implement a Permanently Defueled EAL scheme.

5.2 No Significant Hazards Consideration Determination The proposed changes would revise the PNP Emergency Plan and Emergency Action Level (EAL) scheme commensurate with the hazards associated with the permanently shutdown and defueled condition of PNP.

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

The discussion below addresses each of these criteria and demonstrates that the proposed license amendment for PNP (hereinafter referred to as "facility" or "the facility") does not constitute a significant hazard.

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

Response: No.

The proposed changes to the PNP Post-Shutdown Emergency Plan (PSEP) and EAL scheme do not impact the function of facility structures, systems, or components. The proposed changes do not affect accident initiators or precursors, nor do they alter design assumptions that could increase the probability or consequences of previously evaluated accidents. The proposed changes do not prevent the ability of the on-shift staff and emergency response organization to perform their intended functions to mitigate the

Enclosure Page 14 of 17 consequences of any accident or event that will be credible in the permanently shutdown and defueled condition.

The probability of occurrence of previously evaluated accidents is not increased because most previously analyzed accidents can no longer occur and the probability of the few remaining credible accidents are unaffected by the proposed changes.

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

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

Response: No.

The proposed changes reduce the scope of the PNP PSEP and EAL scheme commensurate with the hazards associated with a permanently shutdown and defueled facility. The proposed changes do not involve installation of new equipment or modification of existing equipment that could create the possibility of a new or different kind of accident. Hence, the proposed changes do not result in a change to the way the facility or equipment is operated in a manner which could cause a new or different kind of accident initiator to be created.

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

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

Response: No.

Margin of safety is associated with confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public. The proposed changes are associated with the PNP PSEP and EAL scheme and do not impact operation of the facility or its response to transients or accidents. The changes do not affect the Technical Specifications or involve a change in the method of facility operation. No accident analyses or safety analyses acceptance criteria will be affected by the proposed changes. The revised Emergency Plan will continue to provide the necessary response staff commensurate with the reduction in consequences of radiological events at PNP when the facility is in the permanently shutdown and defueled condition, and thus, there is no reduction in the margin of safety.

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

Based on the above, HDI concludes that the proposed changes to the PNP PSEP and EAL scheme present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c) and, accordingly, a finding of no significant hazards consideration is justified.

Enclosure Page 15 of 17 5.3 Precedent The changes to the PNP PSEP and associated EAL scheme, including the change to assess, classify, and declare an emergency within 30 minutes, and the change to notify responsible state and local governmental agencies no longer than 60 minutes after the emergency classification, are consistent with changes to Emergency Plans and EALs that have recently been approved by the NRC for other nuclear power facilities transitioning to a permanently shutdown and defueled condition. Specifically, the NRC approved similar changes to: 1)

NextEra Energy for Duane Arnold Energy Center on April 28 2021 (Reference 18); 2) Exelon Generations (Exelon) Three Mile Island Nuclear Station, Unit 1 (TMI-1) (Reference 19), and 3)

Entergy for the Pilgrim Nuclear Power Station (Pilgrim) on January 2, 2020 (Reference 20).

5.4 Conclusion Based on the analyses and considerations described above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

S This amendment request meets the eligibility criteria for categorical exclusion from environmental review set forth in 10 CFR 51.22, Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review, paragraph (c)(9) as follows:

(i) The amendment involves no significant hazard consideration.

As described in Section 5.2 of this evaluation, the proposed amendment involves no significant hazards consideration.

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

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

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

The proposed amendment does not involve a significant increase in individual or cumulative occupational radiation exposure.

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

Enclosure Page 16 of 17

7.0 REFERENCES

1. Holtec Decommissioning International, LLC (HDI) letter to U.S. Nuclear Regulatory Commission (NRC), "Request for Exemptions from Certain Emergency Planning Requirements of 10 CFR 50.47 and 10 CFR Part 50, Appendix E," dated July 11, 2022 (ADAMS Accession No. ML22192A134)

2. Entergy Nuclear Operations, Inc. letter to U.S. Nuclear Regulatory Commission, "Certifications of Permanent Cessation of Power Operations and Permanent Removal of Fuel from the Reactor Vessel," dated June 13, 2022 (ADAMS Accession No. ML22164A067)

3. U.S. Nuclear Regulatory Commission letter to Entergy Nuclear Operations, Inc.,

"Palisades Nuclear Plant - Issuance of Amendment Re: Changes to the Emergency Plan for Permanently Defueled Condition (CAC No. MG0198; EPID L-2017-LLA-0305),"

dated September 24, 2018 (ADAMS Accession No. ML18170A219)

4. U.S. Environmental Protection Agency, "Protective Action Guides and Planning Guidance for Radiological Incidents," EPA-400/R-17-001 (EPA PAG Manual), dated January 2017

5. Nuclear Energy Institute (NEI) 99-01, Revision 5, "Methodology for Development of Emergency Action Levels," dated February 22, 2008 (ADAMS Accession No. ML080450149)

6. NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors," dated November 21, 2012 (ADAMS Accession No. ML12326A805)

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

8. NRC NSIR/DPR-ISG-02, Interim Staff Guidance, "Emergency Planning Exemption Requests for Decommissioning Nuclear Power Plants," dated May 11, 2015 (ADAMS Accession No. ML14106A057)

9. U.S. Nuclear Regulatory Commission letter to Entergy Nuclear Operations, Inc.,

"Palisades Nuclear Plant - Issuance of Amendment No. 272 Re: Permanently Defueled Technical Specifications (EPID L-2021-LLA-0099)," dated May 13, 2022 (ADAMS Accession No. ML22039A198)

10. Entergy Nuclear Operations, Inc. letter to U.S. Nuclear Regulatory Commission, "License Amendment Request to Revise Renewed Facility Operating License and Technical Specifications for Permanently Defueled Condition," dated June 1, 2021 (ADAMS Accession No. ML21152A109)

11. NRC Regulatory Guide 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," dated July 31, 2000 (ADAMS Accession No. ML003716792)

12. EC-92748, Clarify Implications of PDTS FHA Analysis EA-EC89582-01 for PDEP

Enclosure Page 17 of 17

13. NRC, Commission Paper SECY-99-168, "Improving Decommissioning Regulations for Nuclear Power Plants," dated June 30, 1999 (ADAMS Accession No. ML992800087)

14. NRC NUREG-1738, "Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants," dated February 28, 2001 (ADAMS Accession No. ML010430066)

15. NRC NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities," dated November 2002 (ADAMS Accession Nos.

ML023470304, ML023470323, ML023500187, ML023500211, ML023500223)

16. EC-92900, Clarify Applicability of EA-EC72870-01 to May 2022 Shutdown

17. NRC Regulatory Issue Summary 2003-18, "Use of Nuclear Energy Institute (NEI) 99-01,

'Methodology for Development of Emergency Action Levels,'" Revision 4 dated January 2003 (ADAMS Accession No. ML032580518), Supplement 1 dated July 13, 2004 (ADAMS Accession No. ML041550395), and Supplement 2 dated December 12, 2005 (ADAMS Accession No. ML051450482)

18. NRC letter to NextEra Energy, Duane Arnold Energy Center - Issuance of Amendment No. 313 Regarding Changes To The Emergency Plan To Reflect The Permanently Defueled Condition And Make Changes To The Emergency Action Level Scheme (EPID L-2020-LLA-0113), dated April 28, 2021 (ADAMS Accession No. ML21098A166)

19. NRC letter to Exelon Generation Company, LLC, Three Mile Island Nuclear Station, Units 1 and 2 - Issuance of Amendment No. 299 for Unit 1 Re: Permanently Defueled Emergency Plan and Emergency Action Level Scheme Changes (EPID L-2019-LLA-0144), dated December 2, 2020 (ADAMS Accession No. ML20261H925)

20. NRC letter to Entergy, "Pilgrim Nuclear Power Station - Issuance of Amendment No.

251 Re: Changes to the Emergency Plan for Permanently Defueled Emergency Plan and Emergency Action Level Scheme (EIPD L-2018-LLA-0221)," dated January 2, 2020 (ADAMS Accession No. ML19274C674)

Attachment 1 to Enclosure HDI PNP 2022-016 Permanently Defueled Emergency Plan

HDI PNP 2022-016 Enclosure, Attachment 1 Page 1 of 57 Procedure No PDEP Revision 0 Effective Date: TBD PALISADES NUCLEAR PLANT PERMANENTLY DEFUELED EMERGENCY PLAN TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Approved: /

Procedure Sponsor Date Process Applicability Exclusion New Procedure/Revision Summary:

Issued the Permanently Defueled Emergency Plan (PDEP) to incorporate NRC's approval of the exemptions requested by letter dated July 11, 2022, whereby Holtec Decommissioning International, LLC. (HDI), on behalf of Holtec Palisades, LLC, requested exemptions from portions of 10 CFR 50.47(b); 10 CFR 50.47(c)(2); and 10 CFR Part 50, Appendix E reflecting the reduced scope of the emergency planning requirements consistent with the permanently shutdown and defueled condition of the Palisades Nuclear Plant (PNP) reactor.

The NRC has docketed certification that all fuel has been permanently removed from the PNP reactor vessel and placed into the spent fuel pool (SFP), in accordance with 10 CFR 50.82(a)(2). The license for PNP no longer authorizes operation of the reactor, nor emplacement or retention of fuel into the reactor vessel. The irradiated fuel will be stored in the SFP and in dry cask storage at the onsite Independent Spent Fuel Storage Installations (ISFSIs) until it is shipped offsite.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 2 of 57 PDEP Revision 0 Page ii TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Table of Contents Page SOURCES AND REFERENCES .................................................................................... 6 SOURCE DOCUMENTS ........................................................................................... 6 REFERENCE DOCUMENTS ..................................................................................... 6 Part I: INTRODUCTION Section A: Purpose .................................................................................................... 7 Section B: Background .............................................................................................. 7 Section C: Scope ........................................................................................................ 8 Section D: Planning Basis ......................................................................................... 9 Part II: PLANNING STANDARDS AND CRITERIA Section A: Assignment of Responsibility .............................................................. 11

1. PNP Emergency Response and Responsibilities ............................................... 11

2. Offsite Response Organizations ......................................................................... 12 Section B: Emergency Response Organization..................................................... 13

1. PNP Emergency Response Organization ........................................................... 13 1.1 Normal Plant Organization ....................................................................... 13 1.2 Augmenting ERO ..................................................................................... 15

2. Offsite Emergency Assistance ............................................................................ 16 Section C: Emergency Response Support and Resources .................................. 19

1. Support Provided by Local Organizations .......................................................... 19 1.1 Law Enforcement ..................................................................................... 19 1.2 Ambulance Service .................................................................................. 19 1.3 Hospital .................................................................................................... 19 1.4 Fire........................................................................................................... 19

2. State and County (Local) Government Response .............................................. 19

3. Federal Response Support and Resources........................................................ 20

4. Letters of Agreement .......................................................................................... 20 Section D: Emergency Classification System........................................................ 21

1. Emergency Classification System ...................................................................... 21

HDI PNP 2022-016 Enclosure, Attachment 1 Page 3 of 57 PDEP Revision 0 Page iii TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN 1.1 Unusual Event ......................................................................................... 22 1.2 Alert ......................................................................................................... 22

2. Postulated Accidents .......................................................................................... 22

3. State and Local Governmental Authorities ......................................................... 22 Section E: Notification Methods and Procedures ................................................. 23

1. ORO Notification................................................................................................. 23 1.1 Initial Notification ...................................................................................... 23 1.2 Follow-up Messages ................................................................................ 24

2. Notification of the NRC ....................................................................................... 24

3. Notification of the PNP ERO ............................................................................... 24 Section F: Emergency Communications ............................................................... 25

1. Description of Primary and Backup Communications Systems .......................... 25 1.1 Public Address System ............................................................................ 25 1.2 Commercial Telephone Systems ............................................................. 25 1.3 Radio System .......................................................................................... 26

2. Medical Communications ................................................................................... 26

3. Communications Drills and Testing .................................................................... 26 Section G: Public Education and Information ........................................................ 27 Section H: Emergency Facilities and Equipment .................................................. 28

1. Control Room ..................................................................................................... 28

2. Emergency Onsite Monitoring Systems.............................................................. 28 2.1 Radiological Monitors............................................................................... 28 2.2 Process Instrumentation .......................................................................... 29

3. Facility and Equipment Readiness ..................................................................... 29

4. Emergency Equipment and Supplies.................................................................. 29 Section I: Accident Assessment............................................................................ 31

1. Radiological Assessment ................................................................................... 31

2. Dose Assessment............................................................................................... 31

3. Corrective Actions .............................................................................................. 32 Section J: Protective Actions ................................................................................. 33

HDI PNP 2022-016 Enclosure, Attachment 1 Page 4 of 57 PDEP Revision 0 Page iv TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN

1. Notification of Onsite Personnel ......................................................................... 33

2. Assembly ............................................................................................................ 33

3. Accountability ..................................................................................................... 33

4. Radiological Monitoring ...................................................................................... 34

5. Provisions for the Protection of Onsite Personnel .............................................. 34 Section K: Radiological Exposure Control ............................................................ 35

1. Emergency Exposure Guidelines ....................................................................... 35

2. Emergency Radiological Control Program .......................................................... 36

3. Personnel Monitoring.......................................................................................... 37

4. Decontamination and First Aid............................................................................ 37

5. Contamination Control Measures ....................................................................... 38

6. Drinking Water and Food Supplies ..................................................................... 38

7. Return of Areas and Items to Normal Use .......................................................... 38 Section L: Medical and Public Health Support ...................................................... 39 Section M: Re-Entry and Recovery Planning ......................................................... 40

1. Re-Entry ............................................................................................................. 40

2. Recovery ............................................................................................................ 40

3. Recovery Organization ....................................................................................... 41 Section N: Drill and Exercise Program ................................................................... 43

1. Exercises ............................................................................................................ 43

2. Drills ................................................................................................................... 43 2.1 Communication Drills or Surveillances..................................................... 43 2.2 Fire Drills .................................................................................................. 44 2.3 Medical Emergency Drills ........................................................................ 44 2.4 Radiation Protection Drills........................................................................ 44

3. Conduct of Drills and Exercises .......................................................................... 44 Section O: Emergency Response Training ............................................................ 45

1. Emergency Response Training .......................................................................... 45 1.1 ERO Training ........................................................................................... 45 1.2 First Aid Response .................................................................................. 46

HDI PNP 2022-016 Enclosure, Attachment 1 Page 5 of 57 PDEP Revision 0 Page v TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN 1.3 Fire Response ......................................................................................... 46 1.4 Security .................................................................................................... 46

2. General, Initial, and Periodic Training Program Maintenance ............................ 46

3. Local Support Service Personnel Training ......................................................... 46

4. Training Records ................................................................................................ 47 Section P: Responsibility for the Maintenance of the Planning Effort ................ 48

1. Responsibility for Development and Maintenance of the PDEP ......................... 48 1.1 Palisades Nuclear Plant Vice President ................................................... 48 1.2 Manager Responsible for Emergency Planning ....................................... 48 1.3 Emergency Planning Personnel............................................................... 49

2. Emergency Plan Review and Revision ............................................................... 49

3. Emergency Implementing Procedures................................................................ 50

4. Letters of Agreement .......................................................................................... 50

5. Cross-Reference to Planning Criteria ................................................................. 50

6. Review of the Emergency Preparedness Program ............................................. 50

7. Emergency Telephone Directory ........................................................................ 50

8. Inventory and Maintenance of Emergency Equipment ....................................... 50 Appendix 1: Letters of Agreement ........................................................... Appendix-1-1 Appendix 2: Cross-Reference Sections of the PDEP to Emergency Planning Procedures ........................................................... Appendix-2-1 Appendix 3 Abbreviations and Definitions ............................................ Appendix-3-1 Abbreviations .......................................................................... Appendix-3-1 Definitions ............................................................................... Appendix-3-2

HDI PNP 2022-016 Enclosure, Attachment 1 Page 6 of 57 PDEP Revision 0 Page 6 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN SOURCES AND REFERENCES SOURCE DOCUMENTS

1. U.S. Nuclear Regulatory Commission (NRC), NSIR/DPR-ISG-02, Interim Staff Guidance, "Emergency Planning Exemption Requests for Decommissioning Nuclear Power Plants," (ADAMS Accession No. ML14302A490), dated May 11, 2015

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

dated November 2012 REFERENCE DOCUMENTS

1. Palisades Nuclear Plant Emergency Implementing Procedure

2. 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities"

3. Palisades Defueled Safety Analysis Report

4. Palisades Safeguards Contingency Procedures

5. Palisades Health Physics Procedures

6. Palisades Fire Protection Plan

7. Palisades Administrative Procedure 4.00, "Operations Organization, Responsibilities and Conduct"

8. EN-OM-119, "On-Site Safety Review Committee"

HDI PNP 2022-016 Enclosure, Attachment 1 Page 7 of 57 PDEP Revision 0 Page 7 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN INFORMATIONAL USE

• Procedure is available and referenced for review, but not necessarily at the work location.

• Procedure may be performed from memory or referred to as needed.

• User remains responsible for procedure adherence.

Part I: INTRODUCTION Section A: Purpose The purpose of this Permanently Defueled Emergency Plan (PDEP) is to assure an adequate level of response to cope with the spectrum of emergencies, including the means to minimize radiation exposure to facility personnel. This PDEP integrates the necessary elements to provide effective emergency response considering cooperation and coordination of organizations expected to respond to potential emergencies.

Section B: Background Description of the Palisades Nuclear Plant The Palisades Nuclear Plant (PNP) is located in Covert Township, Van Buren County, Michigan. The Plant is bordered to the north by the Van Buren State Park and to the west by Lake Michigan. Areas to the south and east of PNP are sparsely populated, underdeveloped, or used for farming. Interstate 196 and the Blue Star Highway lie within one mile east of the site. Much of the area around the site is devoted to recreation and tourism, which produces a fluctuating and seasonal population.

PNP was permanently shut down on May 20, 2022, and permanently defueled on June 10, 2022. The 10 CFR 50.82(a)(1) certifications for PNP have been submitted to, and docketed by, the NRC. Therefore, the PNP Renewed Facility License no longer authorizes operation of the reactor or emplacement or retention of fuel in the reactor vessel. A detailed description of PNP is contained in the PNP Defueled Safety Analysis Report (DSAR).

Exclusion Area HDI has the authority within the Exclusion Area to determine all activities including the exclusion or removal of personnel and property. Provisions for control of access to the PNP site have been included in the Safeguards Contingency Procedures to address personnel entering for business purposes and for those who might inadvertently enter.

Access to the exclusion areas of PNP is controlled by the facilitys security force.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 8 of 57 PDEP Revision 0 Page 8 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Highway access to PNP is provided from the Blue Star Highway (A-2) via the plant access road.

Protected Area A Security fence marks the perimeter of the Protected Areas of the site. Access beyond the fence is restricted to badged employees or escorted visitors. The permanently shut down reactor and the Independent Spent Fuel Storage Facilities (ISFSIs) are located within the Protected Area boundaries.

A PNP Site Map is included as Figure 1.

Section C: Scope The PDEP has been developed to respond to potential emergencies at PNP considering the permanently shut down and defueled status of the reactor. There are no postulated design basis accidents (DBAs) that would result in dose consequences that are large enough to require pre-planned offsite protective actions. In the unlikely event of a beyond design basis event, a minimum of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> is available to initiate appropriate mitigating actions to restore a means of heat removal to the spent fuel and, if governmental officials deem warranted, for authorities to implement offsite protective actions using a comprehensive approach to emergency planning to protect the health and safety of the public before the hottest fuel assembly reaches the rapid oxidation temperature. Therefore, the overall scope of this PDEP delineates the actions necessary to safeguard onsite personnel and minimize damage to property.

If an emergency were to occur, the PNP Emergency Response Organization (ERO) (as defined in this PDEP) would be put in place and maintained until such time that PNP is returned to a stable condition.

This PDEP describes the operation of the PNP ERO. It does not, nor is it intended to provide guidance for plant equipment manipulations.

An emergency recovery phase is also described in this PDEP.

The concepts presented in this PDEP address the applicable regulations stipulated in 10 CFR 50.47, "Emergency Plans" and 10 CFR Part 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," as exempted.

Exemptions from select portions of 10 CFR 50.47 and 10 CFR 50, Appendix E, were granted by the NRC on [insert date] (ADAMS Accession Number: ML[insert #]. The PDEP is consistent with guidelines established in NRC staff guidance for the evaluation of Permanently Defueled Emergency Plans provided in Attachment 1 of NSIR/DPR-ISG-02, Interim Staff Guidance: Emergency Planning Exemption Requests for

HDI PNP 2022-016 Enclosure, Attachment 1 Page 9 of 57 PDEP Revision 0 Page 9 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Decommissioning Nuclear Power Plants (ISG-02). Appendix 2 of this PDEP contains a cross-reference to PNP Emergency Implementing Procedures and the applicable guidance in ISG-02.

Abbreviations and acronyms used in this PDEP are included in Appendix 3.

Section D: Planning Basis Irradiated fuel is stored in the PNP ISFSIs and in the PNP spent fuel pool (SFP). No reactor operations can take place and the facility is prohibited from emplacement or retention of fuel in the reactor vessel.

The analyses of the potential radiological impacts of postulated DBAs indicate 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 EPAs PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incidents, (EPA-400/R-17/001) dated January 2017. Additionally, the slow progression rate of beyond design basis accidents indicate sufficient time is available to initiate appropriate mitigating actions to protect the health and safety of the public.

The PNP ISFSI contains multiple spent fuel storage cask system designs which are designed to ensure protection of public health and safety through use of physical barriers to guard against the uncontrolled release of radioactivity and through the use of shielding to minimize radiation dose to the public from both normal and off-normal conditions of operation. The analyses summarized in each cask system's applicable Final Safety Analysis Report (FSAR) demonstrate that under assumed accident conditions, the consequences of accidents challenging the integrity of the barriers will not exceed limits established in 10 CFR 72.106. The regulatory requirements for an ISFSI emergency plan are specified in 10 CFR 72.32. In accordance with 10 CFR 72.32(c)(1), the emergency plan required by 10 CFR 50.47 satisfies the requirements for an emergency plan for an ISFSI which is located onsite, and therefore a separate ISFSI emergency plan is not required.

This PDEP documents the methods by which the PNP Emergency Preparedness Program meets the criteria set forth in 10 CFR Part 50, Section 47(b), and Appendix E, as exempted.

The PDEP, Revision 0, was approved per NRC Safety Evaluation in License Amendment [insert #] dated [Insert date].

HDI PNP 2022-016 Enclosure, Attachment 1 Page 10 of 57 PDEP Revision 0 Page 10 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN FIGURE 1 Palisades Nuclear Plant Site Map

HDI PNP 2022-016 Enclosure, Attachment 1 Page 11 of 57 PDEP Revision 0 Page 11 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Part II: PLANNING STANDARDS AND CRITERIA Section A: Assignment of Responsibility Primary responsibilities for emergency response have been assigned. The emergency responsibilities of the various supporting organizations have been specifically established, and each principal response organization has staff to respond and to augment its initial response on a continuous basis.

1. PNP Emergency Response and Responsibilities HDI has established an ERO, consisting of on-shift and augmenting positions, to respond to emergencies. During an emergency, the normal on-shift organization initially functions as the ERO and is referred to as the On-Shift ERO. The minimum on-shift PDEP staffing requirements are described in Part 2, Section B of this Plan.

The On-Shift ERO performs the following functions:

• Control and operation of facility activities

• Mitigation of the emergency condition

• Protection of facility personnel

• Emergency event classification

• Radiological monitoring and dose assessment

• Emergency notification to, and ongoing communications with, Federal, State, and local emergency response organizations

• Coordination of emergency support for firefighting, security, and rescue/first aid The on-shift staff can perform all required Emergency Plan functions until augmented by additional personnel.

In accordance with Permanently Defueled Technical Specifications (PDTS), one (1)

Shift Manager is assigned on a continuous 24-hour-per-day basis and is the senior management position at PNP during off-hours. This position is responsible for monitoring facility conditions and managing the activities at PNP.

When an off-normal, natural phenomenon, or accident event becomes apparent, the Shift Manager shall assess the condition; make an emergency declaration, if appropriate; and assume the position of Emergency Director, with the overall responsibility to direct and control the emergency response. The Emergency Director does not have concurrent duties which conflict with these responsibilities.

The on-shift staff positions described in Part 2, Section B of this Plan are staffed on a continuous 24-hour-per-day basis.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 12 of 57 PDEP Revision 0 Page 12 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Upon declaration of an Alert emergency classification, or at the direction of the Emergency Director, additional personnel will be activated to augment the On-Shift ERO.

The functions assigned to the On-Shift and Augmenting ERO positions are specified in Part 2, Section B of this Plan. The ERO maintains the depth, qualifications, and capability for continuous 24-hour coverage of the emergency response for a protracted period. The Emergency Director has the authority and is responsible for maintaining and ensuring the continuity of personnel and resources.

2. Offsite Response Organizations Offsite Response Organizations (OROs) (i.e., local law enforcement support; medical and ambulance services, including hospital support; and fire/rescue support) may be requested to respond to an emergency at PNP. The Emergency Director is responsible for requesting and coordinating the response provided by the OROs with the onsite activities. The OROs described in this PDEP are capable of 24-hour emergency response. Details related to the anticipated support from each ORO are described in Part 2, Section C of this Plan.

Letters of Agreement (LOAs) are listed in Appendix 1 and are addressed in Part 2, Section C of this Plan.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 13 of 57 PDEP Revision 0 Page 13 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Section B: Emergency Response Organization Key ERO positions and associated responsibilities for each position are outlined below.

The PNP ERO provides for an initial emergency response and timely augmentation of on-shift personnel, when required. The interface among PNP response personnel and OROs has been previously arranged.

1. PNP Emergency Response Organization Table B-1, Emergency Response Organization Minimum Staffing Requirements, outlines the minimum staffing required for emergency response. The ERO may be activated, in part or in whole, at any time at the discretion of the Emergency Director.

Figure B-1 illustrates the overall ERO.

1.1 Normal Plant Organization The normal on-shift staff organization for PNP is specified in PDTS and detailed in Site Administrative Procedures. The normal plant organization functions 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s-per-day, seven days-per-week. Members of the on-shift staff are trained on their responsibilities and duties in the event of an emergency and can perform initial emergency response actions until augmented by additional staff.

The minimum staff required to conduct routine tasks and immediate emergency mitigation is maintained at the facility on a continuous basis. The following positions comprise the On-Shift ERO, and are the minimum on-shift staff positions required to implement the PDEP:

(1) Shift Manager In accordance with PDTS, one (1) Shift Manager is assigned. The Shift Manager is qualified as a Certified Fuel Handler (CFH) and manages on-shift personnel during the shift.

The position is responsible for assuring that all activities are conducted in accordance with approved procedures and the limitations set forth in the PDTS. 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 an emergency and assume the position of Emergency Director upon declaration of an emergency.

Upon declaration of an emergency, the Emergency Director is responsible for directing and coordinating the integrated emergency response effort during the emergency.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 14 of 57 PDEP Revision 0 Page 14 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Specific responsibilities include:

• Declaring and upgrading the emergency as warranted (non-delegable);

• Reviewing and approving notifications to the State and Local authorities (non-delegable);

• Authorizing emergency radiological exposure in excess of 10 CFR Part 20 limits (non-delegable);

• Maintaining command and control of the emergency;

• Ensuring proper communications between the ERO and OROs;

• Reviewing all radiological, meteorological, and operational data and updating the offsite authorities, as necessary;

• Requesting any special assistance or services;

• Directing actions to mitigate the accident;

• Authorizing the mobilization of search and rescue teams;

• Directing accountability within the protected area;

• Releasing non-essential personnel from the site; and

• Initiating the recovery phase when appropriate.

The Emergency Director is assisted in these activities by the On-Shift and Augmenting ERO. However, those tasks which the Emergency Director cannot delegate to others are identified above.

The Emergency Director has the authority to suspend any security measure described in the Physical Security Plan as necessary to facilitate response to emergency conditions.

(2) Non-Certified Operator In accordance with the PDTS, one (1) Non-Certified Operator (NCO) is assigned to the duty shift.

The NCO performs facility operations, minor maintenance activities, and monitoring under the direction of the Shift Manager. Upon declaration of an emergency, the NCO assists the Emergency Director with implementation of this Plan.

(3) Radiation Protection Technician One (1) on-shift Radiation Protection (RP) Technician is on-shift at PNP on a continuous basis. The on-shift RP Technician performs radiation monitoring, surveillance, and decontamination as necessary. The on-shift RP Technician can perform emergency duties for any declared emergency

HDI PNP 2022-016 Enclosure, Attachment 1 Page 15 of 57 PDEP Revision 0 Page 15 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN at PNP. Upon declaration of emergency, the on-shift RP Technician reports to the Emergency Director to support implementation of this Plan.

(4) Security staff (per Security Plan)

The Security organization maintains site security and access in accordance with site security procedures, while working under the direction of the Emergency Director and the Security Shift Leader.

1.2 Augmenting ERO Personnel designated to augment the on-shift ERO are part of the Augmenting ERO. The Augmenting ERO is established to assure that qualified personnel are available on a 24-hour-per-day, 7-day-per-week basis to respond to emergency situations.

During an emergency at PNP, the initial phase of the response is managed by the On-Shift ERO. Following an Alert emergency declaration, or at the discretion of the Emergency Director, the Augmenting ERO is notified using a callout process, including onsite public address announcements.

Personnel assigned to the Augmenting ERO augment the On-Shift ERO within 120 minutes of an Alert declaration.

A partial or complete activation of the Augmenting ERO may be implemented at a Notification of Unusual Event (Unusual Event) classification (refer to Part 2, Section D of this Plan), at the discretion of the Emergency Director.

The Augmenting ERO consists of the following positions:

(1) Technical Coordinator Upon activation, the Technical Coordinator, reports to the Emergency Director. The responsibilities of the Technical Coordinator when implementing this Plan include:

• evaluating technical data pertinent to facility conditions;

• augmenting the ERO staff as deemed necessary;

• designating engineering support, as necessary, to evaluate facility conditions and provide technical support;

• recommending mitigation and corrective actions;

• assisting with search and rescue;

• coordinating maintenance and equipment restoration;

HDI PNP 2022-016 Enclosure, Attachment 1 Page 16 of 57 PDEP Revision 0 Page 16 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN

• establishing and maintaining communications with offsite organizations as desired by the Emergency Director; and

• maintaining a record of event activities.

(2) Radiation Protection Coordinator Upon activation, the Radiation Protection Coordinator reports to the Emergency Director. The responsibilities of the Radiation Protection Coordinator when implementing this Plan include:

• monitoring personnel accumulated dose;

• advising the Emergency Director concerning Radiological Emergency Action Levels (EALs);

• augmenting the ERO staff as deemed necessary;

• establishing radiological controls;

• directing radiological monitoring analysis;

• performing dose assessment;

• coordinating decontamination activities; and

• maintaining a record of event activities.

2. Offsite Emergency Assistance Offsite organizations may respond to a declared emergency at PNP. Each of these organizations are capable of 24-hour-per-day, 7-day-per-week response and operation. The details of their responsibilities are described in Part 2, Section C of this Plan, and are contained in their respective LOAs, listed in Appendix 1.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 17 of 57 PDEP Revision 0 Page 17 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Table B-1 Emergency Response Organization Minimum Staffing Requirements AUGMENTING MAJOR FUNCTIONAL MAJOR TASKS POSITION # ON-SHIFT CAPABILITY AREA (120 MIN.)

Plant Operations and Plant Operations Shift Manager 1* a -

Assessment of Operational NCO 1* b Aspects Emergency Direction & Emergency Director Shift Manager *** -

Control Notification/Communication Notify offsite Shift Manager *** -

personnel and maintain communications Radiological Accident Onsite Dose Radiation *** 1 Assessment and Support of Assessment and Protection Operational Accident Monitoring Coordinator Assessment Protective Actions In-Plant Surveys RP Technician 1* As needed (In-Facility) Radiation Protection

a. Access Control

b. Health Physics Coverage for Repair, Corrective Actions, Search and Rescue, First Aid, and Firefighting

c. Personnel Monitoring

d. Dosimetry Engineering Support Technical Direction Technical - 1 Coordinator Plant Condition Evaluation, Repair, Mitigation, ***

Repair, and Corrective Action and Corrective Action Firefighting Firefighting Per the Fire Protection Plan Offsite Rescue Operations/First Aid Rescue and First Aid *** Response Organizations**

Security Security Per the Security Plan -

a Upon declaration of an emergency, the Shift Manager assumes the role of Emergency Director.

b Upon declaration of an emergency, the NCO assists the Emergency Director with implementation of the PDEP.

• 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 the response capability of the ORO.

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

HDI PNP 2022-016 Enclosure, Attachment 1 Page 18 of 57 PDEP Revision 0 Page 18 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN FIGURE B-1 Emergency Response Organization On-Shift ERO Positions Shift Manager/

Emergency Director (1)

Security Force Non-Certified Radiation (Per Security Operator Protection Plan) (1) Technician (1)

Augmenting ERO Positions Technical Radiation Protection Coordinator (1) Coordinator (1)

Federal State/Local Local Services Agencies Agencies

(#) Denotes number of staff assigned to position

HDI PNP 2022-016 Enclosure, Attachment 1 Page 19 of 57 PDEP Revision 0 Page 19 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Section C: Emergency Response Support and Resources Arrangements for requesting and effectively using resources have been made and other organizations capable of augmenting the planned response have been identified.

1. Support Provided by Local Organizations The availability of local support services to assist with the emergency response has been ascertained and LOAs from each organization described below have been obtained. All support is provided utilizing the National Incident Management System (NIMS) and the Incident Command System (ICS).

1.1 Law Enforcement When notified that assistance is required, the Michigan State Police, Van Buren County Sheriff Department, and the Covert Township Police Department may provide law enforcement assistance. Coordination of security matters is addressed in the Security Safeguards Contingency Plan and Incident Response Plan.

1.2 Ambulance Service Ambulance service for the transportation of accident victims, including radioactively contaminated victims, is provided by the Covert Fire Department. This service is available on a 24-hour-per-day basis. Onsite procedures contain instructions that cover the call for assistance and the handling of the ambulance service personnel.

1.3 Hospital The Bronson South Haven Hospital, located in South Haven, Michigan, approximately 6 miles from PNP, has agreed to accept patients from PNP who have been injured, contaminated, or irradiated. The hospital provides facilities such as an emergency room, a laboratory, a radiology department, and a nuclear medicine department.

1.4 Fire Fire protection response will be provided by the Covert Fire Department with mutual aid provided by the Van Buren County Mutual Aid Pact.

2. State and County (Local) Government Response Except for emergency notifications described in Part 2, Section E of this Plan, and the services described in Part 2, Section C, Paragraph 1 of this Plan, no specific coordination with the State of Michigan or the counties surrounding PNP is required.

State and local response to an emergency will be performed in accordance with each organizations plans and procedures.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 20 of 57 PDEP Revision 0 Page 20 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN

3. Federal Response Support and Resources The NRC is notified via a dedicated telephone line (Emergency Notification System (ENS)) from the Control Room within one hour of an emergency classification. The NRC is responsible for the coordination of the federal government's technical response activities and will act as the lead Federal agency providing coordination and support in response to a nuclear incident, in accordance with the National Response Framework (NRF). This PDEP does not rely upon NRF resources.

However, the Emergency Director is authorized to request Federal assistance, as needed.

The PNP Control Room has space available to accommodate limited NRC response team members.

4. Letters of Agreement Local support service arrangements have been made with offsite groups to provide onsite aid in the event of an emergency situation. Support services encompass such areas as medical assistance, fire control, ambulance services, and law enforcement. Written agreements are entered into to assure these individuals'/agencies'/organizations' availability and capabilities. In the written agreements, the agencies have outlined their responsibilities or have agreed to their responsibilities as outlined in this section. A listing of the letters of agreement, contracts, or signature pages has been included in Appendix 1. In those cases where agency assistance is mandated by law (i.e., the State of Michigan), a letter of agreement may be excluded from the PDEP.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 21 of 57 PDEP Revision 0 Page 21 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Section D: Emergency Classification System A standard emergency classification and EAL scheme is in use and is based on a variety of criteria including instrument readings and status indications; observable events; results of calculations and analyses; entry into procedures; and the occurrence of natural phenomena. This section describes the emergency classification and EAL scheme used to determine the minimum response to an abnormal event at PNP. This scheme is based on systems, effluent parameters, and operating procedures.

1. Emergency Classification System The emergency classification system is based on consideration of conceivable consequences of potential situations ranging from incidents where effects on the facility and personnel are negligible to highly unlikely releases of radioactivity. The emergency classification of these conditions, both radiological and non-radiological, indicates the relative severity for immediate implementation of response actions.

The emergency classification levels (ECL) applicable to PNP, in order of increasing severity, are: Unusual Event and Alert.

The permanently defueled emergency classification system is developed consistent with guidance presented in NEI 99-01, Development of EALs for Non-Passive Reactors, Revision 6. Appendix C of NEI 99-01, Revision 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 emergency classification system referenced in NEI 99-01, Revision 6, has been endorsed by the NRC and provides a standard method for classifying emergencies.

HDI maintains the capability to assess, classify, and declare an emergency condition within 30 minutes after the availability of indications to plant personnel that an EAL threshold has been exceeded. The Shift Manager promptly declares the emergency condition as soon as possible following identification of the appropriate ECL.

Once an emergency is declared it shall remain in effect until:

1. Conditions warrant termination of the event and entry into the Recovery Phase.

2. The event is re-classified at a higher level. Incidents may be classified as a Unusual Event first, and then upgraded to an Alert if the situation deteriorates.

The following subsections summarize each ECL. Refer to the Permanently Defueled Emergency Action Level Technical Bases Document for parameter values,

HDI PNP 2022-016 Enclosure, Attachment 1 Page 22 of 57 PDEP Revision 0 Page 22 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN annunciators, and equipment status used by the Shift Manager / Emergency Director to classify emergencies.

1.1 Unusual Event A Unusual Event classification is used to denote events that are in progress or have occurred, which indicate a potential degradation of the level of safety of the facility or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation occurs.

The purpose of this classification is to assure that the first step in future response has been carried out, to bring the PNP staff to a state of readiness, and to provide systematic handling of Unusual Event information and decision-making.

1.2 Alert An Alert classification indicates events are in progress or have occurred which involve an actual or potential substantial degradation of the 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 PAG exposure levels.

The purpose of this classification is to assure that emergency personnel respond to the Control Room to support the emergency response.

2. Postulated Accidents The PNP DSAR and the ISFSI FSARs describe the postulated accidents applicable to PNP.

Methods for detecting and evaluating these events and declaring emergencies include the use of installed systems, instrumentation, alarms, approved procedures, and field observation.

3. State and Local Governmental Authorities The EALs have been discussed with the State of Michigan and Van Buren County.

Further, State and local governmental authorities are provided the opportunity to review the Permanently Defueled EALs on an annual basis.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 23 of 57 PDEP Revision 0 Page 23 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Section E: Notification Methods and Procedures Procedures are established for notification to the State of Michigan and Van Buren County and PNP ERO personnel. The content of initial and follow-up messages to these organizations has been established.

1. ORO Notification HDI, in cooperation with State and local authorities, has established mutually agreeable methods for notification of response organizations consistent with the emergency classification and EAL scheme. Notification methods to offsite agencies include a means of verification or authentication such as the use of dedicated communications networks (NRC-ENS) or providing call back verification phone numbers. Notification of an emergency declaration is the responsibility of the Emergency Director.

The content of the initial notification and follow-up messages have been coordinated with, and agreed upon by, the State of Michigan and Van Buren County.

1.1 Initial Notification For all classified events, Initial Notification shall be provided to the State of Michigan and Van Buren County promptly following the declaration of the emergency, and within 60 minutes of the emergency declaration.

The initial emergency message will include the following information if it is known and appropriate:

1) Authenticity, i.e. "This is NOT an Exercise (Drill)" or "This is an Exercise (Drill)";

2) Location of incident

3) Name and telephone number (or other applicable contact information) of the individual providing the notification;

4) Date and time of the incident;

5) Emergency classification and EAL;

6) Emergency response actions underway;

7) Whether a release is in progress;

8) Wind direction, speed, and stability class;

9) Any request for onsite support from OROs; and

10) Prognosis for worsening or termination of the event based on available facility information

HDI PNP 2022-016 Enclosure, Attachment 1 Page 24 of 57 PDEP Revision 0 Page 24 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN 1.2 Follow-up Messages Follow-up messages will be provided to the State of Michigan and Van Buren County within 60 minutes of a change in emergency classification or a change in radioactive release condition.

Additionally, follow-up messages should be provided as needed or on agreed upon intervals established with the offsite authorities. The content of follow-up messages is consistent with that provided for initial notifications described above, as known and appropriate.

2. Notification of the NRC The ENS is a dedicated telephone system used to contact the NRC Operations Center. The NRC will be notified as soon as possible after State and local notifications and within 60 minutes of event classification or change in classification.

In the event that ENS fails, commercial phone lines will be used to notify the NRC.

Notification to the NRC is the responsibility of the Emergency Director.

3. Notification of the PNP ERO At the Unusual Event classification, the ERO is notified and can be activated at the discretion of the Emergency Director.

At the Alert classification level, the ERO is notified and activated.

All onsite personnel are notified of the emergency declaration, escalation, or termination of an emergency by an announcement over the PNP Public Address System. Onsite ERO personnel and the PNP ERO personnel away from the site at the time of the PNP ERO activation are notified via an electronic notification system and/or phone calls.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 25 of 57 PDEP Revision 0 Page 25 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Section F: Emergency Communications Provisions exist for prompt communications between principal response organizations and emergency response personnel. The communication systems provide the capability for 24-hour-per-day onsite and offsite communications. This section describes the emergency communications equipment available to support the PNP ERO. It outlines the available communications equipment to:

• Notify the PNP ERO;

• Provide initial and follow-up notifications to governmental agencies;

• Communicate among PNP site personnel;

• Communicate with the NRC, State, and local response agencies; and

• Communicate with medical support, fire/rescue support, law enforcement, and other agencies providing offsite assistance to PNP.

1. Description of Primary and Backup Communications Systems Communications may be established by different means (radio, phone, public address system) within plant buildings and between Control Room personnel and offsite support groups.

1.1 Public Address System The PNP Public Address System is designed to provide alarms and announcements from the Control Room. This system is used to call personnel and notify onsite personnel of the declaration, escalation, or termination of an emergency, and to instruct personnel on actions to be taken upon an emergency declaration.

1.2 Commercial Telephone Systems The commercial telephone system is available in the PNP Control Room and throughout PNP. The commercial telephone system is used for onsite and offsite communications; including the means for requesting medical, law enforcement, and fire/rescue services via 911; and as the primary means of notifying and activating the augmenting PNP ERO positions.

Commercial telephones serve as the primary means of providing emergency notifications to the State of Michigan and Van Buren County and is used to provide initial and follow-up notifications and for general information flow between these organizations.

In the event the commercial telephone system is unavailable, wireless communications can be used as a backup means to make emergency notifications

HDI PNP 2022-016 Enclosure, Attachment 1 Page 26 of 57 PDEP Revision 0 Page 26 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN and maintain continuous communications with the state and county, and can serve as a backup means of notifying and activating the PNP ERO.

The Federal Telephone System (FTS) consists of the ENS dedicated telephone system used to notify the NRC Operations Center. The ENS is used for the dissemination of operational conditions as well as the initial notification from PNP to the NRC. In the event the ENS system is unavailable, commercial telephones (including wireless telephones) provide backup means to communicate with the NRC.

1.3 Radio System A radio system is also available for communication between individuals onsite, including individuals in the PNP Control Room.

2. Medical Communications HDI establishes communications with Bronson South Haven Hospital, via commercial telephone. The Control Room obtains direct ambulance dispatch via 911. The Dispatcher provides for a coordinated communications link to the ambulances responding to PNP or transporting contaminated and/or injured personnel from PNP.

3. Communications Drills and Testing Communications drills between HDI, the State of Michigan, Van Buren County, and the NRC are conducted in accordance with criteria contained in Part 2, Section N of this Plan. Also, Part 2, Section N of this Plan describes surveillances to determine the working condition and availability of communications equipment. Deficiencies are identified and reported for prompt corrective action.

Communications equipment is operationally checked in accordance with Part 2, Section N of this Plan, to ensure reliable operation.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 27 of 57 PDEP Revision 0 Page 27 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Section G: Public Education and Information The principal points of contact with the news media for dissemination of information during an emergency are established in advance, and procedures for coordinated dissemination of information to the public are established.

Communications personnel will be notified of an emergency declaration and will serve as a spokesperson. The spokesperson 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.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 28 of 57 PDEP Revision 0 Page 28 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Section H: Emergency Facilities and Equipment Adequate emergency facilities and equipment to support the emergency response are provided and maintained to aid in the timely and accurate response by the ERO.

Following declaration of an emergency, the activities of the ERO are coordinated from the Control Room.

This section of the PDEP also describes the surveillance programs used to monitor and ensure that facilities and equipment are maintained in a high degree of constant readiness.

1. Control Room During a declared emergency, the Control Room is designated as the location from which evaluation and coordination of all activities related to the emergency are performed. The Control Room contains the necessary instrumentation to monitor facility systems and equipment parameters under normal and accident conditions.

The Control Room is continuously staffed in accordance with PDTS, so there is no need to activate the facility following an emergency declaration. When notified, the Augmenting ERO reports to the Control Room within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of declaration of an Alert classification, or at the discretion of the Emergency Director.

From the Control Room, the Emergency Director will assess conditions; evaluate the magnitude and potential consequences of abnormal conditions; initiate preventative, mitigating, and corrective actions; perform onsite and offsite notifications; and maintain communications.

2. Emergency Onsite Monitoring Systems 2.1 Radiological Monitors (1) Fixed Monitors Fixed process (air, liquid, or gas) monitors and area radiation monitors are installed at key locations with remote readouts and alarm indications in the Control Room. Key fixed radiation-monitoring equipment is identified in the DSAR, and in the Permanently Defueled EAL Technical Bases Document.

(2) Portable Survey Instruments In addition to installed monitoring systems, onsite portable radiation and contamination monitoring equipment is available. Emergency Implementing Procedures describe type, locations, and the amount of equipment available to the ERO.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 29 of 57 PDEP Revision 0 Page 29 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN 2.2 Process Instrumentation 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 the PNP Permanently Defueled EAL Technical Bases Document.

2.3 Fire Detection Heat and smoke detectors are located at key locations in the plant with alarms annunciated in the Control Room. The Fire Protection System, including monitoring devices and fire suppression equipment, is completely detailed in the Fire Protection Implementing Procedures.

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

3. Facility and Equipment Readiness The Control Room and emergency equipment are inspected and inventoried in accordance with Emergency Implementing Procedures. The inspections include an operational check of instruments and equipment. Equipment, supplies, and parts that have a shelf life are identified, checked, and replaced as necessary. Sufficient reserves of instruments/equipment are maintained to replace those that are removed for calibration or repair.

At a minimum, instruments and equipment will be calibrated as recommended by the manufacturer or in accordance with applicable procedures.

Primary and backup equipment in place to ensure communications between Federal, State and local government agencies is described in Part 2, Section F of this Plan and are checked periodically in accordance with Part 2, Section N of this Plan.

4. Emergency Equipment and Supplies Table H.1, "Typical Emergency Equipment," lists equipment that is typically provided for emergency response. Emergency Implementing Procedures provide the equipment details relating to the specific type, location, and content, and are used to inventory emergency supplies.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 30 of 57 PDEP Revision 0 Page 30 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Table H-1 Typical Emergency Equipment Emergency equipment and supplies are stored at various locations throughout the site for immediate use by emergency forces. The following is a listing of the types of equipment and supplies stored at various locations.

Protective Equipment: - Anti-Contamination Clothing

- Respirators Radiological Monitoring - Air Samplers Equipment: - Ionization Chamber Survey Instruments

- G-M Friskers

- Dosimetry Emergency Supplies: - First Aid Kits

- Stretchers / Blankets

- Resuscitators

- Backboards / Splints Communications Equipment: - Telephones

- Radios

HDI PNP 2022-016 Enclosure, Attachment 1 Page 31 of 57 PDEP Revision 0 Page 31 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Section I: Accident Assessment Adequate methods and equipment are in use for assessing and monitoring actual or potential consequences of a radiological emergency condition.

The assessment activities required to evaluate a particular emergency depend on the specific nature and classification of the emergency. The Emergency Director is responsible for accident assessment efforts throughout the emergency.

HDI maintains and operates onsite monitoring systems needed to provide data that is essential for initiating emergency measures and performing accident assessment, including dose assessment. System and effluent parameter values are utilized in the determination of accident severity and subsequent emergency classification.

Environmental and meteorological events are also determining factors in emergency classification.

The specific symptoms, parameter values or events for each level of emergency classification are detailed in the Permanently Defueled EAL Technical Bases Document.

Classification of events is performed by the Shift Manager / Emergency Director in accordance with the EAL scheme.

1. Radiological Assessment PNP has Area Radiation Monitors (ARMs) for the direct measurement of in-plant exposure rates and Process Radiation Monitors (PRMs) for the continuous measurement of facility effluents. The ARM readings allow continuous exposure rate determinations to be made remotely without requiring local hand-held meter surveys. This information may be used, initially, to aid in the determination of accessibility. The PRMs provide an immediate indication of a radiological release of effluents and can be used as an input into dose assessment.

2. Dose Assessment Dose assessment utilizes radiological instrumentation readings and meteorological data to provide a rapid method of determining the magnitude of a radioactive release during an emergency. HDI can perform dose assessment on a 24-hour-per-day basis. Dose assessment is the responsibility of the Emergency Director and can initially be performed by any qualified on-shift individual. CFHs are qualified to perform dose assessment. HDI maintains at least one CFH-qualified individual on-shift on a 24-hour-per-day basis. When augmented, the Radiation Protection Coordinator assumes the dose assessment responsibilities.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 32 of 57 PDEP Revision 0 Page 32 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN

3. Corrective Actions Facility procedures and Emergency Implementing Procedures 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.

HDI maintains procedures and strategies for the movement of any necessary portable equipment that will be relied upon for mitigating the loss of SFP water.

Events involving a loss of SFP cooling and/or water inventory can be addressed by implementation of SFP inventory makeup strategies required under 10 CFR 50.155(b)(2). These capabilities are maintained as a license condition. 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.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 33 of 57 PDEP Revision 0 Page 33 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Section J: Protective Actions A range of protective actions has been developed for onsite individuals and individuals within the Exclusion Area Boundary. Protective actions for personnel onsite are provided for their health and safety. Procedures also provide protective actions to protect personnel during security events.

1. Notification of Onsite Personnel Facility personnel, contractors, and visitors are notified of an emergency using the PNP Public Address System. Announcements include instruction related to response actions to be taken by onsite and contractor personnel. Additionally, the announcements describe any necessary actions for visitors.

The PNP Security Force will ensure that individuals in the Exclusion Area are notified as necessary of any emergency and the response actions to be taken.

2. Assembly During an Alert, or as directed by the Emergency Director, non-essential personnel (personnel not assigned emergency response functions, contractors, and visitors) are directed to relocate and assemble at a pre-designated assembly area outside the Protected Area. The Emergency Director may release non-essential personnel from PNP. Personnel assigned emergency response functions respond to the Control Room.

3. Accountability The Emergency Director has the authority to initiate personnel accountability.

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

Accountability of all personnel inside the Protected Area should be accomplished within 60 minutes after event declaration and maintained thereafter at the discretion of the Emergency Director. Following announcement of an emergency declaration, onsite personnel are responsible for reporting to designated areas and aiding the accountability process. If personnel are not accounted for, the Emergency Director is notified, and onsite announcements are made. If personnel are still unaccounted for following the onsite announcements, search and rescue operations are initiated.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 34 of 57 PDEP Revision 0 Page 34 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Accountability is coordinated between the Emergency Director or Technical Coordinator and Security.

Assembly and accountability could be suspended or delayed if movement of personnel would place them in more danger than leaving them in place, such as outside weather conditions or security events.

Accountability of persons located within the Site Boundary, but outside the Protected Area, is not required.

4. Radiological Monitoring In the event of a radiological release, or a suspected radiological release, personnel are monitored for radioactive contamination prior to leaving the Protected Area.

Monitoring will be performed by Radiation Protection staff or trained monitoring personnel using instrumentation that is normally available or specifically assigned for this purpose.

5. Provisions for the Protection of Onsite Personnel HDI maintains an inventory of respiratory protection equipment, and anti-contamination clothing that is made available to emergency workers remaining onsite should conditions warrant.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 35 of 57 PDEP Revision 0 Page 35 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Section K: Radiological Exposure Control The means for controlling radiological exposures during an emergency are established for emergency workers. Exposure guidelines in this section are consistent with the EPA PAG Manual (EPA-400/R-17/001).

The general guideline for emergency personnel exposure will be to keep it as low as reasonably achievable (ALARA). 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. Emergency Exposure Guidelines Radiation exposure in an emergency is controlled taking every reasonable effort to minimize exposure. However, circumstances may warrant exposure in excess of 10 CFR Part 20 limits. Saving a life, measures to circumvent substantial exposures to the general public, or the prevention of damage to critical equipment may be sufficient cause for above normal exposures. The Emergency Director is responsible for authorizing personnel to receive doses in excess of 10 CFR Part 20 limits, if necessary.

Exposure guidelines for emergency activities are presented in Table K-1.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 36 of 57 PDEP Revision 0 Page 36 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Table K-1 Emergency Exposure Criteria (Refer to Note 1)

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

Exceeding 5 rem is unavoidable and all appropriate actions have Protecting critical infrastructure 10 rem(a) been taken to reduce dose.

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

Exceeding 5 rem is unavoidable and all appropriate actions have Lifesaving or Protection of Large 25 rem(b)(c) been taken to reduce dose.

Population Monitoring available to project or measure dose.

All conditions above and only for Lifesaving or protection of large

>25 rem(b)(c) people fully aware of the risks populations involved.

NOTES:

1. Reference for this table is Table 3-1 of the EPA PAG Manual.

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

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

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

2. Emergency Radiological Control Program The augmenting Radiation Protection Coordinator ensures that proper radiological monitoring equipment is provided to personnel during emergency conditions, exposure accountability is maintained, and personnel are not allowed to enter known or potential high radiation areas unless their exposure has been properly evaluated.

Emergency Implementing Procedures detail the emergency radiological controls utilized during emergencies. Radiation protection guidelines during emergencies include the following:

• Persons undertaking any emergency operation in which the dose will exceed 25 Rem Total Effective Dose Equivalent (TEDE) should do so only on a voluntary basis and with full awareness of the risks involved including the

HDI PNP 2022-016 Enclosure, Attachment 1 Page 37 of 57 PDEP Revision 0 Page 37 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN numerical levels of dose at which acute effects of radiation will be incurred and numerical estimates of the risk of delayed effects.

• In the context of the emergency limits, exposure of workers that is incurred for the protection of critical infrastructure, lifesaving or protection of large populations may be considered justified for situations in which the collective dose avoided by the emergency operation is significantly larger than that incurred by the workers involved.

• Exposure accountability is maintained, and proper personnel radiological monitoring equipment is provided for personnel during emergency conditions.

• Access to high radiation areas is only permitted with prior approval of the Emergency Director, and personnel are not allowed to enter known or potential high radiation areas unless their exposure has been properly evaluated.

• Habitability surveys of the Control Room are performed during an emergency.

If the facility is determined to be uninhabitable, the facility is evacuated in order to prevent or minimize exposure to radiation and radioactive materials.

Alternate areas can be established, as necessary, to relocate and monitor personnel.

3. Personnel Monitoring If abnormal radiological conditions exist outside the Radiologically Controlled Area (RCA), exposure to emergency response personnel not issued personal radiation dosimetry will be tracked by use of surveys and time spent in radiation areas.

Workers who would be expected to enter the RCA are trained and issued personal radiation dosimetry. High range or electronic dosimeters and/or alarming self-indicating dosimetry are used to monitor emergency workers exposure during an accident. Emergency workers are instructed to read self-indicating dosimeters frequently, and dosimetry may be processed with increased periodicity.

Emergency worker dose records are maintained in accordance with procedures.

4. Decontamination and First Aid Normal decontamination measures and contamination control limits apply in emergency conditions. However, these limits may be modified by the Radiation Protection Coordinator should conditions warrant.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 38 of 57 PDEP Revision 0 Page 38 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Decontamination materials and portable first-aid kits are available. Actions for personnel injury onsite involving possible radioactive contamination is described in Part 2, Section L.

5. Contamination Control Measures Areas in the plant found to be contaminated are isolated in accordance with plant procedures with appropriate radiological protection and access control as directed by the Radiation Protection Coordinator.

In order to preclude the spread of contamination from these areas, all personnel and equipment are monitored for radioactive contamination at the nearest monitoring station upon exiting the contaminated areas. Contaminated personnel are decontaminated.

6. Drinking Water and Food Supplies Measures will be taken to control onsite access to potentially contaminated potable water and food supplies. Under emergency conditions when uncontrolled releases of activity have occurred, eating and drinking are prohibited until such time as habitability surveys indicate that such activities are permissible.

7. Return of Areas and Items to Normal Use Restricted areas and contaminated items will be returned to normal use when contamination levels have been returned to acceptable levels. Contamination control criteria for returning areas and items to normal use are contained in the plant procedures.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 39 of 57 PDEP Revision 0 Page 39 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Section L: Medical and Public Health Support Arrangements are made for medical services for contaminated injured individuals. On-shift personnel and equipment are available to provide first aid for personnel working at the site. Medical emergency supplies are located at various locations onsite.

If urgent professional medical help is needed, local ambulance services are available to transport seriously ill, injured, or radioactively contaminated injured personnel.

Arrangements have been made for transporting injured, contaminated and irradiated personnel to the hospital via the Covert Fire Department.

An agreement is in place with Bronson South Haven Hospital for medical treatment of patients from PNP who have injuries complicated by radioactive contamination. The hospital has trained personnel for handling radioactively contaminated patients from PNP.

Part 2, Section C of this Plan contains details of the ambulance and hospital arrangements and capabilities.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 40 of 57 PDEP Revision 0 Page 40 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Section M: Re-Entry and Recovery Planning General plans are developed for recovery and re-entry. The Recovery Organization would be based upon the normal PNP organization. The Shift Manager / Emergency Director would initiate the Recovery Phase.

1. Re-Entry During a declared emergency, immediate actions are directed toward limiting the consequences of the accident, to afford maximum protection to PNP personnel and the general public. After any necessary corrective measures have been taken and effective control of the plant has been re-established, a more methodical approach to re-entry is taken. This PDEP divides re-entry into two categories:

• As directed by the Emergency Director, re-entry during the emergency phase of an accident may be performed to save a life, control a release of radioactive material, prevent further damage to plant equipment, or to restore plant equipment. If necessary, this category of re-entry may be performed using emergency exposure limits described in Part 2, Section K. Briefings and emergency forms, rather than written radiation protection procedures, operating procedures, and maintenance procedures, can be used when making these entries.

• As directed by the Emergency Director or the Recovery Organization, re-entry during the recovery phase is performed using normal exposure limits and normal procedures, or procedures developed specifically for each re-entry are utilized. Survey results and all other pertinent information collected from logs and other records, or other indicators may be used to evaluate the advisability and the timing of re-entry to affected areas.

2. Recovery Recovery is defined as those steps taken to return the facility to its pre-accident condition. Radiation exposure to personnel involved in the recovery will be kept ALARA and within the stated limits of 10 CFR Part 20. Radiation areas will be roped off and posted with warning signs and controlled in accordance with plant procedures. Access to these areas will be controlled, and exposures to personnel entering such areas documented. Shielding will be fully employed, to the extent possible.

The plan is to return facility conditions to within Technical Specification limits. A nuclear safety/review committee reviews and approves recovery operations in accordance with its charter and the Technical Specifications.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 41 of 57 PDEP Revision 0 Page 41 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN The Shift Manager / Emergency Director has the responsibility for determining when an emergency is stable, and the facility is prepared to enter the recovery phase.

Prior to terminating an emergency and entering the recovery phase, the conditions listed below are considered. It is not necessary that all conditions listed below be met. However, all items must be considered prior to entering the recovery phase.

For example, it is possible after severe accidents that some conditions remain which exceed an EAL, but entry into the recovery phase is appropriate.

• Do conditions still meet an EAL? If so, does it appear unlikely that conditions will deteriorate?

• Radioactive releases are under control and are no longer in excess of Technical Specification limits.

• In-plant radiation levels are stable or decreasing, and acceptable, given the plant conditions.

• The potential for uncontrolled radioactive release is acceptably low.

• The SFP is in a stable condition and long-term cooling is available and adequate. There is no foreseeable danger of losing heat removal capability.

• Any fire, flood, earthquake or similar emergency condition no longer exists.

• All required notifications have been made.

• Any contaminated-injured person has been treated and/or transported to a medical care facility.

• Offsite conditions do not unreasonably limit access of outside support to the facility.

3. Recovery Organization Once the decision is made to enter the recovery phase, the extent of the staffing required for the Recovery Organization is determined. For events of a minor nature, (i.e., Unusual Event classifications) the normal on-shift organization is normally adequate to perform necessary recovery actions.

The specific members of the Recovery Organization are selected based on the sequence of events that preceded the recovery activities as well as the requirements of the recovery phase. The Site Recovery Director, as appointed by senior management, is charged with the responsibility for directing the activities of the Recovery Organization. These responsibilities include:

• Ensuring an Event Summary Report is prepared and transmitted to offsite authorities.

• Overseeing the development of, and approving, a Recovery Plan and any special recovery procedures.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 42 of 57 PDEP Revision 0 Page 42 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN

• Deactivating any of the PNP ERO positions that were retained to aid in recovery, in the appropriate manner. Depending upon the type of accident, certain ERO positions may remain in place after initiation of the recovery phase.

• Approving information released by the public information organization that pertains to the emergency or the recovery phase of the accident.

• Maintaining a record/log of specific recovery actions taken.

• Working with senior company management in providing for assistance to employees affected by the event.

• Determining when the recovery phase is terminated. Recovery will be terminated when actions identified in the Recovery Plan have been completed.

• Identifying and documenting issues relating to Recovery operations.

• Coordinating the development and implementation of the recovery plan and procedures.

• Directing all onsite activities in support of recovery.

• Designating other recovery positions required in support of onsite recovery activities.

• Investigating the event in accordance with the Corrective Action Program.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 43 of 57 PDEP Revision 0 Page 43 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Section N: Drill and Exercise Program 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 identified during drills and exercises are documented and corrected.

1. Exercises Biennial exercises shall be conducted to test the integration, timing, and content of Emergency Implementing Procedures and methods to ensure that emergency personnel are familiar with their duties.

Offsite organizations are invited and 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.

2. Drills In addition to the exercises described above, HDI conducts drills for the purpose of training, testing, developing, and maintaining the proficiency of emergency responders. Equipment and proficiency drills may be performed as part of an exercise, as part of a drill, or as an independent drill.

Drills and/or surveillance tests are conducted at PNP for the following:

2.1 Communication Drills or Surveillances (1) The ENS used to communicate with the NRC is tested monthly.

(2) The communication links between the Control Room and the State of Michigan and Van Buren County will be tested monthly.

(3) The communication systems listed below, as detailed in Part 2, Section F of this Plan, are used on a frequent basis. Therefore, periodic testing of these systems is not necessary.

a. Public Address System

b. Commercial Telephone Systems

c. Radio System

HDI PNP 2022-016 Enclosure, Attachment 1 Page 44 of 57 PDEP Revision 0 Page 44 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN 2.2 Fire Drills Drills are conducted in accordance with the PNP Fire Protection Plan which has been reviewed and approved by the NRC.

2.3 Medical Emergency Drills On an annual basis, Medical Emergency Drills are conducted and involve an individual who is simulated to be injured and contaminated. The Covert Fire Department and Bronson South Haven Hospital are invited to participate to demonstrate and practice the receipt and treatment of contaminated patients.

2.4 Radiation Protection Drills On an annual basis, Radiation Protection Drills are conducted which involve response to, and analysis of, simulated airborne samples with elevated levels of activity. These drills also involve direct measurements of radiation levels in the Facility. Normal and emergency radiation procedures and processes are followed for the simulated conditions.

3. Conduct of Drills and Exercises For each emergency preparedness exercise or drill conducted, a scenario package is developed. The information included in the scenario package is in accordance with facility procedures.

Controllers/Observers are assigned to evaluate the drill or exercise performance.

Following each drill or exercise, a critique is conducted to evaluate the ability of the participants to implement the PDEP and Emergency Implementing Procedures.

Biennially, representatives from the NRC observe and evaluate an exercise including an evaluation of the licensees ability to conduct an adequate self-critical critique.

Identified areas of the Emergency Preparedness Program that require improvement are entered, tracked, and resolved in the Corrective Action Program. Feedback is provided to participants through critiques, drills, exercise reports, or in accordance with training program requirements.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 45 of 57 PDEP Revision 0 Page 45 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Section O: Emergency Response Training Radiological emergency response training is provided to those who may be called on to assist in an emergency. Emergency response training is provided to employees and offsite support personnel requiring site access.

1. Emergency Response Training Emergency response personnel in the following categories receive initial training and annual retraining.

1.1 ERO Training Training and qualification of PNP ERO personnel is implemented via the ERO Training Program. PNP ERO personnel receive initial, specialized, and periodic continuing training. Training program details are maintained in Training Department Procedures and are tailored to ensure proficiency in the assigned ERO position.

New ERO personnel receive an initial overview course that familiarizes them with the PDEP by providing basic information in the following areas as well as specific information as delineated in the sections below:

• Planning Basis

• Emergency Classifications

• ERO and Responsibilities

• Activation of the ERO (1) Emergency Directors Personnel qualified as an Emergency Director receive specialized training in the areas of:

• Emergency Notifications

• Emergency Classification

• EALs

• Mitigative and Protective Actions

• Emergency Exposure Control (2) Personnel Responsible for Accident Assessments The skills and knowledge required to perform plant stabilization and mitigation are a normal function of operations specific positions.

Subsequent stabilization and restoration is pursued utilizing facility

HDI PNP 2022-016 Enclosure, Attachment 1 Page 46 of 57 PDEP Revision 0 Page 46 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN procedures. Operations personnel receive periodic training to ensure proficiency in this area.

Additional personnel that are called to assist operators with accident assessment, corrective actions, protective actions, and related activities will receive appropriate training.

(3) Personnel Responsible for Radiological Assessment In addition to the training received to qualify for their normal duties, personnel responsible for radiological assessment receive periodic training on the following topics, as applicable to their assigned emergency response roles:

• Dose Assessment

• Basic Meteorology

• Transportation of contaminated injured individuals 1.2 First Aid Response First aid and rescue personnel are trained to respond to medical emergencies.

1.3 Fire Response Fire Training is conducted in accordance with the PNP Fire Protection Plan.

1.4 Security Security Response is based upon a normal daily security function that is to safeguard the site. Security personnel receive specialized training in the following areas:

• Assembly / Accountability

• Site Evacuation

• Search and Rescue

2. General, Initial, and Periodic Training Program Maintenance Personnel assigned to work at PNP receive initial and periodic refresher training on general facility procedures and policy. This training includes required actions to be taken if an emergency is declared.

3. Local Support Service Personnel Training Training is offered annually to support organizations (fire, ambulance, medical, and law enforcement agencies) that may be called upon to assist in the event of an

HDI PNP 2022-016 Enclosure, Attachment 1 Page 47 of 57 PDEP Revision 0 Page 47 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN emergency. 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 and orientation, basic radiation protection, and interface activities are included in the training.

4. Training Records Records associated with training of PNP personnel are documented and maintained in accordance with plant procedures. Records associated with training offered and/or provided to OROs is documented and maintained in accordance with plant procedures.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 48 of 57 PDEP Revision 0 Page 48 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Section P: Responsibility for the Maintenance of the Planning Effort Responsibilities for development, review, and distribution of the PDEP and actions that must be performed to maintain the PDEP are established, and personnel who perform the planning are properly trained.

1. Responsibility for Development and Maintenance of the PDEP 1.1 Palisades Nuclear Plant Vice President The PNP Vice President has overall authority and responsibility for the Emergency Preparedness Program. This includes the authority to provide the necessary resources to ensure the continuous state of readiness for the PNP ERO.

1.2 Manager Responsible for Emergency Planning This Manager is responsible for the maintenance of the PNP Emergency Preparedness Program. In maintaining the program, the Manager ensures the following:

• Development, maintenance, and revision of the PDEP and Emergency Implementing Procedures are accomplished in accordance with applicable regulations and industry standards.

• LOAs listed in Appendix 1 are reviewed annually and updated as necessary.

• Review and approve the PDEP and Emergency Implementing Procedures prior to implementation.

• Development and maintenance of 10 CFR 50.54(q) evaluations of program changes.

• Adequate support is provided to ensure the training program for offsite response personnel is in place and maintained.

• Development and maintenance of a working relationship with OROs.

• Oversee Emergency Preparedness Training Program and ensuring that proper records are maintained to document training and retraining of the ERO.

• Preparation for and conduct of the EP drill and exercise program.

• Documenting the activities of the Emergency Preparedness Program as required by law and regulations.

• EP Personnel maintain an adequate knowledge of planning techniques and applications of emergency equipment, supplies, and the Control Room.

• Corrective actions identified during the conduct of exercises, drills, training, audits, and inspections are tracked in the Corrective Action Program.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 49 of 57 PDEP Revision 0 Page 49 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN 1.3 Emergency Planning Personnel PNP personnel who perform planning duties for the Emergency Preparedness Program receive on-going training and experiences to maintain or improve their knowledge related to emergency planning. At least once each calendar year, these personnel are involved in one of the following activities at a minimum:

• Training courses specific to emergency preparedness.

• Training courses related to emergency preparedness management, such as problem solving, stress management, or confrontation/media relations courses.

• Observation of, or participation in, drills and/or exercises at another utility or station.

• Participation in an audit or benchmarking at another utility or station.

• Participation in industry review and evaluation programs.

• Participation in regional or national emergency preparedness seminars, committees, workshops, or forums.

• Attend training courses in related areas, such as systems, operations, or radiological protection training.

• Other personnel development as approved by the Manager responsible for Emergency Planning.

2. Emergency Plan Review and Revision The PDEP is reviewed on an annual basis. As necessary to maintain the effectiveness of the PDEP, updates will be developed as a result of the annual reviews. The Manager responsible for Emergency Planning is responsible for determining which recommended changes are incorporated into the PDEP. Editorial changes to the PDEP can be held until the next revision. If no change to the PDEP is required, a memo to file shall be maintained to document the annual review.

All proposed changes will be evaluated in accordance with 10 CFR 50.54(q).

Changes to the PDEP are made without NRC approval only if such changes do not reduce the effectiveness of the PDEP, and the PDEP as changed continues to meet the standards of 10 CFR 50.47(b) and 10 CFR Part 50, Appendix E, as exempted.

Proposed changes that reduce or have a potential to reduce the effectiveness of the approved PDEP are not implemented without prior approval by the NRC.

Technical reviews of the PDEP and Emergency Implementing Procedures shall be conducted in accordance with facility procedures. The reviewer shall determine the need for cross-disciplinary reviews.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 50 of 57 PDEP Revision 0 Page 50 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN The PDEP and Emergency Implementing Procedures are distributed on a controlled basis.

3. Emergency Implementing Procedures Emergency Implementing Procedures (refer to Appendix 2 of this Plan) shall be developed and revised concurrent with the PDEP and reviewed in accordance with facility procedures. The Emergency Implementing Procedures are reviewed biennially and approved in accordance with approved facility procedures.

4. Letters of Agreement Appendix 1 of this Plan contains a listing of LOAs with support agencies which shall be reviewed annually. As a result of the annual review, agreements will be revised or recertified. Recertification may include a recertification letter/memorandum, purchase order, email, documented telephone conversation, or other correspondence. Designated management has the authority to enter into these agreements with outside organizations.

5. Cross-Reference to Planning Criteria The Plan is formatted in the same manner as Attachment 1 of ISG-02, as detailed in Appendix 2 of this Plan. This allows for ease in auditing evaluation criteria.

6. Review of the Emergency Preparedness Program HDI coordinates an independent review of the Emergency Preparedness Program to meet the requirements of 10 CFR 50.54(t). Results of this review are submitted to the PNP Vice President. The Manager responsible for Emergency Planning ensures that any findings that deal with offsite interfaces are reviewed with the appropriate agencies. Written notification will be provided to local agencies documenting the results of the audit and providing notice of availability of the audit records for review at PNP. Records of the review are maintained for at least five years.

7. Emergency Telephone Directory A phone list contains telephone numbers used by the PNP ERO during an emergency. This directory contains names and phone numbers of the PNP ERO, support personnel, and applicable offsite organizations. These numbers are verified and updated at least quarterly.

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

HDI PNP 2022-016 Enclosure, Attachment 1 Page 51 of 57 PDEP Revision 0 Page 51 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN

• Portable radiation monitoring equipment

• Emergency medical response equipment

• Dosimeters

• Portable radios Emergency equipment and instrumentation (refer to Part 2, Section H of this Plan) 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.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 52 of 57 PDEP Appendix 1 Revision 0 Page 52 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Appendix 1 Letters of Agreement Copies of LOAs for the offsite emergency response supporting organizations listed below are maintained in the Emergency Planning Department files.

1. Covert Fire Department (Fire/Ambulance)

2. Bronson South Haven Hospital Per Section P, the LOAs with outside support organizations and government agencies are reviewed and confirmed annually. These letters are updated as needed. Letters with no specific end date remain in effect until terminated in writing by either party. This has been agreed to by the applicable supporting agencies.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 53 of 57 PDEP Appendix 2 Revision 0 Page 53 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Appendix 2 Cross-Reference Sections of the PDEP to Emergency Implementing Procedures Cross reference table of regulations and guidance documents to the PNP Emergency Plan and Emergency Implementing Procedures.

Emergency Planning Planning ISG-02, Attachment Emergency Implementing Plan Standard Requirement 1 Evaluation Criteria Procedure Section 10 CFR 50.47* Appendix E.IV*

A (b)(1) A.1, 2, 4, 7 A To Be Determined (TBD)

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

• Refer to the PNP exemptions from portions of 10 CFR 50.47 and 10 CFR 50, Appendix E, for specific applicability.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 54 of 57 PDEP Appendix 3 Revision 0 Page 54 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Appendix 3 Abbreviations and Definitions Abbreviations Any abbreviation followed by a lower case s denotes the plural form of the term.

ALARA ....................................................................... As Low As Reasonably Achievable ARM .............................................................................................. Area Radiation Monitor CFH ................................................................................................ Certified Fuel Handler CFR ...................................................................................... Code of Federal Regulations DBA ................................................................................................ Design Basis Accident DSAR ............................................................................. Defueled Safety Analysis Report EAL ............................................................................................. Emergency Action Level ECL ..................................................................................Emergency Classification Level ENS .......................................................................(NRC) Emergency Notification System EPA ...................................................................... U.S. Environmental Protection Agency ERO .......................................................................... Emergency Response Organization FSAR.................................................................................... Final Safety Analysis Report FTS ........................................................................................ Federal Telephone System IC.......................................................................................................... Initiating Condition ICS ......................................................................................... Incident Command System ISFSI ............................................................Independent Spent Fuel Storage Installation ISG ................................................................................................. Interim Staff Guidance LOA .................................................................................................... Letter of Agreement mRem................................................................................ milli-Roentgen Equivalent Man mSv ...................................................................................................................millisievert NCO .............................................................................................. Non-Certified Operator NIMS .................................................................... National Incident Management System NRC ....................................................................... U.S. Nuclear Regulatory Commission NRF .................................................................................. National Response Framework ORO ..................................................................................Offsite Response Organization PAG.............................................................................................. Protective Action Guide PDEP .................................................................. Permanently Defueled Emergency Plan PDTS.......................................................Permanently Defueled Technical Specifications PNP ............................................................................................. Palisades Nuclear Plant PRM ........................................................................................ Process Radiation Monitor RCA................................................................................... Radiologically Controlled Area RP ..................................................................................................... Radiation Protection SFP .......................................................................................................... Spent Fuel Pool TEDE................................................................................ Total Effective Dose Equivalent

HDI PNP 2022-016 Enclosure, Attachment 1 Page 55 of 57 PDEP Appendix 3 Revision 0 Page 55 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Definitions Accountability - The process used by the PNP ERO to identify potentially missing and/or injured personnel within the Protected Area during an emergency.

Annual - Frequency of occurrence equal to once per calendar year, between January 1st and December 31st.

Area Radiation Monitors - Fixed radiation detectors placed in strategic locations throughout the Facility for the purpose of continuously monitoring area radiation dose rates; an integral part of the Radiation Monitoring System that provides the Control Room with remote monitoring capabilities.

Assembly - The process of relocating onsite personnel, during an emergency to a pre-designated location. Onsite personnel who do NOT have an emergency response assignment (non-essential personnel) may be released.

Assembly Area - A pre-designated area to which non-essential personnel relocate during an emergency.

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

Biennial - Frequency of occurrence equal to once per two calendar years.

Classification - The classification of emergencies is divided into TWO (2) categories or conditions, covering the postulated spectrum of emergency situations. Each emergency classification is characterized by Emergency Action Levels (EALs) or event initiating conditions. The two classifications address emergencies of increasing severity.

Corrective Actions - Those emergency measures taken to ameliorate or terminate an emergency situation at or near its source.

Drill - A supervised instruction period aimed at testing, developing, and maintaining skill in a particular operation.

Emergency Action Level (EAL) - A predetermined, site-specific, observable threshold for a plant initiating condition that places the plant in a given emergency class.

Emergency Director - A previously designated and trained individual who assumes total responsibility for directing all licensee activities related to an emergency at the site.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 56 of 57 PDEP Appendix 3 Revision 0 Page 56 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Emergency Notification System (ENS) - The NRC Emergency Notification System is a dedicated telephone system (part of the Federal Telephone System). It connects the plant with NRC headquarters. It is used for reporting emergency conditions to NRC personnel.

Emergency Implementing Procedures - Procedures that provide detailed information necessary to maintain the Emergency Preparedness Program and implement required tasks during an emergency.

Essential Personnel - Those individuals needed to achieve the goals and tasks as deemed necessary by the Shift Manager or Emergency Director during an emergency.

Unless otherwise directed, initially all members of the Emergency Response Organization (ERO) are considered essential personnel.

Exclusion Area - The area surrounding the PNP reactor in which the licensee has the authority to determine all activities including exclusion or removal of personnel and property from the area. (10 CFR Part 100)

Facility - The Palisades Nuclear Plant, located in Covert Township, Van Buren County, Michigan.

Manager responsible for Emergency Planning - Individual responsible for reviewing and updating the emergency plan and supporting documents and coordinating all onsite and offsite emergency planning efforts.

Offsite - Locations outside of the Palisades Nuclear Plant Site boundary.

Onsite - The area within the Palisades Nuclear Plant Site boundary.

Owner Controlled Area - The fenced area containing licensee property.

Process Radiation Monitors - Radiation detectors which continuously monitor plant systems or specific effluent release points and provide the Control Room with remote monitoring capabilities and in some cases provide initiation of automatic termination of a specific effluent release.

Protective Action Guide (PAG) - Projected radiological dose values to individuals in the general population who warrant protective action. Protective Action Guides contain criteria used to determine whether the general population needs protective action due to projected radiological doses or from actual committed (measured) dose values.

HDI PNP 2022-016 Enclosure, Attachment 1 Page 57 of 57 PDEP Appendix 3 Revision 0 Page 57 of 57 TITLE: PERMANENTLY DEFUELED EMERGENCY PLAN Protected Area - The area surrounding PNP encompassed by physical barriers and to which access is controlled.

Quarterly - Frequency of occurrence equal to once in each of the following periods:

January 1st through March 31st, April 1st through June 30th, July 1st through September 30th, October 1st through December 31st.

Radiation Area - An area, accessible to individuals, in which radiation levels could result in an individual receiving a deep dose equivalent in excess of 5 mRem (0.05 mSv) in one hour at 30 cm (~ 12 inches) from the radiation source or from any surface that the radiation penetrates.

Radiologically Controlled Area - Any area within plant buildings or on plant property where access is restricted and monitored for the purpose of radiation protection.

Recovery Actions - Those actions taken after the emergency to restore the plant as nearly as possible to its pre-emergency condition.

Shift Manager - Management person responsible for the shift command function and shall be a Certified Fuel Handler.

Site Boundary - That line beyond which the land is neither owned, leased, nor otherwise controlled by the site licensee. For Dose Assessment purposes the Site Boundary is the closest distance at which members of the public would be exposed to a radioactive release.

Site Recovery Director - The individual who reports to senior management of the Company and who directs the Response Organization during the recovery stage. The Site Recovery Director is responsible for the technical direction and control of the integrated recovery effort.

Attachment 2 to Enclosure HDI PNP 2022-016 Permanently Defueled Emergency Action Level Technical Bases

HDI PNP 2022-016 Enclosure, Attachment 2 Page 1 of 40 PD EAL BASES Revision 0 Effective Date TBD PALISADES NUCLEAR PLANT EMERGENCY IMPLEMENTING PROCEDURE TITLE: PERMANENTLY DEFUELED EMERGENCY ACTION LEVEL TECHNICAL BASES Approved: / TBD Procedure Sponsor Date Process Applicability Exclusion New Procedure/Revision Summary:

Issued the Permanently Defueled Emergency Action Level Technical Bases to incorporate NRC's approval of the exemptions requested by letter dated July 11, 2022, whereby Holtec Decommissioning International, LLC (HDI),

on behalf of Holtec Palisades, LLC, requested exemptions from portions of 10 CFR 50.47(b); 10 CFR 50.47(c)(2);

and 10 CFR Part 50, Appendix E reflecting the reduced scope of the emergency planning requirements consistent with the permanently shutdown and defueled condition of the Palisades Nuclear Plant (PNP) reactor.

The NRC has docketed certification that all fuel has been permanently removed from the PNP reactor vessel and placed into the spent fuel pool (SFP), in accordance with 10 CFR 50.82(a)(2). The license for the PNP no longer authorizes operation of the reactor, nor emplacement or retention of fuel into the reactor vessel. The irradiated fuel will be stored in the SFP and in dry cask storage at the onsite independent spent fuel storage installation (ISFSI) until it is shipped offsite.

Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 i

HDI PNP 2022-016 Enclosure, Attachment 2 Page 2 of 40 Table of Contents 1.0 PURPOSE ............................................................................................................. 3 2.0 DISCUSSION ........................................................................................................ 3 2.1 Permanently Defueled Facility............................................................................ 3 2.2 Independent Spent Fuel Storage Installation ..................................................... 4 3.0 KEY TERMINOLOGY USED ................................................................................ 4 3.1 Emergency Classification Level ......................................................................... 4 3.2 Initiating Condition.............................................................................................. 5 3.3 Emergency Action Level .................................................................................... 5 4.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS ............................ 5 4.1 General Considerations ..................................................................................... 5 4.2 Classification Methodology................................................................................. 7 4.3 Classification of Multiple Events and Conditions ................................................ 7 4.4 Classification of Imminent Conditions ................................................................ 7 4.5 Emergency Classification Level Upgrading and Termination ............................. 7 4.6 Classification of Short-Lived Events ................................................................... 8 4.7 Classification of Transient Conditions ................................................................ 8 4.8 After-the-Fact Discovery of an Emergency Event or Condition .......................... 8 4.9 Retraction of an Emergency Declaration............................................................ 8

5.0 REFERENCES

...................................................................................................... 9 5.1 Developmental References ................................................................................ 9 5.2 Implementing References .................................................................................. 9 5.3 Commitments ..................................................................................................... 9 6.0 ACRONYMS, ABBREVIATIONS, AND DEFINITIONS....................................... 10 6.1 Acronyms and Abbreviations............................................................................ 10 6.2 Definitions ........................................................................................................ 11 7.0 ATTACHMENTS ................................................................................................. 13 ............................................................................................................... 14 ............................................................................................................... 19 Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 ii

HDI PNP 2022-016 Enclosure, Attachment 2 Page 3 of 40 1.0 PURPOSE This document provides the detailed set of EMERGENCY ACTION LEVELs (EALs) applicable to the Palisades Nuclear Plant (PNP) and its Independent Spent Fuel Storage Installations (ISFSIs). The associated Technical Bases uses the EAL development methodology found in NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 6 (NEI 99-01, Rev. 6) (Reference 5.1.1).

As a permanently defueled facility, Recognition Category PD (Permanently Defueled) was used to develop the site-specific emergency classification scheme, including a set of INITIATING CONDITIONs (ICs) and EALs associated with the permanently defueled condition. Recognition category "PD" addresses spent fuel stored in the PNP Spent Fuel Pool (SFP). Because spent fuel at PNP is also stored in ISFSIs, this document also includes the applicable Recognition Category "E" EAL presented in Section 8 of NEI 99-01, Rev. 6. All recommendations for changes to this document or associated implementing procedures are reviewed in accordance with 10 CFR 50.54(q).

This document should be used to facilitate review of the PNP EALs, provide historical documentation for future reference, and serve as a resource for training. Individuals responsible for emergency classification (Shift Manager and Emergency Director) may refer to the ICs and EALs contained in the matrix of this document. These individuals may also use the information in the associated "Basis" of each EAL as a technical reference in support of EAL interpretation.

Emergency classifications are to be made as soon as conditions are present and recognizable in accordance with the applicable EALs, but within 30 minutes in all cases after the availability of indications that an EAL threshold has been reached. Use of this document is not intended to delay the emergency classification.

2.0 DISCUSSION 2.1 Permanently Defueled Facility NEI 99-01, Rev. 6, provides guidance for an emergency classification scheme applicable to a permanently defueled station, which is a facility that generated spent fuel under a 10 CFR Part 50 license, has permanently ceased operations, and will store the spent fuel onsite for an extended period. The EMERGENCY CLASSIFICATION LEVELs (ECLs) applicable to a permanently defueled facility are consistent with requirements of 10 CFR Part 50 (Reference 5.1.2), as exempted (Reference 5.1.3), and the guidance presented in NSIR/DPR-ISG-02, "Interim Staff Guidance, Emergency Planning Exemption Requests for Decommissioning Nuclear Power Plants," (ISG-02)

(Reference 5.1.4).

The regulations in 10 CFR Part 50 do not distinguish between an operating plant and a plant that has permanently ceased power operations. To relax the emergency plan requirements, the owner of a permanently defueled station must demonstrate that no Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 3

HDI PNP 2022-016 Enclosure, Attachment 2 Page 4 of 40 credible event can result in a significant radiological release beyond the site boundary.

Holtec Decommissioning International, LLC (HDI) has confirmed that the source term and motive force available in the permanently defueled condition are insufficient to warrant classifications of a Site Area Emergency or General Emergency. Therefore, the generic ICs and EALs applicable to a permanently defueled station may result in either a NOTIFICATION of UNUSUAL EVENT (UNUSUAL EVENT) or an ALERT classification.

2.2 Independent Spent Fuel Storage Installation Selected guidance in NEI 99-01, Rev. 6, is applicable to licensees electing to use their 10 CFR Part 50 emergency plan to fulfill the requirements of 10 CFR 72.32 for a stand-alone ISFSI. The ECLs applicable to an ISFSI are consistent with the requirements of 10 CFR Part 50. The ICs germane to a 10 CFR 72.32 emergency plan (as described in NUREG-1567 (Reference 5.1.5)) are subsumed within the classification scheme for a 10 CFR 50.47 emergency plan.

The analysis of potential onsite and offsite consequences of accidental releases associated with the operation of an ISFSI is contained in NUREG-1140, A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees, (Reference 5.1.6). NUREG-1140 concluded that the postulated worst-case accident involving an ISFSI has insignificant consequences to public health and safety.

This evaluation shows that the maximum offsite dose to a member of the public due to an accidental release of radioactive materials would not exceed 1 Roentgen Equivalent Man (rem) Total Effective Dose Equivalent (TEDE).

Regarding the above information, the expectations for an offsite response to an ALERT classified under a 10 CFR 72.32 emergency plan (Reference 5.1.7) are generally consistent with those for an UNUSUAL EVENT in a 10 CFR 50.47 emergency plan (Reference 5.1.8) (e.g., to provide assistance, if requested).

3.0 KEY TERMINOLOGY USED There are several key terms that appear throughout the NEI 99-01, Rev. 6, methodology. These terms are introduced in this section to support understanding of subsequent material.

3.1 Emergency Classification Level One of a set of names or titles established by the U.S. Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to: (1) potential or actual effects or consequences and (2) resulting onsite and offsite response actions. The ECLs that are applicable to the PNP, in ascending order of severity, are:

Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 4

HDI PNP 2022-016 Enclosure, Attachment 2 Page 5 of 40 3.1.1 UNUSUAL EVENT The purpose of this classification is to assure that the first step in future response has been carried out, to bring the PNP staff to a state of readiness, and to provide systematic handling of information and decision-making.

3.1.2 ALERT The purpose of this classification is to assure that emergency personnel respond to the Control Room to support the emergency response.

3.2 Initiating Condition An IC describes an event or condition, the severity or consequences of which meets the definition of an ECL. An IC can be expressed as a continuous, measurable parameter (e.g., radiation monitor readings) or an event (e.g., an earthquake).

Each IC is given a unique identification code consisting of letter combinations and one number. The first letter(s) establish the scope of the IC followed by hyphen. The next letter identifies the recognition category. The final letter identifies the ECL. Finally, a number identifies the sequence of the IC within the recognition category. The EAL identification codes are developed as follows:

Permanently Defueled Recognition Categories

• PD-A - Abnormal Rad Levels / Radiological Effluent

• PD-H - Hazards and Other Conditions Affecting Plant Safety

• PD-S - System Malfunctions ISFSI Recognition Category

• E-H - Hazards and Other Conditions Affecting ISFSI 3.3 Emergency Action Level EAL statements may utilize a variety of criteria including instrument readings and status indications; observable events; results of calculations and analyses; entry into procedures; and the occurrence of natural phenomena.

4.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS 4.1 General Considerations All emergency classification assessments should be based upon valid indications, reports, or conditions. A valid indication, report, or condition is one that has been verified through appropriate means such that there is no doubt regarding the indicators Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 5

HDI PNP 2022-016 Enclosure, Attachment 2 Page 6 of 40 operability, the conditions existence, or the reports accuracy. For example, validation could be accomplished through an instrument channel check, response on related or redundant indicators, or direct observation by facility personnel. The validation of indications should be completed in a manner that supports timely emergency declaration.

For ICs and EALs that have a stipulated time duration (e.g., 15 minutes, 60 minutes, etc.), the Shift Manager / Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time. If an ongoing radiological release is detected and the release start time is unknown, it should be assumed that the release duration specified in the IC/EAL has been exceeded, absent data to the contrary.

A planned work activity that results in an expected event or condition which meets or exceeds an EAL does not warrant an emergency declaration provided that: (1) the activity proceeds as planned and (2) the facility remains within the limits imposed by the license. Such activities include planned work to test, manipulate, repair, maintain or modify a system or component. In these cases, the controls associated with the planning, preparation and execution of the work will ensure that compliance is maintained with all aspects of the license provided that the activity proceeds and concludes as expected. Events or conditions of this type may be subject to the reporting requirements of 10 CFR 50.72 (Reference 5.1.9).

The assessment of some EALs is based on the results of analyses that are necessary to ascertain whether a specific EAL threshold has been exceeded (e.g., gaseous and liquid effluent sampling, etc.); the EAL and/or the associated basis discussion will identify the necessary analysis. In these cases, the declaration period starts with the availability of the analysis results that show the threshold to be exceeded (i.e., this is the time that the EAL information is first available).

While the EALs have been developed to address a full spectrum of possible events and conditions which may warrant emergency classification, a provision for classification based on operator/management experience and judgment is still necessary. The NEI 99-01 scheme provides the Shift Manager / Emergency Director with the ability to classify events and conditions based upon judgment using EALs that are consistent with the ECL definitions (refer to PD-HU3 and PD-HA3). The Shift Manager / Emergency Director will need to determine if the effects or consequences of the event or condition reasonably meet or exceed a particular ECL definition.

Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 6

HDI PNP 2022-016 Enclosure, Attachment 2 Page 7 of 40 4.2 Classification Methodology To make an emergency classification, the Shift Manager / Emergency Director will compare an event or condition (i.e., the relevant facility indications and reports) to an EAL(s) and determine if the EAL has been met or exceeded. The evaluation of an EAL(s) must be consistent with the related Notes. If an EAL has been met or exceeded, then the IC is considered met and the associated ECL is declared in accordance with facility procedures.

When assessing an EAL that specifies a time duration for the off-normal condition, the EAL time duration runs concurrently with the emergency classification time duration.

4.3 Classification of Multiple Events and Conditions When multiple emergency events or conditions are present, the Shift Manager /

Emergency Director will identify all met or exceeded EALs. The highest applicable ECL identified during this review is declared. For example:

• If an UNUSUAL EVENT EAL and an ALERT EAL are met, an ALERT should be declared.

There is no additive effect from multiple EALs meeting the same ECL. For example:

• If two UNUSUAL EVENT EALs are met, an UNUSUAL EVENT should be declared.

Related guidance concerning classification of rapidly escalating events or conditions is provided in Regulatory Issue Summary (RIS) 2007-02, Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events, (RIS 2007-02)

(Reference 5.1.10).

4.4 Classification of Imminent Conditions Although EALs provide specific thresholds, the Shift Manager / Emergency Director must remain alert to events or conditions that could lead to meeting or exceeding an EAL within a relatively short period of time (i.e., a change in the ECL is IMMINENT). If, in the judgment of the Shift Manager / Emergency Director, meeting an EAL is IMMINENT, the emergency classification should be made as if the EAL has been met.

While applicable to all ECLs, this approach is particularly important at the higher ECL since it provides additional time for implementation of protective measures.

4.5 Emergency Classification Level Upgrading and Termination An ECL may be terminated when the event or condition that meets the IC and EAL no longer exists.

Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 7

HDI PNP 2022-016 Enclosure, Attachment 2 Page 8 of 40 As noted above, guidance concerning classification of rapidly escalating events or conditions is provided in RIS 2007-02 (Reference 5.1.10).

4.6 Classification of Short-Lived Events Event-based ICs and EALs define a variety of specific occurrences that have potential or actual safety significance. By their nature, some of these events may be short-lived and, thus, over before the emergency classification assessment can be completed. If an event occurs that meets or exceeds an EAL, the associated ECL must be declared regardless of its continued presence at the time of declaration. Examples of such events would be an earthquake or an explosion.

4.7 Classification of Transient Conditions It is important to stress that the emergency classification assessment period is not a grace period during which a classification may be delayed allowing the performance of a corrective action that would obviate the need to classify the event. Emergency classification assessments must be deliberate and timely, with no undue delays.

4.8 After-the-Fact Discovery of an Emergency Event or Condition In some cases, an EAL may be met but the emergency classification was not made at the time of the event or condition. This situation can occur when personnel discover that an event or condition existed which met an EAL, but no emergency was declared, and the event or condition no longer exists at the time of discovery. This may be due to the event or condition not being recognized at the time or an error that was made in the emergency classification process.

In these cases, no emergency declaration is warranted; however, the guidance contained in NUREG-1022, Event Report Guidelines 10 CFR 50.72 and 50.73, (NUREG-1022) (Reference 5.1.11) is applicable. Specifically, the event should be reported to the NRC in accordance with 10 CFR § 50.72 within one hour of the discovery of the undeclared event or condition. The licensee should also notify appropriate State and local agencies in accordance with the agreed upon arrangements.

4.9 Retraction of an Emergency Declaration Guidance on the retraction of an emergency declaration reported to the NRC is discussed in NUREG-1022 (Reference 5.1.11).

Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 8

HDI PNP 2022-016 Enclosure, Attachment 2 Page 9 of 40

5.0 REFERENCES

5.1 Developmental References 5.1.1 NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, November 2012 5.1.2 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities 5.1.3 Holtec Decommissioning International, LLC (HDI) letter to NRC, "

Request for Exemptions from Certain Emergency Planning Requirements of 10 CFR 50.47(b); 10 CFR 50.47(c)(2); and 10 CFR Part 50, Appendix E," (HDI PNP 2022-017), dated DATE [Upon issuance of the requested exemptions, this Reference will be eliminated and replaced by Implementing Reference 5.2.3 citing the NRC document approving exemptions]

5.1.4 NSIR/DPR-ISG-02, Interim Staff Guidance, Emergency Planning Exemption Requests for Decommissioning Nuclear Power Plants 5.1.5 NUREG-1567, Spent Fuel Dry Storage Facilities 5.1.6 NUREG-1140, A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees 5.1.7 10 CFR 72.32, Emergency Plan 5.1.8 10 CFR 50.47, Emergency Plans 5.1.9 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors 5.1.10 RIS 2007-02, Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events, February 2007 5.1.11 NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73 5.2 Implementing References 5.2.1 PNP Permanently Defueled Emergency Plan 5.2.2 Procedure Number [TBD], "Emergency Classification and Actions" 5.3 Commitments None Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 9

HDI PNP 2022-016 Enclosure, Attachment 2 Page 10 of 40 6.0 ACRONYMS, ABBREVIATIONS, AND DEFINITIONS 6.1 Acronyms and Abbreviations CAS ................................................................................................. Central Alarm Station CDE....................................................................................... Committed Dose Equivalent CFR ...................................................................................... Code of Federal Regulations CoC ........................................................................................... Certificate of Compliance cpm ....................................................................................................... counts per minute EAL ............................................................................................. Emergency Action Level ECL ..................................................................................Emergency Classification Level EPA .............................................................................. Environmental Protection Agency FAA .................................................................................. Federal Aviation Administration FBI.................................................................................... Federal Bureau of Investigation HOO ............................................................................... Headquarters Operations Officer hr ............................................................................................................................... Hour ISFSI ............................................................Independent Spent Fuel Storage Installation IC.......................................................................................................... Initiating Condition MPC .............................................................................................. Multi-Purpose Canister mRem................................................................................ milli-Roentgen Equivalent Man NEI .............................................................................................. Nuclear Energy Institute NORAD ...................................................North American Aerospace Defense Command NRC ............................................................................... Nuclear Regulatory Commission OCA .............................................................................................. Owner Controlled Area ODCM ............................................................................ Offsite Dose Calculation Manual ORO ..................................................................................Offsite Response Organization PAG.............................................................................................. Protective Action Guide PD .................................................................................................. Permanently Defueled PNP ............................................................................................. Palisades Nuclear Plant rem ........................................................................................... Roentgen Equivalent Man SFP .......................................................................................................... Spent Fuel Pool TEDE................................................................................ Total Effective Dose Equivalent UFSAR ................................................................... Updated Final Safety Analysis Report Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 10

HDI PNP 2022-016 Enclosure, Attachment 2 Page 11 of 40 6.2 Definitions

6.2.1 ALERT

Events are in progress or have occurred which involve an actual or potential substantial degradation of the 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 PAG exposure levels.

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

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

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

6.2.5 EXPLOSION

A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or over pressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.)

should not automatically be considered an explosion. Such events may require a post-event inspection to determine if the attributes of an explosion are present.

6.2.6 FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.

6.2.7 HOSTAGE

A person(s) held as leverage against the licensee to ensure that demands will be met by the facility.

Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 11

HDI PNP 2022-016 Enclosure, Attachment 2 Page 12 of 40 NOTE A Hostile Action-Based program is not necessary for decommissioned nuclear power reactors; however, the consideration of HOSTILE ACTIONS for EAL purposes is still applicable.

6.2.8 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 attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other 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 that are not part of a concerted attack on the facility. Non-terrorism-based EALs should be used to address such activities, (i.e., this may include violent acts between individuals in the Owner Controlled Area (OCA)).

6.2.9 HOSTILE FORCE: One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

6.2.10 IMMINENT: The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

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

6.2.12 INITIATING CONDITION (IC): An event or condition that aligns with the definition of one of the two ECLs by virtue of the potential or actual effects or consequences.

6.2.13 NORMAL LEVELS: As applied to radiological IC/EALs, the highest reading in the past twenty-four hours excluding the current peak value.

6.2.14 OWNER CONTROLLED AREA (OCA): The fenced area containing licensee property.

6.2.15 PROJECTILE: An object directed toward a facility that could cause concern for its continued operability, reliability, or personnel safety.

6.2.16 PROTECTED AREA: The area surrounding PNP encompassed by physical barriers and to which access is controlled.

Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 12

HDI PNP 2022-016 Enclosure, Attachment 2 Page 13 of 40 6.2.17 SECURITY CONDITION: Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the facility. A SECURITY CONDITION does not involve a HOSTILE ACTION.

6.2.18 UNPLANNED: A parameter change or an event that is not: 1) the result of an intended evolution; or 2) an expected facility response to a transient. The cause of the parameter change or event may be known or unknown.

6.2.19 UNUSUAL EVENT (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 protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation occurs.

6.2.20 VISIBLE DAMAGE: Damage to a component or structure that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected component or structure.

7.0 ATTACHMENTS Attachment 1, EAL Matrices Attachment 2, EAL Bases Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 13

HDI PNP 2022-016 Enclosure, Attachment 2 Page 14 of 40 Attachment 1 EAL Matrices Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 14

HDI PNP 2022-016 Enclosure, Attachment 2 Page 15 of 40 Attachment 1 EAL Bases Table PD-1: Recognition Category PD Initiating Condition Summary Matrix UNUSUAL EVENT ALERT PD-AU1 Release of gaseous or liquid PD-AA1 Release of gaseous or liquid radioactivity greater than 2 times the radioactivity resulting in offsite dose Offsite Dose Calculation Manual (ODCM) greater than 10 mRem TEDE or 50 limits for 60 minutes or longer. mRem thyroid CDE.

PD-AU2 UNPLANNED rise in facility PD-AA2 UNPLANNED rise in facility radiation levels. radiation levels that impedes facility access required to maintain spent fuel integrity.

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

PD-HU2 Hazardous event affecting equipment necessary for spent fuel cooling.

PD-HU3 Other conditions exist which in PD-HA3 Other conditions exist which in the judgment of the Emergency Director the judgment of the Emergency Director warrant declaration of an UNUSUAL warrant declaration of an ALERT.

EVENT.

PD-SU1 UNPLANNED spent fuel pool temperature rise.

Table E-1: Recognition Category E Initiating Condition Summary Matrix UNUSUAL EVENT E-HU1 Damage to a loaded cask CONFINEMENT BOUNDARY.

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HDI PNP 2022-016 Enclosure, Attachment 2 Page 16 of 40 Attachment 1 EAL Bases ALERT UNUSUAL EVENT Abnormal Rad Levels / Radiological Effluents PD-AA1 Release of gaseous or liquid radioactivity resulting in PD-AU1 Release of gaseous or liquid radioactivity greater than offsite dose greater than 10 mRem TEDE or 50 mRem 2 times the Offsite Dose Calculation Manual (ODCM) thyroid CDE. limits for 60 minutes or longer.

EMERGENCY ACTION LEVEL (EAL): (1 or 2 or 3 or 4) EMERGENCY ACTION LEVEL (EAL): (1 or 2)

NOTES NOTES

• The Emergency Director should declare the ALERT

• The Emergency Director should declare the UNUSUAL promptly upon determining that the applicable time has EVENT promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded. been exceeded, or will likely be exceeded.

• If an ongoing release is detected and the release start

• If an ongoing release is detected and the release start time is unknown, assume that the release duration has time is unknown, assume that the release duration has exceeded 15 minutes. exceeded 60 minutes.

• If the effluent flow past an effluent monitor is known to

• If the effluent flow past an effluent monitor is known to have stopped due to isolation of the release path, then have stopped due to isolation of the release path, then the effluent monitor reading is no longer valid for the effluent monitor reading is no longer valid for classification purposes. classification purposes.

• The pre-calculated effluent monitor values presented in 1. Valid reading on ANY of the following effluent radiation EAL #1 should be used for emergency classification monitors greater than the reading shown for 60 minutes or Radiological Effluents assessments until the results from a dose assessment longer.

using actual meteorology are available.

Effluent Monitor Classification Thresholds - UNUSUAL EVENT

1. Valid reading on ANY of the following effluent radiation monitors greater than the reading shown for 15 minutes or Monitor UNUSUAL EVENT Threshold Gaseous RIA-2326 2.30E+04 cpm longer.

Liquid RIA-1049 2 X High Alarm Effluent Monitor Classification Thresholds - ALERT Monitor ALERT Threshold RIA-2326 9.00E+06 cpm OR Gaseous Liquid RIA-1049 8.92E+06 cpm 2. Confirmed sample analysis for a gaseous or liquid release OR indicates a concentration or release rate greater than 2 times the ODCM limits for 60 minutes or longer.

2. Dose assessment using actual meteorology indicates doses greater than 10 mRem TEDE or 50 mRem thyroid CDE at or beyond the site boundary.

OR

3. Confirmed 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 the site boundary for one hour of exposure.

OR

4. Field survey results indicate EITHER of the following at or beyond the site boundary:

• Closed window dose rates greater than 10 mRem/hr expected to continue for 60 minutes or longer.

• Analyses of field survey samples indicate thyroid CDE greater than 50 mRem for one hour of inhalation.

Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 16

HDI PNP 2022-016 Enclosure, Attachment 2 Page 17 of 40 Attachment 1 EAL Bases ALERT UNUSUAL EVENT Abnormal Rad Levels / Radiological Effluents PD-AA2 UNPLANNED rise in facility radiation levels that PD-AU2 UNPLANNED rise in facility radiation levels.

impedes facility access required to maintain spent fuel integrity.

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

1. UNPLANNED dose rate greater than 15 mRem/hr in ANY 1. a. UNPLANNED water level drop in the SFP as indicated of the following areas requiring continuous occupancy to by ANY of the following:

Area Rad Levels maintain control of radioactive material or operation of

• EK-1309 systems needed to maintain spent fuel integrity.

• Visual observation of SFP water level

• Control Room (RIA-2310)

• Manual SFP water level measurement

• Central Alarm Station (CAS) (RIA-2311/by survey)

AND OR

b. UNPLANNED rise in area radiation levels as indicated

2. UNPLANNED Area Radiation Monitor readings or survey by spent fuel pool area radiation monitor (RIA-5709 or indicate a rise by 100 mRem/hr over NORMAL LEVELS RIA-2313).

that impedes access to ANY of the following areas needed OR to maintain control of radioactive material or operation of systems needed to maintain spent fuel integrity. 2. Area radiation monitor reading or survey result indicated an UNPLANNED rise of 25 mRem/hr over NORMAL LEVELS.

• SFP Room

• SFP Heat Exchanger Room Hazards and Other Conditions Affecting Facility Safety PD-HA1 HOSTILE ACTION within the OWNER CONTROLLED PD-HU1 Confirmed SECURITY CONDITION or threat.

AREA or airborne attack threat within 30 minutes. EMERGENCY ACTION LEVEL (EAL): (1 or 2 or 3)

EMERGENCY ACTION LEVEL (EAL): (1 or 2) 1. A SECURITY CONDITION that does not involve a

1. A HOSTILE ACTION is occurring or has occurred within HOSTILE ACTION as reported by the Security Shift Security the OWNER CONTROLLED AREA as reported by the Leader.

Leader. OR OR 2. Notification of a credible security threat directed at the site.

2. A validated notification from NRC of an aircraft attack OR threat within 30 minutes of the site. 3. A validated notification from the NRC providing information of an aircraft threat.

PD-HU2 Hazardous event affecting equipment necessary for spent fuel cooling.

EMERGENCY ACTION LEVEL (EAL):

1. a. The occurrence of ANY of the following hazardous events:

• Seismic event (earthquake)

• Internal or External flooding event Hazardous Event

• High winds or tornado strike

• FIRE

• EXPLOSION None

• Other events with similar hazard characteristics as determined by Shift Manager AND

b. The event has damaged at least one SFP cooling pump AND one SFP heat exchanger.

AND

c. The damaged system cannot, or potentially cannot, perform its design function based on EITHER:

• Indications of degraded performance

• VISIBLE DAMAGE Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 17

HDI PNP 2022-016 Enclosure, Attachment 2 Page 18 of 40 Attachment 1 EAL Bases ALERT UNUSUAL EVENT PD-HA3 Other conditions exist which in the judgment of the PD-HU3 Other conditions exist which in the judgment of the Emergency Director warrant declaration of an ALERT. Emergency Director warrant declaration of an Emergency Director Judgment UNUSUAL EVENT.

EMERGENCY ACTION LEVEL (EAL): EMERGENCY ACTION LEVEL (EAL):

Other conditions exist which, in the judgment of the Emergency Other conditions exist which in the judgment of the Emergency Director, indicate that events are in progress or have occurred Director indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of which indicate a potential degradation of the level of safety of the level of safety of the facility or a security event that involves the facility or indicate a security threat to facility protection has probable life threatening risk to site personnel or damage to site been initiated. No releases of radioactive material requiring equipment because of HOSTILE ACTION. Any releases are offsite response or monitoring are expected unless further expected to be limited to small fractions of the EPA Protective degradation of systems needed to maintain spent fuel integrity Action Guideline exposure levels. occurs.

System Malfunctions PD-SU1 UNPLANNED spent fuel pool temperature rise.

Spent Fuel Pool EMERGENCY ACTION LEVEL (EAL):

1. UNPLANNED spent fuel pool temperature rise to greater than 140ºF.

None ISFSI Malfunctions E-HU1 Damage to a loaded cask CONFINEMENT BOUNDARY.

EMERGENCY ACTION LEVEL (EAL):

ISFSI None 1. Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by a radiation reading greater than the applicable values shown on Table E-1 on the spent fuel cask.

Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 18

HDI PNP 2022-016 Enclosure, Attachment 2 Page 19 of 40 Attachment 2 EAL Bases Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 19

HDI PNP 2022-016 Enclosure, Attachment 2 Page 20 of 40 Attachment 2 EAL Bases PD-AU1 EMERGENCY CLASSIFICATION LEVEL:

UNUSUAL EVENT INITIATING CONDITION:

Release of gaseous or liquid radioactivity greater than 2 times the Offsite Dose Calculation Manual (ODCM) limits for 60 minutes or longer.

EMERGENCY ACTION LEVELS (EALs): (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 isolation of the release path, then the effluent monitor reading is no longer valid for classification purposes.

1. Valid reading on ANY of the following effluent radiation monitors greater than the reading shown for 60 minutes or longer.

Effluent Monitor Classification Thresholds - UNUSUAL EVENT Monitor UNUSUAL EVENT Threshold Gaseous RIA-2326 2.30E+04 cpm Liquid RIA-1049 2 X High Alarm OR

2. Confirmed sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times the ODCM limits for 60 minutes or longer.

Basis:

This IC addresses a potential decrease in the level of safety of the facility as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release). It includes any uncontrolled gaseous or liquid radiological release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared.

PNP incorporates design features intended to control the release of radioactive effluents to the environment. Further, there are administrative controls established to prevent Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 20

HDI PNP 2022-016 Enclosure, Attachment 2 Page 21 of 40 Attachment 2 EAL Bases 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 facility conditions alone. The inclusion of both facility 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 isolation of the release path, then the effluent monitor reading is no longer valid for classification purposes.

The 2 x ODCM limit multiples are specified only to distinguish between emergency and non-emergency conditions. While these multiples obviously correspond to an off-site dose or dose rate, the emphasis in classifying these events is the degradation in the level of safety of the plant, not the magnitude of the associated dose or dose rate.

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, 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 ECL would be via IC PD-AA1.

Additional PNP Site-Specific Bases Information Gaseous and liquid releases in excess of two times the ODCM instantaneous limits that continue for 60 minutes or longer represent an uncontrolled situation and hence, a potential degradation in the level of safety. The final integrated dose (which is very low in the UNUSUAL EVENT emergency class) is not the primary concern here; it is the degradation in plant control implied by the fact that the release was not isolated within 60 minutes.

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HDI PNP 2022-016 Enclosure, Attachment 2 Page 22 of 40 Attachment 2 EAL Bases The values shown for each monitor represents two times the calculated monitor alarm set-points (Reference 2) which are set in accordance with the ODCM (Reference 3).

Collecting liquid and gaseous effluent samples to ensure that release conditions above nominal steady state conditions are detected and reported. Confirmed sample analyses in excess of two times the ODCM (Reference 3) that continue for 60 minutes or longer represent an uncontrolled situation and, hence, a potential degradation in the level of safety. The final integrated dose (which is very low in the UNUSUAL EVENT emergency class) is not the primary concern here; it is the degradation in facility control implied by the fact that the release was not isolated within 60 minutes. Therefore, it is not intended that the release be averaged over 60 minutes. For example, a release of 4 times the ODCM limit for 30 minutes does not exceed this initiating condition. Further, the ED should not wait until 60 minutes has elapsed, but should declare the event as soon as it is determined that the release duration has or will likely exceed 60 minutes.

At low classification levels, the concern for classification is the continuing, uncontrolled release of radioactivity and not the magnitude of the release. When the liquid release is isolated, the release is no longer continuing nor is it uncontrolled. Therefore, the classification is not appropriate when the liquid release is isolated.

EAL #2 addresses collecting liquid and gaseous effluent samples to ensure that release conditions above nominal steady state conditions are detected and reported.

Sample analyses are considered "confirmed" when samples have been obtained and analyzed in accordance with plant procedures and the results reported to the Shift Manager or Emergency Director according to established practices. Preliminary sample results that may become available prior to completion of the relevant procedural requirements are not "confirmed" and are not to be used in assessing this EAL.

Basis Reference(s):

1. NEI 99-01, Rev. 6, PD-AU1

2. Enercon Calculation No. ENTGPAL164-CALC-001, Permanently Defueled Gaseous and Liquid Effluent EAL Threshold Calculation Rev. 1, Table 2-1

3. PNP Offsite Dose Calculation Manual Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 22

HDI PNP 2022-016 Enclosure, Attachment 2 Page 23 of 40 Attachment 2 EAL Bases PD-AA1 EMERGENCY CLASSIFICATION LEVEL:

ALERT INITIATING CONDITION:

Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mRem TEDE or 50 mRem thyroid CDE.

EMERGENCY ACTION LEVEL (EALs): (1 or 2 or 3 or 4)

Notes:

• The Emergency Director should declare the ALERT promptly upon determining that the applicable time 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 15 minutes.

• If the effluent flow past an effluent monitor is known to have stopped due to isolation of 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. Valid reading on ANY of the following effluent radiation monitors greater than the reading shown for 15 minutes or longer.

Effluent Monitor Classification Thresholds - ALERT Monitor ALERT Threshold Gaseous RIA-2326 9.00E+06 cpm Liquid RIA-1049 8.92E+06 cpm OR

2. Dose assessment using actual meteorology indicates doses greater than 10 mRem TEDE or 50 mRem thyroid CDE at or beyond the site boundary.

OR

3. Confirmed 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 the site boundary for one hour of exposure.

OR

4. Field survey results indicate EITHER of the following at or beyond the site boundary:

Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 23

HDI PNP 2022-016 Enclosure, Attachment 2 Page 24 of 40 Attachment 2 EAL Bases

• Closed window dose rates greater than 10 mRem/hr expected to continue for 60 minutes or longer.

• Analyses of field survey samples indicate thyroid CDE greater than 50 mRem for one hour of inhalation.

Basis:

This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the facility as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).

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 facility conditions alone. The inclusion of both facility condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mRem while the 50 mRem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

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 isolation of the release path, then the effluent monitor reading is no longer valid for classification purposes.

Additional PNP Site-Specific Bases Information The calculated EAL threshold value for RIA-2326 exceeds the operating range for the effluent monitor (Reference 2). Therefore, a value equal to 90% of the maximum accurate reading of the monitor is used as the threshold to declare an Alert. This value is not based on any particular dose value. However, it ensures that an accurate monitor reading is available, and that an actual or potential substantial degradation of the level of safety of the facility is addressed.

Basis Reference(s):

1. NEI 99-01, Rev. 6, PD-AA1

2. Enercon Calculation No. ENTGPAL164-CALC-001, Permanently Defueled Gaseous and Liquid Effluent EAL Threshold Calculation Rev. 1, Table 2-1

3. PNP ODCM Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 24

HDI PNP 2022-016 Enclosure, Attachment 2 Page 25 of 40 Attachment 2 EAL Bases PD-AU2 EMERGENCY CLASSIFICATION LEVEL:

UNUSUAL EVENT INITIATING CONDITION:

UNPLANNED rise in facility radiation levels.

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

1. a. UNPLANNED water level drop in the SFP as indicated by ANY of the following:

• EK-1309

• Visual observation of SFP water level

• Manual SFP water level measurement AND

b. UNPLANNED rise in area radiation levels as indicated by spent fuel pool area radiation monitor (RIA-5709 or RIA-2313).

OR

2. Area radiation monitor reading or survey result indicated an UNPLANNED rise of 25 mRem/hr over NORMAL LEVELS.

Basis:

This IC addresses elevated facility 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 facility or radioactive materials. Either condition is a potential degradation in the level of safety of the facility.

A water level decrease will be primarily determined by indications from available level instrumentation. Other sources of level indications may include reports from facility personnel. 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.

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HDI PNP 2022-016 Enclosure, Attachment 2 Page 26 of 40 Attachment 2 EAL Bases Escalation of the ECL would be via IC PD-AA1 or PD-AA2.

Additional PNP Site-Specific Bases Information Loss of inventory from the SFP may reduce water shielding above spent fuel and cause unexpected increases in plant radiation. Classification as an UNUSUAL EVENT is warranted as a precursor to a more serious event.

The minimum allowable water level in the (SFP) is the Low Spent Fuel Pool water level.

The low SFP water level alarm setpoint is at 646 ft elevation or 35 ft above the bottom of the SFP. SFP water level is indicated by EK-1309 and alarmed in the Control Room (Reference 2 and 3), or via visual observation or manual SFP water level measurement.

The listed area radiation monitors are those that would likely see an increase in area radiation due to a loss of shielding resulting from a loss of pool inventory (Reference 3).

While a radiation monitor could detect a rise in dose due to a drop in the water level, it might not be a reliable indication, in and of itself, of whether or not the fuel is uncovered.

Elevated radiation monitor indications will need to be combined with another indicator (or personnel report) of water loss.

Calculated dose rates above the SFP and resultant measured dose rates on a nearby ARM (RIA-2313) indicate that measurable increases of radiation will occur when SFP water level drops to approximately the 632 ft elevation and alarm below an elevation of approximately 630 ft elevation (Reference 3).

Assessment of this EAL may be made with survey readings using portable instruments as well as installed radiation monitors.

Basis Reference(s):

1. NEI 99-01, Rev. 6, PD-AU2

2. Permanently Defueled Technical Specifications 3.7.14, Spent Fuel Pool (SFP) Water Level

3. AOP-26, Loss of Spent Fuel Pool Cooling Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 26

HDI PNP 2022-016 Enclosure, Attachment 2 Page 27 of 40 Attachment 2 EAL Bases PD-AA2 EMERGENCY CLASSIFICATION LEVEL:

ALERT INITIATING CONDITION:

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

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

1. UNPLANNED dose rate greater than 15 mRem/hr in ANY of the following areas requiring continuous occupancy to maintain control of radioactive material or operation of systems needed to maintain spent fuel integrity:

• Control Room (RIA-2310)

• Central Alarm Station (CAS) (RIA-2311/by survey)

OR

2. UNPLANNED Area Radiation Monitor readings or survey indicate a rise by 100 mRem/hr over NORMAL LEVELS that impedes access to ANY of the following areas needed to maintain control of radioactive material or operation of systems needed to maintain spent fuel integrity.

• SFP Room

• SFP Heat Exchanger Room Basis:

This IC addresses increased radiation levels that impede necessary access to areas containing equipment that must be operated manually or that 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 facility access. It is this impaired access that results in the actual or potential substantial degradation of the level of safety of the facility.

This IC does not apply to anticipated temporary increases due to planned events.

Additional PNP Site-Specific Bases Information Areas that meet this threshold include the Control Room and the Central Alarm Station (CAS). The Control Room Area Radiation Monitor (RIA-2310) provides indication of area radiation levels in the Control Room.

Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 27

HDI PNP 2022-016 Enclosure, Attachment 2 Page 28 of 40 Attachment 2 EAL Bases The Central Alarm Station (CAS) is included in this EAL because of its importance to permitting access to areas required to assure safe plant operations. CAS has no installed radiation monitoring capability. However, RIA-2311 will provide indication of increasing radiation levels prompting surveys.

Basis Reference(s):

1. NEI 99-01, Rev. 6, PD-AA2 Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 28

HDI PNP 2022-016 Enclosure, Attachment 2 Page 29 of 40 Attachment 2 EAL Bases PD-HU1 EMERGENCY CLASSIFICATION LEVEL:

UNUSUAL EVENT INITIATING CONDITION:

Confirmed SECURITY CONDITION or threat.

EMERGENCY ACTION LEVEL (EALs): (1 or 2 or 3)

1. A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the Security Shift Leader.

OR

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

OR

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

Basis:

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

Security events assessed as HOSTILE ACTIONS are classifiable under IC PD-HA1.

Timely and accurate communications between the Security Shift Leader 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 facility personnel and Offsite Response Organizations (OROs).

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

EAL #1 references the Security Shift Leader because this is the individual 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 the PNP Security Plan (Reference 2).

Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 29

HDI PNP 2022-016 Enclosure, Attachment 2 Page 30 of 40 Attachment 2 EAL Bases EAL #3 addresses the threat from the impact of an aircraft on the facility. 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 is performed by calling the NRC or by other approved methods of authentication.

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 PNP Security Plan.

Escalation of the ECL would be via IC PD-HA1.

Additional PNP Site-Specific Bases Information The intent of these EALs is to ensure that notifications for the aircraft threat are made in a timely manner and that OROs and plant personnel are at a state of heightened awareness regarding the credible threat. It is not the intent of this EAL to replace existing non-hostile related EALs involving aircraft.

The determination of credible is made through use of information found in the PNP Security Plan (Reference 2).

Hostile Action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on PNP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

Basis Reference(s):

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

2. PNP Security Plan Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 30

HDI PNP 2022-016 Enclosure, Attachment 2 Page 31 of 40 Attachment 2 EAL Bases PD-HA1 EMERGENCY CLASSIFICATION LEVEL:

ALERT INITIATING CONDITION:

HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.

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

1. A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the Leader.

OR

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

Basis:

This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the facility and staff for a potential aircraft impact.

Timely and accurate communications between the Security Shift Leader 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 facility staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The ALERT declaration will also heighten the awareness of OROs, 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.

Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 31

HDI PNP 2022-016 Enclosure, Attachment 2 Page 32 of 40 Attachment 2 EAL Bases 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.

EAL #2 addresses the threat from the impact of an aircraft on the facility, 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 facility 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 the PNP Security Plan (Reference 2).

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 PNP Security Plan.

Additional PNP Site-Specific Bases Information HOSTILE ACTION: An act toward a nuclear power plant or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other 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 that are not part of a concerted attack on the nuclear power plant. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

Basis Reference(s):

1. NEI 99-01, Rev. 6, PD-HA1

2. PNP Security Plan Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 32

HDI PNP 2022-016 Enclosure, Attachment 2 Page 33 of 40 Attachment 2 EAL Bases PD-HU2 EMERGENCY CLASSIFICATION LEVEL:

UNUSUAL EVENT INITIATING CONDITION:

Hazardous event affecting equipment necessary for spent fuel cooling.

EMERGENCY ACTION LEVEL (EAL):

1. a. The occurrence of ANY of the following hazardous events:

• Seismic event (earthquake)

• Internal or external flooding event

• High winds or tornado strike

• FIRE

• EXPLOSION

• Other events with similar hazard characteristics as determined by the Shift Manager AND

b. The event has damaged at least one SFP cooling pump AND one SFP heat exchanger.

AND

c. The damaged system cannot, or potentially cannot, perform its design function based on EITHER:

• Indications of degraded performance

• VISIBLE DAMAGE Basis:

This IC addresses a hazardous event that causes damage to at least one train of a system needed for spent fuel cooling. The damage must be of sufficient magnitude that the system(s) train cannot, or potentially cannot, perform its intended 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 facility.

For EAL 1.c., the first bullet addresses damage to equipment that is in service/operation since indications for it will be readily available.

Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 33

HDI PNP 2022-016 Enclosure, Attachment 2 Page 34 of 40 Attachment 2 EAL Bases For EAL 1.c., the second bullet addresses damage to equipment 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 ECL would be via IC PD-AA1 or PD-AA2, PD-HA1 or PD-HA3.

Additional PNP Site-Specific Bases Information The SFP cooling system removes decay heat from spent fuel stored in the SFP. The system was originally designed to remove the decay heat from one-third of the total core fuel elements.

The SFP cooling system is required to maintain the fuel pool water temperature less than 150°F with a minimum of one SFP cooling pump operating. The maximum allowable SFP heat load resulting from off-loaded spent fuel ensures that the SFP water temperature limit of 150°F is maintained with one pump in operation. Heat is removed from the spent fuel pool by the spent fuel pool heat exchanger with component cooling water providing the cooling medium. (Reference 2).

Basis Reference(s):

1. NEI 99-01, Rev. 6, PD-HU2

2. DSAR Section 9.4, Spent Fuel Pool Cooling System Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 34

HDI PNP 2022-016 Enclosure, Attachment 2 Page 35 of 40 Attachment 2 EAL Bases PD-HU3 EMERGENCY CLASSIFICATION LEVEL:

UNUSUAL EVENT INITIATING CONDITION:

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

EMERGENCY ACTION LEVEL (EAL):

Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the facility or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of systems needed to maintain spent fuel integrity occurs.

Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the ECL description for an UNUSUAL EVENT.

Additional PNP Site-Specific Bases Information None Basis Reference(s):

1. NEI 99-01, Rev. 6, PD-HU3

2. PNP Permanently Defueled Emergency Plan, Part 2, Section B, "Emergency Response Organization" Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 35

HDI PNP 2022-016 Enclosure, Attachment 2 Page 36 of 40 Attachment 2 EAL Bases PD-HA3 EMERGENCY CLASSIFICATION LEVEL:

ALERT INITIATING CONDITION:

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

EMERGENCY ACTION LEVEL (EAL):

Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the facility 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.

Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the ECL description for an ALERT.

Additional PNP Site-Specific Bases Information None Basis Reference(s):

1. NEI 99-01, Rev. 6, PD-HA3

2. PNP Permanently Defueled Emergency Plan, Part 2, Section B, "Emergency Response Organization" Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 36

HDI PNP 2022-016 Enclosure, Attachment 2 Page 37 of 40 Attachment 2 EAL Bases PD-SU1 EMERGENCY CLASSIFICATION LEVEL:

UNUSUAL EVENT INITIATING CONDITION:

UNPLANNED spent fuel pool temperature rise.

EMERGENCY ACTION LEVEL (EAL):

UNPLANNED spent fuel pool temperature rise to greater than 140°F.

Basis:

This IC addresses a condition that is a precursor to a more serious event and represents a potential degradation in the level of safety of the facility. If uncorrected, boiling in the SFP will occur, and result in a loss of SFP level and increased radiation levels.

Escalation of the ECL would be via IC PD-AA1 or PD-AA2.

Additional PNP Site-Specific Bases Information AOP-26 (Reference 2) is applicable when there is an unplanned loss of SFP inventory or SFP cooling. This procedure provides instructions to add large volumes of water to the SFP to address beyond design basis events that result in significant losses due to failures of the SFP. Entry into AOP-26 occurs based on HI-HI SFP Temperature Alarm on TIA_0925_D and TIA_0926_D of 140°F.

On-shift personnel will provide initial mitigation for a loss of SFP cooling based on SFP high temperature alarm on TIA_0925_D and TIA_0926_D of 125°F (Reference 3).

Based on RX-EA-SFPHEATUP-11-01 (Reference 4), for a loss of SFP Cooling, at 365 days after shutdown, the heat up rate in the SFP would be approximately 3.5°F per hour. Using the entry condition for the Loss of Spent Fuel Pooling procedure as the EAL threshold provides a precursor for additional actions to restore SFP cooling and provides approximately 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> to mitigate before SFP boiling were to occur.

Basis Reference(s):

1. NEI 99-01, Rev. 6, PD-SU1

2. AOP-26, Loss of Spent Fuel Pool Cooling

3. SOP-27, Fuel Pool System

4. Calculation No. RX-EA-SFPHEATUP-11-01, "Palisades Spent Fuel Pool Heatup Calculation," Revision 6, Attachment 9.8 Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 37

NL-21-012 Page 38 of 40 Attachment 2 EAL Bases E-HU1 EMERGENCY CLASSIFICATION LEVEL:

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

EMERGENCY ACTION LEVEL (EAL):

Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by a radiation reading greater than the applicable values shown on Table E-1 on the spent fuel cask.

Table E-1 Cask Dose Rates Cask System Casks Dose Rates 40 mrem/hr on the sides Ventilated Storage Cask All 100 mrem/hr on the top System (VSC-24) 100 mrem/hr at inlet and outlet ducts 1600 mrem/hr on the HSM front surface 32PT 400 mrem/hr on the HSM door centerline HSM-001 thru HSM-011 16 mrem/hr on the end shield wall exterior Standardized NUHOMS 2600 mrem/hr on the HSM front surface 24PTH 10 mrem/hr on the HSM door centerline HSM-H-012 thru HSM-H-024 20 mrem/hr on the end shield wall exterior 60 mrem/hr (gamma + neutron) on the top of the OVERPACK HI-STORM FW MPC All 600 mrem/hr (gamma + neutron) on the OVERPACK, excluding inlet and outlet ducts Basis:

This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage cask is sealed. The issues of concern are the creation of a potential or actual release path to the environment, degradation of one or more fuel assemblies due to environmental factors, and Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 38

NL-21-012 Page 39 of 40 Attachment 2 EAL Bases configuration changes which could cause challenges in removing the cask or fuel from storage.

The existence of damage is determined by radiological survey. The technical specification multiple of 2 times is used here to distinguish between non-emergency and emergency conditions. The emphasis for this classification is the degradation in the level of safety of the spent fuel cask and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the 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 PD-HU1 and PD-HA1.

Additional PNP Site-Specific Bases Information The PNP ISFSIs utilize multiple dry spent fuel storage systems. These systems consist of the Ventilated Storage Cask System (VSC-24) (Reference 2); the NUHOMS Horizontal Modular Storage System (32PT and 24PTH) (References 3 and 4); and the HI-STORM Flood/Wind (FW) Multipurpose Canister (MPC) Cask System (Reference 5).

The dose rates included in Table E-1 equate to two-times the cask-specific technical specification allowable radiation value for each of the cask systems (References 2, 3, 4, and 5).

This EAL addresses any condition which indicates a loss of a cask CONFINEMENT BOUNDARY and thus a potential degradation in the level of safety of the ISFSI.

Minor surface damage that does not affect storage cask boundary is excluded from the scope of this EAL.

Basis Reference(s):

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

2. Renewal of Initial Certificate of Compliance and Amendments No. 1 through 6 of Certificate of Compliance No. 1007 for the VSC-24 Cask System, Enclosure # -

Attachment A, Technical Specification 1.2.4

3. Renewal of Initial Certificate of Compliance and Amendments No. 1 through 11 and 13, Revision 1, and Amendment No. 14 of Certificate of Compliance No. 1004 for the Standardized NUHOMS Horizontal Modular Storage System, Enclosure 16 (Amendment No. 7, Revision 1) Technical Specification 1.2.7a

4. Renewal of Initial Certificate of Compliance and Amendments No. 1 through 11 and 13, Revision 1, and Amendment No. 14 of Certificate of Compliance No. 1004 for the Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 39

NL-21-012 Page 40 of 40 Attachment 2 EAL Bases Standardized NUHOMS Horizontal Modular Storage System, Enclosure 16 (Amendment No. 9, Revision 1) Technical Specification 1.2.7c

5. Issuance Certification of Compliance No. 1032, Amendment No. 1 Revision No. 1, for the HI-STORM Flood/Wind Multipurpose Canister Storage System (TAC No.

L24775), Appendix A Technical Specification 5.3.4 Palisades Nuclear Plant Permanently Defueled EAL Technical Bases Document Rev. 0 Page 40

Attachment 3 to Enclosure HDI PNP 2022-016 Comparison Matrix for Permanently Defueled Emergency Action Levels Based on NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors," Revision 6

HDI PNP 2022-016 Enclosure, Attachment 3 Page 1 of 38 COMPARISON MATRIX FOR PERMANENTLY DEFUELED EMERGENCY ACTION LEVELS BASED ON NEI 99-01, "DEVELOPMENT OF EMERGENCY ACTION LEVELS FOR NON-PASSIVE REACTORS," REVISION 6 Description of the Permanently Defueled EAL Technical Bases Document The following discussion provides a description of the Palisades Nuclear Plant (PNP)

Permanently Defueled (PD) Emergency Action Level (EAL) Technical Bases Document (provided as Attachment 2 of this Enclosure) and describes any differences and/or deviations between the PNP PD EAL Technical Bases and the guidance presented in Nuclear Energy Institute (NEI) 99-01, "Development of Emergency Action Levels for Non-Passive Reactors,"

Revision 6 (hereinafter referred to as NEI 99-01).

The PNP PD EAL Technical Bases Document provides a stand-alone set of Initiating Conditions (ICs)/EALs to address the permanently shutdown and defueled condition of the PNP reactor.

1.0 PURPOSE The PNP PD EAL Technical Bases Document includes references to Recognition Category PD and Recognition Category E ICs/EALs for the permanently shutdown and defueled reactor and the Independent Spent Fuel Storage Installations (ISFSIs). A comparison between the "Purpose" section of the PNP PD EAL Technical Bases Document and a corresponding section of NEI 99-01 was not performed.

2.0 DISCUSSION The "Discussion" section in the PNP PD EAL Technical Bases Document was developed based on information contained in NEI 99-01, Section 1, Regulatory Background. This section provides a description of a permanently defueled station (Section 2.1) and an ISFSI (Section 2.2). It also provides specific criteria for an ISFSI as it pertains to other regulations and guidance in NEI 99-01.

Section 1.1, Operating Reactors, of NEI 99-01 was excluded from the PNP PD EAL Technical Bases Document because it pertains to operating reactors. By letter dated June 13, 2022, pursuant to 10 CFR 50.82(a)(1)(i), Entergy submitted a certification to the NRC, that power operations ceased at PNP on May 20, 2022. In addition, in accordance with 10 CFR 50.82(a)(1)(ii), Entergy also certified that the spent fuel was permanently removed from the PNP reactor vessel and placed in the PNP SFP on June 10, 2022. Upon the NRC's docketing of the certification that all fuel has been permanently removed from the PNP reactor vessel and placed into the spent fuel pool (SFP), in accordance with 10 CFR 50.82(a)(2), the license for PNP no longer authorizes operation of the reactor, nor emplacement or retention of fuel into the reactor vessel. Therefore, Section 1.1 of NEI 99-01 is not applicable to PNP.

Section 1.2, "Permanently Defueled Station," of NEI 99-01 is addressed in Section 2.1 of the PNP PD EAL Technical Bases Document. Inclusion of this discussion is appropriate because the PNP reactor has been permanently shutdown and defueled prior to implementation of this PD EAL scheme, and analyses have been completed that demonstrate that no credible event can result in a significant radiological release beyond the site boundary. As described in the Enclosure to this amendment request, HDI has performed analyses which demonstrate that

HDI PNP 2022-016 Enclosure, Attachment 3 Page 2 of 38 approximately 12 months after permanent cessation of power operations, the spent fuel stored in the SFP will have decayed to the extent that a minimum of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> is available before the fuel cladding temperature of the hottest fuel assembly in the SFP reaches 900°C with a complete loss of SFP water inventory, assuming no heat loss (adiabatic heat up). Based on the results of these analyses, in the unlikely event of a beyond design basis event involving the PNP SFP, a minimum of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> is available to initiate appropriate mitigating actions to restore a means of heat removal to the spent fuel and, if governmental officials deem warranted, for authorities to implement offsite protective actions using a comprehensive approach to emergency planning to protect the health and safety of the public before the hottest fuel assembly reaches the rapid oxidation temperature. Implementation of the PD EAL scheme would occur approximately 12 months after permanent shutdown of PNP.

Section 1.3, "Independent Spent Fuel Storage Installation (ISFSI)," of NEI 99-01 is addressed in Section 2.2 of the PNP PD EAL Technical Bases Document. Inclusion of this discussion is appropriate because two ISFSIs are in use at PNP.

Section 1.4, "NRC Order EA-12-051," of NEI 99-01 was excluded from the PNP PD EAL Technical Bases Document because the recommendation applies to NEI 99-01 EALs IC AA2, AS2, and AG2, which are only applicable to operating plants. Therefore, the discussion in Section 1.4 of NEI 99-01 does not apply to PNP and has not been included in the PD EAL Technical Bases Document.

Section 1.5, Applicability to Advanced and Small Modular Reactor Designs, of NEI 99-01 was excluded from the PNP PD EAL Technical Bases Document because PNP does not utilize Advanced or Small Modular Reactors Designs. Therefore, the discussion in Section 1.5 of NEI 99-01 does not apply to PNP and has not been included in the PD EAL Technical Bases Document.

3.0 KEY TERMINOLOGY USED This section in of the PNP PD EAL Technical Bases Document was developed based on information contained in Section 2, "Key Terminology Used in NEI 99-01," of NEI 99-01.

Differences between the PNP PD EAL Technical Bases Document and NEI 99-01 are discussed below.

• References to Site Area Emergency and General Emergency were excluded from the PNP PD EAL Technical Bases Document. PNP's Emergency Classification Levels (ECLs) only include Notification of Unusual Event (Unusual Event) and Alert. The PNP PD EALs have been developed using NEI 99-01, Appendix C for the permanently defueled station ICs/EALs and Section 8 for the ISFSIs.

• References to plant were revised to facility to indicate that PNP is no longer an operating nuclear power plant.

• References to Reactor Coolant System (RCS) Leakage and fission product barriers were excluded from PNP PD EAL Technical Bases Document, Section 3.2, Initiating Condition (IC) (Section 2.2 of NEI 99-01). Upon permanent removal of fuel from the PNP reactor, the RCS and Containment will no longer be considered fission product barriers because the reactor will be permanently shutdown and defueled and

HDI PNP 2022-016 Enclosure, Attachment 3 Page 3 of 38 containment integrity is not needed for the SFP. In the permanently shutdown and defueled condition, the fuel cladding is a fission product barrier. However, the Recognition Category "F" matrices containing EALs referred to as Fission Product Barrier Thresholds, are not applicable in the permanently shutdown and defueled condition.

• The purpose of the "Alert" Section 2.1.2 of NEI 99-01 was revised to indicate that emergency personnel would respond at an Alert declaration, rather than "be readily available to respond," to correspond with the actions at an Alert declaration as detailed in the PNP PDEP (provided as Attachment 1 of this Enclosure).

• Section 2.4, Fission Product Barrier Threshold, of NEI 99-01 was excluded for reasons previously identified related to fission product barriers.

4.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS This section of the PNP PD EAL Technical Bases Document was developed based on guidance contained in Section 5, Guidance on Making Emergency Classifications, of NEI 99-01.

Differences between the PNP Permanently Defueled EAL Technical Bases Document and the corresponding section of NEI 99-01 are discussed below.

• References to fission product barrier thresholds in Section 5.1 of NEI 99-01 (Section 4.1 of the PNP PD EAL Technical Bases Document) were excluded as the RCS and Containment will no longer serve as fission product barriers upon permanent cessation of power operations and permanent removal of fuel from the PNP reactor vessel.

• Reference to "Operating Mode Applicability" was removed because Operating Modes are not applicable to a permanently shutdown and defueled facility.

• The second paragraph of Section 5.1 of NEI 99-01 stating that, regulations require the licensee to establish and maintain the capability to assess, classify and declare an emergency condition within 15 minutes, was excluded from Section 4.1 of the PNP PD EAL Technical Bases Document. As detailed in NSIR/DPR-ISG-02, Interim Staff Guidance, Emergency Planning Exemption Requests for Decommissioning Plants, (ISG-02) the staff concludes that a decommissioning power reactor is not required to assess, classify, and declare an emergency condition within 15 minutes. PNP will maintain the ability to assess, classify, and declare an emergency within 30 minutes. As described in Section 1.0 of the PNP PD EAL Technical Bases Document, an emergency declaration is required to be made as soon as conditions warranting classification are present and recognizable, but within 30 minutes in all cases after the availability of indications that an EAL threshold has been reached.

• With respect to the notification of an emergency declaration to State and local authorities, as discussed in the Enclosure to this amendment request, The analyses of the potential radiological impact of accidents while the facility is in a permanently defueled condition indicate that no DBA or reasonably conceivable beyond design basis accident would result in radioactive releases that exceed U.S. Environmental Protection Agency (EPA) Protective Action Guidelines (PAGs) (Reference 8) beyond the exclusion area boundary (EAB). In the permanently defueled condition, the rapidly developing

HDI PNP 2022-016 Enclosure, Attachment 3 Page 4 of 38 scenarios associated with events initiated during reactor power operation are no longer credible. The radiological consequences resulting from the only remaining events develop over a significantly longer period. As such, a 15-minute notification requirement is unnecessarily restrictive. A notification time of 60 minutes after declaring an emergency provides a reasonable amount of time to notify state and local governmental authorities.

• Reference to "Operating Mode Applicability" was excluded from Section 4.2 of the PNP PD EAL Technical Bases Document (Section 5.2 of NEI 99-01), because Operating Modes are not applicable to a permanently defueled facility.

• Section 5.4 of NEI 99-01 was excluded from the PNP PD EAL Technical Bases Document because mode changes during classification are not applicable to a permanently defueled facility.

• In Section 4.4 of the PNPC PD EAL Technical Bases Document (Section 5.5 of NEI 99-01), the word levels was changed to level within the term "Emergency Classification Levels (ECLs) because there is only one higher emergency classification level above an Unusual Event for a permanently defueled facility.

• In Section 4.5 of the PNP PD EAL Technical Bases Document (Section 5.6 of NEI 99-01), references to "Site Area Emergency" and "General Emergency" were excluded.

Based on the analyses described in the Enclosure to this submittal, the "Site Area Emergency" and "General Emergency" classification levels are no longer credible emergency classifications at PNP, and no DBA or reasonable conceivable beyond design basis accident will result in radiological releases requiring offsite protective actions. PNP will not downgrade events.

• In Section 4.6 of the PNP PD EAL Technical Bases Document (Section 5.7 of NEI 99-01), references to an "operating plant short-lived event (e.g., reactor trip)" were removed and replaced with verbiage applicable to a permanently shutdown and defueled facility.

The given example was changed to an "explosion" because the example provided in NEI 99-01, ("failure of the reactor protection system to automatically scram/trip the reactor followed by a successful manual scram/trip") is not possible for a permanently shutdown and defueled facility.

• In Section 4.7 of the PNP PD EAL Technical Bases Document (Section 5.8 of NEI 99-01), the given example was removed because an emergency declaration associated with the auxiliary feedwater system is no longer credible at PNP. The reference to "15-minute emergency classification assessment period" was excluded because the timeframe is not applicable to a permanently shutdown and defueled facility. However, consistent with NEI 99-01, the PNP PDEP EAL Technical Bases Document indicates that the emergency classification assessment period is not a "grace period."

5.0 REFERENCES

This section of the PNP PD EAL Technical Bases Document was added to provide Developmental and Implementing References applicable to the PNP PD EAL Technical Bases.

No corresponding section is included in NEI 99-01.

HDI PNP 2022-016 Enclosure, Attachment 3 Page 5 of 38 6.0 DEFINITIONS AND ACRONYMS This section of the PNP PD EAL Technical Bases Document was developed based on the information presented in Appendices A and B of NEI 99-01. The section incorporates only those acronyms and definitions applicable to, and used in, the PNP PD EAL Technical Bases Document.

• The following definitions contained within NEI 99-01 are not used in the PNP PD EAL Technical Bases Document, as previously discussed:

• General Emergency

• Site Area Emergency

• The definition for "Alert" was revised to change "plant" to "facility" and to delete "of safety systems." The reference to plant was revised to facility to indicate that PNP is no longer an operating nuclear power plant. The term safety system was excluded because only those systems required to maintain spent fuel cooling are necessary in the permanently shutdown and defueled condition. These systems, by definition, are not "safety systems."

• The definition for "Notification of Unusual Event (NOUE)" was revised to change "plant" to "facility" and to delete "of safety systems" for reasons detailed in the preceding bullet.

• The following key term is not used in the PNP PD EAL Technical Bases Document for reasons previously provided:

• Fission Product Barrier Threshold

• The key term, "Initiating Condition," was revised to change four emergency classification levels to two emergency classification levels because the "Site Area Emergency" and "General Emergency" are not applicable to a permanently shutdown and defueled facility.

• The key term, "Emergency Classification Level," was revised to exclude reference to "Site Area Emergency" and "General Emergency" because the classification levels are no longer credible emergency classifications at PNP, and no DBA or reasonable conceivable beyond design basis accident will result in radiological releases requiring offsite protective actions.

Selected terms used in IC and EAL statements are set in all capital letters (e.g., ALL CAPS).

These words are defined terms that have specific meanings as used in NEI 99-01. Definitions not used in the PNP PD EAL Technical Bases Document were excluded.

The term SAFETY SYSTEM was excluded because only those systems required to maintain spent fuel cooling are necessary in the permanently shutdown and defueled condition. These systems, by definition, are not SAFETY SYSTEMS.

HDI PNP 2022-016 Enclosure, Attachment 3 Page 6 of 38 7.0 ATTACHMENTS 7.1 Attachment 1, EAL Matrices

• References to "Operating Modes" were excluded from PNP PD EAL Technical Bases Document Tables PD-1 and E-1 because Operating Modes are not applicable to a permanently shutdown and defueled facility.

• The EALs were developed using Appendix C (Recognition Category "PD") and Section 8 (Recognition Category "E") of NEI 99-01.

7.2 Attachment 2, EAL Bases

• Attachment 2 of the PNP PD EAL Technical Bases Document provides the Permanently Defueled and ISFSI IC/EALs and incorporates Appendix C (Recognition Category "PD")

and Section 8 (Recognition Category "E") of NEI 99-01.

• Reference to Section 3 of NEI 99-01, "Design of the NEI 99-01 Emergency Classification Scheme," was excluded from Attachment 2 because this section was not included in the PNP PD EAL Technical Bases Document (provided as Attachment 2 of this Enclosure).

The table included below provides a comparison of the PNP EALs (PD and ISFSI) against the corresponding information contained in NEI 99-01.

8.0 NEI 99-01 SECTIONS NOT INCLUDED IN THE PNP PD EAL TECHNICAL BASES DOCUMENT The following sections of NEI 99-01 were excluded from the PNP PD EAL Technical Bases Document. Any references made to these sections in NEI 99-01 were also excluded:

• Section 3, Design of the NEI 99-01 Emergency Classification Scheme

• Section 4, Site-Specific Scheme Development Guidance The following sections of NEI 99-01 were excluded from the PNP PD EAL Technical Bases Document because these sections do not apply to a permanently shutdown and 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, and

• Section 11, System Malfunction ICs/EALs

HDI PNP 2022-016 Enclosure, Attachment 3 Page 7 of 38 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for PNP PD-AU1 PD-AU1 No Change Difference Deviation ECL: Notification of Unusual Event ECL: UNUSUAL EVENT

• ECL: Changed Notification of Unusual Event Initiating Condition: Release of gaseous or Initiating Condition: Release of gaseous or liquid to UNUSUAL EVENT to maintain continuity liquid radioactivity greater than 2 times the (site- radioactivity greater than 2 times the Offsite Dose with the previous PNP EAL scheme specific effluent release controlling document) Calculation Manual (ODCM) limits for 60 minutes or

• Initiating Condition: Inserted Offsite Dose limits for 60 minutes or longer. longer. Calculation Manual (ODCM) as the site-specific Operating Mode Applicability: Not Applicable Emergency Action Levels (EALs): (1 or 2) effluent release controlling document Example Emergency Action Levels: (1 or 2) Notes:

• Removed "Operating Mode Applicability" as it does not apply in the permanently defueled Notes:

• The Emergency Director should declare the condition UNUSUAL EVENT promptly upon determining

• The Emergency Director should declare the

• Removed Example from EALs as they are no that 60 minutes has been exceeded, or will likely Unusual Event promptly upon determining that longer examples be exceeded.

60 minutes has been exceeded, or will likely be exceeded.

• If an ongoing release is detected and the release

• Notes, Bullet #3: Replaced "have stopped due start time is unknown, assume that the release to actions to isolate the release path" with "have

• If an ongoing release is detected and the stopped due to isolation of the release path" duration has exceeded 60 minutes.

release start time is unknown, assume that the release duration has exceeded 60 minutes.

• If the effluent flow past an effluent monitor is

• Added "OR" between the EALs as an operator known to have stopped due to isolation of the aid to facilitate EAL navigation.

• If the effluent flow past an effluent monitor is release path, then the effluent monitor reading is known to have stopped due to actions to isolate no longer valid for classification purposes.

the release path, then the effluent monitor reading is no longer valid for classification 1. Valid reading on ANY of the following effluent purposes. radiation monitors greater than the reading

• EAL #1: Added Valid shown for 60 minutes or longer.

(1) Reading on ANY effluent radiation monitor

• EAL #1: Provided PNP site-specific effluent greater than 2 times the alarm setpoint Effluent Monitor Classification Thresholds - UNUSUAL EVENT radiation monitors and calculated threshold established by a current radioactivity discharge Monitor UNUSUAL EVENT Threshold values permit for 60 minutes or longer. Gaseous RIA-2326 2.30E+04 cpm Liquid RIA-1049 2 X High Alarm

• EAL #1: Replaced 2 times the alarm setpoint established by a current radioactivity discharge (2) Sample analysis for a gaseous or liquid OR permit with "the reading shown" and included release indicates a concentration or release rate 2. Confirmed sample analysis for a gaseous or PNP site-specific calculated effluent radiation greater than 2 times the (site-specific effluent liquid release indicates a concentration or monitor threshold values on which to base the release controlling document) limits for 60 minutes release rate greater than two times the ODCM declaration of an UNUSUAL EVENT.

or longer. limits for 60 minutes or longer.

• EAL #2: Added "Confirmed"

HDI PNP 2022-016 Enclosure, Attachment 3 Page 8 of 38 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for PNP

• EAL #2: Inserted "ODCM" as the site-specific effluent release controlling document Basis: Basis: No Change Difference Deviation This IC addresses a potential decrease in the level This IC addresses a potential decrease in the level of

• Replaced plant with facility of safety of the plant as indicated by a low-level safety of the facility as indicated by a low-level radiological release that exceeds regulatory radiological release that exceeds regulatory commitments for an extended period of time (e.g., commitments for an extended period of time (e.g., an an uncontrolled release). It includes any gaseous uncontrolled release). It includes any uncontrolled

• Added "uncontrolled" without changing the or liquid radiological release, monitored or un- gaseous or liquid radiological release, monitored or intent of the EAL monitored, including those for which a radioactivity un-monitored, including those for which a discharge permit is normally prepared. radioactivity discharge permit is normally prepared.

Nuclear power plants incorporate design features PNP incorporates design features intended to control

• Replaced "Nuclear power plants" with "PNP" to intended to control the release of radioactive the release of radioactive effluents to the incorporate PNP site-specific information effluents to the environment. Further, there are environment. Further, there are administrative administrative controls established to prevent controls established to prevent unintentional unintentional releases, and to control and monitor releases, and to control and monitor intentional intentional releases. The occurrence of an releases. The occurrence of an extended, extended, uncontrolled radioactive release to the uncontrolled radioactive release to the environment is environment is indicative of degradation in these indicative of degradation in these features and/or features and/or controls. controls.

Radiological effluent EALs are also included to Radiological effluent EALs are also included to provide a basis for classifying events and provide a basis for classifying events and conditions conditions that cannot be readily or appropriately that cannot be readily or appropriately classified on classified on the basis of plant conditions alone. the basis of facility conditions alone. The inclusion of The inclusion of both plant condition and both facility condition and radiological effluent EALs radiological effluent EALs more fully addresses more fully addresses the spectrum of possible the spectrum of possible accident events and accident events and conditions.

conditions.

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

• Replaced "have stopped due to actions to assumes that a release path to the environment is established. If the effluent flow past an effluent isolate the release path" with "have stopped established. If the effluent flow past an effluent monitor is known to have stopped due to isolation of due to isolation of the release path" consistent monitor is known to have stopped due to actions with the change made in the Notes to isolate the release path, then the effluent

HDI PNP 2022-016 Enclosure, Attachment 3 Page 9 of 38 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for PNP monitor reading is no longer valid for classification the release path, then the effluent monitor reading is purposes. no longer valid for classification purposes.

Releases should not be prorated or averaged. For The 2 x ODCM limit multiples are specified only to example, a release exceeding 4 times release distinguish between emergency and non-emergency limits for 30 minutes does not meet the EAL. conditions. While these multiples obviously correspond to an off-site dose or dose rate, the EAL #1 - This EAL addresses radioactivity emphasis in classifying these events is the releases that cause effluent radiation monitor degradation in the level of safety of the plant, not the readings to exceed 2 times the limit established by magnitude of the associated dose or dose rate.

a radioactivity discharge permit. This EAL will typically be associated with planned batch Releases should not be prorated or averaged. For releases from non-continuous release pathways example, a release exceeding 4 times release limits (e.g., radwaste, waste gas). for 30 minutes does not meet the EAL.

EAL #2 - This EAL addresses uncontrolled EAL #1 - This EAL addresses radioactivity releases gaseous or liquid releases that are detected by that cause effluent radiation monitor readings to sample analyses or environmental surveys, exceed 2 times the limit established by a radioactivity particularly on unmonitored pathways (e.g., spills discharge permit. This EAL will typically be of radioactive liquids into storm drains, heat associated with planned batch releases from non-exchanger leakage in river water systems, etc.). continuous release pathways (e.g., radwaste, waste gas).

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

• Provided PNP site-specific basis information and references Additional PNP Site-Specific Bases Information Gaseous and liquid releases in excess of two times the ODCM instantaneous limits that continue for 60 minutes or longer represent an uncontrolled situation and hence, a potential degradation in the level of safety. The final integrated dose (which is very low in the UNUSUAL EVENT emergency class) is not the primary concern here; it is the degradation in plant

HDI PNP 2022-016 Enclosure, Attachment 3 Page 10 of 38 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for PNP control implied by the fact that the release was not isolated within 60 minutes.

The values shown for each monitor represents two times the calculated monitor alarm set-points (Reference 2) which are set in accordance with the ODCM (Reference 3).

Collecting liquid and gaseous effluent samples to ensure that release conditions above nominal steady state conditions are detected and reported.

Confirmed sample analyses in excess of two times the ODCM (Reference 3) that continue for 60 minutes or longer represent an uncontrolled situation and, hence, a potential degradation in the level of safety. The final integrated dose (which is very low in the UNUSUAL EVENT emergency class) is not the primary concern here; it is the degradation in facility control implied by the fact that the release was not isolated within 60 minutes. Therefore, it is not intended that the release be averaged over 60 minutes. For example, a release of 4 times the ODCM limit for 30 minutes does not exceed this initiating condition. Further, the ED should not wait until 60 minutes has elapsed, but should declare the event as soon as it is determined that the release duration has or will likely exceed 60 minutes.

At low classification levels, the concern for classification is the continuing, uncontrolled release of radioactivity and not the magnitude of the release.

When the liquid release is isolated, the release is no longer continuing nor is it uncontrolled. Therefore, the classification is not appropriate when the liquid release is isolated.

EAL #2 addresses collecting liquid and gaseous effluent samples to ensure that release conditions above nominal steady state conditions are detected and reported.

HDI PNP 2022-016 Enclosure, Attachment 3 Page 11 of 38 NEI 99-01 Rev 6 Appendix C - Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for PNP Sample analyses are considered "confirmed" when samples have been obtained and analyzed in accordance with plant procedures and the results reported to the Shift Manager or Emergency Director according to established practices. Preliminary sample results that may become available prior to completion of the relevant procedural requirements are not "confirmed" and are not to be used in assessing this EAL.

Basis Reference(s):

1. NEI 99-01, Rev. 6, PD-AU1

2. Enercon Calculation No. ENTGPAL164-CALC-001, Permanently Defueled Gaseous and Liquid Effluent EAL Threshold Calculation Rev. 1, Table 2-1

3. PNP Offsite Dose Calculation Manual

HDI PNP 2022-016 Enclosure, Attachment 3 Page 12 of 38 NEI 99-01 Rev 6 Appendix C - Permanently Proposed Permanently Defueled Comparison Defueled Station ICs/EALs EAL for PNP PD-AA1 PD-AA1 No Change Difference Deviation ECL: Alert ECL: ALERT

• Removed "Operating Mode Applicability" as it Initiating Condition: Release of gaseous or liquid Initiating Condition: Release of gaseous or liquid does not apply in the permanently defueled radioactivity resulting in offsite dose greater than radioactivity resulting in offsite dose greater than 10 condition 10 mrem TEDE or 50 mrem thyroid CDE. mRem TEDE or 50 mRem thyroid CDE.

• Removed Example from EALs as they are no Operating Mode Applicability: Not Applicable Emergency Action Levels (EALs): (1 or 2 or 3 or longer examples

4)

• Notes, Bullet #3: Replaced "have stopped due Example Emergency Action Levels: (1 or 2 or 3 or 4) Notes: to actions to isolate the release path" with "have stopped due to isolation of the release path" Notes: The Emergency Director should declare the ALERT promptly upon determining that the The Emergency Director should declare the applicable time has been exceeded, or will likely Alert promptly upon determining that the be exceeded.

applicable time 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 If an ongoing release is detected and the duration has exceeded 15 minutes.

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 isolation of the If the effluent flow past an effluent monitor is release path, then the effluent monitor reading is known to have stopped due to actions to no longer valid for classification purposes.

isolate the release path, then the effluent monitor reading is no longer valid for The pre-calculated effluent monitor values classification purposes. presented in EAL #1 should be used for emergency classification assessments until the The pre-calculated effluent monitor values results from a dose assessment using actual presented in EAL #1 should be used for meteorology are available.

emergency classification assessments until the results from a dose assessment using actual meteorology are available.

1) Reading on ANY of the following 1. Valid reading on ANY of the following effluent No Change Difference Deviation radiation monitors greater than the radiation monitors greater than the reading reading shown for 15 minutes or shown for 15 minutes or longer.

HDI PNP 2022-016 Enclosure, Attachment 3 Page 13 of 38 NEI 99-01 Rev 6 Appendix C - Permanently Proposed Permanently Defueled Comparison Defueled Station ICs/EALs EAL for PNP longer: Effluent Monitor Classification Thresholds - ALERT

• Added "OR" between the EALs as an operator Monitor ALERT Threshold aid to facilitate EAL navigation.

(site-specific monitor list and threshold Gaseous RIA-2326 9.00E+06 cpm values) Liquid RIA-1049 8.92E+06 cpm

• EAL #1: Added Valid

2) Dose assessment using actual OR

• EAL #1: Provided PNP site-specific effluent meteorology indicates doses greater radiation monitors and calculated threshold than 10 mrem TEDE or 50 mrem 2. Dose assessment using actual meteorology values thyroid CDE at or beyond (site-specific indicates doses greater than 10 mRem TEDE or dose receptor point). 50 mRem thyroid CDE at or beyond the site boundary.

3) Analysis of a liquid effluent sample indicates a concentration or release OR rate that would result in doses greater 3. Confirmed analysis of a liquid effluent sample than 10 mrem TEDE or 50 mrem indicates a concentration or release rate that thyroid CDE at or beyond (site-specific would result in doses greater than 10 mRem dose receptor point) for one hour of TEDE or 50 mRem thyroid CDE at or beyond exposure.

• EAL #2: Provided the site boundary as the the site boundary for one hour of exposure.

site-specific dose receptor point

4) Field survey results indicate EITHER OR of the following at or beyond (site-specific dose receptor point): 4. Field survey results indicate EITHER of the following at or beyond the site boundary:

• Closed window dose rates greater than 10 mR/hr expected to

• Closed window dose rates greater than 10

• EAL #3: Added "Confirmed" continue for 60 minutes or longer. mR/hr expected to continue for 60 minutes

• EAL #3: Provided the site boundary as the or longer. site-specific dose receptor point

• Analyses of field survey samples indicate thyroid CDE greater than

• Analyses of field survey samples indicate 50 mrem for one hour of thyroid CDE greater than 50 mRem for one inhalation. hour of inhalation.

• EAL #4: Provided the site boundary as the site-specific dose receptor point Basis: Basis: No Change Difference Deviation This IC addresses a release of gaseous or liquid This IC addresses a release of gaseous or liquid

• Replaced plant with facility radioactivity that results in projected or actual radioactivity that results in projected or actual offsite offsite doses greater than or equal to 1% of the doses greater than or equal to 1% of the EPA EPA PAGs. It includes both monitored and un- Protective Action Guides (PAGs). It includes both monitored releases. Releases of this magnitude monitored and un-monitored releases. Releases of represent an actual or potential substantial this magnitude represent an actual or potential

HDI PNP 2022-016 Enclosure, Attachment 3 Page 14 of 38 NEI 99-01 Rev 6 Appendix C - Permanently Proposed Permanently Defueled Comparison Defueled Station ICs/EALs EAL for PNP degradation of the level of safety of the plant as substantial degradation of the level of safety of the indicated by a radiological release that significantly facility as indicated by a radiological release that exceeds regulatory limits (e.g., a significant significantly exceeds regulatory limits (e.g., a uncontrolled release). significant uncontrolled release).

Radiological effluent EALs are also included to Radiological effluent EALs are also included to provide a basis for classifying events and provide a basis for classifying events and conditions conditions that cannot be readily or appropriately that cannot be readily or appropriately classified on classified on the basis of plant conditions alone. the basis of facility conditions alone. The inclusion The inclusion of both plant condition and of both facility condition and radiological effluent radiological effluent EALs more fully addresses the EALs more fully addresses the spectrum of possible spectrum of possible accident events and accident events and conditions.

conditions.

The TEDE dose is set at 1% of the EPA PAG of The TEDE dose is set at 1% of the EPA PAG of 1,000 mRem while the 50 mRem thyroid CDE was 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

EPA PAG for TEDE and thyroid CDE.

• Replaced "have stopped due to actions to Classification based on effluent monitor readings isolate the release path" with "have stopped Classification based on effluent monitor readings assumes that a release path to the environment is due to isolation of the release path" assumes that a release path to the environment is established. If the effluent flow past an effluent established. If the effluent flow past an effluent monitor is known to have stopped due to isolation of monitor is known to have stopped due to actions to the release path, then the effluent monitor reading is isolate the release path, then the effluent monitor no longer valid for classification purposes.

reading is no longer valid for classification

• Provided PNP site-specific basis information Additional PNP Site-Specific Bases Information purposes. and references The calculated EAL threshold value for RIA-2326 exceeds the operating range for the effluent monitor (Reference 2). Therefore, a value equal to 90% of the maximum accurate reading of the monitor is used as the threshold to declare an Alert. This value is not based on any particular dose value. However, it ensures that an accurate monitor reading is available, and that an actual or potential substantial degradation of the level of safety of the facility is addressed.

Basis Reference(s):

1. NEI 99-01, Rev. 6, PD-AA1

2. Enercon Calculation No. ENTGPAL164-CALC-

HDI PNP 2022-016 Enclosure, Attachment 3 Page 15 of 38 NEI 99-01 Rev 6 Appendix C - Permanently Proposed Permanently Defueled Comparison Defueled Station ICs/EALs EAL for PNP 001, Permanently Defueled Gaseous and Liquid Effluent EAL Threshold Calculation Rev. 1, Table 2-1

3. PNP ODCM

HDI PNP 2022-016 Enclosure, Attachment 3 Page 16 of 38 NEI 99-01 Rev 6 Appendix C - Permanently Proposed Permanently Defueled Comparison Defueled Station ICs/EALs EAL for PNP PD-AU2 PD-AU2 No Change Difference Deviation ECL: Notification of Unusual Event ECL: UNUSUAL EVENT

• ECL: Changed Notification of Unusual Event Initiating Condition: UNPLANNED rise in plant Initiating Condition: UNPLANNED rise in facility to UNUSUAL EVENT to maintain continuity radiation levels. radiation levels. with the previous PNP EAL scheme Operating Mode Applicability: Not Applicable

• Initiating Condition: Replaced plant with facility" Example Emergency Action Levels: (1 or 2) Emergency Action Levels (EALs): (1 or 2)

• Removed "Operating Mode Applicability" as it (1) a. UNPLANNED water level drop in the 1. a. UNPLANNED water level drop in the SFP does not apply in the permanently defueled spent fuel pool as indicated by ANY of the as indicated by ANY of the following: condition following:

• EK-1309

• Removed Example from EALs as they are no (Site specific level indications). longer examples

• Visual observation of SFP water level

• Manual SFP water level measurement

• Added "OR" between the EALs as an operator aid to facilitate EAL navigation.

AND AND

• EAL #1.a: Provided PNP site-specific SFP level

b. UNPLANNED rise in area radiation levels as b. UNPLANNED rise in area radiation levels indications indicated by ANY of the following radiation as indicated by spent fuel pool area monitors: radiation monitor (RIA-5709 or RIA-2313).

• EAL # 1.b: Provided PNP site-specific area radiation monitors (Site specific level indications). OR

2. Area radiation monitor reading or survey result indicates an UNPLANNED rise of 25 mR/hr (2) Area radiation monitor reading or survey result over NORMAL LEVELS.

indicates an UNPLANNED rise of 25 mR/hr over NORMAL LEVELS.

Basis: Basis: No Change Difference Deviation This IC addresses elevated plant radiation levels This IC addresses elevated facility radiation levels

• Replaced "plant" with "facility" caused by a decrease in water level above caused by a decrease in water level above irradiated (spent) fuel or other UNPLANNED irradiated (spent) fuel or other UNPLANNED events. The increased radiation levels are events. The increased radiation levels are indicative of a minor loss in the ability to control indicative of a minor loss in the ability to control radiation levels within the plant or radioactive radiation levels within the facility or radioactive materials. Either condition is a potential materials. Either condition is a potential degradation in the level of safety of the plant. degradation in the level of safety of the facility.

HDI PNP 2022-016 Enclosure, Attachment 3 Page 17 of 38 NEI 99-01 Rev 6 Appendix C - Permanently Proposed Permanently Defueled Comparison Defueled Station ICs/EALs EAL for PNP A water level decrease will be primarily determined A water level decrease will be primarily determined by indications from available level instrumentation. by indications from available level instrumentation.

Other sources of level indications may include Other sources of level indications may include reports from plant personnel or video camera reports from facility personnel. A significant drop in observations (if available). A significant drop in the the water level may also cause an increase in the water level may also cause an increase in the radiation levels of adjacent areas that can be radiation levels of adjacent areas that can be detected by monitors in those locations.

detected by monitors in those locations.

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

movement of radioactive waste materials.

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

would be via IC PD-AA1 or PD-AA2.

• Provided PNP site-specific basis information Additional PNP Site-Specific Bases Information and references Loss of inventory from the SFP may reduce water shielding above spent fuel and cause unexpected increases in plant radiation. Classification as an UNUSUAL EVENT is warranted as a precursor to a more serious event.

The minimum allowable water level in the (SFP) is the Low Spent Fuel Pool water level. The low SFP water level alarm setpoint is at 646 ft elevation or 35 ft above the bottom of the SFP. SFP water level is indicated by EK-1309 and alarmed in the Control Room (Reference 2 and 3), or via visual observation or manual SFP water level measurement.

The listed area radiation monitors are those that would likely see an increase in area radiation due to a loss of shielding resulting from a loss of pool inventory (Reference 4). While a radiation monitor could detect a rise in dose due to a drop in the water level, it might not be a reliable indication, in

HDI PNP 2022-016 Enclosure, Attachment 3 Page 18 of 38 NEI 99-01 Rev 6 Appendix C - Permanently Proposed Permanently Defueled Comparison Defueled Station ICs/EALs EAL for PNP and of itself, of whether or not the fuel is uncovered. Elevated radiation monitor indications will need to be combined with another indicator (or personnel report) of water loss.

Calculated dose rates above the SFP and resultant measured dose rates on a nearby ARM (RIA-2313) indicate that measurable increases of radiation will occur when SFP water level drops to approximately the 632 ft elevation and alarm below an elevation of approximately 630 ft elevation (Reference 5).

Assessment of this EAL may be made with survey readings using portable instruments as well as installed radiation monitors.

Basis Reference(s):

1. NEI 99-01, Rev. 6, PD-AU2

2. Permanently Defueled Technical Specifications 3.7.14, Spent Fuel Pool (SFP) Water Level

3. AOP-26, Loss of Spent Fuel Pool Cooling

HDI PNP 2022-016 Enclosure, Attachment 3 Page 19 of 38 NEI 99-01 Rev 6 Appendix C - Permanently Proposed Permanently Defueled Comparison Defueled Station ICs/EALs EAL for PNP PD-AA2 PD-AA2 No Change Difference Deviation ECL: Alert ECL: ALERT

• Initiating Condition: Replaced plant with Initiating Condition: UNPLANNED rise in plant Initiating Condition: UNPLANNED rise in facility facility radiation levels that impedes plant access required radiation levels that impedes facility access

• Removed "Operating Mode Applicability" as it to maintain spent fuel integrity. required to maintain spent fuel integrity. does not apply in the permanently defueled Operating Mode Applicability: Not Applicable condition Example Emergency Action Levels: (1 or 2) Emergency Action Levels (EALs): (1 or 2)

• Removed Example from EALs as they are no longer examples (1) UNPLANNED dose rate greater than 15 mR/hr 1. UNPLANNED dose rate greater than 15 mR/hr in ANY of the following areas requiring in ANY of the following areas requiring

• Added "OR" between the EALs as an operator continuous occupancy to maintain control of continuous occupancy to maintain control of aid to facilitate EAL navigation.

radioactive material or operation of systems radioactive material or operation of systems

• EAL #1: Provided applicable PNP site-specific needed to maintain spent fuel integrity: needed to maintain spent fuel integrity. areas (site-specific area list)

• Control Room (RIA-2310)

• EAL #2: Re-worded to better align with the IC

• Central Alarm Station (CAS) (RIA-2311/by without changing the intent of the EAL survey)

• EAL #2: Eliminated the word "results" because OR the use of survey results is implied (2) UNPLANNED Area Radiation Monitor readings 2. UNPLANNED Area Radiation Monitor readings

• EAL #2: Provided applicable PNP site-specific or survey results indicate a rise by 100 mR/hr in or survey indicate a rise by 100 mR/hr over areas ANY of the following areas needed to maintain NORMAL LEVELS that impedes access to control of radioactive material or operation of ANY of the following areas needed to maintain systems needed to maintain spent fuel integrity. control of radioactive material or operation of (site specific area list) systems needed to maintain spent fuel integrity.

• SFP Room

• SFP Heat Exchanger Room Basis: Basis: No Change Difference Deviation This IC addresses increased radiation levels that This IC addresses increased radiation levels that

• Replace plant with facility 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 requires local monitoring, in order to maintain requires local monitoring, in order to maintain systems needed to maintain spent fuel integrity. As systems needed to maintain spent fuel integrity. As used here, impede includes hindering or used here, impede includes hindering or

HDI PNP 2022-016 Enclosure, Attachment 3 Page 20 of 38 NEI 99-01 Rev 6 Appendix C - Permanently Proposed Permanently Defueled Comparison Defueled Station ICs/EALs EAL for PNP interfering, provided that the interference or delay interfering, provided that the interference or delay is is sufficient to significantly threaten necessary sufficient to significantly threaten necessary facility plant access. It is this impaired access that results access. It is this impaired access that results in the in the actual or potential substantial degradation of actual or potential substantial degradation of the the level of safety of the plant. level of safety of the facility.

This IC does not apply to anticipated temporary This IC does not apply to anticipated temporary increases due to planned events. increases due to planned events.

Additional PNP Site-Specific Bases Information Areas that meet this threshold include the Control

• Provided PNP site-specific basis information, Room and the Central Alarm Station (CAS). The instrumentation, and references Control Room Area Radiation Monitor (RIA-2310) provides indication of area radiation levels in the Control Room.

The Central Alarm Station (CAS) is included in this EAL because of its importance to permitting access to areas required to assure safe plant operations.

CAS has no installed radiation monitoring capability. However, RIA-2311 will provide indication of increasing radiation levels prompting surveys.

Basis Reference(s):

1. NEI 99-01, Rev. 6, PD-AA2

HDI PNP 2022-016 Enclosure, Attachment 3 Page 21 of 38 NEI 99-01 Rev 6 Appendix C - Permanently Proposed Permanently Defueled Comparison Defueled Station ICs/EALs EAL for PNP PD-HU1 PD-HU1 No Change Difference Deviation ECL: Notification of Unusual Event ECL: UNUSUAL EVENT

• ECL: Changed Notification of Unusual Event to Initiating Condition: Confirmed SECURITY Initiating Condition: Confirmed SECURITY UNUSUAL EVENT to maintain continuity with CONDITION or threat. CONDITION or threat. the previous PNP EAL scheme Operating Mode Applicability: Not Applicable Emergency Action Levels (EALs): (1 or 2 or 3)

• Removed "Operating Mode Applicability" as it does not apply in the permanently defueled Example Emergency Action Levels: (1 or 2 or 3) 1. A SECURITY CONDITION that does not condition.

involve a HOSTILE ACTION as reported by the (1) A SECURITY CONDITION that does not

• Removed Example from EALs as they are no Security Shift Leader.

involve a HOSTILE ACTION as reported by the longer examples (site-specific security shift supervision). OR

• Added "OR" between the EALs as an operator (2) Notification of a credible security threat directed 2. Notification of a credible security threat directed aid to facilitate EAL navigation.

at the site. at the site.

• EAL #1: Provided the Security Shift Leader as (3) A validated notification from the NRC providing OR the PNP "site-specific security shift supervision" information of an aircraft threat.

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

Basis: Basis: No Change Difference Deviation This IC addresses events that pose a threat to plant This IC addresses events that pose a threat to

• Replaced plant with facility personnel or the equipment necessary to maintain facility personnel or the equipment necessary to cooling of spent fuel, and thus represent a potential maintain cooling of spent fuel, and thus represent a degradation in the level of plant safety. Security potential degradation in the level of facility safety.

events which do not meet one of these EALs are Security events which do not meet one of these adequately addressed by the requirements of 10 EALs are adequately addressed by the CFR § 73.71 or 10 CFR § 50.72. Security events requirements of 10 CFR § 73.71 or 10 CFR § assessed as HOSTILE ACTIONS are classifiable 50.72. Security events assessed as HOSTILE under IC PD-HA1. ACTIONS are classifiable under IC PD-HA1.

Timely and accurate communications between Timely and accurate communications between the Security Shift Supervision and the Control Room is Security Shift Leader and the Control Room is essential for proper classification of a security- essential for proper classification of a security-related event. Classification of these events will related event. Classification of these events will initiate appropriate threat-related notifications to initiate appropriate threat-related notifications to plant personnel and OROs. facility personnel and Offsite Response Organizations (OROs).

Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security plans and terminology are based on the Security Plan, Training and Qualification Plan, guidance provided by NEI 03-12, Template for the

HDI PNP 2022-016 Enclosure, Attachment 3 Page 22 of 38 NEI 99-01 Rev 6 Appendix C - Permanently Proposed Permanently Defueled Comparison Defueled Station ICs/EALs EAL for PNP Safeguards Contingency Plan [and Independent Security Plan, Training and Qualification Plan, Spent Fuel Storage Installation Security Program]. Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

EAL #1 references (site-specific security shift supervision) because these are the individuals EAL #1 references the Security Shift Leader trained to confirm that a security event is occurring because this is the individual trained to confirm that

• Changed "(site-specific security shift or has occurred. Training on security event a security event is occurring or has occurred. supervision) because these are the individuals" confirmation and classification is controlled due to Training on security event confirmation and to "Security Shift Leader because this is the the nature of Safeguards and 10 CFR § 2.39 classification is controlled due to the nature of individual" to reflect PNP site-specific information. Safeguards and 10 CFR § 2.39 information. nomenclature EAL #2 addresses the receipt of a credible security EAL #2 addresses the receipt of a credible security threat. The credibility of the threat is assessed in threat. The credibility of the threat is assessed in

• Added "PNP Security Plan" to reflect PNP site-accordance with (site-specific procedure). accordance with the PNP Security Plan (Reference specific nomenclature 2).

EAL #3 addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters EAL #3 addresses the threat from the impact of an Operations Officer (HOO) will communicate to the aircraft on the facility. The NRC Headquarters licensee if the threat involves an aircraft. The status Operations Officer (HOO) will communicate to the and size of the plane may also be provided by licensee if the threat involves an aircraft. The status NORAD through the NRC. Validation of the threat and size of the plane may also be provided by is performed in accordance with (site-specific NORAD through the NRC. Validation is performed procedure). by calling the NRC or by other approved methods of authentication.

Emergency plans and implementing procedures are public documents; therefore, EALs should not Emergency plans and implementing procedures are

• Changed "Security Plan" to "PNP Security Plan" incorporate Security-sensitive information. This public documents; therefore, EALs should not to reflect PNP site-specific nomenclature includes information that may be advantageous to a incorporate Security-sensitive information. This potential adversary, such as the particulars includes information that may be advantageous to a concerning a specific threat or threat location. potential adversary, such as the particulars Security-sensitive information should be contained concerning a specific threat or threat location.

in non-public documents such as the Security Plan. Security-sensitive information should be contained in non-public documents such as the PNP Security Escalation of the emergency classification level Plan.

would be via IC PD-HA1.

Escalation of the ECL would be via IC PD-HA1.

Additional PNP Site-Specific Bases Information

• Provided PNP site-specific basis information and The intent of these EALs is to ensure that references notifications for the aircraft threat are made in a timely manner and that OROs and plant personnel are at a state of heightened awareness regarding

HDI PNP 2022-016 Enclosure, Attachment 3 Page 23 of 38 NEI 99-01 Rev 6 Appendix C - Permanently Proposed Permanently Defueled Comparison Defueled Station ICs/EALs EAL for PNP the credible threat. It is not the intent of this EAL to replace existing non-hostile related EALs involving aircraft.

The determination of credible is made through use of information found in the PNP Security Plan (Reference 2).

Hostile Action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on PNP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

Basis Reference(s):

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

2. PNP Security Plan

HDI PNP 2022-016 Enclosure, Attachment 3 Page 24 of 38 NEI 99-01 Rev 6 Appendix C - Permanently Proposed Permanently Defueled Comparison Defueled Station ICs/EALs EAL for PNP PD-HA1 PD-HA1 No Change Difference Deviation ECL: Alert ECL: ALERT

• Removed "Operating Mode Applicability" as it Initiating Condition: HOSTILE ACTION within the Initiating Condition: HOSTILE ACTION within does not apply in the permanently defueled OWNER CONTROLLED AREA or airborne attack the OWNER CONTROLLED AREA or airborne condition threat within 30 minutes. attack threat within 30 minutes.

• Removed Example from EALs as they are no Operating Mode Applicability: Not Applicable Emergency Action Levels (EALs): (1 or 2) longer examples Example Emergency Action Levels: (1 or 2) 1. A HOSTILE ACTION is occurring or has

• Added "OR" between the EALs as an operator occurred within the OWNER CONTROLLED aid to facilitate EAL navigation.

(1) A HOSTILE ACTION is occurring or has AREA as reported by the Security Shift Leader.

• EAL #1: Provided the Security Shift Leader as occurred within the OWNER CONTROLLED AREA as reported by the (site-specific security OR the PNP "site-specific security shift supervision" shift supervision).

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

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

Basis: Basis: No Change Difference Deviation This IC addresses the occurrence of a HOSTILE This IC addresses the occurrence of a HOSTILE

• Replaced plant with facility.

ACTION within the OWNER CONTROLLED AREA ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event or notification of an aircraft attack threat. This event will require rapid response and assistance due to will require rapid response and assistance due to the possibility of the attack progressing to the the possibility of the attack progressing to the PROTECTED AREA , or the need to prepare the PROTECTED AREA, or the need to prepare the facility and staff for a potential aircraft impact. facility and staff for a potential aircraft impact.

Timely and accurate communications between Timely and accurate communications between the

• Changed "Security Shift Supervision" to Security Shift Supervision and the Control Room is Security Shift Leader and the Control Room is "Security Shift Leader" to reflect PNP site-essential for proper classification of a security- essential for proper classification of a security- specific nomenclature related event.

related event.

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

HDI PNP 2022-016 Enclosure, Attachment 3 Page 25 of 38 NEI 99-01 Rev 6 Appendix C - Permanently Proposed Permanently Defueled Comparison Defueled Station ICs/EALs EAL for PNP and implementation of onsite protective measures As time and conditions allow, these events require (e.g., evacuation, dispersal or sheltering). The Alert a heightened state of readiness by the facility staff declaration will also heighten the awareness of and implementation of onsite protective measures Offsite Response Organizations, allowing them to (e.g., evacuation, dispersal or sheltering). The be better prepared should it be necessary to ALERT declaration will also heighten the consider further actions. awareness of OROs, allowing them to be better This IC does not apply to incidents that are prepared should it be necessary to consider further accidental events, acts of civil disobedience, or actions.

otherwise are not a HOSTILE ACTION perpetrated This IC does not apply to incidents that are by a HOSTILE FORCE. Examples include the accidental events, acts of civil disobedience, or crash of a small aircraft, shots from hunters, otherwise are not a HOSTILE ACTION perpetrated physical disputes between employees, etc.

by a HOSTILE FORCE. Examples include the Reporting of these types of events is adequately addressed by other EALs, or the requirements of crash of a small aircraft, shots from hunters, 10 CFR § 73.71 or 10 CFR § 50.72. physical disputes between employees, etc.

Reporting of these types of events is adequately EAL #1 is applicable for any HOSTILE ACTION addressed by other EALs, or the requirements of occurring, or that has occurred, in the OWNER 10 CFR § 73.71 or 10 CFR § 50.72.

CONTROLLED AREA. This includes any action directed against an ISFSI that is located within the EAL #1 is applicable for any HOSTILE ACTION OWNER CONTROLLED AREA. occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action EAL #2 addresses the threat from the impact of an directed against an ISFSI that is located within the aircraft on the plant, and the anticipated arrival time OWNER CONTROLLED AREA.

is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in EAL #2 addresses the threat from the impact of an a timely manner so that plant personnel and OROs aircraft on the facility, and the anticipated arrival are in a heightened state of readiness. This EAL is time is within 30 minutes. The intent of this EAL is met when the threat-related information has been to ensure that threat-related notifications are made validated in accordance with (site-specific in a timely manner so that facility personnel and procedure). OROs are in a heightened state of readiness. This The NRC Headquarters Operations Officer (HOO) EAL is met when the threat-related information has will communicate to the licensee if the threat been validated in accordance with the PNP involves an aircraft. The status and size of the Security Plan (Reference 2).

plane may be provided by NORAD through the The NRC Headquarters Operations Officer (HOO)

NRC.

will communicate to the licensee if the threat In some cases, it may not be readily apparent if an involves an aircraft. The status and size of the aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It

HDI PNP 2022-016 Enclosure, Attachment 3 Page 26 of 38 NEI 99-01 Rev 6 Appendix C - Permanently Proposed Permanently Defueled Comparison Defueled Station ICs/EALs EAL for PNP is expected, although not certain, that notification plane may be provided by NORAD through the by an appropriate Federal agency to the site would NRC.

clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA In some cases, it may not be readily apparent if an or NRC. The emergency declaration, including one aircraft impact within the OWNER CONTROLLED based on other ICs/EALs, should not be unduly AREA was intentional (i.e., a HOSTILE ACTION). It delayed while awaiting notification by a Federal is expected, although not certain, that notification agency. by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate Emergency plans and implementing procedures are federal agency is intended to be NORAD, FBI, FAA public documents; therefore, EALs should not or NRC. The emergency declaration, including one incorporate Security-sensitive information. This based on other ICs/EALs, should not be unduly includes information that may be advantageous to a delayed while awaiting notification by a Federal potential adversary, such as the particulars concerning a specific threat or threat location. agency.

Security-sensitive information should be contained Emergency plans and implementing procedures in non-public documents such as the Security Plan. are public documents; therefore, EALs should not

• Changed "Security Plan" to "PNP Safeguards Contingency Plan" to reflect PNP site-specific incorporate Security-sensitive information. This nomenclature 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 PNP Security Plan.

Additional PNP Site-Specific Bases Information

• Provided PNP site-specific basis information and HOSTILE ACTION: An act toward a nuclear power references plant or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end.

This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other 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 that are not part of a concerted attack on the nuclear power plant. Non-terrorism-based EALs should be used to address such activities (i.e., this

HDI PNP 2022-016 Enclosure, Attachment 3 Page 27 of 38 NEI 99-01 Rev 6 Appendix C - Permanently Proposed Permanently Defueled Comparison Defueled Station ICs/EALs EAL for PNP may include violent acts between individuals in the OWNER CONTROLLED AREA).

Basis Reference(s):

1. NEI 99-01, Rev. 6, PD-HA1

2. PNP Security Plan

HDI PNP 2022-016 Enclosure, Attachment 3 Page 28 of 38 NEI 99-01 Rev 6 Appendix C - Permanently Proposed Permanently Defueled Comparison Defueled Station ICs/EALs EAL for PNP PD-HU2 PD-HU2 No Change Difference Deviation ECL: Notification of Unusual Event ECL: UNUSUAL EVENT

• ECL: Changed Notification of Unusual Event to Initiating Condition: Hazardous event affecting Initiating Condition: Hazardous event affecting UNUSUAL EVENT to maintain continuity with SAFETY SYSTEM equipment necessary for spent equipment necessary for spent fuel cooling. the previous PNP EAL scheme fuel cooling.

• Removed "Operating Mode Applicability" as it Operating Mode Applicability: Not Applicable Emergency Action Level (EAL): does not apply in the permanently defueled condition Example Emergency Action Levels: 1. a. The occurrence of ANY of the following hazardous events:

• Removed Example from EALs as they are no (1) longer examples

a. The occurrence of ANY of the following

• Seismic event (earthquake) hazardous events:

• Internal or external flooding event

• Seismic event (earthquake)

• High winds or tornado strike

• Internal or external flooding event

• FIRE

• High winds or tornado strike

• EXPLOSION

• FIRE

• Other events with similar

• EXPLOSION characteristics as determined by the Shift Manager

• (site-specific hazards)

AND

• EAL #1.b: Train has been replaced with PNP

• Other events with similar hazard site-specific information because the PNP SFP

b. The event has damaged at least one SFP characteristics as determined by the does not have train separation.

cooling pump AND one SFP heat Shift Manager exchanger.

• EAL #1 (b and c): The term SAFETY SYSTEM AND was excluded because only those systems AND required to maintain spent fuel cooling are

b. The event has damaged at least one train of

c. The damaged system cannot, or potentially necessary in the permanently shut down and a SAFETY SYSTEM needed for spent fuel cannot, perform its design function based defueled condition. These systems, by cooling.

on EITHER: definition, are not SAFETY SYSTEMS.

AND

• Indications of degraded performance

c. The damaged SAFETY SYSTEM train(s) cannot, or potentially cannot, perform its

• VISIBLE DAMAGE design function based on EITHER:

• Indications of degraded performance

HDI PNP 2022-016 Enclosure, Attachment 3 Page 29 of 38 NEI 99-01 Rev 6 Appendix C - Permanently Proposed Permanently Defueled Comparison Defueled Station ICs/EALs EAL for PNP

• VISIBLE DAMAGE Basis: Basis: No Change Difference Deviation This IC addresses a hazardous event that causes This IC addresses a hazardous event that causes

• Replaced plant with facility damage to at least one train of a SAFETY SYSTEM damage to at least one train of a system needed for needed for spent fuel cooling. The damage must be spent fuel cooling. The damage must be of

• The term SAFETY SYSTEM was excluded of sufficient magnitude that the system(s) train sufficient magnitude that the system(s) train cannot, because only those systems required to cannot, or potentially cannot, perform its design or potentially cannot, perform its intended function. maintain spent fuel cooling are necessary in function. This condition reduces the margin to a This condition reduces the margin to a loss or the permanently shut down and defueled loss or potential loss of the fuel clad barrier, and potential loss of the fuel clad barrier, and therefore condition. These systems, by definition, are therefore represents a potential degradation of the represents a potential degradation of the level of not SAFETY SYSTEMS.

level of safety of the plant. safety of the facility.

• Replaced "design function" with "intended For EAL 1.c, the first bullet addresses damage to a For EAL 1.c., the first bullet addresses damage to function" without changing the intent of the SAFETY SYSTEM train that is in service/operation equipment that is in service/operation since EAL.

since indications for it will be readily available. indications for it will be readily available.

For EAL 1.c, the second bullet addresses damage For EAL 1.c., the second bullet addresses damage to a SAFETY SYSTEM train that is not in to equipment that is not in service/operation or service/operation or readily apparent through readily apparent through indications alone.

indications alone. Operators will make this Operators will make this determination based on determination based on the totality of available the totality of available event and damage report event and damage report information. This is information. This is intended to be a brief intended to be a brief assessment not requiring assessment not requiring lengthy analysis or lengthy analysis or quantification of the damage. quantification of the damage.

Escalation of the emergency classification level Escalation of the ECL would be via IC PD-AA1 or could, depending upon the event, be based on any PD-AA2, PD-HA1 or PD-HA3.

of the Alert ICs; PD-AA1, PD-AA2, PD-HA1 or PD-Additional PNP Site-Specific Bases Information HA3.

The SFP cooling system removes decay heat from

• Provided PNP site-specific references spent fuel stored in the SFP. The system was originally designed to remove the decay heat from one-third of the total core fuel elements.

The SFP cooling system is required to maintain the fuel pool water temperature less than 150°F with a minimum of one SFP cooling pump operating. The maximum allowable SFP heat load resulting from off-loaded spent fuel ensures that the SFP water temperature limit of 150°F is maintained with one

HDI PNP 2022-016 Enclosure, Attachment 3 Page 30 of 38 NEI 99-01 Rev 6 Appendix C - Permanently Proposed Permanently Defueled Comparison Defueled Station ICs/EALs EAL for PNP pump in operation. Heat is removed from the spent fuel pool by the spent fuel pool heat exchanger with component cooling water providing the cooling medium. (Reference 2).

Basis Reference(s):

1. NEI 99-01, Rev. 6, PD-HU2

2. DSAR Section 9.4, Spent Fuel Pool Cooling System

HDI PNP 2022-016 Enclosure, Attachment 3 Page 31 of 38 NEI 99-01 Rev 6 Appendix C - Permanently Proposed Permanently Defueled Comparison Defueled Station ICs/EALs EAL for PNP PD-HU3 PD-HU3 No Change Difference Deviation ECL: Notification of Unusual Event ECL: UNUSUAL EVENT

• ECL: Changed Notification of Unusual Event to Initiating Condition: Other conditions exist which Initiating Condition: Other conditions exist which UNUSUAL EVENT to maintain continuity with in the judgment of the Emergency Director warrant in the judgment of the Emergency Director warrant the previous PNP EAL scheme declaration of a (NO)UE. declaration of an UNUSUAL EVENT.

• Removed "Operating Mode Applicability" as it Operating Mode Applicability: Not Applicable Emergency Action Level (EAL): does not apply in the permanently defueled condition Example Emergency Action Levels: Other conditions exist which in the judgment of the Emergency Director indicate that events are in

• Removed Example from EALs as they are no (1) Other conditions exist which in the judgment of longer examples progress or have occurred which indicate a the Emergency Director indicate that events are potential degradation of the level of safety of the

• Removed numbering from EAL because there is in progress or have occurred which indicate a facility or indicate a security threat to facility only one EAL that is associated with the IC potential degradation of the level of safety of protection has been initiated. No releases of the plant or indicate a security threat to facility

• Replaced plant with facility radioactive material requiring offsite response or protection has been initiated. No releases of monitoring are expected unless further degradation radioactive material requiring offsite response

• Replaced SAFETY SYSTEMS with "systems of systems needed to maintain spent fuel integrity or monitoring are expected unless further needed to maintain spent fuel integrity" as the occurs.

degradation of safety systems occurs. term "safety systems" is not applicable in the permanently shut down and defueled condition Basis: Basis: No Change Difference Deviation This IC addresses unanticipated conditions not This IC addresses unanticipated conditions not

• Changed "NOUE" to "UNUSUAL EVENT" to addressed explicitly elsewhere but that warrant addressed explicitly elsewhere but that warrant maintain continuity with the previous PNP EAL declaration of an emergency because conditions declaration of an emergency because conditions scheme 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 ECL description for an UNUSUAL description for a NOUE. EVENT.

Additional PNP Site-Specific Bases Information

• Provided PNP site-specific references None Basis Reference(s):

1. NEI 99-01, Rev. 6, PD-HU3

2. PNP Permanently Defueled Emergency Plan, Part 2, Section B, Emergency Response Organization"

HDI PNP 2022-016 Enclosure, Attachment 3 Page 32 of 38 NEI 99-01 Rev 6 Appendix C - Permanently Proposed Permanently Defueled Comparison Defueled Station ICs/EALs EAL for PNP PD-HA3 PD-HA3 No Change Difference Deviation ECL: Alert ECL: ALERT

• Removed "Operating Mode Applicability" as it Initiating Condition: Other conditions exist which Initiating Condition: Other conditions exist which does not apply in the permanently defueled in the judgment of the Emergency Director warrant in the judgment of the Emergency Director warrant condition declaration of an Alert. declaration of an ALERT.

• Removed Example from EALs as they are no Operating Mode Applicability: Not Applicable longer examples Example Emergency Action Levels: Emergency Action Level (EAL):

• Removed numbering from EAL, because there (1) Other conditions exist which in the judgment of Other conditions exist which in the judgment of the is only one EAL is associated with the IC the Emergency Director indicate that events are Emergency Director indicate that events are in

• Replaced plant with facility in progress or have occurred which involve an progress or have occurred which involve an actual actual or potential substantial degradation of or potential substantial degradation of the level of the level of safety of the plant or a security safety of the facility or a security event that involves event that involves probable life threatening risk probable life threatening risk to site personnel or to site personnel or damage to site equipment damage to site equipment because of HOSTILE because of HOSTILE ACTION. Any releases ACTION. Any releases are expected to be limited are expected to be limited to small fractions of to small fractions of the EPA Protective Action the EPA Protective Action Guideline exposure Guideline exposure levels.

levels.

Basis: Basis: No Change Difference Deviation 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 ECL description for an ALERT.

description for an Alert.

Additional PNP Site-Specific Bases Information

• Provided PNP site-specific references None Basis Reference(s):

1. NEI 99-01, Rev. 6, PD-HA3

2. PNP Permanently Defueled Emergency Plan, Part 2, Section B, Emergency Response Organization"

HDI PNP 2022-016 Enclosure, Attachment 3 Page 33 of 38 NEI 99-01 Rev 6 Appendix C - Permanently Proposed Permanently Defueled Comparison Defueled Station ICs/EALs EAL for PNP NEI 99-01 Rev 6 Appendix C - Permanently Proposed Permanently Defueled Comparison Defueled Station ICs/EALs EAL for PNP PD-SU1 PD-SU1 No Change Difference Deviation ECL: Notification of Unusual Event ECL: UNUSUAL EVENT

• ECL: Changed Notification of Unusual Event Initiating Condition: UNPLANNED spent fuel Initiating Condition: UNPLANNED spent fuel to UNUSUAL EVENT to maintain continuity pool temperature rise. pool temperature rise. with the previous PNP EAL scheme Operating Mode Applicability: Not Applicable

• Removed "Operating Mode Applicability" as it does not apply in the permanently defueled Example Emergency Action Levels: Emergency Action Level (EAL): condition (1) UNPLANNED spent fuel pool temperature rise UNPLANNED spent fuel pool temperature rise to

• Removed Example from EALs as they are no to greater than (site-specific ° F). greater than 140°F. longer examples

• Removed numbering from EAL because there is only one EAL that is associated with the IC

• Provided PNP site-specific temperature for the SFP Basis: Basis: No Change Difference Deviation This IC addresses a condition that is a precursor to This IC addresses a condition that is a precursor to

• Replaced "plant" with "facility" a more serious event and represents a potential a 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 facility. If

• Provided PNP site-specific basis information uncorrected, boiling in the pool will occur, and uncorrected, boiling in the SFP will occur, and and justification for 140°F EAL threshold result in a loss of pool level and increased radiation result in a loss of SFP level and increased radiation provided in the EAL levels. levels.

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

Additional PNP Site-Specific Bases Information AOP-26 (Reference 2) is applicable when there is

• Provided PNP site-specific references an unplanned loss of SFP inventory or SFP cooling.

This procedure provides instructions to add large volumes of water to the SFP to address beyond design basis events that result in significant losses due to failures of the SFP. Entry into AOP-26

HDI PNP 2022-016 Enclosure, Attachment 3 Page 34 of 38 NEI 99-01 Rev 6 Appendix C - Permanently Proposed Permanently Defueled Comparison Defueled Station ICs/EALs EAL for PNP occurs based on HI-HI SFP Temperature Alarm on TIA_0925_D and TIA_0926_D of 140°F.

On-shift personnel will provide initial mitigation for a loss of SFP cooling based on SFP high temperature alarm on TIA_0925_D and TIA_0926_D of 125°F (Reference 3). Based on RX-EA-SFPHEATUP-11-01 (Reference 4), for a loss of SFP Cooling, at 365 days after shutdown, the heat up rate in the SFP would be approximately 3.5°F per hour. Using the entry condition for the Loss of Spent Fuel Pooling procedure as the EAL threshold provides a precursor for additional actions to restore SFP cooling and provides approximately 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> to mitigate before SFP boiling were to occur.

Basis Reference(s):

1. NEI 99-01 Rev. 6, PD-SU1

2. AOP-26, Loss of Spent Fuel Pool Cooling

3. SOP-27, Fuel Pool System

4. Calculation No. RX-EA-SFPHEATUP-11-01, "Palisades Spent Fuel Pool Heatup Calculation," Revision 6, Attachment 9.8

HDI PNP 2022-016 Enclosure, Attachment 3 Page 35 of 38 NEI 99-01 Rev 6, Section 8 Proposed Permanently Defueled Comparison ISFSI ICs/EALs EAL for PNP E-HU1 E-HU1 No Change Difference Deviation ECL: Notification of Unusual Event ECL: UNUSUAL EVENT

• ECL: Changed Notification of Unusual Event Initiating Condition: Damage to a loaded cask Initiating Condition: Damage to a loaded cask to UNUSUAL EVENT to maintain continuity CONFINEMENT BOUNDARY. CONFINEMENT BOUNDARY. with the previous PNP EAL scheme Operating Mode Applicability: All

• Removed "Operating Mode Applicability" as it does not apply in the permanently defueled Example Emergency Action Levels: Emergency Action Level (EAL): condition (1) Damage to a loaded cask CONFINEMENT Damage to a loaded cask CONFINEMENT

• Removed Example from EALs as they are no BOUNDARY as indicated by an on-contact BOUNDARY as indicated by a radiation reading longer examples.

radiation reading greater than (2 times the site- greater than the applicable values shown on Table specific cask specific technical specification E-1 on the spent fuel cask.

• Removed numbering from EAL because there allowable radiation level) on the surface of the is only one EAL that is associated with the IC Table E-1 Cask Dose Rates spent fuel cask.

• Included the cask-specific EAL threshold Cask System Casks Dose Rates values corresponding to two-times the cask 40 mrem/hr on the sides specific technical specification allowable value Ventilated Storage Cask All 100 mrem/hr on the top for each of the cask systems in use at the PNP System (VSC-24) 100 mrem/hr at inlet and outlet ISFSI ducts 1600 mrem/hr on the HSM front surface 32PT HSM-001 400 mrem/hr on the HSM door thru centerline HSM-011 16 mrem/hr on the end shield wall exterior Standardized NUHOMS 2600 mrem/hr on the HSM front 24PTH surface HSM-H-10 mrem/hr on the HSM door 012 thru centerline HSM-H-024 20 mrem/hr on the end shield wall exterior 60 mrem/hr (gamma + neutron) on the top of the OVERPACK HI-STORM FW All 600 mrem/hr (gamma + neutron)

MPC on the OVERPACK, excluding inlet and outlet ducts

HDI PNP 2022-016 Enclosure, Attachment 3 Page 36 of 38 NEI 99-01 Rev 6, Section 8 Proposed Permanently Defueled Comparison ISFSI ICs/EALs EAL for PNP Basis: Basis: No Change Difference Deviation This IC addresses an event that results in damage This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage to the CONFINEMENT BOUNDARY of a storage 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 the fuel that is licensed for dry storage beginning at the point that the loaded storage cask is sealed. The point that the loaded storage cask is sealed. The issues of concern are the creation of a potential or issues of concern are the creation of a potential or actual release path to the environment, degradation actual release path to the environment, degradation of one or more fuel assemblies due to of one or more fuel assemblies due to environmental factors, and configuration changes environmental factors, and configuration changes which could cause challenges in removing the cask which could cause challenges in removing the cask or fuel from storage. or fuel from 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 Recognition Category A IC AU1, is used here to between non-emergency and emergency distinguish between non-emergency and conditions. The emphasis for this classification is emergency conditions. The emphasis for this the degradation in the level of safety of the spent classification is the degradation in the level of fuel cask and not the magnitude of the associated safety of the spent fuel cask and not the magnitude dose or dose rate. It is recognized that in the case of the associated dose or dose rate. It is recognized of extreme damage to a loaded cask, the fact that that in the case of extreme damage to a loaded the on-contact dose rate limit is exceeded may be cask, the fact that the on-contact dose rate limit is determined based on measurement of a dose rate exceeded may be determined based on at some distance from the cask.

measurement of a dose rate at some distance from Security-related events for ISFSIs are covered the cask.

under ICs PD-HU1 and PD-HA1.

Security-related events for ISFSIs are covered Additional PNP Site-Specific Bases Information under ICs HU1 and HA1.

The PNP ISFSIs utilize multiple dry spent fuel

• Provided PNP site-specific and cask-specific storage systems. These systems consist of the basis information and references Ventilated Storage Cask System (VSC-24)

(Reference 2); the NUHOMS Horizontal Modular Storage System (32PT and 24PTH) (References 3 and 4); and the HI-STORM Flood/Wind (FW)

Multipurpose Canister (MPC) Cask System (Reference 5). The dose rates included in Table E-1 equate to two-times the cask-specific technical

HDI PNP 2022-016 Enclosure, Attachment 3 Page 37 of 38 NEI 99-01 Rev 6, Section 8 Proposed Permanently Defueled Comparison ISFSI ICs/EALs EAL for PNP specification allowable radiation value for each of the cask systems (References 2, 3, 4, and 5).

This EAL addresses any condition which indicates a loss of a cask CONFINEMENT BOUNDARY and thus a potential degradation in the level of safety of the ISFSI.

Minor surface damage that does not affect storage cask boundary is excluded from the scope of this EAL.

Basis Reference(s):

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

2. Renewal of Initial Certificate of Compliance and Amendments No. 1 through 6 of Certificate of Compliance No. 1007 for the VSC-24 Cask System, Enclosure # - Attachment A, Technical Specification 1.2.4

3. Renewal of Initial Certificate of Compliance and Amendments No. 1 through 11 and 13, Revision 1, and Amendment No. 14 of Certificate of Compliance No. 1004 for the Standardized NUHOMS Horizontal Modular Storage System, Enclosure 16 (Amendment No. 7, Revision 1) Technical Specification 1.2.7a

4. Renewal of Initial Certificate of Compliance and Amendments No. 1 through 11 and 13, Revision 1, and Amendment No. 14 of Certificate of Compliance No. 1004 for the Standardized NUHOMS Horizontal Modular Storage System, Enclosure 16 (Amendment No. 9, Revision 1) Technical Specification 1.2.7c

5. Issuance Certification of Compliance No. 1032, Amendment No. 1 Revision No. 1, for the HI-STORM Flood/Wind Multipurpose Canister

HDI PNP 2022-016 Enclosure, Attachment 3 Page 38 of 38 NEI 99-01 Rev 6, Section 8 Proposed Permanently Defueled Comparison ISFSI ICs/EALs EAL for PNP Storage System (TAC No. L24775), Appendix A Technical Specification 5.3.4

Attachment 4 to Enclosure HDI PNP 2022-016 Offsite Response Organization Acknowledgment and Concurrence (4 Pages)

STATE OF MICHIGAN DEPARTMENT OF STATE POLICE COL. JOSEPH M. GASPER GRETCHEN WHITMER GOVERNOR LANSING DIRECTOR June 15, 2022 Mr. Michael Schultheis Emergency Planning Manager Holtec International 27780 Blue Star Memorial Highway Covert, Michigan 49043

Dear Mr. Schultheis:

Thank you for your presentation on June 14 concerning Holtecs Permanently Defueled Emergency Plan (PDEP). My staff and I have discussed this and I fully understand and am satisfied with the plants current and future plans as the decommissioning process proceeds.

The Michigan State Police, Emergency Management and Homeland Security Division is confident these plan changes will not impact our ability to effectively implement the states Federal Emergency Management Agency (FEMA)-approved Radiological Emergency Preparedness (REP) Program.

I am fully supportive of the process and will do everything necessary to ensure the safety and protection of the public, as identified in the FEMA REP manual.

Please feel free to reach out to me at sweeneyk@michigan.gov or 517-719-1195 if you have any questions or concerns.

Sincerely, Capt. Kevin Sweeney, Commander Emergency Management and Homeland Security Division EMERGENCY MANAGEMENT AND HOMELAND SECURITY DIVISION 7150 HARRIS DRIVE DIMONDALE, MICHIGAN 48821 MAILING ADDRESS P.O. BOX 30634 LANSING, MICHIGAN 48909 www.michigan.gov/emhsd 517-284-3745

Allegan County Sheriffs Office EMERGENCY MANAGEMENT DEPARTMENT Homeland Security / Local Emergency Planning Committee 3271 - 122nd Avenue, Allegan, Michigan 49010 Telephone: (269) 673-0571 Fax: (269) 673-0566 Sheriff Frank Baker Tuesday June 14, 2022 Undersheriff

Dear Mr. Malone,

Mike Larsen Thank you for the invitation to the June 14, 2022 presentation concerning Permanently Defueling Emergency Plan (PDEP) for Director Palisades Nuclear Plant. Based on this meeting and the discussions that followed after, we feel satisfied that we fully understand the Scott Corbin proposed changes and do not feel that these changes will in any way impact our ability to effectively implement our FEMA-approved REP LEPC Information plans.

Coordinator Brett Apelgren Sincerely, LEPC Chairperson Dean Kapenga Scott Corbin AUXCOM Allegan County Emergency Management Director Coordinator Jason Veenstra Cert Coordinator Philip Holscher Reserve Unit Jim Steuer Search and Rescue Randy MacNeil Web site: http://www.allegancounty.org/EOC

BERRIEN COUNTY SHERIFF S OFFICE E MERG ENCY M AN AG EMENT & H OMELAND S ECURITY D I VISI ON 919 Port Street, Saint Joseph, Michigan 49085 Phone (269) 983-7141 x4915 Email bcoem@berriencounty.org June 14, 2022 Mr. Daniel G. Malone Emergency Planning Manager Entergy Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, Michigan 49043 USA

Subject:

Palisades Nuclear Plant Permanently Defueled Emergency Plan (PDEP)

Dear Mr. Malone,

I am writing to express my appreciation toward your effort to inform us about the Palisades Permanently Defueled Emergency Plan (PDEP) and giving us an open forum to assess any conflict with our community emergency operations plans. Please pass on the same appreciation to Michael Schultheis, as his presentation of the facts was also very helpful to this conversation.

After careful review and understanding of this plan, we see no indication that the proposed changes will impact our ability to effectively implement our emergency plans. We do not see any evidence that the safety of the community in Berrien County will be adversely affected by this proposed plan or from any subsequent license amendments requested based upon this plan.

We will continue to commit any required resources needed when it becomes appropriate during the decommissioning process. We are committed to ensuring the successful decommissioning of the plant is safe and healthy process for our community.

Please feel free to contact me if you have questions or concerns that we need to discuss at Radams1@berriencounty.org or 269-983-7111 ext. 4916.

Respectfully, Capt. Rockey Adams Emergency Management and Homeland Security Coordinator