ML17112A036

NRR E-mail Capture - Fort Calhoun Station - Final RAI Regarding Permanently Defueled EP and EAL Scheme Change LAR

ML17112A036
Person / Time
Site:	Fort Calhoun
Issue date:	04/20/2017
From:	James Kim Special Projects and Process Branch
To:	Matzke E Omaha Public Power District
References
MF8951
Download: ML17112A036 (7)

Text

NRR-PMDAPEm Resource From: Kim, James Sent: Thursday, April 20, 2017 7:31 AM To: MATZKE, ERICK P Cc: BLOME, BRADLEY H

Subject:

FORT CALHOUN STATION - FINAL RAI Regarding Permanently Defueled EP and EAL Scheme Change LAR (CAC NO. MF8951)

Final Request for Additional Information On April 7, 2017, the U.S. Nuclear Regulatory Commission (NRC) staff sent Fort Calhoun Station (FCS) the draft Request for Additional Information (RAI). This RAI relates to the proposed amendment that would revise the FCS Emergency Plan, referred to hereafter as the Permanently Defueled Emergency Plan (PDEP), and Emergency Action Level (EAL) scheme for the permanently defueled condition.

On April 19, 2017, a teleconference between FCS and NRC staff was held to discuss the information requested by the NRC staff was understood and any additional clarifications on the RAI were required. Based on the teleconference, a clarification for the question, FCS-RAI-5 was provided. FCS determined that the information requested by the NRC staff was understood and any other additional clarifications on the RAI was not necessary. FCS agreed to provide a response to this final RAI shown below within 30 days from the date of this correspondence. The NRC staff also informed the licensee that a publicly available version of this final RAI would be placed in the NRCs Agencywide Documents Access and Management System.

REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST 16-07: REVISE THE FORT CALHOUN STATION EMERGENCY PLAN TO THE PERMANENTLY DEFUELED EMERGENCY PLAN AND PERMANENTLY DEFUELED EMERGENCY ACTION LEVEL SCHEME OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION, UNIT NO. 1 DOCKET NO. 50-285 By letter dated June 24, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16176A213), supplemented by letter dated August 25, 2016 (ADAMS Accession No. ML16242A127),

Omaha Public Power District (OPPD) submitted certification to the U.S. Nuclear Regulatory Commission (NRC) indicating its intention to permanently cease power operations at the Fort Calhoun Station, Unit No. 1 (FCS) facility on October 24, 2016, pursuant to10 CFR 50.82(a)(1)(i). By letter dated November 13, 2016 (ADAMS Accession No. ML16319A254), OPPD submitted a certification to the NRC of the removal of fuel from the reactor vessel, pursuant to 10 CFR 50.82(a)(1)(ii). Upon docketing of the certifications, the 10 CFR Part 50 license for FCS no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2).

By letter dated December 16, 2016 (ADAMS Accession No. ML16351A464), OPPD requested an amendment to Renewed Facility Operating License Number DPR-40 for the FCS. The proposed amendment would revise the FCS Emergency Plan, referred to hereafter as the Permanently Defueled Emergency Plan (PDEP), and Emergency Action Level (EAL) scheme for the permanently defueled condition.

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In reviewing the license amendment request (LAR), the NRC staff used the guidance from recent emergency preparedness (EP)-related decommissioning exemption reviews provided in Interim Staff Guidance (ISG) document - NSIR/DPR-ISG-02, Emergency Planning Exemption Requests For Decommissioning Nuclear Power Plants, Attachment 1, Staff Guidance for Evaluating Permanently Defueled Emergency Plans (ADAMS Accession No. ML14106A057). The staff also informed its review of the EAL scheme utilizing the guidance provided in the Nuclear Energy Institute (NEI) document, NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, dated November 2012 (ADAMS Accession No. ML12326A805).

Based on the NRC staff's initial review of OPPD's LAR, the following requests for additional information (RAIs) are required to facilitate completion of the staff's technical review:

FCS-RAI-1 Section 1.0, Summary Description, in Attachment 1 provides the following, in part:

the spent fuel stored in the spent fuel pool (SFP) will have decayed to the extent that the requested exemptions, PDEP, and Permanently Defueled EAL scheme may be implemented without any additional compensatory actions. (emphasis added)

One of the considerations for the granting of the exemptions is that FCS maintains the equipment, procedures and personnel for implementation of SFP mitigation strategies in the unlikely event of a beyond design-basis-accident. This is also maintained as a condition to the operating license.

Please provide a basis for this statement or revise the application to align with continued license commitment under proposed EP exemption to maintain SFP mitigation strategies.

FCS-RAI-2 Section 3.1, Accident Analysis Overview, in Attachment 1 provides the following, in part:

According to the EPA, Protective Action Guides and Planning Guidance for Radiological Incidents, Draft for Interim Use and Public Comment, dated March 2013 (Reference 6), Section 2.3.5, PAGs and Nuclear Facilities Emergency Planning Zones (EPZ), EPZs are not necessary at those facilities where it is not possible for PAGs to be exceeded offsite.

Please update the application accordingly, to reflect current Federal guidance provided in EPA-400/R-17/001 (January 2017) (ADAMS Accession No. ML17044A073).

FCS-RAI-3 Section 3.7, Permanently Defueled Emergency Plan, in Attachment 1 provides the following, in part:

Notification of an emergency declaration will be made to State and County authorities within 60 minutes of an emergency declaration or change in classification. Because of the geographic location of FCS, emergency planning and responsibilities have historically involved coordination with the States of Nebraska and Iowa. 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. These discussions have addressed changes to onsite and offsite emergency preparedness throughout the decommissioning process, including the proposed 30-minute emergency declaration time and the 60-minute notification time to the State of Nebraska. Emergency management officials with both states have agreed that these proposed changes are appropriate. (emphasis added)

Please provide any documentation of discussions with the State of Iowa and Harrison County indicating agreement that notification of an emergency declaration or change in classification is not required, as well as 2

notification of whether a radiological release is taking place. [NOTE: A criteria in the NRCs approval of EP exemption per NSIR/DPR-ISG-02, is that in the likely event of a SFP accident where licensee mitigation strategies may not preclude a significant radiological release, adequate time would exist for offsite officials to implement protective measures for the public if warranted.]

FCS-RAI-4 Section 3.8.3, State and Local Government Review of Proposed Changes, in Attachment 1 states:

State and local emergency management officials are advised of EAL [emergency action levels] changes that are implemented.

Section IV.B.1 of Appendix E to 10 CFR Part 50 states, in part that emergency action levels shall be reviewed with the State and local government authorities on an annual basis. Please provide additional clarification (see Exemption RAI-002).

FCS-RAI-5 Section 2.1, Facility On-Shift Organization, in Enclosure 1 provides the following, in part:

The minimum staff required to conduct routine and immediate emergency mitigation is maintained on-shift 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.

Section 15.1.1, Emergency Response Organization Training, in Enclosure 1 provides the following, in part:

Personnel assigned to liaison with offsite fire departments are trained in accordance with the Fire Protection Program, including mitigating strategies required for a catastrophic loss of SFP inventory.

Page 33 of Attachment 1 to the application dated September 2, 2016, License Amendment Request (LAR) 16-02: Revise the Fort Calhoun Station Emergency Plan to Address the Permanently Defueled Condition, (ADAMS Accession No. ML16246A321) provides the following:

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.

However, there is no reference to any personnel specifically assigned to perform SFP inventory makeup strategies in the proposed PDEP. Please explain who performs SFP inventory makeup strategies in the proposed on-shift staffing and verify that the strategies can be implemented by the on-shift personnel within two hours, without interfering with other designated PDEP actions. Additionally, if the personnel are in addition to the identified on-shift staffing, this need to be identified in the PDEP on in Table 2.1, On-Shift and Emergency Response Organization Staffing Requirements.

FCS-RAI-6 NUREG-0654 Criteria L.1, in Attachment 1 to NSIR/DPR-ISG-02, states:

Each licensee shall arrange for hospital and medical services having the capability for evaluation of radiation exposure and uptake, including assurance that persons providing these services are adequately prepared to handle contaminated individuals.

Section 1.1, Overview of the Permanently Defueled Emergency Plan, of Enclosure 1 states:

Fixed medical services are provided by Blair Hospital to provide medical support for work related injuries, and University of Nebraska Medical Center in Omaha, which maintains a regional Radiation Health 3

Center that provides services for the treatment of radiologically contaminated injuries and radiation exposure evaluation.

Section 12.0, Medical and Health Support, of Enclosure 1 states:

Agreements are in place with Blair Hospital and University of Nebraska Medical Center in Omaha for medical treatment of patients from FCS who have injuries complicated by radioactive contamination.

These hospitals have trained personnel and detailed procedures for handling radioactively contaminated patients from FCS.

Please clarify if Blair Hospital provides medical treatment of patients from FCS who have injuries complicated by radioactive contamination, and revise PDEP accordingly to reflect capability.

FCS-RAI-7 NUREG-0654 Criterion B.9, in Attachment 1 to NSIR/DPR-ISG-02, states:

Reference to the arrangements and agreements reached with contractor, private, and local support agencies shall be appended to the plan.

Section 3.0, Emergency Response Support and Resources, of Enclosure 1 states:

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

Please clarify why references to the letters of agreement, identifying the specific organizations, are not included as an Appendix to the proposed PDEP, or revise accordingly.

FCS-RAI-8 NUREG-0654 Criteria E.4, in Attachment 1 to NSIR/DPR-ISG-02, states:

The licensee, in coordination with State and local organizations, shall establish the contents of the emergency messages to be sent from the nuclear facility. These messages shall contain the following information if it is known and appropriate:

a. location of incident and name and telephone number (or communications channel identification) of caller;

b. date/time of incident;

c. class of emergency;

k. licensee emergency response actions underway;

m. request for any needed onsite support by offsite organizations; and

n. prognosis for worsening or termination of event based on facility information Section 5.1.2, State and Local Government Notification, of Enclosure 1 states:

OPPD, in coordination with the State of Nebraska, have established the contents of the initial emergency messages to be sent from FCS in the event of an emergency is declared. These messages contain such information as the class of the emergency and whether a release is taking place.

Please explain why remaining criteria is not addressed in the proposed PDEP, or provide documentation of agreement by applicable State and local organizations to proposed initial message content.

FCS-RAI-9 4

NUREG-0654 Criterion K.3.a and b, in Attachment 1 to NSIR/DPR-ISG-02, state:

a. Each licensee shall make provision for 24-hour-per-day capability to determine the doses received by emergency personnel involved in any nuclear accident, including volunteers. Each licensee shall make provisions for distribution of dosimeters.

b. Each licensee shall ensure that dosimeters are read at appropriate frequencies and provide for maintaining dose records for emergency workers involved in any nuclear accident.

No reference to these statements could be found in Section 11.0, Radiological Exposure Control, of . Please explain why these criteria are not addressed in the proposed PDEP, or revise accordingly to address.

FCS-RAI-10 NUREG-0654 Criterion K.5.a and b, in Attachment 1 to NSIR/DPR-ISG-02, state:

a. Each licensee, as appropriate, shall specify action levels for determining the need for decontamination.

b. Each licensee, as appropriate, shall establish the means for radiological decontamination of emergency personnel wounds, supplies, instruments and equipment, and for waste disposal.

No reference to these statements could be found in Section 11.0 of Enclosure 1. Please explain why these criteria are not addressed in the proposed PDEP, or revise accordingly to address.

FCS-RAI-11 NUREG-0654 Criteria F.2, in Attachment 1 to NSIR/DPR-ISG-02, states:

Each licensee shall ensure that a coordinated communication link for medical support exists.

Section 12.0, Medical and Health Support, of Enclosure 1 states:

FCS is capable of maintaining communications with the ambulance while transporting a patient.

The proposed PDEP provides no specifics on the method of communications, nor is there any reference to communication methods with the Blair Hospital and the University of Nebraska Medical Center in Omaha.

Please provide a description of the methods of communications to be used between FCS and Blair Hospital and the University of Nebraska Medical Center.

FCS-RAI-12 NUREG-0654 Criteria N.3.c, in Attachment 1 to NSIR/DPR-ISG-02, states:

A medical emergency drill involving a simulated contaminated individual which contains provisions for participation by the local support services agencies (i.e., ambulance and offsite medical treatment facility) shall be conducted annually.

Section 12.0, Medical and Health Support, of Enclosure 1 states:

Agreements are in place with Blair Hospital and University of Nebraska Medical Center in Omaha for medical treatment of patients from FCS who have injuries complicated by radioactive contamination.

These hospitals have trained personnel and detailed procedures for handling radioactively contaminated patients from FCS.

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However, Section 14.2.1, Medical Drills, of Enclosure 1 states:

The University of Nebraska Medical Center 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.

It appears that the PDEP does not address Blair Hospital as also being invited to participate in the annual exercise and/or scheduled drill(s). Additionally, there is no provision for participation of the Emergency Medical Service (EMS) organizations (i.e., victim/patient transport) in the annual exercise and/or scheduled drill(s).

Please explain why these areas are not addressed in the proposed PDEP, or revise accordingly to address.

FCS-RAI-13 NUREG-0654 Criteria O.3, in Attachment 1 to NSIR/DPR-ISG-02, states:

Training for individuals assigned to licensee first aid teams shall include courses equivalent to Red Cross First Aid, CPR, AED for Lay Responders or equivalent.

Section 12.0, Medical and Health Support, of the proposed PDEP states:

FCS maintains on shift personnel and equipment to provide first aid for personnel working at the site.

Please provide further information on who these personnel are on-shift (e.g., is duty performed as a collateral function), and what level and frequency of training they are given.

FCS-RAI-14 NUREG-0654 Criterion P.3 and P.5, in Attachment 1 to NSIR/DPR-ISG-02, states:

3. Each licensee shall designate an Emergency Planning Coordinator with responsibility for the development and updating of emergency plans and coordination of these plans with other response organizations

5. The emergency response plans and approved changes to the plans shall be forwarded to all organizations and appropriate individuals with responsibility for implementation of the plans. Revised pages shall be dated and marked to show where changes have been made.

Section 16.0, Responsibility for the Planning Effort: Periodic Review and Distribution of Emergency Plans, of does not specifically address these criteria. Please explain why these criteria are addressed in the proposed PDEP, or revise accordingly to address.

Regards, Jim Kim Project Manager - Fort Calhoun Station NRR/DORL/LSPB 301-415-4125 6

Hearing Identifier: NRR_PMDA Email Number: 3453 Mail Envelope Properties (James.Kim@nrc.gov20170420073000)

Subject:

FORT CALHOUN STATION - FINAL RAI Regarding Permanently Defueled EP and EAL Scheme Change LAR (CAC NO. MF8951)

Sent Date: 4/20/2017 7:30:38 AM Received Date: 4/20/2017 7:30:00 AM From: Kim, James Created By: James.Kim@nrc.gov Recipients:

"BLOME, BRADLEY H" <bblome@oppd.com>

Tracking Status: None "MATZKE, ERICK P" <ematzke@oppd.com>

Tracking Status: None Post Office:

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