ML14255A004

Supplement 2 and Response to Request for Additional Information Regarding License Amendment Request 257, Permanently Defueled Emergency Plan and Emergency Action Level Scheme

ML14255A004
Person / Time
Site:	Kewaunee
Issue date:	09/09/2014
From:	Mark D. Sartain Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
14-427
Download: ML14255A004 (55)

Text

Dominion Energy Kewaioee, Inc.

5000 Dominion Boulevard, Glen Allen, VA 23060m n Web Address: www.dom.com September 9, 2014 U. S. Nuclear Regulatory Commission Serial No.14-427 Attention: Document Control Desk LIC/JG/RO Washington, DC 20555-0001 Docket No. 50-305 License No. DPR-43 DOMINION ENERGY KEWAUNEE, INC.

KEWAUNEE POWER STATION SUPPLEMENT 2 AND RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST 257, PERMANENTLY DEFUELED EMERGENCY PLAN AND EMERGENCY ACTION LEVEL SCHEME By application dated January 16, 2014 (Reference 1), Dominion Energy Kewaunee, Inc.

(DEK) requested an amendment to Facility Operating License Number DPR-43 for Kewaunee Power Station (KPS). The proposed amendment would revise the radiological emergency response plan and associated emergency action level (EAL) scheme. The proposed changes were submitted to the NRC for approval prior to implementation, as required under 10 CFR 50.54(q)(4) and 10 CFR 50, Appendix E, Section IV.B.2. The application was supplemented on June 19, 2014 (Reference 2).

Subsequently, the Nuclear Regulatory Commission (NRC) transmitted a request for additional information (RAI) regarding the proposed amendment (Reference 3). The RAI questions and associated DEK responses are provided in Attachment 1 to this letter.

In response to an NRC staff request for additional information regarding the proposed Permanently Defueled Emergency Plan (PDEP), DEK is revising the originally proposed amendment. Attachment 2 to this letter provides a supplemental discussion and technical analysis for the proposed amendment. Enclosure 1 to this letter provides the proposed revisions to the originally submitted PDEP (as supplemented in Reference 2) in response to the RAI.

The analyses provided in the originally submitted amendment (Reference 1) remain applicable and bounding to the proposed revisions. The conclusions of the no significant hazards consideration and the environmental considerations contained in the originally submitted amendment are not affected by, and remain applicable to, this supplement.

The EAL scheme and the comparison matrix provided in the original amendment request (Reference 1), and the EAL basis document provided in the first supplement to the amendment request (Reference 2), remain applicable to this second supplement.

Serial No.14-427 License Amendment Request 257 Page 2 of 3 The KPS Facility Safety Review Committee has reviewed this proposed revision to the originally submitted emergency plan and a copy of this submittal has been provided to the State of Wisconsin in accordance with 10 CFR 50.91(b).

The October 31, 2014 requested approval date for the submittal remains unchanged.

Please contact Mr. Jack Gadzala at 920-388-8604 if you have any questions or require additional information.

Sincerely, Mark D. Sartain Vice President - Nuclear Engineering COMMONWEALTH OF VIRGINIA )

)

COUNTY OF HENRICO )

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Mark D. Sartain, who is Vice President - Nuclear Engineering of Dominion Energy Kewaunee, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this q]i day of .. ,2014.

My Commission Expires: 4231//6,

!Notbfy46u blic Notary Public Commonwealth of Virginia I Reg. # 7518653 My Commission Expires December 31, 201/

Attachments:

1. Response to Request for Additional Information

2. Supplement 2, Discussion of Change and Technical Analysis

Enclosure:

1. Supplement 2, Permanently Defueled Emergency Plan

Serial No.14-427 License Amendment Request 257 Page 3 of 3

References:

1. Letter from Mark D. Sartain (DEK) to NRC Document Control Desk, "License Amendment Request 257, Permanently Defueled Emergency Plan and Emergency Action Level Scheme," dated January 16, 2014. [ADAMS Accession No.

ML14029A076]

2. Letter from Mark D. Sartain (DEK) to NRC Document Control Desk, "Supplement 1 and Response to Request for Additional Information Regarding License Amendment Request 257, Permanently Defueled Emergency Plan and Emergency Action Level Scheme," dated June 19, 2014. [ADAMS Accession No.

ML14178A167]

3. Letter from Thomas J. Wengert (NRC) to David A. Heacock (DEK), "Kewaunee Power Station - Request for Additional Information Concerning License Amendment Request for Emergency Plan Changes (TAC No. MF341 1)," dated August 14, 2014. [ADAMS Accession No. ML14115A041]

Commitments made in this letter: None.

cc: Regional Administrator, Region III U. S. Nuclear Regulatory Commission 2443 Warrenville Road, Suite 210 Lisle, IL 60532-4352 Mr. W. C. Huffman Jr., Project Manager U.S. Nuclear Regulatory Commission One White Flint North, Mail Stop 08-Dl 5 11555 Rockville Pike Rockville, MD 20852-2738 Public Service Commission of Wisconsin Electric Division P.O. Box 7854 Madison, WI 53707

Serial No.14-427 ATTACHMENT 1 LICENSE AMENDMENT REQUEST 257 PERMANENTLY DEFUELED EMERGENCY PLAN AND EMERGENCY ACTION LEVEL SCHEME RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No.14-427 Attachment 1 Page 1 of 13 LICENSE AMENDMENT REQUEST 257 PERMANENTLY DEFUELED EMERGENCY PLAN AND EMERGENCY ACTION LEVEL SCHEME RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION:

By application dated January 16, 2014 (Reference 1), Dominion Energy Kewaunee, Inc.

(DEK) requested an amendment to Facility Operating License Number DPR-43 for Kewaunee Power Station (KPS). The proposed amendment would revise the radiological emergency response plan (proposing a Permanently Defueled Emergency Plan (PDEP)) and revise the associated emergency action level (EAL) scheme (proposing a Permanently Defueled EAL (PDEAL) Scheme). The proposed changes were submitted to the NRC for approval prior to implementation, as required under 10 CFR 50.54(q)(4) and 10 CFR 50, Appendix E, Section IV.B.2. The application was supplemented on June 19, 2014 (Reference 2).

Subsequently, the Nuclear Regulatory Commission (NRC) transmitted a request for additional information (RAI) regarding the proposed amendment (Reference 3). The RAI questions and associated DEK responses are provided below.

NRC Question KPS-RAI-19 Under Section 6.4, "Functional Responsibilities," of the PDEP, please respond to the following:

a. NRC's evaluation of the requested exemption considers the licensee's ability to promptly implement mitigation measures for the SFP [spent fuel pool]. Please explain if KPS has performed an on-shift analysis for Emergency Response Organization (ERO) functions to ensure sufficient personnel will be able to respond to a catastrophic loss of SFP water inventory using the minimum shift staffing as indicated in Section 6.4.

The response should include:

• SFP mitigation strategies described in DEK's letters dated January 10, 2014, and April 29, 2014 (ADAMS Accession Nos. ML14016A078 and ML14126A005 respectively); and,

• All functional areas of the table in Section 6.4 to address any potential collateral duties.

b. Please describe the personnel that are assigned on-shift to monitor personnel exposure and determine if radiological conditions exist that may preclude access to the SFP to perform mitigation actions, if required.

Serial No.14-427 Attachment 1 Page 2 of 13

Response

a. On-shift Analysis for ERO Functions.

DEK has performed an analysis for on-shift ERO functions to ensure sufficient personnel will be able to respond to a catastrophic loss of SFP water inventory.

The on-shift staffing analysis shows that sufficient personnel will be able to perform required ERO functions, including response to a catastrophic loss of SFP water inventory, using the shift staffing indicated in Section 6.4 of the PDEP.

The on-shift incipient fire brigade (3 members) can initiate SFP mitigation strategies (described in DEK's letters dated January 10, 2014, and April 29, 2014) within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> from the time it is determined that external makeup is required. The fire brigade is composed of a plant operator, security personnel (who are not relied upon to perform security response duties required by the physical security plan), or other qualified personnel who do not have other required emergency response duties. Therefore, sufficient personnel will be able to respond to a catastrophic loss of SFP water inventory using the minimum shift staffing, accounting for collateral duties, as indicated in Section 6.4 of the PDEP.

On-Shift Staffing Evaluation and Results The approach used for the on-shift analysis of ERO functions is similar to the structured approach used to perform previous on-shift staffing analyses under the guidance provided in NEI 10-05, "Assessment of On-Shift Emergency Response Organization Staffing and Capabilities." The NEI methodology for developing the Emergency Plan on-shift staffing licensing basis is composed of the following:

• Define the on-shift ERO staffing and response time requirements.

" Define the site-specific event scenarios described in the ISG.

" Perform an On-shift Staffing Analysis (OSA) for each event scenario.

• Perform a Time-Motion Study (TMS) to analyze the results of the OSA, if deemed necessary.

The on-shift staff consists of individuals necessary to support the Emergency Plan functional areas described in PDEP Section 6.4. The response time used for this analysis was the maximum acceptable time between emergency declaration and the expected action. The event is conservatively assumed to occur outside of normal work hours when only the required minimum on-shift positions are filled. On-shift staff positions were evaluated, accounting for collateral duties, to ensure their capability to perform required tasks.

The staffing analysis determined that sufficient on-shift personnel will be able to respond to a catastrophic loss of SFP water inventory and promptly implement mitigation measures prior to arrival of ERO augmentation personnel. A three member

Serial No.14-427 Attachment 1 Page 3 of 13 fire brigade is capable of setting up a portable pre-staged diesel-powered pump and initiating water flow to the SFP within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Prompt operator actions required to mitigate the emergency condition do not conflict with or prevent the timely performance of assigned emergency plan functions. There are no on-shift collateral duties inhibiting implementation of the emergency plan.

Revisions to the Proposed PDEP To enhance the ERO, DEK is proposing to add an on-shift radiation technologist to the ERO staffing listed in Section 6.4 and a two hour augmentation response time (reduced from four hours) in Section 6.2 of the PDEP.

Declaration of an event, notification to State and county authorities, and communication to the NRC will be provided by the Shift Manager (SM)/Emergency Director (ED).

Under normal conditions, the SM/ED provides an oversight/command and control function and will continue to provide this function during a declared event. The event assessment, classification, and declaration functions of the SM/ED will be carried out in series and can readily be performed within the proposed time of 30 minutes. The notification function of the SM/ED can be readily performed within the proposed time of 60 minutes of event declaration. Due to the limited number of events that can occur at KPS in the permanently defueled condition and the significant length of time that would be needed to heat up the spent fuel pool before any actions are required, oversight/command and control would have a minimal impact on the ability of the SM/ED to perform his/her other emergency functions.

KPS relies on an on-site incipient fire brigade for fire response. The incipient fire brigade typically consists of the on-shift plant operator as the Incident Commander and two designated members (these two designated members do not have other required response duties (three members total). Incipient fire responses consist of assessing the alarm condition and extinguishing small fires with fire extinguishers or small hand lines (manual hose systems used to apply extinguishing agents). Offsite fire and rescue resources would be called to respond for fires having the potential to exceed the incipient fire response capability. Duties and responsibilities of the fire brigade are contained in the Fire Protection Program Plan.

The table below lists on-shift positions and the augmented positions that fulfill emergency staffing capabilities.

Serial No.14-427 Attachment 1 Page 4 of 13 On-Shift Positions and Assigned Functions AUGMENTEDSPONS STAFF FUNCTIONAL AREA LOCATION ON-SHIFT STAFF 2UR 2 HOUR RESPONSE Plant Operations and Assessment of Operational Control Room Emergency Director ---

Aspects Emergency Direction and Control Room Emergency Director ---

Control Notification Commuication/ Control Room Emergency Director Technical Director Communication Radiological Accident Assessment and Control Room; Emergency Director; Radiation Protection Director Protective Actions On Scene Radiation Technologist (In-Plant)

Plant System Engineering, Control Room; Emergency Director; Repair, and On Scene Plant Operator"" Technical Director Corrective Actions Per Fire Protection Offsite Response Program Plan* Organization' Rescue and First Aid On Scene ** Offsite Response Treatment Organization*

Site Access Control and Securit Station Per Security Plan Accountability SecurityIStatio Per_SecurityPlan ---

• Fire Brigade is composed of Plant Operator, Security personnel, or other qualified personnel. Fire Brigade personnel may be assigned other Emergency Plan functions (e.g. rescue and first aid treatment, repair, and corrective actions).

• • Provided by on-shift personnel who may be assigned other functions (e.g. Fire Brigade personnel or Radiation Technologist).

Response time is based upon Fire Protection Program Plan (fire fighting) or response capability of offsite organization (e.g., ambulance).

Fire Brigade members (3 personnel) are utilized to perform mitigating strategies required for a catastrophic loss of spent fuel pool inventory.

The above table appears in Section 6.4 of the PDEP (Table 6-1, Emergency Response Organization Staffing). The revised PDEP is provided as Enclosure 1 to this letter. The associated technical analysis and discussion of the change is provided in Attachment 2 to this letter.

b. Personnel Exposure and Radiological Conditions Monitoring On-shift personnel are trained in radiological monitoring to assess personnel exposure and determine whether radiological conditions exist that may preclude access to the SFP to perform mitigation actions, if required. Such monitoring can be readily performed by on-shift personnel during the initial phase of an event. Personnel responding to areas around the SFP would be in possession of electronic dosimeters that can be used to monitor dose and dose rates. The Shift Manager has the capability

Serial No.14-427 Attachment 1 Page 5 of 13 to monitor plant conditions using installed area radiation monitors via the plant process computer system and plant operators are trained to self monitor using dose rate meters.

Therefore, no specific personnel are needed on-shift solely to monitor personnel exposure or radiological conditions. Although an on-shift staffing analysis shows that a specific individual for the radiological assessment function is not required to be on-shift to effectively respond to a catastrophic loss of SFP water inventory, the proposed PDEP has been revised to include one Radiation Technologist as part of the on-shift complement to enhance response capabilities for radiological monitoring (see Table 6-1 contained in Section 6.4 of the PDEP).

NRC Question KPS-RAI-20 The PDEP is based on the NRC's granting of exemptions from certain portions of 10 CFR 50.47 and 10 CFR 50, Appendix E Section IV. The NRC staff based its evaluation of the DEK request for exemptions from EP requirements on site-specific analyses.

DEK's analysis is based on reasonable assurance that in granting the requested exemption to DEK: (1) an offsite radiological release will not exceed the Environmental Protection Agency (EPA) Protective Action Guides (PAGs) at the site boundary for a design-basis accident; and (2) in the unlikely event of a severe beyond design-basis accident resulting in a loss of air cooling, there is sufficient time to initiate appropriate mitigating actions and if a release is projected to occur, there is sufficient time for offsite agencies to take protective actions using a Comprehensive Emergency Management Plan (CEMP) to protect the health and safety of the public.

Under Section 6.4, "Functional Responsibilities," of the PDEP, please respond to the following:

a. Historically, the NRC staff has generally approved a range of ERO augmentation times of 1 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Provide further justification why a 4-hour ERO augmentation time is acceptable, in the event of a catastrophic loss of SFP water inventory, to successfully implement required mitigation actions, and, if necessary, for offsite response organizations to implement early protective measures.

Response

Initiation of required mitigation actions is performed by the on-shift staff without a need for ERO augmentation.

As discussed in the response to NRC Question 19 above, DEK has revised the proposed PDEP to specify a two-hour ERO augmentation time rather than a four-hour ERO augmentation time. The analysis described in the response to NRC Question 19 concludes that a two-hour augmentation time in the event of a catastrophic loss of spent fuel pool (SFP) water inventory is adequate to successfully implement required mitigation actions, and if necessary, for offsite response organizations to implement

Serial No.14-427 Attachment 1 Page 6 of 13 early protective measures. In addition, a radiation technologist has been added to the PDEP staffing table as an on-shift asset to enhance response capabilities for radiological monitoring.

The KPS PDEP has been revised accordingly (see PDEP Sections 6.2 and 6.4). The revised PDEP is provided as Enclosure 1 to this letter.

NRC Question KPS-RAI-21 Section 8.0, "Emergency Classification System," of the PDEP, states, in part, "Once indications are available to plant operators that an Emergency Action Level (EAL) has been met, the event is assessed and classified, and the corresponding emergency classification level is declared."

The proposed exemption to rule language is as follows:

B" june 20, 2012, nuc..a pewc. . rc..to. licensees shall establish and maintain the capability to assess, classify, and declare an emergency condition w"thIn 46 minuteo after the availability of indications to plant operators that an emergency action level has been exceeded and shall promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level. ...

The information provided in Section 8.0 does not appear to meet the intent of the regulations, as modified by the proposed exemption, to ensure the prompt declaration of an emergency condition. Please revise accordingly or provide further justification for retaining existing language.

Response

Section 8.0 of the PDEP has been revised to state the following: "Once indications are available to plant operators that an Emergency Action Level (EAL) has been met, the event is assessed and classified, and the corresponding emergency classification level is promptly declared as soon as possible, and within 30 minutes."

The revised PDEP is provided as Enclosure 1 to this letter.

Serial No.14-427 Attachment 1 Page 7 of 13 NRC Question KPS-RAI-22 Appendix E.IV.E.9.a, "Emergency Planning and Preparedness for Production and Utilization Facilities," to 10 CFR 50 requires that State/local and the NRC communication methods be tested monthly. Section 10.0, "Emergency Communications," of the KPS PDEP does not provide any information as to the testing requirements and frequency for the listed communications systems. Please clarify whether this information is provided in any other procedure, and if so, submit a copy for staff review.

Response

Section 10.0 of the PDEP has been revised to specify the testing requirements and frequency for State/local and NRC communication systems consistent with the requirements in 10 CFR 50, Appendix E.IV.E.9.a. The testing frequency for each communication system is specified in Table 10-1, "Communication Systems." The testing frequency "Frequent Use" in Table 10-1 indicates that the associated equipment is normally used at a sufficiently high regularity (e.g., multiple times each day), such that separate additional testing is not needed. Functionality of these communications systems is verified through normal (frequent) use.

For the Nuclear Accident Reporting System (NARS) and the ERO callout system, performance of the drill requirements specified in Section 18 of the PDEP satisfies the testing frequency (in lieu of performing a separate test) because the associated communication equipment is used sufficiently during the drill to verify its functionality.

The revised PDEP is provided as Enclosure 1 to this letter.

NRC Question KPS-RAI-23 Please provide additional detail in Section 12.0, "Emergency Equipment and Facilities,"

and Appendix A, "Emergency Equipment, Supplies and Reference Material," of the proposed KPS PDEP, consistent with information that supports NUREG-0654 evaluation criteria H.1 0 and H.11. For example, Appendix A does not list any emergency supplies or radiation protection equipment.

Response

Section 12.0 of the PDEP has been revised to address NUREG-0654 evaluation criteria H.10. This section specifies that emergency equipment and reference materials are inspected, inventoried, and operationally checked each calendar quarter and after each use. There are sufficient reserves of instruments/equipment to replace those which are removed from emergency kits for calibration or repair. Calibration of equipment is performed at intervals recommended by the supplier of the equipment.

Serial No.14-427 Attachment 1 Page 8 of 13 Appendix A of the PDEP has been revised to address NUREG-0654 evaluation criteria H.11. Additional detail regarding emergency supplies and radiation protection equipment was added to this appendix.

The revised PDEP is provided as Enclosure 1 to this letter.

NRC Question KPS-RAI-24 Section 14.0, "Protective Response," of the KPS PDEP states, in part, "Accountability of all personnel onsite should be accomplished within 60 minutes after the announcement and maintained thereafter." Please revise accordingly to reflect the 60-minutes time clock starting at event declaration or provide further justification for retaining existing language.

Response

Section 14.0 of the PDEP has been revised to reflect that the 60-minute time starts at event declaration.

The revised PDEP is provided as Enclosure 1 to this letter.

NRC Question KPS-RAI-25 Please clarify how Section 15.0, "Radiological Exposure," of the KPS PDEP addresses NUREG-0654 evaluation criteria K.3.a.

Response

NUREG-0654 Evaluation Criterion K.3.a states the following.

a. Each organization 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 organization shall make provisions for distribution of dosimeters, both self-reading and permanent record devices.

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

The PDEP has been enhanced to address NUREG-0654 Evaluation Criterion K.3.a (see PDEP Section 15.0) in response to the staffs question. In particular, the PDEP specifies the following:

"Emergency workers are issued permanent reading dosimeters (e.g.

thermoluminescent dosimeter (TLD)) as a means for recording exposure for

Serial No.14-427 Attachment 1 Page 9 of 13 permanent records prior to entering a radiologically controlled area. Additionally, personnel are issued electronic alarming dosimetry capable of measuring dose and dose rate on a real time basis. Emergency workers are instructed to read their dosimeters frequently. The dosimetry provides 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day capability to determine the dose received by each emergency worker.

Emergency worker dose records are maintained in accordance with Radiation Protection procedures."

The revised PDEP is provided as Enclosure 1 to this letter.

NRC Question KPS-RAI-26 Section 18.0, "Exercise and Drills," of the KPS PDEP does not differentiate between equipment checks and performance enhancing drills for communications. State and county governments require monthly testing as stated in Appendix E.IV.E.9.a, with an annual performance enhancing drill as stated in NUREG-0654.1 1.N.2.a. Please clarify if this information is provided in any other procedure, and if so, submit a copy for the NRC staffs review.

Response

Section 18.0 of the PDEP has been revised to clarify the difference between equipment checks (tests) and performance enhancing drills for communications. The equipment and proficiency drills listed in Section 18.0 are identified as being conducted for the purpose of training, developing, and maintaining the proficiency of emergency responders. Equipment and Proficiency drills may be performed as part of an exercise, a drill, or as an independent drill.

Additional clarifying information was added to Section 18.0 of the PDEP in the subsections titled "Communications Drills," "Augmentation Capability Assessment (ACA) Drills," and "Critique and Evaluation."

The response to NRC Question KPS-RAI-22 (above) provides additional information regarding communications (associated with Section 10.0 of the PDEP).

The revised PDEP is provided as Enclosure 1 to this letter.

NRC Question KPS-RAI-27 In several sections of the KPS PDEP, the expected level of detail needed to support review of the PDEP seems to have been placed within the associated implementing procedure. Please submit, for the NRC staffs review, the following procedures listed in Appendix B, "Cross Reference Table - PDEP Section to Planning Standards/

Serial No.14-427 Attachment 1 Page 10 of 13 Requirements/Criteria to Procedures," of the KPS PDEP, or consider adopting the appropriate information from these procedures (consistent with the criteria from the attached draft emergency plan review guide) into the PDEP, thus removing the need to review these procedures:

" EP-KW-EIP-001,

• EP-KW-EIP-003,

• EP-KW-3001,

• EP-KW-EMP-009-002,

" EP-KW-EIP-005,

• EP-KW-400, and

• TR-KW-TPG-2400.

Response

The appropriate information from the above procedures has been adopted (consistent with the criteria from the draft emergency plan review guide attached to the RAI) into the PDEP, eliminating the need for the NRC staff to review these procedures.

A summary of information that has been adopted into the PDEP from the above listed procedures follows (listed by PDEP section number).

Please note that instructions regarding the performance of drills and exercises have been relocated from procedure EP-KW-400, "Drill and Exercise Program," to procedure EP-KW-3001, "Cyclic and Prompted Emergency Preparedness Tasks." As a result, Procedure EP-KW-400 was subsequently deleted and this procedure is no longer listed in the PDEP Appendix B Cross-Reference Table.

PDEP Section 5 The listed offsite response organizations are capable of 24-hour emergency response.

PDEP Section 7 Letters of agreement for each offsite response agency are maintained on file at KPS.

The Emergency Director is authorized to request Federal assistance as needed.

The Nuclear Regulatory Commission (NRC) will act as the lead Federal agency providing coordination and support in response to a nuclear incident. As requested, office space, telephone service and station liaison will be designated to assist NRC personnel during the emergency.

Serial No.14-427 Attachment 1 Page 11 of 13 PDEP Section 9 Notification to the State and county agencies will include a means of message verification.

Follow-up messages will be communicated to the offsite agencies based upon changing plant conditions or as requested. The follow-up message will contain the following information as available:

• Identification of station.

• Identification of caller.

" Date / time of incident.

• Emergency Classification.

" Radioactive release status.

• Emergency response action.

• Request for any support needed by offsite agencies.

• Prognosis for worsening or termination of event based upon plant information.

PDEP Section 10 Communication systems provide 24-hour onsite and offsite communication capability.

PDEP Section 12 Communication systems are identified in Section 10.

PDEP Section 14 Non-ERO personnel, supplemental personnel, and visitors located outside of the Protected Area (PA) but within the Site Boundary will be directed to report to an assembly area or exit the site as appropriate.

PDEP Section 18 Equipment and Proficiency Drills are conducted for the purpose of training, developing, and maintaining the proficiency of emergency responders. Equipment and proficiency drills may be performed as part of an exercise, a drill or as an independent drill.

Critiques will evaluate the performance of the organization. The ability of emergency response personnel to self-evaluate weaknesses and identify areas for improvement is the key to successful exercise / drill conduct.

Exercise and drill performance objectives are evaluated against measurable demonstration criteria. As soon as possible following the conclusion of each exercise or drill, a critique, including participants and evaluators, is conducted to evaluate the ability of the ERO to implement the PDEP and associated procedures. Deficiencies as a

Serial No.14-427 Attachment 1 Page 12 of 13 result of exercises or drills are identified and entered into the KPS corrective action system.

A written report is prepared following an exercise or drill involving the evaluation of designated objectives. The report evaluates and documents the ability of the ERO to respond to a simulated emergency situation. The report will also contain reference to corrective action and recommendations resulting from the exercise or drill.

PDEP Section 19 Additional training subjects for Emergency Directors, Technical Directors and Radiation Protection Directors to be covered on an annual basis include:

• Emergency exposure control.

• Mitigating strategies required for a catastrophic loss of spent fuel pool inventory.

Security personnel are trained in accordance with Security Program training requirements including ERO notification and accountability procedures.

Fire brigade personnel are trained in accordance with the Fire Protection Program Plan, including mitigating strategies required for a catastrophic loss of spent fuel pool inventory.

Additional training provided to all personnel who are badged for unescorted access plant access training:

• ERO and responsibilities.

• Emergency classification levels.

" Call out of personnel during an emergency.

PDEP Section 20 Executive management position responsibility includes overall authority for emergency response planning.

Exercises require an evaluation and written critique.

The Emergency Telephone Directory will contain names and telephone numbers of ERO and supporting agencies.

Serial No.14-427 Attachment 1 Page 13 of 13 References

1. Letter from Mark D. Sartain (DEK) to NRC Document Control Desk, "License Amendment Request 257, Permanently Defueled Emergency Plan and Emergency Action Level Scheme," dated January 16, 2014 [ADAMS Accession No.

ML14029A076]

2. Letter from Mark D. Sartain (DEK) to NRC Document Control Desk, "Supplement 1 and Response to Request for Additional Information Regarding License Amendment Request 257, Permanently Defueled Emergency Plan and Emergency Action Level Scheme," dated June 19, 2014 ADAMS Accession No. ML14178A167]

3. Letter from Thomas J. Wengert (NRC) to David A. Heacock (DEK), "Kewaunee Power Station - Request for Additional Information Concerning License Amendment Request for Emergency Plan Changes (TAC No. MF341 1)," dated August 14, 2014.

[ADAMS Accession No. ML4115A041]

4. Letter from Mark D. Sartain (DEK) to NRC Document Control Desk, "Supplement 4 and Response to Request for Additional Information Regarding License Amendment Request 256, Permanently Defueled License and Technical Specifications," dated April 29, 2014 [ADAMS Accession No. ML14126A005]

5. Letter from A. J. Jordan (DEK) to NRC Document Control Desk, "Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E," dated July 31, 2013 [ADAMS Accession No. ML13221A182]

Serial No.14-427 ATTACHMENT 2 LICENSE AMENDMENT REQUEST 257 PERMANENTLY DEFUELED EMERGENCY PLAN AND EMERGENCY ACTION LEVEL SCHEME SUPPLEMENT 2:

DISCUSSION OF CHANGE AND TECHNICAL ANALYSIS KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No.14-427 Attachment 2 Page 1 of 4 SUPPLEMENT 2 LICENSE AMENDMENT REQUEST 257 PERMANENTLY DEFUELED EMERGENCY PLAN AND EMERGENCY ACTION LEVEL SCHEME DISCUSSION OF CHANGE AND TECHNICAL ANALYSIS 1.0

SUMMARY

DESCRIPTION By application dated January 16, 2014 (Reference 1), Dominion Energy Kewaunee, Inc.

(DEK) requested an amendment to Facility Operating License Number DPR-43 for Kewaunee Power Station (KPS). The proposed amendment would revise the radiological emergency response plan and associated emergency action level (EAL) scheme. The proposed changes were submitted to the NRC for approval prior to implementation, as required under 10 CFR 50.54(q)(4) and 10 CFR 50, Appendix E, Section IV.B.2. The application was supplemented on June 19, 2014 (Reference 2).

In response to an NRC staff request for additional information (Reference 3) regarding content and level of detail of the proposed Permanently Defueled Emergency Plan (PDEP), DEK is revising the amendment request. The revisions contained in this supplement add detail to the PDEP as discussed in the response to the NRC staffs request for additional information.

A discussion of changes and technical analysis for this supplement is provided below. to this letter provides the proposed PDEP which incorporates the revisions contained in this supplement.

The EAL scheme and the comparison matrix that was provided in Reference 1, as well as the EAL basis document provided in Reference 2, remain unchanged and are applicable to this supplement. The analyses provided in Reference 1 remain applicable and bounding to this proposed change. The conclusions of the no significant hazards consideration and the environmental considerations contained in Reference 1 are not affected by, and also remain applicable to, this supplement.

2.0 PROPOSED CHANGE

This supplement to the proposed amendment would modify the KPS license with additional changes to the proposed PDEP as discussed in the response to the NRC staff's request for additional information in Reference 3. These additional changes consist of enhancements to the level of detail of the PDEP.

Serial No.14-427 Attachment 2 Page 2 of 4 The revised PDEP is provided in Enclosure 1 and replaces the previously submitted PDEP in its entirety. The EAL scheme that was provided in the original submittal (as to Reference 1), as well as the EAL basis document provided in Reference 2, remain unchanged.

3.0 TECHNICAL ANALYSIS

The technical analyses provided in the originally submitted LAR 257 remain applicable to, and unaltered by, this supplement. to this submittal provides a revised version of the originally proposed Kewaunee Power Station (KPS) Permanently Defueled Emergency Plan (PDEP) for NRC review and approval. The revised PDEP addresses the applicable regulations stipulated in 10 CFR 50.47, "Emergency Plans," and 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," and is consistent with the applicable guidelines established in NUREG-0654/FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants." The changes made to the PDEP in this supplement are either more restrictive from those that were originally proposed, clarifications, or editorial. As such, they are bounded by the technical analyses provided in the originally submitted LAR 257.

The KPS Permanently Defueled Emergency Action Level (PDEAL) scheme previously provided for NRC review and approval as Enclosure 2 to Reference 1, including its accompanying comparison matrix (between each generic EAL contained in NEI 99-01, Revision 6 (Reference 4) and the proposed KPS specific PDEAL), is unaltered by this supplement. As stated in the original submittal, the proposed EALs are only applicable to the permanently defueled station condition, with all reactor fuel permanently removed from reactor vessel.

The technical basis document for each recognition category in the proposed EAL scheme, previously provided for NRC review and approval as Enclosure 2 to Reference 2, is also unaltered by this supplement.

4.0

SUMMARY

The proposed amendment (as supplemented) would revise both the PDEP and the emergency action level (EAL) scheme (including its basis document) to reflect the permanently defueled condition of the station. The revised PDEP and EAL scheme (including its basis document) are being submitted to the NRC for approval prior to implementation, as required under Section IV.B.2 of Appendix E to 10 CFR Part 50 and 10 CFR 50.54(q)(4).

Serial No.14-427 Attachment 2 Page 3 of 4 The proposed PDEP does not meet all standards of 10 CFR 50.47(b) and requirements of 10 CFR 50, Appendix E. However, DEK previously submitted requests for exemptions from portions of 10 CFR 50.47(b), 10 CFR 50.47(c)(2), and 10 CFR 50, Appendix E, Section IV, by letter dated July 31, 2013 (Reference 5) that the proposed emergency plan would not meet. The proposed PDEP (as modified by this supplement) continues to be predicated on the approval of these exemption requests. Upon approval of the requested exemptions, the PDEP, as revised, will continue to meet the remaining applicable requirements in 10 CFR 50, Appendix E and the planning standards of § 50.47(b).

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration The conclusions of the no significant hazards consideration contained in Reference 1 are not affected by, and remain applicable to, this supplement.

5.2 Applicable Regulatory Requirements/Criteria The applicable regulatory requirements/criteria contained in Reference 1 are not affected by, and remain applicable to, this supplement.

6.0 ENVIRONMENTAL CONSIDERATION

The conclusions of the environmental considerations contained in Reference 1 are not affected by, and remain applicable to, this supplement.

7.0 REFERENCES

1. Letter from Mark D. Sartain (DEK) to NRC Document Control Desk, "License Amendment Request 257, Permanently Defueled Emergency Plan and Emergency Action Level Scheme," dated January 16, 2014. [ADAMS Accession No. ML14029A076]

2. Letter from Mark D. Sartain (DEK) to NRC Document Control Desk, "Supplement 1 and Response to Request for Additional Information Regarding License Amendment Request 257, Permanently Defueled Emergency Plan and Emergency Action Level Scheme," dated June 19, 2014. [ADAMS Accession No. ML14178A167]

Serial No.14-427 Attachment 2 Page 4 of 4

3. Letter from Thomas J. Wengert (NRC) to David A. Heacock (DEK), "Kewaunee Power Station - Request for Additional Information Concerning License Amendment Request for Emergency Plan Changes (TAC No. MF3411)," dated August 14, 2014. [ADAMS Accession No. ML14115A041]

4. Nuclear Energy Institute (NEI) 99-01, Revision 6, "Methodology for Development of Emergency Action Levels for Non Passive Reactors," November 2012.

[ADAMS Accession No. ML12326A805]

5. Letter from A. J. Jordan (DEK) to NRC Document Control Desk, "Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E," dated July 31, 2013. [ADAMS Accession No. ML13221A182]

6. NUREG-1738, "Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants," February 2001.

7. U.S. Environmental Protection Agency, "Protective Action Guide and Planning Guidance for Radiological Incidents," Draft for Interim Use and Public Comment, dated March 2013 (PAG Manual).

Serial No.14-427 ENCLOSURE 1 LICENSE AMENDMENT REQUEST 257 PERMANENTLY DEFUELED EMERGENCY PLAN AND EMERGENCY ACTION LEVEL SCHEME SUPPLEMENT 2 PERMANENTLY DEFUELED EMERGENCY PLAN KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

WDominionw Permanently Defueled Emergency Plan (PDEP)

Revision Number Effective Date 0 DRAFT I TBD Revision Summary:

Permanently Defueled Emergency Plan (PDEP) describes the station's plan for responding to emergencies that may arise at Kewaunee Power Station while in a permanently shutdown and defueled configuration.

Table of Contents Section Title Page 1.0 Introduction 1 1.1 Purpose 1.2 Scope 2.0 Discussion 2 2.1 Overview of Permanently Defueled Emergency Plan (PDEP) 2.2 Facility Description 3.0 Definitions and Acronyms 3 4.0 References 6 5.0 Assignment of Responsibility 7 5.1 Kewaunee Power Station Emergency Response and Responsibilities 5.2 Offsite Response Organizations (ORO) 6.0 Onsite Emergency Organizations 8 6.1 On-Shift Positions 6.2 ERO Augmented Positions 6.3 Augmentation of Emergency Response Organization 6.4 Functional Responsibilities 7.0 Emergency Response Support and Resources 13 8.0 Emergency Classification System 13 9.0 Notification Methods and Procedures 14 10.0 Emergency Communications 16 11.0 Public Information 16 12.0 Emergency Equipment and Facilities 16 12.1 Emergency Response Facilities 12.2 Emergency Equipment 13.0 Accident Assessment 18 14.0 Protective Response 19 15.0 Radiological Exposure 19 16.0 Medical and Health Support 21 17.0 Plant Recovery 21 18.0 Exercise and Drills 22 19.0 Radiological Emergency Response Training 24 19.1 Emergency Response Personnel Training 19.2 Non-KPS Emergency Response Support Organizations 20.0 Maintaining Emergency Preparedness 25 20.1 Emergency Preparedness Responsibilities 20.2 Review and Updating of the PDEP 20.3 Maintenance and Inventory of Emergency Equipment and Supplies Appendix Emergency Equipment, Supplies and Reference Materials 28 A

Appendix Cross Reference Table B-1 29 B PDEP Section to Planning Standards/Requirements/Criteria to Procedures ii

List of Tables Section Table Title Page 6 6-1 Emergency Response Organization Staffing 11 10 10-1 Communication Systems 16 15 15-1 Response Worker Guidelines 20 Appendix B-1 PDEP Section to Planning Standards/Requirements/Criteria to B Procedures 29 List of Figures Section Figure Title Page 6 6-1 On-Shift and Emergency Response Organization Positions 12 iii

1.0 INTRODUCTION

The Permanently Defueled Emergency Plan (PDEP) describes the station's plan for responding to emergencies that may arise at Kewaunee Power Station (KPS) while in a permanently shutdown and defueled configuration. Irradiated fuel is stored in the Independent Spent Fuel Storage Installation (ISFSI) and in the Spent Fuel Pool. In this condition, no reactor operations can take place and the station is prohibited from moving the fuel from the Spent Fuel Pool to the reactor vessel. This PDEP adequately addresses the risks associated with KPS's current conditions.

The analyses of the potential radiological impacts of postulated accidents in a permanently defueled condition indicates that any releases beyond the Site Boundary would be below the Environmental Protection Agency (EPA) Protective Action Guide (PAG) exposure levels, as detailed in the EPA's "Protective Action Guide and Planning Guidance for Radiological Incidents," Draft for Interim Use and Public Comment dated March 2013 (PAG Manual).

Exposure levels, which warrant pre-planned response measures, are limited to onsite areas.

1.1 PURPOSE The purpose of the PDEP is to assure an adequate level of preparedness to cope with the spectrum of emergencies that could be postulated to occur, including means to minimize radiation exposure to plant personnel. This plan integrates the necessary elements to provide effective emergency response considering cooperation and coordination of organizations expected to respond to potential emergencies.

1.2 SCOPE The PDEP has been developed to respond to potential radiological emergencies at KPS considering the permanently shutdown and defueled status of the plant. Because there are no postulated accidents that would result in offsite dose consequences that are large enough to require offsite emergency planning, the overall scope of this plan delineates the actions necessary to safeguard onsite personnel and minimize damage to property.

The concepts presented in this plan address the applicable regulations stipulated in 10 CFR 50.47, "Emergency Plans," and 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities." The plan is consistent with the applicable guidelines established in NUREG-0654/FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants."

Exemption from selected portions of 10 CFR 50.47 and 10 CFR 50 Appendix E for Kewaunee Power Station were granted by the Nuclear Regulatory Commission (NRC) per XXX.

The PDEP revision 0 was approved for use by the NRC per Safety Evaluation Report (SER)

XXX.

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2.0 DISCUSSION 2.1 OVERVIEW OF PERMANENTLY DEFUELED EMERGENCY PLAN (PDEP)

In the event of an emergency at the plant, actions are required to identify and assess the nature of the emergency and to bring it under control in a manner that protects the health and safety of plant personnel.

This plan is activated by the Shift Manager/Emergency Director (ED) upon identification of an emergency situation based upon the Emergency Action Level criteria. The emergency measures described in the subsequent sections and implementing procedures are implemented in accordance with the classification and nature of the emergency at the direction of the ED.

This Plan describes the organization and responsibilities for implementing emergency measures. It describes interfaces with Federal, State of Wisconsin, and Kewaunee County organizations which may be notified in the event of an emergency, and may provide assistance. Fire, ambulance, and law enforcement services are provided by local public entities. Medical services are provided by Aurora Medical Center in Two Rivers, Wisconsin.

Because there are no postulated accidents that would result in offsite dose consequences that are large enough to require offsite emergency planning, emergencies are divided into two classifications: 1) Notification of Unusual Event (Unusual Event) and 2) Alert.

KPS is responsible for planning and implementing emergency measures within the Site Boundary. This plan is provided to meet this responsibility. To carry out specific emergency measures discussed in this Plan, detailed implementing procedures are established and maintained.

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

2.2 FACILITY DESCRIPTION The Kewaunee Power Station has ceased power operations and is permanently defueled. On May 14, 2013, the station certified permanent removal of fuel from the reactor vessel in accordance with 10 CFR 50.82(a)(1)(i) and (ii). The 10 CFR 50 license for KPS no longer authorizes operation of the reactor, and emplacement or retention of fuel into the reactor vessel, as specified in 10 CFR 50.82(a)(2).

The plant consists of a single unit Westinghouse Electric Corporation Pressurized Water Reactor. The reactor design core power was 1,772 megawatts thermal and gross plant electrical output was approximately 600 megawatts electric. An Independent Spent Fuel Storage Installation (ISFSI) is located on the plant site.

The plant is located in the town of Carlton, Kewaunee County, along the west shore of Lake Michigan in east central Wisconsin. The topography of the region is gently rolling to flat, with elevations varying from 10 to 100 feet above the level of Lake Michigan. The land surrounding the site slopes gradually east towards Lake Michigan from the higher elevations in the west.

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At the northern and southern perimeters of the site, bluffs form the boundary between the plant site and Lake Michigan.

3.0 DEFINITIONS and ACRONYMS This section provides definitions and acronyms that are used in this document. Terms capitalized in the text of the definitions indicate that they are defined elsewhere in this section.

Alert - Events are in progress 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 HOSTILE ACTION.

Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

Annual - Frequency of occurrence is met if performed within 1.25 times a 12 month interval as measured from the previous performance. This definition does not apply to the term "annual" when it relates to the conduct of the Emergency Preparedness Exercise and off-year Drill. The Exercise and off-year Drill are performed within the calendar year.

Accountability - Discretionary protective action taken for all persons onsite (within PROTECTED AREA) that involves the gathering of personnel into pre-designated areas and subsequent verification that the location of all personnel is known.

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

Control Room - The Control Room contains the indications, controls, and communication equipment necessary for both normal and emergency conditions. It is operated under the direction of the Shift Manager/Emergency Director and serves as the primary location for Classification of the incident, Notification of incident to offsite agencies, ASSESSMENT ACTIONS, and CORRECTIVE ACTION direction.

Corrective Action - Those emergency measures taken to mitigate or terminate an emergency situation at or near the source of the problem in order to prevent an uncontrolled release of radioactive material or to reduce the magnitude of a release (e.g., equipment shutdown, fire fighting, equipment repair, and damage control).

Design Basis Accident (DBA) - A hypothetical accident assuming a fission product release based upon a major accident at the plant. The hazards that could potentially occur from this postulated accident would not exceed those resulting from any credible accident described in the Updated Safety Analysis Report.

Emergency Action Levels (EALs) - A pre-determined, site-specific, observable threshold for a plant INITIATING CONDITION (IC) that places the plant in a given emergency class.

Emergency Plan Implementing Procedures - Specific procedures describing actions needed to implement the PDEP.

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Emergency Plan Maintenance Procedures - Specific procedures describing the methods established to maintain and monitor the PDEP.

Emergency Response Organization (ERO) - Individuals who have been assigned an emergency response position within the PDEP.

Hostile Action - An act toward the plant or its personnel that includes the use of violent force to destroy equipment, take hostages, and intimidate to achieve an end. This includes, but is not necessarily limited to, attack by air, land or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. Acts of civil disobedience or felonious acts that are not part of a concerted attack on the plant (e.g., violent acts between individuals in the owner controlled area) do not meet this definition.

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

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

Monthly - Frequency of occurrence is met if performed within 1.25 times a 31 day interval as measured from the previous performance.

Personnel Monitoring Equipment - Radiation exposure measuring devices designed to be worn or carried by an individual for the purpose of measuring the radiation dose received (e.g.,

direct reading dosimeters, and TLDs).

Projected Dose - An estimate of the radiation dose, which affected individuals could potentially receive if PROTECTIVE ACTIONS are not taken.

Protected Area (PA) - That area within the perimeter of the Kewaunee Power Station security fence.

Protective Actions - Those measures taken in anticipation of or after an inadvertent release of radioactive material for the purpose of preventing or minimizing radiological exposures to onsite personnel.

Quarterly - Frequency of occurrence is met if performed within 1.25 times a 92 day interval as measured from the previous performance.

Radioactive Release - Any radioactive material beyond pre-emergency levels and not attributable to normal plant operations, either detected or suspected of migrating beyond the protected area, while in a declared emergency, shall be communicated to the State and county governments as a radioactive release.

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

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Site Boundary - The perimeter of the land owned by Dominion Energy Kewaunee Inc.

surrounding the plant.

Site Relocation Facility (SRF) - A facility located approximately 3 miles northwest of the Plant.

When needed, this facility may be used as a near site relocation and staging area for personnel entering or exiting the site.

Unusual Event (UE) - 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.

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4.0 REFERENCES

• 10 CFR 50.47, "Emergency Plans"

• 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities"

• 10 CFR 72.32, "Emergency Plans"

• 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)

• Updated Safety Analysis Report

• Technical Specifications

• Emergency Preparedness Procedures

• Offsite Dose Calculation Manual (ODCM)

• NEI 99-01, Rev. 6, "Development of Emergency Action Levels for Non-Passive Reactors"

• EPA's "Protective Action Guide and Planning Guidance for Radiological Incidents," Draft for Interim Use and Public Comment dated March 2013

• NRC Regulatory Guide 1.23, "Meteorological Monitoring Programs for Nuclear Power Plants",

Revision 1 dated March 2007

• XXX, Exemption from Selected Portions of 10CFR50.47 and Appendix E, dated xxx

• SER XXX, NRC Approval of PDEP, Revision 0, dated xxx 6

5.0 ASSIGNMENT OF RESPONSIBILITY Primary responsibilities for emergency response by Kewaunee Power Station and by State and local organizations 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.

5.1 Kewaunee Power Station Emergency Response and Responsibilities The Shift Manager is at the station 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day and is the senior management position at the station during off-hours. This position is responsible for monitoring conditions and approving all onsite activities.

When an abnormal situation becomes apparent, the Shift Manager shall assume the position of Emergency Director (ED) once the emergency classification has been made.

The following functions are within the Emergency Director's realm of responsibilities:

• Control of operation of station activities.

• Mitigation of the emergency condition.

• Protection of station personnel.

• Emergency event classification.

• Emergency notification to Federal, State and local government agencies.

• Coordination of emergency support for fire fighting, security and rescue / first aid.

The on-shift staff positions are available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day. The Emergency Response Organization (ERO) will be activated and augment the on-shift staff during an ALERT classification or at the direction of the Emergency Director. The on-shift staff can perform all required response actions until the ERO arrives.

5.2 Offsite Response Organizations (ORO)

Offsite response organization (Fire, Ambulance and local law enforcement agency (LLEA))

response is at the request and direction of the Emergency Director. The Emergency Director coordinates the offsite response organizations' response, plant access and radiological controls with the onsite activities. The ORO's listed below are capable of 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> emergency response.

State and local government agency response will be in accordance with each agency's plans and procedures, and commensurate with the hazard posed by the emergency. Letters of Agreement are in place for those local agencies that will respond to the site, and for the hospital that will treat a contaminated injured individual from the site.

City of Kewaunee Fire Department Arrangements have been made with the City of Kewaunee Fire Department to provide primary assistance to the Plant Fire Brigade. The City of Kewaunee Fire Department is a volunteer department located about 10 miles north of the plant, which allows for a timely response from the initial notification.

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City of Kewaunee Ambulance Arrangements have been made with the City of Kewaunee for ambulance services. The agreement includes a commitment for medical transportation of all radiation injuries and injuries complicated with radioactive contamination.

Aurora Medical Center Arrangements have been made for medical services with the Aurora Medical Center, located approximately 14 miles south of the Kewaunee Power Station. The agreement includes a commitment by the hospital to accept and treat plant personnel with routine industrial injuries as well as injuries complicated by radioactive contamination or radiation exposure. The Aurora Medical Center maintains the capability and facilities to provide decontamination, first aid, and emergency stabilization medical treatment to injured personnel. These services and facilities are available 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day.

Kewaunee County Sheriff's Department An agreement is maintained with the Kewaunee County Sheriff's Department to provide emergency assistance per the Security Plan.

6.0 ONSITE EMERGENCY ORGANIZATION On-shift facility licensee responsibilities for emergency response are 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.

This section of the plan describes the overall emergency organization that would be used during emergency situations at the plant.

6.1 ON-SHIFT POSITIONS KPS has personnel on-shift at all times that provide the initial response to an event. Members of the on-shift organization are trained on their responsibilities and duties in the event of an emergency and are capable of performing all necessary response actions until the augmenting ERO arrives or the event is terminated. The on-shift staffing assignments include the roles and responsibilities for their emergency response functions. The relationship between normal and emergency response positions for the shift personnel is unchanged when an event occurs.

SHIFT MANAGER/EMERGENCY DIRECTOR The Shift Manager is at the station 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day and is the senior management position at the station during off-hours. This position is responsible for monitoring conditions and approving all onsite activities.

When an abnormal situation becomes apparent, the Shift Manager shall assume the position of Emergency Director (ED) once the emergency classification has been made.

The Emergency Director assumes overall Command and Control of a classified event. The Emergency Director cannot delegate the following responsibilities:

" Classification of event.

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

8

Other responsibilities assumed by the Emergency Director include:

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

• Management of available station resources.

• Initiation of mitigative actions.

" Initiation of corrective actions.

" Initiation of onsite protective actions.

" Decision to call for offsite police, fire or ambulance assistance.

" Augmentation of the emergency staff, as deemed necessary.

" Coordination of Security activities.

" Performance of initial Dose Assessment.

" Maintaining a record of event activities.

" Termination of the emergency condition when appropriate.

PLANT OPERATOR Plant Operator performs system and component manipulations to support plant repairs and corrective actions. The organizational relationship to the Shift Manager/Emergency Director is the same during normal situations and during situations where the PDEP has been implemented.

RADIATION TECHNOLOGIST When an event is classified and the PDEP is implemented, the Radiation Technologist reports to the Emergency Director to provide support for radiological accident assessment and protective actions. Support activities while implementing the PDEP include:

" Access control

" Radiological coverage (e.g., monitoring, surveys, and support) for repair, corrective actions, search and rescue, first aid, and firefighting

• Personnel monitoring and dosimetry

" Dose assessment, as requested by ED or RPD SECURITY Station Security is administered by the Security Plan. The Security force will report to the Emergency Director when implementing the PDEP. During non-security events, Security will activate the station ERO callout system and perform accountability at the direction of the Emergency Director.

6.2 ERO AUGMENTED POSITIONS The Emergency Response Organization (ERO) augments the on-shift station organization to respond to declared emergencies when activated. Personnel are trained and assigned to the ERO based on either their normal job qualifications or by being specifically trained to fill a position.

The ERO is activated when an Alert is declared or at the discretion of the Emergency Director for an Unusual Event. The on-shift staff is supplemented by station personnel who report to the Emergency Director after being notified. The Emergency Director is responsible for ensuring that the ERO callout system is initiated to augment the on-shift staff.

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The minimum augmented staff is a Radiation Protection Director and a Technical Director. The Shift Manager assumes the responsibilities of the Emergency Director. The Radiation Protection Director and Technical Director will augment the on-shift station organization within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of an Alert classification.

Augmenting the ERO is accomplished by the assignment of specific personnel to assist the ERO as needed.

TECHNICAL DIRECTOR The Technical Director reports to the Emergency Director. The responsibilities of the Technical Director when implementing the PDEP include:

• Evaluation of technical data pertinent to plant conditions.

" Augmentation of the emergency staff as deemed necessary.

" Recommend mitigative and corrective actions.

• Direction of search and rescue.

• Coordination of maintenance and equipment restoration.

• Establishing and maintaining communications as desired by the Emergency Director.

• Maintaining a record of event activities.

RADIATION PROTECTION DIRECTOR The Radiation Protection Director reports to the Emergency Director. The responsibilities of the Radiation Protection Director when implementing the PDEP include:

" Monitoring of personnel accumulated dose.

" Advising the Emergency Director concerning Radiological EALs.

" Augmentation of the emergency staff as deemed necessary.

• Directing of radiological monitoring, analysis, and controls.

" Dose Assessment.

• Establishing and maintaining communications as desired by the Emergency Director

" Maintaining a record of event activities.

6.3 AUGMENTATION OF EMERGENCY RESPONSE ORGANIZATION In the event of an emergency at KPS that requires personnel and other support resources beyond those available within the KPS ERO, augmentation is available from other KPS staff and Dominion facilities, and can be requested from various contractors. Additional support to KPS is available from offsite organizations, as previously discussed in Section 5.0 of this Plan.

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6.4 FUNCTIONAL RESPONSIBILITIES Table 6-1 below lists the functional responsibilities of on-shift and augmented positions that fulfill emergency staffing capabilities.

TABLE 6-1 Emergency Response Organization Staffing AUGMENTED STAFF FUNCTIONAL AREA LOCATION ON-SHIFT STAFF 2UR SPONS 2 HOUR RESPONSE Plant Operations and Assessment of Operational Control Room Emergency Director ---

Aspects Emergency Direction and Control Room Emergency Director ---

Control Notifications Commuications/

Communications Control Room Emergency Director Technical Director Radiological Accident Assessment and Control Room / Emergency Director Protective Actions On Scene Radiation Technologist (In-Plant)

Plant System Engineering, Control Room / Emergency Director Technical Director Repair and Corrective On Scene Plant Operator****

Actions Fire Fighting On Scene Per Fire Protection Program Offsite Response Plan* Organization*

Rescue and First Aid On Scene ** Offsite Response Treatment Organization*

Site Access Control and Security Station Per Security Plan Accountability SeuitttinPreurtla_-

• Fire Brigade composed of Plant Operator, Security personnel, or other qualified personnel. Fire Brigade personnel may be assigned other Emergency Plan functions (e.g. rescue and first aid treatment, repair, and corrective actions).

• • Provided by on-shift personnel who may be assigned other functions (e.g. Fire Brigade personnel or Radiation Technologist).

Response time is based upon Fire Protection Program Plan (fire fighting) or response capability of offsite organization (e.g., ambulance).

Fire Brigade members (3 personnel) are utilized to perform mitigating strategies required for a catastrophic loss of spent fuel pool inventory.

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FIGURE 6-1 On-Shift and Emergency Response Organization Positions Shift Manager /

Emergency Director Security Plant Radiation Force Operator Technologist ERO Augmented Positions

• II

• Ii Technical Radiation Director Protection Director

-- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -

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7.0 EMERGENCY RESPONSE SUPPORT AND RESOURCES Arrangements for requesting and effectively using assistance resources have been made and other organizations capable of augmenting the planned response have been identified. Letters of Agreement are in place for those local agencies (Fire, Ambulance and Local Law Enforcement) that will respond to the site, and for the hospital that will treat a contaminated injured individual from the site. Letters of Agreement for each agency are maintained on file at KPS.

Fire, Ambulance and LLEA response is at the request and direction of the Emergency Director as previously discussed in Section 5.2 of this Plan.

The Emergency Director is authorized to request Federal assistance as needed. The Nuclear Regulatory Commission (NRC) will act as the lead Federal agency providing coordination and support in response to a nuclear incident. As requested, office space, telephone service and station liaison will be designated to assist NRC personnel during the emergency.

8.0 EMERGENCY CLASSIFICATION SYSTEM A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use. This section describes KPS emergency classifications, initiating events, emergency action levels, and postulated emergency situations.

EMERGENCY CLASSIFICATION SYSTEM The emergency classification system covers an entire spectrum of possible radiological and non-radiological emergencies at the Kewaunee Power Station. The emergency classification system categorizes accidents and/or emergency situations into one of two emergency classification levels depending on emergency conditions at the time of the incident. The emergency classification levels applicable at Kewaunee Power Station, in order of increasing severity, are Unusual Event and Alert. Each of these emergency classes requires notification to the station's ERO, State and county agencies, as well as the NRC.

The emergency classification system is based on NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors".

Once indications are available to plant operators that an Emergency Action Level (EAL) has been met, the event is assessed and classified, and the corresponding emergency classification level is promptly declared as soon as possible, and within 30 minutes.

Notification to the State and county offsite authorities and the NRC is required within 60 minutes of the event being declared.

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

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The following subsections outline the plant actions at each classification level. Refer to Permanently Defueled Emergency Action Level Technical Bases for actual parameter values, annunciators, and equipment status used by emergency response personnel to classify emergencies.

Actions associated with an Unusual Event:

" Bring the Emergency Response Organization (ERO) to a state of readiness.

" Notify Federal, State, and county government authorities.

" Initiate the systematic handling of information and decision making.

" Augment shift personnel, if needed.

The Unusual Event status will be maintained until an escalation in emergency class occurs or the event is terminated. Offsite authorities will be informed of the change in the emergency status and the necessary documentation will be completed as specified in the Emergency Plan Implementing Procedures.

Actions associated with an Alert:

" Activate the Emergency Response Organization (ERO).

" Notify Federal, State, and county government authorities.

" Initiate the systematic handling of information and decision making.

• Initiate immediate and follow-up notification(s) including current plant status information to offsite authorities.

The Alert status shall be maintained until termination of the event or de-escalation in emergency class occurs. The plant may enter recovery operation without de-escalating from a declared Alert. Offsite authorities will be informed of the change in the emergency status and the necessary documentation shall be completed as specified in the Emergency Plan Implementing Procedures.

SPECTRUM OF POSTULATED ACCIDENTS The Updated Safety Analysis Report Chapter 14 describes the postulated accidents applicable to Kewaunee Power Station. Methods for detecting and evaluating for emergency classification of these events include the use of installed systems, instrumentation, alarms, and approved procedures.

9.0 NOTIFICATION METHODS AND PROCEDURES Procedures have been established for notification, by the licensee, of State and local organizations and for notification of emergency personnel by all organizations; the content of initial and follow-up messages to response organizations has been established.

ERO Activation The ERO is activated by a plant announcement and by the ERO callout system directed by the Emergency Director.

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Nuclear Accident Reporting System (NARS)

NARS is a communication process used to notify the State and county agencies of a declared emergency. The NARS form contains information that identifies the station, emergency classification, Emergency Action Level (EAL), and radiological release status. Notification to the State and county agencies will be made within 60 minutes of event classification, and the process includes a means of message verification. Notification using NARS is the responsibility of the Emergency Director.

Based upon changing plant conditions or as requested, follow-up messages will be communicated to the offsite agencies. The follow-up message will contain the following information as available:

• Identification of station.

" Identification of caller.

• Date / time of incident.

" Emergency Classification.

" Radioactive release status.

• Emergency response action.

• Request for any needed support by offsite agencies.

• Prognosis for worsening or termination of event based upon plant information.

NRC Event Notification System (ENS)

The ENS is a dedicated telephone system used to notify the NRC Operations Center. The NRC will be notified as soon as possible after State/county notifications and within 60 minutes of event classification. In the event of failure of the ENS, commercial phone lines will be used to notify the NRC. Notification to the NRC is the responsibility of the Emergency Director.

Support Organizations Medical, local law enforcement agency (LLEA), and fire fighting support services are primarily notified for assistance via the public 911 process. Request for support services are the responsibility of the Emergency Director.

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10.0 EMERGENCY COMMUNICATIONS Provisions exist for prompt communications among principal response organizations to emergency personnel. The communication systems listed in Table 10-1 below provide 24-hour onsite and offsite communications capability. Communication systems are tested to verify proper operation at the testing frequency specified in the table below. Communication systems that are listed with a testing frequency of "Frequent Use" indicates that the associated equipment is normally used at a sufficiently high regularity (e.g., multiple times each day), such that separate additional testing is not needed. Functionality is verified through normal (frequent) use of the system.

TABLE 10-1 Communication Systems Communication System Testing Frequency PBX telephone system Frequent Use Commercial telephone system Monthly Plant public address system Frequent Use Portable radios Monthly Nuclear Accident Reporting System (NARS) Monthly*

ERO callout system Semi-annual*

NRC FTS Network (NRC Emergency Notification System (ENS)) Monthly

• Performance of drill requirements specified in Section 18 satisfies the testing frequency 11.0 PUBLIC INFORMATION Communications Department personnel will be notified of a declared emergency via the ERO callout system. Communications Department will monitor media activity and coordinate with senior management disseminating public information per communication protocols. As necessary, news conference(s) can be conducted on site or other coordinated location.

Communications Department personnel, or senior plant or corporate management will represent the station as the plant spokesperson.

12.0 EMERGENCY FACILITY AND EQUIPMENT Adequate emergency facilities and equipment to support the emergency response are provided and maintained. This section of the plan identifies and describes the emergency response facilities, the communication systems, the assessment facilities and equipment, the first aid and medical facilities, and protective equipment and supplies that can be utilized during an emergency.

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12.1 EMERGENCY RESPONSE FACILITIES Emergency Response Facilities (ERFs) are staffed in accordance with Section 6.0.

Control Room The Control Room is where plant systems and equipment parameters are monitored. The Control Room is the onsite center for emergency Command and Control. Control Room personnel assess plant conditions; evaluate the magnitude and potential consequences of abnormal conditions; initiate preventative, mitigating and corrective actions; and perform notifications. When activated, the ERO reports to the Control Room.

Site Relocation Facility The Site Relocation Facility (SRF) is located in the Carlton Township Hall, 1.6 miles North of KPS on Highway 42 and approximately 2 miles West on County Road G. The SRF functions as a staging area for augmentation of emergency response staff if the site is under threat of or experiencing Hostile Action. The SRF has telephone communication capability.

12.2 EMERGENCY EQUIPMENT This section describes the monitoring instruments and laboratory facilities used to initiate emergency measures and provide continuing assessment of conditions throughout the course of an emergency.

Specific emergency response equipment and reference materials located in the Control Room, Site Relocation Facility, and within the plant are listed in Appendix A, Emergency Equipment, Supplies and Reference Materials. The items listed in Appendix A are inspected, inventoried, and operationally checked each calendar quarter and after each use. There are sufficient reserves of instruments/equipment to replace those which are removed for calibration or repair. Equipment in these inventories is checked and calibrated in accordance with approved procedures.

Meteorological Equipment The meteorological equipment at the site consists of wind speed and direction transmitters, signal translators, and recorders. In addition, the temperature measurement consists of recorders and resistance temperature detectors (RTDs). RTDs on the primary tower are used to monitor ambient temperature and calculate differential temperature. Recorded ambient temperature comes from the ten (10) meter RTD. A RTD on the backup tower is available for monitoring ambient temperature.

Radiation Monitoring System The Radiation Monitoring System provides continuous radiological surveillance. The system performs the following basic functions:

• Warns personnel of potential radiological health hazards.

• Gives early warning of certain plant malfunctions which might lead to a radiological health hazard or plant damage.

• Prevents or minimizes the effects of inadvertent releases of radioactivity to the environment by consequence-limiting automatic responses.

" Provides routine monitoring of controlled offsite plant releases.

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The Radiation Monitoring System is divided into two sub-systems. The Process Radiation Monitoring System monitors various liquid and air streams for indication of radiation levels within those streams. The Area Radiation Monitoring System monitors radiation levels in various areas of the plant.

Portable Radiation and Contamination Monitoring Instruments Portable radiation and contamination monitoring instruments and sampling equipment normally utilized and maintained by the Radiation Protection group are available for emergency use.

Laboratory Facilities Facilities for analyzing radioactive samples are equipped with instruments that can detect alpha and beta radioactivity and the ability to perform radionuclide analysis.

Fire Detection and Suppression Equipment The fire protection system has been designed to detect and extinguish potential fires. The system is designed in accordance with the standards of the National Fire Protection Association (NFPA) and recommendations of the Nuclear Electric Insurance Limited (NEIL).

Fire detectors have been installed throughout the plant with alarms and indicators located in the Control Room.

Communication Systems Communication systems are identified and tested as described in Section 10.

Protective Equipment and Supplies Protective clothing and respiratory equipment are maintained for use by emergency in-plant teams.

13.0 ACCIDENT ASSESSMENT Adequate methods, systems, and equipment for assessing and monitoring actual or potential offsite consequences of a radiological emergency condition are in use.

The assessment activities required to evaluate a particular emergency depend on the specific nature and classification of the emergency. The EALs identify the system parameter and effluent parameter values which can be used to determine the emergency condition.

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

Onsite capabilities and resources are available to provide initial and continuing information for accident assessment throughout the course of an event.

Dose Assessment Implementing procedures utilize radiological instrumentation readings and meteorological data to provide a rapid method of determining the magnitude of a radioactive release during an accident condition. Dose Assessment is capable of being performed on a 24-hour per day basis. Initial dose assessment is the responsibility of the Emergency Director. Subsequent dose assessments are the responsibility of the Radiation Protection Director.

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14.0 PROTECTIVE RESPONSE Protective actions for onsite personnel are provided for their health and safety. Implementation guidelines for onsite protective actions are provided in Emergency Plan Implementing Procedures.

Additionally, the Emergency Plan Implementing Procedures provide for a range of protective actions (e.g. relocation of personnel and personnel take cover) to protect onsite personnel during hostile actions.

Accountability Accountability should be considered and used as a protective action whenever a site wide risk to health or safety exists and prudence dictates. If personnel accountability is required, at the direction of the Emergency Director all individuals at the site (including employees without emergency assignments, visitors and contractor personnel) shall be notified of an emergency over the public address system and by the sounding of the plant alarm. Accountability of all personnel onsite should be accomplished within 60 minutes after event declaration and maintained thereafter. If personnel are unaccounted for, teams shall be dispatched to locate the personnel.

Non-ERO personnel, supplemental personnel, and visitors located outside of the Protected Area (PA) but within the Site Boundary will be directed to report to an assembly area or exit the site as appropriate. The Emergency Director is responsible for controlling access to the station when the ERO is activated.

15.0 RADIOLOGICAL EXPOSURE Means for controlling radiological exposures, in an emergency, are established for emergency workers. The means for controlling radiological exposures shall include exposure guidelines consistent with EPA Emergency Worker and Lifesaving Activity Protective Action Guides.

Radiological Control Areas (RCAs) / Access Control As necessary, the Radiation Protection Director (RPD) will ensure Radiological Control Areas (RCAs) are established in response to the event. The RPD shall direct control of access to all RCAs unless immediate access is authorized by the Emergency Director to facilitate emergency repairs.

Exposure Control and Records Individuals authorized to enter RCAs are required to have in their possession dosimetry capable of measuring a dose received from external sources of ionizing radiation.

Emergency workers are issued permanent reading dosimeters (e.g. thermoluminescent dosimeter (TLD)) as a means for recording exposure for permanent records prior to entering a radiologically controlled area. Additionally, personnel are issued electronic alarming dosimetry capable of measuring dose and dose rate on a real time basis. Emergency workers are instructed to read their dosimeters frequently. The dosimetry provides 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per day capability to determine the dose received by each emergency worker.

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Emergency worker dose records are maintained in accordance with Radiation Protection procedures.

All reasonable measures shall be taken to control the radiation exposure to emergency response personnel providing rescue, first aid, decontamination, emergency transportation, medical treatment services, corrective actions or assessment actions within applicable limits specified in 10 CFR 20. The Emergency Director is responsible for authorizing plant and emergency response personnel to receive doses in excess of 10 CFR 20 limits, if necessary. This authorization is coordinated with the Radiation Protection Director. Table 15-1 contains the guidelines for emergency exposure criteria, which is consistent with the EPA's, "Protective Action Guide and Planning Guidance for Radiological Incidents," Table 2-2, "Response Worker Guidelines."

Personnel Contamination Control All personnel are monitored for radioactive contamination prior to leaving the site. Portable radiation survey meters are available to frisk personnel for potential contamination.

Documentation of surveys, contamination, and decontamination activities shall be maintained in accordance with Radiation Protection procedures.

TABLE 15-1 Response Worker Guidelines Guideline Activity Condition 5 rem All occupational exposures All reasonably achievable actions have been taken to minimize dose.

10 rem(a) Protecting valuable property Exceeding 5 rem necessary for public welfare unavoidable and all appropriate actions taken to reduce dose. Monitoring available to project or measure dose 25 rem(b) Lifesaving or protection of Exceeding 5 rem large populations unavoidable and all appropriate actions taken to reduce dose. Monitoring available to project or measure dose (a) For potential doses >5 rem, medical monitoring programs should be considered.

(b) Inthe case of a very large incident, may need to consider raising the property and lifesaving response worker guidelines to prevent further loss of life and massive spread of destruction.

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16.0 MEDICAL AND HEALTH SUPPORT Arrangements are made for medical services for contaminated injured individuals. The Kewaunee Power Station maintains on-shift personnel and equipment to provide first aid for personnel working at the site. Medical supplies for emergency first aid treatment are provided on the site at various plant locations. Stretchers are available for transporting non-mobile, injured personnel.

If immediate professional medical help is required, local ambulance services are available to assist in the transport of seriously injured or radioactively contaminated injured personnel.

Arrangements have been made with the Aurora Medical Center for the medical treatment of plant personnel. Hospital personnel have been instructed and trained in the treatment and care of patients with contamination and radiation overexposure.

When personnel are transported to the Aurora Medical Center while in a contaminated condition, personnel trained in radiological monitoring will be dispatched to monitor and maintain radiological controls.

17.0 RECOVERY AND REENTRY PLANNING AND POST ACCIDENT PLANT RECOVERY ORGANIZATION The plant recovery organization will be based on the normal Kewaunee Power Station (KPS) organization and would function with the KPS executive management position being responsible for directing all site activities.

PLANT RECOVERY OPERATIONS Kewaunee Power Station is responsible for plant recovery measures and restoring the plant to a stable condition. Notification of onsite personnel and offsite response organizations that the plant recovery is to commence will be performed in accordance with Emergency Plan Implementing Procedures.

The extent and nature of the corrective and protective measures and the extent of plant recovery will depend on the emergency conditions at hand and the status of plant areas and equipment. The general goals for plant recovery are:

0 An orderly evaluation of the cause and effect of the emergency and implementation of solutions to prevent immediate recurrence of the incident.

• A planned approach for returning the plant to a stable condition by obtaining the appropriate manpower, materials, and equipment.

0 A planned approach to coordinate with offsite authorities to identify and resolve situations that may impact the general public.

0 An evaluation of the radiation exposure records for all onsite emergency response personnel involved in the incident.

0 A planned approach to ensure that radiation exposures and contamination controls are consistent with the ALARA program.

• To ensure that all nuclear safety related procedures associated with the recovery operation are submitted to the Facility Safety Review Committee (FSRC) for review and approval prior to their implementation.

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During a declared emergency, a point will be reached where the plant will be placed in a stable condition. With the understanding that this condition could be attained even though specific Emergency Action Levels are still exceeded, the Emergency Director will determine that there is no longer a need to keep the emergency organization in effect and to begin plant recovery.

Although de-escalation to a lower emergency level may be performed, it is not necessary to de-escalate prior to initiating plant recovery.

Plant recovery activities shall be in accordance with the plant Technical Specifications and other license documents. During plant recovery, the radiation exposure limits of 10 CFR 20 shall apply.

If, during plant recovery, an emergency situation again occurs, the KPS emergency response organization would be activated in accordance with this plan and the implementing procedures.

Plant recovery efforts will be suspended until the emergency condition is resolved. The Emergency Director will re-evaluate plant conditions prior to resuming plant recovery.

PLANT RECOVERY TERMINATION The plant recovery will be terminated by the KPS executive management position after the plant has been returned to a stable condition.

18.0 EXERCISE AND DRILLS Periodic exercises are conducted to evaluate major portions of emergency response capabilities. Periodic drills are conducted to develop and maintain key skills. Deficiencies as a result of exercises or drills are identified and corrected.

Exercise and Drill KPS conducts a biennial Exercise to test the adequacy of timing and content of implementing procedures and methods; to test emergency equipment and communication networks; and to ensure that emergency personnel are familiar with their duties. KPS will invite offsite response organizations to participate in the Exercise.

For alternating years, a Drill is conducted for the purpose of testing, developing, and maintaining the proficiency of emergency responders.

Exercise and Drill scenarios will include, at a minimum, the following:

• The basic objective(s) of the exercise / drill.

• The date(s), time period, place(s), and participating organizations.

• A time schedule of real and simulated initiating events.

• A narrative summary describing the conduct of the drill to include such items as simulated casualties, offsite fire assistance, rescue of personnel, and use of protective clothing.

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Equipment and Proficiency Drills The following drills are conducted for the purpose of training, developing, and maintaining the proficiency of emergency responders. Equipment and proficiency drills may be performed as part of an exercise, a drill or as an independent drill.

Communication Drills NARS communications with State and county governments shall be drilled annually.

The communication drill includes the aspect of understanding the content of messages.

Performance of the Communication Drill satisfies the NARS testing requirements specified in Section 10.0.

Medical Emergency Drills A medical emergency drill involving a simulated contaminated individual and containing provisions for participation by the Aurora Medical Center shall be conducted at least annually. Both the Kewaunee Power Station and Point Beach Nuclear Plant share the facilities provided by the Aurora Medical Center. To minimize redundant training for the hospital staff, the two plants will alternate development and conduct of the drill each year.

Radiological Monitoring Drills Radiological monitoring drills, which are conducted annually, demonstrate the ability to perform plant environment and radiological monitoring.

Health Physics Drills Health Physics drills, which are conducted semi-annually, involve a response to, and analysis of, simulated airborne and direct radiation measurements within the plant.

Accountability Drill An accountability drill shall be conducted annually. The drill shall include identifying the locations of all individuals onsite.

Augmentation Capability Assessment (ACA) Drills An unannounced off-shift ACA drill shall be conducted semi-annually. These drills shall involve implementation of the ERO callout system procedure and documentation of the estimated response time for each responder. No actual travel is required. Participants provide an estimation of the time it would take to report to the Control Room. This drill shall serve to demonstrate the capability to augment the on-shift staff after declaration of an emergency.

Performance of the ACA drill satisfies the ERO callout system testing requirements specified in Section 10.0.

Critique and Evaluation Critiques will evaluate the performance of the organization. The ability of emergency response personnel to self-evaluate weaknesses and identify areas for improvement is the key to successful exercise / drill conduct.

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Exercise and drill performance objectives are evaluated against measurable demonstration criteria. As soon as possible following the conclusion of each exercise or drill, a critique, including participants and evaluators, is conducted to evaluate the ability of the ERO to implement the PDEP and associated procedures. Deficiencies as a result of exercises or drills are identified and entered into the KPS corrective action system A written report is prepared following an exercise or drill involving the evaluation of designated objectives. The report evaluates and documents the ability of the ERO to respond to a simulated emergency situation. The report will also contain reference to corrective action and recommendations resulting from the exercise or drill.

19.0 RADIOLOGICAL EMERGENCY RESPONSE TRAINING Radiological emergency response training is provided to those who may be called on to assist in an emergency.

19.1 EMERGENCY RESPONSE PERSONNEL TRAINING Requirements for emergency preparedness training are specified in the Emergency Preparedness Training Program. This program identifies the level and the depth to which individuals are to be trained.

Emergency Preparedness Training Program The training program for emergency response personnel is based on the requirements of 10 CFR 50 Appendix E and position specific responsibilities as defined in the PDEP. Emergency response personnel in the following categories receive initial training and annual retraining:

Shift Managers/Emergency Directors, Technical Directors and Radiation Protection Directors shall have training conducted such that proficiency is maintained on the topics listed below. These subjects shall be covered as a minimum on an annual basis.

" Emergency Action Level Classification.

" Dose Assessment.

• Nuclear Accident Reporting System (NARS) Form completion and use of the NARS system.

" Federal, State and Local notification procedures.

• ERO Activation.

" Emergency Exposure Control.

• Mitigating strategies required for a catastrophic loss of spent fuel pool inventory.

KPS personnel available during declared emergencies to perform emergency response activities as an extension of their normal duties receive duty specific training. Additional emergency preparedness training is provided as part of annual plant access training.

Plant Operators and Maintenance personnel are trained to function as emergency in-plant teams.

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Radiation Technologists are trained to provide support for radiological accident assessment and protective actions. Support activities include access control; radiological coverage (e.g., monitoring, surveys, and support) for repair, corrective actions, search and rescue, first aid, and firefighting; personnel monitoring and dosimetry; and dose assessment.

Security Personnel are trained in accordance with Security Program training requirements including ERO notification and accountability procedures.

First Aid training for personnel assigned to the on-shift responsibility shall include courses equivalent to Red Cross Multi-Media.

Fire Brigade personnel are trained in accordance with the Fire Protection Program Plan, including mitigating strategies required for a catastrophic loss of spent fuel pool inventory.

Personnel who are badged for unescorted access receive plant access training annually.

Information pertaining to their safety and the safety of visitors under escort during a declared emergency is included in this training.

Plant access training shall include the following emergency preparedness topics:

" Basic Emergency Plan and implementing procedure information.

" Emergency Response Organization and responsibilities.

• Emergency classification levels.

• Call out of personnel during an emergency.

• Plant alarms and expected response.

" Use of plant communication systems.

" Personnel accountability procedures.

19.2 Non-KPS Emergency Response Support Organizations Training is offered annually to non-KPS organizations which may provide specialized services during a nuclear plant emergency (e.g., fire-fighting, medical services, transport of injured, etc.). The training shall be structured to meet the needs of that organization with respect to the nature of their support. Training topics such as event notification, basic radiation protection and interface activities between the offsite organization and KPS shall be made available.

The Point Beach Nuclear Power Plant and the Kewaunee Power Station share services from common offsite organizations and agencies. As specified in an established memorandum of understanding, the two plants keep each other informed regarding the emergency preparedness training being presented, thus allowing the two facilities to alternate presentations and minimize redundant training provided to the offsite agencies.

20.0 RESPONSIBILITY FOR PLANNING EFFORT: PERIODIC REVIEW AND DISTRIBUTION OF EMERGENCY PLANS Responsibilities for plan development and review and for distribution of emergency plans are established, and planners are properly trained.

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20.1 EMERGENCY PREPAREDNESS RESPONSIBILITIES KPS Executive Management Position Overall authority and responsibility for emergency response planning. This responsibility includes ensuring that the emergency preparedness program is maintained and implemented as described in this Plan and applicable requirements and regulations.

Emergency Preparedness Staff Responsible for the following tasks:

• Maintaining and updating this PDEP and associated procedures.

" Ensuring Drill/Exercise commitments stated in the plan are met.

• Ensuring material readiness of emergency response facilities.

" Overseeing Emergency Preparedness Training Program.

" Maintaining Emergency Preparedness interfaces with offsite agencies.

" Performing and documenting appropriate evaluations of program and of classified emergency events.

Individuals assigned the duties of maintaining the PDEP maintain an adequate knowledge of regulations, planning techniques, and the latest applications of emergency equipment and supplies. Training for these individuals includes 50.54(q) Evaluation Qualification and may include the following:

• Industry or site specific training courses specific or related to emergency preparedness.

" Observation of or participation in drills and/or exercises at other stations.

" Participation in industry review and evaluation programs.

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

Licensing Responsible for the following tasks:

• Maintaining current knowledge of changes in Federal regulations and other guidance that impact emergency planning activities.

• Submit PDEP and related controlled document revisions to the NRC.

Oversight Responsible for performance of independent audit of the emergency preparedness program to meet the requirements of 10 CFR 50.54(t).

20.2 REVIEW AND UPDATING OF THE PDEP It is important that a state of emergency preparedness be maintained at all times at the Kewaunee Power Station. The PDEP and Emergency Action Level Technical Bases are reviewed annually and updated, as needed. The review shall encompass the need for changes based upon the following aspects:

• Written critiques and evaluations of drills and exercises.

• Changes in the organizational structure.

• Changes in the functions and capabilities of supporting agencies.

• Changes in Federal or State regulations.

• Modifications to the plant facility, site, or operating status which would affect emergency planning.

• Recommendations or agreement changes received from other organizations.

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Any needed changes shall be incorporated in the PDEP, Emergency Action Level Technical Bases, and appropriate implementing procedures.

Proposed activities that may impact the PDEP must be evaluated per 10CFR50.54(q).

Emergency Action Levels (EALs) State and County Review The EALs shall be made available for review with State and county governmental authorities annually.

Emergency Telephone Directory Names and telephone numbers of the ERO and supporting offsite agencies shall be reviewed at least quarterly and updated as necessary.

Letters of Agreements The letters of agreement with the support agencies shall be reviewed with the support agency at least every two years (biennially). Changes shall be made and the agreements renewed, as necessary.

KPS reserves the right to enter agreements or contracts which are perpetual and free from biennial renewal, or of a period other than biennial if mutually agreed upon by the co-signers of the agreement letter or contract. However, a letter designated as a perpetual agreement shall be reviewed by KPS at least biennially.

20.3 MAINTENANCE AND INVENTORY OF EMERGENCY EQUIPMENT AND SUPPLIES Appendix A, "Emergency Equipment, Supplies and Reference Materials," lists each of the emergency response facilities and the required equipment, supplies and reference materials that are to be maintained.

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APPENDIX A Emergency Equipment, Supplies and Reference Materials CONTROL ROOM Procedures / Reference Material Permanently Defueled Emergency Plan Emergency Plan Implementing Procedures Permanently Defueled Emergency Action Level Bases Document Physical Recovery Plan (PRP)

Emergency Telephone Directory (ETD)

Equipment Portable radiation monitoring equipment Portable emergency lighting Medical emergency response bag Electronic Dosimeters Handheld radios SITE RELOCATION FACILITY Procedures / Reference Material Permanently Defueled Emergency Plan Emergency Plan Implementing Procedures Permanently Defueled Emergency Action Level Bases Document Physical Recovery Plan (PRP)

Emergency Telephone Directory (ETD)

Equipment Telephones and cords IN-PLANT LOCATIONS Equipment / Supplies Portable radiation monitoring equipment Contamination control supplies Decontamination control supplies Protective clothing Electronic Dosimeters 28

APPENDIX B Cross Reference Table B-1 PDEP Section to Planning Standards/Requirements/Criteria to Procedures NUREG-Planning Planning 0654, PDEP Standard Requirement 0654, Section (10 CFR (Appendix Evaluation 50,47)** E.IV)** Criteria EP-KW-EIP-001, Emergency Response 7

, EP-KW-EIP-003, Response to Security Threat 5.0 (b)(1) A.1, 2,4, 7A EP-KW-3001, Cyclic and Prompted Emergency Preparedness Tasks 6.0 (b)(2) A.1, 2, 4; C.1 B EP-KW-EIP-001, Emergency Response EP-KW-3001, Cyclic and Prompted Emergency 7.0 (b)(3) A.6, 7 C Peaens Tasks Preparedness ak 8.0 (b)(4) B.1, 2; C.1, 2 D EP-KW-EIP-001, Emergency Response 9.0 (b)(5) 3; E E EP-KW-EIP-002, Emergency Notification EP-KW-3001, Cyclic and Prompted Emergency Preparedness Tasks 10.0 (b)(6) C.1; D.1, 3; E F EP-KW-EMP-009-002, Emergency Communication System and Equipment Inventory Verification 11.0 (b)(7) Exempt G EP-KW-EIP-001, Emergency Response EP-KW-3001, Cyclic and Prompted Emergency Preparedness Tasks 12.0 (b)(8) E; G H EP-KW-EMP-009-002, Emergency Communication System and Equipment Inventory Verification 13.0 (b)(9) A.4; B.1; C.2; E I EP-KW-EIP-001, Emergency Response EP-KW-EIP-005, Emergency Radiation Controls EP-KW-SEC-001, Security Force Response 14.0 (b)(10) C.1; E J During an Emergency EP-KW-EIP-003, Response to Security Threat 15.0 (b)(11) E K EP-KW-EIP-005, Emergency Radiation Controls 16.0 (b)(12) A.6, 7; E L EP-KW-EIP-001, Emergency Response 17.0 (b)(13) H M EP-KW-EIP-001, Emergency Response EP-KW-3001, Cyclic and Prompted Emergency 18.0 (b)(14) E9; F N Peaens ak Preparedness Tasks 19.0 (b)(15) F O TR-KW-TPG-2400, Emergency Preparedness 19.0__ (b)_(15)_F_0Training Program EP-KW-3001, Cyclic and Prompted Emergency 20.0 (b)(16) G p Preparedness Tasks TR-KW-TPG-2400, Emergency Preparedness Training Program

• • Refer to the KPS exemptions from portions of 10 CFR 50.47 and Appendix E for applicability 29