View source for LIC-16-0076, License Amendment Request (LAR) 16-02: Revise the Fort Calhoun Station Emergency Plan to Address the Permanently Defueled Condition

{{Adams
| number = ML16246A321
| issue date = 09/02/2016
| title = License Amendment Request (LAR) 16-02: Revise the Fort Calhoun Station Emergency Plan to Address the Permanently Defueled Condition
| author name = Marik S
| author affiliation = Omaha Public Power District
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000285
| license number = DPR-040
| contact person = 
| case reference number = LAR-16-02, LIC-16-0076
| document type = Letter type:LIC, License-Application for Facility Operating License (Amend/Renewal) DKT 50
| page count = 637
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:10 CFR 50.90 10 CFR 50.54(q)
LIC-16-0076 September 2, 2016 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285

==Subject:==
License Amendment Request (LAR) 16-02: Revise the Fort Calhoun Station Emergency Plan to Address the Permanently Defueled Condition

==Reference:==
Letter from OPPD (T. Burke) to USNRC (Document Control Desk),
Certification of Permanent Cessation of Power Operations, dated June 24, 2016 (LIC-16-0043) (ML16176A213)
By letter dated June 24, 2016 (Reference), Omaha Public Power District (OPPD) provided formal notification to the U.S. Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 50.48(b)(8) and 10 CFR 50.82(a)(1)(i) of OPPDs determination to permanently cease power operations at Fort Calhoun Station (FCS) no later than December 31, 2016.
After certifications of permanent cessation of power operations and of permanent removal of fuel from the reactor vessel for FCS are submitted in accordance with 10 CFR 50.82(a)(1)(i) and (ii), the 10 CFR Part 50 license will no longer authorize reactor operation or placement or retention of fuel in the reactor vessel.
Pursuant to 10 CFR 50.90, OPPD hereby requests an amendment to the license for Fort Calhoun Station (FCS), Unit No. 1. The proposed amendment would revise the OPPD Nuclear Radiological Emergency Response Plan for Fort Calhoun Station (FCS RERP) for the post-shutdown condition. The proposed changes are being submitted to the NRC for approval prior to implementation, as required under 10 CFR 50.54(q)(4).
The proposed FCS RERP changes would revise the shift staffing and Emergency Response Organization (ERO) staffing. OPPD has reviewed the proposed changes against the planning standards in 10 CFR 50.47(b) and requirements in 10 CFR Part 50, Appendix E and concludes that the standards and requirements will continue to be met.
Preliminary discussions on the proposed schedule associated with changes to the FCS RERP and its effects on the off-site resources were conducted as part of meetings with various Federal, State and local agencies. Followup meetings with Federal, State and local agencies will cover this proposed RERP (LAR 16-02), its impact on off-site resources and the FCS decommissioning process. Updates will continue with off-site agencies during the normally scheduled quarterly meetings.
444 SOUTH 16TH STREET MALL
* OMAHA, NE 681022247

LIC-16-0076 Page 2 The proposed changes to the FCS RERP are commensurate with the reduced spectrum of credible accidents in the permanently shut down and defueled condition. In order to assist in the transition from an operating facility to a permanently defueled facility, the changes are required to properly reflect the conditions of the facility while continuing to preserve the FCS Decommissioning Trust Fund and maintain the effectiveness of the FCS RERP.
The description and evaluation of the proposed FCS RERP changes are contained in . Attachment 2 provides a tabular summary of the proposed changes to the FCS RERP. Attachment 3 provides the revised pages of the FCS RERP with the proposed changes and a clean copy. Attachment 4 provides the analysis of the proposed post-shutdown on-shift staffing. Attachment 5 provides the analysis of ERO tasks that will be transferred to remaining ERO positions.
OPPD requests review and approval of the proposed license amendment by September 8, 2017, in order to support future decommissioning efforts and activities at the site. Once approved, this amendment shall be implemented within 60 days.
The proposed changes have been evaluated in accordance with 10 CFR 50.91(a)(1) using criteria in 10 CFR 50.92(c), and OPPD has determined that these changes involve no significant hazards consideration. OPPD has also determined that the proposed changes satisfy the criteria for categorical exclusion in accordance with 10 CFR 51.22(c)(9) and do not require an environmental review. Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment is required.
Pursuant to 10 CFR 50.91, Notice for public comment; State consultation, paragraph (b), OPPD is notifying the State of Nebraska of this application for license amendment by transmitting a copy of this letter and its supporting attachments to the designated state official. If you have any questions regarding this submittal, please contact Mr.
Bradley H. Blome at (402) 533-7270.

LIC-16-0076 Page 3 The proposed changes have been reviewed and approved by the Fort Calhoun Station Plant Operations Review Committee (PORC). Attachment 6 of this letter contains new regulatory commitments.
I declare under penalty of perjury that the foregoing is true and correct. Executed on September 2, 2016.
~J Shane M. Marik Site Vice President and CNO Attachments:
: 1. Description and Evaluation of the Proposed Changes
: 2. Tabular Summary of Proposed Changes to the FCS RERP
: 3. Proposed Revision to the FCS RERP Pages (copy with changes marked and a clean copy)
: 4. Analysis of Proposed Post-Shutdown On-Shift Staffing
: 5. Emergency Response Organization Task Analysis
: 6. List of Regulatory Commitments SMM/JEF/epm C:    K. M. Kennedy, NRC Regional Administrator, Region IV C. F. Lyon, NRC Senior Project Manager S. M. Schneider, NRC Senior Resident Inspector Director of Consumer Health Services, Department of Regulation and Licensure, Nebraska Health and Human Services, State of Nebraska

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION DOCKET NUMBER 50-285 / LICENSE NUMBER DPR-40 ATTACHMENT 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGES

LIC-16-0076 Page 2 License Amendment Request 16-02: Revise the Fort Calhoun Station Emergency Plan to Address the Permanently Defueled Condition DESCRIPTION AND EVALUATION OF PROPOSED CHANGES 1.0    

==SUMMARY==
DESCRIPTION

==2.0    BACKGROUND==

3.0    DETAILED DESCRIPTION

==4.0    TECHNICAL EVALUATION==

4.1   Accident Analysis 4.2   Analysis of Proposed Changes 4.3   Conclusion

==5.0    REGULATORY EVALUATION==

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

==6.0    ENVIRONMENTAL CONSIDERATION==

==7.0    REFERENCES==

LIC-16-0076 Page 3 1.0    

==SUMMARY==
DESCRIPTION This evaluation supports a request to amend the Renewed Facility Operating License (OL) DPR-40 for the Fort Calhoun Station (FCS).
The proposed changes would revise the OPPD Nuclear Radiological Emergency Response Plan for Fort Calhoun Station (FCS RERP), on-shift staffing, and Emergency Response Organization (ERO) staffing to support the planned permanent cessation of power operations and permanent defueling of the FCS reactor (Reference 1).
An analysis of proposed post-shutdown on-shift staffing was performed to provide the basis for the proposed changes to the on-shift staffing. On-shift staffing at FCS currently consists of:
1 Shift Manager (Senior Reactor Operator (SRO))
1 Unit Supervisor (SRO) 1 Shift Technical Advisor (STA) 2 Reactor Operators (RO) 2 Equipment Operators 1 Control Room Communicator 1 Radiation Protection Technician 1 Chemistry Technician 1 Habitability Technician The Fire Brigade currently consists of a minimum of five (5) responders, including a Fire Brigade Leader and a minimum of four (4) trained and qualified Fire Brigade Members.
The analysis of proposed post-shutdown on-shift staffing demonstrated that an on-shift complement of four (4) personnel along with the Fire Brigade is able to cope with the spectrum of analyzed events in the permanently defueled condition because the consequences of credible events will be reduced when compared to the events that can occur with an operating reactor.
The credited post-shutdown on-shift complement will consist of:
1 Shift Manager (SRO/Certified Fuel Handler (CFH))
1 Control Room Operator (SRO or RO/CFH) 1 Equipment Operator/Non-Certified Operator (NCO) 1 Radiation Protection Technician The number of on-shift and ERO staff at FCS following permanent cessation of power operations and defueling will be reduced from current normal operating levels, but are commensurate with the need to safely store spent fuel at the facility in a manner that is protective of public health and safety. The Fire Brigade complement will continue to consist of a minimum of five (5) responders, including a Fire Brigade Leader and a minimum of four (4) trained and qualified Fire Brigade Members in compliance with National Fire Protection Association (NFPA) 805 implementation at FCS.
OPPD has reviewed the proposed changes against the planning standards in 10 CFR 50.47(b) and the requirements in 10 CFR Part 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, and has concluded that the standards and requirements will continue to be met. Therefore, no exemption from 10 CFR 50.47 or 10 CFR 50, Appendix E is requested.

LIC-16-0076 Page 4

==2.0    BACKGROUND==

The proposed changes are intended to reflect the pending permanent cessation of power operations and permanent defueling of the FCS reactor, which will occur no later than December 31, 2016 (Reference 1). After the reactor is shut down, all fuel assemblies will be removed from the reactor vessel and placed in the spent fuel pool (SFP). The irradiated fuel will be stored in the SFP and in the Independent Spent Fuel Storage Installation (ISFSI) until it is removed by the Department of Energy (DOE). Upon docketing of the certifications for permanent cessation of power operations (10 CFR 50.82(a)(1)(i)) and permanent removal of fuel from the reactor vessel (10 CFR 50.82(a)(1)(ii)), pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for FCS will no longer authorize power operations of the reactor or emplacement or retention of fuel into the reactor vessel.
The proposed revisions to the FCS RERP are commensurate with the reduction in hazards associated with the permanently defueled condition and will allow FCS to transition from a staffing level necessary for an operating facility to that necessary for a permanently shut down and defueled facility. The proposed changes are necessary to properly reflect the conditions of the facility while continuing to preserve the FCS Decommissioning Trust Fund and the effectiveness of the FCS RERP.
On-Shift Staffing The on-site emergency response plan regulations in 10 CFR 50.47(b)(2) state, in part, that on-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, [and] timely augmentation of response capabilities is available.
NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, (Reference 2), Section II.B, Onsite Emergency Organization, presents guidance for meeting the planning standards and requirements of 10 CFR 50.47(b) and 10 CFR 50, Appendix E, Section IV.A. The guidance describes the onsite emergency organization, including the staffing requirements found in Table B-1, Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies. This table specifies a minimum of ten on-shift responders in four Major Functional Areas. It also specifies seven on-shift response functions where the duties may be performed by shift personnel who are assigned other functions (i.e., there are no dedicated responders to perform these functions). Table B-1 specifies two Major Functional Areas (i.e., firefighting and site access control/personnel accountability) which must be staffed on a site-specific basis.
The on-shift staff must be able to cope with a spectrum of events until augmenting ERO personnel arrive in accordance with the sites emergency plan commitments. The augmenting ERO responders assume managerial, engineering, and administrative duties from the on-shift personnel, allowing on-shift personnel to focus on their assigned functions.

LIC-16-0076 Page 5 On November 23, 2011, the NRC published a final rule in the Federal Register amending certain emergency preparedness (EP) requirements in its regulations that govern domestic licensing of production and utilization facilities (Reference 3). This final rule amended 10 CFR Part 50, Appendix E, Section IV.A, Organization, to address the assignment of tasks or responsibilities to on-shift ERO personnel that could potentially overburden them and prevent the timely performance of their emergency plan functions. Specifically, Section IV.A.9 states that licensees shall perform a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan.
Coincident with the rule change in 10 CFR Part 50, Appendix E, Section IV.A.9, the NRC issued NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants (ISG-
: 01) (Reference 4). This Interim Staff Guidance (ISG) provides information relevant to performing the on-shift staffing analysis. The ISG states that the NEI developed NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, (Reference 5) to establish a standard methodology for a licensee to perform the required staffing analysis, and that the NRC reviewed NEI 10-05 and found it to be an acceptable methodology for this purpose. The ISG also indicates that the completed staffing analyses are required to be part of the emergency plan and the results documented and submitted to the NRC in accordance with 10 CFR 50.54(q)(5).
In October 2014, an On-Shift Staffing Analysis was performed in accordance with the NEI 10-05 guidance to satisfy the requirements of 10 CFR 50, Appendix E Section IV.A.9. This analysis examined the capability of the minimum staff listed in Section B, Attachment 1, Table B-1 of the FCS RERP to perform the key emergency response actions for events described in ISG-01 until augmenting ERO staff arrive. The analysis was conducted by a cross disciplinary team of personnel and station personnel from the Operations, Training, Radiation Protection, Chemistry, Licensing, and Emergency Preparedness departments. Additionally, members of the Security staff provided input to the analysis.
Each scenario was reviewed to determine what plant actions and emergency plan implementation actions were required based on plant procedures prior to staff augmentation. These actions were then compared to the minimum staffing for emergency response implementation as described in Section B, Attachment 1, Table B-1, ensuring that no actions were assigned to staff members that conflicted with either their dedicated emergency response role or their dedicated operational role, as appropriate. In cases where multiple tasks were assigned to an individual, the team evaluated the timing of the tasks to ensure that they could be performed by the individual in series within any specified time requirements. The accident scenarios considered in the analysis were the main steam line break (MSLB) accident, steam generator tube rupture (SGTR) accident, loss of coolant accident (LOCA), fuel handling accident (FHA) in the SFP, gas decay tank rupture, design basis threat, aircraft probable threat, Control Room fire leading to evacuation and remote shutdown, and station blackout.
The analysis concluded that an on-shift staff of eleven (11) is required to respond to the most limiting accident scenario reviewed.
FCS RERP Section B, Attachment 1, Table B-1 specifies the minimum staffing requirements for the FCS on-shift staff, defines the positions initially responsible for satisfying key ERO functions, and specifies positions that will augment the on-shift staff.

LIC-16-0076 Page 6 Emergency Response Organization Staffing The FCS RERP defines four classes of emergency events: Notification of Unusual Event (NOUE),
Alert, Site Area Emergency (SAE) and General Emergency (GE). Because on-shift personnel can normally address an emergency response to NOUEs without additional support, staff augmentation may not be activated for an NOUE declaration. The Operations Shift Manager maintains responsibility during NOUEs, unless the Emergency Operations Facility (EOF) has been activated.
An Alert declaration results in the activation of the EOF, Technical Support Center (TSC), and Operations Support Center (OSC). The Joint Information Center (JIC) is activated following a SAE and GE classification, and can be activated at an earlier classification based on the decisions of the Corporate Communications Division. Overall responsibility for the event is assumed by the Emergency Director (ED) in the EOF when the EOF is declared operational. When the ERO is activated, notification is sent to those required to respond to their assigned Emergency Response Facility (ERF).
FCS RERP Section A.2, OPPD Concept of Emergency Operations, describes how the normal plant operating organization transitions into an ERO to effectively deal with any incident at FCS.
The FCS Onsite Emergency Organization is described in Section B, Organizational Control of Emergencies, and is depicted in Section B, Attachment 2, Figure B-2 of the FCS RERP. If initiating conditions exist that result in the declaration of an emergency, responsibility for emergency response initially lies with the Shift Manager. Currently, the Shift Manager may be relieved of the task of implementing the FCS RERP by the Control Room Coordinator.
The current Control Room Coordinator position is intended to provide a prompt transition of Command and Control functions from the Shift Manager within the Control Room complex. If the TSC is activated, command and control may be transferred to the Site Director. The Emergency Director in the EOF may assume command and control if that facility is activated. The command and control position is responsible for ensuring the continuity of resources throughout an event.
The normal operating organization will also assume their pre-assigned emergency response roles.
This is considered to be a short-term response organization that will be augmented within approximately one hour after call-out by additional plant personnel.
If an Alert, SAE, or GE is declared, or if the minimum shift crew requires assistance during an NOUE, the onsite emergency organization will be augmented by additional plant personnel as described in Section B of the FCS RERP, Organizational Control of Emergencies and shown in Section B, Attachment 1, Table B-1 and Section B, Attachment 2 Figure B-2. The FCS RERP describes the augmented emergency organization that will staff and operate the EOF, TSC, OSC, and JIC as needed within approximately one hour of the request for activation.
Plans and procedures have been put into place to ensure the timely activation of ERFs. FCS RERP Section B, Attachment 2, Figure B-3 identifies the interrelationships among the various emergency organizations.
3.0     DETAILED DESCRIPTION The proposed changes would revise the FCS RERP to reflect the permanently shut down and defueled condition. Specifically, the proposed changes would eliminate the on-shift positions not needed for the safe storage of spent fuel in the SFP during the initial decommissioning period and eliminate the ERO positions not necessary to effectively respond to credible accidents.

LIC-16-0076 Page 7  of this submittal provides a tabular summary of the proposed changes to the FCS RERP. Attachment 3 of this submittal provides the revised pages of the FCS RERP with the proposed changes shown in strikethrough and underline format. The changes shown in Attachments 2 and 3 include additional changes beyond those involving a reduction in on-shift and ERO staffing. NRC approval of these additional changes is not being requested. These additional changes are included for clarification purposes.
Additional changes, not requiring prior NRC approval, will be made to the FCS RERP and will be dispositioned prior to implementation in accordance with the requirements in 10 CFR 50.54(q),
Conditions of Licenses, related to emergency preparedness, and specifically to making changes to emergency response plans.
On-Shift Staffing Currently, FCS RERP Section B, Attachment 1, Table B-1, OPPD Emergency Response Organization (ERO) Functions and Shift Staff Augmentation Plan, specifies the on-shift and augmented staffing for certain positions in the following Major Functional Areas:
Plant Operations and Assessment of Operational Aspects Emergency Command and Control (Emergency Coordinator)
Notification/Communication Radiological Accident Assessment and Support of Operational Accident Assessment Plant Systems Engineering, Repair and Corrective Actions Protective Actions (Plant)
Firefighting Rescue Operations and First Aid Site Access Control and Personnel Accountability The proposed changes to the FCS RERP will eliminate the following on-shift positions currently identified in Section 4.1.1 of the FCS RERP:
2 Reactor Operators 1 Equipment Operator 1 Control Room Communicator 1 Chemistry Technician 1 Habitability Technician 1 STA The post-shutdown on-shift complement will consist of:
1 Shift Manager (SRO/CFH) 1 Control Room Operator (SRO or RO/CFH) 1 Equipment Operator/NCO 1 Radiation Protection Technician

LIC-16-0076 Page 8 Title changes for Licensed personnel and Equipment Operators to CFHs and NCOs, respectively, are dependent upon NRC approval of proposed changes to the FCS Technical Specifications that revise the minimum shift staffing requirements in the FCS Technical Specifications by replacing references to licensed and non-licensed operators with references to CFHs and NCOs.
Implementation of the FCS RERP, as proposed for revision in this submittal, is not dependent on prior NRC approval of the proposed changes to the FCS Technical Specifications.
These staffing levels have been evaluated in the FCS analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition. The analysis is provided in Attachment 4 of this submittal.
The term NCO is used to differentiate from CFH. CFHs will supervise fuel handling operations in the permanently defueled condition. Both Control Room Operators (CROs) and Shift Managers will be qualified as CFHs. However, the Shift Manager requires additional qualification beyond the CFH training. Therefore, any reference to the CFH position throughout this submittal is considered to be equivalent to the CRO position. NCOs will perform duties typically associated with those performed by Equipment Operators, such as manipulation and monitoring of plant equipment.
Reference 6 submitted a CFH training program for NRC approval. Senior Reactor Operators and Reactor Operators will not be utilized in the permanently defueled condition.
The NCO training program will be developed in accordance with 10 CFR 50.120. The Equipment Operator/NCO position will combine the post-shutdown duties of the licensed Reactor Operator and the non-licensed Equipment Operator. The specific training requirements of the Equipment Operator/NCO position will be drafted by the FCS Training Department and will be reviewed and approved by Operations Management. The training requirements will include classroom training in theory and systems topics, administrative procedures, off-normal and transient procedures/mitigation strategies, and refuel platform operations. The training program will be designed with an emphasis on dose assessment, systems/processes important to maintaining SFP cooling and monitoring and controlling SFP parameters, such as SFP water level and temperature.
Consequently, the Equipment Operators/NCOs will be trained on pertinent Control Room indications and controls that will be monitored and operated to maintain SFP cooling and SFP water level, in addition to plant radiological conditions. The NCO training program will also include training on applicable aspects of the FCS RERP-related NCO duties.
Personnel assigned to fill the NCO positions during the post-shutdown period, prior to implementation of the Permanently Defueled Emergency Plan (PDEP), will include both previously licensed and non-licensed operators. The majority of the required training for the NCO position will already have been completed by the licensed operators because they have previously been trained and qualified as Reactor Operators to support power operations. The current Equipment Operators have been trained and qualified as non-licensed operators only. Therefore, it is expected they will require additional training related to Control Room operations.
Once the specific training requirements for the NCO position have been identified using a systematic approach to training, as required by 10 CFR 50.120, a formal gap analysis will be completed for all operators identified to fill the NCO position. Individualized training plans will be developed and completed to address specific knowledge and skill areas for the selected NCO candidates. This will include training the currently qualified Equipment Operators on Control Room indications, controls, procedures, and Emergency Plan requirements. The initial training for any new NCOs will include all training requirements for the NCO position to ensure the personnel are equipped with the required skills and knowledge to perform their required job functions.

LIC-16-0076 Page 9 The proposed changes to the on-shift organization are identified in the FCS Post Shutdown RERP Section B, Attachment 1, Table B-1, OPPD Emergency Response Organization (ERO) Functions and Shift Staff Augmentation Plan, and Section B, Attachment 2, Figure B-2, Fort Calhoun Station Emergency Response Organization, Attachment 3.
Emergency Response Organization Staffing The proposed changes to the FCS RERP will eliminate ERO positions currently identified in Part 4 of Section B of the FCS RERP and Emergency Plan Implementing Procedures (EPIPs) for the augmentation of the Control Room staff and the activation and operation of the TSC, EOF, OSC, and JIC. Several of these positions are described in FCS EPIPs as positions required to meet the augmentation requirements of the emergency plan and positions needed to declare the ERFs operational. The proposed changes to the FCS RERP will also eliminate non-minimum (i.e., not required for augmentation or facility activation) ERO positions currently identified in EPIPs as support personnel. Specific ERO positions identified for elimination are listed in Table 1 of this attachment. Table 1 also identifies whether each position is currently required to meet the augmentation requirements of the FCS RERP.
Currently, FCS RERP Section B, Attachment 1, Table B-1 specifies the on-shift and augmented staffing for certain positions in the Major Functional Areas identified above. The proposed changes to the FCS RERP will eliminate the following augmenting positions identified in Table B-1:
Control Room Coordinator Control Room ENS Communicator Communicator in TSC Four (4) Radiation Protection (RP) Technicians Electrical and I&C Engineer Primary Systems Engineer Radiation Protection Coordinator Dosimetry Technician The proposed changes to the FCS RERP will also eliminate the following minimum staffing ERO positions for activation of ERFs currently identified in Parts 4.3.3, 4.3.4, and 4.3.5 of Section B of the FCS RERP:
OSC Radiation Protection Coordinator (Table B-1 position identified above as Radiation Protection Coordinator)
TSC COP Communicator (Table B-1 position identified above as Communicator in TSC)
EOF Dose Assessment Coordinator After permanent cessation of power operations and certification of permanent removal of fuel from the reactor vessel, in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license will no longer authorize reactor operation or emplacement or retention of fuel in the reactor vessel. As a result, the title of the Reactor Safety Coordinator position identified in Part 4.3.4 and Attachment 1, Table B-1 of Section B of the FCS RERP is not descriptive of the functions performed by the position. The current Reactor Safety Coordinator position will be retitled to the Engineering Coordinator. The Engineering Coordinator position will be tasked with performing an engineering assessment of plant conditions and/or actions needed to mitigate damage to the plant.

LIC-16-0076 Page 10

==4.0    TECHNICAL EVALUATION==

4.1     Accident Analysis Chapter 14 of the FCS Final Safety Analysis Report as Updated (USAR) describes the Abnormal Operational Transients and Design Basis Accident (DBA) scenarios that are applicable during plant operations. Fire events are addressed throughout the USAR. Upon docketing of the certifications required by 10 CFR 50.82(a)(1)(i) and (ii), the 10 CFR Part 50 license for FCS will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel, as specified in 10 CFR 50.82(a)(2). Therefore, most of the accident scenarios postulated in the USAR will no longer be applicable once FCS is in the permanently defueled condition.
One of the Chapter 14 accidents that will remain applicable to FCS in its permanently shut down and defueled condition is the FHA in the SFP. USAR Chapter 14 will be revised to eliminate the DBAs that will not be applicable in the permanently defueled condition.
The Station Blackout (SBO) event was not considered in the analysis of proposed post-shutdown on-shift staffing. Once the certifications required by 10 CFR 50.82(a)(1)(i) and (ii) are docketed, FCS will no longer be licensed to operate, therefore the provisions of 10 CFR 50.63 (Loss of all alternating current power) will no longer be applicable pursuant to 10 CFR 50.63(a)(1).
A comparison of the accident scenarios included in the current On-Shift Staffing Analysis (EP-FC-1001, Addendum 1) (Reference 7) and the analysis of proposed post-shutdown on-shift staffing is provided in the following section.
A specific analysis was conducted to determine if sufficient on-shift staffing would be available to implement emergency response actions in response to potential aircraft impacts in reflected in 10 CFR 50.54(hh)(1). In the permanently shut down and defueled condition, the Fire Brigade will relocate and prepare for reentry. The task of maintaining communications during this event are transferred to an Equipment Operator/NCO trained and qualified to perform this function.
Therefore, sufficient staffing is available to promptly implement response actions required under 10 CFR 50.54(hh)(1) without impacting the performance of designated emergency plan functions.
A specific analysis to determine if sufficient on-shift staffing would be available to promptly implement SFP inventory makeup strategies was not necessary. The FCS 5-person Fire Brigade is currently responsible for implementing the SFP inventory makeup strategies required under 10 CFR 50.54(hh)(2). In the permanently shut down and defueled condition, FCS will continue to maintain a trained and qualified 5-person Fire Brigade responsible for implementation of the SFP inventory makeup strategies. The Fire Brigade personnel responsibilities identified in the post-shutdown RERP are separate and distinct from those for implementing the major elements of the emergency plan including emergency classification (Shift Manager), offsite notifications (Control Room Operator (or NCO during events requiring Fire Brigade response), and dose assessment/protective action recommendation development (Radiation Protection Specialist or NCO). Therefore, sufficient staffing is available to promptly implement SFP inventory makeup strategies required under 10 CFR 50.54(hh)(2) without impacting the performance of designated emergency plan functions.
As described in Section 4.2.1.2, 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 50.54(hh)(2). These strategies will continue to be maintained to satisfy applicable portions of Condition G of the FCS Renewed Facility Operating License.

LIC-16-0076 Page 11 4.2      Analysis of Proposed Changes 4.2.1    ERO Staffing Prior to an emergency declaration, the normal plant operating organization is in place. The initial classification of an off-normal event occurs in the Control Room. Classification and declaration are performed by the Shift Manager. Upon the classification and declaration of an emergency, the Shift Manager assumes the Command and Control role and retains that role until another designated Command and Control position (currently, the Control Room Coordinator, Site Director in the TSC, or Emergency Director in the EOF) can assume control. The onsite emergency organization is activated by personnel notification or when the station alarm is sounded and the emergency is announced over the public address system. Initially, the ERO consists of the normal operating shift personnel who function as the emergency team members. The normal operating staff is augmented, as needed, by plant personnel. Those personnel onsite respond when the station alarm is sounded and the announcement is made or when individuals are notified by another means. Personnel not onsite during off-hours operations will be notified via an ERO notification system. A designated on-shift plant employee shall perform notifications. The details of notifying all emergency operations personnel during normal and off-hours are contained in EPIPs.
In the permanently defueled condition, FCS will maintain ERO teams, with one team being on duty and on-call at any given time. When the Shift Manager directs the activation of the ERO call out system, all ERO members are notified to ensure adequate coverage of all ERO positions at all ERFs. ERO members not on-call are expected to respond unless they are unavailable.
FCS requires ERO personnel to act promptly in reporting to their assigned ERF even when not on duty. During duty periods, procedures further require that team members respond within the required response time for their ERF and that they remain fit for duty throughout the duty assignment. Individuals are trained to respond to their ERF even if they are not on duty. Excess personnel that respond may be assigned support responsibilities or be designated as a relief shift.
This conservative policy ensures timely activation because some off duty personnel may respond sooner than the on duty personnel.
The proposed revisions to the FCS RERP will not change the requirements described above.
OPPD managements continued expectation is that all duty and support ERO members report to their respective ERF as quickly as possible.
FCS currently has designated ERO members who staff positions that augment the Control Room staff. These Control Room augmenting positions are described in Section 4.5.2 of Part B of the FCS RERP. With the exception of the Control Room Operations Liaison position, the Control Room augmenting positions will not exist in the post-shutdown ERO because the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The set of plant equipment required in the permanently defueled condition is also greatly reduced, which reduces the assessment and mitigation activities the Control Room must perform prior to the TSC and EOF being declared operational.
The retention of the tasks necessary to implement the RERP by the on-shift Control Room staff prior to ERO augmentation, including the ability of the Shift Manager to maintain Command and Control responsibilities, has been evaluated in the FCS analysis of proposed post-shutdown on-shift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.

LIC-16-0076 Page 12 FCS has designated ERO members who staff positions required to meet minimum staffing to activate the TSC, OSC, EOF, and JIC. EPIPs identify ERO positions assigned to each facility and the minimum staffing required before each facility can be declared operational. All ERO personnel are expected to respond when notified by the ERO notification system.
Current ERO positions are identified, and the associated duties are captured, in the ERO Task Analysis provided in Attachment 5. The duties of the ERO positions were reviewed against OPPD procedures and the FCS RERP. Each of the eliminated positions was analyzed to identify the key duties associated with the position and the duties were then evaluated against the planning standards in NUREG-0654.
The Table provided in Attachment 5 contains columns with headings "Implementing Actions" and "Task Assigned To?". These columns provide the details for disposition of each task. Procedures and training materials depicting the changes presented in Attachment 5 will be developed. Some of the tasks are identified as being eliminated because they become unnecessary following permanent cessation of power operations and permanent removal of fuel from the reactor vessel.
Other tasks are identified as eliminated because the tasks are performed by other positions in the ERO and will continue to be performed by these positions in the post-shutdown ERO.
The proposed changes to the FCS RERP, including the changes made to develop the post-shutdown ERO, have been evaluated for impacts on the ERO and for the ability of offsite response organizations to implement their Federal Emergency Management Agency (FEMA) approved Radiological Emergency Preparedness (REP) Plans. Potential impacts on the ability of the State and local response organizations to effectively implement their FEMA-approved REP Plans do not exist because no tasks that require interfacing with State and local response organizations are proposed for elimination. FCS has appropriately addressed elimination of ERO positions that interface with offsite representatives by transferring the necessary tasks to remaining post-shutdown ERO positions. In addition, the FCS ERO will continue to include technical support staff that have dedicated responsibilities for interfacing with State and local representatives.
To validate the results of the analysis, one or more drills will be developed and conducted prior to implementation of the changes described within this LAR. The drills will be conducted to confirm the ability of the post-shutdown ERO to perform the necessary functions of each ERF. The drills will be used to train and qualify post-shutdown ERO members, evaluate and validate the ability to accomplish the stated mission of each ERF, and ensure that the planning standard functions are preserved with no degradation in time sensitive activities or in the ability to communicate with offsite response organizations. The drills will also validate that the post-shutdown ERO continues to address the risks to public health and safety and comply with the FCS RERP, site commitments, and applicable regulations. Implementing procedures will be revised to address the permanently shut down and defueled conditions. The revised procedures will be used to support training of ERO staff and the conduct of drills described above.
Training and procedures will be developed and in place prior to performing post-shutdown ERO drills. The drill scenarios will include SFP events and will be designed to test the major elements of the FCS post shutdown RERP. Major elements to be tested will include communications and coordination with offsite response organizations, including the JIC. State, Local, and Federal response organizations will be provided the opportunity to participate in or observe the drills. New regulatory commitments for scenario elements and communication with offsite agencies are included in Attachment 6.

LIC-16-0076 Attachment 1 Page 13 FCS has not yet finalized a schedule of drills that will be conducted. FCS will provide the schedule to the NRC and FEMA with appropriate advanced notice, thereby providing the NRC and FEMA an opportunity to observe each drill. A new regulatory commitment to provide the schedule to the NRC is included in Attachment 6.
Table 1 - Emergency Response Organization Positions Current FCS Proposed Positions in the RERP Procedure(s)               Current Positions                 Post-Shutdown Emergency Augmentation Plan1 Requirements Technical Support Center EP-FC-112-200       Site Director                           Site Director                     Yes EP-FC-112-200       TSC COP Communicator                                    --                Yes EP-FC-112-200       TSC Protective Measures                 TSC Protective Measures           Yes Coordinator                             Coordinator EP-FC-112-200       TSC Reactor Safety Coordinator          TSC Engineering Coordinator       Yes EP-FC-112-200       TSC Elec/I&C Engineer                                   --                No EP-FC-112-200       TSC Primary Systems Engineer                            --                No EP-FC-112-200       TSC Field Team Technicians              TSC Field Team Technicians        No EP-FC-112-200       TSC Ops Liaison                         TSC Ops Liaison                   No EP-FC-112-200       Admin Logistics Coordinator             Admin Logistics Coordinator       No EP-FC-112-200       TSC Director                                            --                No EP-FC-112-200       Reactor Engineer                                        --                No EP-FC-112-200       TSC Secondary Systems                                   --                No Engineer EP-FC-112-200       Security Coordinator                    Security Coordinator              No EP-FC-112-200       TSC CHP Communicator                                    --                No EP-FC-112-200       Admin Assistant                                         --                No EP-FC-112-200       Site Director Secretary                                 --                No EP-FC-112-200       TSC Status Board Keeper                                 --                No Operations Support Center EP-FC-112-300       OSC Director                            OSC Director                      Yes EP-FC-112-300       RP Coordinator                                          --                Yes or RP Tech EP-FC-112-300       Technicians (Electrical, I&C,           Technicians (Electrical, I&C,     Yes Mechanical Maintenance, RP/HP,          Mechanical Maintenance, Chemistry)                              RP/HP, Chemistry)
EP-FC-112-300       Dosimetry Technician                                    --                No EP-FC-112-300       Operations Liaison                                      --                No EP-FC-112-300       Chemistry Coordinator                                   --                No EP-FC-112-300       ERMS Operator                                           --                No

LIC-16-0076 Attachment 1 Page 14 Current FCS Proposed Positions in the RERP Procedure(s)           Current Positions            Post-Shutdown Emergency Augmentation Plan1 Requirements Operations Support Center (cont.)
EP-FC-112-300    Maintenance Coordinator                          --              No EP-FC-112-300    Maintenance Planner                              --              No EP-FC-112-300    Medical Response Coordinator                     --              No EP-FC-112-300    Radio Operator                                   --              No EP-FC-112-300    Store Keeper                                     --              No EP-FC-112-300    Accountability Clerk                             --              No Emergency Operations Facility EP-FC-112-400   Emergency Director                 Emergency Director             Yes EP-FC-112-400   EOF COP Communicator               EOF COP Communicator           Yes EP-FC-112-400   EOF Protective Measures Manager EOF Protective Measures           Yes or DAC Manager EP-FC-112-400   EOF Dose Assessment Specialist     EOF Dose Assessment            Yes Specialist EP-FC-112-400   EOF Dose Assessment                               --              Yes or PMM Coordinator EP-FC-112-400   EOF Admin Logistics Manager        EOF Admin Logistics Manager    No EP-FC-112-400   EOF Information Specialist         EOF Information Specialist     No EP-FC-112-400   EOF Ops Liaison                    EOF Ops Liaison                No EP-FC-112-400   EOF Field team                     EOF Field Team                 No EP-FC-112-400   Field Team Specialist              Field Team Specialist          No EP-FC-112-400   EOF Technical Liaison              EOF Technical Liaison          Yes EP-FC-112-400   EOF Clerical Assistant                            --              No EP-FC-112-400   Emergency Director Secretary                      --              No EP-FC-112-400   Des Moines Site Representative     Des Moines Site Representative No EP-FC-112-400   IT Specialist                                     --              No EP-FC-112-400   EOF CHP Communicator                              --              No EP-FC-112-400   Communications Specialist                         --              No EP-FC-112-400   Emergency Response Coordinator                    --              No EP-FC-112-400   EOF Secretary                                     --              No EP-FC-112-400   EOF Dose Assessment Assistant                     --              No EP-FC-112-400   EOF Status Board Keeper                           --              No

LIC-16-0076 Attachment 1 Page 15 Current FCS Proposed Positions in the RERP Procedure(s)                Current Positions               Post-Shutdown Emergency Augmentation Plan1 Requirements Joint Information Center Crisis         Company Spokesperson                    Company Spokesperson               Yes Communication Plan Crisis         JIC Manager                             JIC Manager                        Yes Communication Plan Crisis         Executive Liaison                                        --                No Communication Plan Crisis         Internal information Liaison                             --                No Communication      (Spokesperson)
Plan Crisis         JIC Media Information Specialist        JIC Media Information Specialist   Yes Communication Plan Crisis         JIC Technical Liaison                   JIC Technical Liaison              Yes Communication Plan Crisis         Public Inquiry Supervisor                                --                No Communication Plan Crisis         Public Inquiry Specialist (10)          Public Inquiry Specialist (5)      No Communication Plan Crisis         JIC Clerical Supervisor                 JIC Clerical Supervisor            Yes Communication Plan 1-- Indicates the position is proposed for elimination upon implementation of the Post-Shutdown Emergency Plan.
The intent of Table 1 is to compare the current ERO positions against the proposed post-shutdown ERO positions. Table 1 also identifies whether each position is currently required to meet the augmentation requirements of the FCS RERP according to the EPIPs. As an example, the TSC Reactor Engineer is a position that is proposed for elimination in the post-shutdown ERO, because in a permanently shut down and defueled condition, responsibilities associated with a reactor core no longer need to be maintained. Also, Table 1 identifies the TSC COP Communicator as a current minimum staff position. The position is not included as a proposed position in the post-shutdown ERO upon implementation of the changes identified herein. The proposed elimination of the ERO minimum staff positions is described in the following sections.

LIC-16-0076 Page 16 4.2.1.1 Technical Support Center The TSC has been designed to meet the intent of the guidance in NUREG-0696, Functional Criteria for Emergency Response Facilities, and the clarification in NUREG-0737, Supplement 1, Clarification of TMI Action Plan Requirements, as applicable. Following permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the TSC will continue to be located on the north side of the Auxiliary Building. The proposed changes to the FCS RERP do not involve any physical modifications to, or layout/configuration changes in, the TSC.
The current FCS RERP and ERO staffing is intended to address the risks to public health and safety inherent in an operating reactor. The risk in the permanently defueled condition is significantly reduced because many of the potential initiating conditions that would lead to an emergency declaration will no longer be possible.
The spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The set of plant equipment required in the permanently defueled condition is also greatly reduced, which reduces the assessment and mitigation activities the TSC must perform.
Therefore, the TSC COP Communicator, TSC Elec/I&C Engineer, TSC Primary Systems Engineer, TSC Reactor Engineer, TSC Director, TSC Secondary Systems Engineer, Admin Assistant, Site Director Secretary, TSC Status Board Keeper, and TSC CHP Communicator positions can be eliminated without placing an undue burden on the remaining ERO positions in the TSC and without increasing the risk to public health and safety. Attachment 5 contains an analysis of all ERO positions being eliminated and evaluates the transfer of tasks to remaining ERO positions following permanent cessation of power operations. The proposed ERO staffing reductions continue to address the risks to public health and safety, comply with the FCS RERP, site commitments, and applicable regulations.
As previously described, to validate the results of the analysis, one or more drills will be developed and conducted prior to implementation of the changes described within. The drills will be conducted to confirm the ability of the post-shutdown ERO to perform the necessary functions of each ERF. The drills will be used to train and qualify post-shutdown ERO members, evaluate and validate the ability to accomplish the stated mission of each ERF, and ensure that the planning standard functions are preserved with no degradation in time sensitive activities or in the ability to communicate with offsite response organizations. The drills will also validate that the post-shutdown ERO continues to address the risks to public health and safety and comply with the FCS RERP, site commitments, and applicable regulations. Implementing procedures will be revised to address the permanently shut down and defueled conditions. The revised procedures will be used to support training of ERO staff and the conduct of drills described above.
Training and procedures will be developed and in place prior to performing post-shutdown ERO drills. The drill scenarios will include SFP events and be designed to test the major elements of the FCS post shutdown RERP. Major elements to be tested will include communications and coordination with offsite response organizations, including the JIC. State, local, and Federal response organizations will be provided the opportunity to participate in or observe the drills. New regulatory commitments for scenario elements and communication with offsite agencies are included in Attachment 6.

LIC-16-0076 Page 17 The ERF procedures describing activation and operation of each facility will continue to assign responsibilities to ERO responders for the purposes of removing the responsibilities of coordinating with offsite responders and delivering information to the public from the Control Room staff, thereby allowing operations personnel to perform their assigned functions. ERO duties have been reviewed and duties for those positions proposed for elimination will be transferred appropriately.
The proposed staffing changes eliminate one ERO position in the TSC described in FCS EPIPs as a minimum staff position, the TSC COP Communicator.
TSC COP Communicator The TSC COP Communicator position is described in Section B.4.6.1.D of the FCS RERP and further detailed in EP-FC-112-200-F-05, TSC COP Communicator Checklist. According to Section B.4.6.1.D of the FCS RERP, the TSC COP Communicator performs notifications as directed by the Command and Control position. The EOF COP Communicator has redundant duties. Because both positions have the same response time, the TSC COP Communicator duties can be transferred to the EOF COP Communicator with no loss of efficiency. contains an analysis of all ERO positions being eliminated and evaluates the transfer of tasks to remaining ERO positions following permanent cessation of power operations and permanent removal of fuel from the reactor vessel. The proposed ERO staffing reductions continue to address the risks to public health and safety, comply with the FCS RERP, site commitments, and applicable regulations.
In addition to the TSC COP Communicator, the following TSC positions are proposed for elimination following permanent cessation of power operations:
TSC Reactor Engineer TSC Elec/I&C Engineer TSC Primary Systems Engineer TSC Secondary Systems Engineer TSC Director Admin Assistant Site Director Secretary TSC Status Board Keeper TSC CHP Communicator TSC Reactor Engineer While not a minimum staff position in the TSC, the primary duty of the TSC Reactor Engineer is to perform core damage assessments. In a permanently shut down and defueled condition, responsibilities associated with a reactor core no longer need to be maintained. FCS RERP Section B, Attachment 1, Table B-1 indicates that the TSC Reactor Safety Coordinator (retitled the TSC Engineering Coordinator in the Post-Shutdown RERP) is responsible for the core/thermal hydraulics task. Elimination of the TSC Reactor Engineer position will have no effect on emergency response in a permanently defueled condition because the position is not required to assess the condition of fuel in the SFP during an emergency. The TSC Reactor Engineer position can be eliminated without increasing the risk to public health and safety because the major task of evaluating core/thermal hydraulics is not necessary or possible in a permanently shut down and defueled condition.

LIC-16-0076 Page 18 TSC Engineers (Elec/I&C, Primary Systems, Secondary Systems)
The primary duties of the TSC Engineer positions include: providing engineering analysis and troubleshooting, evaluating the implementation of Severe Accident Management Guidelines, and assisting in the assessment and development of repair plans. These duties, described in implementing procedures, are either no longer necessary in a permanently shut down and defueled condition or will be performed by other members of the post-shutdown ERO.
The TSC Reactor Safety Coordinator (retitled the TSC Engineering Coordinator in the post-shutdown RERP) is tasked with performing an engineering assessment of plant conditions and/or actions needed to mitigate damage to the plant. FCS EPIPs will continue to direct the Engineering to continuously evaluate the need for engineering resources and coordinate with the EOF Admin Logistics Manager to call in additional engineering assistance, as needed. These individuals may be tasked with activities to be completed at engineering offices external to the TSC, called to report to the TSC, or directed to other facilities as needed.
FCS EPIPs will continue to identify engineering resources as augmented positions with specific training and qualification requirements for assigned personnel in accordance with the site training program. The required training courses and requalification frequencies will be unchanged in the post-shutdown condition. However, these positions will no longer be identified as on-call positions.
The elimination of the TSC Engineer positions is justified because the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The set of plant equipment required in the permanently defueled condition is also greatly reduced, which reduces the assessment and mitigation activities the TSC must perform.
Other Positions The elimination of the TSC Director, Admin Assistant, Site Director Secretary, TSC Status Board Keeper, and TSC CHP Communicator positions does not impact the capabilities of the on-shift staffing or augmented response. The TSC will continue to be activated at an Alert or higher declaration. Functional responsibilities of the positions eliminated as a result of the changes will be reassigned to remaining positions as illustrated in Attachment 5. The proposed ERO staffing reductions continue to address the risks to public health and safety, comply with the FCS RERP, site commitments, and applicable regulations.
4.2.1.2 Operations Support Center The OSC has been designed to meet the intent of the guidance in NUREG-0696, Functional Criteria for Emergency Response Facilities, and the clarification in NUREG-0737, Supplement 1, Clarification of TMI Action Plan Requirements, as applicable. Following permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the OSC will continue to be located in the TSC Building. The proposed changes to the FCS RERP do not involve any physical modifications to, or layout/configuration changes in, the OSC.

LIC-16-0076 Page 19 The proposed staffing changes do not eliminate any ERO positions in the OSC described in FCS EPIPs as minimum staff positions. Following permanent cessation of power operations, the following OSC positions are proposed for elimination: one RP Technician, RP Coordinator, Maintenance Coordinator, Chemistry Coordinator, Medical Response Coordinator, OSC Operations Liaison, Dosimetry Technician, ERMS Operator, Radio Operator, Storekeeper, and Accountability Clerk. Attachment 5 contains an analysis of all ERO positions being eliminated and evaluates the transfer of tasks to remaining ERO positions following permanent cessation of power operations and permanent removal of fuel from the reactor vessel. The proposed ERO staffing reductions continue to address the risks to public health and safety, comply with the FCS RERP, site commitments, and applicable regulations.
As previously described, to validate the results of the analysis, one or more drills will be developed and conducted prior to implementation of the changes described within. The drills will be conducted to confirm the ability of the post-shutdown ERO to perform the necessary functions of each ERF and will utilize the post-shutdown procedures that will be developed depicting the revised assignment of duties. The drills will be used to train and qualify post-shutdown ERO members, evaluate and validate the ability to accomplish the stated mission of each ERF, and ensure that the planning standard functions are preserved with no degradation in time sensitive activities or in the ability to communicate with offsite response organizations. The drills will also validate that the post-shutdown ERO continues to address the risks to public health and safety and comply with the FCS RERP, site commitments, and applicable regulations. Implementing procedures will be revised to address the permanently shut down and defueled conditions. The revised procedures will be used to support training of ERO staff and the conduct of drills described above.
Training and procedures will be developed and in place prior to performing post-shutdown ERO drills. The drill scenarios will include SFP events and be designed to test the major elements of the FCS post shutdown RERP. Major elements to be tested will include communications and coordination with offsite response organizations, including the JIC. State, Local, and Federal response organizations will be provided the opportunity to participate in or observe the drills. New regulatory commitments for scenario elements and communication with offsite agencies are included in Attachment 6.
In the permanently shut down and defueled condition, the primary functions of the OSC will remain dispatching of, and accounting for, Repair and Corrective Action Teams and dispatching of Site Boundary Teams. The OSC Director is responsible for ensuring adequate staffing of the OSC to support the emergency; working with the Site Director to set priorities for the OSC; and directing the activities of the OSC to support the emergency response. If at any time the OSC Director determines additional manpower is necessary to accomplish the mission of the OSC, the OSC Director will contact the TSC Admin Logistics Coordinator to arrange for augmentation by additional personnel to support the emergency response functions of the OSC.
In the permanently shut down and defueled condition, the spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The primary events of concern in the immediate post-shutdown and defueled condition will be a FHA and a loss of SFP cooling and/or water inventory. During fuel handling activities there will be extra personnel on site that will, were a FHA to occur, be able to respond to the event. Events involving a loss of SFP cooling and/or water inventory will continue to be addressed by implementation of SFP inventory makeup strategies in plant procedures and as required under 10 CFR 50.54(hh)(2).). These strategies will continue to be maintained as a license condition. OSC staff is not relied upon to implement SFP inventory makeup.

LIC-16-0076 Page 20 Restoration of equipment supporting SFP cooling and inventory will be the primary focus of emergency mitigation actions for the TSC and OSC in a permanently shut down and defueled condition. Although ERO activation/response time requirements will be unchanged, the elimination of credible accidents involving an operating reactor provides additional time to plan and execute assessment and mitigation actions. The proposed changes do not impact the capability to assess and monitor actual or potential offsite consequences of a radiological emergency or provide information to offsite authorities in a timely manner. Therefore, the RP Coordinator, Maintenance Coordinator, Chemistry Coordinator, Medical Response Coordinator, OSC Operations Liaison, Dosimetry Technician, ERMS Operator, Radio Operator, Storekeeper, and Accountability Clerk positions can be eliminated without placing an undue burden on the remaining ERO positions in the OSC and without increasing the risk to public health and safety.
4.2.1.3 Emergency Operations Facility As described in Section H.2 of the FCS RERP, the EOF functions to maintain overall management of emergency response and recovery resources; evaluate, coordinate, and communicate emergency response activities with Federal, State, and local emergency response organizations; evaluate offsite accident conditions; and make recommendations to offsite agencies regarding protective actions. Nebraska and Iowa representatives are provided space and communications at the EOF and staff this facility at an Alert or higher classification.
The EOF has been designed to meet the intent of the guidance in NUREG-0696, Functional Criteria for Emergency Response Facilities, and the clarification in NUREG-0737, Supplement 1, Clarification of TMI Action Plan Requirements, as applicable. Following permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the EOF will continue to be located at North Omaha Power Station, approximately 17 miles from the plant site. The proposed changes to the FCS RERP do not involve any physical modifications to, or layout/configuration changes in, the EOF.
The EOF maintains extensive communications capability with all ERFs and direct links are established between the EOF, the Control Room, the State and County Emergency Operations Centers (EOCs), and the JIC to provide up-to-date emergency status reports. The proposed changes to the FCS RERP do not involve changes to the ability of offsite authorities to report to the EOF or the JIC, and as a result, do not impact the ability of the offsite authorities to mobilize to, or operate from, the EOF and JIC.
When activated, the Emergency Director reports to the EOF and directs the activities of the ERO throughout the emergency and until the recovery activities have been terminated. The Emergency Director, or a designated alternate, is notified of all emergency conditions occurring at the plant and issues periodic status reports of the event to the responding offsite representatives. As described in Section B.4.10 of the FCS RERP, the EOF serves as the primary interface with the various offsite support agencies. FCS RERP, Section B, Attachment 2, Figure B-3, Organizational Interrelationships illustrates the interface of the EOF with federal, state, and local support agencies. The proposed changes to the FCS RERP do not reduce the ability of FCS to provide the necessary information regarding the status and progression of an event or in the frequency at which event information updates are provided. Nor do the changes impact the ability to dispatch additional technical support to the EOCs. As a result, the proposed changes do not impact the ability of FCS to communicate with the offsite response organizations.

LIC-16-0076 Page 21 Centralized coordination of the offsite radiological assessment effort with all organizations interested in, and/or performing, assessments is necessary to ensure that the data and its interpretation are reviewed by FCS and offsite response organizations with monitoring and assessment responsibilities. The number and type of organizations performing this effort vary with time and following emergency declarations and offsite notification. Initially, plant emergency response personnel are the only organization performing this function and they are directed from, and their results evaluated, at the EOF. State authorities join the EOF monitoring and assessment activities. Federal response agencies would augment plant and State radiological assessment efforts upon their arrival. Plant and State monitoring efforts are coordinated at the EOF. The proposed changes to the FCS RERP do not involve changes to offsite radiological assessment capabilities or coordination of these efforts with offsite response organizations, and as a result, do not impact the ability of offsite agencies to effectively implement their emergency plans.
FCS will continue to maintain the capability to display plant and meteorological data in the EOF, maintain offsite monitoring equipment at the EOF and maintain the current dose assessment capabilities at the EOF. Additionally, FCS will maintain a goal of approximately sixty (60) minutes after declaration of an emergency to activate the EOF.
The proposed staffing changes would eliminate one ERO position in the EOF described in FCS EPIPs as a minimum staff position. FCS EPIPs identify the Dose Assessment Coordinator or the Protective Measures Manager as required minimum staff position. The Protective Measures Manager position is retained in the post-shutdown ERO.
The following EOF positions are proposed for elimination following permanent cessation of power operations and permanent removal of fuel from the reactor vessel:
Emergency Response Coordinator EOF Secretary EOF Dose Assessment Assistant EOF Status Board Keeper Dose Assessment Coordinator EOF Clerical Assistant Emergency Director Secretary IT Specialist EOF CHP Communicator Communications Specialist The proposed EOF staffing changes described above do not impact the capabilities of the on-shift staffing or augmented response. The positions can be eliminated without placing an undue burden on the remaining ERO positions in the EOF and without increasing the risk to public health and safety. Attachment 5 contains an analysis of all ERO positions being eliminated and evaluates the transfer of tasks to remaining ERO positions following permanent cessation of power operations and permanent removal of fuel from the reactor vessel. The EOF will continue to be activated at an Alert or higher declaration. Functional responsibilities of the positions eliminated as a result of the changes will be reassigned to remaining positions. The proposed ERO staffing reductions continue to address the risks to public health and safety, comply with the FCS RERP, site commitments, and applicable regulations.

LIC-16-0076 Page 22 As previously described, to validate the results of the analysis, one or more drills will be developed and conducted prior to implementation of the changes described within. The drills will be conducted to confirm the ability of the post-shutdown ERO to perform the necessary functions of each ERF. The drills will be used to train and qualify post-shutdown ERO members, evaluate and validate the ability to accomplish the stated mission of each ERF, and ensure that the planning standard functions are preserved with no degradation in time sensitive activities or in the ability to communicate with offsite response organizations. The drills will also validate that the post-shutdown ERO continues to address the risks to public health and safety and comply with the FCS RERP, site commitments, and applicable regulations. Implementing procedures will be revised to address the permanently shut down and defueled conditions. The revised procedures will be used to support training of ERO staff and the conduct of drills described above.
Training and procedures will be developed and in place prior to performing post-shutdown ERO drills. The drill scenarios will include SFP events and be designed to test the major elements of the FCS post shutdown RERP. Major elements to be tested will include communications and coordination with offsite response organizations, including the JIC. State, local and Federal response organizations will be provided the opportunity to participate in or observe the drills. New regulatory commitments for scenario elements and communication with offsite agencies are included in Attachment 6.
4.2.1.4 Joint Information Center The FCS JIC is located at the OPPD Energy Plaza, 444 South 16th Street Mall, in Omaha, Nebraska. As described in Section G of the FCS RERP, the JIC provides a location for the news media to receive information from all involved agencies and companies during an emergency and provide it to the general public. The JIC is equipped to accommodate the news media for large briefings and conferences and contains extensive communications systems. Media monitoring and rumor control is also accomplished at the JIC, allowing FCS and State representatives to address incorrect information or rumors. Responses to media telephone inquiries are also addressed at the JIC.
The JIC meets the intent of the guidance in Planning Standard G of NUREG-0654. Following permanent cessation of power operations, the JIC will continue to be located at the OPPD Energy Plaza in Omaha. The proposed changes to the FCS RERP do not involve any physical modifications to, or layout/configuration changes in, the JIC.
The proposed staffing changes do not eliminate any ERO position in the JIC described in FCS EPIPs as a minimum staff position.
The proposed staffing changes eliminate the following ERO positions in the JIC:
Executive Liaison Internal Information Liaison (Spokesperson)
Public Inquiry Supervisor Five (5) Public Inquiry Specialists

LIC-16-0076 Page 23 In the permanently shut down and defueled condition, media briefings and rumor control will continue to be conducted regularly during an emergency to provide accurate and timely information to the public. The proposed JIC staffing changes described above do not impact the capabilities of the on-shift staffing or augmented response. The positions can be eliminated without placing an undue burden on the remaining ERO positions in the JIC and without increasing the risk to public health and safety. Attachment 5 contains an analysis of all ERO positions being eliminated and evaluates the transfer of tasks to remaining ERO positions following permanent cessation of power operations and permanent removal of fuel from the reactor vessel. The JIC will continue to be activated at Site Area Emergency or higher declaration. Functional responsibilities of the positions eliminated as a result of the changes will be reassigned to remaining positions. The proposed ERO staffing reductions continue to address the risks to public health and safety, comply with the FCS RERP, site commitments, and applicable regulations.
As previously described, to validate the results of the analysis, drills will be developed and conducted prior to implementation of the changes described within. The drills will be conducted to confirm the ability of the post-shutdown ERO to perform the necessary functions of each ERF. The drills will be used to train and qualify post-shutdown ERO members, evaluate and validate the ability to accomplish the stated mission of each ERF, and ensure that the planning standard functions are preserved with no degradation in time sensitive activities or in the ability to communicate with offsite response organizations. The drills will also validate that the post-shutdown ERO continues to address the risks to public health and safety and comply with the FCS RERP, site commitments, and applicable regulations. Implementing procedures will be revised to address the permanently shut down and defueled conditions. The revised procedures will be used to support training of ERO staff and conduct of drills.
Training and procedures will be developed and in place prior to performing post-shutdown ERO drills. The drill scenarios will include SFP events and be designed to test the major elements of the FCS post shutdown RERP. Major elements to be tested will include communications and coordination with offsite response organizations, including the JIC. State, local, and Federal response organizations will be provided the opportunity to participate in or observe the drills. New regulatory commitments for scenario elements and communication with offsite agencies are included in Attachment 6.
4.2.1.5 Impact on Off-Site Response Organizations Because of the geographic location of FCS, the planning and responsibilities at the State and local level involve coordination with the State of Nebraska, State of Iowa, Washington County (Nebraska), Harrison County (Iowa), and Pottawattamie County (Iowa). Section F of the FCS RERP describes the extensive communications network maintained between FCS, the States, and local agencies as a means of promptly notifying and maintaining communications with appropriate authorities. As illustrated in Section F, Figure F-2 of the FCS RERP, the coordination effort with offsite authorities is initiated by notifying the States of Nebraska and, State of Iowa, and Washington, Harrison, and Pottawattamie counties and providing each with information using a pre-arranged notification form that provides key information regarding an emergency. The proposed changes to the FCS RERP do not involve changes to this communications network, and as a result, do not impact the ability of FCS to promptly notify and initiate coordination with the offsite authorities.

LIC-16-0076 Page 24 Formal offsite REP plans, approved by FEMA in accordance with 44 CFR 350, are required to be maintained in effect until such time as the NRC approves an exemption to formal offsite emergency preparedness requirements. Because the changes proposed by FCS, specifically in regards to ERO staffing of the EOF and JIC, have the potential to adversely impact the effective implementation of the State and local REP plans, the proposed changes to the FCS RERP were evaluated for impacts on the ability of the State and local response organizations to effectively implement their FEMA-approved REP Plans. No specific change recommendations were identified; however, FCS will provide the offsite response organizations with the proposed post shutdown ERO positions so that they may revise their procedures as necessary. contains an analysis of all ERO positions being eliminated and evaluates the transfer of tasks to remaining ERO positions following permanent cessation of power operations. The discussion provided previously in this section addresses the potential impacts the proposed changes to the FCS RERP have on the EOF and the JIC and the potential impacts on the ability of the offsite response organizations to implement their FEMA-approved REP Plans.
Decommissioning-related emergency plan submittals for FCS have been discussed with offsite response organizations since OPPD provided notification that it would permanently cease power operations (Reference 1). These discussions have addressed future changes to onsite and offsite emergency preparedness throughout the decommissioning process.
As previously described, State, local, and Federal response organizations will be provided the opportunity to participate in or observe drills prior to implementation of the post-shutdown RERP.
New regulatory commitments for scenario elements and communication with offsite agencies are included in Attachment 6.
4.2.2    On-Shift Staffing To support reduced staffing following permanent cessation of power operations and permanent removal of fuel from the reactor vessel, the proposed post-shutdown on-shift staffing was evaluated in conjunction with the postulated accidents previously submitted to the NRC using methodology presented in NEI 10-05 (Attachment 4). The analysis of proposed post-shutdown on-shift staffing considered the FHA as the DBA. The analysis of proposed post-shutdown on-shift staffing concluded that in a permanently shut down and defueled condition the Shift Manager, one CRO/CFH, one Equipment Operator/NCO, and one Radiation Protection Technician can perform all required Emergency Plan actions in a timely manner and there are no collateral duties that would prevent the timely performance of emergency plan functions. The Fire Brigade complement considered in the analysis of proposed post-shutdown on-shift staffing was consistent with the requirements from the Fire Hazard Analysis.
For the analysis performed in October 2014, the following accident scenarios were evaluated:
Main Steam Line Break Accident This event results in radioactive material releases outside secondary containment and was due to a complete severance of a 16-inch line leading to the turbine bypass steam chest.
Steam Generator Tube Rupture (SGTR) Accident The steam generator tube rupture accident is a penetration of the barrier between the reactor coolant system and the main steam system.

LIC-16-0076 Page 25 Loss of Coolant Accident A loss-of-coolant accident (LOCA) is defined as a breach of the reactor coolant system boundary, which results in interruption of the normal mechanism for removing heat from the reactor core.
Fuel Handling and Fuel Loading Incidents (in Spent Fuel Pool and Containment)
A fuel handling accident is defined as dropping of a spent fuel assembly resulting in the rupture of the fuel cladding of a fuel assembly.
Gas Decay Tank Rupture The accident is defined as the uncontrolled or unanticipated release of the radioactive noble gases stored in a gas decay tank as a result of a failure of a tank or associated piping.
Design Basis Threat The event evaluated for this analysis assumes a land based threat that is neutralized immediately when inside the protected area fence, no significant damage to equipment or systems that require corrective actions before the ERO is staffed, no radiological release, and no fire that requires firefighting response before the ERO is staffed.
Aircraft Potential Threat (50.54(hh))
Notification is received from the NRC that a potential aircraft threat exists.
Fire requiring evacuation of the Control Room and plant shutdown from remote location A fire occurs in the main control room requiring the evacuation of the control room and procedures implemented to remotely shutdown the reactor.
Station Blackout A loss of all offsite AC power occurs and the failure of the emergency diesel generators to load. The SM determines power cannot be restored and declares a Site Area Emergency due to the loss of offsite power.
The following accident scenarios were included in the analysis of proposed post-shutdown on-shift staffing:
Design Basis Threat The event consists of notification to the Shift Manager from the Security Shift Supervisor that a hostile action is occurring at or inside the Protected Area. A hostile force will breach the Protected Area fence but is not sufficient to interrupt SFP cooling or cause a radiological release and is neutralized with no adverse consequences to plant safety.
Damage inflicted on plant systems, structures and components is not sufficient to cause a radiological release. There is no fire significant enough to warrant firefighting efforts prior to the arrival of offsite resources and/or the augmented ERO.

LIC-16-0076 Page 26 Fuel Handling Accident (FHA) with General Emergency and PAR One postulated DBA that will remain applicable to FCS in its permanently shut down and defueled condition is the FHA in the Auxiliary Building where the SFP is located. This event assumes a dose that exceeds the Environmental Protection Agencys (EPA) Protective Action Guides (PAGs) beyond the site boundary, and thus necessitates promulgation of a Protective Action Recommendation (PAR).
Aircraft Potential Threat (50.54(hh)(1))
This event includes emergency response actions in response to potential aircraft impacts in accordance with 10 CFR 50.54(hh)(1).
Event Requiring Control Room Evacuation and Maintain SFP Cooling An event occurs requiring the evacuation of the Control Room and actions implemented to control auxiliary cooling water pumps from a remote location.
The analysis of the proposed post-shutdown on-shift staffing indicates that the proposed on-shift personnel can satisfactorily implement all emergency plan functions as required by regulation without augmented ERO personnel for at least 60 minutes following an emergency declaration.
Currently, the Chemistry Technician is an on-shift position per FCS RERP Section B, Attachment 1, Table B-1 so that a technician is always available to immediately collect and analyze a liquid sample if the applicable radiation monitor is not available during a release, or as directed by the Shift Manager. When the on-shift Chemistry Technician position is eliminated, the on-shift Radiation Protection Technician will be able to perform sampling and analysis, if necessary, so as to not delay information potentially needed by the Shift Manager to determine if an emergency declaration is required. For gaseous releases, the only credible scenario for releasing gas would be to mechanically damage spent fuel during handling or by impact of a heavy object. Activities that could cause mechanical damage will require that a Chemistry Technician be on-site or the radiation monitor listed in gaseous effluent EALs to be in service, thereby alleviating any reliance on a potentially delayed sample analysis to determine EAL applicability. A new regulatory commitment to revise applicable fuel handling procedures to incorporate this prerequisite is included in Attachment 6.
A gap analysis will be performed to determine any differences between current Radiation Protection Technician training requirements and any new specific knowledge requirements associated with emergency plan sampling and analysis. Such specific knowledge requirements would include how to obtain specific liquid samples.
Once the specific training requirements for the Radiation Protection Technician position have been identified using a systematic approach to training, as required by 10 CFR 50.120, a formal gap analysis will be completed for all personnel identified to fill the Radiation Protection Technician position. Individualized training plans will be developed and completed to address specific knowledge and skill areas for each of the selected Radiation Protection Technician candidates.
The initial training for all incumbent Radiation Protection Technicians will include all training requirements to perform liquid sampling and analysis to support an emergency declaration.

LIC-16-0076 Page 27 The initial training requirements for any new Radiation Protection Technician will include all training modules to ensure they are equipped with the required skills and knowledge to perform the required liquid sampling and analysis. These training modules will be specifically identified in the training program description for the Radiation Protection Technician position. This document will be developed in accordance with the requirements of 10 CFR 50.120.
Based on the above, the proposed change in on-shift operations staffing and elimination of the on-shift Chemistry Technician are appropriate given the permanent cessation of power operations and permanent removal of fuel from the reactor vessel.
Because of the reduced number of possible events requiring mitigating actions in the permanently defueled condition and the limited number of actions to be performed by the Control Room positions in a permanently defueled condition, no Licensed Reactor Operators or STA job tasks were noted as being required for any of the events analyzed in the analysis of proposed post-shutdown on-shift staffing. Therefore, the Licensed Reactor Operators and STA positions can be eliminated without reducing the effectiveness of the post-shutdown FCS RERP.
The proposed on-shift staffing changes do not impact the capabilities of the on-shift staff to respond to an emergency and continue to comply with the FCS RERP, site commitments, and applicable regulations.
Additional analysis for each of the staffing changes associated with FCS RERP Section B, , Table B-1 is provided in the following section.
4.2.3   Major Functional Area: Plant Operations & Assessment of Operational Aspects Current Staffing Requirement During normal operations, the minimum staff on duty at the plant during all shifts to satisfy this Major Functional Area consists of:
1 Shift Manager (SRO) 1 Unit Supervisor (SRO) 1 STA 2 Reactor Operators 2 Equipment Operators 1 Control Room Communicator 1 Radiation Protection Technician 1 Chemistry Technician 1 Habitability Technician Proposed Change The proposed changes to the FCS RERP will eliminate the following on-shift positions:
2 Reactor Operators 1 Equipment Operator 1 Control Room Communicator 1 Chemistry Technician 1 Habitability Technician 1 STA

LIC-16-0076 Page 28 Credited on-shift personnel will consist of one Shift Manager (CFH), one CRO (CFH), and one Equipment Operator/NCO. Title changes for Licensed personnel and Equipment Operators to CFHs and NCOs, respectively, are dependent upon NRC approval of proposed changes to the FCS Technical Specifications that revise the minimum shift staffing requirements in the FCS Technical Specifications by replacing references to licensed and non-licensed operators with references to CFHs and NCOs. Implementation of the FCS RERP, as proposed for revision in this submittal, is not dependent on prior NRC approval of the proposed changes to the FCS Technical Specifications.
Analysis The regulatory standard for minimum staffing requirements for NRC licensees is documented in NUREG-0654. The total minimum on-shift staffing expressed in NUREG-0654, Table B-1, is ten personnel. Plant Operations shift staffing, as implemented previously, was based on an operating philosophy that provided defense in depth. The analysis of proposed post-shutdown on-shift staffing concluded that in a permanently shut down and defueled condition, the Shift Manager, CRO, and one Equipment Operator/NCO can perform all required FCS RERP actions in a timely manner and there are no collateral duties that would prevent the timely performance of emergency plan functions. Therefore, this deviation from the guidance presented in NUREG-0654, Table B-1 is acceptable.
4.2.4  Major Functional Area: Notification/Communication Major Tasks: Notify Licensee, State, Local, and Federal personnel and maintain communication.
Current Staffing Requirement The Control Room Communicator performs the function of on-shift notification/communication.
Proposed Change Replace the Control Room Communicator with the CRO/CFH (or NCO).
Analysis This function is currently performed by an on-shift staff position performing emergency plan Communicator requirements. This function is currently augmented by TSC and EOF designated communications positions when those facilities assume communications responsibilities.
Initial notification to offsite authorities are required to occur within 15 minutes of declaration of an emergency and initial NRC notification is required to occur immediately after notification of the appropriate State or Local agencies and not later than 60 minutes after the time of the emergency declaration, for non-security related events. Subsequent notifications are made should the event escalate and for informational updates. The resource commitment to support the communication function is not full time so there is time to support performance of collateral duties during the first 60 minutes until staff augmentation can occur. The on-shift and offsite communicators have advanced communications capabilities available such as the Conference Operations (COP) Network.

LIC-16-0076 Page 29 Communications with the NRC take place over dedicated telephone lines provided for and maintained by the NRC (Emergency Notification System (ENS)). For purposes of the analysis of proposed post-shutdown on-shift staffing, NRC notifications were treated as a continuous action in accordance with 10 CFR 50.72(c)(3), meaning that once the initial NRC communications are established, it was assumed that the NRC will request an open line to be continuously maintained with the NRC Operations Center. The use of dedicated phone circuits and headsets enables these notifications to be performed by the same on-shift communicator who performs the State and Local notifications.
The Shift Manager initially approves the content of the communication with the State and Federal agencies until relieved of this function by the EOF. The FCS RERP goal is to activate the EOF within approximately 60 minutes. The EOF assumes the communication responsibility concurrent with activation. Therefore, the current communication protocol may remain within the Control Room for the first 60 minutes, regardless of the presence of any prior ERO augmentation.
In the post-shutdown condition, the task of notifying and communicating with offsite authorities will be transferred to the CRO/CFH (or NCO). This change is acceptable because the analysis of proposed post-shutdown on-shift staffing concluded that in a permanently defueled condition, the designated on-shift staff can perform this required FCS RERP action in a timely manner and there are no collateral duties that would prevent the timely performance of this emergency plan function.
4.2.5  Major Functional Area: Radiological Accident Assessment and Support of Operational Accident Assessment Major Tasks: Offsite Dose Assessment; Onsite and In-plant surveys; Offsite surveys; Chemistry/Radiochemistry Current Staffing Requirement On-shift Radiation Protection Technician, Habitability Technician, and Chemistry Technician perform the in-plant radiation protective actions.
Augmentation of the on-shift Radiation Protection Technician capability by four Radiation Protection Technicians occurs within approximately 60 minutes.
Augmentation of the on-shift Chemistry Technician capability by one Chemistry Technician occurs within approximately 60 minutes.
Proposed Change Eliminate the on-shift Chemistry Technician position.
Eliminate the on-shift Habitability Technician position.
Analysis During a toxic gas event, tasks would be assigned to the Chemistry Technician in the first 60 minutes. These tasks will be reassigned to a trained and qualified on-shift Radiation Protection Technician with no conflicting duties. Therefore, the Chemistry Technician position does not need to be maintained on-shift.

LIC-16-0076 Page 30 The proposed change in on-shift staffing and elimination of the on-shift Habitability Technician are appropriate given the permanent cessation of power operations and permanent removal of fuel from the reactor vessel. The spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The set of plant equipment required in the permanently defueled condition is also greatly reduced, which reduces the assessment and mitigation activities in the Control Room. Habitability concerns in a permanently shut down and defueled condition do not require a dedicated on-shift position.
4.2.6   Major Functional Area: Plant Systems Engineering, Repair and Corrective Actions 4.2.6.1 Major Task: Technical Support (STA)
Current Staffing Requirement The on-shift STA performs the major task of Technical Support.
Proposed Change Eliminate the on-shift STA position.
Analysis The STA performs independent assessments of plant operating concerns, technical support, appropriate corrective actions, analysis of events and their effects, effectiveness of response(s) to emergent conditions, assistance in classifications of emergencies, protection of the public, and any other actions related to critical safety functions and plant safety during abnormal and emergency situations. The STA also supports operations during normal plant conditions. By routine monitoring of equipment and plant operations, the STA can focus on preventative actions in order to mitigate the consequences of an accident.
Because of the permanent cessation of power operations and removal of fuel from the reactor vessel, the STA position is no longer necessary for technical and analytical assistance. The spectrum of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The set of plant equipment required in the permanently defueled condition is also greatly reduced, which reduces the assessment and mitigation activities in the Control Room. The Technical Support function will be assumed by the remaining Control Room personnel.
The analysis of proposed post-shutdown on-shift staffing concluded that the Shift Manager and CRO/CFH (or NCO during events requiring Fire Brigade response) can perform any required technical analysis, until augmented by the TSC Engineering Coordinator and necessary engineering staff, in a timely manner and there are no collateral duties that would prevent the timely performance of this task.

LIC-16-0076 Page 31 4.2.7   Major Functional Area: Protective Actions (Plant)
The function of these additional resources is to provide radiation protection oversight of the on-shift complement of personnel and augmented personnel who are expected to respond to emergency events for damage repair, corrective actions, search and rescue, first aid, firefighting and personnel monitoring. They can also be expected to provide for access control and the issuance of dosimetry. Analysis of the proposed change for each of these tasks is discussed below. The fire brigade will continue to perform the tasks of search and rescue, first aid, and firefighting in the permanently shut down and defueled condition.
4.2.7.1 Major Tasks: Radiation Protection Access Control Originally, radiological access control was a labor intensive task. Dedicated Radiation Protection Technicians were required to check dose margins, training qualifications, and to ensure workers had read and understood their radiation work permit. Worker access control is now partially automated because many of the Radiation Protection work processes have been computerized. Radiation Work Permit (RWP) access control and electronic dosimeter computer systems work together to provide a fully integrated system allowing workers to sign-in on their RWP and to self-issue electronic dosimeters. During a declared emergency however, RWPs and dose setpoints will change depending on the emergency situation and plant conditions. Both systems have been used by plant workers for several years. Worker dose margins and training qualifications are also automatically verified when the RWP access control system is used. If a worker's dose margin is inadequate or training is expired, the workers access would be precluded and the access control system would not allow issuance of an electronic dosimeter. In an emergency situation, approval to exceed dose margins is required. During the log-in process, workers acknowledge their electronic dosimeter alarm setpoints and that they have read and understand their RWP. The electronic dosimeter provides the worker with a continuous status of dose received and work area dose rates, and will alarm at preset dose and dose rate alarms. Worker use of electronic dosimeters facilitates more efficient use of Radiation Protection Technicians to provide Radiation Protection coverage while preserving the ALARA concept. Access control is maintained because the worker must obtain an electronic dosimeter and enter a RWP number into the access control computer system prior to being allowed access into the Radiologically Controlled Area (RCA). No setup is required for the RWP access control computers, which allows Radiation Protection Technicians to be used for more critical tasks during emergency response. Personnel are required to self-monitor for radioactive contamination whenever they exit the RCA. No Radiation Protection involvement is necessary for this contamination monitoring activity because workers are trained to perform this task without supervision or oversight.
However, contaminated personnel exiting the RCA will require Radiation Protection oversight.
4.2.7.2     Major Task: RP Coverage and Personnel Monitoring Radiation Protection (RP) coverage will only be performed if the radiological status of a room is unknown and there is a definitive need for emergency workers to enter the room to perform a task. The decision to provide RP coverage may be based on plant radiological conditions as indicated by installed area radiation monitors (ARMs) or event mitigation requirements.

LIC-16-0076 Page 32 During the initial stages of an accident, not all areas of the plant would be affected by releases of radioactive materials. Therefore, RP coverage would not be required for all areas. Because entry is expected to be limited to those areas where maintenance necessary to maintain SFP cooling is required and the areas potentially affected by an accident involving the SFP are limited, there is a significant decrease in areas potentially requiring RP coverage in a permanently shut down and defueled condition. If RP coverage is deemed necessary, multiple emergency teams can be covered by the on-shift Radiation Protection Technician. If RP coverage is not provided (for entry into areas with low radiological risk or known radiological status), worker protection is ensured because emergency workers are required to wear electronic dosimeters (which will alarm at preset dose and dose rate setpoints) and because of the installed ARMs (which alarm locally and remotely at preset dose rates) located throughout the plant.
4.2.7.3 Major Task: Dosimetry Originally, dosimetry issuance was a manual process requiring Radiation Protection Technicians to zero and issue dosimeters, verify worker training, and verify and track radiation dose margins. As addressed in the Access Control/Personnel Monitoring Sections above, access control computers are now used for issue of electronic dosimetry with alarming capability. Battery-powered electronic dosimeters are available as a backup.
Worker self-issuance of electronic dosimeters has eliminated the need for Radiation Protection Technicians to physically issue dosimetry, with the exception of any tasks that require specialized dosimetry and/or special body placement of the dosimetry. These types of tasks are not expected in the initial stages of an event, but during the recovery phase.
Prior to self-issuance of dosimetry, workers are assigned a RWP, setpoints are adjusted, and, when required, briefings are conducted by Radiation Protection.
The analysis of proposed post-shutdown on-shift staffing determined there are no time critical Radiation Protection or chemistry tasks, and that task performance is directed and prioritized by the Shift Manager for the 60-minute time frame used in the analysis. There are no overlapping Radiation Protection or chemistry tasks. Radiation Protection tasks were able to be performed without augmented personnel in the 60-minute time frame used in the analysis.
4.2.8   Major Functional Areas: Fire Fighting/Rescue Operations and First Aid 4.2.8.1 Major Task: Combat Fires Current Staffing Requirement The FCS Fire Brigade complement is one (1) Fire Brigade Leader or advisor with commensurate Licensed Operator knowledge, two (2) Fire Brigade trained Equipment Operators-Nuclear Auxiliary (EONA) non-license training with commensurate knowledge and two (2) other Fire Brigade qualified on-shift personnel. If use of a Fire Brigade Advisor (commensurate Licensed Operator knowledge) is chosen, the Fire Brigade Leader will be qualified the equivalent of EONA.

LIC-16-0076 Page 33 All Fire Brigade training and qualification requirements will be maintained utilizing the Fire Hazards Analysis requirements. The Fire Brigade will continue to perform the tasks of search and rescue in the permanently defueled condition. The Fire Brigade will be available to promptly implement SFP inventory makeup strategies required under 10 CFR 50.54(hh)(2) without impacting the performance of designated emergency plan functions.
The analysis of proposed post-shutdown on-shift staffing concluded that during an event requiring a Control Room evacuation in a permanently defueled condition, the Shift Manager and CRO (or NCO) can perform all required FCS RERP actions in a timely manner. There are no collateral duties that would prevent the timely performance of emergency plan functions.
4.3      Conclusion OPPD completed an evaluation of the proposed reduction in on-shift and ERO staffing and completed an analysis of proposed post-shutdown on-shift staffing to analyze the ability of the proposed defueled on-shift and ERO organization to respond to an emergency.
The analysis of proposed post-shutdown on-shift staffing was conducted assuming an on-shift complement of one Shift Manager, one CRO/CFH, one Equipment Operator/NCO, and one Radiation Protection Technician. The results of the analysis indicate that the proposed on-shift personnel can satisfactorily implement all regulatory required emergency plan functions without augmented ERO personnel for at least 60 minutes following an emergency declaration. During a toxic gas event, tasks would be assigned to the Chemistry Technician in the first 60 minutes.
These tasks will be reassigned to a trained and qualified on-shift Radiation Protection Technician with no conflicting duties. Compensatory measures will be implemented to ensure that the ability to assess and declare an emergency during fuel handling activities is maintained. Based on the above, the proposed change in on-shift operations staffing and elimination of the on-shift Chemistry Technician are appropriate for the permanently defueled condition.
Specific training requirements for the Radiation Protection Technician and NCO positions will be identified using a systematic approach to training, as required by 10 CFR 50.120, and formal gap analyses will be completed for all personnel identified to fill these positions. Individualized training plans will be developed and completed to address specific knowledge and skills areas for each of the selected candidates.
The proposed ERO staffing changes do not impact the capabilities of the on-shift staffing or augmented response. The ERFs will continue to be activated within approximately 60 minutes of an Alert or higher declaration. The remaining post-shutdown functional responsibilities of the positions eliminated as a result of the changes described within are being reassigned to remaining positions. The proposed ERO staffing reductions continue to address the risks to public health and safety and comply with the FCS RERP, site commitments, and applicable regulations.
The risk of a major event resulting in radioactive materials being released to the environment is significantly reduced in the permanently defueled condition. All required radiation protection functions are accommodated within the requisite time frames using the proposed on-shift resources. Any anticipated tasks can be handled by the proposed on-shift resources detailed in the post-shutdown on-shift staffing analysis.

LIC-16-0076 Page 34

==5.0     REGULATORY EVALUATION==

5.1     Applicable Regulatory Requirements/Criteria On-Shift and ERO Staffing The specific standards for establishing an onsite emergency organization to respond to emergency events appears in 10 CFR 50.47(b) and 10 CFR 50, Appendix E, Section IV.A. Specifically:
* 10 CFR 50.47(b)(1): Primary responsibilities for emergency response by the nuclear facility licensee and by State and local organizations within the Emergency Planning Zones 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.
* 10 CFR 50.47(b)(2): On-shift facility licensee responsibilities for emergency response are unambiguously defined, adequate staffing to provide initial facility accident response in key functional areas is maintained at all times, timely augmentation of response capabilities is available and the interfaces among various onsite response activities and offsite support and response activities are specified.
* 10 CFR 50, Appendix E Section IV.A.1: [E-Plans must contain] A description of the normal plant operating organization.
* 10 CFR 50, Appendix E Section IV.A.2: [E-Plans must contain] A description of the onsite emergency response organization with a detailed discussion of:
o      Authorities, responsibilities, and duties of the individual(s) who will take charge during an emergency; o      Plant staff emergency assignments; o      Authorities, responsibilities, and duties on an onsite emergency coordinator who shall be in charge of the exchange of information with offsite authorities responsible for coordinating and implementing offsite emergency measures; NUREG-0654 (Reference 2), Section II.B, Onsite Emergency Organization, presents guidance for meeting these requirements. The guidance describes the onsite emergency organization, including the staffing requirements found in Table B-1, Minimum Staffing Requirements for NRC Licensees for Nuclear Power Plant Emergencies.
10 CFR Part 50, Appendix E, Section IV.A.9 states that licensees shall perform a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan.
NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants (Reference 4) provides information relevant to performing the on-shift staffing analysis. The ISG states that NEI 10-05, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities, is an acceptable methodology for performing the staffing analysis. The ISG also indicates that the completed staffing analyses are required to be part of the emergency plan and the results documented and submitted to the NRC in accordance with 10 CFR 50.54(q)(5).

LIC-16-0076 Page 35 NRC Regulatory Guide 1.101, (Reference 8), Section C, states in part "The criteria and recommendations in Revision 1 of NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants (November 1980), are methods acceptable to the NRC staff for complying with the standards in 10 CFR 50.47 that must be met in onsite and offsite emergency response plans.
These criteria provide a basis for NRC licensees and State and local governments to develop acceptable radiological emergency plans and improve emergency preparedness."
Regulatory Guide 1.219, Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors, July 2016 (Reference 9), describes a method that the NRC considers to be acceptable to implement the requirements in 10 CFR 50.54(q). In Section 2.a., the NRC encourages licensees to arrange a conference call with the NRC staff to clarify 10 CFR 50.54(q) requirements and guidance within this regulatory guide for EP changes that increase the activation time of emergency response facilities.
Regulatory Issue Summary 2005-02, "Clarifying the Process for Making Emergency Plan Changes," Revision 1 (Reference 10) was issued by the NRC to clarify the meaning of "decrease in effectiveness" and the process for making changes to emergency plans, and to provide some examples of changes that are considered to be a decrease in effectiveness.
5.2       Precedent The requested changes to the on-shift staffing and ERO staffing are consistent with the post-shutdown changes approved by the NRC and implemented by Vermont Yankee Nuclear Power Station (Reference 11).
5.3       No Significant Hazards Consideration Pursuant to 10 CFR 50.92, OPPD has reviewed the proposed changes and concludes that the changes do not involve a significant hazards consideration because the proposed changes satisfy the criteria in 10 CFR 50.92(c). These criteria require that operation of the facility in accordance with the proposed amendment would not (1) involve a significant increase in the probability or consequences of an accident previously evaluated; (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.
The proposed changes would revise the FCS RERP to reduce the number of on-shift and ERO positions commensurate with the hazards associated with a permanently shut down and defueled facility.

LIC-16-0076 Page 36 The discussion below addresses each of these criteria and demonstrates that the proposed amendment does not constitute a significant hazard.
: 1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed changes to the FCS RERP do not impact the function of plant structures, systems, or components (SSCs). The proposed changes do not affect accident initiators or precursors, nor does it alter design assumptions. The proposed changes do not prevent the ability of the on-shift staff and ERO to perform their intended functions to mitigate the consequences of any accident or event that will be credible in the permanently defueled condition. The proposed changes only remove positions that will no longer be credited in the FCS RERP.
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 number of on-shift and ERO positions commensurate with the hazards associated with a permanently shut down and defueled facility. The proposed changes do not involve installation of new equipment or modification of existing equipment, so that no new equipment failure modes are introduced. Also, the proposed changes do not result in a change to the way that the equipment or facility is operated so that no new accident initiators are 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 FCS RERP staffing and do not impact operation of the plant or its response to transients or accidents. The change does not affect the Technical Specifications. The proposed changes do not involve a change in the method of plant operation, and no accident analyses will be affected by the proposed changes. Safety analysis acceptance criteria are not affected by the proposed changes. The revised FCS RRP will continue to provide the necessary response staff with the proposed changes.
Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.

LIC-16-0076 Page 37 5.4       Conclusion Based on the above, OPPD concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

==6.0       ENVIRONMENTAL CONSIDERATION==

This amendment request meets the eligibility criteria for categorical exclusion from environmental review set forth in 10 CFR 51.22(c)(9) as follows:
(i) The amendment involves no significant hazards consideration.
As described in Section 5.3 of this evaluation, the proposed changes involve no significant hazards consideration.
(ii) There is no significant change in the types or significant increase in the amounts of any effluent that may be released offsite.
The proposed changes do not involve any physical alterations to the plant configuration or any changes to the operation of the facility that could lead to a change in the type or amount of effluent release offsite.
(iii) There is no significant increase in individual or cumulative occupational radiation exposure.
The proposed changes do not involve any physical alterations to the plant configuration or any changes to the operation of the facility that could lead to a significant increase in individual or cumulative occupational radiation exposure.
Based on the above, OPPD concludes that the proposed change meets the eligibility criteria for categorical exclusion as set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.

==7.0       REFERENCES==
: 1. Letter, OPPD to USNRC, Certification of Permanent Cessation of Power Operations, dated June 24, 2016 (LIC-16-0043)(ML16176A213)
: 2. NUREG-0654, FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Revision 1, published November 1980.
: 3. Federal Register Volume 76, Number 226, Wednesday, November 23, 2011, Rules and Regulations, Enhancements to Emergency Preparedness Regulations; Final Rule.
: 4. NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants, Revision 0, November 2011 (ML113010523)
: 5. NEI 10-05, Rev. 0, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities.

LIC-16-0076 Page 38
: 6. Letter, OPPD to USNRC Request for Approval of a Certified Fuel Handler Training Program, dated July 7, 2016 (LIC-16-0049) (ML16190A208)
: 7. EP-FC-1001, Addendum 1, Fort Calhoun Station On-Shift Staffing Technical Basis, Revision 0, dated October 2014.
: 8. NRC Regulatory Guide 1.101, Emergency Response Planning and Preparedness for Nuclear Power Reactors, Revision 4, July 2003
: 9. Regulatory Guide 1.219, Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors, Revision 1, July 2016
: 10. Regulatory Issue Summary 2005-02, "Clarifying the Process for Making Emergency Plan Changes," Revision 1, April 19, 2011
: 11. Letter, USNRC to Entergy Nuclear Operations, Inc., Vermont Yankee Nuclear Power Station - Issuance of Amendment to Renewed Facility Operating License Re: Changes to the Emergency Plan (TAC No. MF3668), dated February 4, 2015 (ML14346A065)

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION DOCKET NUMBER 50-285 / LICENSE NUMBER DPR-40 ATTACHMENT 2 TABULAR 

==SUMMARY==
OF PROPOSED CHANGES TO THE FCS RERP

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                 Before (Rev. 1)                                                                Reason for Change Number)
Cover page                       OPPD Nuclear Radiological                 OPPD Nuclear Post Shutdown              Reflect the changes for Post Emergency Response Plan for Fort          Radiological Emergency Response         Shutdown Calhoun Station                           Plan for Fort Calhoun Station Header                           Revision 0                                Revision TBD                            Changed throughout to reflect the need for a new RERP revision number.
PURPOSE OF THE EMERGENCY PLAN    The purpose of the Fort Calhoun           The purpose of the Fort Calhoun         Title changed to reflect post Station "Radiological Emergency           Station "PostShutdown Radiological     shutdown condition.
1st Sentence Response Plan" RERP)                      Emergency Response Plan" (PSRERP)
Change made to header and all references to the RERP throughout EPFC1001.
PURPOSE OF THE EMERGENCY PLAN    The Emergency Plan Implementing           The Emergency Plan Implementing         FCS will no longer be an operating Procedures (EPIP's), Radiation            Procedures (EPIPs), Radiation           nuclear power plant. The PURPOSE Sentences 25 Protection procedures, Emergency          Protection procedures, and other        OF THE EMERGENCY PLAN has been Operating procedures and other            station references are available at     revised to indicate the permanently station references are available at       the plant to further assist personnel   shut down and defueled condition.
the plant to further assist personnel     during abnormal occurrences. The for operating during abnormal             various emergency procedures are occurrences. The various emergency        put into effect whenever a system, procedures are put into effect            component or circuit failure could whenever a system, component or           lead to a personnel hazard or major circuit failure could lead to a           equipment failure. Procedures are personnel hazard or major                 sufficiently detailed so that the plant equipment failure. Emergency              is maintained in a safe condition.
Operating Procedures are                  The various procedures include such sufficiently detailed so that the plant   items as radiation hazards, weather is placed, as expeditiously as            conditions and availability of possible, in a safe condition. The        technical and plant personnel.
various procedures include such items as radiation hazards, weather conditions and availability of technical and operating personnel.
1

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                 Before (Rev. 1)                                                             Reason for Change Number) 5.0, (ACCIDENT CONSIDERATIONS)   The offsite consequences of a steam      Deleted                              FCS will no longer be an operating MAJOR STEAM RELEASE              line rupture incident has been                                                nuclear power plant. A major steam evaluated and is documented in the                                            release will no longer be applicable Fort Calhoun Station, Unit NO. 1                                              to FCS.
USAR. The maximum size steam line Renumbered subsequent sections.
rupture is a circumferential double ended rupture of the 36inch main steam header. The analysis of this incident at the site boundary is calculated to be 0.9 Rem TEDE.
Plant personnel would be protected by normal health physics practices and procedures. Operator action follows the emergency procedures addressing a Steam Line Rupture with Loss of Offsite Power.
7.0, (ACCIDENT CONSIDERATIONS)   A natural disaster may occur which       A natural disaster may occur which   FCS will no longer be an operating NATURAL DISASTERS                could initiate any of the accidents      could initiate any of the accidents  nuclear power plant. References to previously discussed. The reactor        previously discussed. The Spent Fuel shutting down the reactor as a result may be placed in a shutdown              Pool and ISFSI are designed to       of a natural disaster will no longer be condition, depending upon the            withstand natural phenomena,         applicable to FCS.
anticipated or experienced severity      including the maximum hypothetical of the disaster. The ISFSI is designed   earthquake, design basis tornado to withstand natural phenomena,          and tornadodriven missiles, with no including the maximum hypothetical       release of radioactivity.
earthquake, design basis tornado and tornadodriven missiles, with no release of radioactivity.
2

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                 Before (Rev. 1)                                                       Reason for Change Number)
Section A, 2.3, 2nd sentence     The Shift Manager may be relieved   Deleted                             The Control Room Coordinator of the task of implementing the                                         position will not exist in the post RERP by the Control Room                                                shutdown ERO. The Shift Manager Coordinator.                                                            will implement the RERP in the Control Room.
The retention of the task of implementing the RERP by the Shift Manager has been evaluated in the FCS analysis of proposed post shutdown onshift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.
Section B, 4.1.1, 1st bullet      One Shift Manager (Senior
* One Shift Manager (Senior Reactor The title change from Senior Reactor Reactor Operator)               Operator (SRO)/Certified Fuel       Operator to Certified Fuel Handler Handler (CFH))                      (CFH) is dependent upon NRC approval of proposed changes to Technical Specifications.
Implementation of the Emergency Plan as revised in this LAR is not dependent on prior NRC approval of the proposed changes to the FCS Technical Specifications.
3

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section               Before (Rev. 1)                                                   Reason for Change Number)
Section B, 4.1.1, 2nd bullet      One Unit Supervisor (Senior
* One Control Room Operator       The title Unit Supervisor title is Reactor Operator)             (Senior Reactor Operator (SRO) or changed to Control Room Reactor Operator (RO)/CFH)        Operator here, and throughout the Post Shutdown Emergency Plan for consistency.
Elimination of the title, Senior Reactor Operator, is dependent upon NRC approval of proposed changes to Technical Specifications.
Implementation of the Emergency Plan as revised in this LAR is not dependent on prior NRC approval of the proposed changes to the FCS Technical Specifications.
4

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section              Before (Rev. 1)                                        Reason for Change Number)
Section B, 4.1.1, 3rd bullet      Two Reactor Operators   Deleted                     The Reactor Operator position will not exist in the postshutdown on shift staff.
After permanent cessation of power operations and a certification of permanent removal of fuel from the reactor vessel, in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2), the 10 CFR 50 license will no longer authorize reactor operation or emplacement or retention of fuel in the reactor vessel. As a result, licensed reactor operators will no longer be required to support plant operating activities.
The proposed elimination of the Reactor Operator positions has been evaluated in the FCS analysis of proposed postshutdown onshift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.
5

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section              Before (Rev. 1)                                                  Reason for Change Number)
Section B, 4.1.1, 4th bullet      Two Equipment Operators          One Equipment Operator/Non The proposed staffing of one NCO Certified Operator (NCO)   has been evaluated in the FCS analysis of proposed postshutdown onshift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.
The title change from Equipment Operators to NCOs is dependent upon NRC approval of proposed changes to Technical Specifications.
Implementation of the Emergency Plan as revised in this LAR is not dependent on prior NRC approval of the proposed changes to the FCS Technical Specifications.
Section B, 4.1.1, 5th bullet      One Control Room Communicator   Deleted                       The Control Room Communicator position will not exist in the post shutdown onshift staff. The Control Room Operator will assume these responsibilities as directed by the Shift Manager.
The proposed elimination of the Control Room Communicator position has been evaluated in the FCS analysis of proposed post shutdown onshift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.
6

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section              Before (Rev. 1)                                              Reason for Change Number)
Section B, 4.1.1, 6th bullet      One Chemistry Technician      Deleted                     The Chemistry Technician position will not exist in the postshutdown onshift staff. The shift RP Technician will perform any needed chemistry analysis.
The proposed elimination of the Chemistry Technician position has been evaluated in the FCS analysis of proposed postshutdown onshift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.
Section B, 4.1.1, 8th bullet      One Habitability Technician   Deleted                     The Habitability Technician position will not exist in the postshutdown onshift staff. The postshutdown onshift staff will perform habitability tasks, as necessary.
The proposed elimination of the Habitability Technician position has been evaluated in the FCS analysis of proposed postshutdown onshift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.
7

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section               Before (Rev. 1)                                             Reason for Change Number)
Section B, 4.1.1, 9th bullet      One Shift Technical Advisor   Deleted                     The Shift Technical Advisor position will not exist in the postshutdown onshift staff. The Control Room Operator will perform any necessary tasks previously assigned to the Shift Technical Advisor.
The proposed elimination of the Shift Technical Advisor position has been evaluated in the FCS analysis of proposed postshutdown onshift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.
Section B, 4.3.3, 2nd bullet      One Radiation Protection       One Radiation Protection  The Radiation Protection Technician or Radiation          Technician               Coordinator position will not exist in Protection Coordinator                                    the postshutdown ERO. The OSC Director, RP Technicians, and the TSC Protective Measures Coordinator will perform the functions as needed. The proposed elimination of the Radiation Protection Coordinator position has been evaluated in the FCS analysis of proposed postshutdown ERO staffing. Duties and responsibilities will be transferred to remaining ERO positions.
8

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section              Before (Rev. 1)                                                    Reason for Change Number)
Section B, 4.3.4, 2nd bullet      One TSC COP Communicator         Deleted                        The TSC COP Communicator position will not exist in the postshutdown ERO. The EOF COP Communicator and the TSC Ops Liaison will perform the functions as needed. The proposed elimination of the TSC COP Communicator position has been evaluated in the FCS analysis of proposed postshutdown ERO staffing. Duties and responsibilities will be transferred to remaining ERO positions.
Section B, 4.3.4, 4th bullet      One Reactor Safety Coordinator     One Engineering Coordinator Position title change.
After permanent cessation of power operations and a certification of permanent removal of fuel from the reactor vessel, in accordance with 10 CFR 50.82(a)(1)(i) and (ii), and pursuant to 10 CFR 50.82(a)(2), the 10 CFR 50 license will no longer authorize reactor operation or emplacement or retention of fuel in the reactor vessel. As a result, the title, Reactor Safety Coordinator, is not descriptive of the functions performed by the position.
9

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section               Before (Rev. 1)                                                  Reason for Change Number)
Section B, 4.3.5, 3rd bullet      One EOF Protective Measures
* One EOF Protective Measures  The EOF Dose Assessment Manager or EOF Dose             Manager                        Coordinator position will not exist in Assessment Coordinator                                         the postshutdown ERO. The EOF Protective Measures Manager and the EOF Dose Assessment Specialist will perform dose assessment as needed. The proposed elimination of the EOF Dose Assessment Coordinator position has been evaluated in the FCS analysis of proposed postshutdown ERO staffing. Duties and responsibilities will be transferred to remaining ERO positions.
Section B, 4.4.1, 2nd bullet
* The Control Room Coordinator    Deleted                        The Control Room Coordinator position will not exist in the post shutdown ERO, as previously described.
Section B, 4.4.2                 N/A                               Add:                           This task is currently performed by the Control Room Coordinator. The D. Ensure Control Room Control Room Coordinator position communications are established will not exist in the postshutdown with the TSC, OSC, and EOF.
ERO, as previously described. The Shift Manager will assume these responsibilities. The retention of the task of implementing the PSRERP by the Shift Manager has been evaluated in the FCS analysis of proposed postshutdown onshift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.
10

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                  Before (Rev. 1)                                                   Reason for Change Number)
Section B, 4.4.3                 The Control Room Coordinator              Deleted                     The Control Room Coordinator position is intended to provide a                                     position will not exist in the post prompt transition of Command and                                      shutdown ERO, as previously Control functions from the Shift                                      described. The Shift Manager will Manager within the Control Room                                       assume these responsibilities. The complex. This position may assume                                     retention of the task of Command and Control at any                                            implementing the PSRERP by the emergency classification, and is not                                  Shift Manager has been evaluated in dependent on the reporting or                                         the FCS analysis of proposed post activation of any other portion of the                                shutdown onshift staffing in ERO.                                                                  conjunction with the postulated accidents that will be applicable in A. The Control Room Coordinator the permanently defueled condition.
duties are to promptly relieve the Shift Manager and perform as                                          Renumbered subsequent steps.
Emergency Director until properly relieved by a qualified position.
Additional duties of the Control Room Coordinator are to:
: 1. Ensure a qualified Control Room Operations Liaison establishes communications with the TSC, OSC and EOF to provide operational information.
: 2. Coordinate in plant operations response with the TSC and OSC.
: 3. Assist the Shift Manager and on shift operators with plant operations.
11

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                 Before (Rev. 1)                                                            Reason for Change Number)
Section B, 4.5.1.B               Unit Supervisor duties include          Control Room Operator duties         FCS will no longer be an operating assessment of plant conditions,         include:                             nuclear power plant.
ensuring requirements of the AOPs Assessment of plant conditions,    The title Unit Supervisor is and EOPs are met and supervision of Ensuring requirements of the AOPs  changed to Control Room onshift operations staff.
are met, and                       Operator here, and throughout the Notifications as directed by the   Post Shutdown Emergency Plan for Shift Manager. These notifications consistency.
include the following:
The Control Room Operator will o    Required notifications to the assume notification responsibilities states and counties previously belonging to the Control o    Notifications to the Room Communicator, as directed by Emergency Response the Shift Manager.
Organization The proposed elimination of the Control Room Communicator position has been evaluated in the FCS analysis of proposed post shutdown onshift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.
Section B, 4.5.1.C               Reactor Operators (2) duties include    Deleted                              The Reactor Operator position will implementation of the AOPs and                                               not exist in the postshutdown on EOPs under the direction of the Unit                                         shift staff, as previously described.
Supervisor.
Relettered subsequent steps.
12

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                 Before (Rev. 1)                                                              Reason for Change Number)
Section B, 4.5.1.D               Control Room Communicator duties          Deleted                              The Control Room Communicator include notifications as directed by                                           position will not exist in the post the Control Room Command and                                                   shutdown onshift staff, as Control position. These notifications                                          previously described. The Control include the following:                                                         Room Operator will assume these responsibilities as directed by the
* Required notifications to the states Shift Manager.
and counties Relettered subsequent steps.
* Notifications to the Emergency Response Organization Section B, 4.5.1.E               Equipment Operators (2) duties            Equipment Operator/NCO duties        The proposed staffing of one NCO include making repairs and                include making repairs and           has been evaluated in the FCS corrective actions on plant               corrective actions on plant          analysis of proposed postshutdown equipment until augmented plant           equipment until augmented plant      onshift staffing in conjunction with maintenance staff arrives.                maintenance staff arrives. NCOs also the postulated accidents that will be assist in performing                 applicable in the permanently notifications/communications and     defueled condition.
dose assessment as needed.
The title change from Equipment Operators to NCOs is dependent upon NRC approval of proposed changes to Technical Specifications.
Implementation of the Emergency Plan as revised in this LAR is not dependent on prior NRC approval of the proposed changes to the FCS Technical Specifications.
Section B, 4.5.1.F               Shift Technical Advisor duties include    Deleted                              The Shift Technical Advisor position providing technical support for plant                                          will not exist in the postshutdown systems, engineering, providing                                                onshift staff, as previously input on repair and corrective                                                 described.
actions and making initial Relettered subsequent steps.
notifications to the NRC.
13

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                  Before (Rev. 1)                                                   Reason for Change Number)
Section B, 4.5.1.G               Shift Chemistry Technician duties        Deleted                     The Chemistry Technician position include chemistry and                                                will not exist in the postshutdown radiochemistry analysis, radiological                                onshift staff, as previously accident assessment and support                                      described. The shift RP Technician and offsite dose assessment.                                         will perform any needed chemistry analysis.
The proposed elimination of the Chemistry Technician position has been evaluated in the FCS analysis of proposed postshutdown onshift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.
Relettered subsequent steps.
Section B, 4.5.1.I               Habitability Technician duties           Deleted                     The Habitability Technician position include conducting surveys and                                       will not exist in the postshutdown verifying Control Room habitability                                  onshift staff, as previously using available equipment and                                        described.
initiating protective actions if Relettered subsequent steps.
needed.
14

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                  Before (Rev. 1)                                                               Reason for Change Number)
Section B, 4.5.2                 Control Room (CR) augmenting              The Control Room (CR) Operations      With the exception of the Control positions are:                            Liaison is an augmenting position. Room Operations Liaison position, Duties include transmitting plant     the Control Room augmenting A. Coordinator duties are described status/Control Room information,      positions will not exist in the post in Section 3.2 and 4.4.3.
etc. to the TSC, OSC, and EOF.        shutdown ERO. The spectrum of B. Operations Liaison duties credible accidents and operational include transmitting plant events, and the quantity and status/Control Room complexity of activities required for information, etc. to the TSC, EOF the safe storage of spent nuclear and OSC Operations Liaison fuel is reduced as compared to an positions.
operating plant. The set of plant C. ENS Communicator duties equipment required in the include maintaining an ENS link permanently defueled condition is with the NRC.
also greatly reduced, which reduces D. Equipment Operator duties the assessment and mitigation include providing operations activities in the Control Room.
support to repair teams.
Section B, 4.6.1.A               Site Director duties are described in     Site Director duties are described in Editorial revision to reflect the Steps 3.2 and 4.4.4                       Steps 3.2 and 4.4.3                   revised numbering scheme resulting from changes to the Emergency Plan described within this table.
15

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                 Before (Rev. 1)                                                                Reason for Change Number)
Section B, 4.6.1.B               Reactor Safety Coordinator duties         Engineering Coordinator duties         Position title change, as previously include:                                  include:                               described. The Engineering Coordinator is tasked with
: 1. Directing the activities of the        1. Directing activities of engineering performing an engineering engineering staff in the TSC.             resources requested by the TSC.
assessment of plant conditions
: 2. Directing the analysis of plant        2. Analyzing plant problems and        and/or actions needed to mitigate problems and providing                    providing recommendations for          damage to the plant.
recommendations for plant                 plant modifications to mitigate the The FCS Post Shutdown Emergency modifications to mitigate the effects     effects of the accident.
Plan Implementing Procedures will of the accident.
: 3. Evaluating possible radiological    continue to identify engineering
: 3. Directing core damage assessment       release paths to the environment.      resources as augmented positions calculations.                                                                    with specific training and qualification requirements for
: 4. Directing the evaluation of assigned personnel in accordance possible radiological release paths to with the site training program. The the environment.
required training courses and requalification frequencies will be unchanged in the postshutdown condition. However, these positions will no longer be identified as oncall positions.
Core damage assessment will no longer be needed in the permanently shut down and defueled condition.
16

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                 Before (Rev. 1)                                                    Reason for Change Number)
Section B, 4.6.1.D               COP Communicator duties include          Deleted                     The TSC COP Communicator position performing notifications as directed                                 will not exist in the postshutdown by the Command and Control                                           ERO, as previously described.
position. These notifications include the following:
* Required notifications to states and counties
* Required notifications to the NRC
* Notifications to the Emergency Response Organization. This position also assists in maintaining status boards within the TSC 17

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                  Before (Rev. 1)                                                  Reason for Change Number)
Section B, 4.6.2.B               I&C Electrical Systems Engineer         Deleted                     The oncall I&C Electrical Systems duties include providing engineering                                Engineer position will not exist in the analysis and troubleshooting in that                                postshutdown ERO. The Engineering field of expertise.                                                 Coordinator (position title change) in the TSC will assume this function as needed.
The proposed elimination of the I&C Electrical Systems Engineer position has been evaluated in the FCS analysis of proposed postshutdown ERO staffing. The FCS Emergency Post Shutdown Plan Implementing Procedures will continue to identify engineering resources as augmented positions with specific training and qualification requirements for assigned personnel in accordance with the site training program. The required training courses and requalification frequencies will be unchanged in the postshutdown condition. However, these positions will no longer be identified as oncall positions.
Relettered subsequent steps.
18

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                  Before (Rev. 1)                                                  Reason for Change Number)
Section B, 4.6.2.D               Primary Systems Engineer duties         Deleted                     The oncall Primary Systems include providing engineering                                       Engineer position will not exist in the analysis and troubleshooting in that                                postshutdown ERO. The Engineering field of expertise.                                                 Coordinator (position title change) in the TSC will assume this function as needed.
The proposed elimination of the Primary Systems Engineer position has been evaluated in the FCS analysis of proposed postshutdown ERO staffing. The FCS Post Shutdown Emergency Plan Implementing Procedures will continue to identify engineering resources as augmented positions with specific training and qualification requirements for assigned personnel in accordance with the site training program. The required training courses and requalification frequencies will be unchanged in the postshutdown condition. However, these positions will no longer be identified as oncall positions.
19

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                  Before (Rev. 1)                                                               Reason for Change Number)
Section B, 4.7.2.A               Chemistry Technician duties include      Chemistry Technician duties include     The Chemistry Coordinator position evaluating and performing all            evaluating and performing all           will not exist in the postshutdown chemistry activities on site. Act as     chemistry activities on site.           ERO. The OSC Director and the TSC Chemistry Coordinator until relieved.                                            Protective Measures Coordinator will perform the functions as needed. The proposed elimination of the Chemistry Coordinator position has been evaluated in the FCS analysis of proposed postshutdown ERO staffing. Duties and responsibilities will be transferred to remaining ERO positions.
Section B, 4.7.2.B               Dosimetry Technician duties include      Deleted                                 The Dosimetry Technician position issuing Dosimetry and performing                                                 will not exist in the postshutdown dose extensions as needed.                                                       ERO. The TSC Protective Measures Coordinator will perform the functions as needed. The proposed elimination of the Dosimetry Technician position has been evaluated in the FCS analysis of proposed postshutdown ERO staffing. Duties and responsibilities will be transferred to remaining ERO positions.
Relettered subsequent steps.
Section B, 4.7.2.C               Electrical Maintenance Technicians       Electrical Maintenance Technician       The oncall technician positions will (two positions) duties include           duties include providing repairs and    not exist in the postshutdown ERO.
providing repairs and corrective         corrective actions for plant electrical Technicians will be called in on an as actions for plant electrical             equipment as directed.                  needed basis.
equipment as directed.
20

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                 Before (Rev. 1)                                                               Reason for Change Number)
Section B, 4.7.2, F              Operations Liaison duties include        Deleted                               The OSC Operations Liaison position obtaining plant status/Control Room                                            will not exist in the postshutdown information from the Control Room                                              ERO, as previously described. The Operations Liaison and transmitting                                            TSC Ops Liaison will perform the this information to the OSC staff as                                           functions as needed.
needed. [AR 11390]
The proposed elimination of the Operations Liaison position has been evaluated in the FCS analysis of proposed postshutdown ERO staffing.
Relettered subsequent steps.
Section B, 4.7.2.G               Radiation Protection Technicians         Radiation Protection Technicians      The augmenting Radiation (five positions) duties include          (three positions) duties include      Protection Technician positions will providing radiological surveys and       providing radiological surveys and    be reduced from five to three in the job coverage to repair and corrective    job coverage to repair and corrective postshutdown ERO. The spectrum action teams as directed.                action teams as directed.             of credible accidents and operational events, and the quantity and complexity of activities required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The duties and coverage required for the position is reduced.
21

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                   Before (Rev. 1)                                                              Reason for Change Number)
Section B, 4.7.2.H               H. The Radiation Protection                H. The Protective Measures            The Radiation Protection Coordinator duties include:                Coordinator duties include            Coordinator position will not exist in coordinating all radiation protection the postshutdown ERO, as
: 1. Forming and preparing emergency activities onsite.                    previously described. The OSC response teams as directed by the Director, RP Technicians, and the OSC Director.
TSC Protective Measures
: 2. Coordinating all radiation                                                    Coordinator will perform the protection activities onsite.                                                    functions as needed. The proposed elimination of the Radiation
: 3. Keeping the OSC Director and TSC Protection Coordinator position has Protective Measures Coordinator been evaluated in the FCS analysis of informed of the status of all proposed postshutdown ERO radiation protection activities onsite.
staffing. Duties and responsibilities
: 4. Fulfilling the minimum staffing                                               will be transferred to remaining ERO position of Radiation Protection                                                 positions.
Technician, if required.
Section B, 4.8.1.A               Emergency Director Duties are              Emergency Director duties are         Editorial revision to reflect the described in Section 3.2 and 4.4.5         described in Section 3.2 and 4.4.4    revised numbering scheme resulting from changes to the Post Shutdown Emergency Plan described within this table.
Section B, 4.8.1.C NOTE          Only one of the positions described        Deleted                               The Dose Assessment Coordinator in Step 4.8.1C or Step 4.8.10 is                                                 position (4.8.1D) will not exist in the required for minimum staffing.                                                   postshutdown ERO, therefore eliminating the need for the NOTE.
22

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                 Before (Rev. 1)                                                               Reason for Change Number)
Section B, 4.8.1.C               Protective Measures Manager duties        Protective Measures Manager duties     The Dose Assessment Coordinator include:                                  include:                               position will not exist in the post shutdown ERO, as previously
: 1. Monitoring dose assessment             1. Directing dose assessment described. The Protective Measures operations performed, and keeping         operations performed, coordinating Manager will perform these assigned the Emergency Director informed of        OPPD field teams, and keeping the duties as needed.
projections and field survey results. Emergency Director informed of projections and field survey results.
: 2. Evaluating site radiological conditions and necessary personnel        2. Evaluating site radiological protective measures.                      conditions and necessary personnel protective measures.
: 3. Preparing and submitting state update information, including             3. Preparing and submitting state Protective Action                         update information, including Recommendations, to the                   Protective Action Recommendations, Emergency Director, state and             to the Emergency Director, state and federal officials.                        federal officials.
: 4. Coordinating technical briefings       4. Coordinating technical briefings for the offsite agencies as requested. for the offsite agencies as requested.
: 5. Comparing dose projections against field team results.
: 6. Comparing dose projections and field team results with state and federal agency results.
23

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                  Before (Rev. 1)                                                         Reason for Change Number)
Section B, 4.8.1.D                Dose Assessment Coordinator duties       Deleted                          The Dose Assessment Coordinator include:                                                                  position will not exist in the post shutdown ERO, as previously
: 1. Directing offsite dose assessments described. The proposed elimination and the associated Protective Action of the Dose Assessment Coordinator Recommendations (PARs).
position has been evaluated in the
: 2. Coordinating OPPD field teams.                                         FCS analysis of proposed post shutdown ERO staffing. The
: 3. Comparing dose projections Protective Measures Manager and against field team results.
Dose Assessment Specialist will
: 4. Comparing dose projections and                                         perform these duties as needed.
field team results with state and Relettered subsequent steps.
federal agency results.
Section B, 6.10                   EPFC1001 Addendum 1, OnShift          Fort Calhoun Station Analysis of Revised to address the analysis used Staffing Analysis Report                 Proposed PostShutdown OnShift  to develop the PostShutdown LAR.
Staff, August 2016 Section B, Attachment 1Table B1 1 Shift Manager (SRO)                    1 Shift Manager (SRO/CFH)        The title change from Senior Reactor (On Shift Minimum Number/Title                                                                              Operator to Certified Fuel Handler column, 1st line)                                                                                           (CFH) is dependent upon NRC approval of proposed changes to Technical Specifications.
Implementation of the Emergency Plan as revised in this LAR is not dependent on prior NRC approval of the proposed changes to the FCS Technical Specifications.
Section B, Attachment 1Table B1 Unit Supervisor (SRO)                    Control Room Operator (SRO or    Position title change, as previously (On Shift Minimum Number/Title                                             RO/CFH)***                       discussed.
column, 1st line)
Section B, Attachment 1Table B1 2 Reactor Operators (RO)                 Deleted                          The Reactor Operator position will (On Shift Minimum Number/Title                                                                              not exist in the postshutdown ERO, column, 1st line)                                                                                           as previously described.
24

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                 Before (Rev. 1)                                               Reason for Change Number)
Section B, Attachment 1Table B1 2 Equipment Operators          1 Equipment Operator/NCO        The proposed staffing of one NCO (On Shift Minimum Number/Title                                                                   has been evaluated in the FCS column, 1st line)                                                                                analysis of proposed postshutdown onshift staffing in conjunction with the postulated accidents that will be applicable in the permanently defueled condition.
The title change from Equipment Operators to NCOs is dependent upon NRC approval of proposed changes to Technical Specifications.
Implementation of the Emergency Plan as revised in this LAR is not dependent on prior NRC approval of the proposed changes to the FCS Technical Specifications.
Section B, Attachment 1Table B1 1 Control Room Communicator    1 Control Room Operator (SRO or The Control Room Communicator (On Shift Minimum Number/Title                                   RO/CFH)***                      position will not exist in the post column, 3rd line)                                                                                shutdown ERO, as previously described. The Control Room Operator will assume these responsibilities as directed by the Shift Manager.
Section B, Attachment 1Table B1 1 Habitability Technician      Deleted                         The Habitability Technician position (On Shift Minimum Number/Title                                                                   will not exist in the postshutdown column, 4th line)                                                                                ERO, as previously described.
Section B, Attachment 1Table B1 1 Chemistry Technician         Deleted                         The Chemistry Technician position (On Shift Minimum Number/Title                                                                   will not exist in the postshutdown column, 4th line)                                                                                onshift staff, as previously described.
25

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                  Before (Rev. 1)                                            Reason for Change Number)
Section B, Attachment 1Table B1 1 Shift Technical Advisor***    Deleted                      The Shift Technical Advisor position (On Shift Minimum Number/Title                                                                 will not exist in the postshutdown column, 5th line)                                                                              onshift staff, as previously described.
Section B, Attachment 1Table B1 1** Equipment Operator          1** Equipment Operator/NCO   The title change from Equipment (On Shift Minimum Number/Title                                                                 Operator to NCO is dependent upon (2 instances)                   (2 instances) column, 5th line)                                                                              NRC approval of proposed changes to Technical Specifications.
Implementation of the Emergency Plan as revised in this LAR is not dependent on prior NRC approval of the proposed changes to the FCS Technical Specifications.
Section B, Attachment 1Table B1 2** R.P. Technicians            1 R.P. Technician            The Habitability Technician position (On Shift Minimum Number/Title                                                                 (serving as the 2nd RP Technician) will column, 6th line)                                                                              not exist in the postshutdown ERO, as previously described.
Section B, Attachment 1Table B1 1 CR Coordinator OR             Deleted                      The Control Room augmenting (Goals for 1 hour Augmentation                                                                 positions, including the Control Minimum Number/Title column, 2nd                                                               Room Coordinator position will not line)                                                                                          exist in the postshutdown ERO, as previously described.
Section B, Attachment 1Table B1 1 CR ENS Communicator           Deleted                      The Control Room augmenting (Goals for 1 hour Augmentation                                                                 positions, including the Control Minimum Number/Title column, 3rd                                                               Room ENS Communicator position, line)                                                                                          will not exist in the postshutdown ERO, as previously described.
Section B, Attachment 1Table B1 1 Communicator in TSC           Deleted                      The TSC Communicator position will (Goals for 1 hour Augmentation                                                                 not exist in the postshutdown ERO, Minimum Number/Title column, 3rd                                                               as previously described.
line) 26

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                  Before (Rev. 1)                                            Reason for Change Number)
Section B, Attachment 1Table B1 2 R.P. Technicians               Deleted                     These positions have no defined (Goals for 1 hour Augmentation                                                                 tasks in procedures. All offsite survey Minimum Number/Title column, 4th                                                               tasks are currently performed by the line)                                                                                          Field Team Technicians, which are maintained.
Section B, Attachment 1Table B1 2 R.P. Technicians               1 R.P. Technician           The spectrum of credible accidents (Goals for 1 hour Augmentation                                                                 and operational events, and the Minimum Number/Title column, 4th                                                               quantity and complexity of activities line)                                                                                          required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The duties and coverage required for the position is reduced.
Section B, Attachment 1Table B1 1 Reactor Safety Coordinator     1 Engineering Coordinator   Position title change, as previously (Goals for 1 hour Augmentation                                                                 described.
Minimum Number/Title column, 5th line)
Section B, Attachment 1Table B1 1 Electrical and I&C Engineer    Deleted                     The oncall I&C Electrical Systems (Goals for 1 hour Augmentation                                                                 Engineer position will not exist in the Minimum Number/Title column, 5th                                                               postshutdown ERO, as previously line)                                                                                          described. The Engineering Coordinator (position title change) in the TSC will assume this function as needed.
Section B, Attachment 1Table B1 1 Primary Systems Engineer       Deleted                     The oncall Primary Systems (Goals for 1 hour Augmentation                                                                 Engineer position will not exist in the Minimum Number/Title column, 5th                                                               postshutdown ERO, as previously line)                                                                                          described. The Engineering Coordinator (position title change) in the TSC will assume this function as needed.
27

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                  Before (Rev. 1)                                                            Reason for Change Number)
Section B, Attachment 1Table B1 1 Equipment Operator                    1 Equipment Operator/NCO             The title change from Equipment (Goals for 1 hour Augmentation                                                                                 Operator to NCO is dependent upon Minimum Number/Title column, 5th                                                                               NRC approval of proposed changes line)                                                                                                          to Technical Specifications.
Implementation of the Emergency Plan as revised in this LAR is not dependent on prior NRC approval of the proposed changes to the FCS Technical Specifications.
Section B, Attachment 1Table B1 2 Electrical Maintenance Technicians    1 Electrical Maintenance Technicians The spectrum of credible accidents (Goals for 1 hour Augmentation                                                                                 and operational events, and the Minimum Number/Title column, 5th                                                                               quantity and complexity of activities line)                                                                                                          required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The duties and coverage required for the position is reduced.
Section B, Attachment 1Table B1 2 R.P. Technicians                      1 R.P. Technician                    The spectrum of credible accidents (Goals for 1 hour Augmentation                                                                                 and operational events, and the Minimum Number/Title column, 6th                                                                               quantity and complexity of activities line)                                                                                                          required for the safe storage of spent nuclear fuel is reduced as compared to an operating plant. The duties and coverage required for the position is reduced.
Section B, Attachment 1Table B1 1 R.P. Coordinator                      Deleted                              The Radiation Protection (Goals for 1 hour Augmentation                                                                                 Coordinator position will not exist in Minimum Number/Title column, 6th                                                                               the postshutdown ERO, as line)                                                                                                          previously described.
28

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                  Before (Rev. 1)                                                 Reason for Change Number)
Section B, Attachment 1Table B1  1 Dosimetry Technician               Deleted                     The Dosimetry Technician position (Goals for 1 hour Augmentation                                                                      will not exist in the postshutdown Minimum Number/Title column,6th                                                                     ERO, as previously described.
line)
Section B, Attachment 2Figure B2 S - ED Secretary                     Deleted                     The ED Secretary position will not exist in the postshutdown ERO. The proposed elimination of the ED Secretary position has been evaluated in the FCS analysis of proposed postshutdown ERO staffing.
Section B, Attachment 2Figure B2 S - Emergency Response               Deleted                     The Emergency Response Coordinator                                                      Coordinator position will not exist in the postshutdown ERO. The proposed elimination of the Emergency Response Coordinator position has been evaluated in the FCS analysis of proposed post shutdown ERO staffing.
Section B, Attachment 2Figure B2 M - EOF Dose Assessment              Deleted                     The EOF Dose Assessment Coordinator                                                      Coordinator position will not exist in the postshutdown ERO, as previously described.
Section B, Attachment 2Figure B2 S - EOF Dose Assessment Assistant    Deleted                     The EOF Dose Assessment Assistant position will not exist in the post shutdown ERO. The proposed elimination of the EOF Dose Assessment Assistant position has been evaluated in the FCS analysis of proposed postshutdown ERO staffing.
29

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                  Before (Rev. 1)                                             Reason for Change Number)
Section B, Attachment 2Figure B2 S - CHP Communicator             Deleted                     The CHP Communicator position will not exist in the postshutdown ERO.
The EOF Protective Measures Manager and the EOF Technical Liaison will perform the functions as needed. The proposed elimination of the CHP Communicator position has been evaluated in the FCS analysis of proposed postshutdown ERO staffing. Duties and responsibilities will be transferred to remaining ERO positions.
Section B, Attachment 2Figure B2 S - Communications Specialist    Deleted                     The Communications Specialist position will not exist in the post shutdown ERO. The proposed elimination of the Communications Specialist position has been evaluated in the FCS analysis of proposed postshutdown ERO staffing.
Section B, Attachment 2Figure B2 S - EOF Clerical Assistant       Deleted                     The EOF Clerical Assistant position will not exist in the postshutdown ERO. The EOF Information Specialist and the Admin Logistics Manager will perform the functions as needed. The proposed elimination of the EOF Clerical Assistant position has been evaluated in the FCS analysis of proposed postshutdown ERO staffing. Duties and responsibilities will be transferred to remaining ERO positions.
30

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                   Before (Rev. 1)                                          Reason for Change Number)
Section B, Attachment 2Figure B2 S - EOF Status Board Keeper    Deleted                     The EOF Status Board Keeper position will not exist in the post shutdown ERO. The proposed elimination of the EOF Status Board Keeper position has been evaluated in the FCS analysis of proposed post shutdown ERO staffing.
Section B, Attachment 2Figure B2 S - EOF Secretary              Deleted                     The EOF Secretary position will not exist in the postshutdown ERO. The proposed elimination of the EOF Secretary position has been evaluated in the FCS analysis of proposed postshutdown ERO staffing.
Section B, Attachment 2Figure B2 S - IT Specialist              Deleted                     The IT Specialist position will not exist in the postshutdown ERO. The proposed elimination of the IT Specialist position has been evaluated in the FCS analysis of proposed postshutdown ERO staffing.
31

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                   Before (Rev. 1)                                         Reason for Change Number)
Section B, Attachment 2Figure B2 Public Inquiry Supervisor     Deleted                     The Public Inquiry Supervisor position will not exist in the post shutdown ERO. The JIC Manager and Public Inquiry Specialist will perform this function as needed. The proposed elimination of the Public Inquiry Supervisor position has been evaluated in the FCS analysis of proposed postshutdown ERO staffing. Duties and responsibilities will be transferred to remaining ERO positions.
Section B, Attachment 2Figure B2 2S - SD Secretary             Deleted                     The Site Director Secretary position will not exist in the postshutdown ERO. The proposed elimination of the Site Director Secretary position has been evaluated in the FCS analysis of proposed postshutdown ERO staffing.
Section B, Attachment 2Figure B2 M - COP Communicator          Deleted                     The TSC COP Communicator position will not exist in the postshutdown ERO, as previously described.
Section B, Attachment 2Figure B2 S - OSC ERMS Operator         Deleted                     The OSC ERMS Operator position will not exist in the postshutdown ERO.
The proposed elimination of the OSC ERMS Operator position has been evaluated in the FCS analysis of proposed postshutdown ERO staffing.
Section B, Attachment 2Figure B2 A - OSC Operations Liaison    Deleted                     The OSC Operations Liaison position will not exist in the postshutdown ERO, as previously described.
32

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                  Before (Rev. 1)                                            Reason for Change Number)
Section B, Attachment 2Figure B2 S - Medical Coordinator         Deleted                     The Medical Coordinator position will not exist in the postshutdown ERO. The OSC Director will perform the functions as needed. The proposed elimination of the OSC Medical Response Coordinator position has been evaluated in the FCS analysis of proposed post shutdown ERO staffing. Duties and responsibilities will be transferred to remaining ERO positions.
Section B, Attachment 2Figure B2 M/A - Radiation Protection      Deleted                     The Radiation Protection Coordinator                                                 Coordinator position will not exist in the postshutdown ERO, as previously described.
Section B, Attachment 2Figure B2 S - OSC Radio Operator (2)      Deleted                     The OSC Radio Operator position will not exist in the postshutdown ERO.
The proposed elimination of the OSC Radio Operator position has been evaluated in the FCS analysis of proposed postshutdown ERO staffing.
Section B, Attachment 2Figure B2 A - OSC Dosimetry Technician    Deleted                     The OSC Dosimetry Technician position will not exist in the post shutdown ERO, as previously described.
33

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                  Before (Rev. 1)                                               Reason for Change Number)
Section B, Attachment 2Figure B2 S - OSC Accountability Clerk       Deleted                     The OSC Accountability Clerk position will not exist in the post shutdown ERO. The proposed elimination of the OSC Accountability Clerk position has been evaluated in the FCS analysis of proposed postshutdown ERO staffing.
Section B, Attachment 2Figure B2 S - Chemistry Coordinator          Deleted                     The Chemistry Coordinator position will not exist in the postshutdown ERO, as previously described.
Section B, Attachment 2Figure B2 S - Maintenance Coordinator (2)    Deleted                     The Maintenance Coordinator position will not exist in the post shutdown ERO. The OSC Director will perform the functions as needed.
The proposed elimination of the Maintenance Coordinator position has been evaluated in the FCS analysis of proposed postshutdown ERO staffing. Duties and responsibilities will be transferred to remaining ERO positions.
Section B, Attachment 2Figure B2 S - OSC Maintenance Planners       Deleted                     The OSC Maintenance Planner position will not exist in the post shutdown ERO. The proposed elimination of the OSC Maintenance Planner position has been evaluated in the FCS analysis of proposed post shutdown ERO staffing.
34

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                   Before (Rev. 1)                                                  Reason for Change Number)
Section B, Attachment 2Figure B2 S  Storekeeper                        Deleted                     The Storekeeper position will not exist in the postshutdown ERO. The proposed elimination of the Store Keeper position has been evaluated in the FCS analysis of proposed post shutdown ERO staffing.
Section B, Attachment 2Figure B2 A - Control Room Coordinator (Shift    Deleted                     The Control Room Coordinator Manager Until Relieved)                                            position will not exist in the post shutdown ERO, as previously described.
Section B, Attachment 2Figure B2 A -CR ERMS Communicator                Deleted                     The CR ERMS Communicator position will not exist in the post shutdown ERO, as previously described.
Section B, Attachment 2Figure B2 A - Equipment Operator                 Deleted                     The augmenting Equipment Operator position will not exist in the postshutdown ERO, as previously described.
Section B, Attachment 2Figure B2 S - CR Data Collector                  Deleted                     The CR Data Collector position will not exist in the postshutdown ERO, as previously described.
Section B, Attachment 2Figure B2 S - CR Dose Assessment Specialist      Deleted                     The Control Room Dose Assessment Specialist position will not exist in the postshutdown ERO, as previously described.
Section B, Attachment 2Figure B2 S - CR Accountability Clerk            Deleted                     The CR Accountability position will not exist in the postshutdown ERO, as previously described.
35

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                    Before (Rev. 1)                                                Reason for Change Number)
Section B, Attachment 2Figure B2 S - CR Extra Operators               Deleted                      The CR Extra Operator position will not exist in the postshutdown ERO, as previously described.
Section B, Attachment 2Figure B2 B  Control Room Supervisor          B  Control Room Operator    Title change as previously described.
Section B, Attachment 2Figure B2 2B - Reactor Operator                Deleted                      The Reactor Operator position will not exist in the postshutdown ERO, as previously described.
Section B, Attachment 2Figure B2 B - Shift Technical Advisor          Deleted                      The Shift Technical Advisor position will not exist in the postshutdown ERO, as previously described.
Section B, Attachment 2Figure B2 B - CR Communicator                  Deleted                      The Control Room Communicator position will not exist in the post shutdown ERO, as previously described.
Section B, Attachment 2Figure B2 S - Shift Chemist                    Deleted                      The Shift Chemist position will not exist in the postshutdown ERO, as previously described.
Section B, Attachment 2Figure B2 S - Habitability Technician          Deleted                      The Habitability Technician position will not exist in the postshutdown ERO, as previously described.
Section B, Attachment 2Figure B2 S - TSC Status Board Keeper          Deleted                      The TSC Status Board Keeper position will not exist in the post shutdown ERO.
Section B, Attachment 2Figure B2 2S - TSC Administrative Assistant    Deleted                      The TSC Administrative Assistant position will not exist in the post shutdown ERO.
Section B, Attachment 2Figure B2 M - Reactor Safety Coordinator       MEngineering Coordinator    Title change as previously described.
36

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                  Before (Rev. 1)                                              Reason for Change Number)
Section B, Attachment 2Figure B2 S - Reactor Engineer              Deleted                     The Reactor Engineer position will not exist in the postshutdown ERO.
The TSC Reactor Safety coordinator (retitled to Engineering Coordinator) will perform the functions as needed. The proposed elimination of the Reactor Engineer position has been evaluated in the FCS analysis of proposed postshutdown ERO staffing. Duties and responsibilities will be transferred to remaining ERO positions.
Section B, Attachment 2Figure B2 1A/1S - Electrical/I&C Systems    Deleted                     The Electrical/I&C Systems Engineer Engineer                                                      position will not exist in the post shutdown ERO, as previously described.
Section B, Attachment 2Figure B2 A - Primary Systems Engineer      Deleted                     The Primary Systems Engineer position will not exist in the post shutdown ERO, as previously described.
37

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                    Before (Rev. 1)                                                       Reason for Change Number)
Section B, Attachment 2Figure B2  S - Secondary Systems Engineer        Deleted                           The Secondary Systems Engineer position will not exist in the post shutdown ERO. The TSC Reactor Safety coordinator (retitled to Engineering Coordinator) will perform the functions as needed.
The proposed elimination of the Secondary Systems Engineer position has been evaluated in the FCS analysis of proposed post shutdown ERO staffing. Duties and responsibilities will be transferred to remaining ERO positions.
Section B, Attachment 2Figure B2  S - CHP Communicator                  Deleted                           The CHP Communicator position will not exist in the postshutdown ERO.
The TSC Protective Measures Coordinator and the TSC Ops Liaison will perform the functions as needed. The proposed elimination of the CHP Communicator position has been evaluated in the FCS analysis of proposed postshutdown ERO staffing. Duties and responsibilities will be transferred to remaining ERO positions.
Section B, Attachment 2Figure B2, For activation only, either a Dose    For activation only, a Protective The Dose Assessment Coordinator NOTE 1                              Assessment Coordinator or a           Measures Manager is required. position will not exist in the post Protective Measures Manager is                                          shutdown ERO as previously required.                                                               described.
38

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                   Before (Rev. 1)                                                            Reason for Change Number)
Section B, Attachment 2Figure B2, Minimum staffing for the OSC is an      Minimum staffing for the OSC is an   The RP Coordinator position will not NOTE 2                              OSC Director, one RP Technician or      OSC Director, one RP Technician and  exist in the postshutdown ERO as the RP Coordinator and one other        one other person to form a team. previously described.
person to form a team.
Section D, 1.1                      The Emergency Classification            The Emergency Classification         Editorial change to reflect previous scheme is based on NEI9901,           scheme is based on NEI9901,        EAL update.
Revision 5, Methodology for             Revision 6, Development of Development of Emergency Action         Emergency Action Levels for Non Levels.                                 Passive Reactors.
Section D, 2.4                      Immediate actions to be taken in        Immediate actions to be taken in     FCS will no longer be an operating response to conditions involving        response to conditions involving     nuclear power plant.
3rd Sentence abnormal plant operating                abnormal plant operating parameters are detailed in the Fort     parameters are detailed in the Fort Calhoun Station Emergency               Calhoun Station Abnormal Operating Operating Procedures, Abnormal          Procedures and Operating Operating Procedures and Operating      Instructions. Other immediate Instructions. Other immediate           actions and followup actions are actions and followup actions are       identified in Section J of this plan identified in Section J of this plan    and are described in detail in and are described in detail in          applicable Emergency Plan applicable Emergency Plan               Implementing Procedures, listed in Implementing Procedures, listed in      Appendix C of this plan.
Appendix C of this plan.
39

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                  Before (Rev. 1)                                                             Reason for Change Number)
Section D, 2.6                   In using the ICs as the basis for         In using the ICs as the basis for     FCS will no longer be an operating initiating emergency response             initiating emergency response         nuclear power plant. The word activity, there may be instances          activity, there may be instances      operating is deleted from this when the plant operating staff            when the plant staff cannot           section to reflect the permanently cannot determine which of two             determine which of two emergency      shut down and defueled condition.
emergency classifications is              classifications is appropriate for a The words can not are changed to appropriate for a particular              particular occurrence. In those cases cannot. Editorial change.
occurrence. In those cases where          where the appropriate classification the appropriate classification can not    cannot be defined in a short period be defined in a short period of time,     of time, the occurrence should be the occurrence should be treated as       treated as the higher of the two the higher of the two classifications     classifications and the appropriate and the appropriate response for          response for that level should be that level should be initiated.           initiated.
Section D, 2.7.2                 The primary purpose for this              The primary purpose for this          FCS will no longer be an operating classification is to ensure that the      classification is to ensure that the  nuclear power plant. The word operating plant staff recognizes the      plant staff recognizes the initiating operating is deleted from this initiating condition, takes               condition, takes appropriate action,  section to reflect the permanently appropriate action, such as               such as assessment and verification,  shut down and defueled condition.
assessment and verification, and          and comes to an appropriate state of comes to an appropriate state of          readiness to respond in the event readiness to respond in the event         that the condition worsens.
that the condition worsens.
40

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                    Before (Rev. 1)                                                               Reason for Change Number)
Table D1 - Emergency Classification Fuel Handling Accident (in                Deleted                                FCS will no longer be an operating of Postulated Accidents              Containment)                                                                     nuclear power plant. The deleted postulated accidents will no longer Control Element Assembly Ejection be applicable to FCS since it will be Incident defueled.
Loss of Coolant Accident Single Reactor Coolant Pump Seizure Steam Generator Tube Rupture Main Steam Line Break Section E, 2.1.1                     As discussed in that section, they are    As discussed in that section, they are Editorial change to reflect previous consistent with NEI9901,                consistent with NEI9901,             EAL update.
Methodology Development of                Development of Emergency Action Emergency Action Levels,                 Levels for NonPassive Reactors, Section E, 2.2.2.C                   Emergency information to the              Emergency information to the           FCS will no longer be an operating county Emergency Operations               county Emergency Operations            nuclear power plant. The term Centers (Washington, Harrison and         Centers (Washington, Harrison and      operational progress is deleted Pottawattamie Counties) is given          Pottawattamie Counties) is given       from this section to reflect the verbally using the Conference             verbally using the Conference          permanently shut down and Operation (COP) Network. These            Operation (COP) Network. These         defueled condition.
messages discuss general                  messages discuss general conditions operational progress of the plant.        of the plant.
Section F, 2.3, Table, right column  PrImary/Alternate Communications          Primary/Alternate Communications       Editorial change. Corrected heading                              Responsibility                            Responsibility                         typographical error. Changed Prlmary to Primary.
Section F, 2.3, Table, right column, Shift Manager (Control Room               Shift Manager (Control Room            The Control Room Coordinator and 1st line                             Coordinator)/Control Room                 Operator)                              Control Room Communicator Communicator                                                                     positions will not exist in the post shutdown ERO, as previously described.
Editorial change. Closed parenthesis.
41

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                       Before (Rev. 1)                                                            Reason for Change Number)
Section F, 2.3, Table, right hand     Site Director/TSC COP                    Site Director                         The TSC COP Communicator position column, 2nd line                      Communicator                                                                   will not exist in the postshutdown ERO, as previously described.
Section F, 2.16.1                     This system (similar to the COP and      This system (similar to the COP and   The Control Room Coordinator Ops Liaison Network) provides            Ops Liaison Network) provides         position will not exist in the post dedicated conference capability          dedicated conference capability       shutdown ERO, as previously between the Control Room                 between the Control Room, TSC Site    described. However, the capability Coordinator, TSC Site Director, OSC      Director, OSC Director, EOF           to communicate via the MOP Director, EOF Emergency Director         Emergency Director and the JIC        network between the Control Room, and the JIC Manager. The purpose         Manager. The purpose of the           TSC, OSC, EOF, and JIC via the MOP of the system is to provide              system is to provide information      Network will continue.
information flow between the             flow between the directors of all the directors of all the emergency           emergency facilities.
facilities.
Section F, 2.17                       joint Information Center Hot Line        Joint Information Center Hot Line     Editorial change.
Section F, 2.19.1                     WEBeOC                                   WebEOC                                Editorial change.
Section F, Figure F5, Heading        Figure F5  Operations Liaision         Figure F5  Operations Liaison       Editorial change. Corrected spelling Network                                  Network                               of Liaison.
Section H (Corrected to G, 2.1, 3rd The Joint Information Center also        The Joint Information Center also     The Public Inquiry Supervisor paragraph                             serves as the public inquiry center      serves as the public inquiry center   position will not exist in the post for OPPD, State and Federal              for OPPD, State and Federal           shutdown ERO, as previously authorities. The Public Inquiry          authorities.                          described.
Supervisor will serve as OPPDs representative in this area.
Section H (Corrected to G), 3.0, ,  An JIC Technical Liaison at the Joint    A JIC Technical Liaison at the Joint  Editorial change.
5th sentence                          Information Center will assist in        Information Center will assist in nuclear related information matters. nuclear related information matters.
42

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                 Before (Rev. 1)                                                                  Reason for Change Number)
Section H, 1.1.1                 The TSC's primary function is the           The TSC's primary function is the      FCS will no longer be an operating collection, analysis, and distribution      collection, analysis, and distribution nuclear power plant. The words of technical data required to support       of technical data required to support  plant operations and operational plant operations personnel during an        plant personnel during an              are deleted from this section to emergency. This operational                 emergency. This support is provided    reflect the permanently shut down support is provided from a separate         from a separate and distinct center,   and defueled condition.
and distinct center, thus reducing          thus reducing personnel congestion personnel congestion in the Control         in the Control Room. The TSC has Room. The TSC has the capability to         the capability to perform EOF perform EOF functions and                   functions and responsibilities until responsibilities until that facility can    that facility can be fully activated.
be fully activated.
Section H, 1.2.1.C               An official copy of the Fort Calhoun        An official copy of the Fort Calhoun   FCS will no longer be an operating Station Operating Manual. (This             Station Operating Manual. (This        nuclear power plant.
includes the Operating Procedures           includes the Operating Procedures and Instructions, Emergency                 and Instructions, the Post Shutdown Operation Procedures, the                   Radiological Emergency Response Radiological Emergency Response             Plan and Emergency Plan Plan and Emergency Plan                     Implementing Procedures.
Implementing Procedures.
Section H, 1.2.1.A                   St4atus boards.                         L. Status boards                       Editorial change. Corrected typographical error. Corrected step lettering.
Renumbered subsequent steps.
Section H, 1.2.1.L.              L. The ability to provide output            M. The ability to provide output       Editorial change. Corrected step displays to the OSC and EOF.                displays to the OSC and EOF.           lettering.
43

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                  Before (Rev. 1)                                                           Reason for Change Number)
Section H, 2.2.1.K               Complete latest revision of the Fort    Complete latest revision of the Fort FCS will no longer be an operating Calhoun Station Operating Manual.       Calhoun Station Operating Manual. nuclear power plant.
(This includes the Operating            (This includes the Operating Procedures and Instructions,            Procedures and Instructions, the Emergency Operating Procedures,         Post Shutdown Radiological the Radiological Emergency              Emergency Response Plan and Response Plan and Emergency Plan        Emergency Plan Implementing Implementing Procedures).               Procedures).
Section H, 3.3.1                 OSC management is comprised of an       OSC management is comprised of an    The three OSC coordinator positions OSC Director and three coordinators     OSC Director and three technicians   will not exist in the postshutdown representing the radiation              representing the radiation           ERO, as previously described.
protection, chemistry and               protection, chemistry and            Technicians will perform these maintenance disciplines.                maintenance disciplines. (See        functions as needed.
Technicians comprise the balance of     Section B of this plan for a the OSC personnel (See Section B of     comprehensive organization this plan for a comprehensive           definition).
organization definition).
44

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                  Before (Rev. 1)                                                             Reason for Change Number)
Section H, 4.1.1                 The Control Room functions as the        The Control Room functions as the     FCS will no longer be an operating onsite location from which the           onsite location from which the FCS    nuclear power plant. Hence, the nuclear power plant is operated and      systems are monitored and             term nuclear power plant is from which any ISFSI operations are      controlled and from which any ISFSI   replaced with Fort Calhoun coordinated. It is large enough to       operations are coordinated. It is     Station, and the word operated is contain all the instrumentation,         large enough to contain all the       deleted from this section to reflect controls and displays for the nuclear    instrumentation, controls and         the permanently shut down and systems, reactor coolant systems,        displays for the nuclear systems,     defueled condition.
steam systems, electrical systems,       reactor coolant systems, steam safety and accident monitoring           systems, electrical systems, safety systems. The Control Room plays a        and accident monitoring systems.
vital role in the Emergency Response     The Control Room plays a vital role Organization by providing the initial    in the Emergency Response response actions needed to react to      Organization by providing the initial any emergency situation. The             response actions needed to react to Control Room personnel will              any emergency situation. The respond to all emergency situations      Control Room personnel will in an attempt to mitigate the            respond to all emergency situations emergency and minimize the impact        in an attempt to mitigate the on the surrounding environment,          emergency and minimize the impact health and safety of the public as       on the surrounding environment, well as plant personnel and              health and safety of the public as equipment.                               well as plant personnel and equipment.
Section H, 4.2.1, 4th bullet     Technical Specifications for the         Technical Specifications for FCS and  FCS will no longer be an operating nuclear power plant and the ISFSI        the ISFSI (electronically)            nuclear power plant. Hence, the (electronically)                                                               term nuclear power plant is replaced with Fort Calhoun Station in this section to reflect the permanently shut down and defueled condition.
45

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                 Before (Rev. 1)                                                     Reason for Change Number)
Section H, Figure H2            2 - TSC DIRECTOR                  Updated Figure to remove positions. Positions will not exist in the post shutdown ERO as previously 6 - SITE DIRECTOR SECRETARY described.
11 - TSC STATUS BOARD KEEPER 12 - COP COMMUNICATOR 16 - ELECTRICAL/I&C ENGINEER 17 - PRIMARY SYSTEMS ENGINEER 20 - REACTOR ENGINEER 21 - SECONDARY SYSTEMS ENGINEER 22 - CHP COMMUNICATOR Section H, Figure H2            7 - REACTOR SAFETY COORDINATOR    7 - ENGINEERING COORDINATOR         Position title changed, as previously described.
Section H, Figure H3            1 - TSC ACCOUNTABILITY CLERK      Updated Figure to remove position. The TSC Accountability Clerk position will not exist in the postshutdown ERO. The proposed elimination of the TSC Accountability Clerk position has been evaluated in the FCS analysis of proposed postshutdown ERO staffing.
46

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                  Before (Rev. 1)                                                       Reason for Change Number)
Section H, Figure H4            3 - OSC CHEMISTRY COORDINATOR         Updated Figure to remove positions. Positions will not exist in the post shutdown ERO, as previously 4 - OSC RP COORDINATOR described.
5 - OSC MAINTENANCE COORDINATOR 6 - OSC MAINTENANCE PLANNER 7 - OSC STOREKEEPER 9 - OSC ACCOUNTABILITY CLERK 10 - OSC ERMS OPERATOR 11 - OSC RADIO OPERATOR 12 - OSC DOSIMETRY TECHNICIAN 13 - OSC MEDICAL COORDINATOR Section H, Figure H5            2. Emergency Director                 Updated figure to remove positions. Positions will not exist in the post Secretary/ERMS                                                            shutdown ERO as previously described.
: 6. EOF Dose Assessment Coordinator
: 9. EOF Dose Assessment Assistant
: 14. EOF Secretary
: 15. EOF Clerical Assistant
: 16. EOF Status Board Keeper
: 17. EOF Communications Specialist
: 19. EOF Information Technology Specialist
: 20. EOF Emergency Response Coordinator
: 21. CHP Communicator 47

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                  Before (Rev. 1)                                                              Reason for Change Number)
Section J, 1.4.5.A               Respiratory protective devices may       Respiratory protective devices may      FCS will no longer be an operating be required in any situation arising     be required where an airborne           nuclear power plant. Deleted the from plant operations where an           radioactivity condition is potential or words, in any situation arising from airborne radioactivity condition is      existent. In such cases, the air will   plant operations, to reflect the potential or existent. In such cases,    be monitored and the necessary          permanently shut down and the air will be monitored and the        protective devices specified            defueled condition.
necessary protective devices             according to the concentration and specified according to the               type of airborne contaminants concentration and type of airborne       present. Monitoring and issue of contaminants present. Monitoring         respiratory protection equipment and issue of respiratory protection      will be conducted in accordance with equipment will be conducted in           Radiation Protection Manual accordance with Radiation                Procedures. Precautions will be Protection Manual Procedures.            taken to keep airborne Precautions will be taken to keep        contamination to a minimum airborne contamination to a              through the use of proper minimum through the use of proper        engineering controls and engineering controls and                 decontamination.
decontamination.
Section K, 1.2                   The facility directors, Control Room     The facility directors, Shift Manager   The Control Room Coordinator Coordinator or Shift Manager in the      in the Control Room, Site Director in   position will not exist in the post Control Room, Site Director or TSC       the TSC, the OSC Director in the OSC    shutdown ERO, as previously Director in the TSC, the OSC Director    or the Emergency Director in the        described.
in the OSC or the Emergency              EOF may authorize dose extension Director in the EOF may authorize        up to 5 Rem TEDE per year during dose extension up to 5 Rem TEDE          declared events for workers in their per year during declared events for      facility.
workers in their facility.
48

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                  Before (Rev. 1)                                                              Reason for Change Number)
Section K, 1.5, 3rd bullet       Personnel responding to the site that     Personnel responding to the site that  The OSC Dosimetry Technician require, but do not have, dosimetry       require, but do not have, dosimetry    position will not exist in the post will be issued dosimetry by Security      will be issued dosimetry by Security   shutdown ERO, as previously or Radiation Protection personnel.        or Radiation Protection personnel. described.
The following ERO positions can also      The following ERO positions can also issue dosimetry when necessary:           issue dosimetry when necessary:
Control Room: The Shift RP               Control Room: The Shift RP Technician or OSC RP Technicians          Technician or OSC RP Technicians TSC: OSC RP Technicians                  TSC: OSC RP Technicians OSC: The OSC Dosimetry                   OSC: The OSC RP Technicians Technician or OSC RP Technicians Section L, 1.3                   All injuries at the station must be       All injuries at the station must be    The OSC Medical Coordinator immediately reported to the Shift         immediately reported to the Shift      position will not exist in the post Manager, who will initiate response       Manager, who will initiate response    shutdown ERO, as previously according to the Fort Calhoun             according to the Fort Calhoun          described.
Station Safety Manual, FCSG 15 7,         Station Safety Manual, FCSG 15 7, Medical Emergencies. When the OSC         Medical Emergencies. When the OSC is activated the OSC Director and the     is activated the OSC Director will be OSC Medical Coordinator will be           responsible for response to medical responsible for response to medical       emergencies.
emergencies.
Section M, 2.2                   The Command and Control Position          The Command and Control Position       The Control Room Coordinator has the responsibility for authorizing    has the responsibility for authorizing position will not exist in the post reentry into a previously evacuated       reentry into a previously evacuated    shutdown ERO, as previously area. This could be the Shift             area. This could be the Shift          described.
Manager, Control Room                     Manager, Site Director, or Coordinator, Site Director, or            Emergency Director depending on Emergency Director depending on           the stage that emergency response the stage that emergency response         has reached.
has reached.
49

FCS Emergency Plan Change Summary After (Pending Revision Emergency Plan Section                    Before (Rev. 1)                                                           Reason for Change Number)
Section P, 1.1, 2nd paragraph, Last Radialogical                            Radiological                         Editorial change. Corrected spelling Sentence                                                                                                         of radiological.
Appendix C, 3rd Paragraph           For Section D, Emergency                For Section D, Emergency             Editorial change to reflect previous Classification System, OPPD uses the    Classification System, OPPD uses the EAL update.
guidance of NEI9901, Methodology      guidance of NEI9901, Development for Development of Emergency            of Emergency Action Levels for Non Action Levels. This variance from       Passive Reactors. This variance from NUREG0654 has been approved by         NUREG0654 has been approved by the NRC.                                the NRC.
Appendix C, Throughout              Adendum                                 Addendum                             Editorial changes. Corrected spelling of addendum and seismic seisamic                                seismic throughout Appendix.
50

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION DOCKET NUMBER 50-285 / LICENSE NUMBER DPR-40 ATTACHMENT 3 PROPOSED REVISION TO THE FCS RERP PAGES (copy with changes marked and a clean copy)

FCS                                                  EP-FC-1001 Revision 0TBD Page 1 of 170 POST SHUTDOWN RADIOLOGICAL EMERGENCY RESPONSE PLAN OPPD NUCLEAR POST-SHUTDOWN RADIOLOGICAL EMERGENCY RESPONSE PLAN FOR FORT CALHOUN STATION

FCS                                                                                   EP-FC-1001 Revision 0TBD Page 2 of 170 POST SHUTDOWN RADIOLOGICAL EMERGENCY RESPONSE PLAN AREA DESCRIPTION 1.0  PLANT LOCATION Fort Calhoun Station is located midway between Fort Calhoun and Blair, Nebraska, on the west bank of the Missouri River. The site consists of approximately 660.46 acres with an additional exclusion area of 582.18 acres on the northeast bank of the river directly opposite the plant buildings. The Fort Calhoun Station includes the Independent Spent Fuel Storage Installation (ISFSI), located within the protected area, centered approximately 200 meters north-northwest of the Containment Building. The distance from the reactor containment to the nearest site boundary is approximately 910 meters; and the distance to the nearest residence is beyond the site boundary. Except for the city of Blair and the villages of Fort Calhoun and Kennard, the area within a ten mile radius is predominantly rural. The land use within the ten mile radius is primarily devoted to general farming. There are no private businesses or public recreational facilities on the plant property. The DeSoto National Wildlife Refuge occupies approximately 7821 acres east of the plant site. This area is open to the public for day use year-round.
Visitors to the refuge generally use areas from two to five miles from the plant. Estimates by the U.S. Fish and Wildlife Service place annual usage of the facility at approximately 120,000 for the Visitors Center and 400,000 for the refuge. The expected maximum daily usage of the facility has been placed at 2500 visitors for a winter weekday and 5000 on a summer weekend. The Boyer Chute Federal Recreation Area is a day use facility occupying approximately 2000 acres southeast of the plant site. Visitors to the recreation area generally use areas seven to ten miles from the plant. The estimates for annual usage of this facility is approximately 50,000 visitors.
The State of Nebraska operates the Fort Atkinson State Historic Park five and half miles southeast of the plant site. This day use facility is mostly seasonal and estimates place annual usage at 60,000. The State of Iowa maintains Wilson Island State Park with 275 camping spaces south of the DeSoto National Wildlife Refuge and four miles southeast of the plant site. The estimates for usage of this facility range from 500 on a winter weekday to 1000 on a summer weekend.
Two private facilities lie to the north of the plant along the Missouri River. The Cottonwood Marina is located approximately four and a half miles from the plant.
Estimates place summer weekend usage at 200 people. Riverland Resort Park is a private campground lying directly south of Cottonwood Marina and ranging from four to four and a half miles from the plant. The campground has approximately 235 campsites and is open from April to October.

FCS                                                                                   EP-FC-1001 Revision 0TBD Page 3 of 170 POST SHUTDOWN RADIOLOGICAL EMERGENCY RESPONSE PLAN 2.0  AREA INDUSTRIES A listing of various industries located within a ten mile radius of the Fort Calhoun Station, including firm name, product, number of employees, and location from the plant site is contained in the Updated Safety Analysis Report.
3.0  AREA WATER SUPPLIES Local public drinking water supplies are not taken from the Missouri River in this area.
The first downstream intake is the city of Omaha approximately 19.5 miles downstream.
Industrial water use is limited to cooling purposes in the Omaha area. Drinking water near the Fort Calhoun Station is obtained from either well or reservoirs. Since the known public and private water supplies originate at elevations higher than the river, radioactive liquids that might be discharged from the plant into the river should not contaminate these supplies.
There are also many private wells in the region which draw primarily upon ground water rather than on springs or other surface sources. Several marinas are located along the Missouri River, between 3 miles upstream from Blair and Omaha, 18 miles downstream.
In the event of a significant waterborne release incident from the Fort Calhoun Station, the Nebraska Department of Environmental Control acting in conjunction with the Nebraska Department of Health, Division of Radiological Health and the U. S. Coast Guard are prepared to notify all downstream users of Missouri River water. Notification is made through OPPD management directly to the Metropolitan Utilities District (MUD) in the event of an inadvertent liquid release to the river. Swimming, boating and other recreational activities involving river water can be controlled by the Coast Guard until adequate surveys have been taken to determine when normal activities may be resumed.

FCS                                                                                     EP-FC-1001 Revision 0TBD Page 4 of 170 POST SHUTDOWN RADIOLOGICAL EMERGENCY RESPONSE PLAN PURPOSE OF THE EMERGENCY PLAN The purpose of the Fort Calhoun Station "Post-Shutdown Radiological Emergency Response Plan" (PSRERP) is to delineate an organization for coping with emergencies, to classify emergencies according to severity, define and assign responsibilities and authorities, and to clearly outline the most effective course of action and protective measures required to mitigate the consequences of an accident and to safeguard the public and station personnel in the event of an incident. The Emergency Plan Implementing Procedures (EPIP's), Radiation Protection procedures, Emergency Operating procedures and other station references are available at the plant to further assist personnel for operating during abnormal occurrences. The various emergency procedures are put into effect whenever a system, component or circuit failure could lead to a personnel hazard or major equipment failure. Emergency Operating Procedures are sufficiently detailed so that the plant is placed, as expeditiously as possible, maintained in a safe condition. The various procedures include such items as radiation hazards, weather conditions and availability of technical and operating plant personnel.

FCS                                                                                   EP-FC-1001 Revision 0TBD Page 5 of 170 POST SHUTDOWN RADIOLOGICAL EMERGENCY RESPONSE PLAN ACCIDENT CONSIDERATIONS 1.0  FUEL HANDLING ACCIDENT The possibility of an incident during fuel handling is unlikely due to the many physical limitations imposed on fuel handling operations and systems. In addition, administrative restrictions placed on fuel handling procedures provide greater control. Nevertheless, the offsite consequences of dropping a spent fuel assembly and damaging the entire assembly have been evaluated and are documented in the Fort Calhoun Station, Unit No. 1 USAR, Section 14.18. Emergency onsite and offsite monitoring practices would begin immediately following the accident to determine actual consequences, and appropriate emergency actions would be taken. Emergency procedures addressing a Fuel Handling Incident provide emergency actions for this mishap.
The transfer cask that is used to transfer spent fuel (32 assembly capacity) contained within a dry shielded canister (DSC) from the Auxiliary Building to the ISFSI, has been analyzed for an 80 inch drop accident in the NUHOMS FSAR. The analysis determined that the DSC would retain its leak tight integrity for this 80 inch drop. This bounds the height of the transfer cask while it is being moved by the heavy-haul trailer between the Auxiliary Building and the ISFSI so that a release of radioactivity due to a drop event during transfer operations would not occur.
2.0  FIRES 2.1  Internal Plant Fires (within the Protected Area)
Internal Plant fires are normally handled by the station's Fire Brigade, comprised of trained individuals from the Operations Department and Radiation Protection Department. All efforts are made to prevent the spread of airborne contamination should the fires occur within the Radiological Controlled Area.
2.2  External Fires (outside the Protected Area)
External fires are controlled by local fire department response. In the event high airborne contamination constitutes a possible hazard to areas outside of the protected area, offsite survey teams/personnel can be dispatched immediately.

FCS                                                                                   EP-FC-1001 Revision 0TBD Page 6 of 170 POST SHUTDOWN RADIOLOGICAL EMERGENCY RESPONSE PLAN 3.0  EXPLOSION Because of the accumulation of waste gases in the waste gas decay tanks, the possibility and consequences of an explosion have been considered. An explosion could result in an unexpected, uncontrolled release to the atmosphere of radioactive fission gases that were stored in the waste gas system. A failure of any of the waste gas decay tanks or associated piping could also result in a release of gaseous activity. The noble gases stored in the tanks would diffuse and become diluted during their transport to the site boundary. The projected Deep Dose Equivalent (DDE) at the exclusion area boundary would be less than 1.0 Rem. This conservative analysis is based upon 1% fuel cladding defects, and accumulation of all noble gases without release over a full core cycle.
Emergency procedures addressing a Waste Gas Incident, would be placed into effect immediately and offsite monitoring teams would be dispatched downwind.
The ISFSI horizontal storage modules (HSM) are designed to protect the DSCs from the effects of explosions to ensure the DSCs retain their leak-tight integrity and prevent a release of radioactivity to the atmosphere. An analysis of the haul route used to transfer the DSCs from the Auxiliary Building to the ISFSI was performed, and it identified administrative controls needed to prevent explosions in the vicinity of the transfer cask (designed to withstand 3 psi overpressure) during spent fuel transfer operations.
4.0  TOXIC CHEMICAL RELEASE ACCIDENTS The primary toxic chemical release accidents which may result in toxic gas concentrations at Fort Calhoun Station are shown below:
TOXIC CHEMICAL              ACCIDENT Ammonia (NH3)               Rupture of two 25,000 ton offsite refrigerated tanks.
Ammonia                     Rupture of two 30,000 gal. offsite non-refrigerated tanks.
Ammonia                     Rupture of a 78 ton railroad tank car.
Ammonia                     Rupture of a 2 ton tank truck.
The above accidents will not pose a hazard to control room personnel, due to toxic gas monitors located at the fresh air intake of the control room, which isolates the control room before the gases reach the toxic limit. The stringent odor of ammonia makes station personnel immediately aware of any leakage or toxic gas cloud. Spent Fuel storage at the ISFSI relies on passive means of decay heat removal (natural convection),
so a toxic gas release does not challenge nuclear safety.
The toxic gas monitors sample for NH3 and continuously monitor the fresh air to the control room during normal plant operations.

FCS                                                                                      EP-FC-1001 Revision 0TBD Page 7 of 170 POST SHUTDOWN RADIOLOGICAL EMERGENCY RESPONSE PLAN At different phases of plant operation, Hydrogen and/or Nitrogen gases blanket the volume control tank and the waste gas system. Considering that the deleterious effect of these gases is the exclusion of oxygen, a release to the atmosphere diminishes the harmful effect and a serious hazard is eliminated.
In the event of an offsite accidental release of chemicals, within a five (5) mile radius of the Fort Calhoun Station, the Blair Fire Department emergency procedures require notification to the Fort Calhoun Station. The counties of Washington (Nebraska) and Harrison (Iowa) have agreed to notify the Fort Calhoun Station when hazardous chemical accidents occur within five miles of the station. Appropriate action is taken, especially in the control room, to ensure that air remains breathable. For long duration toxic accidents, six (6) hours of compressed air is available for five (5) control room operators coupled with provisions to obtain additional air within this time period.
5.0    MAJOR STEAM RELEASE The offsite consequences of a steam line rupture incident has been evaluated and is documented in the Fort Calhoun Station, Unit NO. 1 USAR. The maximum size steam line rupture is a circumferential double-ended rupture of the 36-inch main steam header.
The analysis of this incident at the site boundary is calculated to be 0.9 Rem TEDE.
Plant personnel would be protected by normal health physics practices and procedures.
Operator action follows the emergency procedures addressing a Steam Line Rupture with Loss of Offsite Power.
6.05.0 PERSONNEL INJURY A fully stocked First Aid Room is available in the Plant. Immediate and temporary care may be given to the injured person using standard First Aid practices. If the injury involves contamination, efforts to decontaminate the injured person to reasonable levels are made prior to transfer to the First Aid Room or to offsite medical facilities. If decontamination is not practical, the injured person is covered in such a manner as to minimize the spread of contamination until either medical aid can be obtained or until the injured person can be transported to the UNMC Regional Radiation Health Center.
7.06.0 NATURAL DISASTERS A natural disaster may occur which could initiate any of the accidents previously discussed. The reactor may be placed in a shutdown condition, depending upon the anticipated or experienced severity of the disaster. The Spent Fuel Pool and ISFSI isare designed to withstand natural phenomena, including the maximum hypothetical earthquake, design basis tornado and tornado-driven missiles, with no release of radioactivity.

FCS EP-FC-1001 Section A Revision 0TBD Page 8 of 170 ASSIGNMENT OF ORGANIZATIONAL RESPONSIBILITY (ORGANIZATIONAL CONTROL) 1.0  NON-OPPD SUPPORT ORGANIZATIONS The following organizations may respond to a declared emergency at the Fort Calhoun Station. Each of these groups are capable of 24 hour response and operation. The details of their responsibilities are contained in their respective emergency response plans/procedures or if applicable, a Letter of Agreement between that organization and OPPD. Figure A-1 outlines the organizational interrelationships of various response organizations.
1.1  Law Enforcement Support Organizations 1.1.1      Nebraska State Patrol 1.1.2      Iowa State Patrol 1.1.3      Washington County Sheriff's Department 1.1.4      Pottawattamie County Sheriff's Department 1.1.5      Harrison County Sheriff's Department 1.1.6      Douglas County Sheriff's Department 1.2  Fire and Rescue Support Organizations 1.2.1      Blair Fire Department and Rescue Squad 1.2.2      Fort Calhoun Fire/Rescue 1.2.3      Missouri Valley Fire & Rescue Squad 1.2.4      Council Bluffs Fire and Ambulance Department 1.3  Medical Support Organization 1.3.1      UNMC Regional Radiation Health Center 1.4  Nebraska's Governmental Support Organizations 1.4.1      Nebraska Emergency Management Agency 1.4.2      Washington County Emergency Management Agency 1.4.3      Douglas County Emergency Management Agency

FCS EP-FC-1001 Section A Revision 0TBD Page 9 of 170 ASSIGNMENT OF ORGANIZATIONAL RESPONSIBILITY (ORGANIZATIONAL CONTROL) 1.4.4   Nebraska Health and Human Services, Regulation and Licensure 1.4.5   Region 5/6 Emergency Management Agency 1.4.6   Dodge County Emergency Management Agency 1.4.7   Sarpy County Emergency Management Agency 1.5  Iowa's Governmental Support Organizations 1.5.1   Iowa Homeland Security and Emergency Management Division 1.5.2   Iowa Department of Public Health 1.5.3   Harrison County Emergency Management Agency (via Board of Supervisors) 1.5.4   Pottawattamie County Emergency Management Agency (via Board of Supervisors) 1.5.5   Pottawattamie County Division of Communications 1.5.6   Crawford County Emergency Management Agency 1.6  Federal Government Support Organizations 1.6.1   U.S. Coast Guard 1.6.2   Environmental Protection Agency (EPA) 1.6.3   Department of Energy (DOE) 1.6.4   National Weather Service (NWS) 1.6.5   U.S. Nuclear Regulatory Commission (NRC) 1.6.6   Federal Emergency Management Agency (FEMA) Region VII 1.6.7   Federal Aviation Administration (FAA) 1.6.8   Department of the Interior, Branch of Global Seismology

FCS EP-FC-1001 Section A Revision 0TBD Page 10 of 170 ASSIGNMENT OF ORGANIZATIONAL RESPONSIBILITY (ORGANIZATIONAL CONTROL) 1.7  Industrial Support Organizations 1.7.1     Westinghouse Electric 1.7.2     Union Pacific Railroad 1.7.3     Institute of Nuclear Power Operations (INPO) 1.7.4     Institute of Nuclear Power Operations/Electric Power Research Institute/Nuclear Energy Institute 1.8  Other Support Organizations 1.8.1     Metropolitan Utilities District 1.8.2     Nebraska Public Power District (Cooper Nuclear Station) 1.8.3     National Weather Service 1.9  Monitoring and Decontamination Support Organizations 1.9.1     Omaha Fire Department Emergency Worker Decon 2.0  OPPD CONCEPT OF EMERGENCY OPERATIONS 2.1  OPPD's overall goals are to mitigate any emergency conditions which may occur at the Fort Calhoun Station and to provide information and support to State and Local agencies needed to protect the health and safety of the general public.
2.2  A predesignated group is assigned to various roles to ensure capable emergency response and mitigation at the Fort Calhoun Station. These assignments are made to ensure that the administrative, managerial and technical support needed for accident mitigation are met. A sufficient number of individuals are assigned to these positions to ensure around-the-clock and continued long term support.
2.3  Responsibility for emergency response initially lies with the Shift Manager. The Shift Manager may be relieved of the task of implementing the RERP by the Control Room Coordinator. If the Technical Support Center (TSC) is activated, command and control may be transferred to the Site Director. The Emergency Director in the Emergency Operations Facility (EOF) may assume command and control if that facility is activated.
The command and control position is responsible for ensuring the continuity of resources throughout an event.

FCS EP-FC-1001 Section A Revision 0TBD Page 11 of 170 ASSIGNMENT OF ORGANIZATIONAL RESPONSIBILITY (ORGANIZATIONAL CONTROL) 3.0  LETTERS OF AGREEMENT 3.1  Letters of agreement between OPPD and the organizations outlining their roles in the event of an emergency are on file with the Fort Calhoun Station Emergency Planning Department. These letters are reviewed annually in accordance with Emergency Preparedness recurring tasks.

FCS EP-FC-1001 Section A Revision 0TBD Page 12 of 170 ASSIGNMENT OF ORGANIZATIONAL RESPONSIBILITY (ORGANIZATIONAL CONTROL)
Figure A Organizational Interrelationships

FCS EP-FC-1001 Section B Revision 0TBD Page 13 of 170 ORGANIZATIONAL CONTROL OF EMERGENCIES 1.0 PURPOSE AND SCOPE 1.1 Purpose 1.1.1   This PSRERP Section establishes the organizational requirements, reporting locations and duties for the Fort Calhoun Station (FCS) Emergency Response Organization (ERO).
1.2 Scope 1.2.1   The positions established in this PSRERP Section upon declaration of an emergency will comprise the ERO. The EROs responsibility is to mitigate the consequences of an event using the facilities and resources described elsewhere in the PSRERP and the supporting Emergency Plan Implementing Procedures (EPIP).
2.0 DEFINITIONS None 3.0 RESPONSIBILITIES 3.1 Emergency Response Organization (ERO):
3.1.1   OPPD has issued a resolution which authorizes the ERO to provide an immediate and decisive response to mitigate the consequences of any nuclear emergency and for the protection of the health and safety of the public. Resolution No. 4731, as approved by the Board of Directors on January 15, 1998, is Appendix D of the PSRERP.
3.1.2   The ERO is intended to provide a pre-qualified organization capable of fulfilling the actions described above. The ERO is not confined to utilize only those personnel that are currently listed as qualified. Other OPPD personnel may be assigned and utilized to perform necessary functions at the discretion of the Command and Control positions. Assignment of any non-ERO qualified individual(s) should include adequate instruction to ensure the individual(s) is capable of performing the necessary functions and is knowledgeable of any potential hazards associated with responding to the designated facility.
3.2 Command and Control:
3.2.1   The position performing the duties of the Emergency Director is referred to as the Command and Control Position.

FCS EP-FC-1001 Section B Revision 0TBD Page 14 of 170 ORGANIZATIONAL CONTROL OF EMERGENCIES 3.2.2  The Command and Control position has the following responsibilities that cannot be delegated to other personnel. The position may assign other personnel to assist in conducting the actions necessary, but the responsibility of their completion rests with the position, until relieved by another Command and Control position or qualified individual, or the emergency is terminated:
A. Overall command and control of the ERO.
B. Ensuring that the proper classification of the emergency has been made in accordance with the established EAL/Classification scheme and is periodically reviewed to determine if the classification should be upgraded, downgraded or terminated.
C. Ensuring that all required notifications are made to appropriate state, local and federal officials.
D. Ensuring that appropriate Protective Action Recommendations (PARs) are provided to offsite officials.
E. Authorizing OPPD emergency worker exposure extensions beyond the Federal Radiation Protection Guidance.
F. Authorizing issuance of Potassium Iodide for OPPD emergency workers.
3.2.3  The Command and Control position also has the following responsibilities that can be delegated to other personnel, as necessary:
A. Requests for assistance from federal agencies.
B. Authorizing any emergency information to be released to the media or the general public.
C. Coordinating the transfer of the emergency information from the ERO to other OPPD and non-OPPD organizations called upon to assist.
D. Ensuring a timely and complete turnover of information to any qualified relief.
E. Declaring the termination of an emergency and transfer into a Recovery Operations Organization, when appropriate.
F. Providing information to the authorized representatives of the states of Nebraska and Iowa, and associated local governments.
G. Ensuring that the plant is in compliance with Technical Specifications and other licensee conditions, and if deviations are necessary to protect the public health and safety, they are approved, as a minimum, by a Senior Reactor Operator, prior to taking the action.

FCS EP-FC-1001 Section B Revision 0TBD Page 15 of 170 ORGANIZATIONAL CONTROL OF EMERGENCIES 4.0 PROCEDURE 4.1 ERO Staff On-Shift 4.1.1     The staffing of the normal operating organization for each shift is shown in Table B-1. This staffing consists of, as a minimum:
One Shift Manager (Senior Reactor Operator (SRO)/Certified Fuel Handler (CFH))
One Unit Control Room Supervisor Operator (Senior Reactor OperatorSRO or Reactor Operator (RO)/CFH)
Two Reactor Operators TwoOne Equipment Operators/Non-Certified Operator (NCO)
One Control Room Communicator One Chemistry Technician One Radiation Protection Technician One Habitability Technician One Shift Technical Advisor Additionally, there are several shift Security personnel assigned 4.1.2     All or part of these shift personnel may comprise the initial ERO, and are responsible for taking immediate protective measures in any emergency and implementing this Post-Shutdown Radiological Emergency Response Plan when necessary.
4.2 Activation of the ERO 4.2.1     At a Notification of Unusual Event (NOUE), the Shift Manager may elect to not activate the ERO. In this instance, a notification to certain management personnel is performed and other personnel may be notified to assist as necessary.
A. If the Shift Manager elects to activate the ERO, the notification process will call out the entire ERO (with the exception of the JIC).
4.2.2     It is OPPDs goal that the ERO personnel can staff their emergency positions within one hour following declaration of an Alert or higher classification. In the event of adverse weather and/or other conditions that may limit or slow response, either manmade or natural, it is understood that staffing time may exceed this goal.
4.3 Facility Activation and Operation 4.3.1     There are some functional group activities that may be performed within an Emergency Response Facility prior to actually activating the facility. To be beneficial to the Command and Control facility, these activities, such as dose

FCS EP-FC-1001 Section B Revision 0TBD Page 16 of 170 ORGANIZATIONAL CONTROL OF EMERGENCIES assessment and field team functions, are dependent upon the establishment of proper communications between the facilities.
4.3.2  OPPD Emergency Response Facilities are considered activated when minimum staffing and basic setup requirements have been attained to allow the facility to provide minimum support to the operating staff and other facilities.
A. It is OPPDs goal that the OSC, EOF and TSC be activated within one hour following an Alert classification. The JIC will be activated following a Site Area or General Emergency classification, and can be activated at an earlier classification based on the decisions of the Corporate Communications Division.
4.3.3  Minimum staffing for activation of the OSC is as follows:
One OSC Director One Radiation Protection Technician or Radiation Protection Coordinator One other person to form a team 4.3.4  Minimum staffing for activation of the TSC is as follows:
One Site Director One TSC COP Communicator One TSC Protective Measures Coordinator One Reactor SafetyEngineering Coordinator 4.3.5  Minimum staffing for activation of the EOF is as follows:
One Emergency Director One EOF COP Communicator One EOF Protective Measures Manager or EOF Dose Assessment Coordinator One EOF Dose Assessment Specialist 4.3.6  OPPD Emergency Response Facilities are considered augmented when all minimum and augmenting staffing positions are filled.
4.3.7  Selected support staff, which assists the minimum and augmenting staff, is shown on Attachment 1 - Table B OPPD Emergency Response Organization (ERO) Functions and Shift Staff Augmentation Plan. The support staff is intended to supplement and enhance operation of their respective facilities. Additional personnel may respond.
4.3.8  If a toxic chemical/hazardous material or other significant event occurs that threatens the habitability of the station, an option exists to have all or part of

FCS EP-FC-1001 Section B Revision 0TBD Page 17 of 170 ORGANIZATIONAL CONTROL OF EMERGENCIES the TSC and OSC staffs report to the EOF to provide assistance as necessary.
4.3.9  Some ERO personnel may elect to maintain an assistant position. This is acceptable when additional coordination of activities is required or to aid in the turnover process. The primary assignee must maintain overall responsibility of the position, and ensure that 24 hour staffing of the position can be implemented.
4.4 Command and Control Positions 4.4.1  The positions that have Emergency Director Authority are:
The Shift Manager The Control Room Coordinator The Site Director The EOF Emergency Director 4.4.2  The Shift Manager ERO duties are to:
A. Perform as Emergency Director until properly relieved by a qualified position.
B. Direct medical and fire response efforts.
C. Coordinate in-plant operations response with the TSC and OSC. After being relieved by another Command and Control position, the Shift Manager will provide assistance and direction to the Control Room staff as necessary.
C.D.        Ensure Control Room communications are established with the TSC, OSC, and EOF.
4.4.3  The Control Room Coordinator position is intended to provide a prompt transition of Command and Control functions from the Shift Manager within the Control Room complex. This position may assume Command and Control at any emergency classification, and is not dependent on the reporting or activation of any other portion of the ERO.
            . The Control Room Coordinator duties are to promptly relieve the Shift Manager and perform as Emergency Director until properly relieved by a qualified position. Additional duties of the Control Room Coordinator are to:
: 0. Ensure a qualified Control Room Operations Liaison establishes communications with the TSC, OSC and EOF to provide operational information.

FCS EP-FC-1001 Section B Revision 0TBD Page 18 of 170 ORGANIZATIONAL CONTROL OF EMERGENCIES
: 0. Coordinate in-plant operations response with the TSC and OSC.
: 0. Assist the Shift Manager and on-shift operators with plant operations.
4.4.84.4.3     The Site Director position is intended to assume Command and Control functions from the Control Room if the EOF is not available or cannot assume Command and Control. This position may assume Command and Control at any emergency classification. The Site Director may assume Command and Control in the Control Room proper at any time. If the Site Director elects to assume Command and Control within the TSC, the TSC must meet activation requirements.
A. The Site Director duties are to promptly relieve the Control Room Command and Control position and perform as Emergency Director until properly relieved by a qualified position, if the EOF is not available or cannot assume Command and Control. Additional duties of the Site Director are to:
: 1. Manage the onsite activities of the ERO.
: 2. Keep the Emergency Director informed of those onsite activities as necessary.
4.4.94.4.4     The EOF Emergency Director position is intended to assume all Command and Control functions from the plant site. This position may assume Command and Control at any emergency classification, but the EOF must meet activation requirements prior to the transfer of Command and Control duties.
A. The Emergency Director duties are to promptly relieve the onsite Command and Control position and perform as Emergency Director until properly relieved by a qualified position or termination of the emergency response phase.
4.5 Control Room Positions 4.5.1     The following positions are on-shift staff, and augmenting positions for the Control Room. Additional Control Room support staffing is identified on Attachment 2 - Figure B Fort Calhoun Station Emergency Response OrganizationAttachment 2 - Figure B Fort Calhoun Station Emergency Response OrganizationAttachment 2 - Figure B Fort Calhoun Station Emergency Response Organization. Control Room on-shift staff positions are:
A. Shift Managers duties are described in Sections 4.2, 3.2 and 4.4.2.

FCS EP-FC-1001 Section B Revision 0TBD Page 19 of 170 ORGANIZATIONAL CONTROL OF EMERGENCIES B. Unit Control Room Supervisor Operator duties include:
aAssessment of plant conditions, eEnsuring requirements of the AOPs and EOPs are met, and supervision of on-shift operations staff.
Notifications as directed by the Shift Manager. These notifications include the following:
o Required notifications to the states and counties o Notifications to the Emergency Response Organization B. Reactor Operators (2) duties include implementation of the AOPs and EOPs under the direction of the Unit Supervisor.

FCS EP-FC-1001 Section B Revision 0TBD Page 20 of 170 ORGANIZATIONAL CONTROL OF EMERGENCIES C. Control Room Communicator duties include notifications as directed by the Control Room Command and Control position. These notifications include the following:
Required notifications to the states and counties Notifications to the Emergency Response Organization D.C.       Equipment Operators/NCO (2) duties include making repairs and corrective actions on plant equipment until augmented plant maintenance staff arrives. NCOs also assist in performing notifications/communications and dose assessment as needed.
E. Shift Technical Advisor duties include providing technical support for plant systems, engineering, providing input on repair and corrective actions and making initial notifications to the NRC.
F. Shift Chemistry Technician duties include chemistry and radiochemistry analysis, radiological accident assessment and support and offsite dose assessment.
G.D.       Shift Radiation Protection Technician duties include conducting radiological accident assessment and support, offsite dose assessment and onsite in-plant surveys.
               . Habitability Technician duties include conducting surveys and verifying Control Room habitability using available equipment and initiating protective actions if needed.
4.5.34.5.2                             The Control Room (CR) Operations Liaison is an augmenting positions are:. Duties include transmitting plant status/Control Room information, etc. to the TSC, OSC, and EOF.
A. Coordinator duties are described in Section 3.2 and 4.4.3.
B. Operations Liaison duties include transmitting plant status/Control Room information, etc. to the TSC and, EOF. and OSC Operations Liaison positions.
C. ENS Communicator duties include maintaining an ENS link with the NRC.
D. Equipment Operator duties include providing operations support to repair teams.

FCS EP-FC-1001 Section B Revision 0TBD Page 21 of 170 ORGANIZATIONAL CONTROL OF EMERGENCIES 4.6 Technical Support Center Positions 4.6.1    The following are minimum staffing and augmenting positions for the Technical Support Center (TSC). Additional TSC support staffing is identified on Attachment 2 - Figure B Fort Calhoun Station Emergency Response OrganizationAttachment 2 - Figure B Fort Calhoun Station Emergency Response OrganizationAttachment 2 - Figure B Fort Calhoun Station Emergency Response Organization. Minimum staffing positions for the TSC are:
A. Site Director duties are described in Steps 3.2 and 4.4.3.
B. Reactor SafetyEngineering Coordinator duties include:
: 1. Directing the activities of the engineering staff resources requested by in the TSC.
: 2. Analyzing plant problems and providing recommendations for plant modifications to mitigate the effects of the accident.
: 3. Directing core damage assessment calculations.
: 43. Directing the evaluation ofEvaluating possible radiological release paths to the environment.
C. Protective Measures Coordinator duties include:
: 1. Coordinating the dispatch of the TSC field team from the site and performing field team direction until the EOF assumes this duty.
: 2. Monitoring and coordinating on site dose assessment operations performed, and keep the Site Director informed of dose projections and field sample results.
: 3. Evaluating site radiological conditions, and necessary personnel protective measures.
: 4. Evaluating and making recommendations for plant evacuation and evacuation routes.
: 5. Preparing and submitting state update information, including Protective Action Recommendations, to the Site Director for approval and transmittal to state and federal officials if TSC has Command and Control.

FCS EP-FC-1001 Section B Revision 0TBD Page 22 of 170 ORGANIZATIONAL CONTROL OF EMERGENCIES D. COP Communicator duties include performing notifications as directed by the Command and Control position. These notifications include the following:
Required notifications to states and counties Required notifications to the NRC Notifications to the Emergency Response Organization. This position also assists in maintaining status boards within the TSC 4.6.2     Augmenting positions for the TSC are:
A. TSC Field Team duties include providing off-site monitoring in the areas potentially affected by a radiological release.
B. I&C Electrical Systems Engineer duties include providing engineering analysis and troubleshooting in that field of expertise.
B. Operations Liaison duties include:
: 1. Obtaining plant status/Control Room information from the Control Room Operations Liaison and transmitting this information to the TSC staff as needed. [AR 11390]
: 2. Assisting the Site Director in formulating appropriate protective action recommendations when necessary. [AR 11390]
                  . Primary Systems Engineer duties include providing engineering analysis and troubleshooting in that field of expertise.
4.84.7 Operations Support Center Positions 4.8.14.7.1    The following are minimum staffing and augmenting positions for the Operations Support Center (OSC). Additional OSC support staffing is identified on Attachment 2 - Figure B Fort Calhoun Station Emergency Response OrganizationAttachment 2 - Figure B Fort Calhoun Station Emergency Response OrganizationAttachment 2 - Figure B Fort Calhoun Station Emergency Response Organization. Minimum staffing positions for the OSC are:
B. OSC Director duties include:
: 1. Coordinating the development of plans for required maintenance activities.
: 2. Keeping the Site Director informed of OSC activities.

FCS EP-FC-1001 Section B Revision 0TBD Page 23 of 170 ORGANIZATIONAL CONTROL OF EMERGENCIES
: 3. Coordinating emergency team response as requested by the TSC/Control Room to perform search and rescue, damage assessment, damage control, repair and modification, and in-plant radiological monitoring.
C. Radiation Protection Technician duties include coordination of on-site radiation protection activities.
D. One other person to form a team.
4.8.24.7.2    Augmenting positions for the OSC are:
A. Chemistry Technician duties include evaluating and performing all chemistry activities on-site. Act as Chemistry Coordinator until relieved.
B. Dosimetry Technician duties include issuing Dosimetry and performing dose extensions as needed.
C.B.         Electrical Maintenance Technicians (two positions) duties include providing repairs and corrective actions for plant electrical equipment as directed.
D.C.         I&C Technician duties include providing repairs and corrective actions to plant instruments as directed.
E.D.         Machinist or Steam Fitter Mechanic duties include providing repairs and corrective actions to plant mechanical equipment as directed.
F. Operations Liaison duties include obtaining plant status/Control Room information from the Control Room Operations Liaison and transmitting this information to the OSC staff as needed. [AR 11390]
G.E.         Radiation Protection Technicians (five three positions) duties include providing radiological surveys and job coverage to repair and corrective action teams as directed.
H.F.         The Radiation ProtectionProtective Measures Coordinator duties include coordinating all radiation protection activities onsite.:
: 1. Forming and preparing emergency response teams as directed by the OSC Director.
: 2. Coordinating all radiation protection activities onsite.
: 3. Keeping the OSC Director and TSC Protective Measures Coordinator informed of the status of all radiation protection activities onsite.

FCS EP-FC-1001 Section B Revision 0TBD Page 24 of 170 ORGANIZATIONAL CONTROL OF EMERGENCIES
: 4. Fulfilling the minimum staffing position of Radiation Protection Technician, if required.

FCS EP-FC-1001 Section B Revision 0TBD Page 25 of 170 ORGANIZATIONAL CONTROL OF EMERGENCIES 4.8   Emergency Operations Facility Positions 4.8.2     The following positions are minimum staffing and augmented positions for the Emergency Operations Facility (EOF). Additional EOF support staffing is identified on Attachment 2 - Figure B Fort Calhoun Station Emergency Response OrganizationAttachment 2 - Figure B Fort Calhoun Station Emergency Response OrganizationAttachment 2 - Figure B Fort Calhoun Station Emergency Response Organization. Minimum staffing positions for the EOF are:
A. Emergency Director Duties duties are described in Section 3.2 and 4.4.54.4.4.
B. COP Communicator duties include performing notifications as directed by the Command and Control position. These notifications include the following:
Required notifications to states and counties Required notifications to the NRC Notifications to the Emergency Response Organization. This position also assists in maintaining status boards within the EOF NOTE i     Only one of the positions described in Step 4.8.1C or Step 4.8.10 is required for minimum staffing.
i C. Protective Measures Manager duties include:
: 1. Monitoring Directing dose assessment operations performed, coordinating OPPD field teams, and keeping the Emergency Director informed of projections and field survey results.
: 2. Evaluating site radiological conditions and necessary personnel protective measures.
: 3. Preparing and submitting state update information, including Protective Action Recommendations, to the Emergency Director, state and federal officials.
: 4. Coordinating technical briefings for the offsite agencies as requested.

FCS EP-FC-1001 Section B Revision 0TBD Page 26 of 170 ORGANIZATIONAL CONTROL OF EMERGENCIES A. Dose Assessment Coordinator duties include:
: 7. Directing offsite dose assessments and the associated Protective Action Recommendations (PARs).
: 8. Coordinating OPPD field teams.
9.5. Comparing dose projections against field team results.
10.6. Comparing dose projections and field team results with state and federal agency results.
D. Dose Assessment Specialist duties include performing offsite dose assessments and submitting the results to the Emergency Director for approval and transmittal to state and federal officials.
4.8.3  Augmenting positions for the EOF are:
A. Administrative Logistics Manager duties include:
: 1. Coordinating administrative personnel support to the EOF.
: 2. Coordinating scheduling and callout of ERO personnel for 24 hour coverage.
: 3. Activating the Alert Notification System as requested.
: 4. Coordinating OPPD resources for the establishment of emergency logistics for the ERO, such as food, beverages, medical and administrative supplies, transportation, special equipment, etc.
B. The EOF Field Team duties include providing off-site monitoring in the areas potentially affected by a radiological release.
: 1. Field Team Specialist duties include coordinating the activities of the OPPD and state Field Teams to achieve the most efficient use of teams for plume tracking.
C. Information Specialist duties include:
: 1. Preparing information for use in periodic press releases.
: 2. At an Alert or higher emergency classification, submitting all press releases to the Emergency Director (or designee) for approval prior to forwarding the release to the JIC.

FCS EP-FC-1001 Section B Revision 0TBD Page 27 of 170 ORGANIZATIONAL CONTROL OF EMERGENCIES D. Operations Liaison duties include: 1) obtaining plant status/Control Room information from the Control Room Operations Liaison and transmitting this information to the EOF and NRC staff as needed; and,
: 2) assisting the Emergency Director in the review of classifications and formulating appropriate protective action recommendations when necessary. [AR 11390]
4.9  Joint Information Center Positions 4.9.2     The Joint Information Center Manager duties include:
A. Coordinating with government authorities and to provide periodic briefings and news releases to news media personnel.
B. Providing public inquiry services.
C. Keeping OPPD personnel, including senior management, informed of the status of the emergency and emergency response effort. OPPDs Corporate Crisis Communication Plan lists other JIC positions.
4.10 Emergency Response Organization Interface with Onsite and Offsite Organizations 4.10.2    Attachment 2 - Figure B Fort Calhoun Station Emergency Response OrganizationAttachment 2 - Figure B Fort Calhoun Station Emergency Response OrganizationAttachment 2 - Figure B Fort Calhoun Station Emergency Response Organization illustrates the interface between the EOF and other onsite support centers. Attachment 2 - Figure B Organization InterrelationshipsAttachment 2 - Figure B Organization InterrelationshipsAttachment 2 - Figure B Organization Interrelationships illustrates the interface of the EOF with federal, state, and local support agencies.
4.10.3    The EOF interfaces with each of the onsite support centers on a continuous basis. Even though the EOF serves as the primary interface with the various offsite support agencies, the TSC interfaces with various contractors and vendors to gather needed design data, consultation, and evaluation concerning the plant's status.
4.11 Emergency Response Organization Notification 4.11.2    Emergency Response Organization notification occurs as shown in Sections E and M of the PSRERP. The Shift Manager is responsible for initiation of the notification process after an emergency condition has been classified.

FCS EP-FC-1001 Section B Revision 0TBD Page 28 of 170 ORGANIZATIONAL CONTROL OF EMERGENCIES 4.12 Service Provided by Local Agencies 4.12.2   The Nebraska State Patrol and the Washington County Sheriff's Department have agreed to provide the primary law enforcement support to the Fort Calhoun Station Security Department.
4.12.3   The Blair Volunteer Fire Department has agreed to provide the primary fire support services for the Fort Calhoun Station. The Fort Calhoun Volunteer Fire Department has agreed to provide backup fire response.
4.12.4   OPPD vehicles may transport non-injured potentially contaminated personnel. The Blair Volunteer Fire Department has agreed to provide primary rescue and transportation support, for injured and/or contaminated personnel. The Fort Calhoun Volunteer Fire and Rescue, Missouri Valley Fire and Rescue and the Council Bluffs Ambulance and Fire Departments have agreed to provide backup services.
4.12.5   The Blair Hospital has agreed to provide medical support for work related injuries. Nebraska Health Services University Hospital in Omaha, maintains a regional Radiation Health Center which provides services for the treatment of radiologically contaminated injuries and radiation exposure evaluation.
4.12.6   The majority of the organizations listed in this section maintain a Letter of Agreement with OPPD. These letters are on file in the Emergency Planning Department at the Fort Calhoun Station.
5.0  RETENTION/RECORDS None

==6.0  REFERENCES==
AND COMMITMENTS 6.9  AR 11390, LIC-065R 6.10 Fort Calhoun Station Analysis of Proposed Post-Shutdown On-Shift Staff, August 2016EP-FC-1001 Addendum 1, On-Shift Staffing Analysis Report.
7.0  ATTACHMENTS 7.9  Attachment 1 - Table B OPPD Emergency Response Organization (ERO)
Functions and Shift Staff Augmentation Plan 7.10 Attachment 2 - Figure B Normal Fort Calhoun Station Management OrganizationAttachment 2 - Figure B Normal Fort Calhoun Station Management OrganizationAttachment 2 - Figure B Normal Fort Calhoun Station Management

FCS EP-FC-1001 Section B Revision 0TBD Page 29 of 170 ORGANIZATIONAL CONTROL OF EMERGENCIES Organization 7.11 Attachment 2 - Figure B Fort Calhoun Station Emergency Response OrganizationAttachment 2 - Figure B Fort Calhoun Station Emergency Response OrganizationAttachment 2 - Figure B Fort Calhoun Station Emergency Response Organization 7.12 Attachment 2 - Figure B Organization InterrelationshipsAttachment 2 - Figure B Organization InterrelationshipsAttachment 2 - Figure B Organization Interrelationships

FCS EP-FC-1001 Section B Revision 0TBD Page 30 of 170 ORGANIZATIONAL CONTROL OF EMERGENCIES Attachment 1 - Table B OPPD Emergency Response Organization (ERO) Functions and Shift Staff Augmentation Plan NUREG 0654                                               Omaha Public Power District Goals for 1 hour On Shift Minimum Major Functional Area           Major Tasks           Emergency Positions                                  Augmentation Minimum Number/Title Number/Title Plant Operations and                                Shift Manager (SRO)      1 Shift Manager Assessment of                                       Shift Foreman (SRO)      (SRO/CFH)
Operational Aspects                                 Control Room Operators   1 Unit Control Room Auxiliary Operators      Operator (SRO or RO/CFH)***
Supervisor(SRO) 2 Reactor Operators (RO) 21 Equipment Operators/NCO Emergency Command                                   Shift Technical Advisor, 1** Shift Manager             1 CR Coordinator OR and Control                                         Shift Manager or                                       1 Site Director OR (Emergency                                          designated Facility                                    1 Emergency Director Coordinator)*                                       Manager Notification/           Notify License, State local                          1 Control Room                1 CR ENS Communicator Communication           and Federal personnel                                Communicator 1 Control        1 Communicator in TSC and maintain                                         Room Operator (SRO or         1 Communicator in EOF communication                                        RO/CFH)***
Radiological Accident   Emergency Operations        Senior Manager                                         1 Emergency Director Assessment and          Facility (EOF) Director Support of Operational Accident Offsite Dose Assessment     Senior Health Physics    1 R.P Technician              1 Prot. Meas. Coord Assessment                                          (HP) Expertise Offsite Surveys                                                                    4 Field Team Technicians 2 R.P. Technicians Onsite (Out of plant)                                                              2 1 R.P. Technicians In Plant surveys                                     1 Habitability Technician Chemistry/Radiochemistry                             1 Chemistry Technician        1 Chemistry Technician Plant System            Technical Support           Shift Technical Advisor  1 Shift Technical Advisor***
Engineering, Repair and                                                 Core/Thermal hydraulics                                1 Reactor Corrective Actions                                  Electrical                                             SafetyEngineering Coord 1 Electrical and I&C Mechanical                                             Engineer 1 Primary Systems Repair and Corrective       Mechanical Maintenance   1** Equipment                 Engineer Actions                                              Operator/NCO                  1 Machinist OR Steam Fitter Mechanic Electrical Maintenance 1** Equipment                 1 Equipment Operator/NCO                  Operator/NCO Instrument and Control                                 2 1 Electrical Maintenance (I&C) Technician                                       Technicians 1 I&C Technician Protective Actions      Radiation Protection:       HP Technicians           2 1** R.P . Technicians       2 1 R.P. Technicians (Plant)                 a. Access Control                                                                  1 R.P. Coordinator
: b. HP Coverage for repair,                                                         1 Dosimetry Technician corrective actions, search and rescue, first aid and firefighting
: c. Personnel monitoring
: d. Dosimetry Firefighting                                                                 Fire Brigade per SO-G-        Blair Fire Department 28,Station Fire Plan Rescue Operations and                                                        2** Equipment                 Blair Rescue Squad First Aid                                                                    Operators/NCOs

FCS EP-FC-1001 Section B Revision 0TBD Page 31 of 170 ORGANIZATIONAL CONTROL OF EMERGENCIES NUREG 0654                                          Omaha Public Power District Goals for 1 hour On Shift Minimum Major Functional Area           Major Tasks        Emergency Positions                             Augmentation Minimum Number/Title Number/Title Site Access Control and  Security, Firefighting,  Security Personnel   All per Security Plan Personnel                communications, Accountability           personnel accountability
* Emergency Command and Control responsibility is transferred in accordance with Section B of this plan.
** May be provided by Shift personnel assigned other functions.
***Performs initial notification to NRC.

FCS EP-FC-1001 Section B Revision 0TBD Page 32 of 170 ORGANIZATIONAL CONTROL OF EMERGENCIES Attachment 2 - Figure B Normal Fort Calhoun Station Management Organization The Fort Calhoun Organization is described in Chapter 12 of the USAR.

EP-FC-1001 Section B FCS                                                                                               Revision 0TBD Page 33 of 170 ORGANIZATIONAL CONTROL OF EMERGENCIES Attachment 2 - Figure B Fort Calhoun Station Emergency Response Organization

EP-FC-1001 Section B FCS                                        Revision 0TBD Page 34 of 170 ORGANIZATIONAL CONTROL OF EMERGENCIES

FCS EP-FC-1001 Section B Revision 0TBD Page 35 of 170 ORGANIZATIONAL CONTROL OF EMERGENCIES Attachment 2 - Figure B Organization Interrelationships

FCS EP-FC-1001 Section C Revision 0TBD Page 36 of 170 EMERGENCY RESPONSE SUPPORT AND RESOURCES 1.0 FEDERAL RESPONSE 1.1 Personnel Authorized to Request Federal Assistance The Emergency Director typically coordinates with the states to secure federal assistance. However, the Emergency Director may also request federal assistance directly, if timely assistance has not been provided as requested by the states. The states will be kept informed of such requests.
1.2 Federal Response Organizations The Federal Radiological Emergency Response Plan (FRERP) and the Federal Response Plan (FRP) outline the federal response to any type of emergency, including an emergency at a fixed nuclear facility. Some of the typical federal organizations which could respond to an emergency at the Fort Calhoun Station are as follows:
1.2.1 U.S. Coast Guard Upon notification, the U.S. Coast Guard will control traffic on the Missouri River in the area of Fort Calhoun Station. They will provide waterborne patrols for extended periods if contamination levels persist.
A U.S. Coast Guard cutter is based at the Florence Boat Yard, approximately 18 river miles downstream of the Fort Calhoun Station.
1.2.2 U.S. Environmental Protection Agency (EPA)
Upon request, the EPA will provide trained manpower to assist in reviewing survey data, offsite evaluations and advise on protective actions for the public.
They also provide assistance in the collection and analysis of environmental samples.

FCS EP-FC-1001 Section C Revision 0TBD Page 37 of 170 EMERGENCY RESPONSE SUPPORT AND RESOURCES 1.2.3  U.S. Department of Energy (DOE)
DOE is the technical support branch of the Federal Radiological Emergency Response Plan (FRERP). DOE would typically be the agency in charge of initial establishment and control of the Federal Radiological Monitoring and Assessment Center (FRMAC).
Some of the capabilities of DOE and the FRMAC operations are as follows:
A. Support to the state(s) in the coordination of offsite radiological monitoring assessment, evaluation, and reporting activities of all federal agencies during the initial phases of an accident and maintain a technical liaison with the states and local agencies with similar responsibilities.
B. Ensure the orderly transfer of responsibility for coordinating the intermediate and long term radiological monitoring function at the FRMAC to EPA after the initial phases of the emergency.
C. Provide the personnel and equipment required to coordinate and perform the offsite radiological monitoring and evaluation activities.
D. Assist the NRC in assessing the accident potential and in developing technical recommendations on protective measures.
E. Maintain a common set of offsite radiological monitoring data and provide this data and interpretation to the NRC and to appropriate state and local agencies requiring direct knowledge of radiological conditions and monitoring results.
F. Provide consultation and support services to all other entities (e.g.
private contractors) having radiological monitoring functions and capabilities.
G. Assist other federal, state and local agencies by providing technical and medical advice concerning treatment of radiological contamination.
H. Provide telecommunications support and capabilities.
I. Assist other federal agencies in developing and establishing guidelines on effective systems of emergency radiation detection and measurement, including instrumentation.

FCS EP-FC-1001 Section C Revision 0TBD Page 38 of 170 EMERGENCY RESPONSE SUPPORT AND RESOURCES 1.2.4  U.S. National Weather Service (NWS)
The National Weather Service operates on a twenty-four (24) hour per day basis. Upon request, this organization can provide the Fort Calhoun Station with meteorological conditions including predicted temperature inversions, precipitation, wind patterns and velocity.
1.2.5  U.S. Nuclear Regulatory Commission (NRC)
The NRC becomes the Lead Federal Agency (LFA) in a response to a fixed nuclear facility, such as the Fort Calhoun Station. In their role as LFA, the NRC will directly coordinate response activities with OPPD and determine the need for appropriate federal response organizations. The NRC will perform the function of LFA from several response locations including the NRC Operations Center, Region IV's Incident Response Center, all OPPD Emergency Response Facilities (once a site team has arrived), and other federal response facilities established.
1.2.6  Federal Emergency Management Agency (FEMA)
FEMA is responsible for coordinating the non-technical federal support to state and local governments which could include such tasks as logistics and telecommunications. The senior FEMA official on the scene will notify the federal agency(ies) most capable of meeting the state and local governmental needs. FEMA would take the lead at the federal Disaster Field Office, if such location is established. Fort Calhoun Station is located within FEMA, Region VII.
1.2.7  Federal Aviation Administration (FAA)
The FAA controls and directs air traffic in and around the affected area. The FAA has the authority to close the area surrounding the Fort Calhoun Station to all non-response air traffic.
1.2.8  U.S. Department of the Interior The U.S. Department of the Interior, Branch of Global Seismology has the capability to monitor and provide specific seismic activity data should such an event occur in the vicinity of the Fort Calhoun Station.

FCS EP-FC-1001 Section C Revision 0TBD Page 39 of 170 EMERGENCY RESPONSE SUPPORT AND RESOURCES 1.3 Response Times It is anticipated that response time will be based on the level of assistance provided.
For example, information on upcoming weather conditions would be expected to be available in a matter of minutes over the telephone from the National Weather Service.
Conversely, radiological assistance from the Department of Energy would be expected to take considerably longer. It is expected that the federal assistance requested would be available within 8 to 72 hours.
2.0 RESOURCES TO SUPPORT RESPONDING AGENCIES Resources are provided by OPPD in order to support the various federal organizations which respond to an emergency as follows:
2.1 Air fields are available for the use of the radiological monitoring teams as follows:
2.1.1       Eppley Air Field, 18 miles South of Fort Calhoun Station, on Abbott Drive in Sector G.
2.1.2       Eagle Field (City of Blair's Air Field), seven (7) miles Southwest of Fort Calhoun Station on State Hwy. 133 in Sector K.
2.1.3       North Omaha Airfield, eleven (11) miles South Southeast of Fort Calhoun Station, on North 72nd street in Sector H.
2.2 A laboratory for radioisotopic analysis is available at the Fort Calhoun Station and Cooper Nuclear Station near Brownsville, Nebraska.
2.3 A laboratory for non-radiological chemical analysis is available at the Fort Calhoun Station and OPPD's North Omaha Power Station.
2.4 Onsite and offsite survey teams with necessary radiation monitoring instruments are available.
2.5 A boat is available for obtaining river samples.
2.6 Space and communication lines have been set aside to accommodate some federal agencies at the Control Room, Technical Support Center, Emergency Operations Facility, and Joint Information Center.
2.7 Electrical and communication access is available at the Emergency Operations Facility for the federal mobile analytical laboratory.

FCS EP-FC-1001 Section C Revision 0TBD Page 40 of 170 EMERGENCY RESPONSE SUPPORT AND RESOURCES 3.0 SITE REPRESENTATIVES The Nebraska State Governor's Authorized Representative (GAR) reports to the state Field Command Post, located at OPPD's Emergency Operations Facility. The GAR is in direct contact with OPPD personnel and has the authority to approve and issue all protective actions for the public in the State of Nebraska.
The State of Iowa's Governor's Authorized Representative (GAR) typically remains in the State Emergency Operations Center. The Iowa GAR has the authority to approve and issue all protective actions for the public in the State of Iowa. A command and control telephone link exists between this position and OPPD's EOF. If personnel are available, an Iowa liaison is sent to work directly with the staff at the EOF.
An OPPD Site Representative is available for dispatch from the utility to the Iowa State EOC. This position can be staffed on a 24 hour a day basis.
4.0 RADIOLOGICAL ASSISTANCE 4.1 Nebraska Public Power District (Cooper Nuclear Station)
The Cooper Nuclear Station is capable of providing a backup facility in the event Fort Calhoun's radiochemistry laboratory is not functional. The Cooper Station's radiochemistry laboratory is equipped to do gross and isotopic determinations on radionuclides in concentrations and counting geometries necessary for nuclear power plant operation and emergency monitoring. They will provide analysis of liquid, air particulate and cartridges on a priority basis after receiving the sample.
Additionally, Cooper Station could provide monitoring teams equipped with air sampling, radiation and contamination monitoring equipment.
4.2 Contractor Assistance In the event of an emergency, it is anticipated that further assistance could be contracted directly from firms currently being utilized by OPPD for non-emergency work at the Fort Calhoun Station or through the assistance of such organizations as the Institute of Nuclear Power Operations (INPO).
4.3 The analysis of field monitoring data by the states is specified in each respective state plan. OPPD field monitoring data can be analyzed by an independent facility providing such services.

FCS                                                                  EP-FC-1001 Section D Revision 0TBD Page 41 of 170 EMERGENCY CLASSIFICATION SYSTEM

==1.0 INTRODUCTION==

1.1 This section describes the emergency classification scheme adopted by the Omaha Public Power District for Fort Calhoun Station. The Emergency Classification scheme is based on NEI-99-01, Revision 56, Methodology for Development of Emergency Action Levels for Non-Passive Reactors.
1.2 The State of Nebraska and the State of Iowa review the Fort Calhoun Station EALs once per year to ensure that they are consistent with their respective emergency classification schemes in their respective emergency plans. The purpose of this standardized classification is to provide a framework within which all emergency actions can be taken and notifications can be made in response to abnormal plant situations.
1.3 Table D-1 shows the projected worst case emergency classification for certain postulated accidents identified in the Fort Calhoun Station Updated Safety Analysis Report.
2.0 CLASSIFICATION OF EMERGENCIES 2.1 Emergency conditions are classified into one of four severity levels which cover the spectrum of postulated accidents. The postulated accidents range from precursors to potential degradation of plant safety to those involving actual failure of plant safety systems. Emergency preparedness, including a standardized classification system, is based primarily on preventing or minimizing radiation exposure to individuals onsite and offsite.
2.2 The specific Initiating Conditions (ICs) are contained within EP-FC-1001 Addendum 3, Emergency Action Levels For Fort Calhoun Station. The ICs are based on one or more of the key types of initiating conditions, including; symptom based, event based, barrier breach, and essential equipment/system(s) out of service. The ICs at Fort Calhoun Station are presented using six recognition categories as listed below:
R - Abnormal Rad Levels/Radiological Effluent C - Cold Shutdown/Refueling System Malfunction E - Events Related to ISFSI F - Fission Product Barrier Degradation H - Hazards and Other Conditions Affecting Plant Safety M - System Malfunction

FCS                                                                      EP-FC-1001 Section D Revision 0TBD Page 42 of 170 EMERGENCY CLASSIFICATION SYSTEM 2.3 Each one of the recognition categories contains ICs as outlined in EP-FC-1001 Addendum 3, Emergency Action Levels For Fort Calhoun Station. Each specific IC is detailed in individual sections which contain predetermined, site-specific, observable thresholds, such as; instrument readings, equipment status indicators, measurable parameter(s), discrete and observable event(s), results of analysis, entry into specific emergency/abnormal procedures, applicable operating mode(s), and/or any other cautions and/or notes pertaining to that particular IC.
2.4 To the extent feasible, the ICs are based on readily available information such as Control Room instrumentation readings, Emergency Response Facility Computer System (ERFCS) output, specific station procedure steps, and/or dose projection results. The intent is to eliminate "ambiguity" for command and control positions in determining appropriate emergency classifications. Immediate actions to be taken in response to conditions involving abnormal plant operating parameters are detailed in the Fort Calhoun Station Emergency Operating Procedures, Abnormal Operating Procedures and Operating Instructions. Other immediate actions and follow-up actions are identified in Section J of this plan and are described in detail in applicable Emergency Plan Implementing Procedures, listed in Appendix C of this plan.
2.5 The ICs do not signify the need for immediate implementation of protective or corrective measures. They do, however, signify the need for implementation of dose assessment measures both onsite and offsite and assessment of plant status, as applicable.
2.6 In using the ICs as the basis for initiating emergency response activity, there may be instances when the plant operating staff cannot determine which of two emergency classifications is appropriate for a particular occurrence. In those cases where the appropriate classification can not be defined in a short period of time, the occurrence should be treated as the higher of the two classifications and the appropriate response for that level should be initiated.
2.7 Notification of Unusual Event 2.7.1      Notification of Unusual Event (NOUE) - Events are in process or have occurred which indicate a potential degradation of the level of safety of the plant 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 safety systems occurs. Some of these events could indicate a potential degradation in the level of plant safety and/or could escalate to a more severe condition if appropriate action is not taken.
2.7.2      The primary purpose for this classification is to ensure that the plant operating staff recognizes the initiating condition, takes appropriate action, such as assessment and verification, and comes to an appropriate state of readiness to respond in the event that the condition worsens.

FCS                                                                    EP-FC-1001 Section D Revision 0TBD Page 43 of 170 EMERGENCY CLASSIFICATION SYSTEM 2.7.3    With the exception of possible assistance by local support groups such as fire departments or medical facilities, activation of offsite facilities by offsite organizations is not anticipated for events within this classification. The command and control position at Fort Calhoun Station has the option to call all or part of the Emergency Response Organization (ERO) for support at this emergency classification.
2.7.4    Notification of Unusual Event will be made to offsite authorities in accordance with Section E of this plan.
2.8 Alert 2.8.1    Alert - Events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of intentional malicious dedicated efforts of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels. It requires response by the onsite Emergency Response Organization which augments on-shift emergency resources, and constitutes a standby initiation of the offsite emergency plan provisions. Generally, offsite emergency response agencies notify their key staff, and may begin to activate offsite response such as activation of facilities and offsite radiological monitoring. Offsite agencies will maintain this level of preparedness until termination or escalation of the Alert classification.
2.8.2    OPPD will augment the Control Room, staff the Technical Support Center and Operations Support Center at the Alert level. Typically, the Emergency Operations Facility staff will also be augmented to be placed in "standby" mode, ready to assume Command and Control if necessary.
2.8.3    Notification to offsite authorities of the Alert will be made in accordance with Section E of this plan.
2.9 Site Area Emergency 2.9.1    Site Area Emergency - Events are in process or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or security events that result in intentional damage because of intentional malicious dedicated efforts of HOSTILE ACTION; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) prevents effective access to, equipment needed for the protection of the public. Any releases are not expected to result in exposure levels that exceed EPA Protective Action Guideline exposure levels beyond the site boundary.
Offsite response agencies are fully mobilized along with notification to the general public by the sounding of the Alert Notification System (ANS) sirens surrounding the plant site.

FCS                                                                   EP-FC-1001 Section D Revision 0TBD Page 44 of 170 EMERGENCY CLASSIFICATION SYSTEM 2.9.2    OPPD staffs all designated Emergency Response Facilities at a Site Area Emergency or General Emergency. The full Emergency Response Organization will be activated.
2.9.3    Notification to offsite authorities of the Site Area Emergency will be made in accordance with Section E of this plan.
2.10 General Emergency 2.10.1   General Emergency - Events are in process or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity or security events that result in an actual loss of physical control of the facility. Release can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area. Total activation of the onsite and offsite emergency response organizations is required. Protective actions involving offsite populations are highly probable.
2.10.2   OPPD staffs all designated Emergency Response Facilities at a Site Area Emergency or General Emergency. The full Emergency Response Organization will be activated.
2.10.3   Notification to offsite authorities of the General Emergency will be made in accordance with Section E of this plan.

FCS                                                                 EP-FC-1001 Section D Revision 0TBD Page 45 of 170 EMERGENCY CLASSIFICATION SYSTEM Table D Emergency Classification of Postulated Accidents Projected Worst Postulated Accident          Case Emergency                   Key Concern Classification Fuel Handling Accident General Emergency             Radiological Effluents (in Spent Fuel Pool Area)
Fuel Handling Accident General Emergency             Radiological Effluents (in Containment)
Gas Decay Tank Rupture          Site Area Emergency            Radiological Effluents Control Element Assembly General Emergency             Radiological Effluents Ejection Incident Loss of Coolant Accident         General Emergency         Loss of fission product barrier Single Reactor Coolant Pump General Emergency         Loss of fission product barrier Seizure Steam Generator Tube Site Area Emergency        Loss of fission product barrier Rupture Main Steam Line Break           Site Area Emergency            Radiological Effluents Waste Liquid Incident                   Alert                  Radiological Effluents Control Room Habitability During Toxic Chemical                   Alert                       Plant Control Release Accident

FCS EP-FC-1001 Section E Revision 0TBD Page 46 of 170 NOTIFICATION METHODS AND PROCEDURES 1.0   PURPOSE AND SCOPE 1.1   Purpose 1.1.1      The purpose of this PSRERP is to provide guidance for notifying state and local response organizations, the Nuclear Regulatory Commission, and members of the OPPD Emergency Response Organization during radiological emergencies.
1.2   Scope 1.2.1      This PSRERP applies to OPPD Emergency Response Organization personnel responsible for notifying state and local response organizations, the Nuclear Regulatory Commission and members of the OPPD Emergency Response Organization during a radiological emergency.
2.0   PROCEDURE 2.1   Notifications 2.1.1      The decision to make notifications is based on the emergency action levels and corresponding emergency classifications described in Section D of this Plan. As discussed in that section, they are consistent with NEI-99-01, Methodology for Development of Emergency Action Levels for Non-Passive Reactors, which has been approved by the NRC replacing NUREG-0654, Rev. 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Appendix 1. The EALs are reviewed annually by the States of Nebraska and Iowa.
2.1.2      OPPD is capable of notifying and activating its Emergency Response Organization 24 hours per day. It is also able to make notifications to the states, Nuclear Regulatory Commission and, if required, local counties on a 24 hour per day basis. The applicable state plans detail the provisions for 24 hour per day notification and activation of their response organizations.
2.1.3      The Command and Control position is responsible for ensuring appropriate notifications are initiated when an emergency is classified. Fort Calhoun Station personnel in the protected area are notified via the Emergency or Fire Alarm and a public address system message. Personnel outside the protected area are notified by public address systems installed in the Administrative and Training buildings. Site Security personnel may assist in the notification of all other personnel on OPPD property. The OPPD Emergency Response Organization is activated as appropriate for the emergency classification level. This is accomplished by an automated call-out system which activates phone calls, text messages, e-mails, and other functions. Maintenance of telephone numbers is discussed in Section P of 2016

FCS EP-FC-1001 Section E Revision 0TBD Page 47 of 170 NOTIFICATION METHODS AND PROCEDURES this Plan.
2.1.4  Initial notification of the states of Nebraska and Iowa is made within 15 minutes after declaration of an emergency classification. The states, in turn, notify other governmental response agencies as appropriate for the emergency classification. Notification is also made to Washington, Harrison, and Pottawattamie counties within 15 minutes.
2.1.5  The primary means of notification to the states and counties is via the Conference Operations Network (COP) which is a dedicated telephone system. The COP and backup communications systems are discussed in Section F of this plan. Provisions have been made for verification of notification messages when communications are via means other than the COP.
2.1.6  Notification to the NRC is the next contact made. This notification occurs immediately after state and local notifications, not to exceed one hour after the declaration of the emergency classification. The primary means for this notification is the Federal Telecommunications System, Emergency Notification System lines (FTS-ENS). The FTS-ENS system is maintained by the NRC, however, it is routinely tested by OPPD. If the FTS-ENS is not available, notifications are made using the normal commercial telephone system.
2.2   Emergency Messages 2.2.1  Initial Emergency Message The Omaha Public Power District and the states of Nebraska and Iowa have established the contents of the initial emergency messages to be sent from Fort Calhoun Station in the event an emergency is declared. These messages contain such information as the class of emergency, whether a release is taking place, potentially affected population and areas, and whether protective measures may be necessary. This information is transmitted by a dedicated telephone system, normal telephone systems or by facsimile. Forms are used to record the information for verbal or hard copy transmission to ensure each organization receives identical information.
2016

FCS EP-FC-1001 Section E Revision 0TBD Page 48 of 170 NOTIFICATION METHODS AND PROCEDURES 2.2.2   Follow-Up Emergency Messages A. The follow-up emergency messages to the states incorporate the majority of the elements of Criteria E.4 of NUREG 0654, Rev. 1, as determined necessary by the states. These messages are transmitted to the states by telephone, dose assessment computer or facsimile.
Update messages are sent to the states and counties at least every 60 minutes. Updates may be decreased to shiftily during ongoing events if requested by the states and the status of the event has not changed.
B. It is the goal of Fort Calhoun to attempt to provide dose assessment updates at 15 minute intervals during a Radiological Release. During a Site Area Emergency or General Emergency, the Conference Health Physics (CHP) Network, a dedicated telephone system, can be used to maintain communications as needed. This ensures rapid transmittal of dose assessment information and protective action recommendations to the states.
C. Emergency information to the county Emergency Operations Centers (Washington, Harrison and Pottawattamie Counties) is given verbally using the Conference Operation (COP) Network. These messages discuss general operational progressconditions of the plant.
D. The NRC will be kept informed as significant events occur which warrant the upgrading or downgrading of the emergency classification. These communications with the NRC will be via the NRC's FTS-ENS (Emergency Notification System). Dose Assessment personnel will keep the NRC informed of dose assessment information using the NRC's FTS-HPN (Health Physics Network).
E. OPPD has the capability to transmit key plant parameter information directly to the NRC. This system is entitled the Emergency Response Data System (ERDS). This system is normally activated and will be verified to be functioning within one hour of declaring an Alert or higher.
Initiation of this system can be accomplished in either the Control Room or the Technical Support Center.
F. Requests for assistance from local support agencies, and others, are made using normal telephone systems.
2016

FCS EP-FC-1001 Section E Revision 0TBD Page 49 of 170 NOTIFICATION METHODS AND PROCEDURES 2.3   Alert Notification System 2.3.1     A system called the Alert Notification System (ANS) has been designed to provide warning to the public within 15 minutes of the decision by offsite authorities to activate the system. The system includes a series of sirens which provide essentially 100 percent coverage of the population within 10 miles of Fort Calhoun Station.
2.3.2     The states Emergency Response Plans provide guidance as to when the system should be activated. The counties will then perform the actual activation.
2.3.3     Each county has control of only the sirens located within its borders. The exception is one siren which is located in Douglas County, but activated by Washington County. All sirens within a county are sounded simultaneously, and cannot be activated individually.
2.3.4     The sirens are activated by radio signal. The county agencies and the activation locations for the sirens are as follows:
A. Washington County Emergency Communications Center located in the County Court House, Blair, Nebraska.
B. Harrison County Emergency Communications Center located in the County Jail Complex, Logan, Iowa.
C. Pottawattamie County Emergency Communications Center located in the County Court House, Council Bluffs, Iowa.
These locations are continuously staffed, providing the capability to activate the siren system 24 hours per day.
2.3.5     The Omaha Public Power District has made provisions to sound the sirens when requested to do so by government officials, should a county be unable to activate its sirens. This process can be accomplished from the Emergency Operations Facility or the E.O.-Communications division offices.
2.3.6     It is not intended that county or city governments use the ANS for weather alerts or fire signals as frequent use of the system for other purposes would tend to reduce the effectiveness of the sirens if they are needed for a nuclear power plant incident.
2.3.7     In the event that one or more sirens activates during non-emergency conditions, provisions have been made to inform the public that no emergency exists, and initiate repairs to the errant siren(s).
2016

FCS EP-FC-1001 Section E Revision 0TBD Page 50 of 170 NOTIFICATION METHODS AND PROCEDURES 2.3.8  System operability is tested periodically in accordance with the updated design report to FEMA for the outdoor public warning system and backup alert and notification.
2.3.9  Backup ANS for the EPZ is achieved through route alerting by the affected county.
2.4   Emergency Alert System 2.4.1  Members of the public have been instructed (via the Emergency Planning Booklet discussed in Section G of this Plan) to tune to their Emergency Alert System (EAS) station for emergency instructions when the sirens are activated.
2.4.2  Radio station KGOR- 99.9 FM is the Local Primary I (LP1) control station for Omaha, NE. It has the capability to broadcast emergency instructions 24 hours per day. Most other television and radio broadcast stations have the capability of carrying EAS messages during their normal hours of broadcasting.
2.4.3  For messages the risk counties will contact the National Weather Service (NWS) and request that EAS be activated. The NWS will then send out the signal to activate the EAS. KGOR has agreed to pick up this signal and broadcast the message.
2.4.4  While follow-up messages are the responsibility of the states, Omaha Public Power District has the capability to make similar information releases to the media. This is described in Section G of this plan.

==3.0   REFERENCES==
AND COMMITMENTS 3.1   NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plant 2016

FCS                                                                 EP-FC-1001 Section F Revision 0TBD Page 51 of 170 EMERGENCY COMMUNICATIONS

==1.0 INTRODUCTION==

This section describes the available communications for use among the principal response organizations and between the Omaha Public Power District emergency response facilities. Provisions for 24-hour per day notification to and activation of the state and local emergency response organizations are discussed in Section E of this plan. Also discussed in Section E are the provisions for activating Omaha Public Power District emergency response personnel. Provisions for periodic testing of the emergency communications system are described in Section N of this plan.
2.0 COMMUNICATIONS SYSTEMS 2.1 A number of varied communications systems are available for communications between emergency response facilities. These systems are described in this section and are summarized in Figure F-1.
2.2 In the conduct of drills and exercises, OPPD may make use of its training simulator to provide a broad range of Control Room like amenities, without impacting the operating FCS Control Room. The communications equipment in the FCS Control Room is, for the most part, duplicated in the simulator.

FCS                                                                EP-FC-1001 Section F Revision 0TBD Page 52 of 170 EMERGENCY COMMUNICATIONS 2.3 Each emergency response facility and the personnel responsible for 24 hour communications in each facility is listed below:
PrIimary/Alternate Communications Emergency Facility Responsibility Control Room Fort Calhoun Station        Shift Manager /(Control Room Coordinator)/Control Room CommunicatorOperator)
TSC, Fort Calhoun Station                Site Director/TSC COP Communicator Emergency Director/EOF COP EOF, North Omaha Station Communicator EOC, State of Nebraska                   Operations Officer/Communications and Warning Officer Forward Command Post, State of           Nebraska Emergency Management Agency Nebraska                                 Director/Asst Nebraska Emergency Management Agency Director EOC, Washington Cnty (Nebraska)          Washington County Communications Center/County Emergency Management Director EOC, State of Iowa                       Director, Iowa Emergency Management Division/National Guard Adjutant General Forward Command Post State of            Harrison County Sheriffs Department/State Iowa                                     Liaison Officer EOC, Harrison County (Iowa)              Communications Director/Harrison County Sheriff's Department EOC, Pottawattamie County (Iowa)         Communications Director/County Emergency Management Director 2.4 Fort Calhoun Station Alarm System 2.4.1    Emergency and Fire Alarms These alarms are sounded from the Control Room when an emergency requiring ERO activation or fire is declared. Their function is to alert personnel within the Protected Area to an emergency condition.
2.5 Fort Calhoun Station Paging Systems 2.5.1    The Protected Area paging system (Gaitronics) provides a means of intra-plant communications. Stations on this system provide access to the plant paging system and to intercom lines. These stations and speakers are placed throughout the plant including the Control Room, the Technical Support Center and the Operations Support Center.

FCS                                                                  EP-FC-1001 Section F Revision 0TBD Page 53 of 170 EMERGENCY COMMUNICATIONS 2.5.2     The Administrative and Training buildings at the Fort Calhoun Station also have public address announcing capabilities. Access to the public address system in either or both locations can be accomplished via the sites telephone system. This system can be used to notify personnel of a plant emergency.
2.6 Local Private Automatic Branch Exchanges (PABX) 2.6.1     Omaha Public Power District PABXs A. Company telephone systems link Omaha Public Power District facilities with those located in Omaha, Nebraska. These systems provide intracompany telephone communications and access to the public telephone network.
B. The Emergency Operations Facility has installed lines designated for emergency use. These lines are dedicated to specific emergency response positions. Telephone sets for all lines are available in the Emergency Operations Facility.
C. Trunk lines between the company PABX systems in Omaha and the Fort Calhoun Station PABX systems provide the primary means of communication with the plant. Additional lines can be provided by the local telephone company, as requested.
D. This system also provides a redundant means of providing emergency notifications to the states and counties, and is the primary backup to the Conference Operations Network (COP).
2.6.2     Fort Calhoun Station PABXs A. These dedicated telephone systems provide communications within Fort Calhoun Station locations.
B. The Technical Support Center has designated extensions for use during an emergency. They include extensions designated for use by NRC personnel. Additional lines can be diverted from other office areas as required.
C. Dedicated lines from this system are extended to the Emergency Operations Facility. This system is also connected to the company telephone system in Omaha to provide intracompany telephone communications which are not affected by the public telephone network.
D. Redundant routing of access to the public telephone network is provided via links to the public system in Blair, Nebraska as well as Omaha.

FCS                                                                 EP-FC-1001 Section F Revision 0TBD Page 54 of 170 EMERGENCY COMMUNICATIONS 2.7 Conference Operations (COP) Network 2.7.1    The COP system is primary emergency notification system between OPPD, state and county agencies. It is used to provide, initial, and update notifications and for general information flow between these agencies. See Figure F-1 for a list of COP locations.
2.7.2    COP is a dedicated system; each location is capable of making group calls or calling station to station within the network. See Figure F-2 for a system diagram.
2.7.3    A recorder located at the EOF records all conversations on the COP system.
The Nebraska State Patrol and the Iowa Dispatcher also have voice recording capability.
2.8 Conference Health Physics (CHP) Network 2.8.1    This network provides a dedicated means for communicating radiological information between the Technical Support Center, Emergency Operations Facility, Nebraska and Iowa Emergency Operations Centers and the Nebraska and Iowa Radiological Emergency Response Team Coordinators.
The system is shown on Figure F-3.
2.8.2    This system provides the capability for conference conversations between the Technical Support Center or Emergency Operations Facility and any one or all of the agencies on the system. A voice recorder in the Emergency Operations Facility provides a record of conversations on this system.
2.9 Facsimile (FAX) Capability 2.9.1    Facsimile machines provide the capability to link the Control Room, Technical Support Center, Operations Support Center, Emergency Operations Facility, Joint Information Center, other OPPD Headquarters facilities, the Nebraska and Iowa Emergency Operations Centers and the Nebraska and Iowa Forward Command Posts. Capability also exists to access any FAX machine via commercial telephone networks.
2.9.2    The facsimile machines can be used to transmit health physics, operational and dose assessment information from Omaha Public Power District emergency response facilities to state emergency response facilities. They can also be used to disseminate emergency status information to OPPD management. Some of these extensions have voice capabilities and serve as a backup means of voice communications for those locations.

FCS                                                                    EP-FC-1001 Section F Revision 0TBD Page 55 of 170 EMERGENCY COMMUNICATIONS 2.10 800 MHz Radio System 2.10.1     A 800 MHz radio communications system links Fort Calhoun Station onsite emergency response facilities, Emergency Operations Facility, plant portable radios, and mobile radios used by radiological monitoring teams. The multi-talk group/channel system is illustrated by Figures F-6, F-7, F-8, F-9 and F-10.
2.10.2     Figure F-6 illustrates the talk groups available for the Fort Calhoun Station.
Figure F-7 illustrates the dedicated subfleet for the Emergency Response Organization. Figure F-8 illustrates the shared subfleet which the ERO can utilize during emergencies. Figure F-9 provides the details for the "Talk-Around" capability which can be utilized when the 800 MHz trunking system is out of service. Figure F-10 summarizes the subfleets assigned to the Fort Calhoun Station.
2.11 NRC Emergency Notification System (FTS-ENS) 2.11.1     This NRC Operations Center is contacted via this telephone network. The FTS-ENS is a portion of the Federal Telecommunications System (FTS) and is located in the Control Room, Technical Support Center and Emergency Operations Facility. It provides plant operations information to the NRC Operations Center, in Rockville, Maryland.
2.12 NRC Health Physics Network (FTS-HPN) 2.12.1     The FTS-HPN is a portion of the Federal Telecommunications System (FTS) and is located in the Technical Support Center and Emergency Operations Facility. The network is used to exchange radiological and dose assessment information between NRC facilities and OPPD.
2.13 Priorities System 2.13.1     The Technical Support Center establishes priorities for accident mitigation and transmits the priorities to the Operations Support Center and the Emergency Operations Facility for display.
2.14 State of Nebraska Emergency Management Radio System 2.14.1     The Emergency Operations Facility is equipped with various radio equipment for use by Nebraska Emergency Management personnel. This equipment may be used either alone or in conjunction with the State of Nebraska Emergency Management Mobile Van.

FCS                                                                    EP-FC-1001 Section F Revision 0TBD Page 56 of 170 EMERGENCY COMMUNICATIONS 2.15 State of Iowa Emergency Management Radio System 2.15.1     The Emergency Operations Facility can support radio equipment for use by Iowa State Emergency Management personnel. This equipment may be used either alone or in conjunction with the State of Iowa Emergency Management Mobile Van.
2.16 Management Operations (MOP) Network 2.16.1     This system (similar to the COP and Ops Liaison Network) provides dedicated conference capability between the Control Room Coordinator, TSC Site Director, OSC Director, EOF Emergency Director and the JIC Manager. The purpose of the system is to provide information flow between the directors of all the emergency facilities.
2.16.2     The system allows conferencing without dialing, each set is capable of conferences and individual call capability. Records of conversations on this system are captured by a voice recorder in Emergency Operations Facility.
2.17 joint Joint Information Center Hot Line 2.17.1     A dedicated telephone circuit is provided between the Emergency Operations Facility and Joint Information Center. The telephone sets are equipped with a blank dial plate. Lifting either handset causes a connecting ring at the other set.
2.17.2     This system provides a means for uninterrupted private communications for coordination of information releases to the public.
2.18 NAWAS 2.18.1     NAWAS equipment in the Control Room provides a redundant means of providing emergency notifications to the States of Nebraska and Iowa. It also provides the Control Room personnel with weather information.
2.19 Emergency Response Message System (ERMS) 2.19.1     A network of computer terminals is used to link the Technical Support Center, Operations Support Center and Emergency Operations Facility. It provides rapid dissemination of plant status information between facilities and ensures consistency of information at all facilities. The JIC is also equipped with a monitor which provides read-only capability. The software used for this function can be any type that provides for electronic log keeping of emergency response actions (WEBeOCWebEOC, ERMS, etc.)

FCS                                                                  EP-FC-1001 Section F Revision 0TBD Page 57 of 170 EMERGENCY COMMUNICATIONS 2.20 Telephone Service Pedestal for State Mobile Communication Vehicles 2.20.1   A telephone service pedestal is located outside of the Emergency Operations Facility near the designated parking area for the mobile communication vehicles. This pedestal is fed by a 12-pair cable from the Emergency Operations Facility and allows quick connection of various telephone facilities to the mobile vehicles. Several telephone lines and dedicated communication facilities are prewired and operational. Spare pairs are available to add additional telephone facilities quickly as the need arises.
2.21 Telephone Junction Box for NRC Mobile Vehicle 2.21.1   A telephone junction box is located on the outside wall of the Emergency Operations Facility near the designated parking area. This junction box is fed by a 12 pair cable and is equipped with four standard modular telephone jacks. These jacks are prewired to a distribution frame and allow quick connection of telephone lines to support the NRC as required. Additional jacks can be added up to the 12 pair capacity of the feeder cable.
2.22 Operations Liaison Network 2.22.1   This system provides dedicated conference capabilities between the Fort Calhoun Station Control Room/Simulator, TSC, OSC, EOF and JIC. The purpose of the system is to provide operational information from the Control Room to the other facilities for the purpose of developing response plans, determining emergency classifications and implementing assistance to the Control Room.
2.22.2   The system allows conferencing without dialing, and thus permits rapid access to the conference by the Operations Liaisons. Each station is equipped with group call and individual call capability. Records of conversations on this system are captured by a voice recorder in the Emergency Operations Facility.
2.23 Emergency Response Data System (ERDS) 2.23.1   This system provides selected ERFCS data to the NRCs Operations Center for the purpose of evaluating plant conditions. Certain data points from the ERFCS are included in the ERDS data library, and when activated, these data points are transmitted to the Operations Center. The system is normally activated and is required to be activated at an ALERT or higher classification.

FCS                                                                  EP-FC-1001 Section F Revision 0TBD Page 58 of 170 EMERGENCY COMMUNICATIONS 2.24 Interactive Notification System (INS) 2.24.1     This system provides rapid notification to Emergency Response Organization personnel in the event of an emergency where the ERO is activated. The system is also used to perform the Management Notification function, and can be adapted to perform other notification functions as determined necessary by the Fort Calhoun Station. A backup ERO notification process is available in the event of failure of the INS.
2.24.2     The system is activated using the internet or contacting a live operator, normally from the Control Room. The system 1) initiates a call-out to ERO members at home, mobile, or work locations, 2) sends text messages to ERO positions that provide a contact number and 3) sends e-mails to ERO personnel.
2.25 Satellite Phones 2.25.1     Satellite Phones are located in the Control Room, Technical Support Center, and Emergency Operations Facility to serve as an alternate communications option in the event normal communications equipment is unavailable.
3.0  COMMUNICATIONS WITH MEDICAL SUPPORT FACILITIES 3.1  Fort Calhoun Station emergency response organization personnel can communicate with medical support facilities, Washington County Emergency Communications Center or the University of Nebraska Medical Center, via the site telephone systems described earlier in this section.
3.2  Non-OPPD radio systems provide communications between medical support facilities and mobile rescue units as well as inter-unit communications. These radio systems have the capability to use the common medical emergency frequency which ensures coordinated communications.

EP-FC-1001 Section F FCS                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                            Revision 0TBD Page 59 of 170 EMERGENCY COMMUNICATIONS Figure F Summary of Communications Systems Dodge County - Washington County Control Room Control Room Simulator (Training)
Technical Support Center   Operations Support Center   Emergency Operations Facility Joint Information Center FCS Security OPPD Headquarters OPPD Field Monitoring Teams Nebraska EOC Nebraska FCP (North Omaha EOF)
Nebraska State Patrol   Washington County EOC Backup EOC Iowa EOC Iowa FCP (Harrison County EOC)
Iowa Dispatch (Fort Dodge)   Harrison County EOC   Pottawattamie County EOC NRC - Headquarters   NRC - Region IV Drill Communications (Admin 1D)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             NRC - Resident Inspectors FCS Plant Paging (Gai-Tronics)
OPPD PABXs FCS PABXs Commercial Telephone Systems COP Network (Notifications)
CHP Network (HP Information)
FTS-ENS Phones (NRC)
FTS-HPN Phones (NRC)
Available Fax Machines OPPD 800 MHz Radio System JIC Hotline NAWAS Electronic Emergency Logs MOP Network State of Nebraska Radio State of Iowa Radio Law Enforcement Radios Operations Liaison Network ERDS INS Satellite Telephone

EP-FC-1001 Section F FCS                                                                      Revision 0TBD Page 60 of 170 EMERGENCY COMMUNICATIONS Figure F Conference Operations Network

EP-FC-1001 Section F FCS                                                                          Revision 0TBD Page 61 of 170 EMERGENCY COMMUNICATIONS Figure F Conference Health Physics Network

EP-FC-1001 Section F FCS                                                                    Revision 0TBD Page 62 of 170 EMERGENCY COMMUNICATIONS Figure F MOP (Management Operations)

EP-FC-1001 Section F FCS                                                                           Revision 0TBD Page 63 of 170 EMERGENCY COMMUNICATIONS Figure F Operations LiaisionLiaison Network

FCS                                                        EP-FC-1001 Section F Revision 0TBD Page 64 of 170 EMERGENCY COMMUNICATIONS Figure F OPPD/Fort Calhoun Station 800 MHz Radio System

FCS                                                         EP-FC-1001 Section F Revision 0TBD Page 65 of 170 EMERGENCY COMMUNICATIONS Figure F Fort Calhoun Station Subfleet - SF4

FCS                                                         EP-FC-1001 Section F Revision 0TBD Page 66 of 170 EMERGENCY COMMUNICATIONS Figure F Fort Calhoun Station Subfleet - SF5

FCS                                                          EP-FC-1001 Section F Revision 0TBD Page 67 of 170 EMERGENCY COMMUNICATIONS Figure F Fort Calhoun Station Talk-Around Channel (TA)

FCS                                                       EP-FC-1001 Section F Revision 0TBD Page 68 of 170 EMERGENCY COMMUNICATIONS Figure F Summary of 800 MHz Radio Uses Channel     Display               Normal Use               Emergency Use 1       SF1 Sec 1            Security-Primary           Security-Primary 2       SF2 Sec 2           Security-Secondary         Security-Secondary 3        SF3 Ops                Operations                 Operations 4        SF4 EP             Emergency Planning         Field Team Control 5        SF5 RP             Radiation Protection     In-Plant Team Control 6       SF6 Maint.             Maintenance           In-Plant Team Control 7       SF7 ERO             Emergency Planning        Emergency Planning 8      SF8 Work Ch            Work Channel              Available for Use 9      SF9 EP Cntlr            EP Controller            Available for Use 10        Spare 1                   Future 11        Spare 2                   Future 12        Spare 3                   Future 13      Talk Around             Talk Around              Emergency Use 14     Unprogrammed             Not Available              Not Available 15     Unprogrammed             Not Available              Not Available 16     Unprogrammed             Not Available              Not Available

FCS                                                                     EP-FC-1001 Section HG Revision 0TBD Page 69 of 170 PUBLIC EDUCATION AND INFORMATION 1.0  PUBLIC INFORMATION CONTENT AND DISSEMINATION 1.1  Public Information Content The Omaha Public Power District (OPPD) Corporate Communications Division has coordinated with the States of Nebraska and Iowa in the preparation and dissemination of educational information. A brochure entitled Fort Calhoun Nuclear Station Emergency Planning Information incorporates the following information:
1.1.1      A description of natural background and manmade radiation, including estimated annual doses from various sources of radiation.
1.1.2      Public warning procedures and use of radio and television following an emergency at the Fort Calhoun Station.
1.1.3      Radiation protection, including such protective actions as in-house sheltering and evacuation.
1.1.4      Special evacuation notes, including special needs of the handicapped, medical and nursing home patients, registration centers, evacuation routes and a Sub Area map of the EPZ.
1.1.5      Information concerning the primary Emergency Alert System.
1.1.6      Additional protective actions including ad hoc respiratory protective devices.
1.1.7      A list of contact points to obtain additional information.
1.2  Public Information Dissemination The Public Information Brochure is distributed in written form annually by mail to the permanent adult population within an approximate 10-mile radius of Fort Calhoun Station. A general distribution to reach the transient population is achieved by posting information in public areas and by placing supplies of prepared written material in motels, service stations, and government buildings. Media advertisements, utility bill inserts, telephone tape messages, news releases, and public seminars may also be utilized for public education and information.
An Emergency Planning recurring task verifies the content and dissemination of this information.

FCS                                                                     EP-FC-1001 Section HG Revision 0TBD Page 70 of 170 PUBLIC EDUCATION AND INFORMATION 2.0  NEWS MEDIA COORDINATION AND FACILITIES There are two (2) locations available for use of the news media. The Joint Information Center (JIC) is the primary facility for the release of all information; the Emergency Operations Facility (EOF) has limited space for press briefings and may be used on a selective basis. The Corporate Crisis Communication Plan provides the guidance for the operation of the Joint Information Center during emergencies. This plan is reviewed annually in accordance with an Emergency Planning Test.
2.1  Joint Information Center (JIC)
The primary information point is the Joint Information Center located within OPPDs Energy Plaza at 444 South 16th Street Mall, Omaha, Nebraska. This center is activated for either a Site Area Emergency or General Emergency and will accommodate Joint Information Center personnel as well as local, State and Federal public information personnel.
For Classifications below Site Area Emergency, the Division Manager-Corporate Communications shall determine the corporate response for media coordination efforts.
The Joint Information Center also serves as the public inquiry center for OPPD, State and Federal authorities. The Public Inquiry Supervisor will serve as OPPDs representative in this area.
2.2  Emergency Operations Facility Briefing Room A secondary facility is located in the Emergency Operations Facility located at the North Omaha Power Station. However, the Joint Information Center is the preferred point of news media information.
The EOF Briefing Room was constructed as working space for 25 news correspondents. It is anticipated that space in this facility will be for the local media which routinely cover OPPD activities. Remaining space will be allocated to the national and regional media on a pool basis.

FCS                                                                 EP-FC-1001 Section HG Revision 0TBD Page 71 of 170 PUBLIC EDUCATION AND INFORMATION 3.0  EMERGENCY CLASSIFICATION INFORMATION RELEASES Following the classification of an emergency, Corporate Communications Division representatives will be informed of the emergency action level invoked at the plant and the reason or reasons thereof. Once such notification has been made, release of information to the news media will be coordinated by the Division Manager - Corporate Communications or the Joint Information Center Manager. That position will also coordinate the timely exchange and release of information with the official spokespersons for Federal and State agencies. The JIC Manager will report directly to the Emergency Director. An A JIC Technical Liaison at the Joint Information Center will assist in nuclear related information matters. The JIC Technical Liaison will also be in direct contact with the EOF Information Specialist or the EOF Technical Liaison who will provide prompt and accurate information regarding plant status. The Corporate Crisis Communication Plan activates and augments the JIC staff. During all emergency classifications, the Corporate Spokesperson is the official designated spokesperson for OPPD.
4.0  NEWS MEDIA EXPOSURE TO EMERGENCY PLANNING INFORMATION The Corporate Communications Division mails an annual information packet or conducts an annual seminar to acquaint the local news media with the operation of Fort Calhoun Station and its emergency plan, including the public information procedures to be followed in an emergency. The mailing\seminar also provides educational information concerning radiation, and nuclear related subjects deemed appropriate. An Emergency Planning recurring task verifies the transmittal of the information packet or conduct of the seminar to the local news media outlets.

FCS                              EP-FC-1001 Section HG Revision 0TBD Page 72 of 170 PUBLIC EDUCATION AND INFORMATION

FCS                                                                      EP-FC-1001 Section H Revision 0TBD Page 73 of 170 EMERGENCY FACILITIES AND EQUIPMENT NOTE This section lists the Emergency Response Facilities (ERF) available for i   activation in the event of an emergency at the Fort Calhoun Nuclear Station, including the ISFSI. General equipment and staffing of emergency            i facilities are also included in this section. Communications equipment is covered in Section F. Assessment equipment is covered in Section I.
1.0   TECHNICAL SUPPORT CENTER (TSC) 1.1   Facility Function and Description 1.1.1      The TSC's primary function is the collection, analysis, and distribution of technical data required to support plant operations personnel during an emergency. This operational support is provided from a separate and distinct center, thus reducing personnel congestion in the Control Room.
The TSC has the capability to perform EOF functions and responsibilities until that facility can be fully activated.
1.1.2      The TSC building is located on the north side of the Auxiliary Building. (See Figure H-1). The north wall of the auxiliary building is shared as the south wall of the TSC. To the east of the building is the maintenance shop. To the north and west of the TSC is the Chemistry/Radiation Protection Building.
The TSC building was designed to meet the criteria of NUREG 0696 and is less than a two minute walk from the Control Room.
1.1.3      The TSC is composed of a protected area and an equipment area. It is comprised of heavy concrete mat construction with 1-1/2 foot thick reinforced concrete walls and ceiling. This part of the structure is kept at positive pressure and the building air can be filtered through a pre-filter, HEPA filter and charcoal filter. Flood barriers in various locations of the plant protect the TSC from flooding and are designed for a 100 year recurrence frequency.
1.1.4      An "L" shaped equipment area is located to the east and south of the TSC protected area. The equipment area has concrete footings and common steel construction with concrete block walls. Items included in the equipment area are the batteries and UPS power distribution systems, HVAC and HEPA filters.

FCS                                                                  EP-FC-1001 Section H Revision 0TBD Page 74 of 170 EMERGENCY FACILITIES AND EQUIPMENT 1.2 Equipment and Supplies 1.2.1  The TSC is typically equipped with the following items:
A. System Drawings for the nuclear power plant and the ISFSI B. Vendor Manuals C. An official copy of the Fort Calhoun Station Operating Manual. (This includes the Operating Procedures and Instructions, Emergency Operation Procedures, the Post Shutdown Radiological Emergency Response Plan and Emergency Plan Implementing Procedures.
D. Updated Safety Analysis Report (USAR) for the nuclear power plant and the NUHOMS Storage System FSAR for the ISFSI (electronically)
E. Technical Specifications for the nuclear power plant and the ISFSI (electronically)
F. Direct and Airborne Radiation Monitoring Equipment which is permanently installed:
: 1. Area Monitor (RM-093):
The area monitor in the TSC is a GM detector (or equivalent) that detects gamma radiation.
: 2. Particulate, Iodine and Noble Gas (PING) Monitor:
The sampler and detector subsystem contains a combined particulate, iodine and noble gas sampler in one compact, lead-shielded assembly. Three read-outs contain all alarm functions of alert, high and failure, along with check source actuation controls.
The PING is piped directly to the TSC ventilation system to monitor TSC supply air at all times.
G. Emergency Response Facilities Computer System/Safety Parameter Display System (ERFCS/SPDS).
H. Personal Computer(s) with printers.
I. Emergency Response Message System.
J. Sign-in Board with identification tags.
K. Emergency logs.
L. St4atus Status boards.

FCS                                                                       EP-FC-1001 Section H Revision 0TBD Page 75 of 170 EMERGENCY FACILITIES AND EQUIPMENT M.       The ability to provide output displays to the OSC and EOF.
1.3 Staffing 1.3.1     The TSC affords ample space and equipment to support the Emergency Response Organization (ERO) as stated in Section B and additional TSC personnel as defined in the Fort Calhoun ERO Roster. In addition, space has been allocated for NRC representatives.
2.0 EMERGENCY OPERATIONS FACILITY (EOF) 2.1 Facility Functions and Description 2.1.1     The function of the Emergency Operations Facility is to serve as the support facility for the licensee's overall management of emergency response activities (including coordination with Federal, State and local officials), the central collection and coordination point for all off-site radiological and environmental samples and assessments in order to make public protective action recommendations (PARs).
2.1.2     The Emergency Operations Facility is located 17 miles from the Fort Calhoun Station at the North Omaha Power Station. This site was chosen to ensure continuous habitability and is the only Emergency Operations Facility in the district. The building is capable of providing working space for a minimum of 35 persons consistent with the requirements of NUREG-0696, Revision 1.
Space for data systems equipment, communications and storage activities is also available.
2.1.3     The alternative facility maintains the capability for staging the TSC/OSC emergency response organization personnel in the event of a hostile action.
The alternative facility has the capability for communications with the control room, and plant security; the capability to perform offsite notifications; and the capability for engineering assessment activities. The EOF will satisfy the offsite notification responsibilities for the alternative facility. The EOF staff will support offsite notification responsibilities while the TSC/OSC ERO are performing activities supported by the alternate facility. The alternate facility is co-located with the EOF at OPPDs North Omaha Station.

FCS                                                                EP-FC-1001 Section H Revision 0TBD Page 76 of 170 EMERGENCY FACILITIES AND EQUIPMENT 2.2 Equipment and Supplies 2.2.1    The EOF is typically equipped with the following emergency response items:
A. Emergency Status Boards B. 10-Mile EPZ Maps C. Emergency Monitor Kits D. Assignment Board with identification tags E. Portable Calculator(s)
F. Emergency Telephone Books G. Emergency Logs H. Personal Computers and Printers I. Technical Specifications for the nuclear power plant and the ISFSI (electronically)
J. System Drawings for the nuclear power plant and the ISFSI K. Complete latest revision of the Fort Calhoun Station Operating Manual.
(This includes the Operating Procedures and Instructions, Emergency Operating Procedures, the Post Shutdown Radiological Emergency Response Plan and Emergency Plan Implementing Procedures).
L. Emergency Response Facilities Computer System/Safety Parameter Display System (ERFCS/SPDS)
M. Emergency Response Message System (ERMS) 2.3 Staffing 2.3.1    The EOF affords ample space and equipment to support the Emergency Response Organization as stated in Section B. In addition, space has been allocated for NRC Representatives.

FCS                                                                   EP-FC-1001 Section H Revision 0TBD Page 77 of 170 EMERGENCY FACILITIES AND EQUIPMENT 3.0 OPERATIONS SUPPORT CENTER (OSC) 3.1 Facility Function and Description 3.1.1     The Operations Support Center (OSC) is an onsite facility, separate from the Control Room (CR) and the Technical Support Center (TSC) where support personnel assemble and prepare to perform investigative or corrective actions as deemed necessary by the CR or TSC.
3.1.2     The OSC communicates with the CR and the TSC and is located in the TSC Building.
3.2 Equipment and Supplies 3.2.1     Equipment lockers are provided in the OSC for storage of instruments, SCBAs, supplies and reference documents.
3.3 Staffing 3.3.1     OSC management is comprised of an OSC Director and three coordinators technicians representing the radiation protection, chemistry and maintenance disciplines. Technicians comprise the balance of the OSC personnel (See Section B of this plan for a comprehensive organization definition).
4.0 CONTROL ROOM 4.1 Facility Description and Function 4.1.1     The Control Room functions as the onsite location from which the nuclear power plant is operatedFCS systems are monitored and controlled and from which any ISFSI operations are coordinated. It is large enough to contain all the instrumentation, controls and displays for the nuclear systems, reactor coolant systems, steam systems, electrical systems, safety and accident monitoring systems. The Control Room plays a vital role in the Emergency Response Organization by providing the initial response actions needed to react to any emergency situation. The Control Room personnel will respond to all emergency situations in an attempt to mitigate the emergency and minimize the impact on the surrounding environment, health and safety of the public as well as plant personnel and equipment.

FCS                                                                  EP-FC-1001 Section H Revision 0TBD Page 78 of 170 EMERGENCY FACILITIES AND EQUIPMENT 4.2 Equipment and Supplies 4.2.1    The Fort Calhoun Station Control Room is typically supplied with the following emergency supplies:
Emergency Locker (Computer Room)
Operating and Emergency Procedures and Manuals Radiological Monitoring Equipment Technical Specifications for the nuclear power plantFCS and the ISFSI (electronically)
System Drawings for the nuclear power plant and the ISFSI (electronically) 4.3 Staffing 4.3.1    In addition to normal CR personnel, additional positions are called out in the event of an emergency situation as stated in Section B.
5.0 EMERGENCY KITS 5.1 The emergency kits and equipment are inventoried in accordance with Fort Calhoun Station Surveillance Tests Procedures. Extra quantities of equipment, spare parts and supplies are located at the Fort Calhoun Station Warehouse to support extended emergencies.
5.2 Radiological Emergency Kits 5.2.1    These kits include protective equipment, radiological monitoring equipment and emergency supplies. Kits are located in the Control Room, Technical Support Center, Operations Support Center and the Emergency Operations Facility.
5.2.2    The Radiation Protection Department establishes the method and frequency for instrument calibration. Individual instruments are calibrated using approved calibration procedures. Repair/replacement of equipment is coordinated through the Radiation Protection Department.
5.3 Dosimetry Kits 5.3.1    These kits include dosimetry, dosimeter chargers and appropriate paperwork. Kits are located in the Control Room, Technical Support Center, Operations Support Center and Emergency Operations Facility.

FCS                                                                  EP-FC-1001 Section H Revision 0TBD Page 79 of 170 EMERGENCY FACILITIES AND EQUIPMENT 5.4 Medical Kits 5.4.1    First Aid Equipment and Supply Kits A. First aid equipment and supplies are located in the First Aid Room.
Trauma and primary response kits are available throughout the plant.
These kits are inspected and maintained by the Industrial Safety Coordinator.
5.4.2    Contaminated/Injured Person Kit A. These kits are located in the Operations Support Center and near the RP Count Room. These kits are maintained by the Radiation Protection Department.
5.5 Decontamination Area 5.5.1    Decontamination equipment and supplies are located in the main warehouse and the radiation protection work area.
5.6 Field Monitoring Kits 5.6.1    OPPD maintains two vehicles designated for emergency use, each vehicle is equipped with radiological monitoring equipment, emergency supplies, and other equipment/supplies that may be used by teams monitoring radiological conditions on and off site. Each vehicle also has a permanently installed communications system as described in Section F.
5.6.2    Radiological equipment or other equipment that is/or may be affected by climate changes may be stored in a designated storage area.
5.6.3    Use of these emergency vehicles is authorized by the Manager-Emergency Planning or designee. In the event a vehicle requires servicing every effort will be made to have it returned on the same day. A sign reminding users that the vehicle shall be returned to its home base in the event of a declared emergency at Fort Calhoun Station is posted in each vehicle.

FCS                                                                 EP-FC-1001 Section H Revision 0TBD Page 80 of 170 EMERGENCY FACILITIES AND EQUIPMENT 5.7 Other OPPD Resources 5.7.1   OPPD has other facilities and resources that may be useful in support of an emergency at Fort Calhoun Station. Examples are:
A. Fort Calhoun Station Simulator could be used to model plant transients or serve as an alternate location for support and technical personnel.
The simulator has the following communications equipment: Conference Operation Network (COP), Operations Liaison Network, FTS-ENS Phone, Gai-tronics, remote radio base station, regular phone systems, computer terminal for dose assessment, and FAX machine.
B. The FCS Training Center, the FCS Administration Building, and Energy Plaza make available resources such as: briefing rooms, classrooms, technical libraries, a chemistry laboratory, a radiation protection laboratory, communications, computers, food storage and preparation facilities, alternate water supply, and shop areas.

FCS                                                           EP-FC-1001 Section H Revision 0TBD Page 81 of 170 EMERGENCY FACILITIES AND EQUIPMENT Figure H Onsite Emergency Response Facilities

FCS                                                            EP-FC-1001 Section H Revision 0TBD Page 82 of 170 EMERGENCY FACILITIES AND EQUIPMENT Figure H Typical Technical Support Center Layout

FCS                                EP-FC-1001 Section H Revision 0TBD Page 83 of 170 EMERGENCY FACILITIES AND EQUIPMENT

FCS                                EP-FC-1001 Section H Revision 0TBD Page 84 of 170 EMERGENCY FACILITIES AND EQUIPMENT

FCS                                                            EP-FC-1001 Section H Revision 0TBD Page 85 of 170 EMERGENCY FACILITIES AND EQUIPMENT Figure H Typical TSC Entry/Briefing Area

FCS                                EP-FC-1001 Section H Revision 0TBD Page 86 of 170 EMERGENCY FACILITIES AND EQUIPMENT

FCS                                                           EP-FC-1001 Section H Revision 0TBD Page 87 of 170 EMERGENCY FACILITIES AND EQUIPMENT Figure H Typical Operations Support Center Layout

FCS                                EP-FC-1001 Section H Revision 0TBD Page 88 of 170 EMERGENCY FACILITIES AND EQUIPMENT

FCS                                EP-FC-1001 Section H Revision 0TBD Page 89 of 170 EMERGENCY FACILITIES AND EQUIPMENT

FCS                                                                           EP-FC-1001 Section H Revision 0TBD Page 90 of 170 EMERGENCY FACILITIES AND EQUIPMENT Figure H Typical Emergency Operations Facility Layout A. Dose Assessment        E. ENS Phones   I. NRC Van Elect/Tele Hookup    M. Operations Liaison Terminals                                                                Phone B. ERF Terminals          F. Fax Machines J. Nebr. CRUSH Elect/Tele Hookup C. CHP Phones             G. ERF Printer    K. COP Phone D. HPN Phones             H. Siren Terminal L. Mop Phone
: 1. Emergency Director                           30. NE. Governor's Authorized Representative
: 2. Emergency Director Secretary/ERMS            31. NE. GAR Advisor

FCS                                                                   EP-FC-1001 Section H Revision 0TBD Page 91 of 170 EMERGENCY FACILITIES AND EQUIPMENT
: 3. EOF Operations Liaison                32. NE. Manager
: 4. EOF COP Communicator                  33. NE. RAD. Team Coordinator
: 5. Protective Measures Manager           34. NE. Recorder
: 6. EOF Dose Assessment Coordinator       35. NE. Dose Calculations
: 7. EOF Field Team Specialist             36. NE. Public Information Officer
: 8. EOF Dose Assessment Specialist        40. IA. Representative
: 9. EOF Dose Assessment Assistant         41. IA. RAD. Team Coordinator
: 10. EOF Information Specialist            50. NRC Site Team Leader/DSO/MCL
: 11. EOF Technical Liaison                 51. NRC Emergency Response Coordinator
: 12. Des Moines Site Representative        52. NRC Status Summary Coordinator
: 13. EOF Administrative Logistics Manager  53. NRC Governmental Liaison Coordinator
: 14. EOF Secretary                         54. NRC Public Information Representative
: 15. EOF Clerical Assistant                55. NRC Dose Assessment Representative
: 16. EOF Status Board Keeper               56. NRC Reactor Safety Coordinator/RSCL
: 17. EOF Communications Specialist         57. NRC Protective Measures Team Leader
: 18. EOF Security Personnel                58. NRC Protective Measures Coordinator/PMCL
: 19. EOF Information Technology Specialist 59. NRC Status Summary Communicator
: 20. EOF Emergency Response Coordinator    60. NRC Emergency Response Assistant
: 21. CHP Communicator                      70. FEMA Representative

FCS                                                                         EP-FC-1001 Section I Revision 0TBD Page 92 of 170 ACCIDENT ASSESSMENT 1.0  ACCIDENT ASSESSMENT 

==SUMMARY==

Accident assessment is divided into initial and long term phases. At the beginning of an event initial assessments are performed in the Control Room. These early assessments are used as a basis for classifications, immediate actions and emergency response. The Shift Manager is responsible for initial event assessment, classification and initiation of appropriate notifications. Initial dose assessment with recommended protective actions can be performed and evaluated as soon as practical by onsite staff. These projections will be made available to offsite governmental agencies.
Initial assessments using plant parameters or other indicators are compared to pre-determined emergency action levels to select the proper emergency classification.
The plant parameters may be system conditions, system configuration, radiological parameters, etc. The Control Room is equipped with adequate monitoring equipment to determine these parameters for rapid assessment and decision-making.
The long term or continuing accident assessment is performed using the Control Room monitoring equipment and other methods made possible by additional resources from the Emergency Response Organization and offsite organizations. This includes radiological information gathered from field monitoring and environmental monitoring teams.
2.0  ASSESSMENT CAPABILITIES 2.1  Resources for Detection/Assessment of Non-Radiological Events 2.1.1      Fire Detection The fire detection system is detailed in the Station Fire Plan.
2.1.2      Seismic Monitoring Plant seismic instrumentation is provided to determine the response of the containment and auxiliary building structures in the event of an earthquake so that such response can be compared with that used as the basis of design.
Should a seismic disturbance occur in the neighborhood of the plant, the accelerations recorded within the plant will be the basis for a decision as to continued plant operation.
Seismic information is also available offsite through the U.S. Department of the Interior, United States Geologic Survey, National Earthquake Information Service, Boulder, Colorado.

FCS                                                                      EP-FC-1001 Section I Revision 0TBD Page 93 of 170 ACCIDENT ASSESSMENT 2.1.3     River Level River level is available from local read-out in the intake structure, the plant computer and offsite sources.
2.2  Resources for Detection/Assessment of Radiological Releases 2.2.1     Plant Process Radiation Monitors This instrumentation, a part of the Radiation Monitoring System (RMS), is provided to monitor systems in strategic locations throughout the plant for normal and emergency conditions. The monitors are used for trending, determining radioactive material release permit limits, initiating safety signals to limit releases and assessing release rates during an emergency.
The channels of this system provide data both in the Control Room and on the Emergency Response Facility Computer System (ERFCS).
Depending on the type, the various monitors in the system can be used to detect particulate and gaseous radioactivity levels at release points throughout the plant, including containment. The system also provides accident range capability on the Auxiliary Building Ventilation Stack and the Main Steam line.
2.2.2 Area Radiation Monitors Area Radiation Monitors are strategically located throughout the plant to monitor gamma radiation levels.
2.2.3 Meteorological Instrumentation The plant has a permanent 110m meteorological tower with detectors at 10 and 60 meters, and a redundant power supply; the sole output of information from the tower is the ERFCS. In the event of failure of this system, wind speed and direction can be obtained from the National Weather Service in Valley NE, or the Offutt Air Force Base.
The USAR Section 2.5 discusses the terrain around Fort Calhoun Station and its effects on an airborne plume. Historical meteorological data is also available from the plant computer. This data will be made available by OPPD to the appropriate government agencies.

FCS                                                                     EP-FC-1001 Section I Revision 0TBD Page 94 of 170 ACCIDENT ASSESSMENT 2.2.4 Water Analyses Analyses of plant liquid systems may be performed to help ascertain the nature of problems detected by other instrumentation (prior to an emergency situation).
The samples will be collected and analyzed per applicable Fort Calhoun Station procedures.
2.2.5 Post Accident Sampling Methods have been established to collect and analyze samples from the primary coolant system, containment atmosphere, auxiliary building ventilation duct pathway, the main steam safety relief and atmospheric dump valve pathway, and the occupied areas. These methods are described in applicable Fort Calhoun Station procedures.
2.3  Field Monitoring 2.3.1 Monitoring Operations In the event of an unplanned airborne materials release following an accident, field monitoring teams will be dispatched to evaluate activity levels.
River water samples can be collected and analyzed in the event radioactive water or liquid is discharged without proper monitoring per the Environmental Monitoring Program. The Metropolitan Utilities District will be notified when accidental liquid discharges occur.
The primary objective of the emergency onsite and offsite field monitoring teams is to survey areas downwind of the plant site in order to determine the extent and magnitude of any unplanned release of radioactive material following an incident.
The task of each monitoring team is to collect air samples and survey data and transmit information and results to the appropriate emergency response facility.
This information will be used to define affected areas, and assess the extent and significance of the release. Surveys are done per the applicable Radiation Protection or Emergency Plan procedures.
2.3.2 Personnel A. Onsite Field Monitoring The onsite field monitoring teams focus is primarily on obtaining radiological data within the protected area. These teams are typically dispatched from either the Control Room or Operations Support Center.

FCS                                                                     EP-FC-1001 Section I Revision 0TBD Page 95 of 170 ACCIDENT ASSESSMENT B. Offsite Field Monitoring The offsite field monitoring team(s) focus is on obtaining radiological data outside the owner controlled area. Primary direction of the off-site field monitoring teams is from the EOF, with back up capability at the TSC.
C. Environmental Monitoring Environmental monitoring may be done as a function of recovery from an emergency. Types of sample media and team makeup are dependent upon the needs determined by management personnel.
2.3.3 Equipment Section H of this plan and the applicable station procedures list the Emergency Kit locations.
3.0  ASSESSMENT OF RADIOLOGICAL RELEASES 3.1  Methods of Assessment The methods used for the assessment of radioactivity released to the environs are detailed in the Emergency Plan Implementing Procedures.

FCS EP-FC-1001 Section J Revision 0TBD Page 96 of 170 PROTECTIVE RESPONSE 1.0 PUBLIC INFORMATION CONTENT AND DISSEMINATION 1.1 Notification 1.1.1      Onsite personnel are notified of a nuclear emergency via the emergency alarm. This alarm is identified by an intermittent howl and is distinguished from the fire alarm which is a continuous howl. Once the emergency alarm is sounded, the command and control position will give the emergency classification, with other pertinent information, using the intra-plant communication system (Gaitronics). If the owner-controlled area is to be evacuated, personnel will be notified by: 1) Gaitronics System, 2)
Administration and Training Building paging systems, 3) Security Personnel, and/or 4) Alert Notification System, if used.
1.2 Evacuation 1.2.1      If the emergency requires Protected Area evacuation, all onsite personnel considered nonessential to the mitigation of the event will normally proceed to a designated location or to their homes. If a release has occurred or there is reason to suspect contamination the evacuees will be sent to the OPPD Elkhorn Center.
1.2.2      Approximately 600 persons might be evacuated during normal work hours and operation; approximately 900 persons might be evacuated during a major outage. During normal operating off-shift hours, no evacuation of onsite individuals is expected. Both OPPD and personal vehicles are used for site evacuation transportation. Agreements with the State of Nebraska and specifically the State Patrol guarantee professional handling and control of traffic. Normal travel time to Elkhorn Center is 37 minutes using the normal evacuation route and 53 minutes using the alternate evacuation route at an average speed of 40 mph. Personnel at the Elkhorn Center will coordinate personnel/vehicle monitoring and decontamination activities, if required.
1.2.3      Security and RP personnel inspect the owner controlled area after a site evacuation has taken place. If any persons other than emergency workers are in the owner controlled area during or after site evacuation, they will be given specific directions and/or escorted off-site.

FCS EP-FC-1001 Section J Revision 0TBD Page 97 of 170 PROTECTIVE RESPONSE 1.3 Security and Accountability 1.3.1     Security A. The security program is designed to deter, delay and detect an intruder.
The Security Area of the plant site is enclosed by an eight foot security fence topped by three strands of barbed wire. All gates to the fence are normally kept locked. An inner perimeter consists of personnel doors, roof hatches, and overhead doors equipped with magnetic alarm switches.
B. Personnel assigned by the Site Director to enter the plant must pass through the main gate which is guarded. It is extremely unlikely that any unauthorized person would be able to enter the site undetected even during an emergency condition.
1.3.2     Accountability A. If accountability of onsite personnel is necessary, the onsite command and control position will notify personnel onsite by announcements on the Gaitronics System, and by sounding the Emergency Alarm (if required). At the completion of the notification(s), the accountability process begins, to be completed within 30 minutes.
B. Accountability is a process taking place in several areas:
: 1. Accountability of personnel reporting to the Control Room, TSC, or OSC for emergency response will be performed by personnel using the card readers at these locations.
: 2. Accountability of security force personnel will be accomplished using established security procedures.
: 3. Once initial accountability is complete, the command and control position, will be notified of the results.
: 4. Accountability is maintained by the use of rosters at the Control Room, OSC and TSC. Persons must sign in and out as they enter and leave. These rosters will be compared to a list of personnel who accessed the protected area whenever necessary. Continuous accountability of security personnel is accomplished using established security procedures.

FCS EP-FC-1001 Section J Revision 0TBD Page 98 of 170 PROTECTIVE RESPONSE 1.4 Protective Measures 1.4.1     It is the policy of OPPD to keep personnel radiation exposure within federal regulations, and station limits and guidelines, beyond that, to keep it As Low As Reasonably Achievable (ALARA). Every effort will be made to keep their exposures within the limits of 10 CFR 20.
1.4.2     Personnel monitoring devices are required for all personnel meeting the conditions specified in 10 CFR 20 Section 20.1502, Technical Specifications Section 5.11 and in Radiation Protection Procedures. During emergency conditions, implementing procedure EP-FC-113 will be utilized.
1.4.3     Dosimeters and TLDs are typically located in each of the emergency lockers in the Control Room, EOF, OSC and the TSC. Additional dosimeters and TLDs may be obtained from the dosimetry group.
1.4.4     Clothing A. Protective clothing is a normal use item utilizing both washable and disposables. For entry into affected areas, the OSC has approximately 50 complete sets of protective clothing available. The Control Room has approximately 12 complete sets available. Additional sets are available at the Radiation Control Point. Approximately 2000 sets are ready for use and a large supply of washable and/or disposable coveralls is maintained in the warehouse and RP storage areas. Water-proof protective clothing is also a standard stock item.
1.4.5     Respiratory Protection A. Respiratory protective devices may be required in any situation arising from plant operations where an airborne radioactivity condition is potential or existent. In such cases, the air will be monitored and the necessary protective devices specified according to the concentration and type of airborne contaminants present. Monitoring and issue of respiratory protection equipment will be conducted in accordance with Radiation Protection Manual Procedures. Precautions will be taken to keep airborne contamination to a minimum through the use of proper engineering controls and decontamination.
B. Limits for inhalation of radionuclides are established in Appendix B, Table 1 of 10CFR20. The Radiation Protection Manual establishes the station's administrative limits for inhalation which will be adhered to in emergencies if possible.
C. Types and recommended use for each type of respirator is specified in the Radiation Protection Manual.

FCS EP-FC-1001 Section J Revision 0TBD Page 99 of 170 PROTECTIVE RESPONSE D. Approximately 35 self contained breathing apparatus are maintained onsite. Of these, a portion is maintained for fire brigade use, or normal use, and the remainder for emergency response. Spare bottles are also stored in some locations. The site has the capability to refill bottles with a compressor/air bank unit, with a cascade tank unit as a backup.
Full-face respirators are maintained in some emergency gear lockers.
Respirators are staged for use in plant radiation areas. The onsite Stores warehouse stocks approximately 150 full-face respirators for reserve supply.
1.4.6     Radioprotective Drugs A. The need for issuance of radioprotective drugs, specifically potassium-iodide, is determined using appropriate procedures.
B. Radioprotective drugs in the form of potassium iodide tablets are available in the Control Room, Technical Support Center, Operations Support Center, Emergency Operations Facility and the Field Team equipment lockers. Each bottle contains dosage supply for 14 days.
Emergency workers are instructed on the advantages and disadvantages of taking the tablets to provide thyroid blockage. The final decision for use of the potassium iodide is made by the emergency worker.
2.0 PROTECTIVE RESPONSE FOR RESIDENTS WITHIN THE PLUME EXPOSURE PATHWAY 2.1 Protective Action Recommendations 2.1.1     OPPD Guidelines A. Fort Calhoun Station is designed and equipped with a series of safety systems engineered to meet all of 10 CFR 100 criteria for reactor safety.
OPPD recognizes that in any accident situation, it would be prudent and logical to make every effort to further reduce and minimize exposure to the public. OPPD management will recommend to appropriate State and local authorities that protective actions be initiated if any person is expected to receive an emergency exposure in excess of Environmental Protection Agency (EPA) guidelines.
B. Tables J-11 through J-41 provides some information and guidance on formulating Protective Action Recommendations (PAR's). Table J-11 summarizes the considerations for selecting the evacuation Protective Action Guides (PAG's). Table J-21 outlines the early (plume) phase PAG's due to exposure of airborne and deposited radioactivity.
Table J-31 summarizes the considerations for selecting relocation PAG's.
Table J-41 outlines the immediate (relocation) phase PAG's due to exposure to deposited radioactivity.

FCS EP-FC-1001 Section J Revision 0TBD Page 100 of 170 PROTECTIVE RESPONSE C. During the early (plume) phase of a radiological emergency, professional judgement will be required in the application of PAG's, due to varying characteristics, such as; plant conditions, evacuation time estimates, environmental conditions, affected population groups, etc. In all cases, the PAR's transmitted by OPPD to the states of Iowa and/or Nebraska are strictly recommendations. The respective government agencies in each state have the ultimate responsibility for implementing necessary protective actions for the general public.
1 Taken from "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents." EPA-400-R-92-001, Revised May, 1992.
D. Tables J-5 and J-6 provide information pertaining to emergency worker exposure limits and health risks associated with exposure to higher dose levels.
2.1.2      Initiation of Recommendations A. Recommendations will originate from an Emergency Response Facility based upon data derived from implementing procedure, EP-FC-110, Assessment of Emergencies. This procedure establishes a method for determining projected doses to the population-at-risk. Protective action recommendations based on radiological parameters or plant conditions are determined using EP-FC-111, Emergency Classification and Protective Actions. Total population exposure can be estimated using projected or known dose values and population densities.
2.2 Notification 2.2.1      In the event public notification is required, both transient and resident population within the plume exposure pathway will be initially notified through the Alert Notification System (reference Section E) and as described in state and county radiological emergency plans. Information will be provided for transient and resident population as well as the general public outside the EPZ through the Emergency Alert System.
2.2.2      Information brochures describing notification, protective actions and general radiological education are provided to residents by mail and by public service posting to transients within the EPZ. The States of Iowa and Nebraska will issue messages describing the incident and recommended public protective actions.

FCS EP-FC-1001 Section J Revision 0TBD Page 101 of 170 PROTECTIVE RESPONSE 2.3 Evacuation 2.3.1    Evacuation Time Estimate Study A. Studies estimating the time required to evacuate the residents in the plume exposure pathway from the emergency planning zone were conducted in accordance with NUREG-0654, Rev. 1, Appendix 4 criteria.
These studies are supporting documents to this Plan. Summaries of the Nebraska and Iowa evacuation time estimate studies are outlined in KLD Engineering, P.C., Fort Calhoun Nuclear Station, Development of Evacuation Time Estimates (EP-FC-1001 Addendum 2). Reference Figure 6-1, Tables 7-1 through 7-6, and Table 3-7.
2.3.2    Evacuation of Areas within the EPZ A. The Governor (or Governor's Authorized Representative) of Nebraska can authorize the Nebraska State Patrol and Emergency Management Agency, based on recommendations of the State Health Department, to evacuate Nebraska residents to the reception center in Fremont, Nebraska.
B. The Governor (or Governor's Authorized Representative) of Iowa can authorize the Iowa State Patrol and the Emergency Management Division to evacuate Iowa residents to Denison, Iowa, based upon recommendations of the Iowa Department of Public Health.
C. Evacuees from the Nebraska portion of the EPZ should go to the Fremont Reception Center. Evacuees from the Iowa portion of the EPZ should proceed to the Denison Reception Center. Figure J-5 shows the boundaries and highways leading to the Reception Centers.
D. The relocation centers for the host areas are as follows:
Fremont Fremont Middle School 540 Johnson Rd Denison Denison Community High School, North 16th E. The ingestion planning zone (IPZ) encompasses a 50 mile radius as illustrated in Figure J-6. Population for the IPZ is presented in Figure J-7 by sectors.

FCS EP-FC-1001 Section J Revision 0TBD Page 102 of 170 PROTECTIVE RESPONSE F. The plume exposure EPZ encompasses an approximate 10 mile radius as illustrated in Appendix H, (EP-FC-1001 Addendum 2). The EPZ includes portions of Harrison and Pottawattamie Counties in Iowa, Washington and Douglas Counties in Nebraska. The States of Iowa and Nebraska are separated by the Missouri River. Table 3-5 through 3-8, (EP-FC-1001 Addendum 2),shows the total population within the EPZ, and population totals for each Sub Area. This includes showing Estimated Transient population.
2.4 Protective Methods (Other than Evacuation) 2.4.1     Sheltering A. Remaining indoors during the passage of a radioactive cloud affords the dweller a reduction in the quantity of radionuclides inhaled, as well as providing shielding. Figure J-9 shows the ratio of the inhaled dose inside a shelter to that outside the shelter as a function of the ventilation rate. A ventilation rate survey showed a rate variance of 0.07 to 3.0 per hour.
The ventilation rate is affected by temperature differential, wind speed and direction, quality of construction and topographical setting.
B. Walls of buildings absorb and scatter gamma rays, thus providing a lower dose to the occupants. The shielding factor of a building is the ratio of the interior dose to the exterior dose. Shielding factor estimates applicable to residential housing units were made using the shielding technology by Z. G. Burson and A. E. Profio (1975). Table J-7&#xb2; summarizes shielding factors for designated structures/locations from a gamma cloud source.
1,2,3 C.       Table J-83 summarizes the shielding factors for designated structures/locations from surface deposition of radioactive material.
Burson and Profio proved that the fallout shielding technology developed via nuclear weapons tests could be directly applied to radioactivity deposited on surfaces after a reactor accident. The shielding factors listed in Table J-8 assume uniform distribution of the radioactive fallout.
D. In each of the cases discussed, inhalation and shielding factors from a gamma cloud source and shielding factors from surface deposition of radioactive material, it is noted that the shielding factors using sheltering as a method of protection ranges from 0.6 to 0.005. Although the best protection seems to be the basement of large multi-structured buildings, the basement of any house has been proven to provide significant shelter from airborne and surface deposited radioactive material.
1       Taken from WASH-1400(NUREG-75/014), October 1975, Figure VI.11-4.
2       Taken from WASH-1400(NUREG-75/014), October 1975, Figure VI-11-7.
3       Taken from WASH-1400(NUREG-75/014), October 1975, Figure VI-11-8.

FCS EP-FC-1001 Section J Revision 0TBD Page 103 of 170 PROTECTIVE RESPONSE 2.5 Radiological Environmental Monitoring 2.5.1    In the event of an emergency, the permanent air particulate stations are first utilized for immediate data, concerning airborne releases. Background radiation stations (TLDs) provide short term exposure data and are periodically replaced. See the specific Radiological Environmental Monitoring Surveillance Test for more information. TLD use can be increased during the longer term as the District maintains a TLD services contract with an off-site vendor. The environmental laboratory personnel perform accelerated collection and analysis of samples as their primary responsibility after an emergency occurs. Sampling requirements will be determined by the environmental laboratory personnel.
2.5.2    Sample analysis will be performed by the station and at offsite facilities as deemed necessary.

==3.0 REFERENCES==
AND COMMITMENTS 3.1 EP-FC-1001 Addendum 2, Evacuation Time Estimates KLD TR-535 3.2 EP-FC-1001, Evacuation Time Estimates Table 1, 50 Mile 2010 Population Table Table 3-5 Table 3-7, Summary of Population Demand Table 3-8 Table 7-1 through Table 7-6, Time to clear the Indicated Area of 90% of the Affected Population Figure 1, 50 Mile 2010 Population Rose Figure 5-2, Evacuation Mobilization Activities Figure 6-1, FCNS EPZ Sub Areas Appendix K

FCS EP-FC-1001 Section J Revision 0TBD Page 104 of 170 PROTECTIVE RESPONSE Table J Summary of Considerations for Selecting the Evacuation PAG's1 DOSE Rem                                     Consideration(s)
(mrem) 50 Rem           Assumed threshold for acute health effects in adults.
(50000 mrem) 10 Rem           Assumed threshold for acute health effects in the fetus.
(10000 mrem) 5 Rem          Maximum acceptable dose for normal occupational exposure for (5000 mrem)         adults.
5 Rem          Maximum dose justified to average members of the population, (5000 mrem)         based on the cost of evacuation.
0.5 Rem          Maximum acceptable dose to the general population from all (500 mrem)         sources from nonrecurring, non-accidental exposure.
0.5 Rem          Minimum dose justified to average members of the population, (500 mrem)         based on the cost of evacuation.
0.5 Rem          Maximum acceptable dose2 to the fetus from occupational (500 mrem)         exposure of the mother.
0.1 Rem          Maximum acceptable dose to the general population from all (100 mrem)         sources from routine (chronic) non-accidental exposure.
0.03 Rem          Dose that carries a risk assumed to be equal to or less than that (30 mrem)         from evacuation.
1 Taken, in part, from Table C-8, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, EPA-400-R-92-001, May, 1992 2
This is also the dose to the 8 to 15 week-old fetus at which the risk of mental retardation is assumed to be equal to the risk of fatal cancer to adults from a dose of 5 rem.

FCS EP-FC-1001 Section J Revision 0TBD Page 105 of 170 PROTECTIVE RESPONSE Table J Protective Action Recommendations Based on Dose Assessment/Field Team Radiological Data Instructions: Compare URI or Field Team Dose Assessment results to the following table.
Expand PAR to include downwind sectors in accordance with EP-FC-111-AD-F-02.
Projected Dose                    Protective Action Recommendation (PAR)
  < 1 rem TEDE                                           NONE (No Par Required)
  < 5 rem CDE (thyroid)                        And continue monitoring radiological conditions 1 rem TEDE                                             Evacuate *see note 5 rem CDE                                  And continue monitoring radiological conditions 50 rem SDE (skin)                                           Evacuate And continue monitoring radiological conditions NOTE: SHELTERING may be considered for doses up to 5 rem TEDE in special situations such as (1) the presence of severe weather (2) competing disasters (3) institutionalized people who are not readily mobile; and (4) other local factors, which may impede evacuation.

FCS EP-FC-1001 Section J Revision 0TBD Page 106 of 170 PROTECTIVE RESPONSE Table J Summary of Considerations for Selecting PAG's for Relocation1 DOSE Rem Consideration(s)
(mrem) 50 Rem          Assumed threshold for acute health effects in adults.
(50000 mrem) 10 Rem          Assumed threshold for acute health effects in the fetus.
(10000 mrem) 6 Rem         Maximum projected dose in first year to meet 0.5 Rem in the second (6000 mrem)        year2.
5 Rem         Maximum acceptable dose for normal occupational exposure for adults.
(5000 mrem) 5 Rem         Minimum dose that must be avoided by one year relocation based on (5000 mrem)        cost.
3 Rem         Minimum projected first-year dose corresponding to 5 Rem in 50 years2.
(3000 mrem) 3 Rem         Minimum projected first-year dose corresponding to 0.5 Rem in the (3000 mrem)        second year2.
2 Rem         Maximum dose in first year corresponding to 5 Rem in 50 years from a (2000 mrem)        reactor incident, based on radioactive decay and weathering only.
1.25 Rem         Minimum dose in first year corresponding to 5 Rem in 50 years from a (1250 mrem)        reactor incident, based on radioactive decay and weathering only.
0.5 Rem         Maximum acceptable single-year dose to the general population from all (500 mrem)        sources from non-recurring, non-incident exposure.
0.5 Rem         Maximum acceptable dose to the fetus from occupational exposure of (500 mrem)        the mother.
0.1 Rem         Maximum acceptable annual dose to the general population from all (100 mrem)        sources due to routine (chronic), non-incident, exposure.
0.03 Rem         Dose that carries a risk assumed to be equal to or less than that from (30 mrem)        relocation.
1 Taken, in part, from Table E-5, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents", EPA-400-R-92-001, May, 1992.
2 Assumes the source term is from a reactor incident and that simple dose reduction methods are applied during the first month after the incident to reduce the dose to persons not relocated from contaminated areas.

FCS EP-FC-1001 Section J Revision 0TBD Page 107 of 170 PROTECTIVE RESPONSE Table J Protective Action Guides for Exposure to Deposited Radioactivity1 PAG Protective Action             (projected dose                       Comments in first year)2 Relocate the general                2 Rem         Beta dose to skin may be up to 50 times population3                    ( 2000 mrem)       higher.
Apply simple dose                  < 2 Rem         These protective actions should be taken reduction techniques4          (< 2000 mrem)       to reduce doses to as low as practicable levels.
1 Taken, in part, from the "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents", EPA-400-R-92-001, May, 1992.
2 The projected sum of total effective dose equivalent (TEDE) from external gamma radiation and committed effective dose equivalent (CEDE) from inhalation of resuspended materials, from exposure or intake during the first year. Projected dose refers to the dose that would be received in the absence of shielding from structures or the application of dose reduction techniques. These PAG's may not provide adequate protection from some long-lived radionuclides.
3 Persons previously evacuated from areas outside the relocation zone defined by this PAG may return to occupy their residences. Cases involving relocation of persons at high risk from such action (e.g., patients under intensive care) should be evaluated individually.
4 Simple dose reduction techniques include scrubbing and/or flushing hard surfaces, soaking or plowing soil, minor removal of soil from spots where radioactive materials have concentrated, and spending more time than usual indoors or in other low exposure rate areas.

FCS EP-FC-1001 Section J Revision 0TBD Page 108 of 170 PROTECTIVE RESPONSE Table J Emergency Worker Exposure Limits Dose Limit              Activity                       Condition(s) 500 mrem All Activities               Declared Pregnant Emergency Workers TEDE 5 Rem TEDE All Activities               Non-Pregnant Emergency Workers 10 Rem TEDE Protecting Valuable Property A lower dose is not practicable 25 Rem TEDE Life Saving or Protection of A lower dose is not practicable Large Populations
 >25 Rem TEDE  Life Saving or Protection of Only on a voluntary basis to persons fully Large Populations            aware of the risks involved. (See Table J-6)

FCS EP-FC-1001 Section J Revision 0TBD Page 109 of 170 PROTECTIVE RESPONSE Table J Summary of Risks Involved with Higher Dose Limits (taken form EPA 400 R-92-001, May, 1992)
Health Effects Associated with Whole-Body Absorbed Dosed Received Within a Few Hoursa Prodromal Whole Body                   Early               Whole Body Effectsc Absorbed Dose              Fatalitiesb           Absorbed Dose (percent (rad)                  (percent)                 (rad) affected) 140                        5                      50                    2 200                       15                     100                   15 300                       50                     150                   50 400                       85                     200                   85 460                       95                     250                   98 (a)
Risks will be lower for protracted exposure periods.
(b)
Supportive medical treatment may increase the dose at which these frequencies occur by approximately 50 percent.
(c)
Forewarning symptoms of more serious health effects associated with large doses of radiation.
Approximate Cancer Risk to Average Individuals from 25 Rem Effective Dose Equivalent Delivered Promptly Approximate Risk of Premature      Average Years of Life Age at Exposure                          Death                  Lost in Premature (years)                  (deaths per 1,000 persons               Death exposed)                   Occurs (years) 20 to 30                             9.1                            24 30 to 40                             7.2                            19 40 to 50                             5.3                            15 50 to 60                             3.5                            11

FCS EP-FC-1001 Section J Revision 0TBD Page 110 of 170 PROTECTIVE RESPONSE Table J Representative Shielding Factors from Gamma Cloud Source Structure or Location                Shielding Factor(a)       Representative Range Outside                                              1.0                        ----
Vehicles                                             1.0                        ----
(b)
Wood - frame (no basement)                           0.9                        ----
Basement of wood house                               0.6                    0.1 to 0.7(c)
Masonry house (no basement)                          0.6                   0.4 to 0.7(c)
Basement of masonry house                            0.4                   0.1 to 0.5(c)
Large office or industrial building                  0.2                   0.1 to 0.3(c,d)
(a)
The ratio of the interior dose to the exterior dose.
(b)
A wood frame house with brick or stone veneer is approximately equivalent to a masonry house for shielding purposes.
(c)
This range is mainly due to different wall materials and different geometries.
(d)
The reduction factor depends on where the personnel are located within the building (e.g., the basement or an inside room).
NOTE: Consideration is limited to gamma radiation since beta and alpha particles cannot penetrate the walls of structures.
* Taken from WASH-1400 (NUREG-75/104), October 1975.

FCS EP-FC-1001 Section J Revision 0TBD Page 111 of 170 PROTECTIVE RESPONSE Table J Representative Shielding Factors for Surface Deposition Structure or Location                 Representative (a)    Representative Range Shielding Factor 1 m above an infinite smooth surface                   1.00                     ----
1 m above ordinary ground                              0.70                0.47 - 0.85 1 m above center of 50-ft roadways,                    0.55                  0.4 - 0.6 half contaminated Cars on 50-ft road:
Road fully contaminated                            0.5                  0.4 - 0.7 Road 50% decontaminated                            0.5                  0.4 - 0.6 Road fully decontaminated                         0.25                  0.2 - 0.5 Trains                                                 0.40                  0.3 - 0.5 One and two-story wood-frame house (no basement)                                    0.4(b)                0.2 - 0.5 One and two-story block and brick house (no basement)                                    0.2(b)              0.04 - 0.40 House basement, one or two walls fully exposed:                                         0.1(b)              0.03 - 0.15 One story, less than 2 ft of basement, walls exposed                                0.3(b)              0.03 - 0.07 Two stories, less than 2 ft of basement, walls exposed                                0.3(b)              0.02 - 0.05 Three or four-story structures,
 >5,000 ft2 per floor:
First and second floor                                0.05(b)              0.01 - 0.08 Basement                                              0.01(b)              0.001 - 0.07 Multistory structures, >10,000 ft2 per floor:
Upper floors                                          0.01(b)              0.001 - 0.02 Basement                                              0.005(b)            0.001 - 0.015 (a)
The ratio of the interior dose to the exterior dose.
(b)
Away from doors and windows.

FCS EP-FC-1001 Section J Revision 0TBD Page 112 of 170 PROTECTIVE RESPONSE Figure J Routes to Relocation Centers

FCS EP-FC-1001 Section J Revision 0TBD Page 113 of 170 PROTECTIVE RESPONSE Figure J Ingestion Pathway EPZ

FCS EP-FC-1001 Section J Revision 0TBD Page 114 of 170 PROTECTIVE RESPONSE Figure J Ratio of Inhaled Dose Inside a Shelter to that Outside the Shelter as a Function of Ventilation Rates

FCS                                                                   EP-FC-1001 Section K Revision 0TBD Page 115 of 170 RADIOLOGICAL EXPOSURE CONTROL 1.0  EXPOSURE GUIDELINES 1.1  It is OPPD policy to comply with the ALARA concept, and all efforts shall be made to keep all workers within normal Fort Calhoun Station limits, as listed in the Radiation Protection Manual. However, if it is expected that workers may exceed these limits, any dose received during emergency conditions in excess of 5 Rem TEDE will be assigned as once in a lifetime exposure.
1.2  The facility directors, Control Room Coordinator or Shift Manager in the Control Room, Site Director or TSC Director in the TSC, the OSC Director in the OSC or the Emergency Director in the EOF may authorize dose extension up to 5 Rem TEDE per year during declared events for workers in their facility.
1.3  The Command and Control position shall authorize any extensions beyond normal occupational exposure limits and direct that any dose received in excess of these limits be assigned as once in a lifetime exposure. The following guidance is from the FCS Radiation Protection Manual, and the Manual of Protective Action Guidelines and Protective Action for Nuclear Incidents, EPA-400-R-92-001.
5 Rem TEDE for all emergency workers 10 Rem TEDE when action is necessary to reduce a hazard potential to acceptable levels or to prevent substantial loss of property 25 Rem TEDE when action is necessary to perform lifesaving functions or to reduce the potential hazards to the health and safety of the public
         >25 Rem TEDE on a voluntary basis and only to save a life or reduce potential hazards to the health and safety of the public 1.4  Plant personnel that require access to Radiation Controlled Areas are issued TLDs on a frequency specified by Radiation Protection. Many ERO positions are also issued TLDs depending on the likelihood of having to enter a Radiation Controlled Area under emergency conditions. TLD requirements for ERO positions are identified on the ERO Roster.
1.5  Personnel responding to the site that require, but do not have, dosimetry will be issued dosimetry by Security or Radiation Protection personnel. The following ERO positions can also issue dosimetry when necessary:
Control Room: The Shift RP Technician or OSC RP Technicians TSC: OSC RP Technicians OSC: The OSC Dosimetry Technician or OSC RP Technicians

FCS                                                                   EP-FC-1001 Section K Revision 0TBD Page 116 of 170 RADIOLOGICAL EXPOSURE CONTROL 2.0  CONTAMINATION CONTROL 2.1  If actual or potential contamination problems exist onsite, ERO management may elect to establish contamination control and monitoring measures. These may consist of some or all of the following:
Each Emergency Response Facility onsite has the capability to establish control boundaries to minimize contamination spreading into the facility.
Monitoring of personnel evacuating the affected area using installed monitors in the Security Building or personnel with portable equipment. Portable equipment for this purpose is stored both in the warehouse and at the EOF.
2.2  If personnel decontamination becomes necessary, the site maintains two facilities for this purpose. One is located in the Auxiliary Building entry/exit point, and is frequently used. It drains to the Radwaste System. The second facility is located in the Warehouse and is designated for emergency use only. It drains to a holding tank, which is controlled after emergency use to ensure that the contents are monitored and processed if necessary.
2.3  Contaminated personnel that are evacuated will be decontaminated as determined by Radiation Protection personnel. Additional decontamination facilities are available at state decontamination facilities and at the UNMC Regional Radiation Health Center.
2.4  Tools and equipment that become contaminated will be decontaminated as determined by Radiation Protection personnel.
2.5  Areas that become contaminated will be decontaminated as determined by Radiation Protection personnel.
2.6  Priorities for decontaminating tools, equipment and areas will be established by ERO management, with top priority given to contamination within areas that are or will be inhabited by emergency workers. Decontamination of non-essential areas, tool and equipment should be delayed to allow for natural decay of radioactive materials.
2.7  Potable water, normally supplied from the City of Blair, and onsite food supplies can be chemically and radiologically monitored prior to use by emergency workers.
2.8  Contamination limits, contamination control, and decontamination criteria may be adjusted based on professional radiological evaluation by the ERO using guidance in the Radiation Protection Manual.
2.9  Radioactive waste from any decontamination effort will be prepared and shipped in accordance with Radiation Protection Manual requirements.

FCS EP-FC-1001 Section L Revision 0TBD Page 117 of 170 MEDICAL AND PUBLIC HEALTH SUPPORT 1.0  ONSITE FIRST AID 1.1  There are generally four types of response considered at the Fort Calhoun Station:
: 1)      Minor injury, no contamination
: 2)      Minor injury, contaminated
: 3)      Major injury (requiring offsite treatment), no contamination
: 4)      Major injury, contaminated 1.2  The order of medical treatment will be:
: 1)      Care of severe physical injuries
: 2)      Decontamination of personnel
: 3)      First aid to other injuries
: 4)      Monitor for internal contamination
: 5)      Definitive treatment and subsequent therapy as required 1.3  All injuries at the station must be immediately reported to the Shift Manager, who will initiate response according to the Fort Calhoun Station Safety Manual, FCSG-15-7, Medical Emergencies. When the OSC is activated the OSC Director and the OSC Medical Coordinator will be responsible for response to medical emergencies.
1.4  When personnel are severely injured and contaminated, first aid shall take precedence over decontamination. In cases where internal exposure is suspected, a bioassay program may be performed as directed by the Radiation Protection Manual.
1.5  First Aid Facilities 1.5.1       A First Aid Room is located in the Maintenance Building. This room is equipped with various medical supplies to provide emergency first aid to injured personnel.
1.5.2       Other equipment located throughout the plant include first aid kits, Emergency Medical Technician (EMT) kits, personnel carriers, a wheelchair, and contaminated/injured personnel response kit. The Industrial Safety Coordinator inspects and maintains this equipment.

FCS EP-FC-1001 Section L Revision 0TBD Page 118 of 170 MEDICAL AND PUBLIC HEALTH SUPPORT 1.6  Medical Response 1.6.1    Minor Injury, No Contamination A. The Shift Manager or other evaluators will determine the extent of medical response required. This could include:
: 1. On the spot treatment by the individual or first aid qualified responders.
: 2. On the spot treatment by EMT qualified personnel (if available).
: 3. Movement of the injured party to the first aid room by medical responders for access to additional equipment.
: 4. Other response determined necessary by responding personnel.
1.6.2    Minor Injury, Contaminated A. Personnel that are injured and are potentially contaminated will be treated as explained above, and will also be monitored for contamination by Radiation Protection personnel. Monitoring and decontamination will be performed in accordance with Radiation Protection procedures.
1.6.3    Major Injury, No Contamination A. Medical responders will be dispatched to the scene to perform first aid as required. The Shift Manager or designee will notify offsite authorities to provide victim transport to an available medical facility. Both air and ground transportation are available.
1.6.4    Major Injury, Contaminated A. Personnel that are severely injured and are potentially contaminated will be treated as explained above, and will also be monitored for contamination by Radiation Protection personnel. If feasible, monitoring and decontamination will be performed in accordance with Radiation Protection Procedures. If decontamination is successful, the victim may be transported to any available medical facility for treatment.
B. If decontamination is not successful or not feasible, the victim will be transported to the UNMC Regional Radiation Health Center, unless the responding Emergency Medical Services (EMS) personnel deem it medically necessary to proceed to a closer facility. If another facility other than UNMC is used, additional Radiation Protection personnel should be sent to the facility to assist in monitoring, decontamination and clean up.

FCS EP-FC-1001 Section L Revision 0TBD Page 119 of 170 MEDICAL AND PUBLIC HEALTH SUPPORT 2.0  MEDICAL TRANSPORTATION 2.1  Blair Fire Department and Rescue Squad The Blair Fire Department and Rescue Squad Station is located less than four miles from the Fort Calhoun Station. The Rescue squad furnishes transportation for the injured and administers first aid enroute to the hospital.
2.2  Fort Calhoun Fire and Rescue Squad The Fort Calhoun Fire and Rescue Squad headquarters is located approximately 3-1/2 miles from the Fort Calhoun Station. This rescue squad serves as backup to the Blair Fire Department and Rescue Squad.
2.3  Missouri Valley Fire and Rescue Squad The Missouri Valley Fire and Rescue Squad is located approximately fifteen miles from the plant.
2.4  Additional support is available to both the Blair Fire Department and Rescue Squad and the Fort Calhoun Fire and Rescue Squad by request through the Tri-Mutual Aid Association (Douglas, Sarpy, and Washington Counties).
2.5  Other Modes of Transportation If necessary, there are other modes of transportation for delivering injured personnel to appropriate medical facilities.
2.5.1      Medical Ambulance helicopter 2.5.2      Onsite company vehicles 2.5.3      Private autos of company personnel 3.0  OFFSITE MEDICAL SUPPORT 3.1  Non-Contaminated Personnel The nearest medical facility is the Blair Memorial Community Hospital which is located five miles from the plant. A physician is readily available as a general medical consultant. Other facilities may be used as determined necessary by medical response personnel.

FCS EP-FC-1001 Section L Revision 0TBD Page 120 of 170 MEDICAL AND PUBLIC HEALTH SUPPORT 3.2  Contaminated Personnel 3.2.1   Omaha Public Power District maintains an agreement with the UNMC Regional Radiation Health Center to supply 24-hour treatment for all injuries involving contamination and/or personnel radiation exposure. The Regional Radiation Health Center is located approximately 25 miles from the plant in Omaha, Nebraska. The facility is part of the UNMC complex, and was established specifically for the treatment of injuries occurring from nuclear and radiation related incidents. An entrance (Figure L1) is available for the ingress and egress of contaminated victims to a special assessment and decontamination facility. Patients can also be transported to the facility via medical ambulance helicopters.
3.2.2   The UNMC Regional Radiation Health Center staff administers medical, decontamination, internal bioassay, and other nuclear medicine capabilities.
The staff maintains an appropriate "Standard Operating Procedures Manual" which describes their responsibilities and roles. If additional hospital beds should be required during a major incident, the hospital maintains a mutual agreement with several other Omaha area hospitals to assist with decontaminated patients.
3.2.3   Due to the large, highly qualified staff, the distance from the plant, the specialized capabilities, and the overall size of the UNMC complex, the Fort Calhoun Station was granted an exemption from requiring a backup medical facility by the Federal Emergency Management Agency.

FCS EP-FC-1001 Section L Revision 0TBD Page 121 of 170 MEDICAL AND PUBLIC HEALTH SUPPORT Figure L Entrance to Treatment Area UNMC Regional Radiation Health Center

FCS EP-FC-1001 Section M Revision 0TBD Page 122 of 170 MEDICAL AND PUBLIC HEALTH SUPPORT 1.0  RECOVERY ORGANIZATION (RO) 1.1  Responsibilities The Recovery Organization (RO) responsibilities include the overall coordination and management of the recovery effort and has provisions for technical and administrative services, design work, scheduling, planning, quality control/assurance, construction and vendor support.
1.2  Staffing The Recovery Organization would be composed of all the necessary technical, administrative, managerial, and support personnel required for the recovery phase of emergency response. This organization would be capable of 24 hour a day sustained operation.
The lead position in the Recovery Organization would be the Recovery Operations Manager. This individual would be appointed by the Command and Control Position of the Emergency Response Organization. The staffing positions of the rest of the Recovery Organization would be dependent upon the needs based on accident type and magnitude.
The responsibilities of the Recovery Operations Manager and the functions of possible staff members are detailed in the Emergency Plan Implementing Procedures.
1.3  Activation The activation of the Recovery Organization is through the directions given in the Emergency Plan Implementing Procedures governing the downgrading and termination of the emergency response phase. Downgrading and termination is achieved through a checklist format of considering not only the current and past conditions but also those conditions which have the potential to occur.
The ultimate decision for activation of the Recovery Organization rests with the Emergency Command and Control Position.

FCS EP-FC-1001 Section M Revision 0TBD Page 123 of 170 MEDICAL AND PUBLIC HEALTH SUPPORT 1.4  Transition The transition from Emergency Response Organization to Recovery Organization would consist of turning over functions that would continue while terminating other functions that would not be necessary. The extent of the turnover would be based upon the size of the Recovery Operations which would be dependent upon the type and magnitude of the emergency.
As a minimum, the facility directors at each of the Emergency Response Facilities will make an announcement concerning the shift to the Recovery Organization and direct all Emergency Response Organization Members to turn in all pertinent logs and forms to the administrative manager in each facility. A critique would follow at each facility while recovery operations were commencing.
2.0  REENTRY 2.1  Purpose The purpose for a reentry plan is to provide a means to regain access to an onsite or offsite area that was previously made inaccessible due to an emergency.
2.2  Responsibility The Command and Control Position has the responsibility for authorizing reentry into a previously evacuated area. This could be the Shift Manager, Control Room Coordinator, Site Director, or Emergency Director depending on the stage that emergency response has reached.
2.3  Implementation The implementation of the reentry plan is carried out by the Emergency Response Organization. Reentry is normally expected to be accomplished by teams dispatched from the Operations Support Center.
2.4  Emergency Radiation Exposure OPPD is committed to keeping exposure "as low as reasonably achievable" (ALARA).
It is understood that there are emergency situations which transcend the normal requirements for limiting exposure. When such situations exist, the Command and Control Position will make the determination as to the amount of radiation exposure that will be permitted based on the guidelines set forth in Section K of this Plan.

FCS EP-FC-1001 Section N Revision 0TBD Page 124 of 170 EXERCISES AND DRILLS 1.0 EXERCISES An emergency preparedness exercise is an event that tests the integrated capability and a major portion of the basic elements existing within the Radiological Emergency Response Plan (RERP), associated Emergency Plan Implementing Procedures (EPIPs) and the various organizations associated with the implementation of the RERP. Typically, an emergency preparedness exercise shall simulate an emergency that results in offsite radiological releases which would require response by offsite authorities. However, whenever the State of Nebraska and the State of Iowa are not participating in a particular exercise, the scenario should concentrate on realistic in-plant emergencies with less emphasis on offsite response.
Periodic emergency preparedness exercises can be conducted to evaluate major portions of emergency response capabilities. Also, exercises provide the opportunity to identify further improvements to the emergency preparedness program. Areas of improvement, weaknesses and deficiencies noted as a result of an exercise will be evaluated and corrected, as appropriate.
Normally, an exercise is not considered a "training function", as the participants are not guided, nor "coached", during an exercise. Interaction between controller/observers and participants is not allowed during an exercise, except for delivery and explanation of scenario information and data.
Exercises are conducted biennially, as a minimum. The states of Iowa and Nebraska, along with associated local governmental agencies, are invited to participate in all training drills and exercises, and are required to participate in the biennial exercise under evaluation by the Federal Emergency Management Agency. The Nuclear Regulatory Commission also performs routine inspections to evaluate licensee emergency response performance. The Resident Inspector(s) or other NRC personnel may observe licensee performance during training drills or non-evaluated exercises.
Drill and Exercise procedures are used to verify the following criteria:
1.1 State and local personnel and resources capability to respond to a radiological emergency response scenario.
1.2 Scenario variance from year to year in order to provide optimum training for radiological emergency response personnel.
1.3 Variance of hours in which the radiological emergency exercise is performed.
1.4 Joint radiological emergency exercise involving plant and Federal, State and local support groups, including any that involve a time variance.

FCS EP-FC-1001 Section N Revision 0TBD Page 125 of 170 EXERCISES AND DRILLS 2.0 DRILLS A drill is a supervised instruction period aimed at testing, developing and maintaining skills in a particular ERO position, function, center, or operation. A drill can be used as a specific training component of an exercise, if the exercise objectives identify and authorize such component. Drills will be supervised and evaluated by appropriate emergency planning personnel or other personnel with specific expertise pertaining to the drill or function being observed.
Periodic emergency preparedness drills are conducted to develop and maintain key skills within the ERO. Also, drills provide the opportunity to identify further improvements to the emergency preparedness program. Areas for improvement, weaknesses and deficiencies noted as a result of a drill will be evaluated and corrected, as appropriate.
At least one drill between biennial exercises will involve a combination of some of the principal functional areas of the onsite Emergency Response Organization, such as; command and control, accident assessment and classification, protective action recommendation decision making, and plant system and component repair and corrective actions. Simultaneous activation of all of the licensee's emergency response facilities during training drills is not necessary. Special functional drills can be developed and used to; focus on accident management strategies; supervised instruction periods for special or newly developed activities and/or procedures; allow resolution of problems (success paths) by ERO members, and; focus on identified onsite training objectives.
Normally, a drill is considered a "training function", as the participants are guided or "coached" during the actual drill. Interaction between controller/observers and participants is encouraged during a drill, except for instances where specific knowledge and memory are being tested.

FCS EP-FC-1001 Section N Revision 0TBD Page 126 of 170 EXERCISES AND DRILLS 2.1 Communication Drills Emergency Planning procedures provide for communication checks with appropriate agencies to ensure availability and operability of all channels of communication necessary for adequate response to a radiological emergency requiring off-site support. These tests outline those agencies to be contacted, the person (by name or title) who is responsible for verifying that adequate communication exists, the required frequency for which communication is to be checked, and a procedure for accomplishing the test. Below is the communication schedule for these checks or drills to be performed:
2.1.1       Communications are checked monthly from the EOF at the North Omaha Power Station with the States of Nebraska and Iowa and the local governments of the Counties of Harrison, Pottawattamie, and Washington and the NRC using dedicated communications equipment and backup systems. A functional check of the ERFCS is also performed on a monthly basis.
2.1.2       Communications are checked monthly from the Fort Calhoun Station Technical Support Center with the State of Nebraska and Iowa EOCs.
2.1.3       Communications are checked quarterly with Federal response agencies and the States of Nebraska and Iowa within the ingestion exposure pathway EPZ.
Also verified are communications with the JIC and functional checks of the FAX Network, radio system, and the ERF paging systems. Quarterly communications checks are performed from the Control Room with the NRC using both the FTS-ENS phone line and the Emergency Response Data System.
2.1.4       Communications are checked annually between the Fort Calhoun Station, the States of Nebraska and Iowa and local Emergency Operations Centers and field teams.
2.2 Fire Drills Fire drills are conducted by plant personnel on a quarterly basis. The drills are held to test the plant's firefighting capability. The drills are varied in order to test all phases of firefighting techniques.
The Blair Fire Department is annually invited to conduct a drill onsite. Onsite drills assist in familiarizing the fire department members with the types and locations of equipment available to mitigate plant fires.

FCS EP-FC-1001 Section N Revision 0TBD Page 127 of 170 EXERCISES AND DRILLS 2.3 Medical Emergency Drills The Nebraska Health Center, University Hospital Radiation Health Center is invited to participate in an annual exercise and/or scheduled drill(s) to demonstrate and practice the receipt and treatment of contaminated patients. The extent of the Center's participation depends on their work load and schedule for hospital patients at the time the exercise or drill is declared.
2.4 Health Physics and Radiological Monitoring Drills Emergency Planning procedures develop guides for the preparation, execution, and documentation of health physics and radiological monitoring drills. Execution of these procedures is shared by Emergency Planning and Radiation Protection.
There are two (2) types of drills performed by Chemistry and Radiation Protection Departments:
2.4.1      Semi-annually, a health physics drill is conducted to monitor the response to and analysis of simulated elevated airborne releases, and direct radiation measurements in the environment. Normally, this drill is conducted in conjunction with a quarterly training drill.
2.4.2      Annually a drill is held which involves the collection of a type of environmental sampling media by the Chemistry Departments Environmental Group.
The NRC waived the requirement for a Reactor Coolant liquid sample drill in the SER related to Technical Specification (T.S.) Amendment 200. Amendment 200 deleted the Post Accident Sampling System (PASS).
2.5 Augmentation Call Out Drill Notification and/or Augmentation Drills will be conducted at least every 12 months.
The drills shall evaluate the licensee's capability to notify the minimum staffing positions in the Technical Support Center, Operations Support Center and the Emergency Operations Facility, in addition to meeting the staffing requirements of Table B-1 in RERP, Section B.

FCS EP-FC-1001 Section N Revision 0TBD Page 128 of 170 EXERCISES AND DRILLS 3.0 SCENARIOS Scenarios for a drill are developed by either Emergency Planning or the group responsible for conducting the specific drill. Each drill should include a basic objective and appropriate evaluation criteria.
A special group is assigned the scenario development for the biennial exercise. An Emergency Planning procedure develops the plan for the preparation, execution, and documentation of the biennial exercise. This procedure requires input from major Federal, State, and local agencies, as well as OPPD staff, in order to define the objectives to be accomplished in the exercise. The scenario is then prepared to describe the following features:
Objectives of the exercise.
Date, time period, location, and participants.
Simulated events.
Time schedule of real and simulated events.
Summary describing conduct of exercise.
Preparation of the scenario may include such items as identifying Control Room alarms, sequence of alarms, and instrument readings required to initiate the planned emergency exercises essential components.
A strong attempt is made to allow only key officials of Federal, State, and local support agencies to share scenario information in advance of exercises, in order that their participation in the exercise can be developed properly to demonstrate their maximum capabilities without losing confidentiality of exercise information.
4.0 CRITIQUES In addition to the OPPD observers, offsite support agencies may provide observers for the biennial exercise. Observers are given information of the accident scenario prior to the exercise so that they may evaluate participants effectively.
Observers, evaluators, controllers and participants submit their comments and recommendations during a critique that is held after all drills and exercises. An Emergency Planning procedure is used to document and classify all significant comments and issues. Significant observations are incorporated into the plants Corrective Action Program for resolution.

FCS EP-FC-1001 Section N Revision 0TBD Page 129 of 170 EXERCISES AND DRILLS 5.0 ACTUAL EMERGENCIES In the event of an actual emergency, credit for the response may be substituted for a drill or exercise if the event is properly documented according to the guidelines set forth in 10 CFR 50.47 and NUREG-0654, Rev.1/FEMA-REP-1.

FCS EP-FC-1001 Section O Revision 0TBD Page 130 of 170 RADIOLOGICAL EMERGENCY RESPONSE TRAINING 1.0  FIRST AID TRAINING Personnel assigned the responsibility for responding to a medical emergency at the Fort Calhoun Station receive the American Red Cross Standard First Aid Training Program, or equivalent. Normally, these are members of the Fort Calhoun Station Fire Brigade which consists of Operations personnel assigned to shift crews. To maintain qualifications in accordance with the American Red Cross, CPR is conducted annually and First Aid Training is given biannually. The training is conducted by the American Red Cross and the associated training records are maintained in accordance with Training Department procedures.
2.0  FIRE BRIGADE TRAINING Fire Brigade training is outlined in the TQ-AA-173, Emergency Services Training Programs.
3.0  GENERAL EMPLOYEE TRAINING An overview of the Emergency Plan is given to all personnel allowed unescorted access into the protected area at Fort Calhoun Station. Personnel receive this information during initial training and are requalified on an annual basis. This training includes identification of the emergency alarm, the fire alarm and the steps to follow for a plant and site evacuation.
4.0  EMERGENCY PREPAREDNESS TRAINING PROGRAM TQ-FC-113, ERO Training and Qualification identifies the initial and continuing training requirements for emergency response personnel.
As appropriate, members of the onsite emergency response organization are qualified to wear respiratory equipment, including self-contained breathing apparatus (SCBA) through the General Employee Training, Level III, Respiratory Protection Training Program.
5.0  EMERGENCY RESPONSE ORGANIZATION TRAINING Requirements for initial training and continuing training of personnel assigned to the Emergency Response Organization is accomplished in accordance with TQ-FC-113, ERO Training and Qualification.
Requirements for initial training and continuing training of security personnel are outlined in the Security Training and Qualification Plan.
FCS Management is responsible to ensure all members of the Emergency Response Organization receive the required initial training and continuing training.

FCS EP-FC-1001 Section O Revision 0TBD Page 131 of 170 RADIOLOGICAL EMERGENCY RESPONSE TRAINING 6.0  LOCAL SUPPORT SERVICES PERSONNEL TRAINING 6.1  Fire and Rescue Squads The Blair Fire Department and Rescue Squad and the Fort Calhoun Fire/Rescue are offered annual training by the Nebraska Emergency Management Agency. The Missouri Valley Fire and Rescue Squad and the Council Bluffs Fire and Ambulance Squad are offered annual training from the Iowa Homeland Security and Emergency Management Division. OPPD will provide assistance with training as requested.
This training normally includes an overview of the plant facility in order to familiarize them with the general area where their assistance may be requested, a review of the basic emergency classification levels, and a review of proper contamination control procedures.
6.2  Offsite Organizations Lead representatives and selected responders falling under the jurisdiction of the following offsite response organizations shall be offered annual training/retraining.
             - Washington County Emergency Management
             - Harrison County Emergency Management
             - Pottawattamie County Emergency Management
             - Douglas County Emergency Management
             - Nebraska Region 5/6 Emergency Management Members of the Fort Calhoun Station may assist with the state of Nebraska Emergency Management Agency and the state of Iowa Homeland Security and Emergency Management Division in preparing and presenting, on an annual basis, training to their Emergency Management agencies in radiological emergency response. Both states have outlined in their respective emergency plans the type of training to be given. Their training is not limited to Emergency Management agencies, but may also include key public officials and emergency services management as well as the state and police agencies and hospitals.
State and local Emergency Management groups are invited to participate in the biennial exercise conducted by the plant. Their participation in the biennial exercise supplements the annual training.
6.3  Law Enforcement Agencies Training for law enforcement agencies is typically conducted by the states of Iowa and Nebraska.

FCS EP-FC-1001 Section O Revision 0TBD Page 132 of 170 RADIOLOGICAL EMERGENCY RESPONSE TRAINING 7.0  DOCUMENTATION OF TRAINING FCS training procedures outline the process to document training of the Fort Calhoun Station Emergency Response Organization. An Emergency Planning procedure is used to verify training received by offsite organizations.

FCS                                                                  EP-FC-1001 Section P Revision 0TBD Page 133 of 170 RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION 1.0  RESPONSIBILITY FOR RADIOLOGICAL EMERGENCY RESPONSE PLANNING 1.1  The Plant Manager and Nuclear Division Managers are responsible for the implementation of actions required to periodically exercise the Radiological Emergency Response Plan (RERP), and the Implementing Procedures and for maintaining an effective Emergency Response Organization (ERO) staff.
1.2  The Plant Operations Review Committee is responsible for the review and approval of revisions to the RERP and the Implementing Procedure used for emergency classification in accordance with EP-FC-120 Attachment 2, EP Document Structure and Revision Process.
1.3  The Plant Manager is responsible for the final approval of RERP and the Implementing Procedure used for emergency classification, and for maintaining an effective emergency response capability at Fort Calhoun Station.
1.4  Nuclear Organization Responsible Management Contacts are responsible for selecting and proposing personnel to fill ERO positions and for ensuring support of the Radiological Emergency Response Plan.
1.5  The Manager- Site Emergency Planning is responsible for the development, administration and maintenance of the RERP, Implementing Procedures, and EP-FC procedures, review and approval of all Implementing Procedure changes (with the exception of the Implementing Procedure used for emergency classification), planner training, the overall development and implementation of the FCS ERO Training and Qualification Program and coordination of off-site emergency preparedness activities in the states of Iowa and Nebraska.
1.6  The Manager-Nuclear Training is responsible for the independent review and approval of the FCS ERO Training and Qualification Program.
1.7  The Emergency Planning Department is responsible for the preparation of all revisions to the RERP, Implementing Procedures and for coordinating the review processes necessary prior to the implementation of the revisions.
2.0  MAINTENANCE OF THE RERP AND IMPLEMENTING PROCEDURES 2.1  Emergency Planning personnel shall review the RERP and Implementing Procedures annually. Any changes found to be necessary as a result of the review shall be submitted using the established procedure change process.
2.2  Comments and recommendations made as a result of drills/exercises may require procedure changes to be initiated. These processes are detailed in the drill and exercise program.

FCS                                                                   EP-FC-1001 Section P Revision 0TBD Page 134 of 170 RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION 2.3  Recurring tasks ensure that copies of the annual review and annual audit reports are reviewed by the Manager-EP and any changes incorporated as necessary.
2.4  Changes to the plan will be submitted to the NRC within 30 days in accordance with 10CFR50.54(q). The Radiological Emergency Response Plan and approved changes to the plan will also be forwarded to appropriate organizations and individuals with responsibility for implementation of the plan. A new edition of the Radiological Emergency Response Plan will be issued when major technical and significant philosophical changes are required.
2.5  All emergency telephone numbers are updated quarterly.
3.0  AUDITS 3.1  The Nuclear Oversight Department will coordinate an independent audit of the Emergency Preparedness Program at intervals not to exceed 24 months or more frequently as required by 10CFR50.54(t)(1). The audit shall include the Radiological Emergency Response Plan, implementing procedures, practices, drills, exercises, training, readiness testing, equipment and interfaces with state and local governments.
The results of this audit along with the recommendations for improvement must be documented and reported to the licensee's corporate and plant management. Copies of pertinent sections of the audit will be forwarded to appropriate state and local governments. This audit shall fulfill the requirements of 10CFR50.54(t). The results of this audit shall be retained for a minimum of five years.

FCS                                                                    EP-FC-1001 Section P Revision 0TBD Page 135 of 170 RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION 1.0  LETTERS OF AGREEMENT REVIEW 1.1  Written agreements establishing the concept of operations developed between Fort Calhoun Station and other support organizations having an emergency response role within the EPZs have been developed. These agreements identify the emergency measures to be provided, the mutually accepted criteria for implementation, and the arrangements for exchange of information. Agreement letters are not necessary with Federal Agencies who are legally required to respond based on Federal law; however, agreements are necessary if the agency was expected to provide assistance not required by law. Letters of Agreement with private contractors and others who provide services in support of Fort Calhoun Station shall be maintained on file. Letters of Agreement, as a minimum, state that the cooperating organization will provide their normal services in support of an emergency at the affected station. A contract/purchase order with a private contractor is considered acceptable in lieu of a Letter of Agreement for the specified duration of the contract.
Organizations deemed to be First Responders, who are identified as Local Law Enforcement Agency (LLEA), Volunteer Fire Fighting Organizations, Emergency Medical Services (EMS), and the University of Nebraska Medical Center (UNMC), will contain wording to ensure they will respond to a RadialogicalRadiological event to include a Hostile Action Based event.
LLEA will support Fort Calhoun Nuclear Station during a Radiological or Hostile Action Based event, in conjunction with the National Incident Management System upon notification by the station in accordance with established communications protocol.
Fire Fighting Organizations will respond to a Radiological Event, including a Hostile Action Based Event, in conjunction with the National Incident Management System in accordance with established response and communication protocol. Fire Fighting Organizations may be requested to obtain and provide fire response, fire apparatus, and fire personnel.
EMS Support will provide Emergency Medical Services in response to a Radiological Event including a Hostile Action Based Event. This includes transportation of patients from the Fort Calhoun Nuclear Station, including those who may have been exposed to radiation or may have injuries complicated by radioactive contamination, to the University of Nebraska Medical Center by use of established communication protocol.
UNMC agrees in the event of a Radiological event, including a Hostile Action Based Event, to ensure the capability for the evaluation of radiation exposure and uptake, including assurance that persons providing these services are

FCS                                                                    EP-FC-1001 Section P Revision 0TBD Page 136 of 170 RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION adequately prepared to handle contaminated individuals and capable of providing medical support for any contaminated individual.
A contract/purchase order with a private contractor is considered acceptable in lieu of a Letter of Agreement for the specified duration of the contract.
NOTE i  Copies of Current Letters of Agreement are on file in the Emergency Planning Department.
i 1.2   Law Enforcement Support Organizations Nebraska State Patrol Iowa State Patrol Harrison County Sheriff's Department Washington County Sheriff's Department Pottawattamie County Sheriff's Department Douglas County Sheriff's Department 1.3   Fire and Rescue Support Organizations Blair Fire Department Fort Calhoun Fire and Rescue Missouri Valley Fire Department 1.4   Medical Support Organizations UNMC Regional Radiation Health Center 1.5   Nebraska's Governmental Support Organizations State of Nebraska Emergency Management State of Nebraska-Department of Health and Human Services, Regulation and Licensure Washington County Board of Supervisors Nebraska Game and Parks Commission Douglas County Emergency Management Agency 1.6   Iowa's Governmental Support Organizations Iowa Homeland Security and Emergency Management Division

FCS                                                               EP-FC-1001 Section P Revision 0TBD Page 137 of 170 RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION Harrison County Board of Supervisors Pottawattamie County Board of Supervisors Pottawattamie County Division of Telecommunications 1.7  Industrial Support Organizations Union Pacific Railroad Westinghouse Electric Electric Power Research Institute/Nuclear Energy Institute Institute of Nuclear Power Operations (INPO) 1.8  Other Support Organizations Nebraska Public Power District Metropolitan Utilities District National Weather Service Tierney-Blair LLC 1.9  Monitoring and Decontamination Support Organizations Omaha Fire Department Emergency Worker Decon

FCS                                                                    EP-FC-1001 Section P Revision 0TBD Page 138 of 170 RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION The following is a list of plans for organizations that support or supplement emergency response to the Fort Calhoun Station. These are maintained in the EOF.
State Iowa Radiological Emergency Response Plan, Part 2, Nuclear Power Plant Accident/Incident, Annex P of the Iowa Emergency Response Plan.
State of Nebraska - "Radiological Emergency Response Plan for Nuclear Power Plant Incidents" Local Crawford County (Iowa) - "Radiological Emergency Response Plan" Dodge County (Nebraska) - "Radiological Emergency Reception Plan for Nuclear Power Plant Incidents" Douglas County (Nebraska) - "Douglas County Supplement to Washington County Radiological Emergency Response Plan for Nuclear Power Plant Incidents" Harrison County (Iowa) - "Radiological Emergency Response Plan for Nuclear Power Plant Incidents" Pottawattamie County (Iowa) - " Radiological Emergency Response Plan" Sarpy County (Nebraska) - " Radiological Emergency Response Plan for Nuclear Power Plant Incidents" Washington County (Nebraska) - "Radiological Emergency Response Plan for Nuclear Power Plant Incidents"

FCS EP-FC-1001 Appendix C Revision 0TBD Page 139 of 170 NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST PSRERP Appendix C provides a cross reference to track OPPD's implementation of the guidance provided by NUREG 0654, FEMA REP 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Rev. 1.
OPPD generally conforms to the guidance of NUREG-0654 in its Post Shutdown Radiological Emergency Response Plan (PSRERP), Emergency Plan Implementing Procedures (EPIP) and other supporting documents. However, OPPD has and may make exceptions to NUREG-0654 guidance providing it does not reduce the effectiveness or intent of the PSRERP or EPIPs.
For Section D, Emergency Classification System, OPPD uses the guidance of NEI-99-01, Methodology for Development of Emergency Action Levels for Non-Passive Reactors. This variance from NUREG-0654 has been approved by the NRC.
All changes to the PSRERP are subject to a 10 CFR 50.54(q) screening, 10 CFR 50.47(b) and 10 CFR 50 Appendix E reviews. If the reviews determine that the change does not reduce the effectiveness or intent of the plan, the Plant Operating Review Committee (PORC) must then approve the change before it is implemented and sent to the NRC for review. If the screening process finds that the change does reduce the effectiveness or intent of the plan the change must be submitted to NRC for pre-approval prior to implementation.
All changes to EPIPs and other documents governed by the PSRERP are also subject to 10 CFR 50.54(q) screening. If it is determined that the proposed EPIP or other plant document change requires an PSRERP change a full 10 CFR 50.47(b), 10 CFR 50 Appendix E review and PORC approval is required prior to implementation and submittal to the NRC for review. NRC pre-approval must be obtained if a change is determined to reduce the effectiveness or the intent of the plan.
Refer to Attachment 1 - PSRERP Titles - PSRERP Titles - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision 0TBD Page 140 of 170 NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                 NUREG Criteria                 RERP Section      Implementing Procedure(s)
A. Assignment of Responsibility A.1.a     Identify the State, Local, Federal and          A 1.1-1.8      N/A private sector organizations (including utilities) intended to be a part of the ERO.
A.1.b     Each organization shall specify its               A 2.0,       EP-FC-112, Crisis concept of operations and its relationship    C 1.0, 2.0, 3.0, Communication Plan to the total effort.                                4.0 Appendix A A.1.c     Block diagram of organizational                  FIG. A-1      N/A interrelationships.
A.1.d     Identify a specific individual (by title) who      A 2.0       EP-FC-112 shall be in charge of the emergency response.
A.1.e     Provide for 24-hr per day response,                A 1.0       EP-FC-112 including communications links.
A.2.a     State/Local applicability                          N/A         N/A A.2.b     State/Local applicability                          N/A         N/A A.3      Letters of Agreement                            Appen. A       EP-FC-120 (Verification of RERP-Appendix A)
A.4      Capability of continuous 24-hour                A 1.0, 2.0     EP-FC-112 operations. Identify, by title, the individual in the principal organization responsible for continuity of resources.
Refer to Attachment 1 - PSRERP Titles - PSRERP Titles - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision 0TBD Page 141 of 170 NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                 NUREG Criteria               RERP Section      Implementing Procedure(s)
B. Onsite Emergency Organization B.1      Specify the onsite emergency                B 2.1, Table B-1 EP-FC-112-100, EP-FC-112-organization of plant staff personnel for                    200, EP-FC-112-300, EP-FC-all shifts and its relation to the                           112-400, EP-FC-112-500 responsibilities and duties of the normal staff complement.
B.2      Designate an individual as emergency           B 7.1, 7.2    EP-FC-112-100 coordinator who is on shift at all times.
B.3      Identify a line of succession for the             B 7.0      EP-FC-112 emergency coordinator position and identify the specific conditions for higher level utility officials assuming this function.
B.4      Specification of responsibilities, and            B 6.2      EP-FC-112 designation of which may not be delegated.
B.5      Positions or titles and major tasks to be   B 8/9/10/11/12,  EP-FC-112-100, EP-FC-112-performed by the persons assigned to           Table B-1     200, EP-FC-112-300, EP-FC-the functional areas of emergency                            112-400, EP-FC-112-500, activity.                                                    Crisis Communication Plan B.6      Interfaces between and among the            B-13, Table B-3 N/A onsite, offsite, corporate, state and local government response organizations.
B.7      Each licensee shall specify the corporate,     Table B-1     EP-FC-112-100, EP-FC-112-management, admin., and technical                 B 4.0      200, EP-FC-112-300, EP-FC-personnel who will augment plant staff in                    112-400, EP-FC-112-500 Table B-1 and in the following areas:
B.7.a     Logistics support, e.g., trans, comm,          B 9.0, 11.0   EP-FC-112-200-F-03, EP-FC-quarters, food, water, special equipment       Table B-2     112-400-F-07 and supplies purchase; B.7.b     Technical support for planning reentry            B 6.0      EP-FC-115 and recovery operations; B.7.c     Management level interface with                   B 13       EP-FC-112 government authorities; and B.7.d     Release of information to news media            B 12,13       EP-FC-112 during an emergency (coordinated with                         Crisis Comm. Plan governmental authorities).
B.8      Specification of contractor and private       A 1.0, B-13,    EP-FC-112-200-F-03, EP-organizations to provide assistance.         B-15, Fig. B-3,  FC-112-400-F-07, Appen A       EP-FC-120 (Verification of RERP-Appendix A)
B.9      Expected services from local agencies        A 1.0 Appen A    EP-FC-120 (Verification of e.g., police, fire, ambulance, medical,     B 15, Table B-1,  RERP-Appendix A) hospital.                                       Fig B-3 RERP Sec L Refer to Attachment 1 - PSRERP Titles - PSRERP Titles - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision 0TBD Page 142 of 170 NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                NUREG Criteria              RERP Section    Implementing Procedure(s)
C. Emergency Response Support and Resources C.1      Incorporation of Federal response into          C1 the operational plan:
C.1.a     Specific persons to request Federal        C1.1, B 6.3.1  EP-FC-112 assistance (See A.1.d and A.2.a)
C.1.b     Specific Federal resources expected and     C 1.2-1.3     N/A expected times of arrival, and C.1.c     Specific licensee, state, local resources     C 2.0       N/A to support Federal response, air fields, command posts, tel lines, radio frequencies, and telecommunications centers.
C.2.a     State/Local Applicability                      N/A        N/A C.2.b     Licensee representative to offsite EOCs      C 3.0       EP-FC-112-400 C.3      Radiological laboratories, general            C 2.2       N/A capabilities and expected availability to      4.0 provide radiological monitoring and analyses services which can be used in an emergency.
C.4      Identify Nuclear and other facilities,        C 4.0,      EP-FC-112-200-F-03, EP-organizations or individuals which can be   Appen A       FC-112-400-F-07, relied upon in an emergency to provide                    EP-FC-120 (Verification of assistance. Such assistance shall be                      RERP Appendix A) identified and supported by appropriate letters of agreement.
Refer to Attachment 1 - PSRERP Titles - PSRERP Titles - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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D. Emergency Classification System D.1
* Establish an Emergency Action Level        D 2.0    EP-FC-1001 Addendum 3 Scheme and Emergency Classification scheme.
D.2
* Initiating conditions shall include        D 1.0    EP-FC-1001 Addendum 3 NUREG-0654, Appendix 1 conditions and all FSAR postulated accidents.
D.3       State/Local applicability                   N/A     N/A D.4       State/Local applicability                   N/A     N/A
* NEI-99-01 Guidance has replaced NUREG-0654 Appendix 1 guidance.
Refer to Attachment 1 - PSRERP Titles - PSRERP Titles - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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E. Notification Methods and Procedures E.1      Notification procedures consistent with EALs           E 2.0     EP-FC-114 including a means for verification of messages.
E.2      Procedures for alerting, notifying and mobilizing      E 2.0     EP-FC-112-100-F-06 emergency response personnel.
E.3      Licensee and state/local establish content of the      E 3.1     EP-FC-114 initial messages, and shall contain: class, release, potentially affected population, and if PARs are needed.
E.4      Provisions for follow-up messages, and shall           E 3.2     EP-FC-114 contain the following:
E.4.a     Location of incident, and name and telephone           E 3.2     EP-FC-114 number (or communications channel identification) of caller; E.4.b     Date/time of incident;                                 E 3.2     EP-FC-114 E.4.c     Class of emergency;                                    E 3.2     EP-FC-114 E.4.d     Type of actual/projected release, and estimated        E 3.2     EP-FC-114 duration/impact times; E.4.e     Estimate of radioactive material released or           E 3.0     EP-FC-110-200 being released and the points and height of releases.
E.4.f     Chemical and physical form of material,                E 3.0     EP-FC-110-200 estimates of quantities/concentration of noble gases, iodines, and particulates; E.4.g     Met conditions at appropriate levels: wind speed,      E 3.0     EP-FC-114 direction (to and from) stability, precip, if any; E.4.h     Type of actual projected does rates at site            E 3.0     EP-FC-110-200 boundary, projected integrated dose at site boundary:
E.4.i     Projected dose rates and integrated dose at 2, 5,      E 3.0     EP-FC-110-200 and 10 miles, include the sector(s) affected; E.4.j     Estimate of any surface contamination inplant,         E 3.0     EP-FC-110-200 onsite, offsite; E.4.k     Licensee emergency response actions                    E 3.0     EP-FC-114 underway; E.4.l     Recommended emergency actions, including               E 3.2     EP-FC-114 protective measures; E.4.m      Request for any needed onsite support by offsite       E 3.0     EP-FC-114 organizations, and; E.4.n     Prognosis for worsening/termination based on           E 3.2     EP-FC-114 plant information.
E.5      State/Local applicability                               N/A      N/A E.6      Notification/prompt instructions to the public.        E 4.0     EP-FC-112, EP-FC-121 (ANS)
Refer to Attachment 1 - PSRERP Titles - PSRERP Titles - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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E.7      Written messages for the public, consistent with     E 5.0     EP-FC-112 the EALs, to include ad hoc PARs.
Refer to Attachment 1 - PSRERP Titles - PSRERP Titles - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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F. Emergency Communications F.1.a     Provision for 24 hour notification to and       E 2.0         EP-FC-114 activation of the State/local ER network,       F 1.0 with telephone link and backup, and             F 2.0 24-hour manning of communication links          F 2.3 that initiate emergency response actions;       F 2.4 F.1.b     Communications with contiguous             F 2.0, 2.3, 2.4,   EP-FC-114 states/locals;                               Fig F-1, F-2 F.1.c     Communications with Federal EROs;         F 2.3, 2.9, 2.10,   EP-FC-114 F 2.12, F 2.13, Fig. F-1 F.1.d     Communication between the plant, EOF,      F 2.4, 2.5, 2.8, EP-FC-112 state and local EOCs, and rad monitor        2.11, 2.17, teams;                                    Fig. F-1, Fig. F-2 F.1.e     Provision for alerting or activating            E 2.0         EP-FC-112-100-F-06 emergency personnel in each response organization, and F.1.f     Communication (by licensee) with NRC       F 2.3, 2.8, 2.9,   EP-FC-112-400 HQ and Regional Office EOC and the          2.10, F-2.12, EOF and Rad Mon Team Assembly area.              2.22 F.2      Each organization shall ensure that a           F 3.0         EP-FC-112-300-AD-F-coordinated comm link for fixed and                           04,FCSG-15 mobile medical support facilities exists.
F.3      Each organization shall conduct periodic        N 2.1         EP-FC-124 testing of the entire emergency communications system. (See also H.10, N.2.a and Appendix 3).
Refer to Attachment 1 - PSRERP Titles - PSRERP Titles - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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G. Public Education and Information G.1      Each organization shall provide a             G 1.0      Corporate Crisis coordinated periodic (at least annually)                 Communication Plan; dissemination of information to the public               EP-FC-120 re: how they will be notified, and what their actions should be.
G.2      The public information program shall          G 1.0      Corporate Crisis provide permanent and transient adult                    Communication Plan; population within the EPZ an adequate                    EP-FC-120 opportunity to become aware of the information annually. This section also makes reference to: Signs, decals, posted notices, for hotel, motels, gas stations, and phone booths).
G.3.a      Media contact point during an emergency       G 2.0      Corporate Crisis (i.e., JIC, etc).                                        Communication Plan G.3.b      Space for limited number of news media        G 2.0      Corporate Crisis at the EOF.                                              Communication Plan G.4.a      Each organization shall have a                G 3.0      Corporate Crisis spokesperson.                                            Communication Plan G.4.b      Each organization shall establish             G 3.0      Corporate Crisis arrangements for timely exchange of                      Communication Plan information among designated spokes persons.
G.4.c     Each organization shall establish             G 2.1      Corporate Crisis coordinated arrangements for dealing                     Communication Plan with rumors.
G.5      Each organization shall conduct               G 4.0      EP-FC-120 coordinated programs at least annually to acquaint news media with the emergency plans, information concerning radiation, and points of contact for release of public information in an emergency.
Refer to Attachment 1 - PSRERP Titles - PSRERP Titles - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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H. Emergency Facilities and Equipment H.1      Each licensee shall establish a TSC and          H 1.0,      EP-FC-112 an OSC.                                            3.0 H.2      Establish an EOF.                                H 2.0       EP-FC-112 H.3      State/Local applicability                         N/A        N/A H.4      Timely activation of the facilities and      H 1.3, 2.3,     EP-FC-112 centers described in the Plan.                 3.3, 4.3 H.5      Each licensee shall identify and establish onsite monitoring systems that are to be used to initiate emergency measures, in accordance with Appendix 1, as well as those used to conduct assessment. The equipment shall include:
H.5.a     Geophysical phenomena monitors, (e.g.,           I 2.0,      EP-FC-1001 Addendum 3 met, hydrological, seisamicseismic);            I 2.1.2, I 2.1.3, I 2.2.3, I 2.3.2(c)
H.5.b     Rad monitors, (e.g., process, area,        H.1.2, 2.2, 3.2,  EP-FC-1001 Addendum 3 emergency, effluent, wound and portable        4.2, 5.0      EP-FC-110 monitors and sampling equipment);               I 2.2.1      EP-FC-112-500 I 2.2.2      EP-FC-113 RP-AA-350 H.5.c     Process monitors (e.g., reactor coolant           I 2.2      EP-FC-1001 Addendum 3 system pressure and temp, containment                        EP-FC-121 pressure and temp, liquid levels, flow rates, status or lineup of equipment components); and H.5.d     Fire and combustion products detectors.         I 2.1.1      EP-FC-1001 Addendum 3 SO-G-28, Station Fire Plan H.6      Each licensee shall make provision to acquire data from or for emergency access to offsite monitoring and analysis equipment, including:
H.6.a     Geophysical phenomena monitors (e.g.,           I 2.1.2      EP-FC-1001 Addendum 3 met, hydrologic, seismic):                       2.1.3 2.2.3 H.6.b     Radiological monitors including                  H 2.2       EP-FC-112-500 ratemeters and sampling devices.                   5.2       EP-FC-113 Dosimetry shall be provided and shall              5.3       RP-AA-700 meet, as a minimum, the NRC Rad                    5.6 Assessment Branch Tech Position for the Environmental Rad Monitoring program; and H.6.c     Laboratory facilities, fixed or mobile. C 2.0, C 4.0     EP-FC-112-500 H.7      Each organization, where appropriate,           I 2.3.3      EP-FC-112-500 shall provide for offsite rad monitoring          J 2.5 equipment in the vicinity of the plant.
Refer to Attachment 1 - PSRERP Titles - PSRERP Titles - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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H.8      Each licensee shall provide met                 I 2.2.3    EP-FC-110-200 instrumentation and procedures which                       EP-FC-110-201 satisfy the criteria in Appendix 2, and provisions to obtain representative current met data from other sources.
H.9      Each licensee shall provide for an onsite        H 3.0     EP-FC-112-300 OSC which shall have adequate capacity and supplies, including, for example, respiratory protection, protective clothing, portable lighting, portable radiation monitoring equipment, cameras and communications equipment for personnel present in the OSC.
H.10      Inspect/inventory/operationally check            H 5.0     EP-FC-124 equipment at least quarterly and after                     RP-AA-700 each use. There shall be sufficient reserves of instruments/equipment to replace those which are removed from emergency kits for calibration or repair.
H.11      Identify emergency kits, by general              H 5.0     EP-FC-124 category (i.e., protective equipment, comm equipment, rad monitoring equipment.
H.12      Each organization will establish a central       H 2.1     EP-FC-112-500 point for receipt and analysis of all field monitoring data and coordination of sample media.
Refer to Attachment 1 - PSRERP Titles - PSRERP Titles - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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I. Accident Assessment I.1     Identify plant system and effluent             Sec D      EP-FC-1001 Addendum 3 parameter values characteristic of a             I 1.0 spectrum of off-normal conditions and             2.0 accidents, and shall identify the plant parameter values or other information which correspond to the example initiating conditions of Appendix 1.
I.2     Onsite capability and resources to               I 1.0    EP-FC-1001 Addendum 3 provide initial values and continuing             2.0     EP-FC-110-200 assessment throughout the course of an                    EP-FC-110-201 accident shall include post accident sampling capability, radiation and effluent monitors, in-plant iodine instrumentation and containment radiation monitoring.
I.3     Each licensee shall establish methods and techniques to be used for determining:
I.3.a     The source term of releases of                  D 1.0     EP-FC-110-200 radioactive material within plant systems. Table D-1   EP-FC-110-201 I.3.b     The magnitude of the release of                 D 2.0     EP-FC-111-AD-F-02 radioactive materials based on plant                      EP-FC-110-200 system parameters and effluent monitors.                  EP-FC-110-201 I.4     Each licensee shall establish the               D 2.0     EP-FC-111-AD-F-02 relationship between effluent monitor                     EP-FC-110-200 readings and onsite and offsite                           EP-FC-110-201 exposures and contamination for various met conditions.
I.5     Each licensee shall have the capability of     I 2.2.3    EP-FC-111-AD-F-02 acquiring and evaluating met information                  EP-FC-110-200 sufficient to meet the criteria of Appendix               EP-FC-110-201 2.
I.6     Each licensee shall establish the                I 3.1    EP-FC-111-AD-F-02 methodology for determing the release                     EP-FC-110-200 rate/projected doses of the                               EP-FC-110-201 instrumentation used are offscale or inoperable.
I.7     Field monitoring plans.                          I 2.3    EP-FC-112-500 I.8     Provide methods, equipment and                   I 3.0    EP-FC-111-AD-F-02 expertise to make rapid assessment of                     EP-FC-110-200 the actual or potential magnitude of any                  EP-FC-110-201 rad hazard through liquid or gaseous release pathways.
I.9     Each organization shall have a capability        I 3.0    EP-FC-112-500 to detect and measure radioiodine concentrations in air in the plume exposure EPZ as low as 10-7 Ci/cc under field conditions.
Refer to Attachment 1 - PSRERP Titles - PSRERP Titles - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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I.10     Each organization shall establish means         I 3.0      EP-FC-110-200 for relating the various measured                          EP-FC-110-201 parameters (e.g. contamination levels, water and air activity levels) to dose rates for key isotopes and gross radioactivity measurements.
I.11     Arrangements to locate and track the            I 2.3      EP-FC-112-500 plume.                                                     EP-FC-110-200 EP-FC-110-201 Refer to Attachment 1 - PSRERP Titles - PSRERP Titles - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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J. Protective Response J.1       Each licensee shall establish the means        J 1.3.2 and time required to warn or advise             J 1.1 individuals within the owner-controlled area, including:
J.1.a      Employees not having emergency                  J 1.1     EP-FC-113 assignments;                                   J 1.3.2 Visitors;                                       J 1.1     EP-FC-113 J.1.b                                                     J 1.3.2 Contractor and construction personnel,          J 1.1     EP-FC-113 J 1.c      and                                            J 1.3.2 J 1.d      Other persons who may be in the public          J 1.1     EP-FC-113 access areas or passing through the site       J 1.3.2 or within the owner-controlled area.
J.2       Make provisions for evacuation routes           J 1.2     EP-FC-113 and transportation for onsite individuals     Table J-9 to some suitable offsite location, including alternatives for inclement weather, high traffic density and specific rad conditions.
J.3       Each licensee shall provide for                 J 1.2     EP-FC-113 radiological monitoring of people evacuated from the site.
J.4       Each licensee shall provide for the             J 1.2     EP-FC-113 evacuation of onsite non-essential personnel in the event of a Site Area or General Emergency and shall provide a decon capability at or near the monitoring point specified in J.3, above.
J.5       Each licensee shall provide for a              J 1.3.2    EP-FC-113 capability to account for all individuals                 SY-AA-101-121 onsite at the time of the emergency and ascertain the names or missing individuals within 30 minutes of the start of the emergency and account for all onsite individuals continuously thereafter.
J.6       Each licensee shall, for people remaining onsite, make provisions for:
J.6.a      Individual respiratory protection;             J 1.4.4    EP-FC-113 RP Manual J.6.b      Use of protective clothing;                    J 1.4.3    EP-FC-113 RP Manual J.6.c      Use of KI.                                     J 1.4.5    EP-FC-113 J.7       Each licensee shall establish a                J 2.1.1    EP-FC-114 mechanism for recommending PAs to State and locals.
Refer to Attachment 1 - PSRERP Titles - PSRERP Titles - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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J.8     Each licensees plan shall contain an            J 2.3     EP-FC-1001 Addendum 2 ETE. These shall be in accordance with Appendix 4.
J.9     State/local applicability                        N/A      N/A Table J-9 J-10 J.10     The organizations plans to implement protective measures for the EPZ shall include:
J.10.a     Maps showing evacuation routes,                J 2.3.2    EP-FC-113 evacuation areas, preselected                  Fig J-1    ANS Map radiological sampling and monitoring             J-2      10-Mile EPZ Map points, relocation centers in host areas, and shelter areas; J.10.b     Maps showing pop distribution around           J 2.3.3    EP-FC-1001 Addendum 2 the Nuclear facility. This shall also be by    Fig J-4 evacuation areas;                                J-7 J-8 J.10.c     Means for notifying all segments of the         J 2.2     EP-FC-121 transient and resident population; J.10.d     State/local applicability                        N/A      N/A J.10.e     State/local applicability                        N/A      N/A J.10.f    State/local applicability                        N/A      N/A J.10.g     State/local applicability                        N/A      N/A J.10.h     State/local applicability                        N/A      N/A J.10.i    State/local applicability                        N/A      N/A J.10.j    State/local applicability                        N/A      N/A J.10.k     State/local applicability                        N/A      N/A J.10.l    State/local applicability                        N/A      N/A J.10.m     The basis for the choice of recommended         J 2.1     EP-FC-111 protective actions from the EPZ during        Table J-2 emergency conditions.                            J-3 J-4 J.11     State applicability                              N/A      N/A J.12     State/local applicability                        N/A      N/A Refer to Attachment 1 - PSRERP Titles - PSRERP Titles - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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K. Radiological Exposure Control K.1       Each licensee shall establish onsite exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity PAGs for:
K.1.a      Removal of injured persons;                     K 1.0     EP-FC-113, RP Manual K.1.b      Undertaking corrective actions;                 K 1.0     EP-FC-113, RP Manual K.1.c      Performing assessment actions;                  K 1.0     EP-FC-113, RP Manual K.1.d      Providing first aid;                            K 1.0     EPIP-EOF-11, FCSG-15-7 RP Manual K.1.e      Performing personnel decon;                     K 1.0     EP-FC-113, RP Manual K.1.f      Providing ambulance service; and                K 1.0     EP-FC-113, FCSG-15-7 RP Manual K 1.g      Providing medical treatment services.           K 1.0     EP-FC-113, FCSG-15-7 RP Manual K.2       Each licensee shall provide an onsite rad       K 1.0     EP-FC-113 protection program to be implemented                      RP Manual during emergencies, including methods to implement exposure guidelines.
K.3.a      24 hour capability to determine the doses       K 1.2     RP Manual received by emergency personnel                           EP-FC-113 involved in any nuclear accident, including volunteers.
K.3.b      Each organization shall ensure that            J 1.4.2    RP Manual dosimeters are read at appropriate              K 1.2 frequencies.
K.4       State/local applicability                        N/A      N/A K.5.a      Action levels for determining the need for      K 2.1     RP-AA-350 decon.
K.5.b      Decon of personnel wounds, supplies,           K 2.0,     RP-AA-350 instruments and equipment and for waste          3.0 disposal.
K.6       Each licensee shall provide onsite contamination control measure including:
K.6.a      Area access control;                            K 2.0     RP-AA-350 K.6.b      Drinking water and food supplies;               K 2.4     EP-FC-112-200-F-14 K.6.c      Criteria for permitting return of areas and     K 2.5     RP-AA-350 items to normal use (see ANSI 12.13).
Refer to Attachment 1 - PSRERP Titles - PSRERP Titles - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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K.7      Each licensee shall provide the capability  K 2.1, 2.2, 2.3  EP-FC-113 for decon of relocated onsite personnel,        L 3.2 including provisions for extra clothing and decontaminants suitable for the type of contamination given to radioiodine contamination of the skin.
Refer to Attachment 1 - PSRERP Titles - PSRERP Titles - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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L. Medical and Public Health Support L.1      Each organization shall arrange for local       L 3.0      RP-AA-220 and backup hospital and medical                            FCSG-15-7 services having the capability for evaluation of radiation exposure and uptake, including assurances that persons providing these services are adequately prepared to handle contaminated persons.
L.2      Each licensee shall provide for onsite first    L 1.0      FCSG-15-7 aid capability.
L.3      State applicability                              N/A       N/A L.4      Each organization shall arrange for             L 2.0      FCSG-15-7 transportation of rad victims to medical support facilities.
Refer to Attachment 1 - PSRERP Titles - PSRERP Titles - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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M. Recovery and Reentry Planning and post Accident Operations M.1      Each organization shall develop plans            M 1.3      EP-FC-115 and procedures for reentry and recovery           2.0 and describe the means by which decisions to relax protective measures are reached.
M.2      Each licensee plan shall contain the             M 1.2      EP-FC-115 position/title, authority and responsibilities of individuals who will fill key positions in the recovery organization.
M.3      Each licensee and state plan shall               M 1.2      EP-FC-115 specify the means for informing members of the response organizations that a recovery operation is to be initiated, and of any changes in the organizational structure that may occur.
M.4      Each plan shall establish a method for           I 3.0      EP-FC-200 periodically estimating total population exposure.
Refer to Attachment 1 - PSRERP Titles - PSRERP Titles - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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N. Exercises and Drills N.1.a     Exercises shall be conducted as set forth         N          EP-FC-122 in NRC and FEMA rules.
N.1.b     An exercise shall include mobilization of       N 1.0        EP-FC-122 State and local personnel and resources...shall provide for a critique by federal and state observers/evaluators...scenario varied from year to year....6:00 PM and Midnite/Midnite and 6:00 AM exercises....under various weather conditions....some unannounced.
N.2.a     Communications drills:
Comm with State and Locals                      N 2.1        EP-FC-122 (monthly)
Comm with Federal EROs and states               N 2.1        EP-FC-122 within the IPZ (quarterly)
Comm between the plant, state and local         N 2.1        EP-FC-122 EOCs, and field assessment teams (annually)
N.2.b     Fire Drills                                     N 2.2        OP-AA-201-005 N.2.c     Medical Emergency Drills                        N 2.3        EP-FC-122 N.2.d     Rad Monitoring Drills                           N 2.4        EP-FC-122 N.2.e     HP Drills Shall be conducted semi-annually which          N 2.4        EP-FC-122 involve response to and analysis of simulated elevated airborne and liquid samples and direct rad measurements.
The state drills need not be at each site.
Analysis of inplant liquid samples with         N 2.4        EP-FC-122 actual elevated rad levels including use of the PASS shall be included in HP drills by licensees annually.
N.3      Each organization shall describe how exercises and drills are to be carried out to allow free play for decision making and to meet the following objectives. ....The scenarios shall include, but not be limited to, the following:
N.3.a     Basic objectives and appropriate            N 1.0, 2.0, 3.0  EP-FC-122 evaluation criteria; N.3.b     Dates, time periods, places, and            N 1.0, 2.0, 3.0  EP-FC-122 participating organizations; N.3.c     The simulated events;                       N 1.0, 2.0, 3.0  EP-FC-122 N.3.d     Time schedule of real and simulated         N 1.0, 2.0, 3.0  EP-FC-122 initiating events; Refer to Attachment 1 - PSRERP Titles - PSRERP Titles - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision 0TBD Page 159 of 170 NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section               NUREG Criteria               RERP Section     Implementing Procedure(s)
N.3.e     A narrative summary;                      N 1.0, 2.0, 3.0  EP-FC-122 N.3.f     A description of arrangements and           N 1.0, 4.0     EP-FC-122 advance materials for official observers.
N.4      An exercise critique.                         N 4.0        EP-FC-122 N.5      Evaluating the comments from observers        N 4.0        EP-FC-122 and participants.
Refer to Attachment 1 - PSRERP Titles - PSRERP Titles - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision 0TBD Page 160 of 170 NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                 NUREG Criteria               RERP Section  Implementing Procedure(s)
O. Radiological Emergency Response Training O.1       Each organization shall assure training of    O 4.0      TQ-FC-113 appropriate individuals.                       5.0 O.1.a       Each facility shall train members of the      O 5.0      TQ-FC-113 ERO.
O.1.b       State/local applicability                     O 6.0      N/A O.2       Training shall include drills.                N 2.0      TQ-FC-113 O.3       Licensee training for First Aid teams to      O 1.0      TQ-AA-174 include ARC Multi-Media or equivalent.
O.4       Each organization shall establish a training program for ERO. Training shall be in the following categories:
O.4.a       Directors or coordinators of EROs;            O 5.0      TQ-FC-113 O.4.b       Accident assessment personnel;                O 5.0      TQ-FC-113 O.4.c      Rad Mon Teams and rad analysis                O 5.0      TQ-FC-113 personnel; Police, security and fire fighting            O 6.0      EP-FC-10 O.4.d       personnel;                                               SY-AA-150 O.4.e       Repair and damage control/correctional        O 5.0      TQ-FC-113 action teams (onsite);
O.4.f      First aid and rescue personnel;               O 1.0      TQ-AA-173 6.0 O.4.g       Local support services personnel,             O 6.0      EP-FC-10 including CD/Emergency Services personnel; O.4.h       Medical Support Personnel;                    L 3.2      TQ-AA-173 O 6.0 O.4.i      Licensee Headquarters support                 O 4.0      TQ-FC-113 personnel;                                               Crisis Communication Plan O.4.j      Personnel responsible for transmission of     O 4.0      TQ-FC-113 emergency information and instructions.
O.5       Initial and annual retraining.                O 5.0      TQ-FC-113 Refer to Attachment 1 - PSRERP Titles - PSRERP Titles - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision 0TBD Page 161 of 170 NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                  NUREG Criteria                RERP Section  Implementing Procedure(s)
P. Responsibility for the Planning Effort; Development, Periodic Review and Distribution of Emergency Plans P.1       Each organization shall provide for the          P 1.0     EP-FC-11 training of individuals responsible for the planning effort.
P.2       Each organization shall identify by title        P 1.0     EP-FC-11 the individual with overall planning authority; P.3       Each organization will designate an              P 1.0     EP-FC-11 Emergency Planning Coordinator.
P.4       Each organization shall update its plan          P 2.0     EP-FC-120 and agreements as needed, review and certify it to be current on an annual basis.
Changes will take into consideration items from drills and exercises.
P.5       Plans and plan changes shall be                  P 2.0     EP-FC-120 forwarded to all organizations and appropriate persons with EP responsibility. Revised pages dated and marked to show changes.
P.6       List supporting plans and source.              APPEN B     N/A P.7       Each plan shall contain an appendix            APPEN C     N/A listing procedures required to implement the plan. The listing shall include the sections of the plan to be implemented by each procedure.
P.8       Each plan shall contain a table of             APPEN C     N/A contents. Plans submitted for review should be cross-referenced to these criteria.
P.9       Independent review of the plans.                 P 3.0     EP-FC-120 P.10       Quarterly update of plan telephone               P 4.0     EP-FC-124 numbers.
Refer to Attachment 1 - PSRERP Titles - PSRERP Titles - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision 0TBD Page 162 of 170 NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST Attachment 1 - PSRERP Titles Document                                Document Title PSRERP           Radiological Response Plan For Fort Calhoun Station PSRERP-SECTION A Assignment of Organizational Responsibility (Organizational Control)
PSRERP-SECTION B Organizational Control of Emergencies PSRERP-SECTION C Emergency Response Support and Resources PSRERP-SECTION D Emergency Classification System PSRERP-SECTION E Notification Methods and Procedures PSRERP-SECTION F Emergency Communications PSRERP-SECTION G Public Education and Information PSRERP-SECTION H Emergency Facilities and Equipment PSRERP-SECTION I Accident Assessment PSRERP-SECTION J Protective Response PSRERP-SECTION K Radiological Exposure Control PSRERP-SECTION L Medical and Public Health Support PSRERP-SECTION M Recovery and Reentry Planning and Post Accident Operations PSRERP-SECTION N Exercises and Drills PSRERP-SECTION O Radiological Emergency Response Training PSRERP-SECTION P Responsibility for the Planning Effort: Development, Periodic Review and Distribution PSRERP-APPENDIX  Letters of Agreement A
PSRERP-APPENDIX  Supporting Emergency Plans B
PSRERP-APPENDIX  NUREG/RERP/Implementing Procedure Cross Reference List C
PSRERP-APPENDIX  OPPD Resolution #4731, Radiological Emergency Response Plan D                Authority

FCS EP-FC-1001 Appendix C Revision 0TBD Page 163 of 170 NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST PSRERP-APPENDIX  Definitions and Abbreviations E

FCS EP-FC-1001 Appendix C Revision 0TBD Page 164 of 170 NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST Attachment 2 - EPIP Titles Document                           Document Title EP-FC-1001      EMERGENCY ACTION LEVELS FORT CALHOUN STATION Addendum 3 EP-FC-110       ASSESSMENT OF EMERGENCIES EP-FC-111       EMERGENCY CLASSIFICATION AND PROTECTIVE ACTION RECOMMENDATIONS EP-FC-112       EMERGENCY RESPONSE ORGANIZATION (ERO) EMERGENCY RESPONSE FACILITY (ERF) ACTIVATION AND OPERATION EP-FC-112-100   CONTROL ROOM OPERATIONS EP-FC-112-200   TSC ACTIVATION AND OPERATION EP-FC-112-300   OPERATIONS SUPPORT CENTER ACTIVATION AND OPERATION EP-FC-112-400   EMERGENCY OPERATIONS FACILITY ACTIVATION AND OPERATION EP-FC-112-500   EMERGENCY ENVIRONMENTAL MONITORING EP-FC-112-700   ALTERNATE FACILITY OPERATION EP-FC-113       PERSONNEL PROTECTIVE ACTIONS EP-FC-114       NOTIFICATIONS EP-FC-115       TERMINATION AND RECOVERY

FCS                                              EP-FC-1001 Appendix D Revision 0TBD Page 165 of 170 OPPD RESOLUTION # 4731, RADIOLOGICAL EMERGENCY RESPONSE PLAN AUTHORITY

FCS                                              EP-FC-1001 Appendix D Revision 0TBD Page 166 of 170 OPPD RESOLUTION # 4731, RADIOLOGICAL EMERGENCY RESPONSE PLAN AUTHORITY

FCS EP-FC-1001 Appendix E Revision 0TBD Page 167 of 170 DEFINITIONS AND ABBREVIATIONS 1.0  DEFINITIONS AND ABBREVIATIONS 1.1  ALARA - As Low As is Reasonably Achievable - Means making every reasonable effort to maintain exposures to radiation as far below the dose limits as is practical consistent with the purpose for which the licensed activity is undertaken, taking into account the state of technology, the economics of improvements in relation to state of technology, the economics of improvements in relation to benefits to the public health and safety, and other societal and socioeconomic considerations, and in relation to utilization of nuclear energy and licensed materials in the public interest 1.2  ANS - Alert Notification System - Described in Section E 1.3  AR - Action Request 1.4  Assessment Actions - The appropriate actions taken during or following an accident evaluation before implementing the specific corrective and/or protective actions 1.5  CDE - Committed Dose Equivalent - (HT50) The dose equivalent to organs or tissues of reference (T) that will be received from an intake of radioactive material by an individual during the 50 year period following the intake 1.6  CFR - Code of Federal Regulations 1.7  CHP - Conference Health Physics Network - Described in Section E 1.8  Committed Effective Dose Equivalent - (HE50) Sum of the products of the weighing factors applicable to each of the body organs or tissues that are irradiated and the committed dose equivalent to these organs or tissues 1.9  Control Room - Functions described in Section H 1.10 COP - Conference Operations (Phone) Network- Described in Section E 1.11 Corrective Actions - Measures taken to correct or mitigate an emergency condition at its origin in order to prevent an uncontrolled release of radioactive material or reduce the magnitude of the release.
1.12 CR - Control Room - Functions described in Section H 1.13 Deep Dose Equivalent - (DDE or Hd) applies to external whole-body exposure, is the dose equivalent at a tissue depth of 1 cm (1000 mg/cm2) 1.14 T - Delta Temperature - The difference in temperature between points 10 meters and 60 meters above the ground in units of centigrade. The value displayed on the ERFCS equates to; 100m T = [(T @ 60m - T@ 10m) x 2)]
165

FCS EP-FC-1001 Appendix E Revision 0TBD Page 168 of 170 DEFINITIONS AND ABBREVIATIONS 1.15 DOE - Department Of Energy - Role is discussed in Section C 1.16 Drill - Described in Section N 1.17 DSC - Dry Shielded Canister 1.18 DSO - Director of Site Operation (NRC) 1.19 EAD Electronic Alarming Dosimeter 1.20 URI/RASCAL - Emergency Assessment of Gaseous and Liquid Effluent-Section E 1.21 EAL - Emergency Action Level - Described in Section D 1.22 EAS - (Emergency Alerting System) - Described in Section E 1.23 ECCS - Emergency Core Cooling System 1.24 ENS - (FTS-ENS) Federal Telephone System Emergency Notification System -
Described in Section F 1.25 EOC - Emergency Operations Center - Discussed in Sections C and F 1.26 EOF - Emergency Operations Facility - Functions described in Section H 1.27 EPA - Environmental Protection Agency - Role Discussed in Section C 1.28 EPIP - Emergency Plan Implementing Procedures 1.29 EPT - Emergency Plan Test - Described in Section P 1.30 EPZ - Emergency Planning Zone - Described in Section J 1.31 ERDS - Emergency Response Data System - Described in Section F 1.32 ERFCS - Emergency Response Facilities Computer System - Described in Section H 1.33 ERO - Emergency Response Organization - Duties Described in Section B 1.34 Exercise - Described in Section N 1.35 FAA - Federal Aviation Administration - Role discussed in Section C 1.36 FEMA - Federal Emergency Management Agency - Role described in Section C 1.37 FTS - Federal Telecommunications Systems (NRC Phone Circuits) - Discussed in Section F 165

FCS EP-FC-1001 Appendix E Revision 0TBD Page 169 of 170 DEFINITIONS AND ABBREVIATIONS 1.38 GAR - Governors Authorized Representative - Authorized by letters in Appendix A 1.39 HPN - Health Physics Network - Described in Section F 1.40 HSM - Horizontal Storage Module 1.41 ISFSI - Independent Spent Fuel Storage Installation 1.42 IPZ - Ingestion Pathway Zone - Discussed in Section J 1.43 JIC - Joint Information Center - Functions discussed in Section B 1.44 NAWAS - National Warning System - Functions described in Section F 1.45 NRC - Nuclear Regulatory Commission - Role discussed in Section C 1.46 NWS - National Weather Service - Role discussed in Section C 1.47 Operation Liaison Network- Described in Section F 1.48 OSC - Operation Support Center - Functions described in Section H 1.49 PABX - Private Automatic Branch Exchanges - Function described in Section H 1.50 PAG - Protective Action Guideline - Discussed in Section J 1.51 PAR - Protective Action Recommendation - Discussed in Section J 1.52 Protective Actions - Discussed in Section J 1.53 REM - The special unit of any of the quantities expressed as dose equivalent. The dose equivalent in rems is equal to the absorbed dose in rads multiplied by the quality factor (1 rem = .01 sievert).
1.54 SDE - Shallow Dose Equivalent - Is the dose equivalent at a tissue depth of 0.007 cm or 7 mg/cm2 averaged over an area of 10 cm2. It applies to the external exposure of the skin or an extremity.
1.55 TEDE - Total Effective Dose Equivalent - The sum of the deep-dose equivalent (for external exposures) and the committed effective dose equivalent (for internal exposures). This represents the combined dose (DDE+CEDE) to a worker.
1.56 TLD - Thermoluminescent Dosimeter - A device worn by plant personnel to measure the amount of radiation received.
1.57 TSC - Technical Support Center - Functions described in Section H 165

FCS EP-FC-1001 Appendix E Revision 0TBD Page 170 of 170 DEFINITIONS AND ABBREVIATIONS 1.58 UNMC Regional Radiation Health Center - Role discussed in Section L 1.59 USAR - Updated Safety Analysis Report 165

FCS                                                 EP-FC-1001 Revision TBD Page 1 of 156 POST SHUTDOWN RADIOLOGICAL EMERGENCY RESPONSE PLAN OPPD NUCLEAR POST-SHUTDOWN RADIOLOGICAL EMERGENCY RESPONSE PLAN FOR FORT CALHOUN STATION

FCS                                                                                   EP-FC-1001 Revision TBD Page 2 of 156 POST SHUTDOWN RADIOLOGICAL EMERGENCY RESPONSE PLAN AREA DESCRIPTION 1.0  PLANT LOCATION Fort Calhoun Station is located midway between Fort Calhoun and Blair, Nebraska, on the west bank of the Missouri River. The site consists of approximately 660.46 acres with an additional exclusion area of 582.18 acres on the northeast bank of the river directly opposite the plant buildings. The Fort Calhoun Station includes the Independent Spent Fuel Storage Installation (ISFSI), located within the protected area, centered approximately 200 meters north-northwest of the Containment Building. The distance from the reactor containment to the nearest site boundary is approximately 910 meters; and the distance to the nearest residence is beyond the site boundary. Except for the city of Blair and the villages of Fort Calhoun and Kennard, the area within a ten mile radius is predominantly rural. The land use within the ten mile radius is primarily devoted to general farming. There are no private businesses or public recreational facilities on the plant property. The DeSoto National Wildlife Refuge occupies approximately 7821 acres east of the plant site. This area is open to the public for day use year-round.
Visitors to the refuge generally use areas from two to five miles from the plant. Estimates by the U.S. Fish and Wildlife Service place annual usage of the facility at approximately 120,000 for the Visitors Center and 400,000 for the refuge. The expected maximum daily usage of the facility has been placed at 2500 visitors for a winter weekday and 5000 on a summer weekend. The Boyer Chute Federal Recreation Area is a day use facility occupying approximately 2000 acres southeast of the plant site. Visitors to the recreation area generally use areas seven to ten miles from the plant. The estimates for annual usage of this facility is approximately 50,000 visitors.
The State of Nebraska operates the Fort Atkinson State Historic Park five and half miles southeast of the plant site. This day use facility is mostly seasonal and estimates place annual usage at 60,000. The State of Iowa maintains Wilson Island State Park with 275 camping spaces south of the DeSoto National Wildlife Refuge and four miles southeast of the plant site. The estimates for usage of this facility range from 500 on a winter weekday to 1000 on a summer weekend.
Two private facilities lie to the north of the plant along the Missouri River. The Cottonwood Marina is located approximately four and a half miles from the plant.
Estimates place summer weekend usage at 200 people. Riverland Resort Park is a private campground lying directly south of Cottonwood Marina and ranging from four to four and a half miles from the plant. The campground has approximately 235 campsites and is open from April to October.

FCS                                                                                   EP-FC-1001 Revision TBD Page 3 of 156 POST SHUTDOWN RADIOLOGICAL EMERGENCY RESPONSE PLAN 2.0  AREA INDUSTRIES A listing of various industries located within a ten mile radius of the Fort Calhoun Station, including firm name, product, number of employees, and location from the plant site is contained in the Updated Safety Analysis Report.
3.0  AREA WATER SUPPLIES Local public drinking water supplies are not taken from the Missouri River in this area.
The first downstream intake is the city of Omaha approximately 19.5 miles downstream.
Industrial water use is limited to cooling purposes in the Omaha area. Drinking water near the Fort Calhoun Station is obtained from either well or reservoirs. Since the known public and private water supplies originate at elevations higher than the river, radioactive liquids that might be discharged from the plant into the river should not contaminate these supplies.
There are also many private wells in the region which draw primarily upon ground water rather than on springs or other surface sources. Several marinas are located along the Missouri River, between 3 miles upstream from Blair and Omaha, 18 miles downstream.
In the event of a significant waterborne release incident from the Fort Calhoun Station, the Nebraska Department of Environmental Control acting in conjunction with the Nebraska Department of Health, Division of Radiological Health and the U. S. Coast Guard are prepared to notify all downstream users of Missouri River water. Notification is made through OPPD management directly to the Metropolitan Utilities District (MUD) in the event of an inadvertent liquid release to the river. Swimming, boating and other recreational activities involving river water can be controlled by the Coast Guard until adequate surveys have been taken to determine when normal activities may be resumed.

FCS                                                                                     EP-FC-1001 Revision TBD Page 4 of 156 POST SHUTDOWN RADIOLOGICAL EMERGENCY RESPONSE PLAN PURPOSE OF THE EMERGENCY PLAN The purpose of the Fort Calhoun Station "Post-Shutdown Radiological Emergency Response Plan" (PSRERP) is to delineate an organization for coping with emergencies, to classify emergencies according to severity, define and assign responsibilities and authorities, and to clearly outline the most effective course of action and protective measures required to mitigate the consequences of an accident and to safeguard the public and station personnel in the event of an incident. The Emergency Plan Implementing Procedures (EPIPs), Radiation Protection procedures, and other station references are available at the plant to further assist personnel during abnormal occurrences. The various emergency procedures are put into effect whenever a system, component or circuit failure could lead to a personnel hazard or major equipment failure. Procedures are sufficiently detailed so that the plant is maintained in a safe condition.
The various procedures include such items as radiation hazards, weather conditions and availability of technical and plant personnel.

FCS                                                                                   EP-FC-1001 Revision TBD Page 5 of 156 POST SHUTDOWN RADIOLOGICAL EMERGENCY RESPONSE PLAN ACCIDENT CONSIDERATIONS 1.0  FUEL HANDLING ACCIDENT The possibility of an incident during fuel handling is unlikely due to the many physical limitations imposed on fuel handling operations and systems. In addition, administrative restrictions placed on fuel handling procedures provide greater control. Nevertheless, the offsite consequences of dropping a spent fuel assembly and damaging the entire assembly have been evaluated and are documented in the Fort Calhoun Station, Unit No. 1 USAR, Section 14.18. Emergency onsite and offsite monitoring practices would begin immediately following the accident to determine actual consequences, and appropriate emergency actions would be taken. Emergency procedures addressing a Fuel Handling Incident provide emergency actions for this mishap.
The transfer cask that is used to transfer spent fuel (32 assembly capacity) contained within a dry shielded canister (DSC) from the Auxiliary Building to the ISFSI, has been analyzed for an 80 inch drop accident in the NUHOMS FSAR. The analysis determined that the DSC would retain its leak tight integrity for this 80 inch drop. This bounds the height of the transfer cask while it is being moved by the heavy-haul trailer between the Auxiliary Building and the ISFSI so that a release of radioactivity due to a drop event during transfer operations would not occur.
2.0  FIRES 2.1  Internal Plant Fires (within the Protected Area)
Internal Plant fires are normally handled by the station's Fire Brigade, comprised of trained individuals from the Operations Department and Radiation Protection Department. All efforts are made to prevent the spread of airborne contamination should the fires occur within the Radiological Controlled Area.
2.2  External Fires (outside the Protected Area)
External fires are controlled by local fire department response. In the event high airborne contamination constitutes a possible hazard to areas outside of the protected area, offsite survey teams/personnel can be dispatched immediately.

FCS                                                                                   EP-FC-1001 Revision TBD Page 6 of 156 POST SHUTDOWN RADIOLOGICAL EMERGENCY RESPONSE PLAN 3.0  EXPLOSION Because of the accumulation of waste gases in the waste gas decay tanks, the possibility and consequences of an explosion have been considered. An explosion could result in an unexpected, uncontrolled release to the atmosphere of radioactive fission gases that were stored in the waste gas system. A failure of any of the waste gas decay tanks or associated piping could also result in a release of gaseous activity. The noble gases stored in the tanks would diffuse and become diluted during their transport to the site boundary. The projected Deep Dose Equivalent (DDE) at the exclusion area boundary would be less than 1.0 Rem. This conservative analysis is based upon 1% fuel cladding defects, and accumulation of all noble gases without release over a full core cycle.
Emergency procedures addressing a Waste Gas Incident, would be placed into effect immediately and offsite monitoring teams would be dispatched downwind.
The ISFSI horizontal storage modules (HSM) are designed to protect the DSCs from the effects of explosions to ensure the DSCs retain their leak-tight integrity and prevent a release of radioactivity to the atmosphere. An analysis of the haul route used to transfer the DSCs from the Auxiliary Building to the ISFSI was performed, and it identified administrative controls needed to prevent explosions in the vicinity of the transfer cask (designed to withstand 3 psi overpressure) during spent fuel transfer operations.
4.0  TOXIC CHEMICAL RELEASE ACCIDENTS The primary toxic chemical release accidents which may result in toxic gas concentrations at Fort Calhoun Station are shown below:
TOXIC CHEMICAL              ACCIDENT Ammonia (NH3)               Rupture of two 25,000 ton offsite refrigerated tanks.
Ammonia                     Rupture of two 30,000 gal. offsite non-refrigerated tanks.
Ammonia                     Rupture of a 78 ton railroad tank car.
Ammonia                     Rupture of a 2 ton tank truck.
The above accidents will not pose a hazard to control room personnel, due to toxic gas monitors located at the fresh air intake of the control room, which isolates the control room before the gases reach the toxic limit. The stringent odor of ammonia makes station personnel immediately aware of any leakage or toxic gas cloud. Spent Fuel storage at the ISFSI relies on passive means of decay heat removal (natural convection),
so a toxic gas release does not challenge nuclear safety.
The toxic gas monitors sample for NH3 and continuously monitor the fresh air to the control room during normal plant operations.

FCS                                                                                    EP-FC-1001 Revision TBD Page 7 of 156 POST SHUTDOWN RADIOLOGICAL EMERGENCY RESPONSE PLAN At different phases of plant operation, Hydrogen and/or Nitrogen gases blanket the volume control tank and the waste gas system. Considering that the deleterious effect of these gases is the exclusion of oxygen, a release to the atmosphere diminishes the harmful effect and a serious hazard is eliminated.
In the event of an offsite accidental release of chemicals, within a five (5) mile radius of the Fort Calhoun Station, the Blair Fire Department emergency procedures require notification to the Fort Calhoun Station. The counties of Washington (Nebraska) and Harrison (Iowa) have agreed to notify the Fort Calhoun Station when hazardous chemical accidents occur within five miles of the station. Appropriate action is taken, especially in the control room, to ensure that air remains breathable. For long duration toxic accidents, six (6) hours of compressed air is available for five (5) control room operators coupled with provisions to obtain additional air within this time period.
5.0  PERSONNEL INJURY A fully stocked First Aid Room is available in the Plant. Immediate and temporary care may be given to the injured person using standard First Aid practices. If the injury involves contamination, efforts to decontaminate the injured person to reasonable levels are made prior to transfer to the First Aid Room or to offsite medical facilities. If decontamination is not practical, the injured person is covered in such a manner as to minimize the spread of contamination until either medical aid can be obtained or until the injured person can be transported to the UNMC Regional Radiation Health Center.
6.0  NATURAL DISASTERS A natural disaster may occur which could initiate any of the accidents previously discussed. The Spent Fuel Pool and ISFSI are designed to withstand natural phenomena, including the maximum hypothetical earthquake, design basis tornado and tornado-driven missiles, with no release of radioactivity.

FCS EP-FC-1001 Section A Revision TBD Page 8 of 156 ASSIGNMENT OF ORGANIZATIONAL RESPONSIBILITY (ORGANIZATIONAL CONTROL) 1.0  NON-OPPD SUPPORT ORGANIZATIONS The following organizations may respond to a declared emergency at the Fort Calhoun Station. Each of these groups are capable of 24 hour response and operation. The details of their responsibilities are contained in their respective emergency response plans/procedures or if applicable, a Letter of Agreement between that organization and OPPD. Figure A-1 outlines the organizational interrelationships of various response organizations.
1.1  Law Enforcement Support Organizations 1.1.1      Nebraska State Patrol 1.1.2      Iowa State Patrol 1.1.3      Washington County Sheriff's Department 1.1.4      Pottawattamie County Sheriff's Department 1.1.5      Harrison County Sheriff's Department 1.1.6      Douglas County Sheriff's Department 1.2  Fire and Rescue Support Organizations 1.2.1      Blair Fire Department and Rescue Squad 1.2.2      Fort Calhoun Fire/Rescue 1.2.3      Missouri Valley Fire & Rescue Squad 1.2.4      Council Bluffs Fire and Ambulance Department 1.3  Medical Support Organization 1.3.1      UNMC Regional Radiation Health Center 1.4  Nebraska's Governmental Support Organizations 1.4.1      Nebraska Emergency Management Agency 1.4.2      Washington County Emergency Management Agency 1.4.3      Douglas County Emergency Management Agency

FCS EP-FC-1001 Section A Revision TBD Page 9 of 156 ASSIGNMENT OF ORGANIZATIONAL RESPONSIBILITY (ORGANIZATIONAL CONTROL) 1.4.4   Nebraska Health and Human Services, Regulation and Licensure 1.4.5   Region 5/6 Emergency Management Agency 1.4.6   Dodge County Emergency Management Agency 1.4.7   Sarpy County Emergency Management Agency 1.5  Iowa's Governmental Support Organizations 1.5.1   Iowa Homeland Security and Emergency Management Division 1.5.2   Iowa Department of Public Health 1.5.3   Harrison County Emergency Management Agency (via Board of Supervisors) 1.5.4   Pottawattamie County Emergency Management Agency (via Board of Supervisors) 1.5.5   Pottawattamie County Division of Communications 1.5.6   Crawford County Emergency Management Agency 1.6  Federal Government Support Organizations 1.6.1   U.S. Coast Guard 1.6.2   Environmental Protection Agency (EPA) 1.6.3   Department of Energy (DOE) 1.6.4   National Weather Service (NWS) 1.6.5   U.S. Nuclear Regulatory Commission (NRC) 1.6.6   Federal Emergency Management Agency (FEMA) Region VII 1.6.7   Federal Aviation Administration (FAA) 1.6.8   Department of the Interior, Branch of Global Seismology

FCS EP-FC-1001 Section A Revision TBD Page 10 of 156 ASSIGNMENT OF ORGANIZATIONAL RESPONSIBILITY (ORGANIZATIONAL CONTROL) 1.7  Industrial Support Organizations 1.7.1     Westinghouse Electric 1.7.2     Union Pacific Railroad 1.7.3     Institute of Nuclear Power Operations (INPO) 1.7.4     Institute of Nuclear Power Operations/Electric Power Research Institute/Nuclear Energy Institute 1.8  Other Support Organizations 1.8.1     Metropolitan Utilities District 1.8.2     Nebraska Public Power District (Cooper Nuclear Station) 1.8.3     National Weather Service 1.9  Monitoring and Decontamination Support Organizations 1.9.1     Omaha Fire Department Emergency Worker Decon 2.0  OPPD CONCEPT OF EMERGENCY OPERATIONS 2.1  OPPD's overall goals are to mitigate any emergency conditions which may occur at the Fort Calhoun Station and to provide information and support to State and Local agencies needed to protect the health and safety of the general public.
2.2  A predesignated group is assigned to various roles to ensure capable emergency response and mitigation at the Fort Calhoun Station. These assignments are made to ensure that the administrative, managerial and technical support needed for accident mitigation are met. A sufficient number of individuals are assigned to these positions to ensure around-the-clock and continued long term support.
2.3  Responsibility for emergency response initially lies with the Shift Manager. If the Technical Support Center (TSC) is activated, command and control may be transferred to the Site Director. The Emergency Director in the Emergency Operations Facility (EOF) may assume command and control if that facility is activated. The command and control position is responsible for ensuring the continuity of resources throughout an event.

FCS EP-FC-1001 Section A Revision TBD Page 11 of 156 ASSIGNMENT OF ORGANIZATIONAL RESPONSIBILITY (ORGANIZATIONAL CONTROL) 3.0  LETTERS OF AGREEMENT 3.1  Letters of agreement between OPPD and the organizations outlining their roles in the event of an emergency are on file with the Fort Calhoun Station Emergency Planning Department. These letters are reviewed annually in accordance with Emergency Preparedness recurring tasks.

FCS EP-FC-1001 Section A Revision TBD Page 12 of 156 ASSIGNMENT OF ORGANIZATIONAL RESPONSIBILITY (ORGANIZATIONAL CONTROL)
Figure A Organizational Interrelationships

FCS EP-FC-1001 Section B Revision TBD Page 13 of 156 ORGANIZATIONAL CONTROL OF EMERGENCIES 1.0 PURPOSE AND SCOPE 1.1 Purpose 1.1.1   This PSRERP Section establishes the organizational requirements, reporting locations and duties for the Fort Calhoun Station (FCS) Emergency Response Organization (ERO).
1.2 Scope 1.2.1   The positions established in this PSRERP Section upon declaration of an emergency will comprise the ERO. The EROs responsibility is to mitigate the consequences of an event using the facilities and resources described elsewhere in the PSRERP and the supporting Emergency Plan Implementing Procedures (EPIP).
2.0 DEFINITIONS None 3.0 RESPONSIBILITIES 3.1 Emergency Response Organization (ERO):
3.1.1   OPPD has issued a resolution which authorizes the ERO to provide an immediate and decisive response to mitigate the consequences of any nuclear emergency and for the protection of the health and safety of the public. Resolution No. 4731, as approved by the Board of Directors on January 15, 1998, is Appendix D of the PSRERP.
3.1.2   The ERO is intended to provide a pre-qualified organization capable of fulfilling the actions described above. The ERO is not confined to utilize only those personnel that are currently listed as qualified. Other OPPD personnel may be assigned and utilized to perform necessary functions at the discretion of the Command and Control positions. Assignment of any non-ERO qualified individual(s) should include adequate instruction to ensure the individual(s) is capable of performing the necessary functions and is knowledgeable of any potential hazards associated with responding to the designated facility.
3.2 Command and Control:
3.2.1   The position performing the duties of the Emergency Director is referred to as the Command and Control Position.

FCS EP-FC-1001 Section B Revision TBD Page 14 of 156 ORGANIZATIONAL CONTROL OF EMERGENCIES 3.2.2  The Command and Control position has the following responsibilities that cannot be delegated to other personnel. The position may assign other personnel to assist in conducting the actions necessary, but the responsibility of their completion rests with the position, until relieved by another Command and Control position or qualified individual, or the emergency is terminated:
A. Overall command and control of the ERO.
B. Ensuring that the proper classification of the emergency has been made in accordance with the established EAL/Classification scheme and is periodically reviewed to determine if the classification should be upgraded, downgraded or terminated.
C. Ensuring that all required notifications are made to appropriate state, local and federal officials.
D. Ensuring that appropriate Protective Action Recommendations (PARs) are provided to offsite officials.
E. Authorizing OPPD emergency worker exposure extensions beyond the Federal Radiation Protection Guidance.
F. Authorizing issuance of Potassium Iodide for OPPD emergency workers.
3.2.3  The Command and Control position also has the following responsibilities that can be delegated to other personnel, as necessary:
A. Requests for assistance from federal agencies.
B. Authorizing any emergency information to be released to the media or the general public.
C. Coordinating the transfer of the emergency information from the ERO to other OPPD and non-OPPD organizations called upon to assist.
D. Ensuring a timely and complete turnover of information to any qualified relief.
E. Declaring the termination of an emergency and transfer into a Recovery Operations Organization, when appropriate.
F. Providing information to the authorized representatives of the states of Nebraska and Iowa, and associated local governments.
G. Ensuring that the plant is in compliance with Technical Specifications and other licensee conditions, and if deviations are necessary to protect the public health and safety, they are approved, as a minimum, by a Senior Reactor Operator, prior to taking the action.

FCS EP-FC-1001 Section B Revision TBD Page 15 of 156 ORGANIZATIONAL CONTROL OF EMERGENCIES 4.0 PROCEDURE 4.1 ERO Staff On-Shift 4.1.1     The staffing of the normal operating organization for each shift is shown in Table B-1. This staffing consists of, as a minimum:
One Shift Manager (Senior Reactor Operator (SRO)/Certified Fuel Handler (CFH))
One Control Room Operator (SRO or Reactor Operator (RO)/CFH)
One Equipment Operator/Non-Certified Operator (NCO)
One Radiation Protection Technician Additionally, there are several shift Security personnel assigned 4.1.2     All or part of these shift personnel may comprise the initial ERO, and are responsible for taking immediate protective measures in any emergency and implementing this Post-Shutdown Radiological Emergency Response Plan when necessary.
4.2 Activation of the ERO 4.2.1     At a Notification of Unusual Event (NOUE), the Shift Manager may elect to not activate the ERO. In this instance, a notification to certain management personnel is performed and other personnel may be notified to assist as necessary.
A. If the Shift Manager elects to activate the ERO, the notification process will call out the entire ERO (with the exception of the JIC).
4.2.2     It is OPPDs goal that the ERO personnel can staff their emergency positions within one hour following declaration of an Alert or higher classification. In the event of adverse weather and/or other conditions that may limit or slow response, either manmade or natural, it is understood that staffing time may exceed this goal.
4.3 Facility Activation and Operation 4.3.1     There are some functional group activities that may be performed within an Emergency Response Facility prior to actually activating the facility. To be beneficial to the Command and Control facility, these activities, such as dose assessment and field team functions, are dependent upon the establishment of proper communications between the facilities.
4.3.2     OPPD Emergency Response Facilities are considered activated when minimum staffing and basic setup requirements have been attained to allow the facility to provide minimum support to the operating staff and other facilities.

FCS EP-FC-1001 Section B Revision TBD Page 16 of 156 ORGANIZATIONAL CONTROL OF EMERGENCIES A. It is OPPDs goal that the OSC, EOF and TSC be activated within one hour following an Alert classification. The JIC will be activated following a Site Area or General Emergency classification, and can be activated at an earlier classification based on the decisions of the Corporate Communications Division.
4.3.3  Minimum staffing for activation of the OSC is as follows:
One OSC Director One Radiation Protection Technician One other person to form a team 4.3.4  Minimum staffing for activation of the TSC is as follows:
One Site Director One TSC Protective Measures Coordinator One Engineering Coordinator 4.3.5  Minimum staffing for activation of the EOF is as follows:
One Emergency Director One EOF COP Communicator One EOF Protective Measures Manager One EOF Dose Assessment Specialist 4.3.6  OPPD Emergency Response Facilities are considered augmented when all minimum and augmenting staffing positions are filled.
4.3.7  Selected support staff, which assists the minimum and augmenting staff, is shown on Attachment 1 - Table B OPPD Emergency Response Organization (ERO) Functions and Shift Staff Augmentation Plan. The support staff is intended to supplement and enhance operation of their respective facilities. Additional personnel may respond.
4.3.8  If a toxic chemical/hazardous material or other significant event occurs that threatens the habitability of the station, an option exists to have all or part of the TSC and OSC staffs report to the EOF to provide assistance as necessary.
4.3.9  Some ERO personnel may elect to maintain an assistant position. This is acceptable when additional coordination of activities is required or to aid in the turnover process. The primary assignee must maintain overall responsibility of the position, and ensure that 24 hour staffing of the position can be implemented.

FCS EP-FC-1001 Section B Revision TBD Page 17 of 156 ORGANIZATIONAL CONTROL OF EMERGENCIES 4.4 Command and Control Positions 4.4.1  The positions that have Emergency Director Authority are:
The Shift Manager The Site Director The EOF Emergency Director 4.4.2  The Shift Manager ERO duties are to:
A. Perform as Emergency Director until properly relieved by a qualified position.
B. Direct medical and fire response efforts.
C. Coordinate in-plant operations response with the TSC and OSC. After being relieved by another Command and Control position, the Shift Manager will provide assistance and direction to the Control Room staff as necessary.
D. Ensure Control Room communications are established with the TSC, OSC, and EOF.
4.4.3  The Site Director position is intended to assume Command and Control functions from the Control Room if the EOF is not available or cannot assume Command and Control. This position may assume Command and Control at any emergency classification. The Site Director may assume Command and Control in the Control Room proper at any time. If the Site Director elects to assume Command and Control within the TSC, the TSC must meet activation requirements.
A. The Site Director duties are to promptly relieve the Control Room Command and Control position and perform as Emergency Director until properly relieved by a qualified position, if the EOF is not available or cannot assume Command and Control. Additional duties of the Site Director are to:
: 1. Manage the onsite activities of the ERO.
: 2. Keep the Emergency Director informed of those onsite activities as necessary.
4.4.4  The EOF Emergency Director position is intended to assume all Command and Control functions from the plant site. This position may assume Command and Control at any emergency classification, but the EOF must meet activation requirements prior to the transfer of Command and Control duties.

FCS EP-FC-1001 Section B Revision TBD Page 18 of 156 ORGANIZATIONAL CONTROL OF EMERGENCIES A. The Emergency Director duties are to promptly relieve the onsite Command and Control position and perform as Emergency Director until properly relieved by a qualified position or termination of the emergency response phase.
4.5 Control Room Positions 4.5.1    The following positions are on-shift staff, and augmenting positions for the Control Room. Additional Control Room support staffing is identified on Attachment 2 - Figure B Fort Calhoun Station Emergency Response Organization. Control Room on-shift staff positions are:
A. Shift Managers duties are described in Sections 4.2, 3.2 and 4.4.2.
B. Control Room Operator duties include:
Assessment of plant conditions, Ensuring requirements of the AOPs are met, and Notifications as directed by the Shift Manager. These notifications include the following:
o Required notifications to the states and counties o Notifications to the Emergency Response Organization C. Equipment Operator/NCO duties include making repairs and corrective actions on plant equipment until augmented plant maintenance staff arrives. NCOs also assist in performing notifications/communications and dose assessment as needed.
D. Shift Radiation Protection Technician duties include conducting radiological accident assessment and support, offsite dose assessment and onsite in-plant surveys.
4.5.2    The Control Room (CR) Operations Liaison is an augmenting position.
Duties include transmitting plant status/Control Room information, etc. to the TSC, OSC, and EOF.

FCS EP-FC-1001 Section B Revision TBD Page 19 of 156 ORGANIZATIONAL CONTROL OF EMERGENCIES 4.6 Technical Support Center Positions 4.6.1    The following are minimum staffing and augmenting positions for the Technical Support Center (TSC). Additional TSC support staffing is identified on Attachment 2 - Figure B Fort Calhoun Station Emergency Response Organization. Minimum staffing positions for the TSC are:
A. Site Director duties are described in Steps 3.2 and 4.4.3.
B. Engineering Coordinator duties include:
: 1. Directing activities of engineering resources requested by the TSC.
: 2. Analyzing plant problems and providing recommendations for plant modifications to mitigate the effects of the accident.
: 3. Evaluating possible radiological release paths to the environment.
C. Protective Measures Coordinator duties include:
: 1. Coordinating the dispatch of the TSC field team from the site and performing field team direction until the EOF assumes this duty.
: 2. Monitoring and coordinating on site dose assessment operations performed, and keep the Site Director informed of dose projections and field sample results.
: 3. Evaluating site radiological conditions, and necessary personnel protective measures.
: 4. Evaluating and making recommendations for plant evacuation and evacuation routes.
: 5. Preparing and submitting state update information, including Protective Action Recommendations, to the Site Director for approval and transmittal to state and federal officials if TSC has Command and Control.

FCS EP-FC-1001 Section B Revision TBD Page 20 of 156 ORGANIZATIONAL CONTROL OF EMERGENCIES 4.6.2    Augmenting positions for the TSC are:
A. TSC Field Team duties include providing off-site monitoring in the areas potentially affected by a radiological release.
B. Operations Liaison duties include:
: 1. Obtaining plant status/Control Room information from the Control Room Operations Liaison and transmitting this information to the TSC staff as needed. [AR 11390]
: 2. Assisting the Site Director in formulating appropriate protective action recommendations when necessary.
4.7 Operations Support Center Positions 4.7.1    The following are minimum staffing and augmenting positions for the Operations Support Center (OSC). Additional OSC support staffing is identified on Attachment 2 - Figure B Fort Calhoun Station Emergency Response Organization. Minimum staffing positions for the OSC are:
B. OSC Director duties include:
: 1. Coordinating the development of plans for required maintenance activities.
: 2. Keeping the Site Director informed of OSC activities.
: 3. Coordinating emergency team response as requested by the TSC/Control Room to perform search and rescue, damage assessment, damage control, repair and modification, and in-plant radiological monitoring.
C. Radiation Protection Technician duties include coordination of on-site radiation protection activities.
D. One other person to form a team.
4.7.2    Augmenting positions for the OSC are:
A. Chemistry Technician duties include evaluating and performing all chemistry activities on-site.
B. Electrical Maintenance Technician duties include providing repairs and corrective actions for plant electrical equipment as directed.
C. I&C Technician duties include providing repairs and corrective actions to

FCS EP-FC-1001 Section B Revision TBD Page 21 of 156 ORGANIZATIONAL CONTROL OF EMERGENCIES plant instruments as directed.
D. Machinist or Steam Fitter Mechanic duties include providing repairs and corrective actions to plant mechanical equipment as directed.
E. Radiation Protection Technicians (three positions) duties include providing radiological surveys and job coverage to repair and corrective action teams as directed.
F. The Protective Measures Coordinator duties include coordinating all radiation protection activities onsite.

FCS EP-FC-1001 Section B Revision TBD Page 22 of 156 ORGANIZATIONAL CONTROL OF EMERGENCIES 4.8 Emergency Operations Facility Positions 4.8.2  The following positions are minimum staffing and augmented positions for the Emergency Operations Facility (EOF). Additional EOF support staffing is identified on Attachment 2 - Figure B Fort Calhoun Station Emergency Response Organization. Minimum staffing positions for the EOF are:
A. Emergency Director duties are described in Section 3.2 and 4.4.4.
B. COP Communicator duties include performing notifications as directed by the Command and Control position. These notifications include the following:
Required notifications to states and counties Required notifications to the NRC Notifications to the Emergency Response Organization. This position also assists in maintaining status boards within the EOF C. Protective Measures Manager duties include:
: 1. Directing dose assessment operations performed, coordinating OPPD field teams, and keeping the Emergency Director informed of projections and field survey results.
: 2. Evaluating site radiological conditions and necessary personnel protective measures.
: 3. Preparing and submitting state update information, including Protective Action Recommendations, to the Emergency Director, state and federal officials.
: 4. Coordinating technical briefings for the offsite agencies as requested.
: 5. Comparing dose projections against field team results.
: 6. Comparing dose projections and field team results with state and federal agency results.
D. Dose Assessment Specialist duties include performing offsite dose assessments and submitting the results to the Emergency Director for approval and transmittal to state and federal officials.

FCS EP-FC-1001 Section B Revision TBD Page 23 of 156 ORGANIZATIONAL CONTROL OF EMERGENCIES 4.8.3  Augmenting positions for the EOF are:
A. Administrative Logistics Manager duties include:
: 1. Coordinating administrative personnel support to the EOF.
: 2. Coordinating scheduling and callout of ERO personnel for 24 hour coverage.
: 3. Activating the Alert Notification System as requested.
: 4. Coordinating OPPD resources for the establishment of emergency logistics for the ERO, such as food, beverages, medical and administrative supplies, transportation, special equipment, etc.
B. The EOF Field Team duties include providing off-site monitoring in the areas potentially affected by a radiological release.
: 1. Field Team Specialist duties include coordinating the activities of the OPPD and state Field Teams to achieve the most efficient use of teams for plume tracking.
C. Information Specialist duties include:
: 1. Preparing information for use in periodic press releases.
: 2. At an Alert or higher emergency classification, submitting all press releases to the Emergency Director (or designee) for approval prior to forwarding the release to the JIC.

FCS EP-FC-1001 Section B Revision TBD Page 24 of 156 ORGANIZATIONAL CONTROL OF EMERGENCIES D. Operations Liaison duties include: 1) obtaining plant status/Control Room information from the Control Room Operations Liaison and transmitting this information to the EOF and NRC staff as needed; and,
: 2) assisting the Emergency Director in the review of classifications and formulating appropriate protective action recommendations when necessary. [AR 11390]
4.9  Joint Information Center Positions 4.9.2     The Joint Information Center Manager duties include:
A. Coordinating with government authorities and to provide periodic briefings and news releases to news media personnel.
B. Providing public inquiry services.
C. Keeping OPPD personnel, including senior management, informed of the status of the emergency and emergency response effort. OPPDs Corporate Crisis Communication Plan lists other JIC positions.
4.10 Emergency Response Organization Interface with Onsite and Offsite Organizations 4.10.2    Attachment 2 - Figure B Fort Calhoun Station Emergency Response Organization illustrates the interface between the EOF and other onsite support centers. Attachment 2 - Figure B Organization Interrelationships illustrates the interface of the EOF with federal, state, and local support agencies.
4.10.3    The EOF interfaces with each of the onsite support centers on a continuous basis. Even though the EOF serves as the primary interface with the various offsite support agencies, the TSC interfaces with various contractors and vendors to gather needed design data, consultation, and evaluation concerning the plant's status.
4.11 Emergency Response Organization Notification 4.11.2    Emergency Response Organization notification occurs as shown in Sections E and M of the PSRERP. The Shift Manager is responsible for initiation of the notification process after an emergency condition has been classified.
4.12 Service Provided by Local Agencies 4.12.2    The Nebraska State Patrol and the Washington County Sheriff's Department have agreed to provide the primary law enforcement support to the Fort Calhoun Station Security Department.

FCS EP-FC-1001 Section B Revision TBD Page 25 of 156 ORGANIZATIONAL CONTROL OF EMERGENCIES 4.12.3   The Blair Volunteer Fire Department has agreed to provide the primary fire support services for the Fort Calhoun Station. The Fort Calhoun Volunteer Fire Department has agreed to provide backup fire response.
4.12.4   OPPD vehicles may transport non-injured potentially contaminated personnel. The Blair Volunteer Fire Department has agreed to provide primary rescue and transportation support, for injured and/or contaminated personnel. The Fort Calhoun Volunteer Fire and Rescue, Missouri Valley Fire and Rescue and the Council Bluffs Ambulance and Fire Departments have agreed to provide backup services.
4.12.5   The Blair Hospital has agreed to provide medical support for work related injuries. Nebraska Health Services University Hospital in Omaha, maintains a regional Radiation Health Center which provides services for the treatment of radiologically contaminated injuries and radiation exposure evaluation.
4.12.6   The majority of the organizations listed in this section maintain a Letter of Agreement with OPPD. These letters are on file in the Emergency Planning Department at the Fort Calhoun Station.
5.0  RETENTION/RECORDS None

==6.0  REFERENCES==
AND COMMITMENTS 6.9  AR 11390, LIC-065R 6.10 Fort Calhoun Station Analysis of Proposed Post-Shutdown On-Shift Staff, August 2016 7.0  ATTACHMENTS 7.9  Attachment 1 - Table B OPPD Emergency Response Organization (ERO)
Functions and Shift Staff Augmentation Plan 7.10 Attachment 2 - Figure B Normal Fort Calhoun Station Management Organization 7.11 Attachment 2 - Figure B Fort Calhoun Station Emergency Response Organization 7.12 Attachment 2 - Figure B Organization Interrelationships

FCS EP-FC-1001 Section B Revision TBD Page 26 of 156 ORGANIZATIONAL CONTROL OF EMERGENCIES Attachment 1 - Table B OPPD Emergency Response Organization (ERO) Functions and Shift Staff Augmentation Plan NUREG 0654                                                Omaha Public Power District Goals for 1 hour On Shift Minimum Major Functional Area            Major Tasks            Emergency Positions                                Augmentation Minimum Number/Title Number/Title Plant Operations and                                  Shift Manager (SRO)      1 Shift Manager Assessment of                                         Shift Foreman (SRO)      (SRO/CFH)
Operational Aspects                                   Control Room Operators   1 Control Room Operator Auxiliary Operators      (SRO or RO/CFH)***
1 Equipment Operator/NCO Emergency Command                                     Shift Technical Advisor, 1** Shift Manager and Control                                           Shift Manager or                                     1 Site Director OR (Emergency                                            designated Facility                                  1 Emergency Director Coordinator)*                                         Manager Notification/            Notify License, State local                            1 Control Room Operator    1 Communicator in EOF Communication            and Federal personnel                                 (SRO or RO/CFH)***
and maintain communication Radiological Accident    Emergency Operations         Senior Manager                                       1 Emergency Director Assessment and           Facility (EOF) Director Support of Operational Accident  Offsite Dose Assessment      Senior Health Physics    1 R.P Technician            1 Prot. Meas. Coord Assessment                                            (HP) Expertise Offsite Surveys                                                                   4 Field Team Technicians Onsite (Out of plant)                                                             1 R.P. Technician In Plant surveys Chemistry/Radiochemistry                                                          1 Chemistry Technician Plant System             Technical Support            Shift Technical Advisor Engineering, Repair and                                                   Core/Thermal hydraulics                              1 Engineering Coord Corrective Actions                                    Electrical Mechanical                                           1 Machinist OR Steam Fitter Mechanic Repair and Corrective        Mechanical Maintenance   1** Equipment Actions                                               Operator/NCO                1 Equipment Operator/NCO Electrical Maintenance                               1 Electrical Maintenance 1** Equipment               Technicians Operator/NCO Instrument and Control                               1 I&C Technician (I&C) Technician Protective Actions       Radiation Protection:        HP Technicians           1 R.P . Technician          1 R.P. Technician (Plant)                  a. Access Control
: b. HP Coverage for repair, corrective actions, search and rescue, first aid and firefighting
: c. Personnel monitoring
: d. Dosimetry Firefighting                                                                   Fire Brigade per SO-G-      Blair Fire Department 28,Station Fire Plan Rescue Operations and                                                          2** Equipment               Blair Rescue Squad First Aid                                                                      Operators/NCOs Site Access Control and  Security, Firefighting,      Security Personnel       All per Security Plan Personnel                communications, Accountability           personnel accountability
* Emergency Command and Control responsibility is transferred in accordance with Section B of this plan.
** May be provided by Shift personnel assigned other functions.
***Performs initial notification to NRC.

FCS EP-FC-1001 Section B Revision TBD Page 27 of 156 ORGANIZATIONAL CONTROL OF EMERGENCIES Attachment 2 - Figure B Normal Fort Calhoun Station Management Organization The Fort Calhoun Organization is described in Chapter 12 of the USAR.

EP-FC-1001 Section B FCS                                                                                                Revision TBD Page 28 of 156 ORGANIZATIONAL CONTROL OF EMERGENCIES Attachment 2 - Figure B Fort Calhoun Station Emergency Response Organization

FCS EP-FC-1001 Section B Revision TBD Page 29 of 156 ORGANIZATIONAL CONTROL OF EMERGENCIES Attachment 2 - Figure B Organization Interrelationships

FCS EP-FC-1001 Section C Revision TBD Page 30 of 156 EMERGENCY RESPONSE SUPPORT AND RESOURCES 1.0 FEDERAL RESPONSE 1.1 Personnel Authorized to Request Federal Assistance The Emergency Director typically coordinates with the states to secure federal assistance. However, the Emergency Director may also request federal assistance directly, if timely assistance has not been provided as requested by the states. The states will be kept informed of such requests.
1.2 Federal Response Organizations The Federal Radiological Emergency Response Plan (FRERP) and the Federal Response Plan (FRP) outline the federal response to any type of emergency, including an emergency at a fixed nuclear facility. Some of the typical federal organizations which could respond to an emergency at the Fort Calhoun Station are as follows:
1.2.1 U.S. Coast Guard Upon notification, the U.S. Coast Guard will control traffic on the Missouri River in the area of Fort Calhoun Station. They will provide waterborne patrols for extended periods if contamination levels persist.
A U.S. Coast Guard cutter is based at the Florence Boat Yard, approximately 18 river miles downstream of the Fort Calhoun Station.
1.2.2 U.S. Environmental Protection Agency (EPA)
Upon request, the EPA will provide trained manpower to assist in reviewing survey data, offsite evaluations and advise on protective actions for the public.
They also provide assistance in the collection and analysis of environmental samples.

FCS EP-FC-1001 Section C Revision TBD Page 31 of 156 EMERGENCY RESPONSE SUPPORT AND RESOURCES 1.2.3  U.S. Department of Energy (DOE)
DOE is the technical support branch of the Federal Radiological Emergency Response Plan (FRERP). DOE would typically be the agency in charge of initial establishment and control of the Federal Radiological Monitoring and Assessment Center (FRMAC).
Some of the capabilities of DOE and the FRMAC operations are as follows:
A. Support to the state(s) in the coordination of offsite radiological monitoring assessment, evaluation, and reporting activities of all federal agencies during the initial phases of an accident and maintain a technical liaison with the states and local agencies with similar responsibilities.
B. Ensure the orderly transfer of responsibility for coordinating the intermediate and long term radiological monitoring function at the FRMAC to EPA after the initial phases of the emergency.
C. Provide the personnel and equipment required to coordinate and perform the offsite radiological monitoring and evaluation activities.
D. Assist the NRC in assessing the accident potential and in developing technical recommendations on protective measures.
E. Maintain a common set of offsite radiological monitoring data and provide this data and interpretation to the NRC and to appropriate state and local agencies requiring direct knowledge of radiological conditions and monitoring results.
F. Provide consultation and support services to all other entities (e.g.
private contractors) having radiological monitoring functions and capabilities.
G. Assist other federal, state and local agencies by providing technical and medical advice concerning treatment of radiological contamination.
H. Provide telecommunications support and capabilities.
I. Assist other federal agencies in developing and establishing guidelines on effective systems of emergency radiation detection and measurement, including instrumentation.

FCS EP-FC-1001 Section C Revision TBD Page 32 of 156 EMERGENCY RESPONSE SUPPORT AND RESOURCES 1.2.4  U.S. National Weather Service (NWS)
The National Weather Service operates on a twenty-four (24) hour per day basis. Upon request, this organization can provide the Fort Calhoun Station with meteorological conditions including predicted temperature inversions, precipitation, wind patterns and velocity.
1.2.5  U.S. Nuclear Regulatory Commission (NRC)
The NRC becomes the Lead Federal Agency (LFA) in a response to a fixed nuclear facility, such as the Fort Calhoun Station. In their role as LFA, the NRC will directly coordinate response activities with OPPD and determine the need for appropriate federal response organizations. The NRC will perform the function of LFA from several response locations including the NRC Operations Center, Region IV's Incident Response Center, all OPPD Emergency Response Facilities (once a site team has arrived), and other federal response facilities established.
1.2.6  Federal Emergency Management Agency (FEMA)
FEMA is responsible for coordinating the non-technical federal support to state and local governments which could include such tasks as logistics and telecommunications. The senior FEMA official on the scene will notify the federal agency(ies) most capable of meeting the state and local governmental needs. FEMA would take the lead at the federal Disaster Field Office, if such location is established. Fort Calhoun Station is located within FEMA, Region VII.
1.2.7  Federal Aviation Administration (FAA)
The FAA controls and directs air traffic in and around the affected area. The FAA has the authority to close the area surrounding the Fort Calhoun Station to all non-response air traffic.
1.2.8  U.S. Department of the Interior The U.S. Department of the Interior, Branch of Global Seismology has the capability to monitor and provide specific seismic activity data should such an event occur in the vicinity of the Fort Calhoun Station.

FCS EP-FC-1001 Section C Revision TBD Page 33 of 156 EMERGENCY RESPONSE SUPPORT AND RESOURCES 1.3 Response Times It is anticipated that response time will be based on the level of assistance provided.
For example, information on upcoming weather conditions would be expected to be available in a matter of minutes over the telephone from the National Weather Service.
Conversely, radiological assistance from the Department of Energy would be expected to take considerably longer. It is expected that the federal assistance requested would be available within 8 to 72 hours.
2.0 RESOURCES TO SUPPORT RESPONDING AGENCIES Resources are provided by OPPD in order to support the various federal organizations which respond to an emergency as follows:
2.1 Air fields are available for the use of the radiological monitoring teams as follows:
2.1.1       Eppley Air Field, 18 miles South of Fort Calhoun Station, on Abbott Drive in Sector G.
2.1.2       Eagle Field (City of Blair's Air Field), seven (7) miles Southwest of Fort Calhoun Station on State Hwy. 133 in Sector K.
2.1.3       North Omaha Airfield, eleven (11) miles South Southeast of Fort Calhoun Station, on North 72nd street in Sector H.
2.2 A laboratory for radioisotopic analysis is available at the Fort Calhoun Station and Cooper Nuclear Station near Brownsville, Nebraska.
2.3 A laboratory for non-radiological chemical analysis is available at the Fort Calhoun Station and OPPD's North Omaha Power Station.
2.4 Onsite and offsite survey teams with necessary radiation monitoring instruments are available.
2.5 A boat is available for obtaining river samples.
2.6 Space and communication lines have been set aside to accommodate some federal agencies at the Control Room, Technical Support Center, Emergency Operations Facility, and Joint Information Center.
2.7 Electrical and communication access is available at the Emergency Operations Facility for the federal mobile analytical laboratory.

FCS EP-FC-1001 Section C Revision TBD Page 34 of 156 EMERGENCY RESPONSE SUPPORT AND RESOURCES 3.0 SITE REPRESENTATIVES The Nebraska State Governor's Authorized Representative (GAR) reports to the state Field Command Post, located at OPPD's Emergency Operations Facility. The GAR is in direct contact with OPPD personnel and has the authority to approve and issue all protective actions for the public in the State of Nebraska.
The State of Iowa's Governor's Authorized Representative (GAR) typically remains in the State Emergency Operations Center. The Iowa GAR has the authority to approve and issue all protective actions for the public in the State of Iowa. A command and control telephone link exists between this position and OPPD's EOF. If personnel are available, an Iowa liaison is sent to work directly with the staff at the EOF.
An OPPD Site Representative is available for dispatch from the utility to the Iowa State EOC. This position can be staffed on a 24 hour a day basis.
4.0 RADIOLOGICAL ASSISTANCE 4.1 Nebraska Public Power District (Cooper Nuclear Station)
The Cooper Nuclear Station is capable of providing a backup facility in the event Fort Calhoun's radiochemistry laboratory is not functional. The Cooper Station's radiochemistry laboratory is equipped to do gross and isotopic determinations on radionuclides in concentrations and counting geometries necessary for nuclear power plant operation and emergency monitoring. They will provide analysis of liquid, air particulate and cartridges on a priority basis after receiving the sample.
Additionally, Cooper Station could provide monitoring teams equipped with air sampling, radiation and contamination monitoring equipment.
4.2 Contractor Assistance In the event of an emergency, it is anticipated that further assistance could be contracted directly from firms currently being utilized by OPPD for non-emergency work at the Fort Calhoun Station or through the assistance of such organizations as the Institute of Nuclear Power Operations (INPO).
4.3 The analysis of field monitoring data by the states is specified in each respective state plan. OPPD field monitoring data can be analyzed by an independent facility providing such services.

FCS                                                                  EP-FC-1001 Section D Revision TBD Page 35 of 156 EMERGENCY CLASSIFICATION SYSTEM

==1.0 INTRODUCTION==

1.1 This section describes the emergency classification scheme adopted by the Omaha Public Power District for Fort Calhoun Station. The Emergency Classification scheme is based on NEI-99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors.
1.2 The State of Nebraska and the State of Iowa review the Fort Calhoun Station EALs once per year to ensure that they are consistent with their respective emergency classification schemes in their respective emergency plans. The purpose of this standardized classification is to provide a framework within which all emergency actions can be taken and notifications can be made in response to abnormal plant situations.
1.3 Table D-1 shows the projected worst case emergency classification for certain postulated accidents identified in the Fort Calhoun Station Updated Safety Analysis Report.
2.0 CLASSIFICATION OF EMERGENCIES 2.1 Emergency conditions are classified into one of four severity levels which cover the spectrum of postulated accidents. The postulated accidents range from precursors to potential degradation of plant safety to those involving actual failure of plant safety systems. Emergency preparedness, including a standardized classification system, is based primarily on preventing or minimizing radiation exposure to individuals onsite and offsite.
2.2 The specific Initiating Conditions (ICs) are contained within EP-FC-1001 Addendum 3, Emergency Action Levels For Fort Calhoun Station. The ICs are based on one or more of the key types of initiating conditions, including; symptom based, event based, barrier breach, and essential equipment/system(s) out of service. The ICs at Fort Calhoun Station are presented using six recognition categories as listed below:
R - Abnormal Rad Levels/Radiological Effluent C - Cold Shutdown/Refueling System Malfunction E - Events Related to ISFSI F - Fission Product Barrier Degradation H - Hazards and Other Conditions Affecting Plant Safety M - System Malfunction

FCS                                                                      EP-FC-1001 Section D Revision TBD Page 36 of 156 EMERGENCY CLASSIFICATION SYSTEM 2.3 Each one of the recognition categories contains ICs as outlined in EP-FC-1001 Addendum 3, Emergency Action Levels For Fort Calhoun Station. Each specific IC is detailed in individual sections which contain predetermined, site-specific, observable thresholds, such as; instrument readings, equipment status indicators, measurable parameter(s), discrete and observable event(s), results of analysis, entry into specific emergency/abnormal procedures, applicable operating mode(s), and/or any other cautions and/or notes pertaining to that particular IC.
2.4 To the extent feasible, the ICs are based on readily available information such as Control Room instrumentation readings, Emergency Response Facility Computer System (ERFCS) output, specific station procedure steps, and/or dose projection results. The intent is to eliminate "ambiguity" for command and control positions in determining appropriate emergency classifications. Immediate actions to be taken in response to conditions involving abnormal plant operating parameters are detailed in the Fort Calhoun Station Abnormal Operating Procedures and Operating Instructions.
Other immediate actions and follow-up actions are identified in Section J of this plan and are described in detail in applicable Emergency Plan Implementing Procedures, listed in Appendix C of this plan.
2.5 The ICs do not signify the need for immediate implementation of protective or corrective measures. They do, however, signify the need for implementation of dose assessment measures both onsite and offsite and assessment of plant status, as applicable.
2.6 In using the ICs as the basis for initiating emergency response activity, there may be instances when the plant staff cannot determine which of two emergency classifications is appropriate for a particular occurrence. In those cases where the appropriate classification cannot be defined in a short period of time, the occurrence should be treated as the higher of the two classifications and the appropriate response for that level should be initiated.
2.7 Notification of Unusual Event 2.7.1      Notification of Unusual Event (NOUE) - Events are in process or have occurred which indicate a potential degradation of the level of safety of the plant 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 safety systems occurs. Some of these events could indicate a potential degradation in the level of plant safety and/or could escalate to a more severe condition if appropriate action is not taken.
2.7.2      The primary purpose for this classification is to ensure that the plant staff recognizes the initiating condition, takes appropriate action, such as assessment and verification, and comes to an appropriate state of readiness to respond in the event that the condition worsens.

FCS                                                                    EP-FC-1001 Section D Revision TBD Page 37 of 156 EMERGENCY CLASSIFICATION SYSTEM 2.7.3    With the exception of possible assistance by local support groups such as fire departments or medical facilities, activation of offsite facilities by offsite organizations is not anticipated for events within this classification. The command and control position at Fort Calhoun Station has the option to call all or part of the Emergency Response Organization (ERO) for support at this emergency classification.
2.7.4    Notification of Unusual Event will be made to offsite authorities in accordance with Section E of this plan.
2.8 Alert 2.8.1    Alert - Events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of intentional malicious dedicated efforts of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels. It requires response by the onsite Emergency Response Organization which augments on-shift emergency resources, and constitutes a standby initiation of the offsite emergency plan provisions. Generally, offsite emergency response agencies notify their key staff, and may begin to activate offsite response such as activation of facilities and offsite radiological monitoring. Offsite agencies will maintain this level of preparedness until termination or escalation of the Alert classification.
2.8.2    OPPD will augment the Control Room, staff the Technical Support Center and Operations Support Center at the Alert level. Typically, the Emergency Operations Facility staff will also be augmented to be placed in "standby" mode, ready to assume Command and Control if necessary.
2.8.3    Notification to offsite authorities of the Alert will be made in accordance with Section E of this plan.
2.9 Site Area Emergency 2.9.1    Site Area Emergency - Events are in process or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or security events that result in intentional damage because of intentional malicious dedicated efforts of HOSTILE ACTION; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) prevents effective access to, equipment needed for the protection of the public. Any releases are not expected to result in exposure levels that exceed EPA Protective Action Guideline exposure levels beyond the site boundary.
Offsite response agencies are fully mobilized along with notification to the general public by the sounding of the Alert Notification System (ANS) sirens surrounding the plant site.

FCS                                                                   EP-FC-1001 Section D Revision TBD Page 38 of 156 EMERGENCY CLASSIFICATION SYSTEM 2.9.2    OPPD staffs all designated Emergency Response Facilities at a Site Area Emergency or General Emergency. The full Emergency Response Organization will be activated.
2.9.3    Notification to offsite authorities of the Site Area Emergency will be made in accordance with Section E of this plan.
2.10 General Emergency 2.10.1   General Emergency - Events are in process or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity or security events that result in an actual loss of physical control of the facility. Release can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area. Total activation of the onsite and offsite emergency response organizations is required. Protective actions involving offsite populations are highly probable.
2.10.2   OPPD staffs all designated Emergency Response Facilities at a Site Area Emergency or General Emergency. The full Emergency Response Organization will be activated.
2.10.3   Notification to offsite authorities of the General Emergency will be made in accordance with Section E of this plan.

FCS                                                                EP-FC-1001 Section D Revision TBD Page 39 of 156 EMERGENCY CLASSIFICATION SYSTEM Table D Emergency Classification of Postulated Accidents Projected Worst Postulated Accident         Case Emergency                   Key Concern Classification Fuel Handling Accident General Emergency             Radiological Effluents (in Spent Fuel Pool Area)
Gas Decay Tank Rupture         Site Area Emergency            Radiological Effluents Waste Liquid Incident                  Alert                  Radiological Effluents Control Room Habitability During Toxic Chemical                  Alert                      Plant Control Release Accident

FCS EP-FC-1001 Section E Revision TBD Page 40 of 156 NOTIFICATION METHODS AND PROCEDURES 1.0   PURPOSE AND SCOPE 1.1   Purpose 1.1.1      The purpose of this PSRERP is to provide guidance for notifying state and local response organizations, the Nuclear Regulatory Commission, and members of the OPPD Emergency Response Organization during radiological emergencies.
1.2   Scope 1.2.1      This PSRERP applies to OPPD Emergency Response Organization personnel responsible for notifying state and local response organizations, the Nuclear Regulatory Commission and members of the OPPD Emergency Response Organization during a radiological emergency.
2.0   PROCEDURE 2.1   Notifications 2.1.1      The decision to make notifications is based on the emergency action levels and corresponding emergency classifications described in Section D of this Plan. As discussed in that section, they are consistent with NEI-99-01, Development of Emergency Action Levels for Non-Passive Reactors, which has been approved by the NRC replacing NUREG-0654, Rev. 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Appendix 1. The EALs are reviewed annually by the States of Nebraska and Iowa.
2.1.2      OPPD is capable of notifying and activating its Emergency Response Organization 24 hours per day. It is also able to make notifications to the states, Nuclear Regulatory Commission and, if required, local counties on a 24 hour per day basis. The applicable state plans detail the provisions for 24 hour per day notification and activation of their response organizations.
2.1.3      The Command and Control position is responsible for ensuring appropriate notifications are initiated when an emergency is classified. Fort Calhoun Station personnel in the protected area are notified via the Emergency or Fire Alarm and a public address system message. Personnel outside the protected area are notified by public address systems installed in the Administrative and Training buildings. Site Security personnel may assist in the notification of all other personnel on OPPD property. The OPPD Emergency Response Organization is activated as appropriate for the emergency classification level. This is accomplished by an automated call-out system which activates phone calls, text messages, e-mails, and other functions. Maintenance of telephone numbers is discussed in Section P of this Plan.
2016

FCS EP-FC-1001 Section E Revision TBD Page 41 of 156 NOTIFICATION METHODS AND PROCEDURES 2.1.4  Initial notification of the states of Nebraska and Iowa is made within 15 minutes after declaration of an emergency classification. The states, in turn, notify other governmental response agencies as appropriate for the emergency classification. Notification is also made to Washington, Harrison, and Pottawattamie counties within 15 minutes.
2.1.5  The primary means of notification to the states and counties is via the Conference Operations Network (COP) which is a dedicated telephone system. The COP and backup communications systems are discussed in Section F of this plan. Provisions have been made for verification of notification messages when communications are via means other than the COP.
2.1.6  Notification to the NRC is the next contact made. This notification occurs immediately after state and local notifications, not to exceed one hour after the declaration of the emergency classification. The primary means for this notification is the Federal Telecommunications System, Emergency Notification System lines (FTS-ENS). The FTS-ENS system is maintained by the NRC, however, it is routinely tested by OPPD. If the FTS-ENS is not available, notifications are made using the normal commercial telephone system.
2.2   Emergency Messages 2.2.1  Initial Emergency Message The Omaha Public Power District and the states of Nebraska and Iowa have established the contents of the initial emergency messages to be sent from Fort Calhoun Station in the event an emergency is declared. These messages contain such information as the class of emergency, whether a release is taking place, potentially affected population and areas, and whether protective measures may be necessary. This information is transmitted by a dedicated telephone system, normal telephone systems or by facsimile. Forms are used to record the information for verbal or hard copy transmission to ensure each organization receives identical information.
2016

FCS EP-FC-1001 Section E Revision TBD Page 42 of 156 NOTIFICATION METHODS AND PROCEDURES 2.2.2   Follow-Up Emergency Messages A. The follow-up emergency messages to the states incorporate the majority of the elements of Criteria E.4 of NUREG 0654, Rev. 1, as determined necessary by the states. These messages are transmitted to the states by telephone, dose assessment computer or facsimile.
Update messages are sent to the states and counties at least every 60 minutes. Updates may be decreased to shiftily during ongoing events if requested by the states and the status of the event has not changed.
B. It is the goal of Fort Calhoun to attempt to provide dose assessment updates at 15 minute intervals during a Radiological Release. During a Site Area Emergency or General Emergency, the Conference Health Physics (CHP) Network, a dedicated telephone system, can be used to maintain communications as needed. This ensures rapid transmittal of dose assessment information and protective action recommendations to the states.
C. Emergency information to the county Emergency Operations Centers (Washington, Harrison and Pottawattamie Counties) is given verbally using the Conference Operation (COP) Network. These messages discuss general conditions of the plant.
D. The NRC will be kept informed as significant events occur which warrant the upgrading or downgrading of the emergency classification. These communications with the NRC will be via the NRC's FTS-ENS (Emergency Notification System). Dose Assessment personnel will keep the NRC informed of dose assessment information using the NRC's FTS-HPN (Health Physics Network).
E. OPPD has the capability to transmit key plant parameter information directly to the NRC. This system is entitled the Emergency Response Data System (ERDS). This system is normally activated and will be verified to be functioning within one hour of declaring an Alert or higher.
Initiation of this system can be accomplished in either the Control Room or the Technical Support Center.
F. Requests for assistance from local support agencies, and others, are made using normal telephone systems.
2016

FCS EP-FC-1001 Section E Revision TBD Page 43 of 156 NOTIFICATION METHODS AND PROCEDURES 2.3   Alert Notification System 2.3.1     A system called the Alert Notification System (ANS) has been designed to provide warning to the public within 15 minutes of the decision by offsite authorities to activate the system. The system includes a series of sirens which provide essentially 100 percent coverage of the population within 10 miles of Fort Calhoun Station.
2.3.2     The states Emergency Response Plans provide guidance as to when the system should be activated. The counties will then perform the actual activation.
2.3.3     Each county has control of only the sirens located within its borders. The exception is one siren which is located in Douglas County, but activated by Washington County. All sirens within a county are sounded simultaneously, and cannot be activated individually.
2.3.4     The sirens are activated by radio signal. The county agencies and the activation locations for the sirens are as follows:
A. Washington County Emergency Communications Center located in the County Court House, Blair, Nebraska.
B. Harrison County Emergency Communications Center located in the County Jail Complex, Logan, Iowa.
C. Pottawattamie County Emergency Communications Center located in the County Court House, Council Bluffs, Iowa.
These locations are continuously staffed, providing the capability to activate the siren system 24 hours per day.
2.3.5     The Omaha Public Power District has made provisions to sound the sirens when requested to do so by government officials, should a county be unable to activate its sirens. This process can be accomplished from the Emergency Operations Facility or the E.O.-Communications division offices.
2.3.6     It is not intended that county or city governments use the ANS for weather alerts or fire signals as frequent use of the system for other purposes would tend to reduce the effectiveness of the sirens if they are needed for a nuclear power plant incident.
2.3.7     In the event that one or more sirens activates during non-emergency conditions, provisions have been made to inform the public that no emergency exists, and initiate repairs to the errant siren(s).
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FCS EP-FC-1001 Section E Revision TBD Page 44 of 156 NOTIFICATION METHODS AND PROCEDURES 2.3.8  System operability is tested periodically in accordance with the updated design report to FEMA for the outdoor public warning system and backup alert and notification.
2.3.9  Backup ANS for the EPZ is achieved through route alerting by the affected county.
2.4   Emergency Alert System 2.4.1  Members of the public have been instructed (via the Emergency Planning Booklet discussed in Section G of this Plan) to tune to their Emergency Alert System (EAS) station for emergency instructions when the sirens are activated.
2.4.2  Radio station KGOR- 99.9 FM is the Local Primary I (LP1) control station for Omaha, NE. It has the capability to broadcast emergency instructions 24 hours per day. Most other television and radio broadcast stations have the capability of carrying EAS messages during their normal hours of broadcasting.
2.4.3  For messages the risk counties will contact the National Weather Service (NWS) and request that EAS be activated. The NWS will then send out the signal to activate the EAS. KGOR has agreed to pick up this signal and broadcast the message.
2.4.4  While follow-up messages are the responsibility of the states, Omaha Public Power District has the capability to make similar information releases to the media. This is described in Section G of this plan.

==3.0   REFERENCES==
AND COMMITMENTS 3.1   NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plant 2016

FCS                                                                 EP-FC-1001 Section F Revision TBD Page 45 of 156 EMERGENCY COMMUNICATIONS

==1.0 INTRODUCTION==

This section describes the available communications for use among the principal response organizations and between the Omaha Public Power District emergency response facilities. Provisions for 24-hour per day notification to and activation of the state and local emergency response organizations are discussed in Section E of this plan. Also discussed in Section E are the provisions for activating Omaha Public Power District emergency response personnel. Provisions for periodic testing of the emergency communications system are described in Section N of this plan.
2.0 COMMUNICATIONS SYSTEMS 2.1 A number of varied communications systems are available for communications between emergency response facilities. These systems are described in this section and are summarized in Figure F-1.
2.2 In the conduct of drills and exercises, OPPD may make use of its training simulator to provide a broad range of Control Room like amenities, without impacting the operating FCS Control Room. The communications equipment in the FCS Control Room is, for the most part, duplicated in the simulator.

FCS                                                                EP-FC-1001 Section F Revision TBD Page 46 of 156 EMERGENCY COMMUNICATIONS 2.3 Each emergency response facility and the personnel responsible for 24 hour communications in each facility is listed below:
Primary/Alternate Communications Emergency Facility Responsibility Control Room Fort Calhoun Station        Shift Manager/Control Room Operator TSC, Fort Calhoun Station                Site Director Emergency Director/EOF COP EOF, North Omaha Station Communicator EOC, State of Nebraska                   Operations Officer/Communications and Warning Officer Forward Command Post, State of           Nebraska Emergency Management Agency Nebraska                                 Director/Asst Nebraska Emergency Management Agency Director EOC, Washington Cnty (Nebraska)          Washington County Communications Center/County Emergency Management Director EOC, State of Iowa                       Director, Iowa Emergency Management Division/National Guard Adjutant General Forward Command Post State of            Harrison County Sheriffs Department/State Iowa                                     Liaison Officer EOC, Harrison County (Iowa)              Communications Director/Harrison County Sheriff's Department EOC, Pottawattamie County (Iowa)         Communications Director/County Emergency Management Director 2.4 Fort Calhoun Station Alarm System 2.4.1    Emergency and Fire Alarms These alarms are sounded from the Control Room when an emergency requiring ERO activation or fire is declared. Their function is to alert personnel within the Protected Area to an emergency condition.
2.5 Fort Calhoun Station Paging Systems 2.5.1    The Protected Area paging system (Gaitronics) provides a means of intra-plant communications. Stations on this system provide access to the plant paging system and to intercom lines. These stations and speakers are placed throughout the plant including the Control Room, the Technical Support Center and the Operations Support Center.
2.5.2    The Administrative and Training buildings at the Fort Calhoun Station also

FCS                                                                  EP-FC-1001 Section F Revision TBD Page 47 of 156 EMERGENCY COMMUNICATIONS have public address announcing capabilities. Access to the public address system in either or both locations can be accomplished via the sites telephone system. This system can be used to notify personnel of a plant emergency.
2.6 Local Private Automatic Branch Exchanges (PABX) 2.6.1     Omaha Public Power District PABXs A. Company telephone systems link Omaha Public Power District facilities with those located in Omaha, Nebraska. These systems provide intracompany telephone communications and access to the public telephone network.
B. The Emergency Operations Facility has installed lines designated for emergency use. These lines are dedicated to specific emergency response positions. Telephone sets for all lines are available in the Emergency Operations Facility.
C. Trunk lines between the company PABX systems in Omaha and the Fort Calhoun Station PABX systems provide the primary means of communication with the plant. Additional lines can be provided by the local telephone company, as requested.
D. This system also provides a redundant means of providing emergency notifications to the states and counties, and is the primary backup to the Conference Operations Network (COP).
2.6.2     Fort Calhoun Station PABXs A. These dedicated telephone systems provide communications within Fort Calhoun Station locations.
B. The Technical Support Center has designated extensions for use during an emergency. They include extensions designated for use by NRC personnel. Additional lines can be diverted from other office areas as required.
C. Dedicated lines from this system are extended to the Emergency Operations Facility. This system is also connected to the company telephone system in Omaha to provide intracompany telephone communications which are not affected by the public telephone network.
D. Redundant routing of access to the public telephone network is provided via links to the public system in Blair, Nebraska as well as Omaha.
2.7 Conference Operations (COP) Network

FCS                                                                 EP-FC-1001 Section F Revision TBD Page 48 of 156 EMERGENCY COMMUNICATIONS 2.7.1    The COP system is primary emergency notification system between OPPD, state and county agencies. It is used to provide, initial, and update notifications and for general information flow between these agencies. See Figure F-1 for a list of COP locations.
2.7.2    COP is a dedicated system; each location is capable of making group calls or calling station to station within the network. See Figure F-2 for a system diagram.
2.7.3    A recorder located at the EOF records all conversations on the COP system.
The Nebraska State Patrol and the Iowa Dispatcher also have voice recording capability.
2.8 Conference Health Physics (CHP) Network 2.8.1    This network provides a dedicated means for communicating radiological information between the Technical Support Center, Emergency Operations Facility, Nebraska and Iowa Emergency Operations Centers and the Nebraska and Iowa Radiological Emergency Response Team Coordinators.
The system is shown on Figure F-3.
2.8.2    This system provides the capability for conference conversations between the Technical Support Center or Emergency Operations Facility and any one or all of the agencies on the system. A voice recorder in the Emergency Operations Facility provides a record of conversations on this system.
2.9 Facsimile (FAX) Capability 2.9.1    Facsimile machines provide the capability to link the Control Room, Technical Support Center, Operations Support Center, Emergency Operations Facility, Joint Information Center, other OPPD Headquarters facilities, the Nebraska and Iowa Emergency Operations Centers and the Nebraska and Iowa Forward Command Posts. Capability also exists to access any FAX machine via commercial telephone networks.
2.9.2    The facsimile machines can be used to transmit health physics, operational and dose assessment information from Omaha Public Power District emergency response facilities to state emergency response facilities. They can also be used to disseminate emergency status information to OPPD management. Some of these extensions have voice capabilities and serve as a backup means of voice communications for those locations.

FCS                                                                    EP-FC-1001 Section F Revision TBD Page 49 of 156 EMERGENCY COMMUNICATIONS 2.10 800 MHz Radio System 2.10.1     A 800 MHz radio communications system links Fort Calhoun Station onsite emergency response facilities, Emergency Operations Facility, plant portable radios, and mobile radios used by radiological monitoring teams. The multi-talk group/channel system is illustrated by Figures F-6, F-7, F-8, F-9 and F-10.
2.10.2     Figure F-6 illustrates the talk groups available for the Fort Calhoun Station.
Figure F-7 illustrates the dedicated subfleet for the Emergency Response Organization. Figure F-8 illustrates the shared subfleet which the ERO can utilize during emergencies. Figure F-9 provides the details for the "Talk-Around" capability which can be utilized when the 800 MHz trunking system is out of service. Figure F-10 summarizes the subfleets assigned to the Fort Calhoun Station.
2.11 NRC Emergency Notification System (FTS-ENS) 2.11.1     This NRC Operations Center is contacted via this telephone network. The FTS-ENS is a portion of the Federal Telecommunications System (FTS) and is located in the Control Room, Technical Support Center and Emergency Operations Facility. It provides plant operations information to the NRC Operations Center, in Rockville, Maryland.
2.12 NRC Health Physics Network (FTS-HPN) 2.12.1     The FTS-HPN is a portion of the Federal Telecommunications System (FTS) and is located in the Technical Support Center and Emergency Operations Facility. The network is used to exchange radiological and dose assessment information between NRC facilities and OPPD.
2.13 Priorities System 2.13.1     The Technical Support Center establishes priorities for accident mitigation and transmits the priorities to the Operations Support Center and the Emergency Operations Facility for display.
2.14 State of Nebraska Emergency Management Radio System 2.14.1     The Emergency Operations Facility is equipped with various radio equipment for use by Nebraska Emergency Management personnel. This equipment may be used either alone or in conjunction with the State of Nebraska Emergency Management Mobile Van.

FCS                                                                   EP-FC-1001 Section F Revision TBD Page 50 of 156 EMERGENCY COMMUNICATIONS 2.15 State of Iowa Emergency Management Radio System 2.15.1    The Emergency Operations Facility can support radio equipment for use by Iowa State Emergency Management personnel. This equipment may be used either alone or in conjunction with the State of Iowa Emergency Management Mobile Van.
2.16 Management Operations (MOP) Network 2.16.1    This system (similar to the COP and Ops Liaison Network) provides dedicated conference capability between the Control Room, TSC Site Director, OSC Director, EOF Emergency Director and the JIC Manager. The purpose of the system is to provide information flow between the directors of all the emergency facilities.
2.16.2    The system allows conferencing without dialing, each set is capable of conferences and individual call capability. Records of conversations on this system are captured by a voice recorder in Emergency Operations Facility.
2.17 Joint Information Center Hot Line 2.17.1    A dedicated telephone circuit is provided between the Emergency Operations Facility and Joint Information Center. The telephone sets are equipped with a blank dial plate. Lifting either handset causes a connecting ring at the other set.
2.17.2    This system provides a means for uninterrupted private communications for coordination of information releases to the public.
2.18 NAWAS 2.18.1    NAWAS equipment in the Control Room provides a redundant means of providing emergency notifications to the States of Nebraska and Iowa. It also provides the Control Room personnel with weather information.
2.19 Emergency Response Message System (ERMS) 2.19.1    A network of computer terminals is used to link the Technical Support Center, Operations Support Center and Emergency Operations Facility. It provides rapid dissemination of plant status information between facilities and ensures consistency of information at all facilities. The JIC is also equipped with a monitor which provides read-only capability. The software used for this function can be any type that provides for electronic log keeping of emergency response actions (WebEOC, ERMS, etc.)

FCS                                                                  EP-FC-1001 Section F Revision TBD Page 51 of 156 EMERGENCY COMMUNICATIONS 2.20 Telephone Service Pedestal for State Mobile Communication Vehicles 2.20.1   A telephone service pedestal is located outside of the Emergency Operations Facility near the designated parking area for the mobile communication vehicles. This pedestal is fed by a 12-pair cable from the Emergency Operations Facility and allows quick connection of various telephone facilities to the mobile vehicles. Several telephone lines and dedicated communication facilities are prewired and operational. Spare pairs are available to add additional telephone facilities quickly as the need arises.
2.21 Telephone Junction Box for NRC Mobile Vehicle 2.21.1   A telephone junction box is located on the outside wall of the Emergency Operations Facility near the designated parking area. This junction box is fed by a 12 pair cable and is equipped with four standard modular telephone jacks. These jacks are prewired to a distribution frame and allow quick connection of telephone lines to support the NRC as required. Additional jacks can be added up to the 12 pair capacity of the feeder cable.
2.22 Operations Liaison Network 2.22.1   This system provides dedicated conference capabilities between the Fort Calhoun Station Control Room/Simulator, TSC, OSC, EOF and JIC. The purpose of the system is to provide operational information from the Control Room to the other facilities for the purpose of developing response plans, determining emergency classifications and implementing assistance to the Control Room.
2.22.2   The system allows conferencing without dialing, and thus permits rapid access to the conference by the Operations Liaisons. Each station is equipped with group call and individual call capability. Records of conversations on this system are captured by a voice recorder in the Emergency Operations Facility.
2.23 Emergency Response Data System (ERDS) 2.23.1   This system provides selected ERFCS data to the NRCs Operations Center for the purpose of evaluating plant conditions. Certain data points from the ERFCS are included in the ERDS data library, and when activated, these data points are transmitted to the Operations Center. The system is normally activated and is required to be activated at an ALERT or higher classification.

FCS                                                                  EP-FC-1001 Section F Revision TBD Page 52 of 156 EMERGENCY COMMUNICATIONS 2.24 Interactive Notification System (INS) 2.24.1     This system provides rapid notification to Emergency Response Organization personnel in the event of an emergency where the ERO is activated. The system is also used to perform the Management Notification function, and can be adapted to perform other notification functions as determined necessary by the Fort Calhoun Station. A backup ERO notification process is available in the event of failure of the INS.
2.24.2     The system is activated using the internet or contacting a live operator, normally from the Control Room. The system 1) initiates a call-out to ERO members at home, mobile, or work locations, 2) sends text messages to ERO positions that provide a contact number and 3) sends e-mails to ERO personnel.
2.25 Satellite Phones 2.25.1     Satellite Phones are located in the Control Room, Technical Support Center, and Emergency Operations Facility to serve as an alternate communications option in the event normal communications equipment is unavailable.
3.0  COMMUNICATIONS WITH MEDICAL SUPPORT FACILITIES 3.1  Fort Calhoun Station emergency response organization personnel can communicate with medical support facilities, Washington County Emergency Communications Center or the University of Nebraska Medical Center, via the site telephone systems described earlier in this section.
3.2  Non-OPPD radio systems provide communications between medical support facilities and mobile rescue units as well as inter-unit communications. These radio systems have the capability to use the common medical emergency frequency which ensures coordinated communications.

EP-FC-1001 Section F FCS                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             Revision TBD Page 53 of 156 EMERGENCY COMMUNICATIONS Figure F Summary of Communications Systems Dodge County - Washington County Control Room Control Room Simulator (Training)
Technical Support Center   Operations Support Center   Emergency Operations Facility Joint Information Center FCS Security OPPD Headquarters OPPD Field Monitoring Teams Nebraska EOC Nebraska FCP (North Omaha EOF)
Nebraska State Patrol   Washington County EOC Backup EOC Iowa EOC Iowa FCP (Harrison County EOC)
Iowa Dispatch (Fort Dodge)   Harrison County EOC   Pottawattamie County EOC NRC - Headquarters   NRC - Region IV Drill Communications (Admin 1D)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             NRC - Resident Inspectors FCS Plant Paging (Gai-Tronics)
OPPD PABXs FCS PABXs Commercial Telephone Systems COP Network (Notifications)
CHP Network (HP Information)
FTS-ENS Phones (NRC)
FTS-HPN Phones (NRC)
Available Fax Machines OPPD 800 MHz Radio System JIC Hotline NAWAS Electronic Emergency Logs MOP Network State of Nebraska Radio State of Iowa Radio Law Enforcement Radios Operations Liaison Network ERDS INS Satellite Telephone

EP-FC-1001 Section F FCS                                                                       Revision TBD Page 54 of 156 EMERGENCY COMMUNICATIONS Figure F Conference Operations Network

EP-FC-1001 Section F FCS                                                                           Revision TBD Page 55 of 156 EMERGENCY COMMUNICATIONS Figure F Conference Health Physics Network

EP-FC-1001 Section F FCS                                                                     Revision TBD Page 56 of 156 EMERGENCY COMMUNICATIONS Figure F MOP (Management Operations)

EP-FC-1001 Section F FCS                                                                    Revision TBD Page 57 of 156 EMERGENCY COMMUNICATIONS Figure F Operations Liaison Network

FCS                                                        EP-FC-1001 Section F Revision TBD Page 58 of 156 EMERGENCY COMMUNICATIONS Figure F OPPD/Fort Calhoun Station 800 MHz Radio System

FCS                                                         EP-FC-1001 Section F Revision TBD Page 59 of 156 EMERGENCY COMMUNICATIONS Figure F Fort Calhoun Station Subfleet - SF4

FCS                                                         EP-FC-1001 Section F Revision TBD Page 60 of 156 EMERGENCY COMMUNICATIONS Figure F Fort Calhoun Station Subfleet - SF5

FCS                                                          EP-FC-1001 Section F Revision TBD Page 61 of 156 EMERGENCY COMMUNICATIONS Figure F Fort Calhoun Station Talk-Around Channel (TA)

FCS                                                       EP-FC-1001 Section F Revision TBD Page 62 of 156 EMERGENCY COMMUNICATIONS Figure F Summary of 800 MHz Radio Uses Channel     Display               Normal Use               Emergency Use 1       SF1 Sec 1            Security-Primary           Security-Primary 2       SF2 Sec 2           Security-Secondary         Security-Secondary 3        SF3 Ops                Operations                 Operations 4        SF4 EP             Emergency Planning         Field Team Control 5        SF5 RP             Radiation Protection     In-Plant Team Control 6       SF6 Maint.             Maintenance           In-Plant Team Control 7       SF7 ERO             Emergency Planning        Emergency Planning 8      SF8 Work Ch            Work Channel              Available for Use 9      SF9 EP Cntlr            EP Controller            Available for Use 10        Spare 1                   Future 11        Spare 2                   Future 12        Spare 3                   Future 13      Talk Around             Talk Around              Emergency Use 14     Unprogrammed             Not Available              Not Available 15     Unprogrammed             Not Available              Not Available 16     Unprogrammed             Not Available              Not Available

FCS                                                                      EP-FC-1001 Section G Revision TBD Page 63 of 156 PUBLIC EDUCATION AND INFORMATION 1.0  PUBLIC INFORMATION CONTENT AND DISSEMINATION 1.1  Public Information Content The Omaha Public Power District (OPPD) Corporate Communications Division has coordinated with the States of Nebraska and Iowa in the preparation and dissemination of educational information. A brochure entitled Fort Calhoun Nuclear Station Emergency Planning Information incorporates the following information:
1.1.1      A description of natural background and manmade radiation, including estimated annual doses from various sources of radiation.
1.1.2      Public warning procedures and use of radio and television following an emergency at the Fort Calhoun Station.
1.1.3      Radiation protection, including such protective actions as in-house sheltering and evacuation.
1.1.4      Special evacuation notes, including special needs of the handicapped, medical and nursing home patients, registration centers, evacuation routes and a Sub Area map of the EPZ.
1.1.5      Information concerning the primary Emergency Alert System.
1.1.6      Additional protective actions including ad hoc respiratory protective devices.
1.1.7      A list of contact points to obtain additional information.
1.2  Public Information Dissemination The Public Information Brochure is distributed in written form annually by mail to the permanent adult population within an approximate 10-mile radius of Fort Calhoun Station. A general distribution to reach the transient population is achieved by posting information in public areas and by placing supplies of prepared written material in motels, service stations, and government buildings. Media advertisements, utility bill inserts, telephone tape messages, news releases, and public seminars may also be utilized for public education and information.
An Emergency Planning recurring task verifies the content and dissemination of this information.

FCS                                                                       EP-FC-1001 Section G Revision TBD Page 64 of 156 PUBLIC EDUCATION AND INFORMATION 2.0  NEWS MEDIA COORDINATION AND FACILITIES There are two (2) locations available for use of the news media. The Joint Information Center (JIC) is the primary facility for the release of all information; the Emergency Operations Facility (EOF) has limited space for press briefings and may be used on a selective basis. The Corporate Crisis Communication Plan provides the guidance for the operation of the Joint Information Center during emergencies. This plan is reviewed annually in accordance with an Emergency Planning Test.
2.1  Joint Information Center (JIC)
The primary information point is the Joint Information Center located within OPPDs Energy Plaza at 444 South 16th Street Mall, Omaha, Nebraska. This center is activated for either a Site Area Emergency or General Emergency and will accommodate Joint Information Center personnel as well as local, State and Federal public information personnel.
For Classifications below Site Area Emergency, the Division Manager-Corporate Communications shall determine the corporate response for media coordination efforts.
The Joint Information Center also serves as the public inquiry center for OPPD, State and Federal authorities.
2.2  Emergency Operations Facility Briefing Room A secondary facility is located in the Emergency Operations Facility located at the North Omaha Power Station. However, the Joint Information Center is the preferred point of news media information.
The EOF Briefing Room was constructed as working space for 25 news correspondents. It is anticipated that space in this facility will be for the local media which routinely cover OPPD activities. Remaining space will be allocated to the national and regional media on a pool basis.

FCS                                                                  EP-FC-1001 Section G Revision TBD Page 65 of 156 PUBLIC EDUCATION AND INFORMATION 3.0  EMERGENCY CLASSIFICATION INFORMATION RELEASES Following the classification of an emergency, Corporate Communications Division representatives will be informed of the emergency action level invoked at the plant and the reason or reasons thereof. Once such notification has been made, release of information to the news media will be coordinated by the Division Manager - Corporate Communications or the Joint Information Center Manager. That position will also coordinate the timely exchange and release of information with the official spokespersons for Federal and State agencies. The JIC Manager will report directly to the Emergency Director. A JIC Technical Liaison at the Joint Information Center will assist in nuclear related information matters. The JIC Technical Liaison will also be in direct contact with the EOF Information Specialist or the EOF Technical Liaison who will provide prompt and accurate information regarding plant status. The Corporate Crisis Communication Plan activates and augments the JIC staff. During all emergency classifications, the Corporate Spokesperson is the official designated spokesperson for OPPD.
4.0  NEWS MEDIA EXPOSURE TO EMERGENCY PLANNING INFORMATION The Corporate Communications Division mails an annual information packet or conducts an annual seminar to acquaint the local news media with the operation of Fort Calhoun Station and its emergency plan, including the public information procedures to be followed in an emergency. The mailing\seminar also provides educational information concerning radiation, and nuclear related subjects deemed appropriate. An Emergency Planning recurring task verifies the transmittal of the information packet or conduct of the seminar to the local news media outlets.

FCS                              EP-FC-1001 Section G Revision TBD Page 66 of 156 PUBLIC EDUCATION AND INFORMATION

FCS                                                                      EP-FC-1001 Section H Revision TBD Page 67 of 156 EMERGENCY FACILITIES AND EQUIPMENT NOTE This section lists the Emergency Response Facilities (ERF) available for i   activation in the event of an emergency at the Fort Calhoun Nuclear Station, including the ISFSI. General equipment and staffing of emergency            i facilities are also included in this section. Communications equipment is covered in Section F. Assessment equipment is covered in Section I.
1.0   TECHNICAL SUPPORT CENTER (TSC) 1.1   Facility Function and Description 1.1.1      The TSC's primary function is the collection, analysis, and distribution of technical data required to support plant personnel during an emergency.
This support is provided from a separate and distinct center, thus reducing personnel congestion in the Control Room. The TSC has the capability to perform EOF functions and responsibilities until that facility can be fully activated.
1.1.2      The TSC building is located on the north side of the Auxiliary Building. (See Figure H-1). The north wall of the auxiliary building is shared as the south wall of the TSC. To the east of the building is the maintenance shop. To the north and west of the TSC is the Chemistry/Radiation Protection Building.
The TSC building was designed to meet the criteria of NUREG 0696 and is less than a two minute walk from the Control Room.
1.1.3      The TSC is composed of a protected area and an equipment area. It is comprised of heavy concrete mat construction with 1-1/2 foot thick reinforced concrete walls and ceiling. This part of the structure is kept at positive pressure and the building air can be filtered through a pre-filter, HEPA filter and charcoal filter. Flood barriers in various locations of the plant protect the TSC from flooding and are designed for a 100 year recurrence frequency.
1.1.4      An "L" shaped equipment area is located to the east and south of the TSC protected area. The equipment area has concrete footings and common steel construction with concrete block walls. Items included in the equipment area are the batteries and UPS power distribution systems, HVAC and HEPA filters.

FCS                                                                  EP-FC-1001 Section H Revision TBD Page 68 of 156 EMERGENCY FACILITIES AND EQUIPMENT 1.2 Equipment and Supplies 1.2.1  The TSC is typically equipped with the following items:
A. System Drawings for the nuclear power plant and the ISFSI B. Vendor Manuals C. An official copy of the Fort Calhoun Station Operating Manual. (This includes the Operating Procedures and Instructions, the Post Shutdown Radiological Emergency Response Plan and Emergency Plan Implementing Procedures.
D. Updated Safety Analysis Report (USAR) for the nuclear power plant and the NUHOMS Storage System FSAR for the ISFSI (electronically)
E. Technical Specifications for the nuclear power plant and the ISFSI (electronically)
F. Direct and Airborne Radiation Monitoring Equipment which is permanently installed:
: 1. Area Monitor (RM-093):
The area monitor in the TSC is a GM detector (or equivalent) that detects gamma radiation.
: 2. Particulate, Iodine and Noble Gas (PING) Monitor:
The sampler and detector subsystem contains a combined particulate, iodine and noble gas sampler in one compact, lead-shielded assembly. Three read-outs contain all alarm functions of alert, high and failure, along with check source actuation controls.
The PING is piped directly to the TSC ventilation system to monitor TSC supply air at all times.
G. Emergency Response Facilities Computer System/Safety Parameter Display System (ERFCS/SPDS).
H. Personal Computer(s) with printers.
I. Emergency Response Message System.
J. Sign-in Board with identification tags.
K. Emergency logs.
L. Status boards.

FCS                                                                       EP-FC-1001 Section H Revision TBD Page 69 of 156 EMERGENCY FACILITIES AND EQUIPMENT M.       The ability to provide output displays to the OSC and EOF.
1.3 Staffing 1.3.1     The TSC affords ample space and equipment to support the Emergency Response Organization (ERO) as stated in Section B and additional TSC personnel as defined in the Fort Calhoun ERO Roster. In addition, space has been allocated for NRC representatives.
2.0 EMERGENCY OPERATIONS FACILITY (EOF) 2.1 Facility Functions and Description 2.1.1     The function of the Emergency Operations Facility is to serve as the support facility for the licensee's overall management of emergency response activities (including coordination with Federal, State and local officials), the central collection and coordination point for all off-site radiological and environmental samples and assessments in order to make public protective action recommendations (PARs).
2.1.2     The Emergency Operations Facility is located 17 miles from the Fort Calhoun Station at the North Omaha Power Station. This site was chosen to ensure continuous habitability and is the only Emergency Operations Facility in the district. The building is capable of providing working space for a minimum of 35 persons consistent with the requirements of NUREG-0696, Revision 1.
Space for data systems equipment, communications and storage activities is also available.
2.1.3     The alternative facility maintains the capability for staging the TSC/OSC emergency response organization personnel in the event of a hostile action.
The alternative facility has the capability for communications with the control room, and plant security; the capability to perform offsite notifications; and the capability for engineering assessment activities. The EOF will satisfy the offsite notification responsibilities for the alternative facility. The EOF staff will support offsite notification responsibilities while the TSC/OSC ERO are performing activities supported by the alternate facility. The alternate facility is co-located with the EOF at OPPDs North Omaha Station.

FCS                                                                EP-FC-1001 Section H Revision TBD Page 70 of 156 EMERGENCY FACILITIES AND EQUIPMENT 2.2 Equipment and Supplies 2.2.1    The EOF is typically equipped with the following emergency response items:
A. Emergency Status Boards B. 10-Mile EPZ Maps C. Emergency Monitor Kits D. Assignment Board with identification tags E. Portable Calculator(s)
F. Emergency Telephone Books G. Emergency Logs H. Personal Computers and Printers I. Technical Specifications for the nuclear power plant and the ISFSI (electronically)
J. System Drawings for the nuclear power plant and the ISFSI K. Complete latest revision of the Fort Calhoun Station Operating Manual.
(This includes the Operating Procedures and Instructions, the Post Shutdown Radiological Emergency Response Plan and Emergency Plan Implementing Procedures).
L. Emergency Response Facilities Computer System/Safety Parameter Display System (ERFCS/SPDS)
M. Emergency Response Message System (ERMS) 2.3 Staffing 2.3.1    The EOF affords ample space and equipment to support the Emergency Response Organization as stated in Section B. In addition, space has been allocated for NRC Representatives.

FCS                                                                   EP-FC-1001 Section H Revision TBD Page 71 of 156 EMERGENCY FACILITIES AND EQUIPMENT 3.0 OPERATIONS SUPPORT CENTER (OSC) 3.1 Facility Function and Description 3.1.1     The Operations Support Center (OSC) is an onsite facility, separate from the Control Room (CR) and the Technical Support Center (TSC) where support personnel assemble and prepare to perform investigative or corrective actions as deemed necessary by the CR or TSC.
3.1.2     The OSC communicates with the CR and the TSC and is located in the TSC Building.
3.2 Equipment and Supplies 3.2.1     Equipment lockers are provided in the OSC for storage of instruments, SCBAs, supplies and reference documents.
3.3 Staffing 3.3.1     OSC management is comprised of an OSC Director and three technicians representing the radiation protection, chemistry and maintenance disciplines.
(See Section B of this plan for a comprehensive organization definition).
4.0 CONTROL ROOM 4.1 Facility Description and Function 4.1.1     The Control Room functions as the onsite location from which the FCS systems are monitored and controlled and from which any ISFSI operations are coordinated. It is large enough to contain all the instrumentation, controls and displays for the nuclear systems, reactor coolant systems, steam systems, electrical systems, safety and accident monitoring systems. The Control Room plays a vital role in the Emergency Response Organization by providing the initial response actions needed to react to any emergency situation. The Control Room personnel will respond to all emergency situations in an attempt to mitigate the emergency and minimize the impact on the surrounding environment, health and safety of the public as well as plant personnel and equipment.

FCS                                                                  EP-FC-1001 Section H Revision TBD Page 72 of 156 EMERGENCY FACILITIES AND EQUIPMENT 4.2 Equipment and Supplies 4.2.1    The Fort Calhoun Station Control Room is typically supplied with the following emergency supplies:
Emergency Locker (Computer Room)
Operating and Emergency Procedures and Manuals Radiological Monitoring Equipment Technical Specifications for FCS and the ISFSI (electronically)
System Drawings for the nuclear power plant and the ISFSI (electronically) 4.3 Staffing 4.3.1    In addition to normal CR personnel, additional positions are called out in the event of an emergency situation as stated in Section B.
5.0 EMERGENCY KITS 5.1 The emergency kits and equipment are inventoried in accordance with Fort Calhoun Station Surveillance Tests Procedures. Extra quantities of equipment, spare parts and supplies are located at the Fort Calhoun Station Warehouse to support extended emergencies.
5.2 Radiological Emergency Kits 5.2.1    These kits include protective equipment, radiological monitoring equipment and emergency supplies. Kits are located in the Control Room, Technical Support Center, Operations Support Center and the Emergency Operations Facility.
5.2.2    The Radiation Protection Department establishes the method and frequency for instrument calibration. Individual instruments are calibrated using approved calibration procedures. Repair/replacement of equipment is coordinated through the Radiation Protection Department.
5.3 Dosimetry Kits 5.3.1    These kits include dosimetry, dosimeter chargers and appropriate paperwork. Kits are located in the Control Room, Technical Support Center, Operations Support Center and Emergency Operations Facility.

FCS                                                                  EP-FC-1001 Section H Revision TBD Page 73 of 156 EMERGENCY FACILITIES AND EQUIPMENT 5.4 Medical Kits 5.4.1    First Aid Equipment and Supply Kits A. First aid equipment and supplies are located in the First Aid Room.
Trauma and primary response kits are available throughout the plant.
These kits are inspected and maintained by the Industrial Safety Coordinator.
5.4.2    Contaminated/Injured Person Kit A. These kits are located in the Operations Support Center and near the RP Count Room. These kits are maintained by the Radiation Protection Department.
5.5 Decontamination Area 5.5.1    Decontamination equipment and supplies are located in the main warehouse and the radiation protection work area.
5.6 Field Monitoring Kits 5.6.1    OPPD maintains two vehicles designated for emergency use, each vehicle is equipped with radiological monitoring equipment, emergency supplies, and other equipment/supplies that may be used by teams monitoring radiological conditions on and off site. Each vehicle also has a permanently installed communications system as described in Section F.
5.6.2    Radiological equipment or other equipment that is/or may be affected by climate changes may be stored in a designated storage area.
5.6.3    Use of these emergency vehicles is authorized by the Manager-Emergency Planning or designee. In the event a vehicle requires servicing every effort will be made to have it returned on the same day. A sign reminding users that the vehicle shall be returned to its home base in the event of a declared emergency at Fort Calhoun Station is posted in each vehicle.

FCS                                                                 EP-FC-1001 Section H Revision TBD Page 74 of 156 EMERGENCY FACILITIES AND EQUIPMENT 5.7 Other OPPD Resources 5.7.1   OPPD has other facilities and resources that may be useful in support of an emergency at Fort Calhoun Station. Examples are:
A. Fort Calhoun Station Simulator could be used to model plant transients or serve as an alternate location for support and technical personnel.
The simulator has the following communications equipment: Conference Operation Network (COP), Operations Liaison Network, FTS-ENS Phone, Gai-tronics, remote radio base station, regular phone systems, computer terminal for dose assessment, and FAX machine.
B. The FCS Training Center, the FCS Administration Building, and Energy Plaza make available resources such as: briefing rooms, classrooms, technical libraries, a chemistry laboratory, a radiation protection laboratory, communications, computers, food storage and preparation facilities, alternate water supply, and shop areas.

FCS                                                           EP-FC-1001 Section H Revision TBD Page 75 of 156 EMERGENCY FACILITIES AND EQUIPMENT Figure H Onsite Emergency Response Facilities

FCS                                                            EP-FC-1001 Section H Revision TBD Page 76 of 156 EMERGENCY FACILITIES AND EQUIPMENT Figure H Typical Technical Support Center Layout

FCS                                                            EP-FC-1001 Section H Revision TBD Page 77 of 156 EMERGENCY FACILITIES AND EQUIPMENT Figure H Typical TSC Entry/Briefing Area

FCS                                                           EP-FC-1001 Section H Revision TBD Page 78 of 156 EMERGENCY FACILITIES AND EQUIPMENT Figure H Typical Operations Support Center Layout

FCS                                                                               EP-FC-1001 Section H Revision TBD Page 79 of 156 EMERGENCY FACILITIES AND EQUIPMENT Figure H Typical Emergency Operations Facility Layout A. Dose Assessment        E. ENS Phones     I. NRC Van Elect/Tele Hookup     M. Operations Liaison Terminals                                                                   Phone B. ERF Terminals          F. Fax Machines   J. Nebr. CRUSH Elect/Tele Hookup C. CHP Phones             G. ERF Printer    K. COP Phone D. HPN Phones             H. Siren Terminal L. Mop Phone
: 1. Emergency Director                              30. NE. Governor's Authorized Representative
: 31. NE. GAR Advisor
: 3. EOF Operations Liaison                          32. NE. Manager
: 4. EOF COP Communicator                            33. NE. RAD. Team Coordinator
: 5. Protective Measures Manager                     34. NE. Recorder
: 35. NE. Dose Calculations
: 7. EOF Field Team Specialist                       36. NE. Public Information Officer
: 8. EOF Dose Assessment Specialist                  40. IA. Representative
: 41. IA. RAD. Team Coordinator
: 50. NRC Site Team Leader/DSO/MCL
: 11. EOF Technical Liaison                           51. NRC Emergency Response Coordinator
: 12. Des Moines Site Representative                  52. NRC Status Summary Coordinator
: 13. EOF Administrative Logistics Manager            53. NRC Governmental Liaison Coordinator
: 54. NRC Public Information Representative
: 55. NRC Dose Assessment Representative
: 56. NRC Reactor Safety Coordinator/RSCL
: 57. NRC Protective Measures Team Leader
: 18. EOF Security Personnel                          58. NRC Protective Measures Coordinator/PMCL
: 59. NRC Status Summary Communicator
: 60. NRC Emergency Response Assistant
: 70. FEMA Representative

FCS                                                                         EP-FC-1001 Section I Revision TBD Page 80 of 156 ACCIDENT ASSESSMENT 1.0  ACCIDENT ASSESSMENT 

==SUMMARY==

Accident assessment is divided into initial and long term phases. At the beginning of an event initial assessments are performed in the Control Room. These early assessments are used as a basis for classifications, immediate actions and emergency response. The Shift Manager is responsible for initial event assessment, classification and initiation of appropriate notifications. Initial dose assessment with recommended protective actions can be performed and evaluated as soon as practical by onsite staff. These projections will be made available to offsite governmental agencies.
Initial assessments using plant parameters or other indicators are compared to pre-determined emergency action levels to select the proper emergency classification.
The plant parameters may be system conditions, system configuration, radiological parameters, etc. The Control Room is equipped with adequate monitoring equipment to determine these parameters for rapid assessment and decision-making.
The long term or continuing accident assessment is performed using the Control Room monitoring equipment and other methods made possible by additional resources from the Emergency Response Organization and offsite organizations. This includes radiological information gathered from field monitoring and environmental monitoring teams.
2.0  ASSESSMENT CAPABILITIES 2.1  Resources for Detection/Assessment of Non-Radiological Events 2.1.1      Fire Detection The fire detection system is detailed in the Station Fire Plan.
2.1.2      Seismic Monitoring Plant seismic instrumentation is provided to determine the response of the containment and auxiliary building structures in the event of an earthquake so that such response can be compared with that used as the basis of design.
Should a seismic disturbance occur in the neighborhood of the plant, the accelerations recorded within the plant will be the basis for a decision as to continued plant operation.
Seismic information is also available offsite through the U.S. Department of the Interior, United States Geologic Survey, National Earthquake Information Service, Boulder, Colorado.

FCS                                                                      EP-FC-1001 Section I Revision TBD Page 81 of 156 ACCIDENT ASSESSMENT 2.1.3     River Level River level is available from local read-out in the intake structure, the plant computer and offsite sources.
2.2  Resources for Detection/Assessment of Radiological Releases 2.2.1     Plant Process Radiation Monitors This instrumentation, a part of the Radiation Monitoring System (RMS), is provided to monitor systems in strategic locations throughout the plant for normal and emergency conditions. The monitors are used for trending, determining radioactive material release permit limits, initiating safety signals to limit releases and assessing release rates during an emergency.
The channels of this system provide data both in the Control Room and on the Emergency Response Facility Computer System (ERFCS).
Depending on the type, the various monitors in the system can be used to detect particulate and gaseous radioactivity levels at release points throughout the plant, including containment. The system also provides accident range capability on the Auxiliary Building Ventilation Stack and the Main Steam line.
2.2.2 Area Radiation Monitors Area Radiation Monitors are strategically located throughout the plant to monitor gamma radiation levels.
2.2.3 Meteorological Instrumentation The plant has a permanent 110m meteorological tower with detectors at 10 and 60 meters, and a redundant power supply; the sole output of information from the tower is the ERFCS. In the event of failure of this system, wind speed and direction can be obtained from the National Weather Service in Valley NE, or the Offutt Air Force Base.
The USAR Section 2.5 discusses the terrain around Fort Calhoun Station and its effects on an airborne plume. Historical meteorological data is also available from the plant computer. This data will be made available by OPPD to the appropriate government agencies.

FCS                                                                     EP-FC-1001 Section I Revision TBD Page 82 of 156 ACCIDENT ASSESSMENT 2.2.4 Water Analyses Analyses of plant liquid systems may be performed to help ascertain the nature of problems detected by other instrumentation (prior to an emergency situation).
The samples will be collected and analyzed per applicable Fort Calhoun Station procedures.
2.2.5 Post Accident Sampling Methods have been established to collect and analyze samples from the primary coolant system, containment atmosphere, auxiliary building ventilation duct pathway, the main steam safety relief and atmospheric dump valve pathway, and the occupied areas. These methods are described in applicable Fort Calhoun Station procedures.
2.3  Field Monitoring 2.3.1 Monitoring Operations In the event of an unplanned airborne materials release following an accident, field monitoring teams will be dispatched to evaluate activity levels.
River water samples can be collected and analyzed in the event radioactive water or liquid is discharged without proper monitoring per the Environmental Monitoring Program. The Metropolitan Utilities District will be notified when accidental liquid discharges occur.
The primary objective of the emergency onsite and offsite field monitoring teams is to survey areas downwind of the plant site in order to determine the extent and magnitude of any unplanned release of radioactive material following an incident.
The task of each monitoring team is to collect air samples and survey data and transmit information and results to the appropriate emergency response facility.
This information will be used to define affected areas, and assess the extent and significance of the release. Surveys are done per the applicable Radiation Protection or Emergency Plan procedures.
2.3.2 Personnel A. Onsite Field Monitoring The onsite field monitoring teams focus is primarily on obtaining radiological data within the protected area. These teams are typically dispatched from either the Control Room or Operations Support Center.

FCS                                                                     EP-FC-1001 Section I Revision TBD Page 83 of 156 ACCIDENT ASSESSMENT B. Offsite Field Monitoring The offsite field monitoring team(s) focus is on obtaining radiological data outside the owner controlled area. Primary direction of the off-site field monitoring teams is from the EOF, with back up capability at the TSC.
C. Environmental Monitoring Environmental monitoring may be done as a function of recovery from an emergency. Types of sample media and team makeup are dependent upon the needs determined by management personnel.
2.3.3 Equipment Section H of this plan and the applicable station procedures list the Emergency Kit locations.
3.0  ASSESSMENT OF RADIOLOGICAL RELEASES 3.1  Methods of Assessment The methods used for the assessment of radioactivity released to the environs are detailed in the Emergency Plan Implementing Procedures.

FCS EP-FC-1001 Section J Revision TBD Page 84 of 156 PROTECTIVE RESPONSE 1.0 PUBLIC INFORMATION CONTENT AND DISSEMINATION 1.1 Notification 1.1.1      Onsite personnel are notified of a nuclear emergency via the emergency alarm. This alarm is identified by an intermittent howl and is distinguished from the fire alarm which is a continuous howl. Once the emergency alarm is sounded, the command and control position will give the emergency classification, with other pertinent information, using the intra-plant communication system (Gaitronics). If the owner-controlled area is to be evacuated, personnel will be notified by: 1) Gaitronics System, 2)
Administration and Training Building paging systems, 3) Security Personnel, and/or 4) Alert Notification System, if used.
1.2 Evacuation 1.2.1      If the emergency requires Protected Area evacuation, all onsite personnel considered nonessential to the mitigation of the event will normally proceed to a designated location or to their homes. If a release has occurred or there is reason to suspect contamination the evacuees will be sent to the OPPD Elkhorn Center.
1.2.2      Approximately 600 persons might be evacuated during normal work hours and operation; approximately 900 persons might be evacuated during a major outage. During normal operating off-shift hours, no evacuation of onsite individuals is expected. Both OPPD and personal vehicles are used for site evacuation transportation. Agreements with the State of Nebraska and specifically the State Patrol guarantee professional handling and control of traffic. Normal travel time to Elkhorn Center is 37 minutes using the normal evacuation route and 53 minutes using the alternate evacuation route at an average speed of 40 mph. Personnel at the Elkhorn Center will coordinate personnel/vehicle monitoring and decontamination activities, if required.
1.2.3      Security and RP personnel inspect the owner controlled area after a site evacuation has taken place. If any persons other than emergency workers are in the owner controlled area during or after site evacuation, they will be given specific directions and/or escorted off-site.

FCS EP-FC-1001 Section J Revision TBD Page 85 of 156 PROTECTIVE RESPONSE 1.3 Security and Accountability 1.3.1     Security A. The security program is designed to deter, delay and detect an intruder.
The Security Area of the plant site is enclosed by an eight foot security fence topped by three strands of barbed wire. All gates to the fence are normally kept locked. An inner perimeter consists of personnel doors, roof hatches, and overhead doors equipped with magnetic alarm switches.
B. Personnel assigned by the Site Director to enter the plant must pass through the main gate which is guarded. It is extremely unlikely that any unauthorized person would be able to enter the site undetected even during an emergency condition.
1.3.2     Accountability A. If accountability of onsite personnel is necessary, the onsite command and control position will notify personnel onsite by announcements on the Gaitronics System, and by sounding the Emergency Alarm (if required). At the completion of the notification(s), the accountability process begins, to be completed within 30 minutes.
B. Accountability is a process taking place in several areas:
: 1. Accountability of personnel reporting to the Control Room, TSC, or OSC for emergency response will be performed by personnel using the card readers at these locations.
: 2. Accountability of security force personnel will be accomplished using established security procedures.
: 3. Once initial accountability is complete, the command and control position, will be notified of the results.
: 4. Accountability is maintained by the use of rosters at the Control Room, OSC and TSC. Persons must sign in and out as they enter and leave. These rosters will be compared to a list of personnel who accessed the protected area whenever necessary. Continuous accountability of security personnel is accomplished using established security procedures.

FCS EP-FC-1001 Section J Revision TBD Page 86 of 156 PROTECTIVE RESPONSE 1.4 Protective Measures 1.4.1     It is the policy of OPPD to keep personnel radiation exposure within federal regulations, and station limits and guidelines, beyond that, to keep it As Low As Reasonably Achievable (ALARA). Every effort will be made to keep their exposures within the limits of 10 CFR 20.
1.4.2     Personnel monitoring devices are required for all personnel meeting the conditions specified in 10 CFR 20 Section 20.1502, Technical Specifications Section 5.11 and in Radiation Protection Procedures. During emergency conditions, implementing procedure EP-FC-113 will be utilized.
1.4.3     Dosimeters and TLDs are typically located in each of the emergency lockers in the Control Room, EOF, OSC and the TSC. Additional dosimeters and TLDs may be obtained from the dosimetry group.
1.4.4     Clothing A. Protective clothing is a normal use item utilizing both washable and disposables. For entry into affected areas, the OSC has approximately 50 complete sets of protective clothing available. The Control Room has approximately 12 complete sets available. Additional sets are available at the Radiation Control Point. Approximately 2000 sets are ready for use and a large supply of washable and/or disposable coveralls is maintained in the warehouse and RP storage areas. Water-proof protective clothing is also a standard stock item.
1.4.5     Respiratory Protection A. Respiratory protective devices may be required where an airborne radioactivity condition is potential or existent. In such cases, the air will be monitored and the necessary protective devices specified according to the concentration and type of airborne contaminants present.
Monitoring and issue of respiratory protection equipment will be conducted in accordance with Radiation Protection Manual Procedures.
Precautions will be taken to keep airborne contamination to a minimum through the use of proper engineering controls and decontamination.
B. Limits for inhalation of radionuclides are established in Appendix B, Table 1 of 10CFR20. The Radiation Protection Manual establishes the station's administrative limits for inhalation which will be adhered to in emergencies if possible.
C. Types and recommended use for each type of respirator is specified in the Radiation Protection Manual.

FCS EP-FC-1001 Section J Revision TBD Page 87 of 156 PROTECTIVE RESPONSE D. Approximately 35 self contained breathing apparatus are maintained onsite. Of these, a portion is maintained for fire brigade use, or normal use, and the remainder for emergency response. Spare bottles are also stored in some locations. The site has the capability to refill bottles with a compressor/air bank unit, with a cascade tank unit as a backup.
Full-face respirators are maintained in some emergency gear lockers.
Respirators are staged for use in plant radiation areas. The onsite Stores warehouse stocks approximately 150 full-face respirators for reserve supply.
1.4.6     Radioprotective Drugs A. The need for issuance of radioprotective drugs, specifically potassium-iodide, is determined using appropriate procedures.
B. Radioprotective drugs in the form of potassium iodide tablets are available in the Control Room, Technical Support Center, Operations Support Center, Emergency Operations Facility and the Field Team equipment lockers. Each bottle contains dosage supply for 14 days.
Emergency workers are instructed on the advantages and disadvantages of taking the tablets to provide thyroid blockage. The final decision for use of the potassium iodide is made by the emergency worker.
2.0 PROTECTIVE RESPONSE FOR RESIDENTS WITHIN THE PLUME EXPOSURE PATHWAY 2.1 Protective Action Recommendations 2.1.1     OPPD Guidelines A. Fort Calhoun Station is designed and equipped with a series of safety systems engineered to meet all of 10 CFR 100 criteria for reactor safety.
OPPD recognizes that in any accident situation, it would be prudent and logical to make every effort to further reduce and minimize exposure to the public. OPPD management will recommend to appropriate State and local authorities that protective actions be initiated if any person is expected to receive an emergency exposure in excess of Environmental Protection Agency (EPA) guidelines.
B. Tables J-11 through J-41 provides some information and guidance on formulating Protective Action Recommendations (PAR's). Table J-11 summarizes the considerations for selecting the evacuation Protective Action Guides (PAG's). Table J-21 outlines the early (plume) phase PAG's due to exposure of airborne and deposited radioactivity.
Table J-31 summarizes the considerations for selecting relocation PAG's.
Table J-41 outlines the immediate (relocation) phase PAG's due to exposure to deposited radioactivity.

FCS EP-FC-1001 Section J Revision TBD Page 88 of 156 PROTECTIVE RESPONSE C. During the early (plume) phase of a radiological emergency, professional judgement will be required in the application of PAG's, due to varying characteristics, such as; plant conditions, evacuation time estimates, environmental conditions, affected population groups, etc. In all cases, the PAR's transmitted by OPPD to the states of Iowa and/or Nebraska are strictly recommendations. The respective government agencies in each state have the ultimate responsibility for implementing necessary protective actions for the general public.
1 Taken from "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents." EPA-400-R-92-001, Revised May, 1992.
D. Tables J-5 and J-6 provide information pertaining to emergency worker exposure limits and health risks associated with exposure to higher dose levels.
2.1.2      Initiation of Recommendations A. Recommendations will originate from an Emergency Response Facility based upon data derived from implementing procedure, EP-FC-110, Assessment of Emergencies. This procedure establishes a method for determining projected doses to the population-at-risk. Protective action recommendations based on radiological parameters or plant conditions are determined using EP-FC-111, Emergency Classification and Protective Actions. Total population exposure can be estimated using projected or known dose values and population densities.
2.2 Notification 2.2.1      In the event public notification is required, both transient and resident population within the plume exposure pathway will be initially notified through the Alert Notification System (reference Section E) and as described in state and county radiological emergency plans. Information will be provided for transient and resident population as well as the general public outside the EPZ through the Emergency Alert System.
2.2.2      Information brochures describing notification, protective actions and general radiological education are provided to residents by mail and by public service posting to transients within the EPZ. The States of Iowa and Nebraska will issue messages describing the incident and recommended public protective actions.

FCS EP-FC-1001 Section J Revision TBD Page 89 of 156 PROTECTIVE RESPONSE 2.3 Evacuation 2.3.1    Evacuation Time Estimate Study A. Studies estimating the time required to evacuate the residents in the plume exposure pathway from the emergency planning zone were conducted in accordance with NUREG-0654, Rev. 1, Appendix 4 criteria.
These studies are supporting documents to this Plan. Summaries of the Nebraska and Iowa evacuation time estimate studies are outlined in KLD Engineering, P.C., Fort Calhoun Nuclear Station, Development of Evacuation Time Estimates (EP-FC-1001 Addendum 2). Reference Figure 6-1, Tables 7-1 through 7-6, and Table 3-7.
2.3.2    Evacuation of Areas within the EPZ A. The Governor (or Governor's Authorized Representative) of Nebraska can authorize the Nebraska State Patrol and Emergency Management Agency, based on recommendations of the State Health Department, to evacuate Nebraska residents to the reception center in Fremont, Nebraska.
B. The Governor (or Governor's Authorized Representative) of Iowa can authorize the Iowa State Patrol and the Emergency Management Division to evacuate Iowa residents to Denison, Iowa, based upon recommendations of the Iowa Department of Public Health.
C. Evacuees from the Nebraska portion of the EPZ should go to the Fremont Reception Center. Evacuees from the Iowa portion of the EPZ should proceed to the Denison Reception Center. Figure J-5 shows the boundaries and highways leading to the Reception Centers.
D. The relocation centers for the host areas are as follows:
Fremont Fremont Middle School 540 Johnson Rd Denison Denison Community High School, North 16th E. The ingestion planning zone (IPZ) encompasses a 50 mile radius as illustrated in Figure J-6. Population for the IPZ is presented in Figure J-7 by sectors.

FCS EP-FC-1001 Section J Revision TBD Page 90 of 156 PROTECTIVE RESPONSE F. The plume exposure EPZ encompasses an approximate 10 mile radius as illustrated in Appendix H, (EP-FC-1001 Addendum 2). The EPZ includes portions of Harrison and Pottawattamie Counties in Iowa, Washington and Douglas Counties in Nebraska. The States of Iowa and Nebraska are separated by the Missouri River. Table 3-5 through 3-8, (EP-FC-1001 Addendum 2),shows the total population within the EPZ, and population totals for each Sub Area. This includes showing Estimated Transient population.
2.4 Protective Methods (Other than Evacuation) 2.4.1     Sheltering A. Remaining indoors during the passage of a radioactive cloud affords the dweller a reduction in the quantity of radionuclides inhaled, as well as providing shielding. Figure J-9 shows the ratio of the inhaled dose inside a shelter to that outside the shelter as a function of the ventilation rate. A ventilation rate survey showed a rate variance of 0.07 to 3.0 per hour.
The ventilation rate is affected by temperature differential, wind speed and direction, quality of construction and topographical setting.
B. Walls of buildings absorb and scatter gamma rays, thus providing a lower dose to the occupants. The shielding factor of a building is the ratio of the interior dose to the exterior dose. Shielding factor estimates applicable to residential housing units were made using the shielding technology by Z. G. Burson and A. E. Profio (1975). Table J-7&#xb2; summarizes shielding factors for designated structures/locations from a gamma cloud source.
1,2,3 C.       Table J-83 summarizes the shielding factors for designated structures/locations from surface deposition of radioactive material.
Burson and Profio proved that the fallout shielding technology developed via nuclear weapons tests could be directly applied to radioactivity deposited on surfaces after a reactor accident. The shielding factors listed in Table J-8 assume uniform distribution of the radioactive fallout.
D. In each of the cases discussed, inhalation and shielding factors from a gamma cloud source and shielding factors from surface deposition of radioactive material, it is noted that the shielding factors using sheltering as a method of protection ranges from 0.6 to 0.005. Although the best protection seems to be the basement of large multi-structured buildings, the basement of any house has been proven to provide significant shelter from airborne and surface deposited radioactive material.
1       Taken from WASH-1400(NUREG-75/014), October 1975, Figure VI.11-4.
2       Taken from WASH-1400(NUREG-75/014), October 1975, Figure VI-11-7.
3       Taken from WASH-1400(NUREG-75/014), October 1975, Figure VI-11-8.

FCS EP-FC-1001 Section J Revision TBD Page 91 of 156 PROTECTIVE RESPONSE 2.5 Radiological Environmental Monitoring 2.5.1    In the event of an emergency, the permanent air particulate stations are first utilized for immediate data, concerning airborne releases. Background radiation stations (TLDs) provide short term exposure data and are periodically replaced. See the specific Radiological Environmental Monitoring Surveillance Test for more information. TLD use can be increased during the longer term as the District maintains a TLD services contract with an off-site vendor. The environmental laboratory personnel perform accelerated collection and analysis of samples as their primary responsibility after an emergency occurs. Sampling requirements will be determined by the environmental laboratory personnel.
2.5.2    Sample analysis will be performed by the station and at offsite facilities as deemed necessary.

==3.0 REFERENCES==
AND COMMITMENTS 3.1 EP-FC-1001 Addendum 2, Evacuation Time Estimates KLD TR-535 3.2 EP-FC-1001, Evacuation Time Estimates Table 1, 50 Mile 2010 Population Table Table 3-5 Table 3-7, Summary of Population Demand Table 3-8 Table 7-1 through Table 7-6, Time to clear the Indicated Area of 90% of the Affected Population Figure 1, 50 Mile 2010 Population Rose Figure 5-2, Evacuation Mobilization Activities Figure 6-1, FCNS EPZ Sub Areas Appendix K

FCS EP-FC-1001 Section J Revision TBD Page 92 of 156 PROTECTIVE RESPONSE Table J Summary of Considerations for Selecting the Evacuation PAG's1 DOSE Rem                                     Consideration(s)
(mrem) 50 Rem           Assumed threshold for acute health effects in adults.
(50000 mrem) 10 Rem           Assumed threshold for acute health effects in the fetus.
(10000 mrem) 5 Rem          Maximum acceptable dose for normal occupational exposure for (5000 mrem)         adults.
5 Rem          Maximum dose justified to average members of the population, (5000 mrem)         based on the cost of evacuation.
0.5 Rem          Maximum acceptable dose to the general population from all (500 mrem)         sources from nonrecurring, non-accidental exposure.
0.5 Rem          Minimum dose justified to average members of the population, (500 mrem)         based on the cost of evacuation.
0.5 Rem          Maximum acceptable dose2 to the fetus from occupational (500 mrem)         exposure of the mother.
0.1 Rem          Maximum acceptable dose to the general population from all (100 mrem)         sources from routine (chronic) non-accidental exposure.
0.03 Rem          Dose that carries a risk assumed to be equal to or less than that (30 mrem)         from evacuation.
1 Taken, in part, from Table C-8, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, EPA-400-R-92-001, May, 1992 2
This is also the dose to the 8 to 15 week-old fetus at which the risk of mental retardation is assumed to be equal to the risk of fatal cancer to adults from a dose of 5 rem.

FCS EP-FC-1001 Section J Revision TBD Page 93 of 156 PROTECTIVE RESPONSE Table J Protective Action Recommendations Based on Dose Assessment/Field Team Radiological Data Instructions: Compare URI or Field Team Dose Assessment results to the following table.
Expand PAR to include downwind sectors in accordance with EP-FC-111-AD-F-02.
Projected Dose                    Protective Action Recommendation (PAR)
  < 1 rem TEDE                                           NONE (No Par Required)
  < 5 rem CDE (thyroid)                        And continue monitoring radiological conditions 1 rem TEDE                                             Evacuate *see note 5 rem CDE                                  And continue monitoring radiological conditions 50 rem SDE (skin)                                           Evacuate And continue monitoring radiological conditions NOTE: SHELTERING may be considered for doses up to 5 rem TEDE in special situations such as (1) the presence of severe weather (2) competing disasters (3) institutionalized people who are not readily mobile; and (4) other local factors, which may impede evacuation.

FCS EP-FC-1001 Section J Revision TBD Page 94 of 156 PROTECTIVE RESPONSE Table J Summary of Considerations for Selecting PAG's for Relocation1 DOSE Rem Consideration(s)
(mrem) 50 Rem          Assumed threshold for acute health effects in adults.
(50000 mrem) 10 Rem          Assumed threshold for acute health effects in the fetus.
(10000 mrem) 6 Rem         Maximum projected dose in first year to meet 0.5 Rem in the second (6000 mrem)        year2.
5 Rem         Maximum acceptable dose for normal occupational exposure for adults.
(5000 mrem) 5 Rem         Minimum dose that must be avoided by one year relocation based on (5000 mrem)        cost.
3 Rem         Minimum projected first-year dose corresponding to 5 Rem in 50 years2.
(3000 mrem) 3 Rem         Minimum projected first-year dose corresponding to 0.5 Rem in the (3000 mrem)        second year2.
2 Rem         Maximum dose in first year corresponding to 5 Rem in 50 years from a (2000 mrem)        reactor incident, based on radioactive decay and weathering only.
1.25 Rem         Minimum dose in first year corresponding to 5 Rem in 50 years from a (1250 mrem)        reactor incident, based on radioactive decay and weathering only.
0.5 Rem         Maximum acceptable single-year dose to the general population from all (500 mrem)        sources from non-recurring, non-incident exposure.
0.5 Rem         Maximum acceptable dose to the fetus from occupational exposure of (500 mrem)        the mother.
0.1 Rem         Maximum acceptable annual dose to the general population from all (100 mrem)        sources due to routine (chronic), non-incident, exposure.
0.03 Rem         Dose that carries a risk assumed to be equal to or less than that from (30 mrem)        relocation.
1 Taken, in part, from Table E-5, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents", EPA-400-R-92-001, May, 1992.
2 Assumes the source term is from a reactor incident and that simple dose reduction methods are applied during the first month after the incident to reduce the dose to persons not relocated from contaminated areas.

FCS EP-FC-1001 Section J Revision TBD Page 95 of 156 PROTECTIVE RESPONSE Table J Protective Action Guides for Exposure to Deposited Radioactivity1 PAG Protective Action             (projected dose                       Comments in first year)2 Relocate the general                2 Rem         Beta dose to skin may be up to 50 times population3                    ( 2000 mrem)       higher.
Apply simple dose                  < 2 Rem         These protective actions should be taken reduction techniques4          (< 2000 mrem)       to reduce doses to as low as practicable levels.
1 Taken, in part, from the "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents", EPA-400-R-92-001, May, 1992.
2 The projected sum of total effective dose equivalent (TEDE) from external gamma radiation and committed effective dose equivalent (CEDE) from inhalation of resuspended materials, from exposure or intake during the first year. Projected dose refers to the dose that would be received in the absence of shielding from structures or the application of dose reduction techniques. These PAG's may not provide adequate protection from some long-lived radionuclides.
3 Persons previously evacuated from areas outside the relocation zone defined by this PAG may return to occupy their residences. Cases involving relocation of persons at high risk from such action (e.g., patients under intensive care) should be evaluated individually.
4 Simple dose reduction techniques include scrubbing and/or flushing hard surfaces, soaking or plowing soil, minor removal of soil from spots where radioactive materials have concentrated, and spending more time than usual indoors or in other low exposure rate areas.

FCS EP-FC-1001 Section J Revision TBD Page 96 of 156 PROTECTIVE RESPONSE Table J Emergency Worker Exposure Limits Dose Limit              Activity                       Condition(s) 500 mrem All Activities               Declared Pregnant Emergency Workers TEDE 5 Rem TEDE All Activities               Non-Pregnant Emergency Workers 10 Rem TEDE Protecting Valuable Property A lower dose is not practicable 25 Rem TEDE Life Saving or Protection of A lower dose is not practicable Large Populations
 >25 Rem TEDE  Life Saving or Protection of Only on a voluntary basis to persons fully Large Populations            aware of the risks involved. (See Table J-6)

FCS EP-FC-1001 Section J Revision TBD Page 97 of 156 PROTECTIVE RESPONSE Table J Summary of Risks Involved with Higher Dose Limits (taken form EPA 400 R-92-001, May, 1992)
Health Effects Associated with Whole-Body Absorbed Dosed Received Within a Few Hoursa Prodromal Whole Body                   Early               Whole Body Effectsc Absorbed Dose              Fatalitiesb           Absorbed Dose (percent (rad)                  (percent)                 (rad) affected) 140                        5                      50                    2 200                       15                     100                   15 300                       50                     150                   50 400                       85                     200                   85 460                       95                     250                   98 (a)
Risks will be lower for protracted exposure periods.
(b)
Supportive medical treatment may increase the dose at which these frequencies occur by approximately 50 percent.
(c)
Forewarning symptoms of more serious health effects associated with large doses of radiation.
Approximate Cancer Risk to Average Individuals from 25 Rem Effective Dose Equivalent Delivered Promptly Approximate Risk of Premature      Average Years of Life Age at Exposure                          Death                  Lost in Premature (years)                  (deaths per 1,000 persons               Death exposed)                   Occurs (years) 20 to 30                             9.1                            24 30 to 40                             7.2                            19 40 to 50                             5.3                            15 50 to 60                             3.5                            11

FCS EP-FC-1001 Section J Revision TBD Page 98 of 156 PROTECTIVE RESPONSE Table J Representative Shielding Factors from Gamma Cloud Source Structure or Location                Shielding Factor(a)       Representative Range Outside                                              1.0                        ----
Vehicles                                             1.0                        ----
(b)
Wood - frame (no basement)                           0.9                        ----
Basement of wood house                               0.6                    0.1 to 0.7(c)
Masonry house (no basement)                          0.6                   0.4 to 0.7(c)
Basement of masonry house                            0.4                   0.1 to 0.5(c)
Large office or industrial building                  0.2                   0.1 to 0.3(c,d)
(a)
The ratio of the interior dose to the exterior dose.
(b)
A wood frame house with brick or stone veneer is approximately equivalent to a masonry house for shielding purposes.
(c)
This range is mainly due to different wall materials and different geometries.
(d)
The reduction factor depends on where the personnel are located within the building (e.g., the basement or an inside room).
NOTE: Consideration is limited to gamma radiation since beta and alpha particles cannot penetrate the walls of structures.
* Taken from WASH-1400 (NUREG-75/104), October 1975.

FCS EP-FC-1001 Section J Revision TBD Page 99 of 156 PROTECTIVE RESPONSE Table J Representative Shielding Factors for Surface Deposition Structure or Location                 Representative (a)    Representative Range Shielding Factor 1 m above an infinite smooth surface                   1.00                     ----
1 m above ordinary ground                              0.70                0.47 - 0.85 1 m above center of 50-ft roadways,                    0.55                  0.4 - 0.6 half contaminated Cars on 50-ft road:
Road fully contaminated                            0.5                  0.4 - 0.7 Road 50% decontaminated                            0.5                  0.4 - 0.6 Road fully decontaminated                         0.25                  0.2 - 0.5 Trains                                                 0.40                  0.3 - 0.5 One and two-story wood-frame house (no basement)                                    0.4(b)                0.2 - 0.5 One and two-story block and brick house (no basement)                                    0.2(b)              0.04 - 0.40 House basement, one or two walls fully exposed:                                         0.1(b)              0.03 - 0.15 One story, less than 2 ft of basement, walls exposed                                0.3(b)              0.03 - 0.07 Two stories, less than 2 ft of basement, walls exposed                                0.3(b)              0.02 - 0.05 Three or four-story structures,
 >5,000 ft2 per floor:
First and second floor                                0.05(b)              0.01 - 0.08 Basement                                              0.01(b)              0.001 - 0.07 Multistory structures, >10,000 ft2 per floor:
Upper floors                                          0.01(b)              0.001 - 0.02 Basement                                              0.005(b)            0.001 - 0.015 (a)
The ratio of the interior dose to the exterior dose.
(b)
Away from doors and windows.

FCS EP-FC-1001 Section J Revision TBD Page 100 of 156 PROTECTIVE RESPONSE Figure J Routes to Relocation Centers

FCS EP-FC-1001 Section J Revision TBD Page 101 of 156 PROTECTIVE RESPONSE Figure J Ingestion Pathway EPZ

FCS EP-FC-1001 Section J Revision TBD Page 102 of 156 PROTECTIVE RESPONSE Figure J Ratio of Inhaled Dose Inside a Shelter to that Outside the Shelter as a Function of Ventilation Rates

FCS                                                                   EP-FC-1001 Section K Revision TBD Page 103 of 156 RADIOLOGICAL EXPOSURE CONTROL 1.0  EXPOSURE GUIDELINES 1.1  It is OPPD policy to comply with the ALARA concept, and all efforts shall be made to keep all workers within normal Fort Calhoun Station limits, as listed in the Radiation Protection Manual. However, if it is expected that workers may exceed these limits, any dose received during emergency conditions in excess of 5 Rem TEDE will be assigned as once in a lifetime exposure.
1.2  The facility directors, Shift Manager in the Control Room, Site Director in the TSC, the OSC Director in the OSC or the Emergency Director in the EOF may authorize dose extension up to 5 Rem TEDE per year during declared events for workers in their facility.
1.3  The Command and Control position shall authorize any extensions beyond normal occupational exposure limits and direct that any dose received in excess of these limits be assigned as once in a lifetime exposure. The following guidance is from the FCS Radiation Protection Manual, and the Manual of Protective Action Guidelines and Protective Action for Nuclear Incidents, EPA-400-R-92-001.
5 Rem TEDE for all emergency workers 10 Rem TEDE when action is necessary to reduce a hazard potential to acceptable levels or to prevent substantial loss of property 25 Rem TEDE when action is necessary to perform lifesaving functions or to reduce the potential hazards to the health and safety of the public
         >25 Rem TEDE on a voluntary basis and only to save a life or reduce potential hazards to the health and safety of the public 1.4  Plant personnel that require access to Radiation Controlled Areas are issued TLDs on a frequency specified by Radiation Protection. Many ERO positions are also issued TLDs depending on the likelihood of having to enter a Radiation Controlled Area under emergency conditions. TLD requirements for ERO positions are identified on the ERO Roster.
1.5  Personnel responding to the site that require, but do not have, dosimetry will be issued dosimetry by Security or Radiation Protection personnel. The following ERO positions can also issue dosimetry when necessary:
Control Room: The Shift RP Technician or OSC RP Technicians TSC: OSC RP Technicians OSC: The OSC RP Technicians

FCS                                                                   EP-FC-1001 Section K Revision TBD Page 104 of 156 RADIOLOGICAL EXPOSURE CONTROL 2.0  CONTAMINATION CONTROL 2.1  If actual or potential contamination problems exist onsite, ERO management may elect to establish contamination control and monitoring measures. These may consist of some or all of the following:
Each Emergency Response Facility onsite has the capability to establish control boundaries to minimize contamination spreading into the facility.
Monitoring of personnel evacuating the affected area using installed monitors in the Security Building or personnel with portable equipment. Portable equipment for this purpose is stored both in the warehouse and at the EOF.
2.2  If personnel decontamination becomes necessary, the site maintains two facilities for this purpose. One is located in the Auxiliary Building entry/exit point, and is frequently used. It drains to the Radwaste System. The second facility is located in the Warehouse and is designated for emergency use only. It drains to a holding tank, which is controlled after emergency use to ensure that the contents are monitored and processed if necessary.
2.3  Contaminated personnel that are evacuated will be decontaminated as determined by Radiation Protection personnel. Additional decontamination facilities are available at state decontamination facilities and at the UNMC Regional Radiation Health Center.
2.4  Tools and equipment that become contaminated will be decontaminated as determined by Radiation Protection personnel.
2.5  Areas that become contaminated will be decontaminated as determined by Radiation Protection personnel.
2.6  Priorities for decontaminating tools, equipment and areas will be established by ERO management, with top priority given to contamination within areas that are or will be inhabited by emergency workers. Decontamination of non-essential areas, tool and equipment should be delayed to allow for natural decay of radioactive materials.
2.7  Potable water, normally supplied from the City of Blair, and onsite food supplies can be chemically and radiologically monitored prior to use by emergency workers.
2.8  Contamination limits, contamination control, and decontamination criteria may be adjusted based on professional radiological evaluation by the ERO using guidance in the Radiation Protection Manual.
2.9  Radioactive waste from any decontamination effort will be prepared and shipped in accordance with Radiation Protection Manual requirements.

FCS EP-FC-1001 Section L Revision TBD Page 105 of 156 MEDICAL AND PUBLIC HEALTH SUPPORT 1.0  ONSITE FIRST AID 1.1  There are generally four types of response considered at the Fort Calhoun Station:
: 1)      Minor injury, no contamination
: 2)      Minor injury, contaminated
: 3)      Major injury (requiring offsite treatment), no contamination
: 4)      Major injury, contaminated 1.2  The order of medical treatment will be:
: 1)      Care of severe physical injuries
: 2)      Decontamination of personnel
: 3)      First aid to other injuries
: 4)      Monitor for internal contamination
: 5)      Definitive treatment and subsequent therapy as required 1.3  All injuries at the station must be immediately reported to the Shift Manager, who will initiate response according to the Fort Calhoun Station Safety Manual, FCSG-15-7, Medical Emergencies. When the OSC is activated the OSC Director will be responsible for response to medical emergencies.
1.4  When personnel are severely injured and contaminated, first aid shall take precedence over decontamination. In cases where internal exposure is suspected, a bioassay program may be performed as directed by the Radiation Protection Manual.
1.5  First Aid Facilities 1.5.1       A First Aid Room is located in the Maintenance Building. This room is equipped with various medical supplies to provide emergency first aid to injured personnel.
1.5.2       Other equipment located throughout the plant include first aid kits, Emergency Medical Technician (EMT) kits, personnel carriers, a wheelchair, and contaminated/injured personnel response kit. The Industrial Safety Coordinator inspects and maintains this equipment.

FCS EP-FC-1001 Section L Revision TBD Page 106 of 156 MEDICAL AND PUBLIC HEALTH SUPPORT 1.6  Medical Response 1.6.1    Minor Injury, No Contamination A. The Shift Manager or other evaluators will determine the extent of medical response required. This could include:
: 1. On the spot treatment by the individual or first aid qualified responders.
: 2. On the spot treatment by EMT qualified personnel (if available).
: 3. Movement of the injured party to the first aid room by medical responders for access to additional equipment.
: 4. Other response determined necessary by responding personnel.
1.6.2    Minor Injury, Contaminated A. Personnel that are injured and are potentially contaminated will be treated as explained above, and will also be monitored for contamination by Radiation Protection personnel. Monitoring and decontamination will be performed in accordance with Radiation Protection procedures.
1.6.3    Major Injury, No Contamination A. Medical responders will be dispatched to the scene to perform first aid as required. The Shift Manager or designee will notify offsite authorities to provide victim transport to an available medical facility. Both air and ground transportation are available.
1.6.4    Major Injury, Contaminated A. Personnel that are severely injured and are potentially contaminated will be treated as explained above, and will also be monitored for contamination by Radiation Protection personnel. If feasible, monitoring and decontamination will be performed in accordance with Radiation Protection Procedures. If decontamination is successful, the victim may be transported to any available medical facility for treatment.
B. If decontamination is not successful or not feasible, the victim will be transported to the UNMC Regional Radiation Health Center, unless the responding Emergency Medical Services (EMS) personnel deem it medically necessary to proceed to a closer facility. If another facility other than UNMC is used, additional Radiation Protection personnel should be sent to the facility to assist in monitoring, decontamination and clean up.

FCS EP-FC-1001 Section L Revision TBD Page 107 of 156 MEDICAL AND PUBLIC HEALTH SUPPORT 2.0  MEDICAL TRANSPORTATION 2.1  Blair Fire Department and Rescue Squad The Blair Fire Department and Rescue Squad Station is located less than four miles from the Fort Calhoun Station. The Rescue squad furnishes transportation for the injured and administers first aid enroute to the hospital.
2.2  Fort Calhoun Fire and Rescue Squad The Fort Calhoun Fire and Rescue Squad headquarters is located approximately 3-1/2 miles from the Fort Calhoun Station. This rescue squad serves as backup to the Blair Fire Department and Rescue Squad.
2.3  Missouri Valley Fire and Rescue Squad The Missouri Valley Fire and Rescue Squad is located approximately fifteen miles from the plant.
2.4  Additional support is available to both the Blair Fire Department and Rescue Squad and the Fort Calhoun Fire and Rescue Squad by request through the Tri-Mutual Aid Association (Douglas, Sarpy, and Washington Counties).
2.5  Other Modes of Transportation If necessary, there are other modes of transportation for delivering injured personnel to appropriate medical facilities.
2.5.1      Medical Ambulance helicopter 2.5.2      Onsite company vehicles 2.5.3      Private autos of company personnel 3.0  OFFSITE MEDICAL SUPPORT 3.1  Non-Contaminated Personnel The nearest medical facility is the Blair Memorial Community Hospital which is located five miles from the plant. A physician is readily available as a general medical consultant. Other facilities may be used as determined necessary by medical response personnel.

FCS EP-FC-1001 Section L Revision TBD Page 108 of 156 MEDICAL AND PUBLIC HEALTH SUPPORT 3.2  Contaminated Personnel 3.2.1   Omaha Public Power District maintains an agreement with the UNMC Regional Radiation Health Center to supply 24-hour treatment for all injuries involving contamination and/or personnel radiation exposure. The Regional Radiation Health Center is located approximately 25 miles from the plant in Omaha, Nebraska. The facility is part of the UNMC complex, and was established specifically for the treatment of injuries occurring from nuclear and radiation related incidents. An entrance (Figure L1) is available for the ingress and egress of contaminated victims to a special assessment and decontamination facility. Patients can also be transported to the facility via medical ambulance helicopters.
3.2.2   The UNMC Regional Radiation Health Center staff administers medical, decontamination, internal bioassay, and other nuclear medicine capabilities.
The staff maintains an appropriate "Standard Operating Procedures Manual" which describes their responsibilities and roles. If additional hospital beds should be required during a major incident, the hospital maintains a mutual agreement with several other Omaha area hospitals to assist with decontaminated patients.
3.2.3   Due to the large, highly qualified staff, the distance from the plant, the specialized capabilities, and the overall size of the UNMC complex, the Fort Calhoun Station was granted an exemption from requiring a backup medical facility by the Federal Emergency Management Agency.

FCS EP-FC-1001 Section L Revision TBD Page 109 of 156 MEDICAL AND PUBLIC HEALTH SUPPORT Figure L Entrance to Treatment Area UNMC Regional Radiation Health Center

FCS EP-FC-1001 Section M Revision TBD Page 110 of 156 MEDICAL AND PUBLIC HEALTH SUPPORT 1.0  RECOVERY ORGANIZATION (RO) 1.1  Responsibilities The Recovery Organization (RO) responsibilities include the overall coordination and management of the recovery effort and has provisions for technical and administrative services, design work, scheduling, planning, quality control/assurance, construction and vendor support.
1.2  Staffing The Recovery Organization would be composed of all the necessary technical, administrative, managerial, and support personnel required for the recovery phase of emergency response. This organization would be capable of 24 hour a day sustained operation.
The lead position in the Recovery Organization would be the Recovery Operations Manager. This individual would be appointed by the Command and Control Position of the Emergency Response Organization. The staffing positions of the rest of the Recovery Organization would be dependent upon the needs based on accident type and magnitude.
The responsibilities of the Recovery Operations Manager and the functions of possible staff members are detailed in the Emergency Plan Implementing Procedures.
1.3  Activation The activation of the Recovery Organization is through the directions given in the Emergency Plan Implementing Procedures governing the downgrading and termination of the emergency response phase. Downgrading and termination is achieved through a checklist format of considering not only the current and past conditions but also those conditions which have the potential to occur.
The ultimate decision for activation of the Recovery Organization rests with the Emergency Command and Control Position.

FCS EP-FC-1001 Section M Revision TBD Page 111 of 156 MEDICAL AND PUBLIC HEALTH SUPPORT 1.4  Transition The transition from Emergency Response Organization to Recovery Organization would consist of turning over functions that would continue while terminating other functions that would not be necessary. The extent of the turnover would be based upon the size of the Recovery Operations which would be dependent upon the type and magnitude of the emergency.
As a minimum, the facility directors at each of the Emergency Response Facilities will make an announcement concerning the shift to the Recovery Organization and direct all Emergency Response Organization Members to turn in all pertinent logs and forms to the administrative manager in each facility. A critique would follow at each facility while recovery operations were commencing.
2.0  REENTRY 2.1  Purpose The purpose for a reentry plan is to provide a means to regain access to an onsite or offsite area that was previously made inaccessible due to an emergency.
2.2  Responsibility The Command and Control Position has the responsibility for authorizing reentry into a previously evacuated area. This could be the Shift Manager, Site Director, or Emergency Director depending on the stage that emergency response has reached.
2.3  Implementation The implementation of the reentry plan is carried out by the Emergency Response Organization. Reentry is normally expected to be accomplished by teams dispatched from the Operations Support Center.
2.4  Emergency Radiation Exposure OPPD is committed to keeping exposure "as low as reasonably achievable" (ALARA).
It is understood that there are emergency situations which transcend the normal requirements for limiting exposure. When such situations exist, the Command and Control Position will make the determination as to the amount of radiation exposure that will be permitted based on the guidelines set forth in Section K of this Plan.

FCS EP-FC-1001 Section N Revision TBD Page 112 of 156 EXERCISES AND DRILLS 1.0 EXERCISES An emergency preparedness exercise is an event that tests the integrated capability and a major portion of the basic elements existing within the Radiological Emergency Response Plan (RERP), associated Emergency Plan Implementing Procedures (EPIPs) and the various organizations associated with the implementation of the RERP. Typically, an emergency preparedness exercise shall simulate an emergency that results in offsite radiological releases which would require response by offsite authorities. However, whenever the State of Nebraska and the State of Iowa are not participating in a particular exercise, the scenario should concentrate on realistic in-plant emergencies with less emphasis on offsite response.
Periodic emergency preparedness exercises can be conducted to evaluate major portions of emergency response capabilities. Also, exercises provide the opportunity to identify further improvements to the emergency preparedness program. Areas of improvement, weaknesses and deficiencies noted as a result of an exercise will be evaluated and corrected, as appropriate.
Normally, an exercise is not considered a "training function", as the participants are not guided, nor "coached", during an exercise. Interaction between controller/observers and participants is not allowed during an exercise, except for delivery and explanation of scenario information and data.
Exercises are conducted biennially, as a minimum. The states of Iowa and Nebraska, along with associated local governmental agencies, are invited to participate in all training drills and exercises, and are required to participate in the biennial exercise under evaluation by the Federal Emergency Management Agency. The Nuclear Regulatory Commission also performs routine inspections to evaluate licensee emergency response performance. The Resident Inspector(s) or other NRC personnel may observe licensee performance during training drills or non-evaluated exercises.
Drill and Exercise procedures are used to verify the following criteria:
1.1 State and local personnel and resources capability to respond to a radiological emergency response scenario.
1.2 Scenario variance from year to year in order to provide optimum training for radiological emergency response personnel.
1.3 Variance of hours in which the radiological emergency exercise is performed.
1.4 Joint radiological emergency exercise involving plant and Federal, State and local support groups, including any that involve a time variance.

FCS EP-FC-1001 Section N Revision TBD Page 113 of 156 EXERCISES AND DRILLS 2.0 DRILLS A drill is a supervised instruction period aimed at testing, developing and maintaining skills in a particular ERO position, function, center, or operation. A drill can be used as a specific training component of an exercise, if the exercise objectives identify and authorize such component. Drills will be supervised and evaluated by appropriate emergency planning personnel or other personnel with specific expertise pertaining to the drill or function being observed.
Periodic emergency preparedness drills are conducted to develop and maintain key skills within the ERO. Also, drills provide the opportunity to identify further improvements to the emergency preparedness program. Areas for improvement, weaknesses and deficiencies noted as a result of a drill will be evaluated and corrected, as appropriate.
At least one drill between biennial exercises will involve a combination of some of the principal functional areas of the onsite Emergency Response Organization, such as; command and control, accident assessment and classification, protective action recommendation decision making, and plant system and component repair and corrective actions. Simultaneous activation of all of the licensee's emergency response facilities during training drills is not necessary. Special functional drills can be developed and used to; focus on accident management strategies; supervised instruction periods for special or newly developed activities and/or procedures; allow resolution of problems (success paths) by ERO members, and; focus on identified onsite training objectives.
Normally, a drill is considered a "training function", as the participants are guided or "coached" during the actual drill. Interaction between controller/observers and participants is encouraged during a drill, except for instances where specific knowledge and memory are being tested.

FCS EP-FC-1001 Section N Revision TBD Page 114 of 156 EXERCISES AND DRILLS 2.1 Communication Drills Emergency Planning procedures provide for communication checks with appropriate agencies to ensure availability and operability of all channels of communication necessary for adequate response to a radiological emergency requiring off-site support. These tests outline those agencies to be contacted, the person (by name or title) who is responsible for verifying that adequate communication exists, the required frequency for which communication is to be checked, and a procedure for accomplishing the test. Below is the communication schedule for these checks or drills to be performed:
2.1.1       Communications are checked monthly from the EOF at the North Omaha Power Station with the States of Nebraska and Iowa and the local governments of the Counties of Harrison, Pottawattamie, and Washington and the NRC using dedicated communications equipment and backup systems. A functional check of the ERFCS is also performed on a monthly basis.
2.1.2       Communications are checked monthly from the Fort Calhoun Station Technical Support Center with the State of Nebraska and Iowa EOCs.
2.1.3       Communications are checked quarterly with Federal response agencies and the States of Nebraska and Iowa within the ingestion exposure pathway EPZ.
Also verified are communications with the JIC and functional checks of the FAX Network, radio system, and the ERF paging systems. Quarterly communications checks are performed from the Control Room with the NRC using both the FTS-ENS phone line and the Emergency Response Data System.
2.1.4       Communications are checked annually between the Fort Calhoun Station, the States of Nebraska and Iowa and local Emergency Operations Centers and field teams.
2.2 Fire Drills Fire drills are conducted by plant personnel on a quarterly basis. The drills are held to test the plant's firefighting capability. The drills are varied in order to test all phases of firefighting techniques.
The Blair Fire Department is annually invited to conduct a drill onsite. Onsite drills assist in familiarizing the fire department members with the types and locations of equipment available to mitigate plant fires.

FCS EP-FC-1001 Section N Revision TBD Page 115 of 156 EXERCISES AND DRILLS 2.3 Medical Emergency Drills The Nebraska Health Center, University Hospital Radiation Health Center is invited to participate in an annual exercise and/or scheduled drill(s) to demonstrate and practice the receipt and treatment of contaminated patients. The extent of the Center's participation depends on their work load and schedule for hospital patients at the time the exercise or drill is declared.
2.4 Health Physics and Radiological Monitoring Drills Emergency Planning procedures develop guides for the preparation, execution, and documentation of health physics and radiological monitoring drills. Execution of these procedures is shared by Emergency Planning and Radiation Protection.
There are two (2) types of drills performed by Chemistry and Radiation Protection Departments:
2.4.1      Semi-annually, a health physics drill is conducted to monitor the response to and analysis of simulated elevated airborne releases, and direct radiation measurements in the environment. Normally, this drill is conducted in conjunction with a quarterly training drill.
2.4.2      Annually a drill is held which involves the collection of a type of environmental sampling media by the Chemistry Departments Environmental Group.
The NRC waived the requirement for a Reactor Coolant liquid sample drill in the SER related to Technical Specification (T.S.) Amendment 200. Amendment 200 deleted the Post Accident Sampling System (PASS).
2.5 Augmentation Call Out Drill Notification and/or Augmentation Drills will be conducted at least every 12 months.
The drills shall evaluate the licensee's capability to notify the minimum staffing positions in the Technical Support Center, Operations Support Center and the Emergency Operations Facility, in addition to meeting the staffing requirements of Table B-1 in RERP, Section B.

FCS EP-FC-1001 Section N Revision TBD Page 116 of 156 EXERCISES AND DRILLS 3.0 SCENARIOS Scenarios for a drill are developed by either Emergency Planning or the group responsible for conducting the specific drill. Each drill should include a basic objective and appropriate evaluation criteria.
A special group is assigned the scenario development for the biennial exercise. An Emergency Planning procedure develops the plan for the preparation, execution, and documentation of the biennial exercise. This procedure requires input from major Federal, State, and local agencies, as well as OPPD staff, in order to define the objectives to be accomplished in the exercise. The scenario is then prepared to describe the following features:
Objectives of the exercise.
Date, time period, location, and participants.
Simulated events.
Time schedule of real and simulated events.
Summary describing conduct of exercise.
Preparation of the scenario may include such items as identifying Control Room alarms, sequence of alarms, and instrument readings required to initiate the planned emergency exercises essential components.
A strong attempt is made to allow only key officials of Federal, State, and local support agencies to share scenario information in advance of exercises, in order that their participation in the exercise can be developed properly to demonstrate their maximum capabilities without losing confidentiality of exercise information.
4.0 CRITIQUES In addition to the OPPD observers, offsite support agencies may provide observers for the biennial exercise. Observers are given information of the accident scenario prior to the exercise so that they may evaluate participants effectively.
Observers, evaluators, controllers and participants submit their comments and recommendations during a critique that is held after all drills and exercises. An Emergency Planning procedure is used to document and classify all significant comments and issues. Significant observations are incorporated into the plants Corrective Action Program for resolution.

FCS EP-FC-1001 Section N Revision TBD Page 117 of 156 EXERCISES AND DRILLS 5.0 ACTUAL EMERGENCIES In the event of an actual emergency, credit for the response may be substituted for a drill or exercise if the event is properly documented according to the guidelines set forth in 10 CFR 50.47 and NUREG-0654, Rev.1/FEMA-REP-1.

FCS EP-FC-1001 Section O Revision TBD Page 118 of 156 RADIOLOGICAL EMERGENCY RESPONSE TRAINING 1.0  FIRST AID TRAINING Personnel assigned the responsibility for responding to a medical emergency at the Fort Calhoun Station receive the American Red Cross Standard First Aid Training Program, or equivalent. Normally, these are members of the Fort Calhoun Station Fire Brigade which consists of Operations personnel assigned to shift crews. To maintain qualifications in accordance with the American Red Cross, CPR is conducted annually and First Aid Training is given biannually. The training is conducted by the American Red Cross and the associated training records are maintained in accordance with Training Department procedures.
2.0  FIRE BRIGADE TRAINING Fire Brigade training is outlined in the TQ-AA-173, Emergency Services Training Programs.
3.0  GENERAL EMPLOYEE TRAINING An overview of the Emergency Plan is given to all personnel allowed unescorted access into the protected area at Fort Calhoun Station. Personnel receive this information during initial training and are requalified on an annual basis. This training includes identification of the emergency alarm, the fire alarm and the steps to follow for a plant and site evacuation.
4.0  EMERGENCY PREPAREDNESS TRAINING PROGRAM TQ-FC-113, ERO Training and Qualification identifies the initial and continuing training requirements for emergency response personnel.
As appropriate, members of the onsite emergency response organization are qualified to wear respiratory equipment, including self-contained breathing apparatus (SCBA) through the General Employee Training, Level III, Respiratory Protection Training Program.
5.0  EMERGENCY RESPONSE ORGANIZATION TRAINING Requirements for initial training and continuing training of personnel assigned to the Emergency Response Organization is accomplished in accordance with TQ-FC-113, ERO Training and Qualification.
Requirements for initial training and continuing training of security personnel are outlined in the Security Training and Qualification Plan.
FCS Management is responsible to ensure all members of the Emergency Response Organization receive the required initial training and continuing training.

FCS EP-FC-1001 Section O Revision TBD Page 119 of 156 RADIOLOGICAL EMERGENCY RESPONSE TRAINING 6.0  LOCAL SUPPORT SERVICES PERSONNEL TRAINING 6.1  Fire and Rescue Squads The Blair Fire Department and Rescue Squad and the Fort Calhoun Fire/Rescue are offered annual training by the Nebraska Emergency Management Agency. The Missouri Valley Fire and Rescue Squad and the Council Bluffs Fire and Ambulance Squad are offered annual training from the Iowa Homeland Security and Emergency Management Division. OPPD will provide assistance with training as requested.
This training normally includes an overview of the plant facility in order to familiarize them with the general area where their assistance may be requested, a review of the basic emergency classification levels, and a review of proper contamination control procedures.
6.2  Offsite Organizations Lead representatives and selected responders falling under the jurisdiction of the following offsite response organizations shall be offered annual training/retraining.
             - Washington County Emergency Management
             - Harrison County Emergency Management
             - Pottawattamie County Emergency Management
             - Douglas County Emergency Management
             - Nebraska Region 5/6 Emergency Management Members of the Fort Calhoun Station may assist with the state of Nebraska Emergency Management Agency and the state of Iowa Homeland Security and Emergency Management Division in preparing and presenting, on an annual basis, training to their Emergency Management agencies in radiological emergency response. Both states have outlined in their respective emergency plans the type of training to be given. Their training is not limited to Emergency Management agencies, but may also include key public officials and emergency services management as well as the state and police agencies and hospitals.
State and local Emergency Management groups are invited to participate in the biennial exercise conducted by the plant. Their participation in the biennial exercise supplements the annual training.
6.3  Law Enforcement Agencies Training for law enforcement agencies is typically conducted by the states of Iowa and Nebraska.

FCS EP-FC-1001 Section O Revision TBD Page 120 of 156 RADIOLOGICAL EMERGENCY RESPONSE TRAINING 7.0  DOCUMENTATION OF TRAINING FCS training procedures outline the process to document training of the Fort Calhoun Station Emergency Response Organization. An Emergency Planning procedure is used to verify training received by offsite organizations.

FCS                                                                  EP-FC-1001 Section P Revision TBD Page 121 of 156 RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION 1.0  RESPONSIBILITY FOR RADIOLOGICAL EMERGENCY RESPONSE PLANNING 1.1  The Plant Manager and Nuclear Division Managers are responsible for the implementation of actions required to periodically exercise the Radiological Emergency Response Plan (RERP), and the Implementing Procedures and for maintaining an effective Emergency Response Organization (ERO) staff.
1.2  The Plant Operations Review Committee is responsible for the review and approval of revisions to the RERP and the Implementing Procedure used for emergency classification in accordance with EP-FC-120 Attachment 2, EP Document Structure and Revision Process.
1.3  The Plant Manager is responsible for the final approval of RERP and the Implementing Procedure used for emergency classification, and for maintaining an effective emergency response capability at Fort Calhoun Station.
1.4  Nuclear Organization Responsible Management Contacts are responsible for selecting and proposing personnel to fill ERO positions and for ensuring support of the Radiological Emergency Response Plan.
1.5  The Manager- Site Emergency Planning is responsible for the development, administration and maintenance of the RERP, Implementing Procedures, and EP-FC procedures, review and approval of all Implementing Procedure changes (with the exception of the Implementing Procedure used for emergency classification), planner training, the overall development and implementation of the FCS ERO Training and Qualification Program and coordination of off-site emergency preparedness activities in the states of Iowa and Nebraska.
1.6  The Manager-Nuclear Training is responsible for the independent review and approval of the FCS ERO Training and Qualification Program.
1.7  The Emergency Planning Department is responsible for the preparation of all revisions to the RERP, Implementing Procedures and for coordinating the review processes necessary prior to the implementation of the revisions.
2.0  MAINTENANCE OF THE RERP AND IMPLEMENTING PROCEDURES 2.1  Emergency Planning personnel shall review the RERP and Implementing Procedures annually. Any changes found to be necessary as a result of the review shall be submitted using the established procedure change process.
2.2  Comments and recommendations made as a result of drills/exercises may require procedure changes to be initiated. These processes are detailed in the drill and exercise program.

FCS                                                                   EP-FC-1001 Section P Revision TBD Page 122 of 156 RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION 2.3  Recurring tasks ensure that copies of the annual review and annual audit reports are reviewed by the Manager-EP and any changes incorporated as necessary.
2.4  Changes to the plan will be submitted to the NRC within 30 days in accordance with 10CFR50.54(q). The Radiological Emergency Response Plan and approved changes to the plan will also be forwarded to appropriate organizations and individuals with responsibility for implementation of the plan. A new edition of the Radiological Emergency Response Plan will be issued when major technical and significant philosophical changes are required.
2.5  All emergency telephone numbers are updated quarterly.
3.0  AUDITS 3.1  The Nuclear Oversight Department will coordinate an independent audit of the Emergency Preparedness Program at intervals not to exceed 24 months or more frequently as required by 10CFR50.54(t)(1). The audit shall include the Radiological Emergency Response Plan, implementing procedures, practices, drills, exercises, training, readiness testing, equipment and interfaces with state and local governments.
The results of this audit along with the recommendations for improvement must be documented and reported to the licensee's corporate and plant management. Copies of pertinent sections of the audit will be forwarded to appropriate state and local governments. This audit shall fulfill the requirements of 10CFR50.54(t). The results of this audit shall be retained for a minimum of five years.

FCS                                                                    EP-FC-1001 Section P Revision TBD Page 123 of 156 RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION 1.0  LETTERS OF AGREEMENT REVIEW 1.1  Written agreements establishing the concept of operations developed between Fort Calhoun Station and other support organizations having an emergency response role within the EPZs have been developed. These agreements identify the emergency measures to be provided, the mutually accepted criteria for implementation, and the arrangements for exchange of information. Agreement letters are not necessary with Federal Agencies who are legally required to respond based on Federal law; however, agreements are necessary if the agency was expected to provide assistance not required by law. Letters of Agreement with private contractors and others who provide services in support of Fort Calhoun Station shall be maintained on file. Letters of Agreement, as a minimum, state that the cooperating organization will provide their normal services in support of an emergency at the affected station. A contract/purchase order with a private contractor is considered acceptable in lieu of a Letter of Agreement for the specified duration of the contract.
Organizations deemed to be First Responders, who are identified as Local Law Enforcement Agency (LLEA), Volunteer Fire Fighting Organizations, Emergency Medical Services (EMS), and the University of Nebraska Medical Center (UNMC), will contain wording to ensure they will respond to a Radiological event to include a Hostile Action Based event.
LLEA will support Fort Calhoun Nuclear Station during a Radiological or Hostile Action Based event, in conjunction with the National Incident Management System upon notification by the station in accordance with established communications protocol.
Fire Fighting Organizations will respond to a Radiological Event, including a Hostile Action Based Event, in conjunction with the National Incident Management System in accordance with established response and communication protocol. Fire Fighting Organizations may be requested to obtain and provide fire response, fire apparatus, and fire personnel.
EMS Support will provide Emergency Medical Services in response to a Radiological Event including a Hostile Action Based Event. This includes transportation of patients from the Fort Calhoun Nuclear Station, including those who may have been exposed to radiation or may have injuries complicated by radioactive contamination, to the University of Nebraska Medical Center by use of established communication protocol.
UNMC agrees in the event of a Radiological event, including a Hostile Action Based Event, to ensure the capability for the evaluation of radiation exposure and uptake, including assurance that persons providing these services are

FCS                                                                    EP-FC-1001 Section P Revision TBD Page 124 of 156 RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION adequately prepared to handle contaminated individuals and capable of providing medical support for any contaminated individual.
A contract/purchase order with a private contractor is considered acceptable in lieu of a Letter of Agreement for the specified duration of the contract.
NOTE i  Copies of Current Letters of Agreement are on file in the Emergency Planning Department.
i 1.2   Law Enforcement Support Organizations Nebraska State Patrol Iowa State Patrol Harrison County Sheriff's Department Washington County Sheriff's Department Pottawattamie County Sheriff's Department Douglas County Sheriff's Department 1.3   Fire and Rescue Support Organizations Blair Fire Department Fort Calhoun Fire and Rescue Missouri Valley Fire Department 1.4   Medical Support Organizations UNMC Regional Radiation Health Center 1.5   Nebraska's Governmental Support Organizations State of Nebraska Emergency Management State of Nebraska-Department of Health and Human Services, Regulation and Licensure Washington County Board of Supervisors Nebraska Game and Parks Commission Douglas County Emergency Management Agency 1.6   Iowa's Governmental Support Organizations Iowa Homeland Security and Emergency Management Division

FCS                                                               EP-FC-1001 Section P Revision TBD Page 125 of 156 RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION Harrison County Board of Supervisors Pottawattamie County Board of Supervisors Pottawattamie County Division of Telecommunications 1.7  Industrial Support Organizations Union Pacific Railroad Westinghouse Electric Electric Power Research Institute/Nuclear Energy Institute Institute of Nuclear Power Operations (INPO) 1.8  Other Support Organizations Nebraska Public Power District Metropolitan Utilities District National Weather Service Tierney-Blair LLC 1.9  Monitoring and Decontamination Support Organizations Omaha Fire Department Emergency Worker Decon

FCS                                                                    EP-FC-1001 Section P Revision TBD Page 126 of 156 RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION The following is a list of plans for organizations that support or supplement emergency response to the Fort Calhoun Station. These are maintained in the EOF.
State Iowa Radiological Emergency Response Plan, Part 2, Nuclear Power Plant Accident/Incident, Annex P of the Iowa Emergency Response Plan.
State of Nebraska - "Radiological Emergency Response Plan for Nuclear Power Plant Incidents" Local Crawford County (Iowa) - "Radiological Emergency Response Plan" Dodge County (Nebraska) - "Radiological Emergency Reception Plan for Nuclear Power Plant Incidents" Douglas County (Nebraska) - "Douglas County Supplement to Washington County Radiological Emergency Response Plan for Nuclear Power Plant Incidents" Harrison County (Iowa) - "Radiological Emergency Response Plan for Nuclear Power Plant Incidents" Pottawattamie County (Iowa) - " Radiological Emergency Response Plan" Sarpy County (Nebraska) - " Radiological Emergency Response Plan for Nuclear Power Plant Incidents" Washington County (Nebraska) - "Radiological Emergency Response Plan for Nuclear Power Plant Incidents"

FCS EP-FC-1001 Appendix C Revision TBD Page 127 of 156 NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST PSRERP Appendix C provides a cross reference to track OPPD's implementation of the guidance provided by NUREG 0654, FEMA REP 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Rev. 1.
OPPD generally conforms to the guidance of NUREG-0654 in its Post Shutdown Radiological Emergency Response Plan (PSRERP), Emergency Plan Implementing Procedures (EPIP) and other supporting documents. However, OPPD has and may make exceptions to NUREG-0654 guidance providing it does not reduce the effectiveness or intent of the PSRERP or EPIPs.
For Section D, Emergency Classification System, OPPD uses the guidance of NEI-99-01, Development of Emergency Action Levels for Non-Passive Reactors. This variance from NUREG-0654 has been approved by the NRC.
All changes to the PSRERP are subject to a 10 CFR 50.54(q) screening, 10 CFR 50.47(b) and 10 CFR 50 Appendix E reviews. If the reviews determine that the change does not reduce the effectiveness or intent of the plan, the Plant Operating Review Committee (PORC) must then approve the change before it is implemented and sent to the NRC for review. If the screening process finds that the change does reduce the effectiveness or intent of the plan the change must be submitted to NRC for pre-approval prior to implementation.
All changes to EPIPs and other documents governed by the PSRERP are also subject to 10 CFR 50.54(q) screening. If it is determined that the proposed EPIP or other plant document change requires a PSRERP change a full 10 CFR 50.47(b), 10 CFR 50 Appendix E review and PORC approval is required prior to implementation and submittal to the NRC for review. NRC pre-approval must be obtained if a change is determined to reduce the effectiveness or the intent of the plan.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD Page 128 of 156 NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                 NUREG Criteria                 RERP Section      Implementing Procedure(s)
A. Assignment of Responsibility A.1.a     Identify the State, Local, Federal and          A 1.1-1.8      N/A private sector organizations (including utilities) intended to be a part of the ERO.
A.1.b     Each organization shall specify its               A 2.0,       EP-FC-112, Crisis concept of operations and its relationship    C 1.0, 2.0, 3.0, Communication Plan to the total effort.                                4.0 Appendix A A.1.c     Block diagram of organizational                  FIG. A-1      N/A interrelationships.
A.1.d     Identify a specific individual (by title) who      A 2.0       EP-FC-112 shall be in charge of the emergency response.
A.1.e     Provide for 24-hr per day response,                A 1.0       EP-FC-112 including communications links.
A.2.a     State/Local applicability                          N/A         N/A A.2.b     State/Local applicability                          N/A         N/A A.3      Letters of Agreement                            Appen. A       EP-FC-120 (Verification of RERP-Appendix A)
A.4      Capability of continuous 24-hour                A 1.0, 2.0     EP-FC-112 operations. Identify, by title, the individual in the principal organization responsible for continuity of resources.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD Page 129 of 156 NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                 NUREG Criteria               RERP Section      Implementing Procedure(s)
B. Onsite Emergency Organization B.1      Specify the onsite emergency                B 2.1, Table B-1 EP-FC-112-100, EP-FC-112-organization of plant staff personnel for                    200, EP-FC-112-300, EP-FC-all shifts and its relation to the                           112-400, EP-FC-112-500 responsibilities and duties of the normal staff complement.
B.2      Designate an individual as emergency           B 7.1, 7.2    EP-FC-112-100 coordinator who is on shift at all times.
B.3      Identify a line of succession for the             B 7.0      EP-FC-112 emergency coordinator position and identify the specific conditions for higher level utility officials assuming this function.
B.4      Specification of responsibilities, and            B 6.2      EP-FC-112 designation of which may not be delegated.
B.5      Positions or titles and major tasks to be   B 8/9/10/11/12,  EP-FC-112-100, EP-FC-112-performed by the persons assigned to           Table B-1     200, EP-FC-112-300, EP-FC-the functional areas of emergency                            112-400, EP-FC-112-500, activity.                                                    Crisis Communication Plan B.6      Interfaces between and among the            B-13, Table B-3 N/A onsite, offsite, corporate, state and local government response organizations.
B.7      Each licensee shall specify the corporate,     Table B-1     EP-FC-112-100, EP-FC-112-management, admin., and technical                 B 4.0      200, EP-FC-112-300, EP-FC-personnel who will augment plant staff in                    112-400, EP-FC-112-500 Table B-1 and in the following areas:
B.7.a     Logistics support, e.g., trans, comm,          B 9.0, 11.0   EP-FC-112-200-F-03, EP-FC-quarters, food, water, special equipment       Table B-2     112-400-F-07 and supplies purchase; B.7.b     Technical support for planning reentry            B 6.0      EP-FC-115 and recovery operations; B.7.c     Management level interface with                   B 13       EP-FC-112 government authorities; and B.7.d     Release of information to news media            B 12,13       EP-FC-112 during an emergency (coordinated with                         Crisis Comm. Plan governmental authorities).
B.8      Specification of contractor and private       A 1.0, B-13,    EP-FC-112-200-F-03, EP-organizations to provide assistance.         B-15, Fig. B-3,  FC-112-400-F-07, Appen A       EP-FC-120 (Verification of RERP-Appendix A)
B.9      Expected services from local agencies        A 1.0 Appen A    EP-FC-120 (Verification of e.g., police, fire, ambulance, medical,     B 15, Table B-1,  RERP-Appendix A) hospital.                                       Fig B-3 RERP Sec L Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD Page 130 of 156 NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                NUREG Criteria              RERP Section    Implementing Procedure(s)
C. Emergency Response Support and Resources C.1      Incorporation of Federal response into          C1 the operational plan:
C.1.a     Specific persons to request Federal        C1.1, B 6.3.1  EP-FC-112 assistance (See A.1.d and A.2.a)
C.1.b     Specific Federal resources expected and     C 1.2-1.3     N/A expected times of arrival, and C.1.c     Specific licensee, state, local resources     C 2.0       N/A to support Federal response, air fields, command posts, tel lines, radio frequencies, and telecommunications centers.
C.2.a     State/Local Applicability                      N/A        N/A C.2.b     Licensee representative to offsite EOCs      C 3.0       EP-FC-112-400 C.3      Radiological laboratories, general            C 2.2       N/A capabilities and expected availability to      4.0 provide radiological monitoring and analyses services which can be used in an emergency.
C.4      Identify Nuclear and other facilities,        C 4.0,      EP-FC-112-200-F-03, EP-organizations or individuals which can be   Appen A       FC-112-400-F-07, relied upon in an emergency to provide                    EP-FC-120 (Verification of assistance. Such assistance shall be                      RERP Appendix A) identified and supported by appropriate letters of agreement.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD Page 131 of 156 NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                 NUREG Criteria          RERP Section  Implementing Procedure(s)
D. Emergency Classification System D.1
* Establish an Emergency Action Level        D 2.0    EP-FC-1001 Addendum 3 Scheme and Emergency Classification scheme.
D.2
* Initiating conditions shall include        D 1.0    EP-FC-1001 Addendum 3 NUREG-0654, Appendix 1 conditions and all FSAR postulated accidents.
D.3       State/Local applicability                   N/A     N/A D.4       State/Local applicability                   N/A     N/A
* NEI-99-01 Guidance has replaced NUREG-0654 Appendix 1 guidance.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD Page 132 of 156 NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                    NUREG Criteria                 RERP Section  Implementing Procedure(s)
E. Notification Methods and Procedures E.1      Notification procedures consistent with EALs           E 2.0     EP-FC-114 including a means for verification of messages.
E.2      Procedures for alerting, notifying and mobilizing      E 2.0     EP-FC-112-100-F-06 emergency response personnel.
E.3      Licensee and state/local establish content of the      E 3.1     EP-FC-114 initial messages, and shall contain: class, release, potentially affected population, and if PARs are needed.
E.4      Provisions for follow-up messages, and shall           E 3.2     EP-FC-114 contain the following:
E.4.a     Location of incident, and name and telephone           E 3.2     EP-FC-114 number (or communications channel identification) of caller; E.4.b     Date/time of incident;                                 E 3.2     EP-FC-114 E.4.c     Class of emergency;                                    E 3.2     EP-FC-114 E.4.d     Type of actual/projected release, and estimated        E 3.2     EP-FC-114 duration/impact times; E.4.e     Estimate of radioactive material released or           E 3.0     EP-FC-110-200 being released and the points and height of releases.
E.4.f     Chemical and physical form of material,                E 3.0     EP-FC-110-200 estimates of quantities/concentration of noble gases, iodines, and particulates; E.4.g     Met conditions at appropriate levels: wind speed,      E 3.0     EP-FC-114 direction (to and from) stability, precip, if any; E.4.h     Type of actual projected does rates at site            E 3.0     EP-FC-110-200 boundary, projected integrated dose at site boundary:
E.4.i     Projected dose rates and integrated dose at 2, 5,      E 3.0     EP-FC-110-200 and 10 miles, include the sector(s) affected; E.4.j     Estimate of any surface contamination inplant,         E 3.0     EP-FC-110-200 onsite, offsite; E.4.k     Licensee emergency response actions                    E 3.0     EP-FC-114 underway; E.4.l     Recommended emergency actions, including               E 3.2     EP-FC-114 protective measures; E.4.m      Request for any needed onsite support by offsite       E 3.0     EP-FC-114 organizations, and; E.4.n     Prognosis for worsening/termination based on           E 3.2     EP-FC-114 plant information.
E.5      State/Local applicability                               N/A      N/A E.6      Notification/prompt instructions to the public.        E 4.0     EP-FC-112, EP-FC-121 (ANS)
E.7      Written messages for the public, consistent with       E 5.0     EP-FC-112 the EALs, to include ad hoc PARs.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD Page 133 of 156 NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                 NUREG Criteria              RERP Section       Implementing Procedure(s)
F. Emergency Communications F.1.a     Provision for 24 hour notification to and       E 2.0         EP-FC-114 activation of the State/local ER network,       F 1.0 with telephone link and backup, and             F 2.0 24-hour manning of communication links          F 2.3 that initiate emergency response actions;       F 2.4 F.1.b     Communications with contiguous             F 2.0, 2.3, 2.4,   EP-FC-114 states/locals;                               Fig F-1, F-2 F.1.c     Communications with Federal EROs;         F 2.3, 2.9, 2.10,   EP-FC-114 F 2.12, F 2.13, Fig. F-1 F.1.d     Communication between the plant, EOF,      F 2.4, 2.5, 2.8, EP-FC-112 state and local EOCs, and rad monitor        2.11, 2.17, teams;                                    Fig. F-1, Fig. F-2 F.1.e     Provision for alerting or activating            E 2.0         EP-FC-112-100-F-06 emergency personnel in each response organization, and F.1.f     Communication (by licensee) with NRC       F 2.3, 2.8, 2.9,   EP-FC-112-400 HQ and Regional Office EOC and the          2.10, F-2.12, EOF and Rad Mon Team Assembly area.              2.22 F.2      Each organization shall ensure that a           F 3.0         EP-FC-112-300-AD-F-coordinated comm link for fixed and                           04,FCSG-15 mobile medical support facilities exists.
F.3      Each organization shall conduct periodic        N 2.1         EP-FC-124 testing of the entire emergency communications system. (See also H.10, N.2.a and Appendix 3).
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD Page 134 of 156 NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                 NUREG Criteria              RERP Section  Implementing Procedure(s)
G. Public Education and Information G.1      Each organization shall provide a             G 1.0      Corporate Crisis coordinated periodic (at least annually)                 Communication Plan; dissemination of information to the public               EP-FC-120 re: how they will be notified, and what their actions should be.
G.2      The public information program shall          G 1.0      Corporate Crisis provide permanent and transient adult                    Communication Plan; population within the EPZ an adequate                    EP-FC-120 opportunity to become aware of the information annually. This section also makes reference to: Signs, decals, posted notices, for hotel, motels, gas stations, and phone booths).
G.3.a      Media contact point during an emergency       G 2.0      Corporate Crisis (i.e., JIC, etc).                                        Communication Plan G.3.b      Space for limited number of news media        G 2.0      Corporate Crisis at the EOF.                                              Communication Plan G.4.a      Each organization shall have a                G 3.0      Corporate Crisis spokesperson.                                            Communication Plan G.4.b      Each organization shall establish             G 3.0      Corporate Crisis arrangements for timely exchange of                      Communication Plan information among designated spokes persons.
G.4.c     Each organization shall establish             G 2.1      Corporate Crisis coordinated arrangements for dealing                     Communication Plan with rumors.
G.5      Each organization shall conduct               G 4.0      EP-FC-120 coordinated programs at least annually to acquaint news media with the emergency plans, information concerning radiation, and points of contact for release of public information in an emergency.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD Page 135 of 156 NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                NUREG Criteria               RERP Section      Implementing Procedure(s)
H. Emergency Facilities and Equipment H.1      Each licensee shall establish a TSC and          H 1.0,      EP-FC-112 an OSC.                                            3.0 H.2      Establish an EOF.                                H 2.0       EP-FC-112 H.3      State/Local applicability                         N/A        N/A H.4      Timely activation of the facilities and      H 1.3, 2.3,     EP-FC-112 centers described in the Plan.                 3.3, 4.3 H.5      Each licensee shall identify and establish onsite monitoring systems that are to be used to initiate emergency measures, in accordance with Appendix 1, as well as those used to conduct assessment. The equipment shall include:
H.5.a     Geophysical phenomena monitors, (e.g.,           I 2.0,      EP-FC-1001 Addendum 3 met, hydrological, seismic);                    I 2.1.2, I 2.1.3, I 2.2.3, I 2.3.2(c)
H.5.b     Rad monitors, (e.g., process, area,        H.1.2, 2.2, 3.2,  EP-FC-1001 Addendum 3 emergency, effluent, wound and portable        4.2, 5.0      EP-FC-110 monitors and sampling equipment);               I 2.2.1      EP-FC-112-500 I 2.2.2      EP-FC-113 RP-AA-350 H.5.c     Process monitors (e.g., reactor coolant           I 2.2      EP-FC-1001 Addendum 3 system pressure and temp, containment                        EP-FC-121 pressure and temp, liquid levels, flow rates, status or lineup of equipment components); and H.5.d     Fire and combustion products detectors.         I 2.1.1      EP-FC-1001 Addendum 3 SO-G-28, Station Fire Plan H.6      Each licensee shall make provision to acquire data from or for emergency access to offsite monitoring and analysis equipment, including:
H.6.a     Geophysical phenomena monitors (e.g.,           I 2.1.2      EP-FC-1001 Addendum 3 met, hydrologic, seismic):                       2.1.3 2.2.3 H.6.b     Radiological monitors including                  H 2.2       EP-FC-112-500 ratemeters and sampling devices.                   5.2       EP-FC-113 Dosimetry shall be provided and shall              5.3       RP-AA-700 meet, as a minimum, the NRC Rad                    5.6 Assessment Branch Tech Position for the Environmental Rad Monitoring program; and H.6.c     Laboratory facilities, fixed or mobile. C 2.0, C 4.0     EP-FC-112-500 H.7      Each organization, where appropriate,           I 2.3.3      EP-FC-112-500 shall provide for offsite rad monitoring          J 2.5 equipment in the vicinity of the plant.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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H.8      Each licensee shall provide met                 I 2.2.3    EP-FC-110-200 instrumentation and procedures which                       EP-FC-110-201 satisfy the criteria in Appendix 2, and provisions to obtain representative current met data from other sources.
H.9      Each licensee shall provide for an onsite        H 3.0     EP-FC-112-300 OSC which shall have adequate capacity and supplies, including, for example, respiratory protection, protective clothing, portable lighting, portable radiation monitoring equipment, cameras and communications equipment for personnel present in the OSC.
H.10      Inspect/inventory/operationally check            H 5.0     EP-FC-124 equipment at least quarterly and after                     RP-AA-700 each use. There shall be sufficient reserves of instruments/equipment to replace those which are removed from emergency kits for calibration or repair.
H.11      Identify emergency kits, by general              H 5.0     EP-FC-124 category (i.e., protective equipment, comm equipment, rad monitoring equipment.
H.12      Each organization will establish a central       H 2.1     EP-FC-112-500 point for receipt and analysis of all field monitoring data and coordination of sample media.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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I. Accident Assessment I.1     Identify plant system and effluent             Sec D      EP-FC-1001 Addendum 3 parameter values characteristic of a             I 1.0 spectrum of off-normal conditions and             2.0 accidents, and shall identify the plant parameter values or other information which correspond to the example initiating conditions of Appendix 1.
I.2     Onsite capability and resources to               I 1.0    EP-FC-1001 Addendum 3 provide initial values and continuing             2.0     EP-FC-110-200 assessment throughout the course of an                    EP-FC-110-201 accident shall include post accident sampling capability, radiation and effluent monitors, in-plant iodine instrumentation and containment radiation monitoring.
I.3     Each licensee shall establish methods and techniques to be used for determining:
I.3.a     The source term of releases of                  D 1.0     EP-FC-110-200 radioactive material within plant systems. Table D-1   EP-FC-110-201 I.3.b     The magnitude of the release of                 D 2.0     EP-FC-111-AD-F-02 radioactive materials based on plant                      EP-FC-110-200 system parameters and effluent monitors.                  EP-FC-110-201 I.4     Each licensee shall establish the               D 2.0     EP-FC-111-AD-F-02 relationship between effluent monitor                     EP-FC-110-200 readings and onsite and offsite                           EP-FC-110-201 exposures and contamination for various met conditions.
I.5     Each licensee shall have the capability of     I 2.2.3    EP-FC-111-AD-F-02 acquiring and evaluating met information                  EP-FC-110-200 sufficient to meet the criteria of Appendix               EP-FC-110-201 2.
I.6     Each licensee shall establish the                I 3.1    EP-FC-111-AD-F-02 methodology for determing the release                     EP-FC-110-200 rate/projected doses of the                               EP-FC-110-201 instrumentation used are offscale or inoperable.
I.7     Field monitoring plans.                          I 2.3    EP-FC-112-500 I.8     Provide methods, equipment and                   I 3.0    EP-FC-111-AD-F-02 expertise to make rapid assessment of                     EP-FC-110-200 the actual or potential magnitude of any                  EP-FC-110-201 rad hazard through liquid or gaseous release pathways.
I.9     Each organization shall have a capability        I 3.0    EP-FC-112-500 to detect and measure radioiodine concentrations in air in the plume exposure EPZ as low as 10-7 Ci/cc under field conditions.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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I.10     Each organization shall establish means         I 3.0      EP-FC-110-200 for relating the various measured                          EP-FC-110-201 parameters (e.g. contamination levels, water and air activity levels) to dose rates for key isotopes and gross radioactivity measurements.
I.11     Arrangements to locate and track the            I 2.3      EP-FC-112-500 plume.                                                     EP-FC-110-200 EP-FC-110-201 Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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J. Protective Response J.1       Each licensee shall establish the means        J 1.3.2 and time required to warn or advise             J 1.1 individuals within the owner-controlled area, including:
J.1.a      Employees not having emergency                  J 1.1     EP-FC-113 assignments;                                   J 1.3.2 Visitors;                                       J 1.1     EP-FC-113 J.1.b                                                     J 1.3.2 Contractor and construction personnel,          J 1.1     EP-FC-113 J 1.c      and                                            J 1.3.2 J 1.d      Other persons who may be in the public          J 1.1     EP-FC-113 access areas or passing through the site       J 1.3.2 or within the owner-controlled area.
J.2       Make provisions for evacuation routes           J 1.2     EP-FC-113 and transportation for onsite individuals     Table J-9 to some suitable offsite location, including alternatives for inclement weather, high traffic density and specific rad conditions.
J.3       Each licensee shall provide for                 J 1.2     EP-FC-113 radiological monitoring of people evacuated from the site.
J.4       Each licensee shall provide for the             J 1.2     EP-FC-113 evacuation of onsite non-essential personnel in the event of a Site Area or General Emergency and shall provide a decon capability at or near the monitoring point specified in J.3, above.
J.5       Each licensee shall provide for a              J 1.3.2    EP-FC-113 capability to account for all individuals                 SY-AA-101-121 onsite at the time of the emergency and ascertain the names or missing individuals within 30 minutes of the start of the emergency and account for all onsite individuals continuously thereafter.
J.6       Each licensee shall, for people remaining onsite, make provisions for:
J.6.a      Individual respiratory protection;             J 1.4.4    EP-FC-113 RP Manual J.6.b      Use of protective clothing;                    J 1.4.3    EP-FC-113 RP Manual J.6.c      Use of KI.                                     J 1.4.5    EP-FC-113 J.7       Each licensee shall establish a                J 2.1.1    EP-FC-114 mechanism for recommending PAs to State and locals.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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J.8     Each licensees plan shall contain an            J 2.3     EP-FC-1001 Addendum 2 ETE. These shall be in accordance with Appendix 4.
J.9     State/local applicability                        N/A      N/A Table J-9 J-10 J.10     The organizations plans to implement protective measures for the EPZ shall include:
J.10.a     Maps showing evacuation routes,                J 2.3.2    EP-FC-113 evacuation areas, preselected                  Fig J-1    ANS Map radiological sampling and monitoring             J-2      10-Mile EPZ Map points, relocation centers in host areas, and shelter areas; J.10.b     Maps showing pop distribution around           J 2.3.3    EP-FC-1001 Addendum 2 the Nuclear facility. This shall also be by    Fig J-4 evacuation areas;                                J-7 J-8 J.10.c     Means for notifying all segments of the         J 2.2     EP-FC-121 transient and resident population; J.10.d     State/local applicability                        N/A      N/A J.10.e     State/local applicability                        N/A      N/A J.10.f    State/local applicability                        N/A      N/A J.10.g     State/local applicability                        N/A      N/A J.10.h     State/local applicability                        N/A      N/A J.10.i    State/local applicability                        N/A      N/A J.10.j    State/local applicability                        N/A      N/A J.10.k     State/local applicability                        N/A      N/A J.10.l    State/local applicability                        N/A      N/A J.10.m     The basis for the choice of recommended         J 2.1     EP-FC-111 protective actions from the EPZ during        Table J-2 emergency conditions.                            J-3 J-4 J.11     State applicability                              N/A      N/A J.12     State/local applicability                        N/A      N/A Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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K. Radiological Exposure Control K.1       Each licensee shall establish onsite exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity PAGs for:
K.1.a      Removal of injured persons;                     K 1.0        EP-FC-113, RP Manual K.1.b      Undertaking corrective actions;                 K 1.0        EP-FC-113, RP Manual K.1.c      Performing assessment actions;                  K 1.0        EP-FC-113, RP Manual K.1.d      Providing first aid;                            K 1.0        EPIP-EOF-11, FCSG-15-7 RP Manual K.1.e      Performing personnel decon;                     K 1.0        EP-FC-113, RP Manual K.1.f      Providing ambulance service; and                K 1.0        EP-FC-113, FCSG-15-7 RP Manual K 1.g      Providing medical treatment services.           K 1.0        EP-FC-113, FCSG-15-7 RP Manual K.2       Each licensee shall provide an onsite rad       K 1.0        EP-FC-113 protection program to be implemented                         RP Manual during emergencies, including methods to implement exposure guidelines.
K.3.a      24 hour capability to determine the doses       K 1.2        RP Manual received by emergency personnel                              EP-FC-113 involved in any nuclear accident, including volunteers.
K.3.b      Each organization shall ensure that            J 1.4.2       RP Manual dosimeters are read at appropriate              K 1.2 frequencies.
K.4       State/local applicability                        N/A         N/A K.5.a      Action levels for determining the need for      K 2.1        RP-AA-350 decon.
K.5.b      Decon of personnel wounds, supplies,            K 2.0,       RP-AA-350 instruments and equipment and for waste          3.0 disposal.
K.6       Each licensee shall provide onsite contamination control measure including:
K.6.a      Area access control;                            K 2.0        RP-AA-350 K.6.b      Drinking water and food supplies;               K 2.4        EP-FC-112-200-F-14 K.6.c      Criteria for permitting return of areas and     K 2.5        RP-AA-350 items to normal use (see ANSI 12.13).
K.7       Each licensee shall provide the capability  K 2.1, 2.2, 2.3  EP-FC-113 for decon of relocated onsite personnel,        L 3.2 including provisions for extra clothing and decontaminants suitable for the type of contamination given to radioiodine contamination of the skin.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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L. Medical and Public Health Support L.1      Each organization shall arrange for local       L 3.0      RP-AA-220 and backup hospital and medical                            FCSG-15-7 services having the capability for evaluation of radiation exposure and uptake, including assurances that persons providing these services are adequately prepared to handle contaminated persons.
L.2      Each licensee shall provide for onsite first    L 1.0      FCSG-15-7 aid capability.
L.3      State applicability                              N/A       N/A L.4      Each organization shall arrange for             L 2.0      FCSG-15-7 transportation of rad victims to medical support facilities.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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M. Recovery and Reentry Planning and post Accident Operations M.1      Each organization shall develop plans            M 1.3      EP-FC-115 and procedures for reentry and recovery           2.0 and describe the means by which decisions to relax protective measures are reached.
M.2      Each licensee plan shall contain the             M 1.2      EP-FC-115 position/title, authority and responsibilities of individuals who will fill key positions in the recovery organization.
M.3      Each licensee and state plan shall               M 1.2      EP-FC-115 specify the means for informing members of the response organizations that a recovery operation is to be initiated, and of any changes in the organizational structure that may occur.
M.4      Each plan shall establish a method for           I 3.0      EP-FC-200 periodically estimating total population exposure.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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N. Exercises and Drills N.1.a     Exercises shall be conducted as set forth         N          EP-FC-122 in NRC and FEMA rules.
N.1.b     An exercise shall include mobilization of       N 1.0        EP-FC-122 State and local personnel and resources...shall provide for a critique by federal and state observers/evaluators...scenario varied from year to year....6:00 PM and Midnite/Midnite and 6:00 AM exercises....under various weather conditions....some unannounced.
N.2.a     Communications drills:
Comm with State and Locals                      N 2.1        EP-FC-122 (monthly)
Comm with Federal EROs and states               N 2.1        EP-FC-122 within the IPZ (quarterly)
Comm between the plant, state and local         N 2.1        EP-FC-122 EOCs, and field assessment teams (annually)
N.2.b     Fire Drills                                     N 2.2        OP-AA-201-005 N.2.c     Medical Emergency Drills                        N 2.3        EP-FC-122 N.2.d     Rad Monitoring Drills                           N 2.4        EP-FC-122 N.2.e     HP Drills Shall be conducted semi-annually which          N 2.4        EP-FC-122 involve response to and analysis of simulated elevated airborne and liquid samples and direct rad measurements.
The state drills need not be at each site.
Analysis of inplant liquid samples with         N 2.4        EP-FC-122 actual elevated rad levels including use of the PASS shall be included in HP drills by licensees annually.
N.3      Each organization shall describe how exercises and drills are to be carried out to allow free play for decision making and to meet the following objectives. ....The scenarios shall include, but not be limited to, the following:
N.3.a     Basic objectives and appropriate            N 1.0, 2.0, 3.0  EP-FC-122 evaluation criteria; N.3.b     Dates, time periods, places, and            N 1.0, 2.0, 3.0  EP-FC-122 participating organizations; N.3.c     The simulated events;                       N 1.0, 2.0, 3.0  EP-FC-122 N.3.d     Time schedule of real and simulated         N 1.0, 2.0, 3.0  EP-FC-122 initiating events; N.3.e     A narrative summary;                        N 1.0, 2.0, 3.0  EP-FC-122 Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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N.3.f     A description of arrangements and           N 1.0, 4.0  EP-FC-122 advance materials for official observers.
N.4      An exercise critique.                         N 4.0     EP-FC-122 N.5      Evaluating the comments from observers        N 4.0     EP-FC-122 and participants.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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O. Radiological Emergency Response Training O.1       Each organization shall assure training of    O 4.0      TQ-FC-113 appropriate individuals.                       5.0 O.1.a       Each facility shall train members of the      O 5.0      TQ-FC-113 ERO.
O.1.b       State/local applicability                     O 6.0      N/A O.2       Training shall include drills.                N 2.0      TQ-FC-113 O.3       Licensee training for First Aid teams to      O 1.0      TQ-AA-174 include ARC Multi-Media or equivalent.
O.4       Each organization shall establish a training program for ERO. Training shall be in the following categories:
O.4.a       Directors or coordinators of EROs;            O 5.0      TQ-FC-113 O.4.b       Accident assessment personnel;                O 5.0      TQ-FC-113 O.4.c      Rad Mon Teams and rad analysis                O 5.0      TQ-FC-113 personnel; Police, security and fire fighting            O 6.0      EP-FC-10 O.4.d       personnel;                                               SY-AA-150 O.4.e       Repair and damage control/correctional        O 5.0      TQ-FC-113 action teams (onsite);
O.4.f      First aid and rescue personnel;               O 1.0      TQ-AA-173 6.0 O.4.g       Local support services personnel,             O 6.0      EP-FC-10 including CD/Emergency Services personnel; O.4.h       Medical Support Personnel;                    L 3.2      TQ-AA-173 O 6.0 O.4.i      Licensee Headquarters support                 O 4.0      TQ-FC-113 personnel;                                               Crisis Communication Plan O.4.j      Personnel responsible for transmission of     O 4.0      TQ-FC-113 emergency information and instructions.
O.5       Initial and annual retraining.                O 5.0      TQ-FC-113 Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

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P. Responsibility for the Planning Effort; Development, Periodic Review and Distribution of Emergency Plans P.1       Each organization shall provide for the          P 1.0     EP-FC-11 training of individuals responsible for the planning effort.
P.2       Each organization shall identify by title        P 1.0     EP-FC-11 the individual with overall planning authority; P.3       Each organization will designate an              P 1.0     EP-FC-11 Emergency Planning Coordinator.
P.4       Each organization shall update its plan          P 2.0     EP-FC-120 and agreements as needed, review and certify it to be current on an annual basis.
Changes will take into consideration items from drills and exercises.
P.5       Plans and plan changes shall be                  P 2.0     EP-FC-120 forwarded to all organizations and appropriate persons with EP responsibility. Revised pages dated and marked to show changes.
P.6       List supporting plans and source.              APPEN B     N/A P.7       Each plan shall contain an appendix            APPEN C     N/A listing procedures required to implement the plan. The listing shall include the sections of the plan to be implemented by each procedure.
P.8       Each plan shall contain a table of             APPEN C     N/A contents. Plans submitted for review should be cross-referenced to these criteria.
P.9       Independent review of the plans.                 P 3.0     EP-FC-120 P.10       Quarterly update of plan telephone               P 4.0     EP-FC-124 numbers.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD Page 148 of 156 NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST Attachment 1 - PSRERP Titles Document                                Document Title PSRERP           Radiological Response Plan For Fort Calhoun Station PSRERP-SECTION A Assignment of Organizational Responsibility (Organizational Control)
PSRERP-SECTION B Organizational Control of Emergencies PSRERP-SECTION C Emergency Response Support and Resources PSRERP-SECTION D Emergency Classification System PSRERP-SECTION E Notification Methods and Procedures PSRERP-SECTION F Emergency Communications PSRERP-SECTION G Public Education and Information PSRERP-SECTION H Emergency Facilities and Equipment PSRERP-SECTION I Accident Assessment PSRERP-SECTION J Protective Response PSRERP-SECTION K Radiological Exposure Control PSRERP-SECTION L Medical and Public Health Support PSRERP-SECTION M Recovery and Reentry Planning and Post Accident Operations PSRERP-SECTION N Exercises and Drills PSRERP-SECTION O Radiological Emergency Response Training PSRERP-SECTION P Responsibility for the Planning Effort: Development, Periodic Review and Distribution PSRERP-APPENDIX  Letters of Agreement A
PSRERP-APPENDIX  Supporting Emergency Plans B
PSRERP-APPENDIX  NUREG/RERP/Implementing Procedure Cross Reference List C
PSRERP-APPENDIX  OPPD Resolution #4731, Radiological Emergency Response Plan D                Authority

FCS EP-FC-1001 Appendix C Revision TBD Page 149 of 156 NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST PSRERP-APPENDIX  Definitions and Abbreviations E

FCS EP-FC-1001 Appendix C Revision TBD Page 150 of 156 NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST Attachment 2 - EPIP Titles Document                           Document Title EP-FC-1001      EMERGENCY ACTION LEVELS FORT CALHOUN STATION Addendum 3 EP-FC-110       ASSESSMENT OF EMERGENCIES EP-FC-111       EMERGENCY CLASSIFICATION AND PROTECTIVE ACTION RECOMMENDATIONS EP-FC-112       EMERGENCY RESPONSE ORGANIZATION (ERO) EMERGENCY RESPONSE FACILITY (ERF) ACTIVATION AND OPERATION EP-FC-112-100   CONTROL ROOM OPERATIONS EP-FC-112-200   TSC ACTIVATION AND OPERATION EP-FC-112-300   OPERATIONS SUPPORT CENTER ACTIVATION AND OPERATION EP-FC-112-400   EMERGENCY OPERATIONS FACILITY ACTIVATION AND OPERATION EP-FC-112-500   EMERGENCY ENVIRONMENTAL MONITORING EP-FC-112-700   ALTERNATE FACILITY OPERATION EP-FC-113       PERSONNEL PROTECTIVE ACTIONS EP-FC-114       NOTIFICATIONS EP-FC-115       TERMINATION AND RECOVERY

FCS                                              EP-FC-1001 Appendix D Revision TBD Page 151 of 156 OPPD RESOLUTION # 4731, RADIOLOGICAL EMERGENCY RESPONSE PLAN AUTHORITY

FCS                                              EP-FC-1001 Appendix D Revision TBD Page 152 of 156 OPPD RESOLUTION # 4731, RADIOLOGICAL EMERGENCY RESPONSE PLAN AUTHORITY

FCS EP-FC-1001 Appendix E Revision TBD Page 153 of 156 DEFINITIONS AND ABBREVIATIONS 1.0  DEFINITIONS AND ABBREVIATIONS 1.1  ALARA - As Low As is Reasonably Achievable - Means making every reasonable effort to maintain exposures to radiation as far below the dose limits as is practical consistent with the purpose for which the licensed activity is undertaken, taking into account the state of technology, the economics of improvements in relation to state of technology, the economics of improvements in relation to benefits to the public health and safety, and other societal and socioeconomic considerations, and in relation to utilization of nuclear energy and licensed materials in the public interest 1.2  ANS - Alert Notification System - Described in Section E 1.3  AR - Action Request 1.4  Assessment Actions - The appropriate actions taken during or following an accident evaluation before implementing the specific corrective and/or protective actions 1.5  CDE - Committed Dose Equivalent - (HT50) The dose equivalent to organs or tissues of reference (T) that will be received from an intake of radioactive material by an individual during the 50 year period following the intake 1.6  CFR - Code of Federal Regulations 1.7  CHP - Conference Health Physics Network - Described in Section E 1.8  Committed Effective Dose Equivalent - (HE50) Sum of the products of the weighing factors applicable to each of the body organs or tissues that are irradiated and the committed dose equivalent to these organs or tissues 1.9  Control Room - Functions described in Section H 1.10 COP - Conference Operations (Phone) Network- Described in Section E 1.11 Corrective Actions - Measures taken to correct or mitigate an emergency condition at its origin in order to prevent an uncontrolled release of radioactive material or reduce the magnitude of the release.
1.12 CR - Control Room - Functions described in Section H 1.13 Deep Dose Equivalent - (DDE or Hd) applies to external whole-body exposure, is the dose equivalent at a tissue depth of 1 cm (1000 mg/cm2) 1.14 T - Delta Temperature - The difference in temperature between points 10 meters and 60 meters above the ground in units of centigrade. The value displayed on the ERFCS equates to; 100m T = [(T @ 60m - T@ 10m) x 2)]

FCS EP-FC-1001 Appendix E Revision TBD Page 154 of 156 DEFINITIONS AND ABBREVIATIONS 1.15 DOE - Department Of Energy - Role is discussed in Section C 1.16 Drill - Described in Section N 1.17 DSC - Dry Shielded Canister 1.18 DSO - Director of Site Operation (NRC) 1.19 EAD Electronic Alarming Dosimeter 1.20 URI/RASCAL - Emergency Assessment of Gaseous and Liquid Effluent-Section E 1.21 EAL - Emergency Action Level - Described in Section D 1.22 EAS - (Emergency Alerting System) - Described in Section E 1.23 ECCS - Emergency Core Cooling System 1.24 ENS - (FTS-ENS) Federal Telephone System Emergency Notification System -
Described in Section F 1.25 EOC - Emergency Operations Center - Discussed in Sections C and F 1.26 EOF - Emergency Operations Facility - Functions described in Section H 1.27 EPA - Environmental Protection Agency - Role Discussed in Section C 1.28 EPIP - Emergency Plan Implementing Procedures 1.29 EPT - Emergency Plan Test - Described in Section P 1.30 EPZ - Emergency Planning Zone - Described in Section J 1.31 ERDS - Emergency Response Data System - Described in Section F 1.32 ERFCS - Emergency Response Facilities Computer System - Described in Section H 1.33 ERO - Emergency Response Organization - Duties Described in Section B 1.34 Exercise - Described in Section N 1.35 FAA - Federal Aviation Administration - Role discussed in Section C 1.36 FEMA - Federal Emergency Management Agency - Role described in Section C 1.37 FTS - Federal Telecommunications Systems (NRC Phone Circuits) - Discussed in Section F

FCS EP-FC-1001 Appendix E Revision TBD Page 155 of 156 DEFINITIONS AND ABBREVIATIONS 1.38 GAR - Governors Authorized Representative - Authorized by letters in Appendix A 1.39 HPN - Health Physics Network - Described in Section F 1.40 HSM - Horizontal Storage Module 1.41 ISFSI - Independent Spent Fuel Storage Installation 1.42 IPZ - Ingestion Pathway Zone - Discussed in Section J 1.43 JIC - Joint Information Center - Functions discussed in Section B 1.44 NAWAS - National Warning System - Functions described in Section F 1.45 NRC - Nuclear Regulatory Commission - Role discussed in Section C 1.46 NWS - National Weather Service - Role discussed in Section C 1.47 Operation Liaison Network- Described in Section F 1.48 OSC - Operation Support Center - Functions described in Section H 1.49 PABX - Private Automatic Branch Exchanges - Function described in Section H 1.50 PAG - Protective Action Guideline - Discussed in Section J 1.51 PAR - Protective Action Recommendation - Discussed in Section J 1.52 Protective Actions - Discussed in Section J 1.53 REM - The special unit of any of the quantities expressed as dose equivalent. The dose equivalent in rems is equal to the absorbed dose in rads multiplied by the quality factor (1 rem = .01 sievert).
1.54 SDE - Shallow Dose Equivalent - Is the dose equivalent at a tissue depth of 0.007 cm or 7 mg/cm2 averaged over an area of 10 cm2. It applies to the external exposure of the skin or an extremity.
1.55 TEDE - Total Effective Dose Equivalent - The sum of the deep-dose equivalent (for external exposures) and the committed effective dose equivalent (for internal exposures). This represents the combined dose (DDE+CEDE) to a worker.
1.56 TLD - Thermoluminescent Dosimeter - A device worn by plant personnel to measure the amount of radiation received.
1.57 TSC - Technical Support Center - Functions described in Section H

FCS EP-FC-1001 Appendix E Revision TBD Page 156 of 156 DEFINITIONS AND ABBREVIATIONS 1.58 UNMC Regional Radiation Health Center - Role discussed in Section L 1.59 USAR - Updated Safety Analysis Report

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION DOCKET NUMBER 50-285 / LICENSE NUMBER DPR-40 ATTACHMENT 4 ANALYSIS OF PROPOSED POST-SHUTDOWN ON-SHIFT STAFFING

FCS                                                 EP-FC-1001 Revision TBD POST SHUTDOWN RADIOLOGICAL EMERGENCY RESPONSE PLAN OPPD NUCLEAR POST-SHUTDOWN RADIOLOGICAL EMERGENCY RESPONSE PLAN FOR FORT CALHOUN STATION

FCS                                                                                   EP-FC-1001 Revision TBD POST SHUTDOWN RADIOLOGICAL EMERGENCY RESPONSE PLAN AREA DESCRIPTION 1.0  PLANT LOCATION Fort Calhoun Station is located midway between Fort Calhoun and Blair, Nebraska, on the west bank of the Missouri River. The site consists of approximately 660.46 acres with an additional exclusion area of 582.18 acres on the northeast bank of the river directly opposite the plant buildings. The Fort Calhoun Station includes the Independent Spent Fuel Storage Installation (ISFSI), located within the protected area, centered approximately 200 meters north-northwest of the Containment Building. The distance from the reactor containment to the nearest site boundary is approximately 910 meters; and the distance to the nearest residence is beyond the site boundary. Except for the city of Blair and the villages of Fort Calhoun and Kennard, the area within a ten mile radius is predominantly rural. The land use within the ten mile radius is primarily devoted to general farming. There are no private businesses or public recreational facilities on the plant property. The DeSoto National Wildlife Refuge occupies approximately 7821 acres east of the plant site. This area is open to the public for day use year-round.
Visitors to the refuge generally use areas from two to five miles from the plant. Estimates by the U.S. Fish and Wildlife Service place annual usage of the facility at approximately 120,000 for the Visitors Center and 400,000 for the refuge. The expected maximum daily usage of the facility has been placed at 2500 visitors for a winter weekday and 5000 on a summer weekend. The Boyer Chute Federal Recreation Area is a day use facility occupying approximately 2000 acres southeast of the plant site. Visitors to the recreation area generally use areas seven to ten miles from the plant. The estimates for annual usage of this facility is approximately 50,000 visitors.
The State of Nebraska operates the Fort Atkinson State Historic Park five and half miles southeast of the plant site. This day use facility is mostly seasonal and estimates place annual usage at 60,000. The State of Iowa maintains Wilson Island State Park with 275 camping spaces south of the DeSoto National Wildlife Refuge and four miles southeast of the plant site. The estimates for usage of this facility range from 500 on a winter weekday to 1000 on a summer weekend.
Two private facilities lie to the north of the plant along the Missouri River. The Cottonwood Marina is located approximately four and a half miles from the plant.
Estimates place summer weekend usage at 200 people. Riverland Resort Park is a private campground lying directly south of Cottonwood Marina and ranging from four to four and a half miles from the plant. The campground has approximately 235 campsites and is open from April to October.

FCS                                                                                   EP-FC-1001 Revision TBD POST SHUTDOWN RADIOLOGICAL EMERGENCY RESPONSE PLAN 2.0  AREA INDUSTRIES A listing of various industries located within a ten mile radius of the Fort Calhoun Station, including firm name, product, number of employees, and location from the plant site is contained in the Updated Safety Analysis Report.
3.0  AREA WATER SUPPLIES Local public drinking water supplies are not taken from the Missouri River in this area.
The first downstream intake is the city of Omaha approximately 19.5 miles downstream.
Industrial water use is limited to cooling purposes in the Omaha area. Drinking water near the Fort Calhoun Station is obtained from either well or reservoirs. Since the known public and private water supplies originate at elevations higher than the river, radioactive liquids that might be discharged from the plant into the river should not contaminate these supplies.
There are also many private wells in the region which draw primarily upon ground water rather than on springs or other surface sources. Several marinas are located along the Missouri River, between 3 miles upstream from Blair and Omaha, 18 miles downstream.
In the event of a significant waterborne release incident from the Fort Calhoun Station, the Nebraska Department of Environmental Control acting in conjunction with the Nebraska Department of Health, Division of Radiological Health and the U. S. Coast Guard are prepared to notify all downstream users of Missouri River water. Notification is made through OPPD management directly to the Metropolitan Utilities District (MUD) in the event of an inadvertent liquid release to the river. Swimming, boating and other recreational activities involving river water can be controlled by the Coast Guard until adequate surveys have been taken to determine when normal activities may be resumed.

FCS                                                                                     EP-FC-1001 Revision TBD POST SHUTDOWN RADIOLOGICAL EMERGENCY RESPONSE PLAN PURPOSE OF THE EMERGENCY PLAN The purpose of the Fort Calhoun Station "Post-Shutdown Radiological Emergency Response Plan" (PSRERP) is to delineate an organization for coping with emergencies, to classify emergencies according to severity, define and assign responsibilities and authorities, and to clearly outline the most effective course of action and protective measures required to mitigate the consequences of an accident and to safeguard the public and station personnel in the event of an incident. The Emergency Plan Implementing Procedures (EPIPs), Radiation Protection procedures, and other station references are available at the plant to further assist personnel during abnormal occurrences. The various emergency procedures are put into effect whenever a system, component or circuit failure could lead to a personnel hazard or major equipment failure. Procedures are sufficiently detailed so that the plant is maintained in a safe condition.
The various procedures include such items as radiation hazards, weather conditions and availability of technical and plant personnel.

FCS                                                                                   EP-FC-1001 Revision TBD POST SHUTDOWN RADIOLOGICAL EMERGENCY RESPONSE PLAN ACCIDENT CONSIDERATIONS 1.0  FUEL HANDLING ACCIDENT The possibility of an incident during fuel handling is unlikely due to the many physical limitations imposed on fuel handling operations and systems. In addition, administrative restrictions placed on fuel handling procedures provide greater control. Nevertheless, the offsite consequences of dropping a spent fuel assembly and damaging the entire assembly have been evaluated and are documented in the Fort Calhoun Station, Unit No. 1 USAR, Section 14.18. Emergency onsite and offsite monitoring practices would begin immediately following the accident to determine actual consequences, and appropriate emergency actions would be taken. Emergency procedures addressing a Fuel Handling Incident provide emergency actions for this mishap.
The transfer cask that is used to transfer spent fuel (32 assembly capacity) contained within a dry shielded canister (DSC) from the Auxiliary Building to the ISFSI, has been analyzed for an 80 inch drop accident in the NUHOMS FSAR. The analysis determined that the DSC would retain its leak tight integrity for this 80 inch drop. This bounds the height of the transfer cask while it is being moved by the heavy-haul trailer between the Auxiliary Building and the ISFSI so that a release of radioactivity due to a drop event during transfer operations would not occur.
2.0  FIRES 2.1  Internal Plant Fires (within the Protected Area)
Internal Plant fires are normally handled by the station's Fire Brigade, comprised of trained individuals from the Operations Department and Radiation Protection Department. All efforts are made to prevent the spread of airborne contamination should the fires occur within the Radiological Controlled Area.
2.2  External Fires (outside the Protected Area)
External fires are controlled by local fire department response. In the event high airborne contamination constitutes a possible hazard to areas outside of the protected area, offsite survey teams/personnel can be dispatched immediately.

FCS                                                                                   EP-FC-1001 Revision TBD POST SHUTDOWN RADIOLOGICAL EMERGENCY RESPONSE PLAN 3.0  EXPLOSION Because of the accumulation of waste gases in the waste gas decay tanks, the possibility and consequences of an explosion have been considered. An explosion could result in an unexpected, uncontrolled release to the atmosphere of radioactive fission gases that were stored in the waste gas system. A failure of any of the waste gas decay tanks or associated piping could also result in a release of gaseous activity. The noble gases stored in the tanks would diffuse and become diluted during their transport to the site boundary. The projected Deep Dose Equivalent (DDE) at the exclusion area boundary would be less than 1.0 Rem. This conservative analysis is based upon 1% fuel cladding defects, and accumulation of all noble gases without release over a full core cycle.
Emergency procedures addressing a Waste Gas Incident, would be placed into effect immediately and offsite monitoring teams would be dispatched downwind.
The ISFSI horizontal storage modules (HSM) are designed to protect the DSCs from the effects of explosions to ensure the DSCs retain their leak-tight integrity and prevent a release of radioactivity to the atmosphere. An analysis of the haul route used to transfer the DSCs from the Auxiliary Building to the ISFSI was performed, and it identified administrative controls needed to prevent explosions in the vicinity of the transfer cask (designed to withstand 3 psi overpressure) during spent fuel transfer operations.
4.0  TOXIC CHEMICAL RELEASE ACCIDENTS The primary toxic chemical release accidents which may result in toxic gas concentrations at Fort Calhoun Station are shown below:
TOXIC CHEMICAL              ACCIDENT Ammonia (NH3)               Rupture of two 25,000 ton offsite refrigerated tanks.
Ammonia                     Rupture of two 30,000 gal. offsite non-refrigerated tanks.
Ammonia                     Rupture of a 78 ton railroad tank car.
Ammonia                     Rupture of a 2 ton tank truck.
The above accidents will not pose a hazard to control room personnel, due to toxic gas monitors located at the fresh air intake of the control room, which isolates the control room before the gases reach the toxic limit. The stringent odor of ammonia makes station personnel immediately aware of any leakage or toxic gas cloud. Spent Fuel storage at the ISFSI relies on passive means of decay heat removal (natural convection),
so a toxic gas release does not challenge nuclear safety.
The toxic gas monitors sample for NH3 and continuously monitor the fresh air to the control room during normal plant operations.

FCS                                                                                    EP-FC-1001 Revision TBD POST SHUTDOWN RADIOLOGICAL EMERGENCY RESPONSE PLAN At different phases of plant operation, Hydrogen and/or Nitrogen gases blanket the volume control tank and the waste gas system. Considering that the deleterious effect of these gases is the exclusion of oxygen, a release to the atmosphere diminishes the harmful effect and a serious hazard is eliminated.
In the event of an offsite accidental release of chemicals, within a five (5) mile radius of the Fort Calhoun Station, the Blair Fire Department emergency procedures require notification to the Fort Calhoun Station. The counties of Washington (Nebraska) and Harrison (Iowa) have agreed to notify the Fort Calhoun Station when hazardous chemical accidents occur within five miles of the station. Appropriate action is taken, especially in the control room, to ensure that air remains breathable. For long duration toxic accidents, six (6) hours of compressed air is available for five (5) control room operators coupled with provisions to obtain additional air within this time period.
5.0  PERSONNEL INJURY A fully stocked First Aid Room is available in the Plant. Immediate and temporary care may be given to the injured person using standard First Aid practices. If the injury involves contamination, efforts to decontaminate the injured person to reasonable levels are made prior to transfer to the First Aid Room or to offsite medical facilities. If decontamination is not practical, the injured person is covered in such a manner as to minimize the spread of contamination until either medical aid can be obtained or until the injured person can be transported to the UNMC Regional Radiation Health Center.
6.0  NATURAL DISASTERS A natural disaster may occur which could initiate any of the accidents previously discussed. The Spent Fuel Pool and ISFSI are designed to withstand natural phenomena, including the maximum hypothetical earthquake, design basis tornado and tornado-driven missiles, with no release of radioactivity.

FCS EP-FC-1001 Section A Revision TBD ASSIGNMENT OF ORGANIZATIONAL RESPONSIBILITY (ORGANIZATIONAL CONTROL) 1.0  NON-OPPD SUPPORT ORGANIZATIONS The following organizations may respond to a declared emergency at the Fort Calhoun Station. Each of these groups are capable of 24 hour response and operation. The details of their responsibilities are contained in their respective emergency response plans/procedures or if applicable, a Letter of Agreement between that organization and OPPD. Figure A-1 outlines the organizational interrelationships of various response organizations.
1.1  Law Enforcement Support Organizations 1.1.1      Nebraska State Patrol 1.1.2      Iowa State Patrol 1.1.3      Washington County Sheriff's Department 1.1.4      Pottawattamie County Sheriff's Department 1.1.5      Harrison County Sheriff's Department 1.1.6      Douglas County Sheriff's Department 1.2  Fire and Rescue Support Organizations 1.2.1      Blair Fire Department and Rescue Squad 1.2.2      Fort Calhoun Fire/Rescue 1.2.3      Missouri Valley Fire & Rescue Squad 1.2.4      Council Bluffs Fire and Ambulance Department 1.3  Medical Support Organization 1.3.1      UNMC Regional Radiation Health Center 1.4  Nebraska's Governmental Support Organizations 1.4.1      Nebraska Emergency Management Agency 1.4.2      Washington County Emergency Management Agency 1.4.3      Douglas County Emergency Management Agency

FCS EP-FC-1001 Section A Revision TBD ASSIGNMENT OF ORGANIZATIONAL RESPONSIBILITY (ORGANIZATIONAL CONTROL) 1.4.4   Nebraska Health and Human Services, Regulation and Licensure 1.4.5   Region 5/6 Emergency Management Agency 1.4.6   Dodge County Emergency Management Agency 1.4.7   Sarpy County Emergency Management Agency 1.5  Iowa's Governmental Support Organizations 1.5.1   Iowa Homeland Security and Emergency Management Division 1.5.2   Iowa Department of Public Health 1.5.3   Harrison County Emergency Management Agency (via Board of Supervisors) 1.5.4   Pottawattamie County Emergency Management Agency (via Board of Supervisors) 1.5.5   Pottawattamie County Division of Communications 1.5.6   Crawford County Emergency Management Agency 1.6  Federal Government Support Organizations 1.6.1   U.S. Coast Guard 1.6.2   Environmental Protection Agency (EPA) 1.6.3   Department of Energy (DOE) 1.6.4   National Weather Service (NWS) 1.6.5   U.S. Nuclear Regulatory Commission (NRC) 1.6.6   Federal Emergency Management Agency (FEMA) Region VII 1.6.7   Federal Aviation Administration (FAA) 1.6.8   Department of the Interior, Branch of Global Seismology

FCS EP-FC-1001 Section A Revision TBD ASSIGNMENT OF ORGANIZATIONAL RESPONSIBILITY (ORGANIZATIONAL CONTROL) 1.7  Industrial Support Organizations 1.7.1     Westinghouse Electric 1.7.2     Union Pacific Railroad 1.7.3     Institute of Nuclear Power Operations (INPO) 1.7.4     Institute of Nuclear Power Operations/Electric Power Research Institute/Nuclear Energy Institute 1.8  Other Support Organizations 1.8.1     Metropolitan Utilities District 1.8.2     Nebraska Public Power District (Cooper Nuclear Station) 1.8.3     National Weather Service 1.9  Monitoring and Decontamination Support Organizations 1.9.1     Omaha Fire Department Emergency Worker Decon 2.0  OPPD CONCEPT OF EMERGENCY OPERATIONS 2.1  OPPD's overall goals are to mitigate any emergency conditions which may occur at the Fort Calhoun Station and to provide information and support to State and Local agencies needed to protect the health and safety of the general public.
2.2  A predesignated group is assigned to various roles to ensure capable emergency response and mitigation at the Fort Calhoun Station. These assignments are made to ensure that the administrative, managerial and technical support needed for accident mitigation are met. A sufficient number of individuals are assigned to these positions to ensure around-the-clock and continued long term support.
2.3  Responsibility for emergency response initially lies with the Shift Manager. If the Technical Support Center (TSC) is activated, command and control may be transferred to the Site Director. The Emergency Director in the Emergency Operations Facility (EOF) may assume command and control if that facility is activated. The command and control position is responsible for ensuring the continuity of resources throughout an event.

FCS EP-FC-1001 Section A Revision TBD ASSIGNMENT OF ORGANIZATIONAL RESPONSIBILITY (ORGANIZATIONAL CONTROL) 3.0  LETTERS OF AGREEMENT 3.1  Letters of agreement between OPPD and the organizations outlining their roles in the event of an emergency are on file with the Fort Calhoun Station Emergency Planning Department. These letters are reviewed annually in accordance with Emergency Preparedness recurring tasks.

FCS EP-FC-1001 Section A Revision TBD ASSIGNMENT OF ORGANIZATIONAL RESPONSIBILITY (ORGANIZATIONAL CONTROL)
Figure A Organizational Interrelationships

FCS EP-FC-1001 Section B Revision TBD ORGANIZATIONAL CONTROL OF EMERGENCIES 1.0 PURPOSE AND SCOPE 1.1 Purpose 1.1.1   This PSRERP Section establishes the organizational requirements, reporting locations and duties for the Fort Calhoun Station (FCS) Emergency Response Organization (ERO).
1.2 Scope 1.2.1   The positions established in this PSRERP Section upon declaration of an emergency will comprise the ERO. The EROs responsibility is to mitigate the consequences of an event using the facilities and resources described elsewhere in the PSRERP and the supporting Emergency Plan Implementing Procedures (EPIP).
2.0 DEFINITIONS None 3.0 RESPONSIBILITIES 3.1 Emergency Response Organization (ERO):
3.1.1   OPPD has issued a resolution which authorizes the ERO to provide an immediate and decisive response to mitigate the consequences of any nuclear emergency and for the protection of the health and safety of the public. Resolution No. 4731, as approved by the Board of Directors on January 15, 1998, is Appendix D of the PSRERP.
3.1.2   The ERO is intended to provide a pre-qualified organization capable of fulfilling the actions described above. The ERO is not confined to utilize only those personnel that are currently listed as qualified. Other OPPD personnel may be assigned and utilized to perform necessary functions at the discretion of the Command and Control positions. Assignment of any non-ERO qualified individual(s) should include adequate instruction to ensure the individual(s) is capable of performing the necessary functions and is knowledgeable of any potential hazards associated with responding to the designated facility.
3.2 Command and Control:
3.2.1   The position performing the duties of the Emergency Director is referred to as the Command and Control Position.

FCS EP-FC-1001 Section B Revision TBD ORGANIZATIONAL CONTROL OF EMERGENCIES 3.2.2  The Command and Control position has the following responsibilities that cannot be delegated to other personnel. The position may assign other personnel to assist in conducting the actions necessary, but the responsibility of their completion rests with the position, until relieved by another Command and Control position or qualified individual, or the emergency is terminated:
A. Overall command and control of the ERO.
B. Ensuring that the proper classification of the emergency has been made in accordance with the established EAL/Classification scheme and is periodically reviewed to determine if the classification should be upgraded, downgraded or terminated.
C. Ensuring that all required notifications are made to appropriate state, local and federal officials.
D. Ensuring that appropriate Protective Action Recommendations (PARs) are provided to offsite officials.
E. Authorizing OPPD emergency worker exposure extensions beyond the Federal Radiation Protection Guidance.
F. Authorizing issuance of Potassium Iodide for OPPD emergency workers.
3.2.3  The Command and Control position also has the following responsibilities that can be delegated to other personnel, as necessary:
A. Requests for assistance from federal agencies.
B. Authorizing any emergency information to be released to the media or the general public.
C. Coordinating the transfer of the emergency information from the ERO to other OPPD and non-OPPD organizations called upon to assist.
D. Ensuring a timely and complete turnover of information to any qualified relief.
E. Declaring the termination of an emergency and transfer into a Recovery Operations Organization, when appropriate.
F. Providing information to the authorized representatives of the states of Nebraska and Iowa, and associated local governments.
G. Ensuring that the plant is in compliance with Technical Specifications and other licensee conditions, and if deviations are necessary to protect the public health and safety, they are approved, as a minimum, by a Senior Reactor Operator, prior to taking the action.

FCS EP-FC-1001 Section B Revision TBD ORGANIZATIONAL CONTROL OF EMERGENCIES 4.0 PROCEDURE 4.1 ERO Staff On-Shift 4.1.1     The staffing of the normal operating organization for each shift is shown in Table B-1. This staffing consists of, as a minimum:
One Shift Manager (Senior Reactor Operator (SRO)/Certified Fuel Handler (CFH))
One Control Room Operator (SRO or Reactor Operator (RO)/CFH)
One Equipment Operator/Non-Certified Operator (NCO)
One Radiation Protection Technician Additionally, there are several shift Security personnel assigned 4.1.2     All or part of these shift personnel may comprise the initial ERO, and are responsible for taking immediate protective measures in any emergency and implementing this Post-Shutdown Radiological Emergency Response Plan when necessary.
4.2 Activation of the ERO 4.2.1     At a Notification of Unusual Event (NOUE), the Shift Manager may elect to not activate the ERO. In this instance, a notification to certain management personnel is performed and other personnel may be notified to assist as necessary.
A. If the Shift Manager elects to activate the ERO, the notification process will call out the entire ERO (with the exception of the JIC).
4.2.2     It is OPPDs goal that the ERO personnel can staff their emergency positions within one hour following declaration of an Alert or higher classification. In the event of adverse weather and/or other conditions that may limit or slow response, either manmade or natural, it is understood that staffing time may exceed this goal.
4.3 Facility Activation and Operation 4.3.1     There are some functional group activities that may be performed within an Emergency Response Facility prior to actually activating the facility. To be beneficial to the Command and Control facility, these activities, such as dose assessment and field team functions, are dependent upon the establishment of proper communications between the facilities.
4.3.2     OPPD Emergency Response Facilities are considered activated when minimum staffing and basic setup requirements have been attained to allow the facility to provide minimum support to the operating staff and other facilities.

FCS EP-FC-1001 Section B Revision TBD ORGANIZATIONAL CONTROL OF EMERGENCIES A. It is OPPDs goal that the OSC, EOF and TSC be activated within one hour following an Alert classification. The JIC will be activated following a Site Area or General Emergency classification, and can be activated at an earlier classification based on the decisions of the Corporate Communications Division.
4.3.3  Minimum staffing for activation of the OSC is as follows:
One OSC Director One Radiation Protection Technician One other person to form a team 4.3.4  Minimum staffing for activation of the TSC is as follows:
One Site Director One TSC Protective Measures Coordinator One Engineering Coordinator 4.3.5  Minimum staffing for activation of the EOF is as follows:
One Emergency Director One EOF COP Communicator One EOF Protective Measures Manager One EOF Dose Assessment Specialist 4.3.6  OPPD Emergency Response Facilities are considered augmented when all minimum and augmenting staffing positions are filled.
4.3.7  Selected support staff, which assists the minimum and augmenting staff, is shown on Attachment 1 - Table B OPPD Emergency Response Organization (ERO) Functions and Shift Staff Augmentation Plan. The support staff is intended to supplement and enhance operation of their respective facilities. Additional personnel may respond.
4.3.8  If a toxic chemical/hazardous material or other significant event occurs that threatens the habitability of the station, an option exists to have all or part of the TSC and OSC staffs report to the EOF to provide assistance as necessary.
4.3.9  Some ERO personnel may elect to maintain an assistant position. This is acceptable when additional coordination of activities is required or to aid in the turnover process. The primary assignee must maintain overall responsibility of the position, and ensure that 24 hour staffing of the position can be implemented.

FCS EP-FC-1001 Section B Revision TBD ORGANIZATIONAL CONTROL OF EMERGENCIES 4.4 Command and Control Positions 4.4.1  The positions that have Emergency Director Authority are:
The Shift Manager The Site Director The EOF Emergency Director 4.4.2  The Shift Manager ERO duties are to:
A. Perform as Emergency Director until properly relieved by a qualified position.
B. Direct medical and fire response efforts.
C. Coordinate in-plant operations response with the TSC and OSC. After being relieved by another Command and Control position, the Shift Manager will provide assistance and direction to the Control Room staff as necessary.
D. Ensure Control Room communications are established with the TSC, OSC, and EOF.
4.4.3  The Site Director position is intended to assume Command and Control functions from the Control Room if the EOF is not available or cannot assume Command and Control. This position may assume Command and Control at any emergency classification. The Site Director may assume Command and Control in the Control Room proper at any time. If the Site Director elects to assume Command and Control within the TSC, the TSC must meet activation requirements.
A. The Site Director duties are to promptly relieve the Control Room Command and Control position and perform as Emergency Director until properly relieved by a qualified position, if the EOF is not available or cannot assume Command and Control. Additional duties of the Site Director are to:
: 1. Manage the onsite activities of the ERO.
: 2. Keep the Emergency Director informed of those onsite activities as necessary.
4.4.4  The EOF Emergency Director position is intended to assume all Command and Control functions from the plant site. This position may assume Command and Control at any emergency classification, but the EOF must meet activation requirements prior to the transfer of Command and Control duties.

FCS EP-FC-1001 Section B Revision TBD ORGANIZATIONAL CONTROL OF EMERGENCIES A. The Emergency Director duties are to promptly relieve the onsite Command and Control position and perform as Emergency Director until properly relieved by a qualified position or termination of the emergency response phase.
4.5 Control Room Positions 4.5.1    The following positions are on-shift staff, and augmenting positions for the Control Room. Additional Control Room support staffing is identified on Attachment 2 - Figure B Fort Calhoun Station Emergency Response Organization. Control Room on-shift staff positions are:
A. Shift Managers duties are described in Sections 4.2, 3.2 and 4.4.2.
B. Control Room Operator duties include:
Assessment of plant conditions, Ensuring requirements of the AOPs are met, and Notifications as directed by the Shift Manager. These notifications include the following:
o Required notifications to the states and counties o Notifications to the Emergency Response Organization C. Equipment Operator/NCO duties include making repairs and corrective actions on plant equipment until augmented plant maintenance staff arrives. NCOs also assist in performing notifications/communications and dose assessment as needed.
D. Shift Radiation Protection Technician duties include conducting radiological accident assessment and support, offsite dose assessment and onsite in-plant surveys.
4.5.2    The Control Room (CR) Operations Liaison is an augmenting position.
Duties include transmitting plant status/Control Room information, etc. to the TSC, OSC, and EOF.

FCS EP-FC-1001 Section B Revision TBD ORGANIZATIONAL CONTROL OF EMERGENCIES 4.6 Technical Support Center Positions 4.6.1    The following are minimum staffing and augmenting positions for the Technical Support Center (TSC). Additional TSC support staffing is identified on Attachment 2 - Figure B Fort Calhoun Station Emergency Response Organization. Minimum staffing positions for the TSC are:
A. Site Director duties are described in Steps 3.2 and 4.4.3.
B. Engineering Coordinator duties include:
: 1. Directing activities of engineering resources requested by the TSC.
: 2. Analyzing plant problems and providing recommendations for plant modifications to mitigate the effects of the accident.
: 3. Evaluating possible radiological release paths to the environment.
C. Protective Measures Coordinator duties include:
: 1. Coordinating the dispatch of the TSC field team from the site and performing field team direction until the EOF assumes this duty.
: 2. Monitoring and coordinating on site dose assessment operations performed, and keep the Site Director informed of dose projections and field sample results.
: 3. Evaluating site radiological conditions, and necessary personnel protective measures.
: 4. Evaluating and making recommendations for plant evacuation and evacuation routes.
: 5. Preparing and submitting state update information, including Protective Action Recommendations, to the Site Director for approval and transmittal to state and federal officials if TSC has Command and Control.

FCS EP-FC-1001 Section B Revision TBD ORGANIZATIONAL CONTROL OF EMERGENCIES 4.6.2    Augmenting positions for the TSC are:
A. TSC Field Team duties include providing off-site monitoring in the areas potentially affected by a radiological release.
B. Operations Liaison duties include:
: 1. Obtaining plant status/Control Room information from the Control Room Operations Liaison and transmitting this information to the TSC staff as needed. [AR 11390]
: 2. Assisting the Site Director in formulating appropriate protective action recommendations when necessary.
4.7 Operations Support Center Positions 4.7.1    The following are minimum staffing and augmenting positions for the Operations Support Center (OSC). Additional OSC support staffing is identified on Attachment 2 - Figure B Fort Calhoun Station Emergency Response Organization. Minimum staffing positions for the OSC are:
B. OSC Director duties include:
: 1. Coordinating the development of plans for required maintenance activities.
: 2. Keeping the Site Director informed of OSC activities.
: 3. Coordinating emergency team response as requested by the TSC/Control Room to perform search and rescue, damage assessment, damage control, repair and modification, and in-plant radiological monitoring.
C. Radiation Protection Technician duties include coordination of on-site radiation protection activities.
D. One other person to form a team.
4.7.2    Augmenting positions for the OSC are:
A. Chemistry Technician duties include evaluating and performing all chemistry activities on-site.
B. Electrical Maintenance Technician duties include providing repairs and corrective actions for plant electrical equipment as directed.
C. I&C Technician duties include providing repairs and corrective actions to

FCS EP-FC-1001 Section B Revision TBD ORGANIZATIONAL CONTROL OF EMERGENCIES plant instruments as directed.
D. Machinist or Steam Fitter Mechanic duties include providing repairs and corrective actions to plant mechanical equipment as directed.
E. Radiation Protection Technicians (three positions) duties include providing radiological surveys and job coverage to repair and corrective action teams as directed.
F. The Protective Measures Coordinator duties include coordinating all radiation protection activities onsite.

FCS EP-FC-1001 Section B Revision TBD ORGANIZATIONAL CONTROL OF EMERGENCIES 4.8 Emergency Operations Facility Positions 4.8.2  The following positions are minimum staffing and augmented positions for the Emergency Operations Facility (EOF). Additional EOF support staffing is identified on Attachment 2 - Figure B Fort Calhoun Station Emergency Response Organization. Minimum staffing positions for the EOF are:
A. Emergency Director duties are described in Section 3.2 and 4.4.4.
B. COP Communicator duties include performing notifications as directed by the Command and Control position. These notifications include the following:
Required notifications to states and counties Required notifications to the NRC Notifications to the Emergency Response Organization. This position also assists in maintaining status boards within the EOF C. Protective Measures Manager duties include:
: 1. Directing dose assessment operations performed, coordinating OPPD field teams, and keeping the Emergency Director informed of projections and field survey results.
: 2. Evaluating site radiological conditions and necessary personnel protective measures.
: 3. Preparing and submitting state update information, including Protective Action Recommendations, to the Emergency Director, state and federal officials.
: 4. Coordinating technical briefings for the offsite agencies as requested.
: 5. Comparing dose projections against field team results.
: 6. Comparing dose projections and field team results with state and federal agency results.
D. Dose Assessment Specialist duties include performing offsite dose assessments and submitting the results to the Emergency Director for approval and transmittal to state and federal officials.

FCS EP-FC-1001 Section B Revision TBD ORGANIZATIONAL CONTROL OF EMERGENCIES 4.8.3  Augmenting positions for the EOF are:
A. Administrative Logistics Manager duties include:
: 1. Coordinating administrative personnel support to the EOF.
: 2. Coordinating scheduling and callout of ERO personnel for 24 hour coverage.
: 3. Activating the Alert Notification System as requested.
: 4. Coordinating OPPD resources for the establishment of emergency logistics for the ERO, such as food, beverages, medical and administrative supplies, transportation, special equipment, etc.
B. The EOF Field Team duties include providing off-site monitoring in the areas potentially affected by a radiological release.
: 1. Field Team Specialist duties include coordinating the activities of the OPPD and state Field Teams to achieve the most efficient use of teams for plume tracking.
C. Information Specialist duties include:
: 1. Preparing information for use in periodic press releases.
: 2. At an Alert or higher emergency classification, submitting all press releases to the Emergency Director (or designee) for approval prior to forwarding the release to the JIC.

FCS EP-FC-1001 Section B Revision TBD ORGANIZATIONAL CONTROL OF EMERGENCIES D. Operations Liaison duties include: 1) obtaining plant status/Control Room information from the Control Room Operations Liaison and transmitting this information to the EOF and NRC staff as needed; and,
: 2) assisting the Emergency Director in the review of classifications and formulating appropriate protective action recommendations when necessary. [AR 11390]
4.9  Joint Information Center Positions 4.9.2     The Joint Information Center Manager duties include:
A. Coordinating with government authorities and to provide periodic briefings and news releases to news media personnel.
B. Providing public inquiry services.
C. Keeping OPPD personnel, including senior management, informed of the status of the emergency and emergency response effort. OPPDs Corporate Crisis Communication Plan lists other JIC positions.
4.10 Emergency Response Organization Interface with Onsite and Offsite Organizations 4.10.2    Attachment 2 - Figure B Fort Calhoun Station Emergency Response Organization illustrates the interface between the EOF and other onsite support centers. Attachment 2 - Figure B Organization Interrelationships illustrates the interface of the EOF with federal, state, and local support agencies.
4.10.3    The EOF interfaces with each of the onsite support centers on a continuous basis. Even though the EOF serves as the primary interface with the various offsite support agencies, the TSC interfaces with various contractors and vendors to gather needed design data, consultation, and evaluation concerning the plant's status.
4.11 Emergency Response Organization Notification 4.11.2    Emergency Response Organization notification occurs as shown in Sections E and M of the PSRERP. The Shift Manager is responsible for initiation of the notification process after an emergency condition has been classified.
4.12 Service Provided by Local Agencies 4.12.2    The Nebraska State Patrol and the Washington County Sheriff's Department have agreed to provide the primary law enforcement support to the Fort Calhoun Station Security Department.

FCS EP-FC-1001 Section B Revision TBD ORGANIZATIONAL CONTROL OF EMERGENCIES 4.12.3   The Blair Volunteer Fire Department has agreed to provide the primary fire support services for the Fort Calhoun Station. The Fort Calhoun Volunteer Fire Department has agreed to provide backup fire response.
4.12.4   OPPD vehicles may transport non-injured potentially contaminated personnel. The Blair Volunteer Fire Department has agreed to provide primary rescue and transportation support, for injured and/or contaminated personnel. The Fort Calhoun Volunteer Fire and Rescue, Missouri Valley Fire and Rescue and the Council Bluffs Ambulance and Fire Departments have agreed to provide backup services.
4.12.5   The Blair Hospital has agreed to provide medical support for work related injuries. Nebraska Health Services University Hospital in Omaha, maintains a regional Radiation Health Center which provides services for the treatment of radiologically contaminated injuries and radiation exposure evaluation.
4.12.6   The majority of the organizations listed in this section maintain a Letter of Agreement with OPPD. These letters are on file in the Emergency Planning Department at the Fort Calhoun Station.
5.0  RETENTION/RECORDS None

==6.0  REFERENCES==
AND COMMITMENTS 6.9  AR 11390, LIC-065R 6.10 Fort Calhoun Station Analysis of Proposed Post-Shutdown On-Shift Staff, August 2016 7.0  ATTACHMENTS 7.9  Attachment 1 - Table B OPPD Emergency Response Organization (ERO)
Functions and Shift Staff Augmentation Plan 7.10 Attachment 2 - Figure B Normal Fort Calhoun Station Management Organization 7.11 Attachment 2 - Figure B Fort Calhoun Station Emergency Response Organization 7.12 Attachment 2 - Figure B Organization Interrelationships

FCS EP-FC-1001 Section B Revision TBD ORGANIZATIONAL CONTROL OF EMERGENCIES Attachment 1 - Table B OPPD Emergency Response Organization (ERO) Functions and Shift Staff Augmentation Plan NUREG 0654                                                Omaha Public Power District Goals for 1 hour On Shift Minimum Major Functional Area            Major Tasks            Emergency Positions                                Augmentation Minimum Number/Title Number/Title Plant Operations and                                  Shift Manager (SRO)      1 Shift Manager Assessment of                                         Shift Foreman (SRO)      (SRO/CFH)
Operational Aspects                                   Control Room Operators   1 Control Room Operator Auxiliary Operators      (SRO or RO/CFH)***
1 Equipment Operator/NCO Emergency Command                                     Shift Technical Advisor, 1** Shift Manager and Control                                           Shift Manager or                                     1 Site Director OR (Emergency                                            designated Facility                                  1 Emergency Director Coordinator)*                                         Manager Notification/            Notify License, State local                            1 Control Room Operator    1 Communicator in EOF Communication            and Federal personnel                                 (SRO or RO/CFH)***
and maintain communication Radiological Accident    Emergency Operations         Senior Manager                                       1 Emergency Director Assessment and           Facility (EOF) Director Support of Operational Accident  Offsite Dose Assessment      Senior Health Physics    1 R.P Technician            1 Prot. Meas. Coord Assessment                                            (HP) Expertise Offsite Surveys                                                                   4 Field Team Technicians Onsite (Out of plant)                                                             1 R.P. Technician In Plant surveys Chemistry/Radiochemistry                                                          1 Chemistry Technician Plant System             Technical Support            Shift Technical Advisor Engineering, Repair and                                                   Core/Thermal hydraulics                              1 Engineering Coord Corrective Actions                                    Electrical Mechanical                                           1 Machinist OR Steam Fitter Mechanic Repair and Corrective        Mechanical Maintenance   1** Equipment Actions                                               Operator/NCO                1 Equipment Operator/NCO Electrical Maintenance                               1 Electrical Maintenance 1** Equipment               Technicians Operator/NCO Instrument and Control                               1 I&C Technician (I&C) Technician Protective Actions       Radiation Protection:        HP Technicians           1 R.P . Technician          1 R.P. Technician (Plant)                  a. Access Control
: b. HP Coverage for repair, corrective actions, search and rescue, first aid and firefighting
: c. Personnel monitoring
: d. Dosimetry Firefighting                                                                   Fire Brigade per SO-G-      Blair Fire Department 28,Station Fire Plan Rescue Operations and                                                          2** Equipment               Blair Rescue Squad First Aid                                                                      Operators/NCOs Site Access Control and  Security, Firefighting,      Security Personnel       All per Security Plan Personnel                communications, Accountability           personnel accountability
* Emergency Command and Control responsibility is transferred in accordance with Section B of this plan.
** May be provided by Shift personnel assigned other functions.
***Performs initial notification to NRC.

FCS EP-FC-1001 Section B Revision TBD ORGANIZATIONAL CONTROL OF EMERGENCIES Attachment 2 - Figure B Normal Fort Calhoun Station Management Organization The Fort Calhoun Organization is described in Chapter 12 of the USAR.

EP-FC-1001 Section B FCS                                                                                                Revision TBD ORGANIZATIONAL CONTROL OF EMERGENCIES Attachment 2 - Figure B Fort Calhoun Station Emergency Response Organization

FCS EP-FC-1001 Section B Revision TBD ORGANIZATIONAL CONTROL OF EMERGENCIES Attachment 2 - Figure B Organization Interrelationships

FCS EP-FC-1001 Section C Revision TBD EMERGENCY RESPONSE SUPPORT AND RESOURCES 1.0 FEDERAL RESPONSE 1.1 Personnel Authorized to Request Federal Assistance The Emergency Director typically coordinates with the states to secure federal assistance. However, the Emergency Director may also request federal assistance directly, if timely assistance has not been provided as requested by the states. The states will be kept informed of such requests.
1.2 Federal Response Organizations The Federal Radiological Emergency Response Plan (FRERP) and the Federal Response Plan (FRP) outline the federal response to any type of emergency, including an emergency at a fixed nuclear facility. Some of the typical federal organizations which could respond to an emergency at the Fort Calhoun Station are as follows:
1.2.1 U.S. Coast Guard Upon notification, the U.S. Coast Guard will control traffic on the Missouri River in the area of Fort Calhoun Station. They will provide waterborne patrols for extended periods if contamination levels persist.
A U.S. Coast Guard cutter is based at the Florence Boat Yard, approximately 18 river miles downstream of the Fort Calhoun Station.
1.2.2 U.S. Environmental Protection Agency (EPA)
Upon request, the EPA will provide trained manpower to assist in reviewing survey data, offsite evaluations and advise on protective actions for the public.
They also provide assistance in the collection and analysis of environmental samples.

FCS EP-FC-1001 Section C Revision TBD EMERGENCY RESPONSE SUPPORT AND RESOURCES 1.2.3  U.S. Department of Energy (DOE)
DOE is the technical support branch of the Federal Radiological Emergency Response Plan (FRERP). DOE would typically be the agency in charge of initial establishment and control of the Federal Radiological Monitoring and Assessment Center (FRMAC).
Some of the capabilities of DOE and the FRMAC operations are as follows:
A. Support to the state(s) in the coordination of offsite radiological monitoring assessment, evaluation, and reporting activities of all federal agencies during the initial phases of an accident and maintain a technical liaison with the states and local agencies with similar responsibilities.
B. Ensure the orderly transfer of responsibility for coordinating the intermediate and long term radiological monitoring function at the FRMAC to EPA after the initial phases of the emergency.
C. Provide the personnel and equipment required to coordinate and perform the offsite radiological monitoring and evaluation activities.
D. Assist the NRC in assessing the accident potential and in developing technical recommendations on protective measures.
E. Maintain a common set of offsite radiological monitoring data and provide this data and interpretation to the NRC and to appropriate state and local agencies requiring direct knowledge of radiological conditions and monitoring results.
F. Provide consultation and support services to all other entities (e.g.
private contractors) having radiological monitoring functions and capabilities.
G. Assist other federal, state and local agencies by providing technical and medical advice concerning treatment of radiological contamination.
H. Provide telecommunications support and capabilities.
I. Assist other federal agencies in developing and establishing guidelines on effective systems of emergency radiation detection and measurement, including instrumentation.

FCS EP-FC-1001 Section C Revision TBD EMERGENCY RESPONSE SUPPORT AND RESOURCES 1.2.4  U.S. National Weather Service (NWS)
The National Weather Service operates on a twenty-four (24) hour per day basis. Upon request, this organization can provide the Fort Calhoun Station with meteorological conditions including predicted temperature inversions, precipitation, wind patterns and velocity.
1.2.5  U.S. Nuclear Regulatory Commission (NRC)
The NRC becomes the Lead Federal Agency (LFA) in a response to a fixed nuclear facility, such as the Fort Calhoun Station. In their role as LFA, the NRC will directly coordinate response activities with OPPD and determine the need for appropriate federal response organizations. The NRC will perform the function of LFA from several response locations including the NRC Operations Center, Region IV's Incident Response Center, all OPPD Emergency Response Facilities (once a site team has arrived), and other federal response facilities established.
1.2.6  Federal Emergency Management Agency (FEMA)
FEMA is responsible for coordinating the non-technical federal support to state and local governments which could include such tasks as logistics and telecommunications. The senior FEMA official on the scene will notify the federal agency(ies) most capable of meeting the state and local governmental needs. FEMA would take the lead at the federal Disaster Field Office, if such location is established. Fort Calhoun Station is located within FEMA, Region VII.
1.2.7  Federal Aviation Administration (FAA)
The FAA controls and directs air traffic in and around the affected area. The FAA has the authority to close the area surrounding the Fort Calhoun Station to all non-response air traffic.
1.2.8  U.S. Department of the Interior The U.S. Department of the Interior, Branch of Global Seismology has the capability to monitor and provide specific seismic activity data should such an event occur in the vicinity of the Fort Calhoun Station.

FCS EP-FC-1001 Section C Revision TBD EMERGENCY RESPONSE SUPPORT AND RESOURCES 1.3 Response Times It is anticipated that response time will be based on the level of assistance provided.
For example, information on upcoming weather conditions would be expected to be available in a matter of minutes over the telephone from the National Weather Service.
Conversely, radiological assistance from the Department of Energy would be expected to take considerably longer. It is expected that the federal assistance requested would be available within 8 to 72 hours.
2.0 RESOURCES TO SUPPORT RESPONDING AGENCIES Resources are provided by OPPD in order to support the various federal organizations which respond to an emergency as follows:
2.1 Air fields are available for the use of the radiological monitoring teams as follows:
2.1.1       Eppley Air Field, 18 miles South of Fort Calhoun Station, on Abbott Drive in Sector G.
2.1.2       Eagle Field (City of Blair's Air Field), seven (7) miles Southwest of Fort Calhoun Station on State Hwy. 133 in Sector K.
2.1.3       North Omaha Airfield, eleven (11) miles South Southeast of Fort Calhoun Station, on North 72nd street in Sector H.
2.2 A laboratory for radioisotopic analysis is available at the Fort Calhoun Station and Cooper Nuclear Station near Brownsville, Nebraska.
2.3 A laboratory for non-radiological chemical analysis is available at the Fort Calhoun Station and OPPD's North Omaha Power Station.
2.4 Onsite and offsite survey teams with necessary radiation monitoring instruments are available.
2.5 A boat is available for obtaining river samples.
2.6 Space and communication lines have been set aside to accommodate some federal agencies at the Control Room, Technical Support Center, Emergency Operations Facility, and Joint Information Center.
2.7 Electrical and communication access is available at the Emergency Operations Facility for the federal mobile analytical laboratory.

FCS EP-FC-1001 Section C Revision TBD EMERGENCY RESPONSE SUPPORT AND RESOURCES 3.0 SITE REPRESENTATIVES The Nebraska State Governor's Authorized Representative (GAR) reports to the state Field Command Post, located at OPPD's Emergency Operations Facility. The GAR is in direct contact with OPPD personnel and has the authority to approve and issue all protective actions for the public in the State of Nebraska.
The State of Iowa's Governor's Authorized Representative (GAR) typically remains in the State Emergency Operations Center. The Iowa GAR has the authority to approve and issue all protective actions for the public in the State of Iowa. A command and control telephone link exists between this position and OPPD's EOF. If personnel are available, an Iowa liaison is sent to work directly with the staff at the EOF.
An OPPD Site Representative is available for dispatch from the utility to the Iowa State EOC. This position can be staffed on a 24 hour a day basis.
4.0 RADIOLOGICAL ASSISTANCE 4.1 Nebraska Public Power District (Cooper Nuclear Station)
The Cooper Nuclear Station is capable of providing a backup facility in the event Fort Calhoun's radiochemistry laboratory is not functional. The Cooper Station's radiochemistry laboratory is equipped to do gross and isotopic determinations on radionuclides in concentrations and counting geometries necessary for nuclear power plant operation and emergency monitoring. They will provide analysis of liquid, air particulate and cartridges on a priority basis after receiving the sample.
Additionally, Cooper Station could provide monitoring teams equipped with air sampling, radiation and contamination monitoring equipment.
4.2 Contractor Assistance In the event of an emergency, it is anticipated that further assistance could be contracted directly from firms currently being utilized by OPPD for non-emergency work at the Fort Calhoun Station or through the assistance of such organizations as the Institute of Nuclear Power Operations (INPO).
4.3 The analysis of field monitoring data by the states is specified in each respective state plan. OPPD field monitoring data can be analyzed by an independent facility providing such services.

FCS                                                                  EP-FC-1001 Section D Revision TBD EMERGENCY CLASSIFICATION SYSTEM

==1.0 INTRODUCTION==

1.1 This section describes the emergency classification scheme adopted by the Omaha Public Power District for Fort Calhoun Station. The Emergency Classification scheme is based on NEI-99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors.
1.2 The State of Nebraska and the State of Iowa review the Fort Calhoun Station EALs once per year to ensure that they are consistent with their respective emergency classification schemes in their respective emergency plans. The purpose of this standardized classification is to provide a framework within which all emergency actions can be taken and notifications can be made in response to abnormal plant situations.
1.3 Table D-1 shows the projected worst case emergency classification for certain postulated accidents identified in the Fort Calhoun Station Updated Safety Analysis Report.
2.0 CLASSIFICATION OF EMERGENCIES 2.1 Emergency conditions are classified into one of four severity levels which cover the spectrum of postulated accidents. The postulated accidents range from precursors to potential degradation of plant safety to those involving actual failure of plant safety systems. Emergency preparedness, including a standardized classification system, is based primarily on preventing or minimizing radiation exposure to individuals onsite and offsite.
2.2 The specific Initiating Conditions (ICs) are contained within EP-FC-1001 Addendum 3, Emergency Action Levels For Fort Calhoun Station. The ICs are based on one or more of the key types of initiating conditions, including; symptom based, event based, barrier breach, and essential equipment/system(s) out of service. The ICs at Fort Calhoun Station are presented using six recognition categories as listed below:
R - Abnormal Rad Levels/Radiological Effluent C - Cold Shutdown/Refueling System Malfunction E - Events Related to ISFSI F - Fission Product Barrier Degradation H - Hazards and Other Conditions Affecting Plant Safety M - System Malfunction

FCS                                                                      EP-FC-1001 Section D Revision TBD EMERGENCY CLASSIFICATION SYSTEM 2.3 Each one of the recognition categories contains ICs as outlined in EP-FC-1001 Addendum 3, Emergency Action Levels For Fort Calhoun Station. Each specific IC is detailed in individual sections which contain predetermined, site-specific, observable thresholds, such as; instrument readings, equipment status indicators, measurable parameter(s), discrete and observable event(s), results of analysis, entry into specific emergency/abnormal procedures, applicable operating mode(s), and/or any other cautions and/or notes pertaining to that particular IC.
2.4 To the extent feasible, the ICs are based on readily available information such as Control Room instrumentation readings, Emergency Response Facility Computer System (ERFCS) output, specific station procedure steps, and/or dose projection results. The intent is to eliminate "ambiguity" for command and control positions in determining appropriate emergency classifications. Immediate actions to be taken in response to conditions involving abnormal plant operating parameters are detailed in the Fort Calhoun Station Abnormal Operating Procedures and Operating Instructions.
Other immediate actions and follow-up actions are identified in Section J of this plan and are described in detail in applicable Emergency Plan Implementing Procedures, listed in Appendix C of this plan.
2.5 The ICs do not signify the need for immediate implementation of protective or corrective measures. They do, however, signify the need for implementation of dose assessment measures both onsite and offsite and assessment of plant status, as applicable.
2.6 In using the ICs as the basis for initiating emergency response activity, there may be instances when the plant staff cannot determine which of two emergency classifications is appropriate for a particular occurrence. In those cases where the appropriate classification cannot be defined in a short period of time, the occurrence should be treated as the higher of the two classifications and the appropriate response for that level should be initiated.
2.7 Notification of Unusual Event 2.7.1      Notification of Unusual Event (NOUE) - Events are in process or have occurred which indicate a potential degradation of the level of safety of the plant 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 safety systems occurs. Some of these events could indicate a potential degradation in the level of plant safety and/or could escalate to a more severe condition if appropriate action is not taken.
2.7.2      The primary purpose for this classification is to ensure that the plant staff recognizes the initiating condition, takes appropriate action, such as assessment and verification, and comes to an appropriate state of readiness to respond in the event that the condition worsens.

FCS                                                                    EP-FC-1001 Section D Revision TBD EMERGENCY CLASSIFICATION SYSTEM 2.7.3    With the exception of possible assistance by local support groups such as fire departments or medical facilities, activation of offsite facilities by offsite organizations is not anticipated for events within this classification. The command and control position at Fort Calhoun Station has the option to call all or part of the Emergency Response Organization (ERO) for support at this emergency classification.
2.7.4    Notification of Unusual Event will be made to offsite authorities in accordance with Section E of this plan.
2.8 Alert 2.8.1    Alert - Events are in process or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of intentional malicious dedicated efforts of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels. It requires response by the onsite Emergency Response Organization which augments on-shift emergency resources, and constitutes a standby initiation of the offsite emergency plan provisions. Generally, offsite emergency response agencies notify their key staff, and may begin to activate offsite response such as activation of facilities and offsite radiological monitoring. Offsite agencies will maintain this level of preparedness until termination or escalation of the Alert classification.
2.8.2    OPPD will augment the Control Room, staff the Technical Support Center and Operations Support Center at the Alert level. Typically, the Emergency Operations Facility staff will also be augmented to be placed in "standby" mode, ready to assume Command and Control if necessary.
2.8.3    Notification to offsite authorities of the Alert will be made in accordance with Section E of this plan.
2.9 Site Area Emergency 2.9.1    Site Area Emergency - Events are in process or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or security events that result in intentional damage because of intentional malicious dedicated efforts of HOSTILE ACTION; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) prevents effective access to, equipment needed for the protection of the public. Any releases are not expected to result in exposure levels that exceed EPA Protective Action Guideline exposure levels beyond the site boundary.
Offsite response agencies are fully mobilized along with notification to the general public by the sounding of the Alert Notification System (ANS) sirens surrounding the plant site.

FCS                                                                   EP-FC-1001 Section D Revision TBD EMERGENCY CLASSIFICATION SYSTEM 2.9.2    OPPD staffs all designated Emergency Response Facilities at a Site Area Emergency or General Emergency. The full Emergency Response Organization will be activated.
2.9.3    Notification to offsite authorities of the Site Area Emergency will be made in accordance with Section E of this plan.
2.10 General Emergency 2.10.1   General Emergency - Events are in process or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity or security events that result in an actual loss of physical control of the facility. Release can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area. Total activation of the onsite and offsite emergency response organizations is required. Protective actions involving offsite populations are highly probable.
2.10.2   OPPD staffs all designated Emergency Response Facilities at a Site Area Emergency or General Emergency. The full Emergency Response Organization will be activated.
2.10.3   Notification to offsite authorities of the General Emergency will be made in accordance with Section E of this plan.

FCS                                                                EP-FC-1001 Section D Revision TBD EMERGENCY CLASSIFICATION SYSTEM Table D Emergency Classification of Postulated Accidents Projected Worst Postulated Accident         Case Emergency                   Key Concern Classification Fuel Handling Accident General Emergency             Radiological Effluents (in Spent Fuel Pool Area)
Gas Decay Tank Rupture         Site Area Emergency            Radiological Effluents Waste Liquid Incident                  Alert                  Radiological Effluents Control Room Habitability During Toxic Chemical                  Alert                      Plant Control Release Accident

FCS EP-FC-1001 Section E Revision TBD NOTIFICATION METHODS AND PROCEDURES 1.0   PURPOSE AND SCOPE 1.1   Purpose 1.1.1      The purpose of this PSRERP is to provide guidance for notifying state and local response organizations, the Nuclear Regulatory Commission, and members of the OPPD Emergency Response Organization during radiological emergencies.
1.2   Scope 1.2.1      This PSRERP applies to OPPD Emergency Response Organization personnel responsible for notifying state and local response organizations, the Nuclear Regulatory Commission and members of the OPPD Emergency Response Organization during a radiological emergency.
2.0   PROCEDURE 2.1   Notifications 2.1.1      The decision to make notifications is based on the emergency action levels and corresponding emergency classifications described in Section D of this Plan. As discussed in that section, they are consistent with NEI-99-01, Development of Emergency Action Levels for Non-Passive Reactors, which has been approved by the NRC replacing NUREG-0654, Rev. 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Appendix 1. The EALs are reviewed annually by the States of Nebraska and Iowa.
2.1.2      OPPD is capable of notifying and activating its Emergency Response Organization 24 hours per day. It is also able to make notifications to the states, Nuclear Regulatory Commission and, if required, local counties on a 24 hour per day basis. The applicable state plans detail the provisions for 24 hour per day notification and activation of their response organizations.
2.1.3      The Command and Control position is responsible for ensuring appropriate notifications are initiated when an emergency is classified. Fort Calhoun Station personnel in the protected area are notified via the Emergency or Fire Alarm and a public address system message. Personnel outside the protected area are notified by public address systems installed in the Administrative and Training buildings. Site Security personnel may assist in the notification of all other personnel on OPPD property. The OPPD Emergency Response Organization is activated as appropriate for the emergency classification level. This is accomplished by an automated call-out system which activates phone calls, text messages, e-mails, and other functions. Maintenance of telephone numbers is discussed in Section P of this Plan.
2016

FCS EP-FC-1001 Section E Revision TBD NOTIFICATION METHODS AND PROCEDURES 2.1.4  Initial notification of the states of Nebraska and Iowa is made within 15 minutes after declaration of an emergency classification. The states, in turn, notify other governmental response agencies as appropriate for the emergency classification. Notification is also made to Washington, Harrison, and Pottawattamie counties within 15 minutes.
2.1.5  The primary means of notification to the states and counties is via the Conference Operations Network (COP) which is a dedicated telephone system. The COP and backup communications systems are discussed in Section F of this plan. Provisions have been made for verification of notification messages when communications are via means other than the COP.
2.1.6  Notification to the NRC is the next contact made. This notification occurs immediately after state and local notifications, not to exceed one hour after the declaration of the emergency classification. The primary means for this notification is the Federal Telecommunications System, Emergency Notification System lines (FTS-ENS). The FTS-ENS system is maintained by the NRC, however, it is routinely tested by OPPD. If the FTS-ENS is not available, notifications are made using the normal commercial telephone system.
2.2   Emergency Messages 2.2.1  Initial Emergency Message The Omaha Public Power District and the states of Nebraska and Iowa have established the contents of the initial emergency messages to be sent from Fort Calhoun Station in the event an emergency is declared. These messages contain such information as the class of emergency, whether a release is taking place, potentially affected population and areas, and whether protective measures may be necessary. This information is transmitted by a dedicated telephone system, normal telephone systems or by facsimile. Forms are used to record the information for verbal or hard copy transmission to ensure each organization receives identical information.
2016

FCS EP-FC-1001 Section E Revision TBD NOTIFICATION METHODS AND PROCEDURES 2.2.2   Follow-Up Emergency Messages A. The follow-up emergency messages to the states incorporate the majority of the elements of Criteria E.4 of NUREG 0654, Rev. 1, as determined necessary by the states. These messages are transmitted to the states by telephone, dose assessment computer or facsimile.
Update messages are sent to the states and counties at least every 60 minutes. Updates may be decreased to shiftily during ongoing events if requested by the states and the status of the event has not changed.
B. It is the goal of Fort Calhoun to attempt to provide dose assessment updates at 15 minute intervals during a Radiological Release. During a Site Area Emergency or General Emergency, the Conference Health Physics (CHP) Network, a dedicated telephone system, can be used to maintain communications as needed. This ensures rapid transmittal of dose assessment information and protective action recommendations to the states.
C. Emergency information to the county Emergency Operations Centers (Washington, Harrison and Pottawattamie Counties) is given verbally using the Conference Operation (COP) Network. These messages discuss general conditions of the plant.
D. The NRC will be kept informed as significant events occur which warrant the upgrading or downgrading of the emergency classification. These communications with the NRC will be via the NRC's FTS-ENS (Emergency Notification System). Dose Assessment personnel will keep the NRC informed of dose assessment information using the NRC's FTS-HPN (Health Physics Network).
E. OPPD has the capability to transmit key plant parameter information directly to the NRC. This system is entitled the Emergency Response Data System (ERDS). This system is normally activated and will be verified to be functioning within one hour of declaring an Alert or higher.
Initiation of this system can be accomplished in either the Control Room or the Technical Support Center.
F. Requests for assistance from local support agencies, and others, are made using normal telephone systems.
2016

FCS EP-FC-1001 Section E Revision TBD NOTIFICATION METHODS AND PROCEDURES 2.3   Alert Notification System 2.3.1     A system called the Alert Notification System (ANS) has been designed to provide warning to the public within 15 minutes of the decision by offsite authorities to activate the system. The system includes a series of sirens which provide essentially 100 percent coverage of the population within 10 miles of Fort Calhoun Station.
2.3.2     The states Emergency Response Plans provide guidance as to when the system should be activated. The counties will then perform the actual activation.
2.3.3     Each county has control of only the sirens located within its borders. The exception is one siren which is located in Douglas County, but activated by Washington County. All sirens within a county are sounded simultaneously, and cannot be activated individually.
2.3.4     The sirens are activated by radio signal. The county agencies and the activation locations for the sirens are as follows:
A. Washington County Emergency Communications Center located in the County Court House, Blair, Nebraska.
B. Harrison County Emergency Communications Center located in the County Jail Complex, Logan, Iowa.
C. Pottawattamie County Emergency Communications Center located in the County Court House, Council Bluffs, Iowa.
These locations are continuously staffed, providing the capability to activate the siren system 24 hours per day.
2.3.5     The Omaha Public Power District has made provisions to sound the sirens when requested to do so by government officials, should a county be unable to activate its sirens. This process can be accomplished from the Emergency Operations Facility or the E.O.-Communications division offices.
2.3.6     It is not intended that county or city governments use the ANS for weather alerts or fire signals as frequent use of the system for other purposes would tend to reduce the effectiveness of the sirens if they are needed for a nuclear power plant incident.
2.3.7     In the event that one or more sirens activates during non-emergency conditions, provisions have been made to inform the public that no emergency exists, and initiate repairs to the errant siren(s).
2016

FCS EP-FC-1001 Section E Revision TBD NOTIFICATION METHODS AND PROCEDURES 2.3.8  System operability is tested periodically in accordance with the updated design report to FEMA for the outdoor public warning system and backup alert and notification.
2.3.9  Backup ANS for the EPZ is achieved through route alerting by the affected county.
2.4   Emergency Alert System 2.4.1  Members of the public have been instructed (via the Emergency Planning Booklet discussed in Section G of this Plan) to tune to their Emergency Alert System (EAS) station for emergency instructions when the sirens are activated.
2.4.2  Radio station KGOR- 99.9 FM is the Local Primary I (LP1) control station for Omaha, NE. It has the capability to broadcast emergency instructions 24 hours per day. Most other television and radio broadcast stations have the capability of carrying EAS messages during their normal hours of broadcasting.
2.4.3  For messages the risk counties will contact the National Weather Service (NWS) and request that EAS be activated. The NWS will then send out the signal to activate the EAS. KGOR has agreed to pick up this signal and broadcast the message.
2.4.4  While follow-up messages are the responsibility of the states, Omaha Public Power District has the capability to make similar information releases to the media. This is described in Section G of this plan.

==3.0   REFERENCES==
AND COMMITMENTS 3.1   NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plant 2016

FCS                                                                 EP-FC-1001 Section F Revision TBD EMERGENCY COMMUNICATIONS

==1.0 INTRODUCTION==

This section describes the available communications for use among the principal response organizations and between the Omaha Public Power District emergency response facilities. Provisions for 24-hour per day notification to and activation of the state and local emergency response organizations are discussed in Section E of this plan. Also discussed in Section E are the provisions for activating Omaha Public Power District emergency response personnel. Provisions for periodic testing of the emergency communications system are described in Section N of this plan.
2.0 COMMUNICATIONS SYSTEMS 2.1 A number of varied communications systems are available for communications between emergency response facilities. These systems are described in this section and are summarized in Figure F-1.
2.2 In the conduct of drills and exercises, OPPD may make use of its training simulator to provide a broad range of Control Room like amenities, without impacting the operating FCS Control Room. The communications equipment in the FCS Control Room is, for the most part, duplicated in the simulator.

FCS                                                                EP-FC-1001 Section F Revision TBD EMERGENCY COMMUNICATIONS 2.3 Each emergency response facility and the personnel responsible for 24 hour communications in each facility is listed below:
Primary/Alternate Communications Emergency Facility Responsibility Control Room Fort Calhoun Station        Shift Manager/Control Room Operator TSC, Fort Calhoun Station                Site Director Emergency Director/EOF COP EOF, North Omaha Station Communicator EOC, State of Nebraska                   Operations Officer/Communications and Warning Officer Forward Command Post, State of           Nebraska Emergency Management Agency Nebraska                                 Director/Asst Nebraska Emergency Management Agency Director EOC, Washington Cnty (Nebraska)          Washington County Communications Center/County Emergency Management Director EOC, State of Iowa                       Director, Iowa Emergency Management Division/National Guard Adjutant General Forward Command Post State of            Harrison County Sheriffs Department/State Iowa                                     Liaison Officer EOC, Harrison County (Iowa)              Communications Director/Harrison County Sheriff's Department EOC, Pottawattamie County (Iowa)         Communications Director/County Emergency Management Director 2.4 Fort Calhoun Station Alarm System 2.4.1    Emergency and Fire Alarms These alarms are sounded from the Control Room when an emergency requiring ERO activation or fire is declared. Their function is to alert personnel within the Protected Area to an emergency condition.
2.5 Fort Calhoun Station Paging Systems 2.5.1    The Protected Area paging system (Gaitronics) provides a means of intra-plant communications. Stations on this system provide access to the plant paging system and to intercom lines. These stations and speakers are placed throughout the plant including the Control Room, the Technical Support Center and the Operations Support Center.
2.5.2    The Administrative and Training buildings at the Fort Calhoun Station also

FCS                                                                  EP-FC-1001 Section F Revision TBD EMERGENCY COMMUNICATIONS have public address announcing capabilities. Access to the public address system in either or both locations can be accomplished via the sites telephone system. This system can be used to notify personnel of a plant emergency.
2.6 Local Private Automatic Branch Exchanges (PABX) 2.6.1     Omaha Public Power District PABXs A. Company telephone systems link Omaha Public Power District facilities with those located in Omaha, Nebraska. These systems provide intracompany telephone communications and access to the public telephone network.
B. The Emergency Operations Facility has installed lines designated for emergency use. These lines are dedicated to specific emergency response positions. Telephone sets for all lines are available in the Emergency Operations Facility.
C. Trunk lines between the company PABX systems in Omaha and the Fort Calhoun Station PABX systems provide the primary means of communication with the plant. Additional lines can be provided by the local telephone company, as requested.
D. This system also provides a redundant means of providing emergency notifications to the states and counties, and is the primary backup to the Conference Operations Network (COP).
2.6.2     Fort Calhoun Station PABXs A. These dedicated telephone systems provide communications within Fort Calhoun Station locations.
B. The Technical Support Center has designated extensions for use during an emergency. They include extensions designated for use by NRC personnel. Additional lines can be diverted from other office areas as required.
C. Dedicated lines from this system are extended to the Emergency Operations Facility. This system is also connected to the company telephone system in Omaha to provide intracompany telephone communications which are not affected by the public telephone network.
D. Redundant routing of access to the public telephone network is provided via links to the public system in Blair, Nebraska as well as Omaha.
2.7 Conference Operations (COP) Network

FCS                                                                 EP-FC-1001 Section F Revision TBD EMERGENCY COMMUNICATIONS 2.7.1    The COP system is primary emergency notification system between OPPD, state and county agencies. It is used to provide, initial, and update notifications and for general information flow between these agencies. See Figure F-1 for a list of COP locations.
2.7.2    COP is a dedicated system; each location is capable of making group calls or calling station to station within the network. See Figure F-2 for a system diagram.
2.7.3    A recorder located at the EOF records all conversations on the COP system.
The Nebraska State Patrol and the Iowa Dispatcher also have voice recording capability.
2.8 Conference Health Physics (CHP) Network 2.8.1    This network provides a dedicated means for communicating radiological information between the Technical Support Center, Emergency Operations Facility, Nebraska and Iowa Emergency Operations Centers and the Nebraska and Iowa Radiological Emergency Response Team Coordinators.
The system is shown on Figure F-3.
2.8.2    This system provides the capability for conference conversations between the Technical Support Center or Emergency Operations Facility and any one or all of the agencies on the system. A voice recorder in the Emergency Operations Facility provides a record of conversations on this system.
2.9 Facsimile (FAX) Capability 2.9.1    Facsimile machines provide the capability to link the Control Room, Technical Support Center, Operations Support Center, Emergency Operations Facility, Joint Information Center, other OPPD Headquarters facilities, the Nebraska and Iowa Emergency Operations Centers and the Nebraska and Iowa Forward Command Posts. Capability also exists to access any FAX machine via commercial telephone networks.
2.9.2    The facsimile machines can be used to transmit health physics, operational and dose assessment information from Omaha Public Power District emergency response facilities to state emergency response facilities. They can also be used to disseminate emergency status information to OPPD management. Some of these extensions have voice capabilities and serve as a backup means of voice communications for those locations.

FCS                                                                    EP-FC-1001 Section F Revision TBD EMERGENCY COMMUNICATIONS 2.10 800 MHz Radio System 2.10.1     A 800 MHz radio communications system links Fort Calhoun Station onsite emergency response facilities, Emergency Operations Facility, plant portable radios, and mobile radios used by radiological monitoring teams. The multi-talk group/channel system is illustrated by Figures F-6, F-7, F-8, F-9 and F-10.
2.10.2     Figure F-6 illustrates the talk groups available for the Fort Calhoun Station.
Figure F-7 illustrates the dedicated subfleet for the Emergency Response Organization. Figure F-8 illustrates the shared subfleet which the ERO can utilize during emergencies. Figure F-9 provides the details for the "Talk-Around" capability which can be utilized when the 800 MHz trunking system is out of service. Figure F-10 summarizes the subfleets assigned to the Fort Calhoun Station.
2.11 NRC Emergency Notification System (FTS-ENS) 2.11.1     This NRC Operations Center is contacted via this telephone network. The FTS-ENS is a portion of the Federal Telecommunications System (FTS) and is located in the Control Room, Technical Support Center and Emergency Operations Facility. It provides plant operations information to the NRC Operations Center, in Rockville, Maryland.
2.12 NRC Health Physics Network (FTS-HPN) 2.12.1     The FTS-HPN is a portion of the Federal Telecommunications System (FTS) and is located in the Technical Support Center and Emergency Operations Facility. The network is used to exchange radiological and dose assessment information between NRC facilities and OPPD.
2.13 Priorities System 2.13.1     The Technical Support Center establishes priorities for accident mitigation and transmits the priorities to the Operations Support Center and the Emergency Operations Facility for display.
2.14 State of Nebraska Emergency Management Radio System 2.14.1     The Emergency Operations Facility is equipped with various radio equipment for use by Nebraska Emergency Management personnel. This equipment may be used either alone or in conjunction with the State of Nebraska Emergency Management Mobile Van.

FCS                                                                   EP-FC-1001 Section F Revision TBD EMERGENCY COMMUNICATIONS 2.15 State of Iowa Emergency Management Radio System 2.15.1    The Emergency Operations Facility can support radio equipment for use by Iowa State Emergency Management personnel. This equipment may be used either alone or in conjunction with the State of Iowa Emergency Management Mobile Van.
2.16 Management Operations (MOP) Network 2.16.1    This system (similar to the COP and Ops Liaison Network) provides dedicated conference capability between the Control Room, TSC Site Director, OSC Director, EOF Emergency Director and the JIC Manager. The purpose of the system is to provide information flow between the directors of all the emergency facilities.
2.16.2    The system allows conferencing without dialing, each set is capable of conferences and individual call capability. Records of conversations on this system are captured by a voice recorder in Emergency Operations Facility.
2.17 Joint Information Center Hot Line 2.17.1    A dedicated telephone circuit is provided between the Emergency Operations Facility and Joint Information Center. The telephone sets are equipped with a blank dial plate. Lifting either handset causes a connecting ring at the other set.
2.17.2    This system provides a means for uninterrupted private communications for coordination of information releases to the public.
2.18 NAWAS 2.18.1    NAWAS equipment in the Control Room provides a redundant means of providing emergency notifications to the States of Nebraska and Iowa. It also provides the Control Room personnel with weather information.
2.19 Emergency Response Message System (ERMS) 2.19.1    A network of computer terminals is used to link the Technical Support Center, Operations Support Center and Emergency Operations Facility. It provides rapid dissemination of plant status information between facilities and ensures consistency of information at all facilities. The JIC is also equipped with a monitor which provides read-only capability. The software used for this function can be any type that provides for electronic log keeping of emergency response actions (WebEOC, ERMS, etc.)

FCS                                                                  EP-FC-1001 Section F Revision TBD EMERGENCY COMMUNICATIONS 2.20 Telephone Service Pedestal for State Mobile Communication Vehicles 2.20.1   A telephone service pedestal is located outside of the Emergency Operations Facility near the designated parking area for the mobile communication vehicles. This pedestal is fed by a 12-pair cable from the Emergency Operations Facility and allows quick connection of various telephone facilities to the mobile vehicles. Several telephone lines and dedicated communication facilities are prewired and operational. Spare pairs are available to add additional telephone facilities quickly as the need arises.
2.21 Telephone Junction Box for NRC Mobile Vehicle 2.21.1   A telephone junction box is located on the outside wall of the Emergency Operations Facility near the designated parking area. This junction box is fed by a 12 pair cable and is equipped with four standard modular telephone jacks. These jacks are prewired to a distribution frame and allow quick connection of telephone lines to support the NRC as required. Additional jacks can be added up to the 12 pair capacity of the feeder cable.
2.22 Operations Liaison Network 2.22.1   This system provides dedicated conference capabilities between the Fort Calhoun Station Control Room/Simulator, TSC, OSC, EOF and JIC. The purpose of the system is to provide operational information from the Control Room to the other facilities for the purpose of developing response plans, determining emergency classifications and implementing assistance to the Control Room.
2.22.2   The system allows conferencing without dialing, and thus permits rapid access to the conference by the Operations Liaisons. Each station is equipped with group call and individual call capability. Records of conversations on this system are captured by a voice recorder in the Emergency Operations Facility.
2.23 Emergency Response Data System (ERDS) 2.23.1   This system provides selected ERFCS data to the NRCs Operations Center for the purpose of evaluating plant conditions. Certain data points from the ERFCS are included in the ERDS data library, and when activated, these data points are transmitted to the Operations Center. The system is normally activated and is required to be activated at an ALERT or higher classification.

FCS                                                                  EP-FC-1001 Section F Revision TBD EMERGENCY COMMUNICATIONS 2.24 Interactive Notification System (INS) 2.24.1     This system provides rapid notification to Emergency Response Organization personnel in the event of an emergency where the ERO is activated. The system is also used to perform the Management Notification function, and can be adapted to perform other notification functions as determined necessary by the Fort Calhoun Station. A backup ERO notification process is available in the event of failure of the INS.
2.24.2     The system is activated using the internet or contacting a live operator, normally from the Control Room. The system 1) initiates a call-out to ERO members at home, mobile, or work locations, 2) sends text messages to ERO positions that provide a contact number and 3) sends e-mails to ERO personnel.
2.25 Satellite Phones 2.25.1     Satellite Phones are located in the Control Room, Technical Support Center, and Emergency Operations Facility to serve as an alternate communications option in the event normal communications equipment is unavailable.
3.0  COMMUNICATIONS WITH MEDICAL SUPPORT FACILITIES 3.1  Fort Calhoun Station emergency response organization personnel can communicate with medical support facilities, Washington County Emergency Communications Center or the University of Nebraska Medical Center, via the site telephone systems described earlier in this section.
3.2  Non-OPPD radio systems provide communications between medical support facilities and mobile rescue units as well as inter-unit communications. These radio systems have the capability to use the common medical emergency frequency which ensures coordinated communications.

EP-FC-1001 Section F FCS                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             Revision TBD EMERGENCY COMMUNICATIONS Figure F Summary of Communications Systems Dodge County - Washington County Control Room Control Room Simulator (Training)
Technical Support Center   Operations Support Center   Emergency Operations Facility Joint Information Center FCS Security OPPD Headquarters OPPD Field Monitoring Teams Nebraska EOC Nebraska FCP (North Omaha EOF)
Nebraska State Patrol   Washington County EOC Backup EOC Iowa EOC Iowa FCP (Harrison County EOC)
Iowa Dispatch (Fort Dodge)   Harrison County EOC   Pottawattamie County EOC NRC - Headquarters   NRC - Region IV Drill Communications (Admin 1D)                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             NRC - Resident Inspectors FCS Plant Paging (Gai-Tronics)
OPPD PABXs FCS PABXs Commercial Telephone Systems COP Network (Notifications)
CHP Network (HP Information)
FTS-ENS Phones (NRC)
FTS-HPN Phones (NRC)
Available Fax Machines OPPD 800 MHz Radio System JIC Hotline NAWAS Electronic Emergency Logs MOP Network State of Nebraska Radio State of Iowa Radio Law Enforcement Radios Operations Liaison Network ERDS INS Satellite Telephone

EP-FC-1001 Section F FCS                                                                       Revision TBD EMERGENCY COMMUNICATIONS Figure F Conference Operations Network

EP-FC-1001 Section F FCS                                                                           Revision TBD EMERGENCY COMMUNICATIONS Figure F Conference Health Physics Network

EP-FC-1001 Section F FCS                                                                     Revision TBD EMERGENCY COMMUNICATIONS Figure F MOP (Management Operations)

EP-FC-1001 Section F FCS                                                                    Revision TBD EMERGENCY COMMUNICATIONS Figure F Operations Liaison Network

FCS                                                        EP-FC-1001 Section F Revision TBD EMERGENCY COMMUNICATIONS Figure F OPPD/Fort Calhoun Station 800 MHz Radio System

FCS                                                         EP-FC-1001 Section F Revision TBD EMERGENCY COMMUNICATIONS Figure F Fort Calhoun Station Subfleet - SF4

FCS                                                         EP-FC-1001 Section F Revision TBD EMERGENCY COMMUNICATIONS Figure F Fort Calhoun Station Subfleet - SF5

FCS                                                          EP-FC-1001 Section F Revision TBD EMERGENCY COMMUNICATIONS Figure F Fort Calhoun Station Talk-Around Channel (TA)

FCS                                                       EP-FC-1001 Section F Revision TBD EMERGENCY COMMUNICATIONS Figure F Summary of 800 MHz Radio Uses Channel     Display               Normal Use               Emergency Use 1       SF1 Sec 1            Security-Primary           Security-Primary 2       SF2 Sec 2           Security-Secondary         Security-Secondary 3        SF3 Ops                Operations                 Operations 4        SF4 EP             Emergency Planning         Field Team Control 5        SF5 RP             Radiation Protection     In-Plant Team Control 6       SF6 Maint.             Maintenance           In-Plant Team Control 7       SF7 ERO             Emergency Planning        Emergency Planning 8      SF8 Work Ch            Work Channel              Available for Use 9      SF9 EP Cntlr            EP Controller            Available for Use 10        Spare 1                   Future 11        Spare 2                   Future 12        Spare 3                   Future 13      Talk Around             Talk Around              Emergency Use 14     Unprogrammed             Not Available              Not Available 15     Unprogrammed             Not Available              Not Available 16     Unprogrammed             Not Available              Not Available

FCS                                                                      EP-FC-1001 Section G Revision TBD PUBLIC EDUCATION AND INFORMATION 1.0  PUBLIC INFORMATION CONTENT AND DISSEMINATION 1.1  Public Information Content The Omaha Public Power District (OPPD) Corporate Communications Division has coordinated with the States of Nebraska and Iowa in the preparation and dissemination of educational information. A brochure entitled Fort Calhoun Nuclear Station Emergency Planning Information incorporates the following information:
1.1.1      A description of natural background and manmade radiation, including estimated annual doses from various sources of radiation.
1.1.2      Public warning procedures and use of radio and television following an emergency at the Fort Calhoun Station.
1.1.3      Radiation protection, including such protective actions as in-house sheltering and evacuation.
1.1.4      Special evacuation notes, including special needs of the handicapped, medical and nursing home patients, registration centers, evacuation routes and a Sub Area map of the EPZ.
1.1.5      Information concerning the primary Emergency Alert System.
1.1.6      Additional protective actions including ad hoc respiratory protective devices.
1.1.7      A list of contact points to obtain additional information.
1.2  Public Information Dissemination The Public Information Brochure is distributed in written form annually by mail to the permanent adult population within an approximate 10-mile radius of Fort Calhoun Station. A general distribution to reach the transient population is achieved by posting information in public areas and by placing supplies of prepared written material in motels, service stations, and government buildings. Media advertisements, utility bill inserts, telephone tape messages, news releases, and public seminars may also be utilized for public education and information.
An Emergency Planning recurring task verifies the content and dissemination of this information.

FCS                                                                       EP-FC-1001 Section G Revision TBD PUBLIC EDUCATION AND INFORMATION 2.0  NEWS MEDIA COORDINATION AND FACILITIES There are two (2) locations available for use of the news media. The Joint Information Center (JIC) is the primary facility for the release of all information; the Emergency Operations Facility (EOF) has limited space for press briefings and may be used on a selective basis. The Corporate Crisis Communication Plan provides the guidance for the operation of the Joint Information Center during emergencies. This plan is reviewed annually in accordance with an Emergency Planning Test.
2.1  Joint Information Center (JIC)
The primary information point is the Joint Information Center located within OPPDs Energy Plaza at 444 South 16th Street Mall, Omaha, Nebraska. This center is activated for either a Site Area Emergency or General Emergency and will accommodate Joint Information Center personnel as well as local, State and Federal public information personnel.
For Classifications below Site Area Emergency, the Division Manager-Corporate Communications shall determine the corporate response for media coordination efforts.
The Joint Information Center also serves as the public inquiry center for OPPD, State and Federal authorities.
2.2  Emergency Operations Facility Briefing Room A secondary facility is located in the Emergency Operations Facility located at the North Omaha Power Station. However, the Joint Information Center is the preferred point of news media information.
The EOF Briefing Room was constructed as working space for 25 news correspondents. It is anticipated that space in this facility will be for the local media which routinely cover OPPD activities. Remaining space will be allocated to the national and regional media on a pool basis.

FCS                                                                  EP-FC-1001 Section G Revision TBD PUBLIC EDUCATION AND INFORMATION 3.0  EMERGENCY CLASSIFICATION INFORMATION RELEASES Following the classification of an emergency, Corporate Communications Division representatives will be informed of the emergency action level invoked at the plant and the reason or reasons thereof. Once such notification has been made, release of information to the news media will be coordinated by the Division Manager - Corporate Communications or the Joint Information Center Manager. That position will also coordinate the timely exchange and release of information with the official spokespersons for Federal and State agencies. The JIC Manager will report directly to the Emergency Director. A JIC Technical Liaison at the Joint Information Center will assist in nuclear related information matters. The JIC Technical Liaison will also be in direct contact with the EOF Information Specialist or the EOF Technical Liaison who will provide prompt and accurate information regarding plant status. The Corporate Crisis Communication Plan activates and augments the JIC staff. During all emergency classifications, the Corporate Spokesperson is the official designated spokesperson for OPPD.
4.0  NEWS MEDIA EXPOSURE TO EMERGENCY PLANNING INFORMATION The Corporate Communications Division mails an annual information packet or conducts an annual seminar to acquaint the local news media with the operation of Fort Calhoun Station and its emergency plan, including the public information procedures to be followed in an emergency. The mailing\seminar also provides educational information concerning radiation, and nuclear related subjects deemed appropriate. An Emergency Planning recurring task verifies the transmittal of the information packet or conduct of the seminar to the local news media outlets.

FCS                              EP-FC-1001 Section G Revision TBD PUBLIC EDUCATION AND INFORMATION

FCS                                                                      EP-FC-1001 Section H Revision TBD EMERGENCY FACILITIES AND EQUIPMENT NOTE This section lists the Emergency Response Facilities (ERF) available for i   activation in the event of an emergency at the Fort Calhoun Nuclear Station, including the ISFSI. General equipment and staffing of emergency            i facilities are also included in this section. Communications equipment is covered in Section F. Assessment equipment is covered in Section I.
1.0   TECHNICAL SUPPORT CENTER (TSC) 1.1   Facility Function and Description 1.1.1      The TSC's primary function is the collection, analysis, and distribution of technical data required to support plant personnel during an emergency.
This support is provided from a separate and distinct center, thus reducing personnel congestion in the Control Room. The TSC has the capability to perform EOF functions and responsibilities until that facility can be fully activated.
1.1.2      The TSC building is located on the north side of the Auxiliary Building. (See Figure H-1). The north wall of the auxiliary building is shared as the south wall of the TSC. To the east of the building is the maintenance shop. To the north and west of the TSC is the Chemistry/Radiation Protection Building.
The TSC building was designed to meet the criteria of NUREG 0696 and is less than a two minute walk from the Control Room.
1.1.3      The TSC is composed of a protected area and an equipment area. It is comprised of heavy concrete mat construction with 1-1/2 foot thick reinforced concrete walls and ceiling. This part of the structure is kept at positive pressure and the building air can be filtered through a pre-filter, HEPA filter and charcoal filter. Flood barriers in various locations of the plant protect the TSC from flooding and are designed for a 100 year recurrence frequency.
1.1.4      An "L" shaped equipment area is located to the east and south of the TSC protected area. The equipment area has concrete footings and common steel construction with concrete block walls. Items included in the equipment area are the batteries and UPS power distribution systems, HVAC and HEPA filters.

FCS                                                                  EP-FC-1001 Section H Revision TBD EMERGENCY FACILITIES AND EQUIPMENT 1.2 Equipment and Supplies 1.2.1  The TSC is typically equipped with the following items:
A. System Drawings for the nuclear power plant and the ISFSI B. Vendor Manuals C. An official copy of the Fort Calhoun Station Operating Manual. (This includes the Operating Procedures and Instructions, the Post Shutdown Radiological Emergency Response Plan and Emergency Plan Implementing Procedures.
D. Updated Safety Analysis Report (USAR) for the nuclear power plant and the NUHOMS Storage System FSAR for the ISFSI (electronically)
E. Technical Specifications for the nuclear power plant and the ISFSI (electronically)
F. Direct and Airborne Radiation Monitoring Equipment which is permanently installed:
: 1. Area Monitor (RM-093):
The area monitor in the TSC is a GM detector (or equivalent) that detects gamma radiation.
: 2. Particulate, Iodine and Noble Gas (PING) Monitor:
The sampler and detector subsystem contains a combined particulate, iodine and noble gas sampler in one compact, lead-shielded assembly. Three read-outs contain all alarm functions of alert, high and failure, along with check source actuation controls.
The PING is piped directly to the TSC ventilation system to monitor TSC supply air at all times.
G. Emergency Response Facilities Computer System/Safety Parameter Display System (ERFCS/SPDS).
H. Personal Computer(s) with printers.
I. Emergency Response Message System.
J. Sign-in Board with identification tags.
K. Emergency logs.
L. Status boards.

FCS                                                                       EP-FC-1001 Section H Revision TBD EMERGENCY FACILITIES AND EQUIPMENT M.       The ability to provide output displays to the OSC and EOF.
1.3 Staffing 1.3.1     The TSC affords ample space and equipment to support the Emergency Response Organization (ERO) as stated in Section B and additional TSC personnel as defined in the Fort Calhoun ERO Roster. In addition, space has been allocated for NRC representatives.
2.0 EMERGENCY OPERATIONS FACILITY (EOF) 2.1 Facility Functions and Description 2.1.1     The function of the Emergency Operations Facility is to serve as the support facility for the licensee's overall management of emergency response activities (including coordination with Federal, State and local officials), the central collection and coordination point for all off-site radiological and environmental samples and assessments in order to make public protective action recommendations (PARs).
2.1.2     The Emergency Operations Facility is located 17 miles from the Fort Calhoun Station at the North Omaha Power Station. This site was chosen to ensure continuous habitability and is the only Emergency Operations Facility in the district. The building is capable of providing working space for a minimum of 35 persons consistent with the requirements of NUREG-0696, Revision 1.
Space for data systems equipment, communications and storage activities is also available.
2.1.3     The alternative facility maintains the capability for staging the TSC/OSC emergency response organization personnel in the event of a hostile action.
The alternative facility has the capability for communications with the control room, and plant security; the capability to perform offsite notifications; and the capability for engineering assessment activities. The EOF will satisfy the offsite notification responsibilities for the alternative facility. The EOF staff will support offsite notification responsibilities while the TSC/OSC ERO are performing activities supported by the alternate facility. The alternate facility is co-located with the EOF at OPPDs North Omaha Station.

FCS                                                                EP-FC-1001 Section H Revision TBD EMERGENCY FACILITIES AND EQUIPMENT 2.2 Equipment and Supplies 2.2.1    The EOF is typically equipped with the following emergency response items:
A. Emergency Status Boards B. 10-Mile EPZ Maps C. Emergency Monitor Kits D. Assignment Board with identification tags E. Portable Calculator(s)
F. Emergency Telephone Books G. Emergency Logs H. Personal Computers and Printers I. Technical Specifications for the nuclear power plant and the ISFSI (electronically)
J. System Drawings for the nuclear power plant and the ISFSI K. Complete latest revision of the Fort Calhoun Station Operating Manual.
(This includes the Operating Procedures and Instructions, the Post Shutdown Radiological Emergency Response Plan and Emergency Plan Implementing Procedures).
L. Emergency Response Facilities Computer System/Safety Parameter Display System (ERFCS/SPDS)
M. Emergency Response Message System (ERMS) 2.3 Staffing 2.3.1    The EOF affords ample space and equipment to support the Emergency Response Organization as stated in Section B. In addition, space has been allocated for NRC Representatives.

FCS                                                                   EP-FC-1001 Section H Revision TBD EMERGENCY FACILITIES AND EQUIPMENT 3.0 OPERATIONS SUPPORT CENTER (OSC) 3.1 Facility Function and Description 3.1.1     The Operations Support Center (OSC) is an onsite facility, separate from the Control Room (CR) and the Technical Support Center (TSC) where support personnel assemble and prepare to perform investigative or corrective actions as deemed necessary by the CR or TSC.
3.1.2     The OSC communicates with the CR and the TSC and is located in the TSC Building.
3.2 Equipment and Supplies 3.2.1     Equipment lockers are provided in the OSC for storage of instruments, SCBAs, supplies and reference documents.
3.3 Staffing 3.3.1     OSC management is comprised of an OSC Director and three technicians representing the radiation protection, chemistry and maintenance disciplines.
(See Section B of this plan for a comprehensive organization definition).
4.0 CONTROL ROOM 4.1 Facility Description and Function 4.1.1     The Control Room functions as the onsite location from which the FCS systems are monitored and controlled and from which any ISFSI operations are coordinated. It is large enough to contain all the instrumentation, controls and displays for the nuclear systems, reactor coolant systems, steam systems, electrical systems, safety and accident monitoring systems. The Control Room plays a vital role in the Emergency Response Organization by providing the initial response actions needed to react to any emergency situation. The Control Room personnel will respond to all emergency situations in an attempt to mitigate the emergency and minimize the impact on the surrounding environment, health and safety of the public as well as plant personnel and equipment.

FCS                                                                  EP-FC-1001 Section H Revision TBD EMERGENCY FACILITIES AND EQUIPMENT 4.2 Equipment and Supplies 4.2.1    The Fort Calhoun Station Control Room is typically supplied with the following emergency supplies:
Emergency Locker (Computer Room)
Operating and Emergency Procedures and Manuals Radiological Monitoring Equipment Technical Specifications for FCS and the ISFSI (electronically)
System Drawings for the nuclear power plant and the ISFSI (electronically) 4.3 Staffing 4.3.1    In addition to normal CR personnel, additional positions are called out in the event of an emergency situation as stated in Section B.
5.0 EMERGENCY KITS 5.1 The emergency kits and equipment are inventoried in accordance with Fort Calhoun Station Surveillance Tests Procedures. Extra quantities of equipment, spare parts and supplies are located at the Fort Calhoun Station Warehouse to support extended emergencies.
5.2 Radiological Emergency Kits 5.2.1    These kits include protective equipment, radiological monitoring equipment and emergency supplies. Kits are located in the Control Room, Technical Support Center, Operations Support Center and the Emergency Operations Facility.
5.2.2    The Radiation Protection Department establishes the method and frequency for instrument calibration. Individual instruments are calibrated using approved calibration procedures. Repair/replacement of equipment is coordinated through the Radiation Protection Department.
5.3 Dosimetry Kits 5.3.1    These kits include dosimetry, dosimeter chargers and appropriate paperwork. Kits are located in the Control Room, Technical Support Center, Operations Support Center and Emergency Operations Facility.

FCS                                                                  EP-FC-1001 Section H Revision TBD EMERGENCY FACILITIES AND EQUIPMENT 5.4 Medical Kits 5.4.1    First Aid Equipment and Supply Kits A. First aid equipment and supplies are located in the First Aid Room.
Trauma and primary response kits are available throughout the plant.
These kits are inspected and maintained by the Industrial Safety Coordinator.
5.4.2    Contaminated/Injured Person Kit A. These kits are located in the Operations Support Center and near the RP Count Room. These kits are maintained by the Radiation Protection Department.
5.5 Decontamination Area 5.5.1    Decontamination equipment and supplies are located in the main warehouse and the radiation protection work area.
5.6 Field Monitoring Kits 5.6.1    OPPD maintains two vehicles designated for emergency use, each vehicle is equipped with radiological monitoring equipment, emergency supplies, and other equipment/supplies that may be used by teams monitoring radiological conditions on and off site. Each vehicle also has a permanently installed communications system as described in Section F.
5.6.2    Radiological equipment or other equipment that is/or may be affected by climate changes may be stored in a designated storage area.
5.6.3    Use of these emergency vehicles is authorized by the Manager-Emergency Planning or designee. In the event a vehicle requires servicing every effort will be made to have it returned on the same day. A sign reminding users that the vehicle shall be returned to its home base in the event of a declared emergency at Fort Calhoun Station is posted in each vehicle.

FCS                                                                 EP-FC-1001 Section H Revision TBD EMERGENCY FACILITIES AND EQUIPMENT 5.7 Other OPPD Resources 5.7.1   OPPD has other facilities and resources that may be useful in support of an emergency at Fort Calhoun Station. Examples are:
A. Fort Calhoun Station Simulator could be used to model plant transients or serve as an alternate location for support and technical personnel.
The simulator has the following communications equipment: Conference Operation Network (COP), Operations Liaison Network, FTS-ENS Phone, Gai-tronics, remote radio base station, regular phone systems, computer terminal for dose assessment, and FAX machine.
B. The FCS Training Center, the FCS Administration Building, and Energy Plaza make available resources such as: briefing rooms, classrooms, technical libraries, a chemistry laboratory, a radiation protection laboratory, communications, computers, food storage and preparation facilities, alternate water supply, and shop areas.

FCS                                                           EP-FC-1001 Section H Revision TBD EMERGENCY FACILITIES AND EQUIPMENT Figure H Onsite Emergency Response Facilities

FCS                                                            EP-FC-1001 Section H Revision TBD EMERGENCY FACILITIES AND EQUIPMENT Figure H Typical Technical Support Center Layout

FCS                                                            EP-FC-1001 Section H Revision TBD EMERGENCY FACILITIES AND EQUIPMENT Figure H Typical TSC Entry/Briefing Area

FCS                                                           EP-FC-1001 Section H Revision TBD EMERGENCY FACILITIES AND EQUIPMENT Figure H Typical Operations Support Center Layout

FCS                                                                               EP-FC-1001 Section H Revision TBD EMERGENCY FACILITIES AND EQUIPMENT Figure H Typical Emergency Operations Facility Layout A. Dose Assessment        E. ENS Phones     I. NRC Van Elect/Tele Hookup     M. Operations Liaison Terminals                                                                   Phone B. ERF Terminals          F. Fax Machines   J. Nebr. CRUSH Elect/Tele Hookup C. CHP Phones             G. ERF Printer    K. COP Phone D. HPN Phones             H. Siren Terminal L. Mop Phone
: 1. Emergency Director                              30. NE. Governor's Authorized Representative
: 31. NE. GAR Advisor
: 3. EOF Operations Liaison                          32. NE. Manager
: 4. EOF COP Communicator                            33. NE. RAD. Team Coordinator
: 5. Protective Measures Manager                     34. NE. Recorder
: 35. NE. Dose Calculations
: 7. EOF Field Team Specialist                       36. NE. Public Information Officer
: 8. EOF Dose Assessment Specialist                  40. IA. Representative
: 41. IA. RAD. Team Coordinator
: 50. NRC Site Team Leader/DSO/MCL
: 11. EOF Technical Liaison                           51. NRC Emergency Response Coordinator
: 12. Des Moines Site Representative                  52. NRC Status Summary Coordinator
: 13. EOF Administrative Logistics Manager            53. NRC Governmental Liaison Coordinator
: 54. NRC Public Information Representative
: 55. NRC Dose Assessment Representative
: 56. NRC Reactor Safety Coordinator/RSCL
: 57. NRC Protective Measures Team Leader
: 18. EOF Security Personnel                          58. NRC Protective Measures Coordinator/PMCL
: 59. NRC Status Summary Communicator
: 60. NRC Emergency Response Assistant
: 70. FEMA Representative

FCS                                                                         EP-FC-1001 Section I Revision TBD ACCIDENT ASSESSMENT 1.0  ACCIDENT ASSESSMENT 

==SUMMARY==

Accident assessment is divided into initial and long term phases. At the beginning of an event initial assessments are performed in the Control Room. These early assessments are used as a basis for classifications, immediate actions and emergency response. The Shift Manager is responsible for initial event assessment, classification and initiation of appropriate notifications. Initial dose assessment with recommended protective actions can be performed and evaluated as soon as practical by onsite staff. These projections will be made available to offsite governmental agencies.
Initial assessments using plant parameters or other indicators are compared to pre-determined emergency action levels to select the proper emergency classification.
The plant parameters may be system conditions, system configuration, radiological parameters, etc. The Control Room is equipped with adequate monitoring equipment to determine these parameters for rapid assessment and decision-making.
The long term or continuing accident assessment is performed using the Control Room monitoring equipment and other methods made possible by additional resources from the Emergency Response Organization and offsite organizations. This includes radiological information gathered from field monitoring and environmental monitoring teams.
2.0  ASSESSMENT CAPABILITIES 2.1  Resources for Detection/Assessment of Non-Radiological Events 2.1.1      Fire Detection The fire detection system is detailed in the Station Fire Plan.
2.1.2      Seismic Monitoring Plant seismic instrumentation is provided to determine the response of the containment and auxiliary building structures in the event of an earthquake so that such response can be compared with that used as the basis of design.
Should a seismic disturbance occur in the neighborhood of the plant, the accelerations recorded within the plant will be the basis for a decision as to continued plant operation.
Seismic information is also available offsite through the U.S. Department of the Interior, United States Geologic Survey, National Earthquake Information Service, Boulder, Colorado.

FCS                                                                      EP-FC-1001 Section I Revision TBD ACCIDENT ASSESSMENT 2.1.3     River Level River level is available from local read-out in the intake structure, the plant computer and offsite sources.
2.2  Resources for Detection/Assessment of Radiological Releases 2.2.1     Plant Process Radiation Monitors This instrumentation, a part of the Radiation Monitoring System (RMS), is provided to monitor systems in strategic locations throughout the plant for normal and emergency conditions. The monitors are used for trending, determining radioactive material release permit limits, initiating safety signals to limit releases and assessing release rates during an emergency.
The channels of this system provide data both in the Control Room and on the Emergency Response Facility Computer System (ERFCS).
Depending on the type, the various monitors in the system can be used to detect particulate and gaseous radioactivity levels at release points throughout the plant, including containment. The system also provides accident range capability on the Auxiliary Building Ventilation Stack and the Main Steam line.
2.2.2 Area Radiation Monitors Area Radiation Monitors are strategically located throughout the plant to monitor gamma radiation levels.
2.2.3 Meteorological Instrumentation The plant has a permanent 110m meteorological tower with detectors at 10 and 60 meters, and a redundant power supply; the sole output of information from the tower is the ERFCS. In the event of failure of this system, wind speed and direction can be obtained from the National Weather Service in Valley NE, or the Offutt Air Force Base.
The USAR Section 2.5 discusses the terrain around Fort Calhoun Station and its effects on an airborne plume. Historical meteorological data is also available from the plant computer. This data will be made available by OPPD to the appropriate government agencies.

FCS                                                                     EP-FC-1001 Section I Revision TBD ACCIDENT ASSESSMENT 2.2.4 Water Analyses Analyses of plant liquid systems may be performed to help ascertain the nature of problems detected by other instrumentation (prior to an emergency situation).
The samples will be collected and analyzed per applicable Fort Calhoun Station procedures.
2.2.5 Post Accident Sampling Methods have been established to collect and analyze samples from the primary coolant system, containment atmosphere, auxiliary building ventilation duct pathway, the main steam safety relief and atmospheric dump valve pathway, and the occupied areas. These methods are described in applicable Fort Calhoun Station procedures.
2.3  Field Monitoring 2.3.1 Monitoring Operations In the event of an unplanned airborne materials release following an accident, field monitoring teams will be dispatched to evaluate activity levels.
River water samples can be collected and analyzed in the event radioactive water or liquid is discharged without proper monitoring per the Environmental Monitoring Program. The Metropolitan Utilities District will be notified when accidental liquid discharges occur.
The primary objective of the emergency onsite and offsite field monitoring teams is to survey areas downwind of the plant site in order to determine the extent and magnitude of any unplanned release of radioactive material following an incident.
The task of each monitoring team is to collect air samples and survey data and transmit information and results to the appropriate emergency response facility.
This information will be used to define affected areas, and assess the extent and significance of the release. Surveys are done per the applicable Radiation Protection or Emergency Plan procedures.
2.3.2 Personnel A. Onsite Field Monitoring The onsite field monitoring teams focus is primarily on obtaining radiological data within the protected area. These teams are typically dispatched from either the Control Room or Operations Support Center.

FCS                                                                     EP-FC-1001 Section I Revision TBD ACCIDENT ASSESSMENT B. Offsite Field Monitoring The offsite field monitoring team(s) focus is on obtaining radiological data outside the owner controlled area. Primary direction of the off-site field monitoring teams is from the EOF, with back up capability at the TSC.
C. Environmental Monitoring Environmental monitoring may be done as a function of recovery from an emergency. Types of sample media and team makeup are dependent upon the needs determined by management personnel.
2.3.3 Equipment Section H of this plan and the applicable station procedures list the Emergency Kit locations.
3.0  ASSESSMENT OF RADIOLOGICAL RELEASES 3.1  Methods of Assessment The methods used for the assessment of radioactivity released to the environs are detailed in the Emergency Plan Implementing Procedures.

FCS EP-FC-1001 Section J Revision TBD PROTECTIVE RESPONSE 1.0 PUBLIC INFORMATION CONTENT AND DISSEMINATION 1.1 Notification 1.1.1      Onsite personnel are notified of a nuclear emergency via the emergency alarm. This alarm is identified by an intermittent howl and is distinguished from the fire alarm which is a continuous howl. Once the emergency alarm is sounded, the command and control position will give the emergency classification, with other pertinent information, using the intra-plant communication system (Gaitronics). If the owner-controlled area is to be evacuated, personnel will be notified by: 1) Gaitronics System, 2)
Administration and Training Building paging systems, 3) Security Personnel, and/or 4) Alert Notification System, if used.
1.2 Evacuation 1.2.1      If the emergency requires Protected Area evacuation, all onsite personnel considered nonessential to the mitigation of the event will normally proceed to a designated location or to their homes. If a release has occurred or there is reason to suspect contamination the evacuees will be sent to the OPPD Elkhorn Center.
1.2.2      Approximately 600 persons might be evacuated during normal work hours and operation; approximately 900 persons might be evacuated during a major outage. During normal operating off-shift hours, no evacuation of onsite individuals is expected. Both OPPD and personal vehicles are used for site evacuation transportation. Agreements with the State of Nebraska and specifically the State Patrol guarantee professional handling and control of traffic. Normal travel time to Elkhorn Center is 37 minutes using the normal evacuation route and 53 minutes using the alternate evacuation route at an average speed of 40 mph. Personnel at the Elkhorn Center will coordinate personnel/vehicle monitoring and decontamination activities, if required.
1.2.3      Security and RP personnel inspect the owner controlled area after a site evacuation has taken place. If any persons other than emergency workers are in the owner controlled area during or after site evacuation, they will be given specific directions and/or escorted off-site.

FCS EP-FC-1001 Section J Revision TBD PROTECTIVE RESPONSE 1.3 Security and Accountability 1.3.1     Security A. The security program is designed to deter, delay and detect an intruder.
The Security Area of the plant site is enclosed by an eight foot security fence topped by three strands of barbed wire. All gates to the fence are normally kept locked. An inner perimeter consists of personnel doors, roof hatches, and overhead doors equipped with magnetic alarm switches.
B. Personnel assigned by the Site Director to enter the plant must pass through the main gate which is guarded. It is extremely unlikely that any unauthorized person would be able to enter the site undetected even during an emergency condition.
1.3.2     Accountability A. If accountability of onsite personnel is necessary, the onsite command and control position will notify personnel onsite by announcements on the Gaitronics System, and by sounding the Emergency Alarm (if required). At the completion of the notification(s), the accountability process begins, to be completed within 30 minutes.
B. Accountability is a process taking place in several areas:
: 1. Accountability of personnel reporting to the Control Room, TSC, or OSC for emergency response will be performed by personnel using the card readers at these locations.
: 2. Accountability of security force personnel will be accomplished using established security procedures.
: 3. Once initial accountability is complete, the command and control position, will be notified of the results.
: 4. Accountability is maintained by the use of rosters at the Control Room, OSC and TSC. Persons must sign in and out as they enter and leave. These rosters will be compared to a list of personnel who accessed the protected area whenever necessary. Continuous accountability of security personnel is accomplished using established security procedures.

FCS EP-FC-1001 Section J Revision TBD PROTECTIVE RESPONSE 1.4 Protective Measures 1.4.1     It is the policy of OPPD to keep personnel radiation exposure within federal regulations, and station limits and guidelines, beyond that, to keep it As Low As Reasonably Achievable (ALARA). Every effort will be made to keep their exposures within the limits of 10 CFR 20.
1.4.2     Personnel monitoring devices are required for all personnel meeting the conditions specified in 10 CFR 20 Section 20.1502, Technical Specifications Section 5.11 and in Radiation Protection Procedures. During emergency conditions, implementing procedure EP-FC-113 will be utilized.
1.4.3     Dosimeters and TLDs are typically located in each of the emergency lockers in the Control Room, EOF, OSC and the TSC. Additional dosimeters and TLDs may be obtained from the dosimetry group.
1.4.4     Clothing A. Protective clothing is a normal use item utilizing both washable and disposables. For entry into affected areas, the OSC has approximately 50 complete sets of protective clothing available. The Control Room has approximately 12 complete sets available. Additional sets are available at the Radiation Control Point. Approximately 2000 sets are ready for use and a large supply of washable and/or disposable coveralls is maintained in the warehouse and RP storage areas. Water-proof protective clothing is also a standard stock item.
1.4.5     Respiratory Protection A. Respiratory protective devices may be required where an airborne radioactivity condition is potential or existent. In such cases, the air will be monitored and the necessary protective devices specified according to the concentration and type of airborne contaminants present.
Monitoring and issue of respiratory protection equipment will be conducted in accordance with Radiation Protection Manual Procedures.
Precautions will be taken to keep airborne contamination to a minimum through the use of proper engineering controls and decontamination.
B. Limits for inhalation of radionuclides are established in Appendix B, Table 1 of 10CFR20. The Radiation Protection Manual establishes the station's administrative limits for inhalation which will be adhered to in emergencies if possible.
C. Types and recommended use for each type of respirator is specified in the Radiation Protection Manual.

FCS EP-FC-1001 Section J Revision TBD PROTECTIVE RESPONSE D. Approximately 35 self contained breathing apparatus are maintained onsite. Of these, a portion is maintained for fire brigade use, or normal use, and the remainder for emergency response. Spare bottles are also stored in some locations. The site has the capability to refill bottles with a compressor/air bank unit, with a cascade tank unit as a backup.
Full-face respirators are maintained in some emergency gear lockers.
Respirators are staged for use in plant radiation areas. The onsite Stores warehouse stocks approximately 150 full-face respirators for reserve supply.
1.4.6     Radioprotective Drugs A. The need for issuance of radioprotective drugs, specifically potassium-iodide, is determined using appropriate procedures.
B. Radioprotective drugs in the form of potassium iodide tablets are available in the Control Room, Technical Support Center, Operations Support Center, Emergency Operations Facility and the Field Team equipment lockers. Each bottle contains dosage supply for 14 days.
Emergency workers are instructed on the advantages and disadvantages of taking the tablets to provide thyroid blockage. The final decision for use of the potassium iodide is made by the emergency worker.
2.0 PROTECTIVE RESPONSE FOR RESIDENTS WITHIN THE PLUME EXPOSURE PATHWAY 2.1 Protective Action Recommendations 2.1.1     OPPD Guidelines A. Fort Calhoun Station is designed and equipped with a series of safety systems engineered to meet all of 10 CFR 100 criteria for reactor safety.
OPPD recognizes that in any accident situation, it would be prudent and logical to make every effort to further reduce and minimize exposure to the public. OPPD management will recommend to appropriate State and local authorities that protective actions be initiated if any person is expected to receive an emergency exposure in excess of Environmental Protection Agency (EPA) guidelines.
B. Tables J-11 through J-41 provides some information and guidance on formulating Protective Action Recommendations (PAR's). Table J-11 summarizes the considerations for selecting the evacuation Protective Action Guides (PAG's). Table J-21 outlines the early (plume) phase PAG's due to exposure of airborne and deposited radioactivity.
Table J-31 summarizes the considerations for selecting relocation PAG's.
Table J-41 outlines the immediate (relocation) phase PAG's due to exposure to deposited radioactivity.

FCS EP-FC-1001 Section J Revision TBD PROTECTIVE RESPONSE C. During the early (plume) phase of a radiological emergency, professional judgement will be required in the application of PAG's, due to varying characteristics, such as; plant conditions, evacuation time estimates, environmental conditions, affected population groups, etc. In all cases, the PAR's transmitted by OPPD to the states of Iowa and/or Nebraska are strictly recommendations. The respective government agencies in each state have the ultimate responsibility for implementing necessary protective actions for the general public.
1 Taken from "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents." EPA-400-R-92-001, Revised May, 1992.
D. Tables J-5 and J-6 provide information pertaining to emergency worker exposure limits and health risks associated with exposure to higher dose levels.
2.1.2      Initiation of Recommendations A. Recommendations will originate from an Emergency Response Facility based upon data derived from implementing procedure, EP-FC-110, Assessment of Emergencies. This procedure establishes a method for determining projected doses to the population-at-risk. Protective action recommendations based on radiological parameters or plant conditions are determined using EP-FC-111, Emergency Classification and Protective Actions. Total population exposure can be estimated using projected or known dose values and population densities.
2.2 Notification 2.2.1      In the event public notification is required, both transient and resident population within the plume exposure pathway will be initially notified through the Alert Notification System (reference Section E) and as described in state and county radiological emergency plans. Information will be provided for transient and resident population as well as the general public outside the EPZ through the Emergency Alert System.
2.2.2      Information brochures describing notification, protective actions and general radiological education are provided to residents by mail and by public service posting to transients within the EPZ. The States of Iowa and Nebraska will issue messages describing the incident and recommended public protective actions.

FCS EP-FC-1001 Section J Revision TBD PROTECTIVE RESPONSE 2.3 Evacuation 2.3.1    Evacuation Time Estimate Study A. Studies estimating the time required to evacuate the residents in the plume exposure pathway from the emergency planning zone were conducted in accordance with NUREG-0654, Rev. 1, Appendix 4 criteria.
These studies are supporting documents to this Plan. Summaries of the Nebraska and Iowa evacuation time estimate studies are outlined in KLD Engineering, P.C., Fort Calhoun Nuclear Station, Development of Evacuation Time Estimates (EP-FC-1001 Addendum 2). Reference Figure 6-1, Tables 7-1 through 7-6, and Table 3-7.
2.3.2    Evacuation of Areas within the EPZ A. The Governor (or Governor's Authorized Representative) of Nebraska can authorize the Nebraska State Patrol and Emergency Management Agency, based on recommendations of the State Health Department, to evacuate Nebraska residents to the reception center in Fremont, Nebraska.
B. The Governor (or Governor's Authorized Representative) of Iowa can authorize the Iowa State Patrol and the Emergency Management Division to evacuate Iowa residents to Denison, Iowa, based upon recommendations of the Iowa Department of Public Health.
C. Evacuees from the Nebraska portion of the EPZ should go to the Fremont Reception Center. Evacuees from the Iowa portion of the EPZ should proceed to the Denison Reception Center. Figure J-5 shows the boundaries and highways leading to the Reception Centers.
D. The relocation centers for the host areas are as follows:
Fremont Fremont Middle School 540 Johnson Rd Denison Denison Community High School, North 16th E. The ingestion planning zone (IPZ) encompasses a 50 mile radius as illustrated in Figure J-6. Population for the IPZ is presented in Figure J-7 by sectors.

FCS EP-FC-1001 Section J Revision TBD PROTECTIVE RESPONSE F. The plume exposure EPZ encompasses an approximate 10 mile radius as illustrated in Appendix H, (EP-FC-1001 Addendum 2). The EPZ includes portions of Harrison and Pottawattamie Counties in Iowa, Washington and Douglas Counties in Nebraska. The States of Iowa and Nebraska are separated by the Missouri River. Table 3-5 through 3-8, (EP-FC-1001 Addendum 2),shows the total population within the EPZ, and population totals for each Sub Area. This includes showing Estimated Transient population.
2.4 Protective Methods (Other than Evacuation) 2.4.1     Sheltering A. Remaining indoors during the passage of a radioactive cloud affords the dweller a reduction in the quantity of radionuclides inhaled, as well as providing shielding. Figure J-9 shows the ratio of the inhaled dose inside a shelter to that outside the shelter as a function of the ventilation rate. A ventilation rate survey showed a rate variance of 0.07 to 3.0 per hour.
The ventilation rate is affected by temperature differential, wind speed and direction, quality of construction and topographical setting.
B. Walls of buildings absorb and scatter gamma rays, thus providing a lower dose to the occupants. The shielding factor of a building is the ratio of the interior dose to the exterior dose. Shielding factor estimates applicable to residential housing units were made using the shielding technology by Z. G. Burson and A. E. Profio (1975). Table J-7&#xb2; summarizes shielding factors for designated structures/locations from a gamma cloud source.
1,2,3 C.       Table J-83 summarizes the shielding factors for designated structures/locations from surface deposition of radioactive material.
Burson and Profio proved that the fallout shielding technology developed via nuclear weapons tests could be directly applied to radioactivity deposited on surfaces after a reactor accident. The shielding factors listed in Table J-8 assume uniform distribution of the radioactive fallout.
D. In each of the cases discussed, inhalation and shielding factors from a gamma cloud source and shielding factors from surface deposition of radioactive material, it is noted that the shielding factors using sheltering as a method of protection ranges from 0.6 to 0.005. Although the best protection seems to be the basement of large multi-structured buildings, the basement of any house has been proven to provide significant shelter from airborne and surface deposited radioactive material.
1       Taken from WASH-1400(NUREG-75/014), October 1975, Figure VI.11-4.
2       Taken from WASH-1400(NUREG-75/014), October 1975, Figure VI-11-7.
3       Taken from WASH-1400(NUREG-75/014), October 1975, Figure VI-11-8.

FCS EP-FC-1001 Section J Revision TBD PROTECTIVE RESPONSE 2.5 Radiological Environmental Monitoring 2.5.1    In the event of an emergency, the permanent air particulate stations are first utilized for immediate data, concerning airborne releases. Background radiation stations (TLDs) provide short term exposure data and are periodically replaced. See the specific Radiological Environmental Monitoring Surveillance Test for more information. TLD use can be increased during the longer term as the District maintains a TLD services contract with an off-site vendor. The environmental laboratory personnel perform accelerated collection and analysis of samples as their primary responsibility after an emergency occurs. Sampling requirements will be determined by the environmental laboratory personnel.
2.5.2    Sample analysis will be performed by the station and at offsite facilities as deemed necessary.

==3.0 REFERENCES==
AND COMMITMENTS 3.1 EP-FC-1001 Addendum 2, Evacuation Time Estimates KLD TR-535 3.2 EP-FC-1001, Evacuation Time Estimates Table 1, 50 Mile 2010 Population Table Table 3-5 Table 3-7, Summary of Population Demand Table 3-8 Table 7-1 through Table 7-6, Time to clear the Indicated Area of 90% of the Affected Population Figure 1, 50 Mile 2010 Population Rose Figure 5-2, Evacuation Mobilization Activities Figure 6-1, FCNS EPZ Sub Areas Appendix K

FCS EP-FC-1001 Section J Revision TBD PROTECTIVE RESPONSE Table J Summary of Considerations for Selecting the Evacuation PAG's1 DOSE Rem                                     Consideration(s)
(mrem) 50 Rem           Assumed threshold for acute health effects in adults.
(50000 mrem) 10 Rem           Assumed threshold for acute health effects in the fetus.
(10000 mrem) 5 Rem          Maximum acceptable dose for normal occupational exposure for (5000 mrem)         adults.
5 Rem          Maximum dose justified to average members of the population, (5000 mrem)         based on the cost of evacuation.
0.5 Rem          Maximum acceptable dose to the general population from all (500 mrem)         sources from nonrecurring, non-accidental exposure.
0.5 Rem          Minimum dose justified to average members of the population, (500 mrem)         based on the cost of evacuation.
0.5 Rem          Maximum acceptable dose2 to the fetus from occupational (500 mrem)         exposure of the mother.
0.1 Rem          Maximum acceptable dose to the general population from all (100 mrem)         sources from routine (chronic) non-accidental exposure.
0.03 Rem          Dose that carries a risk assumed to be equal to or less than that (30 mrem)         from evacuation.
1 Taken, in part, from Table C-8, Manual of Protective Action Guides and Protective Actions for Nuclear Incidents, EPA-400-R-92-001, May, 1992 2
This is also the dose to the 8 to 15 week-old fetus at which the risk of mental retardation is assumed to be equal to the risk of fatal cancer to adults from a dose of 5 rem.

FCS EP-FC-1001 Section J Revision TBD PROTECTIVE RESPONSE Table J Protective Action Recommendations Based on Dose Assessment/Field Team Radiological Data Instructions: Compare URI or Field Team Dose Assessment results to the following table.
Expand PAR to include downwind sectors in accordance with EP-FC-111-AD-F-02.
Projected Dose                    Protective Action Recommendation (PAR)
  < 1 rem TEDE                                           NONE (No Par Required)
  < 5 rem CDE (thyroid)                        And continue monitoring radiological conditions 1 rem TEDE                                             Evacuate *see note 5 rem CDE                                  And continue monitoring radiological conditions 50 rem SDE (skin)                                           Evacuate And continue monitoring radiological conditions NOTE: SHELTERING may be considered for doses up to 5 rem TEDE in special situations such as (1) the presence of severe weather (2) competing disasters (3) institutionalized people who are not readily mobile; and (4) other local factors, which may impede evacuation.

FCS EP-FC-1001 Section J Revision TBD PROTECTIVE RESPONSE Table J Summary of Considerations for Selecting PAG's for Relocation1 DOSE Rem Consideration(s)
(mrem) 50 Rem          Assumed threshold for acute health effects in adults.
(50000 mrem) 10 Rem          Assumed threshold for acute health effects in the fetus.
(10000 mrem) 6 Rem         Maximum projected dose in first year to meet 0.5 Rem in the second (6000 mrem)        year2.
5 Rem         Maximum acceptable dose for normal occupational exposure for adults.
(5000 mrem) 5 Rem         Minimum dose that must be avoided by one year relocation based on (5000 mrem)        cost.
3 Rem         Minimum projected first-year dose corresponding to 5 Rem in 50 years2.
(3000 mrem) 3 Rem         Minimum projected first-year dose corresponding to 0.5 Rem in the (3000 mrem)        second year2.
2 Rem         Maximum dose in first year corresponding to 5 Rem in 50 years from a (2000 mrem)        reactor incident, based on radioactive decay and weathering only.
1.25 Rem         Minimum dose in first year corresponding to 5 Rem in 50 years from a (1250 mrem)        reactor incident, based on radioactive decay and weathering only.
0.5 Rem         Maximum acceptable single-year dose to the general population from all (500 mrem)        sources from non-recurring, non-incident exposure.
0.5 Rem         Maximum acceptable dose to the fetus from occupational exposure of (500 mrem)        the mother.
0.1 Rem         Maximum acceptable annual dose to the general population from all (100 mrem)        sources due to routine (chronic), non-incident, exposure.
0.03 Rem         Dose that carries a risk assumed to be equal to or less than that from (30 mrem)        relocation.
1 Taken, in part, from Table E-5, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents", EPA-400-R-92-001, May, 1992.
2 Assumes the source term is from a reactor incident and that simple dose reduction methods are applied during the first month after the incident to reduce the dose to persons not relocated from contaminated areas.

FCS EP-FC-1001 Section J Revision TBD PROTECTIVE RESPONSE Table J Protective Action Guides for Exposure to Deposited Radioactivity1 PAG Protective Action             (projected dose                       Comments in first year)2 Relocate the general                2 Rem         Beta dose to skin may be up to 50 times population3                    ( 2000 mrem)       higher.
Apply simple dose                  < 2 Rem         These protective actions should be taken reduction techniques4          (< 2000 mrem)       to reduce doses to as low as practicable levels.
1 Taken, in part, from the "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents", EPA-400-R-92-001, May, 1992.
2 The projected sum of total effective dose equivalent (TEDE) from external gamma radiation and committed effective dose equivalent (CEDE) from inhalation of resuspended materials, from exposure or intake during the first year. Projected dose refers to the dose that would be received in the absence of shielding from structures or the application of dose reduction techniques. These PAG's may not provide adequate protection from some long-lived radionuclides.
3 Persons previously evacuated from areas outside the relocation zone defined by this PAG may return to occupy their residences. Cases involving relocation of persons at high risk from such action (e.g., patients under intensive care) should be evaluated individually.
4 Simple dose reduction techniques include scrubbing and/or flushing hard surfaces, soaking or plowing soil, minor removal of soil from spots where radioactive materials have concentrated, and spending more time than usual indoors or in other low exposure rate areas.

FCS EP-FC-1001 Section J Revision TBD PROTECTIVE RESPONSE Table J Emergency Worker Exposure Limits Dose Limit              Activity                       Condition(s) 500 mrem All Activities               Declared Pregnant Emergency Workers TEDE 5 Rem TEDE All Activities               Non-Pregnant Emergency Workers 10 Rem TEDE Protecting Valuable Property A lower dose is not practicable 25 Rem TEDE Life Saving or Protection of A lower dose is not practicable Large Populations
 >25 Rem TEDE  Life Saving or Protection of Only on a voluntary basis to persons fully Large Populations            aware of the risks involved. (See Table J-6)

FCS EP-FC-1001 Section J Revision TBD PROTECTIVE RESPONSE Table J Summary of Risks Involved with Higher Dose Limits (taken form EPA 400 R-92-001, May, 1992)
Health Effects Associated with Whole-Body Absorbed Dosed Received Within a Few Hoursa Prodromal Whole Body                   Early               Whole Body Effectsc Absorbed Dose              Fatalitiesb           Absorbed Dose (percent (rad)                  (percent)                 (rad) affected) 140                        5                      50                    2 200                       15                     100                   15 300                       50                     150                   50 400                       85                     200                   85 460                       95                     250                   98 (a)
Risks will be lower for protracted exposure periods.
(b)
Supportive medical treatment may increase the dose at which these frequencies occur by approximately 50 percent.
(c)
Forewarning symptoms of more serious health effects associated with large doses of radiation.
Approximate Cancer Risk to Average Individuals from 25 Rem Effective Dose Equivalent Delivered Promptly Approximate Risk of Premature      Average Years of Life Age at Exposure                          Death                  Lost in Premature (years)                  (deaths per 1,000 persons               Death exposed)                   Occurs (years) 20 to 30                             9.1                            24 30 to 40                             7.2                            19 40 to 50                             5.3                            15 50 to 60                             3.5                            11

FCS EP-FC-1001 Section J Revision TBD PROTECTIVE RESPONSE Table J Representative Shielding Factors from Gamma Cloud Source Structure or Location                Shielding Factor(a)       Representative Range Outside                                              1.0                        ----
Vehicles                                             1.0                        ----
(b)
Wood - frame (no basement)                           0.9                        ----
Basement of wood house                               0.6                    0.1 to 0.7(c)
Masonry house (no basement)                          0.6                   0.4 to 0.7(c)
Basement of masonry house                            0.4                   0.1 to 0.5(c)
Large office or industrial building                  0.2                   0.1 to 0.3(c,d)
(a)
The ratio of the interior dose to the exterior dose.
(b)
A wood frame house with brick or stone veneer is approximately equivalent to a masonry house for shielding purposes.
(c)
This range is mainly due to different wall materials and different geometries.
(d)
The reduction factor depends on where the personnel are located within the building (e.g., the basement or an inside room).
NOTE: Consideration is limited to gamma radiation since beta and alpha particles cannot penetrate the walls of structures.
* Taken from WASH-1400 (NUREG-75/104), October 1975.

FCS EP-FC-1001 Section J Revision TBD PROTECTIVE RESPONSE Table J Representative Shielding Factors for Surface Deposition Structure or Location                 Representative (a)    Representative Range Shielding Factor 1 m above an infinite smooth surface                   1.00                     ----
1 m above ordinary ground                              0.70                0.47 - 0.85 1 m above center of 50-ft roadways,                    0.55                  0.4 - 0.6 half contaminated Cars on 50-ft road:
Road fully contaminated                            0.5                  0.4 - 0.7 Road 50% decontaminated                            0.5                  0.4 - 0.6 Road fully decontaminated                         0.25                  0.2 - 0.5 Trains                                                 0.40                  0.3 - 0.5 One and two-story wood-frame house (no basement)                                    0.4(b)                0.2 - 0.5 One and two-story block and brick house (no basement)                                    0.2(b)              0.04 - 0.40 House basement, one or two walls fully exposed:                                         0.1(b)              0.03 - 0.15 One story, less than 2 ft of basement, walls exposed                                0.3(b)              0.03 - 0.07 Two stories, less than 2 ft of basement, walls exposed                                0.3(b)              0.02 - 0.05 Three or four-story structures,
 >5,000 ft2 per floor:
First and second floor                                0.05(b)              0.01 - 0.08 Basement                                              0.01(b)              0.001 - 0.07 Multistory structures, >10,000 ft2 per floor:
Upper floors                                          0.01(b)              0.001 - 0.02 Basement                                              0.005(b)            0.001 - 0.015 (a)
The ratio of the interior dose to the exterior dose.
(b)
Away from doors and windows.

FCS EP-FC-1001 Section J Revision TBD PROTECTIVE RESPONSE Figure J Routes to Relocation Centers

FCS EP-FC-1001 Section J Revision TBD PROTECTIVE RESPONSE Figure J Ingestion Pathway EPZ

FCS EP-FC-1001 Section J Revision TBD PROTECTIVE RESPONSE Figure J Ratio of Inhaled Dose Inside a Shelter to that Outside the Shelter as a Function of Ventilation Rates

FCS                                                                   EP-FC-1001 Section K Revision TBD RADIOLOGICAL EXPOSURE CONTROL 1.0  EXPOSURE GUIDELINES 1.1  It is OPPD policy to comply with the ALARA concept, and all efforts shall be made to keep all workers within normal Fort Calhoun Station limits, as listed in the Radiation Protection Manual. However, if it is expected that workers may exceed these limits, any dose received during emergency conditions in excess of 5 Rem TEDE will be assigned as once in a lifetime exposure.
1.2  The facility directors, Shift Manager in the Control Room, Site Director in the TSC, the OSC Director in the OSC or the Emergency Director in the EOF may authorize dose extension up to 5 Rem TEDE per year during declared events for workers in their facility.
1.3  The Command and Control position shall authorize any extensions beyond normal occupational exposure limits and direct that any dose received in excess of these limits be assigned as once in a lifetime exposure. The following guidance is from the FCS Radiation Protection Manual, and the Manual of Protective Action Guidelines and Protective Action for Nuclear Incidents, EPA-400-R-92-001.
5 Rem TEDE for all emergency workers 10 Rem TEDE when action is necessary to reduce a hazard potential to acceptable levels or to prevent substantial loss of property 25 Rem TEDE when action is necessary to perform lifesaving functions or to reduce the potential hazards to the health and safety of the public
         >25 Rem TEDE on a voluntary basis and only to save a life or reduce potential hazards to the health and safety of the public 1.4  Plant personnel that require access to Radiation Controlled Areas are issued TLDs on a frequency specified by Radiation Protection. Many ERO positions are also issued TLDs depending on the likelihood of having to enter a Radiation Controlled Area under emergency conditions. TLD requirements for ERO positions are identified on the ERO Roster.
1.5  Personnel responding to the site that require, but do not have, dosimetry will be issued dosimetry by Security or Radiation Protection personnel. The following ERO positions can also issue dosimetry when necessary:
Control Room: The Shift RP Technician or OSC RP Technicians TSC: OSC RP Technicians OSC: The OSC RP Technicians

FCS                                                                   EP-FC-1001 Section K Revision TBD RADIOLOGICAL EXPOSURE CONTROL 2.0  CONTAMINATION CONTROL 2.1  If actual or potential contamination problems exist onsite, ERO management may elect to establish contamination control and monitoring measures. These may consist of some or all of the following:
Each Emergency Response Facility onsite has the capability to establish control boundaries to minimize contamination spreading into the facility.
Monitoring of personnel evacuating the affected area using installed monitors in the Security Building or personnel with portable equipment. Portable equipment for this purpose is stored both in the warehouse and at the EOF.
2.2  If personnel decontamination becomes necessary, the site maintains two facilities for this purpose. One is located in the Auxiliary Building entry/exit point, and is frequently used. It drains to the Radwaste System. The second facility is located in the Warehouse and is designated for emergency use only. It drains to a holding tank, which is controlled after emergency use to ensure that the contents are monitored and processed if necessary.
2.3  Contaminated personnel that are evacuated will be decontaminated as determined by Radiation Protection personnel. Additional decontamination facilities are available at state decontamination facilities and at the UNMC Regional Radiation Health Center.
2.4  Tools and equipment that become contaminated will be decontaminated as determined by Radiation Protection personnel.
2.5  Areas that become contaminated will be decontaminated as determined by Radiation Protection personnel.
2.6  Priorities for decontaminating tools, equipment and areas will be established by ERO management, with top priority given to contamination within areas that are or will be inhabited by emergency workers. Decontamination of non-essential areas, tool and equipment should be delayed to allow for natural decay of radioactive materials.
2.7  Potable water, normally supplied from the City of Blair, and onsite food supplies can be chemically and radiologically monitored prior to use by emergency workers.
2.8  Contamination limits, contamination control, and decontamination criteria may be adjusted based on professional radiological evaluation by the ERO using guidance in the Radiation Protection Manual.
2.9  Radioactive waste from any decontamination effort will be prepared and shipped in accordance with Radiation Protection Manual requirements.

FCS EP-FC-1001 Section L Revision TBD MEDICAL AND PUBLIC HEALTH SUPPORT 1.0  ONSITE FIRST AID 1.1  There are generally four types of response considered at the Fort Calhoun Station:
: 1)      Minor injury, no contamination
: 2)      Minor injury, contaminated
: 3)      Major injury (requiring offsite treatment), no contamination
: 4)      Major injury, contaminated 1.2  The order of medical treatment will be:
: 1)      Care of severe physical injuries
: 2)      Decontamination of personnel
: 3)      First aid to other injuries
: 4)      Monitor for internal contamination
: 5)      Definitive treatment and subsequent therapy as required 1.3  All injuries at the station must be immediately reported to the Shift Manager, who will initiate response according to the Fort Calhoun Station Safety Manual, FCSG-15-7, Medical Emergencies. When the OSC is activated the OSC Director will be responsible for response to medical emergencies.
1.4  When personnel are severely injured and contaminated, first aid shall take precedence over decontamination. In cases where internal exposure is suspected, a bioassay program may be performed as directed by the Radiation Protection Manual.
1.5  First Aid Facilities 1.5.1       A First Aid Room is located in the Maintenance Building. This room is equipped with various medical supplies to provide emergency first aid to injured personnel.
1.5.2       Other equipment located throughout the plant include first aid kits, Emergency Medical Technician (EMT) kits, personnel carriers, a wheelchair, and contaminated/injured personnel response kit. The Industrial Safety Coordinator inspects and maintains this equipment.

FCS EP-FC-1001 Section L Revision TBD MEDICAL AND PUBLIC HEALTH SUPPORT 1.6  Medical Response 1.6.1    Minor Injury, No Contamination A. The Shift Manager or other evaluators will determine the extent of medical response required. This could include:
: 1. On the spot treatment by the individual or first aid qualified responders.
: 2. On the spot treatment by EMT qualified personnel (if available).
: 3. Movement of the injured party to the first aid room by medical responders for access to additional equipment.
: 4. Other response determined necessary by responding personnel.
1.6.2    Minor Injury, Contaminated A. Personnel that are injured and are potentially contaminated will be treated as explained above, and will also be monitored for contamination by Radiation Protection personnel. Monitoring and decontamination will be performed in accordance with Radiation Protection procedures.
1.6.3    Major Injury, No Contamination A. Medical responders will be dispatched to the scene to perform first aid as required. The Shift Manager or designee will notify offsite authorities to provide victim transport to an available medical facility. Both air and ground transportation are available.
1.6.4    Major Injury, Contaminated A. Personnel that are severely injured and are potentially contaminated will be treated as explained above, and will also be monitored for contamination by Radiation Protection personnel. If feasible, monitoring and decontamination will be performed in accordance with Radiation Protection Procedures. If decontamination is successful, the victim may be transported to any available medical facility for treatment.
B. If decontamination is not successful or not feasible, the victim will be transported to the UNMC Regional Radiation Health Center, unless the responding Emergency Medical Services (EMS) personnel deem it medically necessary to proceed to a closer facility. If another facility other than UNMC is used, additional Radiation Protection personnel should be sent to the facility to assist in monitoring, decontamination and clean up.

FCS EP-FC-1001 Section L Revision TBD MEDICAL AND PUBLIC HEALTH SUPPORT 2.0  MEDICAL TRANSPORTATION 2.1  Blair Fire Department and Rescue Squad The Blair Fire Department and Rescue Squad Station is located less than four miles from the Fort Calhoun Station. The Rescue squad furnishes transportation for the injured and administers first aid enroute to the hospital.
2.2  Fort Calhoun Fire and Rescue Squad The Fort Calhoun Fire and Rescue Squad headquarters is located approximately 3-1/2 miles from the Fort Calhoun Station. This rescue squad serves as backup to the Blair Fire Department and Rescue Squad.
2.3  Missouri Valley Fire and Rescue Squad The Missouri Valley Fire and Rescue Squad is located approximately fifteen miles from the plant.
2.4  Additional support is available to both the Blair Fire Department and Rescue Squad and the Fort Calhoun Fire and Rescue Squad by request through the Tri-Mutual Aid Association (Douglas, Sarpy, and Washington Counties).
2.5  Other Modes of Transportation If necessary, there are other modes of transportation for delivering injured personnel to appropriate medical facilities.
2.5.1      Medical Ambulance helicopter 2.5.2      Onsite company vehicles 2.5.3      Private autos of company personnel 3.0  OFFSITE MEDICAL SUPPORT 3.1  Non-Contaminated Personnel The nearest medical facility is the Blair Memorial Community Hospital which is located five miles from the plant. A physician is readily available as a general medical consultant. Other facilities may be used as determined necessary by medical response personnel.

FCS EP-FC-1001 Section L Revision TBD MEDICAL AND PUBLIC HEALTH SUPPORT 3.2  Contaminated Personnel 3.2.1   Omaha Public Power District maintains an agreement with the UNMC Regional Radiation Health Center to supply 24-hour treatment for all injuries involving contamination and/or personnel radiation exposure. The Regional Radiation Health Center is located approximately 25 miles from the plant in Omaha, Nebraska. The facility is part of the UNMC complex, and was established specifically for the treatment of injuries occurring from nuclear and radiation related incidents. An entrance (Figure L1) is available for the ingress and egress of contaminated victims to a special assessment and decontamination facility. Patients can also be transported to the facility via medical ambulance helicopters.
3.2.2   The UNMC Regional Radiation Health Center staff administers medical, decontamination, internal bioassay, and other nuclear medicine capabilities.
The staff maintains an appropriate "Standard Operating Procedures Manual" which describes their responsibilities and roles. If additional hospital beds should be required during a major incident, the hospital maintains a mutual agreement with several other Omaha area hospitals to assist with decontaminated patients.
3.2.3   Due to the large, highly qualified staff, the distance from the plant, the specialized capabilities, and the overall size of the UNMC complex, the Fort Calhoun Station was granted an exemption from requiring a backup medical facility by the Federal Emergency Management Agency.

FCS EP-FC-1001 Section L Revision TBD MEDICAL AND PUBLIC HEALTH SUPPORT Figure L Entrance to Treatment Area UNMC Regional Radiation Health Center

FCS EP-FC-1001 Section M Revision TBD MEDICAL AND PUBLIC HEALTH SUPPORT 1.0  RECOVERY ORGANIZATION (RO) 1.1  Responsibilities The Recovery Organization (RO) responsibilities include the overall coordination and management of the recovery effort and has provisions for technical and administrative services, design work, scheduling, planning, quality control/assurance, construction and vendor support.
1.2  Staffing The Recovery Organization would be composed of all the necessary technical, administrative, managerial, and support personnel required for the recovery phase of emergency response. This organization would be capable of 24 hour a day sustained operation.
The lead position in the Recovery Organization would be the Recovery Operations Manager. This individual would be appointed by the Command and Control Position of the Emergency Response Organization. The staffing positions of the rest of the Recovery Organization would be dependent upon the needs based on accident type and magnitude.
The responsibilities of the Recovery Operations Manager and the functions of possible staff members are detailed in the Emergency Plan Implementing Procedures.
1.3  Activation The activation of the Recovery Organization is through the directions given in the Emergency Plan Implementing Procedures governing the downgrading and termination of the emergency response phase. Downgrading and termination is achieved through a checklist format of considering not only the current and past conditions but also those conditions which have the potential to occur.
The ultimate decision for activation of the Recovery Organization rests with the Emergency Command and Control Position.

FCS EP-FC-1001 Section M Revision TBD MEDICAL AND PUBLIC HEALTH SUPPORT 1.4  Transition The transition from Emergency Response Organization to Recovery Organization would consist of turning over functions that would continue while terminating other functions that would not be necessary. The extent of the turnover would be based upon the size of the Recovery Operations which would be dependent upon the type and magnitude of the emergency.
As a minimum, the facility directors at each of the Emergency Response Facilities will make an announcement concerning the shift to the Recovery Organization and direct all Emergency Response Organization Members to turn in all pertinent logs and forms to the administrative manager in each facility. A critique would follow at each facility while recovery operations were commencing.
2.0  REENTRY 2.1  Purpose The purpose for a reentry plan is to provide a means to regain access to an onsite or offsite area that was previously made inaccessible due to an emergency.
2.2  Responsibility The Command and Control Position has the responsibility for authorizing reentry into a previously evacuated area. This could be the Shift Manager, Site Director, or Emergency Director depending on the stage that emergency response has reached.
2.3  Implementation The implementation of the reentry plan is carried out by the Emergency Response Organization. Reentry is normally expected to be accomplished by teams dispatched from the Operations Support Center.
2.4  Emergency Radiation Exposure OPPD is committed to keeping exposure "as low as reasonably achievable" (ALARA).
It is understood that there are emergency situations which transcend the normal requirements for limiting exposure. When such situations exist, the Command and Control Position will make the determination as to the amount of radiation exposure that will be permitted based on the guidelines set forth in Section K of this Plan.

FCS EP-FC-1001 Section N Revision TBD EXERCISES AND DRILLS 1.0 EXERCISES An emergency preparedness exercise is an event that tests the integrated capability and a major portion of the basic elements existing within the Radiological Emergency Response Plan (RERP), associated Emergency Plan Implementing Procedures (EPIPs) and the various organizations associated with the implementation of the RERP. Typically, an emergency preparedness exercise shall simulate an emergency that results in offsite radiological releases which would require response by offsite authorities. However, whenever the State of Nebraska and the State of Iowa are not participating in a particular exercise, the scenario should concentrate on realistic in-plant emergencies with less emphasis on offsite response.
Periodic emergency preparedness exercises can be conducted to evaluate major portions of emergency response capabilities. Also, exercises provide the opportunity to identify further improvements to the emergency preparedness program. Areas of improvement, weaknesses and deficiencies noted as a result of an exercise will be evaluated and corrected, as appropriate.
Normally, an exercise is not considered a "training function", as the participants are not guided, nor "coached", during an exercise. Interaction between controller/observers and participants is not allowed during an exercise, except for delivery and explanation of scenario information and data.
Exercises are conducted biennially, as a minimum. The states of Iowa and Nebraska, along with associated local governmental agencies, are invited to participate in all training drills and exercises, and are required to participate in the biennial exercise under evaluation by the Federal Emergency Management Agency. The Nuclear Regulatory Commission also performs routine inspections to evaluate licensee emergency response performance. The Resident Inspector(s) or other NRC personnel may observe licensee performance during training drills or non-evaluated exercises.
Drill and Exercise procedures are used to verify the following criteria:
1.1 State and local personnel and resources capability to respond to a radiological emergency response scenario.
1.2 Scenario variance from year to year in order to provide optimum training for radiological emergency response personnel.
1.3 Variance of hours in which the radiological emergency exercise is performed.
1.4 Joint radiological emergency exercise involving plant and Federal, State and local support groups, including any that involve a time variance.

FCS EP-FC-1001 Section N Revision TBD EXERCISES AND DRILLS 2.0 DRILLS A drill is a supervised instruction period aimed at testing, developing and maintaining skills in a particular ERO position, function, center, or operation. A drill can be used as a specific training component of an exercise, if the exercise objectives identify and authorize such component. Drills will be supervised and evaluated by appropriate emergency planning personnel or other personnel with specific expertise pertaining to the drill or function being observed.
Periodic emergency preparedness drills are conducted to develop and maintain key skills within the ERO. Also, drills provide the opportunity to identify further improvements to the emergency preparedness program. Areas for improvement, weaknesses and deficiencies noted as a result of a drill will be evaluated and corrected, as appropriate.
At least one drill between biennial exercises will involve a combination of some of the principal functional areas of the onsite Emergency Response Organization, such as; command and control, accident assessment and classification, protective action recommendation decision making, and plant system and component repair and corrective actions. Simultaneous activation of all of the licensee's emergency response facilities during training drills is not necessary. Special functional drills can be developed and used to; focus on accident management strategies; supervised instruction periods for special or newly developed activities and/or procedures; allow resolution of problems (success paths) by ERO members, and; focus on identified onsite training objectives.
Normally, a drill is considered a "training function", as the participants are guided or "coached" during the actual drill. Interaction between controller/observers and participants is encouraged during a drill, except for instances where specific knowledge and memory are being tested.

FCS EP-FC-1001 Section N Revision TBD EXERCISES AND DRILLS 2.1 Communication Drills Emergency Planning procedures provide for communication checks with appropriate agencies to ensure availability and operability of all channels of communication necessary for adequate response to a radiological emergency requiring off-site support. These tests outline those agencies to be contacted, the person (by name or title) who is responsible for verifying that adequate communication exists, the required frequency for which communication is to be checked, and a procedure for accomplishing the test. Below is the communication schedule for these checks or drills to be performed:
2.1.1       Communications are checked monthly from the EOF at the North Omaha Power Station with the States of Nebraska and Iowa and the local governments of the Counties of Harrison, Pottawattamie, and Washington and the NRC using dedicated communications equipment and backup systems. A functional check of the ERFCS is also performed on a monthly basis.
2.1.2       Communications are checked monthly from the Fort Calhoun Station Technical Support Center with the State of Nebraska and Iowa EOCs.
2.1.3       Communications are checked quarterly with Federal response agencies and the States of Nebraska and Iowa within the ingestion exposure pathway EPZ.
Also verified are communications with the JIC and functional checks of the FAX Network, radio system, and the ERF paging systems. Quarterly communications checks are performed from the Control Room with the NRC using both the FTS-ENS phone line and the Emergency Response Data System.
2.1.4       Communications are checked annually between the Fort Calhoun Station, the States of Nebraska and Iowa and local Emergency Operations Centers and field teams.
2.2 Fire Drills Fire drills are conducted by plant personnel on a quarterly basis. The drills are held to test the plant's firefighting capability. The drills are varied in order to test all phases of firefighting techniques.
The Blair Fire Department is annually invited to conduct a drill onsite. Onsite drills assist in familiarizing the fire department members with the types and locations of equipment available to mitigate plant fires.

FCS EP-FC-1001 Section N Revision TBD EXERCISES AND DRILLS 2.3 Medical Emergency Drills The Nebraska Health Center, University Hospital Radiation Health Center is invited to participate in an annual exercise and/or scheduled drill(s) to demonstrate and practice the receipt and treatment of contaminated patients. The extent of the Center's participation depends on their work load and schedule for hospital patients at the time the exercise or drill is declared.
2.4 Health Physics and Radiological Monitoring Drills Emergency Planning procedures develop guides for the preparation, execution, and documentation of health physics and radiological monitoring drills. Execution of these procedures is shared by Emergency Planning and Radiation Protection.
There are two (2) types of drills performed by Chemistry and Radiation Protection Departments:
2.4.1      Semi-annually, a health physics drill is conducted to monitor the response to and analysis of simulated elevated airborne releases, and direct radiation measurements in the environment. Normally, this drill is conducted in conjunction with a quarterly training drill.
2.4.2      Annually a drill is held which involves the collection of a type of environmental sampling media by the Chemistry Departments Environmental Group.
The NRC waived the requirement for a Reactor Coolant liquid sample drill in the SER related to Technical Specification (T.S.) Amendment 200. Amendment 200 deleted the Post Accident Sampling System (PASS).
2.5 Augmentation Call Out Drill Notification and/or Augmentation Drills will be conducted at least every 12 months.
The drills shall evaluate the licensee's capability to notify the minimum staffing positions in the Technical Support Center, Operations Support Center and the Emergency Operations Facility, in addition to meeting the staffing requirements of Table B-1 in RERP, Section B.

FCS EP-FC-1001 Section N Revision TBD EXERCISES AND DRILLS 3.0 SCENARIOS Scenarios for a drill are developed by either Emergency Planning or the group responsible for conducting the specific drill. Each drill should include a basic objective and appropriate evaluation criteria.
A special group is assigned the scenario development for the biennial exercise. An Emergency Planning procedure develops the plan for the preparation, execution, and documentation of the biennial exercise. This procedure requires input from major Federal, State, and local agencies, as well as OPPD staff, in order to define the objectives to be accomplished in the exercise. The scenario is then prepared to describe the following features:
Objectives of the exercise.
Date, time period, location, and participants.
Simulated events.
Time schedule of real and simulated events.
Summary describing conduct of exercise.
Preparation of the scenario may include such items as identifying Control Room alarms, sequence of alarms, and instrument readings required to initiate the planned emergency exercises essential components.
A strong attempt is made to allow only key officials of Federal, State, and local support agencies to share scenario information in advance of exercises, in order that their participation in the exercise can be developed properly to demonstrate their maximum capabilities without losing confidentiality of exercise information.
4.0 CRITIQUES In addition to the OPPD observers, offsite support agencies may provide observers for the biennial exercise. Observers are given information of the accident scenario prior to the exercise so that they may evaluate participants effectively.
Observers, evaluators, controllers and participants submit their comments and recommendations during a critique that is held after all drills and exercises. An Emergency Planning procedure is used to document and classify all significant comments and issues. Significant observations are incorporated into the plants Corrective Action Program for resolution.

FCS EP-FC-1001 Section N Revision TBD EXERCISES AND DRILLS 5.0 ACTUAL EMERGENCIES In the event of an actual emergency, credit for the response may be substituted for a drill or exercise if the event is properly documented according to the guidelines set forth in 10 CFR 50.47 and NUREG-0654, Rev.1/FEMA-REP-1.

FCS EP-FC-1001 Section O Revision TBD RADIOLOGICAL EMERGENCY RESPONSE TRAINING 1.0  FIRST AID TRAINING Personnel assigned the responsibility for responding to a medical emergency at the Fort Calhoun Station receive the American Red Cross Standard First Aid Training Program, or equivalent. Normally, these are members of the Fort Calhoun Station Fire Brigade which consists of Operations personnel assigned to shift crews. To maintain qualifications in accordance with the American Red Cross, CPR is conducted annually and First Aid Training is given biannually. The training is conducted by the American Red Cross and the associated training records are maintained in accordance with Training Department procedures.
2.0  FIRE BRIGADE TRAINING Fire Brigade training is outlined in the TQ-AA-173, Emergency Services Training Programs.
3.0  GENERAL EMPLOYEE TRAINING An overview of the Emergency Plan is given to all personnel allowed unescorted access into the protected area at Fort Calhoun Station. Personnel receive this information during initial training and are requalified on an annual basis. This training includes identification of the emergency alarm, the fire alarm and the steps to follow for a plant and site evacuation.
4.0  EMERGENCY PREPAREDNESS TRAINING PROGRAM TQ-FC-113, ERO Training and Qualification identifies the initial and continuing training requirements for emergency response personnel.
As appropriate, members of the onsite emergency response organization are qualified to wear respiratory equipment, including self-contained breathing apparatus (SCBA) through the General Employee Training, Level III, Respiratory Protection Training Program.
5.0  EMERGENCY RESPONSE ORGANIZATION TRAINING Requirements for initial training and continuing training of personnel assigned to the Emergency Response Organization is accomplished in accordance with TQ-FC-113, ERO Training and Qualification.
Requirements for initial training and continuing training of security personnel are outlined in the Security Training and Qualification Plan.
FCS Management is responsible to ensure all members of the Emergency Response Organization receive the required initial training and continuing training.

FCS EP-FC-1001 Section O Revision TBD RADIOLOGICAL EMERGENCY RESPONSE TRAINING 6.0  LOCAL SUPPORT SERVICES PERSONNEL TRAINING 6.1  Fire and Rescue Squads The Blair Fire Department and Rescue Squad and the Fort Calhoun Fire/Rescue are offered annual training by the Nebraska Emergency Management Agency. The Missouri Valley Fire and Rescue Squad and the Council Bluffs Fire and Ambulance Squad are offered annual training from the Iowa Homeland Security and Emergency Management Division. OPPD will provide assistance with training as requested.
This training normally includes an overview of the plant facility in order to familiarize them with the general area where their assistance may be requested, a review of the basic emergency classification levels, and a review of proper contamination control procedures.
6.2  Offsite Organizations Lead representatives and selected responders falling under the jurisdiction of the following offsite response organizations shall be offered annual training/retraining.
             - Washington County Emergency Management
             - Harrison County Emergency Management
             - Pottawattamie County Emergency Management
             - Douglas County Emergency Management
             - Nebraska Region 5/6 Emergency Management Members of the Fort Calhoun Station may assist with the state of Nebraska Emergency Management Agency and the state of Iowa Homeland Security and Emergency Management Division in preparing and presenting, on an annual basis, training to their Emergency Management agencies in radiological emergency response. Both states have outlined in their respective emergency plans the type of training to be given. Their training is not limited to Emergency Management agencies, but may also include key public officials and emergency services management as well as the state and police agencies and hospitals.
State and local Emergency Management groups are invited to participate in the biennial exercise conducted by the plant. Their participation in the biennial exercise supplements the annual training.
6.3  Law Enforcement Agencies Training for law enforcement agencies is typically conducted by the states of Iowa and Nebraska.

FCS EP-FC-1001 Section O Revision TBD RADIOLOGICAL EMERGENCY RESPONSE TRAINING 7.0  DOCUMENTATION OF TRAINING FCS training procedures outline the process to document training of the Fort Calhoun Station Emergency Response Organization. An Emergency Planning procedure is used to verify training received by offsite organizations.

FCS                                                                  EP-FC-1001 Section P Revision TBD RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION 1.0  RESPONSIBILITY FOR RADIOLOGICAL EMERGENCY RESPONSE PLANNING 1.1  The Plant Manager and Nuclear Division Managers are responsible for the implementation of actions required to periodically exercise the Radiological Emergency Response Plan (RERP), and the Implementing Procedures and for maintaining an effective Emergency Response Organization (ERO) staff.
1.2  The Plant Operations Review Committee is responsible for the review and approval of revisions to the RERP and the Implementing Procedure used for emergency classification in accordance with EP-FC-120 Attachment 2, EP Document Structure and Revision Process.
1.3  The Plant Manager is responsible for the final approval of RERP and the Implementing Procedure used for emergency classification, and for maintaining an effective emergency response capability at Fort Calhoun Station.
1.4  Nuclear Organization Responsible Management Contacts are responsible for selecting and proposing personnel to fill ERO positions and for ensuring support of the Radiological Emergency Response Plan.
1.5  The Manager- Site Emergency Planning is responsible for the development, administration and maintenance of the RERP, Implementing Procedures, and EP-FC procedures, review and approval of all Implementing Procedure changes (with the exception of the Implementing Procedure used for emergency classification), planner training, the overall development and implementation of the FCS ERO Training and Qualification Program and coordination of off-site emergency preparedness activities in the states of Iowa and Nebraska.
1.6  The Manager-Nuclear Training is responsible for the independent review and approval of the FCS ERO Training and Qualification Program.
1.7  The Emergency Planning Department is responsible for the preparation of all revisions to the RERP, Implementing Procedures and for coordinating the review processes necessary prior to the implementation of the revisions.
2.0  MAINTENANCE OF THE RERP AND IMPLEMENTING PROCEDURES 2.1  Emergency Planning personnel shall review the RERP and Implementing Procedures annually. Any changes found to be necessary as a result of the review shall be submitted using the established procedure change process.
2.2  Comments and recommendations made as a result of drills/exercises may require procedure changes to be initiated. These processes are detailed in the drill and exercise program.

FCS                                                                   EP-FC-1001 Section P Revision TBD RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION 2.3  Recurring tasks ensure that copies of the annual review and annual audit reports are reviewed by the Manager-EP and any changes incorporated as necessary.
2.4  Changes to the plan will be submitted to the NRC within 30 days in accordance with 10CFR50.54(q). The Radiological Emergency Response Plan and approved changes to the plan will also be forwarded to appropriate organizations and individuals with responsibility for implementation of the plan. A new edition of the Radiological Emergency Response Plan will be issued when major technical and significant philosophical changes are required.
2.5  All emergency telephone numbers are updated quarterly.
3.0  AUDITS 3.1  The Nuclear Oversight Department will coordinate an independent audit of the Emergency Preparedness Program at intervals not to exceed 24 months or more frequently as required by 10CFR50.54(t)(1). The audit shall include the Radiological Emergency Response Plan, implementing procedures, practices, drills, exercises, training, readiness testing, equipment and interfaces with state and local governments.
The results of this audit along with the recommendations for improvement must be documented and reported to the licensee's corporate and plant management. Copies of pertinent sections of the audit will be forwarded to appropriate state and local governments. This audit shall fulfill the requirements of 10CFR50.54(t). The results of this audit shall be retained for a minimum of five years.

FCS                                                                    EP-FC-1001 Section P Revision TBD RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION 1.0  LETTERS OF AGREEMENT REVIEW 1.1  Written agreements establishing the concept of operations developed between Fort Calhoun Station and other support organizations having an emergency response role within the EPZs have been developed. These agreements identify the emergency measures to be provided, the mutually accepted criteria for implementation, and the arrangements for exchange of information. Agreement letters are not necessary with Federal Agencies who are legally required to respond based on Federal law; however, agreements are necessary if the agency was expected to provide assistance not required by law. Letters of Agreement with private contractors and others who provide services in support of Fort Calhoun Station shall be maintained on file. Letters of Agreement, as a minimum, state that the cooperating organization will provide their normal services in support of an emergency at the affected station. A contract/purchase order with a private contractor is considered acceptable in lieu of a Letter of Agreement for the specified duration of the contract.
Organizations deemed to be First Responders, who are identified as Local Law Enforcement Agency (LLEA), Volunteer Fire Fighting Organizations, Emergency Medical Services (EMS), and the University of Nebraska Medical Center (UNMC), will contain wording to ensure they will respond to a Radiological event to include a Hostile Action Based event.
LLEA will support Fort Calhoun Nuclear Station during a Radiological or Hostile Action Based event, in conjunction with the National Incident Management System upon notification by the station in accordance with established communications protocol.
Fire Fighting Organizations will respond to a Radiological Event, including a Hostile Action Based Event, in conjunction with the National Incident Management System in accordance with established response and communication protocol. Fire Fighting Organizations may be requested to obtain and provide fire response, fire apparatus, and fire personnel.
EMS Support will provide Emergency Medical Services in response to a Radiological Event including a Hostile Action Based Event. This includes transportation of patients from the Fort Calhoun Nuclear Station, including those who may have been exposed to radiation or may have injuries complicated by radioactive contamination, to the University of Nebraska Medical Center by use of established communication protocol.
UNMC agrees in the event of a Radiological event, including a Hostile Action Based Event, to ensure the capability for the evaluation of radiation exposure and uptake, including assurance that persons providing these services are

FCS                                                                    EP-FC-1001 Section P Revision TBD RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION adequately prepared to handle contaminated individuals and capable of providing medical support for any contaminated individual.
A contract/purchase order with a private contractor is considered acceptable in lieu of a Letter of Agreement for the specified duration of the contract.
NOTE i  Copies of Current Letters of Agreement are on file in the Emergency Planning Department.
i 1.2   Law Enforcement Support Organizations Nebraska State Patrol Iowa State Patrol Harrison County Sheriff's Department Washington County Sheriff's Department Pottawattamie County Sheriff's Department Douglas County Sheriff's Department 1.3   Fire and Rescue Support Organizations Blair Fire Department Fort Calhoun Fire and Rescue Missouri Valley Fire Department 1.4   Medical Support Organizations UNMC Regional Radiation Health Center 1.5   Nebraska's Governmental Support Organizations State of Nebraska Emergency Management State of Nebraska-Department of Health and Human Services, Regulation and Licensure Washington County Board of Supervisors Nebraska Game and Parks Commission Douglas County Emergency Management Agency 1.6   Iowa's Governmental Support Organizations Iowa Homeland Security and Emergency Management Division

FCS                                                               EP-FC-1001 Section P Revision TBD RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION Harrison County Board of Supervisors Pottawattamie County Board of Supervisors Pottawattamie County Division of Telecommunications 1.7  Industrial Support Organizations Union Pacific Railroad Westinghouse Electric Electric Power Research Institute/Nuclear Energy Institute Institute of Nuclear Power Operations (INPO) 1.8  Other Support Organizations Nebraska Public Power District Metropolitan Utilities District National Weather Service Tierney-Blair LLC 1.9  Monitoring and Decontamination Support Organizations Omaha Fire Department Emergency Worker Decon

FCS                                                                    EP-FC-1001 Section P Revision TBD RESPONSIBILITY FOR THE PLANNING EFFORT: DEVELOPMENT, PERIODIC REVIEW AND DISTRIBUTION The following is a list of plans for organizations that support or supplement emergency response to the Fort Calhoun Station. These are maintained in the EOF.
State Iowa Radiological Emergency Response Plan, Part 2, Nuclear Power Plant Accident/Incident, Annex P of the Iowa Emergency Response Plan.
State of Nebraska - "Radiological Emergency Response Plan for Nuclear Power Plant Incidents" Local Crawford County (Iowa) - "Radiological Emergency Response Plan" Dodge County (Nebraska) - "Radiological Emergency Reception Plan for Nuclear Power Plant Incidents" Douglas County (Nebraska) - "Douglas County Supplement to Washington County Radiological Emergency Response Plan for Nuclear Power Plant Incidents" Harrison County (Iowa) - "Radiological Emergency Response Plan for Nuclear Power Plant Incidents" Pottawattamie County (Iowa) - " Radiological Emergency Response Plan" Sarpy County (Nebraska) - " Radiological Emergency Response Plan for Nuclear Power Plant Incidents" Washington County (Nebraska) - "Radiological Emergency Response Plan for Nuclear Power Plant Incidents"

FCS EP-FC-1001 Appendix C Revision TBD NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST PSRERP Appendix C provides a cross reference to track OPPD's implementation of the guidance provided by NUREG 0654, FEMA REP 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Rev. 1.
OPPD generally conforms to the guidance of NUREG-0654 in its Post Shutdown Radiological Emergency Response Plan (PSRERP), Emergency Plan Implementing Procedures (EPIP) and other supporting documents. However, OPPD has and may make exceptions to NUREG-0654 guidance providing it does not reduce the effectiveness or intent of the PSRERP or EPIPs.
For Section D, Emergency Classification System, OPPD uses the guidance of NEI-99-01, Development of Emergency Action Levels for Non-Passive Reactors. This variance from NUREG-0654 has been approved by the NRC.
All changes to the PSRERP are subject to a 10 CFR 50.54(q) screening, 10 CFR 50.47(b) and 10 CFR 50 Appendix E reviews. If the reviews determine that the change does not reduce the effectiveness or intent of the plan, the Plant Operating Review Committee (PORC) must then approve the change before it is implemented and sent to the NRC for review. If the screening process finds that the change does reduce the effectiveness or intent of the plan the change must be submitted to NRC for pre-approval prior to implementation.
All changes to EPIPs and other documents governed by the PSRERP are also subject to 10 CFR 50.54(q) screening. If it is determined that the proposed EPIP or other plant document change requires a PSRERP change a full 10 CFR 50.47(b), 10 CFR 50 Appendix E review and PORC approval is required prior to implementation and submittal to the NRC for review. NRC pre-approval must be obtained if a change is determined to reduce the effectiveness or the intent of the plan.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                 NUREG Criteria                 RERP Section      Implementing Procedure(s)
A. Assignment of Responsibility A.1.a     Identify the State, Local, Federal and          A 1.1-1.8      N/A private sector organizations (including utilities) intended to be a part of the ERO.
A.1.b     Each organization shall specify its               A 2.0,       EP-FC-112, Crisis concept of operations and its relationship    C 1.0, 2.0, 3.0, Communication Plan to the total effort.                                4.0 Appendix A A.1.c     Block diagram of organizational                  FIG. A-1      N/A interrelationships.
A.1.d     Identify a specific individual (by title) who      A 2.0       EP-FC-112 shall be in charge of the emergency response.
A.1.e     Provide for 24-hr per day response,                A 1.0       EP-FC-112 including communications links.
A.2.a     State/Local applicability                          N/A         N/A A.2.b     State/Local applicability                          N/A         N/A A.3      Letters of Agreement                            Appen. A       EP-FC-120 (Verification of RERP-Appendix A)
A.4      Capability of continuous 24-hour                A 1.0, 2.0     EP-FC-112 operations. Identify, by title, the individual in the principal organization responsible for continuity of resources.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                 NUREG Criteria               RERP Section      Implementing Procedure(s)
B. Onsite Emergency Organization B.1      Specify the onsite emergency                B 2.1, Table B-1 EP-FC-112-100, EP-FC-112-organization of plant staff personnel for                    200, EP-FC-112-300, EP-FC-all shifts and its relation to the                           112-400, EP-FC-112-500 responsibilities and duties of the normal staff complement.
B.2      Designate an individual as emergency           B 7.1, 7.2    EP-FC-112-100 coordinator who is on shift at all times.
B.3      Identify a line of succession for the             B 7.0      EP-FC-112 emergency coordinator position and identify the specific conditions for higher level utility officials assuming this function.
B.4      Specification of responsibilities, and            B 6.2      EP-FC-112 designation of which may not be delegated.
B.5      Positions or titles and major tasks to be   B 8/9/10/11/12,  EP-FC-112-100, EP-FC-112-performed by the persons assigned to           Table B-1     200, EP-FC-112-300, EP-FC-the functional areas of emergency                            112-400, EP-FC-112-500, activity.                                                    Crisis Communication Plan B.6      Interfaces between and among the            B-13, Table B-3 N/A onsite, offsite, corporate, state and local government response organizations.
B.7      Each licensee shall specify the corporate,     Table B-1     EP-FC-112-100, EP-FC-112-management, admin., and technical                 B 4.0      200, EP-FC-112-300, EP-FC-personnel who will augment plant staff in                    112-400, EP-FC-112-500 Table B-1 and in the following areas:
B.7.a     Logistics support, e.g., trans, comm,          B 9.0, 11.0   EP-FC-112-200-F-03, EP-FC-quarters, food, water, special equipment       Table B-2     112-400-F-07 and supplies purchase; B.7.b     Technical support for planning reentry            B 6.0      EP-FC-115 and recovery operations; B.7.c     Management level interface with                   B 13       EP-FC-112 government authorities; and B.7.d     Release of information to news media            B 12,13       EP-FC-112 during an emergency (coordinated with                         Crisis Comm. Plan governmental authorities).
B.8      Specification of contractor and private       A 1.0, B-13,    EP-FC-112-200-F-03, EP-organizations to provide assistance.         B-15, Fig. B-3,  FC-112-400-F-07, Appen A       EP-FC-120 (Verification of RERP-Appendix A)
B.9      Expected services from local agencies        A 1.0 Appen A    EP-FC-120 (Verification of e.g., police, fire, ambulance, medical,     B 15, Table B-1,  RERP-Appendix A) hospital.                                       Fig B-3 RERP Sec L Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                NUREG Criteria              RERP Section    Implementing Procedure(s)
C. Emergency Response Support and Resources C.1      Incorporation of Federal response into          C1 the operational plan:
C.1.a     Specific persons to request Federal        C1.1, B 6.3.1  EP-FC-112 assistance (See A.1.d and A.2.a)
C.1.b     Specific Federal resources expected and     C 1.2-1.3     N/A expected times of arrival, and C.1.c     Specific licensee, state, local resources     C 2.0       N/A to support Federal response, air fields, command posts, tel lines, radio frequencies, and telecommunications centers.
C.2.a     State/Local Applicability                      N/A        N/A C.2.b     Licensee representative to offsite EOCs      C 3.0       EP-FC-112-400 C.3      Radiological laboratories, general            C 2.2       N/A capabilities and expected availability to      4.0 provide radiological monitoring and analyses services which can be used in an emergency.
C.4      Identify Nuclear and other facilities,        C 4.0,      EP-FC-112-200-F-03, EP-organizations or individuals which can be   Appen A       FC-112-400-F-07, relied upon in an emergency to provide                    EP-FC-120 (Verification of assistance. Such assistance shall be                      RERP Appendix A) identified and supported by appropriate letters of agreement.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                 NUREG Criteria          RERP Section  Implementing Procedure(s)
D. Emergency Classification System D.1
* Establish an Emergency Action Level        D 2.0    EP-FC-1001 Addendum 3 Scheme and Emergency Classification scheme.
D.2
* Initiating conditions shall include        D 1.0    EP-FC-1001 Addendum 3 NUREG-0654, Appendix 1 conditions and all FSAR postulated accidents.
D.3       State/Local applicability                   N/A     N/A D.4       State/Local applicability                   N/A     N/A
* NEI-99-01 Guidance has replaced NUREG-0654 Appendix 1 guidance.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                    NUREG Criteria                 RERP Section  Implementing Procedure(s)
E. Notification Methods and Procedures E.1      Notification procedures consistent with EALs           E 2.0     EP-FC-114 including a means for verification of messages.
E.2      Procedures for alerting, notifying and mobilizing      E 2.0     EP-FC-112-100-F-06 emergency response personnel.
E.3      Licensee and state/local establish content of the      E 3.1     EP-FC-114 initial messages, and shall contain: class, release, potentially affected population, and if PARs are needed.
E.4      Provisions for follow-up messages, and shall           E 3.2     EP-FC-114 contain the following:
E.4.a     Location of incident, and name and telephone           E 3.2     EP-FC-114 number (or communications channel identification) of caller; E.4.b     Date/time of incident;                                 E 3.2     EP-FC-114 E.4.c     Class of emergency;                                    E 3.2     EP-FC-114 E.4.d     Type of actual/projected release, and estimated        E 3.2     EP-FC-114 duration/impact times; E.4.e     Estimate of radioactive material released or           E 3.0     EP-FC-110-200 being released and the points and height of releases.
E.4.f     Chemical and physical form of material,                E 3.0     EP-FC-110-200 estimates of quantities/concentration of noble gases, iodines, and particulates; E.4.g     Met conditions at appropriate levels: wind speed,      E 3.0     EP-FC-114 direction (to and from) stability, precip, if any; E.4.h     Type of actual projected does rates at site            E 3.0     EP-FC-110-200 boundary, projected integrated dose at site boundary:
E.4.i     Projected dose rates and integrated dose at 2, 5,      E 3.0     EP-FC-110-200 and 10 miles, include the sector(s) affected; E.4.j     Estimate of any surface contamination inplant,         E 3.0     EP-FC-110-200 onsite, offsite; E.4.k     Licensee emergency response actions                    E 3.0     EP-FC-114 underway; E.4.l     Recommended emergency actions, including               E 3.2     EP-FC-114 protective measures; E.4.m      Request for any needed onsite support by offsite       E 3.0     EP-FC-114 organizations, and; E.4.n     Prognosis for worsening/termination based on           E 3.2     EP-FC-114 plant information.
E.5      State/Local applicability                               N/A      N/A E.6      Notification/prompt instructions to the public.        E 4.0     EP-FC-112, EP-FC-121 (ANS)
E.7      Written messages for the public, consistent with       E 5.0     EP-FC-112 the EALs, to include ad hoc PARs.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                 NUREG Criteria              RERP Section       Implementing Procedure(s)
F. Emergency Communications F.1.a     Provision for 24 hour notification to and       E 2.0         EP-FC-114 activation of the State/local ER network,       F 1.0 with telephone link and backup, and             F 2.0 24-hour manning of communication links          F 2.3 that initiate emergency response actions;       F 2.4 F.1.b     Communications with contiguous             F 2.0, 2.3, 2.4,   EP-FC-114 states/locals;                               Fig F-1, F-2 F.1.c     Communications with Federal EROs;         F 2.3, 2.9, 2.10,   EP-FC-114 F 2.12, F 2.13, Fig. F-1 F.1.d     Communication between the plant, EOF,      F 2.4, 2.5, 2.8, EP-FC-112 state and local EOCs, and rad monitor        2.11, 2.17, teams;                                    Fig. F-1, Fig. F-2 F.1.e     Provision for alerting or activating            E 2.0         EP-FC-112-100-F-06 emergency personnel in each response organization, and F.1.f     Communication (by licensee) with NRC       F 2.3, 2.8, 2.9,   EP-FC-112-400 HQ and Regional Office EOC and the          2.10, F-2.12, EOF and Rad Mon Team Assembly area.              2.22 F.2      Each organization shall ensure that a           F 3.0         EP-FC-112-300-AD-F-coordinated comm link for fixed and                           04,FCSG-15 mobile medical support facilities exists.
F.3      Each organization shall conduct periodic        N 2.1         EP-FC-124 testing of the entire emergency communications system. (See also H.10, N.2.a and Appendix 3).
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                 NUREG Criteria              RERP Section  Implementing Procedure(s)
G. Public Education and Information G.1      Each organization shall provide a             G 1.0      Corporate Crisis coordinated periodic (at least annually)                 Communication Plan; dissemination of information to the public               EP-FC-120 re: how they will be notified, and what their actions should be.
G.2      The public information program shall          G 1.0      Corporate Crisis provide permanent and transient adult                    Communication Plan; population within the EPZ an adequate                    EP-FC-120 opportunity to become aware of the information annually. This section also makes reference to: Signs, decals, posted notices, for hotel, motels, gas stations, and phone booths).
G.3.a      Media contact point during an emergency       G 2.0      Corporate Crisis (i.e., JIC, etc).                                        Communication Plan G.3.b      Space for limited number of news media        G 2.0      Corporate Crisis at the EOF.                                              Communication Plan G.4.a      Each organization shall have a                G 3.0      Corporate Crisis spokesperson.                                            Communication Plan G.4.b      Each organization shall establish             G 3.0      Corporate Crisis arrangements for timely exchange of                      Communication Plan information among designated spokes persons.
G.4.c     Each organization shall establish             G 2.1      Corporate Crisis coordinated arrangements for dealing                     Communication Plan with rumors.
G.5      Each organization shall conduct               G 4.0      EP-FC-120 coordinated programs at least annually to acquaint news media with the emergency plans, information concerning radiation, and points of contact for release of public information in an emergency.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                NUREG Criteria               RERP Section      Implementing Procedure(s)
H. Emergency Facilities and Equipment H.1      Each licensee shall establish a TSC and          H 1.0,      EP-FC-112 an OSC.                                            3.0 H.2      Establish an EOF.                                H 2.0       EP-FC-112 H.3      State/Local applicability                         N/A        N/A H.4      Timely activation of the facilities and      H 1.3, 2.3,     EP-FC-112 centers described in the Plan.                 3.3, 4.3 H.5      Each licensee shall identify and establish onsite monitoring systems that are to be used to initiate emergency measures, in accordance with Appendix 1, as well as those used to conduct assessment. The equipment shall include:
H.5.a     Geophysical phenomena monitors, (e.g.,           I 2.0,      EP-FC-1001 Addendum 3 met, hydrological, seismic);                    I 2.1.2, I 2.1.3, I 2.2.3, I 2.3.2(c)
H.5.b     Rad monitors, (e.g., process, area,        H.1.2, 2.2, 3.2,  EP-FC-1001 Addendum 3 emergency, effluent, wound and portable        4.2, 5.0      EP-FC-110 monitors and sampling equipment);               I 2.2.1      EP-FC-112-500 I 2.2.2      EP-FC-113 RP-AA-350 H.5.c     Process monitors (e.g., reactor coolant           I 2.2      EP-FC-1001 Addendum 3 system pressure and temp, containment                        EP-FC-121 pressure and temp, liquid levels, flow rates, status or lineup of equipment components); and H.5.d     Fire and combustion products detectors.         I 2.1.1      EP-FC-1001 Addendum 3 SO-G-28, Station Fire Plan H.6      Each licensee shall make provision to acquire data from or for emergency access to offsite monitoring and analysis equipment, including:
H.6.a     Geophysical phenomena monitors (e.g.,           I 2.1.2      EP-FC-1001 Addendum 3 met, hydrologic, seismic):                       2.1.3 2.2.3 H.6.b     Radiological monitors including                  H 2.2       EP-FC-112-500 ratemeters and sampling devices.                   5.2       EP-FC-113 Dosimetry shall be provided and shall              5.3       RP-AA-700 meet, as a minimum, the NRC Rad                    5.6 Assessment Branch Tech Position for the Environmental Rad Monitoring program; and H.6.c     Laboratory facilities, fixed or mobile. C 2.0, C 4.0     EP-FC-112-500 H.7      Each organization, where appropriate,           I 2.3.3      EP-FC-112-500 shall provide for offsite rad monitoring          J 2.5 equipment in the vicinity of the plant.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                NUREG Criteria                 RERP Section  Implementing Procedure(s)
H.8      Each licensee shall provide met                 I 2.2.3    EP-FC-110-200 instrumentation and procedures which                       EP-FC-110-201 satisfy the criteria in Appendix 2, and provisions to obtain representative current met data from other sources.
H.9      Each licensee shall provide for an onsite        H 3.0     EP-FC-112-300 OSC which shall have adequate capacity and supplies, including, for example, respiratory protection, protective clothing, portable lighting, portable radiation monitoring equipment, cameras and communications equipment for personnel present in the OSC.
H.10      Inspect/inventory/operationally check            H 5.0     EP-FC-124 equipment at least quarterly and after                     RP-AA-700 each use. There shall be sufficient reserves of instruments/equipment to replace those which are removed from emergency kits for calibration or repair.
H.11      Identify emergency kits, by general              H 5.0     EP-FC-124 category (i.e., protective equipment, comm equipment, rad monitoring equipment.
H.12      Each organization will establish a central       H 2.1     EP-FC-112-500 point for receipt and analysis of all field monitoring data and coordination of sample media.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                NUREG Criteria                RERP Section  Implementing Procedure(s)
I. Accident Assessment I.1     Identify plant system and effluent             Sec D      EP-FC-1001 Addendum 3 parameter values characteristic of a             I 1.0 spectrum of off-normal conditions and             2.0 accidents, and shall identify the plant parameter values or other information which correspond to the example initiating conditions of Appendix 1.
I.2     Onsite capability and resources to               I 1.0    EP-FC-1001 Addendum 3 provide initial values and continuing             2.0     EP-FC-110-200 assessment throughout the course of an                    EP-FC-110-201 accident shall include post accident sampling capability, radiation and effluent monitors, in-plant iodine instrumentation and containment radiation monitoring.
I.3     Each licensee shall establish methods and techniques to be used for determining:
I.3.a     The source term of releases of                  D 1.0     EP-FC-110-200 radioactive material within plant systems. Table D-1   EP-FC-110-201 I.3.b     The magnitude of the release of                 D 2.0     EP-FC-111-AD-F-02 radioactive materials based on plant                      EP-FC-110-200 system parameters and effluent monitors.                  EP-FC-110-201 I.4     Each licensee shall establish the               D 2.0     EP-FC-111-AD-F-02 relationship between effluent monitor                     EP-FC-110-200 readings and onsite and offsite                           EP-FC-110-201 exposures and contamination for various met conditions.
I.5     Each licensee shall have the capability of     I 2.2.3    EP-FC-111-AD-F-02 acquiring and evaluating met information                  EP-FC-110-200 sufficient to meet the criteria of Appendix               EP-FC-110-201 2.
I.6     Each licensee shall establish the                I 3.1    EP-FC-111-AD-F-02 methodology for determing the release                     EP-FC-110-200 rate/projected doses of the                               EP-FC-110-201 instrumentation used are offscale or inoperable.
I.7     Field monitoring plans.                          I 2.3    EP-FC-112-500 I.8     Provide methods, equipment and                   I 3.0    EP-FC-111-AD-F-02 expertise to make rapid assessment of                     EP-FC-110-200 the actual or potential magnitude of any                  EP-FC-110-201 rad hazard through liquid or gaseous release pathways.
I.9     Each organization shall have a capability        I 3.0    EP-FC-112-500 to detect and measure radioiodine concentrations in air in the plume exposure EPZ as low as 10-7 Ci/cc under field conditions.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                NUREG Criteria                 RERP Section  Implementing Procedure(s)
I.10     Each organization shall establish means         I 3.0      EP-FC-110-200 for relating the various measured                          EP-FC-110-201 parameters (e.g. contamination levels, water and air activity levels) to dose rates for key isotopes and gross radioactivity measurements.
I.11     Arrangements to locate and track the            I 2.3      EP-FC-112-500 plume.                                                     EP-FC-110-200 EP-FC-110-201 Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                 NUREG Criteria                RERP Section  Implementing Procedure(s)
J. Protective Response J.1       Each licensee shall establish the means        J 1.3.2 and time required to warn or advise             J 1.1 individuals within the owner-controlled area, including:
J.1.a      Employees not having emergency                  J 1.1     EP-FC-113 assignments;                                   J 1.3.2 Visitors;                                       J 1.1     EP-FC-113 J.1.b                                                     J 1.3.2 Contractor and construction personnel,          J 1.1     EP-FC-113 J 1.c      and                                            J 1.3.2 J 1.d      Other persons who may be in the public          J 1.1     EP-FC-113 access areas or passing through the site       J 1.3.2 or within the owner-controlled area.
J.2       Make provisions for evacuation routes           J 1.2     EP-FC-113 and transportation for onsite individuals     Table J-9 to some suitable offsite location, including alternatives for inclement weather, high traffic density and specific rad conditions.
J.3       Each licensee shall provide for                 J 1.2     EP-FC-113 radiological monitoring of people evacuated from the site.
J.4       Each licensee shall provide for the             J 1.2     EP-FC-113 evacuation of onsite non-essential personnel in the event of a Site Area or General Emergency and shall provide a decon capability at or near the monitoring point specified in J.3, above.
J.5       Each licensee shall provide for a              J 1.3.2    EP-FC-113 capability to account for all individuals                 SY-AA-101-121 onsite at the time of the emergency and ascertain the names or missing individuals within 30 minutes of the start of the emergency and account for all onsite individuals continuously thereafter.
J.6       Each licensee shall, for people remaining onsite, make provisions for:
J.6.a      Individual respiratory protection;             J 1.4.4    EP-FC-113 RP Manual J.6.b      Use of protective clothing;                    J 1.4.3    EP-FC-113 RP Manual J.6.c      Use of KI.                                     J 1.4.5    EP-FC-113 J.7       Each licensee shall establish a                J 2.1.1    EP-FC-114 mechanism for recommending PAs to State and locals.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section               NUREG Criteria                 RERP Section  Implementing Procedure(s)
J.8     Each licensees plan shall contain an            J 2.3     EP-FC-1001 Addendum 2 ETE. These shall be in accordance with Appendix 4.
J.9     State/local applicability                        N/A      N/A Table J-9 J-10 J.10     The organizations plans to implement protective measures for the EPZ shall include:
J.10.a     Maps showing evacuation routes,                J 2.3.2    EP-FC-113 evacuation areas, preselected                  Fig J-1    ANS Map radiological sampling and monitoring             J-2      10-Mile EPZ Map points, relocation centers in host areas, and shelter areas; J.10.b     Maps showing pop distribution around           J 2.3.3    EP-FC-1001 Addendum 2 the Nuclear facility. This shall also be by    Fig J-4 evacuation areas;                                J-7 J-8 J.10.c     Means for notifying all segments of the         J 2.2     EP-FC-121 transient and resident population; J.10.d     State/local applicability                        N/A      N/A J.10.e     State/local applicability                        N/A      N/A J.10.f    State/local applicability                        N/A      N/A J.10.g     State/local applicability                        N/A      N/A J.10.h     State/local applicability                        N/A      N/A J.10.i    State/local applicability                        N/A      N/A J.10.j    State/local applicability                        N/A      N/A J.10.k     State/local applicability                        N/A      N/A J.10.l    State/local applicability                        N/A      N/A J.10.m     The basis for the choice of recommended         J 2.1     EP-FC-111 protective actions from the EPZ during        Table J-2 emergency conditions.                            J-3 J-4 J.11     State applicability                              N/A      N/A J.12     State/local applicability                        N/A      N/A Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                 NUREG Criteria                RERP Section     Implementing Procedure(s)
K. Radiological Exposure Control K.1       Each licensee shall establish onsite exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity PAGs for:
K.1.a      Removal of injured persons;                     K 1.0        EP-FC-113, RP Manual K.1.b      Undertaking corrective actions;                 K 1.0        EP-FC-113, RP Manual K.1.c      Performing assessment actions;                  K 1.0        EP-FC-113, RP Manual K.1.d      Providing first aid;                            K 1.0        EPIP-EOF-11, FCSG-15-7 RP Manual K.1.e      Performing personnel decon;                     K 1.0        EP-FC-113, RP Manual K.1.f      Providing ambulance service; and                K 1.0        EP-FC-113, FCSG-15-7 RP Manual K 1.g      Providing medical treatment services.           K 1.0        EP-FC-113, FCSG-15-7 RP Manual K.2       Each licensee shall provide an onsite rad       K 1.0        EP-FC-113 protection program to be implemented                         RP Manual during emergencies, including methods to implement exposure guidelines.
K.3.a      24 hour capability to determine the doses       K 1.2        RP Manual received by emergency personnel                              EP-FC-113 involved in any nuclear accident, including volunteers.
K.3.b      Each organization shall ensure that            J 1.4.2       RP Manual dosimeters are read at appropriate              K 1.2 frequencies.
K.4       State/local applicability                        N/A         N/A K.5.a      Action levels for determining the need for      K 2.1        RP-AA-350 decon.
K.5.b      Decon of personnel wounds, supplies,            K 2.0,       RP-AA-350 instruments and equipment and for waste          3.0 disposal.
K.6       Each licensee shall provide onsite contamination control measure including:
K.6.a      Area access control;                            K 2.0        RP-AA-350 K.6.b      Drinking water and food supplies;               K 2.4        EP-FC-112-200-F-14 K.6.c      Criteria for permitting return of areas and     K 2.5        RP-AA-350 items to normal use (see ANSI 12.13).
K.7       Each licensee shall provide the capability  K 2.1, 2.2, 2.3  EP-FC-113 for decon of relocated onsite personnel,        L 3.2 including provisions for extra clothing and decontaminants suitable for the type of contamination given to radioiodine contamination of the skin.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                NUREG Criteria                 RERP Section  Implementing Procedure(s)
L. Medical and Public Health Support L.1      Each organization shall arrange for local       L 3.0      RP-AA-220 and backup hospital and medical                            FCSG-15-7 services having the capability for evaluation of radiation exposure and uptake, including assurances that persons providing these services are adequately prepared to handle contaminated persons.
L.2      Each licensee shall provide for onsite first    L 1.0      FCSG-15-7 aid capability.
L.3      State applicability                              N/A       N/A L.4      Each organization shall arrange for             L 2.0      FCSG-15-7 transportation of rad victims to medical support facilities.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                 NUREG Criteria                 RERP Section  Implementing Procedure(s)
M. Recovery and Reentry Planning and post Accident Operations M.1      Each organization shall develop plans            M 1.3      EP-FC-115 and procedures for reentry and recovery           2.0 and describe the means by which decisions to relax protective measures are reached.
M.2      Each licensee plan shall contain the             M 1.2      EP-FC-115 position/title, authority and responsibilities of individuals who will fill key positions in the recovery organization.
M.3      Each licensee and state plan shall               M 1.2      EP-FC-115 specify the means for informing members of the response organizations that a recovery operation is to be initiated, and of any changes in the organizational structure that may occur.
M.4      Each plan shall establish a method for           I 3.0      EP-FC-200 periodically estimating total population exposure.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                NUREG Criteria                RERP Section     Implementing Procedure(s)
N. Exercises and Drills N.1.a     Exercises shall be conducted as set forth         N          EP-FC-122 in NRC and FEMA rules.
N.1.b     An exercise shall include mobilization of       N 1.0        EP-FC-122 State and local personnel and resources...shall provide for a critique by federal and state observers/evaluators...scenario varied from year to year....6:00 PM and Midnite/Midnite and 6:00 AM exercises....under various weather conditions....some unannounced.
N.2.a     Communications drills:
Comm with State and Locals                      N 2.1        EP-FC-122 (monthly)
Comm with Federal EROs and states               N 2.1        EP-FC-122 within the IPZ (quarterly)
Comm between the plant, state and local         N 2.1        EP-FC-122 EOCs, and field assessment teams (annually)
N.2.b     Fire Drills                                     N 2.2        OP-AA-201-005 N.2.c     Medical Emergency Drills                        N 2.3        EP-FC-122 N.2.d     Rad Monitoring Drills                           N 2.4        EP-FC-122 N.2.e     HP Drills Shall be conducted semi-annually which          N 2.4        EP-FC-122 involve response to and analysis of simulated elevated airborne and liquid samples and direct rad measurements.
The state drills need not be at each site.
Analysis of inplant liquid samples with         N 2.4        EP-FC-122 actual elevated rad levels including use of the PASS shall be included in HP drills by licensees annually.
N.3      Each organization shall describe how exercises and drills are to be carried out to allow free play for decision making and to meet the following objectives. ....The scenarios shall include, but not be limited to, the following:
N.3.a     Basic objectives and appropriate            N 1.0, 2.0, 3.0  EP-FC-122 evaluation criteria; N.3.b     Dates, time periods, places, and            N 1.0, 2.0, 3.0  EP-FC-122 participating organizations; N.3.c     The simulated events;                       N 1.0, 2.0, 3.0  EP-FC-122 N.3.d     Time schedule of real and simulated         N 1.0, 2.0, 3.0  EP-FC-122 initiating events; N.3.e     A narrative summary;                        N 1.0, 2.0, 3.0  EP-FC-122 Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section               NUREG Criteria               RERP Section  Implementing Procedure(s)
N.3.f     A description of arrangements and           N 1.0, 4.0  EP-FC-122 advance materials for official observers.
N.4      An exercise critique.                         N 4.0     EP-FC-122 N.5      Evaluating the comments from observers        N 4.0     EP-FC-122 and participants.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                 NUREG Criteria               RERP Section  Implementing Procedure(s)
O. Radiological Emergency Response Training O.1       Each organization shall assure training of    O 4.0      TQ-FC-113 appropriate individuals.                       5.0 O.1.a       Each facility shall train members of the      O 5.0      TQ-FC-113 ERO.
O.1.b       State/local applicability                     O 6.0      N/A O.2       Training shall include drills.                N 2.0      TQ-FC-113 O.3       Licensee training for First Aid teams to      O 1.0      TQ-AA-174 include ARC Multi-Media or equivalent.
O.4       Each organization shall establish a training program for ERO. Training shall be in the following categories:
O.4.a       Directors or coordinators of EROs;            O 5.0      TQ-FC-113 O.4.b       Accident assessment personnel;                O 5.0      TQ-FC-113 O.4.c      Rad Mon Teams and rad analysis                O 5.0      TQ-FC-113 personnel; Police, security and fire fighting            O 6.0      EP-FC-10 O.4.d       personnel;                                               SY-AA-150 O.4.e       Repair and damage control/correctional        O 5.0      TQ-FC-113 action teams (onsite);
O.4.f      First aid and rescue personnel;               O 1.0      TQ-AA-173 6.0 O.4.g       Local support services personnel,             O 6.0      EP-FC-10 including CD/Emergency Services personnel; O.4.h       Medical Support Personnel;                    L 3.2      TQ-AA-173 O 6.0 O.4.i      Licensee Headquarters support                 O 4.0      TQ-FC-113 personnel;                                               Crisis Communication Plan O.4.j      Personnel responsible for transmission of     O 4.0      TQ-FC-113 emergency information and instructions.
O.5       Initial and annual retraining.                O 5.0      TQ-FC-113 Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST NUREG Section                  NUREG Criteria                RERP Section  Implementing Procedure(s)
P. Responsibility for the Planning Effort; Development, Periodic Review and Distribution of Emergency Plans P.1       Each organization shall provide for the          P 1.0     EP-FC-11 training of individuals responsible for the planning effort.
P.2       Each organization shall identify by title        P 1.0     EP-FC-11 the individual with overall planning authority; P.3       Each organization will designate an              P 1.0     EP-FC-11 Emergency Planning Coordinator.
P.4       Each organization shall update its plan          P 2.0     EP-FC-120 and agreements as needed, review and certify it to be current on an annual basis.
Changes will take into consideration items from drills and exercises.
P.5       Plans and plan changes shall be                  P 2.0     EP-FC-120 forwarded to all organizations and appropriate persons with EP responsibility. Revised pages dated and marked to show changes.
P.6       List supporting plans and source.              APPEN B     N/A P.7       Each plan shall contain an appendix            APPEN C     N/A listing procedures required to implement the plan. The listing shall include the sections of the plan to be implemented by each procedure.
P.8       Each plan shall contain a table of             APPEN C     N/A contents. Plans submitted for review should be cross-referenced to these criteria.
P.9       Independent review of the plans.                 P 3.0     EP-FC-120 P.10       Quarterly update of plan telephone               P 4.0     EP-FC-124 numbers.
Refer to Attachment 1 - PSRERP Titles, for names of PSRERP Sections Refer to Attachment 2 - EPIP Titles, for names of EPIP's

FCS EP-FC-1001 Appendix C Revision TBD NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST Attachment 1 - PSRERP Titles Document                                Document Title PSRERP           Radiological Response Plan For Fort Calhoun Station PSRERP-SECTION A Assignment of Organizational Responsibility (Organizational Control)
PSRERP-SECTION B Organizational Control of Emergencies PSRERP-SECTION C Emergency Response Support and Resources PSRERP-SECTION D Emergency Classification System PSRERP-SECTION E Notification Methods and Procedures PSRERP-SECTION F Emergency Communications PSRERP-SECTION G Public Education and Information PSRERP-SECTION H Emergency Facilities and Equipment PSRERP-SECTION I Accident Assessment PSRERP-SECTION J Protective Response PSRERP-SECTION K Radiological Exposure Control PSRERP-SECTION L Medical and Public Health Support PSRERP-SECTION M Recovery and Reentry Planning and Post Accident Operations PSRERP-SECTION N Exercises and Drills PSRERP-SECTION O Radiological Emergency Response Training PSRERP-SECTION P Responsibility for the Planning Effort: Development, Periodic Review and Distribution PSRERP-APPENDIX  Letters of Agreement A
PSRERP-APPENDIX  Supporting Emergency Plans B
PSRERP-APPENDIX  NUREG/RERP/Implementing Procedure Cross Reference List C
PSRERP-APPENDIX  OPPD Resolution #4731, Radiological Emergency Response Plan D                Authority

FCS EP-FC-1001 Appendix C Revision TBD NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST PSRERP-APPENDIX  Definitions and Abbreviations E

FCS EP-FC-1001 Appendix C Revision TBD NUREG/PSRERP/IMPLEMENTING PROCEDURE CROSS REFERENCE LIST Attachment 2 - EPIP Titles Document                           Document Title EP-FC-1001      EMERGENCY ACTION LEVELS FORT CALHOUN STATION Addendum 3 EP-FC-110       ASSESSMENT OF EMERGENCIES EP-FC-111       EMERGENCY CLASSIFICATION AND PROTECTIVE ACTION RECOMMENDATIONS EP-FC-112       EMERGENCY RESPONSE ORGANIZATION (ERO) EMERGENCY RESPONSE FACILITY (ERF) ACTIVATION AND OPERATION EP-FC-112-100   CONTROL ROOM OPERATIONS EP-FC-112-200   TSC ACTIVATION AND OPERATION EP-FC-112-300   OPERATIONS SUPPORT CENTER ACTIVATION AND OPERATION EP-FC-112-400   EMERGENCY OPERATIONS FACILITY ACTIVATION AND OPERATION EP-FC-112-500   EMERGENCY ENVIRONMENTAL MONITORING EP-FC-112-700   ALTERNATE FACILITY OPERATION EP-FC-113       PERSONNEL PROTECTIVE ACTIONS EP-FC-114       NOTIFICATIONS EP-FC-115       TERMINATION AND RECOVERY

FCS                                              EP-FC-1001 Appendix D Revision TBD OPPD RESOLUTION # 4731, RADIOLOGICAL EMERGENCY RESPONSE PLAN AUTHORITY

FCS                                              EP-FC-1001 Appendix D Revision TBD OPPD RESOLUTION # 4731, RADIOLOGICAL EMERGENCY RESPONSE PLAN AUTHORITY

FCS EP-FC-1001 Appendix E Revision TBD DEFINITIONS AND ABBREVIATIONS 1.0  DEFINITIONS AND ABBREVIATIONS 1.1  ALARA - As Low As is Reasonably Achievable - Means making every reasonable effort to maintain exposures to radiation as far below the dose limits as is practical consistent with the purpose for which the licensed activity is undertaken, taking into account the state of technology, the economics of improvements in relation to state of technology, the economics of improvements in relation to benefits to the public health and safety, and other societal and socioeconomic considerations, and in relation to utilization of nuclear energy and licensed materials in the public interest 1.2  ANS - Alert Notification System - Described in Section E 1.3  AR - Action Request 1.4  Assessment Actions - The appropriate actions taken during or following an accident evaluation before implementing the specific corrective and/or protective actions 1.5  CDE - Committed Dose Equivalent - (HT50) The dose equivalent to organs or tissues of reference (T) that will be received from an intake of radioactive material by an individual during the 50 year period following the intake 1.6  CFR - Code of Federal Regulations 1.7  CHP - Conference Health Physics Network - Described in Section E 1.8  Committed Effective Dose Equivalent - (HE50) Sum of the products of the weighing factors applicable to each of the body organs or tissues that are irradiated and the committed dose equivalent to these organs or tissues 1.9  Control Room - Functions described in Section H 1.10 COP - Conference Operations (Phone) Network- Described in Section E 1.11 Corrective Actions - Measures taken to correct or mitigate an emergency condition at its origin in order to prevent an uncontrolled release of radioactive material or reduce the magnitude of the release.
1.12 CR - Control Room - Functions described in Section H 1.13 Deep Dose Equivalent - (DDE or Hd) applies to external whole-body exposure, is the dose equivalent at a tissue depth of 1 cm (1000 mg/cm2) 1.14 T - Delta Temperature - The difference in temperature between points 10 meters and 60 meters above the ground in units of centigrade. The value displayed on the ERFCS equates to; 100m T = [(T @ 60m - T@ 10m) x 2)]
153

FCS EP-FC-1001 Appendix E Revision TBD DEFINITIONS AND ABBREVIATIONS 1.15 DOE - Department Of Energy - Role is discussed in Section C 1.16 Drill - Described in Section N 1.17 DSC - Dry Shielded Canister 1.18 DSO - Director of Site Operation (NRC) 1.19 EAD Electronic Alarming Dosimeter 1.20 URI/RASCAL - Emergency Assessment of Gaseous and Liquid Effluent-Section E 1.21 EAL - Emergency Action Level - Described in Section D 1.22 EAS - (Emergency Alerting System) - Described in Section E 1.23 ECCS - Emergency Core Cooling System 1.24 ENS - (FTS-ENS) Federal Telephone System Emergency Notification System -
Described in Section F 1.25 EOC - Emergency Operations Center - Discussed in Sections C and F 1.26 EOF - Emergency Operations Facility - Functions described in Section H 1.27 EPA - Environmental Protection Agency - Role Discussed in Section C 1.28 EPIP - Emergency Plan Implementing Procedures 1.29 EPT - Emergency Plan Test - Described in Section P 1.30 EPZ - Emergency Planning Zone - Described in Section J 1.31 ERDS - Emergency Response Data System - Described in Section F 1.32 ERFCS - Emergency Response Facilities Computer System - Described in Section H 1.33 ERO - Emergency Response Organization - Duties Described in Section B 1.34 Exercise - Described in Section N 1.35 FAA - Federal Aviation Administration - Role discussed in Section C 1.36 FEMA - Federal Emergency Management Agency - Role described in Section C 1.37 FTS - Federal Telecommunications Systems (NRC Phone Circuits) - Discussed in Section F 154

FCS EP-FC-1001 Appendix E Revision TBD DEFINITIONS AND ABBREVIATIONS 1.38 GAR - Governors Authorized Representative - Authorized by letters in Appendix A 1.39 HPN - Health Physics Network - Described in Section F 1.40 HSM - Horizontal Storage Module 1.41 ISFSI - Independent Spent Fuel Storage Installation 1.42 IPZ - Ingestion Pathway Zone - Discussed in Section J 1.43 JIC - Joint Information Center - Functions discussed in Section B 1.44 NAWAS - National Warning System - Functions described in Section F 1.45 NRC - Nuclear Regulatory Commission - Role discussed in Section C 1.46 NWS - National Weather Service - Role discussed in Section C 1.47 Operation Liaison Network- Described in Section F 1.48 OSC - Operation Support Center - Functions described in Section H 1.49 PABX - Private Automatic Branch Exchanges - Function described in Section H 1.50 PAG - Protective Action Guideline - Discussed in Section J 1.51 PAR - Protective Action Recommendation - Discussed in Section J 1.52 Protective Actions - Discussed in Section J 1.53 REM - The special unit of any of the quantities expressed as dose equivalent. The dose equivalent in rems is equal to the absorbed dose in rads multiplied by the quality factor (1 rem = .01 sievert).
1.54 SDE - Shallow Dose Equivalent - Is the dose equivalent at a tissue depth of 0.007 cm or 7 mg/cm2 averaged over an area of 10 cm2. It applies to the external exposure of the skin or an extremity.
1.55 TEDE - Total Effective Dose Equivalent - The sum of the deep-dose equivalent (for external exposures) and the committed effective dose equivalent (for internal exposures). This represents the combined dose (DDE+CEDE) to a worker.
1.56 TLD - Thermoluminescent Dosimeter - A device worn by plant personnel to measure the amount of radiation received.
1.57 TSC - Technical Support Center - Functions described in Section H 155

FCS EP-FC-1001 Appendix E Revision TBD DEFINITIONS AND ABBREVIATIONS 1.58 UNMC Regional Radiation Health Center - Role discussed in Section L 1.59 USAR - Updated Safety Analysis Report 156

FORT CALHOUN STATION ANALYSIS OF PROPOSED POST-SHUTDOWN ON-SHIFT STAFF August 18, 2016 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing TABLE OF CONTENTS I. INTRODUCTION..................................................................................................................... 2 II. ANALYSIS 

==SUMMARY==
 ........................................................................................................... 3 A.       Emergency Plan Minimum Staffing ............................................................................. 4 B.       Other Commitments to Shift Staffing ........................................................................... 6 C.       Staffing Exceptions and Time Motion Studies (TMS) .................................................. 6 D.       Emergency Plan Tasks Not Analyzed ......................................................................... 7 III. ANALYSIS PROCESS ............................................................................................................ 8 IV. ACCIDENT SCENARIOS........................................................................................................ 8 A.       Accident Selection ....................................................................................................... 8 B.       Accident Scenarios included in this Analysis .............................................................. 9 C.       Accident Scenarios not included in the Analysis ....................................................... 10 V. GENERAL ASSUMPTIONS AND LIMITATIONS.................................................................. 11 A.       Notes and Assumptions applicable to all accidents in FCS Staffing Analysis: .......... 11 B.       NEI 10-05 Rev 0 Assumptions: ................................................................................. 12 VI. APPENDIX A - ANALYZED EVENTS AND ACCIDENTS ..................................................... 14 VII. APPENDIX B - ON-SHIFT STAFFING ANALYSIS .............................................................. 15 A.       Accident Analysis #1 - Design Basis Threat ............................................................. 15 B.       Accident Analysis #2 - Fuel Handling Accident with General Emergency and PAR 20 C.       Accident Analysis #3 - Aircraft Potential Threat ....................................................... 25 D.       Accident Analysis #4 - Event Requiring Control Room Evacuation and Maintain SFP Cooling ...................................................................................................................... 30 VIII. APPENDIX C - TIME MOTION STUDIES SUPPORTING THE STAFFING ANALYSIS ..... 35 A.       Analysis #1 - Design Basis Threat............................................................................ 35 B.       Analysis #2 - Fuel Handling Accident with General Emergency and PAR ............... 38 C.       Analysis #3 - Aircraft Potential Threat ...................................................................... 41 D.       Analysis #4 - Event Requiring Control Room Evacuation and Maintain SFP Cooling44 IX. OVERLAP OF TASKS ACTIVITIES OR OTHER CONFLICTS IDENTIFIED ....................... 47 A.       Overlap Requiring Compensatory Measures ............................................................ 47 X. REFERENCES...................................................................................................................... 47 Fort Calhoun Station                                                                                                                                  Page 1 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing I.      INTRODUCTION On June 24, 2016, Omaha Public Power District (OPPD) informed the Nuclear Regulatory Commission (NRC) that the Fort Calhoun Station (FCS) will permanently cease operations no later than December 31, 2016. OPPD will supplement the June 24, 2016 letter certifying the cessation date in accordance with 10 CFR 50.82(a)(1)(i) and 10 CFR 50.4(b)(9). Once fuel has been permanently removed from the reactor vessel, OPPD will submit a written certification to the NRC, in accordance with 10 CFR 50.82(a)(1)(ii) that meets the requirements of 10 CFR 50.4(b)(9). Upon docketing of these certifications, the 10 CFR Part 50 license for FCS will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel, as specified in 10 CFR 50.82(a)(2). In the permanently defueled condition, the Updated Safety Analysis Report (USAR) credible accidents (postulated accidents) are reduced via the 50.59 process. In order to address the transition from an operating facility to a permanently defueled facility, changes are required to maintain the effectiveness of the Emergency Plan and to properly reflect the conditions of the facility.
This report details the analysis of the proposed post-shutdown on-shift staffing for FCS, incorporating anticipated changes to the on-shift staffing to address post-shutdown and permanently defueled conditions. Specifically, it reassigns some on-shift tasks to align with proposed changes to on-shift staffing and the resulting changes to FCS Emergency Plan Implementing Procedures. This analysis will be updated and formal Time Motion Studies (TMSs) will be conducted, as necessary, following development and validation of procedures that address FCS permanently shut down and defueled conditions.
This analysis evaluates the ability of the proposed post-shutdown minimum on-shift staff to implement all emergency tasks, evaluated in accordance with NEI 10-05, Rev. 0, Assessment of On-shift Emergency Response Organization Staffing and Capabilities, as applicable to the post-shutdown and permanently defueled conditions.
This analysis satisfies the requirements of 10 CFR Part 50, Appendix E Section IV.A.9, which states that nuclear power licensees shall perform a detailed analysis demonstrating that on-shift personnel assigned emergency plan implementation functions are not assigned responsibilities that would prevent the timely performance of their assigned functions as specified in the emergency plan. To support reduced staffing following permanent cessation of operations and permanent removal of fuel from the reactor vessel, the proposed post-shutdown on-shift staffing was evaluated in conjunction with the postulated accidents that will be applicable in the permanently defueled condition and assumed corresponding changes to procedures. This analysis examined the anticipated capability of the proposed post-shutdown minimum on-shift staff to perform the actions for the key functional areas of events described in NSIR/DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants, until augmenting Emergency Response Organization (ERO) staff arrives in accordance with the Emergency Plan.
Fort Calhoun Station                                                                                                   Page 2 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing II. ANALYSIS 

==SUMMARY==

This analysis determined that a proposed post-shutdown on-shift staff of eight (8) is able to cope with the spectrum of analyzed events, as described in Section IV of this report, until augmenting ERO staff arrives. The on-shift staff consists of individuals necessary to support each of the following emergency plan functional areas or tasks:
Emergency Direction and Control Plant Operations and SFP Cooling Fire Fighting (Fire Brigade)
Accident/Dose Assessment Radiation Protection Notification/Communication Access Control and Accountability FCS intends to enter the post-shutdown and permanently defueled condition with a 5-person Fire Brigade.
However, 10 CFR 50.48(f) states, Licensees that have submitted the certifications required under &sect; 50.82(a)(1) shall maintain a fire protection program to address the potential for fires that could cause the release or spread of radioactive materials (i.e., that could result in a radiological hazard). 10 CFR 50.48(f)(1)(ii) requires the plant to rapidly detect, control, and extinguish fires that do occur. The NRC has provided guidance in Regulatory Guide 1.191, Fire protection Program for Nuclear Plants During Decommissioning and Permanent Shutdown.
Subsection 4.3.4 Onsite Fire Brigade and Offsite Fire Emergency Response, provides guidance with regards to maintenance of a fire brigade during the post-shutdown period. The following factors should be considered in determining the manual firefighting capability:
The magnitude and complexity of potential fires in and around plant areas where radioactive materials or contamination are present The availability of onsite staffing for a fire brigade at any time.
The availability of offsite emergency services, the capability of their staff and equipment, the response time, the staffs training, and access to the plant.
The compatibility of the plants fire system connections and fittings with the fire apparatus and equipment of the offsite responders.
Considering the guidance in RG 1.191, FCS could elect to evaluate the possibility of making changes to the fire protection program, considering system abandonments and the reduction of hazards. This analysis could potentially include an evaluation of the feasibility of a smaller fire brigade. However, this analysis of proposed post-shutdown on-shift staffing considers the current 5-person fire brigade.
NEI 10-05 states it is acceptable for certain functions to be assigned to personnel already assigned other functions/tasks. These include Repair and Corrective Action, Rescue Operations, and First Aid.
Fort Calhoun Station                                                                                                      Page 3 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing A. Emergency Plan Minimum Staffing Per 10 CFR 50.54(q)(1)(iii), Emergency planning function means a capability or resource necessary to prepare for and respond to a radiological emergency, as set forth in the elements of section IV of Appendix E and, for nuclear power reactor licensees, the planning standards of &sect; 50.47(b).
Only personnel proposed to be on-shift are credited in this analysis. This proposed staffing consists of a Shift Manager (SM)/Certified Fuel Handler (CFH); a Control Room Operator (CRO); three Equipment Operators; and a Radiation Protection Technician. Additionally, two additional Fire Brigade positions and shift Security personnel are assigned. The on-shift staffing utilized for this analysis was defined with the following considerations:
The Shift Manager performs as Emergency Director until properly relieved by a qualified position.
After being relieved by another Command and Control position, the Shift Manager will provide assistance and direction to the Control Room staff as necessary.
Control Room Operator duties include providing technical support for plant systems, providing input on repair and corrective actions, and notifications as directed by the Shift Manager. These notifications include the following: 1) required notifications to the states and counties; 2) required notifications to the NRC; and 3) notifications to the Emergency Response Organization. A CRO will also serve as the Fire Brigade Leader in compliance with National Fire Protection Association (NFPA) 805 implementation at FCS with requisite plant knowledge to fill this role.
Equipment Operators duties include making repairs and corrective actions on plant equipment until augmented plant maintenance staff arrives, participating as an active member of the Fire Brigade, or as Fire Brigade Leader when assigned by the Shift Manager.
Shift Radiation Protection (RP) Technician duties include conducting radiological accident assessment and support, offsite dose assessment, onsite in plant surveys, offsite dose assessment, and chemistry and radiochemistry analysis.
The proposed Fire Brigade minimum complement is 5, consisting of a CRO (Fire Brigade Leader), 2 assigned Equipment Operators, and two (2) other Fire Brigade qualified staff members assigned other functions.
The following table contains the proposed post-shutdown on-shift positions expected to be in place following shutdown and permanent removal of fuel from the reactor vessel.
This analysis will be updated and formal TMSs will be conducted, as necessary, following development and validation of procedures that address FCSs permanently shut down and defueled conditions to verify the proposed post-shutdown on-shift staffing is appropriate.
Fort Calhoun Station                                                                                                    Page 4 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing On-Shift Licensing Basis                                                           Staffing Position                                                          E-Plan Functional Area Requirement                                                              Analysis Results Shift Manager (SM)/Certified Fuel                                                   Emergency Direction E-Plan Table B-1                                                               1 Handler (CFH)1                                                                 and Control Notifications/Communications /
Control Room Operator (CRO #1)                    E-Plan Table B-1                                                               1 Fire Brigade Leader Equipment Operator/Non-Certified                                               Notifications/Communications /
E-Plan Table B-1                                                               1 Operator (NCO) #11                                                            Dose Assessment Equipment Operator/NCO #21 (FB E-Plan Table B-1                         Fire Brigade                        1(a)
                       #2)
NCO #31 (FB #3)                         E-Plan Table B-1                         Fire Brigade                        1(a)
Fire Brigade #4 (FB #4)                     E-Plan Table B-1                         Fire Brigade                      1(a) (b)
Fire Brigade #5 (FB #5)                     E-Plan Table B-1                         Fire Brigade                      1(a) (b)
Radiation Protection (RP)                                                       Radiation Protection E-Plan Table B-1                                                               1 Technician                                                        Accident/Dose Assessment2 Security Contingency                  Access Control and                   Per Security Security Plan/E-Plan Table B-1                      Accountability                Contingency Plan TOTAL                                                                                                           8 1 Titles are dependent upon NRC approval of future changes to Technical Specifications. CFHs will supervise fuel handling operations in the permanently defueled condition. NCOs will perform duties typically associated with those performed by Equipment Operators, such as manipulation and monitoring of plant equipment.
2 The  RP Technician or an NCO is assigned Accident/Dose Assessment responsibilities in the Fuel Handling Accident analyses (Analyses #2 and #5), as directed by the Shift Manager. There are no Accident/Dose Assessment tasks identified as being required during the remaining analyses.
(a)    Per SO-G-28, Station Fire Plan, the Fire Brigade consists of a minimum of 5 responders, the Fire Brigade Leader and a minimum of four (4) trained and qualified Fire Brigade Members with no less than two members who have completed Equipment Operator non-license classroom training. These positions do not have any emergency plan actions or tasks that would conflict with Fire Brigade responsibilities in the events analyzed. The Fire Brigade qualified staff is available to support the Shift Manager, where qualified, in non-fire events.
(b)    Provided by Fire Brigade qualified staff assigned other functions.
Fort Calhoun Station                                                                                                                Page 5 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing B. Other Commitments to Shift Staffing None C. Staffing Exceptions and Time Motion Studies (TMS)
: 1.       No chemistry job tasks were noted as being required within the first 90 minutes of any of the analyzed events. Because the Chemistry Technician was not identified as having any specific Chemistry/Radio-Chemistry related emergency tasks during the scenarios evaluated for this analysis, the Chemistry Technician position is not included in the proposed post-shutdown on-shift staffing complement.
: 2.       During fuel movement, Operations and Radiation Protection personnel that are not part of the on-shift staff are assigned to conduct and monitor that activity. Consequently, there are an adequate number of qualified personnel to perform plant surveys and dose assessment in the event of a fuel handling accident as discussed in Events 2 and 5. It is acceptable to assign the RP Technician the emergency plan function of dose assessment. No further analysis or TMS is required.
: 3.       Because FCS will no longer be authorized to operate the reactor or place fuel into the reactor vessel, the Shift Technical Advisor (STA) position is unnecessary and is not included in the proposed post-shutdown on-shift staffing complement.
: 4.       Because FCS will no longer be authorized to operate the reactor or place fuel into the reactor vessel, the Safe Shutdown (SSD) task is not necessary and is not considered in this analysis.
: 5.       Because of the reduced actions necessary to mitigate an emergency in the permanently defueled condition and the minimal actions of the Control Room positions in a permanently defueled condition, no Licensed Nuclear Operator (RO) job tasks were noted as being required for any of the analyzed events. Because the ROs were not identified as having any specific emergency tasks during the scenarios evaluated for this analysis, the RO position is not included in the proposed post-shutdown on-shift staffing complement.
: 6.       Guidance provided in Table 3.1 of NEI 10-05 indicates the need to perform a TMS to verify the capability of the CRO to perform the Notification/Communication responsibilities assigned in each analysis. The FCS process for completing state and local emergency notifications and performing the off-site notifications requires minimal manual actions. A TMS was conducted and demonstrated that these tasks could be performed by the on-shift CRO without impacting the ability of the CRO to remain in role providing support and oversight during the emergency. The TMS demonstrated the Notification/Communication responsibilities could be performed individually or in series without impacting the CRO function. The results are documented in Section VIII of this analysis.
Fort Calhoun Station                                                                                                  Page 6 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing
: 7. Plant staff are required to maintain continuous communications with the notification source during an aircraft threat in accordance with 10 CFR 50.54(hh) and Reg. Guide 1.214. There are no specific qualifications required to perform this task and the function is not required to be assigned in advance. A TMS of CRO activities during an aircraft threat confirmed that the proposed plant staffing is adequate to perform this task.
: 8. The Emergency Response Data System (ERDS) requirement in Appendix E to 10 CFR Part 50 exempts all nuclear power facilities that are shut down permanently from the need to provide an ERDS interface with the NRC. Therefore, the FCS ERDS link to the NRC is not required to be operational in a permanently shut down and defueled condition. Although use of ERDS may be continued, the task of ERDS verification is not included as an on-shift task requiring evaluation as part of this staffing analysis.
: 9. NRC event notifications required due to the declaration of an Emergency Classification in accordance with 10 CFR 50.72 are made in accordance with EP-FC-114, Notifications.
D. Emergency Plan Tasks Not Analyzed
: 1. Repair and Corrective Action - Per the guidance of NUREG-0654, Table B-1, repair and corrective action tasks may be performed by shift personnel assigned other functions. Repair and corrective action is defined as:
An action that can be performed promptly to restore a non-functional component to functional status (e.g., resetting a breaker), or to place a component in a desired configuration (e.g.,
open a valve), and which does not require work planning or implementation of lockout/tagout controls to complete.
In accordance with NEI 10-05 section 2.5, the analysis included a review of repair and corrective action tasks. For the purpose of this analysis, the tasks were considered to fall into two broad categories:
Unplanned/unexpected actions that address equipment failures. These actions are contingent in nature and cannot be specified in advance.
Planned/expected actions performed in support of operating procedure implementation, including severe accident management guidelines.
At FCS the NCOs are trained to perform the actions associated with this functional area. Actions (e.g., reset breakers, valve manipulation) directed by the CRO to mitigate the event per procedures were performed by the NCOs in this analysis. Repair and Corrective Action is an acceptable collateral duty per the guidance of NEI 10-05 and was not analyzed.
Fort Calhoun Station                                                                                                Page 7 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing
: 2.       Rescue Operations and First Aid: In accordance with NEI 10-05 section 2.6, the analysis also included a review of rescue operations and first aid response although neither task was required during the evaluated scenarios. Per the guidance of NUREG-0654, Table B-1, rescue operations and first aid may be performed by shift personnel assigned other functions. An on-shift RP Technician will provide radiation protection oversight. The station fire brigade staff is trained in rescue operations and is available to perform these tasks if required. First aid and rescue operations are acceptable collateral duties per the guidance of NEI 10-05.
III. ANALYSIS PROCESS This analysis was developed by reviewing each scenario from EP-FC-1001, Addendum 1, Fort Calhoun Station On-Shift Technical Basis, to determine its applicability in a permanently shut down and defueled condition and to evaluate the plant actions and emergency plan implementation actions that would be required based on plant procedures prior to staff augmentation. These actions were then compared to the proposed post-shutdown on-shift positions expected to be in place following permanent shutdown and permanent removal of fuel from the reactor vessel, ensuring that no actions were assigned to staff members that conflicted with either their proposed emergency plan role or operational role as appropriate. In cases where multiple tasks were assigned to an individual in their role, an evaluation of the timing of the tasks was conducted to ensure that they could be performed by the individual in series within any specified time requirements.
The results of the analysis for each of the scenarios are included in Section VII, APPENDIX B - ON-SHIFT STAFFING ANALYSIS. Note that NSIR/DPR-ISG-01 states that only Design Basis Accidents (DBA) which would result in an emergency declaration should be evaluated in the staffing assessment. In a permanently shut down and defueled condition, USAR Chapter 14 will be revised to eliminate the DBAs that will not be applicable in the permanently defueled condition. These DBAs include the loss of coolant accident and main steam line break.
IV. ACCIDENT SCENARIOS A.       Accident Selection
: 1.       The scenarios were chosen using the guidance of NEI 10-05 and NSIR/DPR-ISG-01, based on the applicability in a permanently shut down and defueled condition. The evaluation considered the plant DBAs described in the USAR along with additional scenarios specified by the guidance documents. The following scenarios were considered for inclusion in this analysis:
: 1.        Design Basis Threat (DBT) ground assault as described in NEI 10-05
: 2.        Fuel Handling Accident (FHA) with General Emergency and Protective Action Recommendation (PAR)
: 3.        Aircraft Potential Threat as described in 10 CFR 50.54(hh)
: 4.        Event requiring evacuation of the Control Room Fort Calhoun Station                                                                                                      Page 8 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing
: 5.        Control Room habitability during toxic chemical release accidents
: 6.        Station Blackout (SBO) as described in NEI 10-05.
B. Accident Scenarios included in this Analysis
: 1. Design Basis Threat The event consists of notification to the Shift Manager from the Security Shift Supervisor that a hostile action is occurring at or inside the Protected Area. A hostile force will breach the Protected Area fence but is not sufficient to interrupt SFP cooling or cause a radiological release and is neutralized with no adverse consequences to plant safety. Damage inflicted on plant systems, structures and components is not sufficient to cause a radiological release. There is no fire significant enough to warrant firefighting efforts prior to the arrival of offsite resources and/or the augmented ERO.
The event must account for the expected constraints on the movement of personnel (e.g.,
movement not allowed, limited movement using the 2-person rule, etc.). Specifically, individuals must usually be in, or readily able to respond to, assigned response locations before being credited with performing a function/task that implements the emergency plan.
An analysis objective is to confirm that sufficient staff is available to simultaneously implement both the emergency plan and the security plan.
: 2. Fuel Handling Accident (FHA) with General Emergency and PAR The postulated design basis accident that will remain applicable to FCS in its permanently shut down and defueled condition is the FHA in the Auxiliary Building where the SFP is located. The activity associated with a FHA in the spent fuel pool is collected by the fuel pool area ventilation system and released, unfiltered, to the environment, via the auxiliary building vent stack. Since there is no means of isolating, the spent fuel pool area, all of the airborne activity resulting from the FHA is exhausted out of the auxiliary building in a period of two hours.
This event assumes a dose that exceeds the Environmental Protection Agencys (EPA)
Protective Action Guides (PAGs) beyond the site boundary, and thus necessitates promulgation of a PAR.
: 3. Aircraft Potential Threat (50.54(hh))
This event includes all emergency response actions taken prior to an aircraft impact in accordance with RG 1.214 for an aircraft threat that is greater than 5 minutes, but less than 30 minutes, from the site, including the dispersal of the fire brigade away from target areas. These actions should generally reflect those listed in 10 CFR 50.54(hh)(1), as expanded upon in Regulatory Guide 1.214, and others required by the emergency plan.
Fort Calhoun Station                                                                                                      Page 9 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing The event consists of notification to the Shift Manager from the NRC Headquarters Operations Officer that an Aircraft Potential Threat has been declared for Fort Calhoun Station.
: 4. Event Requiring Evacuation of the Control Room An event occurs requiring the evacuation of the Control Room and procedures implemented to control auxiliary cooling water pumps from a remote location.
C. Accident Scenarios not included in the Analysis
: 1. Control Room Habitability during Toxic Chemical Release Accidents A control room habitability study was prepared which determined the effect of accidental release of toxic gases on the Fort Calhoun Control Room. The onsite spill analysis postulates that either hydrazine ethanolamine or morpholine spills outside during container movement. The analysis demonstrates that the Control Room toxic gas concentration resulting from such a spill will not exceed the toxicity limit, thus Control Room habitability will not be affected. The analysis also demonstrates that the outside spill scenario is the limiting case.
The ammonia toxic chemical accident caused by the failure of two 25,000 ton offsite refrigerated tanks required detectors at the fresh air intake of the Control Room to provide for operator warning and automatic isolation of the Control Room. The toxic limit for ammonia given in RG 1.78 is 100 ppm. For FCS toxic gas analysis, the limit chosen for ammonia is 300 ppm based on evaluation of exposure data to determine a suitable short term toxic limit. FCS conservatively assumes incapacitation if the instantaneous concentration exceeds the toxic limit of 300 ppm for ammonia. Control Room Personnel are adequately protected against the effects of accidental release of toxic gas by the use of monitors, which automatically isolate the Control Room during a toxic gas accident.
On-shift staff duties and responsibilities to mitigate the consequences of this incident are bounded by those performed in response to Design or License Basis Accidents. Therefore, this scenario is not considered in this analysis.
: 2. Station Blackout ISG-01 provides guidance associated with the staffing analysis for a Station Blackout (SBO). ISG-01 states, in part:
Station blackouts are beyond the plants design basis and may not need to be addressed in the staffing analysis. The blackout coping analyses performed by licensees pursuant to 10 CFR 50.63 establish blackout coping times that exceed the required on-shift staff augmentation time.
Fort Calhoun Station                                                                                                Page 10 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing 10 CFR 50.63(a)(1) states, in part:
Each light-water-cooled nuclear power plant licensed to operate under this part, each light-water-cooled nuclear power plant licensed under subpart C of 10 CFR part 52 after the Commission makes the finding under &sect; 52.103(g) of this chapter, and each design for a light-water-cooled nuclear power plant approved under a standard design approval, standard design certification, and manufacturing license under part 52 of this chapter must be able to withstand for a specified duration and recover from a station blackout as defined in &sect; 50.2.
Upon docketing of the certification of permanent removal of fuel in accordance with 10 CFR 50.82(a)(1)(ii), per 10 CFR 50.82(a)(2) the Part 50 license will no longer authorize operation of the reactor or emplacement of fuel in the reactor vessel. FCS will no longer be a nuclear power plant licensed to operate under 10 CFR Part 50, therefore the provisions of 10 CFR 50.63 will no longer be applicable. The SBO scenario is no longer considered an appropriate gauge by which to measure whether an event presents on-shift staff with responsibilities that would prevent the timely performance of assigned functions in the E-Plan. Therefore, this scenario is not considered in this analysis.
V.      GENERAL ASSUMPTIONS AND LIMITATIONS A. Notes and Assumptions applicable to all accidents in FCS Staffing Analysis:
: 1. The RP and Chemistry tasks reviewed were those directed by the Shift Manager to support actions in Operations procedures for Off-Normal and Emergency conditions, and Emergency Plan procedures and checklists. Any additional tasks directed by the Technical Support Center (TSC),
Operations Support Center (OSC), or Emergency Operations Facility (EOF) procedures were not reviewed.
: 2. This analysis was conducted assuming a 60 minute response of the augmented ERO . Tasks for event response were reviewed for 60 minutes following the declaration. No specific emergency response tasks requiring the augmented ERO were identified during the 60 minutes following the emergency declaration.
: 3. There are no time critical RP or Chemistry tasks and task performance is directed and prioritized by the Shift Manager. The time RP is directed to perform a task and the amount of time taken to complete tasks are estimated. No Chemistry samples are required by Tech Specs within the 90 minute period after a declaration.
Fort Calhoun Station                                                                                              Page 11 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing B. NEI 10-05 Rev 0 Assumptions:
: 1. Response time used for this analysis was the maximum acceptable number of minutes elapsed between emergency declaration and the augmented ERO position holder at a location necessary to relieve an on-shift position of the emergency response task.
: 2. On-shift personnel complement was based on the proposed post-shutdown on-shift positions expected to be in place following shutdown and permanent removal of fuel from the reactor vessel.
: 3. Although the temporary absence of a position may be allowed by Technical Specifications, the analysis was performed assuming that all required on-shift positions are filled.
: 4. Each analyzed event occurred during off-normal work hours where the ERO was offsite and all required minimum on-shift positions were filled.
: 5. On-shift personnel reported to their assigned response locations within timeframes sufficient to allow for performance of assigned actions.
: 6. On-shift staff had necessary Radiation Worker qualification to obtain normal dosimetry and enter the radiological control area (RCA) (but not locked high or very high radiation areas) without the aid of an RP Technician.
: 7. Personnel assigned plant operations met the requirements and guidance (analyzed through other programs such as Operator training) and were not evaluated as part of this assessment unless a role/function/task from another major response area was assigned as a collateral duty.
: 8. In-plant (manual) operator actions to manipulate components and equipment from locations outside the Control Room to achieve and maintain SFP cooling was done by a member of the on-shift staff as defined in Technical Specifications.
: 9. Fire Brigade staff performance is analyzed through other plant programs (e.g., fire drills) and was not evaluated as part of this assessment unless a role/function/task from another major response area was assigned as a collateral duty.
: 10. Individuals holding the position of RP Technician are qualified to perform the range of tasks expected of their position.
: 11. Security was not evaluated unless a role or function from another major response area was assigned as a collateral duty.
: 12. Communications, briefings, and peer checks are acceptable collateral duties.
: 13. All on-shift staff positions were evaluated, even if they had no known collateral duties, to ensure they can perform the tasks assigned to them. [Ref NSIR/DPR-ISG-01]
Fort Calhoun Station                                                                                                Page 12 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing
: 14. The analysis specified the resources available to perform Repair and Corrective Actions and Rescue Operations and First Aid but these may be assigned as collateral duty to a designated on-shift responder.
: 15. For assessment purposes, NRC notifications were treated as a continuous action per 10CFR50.72(c)(3) and 73.71(b)(1). This means once the initial NRC communications are established, the NRC will request an open line be maintained with the NRC Operations Center.
: 16. DBA (postulated accident, Condition IV event, or limiting fault) is considered as Unanticipated occurrences that are postulated for accident analysis purposes but not expected to occur during the life of the plant. A postulated accident could result in sufficient damage to preclude resumption of plant operation. As a result, a greater number and variety of actions would need to be implemented by plant personnel.
: 17. DBT assumed a hostile force breached the Protected Area fence but was neutralized with no adverse consequences to plant safety. Damage inflicted on plant systems, structures and components was not sufficient to interrupt SFP cooling or cause a radiological release. There was no fire significant enough to warrant firefighting efforts prior to arrival of offsite resources and/or the augmented ERO.
: 18. The analysis used DBA analysis assumptions, inputs, timing of events, plant protective response, and specified manual operator actions and their timing, as documented in the USAR.
: 19. In cases where a DBA analysis included a radiological release, and the starting point of the release was not clearly defined, the staffing analysis assumed that the release began 15-minutes after the initiating event.
Fort Calhoun Station                                                                                                   Page 13 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing VI. APPENDIX A - ANALYZED EVENTS AND ACCIDENTS Summary Event                                                            Reference                            Analysis Event #                          Description of            Plant Mode1                                Event ECL Type                                                          Document(s)                           Required?
Event 1             DBT         Land and/or                   Permanently     NEI 10-05                  Site Area           Yes waterborne                     Defueled                                 Emergency HOSTILE ACTION directed against the Protected Area by a HOSTILE FORCE.
Assume adversary characteristics defined by the Design Basis Threat (DBT).
2             DBA         Fuel Handling                 Permanently     USAR Chapter 14            General             Yes (General      Accident with                  Defueled       (as revised to            Emergency Emergency       General Emergency                             address with PAR       and PAR                                       permanently assumed                                                      defueled for                                                      conditions)
Analysis Purposes) 3          Assumed        Aircraft Potential            Permanently     10 CFR                        Alert            Yes for        Threat                         Defueled       50.54hh(1)
Analysis Purposes                                                     RG 1.214 4          Assumed        Event requiring               Permanently     10 CFR Part 50.48             Alert            Yes for        Control Room                   Defueled Analysis      evacuation Purposes 5          Assumed        Control Room                  Permanently     USAR Chapter 14               Alert            No2 for        habitability during a          Defueled Analysis      toxic chemical Purposes       release accident 6          Assumed        Station Blackout              Permanently     10 CFR 50.63               Site Area           No3 for                                       Defueled                                 Emergency Analysis Purposes 1
Once FCS submits the certification of permanent removal of fuel in accordance with 10 CFR 50.82(a)(1)(ii), per 10 CFR 50.82(a)(2) the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement of fuel in the reactor vessel. FCS will no longer be a nuclear power plant licensed to operate under Part 50.
2 On-shift staff duties and responsibilities to mitigate the consequences of this incident are bounded by those performed in response to Design or License Basis Accidents. Therefore, this scenario is not considered in this analysis.
3 Once FCS submits the certification of permanent removal of fuel in accordance with 10 CFR 50.82(a)(1)(ii), per 10 CFR 50.82(a)(2) the 10 CFR Part 50 license will no longer authorize operation of the reactor or emplacement of fuel in the reactor vessel, therefore the provisions of 10 CFR 50.63 will no longer be applicable.
Fort Calhoun Station                                                                                                                          Page 14 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing VII. APPENDIX B - ON-SHIFT STAFFING ANALYSIS A. Accident Analysis #1 - Design Basis Threat
: 1. Accident Summary Land and/or waterborne HOSTILE ACTION directed against the Protected Area by a HOSTILE FORCE. Assume adversary characteristics defined by the DBT.
: 2. Accident Specific Assumptions Made This event assumes the threat is neutralized immediately when inside the Protected Area fence, no significant damage to equipment or systems that require corrective actions before the ERO is staffed, no radiological release, and no fire that requires firefighting response before the ERO is staffed.
Assume Spent Fuel Pool Temperature of 125&#xba;F.
Security notifies the Shift Manager of condition of hostile action occurring within the Protected Area.
Assume all non-security staff is located inside the Protected Area at their normal work station when the event occurs.
Assume all systems function and the spent fuel remains covered. No fuel damage and no release.
: 3. Procedures for Accident Response AOP 37, Security Events EP-FC-112, Emergency Classification and Protective Action Recommendations EP-FC-1001, Addendum 3, Emergency Action Levels for Fort Calhoun Station Fort Calhoun Station                                                                                              Page 15 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing FCS TABLE 1 - ON-SHIFT POSITIONS Analysis # 1 DBT Security Threat Augmentation Role in Table #
Line                                                                       Unanalyzed     TMS On-shift Position E-Plan Reference     Elapsed Time       / Line #
        #                                                                           Task?     Required?
(min)*
T2/L1 T5/L1 Emergency Plan                            T5/L3 1       Shift Manager                                                          No         No Table B-1                                 T5/L5 T5/L7 T5/L8 T2/L2 T5/L6 Control Room  Emergency Plan                            T5/L9 2                                                                              No        Yes1 Operator #1  Table B-1                                T5/L10 T5/L13 T5/L14 Emergency Plan 3          NCO #1                                                N/A           No         No Table B-1 Emergency Plan 4      NCO #2 (FB #2)                                            N/A           No         No Table B-1 Emergency Plan                             N/A 5      NCO #3 (FB #3)                                                          No         No Table B-1 Emergency Plan                             N/A 6            FB #4                                                             No         No Table B-1 Emergency Plan                             N/A 7            FB #5                                                             No         No Table B-1 Emergency Plan                             N/A 8       RP Technician                            60                            No         No Table B-1 Emergency Plan                            T2/L8 9          Security                                                            No         No Table B-1                                T5/L15 1
See Section VIII.A Fort Calhoun Station                                                                                    Page 16 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing Minimum Operations Crew Necessary to Implement AOPs if Applicable FCS TABLE 2 - PLANT OPERATIONS One Unit - One Control Room Analysis # 1 - DBT Security Threat Task Analysis Line #            Generic Title/Role             On-Shift Position              Task Description Controlling Method Crew direction and   Ops Training Program 1    Shift Manager                               Shift Manager oversight Perform CR Ops     Ops Training Program 2    CRO #1                                 Control Room Operator tasks/Communications 3    NCO #2                                             N/A                         N/A                  N/A 4    NCO #3                                             N/A                         N/A                  N/A Other (non-Operations) Personnel Necessary to Implement AOPs if Applicable Task Analysis Line #       Generic Title/Role             On-Shift Position                  Task Description Controlling Method N/A             Mechanic                          N/A                                N/A                  N/A N/A            Electrician                        N/A                                N/A                  N/A N/A          I&C Technician                       N/A                                N/A                  N/A N/A            Security Training 8              Security                    Security Force Program Fire Brigade FCS TABLE 3 - FIREFIGHTING Analysis # 1 - DBT Security Threat Line                 Performed by                                Task Analysis Controlling Method 1                        N/A                                                    N/A 2                        N/A                                                    N/A 3                        N/A                                                    N/A 4                        N/A                                                    N/A 5                        N/A                                                    N/A This accident does not include the need for firefighting, first aid, or search & rescue.
Fort Calhoun Station                                                                                                Page 17 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing FCS TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis # 1 - DBT Security Threat L Position Performing                  Performance Time Period After Emergency Declaration (minutes)
I Function / Task N                       0-5 5-10 10 20 30 40 50 60 70 80   E                                   15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 1 In-Plant Survey:
RP Technician       N/A 2   On-site Survey:
3   Personnel Monitoring:
4   Job Coverage:
5   Offsite Rad Assessment:
6   Other site specific RP (describe):
7   Chemistry Function task #1 (describe) 8   Chemistry Function task #2 (describe)
No Chemistry or RP job function tasks for the conditions described in the DBT assumptions. RP takes cover as directed.
Fort Calhoun Station                                                                                           Page 18 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing FCS TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis # 1 - DBT Security Threat Function / Task                                     On-Shift        Task Analysis Controlling Line#
Position                    Method Ops Training Program 1      Declare the emergency classification level (ECL)                        Shift Manager       EP Drill & Exercise Program 2      Approve Offsite Protective Action Recommendations                              N/A                        N/A Ops Training Program 3      Approve content of State/local notifications                            Shift Manager       EP Drill & Exercise Program 4      Approve extension to allowable dose                                            N/A                        N/A Ops Training Program Notification and direction to on-shift staff (e.g., to assemble, 5                                                                              Shift Manager       EP Drill & Exercise evacuate, etc.)
Program Ops Training Program 6      ERO notification                                                            CRO #1          EP Drill & Exercise Program AOP-37 Security Events, 7      Abbreviated NRC notification for DBT event                              Shift Manager Section 1 Ops Training Program 8      Complete State/local notification form                                  Shift Manager       EP Drill & Exercise Program Ops Training Program 9      Perform State/local notifications                                           CRO #1          EP Drill & Exercise Program Ops Training Program 10     Complete NRC event notification form                                        CRO #1          EP Drill & Exercise Program 11     Activate ERDS*                                                                 N/A          N/A EP Drill & Exercise 12     Offsite radiological assessment                                                N/A Program Ops Training Program 13     Perform NRC notifications                                                   CRO #1          EP Drill & Exercise Program Perform other site-specific event notifications (e.g., Duty                                 Ops Training Program 14     Plant Manager, INPO, ANI, etc.)                                             CRO #1          EP Drill & Exercise Program Security Emergency Response Training 15     Personnel Accountability                                                    Security EP Drill & Exercise Program
* The ERDS requirement in Appendix E to 10 CFR Part 50 exempts all nuclear power facilities that are shut down permanently from the need to provide an ERDS interface with the NRC. Therefore, the FCS ERDS link to the NRC is not required to be operational in a permanently shut down and defueled condition. Although use of ERDS may be continued, the task of ERDS verification is not included as an on-shift task requiring evaluation as part of this staffing analysis. Refer to Section C.8.
Fort Calhoun Station                                                                                                               Page 19 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing B. Accident Analysis #2 - Fuel Handling Accident with General Emergency and PAR
: 1. Accident Summary The FHA assumes the drop of a spent fuel assembly onto the spent fuel racks within the SFP resulting in breaking the fuel rods.
A General Emergency is declared when the Shift Manager is given a dose assessment update that projects >1 Rem TEDE dose at the site boundary.
: 2. Accident Specific Assumptions Made This analysis assumes a General Emergency declaration based on area radiation monitors reaching levels to prompt an emergency declaration.
Additional plant personnel, including Operations, Chemistry, and RP Technician, would be on-site during fuel assembly movement. The presence of additional plant personnel would free the on-shift RP Technician to perform dose assessment.
: 3. Procedures for Accident Response AOP-08, Fuel Handling Accident EP-FC-112, Emergency Classification and Protective Action Recommendations EP-FC-1001, Addendum 3, Emergency Action Levels for Fort Calhoun Station EP-FC-110-200, Dose Assessment Fort Calhoun Station                                                                                         Page 20 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing FCS TABLE 1 - ON-SHIFT POSITIONS Analysis # 2 - Fuel Handling Accident with General Emergency and PAR Augmentation Role in Table #
Line                                                                                       Unanalyzed       TMS On-shift Position       E-Plan Reference          Elapsed Time          / Line #
        #                                                                                           Task?       Required?
(min)
T2/L1 T5/L1 Emergency Plan                                    T5/L2 1        Shift Manager                                                                        No             No Table B-1                                         T5/L3 T5/L5 T5/L8 T2/L2 T5/L6 Control Room        Emergency Plan                                    T5/L9 2                                                                                             No            Yes1 Operator #1        Table B-1                                        T5/L10 T5/L13 T5/L14 Emergency Plan 3           NCO #1                                                              N/A           No             No Table B-1 Emergency Plan 4      NCO #2 (FB #2)                                                           N/A           No             No Table B-1 Emergency Plan                                     N/A 5      NCO #3 (FB #3)                                                                         No             No Table B-1 Emergency Plan                                     N/A 6            FB #4                                                                            No             No Table B-1 Emergency Plan                                     N/A 7            FB #5                                                                            No             No Table B-1 T4/L1 Emergency Plan                                    T4/L5 8       RP Technician                                        60                               No            Yes2 Table B-1 T5/L12 Emergency Plan 9           Security                                                          T5/L15           No            No Table B-1 1
See Section VIII.B 2 See Section II.C.2 for the exception taken for the RP Technician to perform dose assessment. No Time Motion Study or corrective action required.
Fort Calhoun Station                                                                                                      Page 21 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing Minimum Operations Crew Necessary to Implement AOPs if Applicable FCS TABLE 2 - PLANT OPERATIONS One Unit - One Control Room Analysis # 2 - Fuel Handling Accident with General Emergency and PAR Task Analysis Line #            Generic Title/Role             On-Shift Position              Task Description Controlling Method Crew direction and   Ops Training Program 1    Shift Manager                               Shift Manager oversight Perform CR Ops     Ops Training Program 2    CRO #1                                 Control Room Operator tasks/Communications 3    NCO #2                                             N/A                         N/A                  N/A 4    NCO #3                                             N/A                         N/A                  N/A Other (non-Operations) Personnel Necessary to Implement AOPs if Applicable Task Analysis Line #       Generic Title/Role             On-Shift Position                  Task Description Controlling Method N/A             Mechanic                          N/A                                N/A                  N/A N/A            Electrician                        N/A                                N/A                  N/A N/A          I&C Technician                       N/A                                N/A                  N/A N/A            Security Training 8              Security                    Security Force Program Fire Brigade FCS TABLE 3 - FIREFIGHTING Analysis # 2 - Fuel Handling Accident with General Emergency and PAR Line                 Performed by                                Task Analysis Controlling Method 1                        N/A                                                    N/A 2                        N/A                                                    N/A 3                        N/A                                                    N/A 4                        N/A                                                    N/A 5                        N/A                                                    N/A This accident does not include the need for firefighting, first aid, or search & rescue.
Fort Calhoun Station                                                                                                Page 22 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing FCS TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis # 2 - Fuel Handling Accident with General Emergency and PAR L Position Performing Performance Time Period After Emergency Declaration (minutes)
I Function / Task N                                    10 20 30 40 50 60 70 80   E                         0-5 5-10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 1 In-Plant Survey:
RP Technician                      X   X                                                       X     X 2   On-site Survey:
3   Personnel Monitoring:
4   Job Coverage:
5   Offsite Rad Assessment:                        X   X    X   X      X    X    X    X     X   X    X    X    X     X      X     X RP Technician 6   Other site specific RP (describe):
7   Chemistry Function task #1 (describe) 8   Chemistry Function task #2 (describe)
The on-shift RP Technician will perform the above task as directed by the Shift Manager. Tasks are not time critical. The on-shift RP Technician is available for dose assessment if a release occurs.
Fort Calhoun Station                                                                                               Page 23 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing FCS TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis # 2 - Fuel Handling Accident with General Emergency and PAR Function / Task                                    On-Shift         Task Analysis Controlling Line #
Position                     Method Ops Training Program 1     Declare the emergency classification level (ECL)                        Shift Manager       EP Drill & Exercise Program Ops Training Program 2     Approve Offsite Protective Action Recommendations                       Shift Manager       EP Drill & Exercise Program Ops Training Program 3     Approve content of State/local notifications                            Shift Manager EP Drill & Exercise Program 4     Approve extension to allowable dose                                           N/A                         N/A Ops Training Program Notification and direction to on-shift staff (e.g., to 5                                                                             Shift Manager EP Drill & Exercise assemble, evacuate, etc.)
Program Ops Training Program 6     ERO notification                                                            CRO #1          EP Drill & Exercise Program 7     Abbreviated NRC notification for DBT event                                    N/A                         N/A Ops Training Program 8     Complete State/local notification form                                  Shift Manager EP Drill & Exercise Program Ops Training Program 9     Perform State/local notifications                                           CRO #1          EP Drill & Exercise Program Ops Training Program 10     Complete NRC event notification form                                        CRO #1          EP Drill & Exercise Program 11     Activate ERDS*                                                                N/A                         N/A RP Technician EP Drill & Exercise 12     Offsite radiological assessment (or NCO)         Program Ops Training Program 13     Perform NRC notifications                                                   CRO #1          EP Drill & Exercise Program Perform other site-specific event notifications (e.g., Duty                                 Ops Training Program 14     Plant Manager, INPO, ANI, etc.)                                             CRO #1          EP Drill & Exercise Program Security Emergency Response Training 15     Personnel Accountability                                                    Security EP Drill & Exercise Program
* The ERDS requirement in Appendix E to 10 CFR Part 50 exempts all nuclear power facilities that are shut down permanently from the need to provide an ERDS interface with the NRC. Therefore, the FCS ERDS link to the NRC is not required to be operational in a permanently shut down and defueled condition. Although use of ERDS may be continued, the task of ERDS verification is not included as an on-shift task requiring evaluation as part of this staffing analysis. Refer to Section C.8.
Fort Calhoun Station                                                                                                               Page 24 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing C. Accident Analysis #3 - Aircraft Potential Threat
: 1. Accident Summary The analysis includes all emergency response actions taken prior to an aircraft impact in accordance with RG 1.214.
The analysis does not include a scenario or response actions taken during or after a crash.
: 2. Accident Specific Assumptions Made The Shift Manager receives the call from the NRC of potential aircraft threat.
All non-security on-shift personnel are inside the Protected Area fence at their normal workstation.
: 3. Procedures for Accident Response AOP 37, Security Events EP-FC-112, Emergency Classification and Protective Action Recommendations EP-FC-1001, Addendum 3, Emergency Action Levels for Fort Calhoun Station Fort Calhoun Station                                                                                            Page 25 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing FCS TABLE 1 - ON-SHIFT POSITIONS Analysis # 3 - Aircraft Potential Threat Augmentation Role in Table #
Line                                                                            Unanalyzed     TMS On-shift Position   E-Plan Reference      Elapsed Time         / Line #
       #                                                                                Task?     Required?
(min)
T2/L1 T5/L1 Emergency Plan 1       Shift Manager                                                T5/L3         No         No Table B-1 T5/L5 T5/L8 Control Room    Emergency Plan 2                                                                     N/A          No         No Operator #1    Table B-1 T2/L2 T5/L6 Emergency Plan                               T5/L9 3         NCO #1                                                                   No        Yes1 Table B-1                                   T5/L10 T5/L13 T5/L14 Emergency Plan 4     NCO #2 (FB #2)                                                  N/A          No         No Table B-1 Emergency Plan                                N/A 5     NCO #3 (FB #3)                                                               No         No Table B-1 Emergency Plan 6           FB #4                                                     N/A          No         No Table B-1 Emergency Plan                                N/A 7           FB #5                                                                  No         No Table B-1 Emergency Plan                                N/A 8      RP Technician                                60                             No         No Table B-1 Emergency Plan                               T2/L8 9         Security                                                                 No         No Table B-1                                   T5/L15 1
See Section VIII.C.
Fort Calhoun Station                                                                                      Page 26 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing Minimum Operations Crew Necessary to Implement AOPs if Applicable FCS TABLE 2 - PLANT OPERATIONS One Unit - One Control Room Analysis # 3 - Aircraft Potential Threat Task Analysis Line #            Generic Title/Role             On-Shift Position              Task Description Controlling Method Crew direction and    Ops Training Program 1    Shift Manager                               Shift Manager             oversight from Admin Building 2    CRO #1                                 Control Room Operator                  N/A                      N/A Perform Ops tasks/
3    NCO #2                                             N/A                                       Ops Training Program Communications 4    NCO #3                                             N/A                        N/A                      N/A Other (non-Operations) Personnel Necessary to Implement AOPs if Applicable Task Analysis Line #       Generic Title/Role             On-Shift Position                  Task Description Controlling Method N/A             Mechanic                          N/A                               N/A                      N/A N/A             Electrician                       N/A                               N/A                      N/A N/A          I&C Technician                       N/A                               N/A                      N/A N/A               Security Training 8               Security                   Security Force Program Fire Brigade FCS TABLE 3 - FIREFIGHTING Analysis # 3 - Aircraft Potential Threat Line                 Performed by                               Task Analysis Controlling Method 1                        N/A                                                     N/A 2                        N/A                                                     N/A 3                        N/A                                                     N/A 4                        N/A                                                     N/A 5                        N/A                                                     N/A This accident does not include the need for firefighting, first aid, or search & rescue. The Fire Brigade relocates outside the PA and stands by.
Fort Calhoun Station                                                                                                   Page 27 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing FCS TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis # 3 - Aircraft Potential Threat L Position Performing               Performance Time Period After Emergency Declaration (minutes)
I Function / Task N                       0-5 5-10 10 20 30 40 50 60 70 80   E                                15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 1 In-Plant Survey:
RP Technician       NA 2   On-site Survey:
3   Personnel Monitoring:
4   Job Coverage:
5   Offsite Rad Assessment:
6   Other site specific RP (describe):
7   Chemistry Function task #1 (describe) 8   Chemistry Function task #2 (describe)
Fort Calhoun Station                                                                                    Page 28 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing FCS TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis # 3 - Aircraft Potential Threat Function / Task                               On-Shift Position             Task Analysis Line #
Controlling Method Ops Training Program 1    Declare the emergency classification level (ECL)                          Shift Manager         EP Drill & Exercise Program 2    Approve Offsite Protective Action Recommendations                                N/A                        N/A Ops Training Program 3    Approve content of State/local notifications                              Shift Manager         EP Drill & Exercise Program 4    Approve extension to allowable dose                                              N/A                        N/A Ops Training Program Notification and direction to on-shift staff (e.g., to 5                                                                              Shift Manager         EP Drill & Exercise assemble, evacuate, etc.)
Program Ops Training Program 6    ERO notification                                                              NCO #1            EP Drill & Exercise Program 7    Abbreviated NRC notification for DBT event                                       N/A                        N/A Ops Training Program 8    Complete State/local notification form                                    Shift Manager         EP Drill & Exercise Program Ops Training Program 9    Perform State/local notifications                                             NCO #1            EP Drill & Exercise Program Ops Training Program 10    Complete NRC event notification form                                          NCO #1            EP Drill & Exercise Program 11    Activate ERDS*                                                                   N/A                        N/A 12    Offsite radiological assessment                                                  N/A                        N/A Ops Training Program 13    Perform NRC notifications                                                     NCO #1            EP Drill & Exercise Program Perform other site-specific event notifications (e.g., Duty                                     Ops Training Program 14    Plant Manager, INPO, ANI, etc.)                                               NCO #1            EP Drill & Exercise Program Security Emergency Response Training 15    Personnel Accountability                                                      Security EP Drill & Exercise Program
* The ERDS requirement in Appendix E to 10 CFR Part 50 exempts all nuclear power facilities that are shut down permanently from the need to provide an ERDS interface with the NRC. Therefore, the FCS ERDS link to the NRC is not required to be operational in a permanently shut down and defueled condition. Although use of ERDS may be continued, the task of ERDS verification is not included as an on-shift task requiring evaluation as part of this staffing analysis. Refer to Section C.8.
Fort Calhoun Station                                                                                                                 Page 29 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing D. Accident Analysis #4 - Event Requiring Control Room Evacuation and Maintain SFP Cooling
: 1. Accident Summary This event involves evacuation of the Control Room. The event has the potential to include shorts and/or spurious signals producing potential to lose SFP cooling capabilities.
: 2. Accident Specific Assumptions Made Assumed Control Room staff does not have time to perform any procedural actions other than declare the Alert and make the plant announcement before leaving the control room.
: 3. Procedures for Accident Response AOP-06, Fire Emergency AOP-07, Control Room Evacuation EP-FC-112, Emergency Classification and Protective Action Recommendations EP-FC-1001, Addendum 3, Emergency Action Levels for Fort Calhoun Station Fort Calhoun Station                                                                                         Page 30 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing FCS TABLE 1 - ON-SHIFT POSITIONS Analysis # 4 - Event Requiring Control Room Evacuation and Maintain SFP Cooling Augmentation Role in Table #
Line                                                                           Unanalyzed     TMS On-shift Position   E-Plan Reference     Elapsed Time       / Line #
       #                                                                               Task?     Required?
(min)
T2/L1 T5/L1 Emergency Plan 1       Shift Manager                                             T5/L3           No         No Table B-1 T5/L5 T5/L8 T2/L2 T5/L6 Control Room    Emergency Plan                            T5/L9 2                                                                                 No        Yes1 Operator #1    Table B-1                                T5/L10 T5/L13 T5/L14 Emergency Plan 3         NCO #1                                                   N/A            No         No Table B-1 Emergency Plan 4     NCO #2 (FB #2)                                               N/A            No         No Table B-1 Emergency Plan                             N/A 5     NCO #3 (FB #3)                                                              No         No Table B-1 Emergency Plan                            T3/L4 6           FB #4                                                                 No         No Table B-1 Emergency Plan                            T3/L5 7           FB #5                                                                 No         No Table B-1 Emergency Plan                            T4/L4 8      RP Technician                               60                             No         No Table B-1 Emergency Plan 9         Security                                               T5/L15           No         No Table B-1 1
See Section VIII.D.
Fort Calhoun Station                                                                                     Page 31 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing Minimum Operations Crew Necessary to Implement AOPs if Applicable FCS TABLE 2 - PLANT OPERATIONS One Unit - One Control Room Analysis # 4 - Event Requiring Control Room Evacuation and Maintain SFP Cooling Task Analysis Line #            Generic Title/Role              On-Shift Position            Task Description Controlling Method Crew direction and   Ops Training Program 1    Shift Manager                                Shift Manager oversight Perform CR Ops      Ops Training Program 2    CRO #1                                 Control Room Operator tasks/Communications 3    NCO #2                                             N/A                        N/A                   N/A 4    NCO #3                                             N/A                        N/A                   N/A Other (non-Operations) Personnel Necessary to Implement AOPs if Applicable Task Analysis Line #       Generic Title/Role            On-Shift Position                   Task Description Controlling Method N/A             Mechanic                           N/A                              N/A                   N/A N/A             Electrician                        N/A                              N/A                   N/A N/A          I&C Technician                        N/A                              N/A                   N/A N/A             Security Training 8               Security                   Security Force Program Fire Brigade FCS TABLE 3 - FIREFIGHTING Analysis # 4 - Event Requiring Control Room Evacuation and Maintain SFP Cooling Line                  Performed by                               Task Analysis Controlling Method 1                        N/A                                                    N/A 2                        N/A                                                    N/A 3                        N/A                                                    N/A 4                        N/A                                                    N/A 5                        N/A                                                    N/A This event does not include the need for firefighting, first aid, or search & rescue.
Fort Calhoun Station                                                                                                Page 32 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing FCS TABLE 4 - RADIATION PROTECTION AND CHEMISTRY Analysis # 4 - Event Requiring Control Room Evacuation and Maintain SFP Cooling L Position Performing                 Performance Time Period After Emergency Declaration (minutes)
I Function / Task N                         0-5 5-10 10 20 30 40 50 60 70 80   E                                  15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 1 In-Plant Survey:
2   On-site Survey:
3   Personnel Monitoring:
4   Job Coverage:
RP Technician                            X    X   X     X    X    X   X    X    X     X   X     X X     X 5   Offsite Rad Assessment:
6   Other site specific RP (describe):
7   Chemistry Function task #1 (describe) 8   Chemistry Function task #2 (describe)
Fort Calhoun Station                                                                                     Page 33 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing FCS TABLE 5 - EMERGENCY PLAN IMPLEMENTATION Analysis # 4 - Event Requiring Control Room Evacuation and Maintain SFP Cooling Function / Task                                On-Shift Position              Task Analysis Line #
Controlling Method Ops Training Program 1    Declare the emergency classification level (ECL)                           Shift Manager          EP Drill & Exercise Program 2    Approve Offsite Protective Action Recommendations                                 N/A                        N/A Ops Training Program 3    Approve content of State/local notifications                               Shift Manager          EP Drill & Exercise Program 4    Approve extension to allowable dose                                               N/A                        N/A Ops Training Program Notification and direction to on-shift staff (e.g., to 5                                                                               Shift Manager          EP Drill & Exercise assemble, evacuate, etc.)
Program Ops Training Program 6    ERO notification                                                               CRO #1             EP Drill & Exercise Program 7    Abbreviated NRC notification for DBT event                                        N/A                        N/A Ops Training Program 8    Complete State/local notification form                                     Shift Manager          EP Drill & Exercise Program Ops Training Program 9    Perform State/local notifications                                              CRO #1             EP Drill & Exercise Program Ops Training Program 10    Complete NRC event notification form                                           CRO #1             EP Drill & Exercise Program 11    Activate ERDS*                                                                    N/A                        N/A 12    Offsite radiological assessment                                                   N/A                        N/A Ops Training Program 13    Perform NRC notifications                                                      CRO #1             EP Drill & Exercise Program Perform other site-specific event notifications (e.g., Duty                                       Ops Training Program 14    Plant Manager, INPO, ANI, etc.)                                                CRO #1             EP Drill & Exercise Program Security Emergency Response Training 15    Personnel Accountability                                                       Security EP Drill & Exercise Program
* The ERDS requirement in Appendix E to 10 CFR Part 50 exempts all nuclear power facilities that are shut down permanently from the need to provide an ERDS interface with the NRC. Therefore, the FCS ERDS link to the NRC is not required to be operational in a permanently shut down and defueled condition. Although use of ERDS may be continued, the task of ERDS verification is not included as an on-shift task requiring evaluation as part of this staffing analysis. Refer to Section C.8.
Fort Calhoun Station                                                                                                                Page 34 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing VIII. APPENDIX C - TIME MOTION STUDIES SUPPORTING THE STAFFING ANALYSIS A. Analysis #1 - Design Basis Threat TIME MOTION STUDY OF OVERLAPPING TASKS Analysis #1 Design Basis Threat TASK 1: Complete the State Notification JOB: Control Room Operator TASK 2: Perform NRC Notification JOB: Control Room Operator TASK 3: Perform Event Mitigation JOB: Control Room Operator Fort Calhoun Station                                                                                  Page 35 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing PURPOSE:
Perform a Time Motion Study to evaluate whether the performance of notification actions assigned to the Control Room Operator is an acceptable task overlap to the Control Room Operators primary emergency plan function of event mitigation.
NOTE:
The Time Motion Study should be completed in a manner that demonstrates notification actions while the Shift Manager is demonstrating the Emergency Director function.
Times for the activities performed are based on operating experience (e.g., drills, real events, etc.) and/or informed judgment with consideration given to the limited Operator actions in a permanently shutdown and defueled condition. Validation of actual times will be performed with updated procedures.
CONCLUSION:
The Time Motion Study demonstrated the Control Room Operator could perform the tasks of completing State, local and NRC notifications successfully, individually or in series, without impacting the ability of the CRO to remain in role providing support and oversight during the emergency.
LOCATION:
The response to this event was determined by conducting a tabletop of the event using the emergency plan and procedures and the applicable department procedures such as Operations emergency and abnormal operating procedures.
REQUIRED TOOLS/EQUIPMENT:
AOP 37, Security Events EP-FC-112, Emergency Classification and Protective Action Recommendations EP-FC-1001, Addendum 3, Emergency Action Levels for Fort Calhoun Station EP-FC-112-100-F-06, ERO Notification or Augmentation EP-FC-114-100, Off-Site Notifications Fort Calhoun Station                                                                                              Page 36 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing Function / Responsibility (Task) Analysis Template Event: # 1           Site: FCS                              Position: Control Room Operator _             Line #: 6, 9-10, 13, 14 Function             Responsibility (Task)                                 Action Step                      Duration
: 1. ERO notification    1.1 Complete the ERO                Retrieve procedure EP-FC-112-100-F-06, ERO notification.                   Notification or Augmentation.                                5 Perform ERO notification 3
Task duration       8
: 2. State/local         2.1 Perform state/local             Retrieve and complete procedure EP-FC-114-100,          Performed notification            notification.                   Offsite Notifications.                                    by Shift Manager Approve content of state/local notification.            Performed by Shift Manager Perform state/local notification.                            4 Task duration       4
: 3. NRC Notification    3.1 Perform NRC notification.       Retrieve and complete procedure EP-FC-114-100, Offsite Notifications.                                      10 Perform NRC notification.                                    2 Task duration      12
: 4. Site-specific       4.1 Perform site-specific           Perform site-specific notifications.                         2 notifications           notifications, including plant announcements.                                                           Task duration       2
: 5. Event Mitigation    5.1 Assess and respond to plant     Provide assistance to the Shift Manager in mitigating conditions                      the event as directed.                                       5 Task duration       5 TOTAL DURATION         31 Task Performer:     Chris Hayes                           Position:     Control Room Operator _           Date:    8/3/16 Evaluator: Jason Fickbohm                                 Position:      EP Coordinator                   Date:    8/3/16 Fort Calhoun Station                                                                                                      Page 37 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing B. Analysis #2 - Fuel Handling Accident with General Emergency and PAR TIME MOTION STUDY OF OVERLAPPING TASKS Analysis #2 Fuel Handling Accident with General Emergency and PAR TASK 1: Complete the Off-Site Notification JOB: Control Room Operator TASK 2: Perform NRC Notification JOB: Control Room Operator TASK 3: Perform Event Mitigation JOB: Control Room Operator Fort Calhoun Station                                                                                       Page 38 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing PURPOSE:
Perform a Time Motion Study to evaluate whether the performance of notification actions assigned to the Control Room Operator are acceptable task overlaps to the Control Room Operators primary emergency plan function of event mitigation.
NOTE:
Times for the activities performed are based on operating experience (e.g., drills, real events, etc.) and/or informed judgment with consideration given to the limited Operator actions in a permanently shutdown and defueled condition. Validation of actual times will be performed with updated procedures.
CONCLUSION:
The Time Motion Study demonstrated the Control Room Operator could perform the tasks of completing State, local and NRC notifications successfully, individually or in series, without impacting the ability of the CRO to remain in role providing support and oversight during the emergency.
LOCATION:
The response to this event was determined by conducting a tabletop of the event using the emergency plan and procedures and the applicable department procedures.
REQUIRED TOOLS/EQUIPMENT:
AOP-08, Fuel Handling Accident EP-FC-112, Emergency Classification and Protective Action Recommendations EP-FC-1001, Addendum 3, Emergency Action Levels for Fort Calhoun Station EP-FC-112-100-F-06, ERO Notification or Augmentation EP-FC-114-100, Off-Site Notifications Fort Calhoun Station                                                                                              Page 39 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing Function / Responsibility (Task) Analysis Template Event: # 2            Site: FCS                              Position: Control Room Operator _             Line #: 6, 9-10, 13, 14 Function              Responsibility (Task)                                 Action Step                      Duration
: 1. ERO notification     1.1 Complete the ERO                Retrieve procedure EP-FC-112-100-F-06, ERO notification.                   Notification or Augmentation.                                5 Perform ERO notification 3
Task duration       8
: 2. State/local          2.1 Perform state/local             Retrieve and complete procedure EP-FC-114-100-,         Performed notification             notification.                   Offsite Notifications.                                    by Shift Manager Approve content of state/local notification.            Performed by Shift Manager Perform state/local notification.                            5 Task duration       5
: 3. NRC Notification     3.1 Perform NRC notification.       Retrieve and complete procedure EP-FC-114-100-,
Offsite Notifications.                                      10 Perform NRC notification.                                    2 Task duration      12
: 4. Site-specific        4.1 Perform site-specific           Perform site-specific notifications.                         2 notifications            notifications, including plant announcements.                                                           Task duration       2
: 5. Event Mitigation     5.1 Assess and respond to plant     Provide assistance to the Shift Manager in mitigating conditions                      the event as directed.                                       5 Task duration       5 TOTAL DURATION         32 Task Performer: Chris Hayes                                Position:     Control Room Operator _           Date:   8/3/16 Evaluator:        Jason Fickbohm                           Position:     EP Coordinator                    Date:   8/3/16 Fort Calhoun Station                                                                                                       Page 40 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing C. Analysis #3 - Aircraft Potential Threat TIME MOTION STUDY OF OVERLAPPING TASKS Analysis #3 Aircraft Potential Threat TASK 1: Complete the State Notification JOB: Non-Certified Operator TASK 2: Perform NRC Notification JOB: Non-Certified Operator TASK 3: Perform Event Mitigation JOB: Non-Certified Operator Fort Calhoun Station                                                                                    Page 41 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing PURPOSE:
Perform a Time Motion Study to evaluate whether the performance of NRC notification actions assigned to the NCO is an acceptable task overlap to the NCOs primary emergency plan function.
NOTE:
The Time Motion Study should be completed in a manner that demonstrates notification actions while the Shift Manager is demonstrating the Emergency Director function.
Times for the activities performed are based on operating experience (e.g., drills, real events, etc.) and/or informed judgment with consideration given to the limited Operator actions in a permanently shutdown and defueled condition. Validation of actual times will be performed with updated procedures.
CONCLUSION:
The Time Motion Study demonstrated the NCO could perform the tasks of completing State, local and NRC notifications successfully, individually or in series, without impacting the ability of the NCO to remain in role providing support and oversight during the emergency.
LOCATION:
The response to this event was determined by conducting a tabletop of the event using the emergency plan and procedures and the applicable department procedures such as Operations emergency and abnormal operating procedures.
REQUIRED TOOLS/EQUIPMENT:
AOP 37, Security Events EP-FC-112, Emergency Classification and Protective Action Recommendations EP-FC-1001, Addendum 3, Emergency Action Levels for Fort Calhoun Station EP-FC-112-100-F-06, ERO Notification or Augmentation EP-FC-114-100, Off-Site Notifications Fort Calhoun Station                                                                                            Page 42 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing Function / Responsibility (Task) Analysis Template Event: #3             Site: FCS                              Position: Non-Certified Operator _            Line #: 6, 9-10, 13, 14 Function              Responsibility (Task)                                 Action Step                       Duration
: 1. ERO notification     1.1 Complete the ERO                Retrieve procedure EP-FC-112-100-F-06, ERO notification.                   Notification or Augmentation.                                5 Perform ERO notification 3
Task duration       8
: 2. State/local          2.1 Perform state/local             Retrieve and complete procedure EP-FC-114-100,          Performed notification             notification.                   Offsite Notifications.                                    by Shift Manager Approve content of state/local notification.            Performed by Shift Manager Perform state/local notification.                            4 Task duration       4
: 3. NRC Notification     3.1 Perform NRC notification.       Retrieve and complete procedure EP-FC-114-100, Offsite Notifications.                                      10 Perform NRC notification.                                    2 Task duration      12
: 4. Site-specific        4.1 Perform site-specific           Perform site-specific notifications.                         2 notifications            notifications, including plant announcements.                                                           Task duration       2
: 5. Event Mitigation     5.1 Assess and respond to plant     Provide assistance to the Shift Manager in mitigating conditions                      the event as directed.                                       5 Task duration       5 TOTAL DURATION         31 Task Performer:      Chris Hayes                           Position:     Control Room Operator _           Date:   8/3/16 Evaluator:         Jason Fickbohm                          Position:     EP Coordinator                    Date:    8/3/16 Fort Calhoun Station                                                                                                       Page 43 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing D. Analysis #4 - Control Room Fire Requiring Evacuation and Maintain SFP Cooling TIME MOTION STUDY OF OVERLAPPING TASKS Analysis #4 Event Requiring Control Room Evacuation and Maintain SFP Cooling TASK 1: Complete the State Notification JOB: Control Room Operator TASK 2: Perform NRC Notification JOB: Control Room Operator TASK 3: Perform Event Mitigation JOB: Control Room Operator Fort Calhoun Station                                                                                      Page 44 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing PURPOSE:
Perform a Time Motion Study to evaluate whether the performance of notification actions assigned to the Control Room Operator is an acceptable task overlap to the Control Room Operators primary emergency plan function of event mitigation.
NOTE:
The Time Motion Study should be completed in a manner that demonstrates notification actions while the Shift Manager is demonstrating the Emergency Director function.
Times for the activities performed are based on operating experience (e.g., drills, real events, etc.) and/or informed judgment with consideration given to the limited Operator actions in a permanently shutdown and defueled condition. Validation of actual times will be performed with updated procedures.
CONCLUSION:
The Time Motion Study demonstrated the Control Room Operator could perform the tasks of completing State, local and NRC notifications successfully, individually or in series, without impacting the ability of the CRO to remain in role providing support and oversight during the emergency.
LOCATION:
The response to this event was determined by conducting a tabletop of the event using the emergency plan and procedures and the applicable department procedures such as Operations emergency and abnormal operating procedures.
REQUIRED TOOLS/EQUIPMENT:
AOP-06, Fire Emergency AOP-07, Control Room Evacuation EP-FC-112, Emergency Classification and Protective Action Recommendations EP-FC-1001, Addendum 3, Emergency Action Levels for Fort Calhoun Station EP-FC-112-100-F-06, ERO Notification or Augmentation EP-FC-114-100, Off-Site Notifications Fort Calhoun Station                                                                                              Page 45 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing Function / Responsibility (Task) Analysis Template Event: #4              Site: FCS                              Position: Control Room Operator _             Line #: 6, 9-10, 13, 14 Function               Responsibility (Task)                                 Action Step                       Duration
: 1. ERO notification      1.1 Complete the ERO                Retrieve procedure EP-FC-112-100-F-06, ERO notification.                   Notification or Augmentation.                                 5 Perform ERO notification 3
Task duration        8
: 2. State/local           2.1 Perform state/local             Retrieve and complete procedure EP-FC-114-100,           Performed notification              notification.                   Offsite Notifications.                                    by Shift Manager Approve content of state/local notification.             Performed by Shift Manager Perform state/local notification.                            4 Task duration        4
: 3. NRC Notification      3.1 Perform NRC notification.       Retrieve and complete procedure EP-FC-114-100, Offsite Notifications.                                       10 Perform NRC notification.                                    2 Task duration       12
: 4. Site-specific         4.1 Perform site-specific           Perform site-specific notifications.                          2 notifications             notifications, including plant announcements.                                                           Task duration        2
: 5. Event Mitigation      5.1 Assess and respond to plant     Provide assistance to the Shift Manager in mitigating conditions                      the event as directed.                                        5 Task duration        5 TOTAL DURATION          31 Task Performer: Chris Hayes                                 Position:     Control Room Operator _           Date:   8/3/16 Evaluator:      Jason Fickbohm                              Position:     EP Coordinator                    Date:   8/3/16 Fort Calhoun Station                                                                                                         Page 46 Rev. 0

FCS Analysis of Proposed Post-Shutdown On-Shift Staffing IX. OVERLAP OF TASKS ACTIVITIES OR OTHER CONFLICTS IDENTIFIED A. Overlap Requiring Compensatory Measures None X.      REFERENCES Omaha Public Power District to USNRC, Certification of Permanent Cessation of Power Operations, Letter LIC-16-0043, dated June 24, 2016 NEI 10-05, Rev 0, Assessment of On-Shift Emergency Response Organization Staffing and Capabilities NSIR DPR-ISG-01, Interim Staff Guidance - Emergency Planning for Nuclear Power Plants NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants.
EP-FC-1001, Rev. 0, Radiological Emergency Response Plan for Fort Calhoun Station EP-FC-1001, Addendum 1, Revision 0, Fort Calhoun Station On-Shift Staffing Technical Basis Fort Calhoun Station                                                                                        Page 47 Rev. 0

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION DOCKET NUMBER 50-285 / LICENSE NUMBER DPR-40 ATTACHMENT 5 EMERGENCY RESPONSE ORGANIZATION TASK ANALYSIS

ERO POSITION MATRIX Position                      Min       Key     Procedure(s)                Regulatory Current ERO Position           Tasks (T#)                                                                                                  Implementing Actions                 eliminated? Task Assigned to? Staffing? NRC PI? EPlan (Rev. 0) section Requirement EMERGENCY OPERATIONS FACILITY Emergency Director             T1. Receive turnover and assume command/control of EOF and activities outside the area controlled by        N/A                                  No          N/A               Yes       Yes     EPFC112400               T1/T2 NUREG 0654 II.A.1.d/II.B.3/II.B.5 the TSC                                                                                                                                                                                          EPFC1001 Section B, 3.2.2 T2 NUREG 0654 II.A.4 T2. Direct the activation, operation and deactivation of the EOF                                                                                                                                 EPFC1001 Section B, 3.2.3 T4 NUREG 0654 II.B.4 T3. Coordinate all OPPD activities involved with the emergency response                                                                                                                          EPFC1001 Section B, 4.3.5 T5 NUREG 0654 II.B.4/II.J.7 T4. Upgrade the emergency classification level (cannot delegate)
EPFC1001 Section B, 4.4.5 T6 NUREG 0654 II.B.4 T5. Make protective action recommendations (PAR) to offsite agencies (cannot delegate)
EPFC1001 Section B,       T10 NUREG 0654 II.B.7.c T6. Direct and approve offsite notification to State and local agencies (cannot delegate)
T7. Ensure offsite agency updates are periodically communicated as required/requested                                                                                                           4.8.1.A                     T17 NUREG 0654 II.B.7.a T8. Coordinate OPPD press releases with the Public Affairs                                                                                                                                       EPFC112400F03          T24 NUREG 0654 II.K.2 T9. Request assistance from the OPPD organization, as necessary                                                                                                                                  EPFC112400F39          T10 NUREG 0654 II.C.1.a T10. Ensure that Federal, State and local authorities and industry support agencies remain cognizant of                                                                                                                      T2 NUREG 0654 II.K.6.c/II.M.2 the status of the emergency situation T11. If requested, dispatch informed individuals to offsite governmental Emergency Operation Center (EOCs)
T12. Approve the technical content of OPPD Nuclear press release prior to their being released to the media T13. Evaluate the need to augment EOF staff based in events in progress T14. Assess the effectiveness of ongoing EOF working relationships T15. Monitor information flow within the EOF to ensure that facility activities remain coordinated T16. Prepare state/local notification forms with the assistance of the Protective Measures Manager T17. Coordinate services as necessary to support EOF operations T18. Coordinate with the Administrative Logistics Manager for continual shift staffing requirements T19. Act as the designated alternate for approval of the technical content of OPPD Press Releases and information released to the News Media T20. Act as purchasing agent in support contract negotiation/administration T21. Direct implementation of accountability actions T22. Review and update station priorities T23. Conduct facility briefings T24. Review and approve emergency exposure controls T25. Coordinate facility relocation as needed EOF COP Communicator           T1. Communicate and receive information via the COP network or commercial telephone line with               N/A                                  No          N/A               Yes       No      EPFC112400               T1 NUREG 0654 II.A.1.e appropriate State and County agencies                                                                                                                                                            EPFC1001 Section B, 4.3.5 T2 NUREG 0654 II.A.1.e T2. Ensure that the Emergency Director is made aware of issues and questions raised by offsite agencies                                                                                          EPFC1001 Section B,       T3 NUREG 0654 II.A.1.e and then relay the replies to these requests                                                                                                                                                     4.8.1.B T3. Perform required notifications to States and Counties EPFC112400F05 T4. Perform required notifications to the NRC EPFC112400F39 T5. Perform required notifications to the Emergency Response Organization T6. Assist in maintaining status boards within the EOF EOF Protective Measures        T1. Recommend changes in event classification and PARs based upon effluent releases, dose projections       T1 from Dose Assessment Coordinator No           N/A               Yes       Yes     EPFC112400               N/A Manager                        or measured dose rates in the field                                                                         T6 from Dose Assessment Coordinator                                or DAC            EPFC1001 Section B, 4.3.5 T2. Assist the Emergency Director in the evaluation of the significance of an emergency with respect to     T7 from Dose Assessment Coordinator                                                  EPFC1001 Section B, the public                                                                                                  T8 from Dose Assessment Coordinator                                                  4.8.1.C T3. Notify the Emergency Director of meteorological changes that may impact identification of downwind T9 from Dose Assessment Coordinator                                                  EPFC112400F16 areas T10 from Dose Assessment Coordinator                                                 EPFC112400F39 T4. Advise the Emergency Director of protective actions taken by the station for plant personnel T5. Assist the TSC in the planning and coordination of activities associated with the evacuation of non    T2 from EOF CHP Communicator essential personnel                                                                                         T7 from EOF CHP Communicator T6. Advise the Emergency Director on the need for emergency exposures or for issuance of KI to the Field Monitoring Teams or OPPD personnel required to enter the plume T7. Monitor plant radiological conditions and advise the TSC Protective Measures Coordinator of any adverse trend or potential release pathways that may impact existing event classification T8. Assist in the completion and review of the State/Local notifications form T9. Maintain cognizance of field team sampling activities T10. Ensure State authorities are provided information pertaining to OPPD Field Monitoring Team activities and sample results T11. Assist the station with planning and coordination of activities associated with the evacuation of non essential personnel T12. Assist the station with acquisition of additional instrumentation, dosimetry, protective equipment and radiological support personnel T13. Assist and interface with station in the development of plans for plant surveys, sampling, shielding, and special tools in support of waste system processing and design modification activities T14. Upon request, provide inplant health physics data to Emergency Public Information personnel and the CHP Communicator T15. Monitor dose assessment operations performed T16. Keep the Emergency Director informed of projections and field survey results T17. Evaluate site radiological conditions and necessary personnel protective measures T18. Prepare and submit state update information including PARs, to the Emergency Director, state and federal officials EOF Dose Assessment Specialist T1. Perform dose projections using the Dose Assessment computer models as directed by the Dose              N/A                                  No          N/A               Yes       No      EPFC112400               N/A Assessment Coordinator                                                                                                                                                                           EPFC1001 Section B, 4.3.5 T2. Monitor meteorological and plant radiological/effluent conditions                                                                                                                            EPFC1001 Section B, T3. Notify the Dose Assessment Coordinator of meteorological changes that may impact identification of                                                                                           4.8.1.E downwind areas EPFC112400F18 T4. Evaluate the need for administering KI to OPPD workers when requested by the Dose Assessment EPFC112400F39 Coordinator T5. Update status boards 1 OF 10

ERO POSITION MATRIX Position                                             Min       Key     Procedure(s)                Regulatory Current ERO Position        Tasks (T#)                                                                                                  Implementing Actions               eliminated? Task Assigned to?                        Staffing? NRC PI? EPlan (Rev. 0) section Requirement EOF Dose Assessment         T1. Interpret radiological data and provide PARs based upon dose projections to the Protective N/A                                             Yes         Eliminate position                       Yes       No      EPFC112400               N/A Coordinator                 Measures Manager                                                                                                                                           T1 to Protective Measures Manager        or PMM            EPFC1001 Section B, 4.3.5 T2. Advise the Protective Measures Manager of changes in event classification based on effluent                                                            T2 Protective Measures Manager has (T1)                    EPFC1001 Section B, releases, dose projections or measured dose rates in the field                                                                                             T3 Dose Assessment Specialist has (T4)                     4.8.1.D T4 Dose Assessment Specialist has (T2)
T3. Initiate evaluation of the need for administering KI to OPPD nuclear workers when                                                                                                                                 EPFC112400F17 T5 Dose Assessment Specialist has (T3) requested by the Environmental Coordinator                                                                                                                                                                            EPFC112400F39 T6 to Protective Measures Manager T4. Remain cognizant of forecast and meteorological data to ensure the status is updated                                                                   T7 to Protective Measures Manager periodically                                                                                                                                               T8 to Protective Measures Manager T5. Notify the Protective Manager of meteorological changes that may impact identification of                                                              T9 to Protective Measures Manager downwind areas                                                                                                                                             T10 to Protective Measures Manager T6. Upon request, provide release and dose assessment data to Emergency Public Information                                                                 T11 Dose Assessment Specialist has all personnel and the CHP Communicator                                                                                                                         T12 Protective Measures Manager has (T8)
T7. Direct offsite dose assessment T8. Coordinate OPPD Field teams T9. Compare dose projections against field team results T10. Compare dose projections and field team results with state and federal results T11. If Dose Assessment Specialist is not present, perform Dose Assessment Specialist actions until relieved T12. Assist in completing notification forms EOF Admin Logistics Manager T1. Ensure contact is made and communications are maintained with appropriate NonOPPD Nuclear              T3 from EOF Clerical Assistant     No          N/A                                      No        No      EPFC112400               T10 NUREG 0654 II.A.1.e personnel whose assistance may be required to terminate the emergency conditions and to expedite            T2 from Emergency Response                                                                                EPFC1001 Section B,       T3 NUREG 0654 II.A.4/II.B.7.a recovery                                                                                                    Coordinator                                                                                               4.8.2.A                     T8 NUREG 0654 II.A.4/II.B.7.a T2. Advise the EOF Director concerning the status of activities relating to governmental interfaces         T4 from Emergency Response                                                                                EPFC112400F04          T14 NUREG 0654 II.A.4/II.B.7.a T3. Obtain support from Human Resources, the Legal Department, Accounting Department and others as Coordinator                                                                                               EPFC112400F39 required T4. Maintain communications with ANI, INPO, and SAFER as necessary T5. Ensure that access to the EOF is limited to Emergency Responders and authorize admittance to non OPPD personnel T6. Ensure that NRC Site Team Representatives are directed to the Ops Liaison upon arrival at the EOF T7. Ensure that updates and information are provided to the EOC Liaisons and to offsite officials present in the EOF T8. Assist in obtaining and coordinating additional technical expertise to support station requests, including Corporate staff, unaffected stations and vendor/contractors T9. Coordinate maintenance of EOF equipment as necessary T10. Ensure shift relief and continual staffing for the EOF T11. Activate the Alert Notification System as requested T12. If Emergency Director is not present, perform initial Emergency Director actions T13. Participate in periodic EOF briefings T14. Assist in obtaining food, water and other supplies as requested T15. Implement SAFER Response Plan as needed EOF Information Specialist  T1. Prepare information for use in periodic press releases                                                  T1 from EOF Clerical Assistant     No          N/A                                      No        No      EPFC112400F39          N/A T2. At an Alert or higher emergency classification, submit all press release to the Emergency Director (or                                                                                                            EPFC1001 Section B, designee) for approval prior to forwarding the release to the Joint Information Center                                                                                                                                4.8.2.C T3. Establish communications with the Emergency Director, Corporate Spokesperson and JIC Manager, if                                                                                                                  Crisis Communication Plan available T4. Gather information pertaining to the incident T5. Relay information as it develops to the JIC Manager (or designee)
T6. Work with the EOF Technical Liaison to gather plant status information and prepare emergency information messages for approval by the EOF Emergency Director T7. Assist with preparation of closeout postings on the FCS Emergency Information website and/or news release T8. Coordinate activities with state and federal information officers when they arrive at the EOF to ensure they receive prompt and accurate plant information T9. Prepare routine News Media Update messages T10. Service as plant status information source for the JIC 2 OF 10

ERO POSITION MATRIX Position                                         Min       Key     Procedure(s)              Regulatory Current ERO Position           Tasks (T#)                                                                                                 Implementing Actions             eliminated? Task Assigned to?                    Staffing? NRC PI? EPlan (Rev. 0) section Requirement EOF Ops Liaison                T1. Monitor the Ops Liaison Network to keep appraised of Control Room activities including progress on N/A                                  No          N/A                                  No        No      EPFC112400             N/A Emergency Operating Procedures                                                                                                                                                                                 EPFC1001 Section B, T2. Monitor the Ops Liaison Network to keep appraised of significant changes in plant system/equipment                                                                                                         4.8.2.D status and critical parameters                                                                                                                                                                                 EPFC112400F09 T3. Monitor the Ops Liaison Network to keep appraised of possible changes in event classification EPFC112400F39 T4. Identify and track critical parameters for the identification and trending of current plant status information T5. Assist the station in identifying Operations resources from corporate staff or unaffected stations for direct support of plant shift operations personnel T6. Assist the ENS Communicator in the completion of the NRC Event Notification Worksheet and in responding to NRC inquiries T7. Ensure that the Protective Measures Manager is informed of changes in plant status that impact or potentially impact the offsite environment or PARs T8. Obtain plant status/Control Room information from the Control Room Ops Liaison and transmit this information to the EOF and NRC staff as needed T9. Assist the Emergency Director in the review of classifications and formulating appropriate PARs when necessary T10. Assist in maintaining electronic logs and status boards, as needed EOF Field Team (2)             T1. Provide offsite monitoring in the areas potentially affected by a radiological release                 N/A                              No          N/A                                  No        No      EPFC1001 Section B,     T1 NUREG 0654 II.B.5 (Table B1) 4.8.2.B EPFC112500F01 EPFC112400F39 Field Team Specialist          T1. Ensure communications are established with the TSC to obtain information on the accident conditions, N/A                                No          N/;A                                 No        No      EPFC112400             N/A meteorological conditions and estimates of radioactive material releases                                                                                                                                       EPFC1001 Section B, T2. Maintain cognizance of Field Monitoring Team exposure                                                                                                                                                      4.8.2.B.1 T3. When warranted, ask the Dose Assessment Coordinator to initiate an evaluation of the need for                                                                                                              EPFC112400F21 administering KI to OPPD nuclear workers EPFC112400F39 T4. Determine needs of the Dose Assessment Coordinator, the Dose Assessment Specialist, and the CHP Communicator for updates on Field Monitoring Team data and ensure distribution of new data to them in accordance with those needs T5. Upon request, provide field team data to Emergency Public Information personnel T6. Evaluate and coordinate additional equipment and personnel as necessary T7. Establish and maintain contact with dispatched Field Monitoring Teams T7. Document the Dose Assessment Coordinator's instructions and the relay the information to the Field Monitoring Teams T8. Provide periodic updates to the Field Monitoring Teams on classification, plant conditions, release status, meteorological data, etc.
T9. Document environmental data reported by the Field Monitoring Teams T10. Periodically obtain and document information on Field Monitoring Team radiological exposure T11. Promptly report new environmental or Field Monitoring Team exposure data to the Dose Assessment Coordinator T12. Document questions and answers directed to and received from the Field Monitoring Teams. Ensure the Dose Assessment Coordinator is cognizant of these information requests and relay replies to these requests T13. Coordinate the activities of the OPPD and State Field Teams to achieve the most efficient use of teams for plume tracking T14. Develop and coordinate a Recovery Environmental Monitoring Plan and Sampling Plan in conjunction with affected States EOF Technical Liaison          T1. Monitor status of the emergency                                                                        T3 from EOF CHP Communicator     No          N/A                                  Yes       No      EPFC112400F39        N/A T2. Assist the EOF Information Specialist in collecting and interpreting eventrelated information         T4 from EOF CHP Communicator                                                                        Crisis Communication Plan T3. Assist the EOF Information Specialist in providing prompt and accurate plant information to federal,   T6 from EOF CHP Communicator state and local public information personnel T4. Review Emergency Information messages for technical accuracy before they are submitted to the Emergency Director for approval T5. Serve as EOF contact for the JIC Technical Liaison T6. Transmit status board technical information to the JIC Technical Liaison as it becomes available T7. Provide information on how the plant is analyzing technical information for the JIC EOF Clerical Assistant         T1. Distribute copies of notification forms                                                                N/A                              Yes         Eliminate position                   No        No      EPFC112400F07        N/A T2. Assist the Administrative staff                                                                                                                     T1 to EOF Information Specialist                       EPFC112400F39 T3. Coordinate with the TSC Administrative Logistics Coordinator for special training as required                                                       T2 N/A T4. Implement SAFER Response Plan as needed                                                                                                             T3 to Admin Logistics Manager T4 Admin Logistics Manager has (T15)
Emergency Director Secretary   No tasks listed in procedures                                                                              N/A                              Yes         Eliminate position                   No        No      EPFC112400F39        N/A Des Moines Site Representative T1. Assist with the interface between OPPD and the offsite governmental officials in the Iowa State EOC    N/A                              No          N/A                                  No        No      EPFC112400             T1 NUREG 0654 II.C.2.b EPFC112400F39 3 OF 10

ERO POSITION MATRIX Position                                      Min       Key     Procedure(s)                Regulatory Current ERO Position          Tasks (T#)                                                                                                  Implementing Actions     eliminated? Task Assigned to?                 Staffing? NRC PI? EPlan (Rev. 0) section Requirement IT Specialist                 T1. Assist any personnel in logging in, initializing or using a desired computer program                    N/A                      Yes         Eliminate position                No        No      EPFC112400               N/A T2. Investigate and repair problems encountered with communications equipment and computer                                                       T1 to Helpdesk                                      EPFC112400F08 equipment/applications                                                                                                                           T2 to Helpdesk                                      EPFC112400F39 EOF CHP Communicator          T1. Establish contact with states and other CHP stations                                                    N/A                      Yes         Eliminate position                No        No      EPFC112400               N/A T2. Update all parties on status of protective measures as directed by the Protective Measures Manager                                           T1 N/A                                              EPFC112400F19 T3. Field and obtain satisfactory answers from appropriate source for any questions or concerns that state                                       T2 to Protective Measures Manager                   EPFC112400F39 officials may have about plant or protective measures issues                                                                                     T3 to EOF Technical Liaison T4. Provide updates and respond to inquiries from the NRC on offsite environmental data, release status,                                         T4 to EOF Technical Liaison dose projections and changes to PARs for the general public                                                                                      T5 N/A T5. Obtain release and dose assessment data from the Dose Assessment Coordinator and Field                                                       T6 to EOF Technical Liaison Monitoring Team data from the Environmental Coordinator                                                                                          T7 to Protective Measures Manager T6. Maintain continuous communications with the NRC, if requested, via the NRC HPN phone or commercial telephone line T7. Communicate current Health Physics information to NRC representatives, as requested Communications Specialist     No tasks listed in procedures                                                                               N/A                      Yes         Eliminate position                No        No      EPFC112400F39          N/A Emergency Response            T1. Assist in activation of the EOF                                                                         N/A                      Yes         Eliminate position                No        No      EPFC112400F91          N/A Coordinator                   T2. Ensure State and Federal representatives are kept informed and given access to all needed                                                    T1 N/A                                              EPFC112400F39 resources                                                                                                                                        T2 to Admin Logistics Manager T3. Ensure notifications are being made to States, Counties, NRC and the Emergency Response                                                      T3 N/A T4 to Admin Logistics Manager Organization T5 N/A T4. Initiate Business Continuity Plan as directed T5. Participate in periodic facility briefings EOF Secretary                 No tasks listed in procedures                                                                               N/A                      Yes         Eliminate position                No        No      EPFC112400F39          N/A EOF Dose Assessment Assistant No tasks listed in procedures                                                                               N/A                      Yes         Eliminate position                No        No      EPFC112400F39          N/A EOF Status Board Keeper       No tasks listed in procedures                                                                               N/A                      Yes         Eliminate position                No        No      EPFC112400F39          N/A TECHNICAL SUPPORT CENTER Site Director                 T1. Receive turnover and assume command/control of TSC and activities for onsite emergency efforts          N/A                      No          N/A                               Yes       Yes     EPFC112200               T1/T2 NUREG 0654 II.A.1.d/II.B.3 T2. Direct the activation, operation and deactivation of the TSC                                                                                                                                     EPFC1001 Section B, 3.2.2 T3 NUREG 0654 II.J.5 T3. Direct personnel assembly/accountability and evacuation of nonessential personnel at Site Area                                                                                                  EPFC1001 Section B, 3.2.3 T9 NUREG 0654 II.K.2 Emergency, General Emergency or as conditions warrant                                                                                                                                                EPFC1001 Section B, 4.3.4 T4. Upgrade the emergency classification level (cannot delegate)
EPFC1001 Section B, 4.4.4 T5. Make protective action recommendations (PAR) to offsite agencies (cannot delegate)
EPFC1001 Section B, T6. Direct and approve offsite notification to State and local agencies (cannot delegate)
T7. If the emergency involves a hazardous substance and/or oil discharge, ensure that appropriate                                                                                                    4.6.1.A notifications and responses have been made                                                                                                                                                           EPFC112200F01 T8. Determine if the OSC is to remain activated at the Alert                                                                                                                                         EPFC112200F24 T9. Approve emergency exposure controls T10. Ensure protective actions for all onsite personnel T11. Supervise the Station ERO T12. Inform the EOF Emergency Director and onsite NRC as to the status of the plant T13. Assist the EOF Emergency Director in the acquisition of information for the State/Local notifications, NRC Event Notification Worksheet and offsite agency updates T14. Provide information and recommendations to the EOF Emergency Director T15. Implement plans, procedures and schedules to meet emergency response objectives as directed by the EOF Emergency Director T16. Request from the EOF any additional material, personnel resources or equipment needed to implement response plans and operations T17. Assume the duties and responsibilities of DecisionMaker when a transition to Severe Accident Management Guidelines (SAMGs) is initiated T18. Perform Command and Control turnover to the EOF T19. Review and update station priorities T20. Perform periodic facility briefings T21. Invoke 10 CFR 50.54(x), if needed T22. Coordinate facility relocation if needed T23. Implement Beyond Design Basis External Event (BDBEE) response if needed TSC COP Communicator          T1. Communicate and receive information via the COP network or commercial telephone line with               N/A                      Yes         Eliminate position                Yes       No      EPFC112200               N/A appropriate State and County agencies (prior to EOF accepting Command and Control)                                                               T1 EOF COP Communicator has (T1)                    EPFC1001 Section B, 4.3.4 T2. Monitor State/Local communications until released by the TSC Director                                                                        T2 EOF COP Communicator has (T2)                    EPFC1001 Section B, T3. Perform required notifications to states and counties                                                                                        T3 EOF COP Communicator has (T3)                    4.6.1.D T4. Perform required notifications to the NRC                                                                                                    T4 EOF COP Communicator has (T4)
EPFC112200F05 T5. Perform notifications to the Emergency Response Organization                                                                                 T5 EOF COP Communicator has (T5)
EPFC112200F24 T6. Assist in maintaining status boards in the TSC                                                                                               T6 to TSC Ops Liaison 4 OF 10

ERO POSITION MATRIX Position                                                      Min       Key     Procedure(s)                Regulatory Current ERO Position           Tasks (T#)                                                                                                                             Implementing Actions                  eliminated? Task Assigned to?                                 Staffing? NRC PI? EPlan (Rev. 0) section Requirement TSC Protective Measures        T1. Accumulate, tabulate and evaluate data on plant conditions, such as meteorological and radiological monitoring readings, and       T1 from TSC CHP Communicator          No          N/A                                               Yes       Yes     EPFC112200               T11 NUREG 0654 II.K.1.a other pertinent data Coordinator                    T2. Act as the TSC liaison with the appropriate NRC Site Team representative T3 from OSC RP Coordinator                                                                                            EPFC1001 Section B, 4.3.4 T5 NUREG 0654 II.K.1.e T3. Ensure use of protective clothing, respiratory protection, and access control within the plant as deemed appropriate to control    T4 from OSC RP Coordinator                                                                                            EPFC1001 Section B, personnel exposure                                                                                                                     T6 from OSC RP Coordinator                                                                                            4.6.1.C T4. Ensure that appropriate bioassay procedures have been implemented for onsite personnel when a radioactivity incident has occurred                                                                                                                               T7 from OSC RP Coordinator                                                                                            EPFC112200F14 T5. Ensure that personnel are decontaminated, if necessary                                                                             T9 from OSC RP Coordinator                                                                                            EPFC112200F24 T6. Authorize personnel exposures below 5 Rem TEDE (EPA400 lower limit)                                                               T12 from OSC RP Coordinator T7. Assist the TSC Site Director in determining if exposures in excess of the 5 REM TEDE (EPA400 lower limit) are necessary T8. Advise the TSC Site Director of situations when the use of KI should be considered                                                 T15 from OSC RP Coordinator T9. Assist the TSC Site Director in evaluating dosebased PARs (prior to EOF accepting command and control) and changes in             T16 from OSC RP Coordinator radiological event classification T1 from Dosimetry Technician T10. Advise the TSC Site Director and EOF Protective Measures Manager of changes in radiological release status T11. Assist the TSC Site Director in planning rescue operations and provide monitoring services as required, including the transfer of T2 from Dosimetry Technician injured and/or contaminated personnel                                                                                                  T3 from Dosimetry Technician T12. Coordinate with the Security Coordinator to determine the routes to be used for evacuation of nonessential personnel T5 from OSC Chemistry Coordinator T13. Assure additional radiation protection personnel and/or equipment is arranged for, as necessary T14. Support the OSC Radiation Protection Coordinator in the dispatching of OSC Teams T15. Assist the TSC Director in planning radiological controls for personnel dispatched from the Control Room T16. Monitor habitability concerns impacting access to plant and site areas T17. In coordination with the OSC Radiation Protection Coordinator, assemble and dispatch the Field Monitoring Teams as required T18. Supervise the activities of the CHP Communicator in the TSC T19. Request additional Radiation Protection personnel and/or equipment, as necessary in support of station activities and staff relief T20. Prior to EOF Protective Measures Group staffing, perform dose assessments and provide appropriate dosebased PARs T21. Prior to EOF Protective Measures Group staffing, coordinate Field Team Monitoring activities T22. Prior to EOF Protective Measures Group staffing, monitor meteorological conditions and remain cognizant of forecast data T23. Transfer control of the Field Monitoring Teams to the EOF Field Team Specialist T24. Transfer responsibility of dose assessment activities to the EOF Dose Assessment Coordinator T25. Assist the EOF Field Team Specialist in the acquisition of information for the offsite agency updates T26. If radiological hazard exists, ensure TSC HVAC system is placed into applicable mode T27. Ensure the COP Communicator properly updates the Radiological Status Board T28. Evaluate and authorize entry into High Radiation Areas T29. Participate in periodic TSC briefings T30. Ensure and RP Technician is assigned to escort transport of contaminated injured personnel to offsite hospital TSC Reactor Safety Coordinator T1. Accumulate, tabulate and evaluate data on plant conditions                                                                         T1 from Elec/I&C Systems Engineer     No          N/A                                               Yes       No      EPFC112200               N/A (Engineering Coordinator)      T2. Evaluate plant parameters during an emergency to determine the overall plant condition                                             T2 from Elec/I&C Systems Engineer     (retitle)                                                                       EPFC1001 Section B, 4.3.4 T3. Coordinate core damage assessment activities                                                                                       T3 from Elec/I&C Systems Engineer                                                                                     EPFC1001 Section B, T4. Identify data points and control parameters that the Operations staff should monitor                                               T1 from Primary Systems Engineer                                                                                      4.6.1.B T5. Ensure that the current and adequate technical information is depicted on status boards T2 from Primary Systems Engineer                                                                                      EPFC112200F09 T6. Identify and direct staff in the development of special procedures needed to effect longterm safe T3 from Primary Systems Engineer                                                                                      EPFC112200F24 shutdown or to mitigate a release T7. Supervise the total onsite technical staff effort                                                                                  T4 from Primary Systems Engineer T8. Act as the TSC liaison with state and appropriate NRC Site Team representatives                                                    T1 from Reactor Engineer T9. Assist the Protective Measures Coordinator for onsite radiological/technical matters                                               T2 from Reactor Engineer T10. Assist the TSC Site Director in evaluating plant based PARs (prior to EOF accepting command and                                   T1 from Secondary Systems Engineer control) and changes in event classification                                                                                           T2 from Secondary Systems Engineer T11. Assume the duties and responsibilities of an Evaluator when transition to Severe Accident Management Guidelines (SAMG) is initiated and supervise the activities of the SAMG Evaluator Team T12. Direct the activities of the engineering staff in the TSC T13. Direct the analysis of plant problems and provide recommendations for plant modifications to mitigate the effects of the accident T14. Direct the evaluation of possible radiological release paths to the environment T15. Assist the OSC in evaluation of emergency repairs and parts evaluation T16. Participate in periodic TSC briefings T17. Ensure tracking of longterm recovery issues T18. Coordinate required engineering support from Exelon Corporate, unaffected stations, industry groups and contractors through the EOF TSC Elec/I&C Systems Engineer T1. Provide support to the TSC staff                                                                                                    N/A                                   Yes         Eliminate position                                No        No      EPFC112200               T3 NUREG 0654 II.B.5 (Table B1)
(2)                            T2. Aid the assessment and development of repair plans                                                                                                                                   T1 to TSC Reactor Safety Coordinator (Engineering                   EPFC1001 Section B, T3. Provide engineering analysis and troubleshooting                                                                                                                                     Coordinator)                                                        4.6.2.B T2 to TSC Reactor Safety Coordinator (Engineering                   EPFC112200F29 Coordinator)
EPFC112200F24 T3 to TSC Reactor Safety Coordinator (Engineering Coordinator)
TSC Primary Systems Engineer   T1. Provide support to the TSC staff                                                                                                   N/A                                   Yes         Eliminate position                                No        No      EPFC112200               T3 NUREG 0654 II.B.5 (Table B1)
T2. Aid the assessment and development of repair plans                                                                                                                                   T1 to TSC Reactor Safety Coordinator (Engineering                   EPFC1001 Section B, T3. Provide engineering analysis and troubleshooting                                                                                                                                     Coordinator)                                                        4.6.2.D T4. Perform SAMG evaluations as directed                                                                                                                                                 T2 to TSC Reactor Safety Coordinator (Engineering                   EPFC112200F28 Coordinator)
EPFC112200F24 T3 to TSC Reactor Safety Coordinator (Engineering Coordinator)
T4 to TSC Reactor Safety Coordinator (Engineering Coordinator) 5 OF 10

ERO POSITION MATRIX Position                                                      Min       Key     Procedure(s)            Regulatory Current ERO Position          Tasks (T#)                                                                                                   Implementing Actions                 eliminated? Task Assigned to?                                 Staffing? NRC PI? EPlan (Rev. 0) section Requirement TSC Field Team Technician (2) T1. Provide offsite monitoring in the areas potentially affected by a radiological release                  N/A                                  No          N/A                                               No        No      EPFC1001 Section B,   T1 NUREG 0654 II.B.5 (Table B1) 4.6.2.A EPFC112500F01 EPFC112200F24 TSC Ops Liaison               T1. Appraise the Control Room, TSC, and EOF staff of the overall plant conditions and significant changes    T6 from TSC COP Communicator         No          N/A                                               No        Yes     EPFC112200           N/A to system and equipment status                                                                               T2 from the TSC CHP Communicator                                                                                     EPFC1001 Section B, T2. Inform the Control Room, TSC, and EOF of significant changes in event status (e.g., changes in           T2 from OSC Ops Liaison                                                                                              4.6.2.C classification, command and control, initiation of station assembly, accountability, evacuation, etc.)       T4 from OSC Ops Liaison                                                                                              EPFC112200F08 T3. Assist the Site Director in formulating appropriate protective action recommendations when T5 from OSC Ops Liaison                                                                                              EPFC112200F24 necessary T4. Assist the TSC Director in monitoring and tracking proper implementation of EOP actions by the Control Room T5. Assist the TSC Director in maintaining facility status boards, as instructed T6. Assist the ENS Communicator with completion of NRC Emergency Notification Worksheet and in Admin Logistics Coordinator   T1. Coordinate shift relief and continual staffing of the station                                            T1 from TSC Director                 No          N/A                                               No        No      EPFC112200           N/A T2. Assist the Security Coordinator in coordinating ERO and station activities in support of ongoing        T3 from TSC Director                                                                                                 EPFC112200F03 security contingency, accountability or site/area evacuation efforts                                         T4 from TSC Director                                                                                                 EPFC112200F24 T3. Support the processing of special procedures and interim reports during an emergency                     T5 from TSC Director T4. Ensure that event status and priority logs are being maintained in the TSC T6 from TSC Director T5. Coordinate record keeping efforts at the station T7 from TSC Director T6. Arrange for food, sleeping facilities and other necessary accommodations for onsite emergency workers                                                                                                      T8 from TSC Director T7. Arrange for specialized training of Emergency Response personnel as needed                               T9 from TSC Director T8. If TSC Director is not available, perform TSC Director initial actions                                   T10 from TSC Director T9. Perform routine posting, faxing and distribution                                                         T11 from TSC Director T10. Assist in maintaining status boards and logs TSC Director                  T1. Activate, or verify activation of the Emergency Response Data System (ERDS)                              N/A                                  Yes         Eliminate position                                No        Yes     EPFC112200           N/A T2. Supervise the activities of the Admin Logistics Coordinator and COP Communicator                                                                          T1 to Admin Logistics Coordinator                                   EPFC112200F02 T3. Ensure that communications are established with appropriate parties as directed by the TSC Site                                                           T2 N/A                                                              EPFC112200F24 Director                                                                                                                                                      T3 to Admin Logistics Coordinator T4. Ensure that all required notifications to offsite governmental agencies (State/Local and NRC) are                                                         T4 to Admin Logistics Coordinator timely and accurate                                                                                                                                           T5 to Admin Logistics Coordinator T5. Act as the FCS Liaison to any NRC Site Team Representatives                                                                                               T6 to Admin Logistics Coordinator T6. Ensure that the NRC Site Team Representatives are directed to their appropriate counterparts                                                              T7 to Admin Logistics Coordinator T7. Assist the EOF Emergency Director in the acquisition of information for offsite agency updates                                                           T8 to Admin Logistics Coordinator T8. Record and relay inquiries to the TSC Site Director and record responses to such inquiries prior to                                                       T9 to Admin Logistics Coordinator transmission                                                                                                                                                  T10 to Admin Logistics Coordinator T9. Assist the TSC Site Director in maintaining proper records                                                                                                T11 to Admin Logistics Coordinator T10. Participate in periodic facility briefings T11. Assist with accountability and evacuation Reactor Engineer              T1. Perform core damage assessments                                                                          N/A                                  Yes         Eliminate position                                No        No      EPFC112200           T1 NUREG 0654 II.B.5 (Table B1)
T2. Provide engineering support to the TSC and Control Room staffs                                                                                            T1 to TSC Reactor Safety Coordinator (Engineering                   EPFC112200F11 Coordinator)                                                        EPFC112200F24 T2 to TSC Reactor Safety Coordinator (Engineering Coordinator)
TSC Secondary Systems         T1. Provide support to the TSC staff                                                                         N/A                                  Yes         Eliminate position                                No        No      EPFC112200           N/A Engineer                      T2. Aid the assessment and development of repair plans                                                                                                        T1 to TSC Reactor Safety Coordinator (Engineering                   EPFC112200F30 Coordinator)                                                        EPFC112200F24 T2 to TSC Reactor Safety Coordinator (Engineering Coordinator)
Security Coordinator          T1. Maintain plant security and account for all personnel within the protected area                          N/A                                  No          N/A                                               No        No      EPFC112200           N/A T2. Assist the TSC Site Director in evaluating changes in security related threats and event classifications                                                                                                                      EPFC112200F04 T3. Identify any nonroutine security procedures and/or contingencies that are in effect or that require a                                                                                                                        EPFC112200F31 response                                                                                                                                                                                                                          EPFC112200F24 T4. Expedite ingress and egress of emergency response personnel T5. Coordinate with the Protective Measures Coordinator in controlling ingress and egress to and from the Protected Area if radiological concerns are present T6. Provide for access control to the TSC and OSC, as appropriate T7. Expedite entry into the Protected Area, as necessary, for the NRC Site Team T8. Act as the TSC Liaison with the appropriate NRC Site Team representative T9. Assist the Protective Measures Coordinator in determining personnel evacuation routes as necessary T10. Coordinate the evacuation of station nonessential personnel with the appropriate Local Law Enforcement Agencies (LLEAs)
T11. Communicate radiological conditions which may impact Security operations T12. Participate in periodic facility briefings T13. Respond to Hostile Action as needed 6 OF 10

ERO POSITION MATRIX Position                                           Min        Key    Procedure(s)                Regulatory Current ERO Position          Tasks (T#)                                                                                            Implementing Actions                 eliminated? Task Assigned to?                      Staffing? NRC PI? EPlan (Rev. 0) section Requirement TSC CHP Communicator          T1. Maintain continuous communications with the NRC, if requested, via the NRC HPN phone or           N/A                                  Yes         Eliminate position                     No         No     EPFC112200               N/A commercial telephone line                                                                                                                              T1 to Protective Measures Coordinator                    EPFC112200F17 T2. Communicate current Health Physics information to NRC representatives, as requested                                                                T2 to TSC Ops Liaison                                    EPFC112200F24 T3. Coordinate the communications of radiological information to the NRC with the EOF HPN                                                              T3 N/A Communicator (onsite vs. environmental data)                                                                                                           T4 N/A T4. Update status boards, if applicable Admin Assistant (2)           No tasks listed in procedures                                                                         N/A                                  Yes         Eliminate position                     No         No     EPFC112200F24          N/A Site Director Secretary (2)   No tasks listed in procedures                                                                         N/A                                  Yes         Eliminate position                     No         No     EPFC112200F24          N/A TSC Status Board Keeper       No tasks listed in procedures                                                                         N/A                                  Yes         Eliminate position                     No         No     EPFC112200F24          N/A OPERATIONS SUPPORT CENTER OSC Director                  T1. Direct the activation, operation and deactivation activities of the OSC                           T2 from OSC RP Coordinator           No          N/A                                    Yes        Yes    EPFC112300               N/A T2. Manage and supervise the activities of OSC personnel                                              T8 from OSC RP Coordinator                                                                                EPFC1001 Section B, 4.3.3 T3. Assign tasks to designated OSC Coordinators                                                       T1 from Chemistry Coordinator                                                                             EPFC1001 Section B, T4. Coordinate with the OSC Coordinators in the dispatch of Operations Personnel to support Control   T4 from Maintenance Coordinator                                                                           4.7.1.A Room and OSC Team activities T5 from Maintenance Coordinator                                                                           EPFC112300F01 T5. Notify the Control Room and TSC prior to dispatch of OSC Teams into the plant T7 from Maintenance Coordinator                                                                           EPFC112300ADF02 T6. Maintain OSC resources including personnel, materials and equipment to support emergency response                                                                                              T8 from Maintenance Coordinator T7. Maintain accountability for all individuals dispatched from the OSC                               T10 from Maintenance Coordinator T8. Conduct periodic briefings in the overall plant status, emergency response activities and station T1 from Medical Response Coordinator priorities                                                                                            T2 from Medical Response Coordinator T9. Coordinate the development of plans for required maintenance activities T10. Keep the Site Director informed of OSC activities T11. Coordinate emergency team response as requested by the TSC/Control Room to perform search and rescue, damage assessment, damage control, repair and modification, and inplant radiological monitoring T12. Coordinate facility relocation as needed T13. Activate SAFER Response Plan as needed RP Coordinator                T1. Manage OSC manpower needs                                                                         N/A                                  Yes         Eliminate position                     Yes        No     EPFC112300               N/A T2. Brief and dispatch the onsite/offsite radiation monitoring teams                                                                                   T1 OSC Coordinator has (T6)            or RP Tech        EPFC1001 Section B, 4.3.3 T3. Monitor inplant radiological conditions                                                                                                           T2 to OSC Director                                       EPFC1001 Section B T4. Ensure habitability is established and maintained for occupied onsite areas                                                                        T3 to Protective Measures Coordinator                    4.7.2.H T5. Participate with OSC team dispatch and control                                                                                                     T4 to Protective Measures Coordinator EPFC112300F03 T6. Coordinate RP support for OSC teams                                                                                                                T5 N/A EPFC112300ADF02 T7. Track OSC team emergency exposure                                                                                                                  T6 to Protective Measures Coordinator T8. Implement appropriate protective measures for OSC personnel                                                                                        T7 to Protective Measures Coordinator T9. Establish OSC and plant access radiological controls                                                                                               T8 to OSC Director T10. Provide input for facility briefs and updates                                                                                                     T9 to Protective Measures Coordinator T11. Form and prepare emergency response teams as directed by the OSC Director                                                                         T10 N/A T12. Coordinate all RP activities on site                                                                                                              T11 N/A T13. Keep the OSC Director and TSC Protective Measures Coordinator informed of the status of all RP                                                    T12 to Protective Measures Coordinator activities on site                                                                                                                                     T13 N/A T14. Fulfill minimum staffing position of RP Technician if required                                                                                    T14 N/A T15. Direct personnel decontamination, as needed                                                                                                       T15 to Protective Measures Coordinator T16. Maintain accumulated exposure records for all essential onsite personnel                                                                         T16 to Protective Measures Coordinator Technicians (Electrical, I&C, T1. Support the OSC as needed                                                                         N/A                                  No          N/A                                    Yes        No     EPFC1001 Section B, 4.3.3 T1 NUREG 0654 II.B.5 (Table B1)
Mechanical, RP, Chemistry)    T2. Perform initial actions per checklist upon arrival at the OSC                                                                                                                                               EPFC1001 Section B, T3. Attend prejob briefing prior to performing work                                                                                                                                                            4.7.1.B T4. Debrief team activity upon return to the OSC                                                                                                                                                                EPFC1001 Section B, T5. (RP) Coordinate onsite RP activities                                                                                                                                                                        4.7.2.A T6. (RP) Provide radiological surveys and job coverage to repair and corrective action teams as                                                                                                                 EPFC1001 Section B, directed                                                                                                                                                                                                        4.7.2.C T7. (CH) Evaluate and perform all chemistry activities onsite                                                                                                                                                   EPFC1001 Section B, T8. (CH) Act as Chemistry Coordinator until relieved                                                                                                                                                            4.7.2.D T9. Provide repair and corrective actions as directed                                                                                                                                                           EPFC1001 Section B, 4.7.2.E EPFC1001 Section B, 4.7.2.G EPFC112300F16 EPFC112300ADF02 Dosimetry Technician          T1. Issue dosimetry                                                                                   N/A                                  Yes         Eliminate position                     No         No     EPFC1001 Section B,       N/A T2. Perform dose extensions as needed                                                                                                                  T1 to Protective Measures Coordinator                    4.7.2.B T3. Establish OSC dosimetry control point for radiological control areas                                                                               T2 to Protective Measures Coordinator                    EPFC112300F07 T3 to Protective Measures Coordinator                    EPFC112300ADF02 7 OF 10

ERO POSITION MATRIX Position                                          Min       Key     Procedure(s)              Regulatory Current ERO Position         Tasks (T#)                                                                                                    Implementing Actions             eliminated? Task Assigned to?                     Staffing? NRC PI? EPlan (Rev. 0) section Requirement Operations Liaison           T1. Monitor plant status                                                                                      N/A                              Yes         Eliminate position                    No        No      EPFC112300             N/A T2. Assist with status of AOPs and EOPs                                                                                                                    T1 N/A                                                  EPFC1001 Section B, T3. Participate with OSC team dispatch and control                                                                                                         T2 to TSC Ops Liaison                                   4.7.2.F T4. Provide technical support to OSC teams                                                                                                                 T3 N/A                                                  EPFC112300F10 T5. Obtain plant status/Control Room information from Control Room Ops Liaison and transmit this                                                           T4 to TSC Ops Liaison EPFC112300ADF02 information to OSC staff as needed                                                                                                                         T5 to TSC Ops Liaison T6. Assist in maintaining electronic logs and status boards as directed                                                                                    T6 N/A Chemistry Coordinator        T1. Manage OSC manpower needs                                                                                 N/A                              Yes         Eliminate position                    No        No      EPFC112300             N/A T2. Assist with formation of OSC teams                                                                                                                     T1 to OSC Director                                      EPFC112300F03 T3. Participate with OSC team dispatch and control                                                                                                         T2 N/A                                                  EPFC112300ADF02 T4. Provide technical support to dispatched OSC teams                                                                                                      T3 N/A T5. Direct setup of Chemistry Lab(s) for emergency sample collection and analysis if available                                                            T4 N/A T5 to Protective Measures Coordinator ERMS Operator                No tasks listed in procedures                                                                                 N/A                              Yes         Eliminate position                    No        No      EPFC112300ADF02     N/A Maintenance Coordinator (2)  T1. Assist the OSC Director in supervision of OSC personnel                                                   N/A                              Yes         Eliminate position                    No        No      EPFC112300             N/A T2. Assist in formulation of Field Monitoring Teams                                                                                                        T1 N/A                                                  EPFC112300F02 T3. Assist in formulation of sampling teams                                                                                                                T2 N/A                                                  EPFC112300ADF02 T4. Ensure inplant survey information and radiochemistry results are maintained                                                                           T3 N/A T4 to OSC Director T5. Ensure exposure records for essential onsite personnel are maintained T5 to OSC Director T6. Coordinate with the OSC Coordinators to organize inplant teams T6 N/A T7. Ensure inplant team briefings include expected activities and radiological hazards                                                                    T7 to OSC Director T8. Ensure periodic facility briefings are conducted on plant radiological conditions                                                                      T8 to OSC Director T9. Assume OSC Director duties if OSC Director is unavailable                                                                                              T9 N/A T10. Coordinate the acquisition of parts and supplies                                                                                                      T10 to OSC Director Maintenance Planner (2)      No tasks listed in procedures                                                                                 N/A                              Yes         Eliminate position                    No        No      EPFC112300ADF02     N/A Medical Response Coordinator T1. Identify available qualified personnel                                                                    N/A                              Yes         Eliminate position                    No        No      EPFC112300             N/A T2. Provide briefings as time and conditions allow                                                                                                         T1 to OSC Director                                      EPFC112300F04 T2 to OSC Director                                      EPFC112300ADF02 Radio Operator (2)           No tasks listed in procedures                                                                                 N/A                              Yes         Eliminate position                    No        No      EPFC112300ADF02     N/A Store Keeper                 No tasks listed in procedures                                                                                 N/A                              Yes         Eliminate position                    No        No      EPFC112300ADF02     N/A Accountability Clerk         No tasks listed in procedures                                                                                 N/A                              Yes         Eliminate position                    No        No      EPFC112300ADF02     N/A JOINT INFORMATION CENTER Company Spokesperson         T1. Establish communications with the EOF Information Specialist                                              T1 from Executive Liaison        No          N/A                                   Yes       No      Crisis Communication Plan T7 NUREG 0654 II.B.7.d/ II.G.3.a/II.G.4.a T2. Keep Senior Management informed and respond to their inquiries                                            T1 from Internal Information T3. Designate a Senior Manager at corporate headquarters as Executive Liaison to brief other Senior           Spokesperson (Liaison)
Managers and the Board of Directors on emergency status                                                       T2 from Internal Information T4. Respond to congressional and other government inquiries Spokesperson (Liaison)
T5. Designate a Senior Manager at corporate headquarters as Internal Informational Spokesperson T6. Participate in periodic media briefings T7. Coordinate releases of plant information with release of offsite information by federal, state and local officials T8. Ensure that all emergency information messages and news releases are emailed or faxed to the Executive Liaison 8 OF 10

ERO POSITION MATRIX Position                               Min       Key     Procedure(s)                Regulatory Current ERO Position         Tasks (T#)                                                                                           Implementing Actions                  eliminated? Task Assigned to?          Staffing? NRC PI? EPlan (Rev. 0) section Requirement JIC Manager                  T1. Implement the Crisis Communication Plan                                                          T2 from Public Inquiry Supervisor     No          N/A                        Yes       No      EPFC1001 Section B, 4.9.1 N/A T2. Establish communications with the EOF Information Specialist and the Corporate Spokesperson      T3 from Public Inquiry Supervisor                                                              Crisis Communication Plan T3. Evaluate information received to determine type of notification required                         T4 from Public Inquiry Supervisor T4. Ensure Corporate Marketing and Communications is staffed to handle media inquiries or make media T6 from Public Inquiry Supervisor contacts, if required T8 from Public Inquiry Supervisor T5. Keep the Corporate Spokesperson informed of all media activity T6. Activate the Joint Information Center T7. Synchronize the JIC clocks with EOF time T8. Activate the Call Center T9. Ensure distribution of plant status reports T10. Assist the Corporate Spokesperson with timely exchange and release of information with federal, state and local response organizations T11. If the Corporate Spokesperson has not arrived, assume duties as official spokesperson for OPPD T12. Schedule news briefings and/or news conferences and technical briefings as appropriate and in cooperation with other response agencies T13. Serve as moderator at briefings T14. Supervise preparation of FCS Emergency Information website postings, written news releases and emergency status information sheets and serve as final release authority T15. Ensure OPPD participates in Public Inquiry efforts T16. Ensure that briefings and news conferences are recorded and available for transcription T17. Arrange for continuous news media and social media monitoring T18. Ensure aroundtheclock coverage of JIC staffing requirements Executive Liaison            T1. Assist Corporate Spokesperson and Internal Information Spokesperson in disseminating             N/A                                   Yes         Eliminate position         No        No      Crisis Communication Plan N/A information on the emergency status                                                                                                                    T1 to Company Spokesperson Internal Information Liaison T1. Oversee distribution of periodic information updates to OPPD employees                           N/A                                   Yes         Eliminate position         No        No      Crisis Communication Plan N/A (Spokesperson)               T2. Coordinate with Human Resources representatives in responding to calls from family                                                                 T1 to Company Spokesperson members regarding status of employees                                                                                                                  T2 to Company Spokesperson JIC Media Information        T1. Assist in facility activation                                                                    N/A                                   No          N/A                        Yes       No      Crisis Communication Plan N/A Specialist                   T2. Establish contact with the EOF Information Specialist T3. Ensure news conference and media reception area are established and supplied with up to date information T4. Issue JIC activation news release T5. Ensure latest messages from EOF Information Specialist have been forwarded to the JIC T6. Coordinate with state and other agencies to ensure any news releases or PARs are included on FCS's Emergency Information website T7. Prepare written corporate news releases/information updates T8. Post general information updates on FCS Emergency Information website following media briefings T9. Secure JIC Manager review of authorization to release Media Update Messages, website postings and news releases T10. Provide reviewed copy to JIC Clerical Supervisor for appropriate duplication and distribution T11. Coordinate with Public Inquiry Supervisor to ensure regular contact with Universal News Service with special attention toward rumors/media errors or other items of interest T12. Work with the JIC Manager, Corporate Spokesperson and others to ensure needed materials are prepared and ready for use during media briefings T13. Provide assistance for news conferences and briefings as directed by the JIC Manager T14. Greet and orient news personnel as the arrive 9 OF 10

ERO POSITION MATRIX Position                                      Min       Key     Procedure(s)              Regulatory Current ERO Position           Tasks (T#)                                                                                      Implementing Actions                   eliminated? Task Assigned to?                 Staffing? NRC PI? EPlan (Rev. 0) section Requirement JIC Technical Liaison          T1. Establish communication with the EOF Technical Liaison                                      N/A                                    No            N/A                             Yes       No      Crisis Communication Plan N/A T2. Receive and evaluate plant status board reports and review significant changes with the Corporate Spokesperson, JIC Manager and JIC Media Information Specialist T3. Assist the JIC Manager and JIC Media Information Specialist in checking corporate news releases for technical accuracy T4. Assist the Corporate Spokesperson in interpretation and evaluation of nuclearrelated information T5. Attend all media briefings and provide necessary technical support T6. Serve as a technical information source for Public Inquiry Public Inquiry Supervisor      T1. Set up and staff the Public Inquiry Center                                                  N/A                                    Yes           Eliminate position              No        No      Crisis Communication Plan T6 NUREG 0654 II.G.4.c T2. Coordinate activities with state and local information officers                                                                                  T1 N/A T3. Assign a Public Inquiry Specialist to act as liaison between Public Inquiry and JIC Manager                                                      T2 to JIC Manager T4. Keep the Public Inquiry Specialists fully informed on status of the emergency                                                                    T3 to JIC Manager T4 to JIC Manager T5. Ensure any media error reported to Public Inquiry are brought immediately to the attention T5 to Public Inquiry Specialist of the JIC Manager or Corporate Spokesperson T6 to JIC Manager T6. Ensure any rumors/requests for information from the Call Center are responded to                                                                 T7 N/A T7. Coordinate with the JIC Media Information Specialist to ensure regular contact with media                                                        T8 JIC Manager has (T8) monitoring T8. Contact Call Center to ensure they are activated Public Inquiry Specialist (10) T1. Assist in facility activation                                                               Reduce to 5 positions                  No            N/A                             No        No      Crisis Communication Plan N/A T2. Staff telephones and provide prompt and accurate information to citizen callers             T5 from Public Inquiry Supervisor      (reduce to 5)
T3. Direct media to attend news briefings and to access the website T4. Report all unusual or new rumors to the Public Inquiry Supervisor T5. Record all calls on appropriate forms JIC Clerical Supervisor        T1. Assist the JIC Manager in staffing and activating the JIC                                   N/A                                    No            N/A                             Yes       No      Crisis Communication Plan N/A T2. Set up clerical center and supervise staffing and equipping of JIC T3. Assist with notifying locals news media and state and local public information officers as directed T4. Ensure media information updates/news releases are retrieved, copied and distributed as directed T5. During news media briefings, ensure the JIC Manager is immediately notified of emergency classification changes T6. Escort outside agencies to their work areas T7. Assist outside agencies with set up and provide orientation to the JIC T8. Provide clerical and other support to outside agencies, as needed T9. Provide information to the Executive Liaison/Internal Information Spokesperson, as directed T10. Assist the JIC Manager with scheduling of news conferences and briefings T11. Assign clerical help to assist JIC Manager and Corporate Spokesperson as required T12. Supervise reproduction and distribution of emergency messages from the EOF, website postings, written news releases and media update sheets, and all messages and news releases provided by the state and federal information officers, as directed T13. Assist in receiving telephone calls and messages for the JIC Manager if needed T14. Maintain a complete file of all information processed through the clerical center 10 OF 10

OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION DOCKET NUMBER 50-285 / LICENSE NUMBER DPR-40 ATTACHMENT 6 LIST OF REGULATORY COMMITMENTS

LIC-16-0076 Attachment 6 Page 1 Regulatory Commitments This table identifies actions discussed in this letter for which OPPD commits to perform. Any other actions discussed in this submittal are described for the NRCs information and are not commitments.
TYPE (Check one)              SCHEDULED ONE-TIME       CONTINUING      COMPLETION DATE COMMITMENT                            ACTION      COMPLIANCE           (If Required)
FCS has not yet finalized a schedule of drills               x                    Appropriate advanced that will be conducted. Provide the NRC Project                                   notice to allow the NRC Manager a schedule of drills that will be                                         and FEMA an conducted in preparation for implementation of                                    opportunity to observe the FCS post-shutdown RERP.                                                       each drill.
Revise applicable fuel handling procedures to                x                    Prior to implementation require that a Chemistry Technician be on-site                                    of ERO changes.
or the radiation monitors listed in the gaseous effluent EALs are in service as a prerequisite to handling or moving spent fuel.
Training and procedures will be developed and                x                    Prior to implementation in place prior to performing post-shutdown                                        of ERO changes.
ERO drills. The drill scenarios will include spent fuel pool events and be designed to test the major elements of the FCS post shutdown emergency plan. Major elements to be tested will include communications and coordination with offsite response organizations, including the Joint Information Center.
State, local and Federal response                            x                    Appropriate advanced organizations will be provided the opportunity                                    notice to allow the NRC to participate in or observe the drills conducted                                 and FEMA an in preparation for implementation of the FCS                                      opportunity to observe post-shutdown RERP.                                                               each drill and to allow the State/local organizations to participate.}}