Text

License Amendment Request (TSCR-187): Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme
	ML20136A438
Person / Time
Site:	Duane Arnold
Issue date:	05/15/2020
From:	Dean Curtland; NextEra Energy Duane Arnold
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NG-20-0028
	Download: ML20136A438 (126)
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OUAN E ARN OL D May 15, 2020 NG-20-0028 10 CFR 50.90 10 CFR 50.54(q)

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Duane Arnold Energy Center Docket No. 50-331 Renewed Facility Operating License No. DPR-49 License Amendment Request (TSCR-187): Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme

References:

1. Letter from NEDA (D. Curtland) to USN RC , "Certification of Permanent Cessation of Power Operations," NG-19-0136, dated March 2, 2020 (ML20062E489)

2. Letter from NEDA (D. Curtland) to USNRC, "License Amendment Request (TSCR-182): Proposed Changes to the Emergency Plan for Permanently Defueled Condition, " NG-19-0017, dated April 9, 2019(ML19101A261)

3. Letter from NEDA (D. Curtland) to USNRC, "Request for Exemption from Portions of 10 CFR 50.47 and 10 CFR 50 , Appendix E," NG-19-0142, dated April 2, 2020 (ML20101M779)

Pursuant to 10 CFR 50.90, NextEra Energy Duane Arnold , LLC (NEDA) requests an amendment to the license for the Duane Arnold Energy Center (DAEC). The proposed amendment would revise the DAEC Emergency Plan and Emergency Action Level (EAL) scheme for the permanently defueled condition . The proposed changes are being submitted to the NRC for approval prior to implementation, as required under 10 CFR 50.54(q)(4) and 10 CFR Part 50, Appendix E, Section IV.B.2.

In Reference 1, NEDA provided formal notification to the U.S. Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 50.82(a)(1 )(i) and 10 CFR 50.4(b)(8) of the intention to permanently cease power operations at the DAEC on October 30, 2020. In Reference 2, NEDA submitted proposed changes to the DAEC Emergency Plan to reduce the minimum required on-shift and Emergency Response Organization (ERO) staffing following the transition from an operating facility to a permanently defueled facility. In Reference 3, NEDA requested exemptions from portions of 10 CFR 50.47 and 10 CFR 50, Appendix E.

The proposed changes would result in a Permanently Defueled Emergency Plan (PDEP) and a Permanently Defueled EAL scheme, consistent with Nuclear Energy Institute (NEI) 99-01, "Development of Emergency Action Levels for Non-Passive Reactors," Revision 6.

NextEra Energy Duane Arnold , LLC , 3277 DAEC Road, Palo, IA 52324

NG-20-0028 Page 2 of 3 The proposed PDEP and Permanently Defueled EAL scheme are predicated on approval of requests for exemptions from portions of 10 CFR 50.47 and 10 CFR Part 50, Appendix E, previously submitted in Reference 3. The proposed PDEP reduces the scope of offsite and onsite emergency planning commensurate with the permanently defueled condition.

Additionally, the proposed PDEP states that notification of an emergency declaration will be made to State authorities within 60 minutes of an emergency declaration or change in classification.

Reference 3 included an analysis which shows that 10 months following shutdown of the DAEC reactor, the spent fuel stored in the spent fuel pool will have decayed to the point where the requested exemptions, PDEP and Permanently Defueled EAL scheme may be implemented. Following the final DAEC shutdown, which is planned to occur on October 30, 2020 (Reference 1), 10 months after shutdown would be August 30, 2021.

The proposed PDEP and Permanently Defueled EAL scheme are commensurate with the significantly reduced spectrum of credible accidents that can occur in the permanently defueled condition, and are necessary to properly reflect the conditions of the facility while continuing to preserve the DAEC decommissioning trust funds and the effectiveness of the emergency plan.

As presented in the evaluation, the proposed change does not involve a significant hazards consideration pursuant to 10 CFR 50.92, and there are no significant environmental impacts associated with the change. This change has been reviewed and concurred with by the DAEC Onsite Review Group.

The Enclosure to this letter provides the description and evaluation of the proposed changes. to the Enclosure provides the proposed PDEP. Attachment 2 provides a comparison of the proposed Permanently Defueled EAL Bases Document to the corresponding information contained in NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors," Revision 6. Attachment 3 provides the Permanently Defueled EAL Bases Document. Attachment 4 provides the proposed Permanently Defueled EAL scheme. contains a letter of concurrence from Offsite Response Organizations.

This letter contains no new or revised regulatory commitments.

In accordance with 10 CFR 50.91, a copy of this letter and the supporting Enclosure is being forwarded to the State of Iowa designee.

NEDA requests review and approval of the amendment by June 1, 2021, with an effective date of September 1, 2021 and a 90-day implementation period. Approval of these changes by June 1, 2021, will allow NEDA adequate time to implement the PDEP and EAL scheme by the requested effective date.

If you have any questions regarding this submittal, please contact Mike Davis, Licensing Manager, at 319-851-7032.

NG-20-0028 Page 3 of 3 I declare under penalty of perjury that the foregoing is true and correct . Executed on May 15, 2020 .

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

NextEra Energy Duane Arnold, LLC NG-20-0028 Page 1 of 14 ENCLOSURE Evaluation of the Proposed Change

Subject:

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

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION 2.1 Description of the Proposed Changes 2.2 Reason for the Proposed Changes

3. TECHNICAL EVALUATION 3.1 Accident Analysis Overview 3.2 Consequences of a Design Basis Event 3.3 Consequences of a Beyond Design Basis Event 3.4 Consequences of Other Analyzed Events 3.5 Comparison to NUREG-1738 Industry Decommissioning Commitments and Staff Decommissioning Assumptions 3.6 Consequences of a Beyond Design Basis Earthquake

3. 7 Permanently Defueled Emergency Plan 3.8 Permanently Defueled Emergency Action Levels 3.9 Conclusion I

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration Determination 4.4 Conclusions

5. ENVIRONMENTAL CONSIDERATION

6. REFERENCES ATTACHMENTS:

1. Permanently Defueled Emergency Plan

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

3. Permanently Defueled Emergency Action Level Bases Document

4. Permanently Defueled Emergency Action Level Scheme

5. Offsite Response Organization Acknowledgment and Concurrence

NextEra Energy Duane Arnold, LLC NG-20-0028 Page 2of14

1.

SUMMARY

DESCRIPTION The proposed changes would revise the DAEC Emergency Plan and Emergency Action Level (EAL) scheme to support the permanent cessation of power operations and permanent removal of fuel from the reactor vessel. This request contains the proposed DAEC Permanently Defueled Emergency Plan (PDEP) and the Permanently Defueled EAL scheme for NRC review and approval.

The proposed PDEP and Permanently Defueled EAL scheme satisfy the applicable standards of 10 CFR 50.47(b) and the requirements of 10 CFR Part 50, Appendix E for a permanently defueled reactor, as exempted. NextEra Energy Duane Arnold, LLC (NEDA) has submitted a separate request for exemptions from portions of 10 CFR 50.47(b); 10 CFR 50.47(c)(2); and 10 CFR Part 50, Appendix E by letter dated April 2, 2020 (Reference 1). Reference 1 contained an analysis which demonstrated that 10 months after permanent cessation of power operations, the spent fuel stored in the spent fuel pool (SFP) will have decayed to the extent that the requested exemptions, PDEP, and Permanently Defueled EAL scheme may be implemented. DAEC plans to permanently shut down on October 30, 2020 (Reference 2), therefore, 10 months after permanent cessation of power operations will occur on August 30, 2021.

2. DETAILED DESCRIPTION 2.1 Description of the Proposed Changes The proposed amendment would modify the DAEC license by revising the DAEC Emergency Plan and the associated EAL scheme to reflect the pending permanent cessation of power operations and permanent defueling of the reactor. In the permanently defueled condition, the number and severity of potential radiological accidents is significantly less than when the plant is operating.

Therefore, the offsite radiological consequences of postulated accidents at DAEC are substantially lower. Because no postulated accident or reasonably conceivable beyond design basis event will be expected to result in radioactive releases that exceed Environmental Protection Agency (EPA) Protective Action Guides (PAGs) beyond the site boundary, and the slow progression rate of postulated event scenarios indicate sufficient time is available to initiate appropriate mitigating actions to protect the health and safety of the public (Reference 1), the proposed PDEP states that NEDA will maintain the ability to assess, classify, and declare an emergency within 30 minutes after the availability of indications to operators that an EAL threshold has been reached. Emergency declaration is required to be made as soon as conditions warranting classification are present and recognizable, but within 30 minutes in all cases of conditions being present. Notification of an emergency declaration will be made to State and County authorities within 60 minutes of an emergency declaration or change in classification. The proposed PDEP reduces the scope of onsite and offsite emergency planning activities commensurate with the spectrum of credible accidents that can occur in a permanently shutdown and defueled condition.

The proposed PDEP meets the applicable standards of 10 CFR 50.47(b) and requirements of 10 CFR Part 50, Appendix E, in view of the separately submitted request for exemptions (Reference 1).

The current EAL scheme is based on the guidance presented in NEI 99-01, "Methodology for Development of Emergency Action Levels," Revision 6, (Reference 3) endorsed by the NRC in

NextEra Energy Duane Arnold, LLC NG-20-0028 Page 3of14 a letter dated March 28, 2013 (Reference 4). NEDA determined that a revision to implement the EAL scheme contained in Appendix C of NEI 99-01, Rev. 6, Recognition Category PD (Permanently Defueled), is appropriate to address the permanently shut down and defueled condition. This determination is supported by the analyses presented in Reference 1.

2.2 Reason for the Proposed Changes The proposed changes are desired to reflect the pending permanent cessation of operation and permanent defueling of the DAEC reactor, and anticipated conditions following 1O months of decay of the spent fuel. After the reactor is shut down, all fuel assemblies will be removed from the reactor vessel and placed in the SFP. Upon docketing of the certifications for permanent cessation of operations (1 O CFR 50.82(a)(1 )(i)) and permanent removal of fuel from the reactor vessel (1 O CFR 50.82(a)(1)(ii)), pursuant to 10CFR 50.82(a)(2), the 10 CFR 50 license for DAEC will no longer authorize operation of the reactor or emplacement or retention of fuel into the reactor vessel. The irradiated fuel will be stored in the SFP and in the Independent Spent Fuel Storage Installation (ISFSI) until it is removed by the U.S. Department of Energy (DOE).

The proposed revisions to the DAEC Emergency Plan and EAL scheme are commensurate with the reduction in radiological hazards associated with the permanently shut down and defueled condition, and will allow the facility to transition to an emergency plan and EAL scheme required for a permanently shut down and defueled facility. The proposed changes are necessary to properly reflect the conditions of the facility 10 months following permanent cessation of power operations while continuing to preserve the DAEC Decommissioning Trust Fund and maintain the effectiveness of the DAEC Emergency Plan.

3. TECHNICAL EVALUATION 3.1 Accident Analysis Overview Following the cessation of reactor operations at DAEC and the permanent removal of the fuel from the reactor vessel, the postulated accidents involving failure or malfunction of the reactor and supporting structures, systems and components will no longer be applicable.

A summary of the postulated radiological accidents analyzed for the permanently shut down and defueled condition is presented below. Current Federal guidance provided in the EPA's, "Protective Action Guides and Planning Guidance for Radiological Incidents, EPA-400/R- 17/001 ,"

(Reference 5) Section 2.2.4, "PAGs and Nuclear Facilities Emergency Planning Zones (EPZ),"

states that the EPZ is based on the maximum distance at which a PAG might be exceeded.

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

NEDA described these analyses and provided each for NRC review in Reference 1. The specific

NextEra Energy Duane Arnold, LLC NG-20-0028 Page 4of14 analyses are summarized in the following sections.

3.2 Consequences of a Postulated Accident The postulated design basis accident that will remain applicable to DAEC in its permanently shut down and defueled condition is the Fuel Handling Accident (FHA) in the reactor building where the SFP is located. Analysis based on the FHA was performed to determine the dose to personnel in the Control Room and to the public at the Exclusion Area Boundary (EAB or "Site Boundary") as a function of time after shutdown. The analysis used the Alternative Source Term methodology from Regulatory Guide 1.183 and concluded that the dose at the EAB 19 days after shutdown (with open containment) is less than 1 rem TEDE, which is below the EPA PAG threshold of 1 rem for recommended evacuation.

The results of this analysis may be applied after November 18, 2020, assuming a DAEC shutdown by October 30, 2020.

This analysis is also described in Reference 1.

3.3 Consequences of a Beyond Design Basis Event With respect to beyond design basis events, NEDA analyzed a partial drain down of the SFP water that would effectively impede any decay heat removal (adiabatic heatup). The analysis compares the conditions for the hottest fuel assembly stored in the DAEC SFP to a criterion proposed in SECY-99-168 (Reference 7) applicable to offsite emergency response for a unit in the decommissioning process. This criterion considers the time for the hottest assembly to heat up from 30 degrees Celsius (°C) to 900°C adiabatically. If the heat up time is greater than 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , then offsite emergency planning involving the facility is not necessary.

Based on the limiting fuel assembly for decay heat and adiabatic heatup analysis, at 1O months after shutdown the time for the hottest fuel assembly to reach 900°C is >10 hours after the assemblies have been uncovered. As stated in NUREG-1738 (Reference 8), 900°C is an acceptable temperature to use for assessing onset of fission product release under transient conditions (to establish the critical decay time for determining availability of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months to evacuate) if

. fuel and cladding oxidation occurs in air.

Because of the length of time it would take for the adi'abatic heatup to occur, there is ample time to respond to any partial drain down event that might cause such an occurrence by restoring cooling or makeup, or providing spray. As a result, the likelihood that such a scenario would progress to a zirconium fire is not deemed credible, and offsite emergency planning involving facilities is not necessary. This analysis was submitted for NRC Review in Reference 1.

3.4 Consequences of Other Analyzed Events NEDA analyzed a complete drain down event of the SFP to determine a dose rate curve at the EAB and Control Room. A loss of water shielding above the fuel could increase the offsite radiation levels because of the gamma rays streaming up out of the pool being scattered back to a receptor at the site boundary.

The offsite radiological impact of a postulated complete loss of SFP water was assessed. It was determined that the gamma radiation dose rate at the EAB would be less than the EPA PAG exposure levels. The extended period required to exceed the integrated PAG limit of 1 rem TEDE

NextEra Energy Duane Arnold, LLC NG-20-0028 Page 5of14 would allow sufficient time to develop and implement onsite mitigative actions and provide confidence that additional offsite measures could be taken without planning if efforts to reestablish shielding over the fuel are delayed. The analysis shows that after approximately 9 months (0.75 years) of decay time, the time needed to exceed the PAG limit of 1 rem TEDE at the EAB following a SFP drain down is approximately 198 days, or about 6.5 months. This value can be compared to the 10-hour time limit for zirconium ignition in ISG-02 mitigative actions will have been taken far in advanced of exceeding 1 rem TEDE at the EAB. Therefore, conditions 10 months following reactor shutdown are bounded.

The dose rate to the Control Room was determined to be <0.03 mrem/hr. While there is no acceptance criteria for the Control Room in ISG-02, the dose rate values are considered reasonably low.

The analysis was submitted for NRC review in Reference 1.

3.5 Comparison to NUREG-1738 Industry Decommissioning Commitments and Staff Decommissioning Assumptions NEDA also evaluated the industry decommissioning commitments (IDCs) and staff decommissioning assumptions (SDAs) contained in NUREG-1738 (Reference 8). NUREG-1738 contains the results of the NRC staff's evaluation of the potential accident risk in spent fuel pools at decommissioning plants in the United States. The study was undertaken to support development of a risk-informed technical basis for reviewing exemption requests and a regulatory framework for integrated rulemaking. The NRC staff performed analyses and sensitivity studies on evacuation timing to assess the risk significance of relaxed offsite emergency preparedness requirements during decommissioning. The staff based its sensitivity assessment on the guidance in Regulatory Guide (RG) 1.174, "An Approach for Using Probabilistic Risk Assessment In Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis" (Reference 9). The staffs analyses and conclusions apply to decommissioning facilities with SFPs that meet the design and operational characteristics assumed in the risk analysis.

The study found that the risk at decommissioning plants is low and well within the Commission's Safety Goals. The risk is low because of the very low likelihood of a zirconium fire (resulting from a postulated irrecoverable loss of SFP cooling water inventory).

The study provided the following assessment:

"The staff found that the event sequences important to risk at decommissioning plants are limited to large earthquakes and cask drop events. For emergency planning (EP) assessments, this is an important difference relative to operating plants where typically a large number of different sequences make significant contributions to risk. Relaxation of offsite EP a few months after shutdown resulted in only a "small change" in risk, consistent with the guidance of RG 1.174. Figures ES-1 and ES-2 [in NUREG-1738]

illustrate this finding. The change in risk due to relaxation of offsite EP is small because the overall risk is low, and because even under current EP requirements, EP was judged to have marginal impact on evacuation effectiveness in the severe earthquakes that dominate SFP risk. All other sequences including cask drops (for which emergency planning is expected to be more effective) are too low in likelihood to have a significant impact on risk. For comparison, at operating reactors, additional risk-significant accidents for which EP is expected to provide dose savings are on the order of 1x10-5 per year,

NextEra Energy Duane Arnold, LLC NG-20-0028 Page 6of14 while for decommissioning facilities, the largest contributor for which EP would provide dose savings is about two orders of magnitude lower (cask drop sequence at 2x10- 7 per year)."

The Executive Summary in NUREG-1738 states, in part, "the staff's analyses and conclusions apply to decommissioning facilities with SFPs that meet the design and operational characteristics assumed in the risk analysis. These characteristics are identified in the study as IDCs and SDAs.

Provisions for confirmation of these characteristics would need to be an integral part of rulemaking." The IDCs and SDAs are listed in Tables 4.1-1 and 4.1-2, respectively, of NUREG-1738. Tables 4 and 5 of Reference 1 identify how NEDA meets or compares with each of these IDCs and SDAs.

3.6 Consequences of a Beyond-Design Basis Earthquake NUREG-1738 (Reference 8) identifies beyond design basis seismic events as the dominant contributor to events that could result in a loss of SFP coolant that uncovers fuel for plants in the Central and Eastern United States. Additionally, NUREG-1738 identifies a zirconium fire resulting from substantial loss-of-water inventory from the SFP as the only postulated scenario at a decommissioning plant that could result in significant offsite radiological release. The scenarios that lead to this condition have very low frequencies of occurrence (i.e., on the order of one to tens of times in a million years) and are considered beyond design basis events because the SFP and attached systems are designed to prevent a substantial loss of coolant inventory under accident conditions. However, the consequences of such accidents could potentially lead to an offsite radiological dose in excess of the EPA PAGs (Reference 5) at the EAB.

The risk associated with zirconium cladding fire events decreases as the spent fuel ages. When the spent fuel ages, the decay time increases, the decay heat decreases, and the short-lived radionuclides decay away. As the decay time increases, the overall risk of zirconium cladding fire continues to decrease due to two factors: (1) the amount of time available for preventative actions increases, which reduces the probability that the actions would not be successful; and (2) the increased likelihood that the fuel is able to be cooled by air, which decreases the reliance on actions to prevent a zirconium fire. The results of the research conducted for NUREG-1738 and NUREG-2161, "Consequence Study of a Beyond-Design-Basis Earthquake Affecting the Spent Fuel Pool for a U.S. Mark I Boiling Water Reactor," (Reference 10) suggests that, while other radiological consequences can be extensive, a postulated accident scenario leading to a SFP zirconium fire, where the fuel has had significant decay time, will have little potential to cause offsite early fatalities due to dose, regardless of the type of offsite response (i.e., formal offsite radiological emergency preparedness plan or Comprehensive Emergency Management Plan).

The purpose of NUREG-2161 was to determine if accelerated transfer of older, colder spent fuel from the SFP at a reference plant to dry cask storage significantly reduces the risks to public health and safety. The study states that "this study's results are consistent with earlier research studies' conclusions that spent fuel pools are robust structures that are likely to withstand severe earthquakes without leaking cooling water."

NUREG-2161 also states:

"The study shows the likelihood of a radiological release from the spent fuel pool after the analyzed severe earthquake at the reference plant to be about one time in 1O million years or lower. If a leak and radiological release were to occur, this study shows that individual cancer fatality risk for a member of the public is several orders of magnitude lower than the

NextEra Energy Duane Arnold, LLC NG-20-0028 Page 7of14 Commission's Quantitative Health Objective of two in one million (2 x 10- 6/year). For such a radiological release, this study shows public and environmental effects are generally the same or smaller than earlier studies."

The reference plant for the study (a General Electric Type 4 BWR with a Mark I containment) generated approximately 3500 MWt and the SFP contained 2844 fuel assemblies. DAEC is a General Electric Type 4 BWR with a Mark I containment licensed to generate 1912 MWt. Following permanent cessation of power operations and transfer of all fuel from the reactor vessel to the SFP, the SFP will contain a maximum of 1818 fuel assemblies. Therefore, the risks and consequences of an event involving the SFP at DAEC are bounded by those in the NUREG-2161 study.

NEDA conducted a seismic evaluation in response to Recommendation 2.1 of the Near Term Task Force (NTTF) review of the accident at the Fukushima Dia-ichi nuclear facility. This evaluation included the spent fuel pool and was submitted to the NRC for review (Reference 11). This evaluation provides a specific assessment of earthquake probabilities versus acceleration for the Duane Arnold, and concludes, regardless of response spectral frequency, the probability is less than 2 x 1o-6 /year. The NRC review of this evaluation is documented in References 12 and 13.

Additionally, NEDA has also included the Reactor Building structure (and SFP) into the Maintenance Rule - Structures Monitoring Program. The program requires a validation by walkdown and drawing review that there are no changes or degradation of the equipment, structure and components and is completed every 2 years. This will continue until all fuel is removed from the pool.

3. 7 Permanently Defueled Emergency Plan The DAEC PDEP is provided as Attachment 1 of this submittal for NRC review and approval. The PDEP describes NEDA's plan for responding to emergencies that may arise while in a permanently shutdown and defueled configuration. The PDEP was developed considering the guidance contained within Attachment 1 of ISG-02 (Reference 6).

The analyses of the potential radiological impact of accidents while the facility is in a permanently shutdown and defueled condition indicate that no postulated accident or reasonably conceivable beyond design basis event will be expected to result in radioactive releases that exceed EPA PAGs beyond the site boundary. The slow progression rate of postulated event scenarios indicate sufficient time is available to initiate appropriate mitigating actions to protect the health and safety of the public (Reference 1). Therefore, the proposed PDEP states that NEDA will maintain the ability to assess, classify, and declare an emergency within 30 minutes after the availability of indications to operators that an EAL threshold has been reached. Emergency declaration is required to be made as soon as conditions warranting classification are present and recognizable, but within 30 minutes in all cases of conditions being present. Notification of an emergency declaration will be made to State and County authorities within 60 minutes of an emergency declaration or change in classification. Decommissioning-related emergency plan submittals for DAEC have been discussed with offsite response organizations since NEDA provided notification that it would permanently cease power operations. These discussions have addressed changes to onsite and offsite emergency preparedness throughout the decommissioning process, including the proposed 30-minute emergency declaration time and the 60-minute notification time to the State of Iowa. Emergency management officials with both states have agreed that these proposed changes are appropriate.

NextEra Energy Duane Arnold, LLC NG-20-0028 Page 8of14 Based on the results of accident analysis, the proposed emergency declaration and notification times and the reduced scope of onsite and offsite emergency response plans can be implemented without undue risk to public health and safety, commensurate with the reduced offsite radiological consequences associated with the permanently defueled and decommissioning status of the facility. As described in Attachment 1, offsite notifications will be made via commercial telephone with wireless communications serving as the backup means of communication.

In the event of a large area fire, deliberate attack, or other rapidly developing beyond design basis events, the rapid deployment of offsite resources, including law enforcement, ambulance, and fire/rescue services may be requested by the station to assist with the onsite response.

These requests would be made via direct contact with local response agencies using established communications methods.

The PDEP addresses the applicable regulations contained in 10 CFR 50.47, "Emergency Plans" and 10 CFR Part 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities" and is consistent with the applicable guidance established in ISG-02 (Reference 6) and 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," (Reference 14) that remain applicable after the separately requested exemptions (Reference 1) are approved by the NRC.

3.8 Permanently Defueled Emergency Action Levels The current DAEC EAL scheme was developed based on the guidance presented in NEI 99-01, Rev. 6 (Reference 3). provides the proposed Permanently Defueled EAL Technical Bases Document, containing the site-specific technical bases for the proposed Permanently Defueled EAL scheme. The EALs that comprise the proposed Permanently Defueled EAL scheme are also presented in the matrix provided in Attachment 4.

3.8.1 Differences and Deviations provides a cross-reference between each generic EAL contained in NEI 99-01, Revision 6 (Reference 3) and the proposed Permanently Defueled EALs. Differences and deviations are identified in accordance with the guidance contained in NRC Regulatory Issue Summary (RIS) 2003-18, "Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels," Revision 4, dated January 2003 (and Supplements)

(Reference 15). As discussed in RIS 2003-18, Supplement 1, dated July 13, 2004, differences and deviations are defined as follows:

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

An explanation for each difference between the Permanently Defueled EALs and the guidance presented in NEI 99-01, Revision 6 is included in Attachment 2. The differences do not alter the meaning or intent of the Initiating Condition or EAL.

NextEra Energy Duane Arnold, LLC NG-20-0028 Page 9of14 "A deviation is an EAL change where the basis scheme guidance differs in wording and is altered in meaning or intent, such that classification of the event could be different between the basis scheme guidance and the site-specific proposed EAL. Examples of deviations include the use of altered mode applicability, altering key words or time limits, or changing words of physical reference (protected area, safety- related equipment, etc.)."

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

3.8.2 Operating Modes and Applicability The proposed Permanently Defueled EALs are only applicable in the permanently shutdown and defueled condition, with all fuel permanently removed from the reactor vessel and following 10 months of decay of the spent fuel.

3.8.3 State and Local Government Review of Proposed Changes State and local emergency management officials are advised of EAL changes that are implemented. Following NRC approval and prior to implementation, NEDA will provide an overview of the new classification scheme to State and local emergency management officials in accordance with 10 CFR Part 50, Appendix E, Section IV. B.1.

3.9 Conclusion NEDA has demonstrated that no credible accident will result in radiological releases requiring offsite protective actions. Additionally, there is sufficient time, resources and personnel available to initiate mitigative actions that will prevent an offsite release that exceeds EPA PAGs.

This proposed amendment would revise the DAEC Emergency Plan and the EAL scheme to reflect the permanently shutdown and defueled condition following 1O months of decay of the spent fuel. The proposed PDEP and Permanently Defueled EAL scheme are being submitted to the NRC for approval prior to implementation, as required under 10 CFR 50.54(q)(4) and 10 CFR Part 50, Appendix E, Section IV.B.2.

4. REGULATORY EVALUATION The proposed PDEP and Permanently Defueled EAL scheme implement the separately requested exemptions from portions of 10 CFR 50.47(b); 10 CFR 50.47(c)(2); and 10 CFR Part 50, Appendix E, submitted in Reference 1.

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.47, "Emergency Plans," sets forth emergency plan requirements for nuclear power plant facilities. The regulations in 10 CFR 50.47(a)(1 )(i) state, in part: " ... no initial operating license for a nuclear power reactor will be issued unless a finding is made by the NRG that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency."

NextEra Energy Duane Arnold, LLC NG-20-0028 Page 10of14 10 CFR 50.47(b) establishes the standards that the onsite and offsite emergency response plans must meet for NRC staff to make a positive finding that there is reasonable assurance that the licensee can and will take adequate protective measures in the event of a radiological emergency. Planning Standard (4) of this section (with exemption) (regulation requested for exemption in Reference 1 is included below in strikeout text) requires that a licensee's emergency response plan contain the following:

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

10 CFR 50.54(q)(4) specifies the process for revising emergency plans where the changes reduce the effectiveness of the plan. This regulation states the following:

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

Section IV.B.1 of Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," to 10 CFR Part 50, states, in part (with exemption):

The means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of local and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring. By o1une 20, 2012, for nuclear power reactor licensees, these action le'lels must include hostile action that may ad'lerse!y affect the nuclear po1Ner plant.

Section IV.B.2 of Appendix Estates that: "A licensee desiring to change its entire emergency action level scheme shall submit an application for an amendment to its license and receive NRG approval before implementing the change."

Section IV.C.1 of Appendix E requires (with exemption) each emergency plan to define the emergency classification levels that determine the extent of the participation of the emergency response organization. The emergency classification levels include: (1) notification of unusual events, (2) alert. EALs are used by facility personnel in determining the appropriate emergency classification level to declare.

In November 2012, NEI published NEI 99-01, Revision 6 (Reference 3). The EAL scheme being requested herein is based on Revision 6 to NEI 99-01. The NRC endorsed NEI 99-01,

NextEra Energy Duane Arnold, LLC NG-20-0028 Page 11 of14 Revision 6, by letter dated March 28, 2013 (Reference 4). Because no postulated accident or reasonably conceivable beyond design basis event will be expected to result in radioactive releases that exceed EPA PAGs beyond the site boundary, or there is sufficient time to initiate appropriate mitigating actions to protect the health and safety of the public (Reference 1), the Permanently Defueled EALs, detailed in NEI 99-01, Revision 6, will be adopted, with certain differences. Pursuant to 10 CFR Part 50, Appendix E, Section IV.B.2, a revision to an entire EAL scheme must be approved by the NRC before implementation.

ISG-02 (Reference 6) contains guidance for NRC staff evaluation of decommissioning emergency plans.

The proposed amendment is being submitted to the NRC pursuant to 10 CFR 50.90, for the purpose of revising the DAEC Emergency Plan in order to establish a plan appropriate for a permanently defueled facility and to implement a Permanently Defueled EAL scheme.

4.2 Precedent The changes to the DAEC Emergency Plan and associated EAL scheme, including the change to assess, classify, and declare an emergency within 30 minutes, are consistent with changes to emergency plans and EALs for the transition to a permanently defueled condition that have recently been approved by the NRC for other nuclear power reactor facilities beginning decommissioning. Specifically, the NRC approved similar changes for the Vermont Yankee Nuclear Power Station (ML15233A166), San Onofre Nuclear Generating Station, Units 1, 2, and 3 (ML15105A349 and ML15126A461), Crystal River Unit 3 Nuclear Generating Station (ML15027A209), Kewaunee Power Station (ML14279A482) and Fort Calhoun Station (ML17276B286).

Similar changes to the emergency plan and the associated EAL scheme were approved by the NRC for the Zion station as it transitioned from an operating plant to a decommissioned facility (ADAMS Legacy No. 9909070087 and ML072680350).

Increasing the notification time to responsible state and local governmental agencies to 60 minutes from emergency declaration was approved for the Haddam Neck Plant (ML13064A374),

the La Crosse Boiling Water Reactor (LACBWR) facility (ML13008A565), Maine Yankee (ML13112A842) and Yankee Rowe (ML13121A560).

4.3 No Significant Hazards Consideration Determination The proposed changes would revise the DAEC Emergency Plan and EAL scheme commensurate with the hazards associated with a permanently shutdown and defueled facility.

NEDA has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No.

The proposed changes to the DAEC Emergency Plan and EAL scheme do not impact

NextEra Energy Duane Arnold, LLC NG-20-0028 Page 12of14 the function of facility structures, systems, or components. The proposed changes do not affect accident initiators or precursors, nor do they alter design assumptions. The proposed changes do not prevent the ability of the on-shift staff and emergency response organization to perform their intended functions to mitigate the consequences of any accident or event that will be credible in the permanently defueled condition.

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

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

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

Response: No.

The proposed changes reduce the scope of the DAEC Emergency Plan and EAL scheme commensurate with the hazards associated with a permanently shutdown and defueled facility. The proposed changes do not involve installation of new equipment or modification of existing equipment, so that no new equipment failure modes are introduced. Also, the proposed changes do not result in a change to the way that the equipment or facility is operated resulting in new or different kinds of accident initiators or accident mitigation.

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

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

Response: No.

Margin of safety is associated with confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to limit the level of radiation dose to the public. The proposed changes are associated with the DAEC Emergency Plan and EAL scheme and do not impact operation of the facility or its response to transients or accidents. The proposed changes do not affect the Technical Specifications. The proposed changes do not involve a change in the method of facility operation, and no accident analyses will be affected by the proposed changes. Safety analysis acceptance criteria are not affected by the proposed changes and margins of safety are maintained. The revised Emergency Plan will continue to provide the necessary response staff.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above, NEDA concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

NextEra Energy Duane Arnold, LLC NG-20-0028 Page 13of14 4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5. ENVIRONMENTAL CONSIDERATION This amendment request meets the eligibility criteria for categorical exclusion from environmental review set forth in 10 CFR 51.22(c)(9) as follows:

(i) The amendment involves no significant hazards consideration.

As described in Section 4.3 of this evaluation, the proposed changes involve no significant hazards consideration.

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

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

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

The proposed changes do not involve any physical alterations to the facility configuration or any changes to the operation of the facility that could lead to a significant increase in individual or cumulative occupational radiation exposure.

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

6. REFERENCES

1. Letter from NEDA (D. Curtland) to USN RC, "Request for Exemption from Portions of 10 CFR 50.47 and 10 CFR 50, Appendix E," NG-19-0142, dated April 2, 2020 (ML20101M779)

2. Letter from NEDA (D. Curtland) to USN RC, "Certification of Permanent Cessation of Power Operations," NG-19-0136, dated March 2, 2020 (ML20062E489)

3. Nuclear Energy Institute (NEI) 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors," dated November 2012(ML12326A805)

4. Letter from USN RC to NEI, "U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 6, Dated November 2012 (TAC NO. D92368)," dated March 28, 2013 (ML12346A463)

NextEra Energy Duane Arnold, LLC NG-20-0028 Page 14of14

5. EPA-400/R-17 /001, "PAG Manual: Protective Action Guides and Planning Guidance for Radiological Incidents," dated January 2017 (ML17044A073)

6. NSIR/DPR-ISG-02, "Interim Staff Guidance, Emergency Planning Exemption Requests for Decommissioning Nuclear Power Plants," dated May 2015(ML14106A057)

7. Commissioning Paper SECY-99-168, "Improving Decommissioning Regulations for Nuclear Power Plants," dated June 30, 1999 (ML12265A598)

8. NUREG-1738, "Technical Study of Spent Fuel Pool Accident Risk at Decommissioning Nuclear Power Plants," dated February 2001 (ML010430066)

9. Regulatory Guide 1.174, "An Approach for Using Probabilistic Risk Assessment In Risk Informed Decisions on Plant-Specific Changes to the Licensing Basis," dated July 1998 (ML003740133)

10. NUREG-2161, "Consequence Study of a Beyond-Design-Basis Earthquake Affecting the Spent Fuel Pool for a U.S. Mark I Boiling Water Reactor," September 2014(ML14255A365)

11. Letter from NEDA (R. Anderson) to USN RC, "NextEra Energy Duane Arnold, LLC Seismic Hazard and Screening Report (CEUS Sites), Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident," NG-14-0092, dated March 28, 2014 (ML14092A331)

12. Letter from USN RC to NEDA (T. Vehec), "Duane Arnold Energy Center- Staff Assessment of Information Provided Pursuant to Title 10 of the Code of Federal Regulations Part 50, Section 50.54(f), Seismic Hazard Reevaluations for Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident (TAC No. MF3783)," dated December 15, 2015 (ML15324A176)

13. Letter from USN RC to Listed Power Reactor Licensees, "Staff Review of High Frequency Confirmation Associated with Reevaluated Seismic Hazard Implementing Near-Term Task Force Recommendation 2.1 "Seismic" for Specific Licensees," dated February 18, 2016 (ML15364A544)

14. NUREG-0654, FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," Revision 1, dated November 1980 (ML040420012)

15. NRC Regulatory Issue Summary (RIS) 2003-18, "Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels," Revision 4, dated January 2003 (ML032580518)

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

ATTACHMENT 1 PERMANENTLY DEFUELED EMERGENCY PLAN 32 pages follow

Table of Contents Introduction ..............................................................................................................................................3 1.1 Overview of the Permanently Defueled Emergency Plan ...................................................... 3 1.2 Site Description ............................................................................................................................5 Section A Organizational Responsibility .......................................................................................5 Section B Emergency Response Organization ............................................................................ 6 1.1 Facility On-Shift Organization ....................................................................................................6 1.2 Emergency Response Organization Augmentation ................................................................ 7 1.3. Offsite Organizations ..................................................................................................................8 Section C Emergency Response Support and Resources ....................................................... 11 1.1 Support Provided by Local Organizations ..............................................................................11 Section D Emergency Classification System .............................................................................. 11 1.1 Classification of Emergencies ..................................................................................................11 1.2 Postulated Accidents .................................................................................................................12

1. 3 Emergency Classification System Review ............................................................................. 13 Section E Notification Methods and Procedures ........................................................................ 13 1.1 Notification and Activation ........................................................................................................13 Section F Emergency Communications ......................................................................................14 1.1 DAEC Alarm System .................................................................................................................14 1.2 Communication Systems ..........................................................................................................14 Section G Public Information .........................................................................................................15 Section H Emergency Facilities and Equipment ........................................................................ 15 1.1 Control Room ..............................................................................................................................16 1.2 Laboratory Facilities ...................................................................................................................16 1.3 Emergency Equipment ..............................................................................................................16 1.4 Emergency Kits ..........................................................................................................................17 Section I Accident Assessment. ..................................................................................................17 1.1 Radiological Assessment ..........................................................................................................18 1.2 Corrective Actions ......................................................................................................................18 1.3 Dose Assessment ......................................................................................................................18 Section J Protective Actions .........................................................................................................18 1.1 Accountability ........................................................................................................................18 1

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

1.1.3 Objectives The basic objectives of this plan are:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Other Emergency Director responsibilities are outlined below:

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

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

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

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

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

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

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

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

evaluating technical data pertinent to facility conditions, augmenting the emergency staff as deemed necessary, designating engineering support, as necessary, to evaluate facility conditions and provide technical support,

recommending mitigation and corrective actions, coordinating search and rescue,

coordinating maintenance and equipment restoration, establishing and maintaining communications as desired by the Emergency Director, and

maintaining a record of event activities.

7

1.2.2. Site Radiation Protection Coordinator (SRPC)

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

monitoring personnel accumulated dose, advising the Emergency Director concerning Radiological EALs augmenting the emergency staff as deemed necessary, directing radiological monitoring analysis, performing dose assessment,

coordinating decontamination activities, establishing and maintaining communications as desired by the Emergency Director, and maintaining a record of event activities.

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

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

8

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

Shift Manager (1)

Emergency Director I I Security Force NCO (1) HP Technician (1)

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

I I

I I I Federal State/Local Fire/EMS/

Agencies Agencies LE Agencies

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

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

Operations and Assessment of Control Room Non-Certified 11 -

Operational Aspects On-Scene Operator*

Emergency Direction & Control Control Room Shift Manager 1

Notification/Communication Control Room Shift Manager 1

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

- Radiation Monitoring Assessment Director personnel if necessary)

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

Technician*

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

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

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

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

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

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

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

10

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Emergency kits are described in Section H.

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

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

Warns personnel of potential radiological health hazards Gives early warning of certain equipment malfunctions that might lead to a radiological hazard or facility damage

Prevents or minimizes the effects of inadvertent releases of radioactivity Plant instrumentation provides Control Room personnel with the following parameters necessary to perform dose assessment and determine the magnitude of a potential release:

Gaseous and liquid effluent monitor readings 16

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The recovery organization's responsibilities include:

Maintaining comprehensive radiological surveillance of the facility to assure continuous control and recognition of problems Controlling access to the area and exposure to workers

Decontaminating affected areas and/or equipment Conducting clean-up and restoration activities 21

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

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

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

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

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

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

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

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

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

1.2.6 Communication Tests

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

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

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

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

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

Objective( s)

Date, time period, place and participating organizations

Simulation lists Timeline of real and simulated events A narrative summary

List of controllers and participants The final scenario shall be approved by a designated member of senior facility management.

Drill/Exercise confidentiality must be maintained.

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

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

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

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

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

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

Emergency Action Level Classification Dose Assessment Federal, State, and local notification procedures ERO Augmentation Emergency Exposure Control Mitigating strategies for a catastrophic loss of spent fuel pool inventory

Recovery DAEC personnel available during emergencies to perform emergency response activities as an extension of their normal duties receive duty specific training. This includes facility on-shift personnel, maintenance, radiation protection, and security personnel. Personnel assigned to 24

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

As Exempted 27

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

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

Mercy Medical Center Hiawatha Fire and Rescue 28

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Onsite - The area within the Exclusion Area Boundary.

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

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

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

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

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

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

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

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

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

ATTACHMENT 2 COMPARISON MATRIX FOR PERMANENTLY DEFUELED EALS BASED ON NEI 99-01, "DEVELOPMENT OF EMERGENCY ACTION LEVELS FOR NON-PASSIVE REACTORS," REVISION 6 31 pages follow

COMPARISON DOCUMENT FOR PERMANENTLY DEFUELED EALS BASED UPON NUCLEAR ENERGY INSTITUTE (NEI) 99-01, "METHODOLOGY FOR DEVELOPMENT OF EMERGENCY ACTION LEVELS," REVISION 6

Subject:

Revise the Duane Arnold Energy Center Emergency Plan and Emergency Action Level Scheme to Address the Permanently Defueled Condition 1.0 PURPOSE 2.0 DISCUSSION 3.0 KEY TERMINOLOGY USED 4.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS

5.0 REFERENCES

6.0 DEFINITIONS AND ACRONYMS 7.0 DAEC TO NEI 99-01 EAL CROSS-REFERENCE 8.0 ATTACHMENTS 8.1 Attachment 1, Recognition Category PD EAL Bases 8.2 Attachment 2, Recognition Category E EAL Bases

Description of the Permanently Defueled EAL Technical Basis Document This document provides a description of each section in the proposed Duane Arnold Energy Center (DAEC) Permanently Defueled (PD) Emergency Action Level (EAL) Technical Bases Document and describes the results of a comparison of the proposed DAEC PD EAL scheme against the corresponding information contained in NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors," Revision 6.

1.0 PURPOSE A comparison between this section and NEI 99-01 was not performed. The DAEC PD EAL Technical Bases Document includes reference to the Recognition Category "PD" based on the plant's permanently shut down and defueled condition, providing a stand-alone set of Initiating Conditions (ICs)/EALs for a permanently defueled nuclear power plant, and Recognition Category "E" ICs for the Independent Spent Fuel Storage Installation (ISFSI).

2.0 DISCUSSION This section was developed based on information contained in NEI 99-01 Rev. 6, Section 1, "Regulatory Background." Differences are discussed between the DAEC PD EAL Technical Bases Document and NEI 99-01, Rev. 6. It also provides a description of a permanently defueled station (Section 2.1) and an Independent Spent Fuel Storage Installation (ISFSI)

(Section 2.2). It provides specific criteria for an ISFSI as it pertains to other regulations as well as guidance in NEI 99-01.

NEI 99-01, Section 1.1, "Operating Reactors," was excluded as it pertains to operating reactors.

Pursuant to 10 CFR 50.82(a)(1)(ii), once DAEC certified that the fuel has been permanently removed from the reactor vessel and placed in the spent fuel pool. Pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for DAEC will no longer authorize operation of the reactor or emplacement or retention of fuel in the reactor vessel. The EALs described in the DAEC PD EAL Technical Bases Document will be implemented after DAEC has permanently ceased power operations.

NEI 99-01, Section 1.5, "Applicability to Advanced and Small Modular Reactor Designs," was excluded because it does not apply to DAEC.

3.0 KEY TERMINOLOGY USED Differences between the DAEC PD EALs Technical Bases Document and NEI 99-01, Rev. 6 are discussed below.

References to Site Area Emergency and General Emergency were removed throughout the section. EALs have been developed using Section 8 for the ISFSI and Appendix C for the permanently defueled station ICs/EALs. Emergency Classification Levels only include Notification of Unusual Event (Unusual Event) and Alert.

References to "company" and "owner" have been revised to "licensee" to provide consistency throughout the document.

In Section 3.2, "Initiating Condition (IC)" (Section 2.2 of NEI 99-01, Rev. 6), references to RCS Leakage and fission product barriers were removed. Upon permanent cessation of operations, the RCS and Containment will no longer be considered fission product barriers because the reactor will be permanently defueled. In the permanently defueled condition, the fuel cladding is a fission product barrier. However, the Recognition Category F matrices containing EALs referred to as Fission Product Barrier Thresholds, are not applicable in the permanently defueled condition.

NEI 99-01, Section 2.4, "Fission Product Barrier Threshold," was excluded for reasons previously identified related to fission product barriers.

4.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS This section was developed based on information contained in NEI 99-01, Section 5, "Guidance on Making Emergency Classifications." Differences between the DAEC Permanently Defueled EAL Technical Bases Document and NEI 99-01, Rev. 6 are discussed below.

In Section 4.1 (Section 5.1 of NEI 99-01), references to fission product barrier thresholds were removed as the RCS and Containment will no longer serve as fission product barriers upon permanent cessation of power operations and permanent removal of fuel from the reactor.

In Section 4.1(Section5.1 of NEI 99-01), the second paragraph of NEI 99-01 stating that, "regulations require the licensee to establish and maintain the capability to assess, classify and declare an emergency condition within 15 minutes," was excluded. As detailed in NSIR/DPR-ISG-02, Interim Staff Guidance, "Emergency Planning Exemption Requests for Decommissioning Plants," "... the staff concludes that a decommissioning power reactor is not required to assess, classify, and declare an emergency condition within 15 minutes." DAEC will maintain the ability to assess, classify, and declare an emergency within 30 minutes. Emergency declaration is required to be made as soon as conditions warranting classification are present and recognizable, but within 30 minutes in all cases of conditions being present.

With respect to the notification of an emergency declaration to State and local authorities, no design basis accident or reasonably conceivable beyond design basis accident will be expected to result in radioactive releases that will exceed Environmental Protection Agency (EPA) Protective Action Guides (PAGs) beyond the site boundary. In the permanently defueled condition, the rapidly developing scenarios associated with events initiated during reactor power operation are no longer credible. The radiological consequences resulting from the only remaining events (e.g., fuel handling accident) develop over a significantly longer period. As such, a 15-minute notification requirement

is unnecessarily restrictive. Sixty (60) minutes provides a reasonable amount of time to provide notification to state and local governmental authorities. This notification timeliness is also consistent with the notification requirement to the NRC Operations Center, contained in 10 CFR 50.72(a)(1)(i), for the declaration of an emergency class.

In Section 4.2 (Section 5.2 in NEI 99-01), reference to Operating Mode Applicability was removed because Operating Modes are not applicable to a permanently defueled plant.

In Section 4.3 (Section 5.3 of NEI 99-01), references to two units were removed because DAEC is a single unit site.

Information provided in Section 5.4 of NEI 99-01 was excluded from the DAEC PD EAL Technical Bases Document because mode changes during classification are not applicable to a permanently defueled plant.

In Section 4.4 (Section 5.5 of NEI 99-01), the word "levels" was changed to "level" because there is only one higher emergency classification level above an Unusual Event for a permanently defueled plant.

In Section 4.5 (Section 5.6 of NEI 99-01), references to Site Area Emergency and General Emergency were removed. Site Area Emergency and General Emergency are no longer credible emergency classifications at DAEC. Also removed references to "downgrading."

In Section 4.6 (Section 5.7 of NEI 99-01) references to an operating plant short-lived event (reactor trip) were removed and replaced with verbiage applicable to a permanently defueled plant.

In Section 4.7 (Section 5.8 of NEI 99-01) the example was removed because it does not apply to a non-operating reactor plant.

5.0 REFERENCES

This section was added to provide developmental and implementing references applicable to the DAEC PD EAL Technical Bases Document. No corresponding section is included in NEI 99-01.

6.0 DEFINITIONS AND ACRONYMS This section was developed based on the information presented in Appendices A and B of NEI 99-01, Rev. 6. The list incorporates only those acronyms used in the DAEC PD EAL Technical Bases Document.

The following definitions, included in NEI 99-01, Rev. 6, were excluded because they are not used in the DAEC PD EAL Technical Bases Document:

o General Emergency o Site Area Emergency

The following key term necessary for overall understanding of the NEI 99-01 emergency classification scheme was excluded because it was not used in the DAEC PD EAL Technical Bases Document:

o Fission Product Barrier Threshold

The key term, Initiating Condition (IC), was revised to change "four emergency classification levels" to "two emergency classification levels" because Site Area Emergency and General Emergency are not used in the DAEC PD EAL Technical Bases Document.

The key term, Emergency Classification Level, was revised to exclude reference to Site Area Emergency and General Emergency because they are not used in the DAEC PD EAL Technical Bases Document.

Selected terms used in IC and EAL statements are set in all capital letters (e.g., ALL CAPS).

These words are defined terms that have specific meanings as used in NEI 99-01, Rev. 6.

Definitions not used in the DAEC PD EAL Technical Bases Document were excluded.

The term "SAFETY SYSTEM" was excluded because only those systems required to maintain spent fuel cooling are necessary in the permanently shut down and defueled condition. These systems are not, by definition, SAFETY SYSTEMS.

7.0 DAEC TO NEI 99-01 EAL CROSS-REFERENCE There is no corresponding section included in NEI 99-01, Rev. 6. This section was added to facilitate association and location of a DAEC PD EAL within the Appendix C NEI 99-01, Rev. 6 IC/EAL identification scheme. Further information regarding the development of the DAEC PD EALs based on the NEI guidance can be found in the Recognition Category "PD" and "ISFSI" EAL Comparison Matrices in the Attachment 1 and 2 comparisons, respectively.

8.0 ATTACHMENTS 8.1 Attachment 1, Recognition Category PD EAL Bases

Attachment 1 of the DAEC PD EAL Technical Bases Document provides the PD IC/EALs and incorporates Appendix C of NEI 99-01, Rev. 6.

Reference to Section 3 of NEI 99-01, Rev. 6 was excluded.

References to Operating Modes were removed from Table PD-1.

The table included in Attachment 1, "Comparison of DAEC PD IC/EAL against NEI 99-01, Appendix C, Rev. 6 for Recognition Category PD," provides a comparison of the DAEC PD EALs against the corresponding information contained in NEI 99-01, Rev. 6.

8.2 Attachment 2, Recognition Category E EAL Basis

Attachment 2 of the DAEC PD EAL Technical Bases provides the ISFSI IC/EALs and incorporates Section 8 of NEI 99-01, Rev. 6.

Reference to Operating Mode was removed from Table E-1.

The table included in the Attachment 2, "Comparison of DAEC E IC/EAL against NEI 99-01, Rev. 6 for Recognition Category E," provides a comparison of the DAEC ISFSI EALs against the corresponding information contained in NEI 99-01, Rev. 6.

NEI 99-01 Sections Not Included The following sections of NEI 99-01, Rev. 6 were not included and references made to these sections were also removed:

Section 3, "Design of the NEI 99-01 Emergency Classification Scheme"

Section 4, "Site-Specific Scheme Development Guidance" The following sections of NEI 99-01, Rev. 6 were removed from the DAEC Permanently Defueled EAL matrix as these do not apply to a permanently defueled plant:

Section 6, Abnormal Rad Levels/Radiological Effluent ICs/EALs,

Section 7, Cold Shutdown/Refueling System Malfunction ICs/EALs,

Section 9, Fission Product Barrier ICs/EALs,

Section 10, Hazards and Other Conditions Affecting Plant Safety ICs/EALs, and

Section 11, System Malfunction ICs/EALs.

Attachment 1 Comparison of DAEC PD IC/EAL against NEI 99-01, Appendix C, Rev. 6 for Recognition Category PD

NEI 99-01 Rev 6 Appendix C Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for DAEC PD-AU1 PD-RU1 * "AU1" is replaced with "RU1"to better signify a ECL: Notification of Unusual Event ECL: Notification of Unusual Event radiological event and to maintain continuity with the Initiating Condition: Release of gaseous Initiating Condition: Release of gaseous or liquid radioactivity previous DAEC emergency or liquid radioactivity greater than 2 times greater than 2 times the ODAM limits for 60 minutes or longer. action level scheme.

the (site-specific effluent release controlling document) limits for 60 minutes

Replaced (1 or 2) with DAEC or longer. EA Ls.

Used generic term of "event" Operating Mode Applicability: Not instead of Unusual event to Applicable maintain continuity with previous DAEC emergency Example Emergency Action Levels: (1 Emergency Action Levels: action level scheme.

or 2)

Used 'applicable time limit' Notes: Notes: and 'specified time limit'

The Emergency Director should declare the

The Emergency Director should declare the event promptly upon instead of 60 minutes in the Unusual Event promptly upon determining determining that the applicable time has been exceeded, or will note to maintain continuity that 60 minutes has been exceeded, or will likely be exceeded. with previous DAEC likely be exceeded. emergency action level

If an ongoing release is detected and the release start time is scheme.

unknown, assume that the release duration has exceeded the

If an ongoing release is detected and the release start time is unknown, assume that specified time limit.

Inserted Offsite Dose Assessment Manual (ODAM) the release duration has exceeded 60 minutes.

If the effluent flow past an effluent monitor is known to have as the site specific effluent stopped due to actions to isolate the release path, then the release controlling

If the effluent flow past an effluent monitor is effluent monitor reading is no longer valid for classification document.

known to have stopped due to actions to purposes.

isolate the release path, then the effluent

Removed Operating Mode monitor reading is no longer valid for PD-RU1.1 Reading on ANY effluent radiation monitor greater than Applicability as it does not classification purposes. 2 times the alarm setpoint established by a current apply in a permanently radioactivity discharge permit for 60 minutes or longer. defueled condition.

1) Reading on ANY effluent radiation monitor greater than 2 times the alarm

Removed "Example" from Emergency Action Levels setpoint established by a current

NEI 99-01 Rev 6 Appendix C Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for DAEC radioactivity discharge permit for 60 PD-RU1.2 Sample analysis for a gaseous or liquid release as they are no longer minutes or longer. indicates a concentration or release rate greater than 2 examples.

times the ODAM limits for 60 minutes or longer.

(2) Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times the (site specific effluent release controlling document) limits for 60 minutes or longer NEI 99-01 Basis: DAEC Basis:

Added DAEC specific EAL basis information.

This IC addresses a potential decrease in This IC addresses a potential decrease in the level of safety of the the level of safety of the plant as indicated by a facility as indicated by a low-level radiological release that exceeds

Replaced "plant" with low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an "facility".

regulatory commitments for an extended period uncontrolled release). It includes any gaseous or liquid radiological of time (e.g., an uncontrolled release). It release, monitored or un-monitored, including those for which a includes any gaseous or liquid radiological radioactivity discharge permit is normally prepared.

release, monitored or un-monitored, including those for which a radioactivity discharge permit DAEC incorporates design features intended to control the release is normally prepared. of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, Nuclear power plants incorporate design and to control and monitor intentional releases. The occurrence of features intended to control the release of an extended, uncontrolled radioactive release to the environment is radioactive effluents to the environment. indicative of degradation in these features and/or controls.

Further, there are administrative controls established to prevent unintentional releases, Radiological effluent EALs are also included to provide a basis for and to control and monitor intentional releases. classifying events and conditions that cannot be readily or The occurrence of an extended, uncontrolled appropriately classified on the basis of facility conditions alone. The radioactive release to the environment is inclusion of both facility condition and radiological effluent EALs indicative of degradation in these features more fully addresses the spectrum of possible accident events and and/or controls. conditions.

Radiological effluent EALs are also included to Classification based on effluent monitor readings assumes that a provide a basis for classifying events and release path to the environment is established. If the effluent flow conditions that cannot be readily or past an effluent monitor is known to have stopped due to actions to appropriately classified on the basis of plant isolate the release path, then the effluent monitor reading is no conditions alone. The inclusion of both plant longer valid for classification purposes.

condition and radiological effluent EALs more

NEI 99-01 Rev 6 Appendix C Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for DAEC fully addresses the spectrum of possible Releases should not be prorated or averaged. For example, a accident events and conditions. release exceeding 4 times release limits for 30 minutes does not meet the EAL.

Classification based on effluent monitor readings assumes that a release path to the EAL PD-RU1 .1 - This EAL addresses radioactivity releases that environment is established. If the effluent flow cause effluent radiation monitor readings to exceed 2 times the limit past an effluent monitor is known to have established by a radioactivity discharge permit. This EAL will stopped due to actions to isolate the release typically be associated with planned batch releases from non-path, then the effluent monitor reading is no continuous release pathways (e.g., radwaste, waste gas).

longer valid for classification. purposes.

EAL PD-RU1 .2 - This EAL addresses uncontrolled gaseous or liquid Releases should not be prorated or averaged. releases that are detected by sample analysis or environmental For example, exceeding 4 times release limits surveys, particularly on unmonitored pathways (e.g., spills of for 30 minutes does not meet the EAL. radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).

EAL #1 - This EAL addresses radioactivity releases that cause effluent radiation monitor Escalation of the emergency classification level would be via IC PD-readings to exceed 2 times the limit RA1.

established by a radioactivity discharge permit.

This EAL will typically be associated with planned batch releases from non-continuous release pathways (e.g.,radwaste, waste gas).

EAL #2 - This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g.,

spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).

Escalation of the emergency classification level would be via IC PD-AA 1.

PD-AA1 PD-RA1 * "AA1 is replaced with ff "RA 1 to better signify a ff ECL: Alert ECL: Alert radiological event and to Initiating Condition: Release of gaseous or Initiating Condition: Release of gaseous or liquid maintain continuity with the liquid radioactivity resulting in offsite dose radioactivity resulting in offsite dose greater than 10 mRem previous DAEC action level qreater than 10 mRem TEDE or 50 mRem TEDE or 50 mRem thyroid CDE. scheme.

NEI 99-01 Rev 6 Appendix C Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for DAEC thyroid COE.

Replaced (1 or 2 or 3 or 4)

Operating Mode Applicability: Not with DAEC EALs.

Applicable Example Emergency Action Levels: (1 or Emergency Action Levels:

Removed Operating 2 or 3 or 4) Mode Applicability as it does not apply in a Notes: permanently defueled Notes:

The Emergency Director should condition.

declare the Alert promptly upon

The Emergency Director should declare the Alert promptly upon determining that the applicable time has been exceeded

Removed "Example" from determining that the applicable time or will likely be exceeded. ' Emergency Action Levels as has been exceeded, or will likely be exceeded. If an ongoing release is detected and the release start time is they are no longer examples.

unknown, assume that the release duration has exceeded the

If an ongoing release is detected and specified time limit

Used 'the specified time limit' the release start time is unknown, instead of 15 minutes to assume that the release duration has

If the effluent flow past an effluent monitor is known to have maintain continuity with exceeded 15 minutes. stopped due to actions to isolate the release path, then the previous DAEC emergency effluent monitor reading is no longer valid for classification action level scheme .

If the effluent flow past an effluent monitor purposes.

is known to have stopped due to actions to isolate the release path, then the

The pre-calculated effluent monitor values presented in Table R-

Included Table R-1 in the 1 should be used for emergency classification assessments until notes instead of 'EAL #1' to effluent monitor reading is no longer valid maintain continuity with the results from a dose assessment using actual meteorology for classification purposes. existing DAEC EAL scheme.

are available.

The pre-calculated effluent monitor values

Added site-specific monitor presented in EAL #1 should be used for list and table with PD-RA1.1 Reading on ANY Table R-1 effluent radiation monitor threshold values.

emergency classification assessments until greater than column "Alert" for 15 minutes or longer:

the results from a dose assessment using

Added SITE BOUNDARY actual meteorology are available. PD-RA1.2 Dose assessment using actual meteorology indicates as the site specific dose doses greater than 10 mrem TEDE or 50 mrem thyroid receptor point.

1) Reading on ANY of the COE at or beyond SITE BOUNDARY.

following radiation monitors greater than the reading shown PD-RA 1.3 Analysis of a liquid effluent sample indicates a for 15 minutes or longer: (site- concentration or release rate that would result in doses specific monitor list and greater than 10 mrem TEDE or 50 mrem thyroid COE at threshold values) or beyond the SITE BOUNDARY for one hour of exposure.

2) Dose assessment usinQ actual

NEI 99-01 Rev 6 Appendix C Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for DAEC meteorology indicates doses greater than 10 mRem TEDE or 50 mRem PD-RA 1.4 Field survey results indicate EITHER of the following at thyroid COE at or beyond (site- or beyond the SITE BOUNDARY:

specific dose receptor point).

Closed window dose rates greater than 10 mR/hr

3) Analysis of a liquid effluent sample expected to continue for 60 minutes or longer.

indicates a concentration or release

Analyses of field survey samples indicate thyroid rate that would result in doses COE greater than 50 mrem for one hour of inhalation .

greater than 1O mRem TEDE or 50 mRem thyroid COE at or beyond Table R Effluent Monitor Classification Thresholds (site-specific dose receptor point) for Monitor :i~iiS:Sllli! 11.~lli Alert ;:~i.h:~:,,

one hour of exposure. Reactor Building ,w.m;i~*m-o*--* *d** .. m~*"*i.:;.,,. ' *.. ~........... ,: ._*., .*. *

4) Field survey results indicate Cl) ventilation rad 1.1E-02 uci/cc EITHER of the following at or 5 monitor (Kaman

~ 3/4, 5/6, 718 beyond (site-specific dose receptor cu LLRPSF rad point): 0 monitor 1.4E-02 uci/cc Kaman 12

Closed window dose rates greater GSW rad monitor than 10 mR/hr expected to continue 1.7E+04 cps (RIS-4767) for 60 minutes or longer. -o RHRSW & ESW

s rad monitor 1.2E+04 cps

Analyses of field survey samples indicate .2" RM-1997

_J !--'-~~~~~~--+

thyroid COE greater than 50 mRem for RHRSW&ESW one hour of inhalation . Rupture Disc rad 1.8E+04 cps monitor !RM-4268 NEI 99-01 Basis: DAEC Basis

Added definition of SITE BOUNDARY.

This IC addresses a release of gaseous or Definitions:

liquid radioactivity that results in projected or

Added note stated that the SITE BOUNDARY: That line beyond which the land is neither actual offsite doses greater than or equal to IC is modified for EAL RA 1.1 owned , nor leased , nor otherwise controlled by the licensee.

1% of the EPA PAGs. It includes both as this is only assessed for monitored and un-monitored releases. Basis: emergency classification Releases of th is magnitude represent an This IC addresses a release of gaseous or liquid radioactivity that until a qualified dose actual or potential substantial degradation of results in oroiected or actual offsite doses areater than or eaual to assessor is performing

NEI 99-01 Rev 6 Appendix C Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for DAEC the level of safety of the plant as indicated by 1% of the EPA Protective Action Guides (PAGs). It includes both assessments using dose a radiological release that significantly monitored and un-monitored releases. Releases of this magnitude projection software exceeds regulatory limits (e.g., a significant represent an actual or potential substantial degradation of the level incorporating actual uncontrolled release). of safety of the facility as indicated by a radiological release that meteorological data and significantly exceeds regulatory limits (e.g., a significant current radiological Radiological effluent EALs are also included uncontrolled release). conditions which is to provide a basis for classifying events and consistent with current conditions that cannot be readily or This IC is modified by a note that EAL RA 1.1 is only assessed for DAEC EAL scheme.

appropriately classified on the basis of plant emergency classification until a qualified dose assessor is performing conditions alone. The inclusion of both plant assessments using dose projection software incorporating actual

Replaced "plant" with condition and radiological effluent EALs meteorological data and current radiological conditions. "facility".

more fully addresses the spectrum of possible accident events and conditions. Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or The TEDE dose is set at 1% of the EPA appropriately classified on the basis of facility conditions alone.

PAG of 1,000 mRem while the 50 mRem The inclusion of both facility condition and radiological effluent thyroid COE was established in EALs more fully addresses the spectrum of possible accident consideration of the 1:5 ratio of the EPA events and conditions.

PAG for TEDE and thyroid COE.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while Classification based on effluent monitor the 50 mrem thyroid COE was established in consideration of the readings assumes that a release path to the 1:5 ratio of the EPA PAG for TEDE and thyroid COE.

environment is established. If the effluent flow past an effluent monitor is known to have Classification based on effluent monitor readings assumes that a stopped due to actions to isolate the release release path to the environment is established. If the effluent flow path, then the effluent monitor reading is no past an effluent monitor is known to have stopped due to actions to longer valid for classification purposes. isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

PD-AU2 PD-RU2

AU2" is replaced with "RU2" to better signify a radiological ECL: Notification of Unusual Event ECL: Notification of Unusual Event event and to maintain Initiating Condition: UNPLANNED rise Initiating Condition: UNPLANNED rise in facility radiation continuity with the previous in plant radiation levels. levels. DAEC action level scheme.

Operating Mode Applicability: Not Applicable

Replaced (1 or 2) with DAEC Example Emergency Action Levels: (1 or 2) Emergency Action Levels: EA Ls.

(1) a. UNPLANNED water level drop in the PD-RU2.1

NEI 99-01 Rev 6 Appendix C Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for DAEC spent fuel pool as indicated by ANY of a. UNPLANNED water level drop in the spent fuel pool as

Removed Operating Mode the following: indicated by ANY of the following: Applicability as it does not (Site specific level indications).

Report to control room (visual observation) apply in a permanently

Fuel pool level indication (Ll-3413) less than 36 feet and defueled condition .

AND lowering

Removed "Example" from

b. UNPLANNED rise in area radiation AND Emergency Action Levels as levels as indicated by ANY of the b. UNPLANNED rise in area radiation levels as indicated by they are no longer examples.

following radiation monitors:

ANY of the following radiation monitors.

Added DAEC specific EAL (Site specific level indications). basis information.

Spent Fuel Pool Area, Rl-9178 (2) Area radiation monitor reading or survey

North Refuel Floor, Rl-9163

Added site-specific monitor result indicates an UNPLANNED rise of 25

_New Fuel Vault Area, Rl-9153 list and threshold values.

mR/hr over NORMAL LEVELS.

South Refuel Floor, Rl-9164

Replaced "plant" with PD-RU2.2 Area radiation monitor reading or survey result indicates "facility".

an UNPLANNED rise of 25 mR/hr over NORMAL LEVELS NEI 99-01 Basis: DAEC Basis:

Added definitions for UNPLANNED and NORMAL This IC addresses elevated plant radiation Definitions:

LEVELS.

levels caused by a decrease in water level UNPLANNED: A parameter change or an event that is not 1) the above irradiated (spent) fuel or other

Added DAEC site-specific result of an intended evolution or 2) an expected facility response UNPLANNED events. The increased radiation basis information, to a transient. The cause of the parameter change or event may levels are indicative of a minor loss in the instrumentation and be known or unknown.

ability to control radiation levels within the documented references.

plant or radioactive materials. Either condition NORMAL LEVELS: As applied to radiological IC/EALs, the highest is a potential degradation in the level of safety reading in the past

Added an example for a of the plant. twenty-four hours excluding the current peak value. planned evolution (Refuel bridge area radiation A water level decrease will be primarily Basis: monitor).

determined by indications from available level This IC addresses elevated facility radiation levels caused by a instrumentation. Other sources of level

Replaced "plant" with indications may include reports from plant decrease in water level above irradiated (spent) fuel or other "facility".

personnel or video camera observations (if UNPLANNED events. The increased radiation levels are indicative available). A significant drop in the water level of a minor loss in the ability to control radiation levels within the may also cause an increase in the radiation facility or radioactive materials. Either condition is a potential levels of adjacent areas that can be detected degradation in the level of safety of the facility.

NEI 99-01 Rev 6 Appendix C Proposed Permanently Defueled Comparison

Permanently Defueled Station ICs/EALs EAL for DAEC by monitors in those locations. A water level decrease will be primarily determined by indications from available level instrumentation. Other sources of level The effects of planned evolutions should be indications may include reports from facility personnel or video considered. Note that EAL #1 is applicable camera observations (if available). A significant drop in the water only in cases where the elevated reading is level may also cause an increase in the radiation levels of adjacent due to an UNPLANNED water level drop.

areas that can be detected by monitors in those locations.

EAL #2 excludes radiation level increases The effects of planned evolutions should be considered. For that result from planned activities such as example, a refueling bridge area radiation monitor reading may use of radiographic sources and movement increase due to planned evolutions such as movement of a fuel of radioactive waste materials.

assembly. Note that this RU2.1 is applicable only in cases where Escalation of the emergency classification level the elevated reading is due to an UNPLANNED water level drop.

would be via IC PD-AA 1 or PD-AA2. RU2.2 excludes radiation level increases that result from planned activities such as use of radiographic sources and movement of radioactive waste materials.

DAEC Technical Specifications require a minimum of 36 feet of water in the spent fuel pool. The spent fuel pool level indicator LI-3413 is used to monitor refueling water level. Procedures require that a normal refueling water level be maintained at 37 feet 5 inches.

A low level alarm actuates when spent fuel pool level drops below 37 feet 1 inch. Symptoms of inventory loss at DAEC include visual observation of decreasing water levels in the spent fuel storage pool, Reactor Building (RB) fuel storage pool radiation monitor or refueling area radiation monitor alarms, observation of a decreasing trend on the spent fuel pool water level indicator, and actuation of the spent fuel pool low water level alarm. To eliminate minor level perturbations from concern, DAEC uses Ll-3413 indicated water level below 36 feet and lowering.

Escalation of the emergency classification level would be via IC PD-RA 1 and PD-RA2.

NEI 99-01 Rev 6 Appendix C Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for DAEC PD-AA2 PD-RA2

AA2" is replaced with "RA2" ECL: Alert ECL: Alert to better signify a radiological event and to maintain Initiating Condition: UNPLANNED rise in Initiating Condition: UNPLANNED rise in facility radiation levels continuity with the previous plant radiation levels that impedes plant that impedes plant access required to maintain spent fuel integrity. DAEC action level scheme.

access required to maintain spent fuel integrity.

Replaced (1 or 2) with DAEC EALs.

Operating Mode Applicability: Not Applicable

Removed Operating Mode Example Emergency Action Levels: (1 or 2) Emergency Action Levels: Applicability as it does not (1) UNPLANNED dose rate greater than PD-RA2.1 UNPLANNED dose rate greater than 15 mR/hr in ANY apply in a permanently 15 mR/hr in ANY of the following areas of the following areas requiring continuous occupancy defueled condition.

requiring continuous occupancy to maintain to maintain control of radioactive material or operation

Removed "Example" from control of radioactive material or operation of of systems needed to maintain spent fuel integrity. Emergency Action Levels as systems needed to maintain spent fuel no longer example.

integrity:

Control Room (RM-9162)

Central Alarm Station (by survey)

Added site specific areas.

(site-specific area list)

(2) UNPLANNED Area Radiation Monitor OR

Replaced "plant" with readings or survey results indicate a rise by PD-RA2.2 UNPLANNED Area Radiation Monitor readings or "facility".

100 mR/hr in ANY of the following areas survey results indicate a rise by 100 mR/hr over needed to maintain control of radioactive NORMAL LEVELS that impedes access to ANY of the material or operation of systems needed to following areas needed to maintain control of maintain spent fuel integrity. radioactive material or operation of systems needed (site specific area list) to maintain spent fuel integrity.

Spent fuel pool pump area (by survey)

NEI 99-01 Basis: DAEC Basis:

Added definitions for UNPLANNED and NORMAL This IC addresses increased radiation levels Definitions:

LEVELS.

that impede necessary access to areas containing equipment that must be operated UNPLANNED: A parameter change or an event that is not 1) the

Replaced "plant" with manually or that requires local monitoring, in result of an intended evolution or 2) an expected facility response "facility".

order to maintain systems needed to maintain to a transient. The cause of the parameter change or event may spent fuel integrity. As used here, 'impede' be known or unknown.

NEI 99-01 Rev 6 Appendix C Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for DAEC includes hindering or interfering, provided that NORMAL LEVELS: As applied to radiological IC/EALs, the highest the interference or delay is sufficient to reading in the past twenty-four hours excluding the current peak significantly threaten necessary plant access. It value.

is this impaired access that results in the actual Basis:

or potential substantial degradation of the level of safety of the plant. This IC addresses increased radiation levels that impede necessary access to areas containing equipment that must be operated This IC does not apply to anticipated temporary manually or that requires local monitoring, in order to maintain increases due to planned events.

systems needed to maintain spent fuel integrity. As used here,

'impede' includes hindering or interfering, provided that the interference or delay is sufficient to significantly threaten necessary facility access. It is this impaired access that results in the actual or potential substantial degradation of the level of safety of the facility.

This IC does not apply to anticipated temporary access due to planned events.

PD-HU1 PD-HU1

Replaced (1 or 2 or 3) with DAEC EALs.

ECL: Notification of Unusual Event ECL: Notification of Unusual Event Initiating Condition: Confirmed

Removed Operating Mode Initiating Condition: Confirmed SECURITY CONDITION or threat. Applicability as it does not SECURITY CONDITION or threat.

apply in a permanently Operating Mode Applicability: Not Applicable defueled condition.

Example Emergency Action Levels: (1 or Emergency Action Levels:

2 or 3)

PD-HU1.1 A SECURITY CONDITION that does not involve a

1. A SECURITY CONDITION that does not HOSTILE ACTION as reported by DAEC Security Shift involve a HOSTILE ACTION as reported Supervision.

by the (site-specific security shift supervision). PD-HU1.2 Notification of a credible security threat directed at DAEC.

2. Notification of a credible security threat directed at the site. PD-HU1.3 A validated notification from the NRC providing information of an aircraft threat.

3. A validated notification from the NRC providinQ information of an aircraft threat.

NEI 99-01 Rev 6 Appendix C Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for DAEC NEI 99-01 Basis: DAEC Basis:

Added definitions for This IC addresses events that pose a threat to HOSTAGE, HOSTILE Definitions:

plant personnel or the equipment necessary to ACTION, PROJECTILE, and

~OSTILE ACTION: An act toward a facility or its personnel that SECURITY CONDITION.

maintain cooling of spent fuel, and thus represent a potential degradation in the level includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This

DAEC Security Shift of plant safety. Security events which do not Supervision is the site-meet one of these EALs are adequately includes attack by air, land, or water using guns, explosives, specific security shift addressed by the requirements of 10 CFR § PROJECTILES, vehicles, or other devices used to deliver supervision.

73.71 or 10 CFR § 50.72. Security events ?estructive force. Other acts that satisfy the overall intent may be assessed as HOSTILE ACTIONS are included. HOSTILE ACTION should not be construed to include

Added AOP 914, Security classifiable under IC PD-HA 1. acts of civil disobedience or felonious acts that are not part of a Events as this is DAEC concerted attack on the facility. Non-terrorism-based EALs should specific procedure.

Timely and accurate communications be used to address such activities (i.e., this may include violent between Security Shift Supervision and the acts between individuals in the owner controlled area).

Replaced "plant" with Control Room is essential for proper "facility".

classification of a security-related event. PROJECTILE: an object directed toward a facility that could cause Classification of these events will initiate concern for its continued operability, reliability, or personnel appropriate threat-related notifications to safety.

plant personnel and OROs. SECURITY CONDITION: Any Security Event as listed in the Security plans and terminology are based on approved security contingency plan that constitutes a the guidance provided by NEI 03-12, threat/compromise to site security, threat/risk to site personnel Template for the Security Plan, Training and or a potential degradation to the level of safety of the facility. A '

Qualification Plan, Safeguards Contingency SECURITY CONDITION does not involve a HOSTILE ACTION.

Plan [and Independent Spent Fuel Storage Basis:

Installation Security Program].

This IC .addresses events that pose a threat to facility personnel or This EAL references (site-specific security the equipment necessary to maintain cooling of spent fuel, and shift supervision) because these are the thus represent a potential degradation in the level of facility safety.

individuals trained to confirm that a security Security events which do not meet one of these EALs are event is occurring or has occurred. Training adequately addressed by the requirements of 10 CFR § 73.71 or on security event confirmation and 10 CFR § 50.72. Security events assessed as HOSTILE classification is controlled due to the nature ACTIONS are classifiable under IC PD-HA 1.

of Safeguards and 10 CFR § 2.390 information. Timely ~~d accurate communications between Security Shift Supe'.'.'1s1~n and the Control Room is essential for proper class1f1cat1on of a securitv-related event. Classification of these

NEI 99-01 Rev 6 Appendix C Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for DAEC events will initiate appropriate threat-related notifications to facility personnel and Off- Site Response Organizations.

Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

PD-HU1.1 references DAEC Security Shift Supervision because these are the individuals trained to confirm that a security event is occurring or has occurred. Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR § 2.390 information PD-HU1 .2 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with Abnormal Operating Procedure (AOP) 914, Security Events.

PD-HU 1.3 addresses the threat from the impact of an aircraft on the facility. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may also be provided by NORAD through the NRC. Validation of the threat is performed in accordance with AOP 914, Security Events.

Escalation of the emergency classification level would be via IC PD-HA1.

PD-HA1 PD-HA1

Removed Operating Mode Applicability as it does not ECL: Alert ECL: Alert apply in a permanently Initiating Condition: HOSTILE ACTION Initiating Condition: HOSTILE ACTION within the OWNER defueled condition.

within the OWNER CONTROLLED AREA or CONTROLLED AREA or airborne attack threat within 30 airborne attack threat within 30 minutes. minutes.

Replaced (1 or 2) with DAEC EA Ls.

Operating Mode Applicability: Not Applicable Example Emergency Action Levels: (1 or 2) Emergency Action Levels:

Removed "Example" from Emergency Action Levels as (1) A HOSTILE ACTION is occurrinq or PD-HA1.1 A HOSTILE ACTION is occurring or has occurred no longer example.

NEI 99-01 Rev 6 Appendix C Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for DAEC has occurred within the OWNER within the OWNER CONTROLLED AREA as reported

Security Shift Supervisor is CONTROLLED AREA as reported by the Security Shift Supervisor. provided as the site-specific by the (site-specific security shift security shift supervision.

PD-HA 1.2 A validated notification from NRC of an aircraft attack supervision).

threat within 30 minutes of the site.

(2) A validated notification from NRC of an aircraft attack threat within 30 minutes of the site NEI 99-01 Basis: DAEC Basis:

Added the definitions for HOSTAGE, HOSTILE This IC addresses the occurrence of a Definitions:

ACTION, HOSTILE FORCE, HOSTILE ACTION within the OWNER HOSTAGE: A person(s) held as leverage against the licensee to OWNER CONTROLLED CONTROLLED AREA or notification of an ensure that demands will be met by the facility. AREA (OCA), PROJECTILE, aircraft attack threat. This event will require and PROTECTED AREA rapid response and assistance due to the HOSTILE ACTION: An act toward a facility or its personnel that possibility of the attack progressing to the includes the use of violent force to destroy equipment, take

Added DAEC to Security PROTECTED AREA HOSTAGES, and/or intimidate the licensee to achieve an end. This Shift Supervision.

Timely and accurate communications includes attack by air, land, or water using guns, explosives,

Added (OROs) for between Security Shift Supervision and the PROJECTILES, vehicles, or other devices used to deliver .

abbreviation of Offsite Control Room is essential for proper destructive force. Other acts that satisfy the overall intent may be Response Organizations.

classification of a security- related event. included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a

Defined the location of the Security plans and terminology are based on concerted attack on the facility. Non-terrorism-based EALs should ISFSI to outside of the the guidance provided by NEI 03-12, be used to address such activities (i.e., this may include violent protected area.

Template for the Security Plan, Training and acts between individuals in the owner controlled area).

Qualification Plan, Safeguards Contingency

Added Site specific Plan [and Independent Spent Fuel Storage HOSTILE FORCE: One or more individuals who are engaged in procedure AOP 914, Installation Security Program]. a determined assault, overtly or by stealth and deception, equipped Security Events.

with suitable weapons capable of killing, maiming, or causing As time and conditions allow, these events destruction.

Replaced "plant" with require a heightened state of readiness by "facility".

the plant staff and implementation of onsite OWNER CONTROLLED AREA (OCA): The property protective measures (e.g., evacuation, associated with the facility and owned by the licensee. Access dispersal or sheltering). The Alert declaration is normally limited to persons entering for official business.

will also heighten the awareness of Offsite Response Organizations, allowing them to be PROJECTILE: An object directed toward a facility that could cause better prepared should it be necessary to concern for its continued operability, reliability, or personnel safety.

NEI 99-01 Rev 6 Appendix C Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for DAEC consider further actions.

This IC does not apply to incidents that are PROTECTED AREA: The area normally within the facility security accidental events, acts of civil disobedience, or fence designated to implement the security requirements of 10 otherwise are not a HOSTILE ACTION CFR 73 perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from Basis:

hunters, physical disputes between employees, This IC addresses the occurrence of a HOSTILE ACTION within etc. Reporting of these types of events is the OWNER CONTROLLED AREA or notification of an aircraft adequately addressed by other EALs, or the attack threat. This event will require rapid response and assistance requirements of 10 CFR § 73.71 or 10 CFR § due to the possibility of the attack progressing to the PROTECTED 50.72. - AREA, or the need to prepare the facility and staff for a potential aircraft impact.

EAL #1 is applicable for any HOSTILE ACTION occurring, or that has occurred, in the Timely and accurate communication between DAEC Security Shift OWNER CONTROLLED AREA. This includes Supervision and the Control Room is essential for proper any action directed against an ISFSI that is classification of a security-related event.

located within the OWNER CONTROLLED AREA. Security plans and terminology are based on the guidance EAL #2 addresses the threat from the impact of provided by NEI 03-12, Template for the Security Plan, Training an aircraft on the plant, and the anticipated and Qualification Plan, Safeguards Contingency Plan [and arrival time is within 30 minutes. The intent of Independent Spent Fuel Storage Installation Security Program].

this EAL is to ensure that threat-related notifications are made in a timely manner so As time and conditions allow, these events require a heightened that plant personnel and OROs are in a state of readiness by the facility staff and implementation of onsite heightened state of readiness. This EAL is met protective measures (e.g., evacuation, dispersal or sheltering).

when the threat-related information has been The Alert declaration will also heighten the awareness of Offsite validated in accordance with (site-specific Response Organizations (OROs), allowing them to be better procedure). prepared should it be necessary to consider further actions.

The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the This IC does not apply to incidents that are accidental events, threat involves an aircraft. The status and size acts of civil disobedience, or otherwise are not a HOSTILE of the plane may be provided by NORAD ACTION perpetrated by a HOSTILE FORCE. Examples include through the NRC. the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is In some cases, it may not be readily apparent if adequately addressed by other EALs, or the requirements of 10 an aircraft impact within the OWNER CFR § 73.71 or 10 CFR § 50.72 CONTROLLED AREA was intentional (i.e., a

NEI 99-01 Rev 6 Appendix C Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for DAEC HOSTILE ACTION). It is expected, although EAL PD-HA 1.1 is applicable for any HOSTILE ACTION occurring, not certain, that notification by an appropriate or that has occurred, in the OWNER CONTROLLED AREA. This Federal agency to the site would clarify this includes any action directed against the ISFSI which is located point. In this case, the appropriate federal outside the facility PROTECTED AREA.

agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including EAL PD-HA 1.2 addresses the threat from the impact of an aircraft one based on other ICs/EALs, should not be on the facility, and the anticipated arrival time is within 30 minutes.

unduly delayed while awaiting notification,by a The intent of this EAL is to ensure that threat- related Federal agency. notifications are made in a timely manner so that onsite personnel and OROs are in a heightened state of readiness.

Emergency plans and implementing This EAL is met when the threat-related information has been procedures are public documents; therefore, validated in accordance with Abnormal Operating Procedure (AOP) 914, EALs should not incorporate Security-sensitive Security Events.

information. This includes information that may be advantageous to a potential adversary, The NRC Headquarters Operations Officer (HOO) will such as the particulars concerning a specific communicate to the licensee if the threat involves an aircraft. The threat or threat location. Security-sensitive status and size of the plane may be provided by NORAD through information should be contained in non-public the NRC.

documents such as the Security Plan.

In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan.

NEI 99-01 Rev 6 Appendix C Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for DAEC PD-HU2 PD-HU2

Inserted Table H-1 ECL: Notification of Unusual Event ECL: Notification of Unusual Event Hazardous Events.

Initiating Condition: Hazardous event Initiating Condition: Hazardous event affecting equipment

Replaced (1 ) with DAEC affecting SAFETY SYSTEM equipment necessary for spent fuel cooling . EAL number.

necessary for spent fuel cooling.

Removed "SAFETY Operating Mode Applicability: Not SYSTEM" as the term is not Applicable applicable in the permanently shut down and Example Emergency Action Levels: Emergency Action Levels: defueled condition .

(1) a. The occurrence of ANY of the PD-HU2.1 a. The occurrence of ANY of the Table H-1 hazardous

Removed Operating Mode following hazardous events: events Applicability as it does not

Seismic event (earthquake) Table H-1 Hazardous Events apply in a permanently

Internal or external flooding defueled cond ition .

Seismic Event (earthquake) event

High winds or tornado strike

Internal or external flooding event

FIRE

High winds of tornado strike

EXPLOSION

FIRE

(site-specific hazards)

EXPLOSION

Other events with similar hazard characteristics as

Other events with similar hazard determined by the Shift characteristics as determined by the Manager Shift Manager or Emergency Director AND

b. The event has damaged at least AND one train of a SAFETY SYSTEM needed for spent fuel cooling. b. The event has damaged at least one train of a system needed for spent fuel cooling .

AND The damaged SAFETY SYSTEM AND train(s) cannot, or potentially cannot, perform its design function c. The damaged equipment cannot, or potentially based on cannot, perform its design function on EITHER:

EITHER:

Indications of degraded performance

Indications of degraded

VISIBLE DAMAGE

NEI 99-01 Rev 6 Appendix C Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for DAEC performance

VISIBLE DAMAGE NEI 99-01 Basis: DAEC Basis

Added definitions for This IC addresses a hazardous event that EXPLOSION, FIRE, and Definitions:

VISIBLE DAMAGE.

causes damage to at least one train of a SAFETY SYSTEM needed for spent fuel EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction, or

Replaced "SAFETY cooling. The damage must be of sufficient SYSTEM" with "equipment."

magnitude that the system(s) train cannot, or overpressurization. A release of steam (from high energy lines or potentially cannot, perform its design function. components) or an electrical component failure (caused by short

The designation "AA" is This condition reduces the margin to a loss or circuits, grounding, arcing, etc.) should not automatically be revised to "RA" to better potential loss of the fuel clad barrier, and considered an explosion. Such events may require a post-event signify radioactivity and to therefore represents a potential degradation inspection to determine if the attributes of an explosion are present. maintain continuity with the of the level of safety of the plant. FIRE: Combustion characterized by heat and light. Sources of previous DAEC action level smoke such as slipping drive belts or overheated electrical scheme.

For EAL 1.c, the first bullet addresses damage to a SAFETY SYSTEM train that is equipment do not constitute FIRES. Observation of flame is

Replaced "plant" with in service/operation since indications for it preferred but is NOT required if large quantities of smoke and heat "facility".

will be readily available. are observed.

For EAL 1.c, the second bullet addresses VISIBLE DAMAGE: Damage to a component or structure that is r~adily_ observable without measurements, testing, or analysis. The damage to a SAFETY SYSTEM train that is not in service/operation or readily apparent visual impact of the damage is sufficient to cause concern regarding through indications alone. Operators will the operability or reliability of the affected component or structure.

make this determination based on the Damage resulting from an equipment failure and limited to the failed totality of available event and damage component (i.e., the failure did not cause damage to a structure or report information. This is intended to be a any other equipment) is not VISIBLE DAMAGE.

brief assessment not requiring lengthy Basis:

analysis or quantification of the damage This IC addresses a hazardous event that causes damage to at least one train of equipment needed for spent fuel cooling. The damage must be of sufficient magnitude that the system(s) train cannot, or potentially cannot, perform its intended function. This condition reduces the margin to a loss or potential loss of the fuel clad barrier, and therefore, represents a potential degradation of the level of safety of the facility.

NEI 99-01 Rev 6 Appendix C Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for DAEC For EAL PD-HU2.1c., the first bullet addresses damage to equipment that is in service/operation since indications for it will be readily available.

For EAL PD-HU2.1c., the second bullet addresses damage to equipment that is not in service/operation or readily apparent through indications alone. Operators will make this determination based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.

Escalation of the emergency classification level could, depending on the event, be based on any of the Alert !Cs; PD-RA 1, PD-RA2, PD-HA1 or PD-HA3 PD-HU3 PD-HU3

Removed Operating Mode Applicability as it does not ECL: Notification of Unusual Event ECL: Unusual Event apply in a permanently Initiating Condition: Other conditions exist Initiating Condition: Other conditions exist which in the defueled condition.

which in the judgment of the Emergency judgment of the Emergency Director warrant declaration of an Director warrant declaration of a (NO)UE. Unusual Event.

Removed "Example" from Emergency Action Levels as Operating Mode Applicability: Not no longer example.

Applicable

Replaced (1) with DAEC Example Emergency Action Levels: Emergency Action Levels: EAL number.

(1) Other conditions exist which in the judgment of the Emergency Director PD-HU3.1 Other conditions exist which in the judgment of the

Replaced "SAFETY indicate that events are in progress or Emergency Director indicate that events are in progress SYSTEMS" with "systems have occurred which indicate a or have occurred which indicate a potential degradation needed to maintain spent potential degradation of the level of of the level of safety of the plant or indicate a security fuel cooling."

safety of the plant or indicate a security threat to plant protection has been initiated. No releases threat to plant protection has been of radioactive material requiring offsite response or initiated. No releases of radioactive monitoring are expected unless further degradation of material requiring offsite response or systems needed to maintain spent fuel cooling occurs.

monitoring are expected unless further degradation of safety systems occurs.

NEI 99-01 Rev 6 Appendix C Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for DAEC NEI 99-01 Basis: DAEC Basis This IC addresses unanticipated conditions Basis:

not addressed explicitly elsewhere but that warrant declaration of an emergency because This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the conditions exist which are believed by the Emergency Director to fall emergency classification level description for under the emergency classification level description for a NOUE.

an Unusual Event.

PD-HA3 PD-HA3

Replaced (1) with DAEC EAL number.

ECL: Alert ECL: Alert Initiating Condition: Other conditions Initiating Condition: Other conditions exist which in the

Removed Operating Mode exist which in the judgment of the judgment of the Emergency Director warrant declaration of an Applicability as it does not Emergency Director warrant declaration of Alert. apply in a permanently an Alert. defueled condition.

Operating Mode Applicability: Not Applicable Emergency Action Levels:

Example Emergency Action Levels:

PD-HA3.1 Other conditions exist which in the judgment of the

( 1) Other conditions exist which in the Emergency Director indicate that events are in progress or have judgment of the Emergency Director occurred which involve an actual or potential substantial degradation indicate that events are in progress or of the level of safety of the plant or a security event that involves have occurred which involve an actual probable life threatening risk to site personnel or damage to site or potential substantial degradation of equipment because of HOSTILE ACTION. Any releases are the level of safety of the plant or a expected to be limited to small fractions of the EPA Protective Action security event that involves probable Guideline exposure levels.

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.

NEI 99-01 Rev 6 Appendix C Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for DAEC NEI 99-01 Basis: DAEC Basis

Added definitions for HOSTAGE, HOSTILE This IC addresses unanticipated conditions not Definitions:

ACTION, PROJECTILE.

addressed explicitly elsewhere but that warrant declaration of an emergency because HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.

conditions exist which are believed by the Emergency Director to fall under the HOSTILE ACTION: An act toward DAEC or its personnel that emergency classification level description for includes the use of violent force to destroy equipment, take an Alert. HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the nuclear power plant. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).

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

Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an Alert.

PD-SU1 PD-SU1

Replaced (1) with DAEC EAL number.

ECL: Notification of Unusual Event ECL: Unusual Event Initiating Condition: UNPLANNED spent Initiating Condition: UNPLANNED spent fuel pool

Added site-specific DAEC fuel pool temperature rise. temperature rise. fuel pool temperature number.

Operating Mode Applicability: Not Applicable

Removed Operating Mode Applicability as it does not

NEI 99-01 Rev 6 Appendix C Proposed Permanently Defueled Comparison Permanently Defueled Station ICs/EALs EAL for DAEC apply in a permanently Example Emergency Action Levels: Emergency Action Levels:

defueled condition.

(1) UNPLANNED spent fuel pool PD-SU 1. 1 UNPLANNED spent fuel pool temperature rise to temperature rise to greater than (site- greater than 150°F.

specific ° F).

NEI 99-01 Basis: DAEC Basis

Added definition for UNPLANNED.

This IC addresses a condition that is a Definitions:

precursor to a more serious event and

Replaced "plant" with UNPLANNED: A parameter change or an event that is not: 1) the represents a potential degradation in the level "facility".

result of an intended evolution; or 2) an expected facility response of safety of the plant. If uncorrected, boiling in the pool will occur, and result in a loss of pool to a transient. The cause of the parameter change or event may * "PD-AA1" and "PD-AA2" is be known or unknown. replaced with "PD-RA 1" and level and increased radiation levels.

Basis:

"PD-RA2" to better signify a Escalation of the emergency classification level radiological event and to would be via IC PD-AA 1 or PD-AA2 This IC addresses a condition that is a precursor to a more maintain continuity with the serious event and represents a potential degradation in the level previous DAEC action level of safety of the facility. If uncorrected, boiling in the pool will scheme.

occur and result in a loss of pool level and increased radiation levels.

Escalation of the emergency classification level would be via IC PO-RA 1 or PD-RA2

Attachment 2 Comparison of DAEC E IC/EALs against NEI 99-01, Rev. 6 for Recognition Category E

DAEC Proposed ISFSI ICs/EALs NEI 99-01 Rev 6, Section Proposed Permanently Defueled EAL Comparison 8 ISFSI ICs/EALs for DAEC E-HU1 E-HU1

Removed Operating Mode ECL: Notification of Unusual Event ECL: Notification of Unusual Event Applicability as it does not apply in a permanently Initiating Condition: Damage to a Initiating Condition: Damage to a loaded cask CONFINEMENT defueled condition.

loaded cask CONFINEMENT BOUNDARY.

BOUNDARY.

Removed "Example" from Emergency Action Levels: Emergency Action Levels as Example Emergency Action Levels:

no longer example.

(1) Damage to a loaded cask E-HU 1.1 Damage to a loaded cask confinement BOUNDARY as CONFINEMENT BOUNDARY as

Included the site-specific indicated by a radiation reading greater than the values indicated by an on-contact shown on Table E-1 on the spent fuel cask. technical specification values.

radiation reading greater than (2

Added table for cask dose times the site-specific cask Table E*1 Cask Dose Rates rates.

specific technical specification 61BT DSC (HSM;llfthrough HSM-20) I 61BTH DSC (HSM;21 through HSM-30) allowable radiation level) on the 3 feet from HSM Surface I 800 mrem/hr I HSM Front Bird Screen I 400 mremlhr surface of the spent fuel cask. Outside HSM Door - Centerline of DSC 200 mrem/hr Outside HSM Door -Centerline of DSC 200 mremlhr End Shield Wall Exterior 40 mremlhr End Shield Wall Exterior 30 rem/hr

NEI 99-01 Rev 6, Section Proposed Permanently Defueled EAL Comparison 8 ISFSI ICs/EALs forDAEC NEI 99-01 Basis: DAEC Basis:

Added definitions for This IC addresses an event that results CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask CONFINEMENT in damage to the CONFINEMENT barrier(s) between areas containing radioactive substances and the BOUNDARY and BOUNDARY of a storage cask environment. INDEPENDENT SPENT containing spent fuel. It applies to FUEL STORAGE INDEPENDENT SPENT FUEL STORAGE INSTALLATION irradiated fuel that is licensed for dry INSTALLATION (ISFSI).

(ISFSI): A complex that is designed and construct~d fo~ the storage beginning at the point that the interim storage of spent nuclear fuel and other rad1oact1ve

Replaced Category "A" and loaded storage cask is sealed. The materials associated with spent fuel storage. IC AUi with Category R and issues of concern are the creation of a potential or actual release path to the IC RD-RU1 to align with This IC addresses an event that results in damage to the current DAEC EAL scheme.

environment, degradation of one or CONFINEMENT BOUNDARY of a storage cask containing spent fuel.

more fuel assemblies due to It applies to irradiated fuel that is licensed for dry storage beginning at environmental factors, and configuration the point that the loaded storage cask is sealed. The issues of changes which could cause challenges concern are the creation of a potential or actual release path to the in removing the cask or fuel from environment, degradation of one or more fuel assemblies due to storage.

environmental factors, and configuration changes which could cause The existence of "damage" is determined challenges in removing the cask or fuel from storage.

by radiological survey. The technical The existence of "damage" is determined by radiological survey. The specification multiple of "2 times", which technical specification multiple of "2 times" which is also used in is also used in Recognition Category A Recognition Category RIC PD-RU1 is used here to distinguish .

IC AU1, is used here to distinguish between non-emergency and emergency conditions. The emphasis between non-emergency and for this classification is the degradation in the level of safety of the emergency conditions. The emphasis for spent fuel cask and not the magnitude of the associated dose or dose this classification is the degradation in rate. It is recognized that in the case of extreme damage to a loaded the level of safety of the spent fuel cask cask the fact that the "on-contact" dose rate limit is exceeded may be and not the magnitude of the associated dete;mined based on measurement of a dose rate at some distance dose or dose rate. It is recognized that in from the cask.

the case of extreme damage to a loaded cask, the fact that the "on-contacf' dose Security-related events for ISFSls are covered under ICs PD-HU1 and rate limit is exceeded may be PD-HA1.

determined based on measurement of a dose rate at some distance from the cask.

Security-related events for ISFSls are covered under ICs HU1 and HA1.

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

ATTACHMENT 3 PERMANENTLY DEFUELED EMERGENCY ACTION LEVEL TECHNICAL BASES DOCUMENT 38 pages follow

DAEC PERMANENTLYDEFUELEDEMERGENCY ACTION LEVEL TECHNICAL BASES

TABLE OF CONTENTS 1.0 PURPOSE ...................................................................................................... 1 2.0 DISCUSSION .................................................................................................................. 1 2 .1 Permanently Defueled Plant ....................................................................................... 1 2.2 Independent Spent Fuel Storage Installation ............................................................... 2 3.0 KEY TERMINOLOGY USED .............................................................................. 2 3.1 Emergency Classification Levels ................................................................................. 3 3.2 Initiating Condition ...................................................................................................... 3 3.3 Emergency Action Level ............................................................................................. 4 4.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS ................................... 4 4.1 General Considerations .............................................................................................. 4 4.2 Classification Methodology .......................................................................................... 5 4.3 Classification of Multiple Events and Conditions .......................................................... 5 4.4 Classification of Imminent Conditions ......................................................................... 6 4.5 Emergency Classification Level Upgrading and Termination ....................................... 6 4.6 Classification of Short-Lived Events ............................................................................ 6 4.7 Classification of Transient Conditions .......................................................................... 6 4.8 After-the-Fact Discovery of an Emergency Event or Condition .................................... 7 4.9 Retraction of an Emergency Declaration ..................................................................... 7

5.0 REFERENCES

................................................................................................................ 7 5.1 Developmental ............................................................................................................ 7 5.2 Implementing .............................................................................................................. 8 5.3 Commitments ............................................................................................................. 8 6.0 ACRONYMS & DEFINITIONS ......................................................................................... 9 6.1 Acronyms ................................................................................................................... 9 6.2 Definitions ................................................................................................................. 10

7. 0 DAEC-TO-NEI 99-01 EAL CROSS-REFERENCE ......................................................... 12.

8.0 ATTACHMENTS ........................................................................................................... 13 ........................................................................................................... 14 ........................................................................................................... 3 7

1.0 PURPOSE This document provides the detailed set of Emergency Action Levels (EALs) applicable to the Duane Arnold Energy Center (DAEC) and the associated Technical Bases using the EAL development methodology found in NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors," Revision 6 (NEI 99-01, Rev. 6). As a permanently defueled plant, DAEC will use the Recognition Category "PD" (Permanently Defueled) providing a stand-alone set of Initiating Conditions (ICs)/Emergency Action Levels (EALs) for a permanently defueled plant to consider for use in developing a site- specific emergency classification scheme and Recognition Category "E" ICs for the ISFSI. Permanently defueled ICs and EALs are addressed in Appendix C of NEI 99-01, Rev. 6. All recommendations for changes to this document or associated implementing procedures are reviewed in accordance with 10 Code of Federal Regulations (CFR) 50.54(q).

This document should be used to facilitate review of the DAEC Permanently Defueled EALs, provide historical documentation for future reference and serve as a resource for training. Decision-makers responsible for implementation of the Permanently Defueled Emergency Plan (PDEP) may use this document as a technical reference in support of EAL interpretation.

The expectation is that emergency classifications are to be made as soon as conditions are present and recognizable for the classification, but within 30 minutes or less in all cases of conditions present. Use of this document for assistance is not intended to delay the emergency classification.

2.0 DISCUSSION 2.1 Permanently Defueled Station NEI 99-01 provides guidance for an emergency classification scheme applicable to a permanently defueled station. This is a station that generated spent fuel under a 10 CFR Part 50 license, has permanently ceased operations, and will store the spent fuel onsite for an extended period of time. The emergency classification levels (ECLs) applicable to this type of plant are consistent with the requirements of 10 CFR Part 50 and the guidance in NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, Rev. 1" (NUREG-0654).

In order to relax the emergency plan requirements previously applicable to an operating station, the licensee must demonstrate that no credible event can result in a significant radiological release beyond the site boundary. This verification confirms that the source term and motive force available in the permanently defueled condition are insufficient to warrant classifications of a Site Area Emergency or General Emergency. Therefore, the generic ICs and EALs applicable to a permanently defueled station may result in either a Notification of Unusual Event (Unusual Event) or an Alert classification.

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

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

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

Regarding the above information, the expectations for an offsite response to an Alert classified under a 10 CFR 72.32 emergency plan are generally consistent with those for an Unusual Event in a 10 CFR 50.47 emergency plan (e.g., to provide assistance, if requested). Also, the licensee's Emergency Response Organization (ERO) required for a 10 CFR 72.32 emergency plan is different than that prescribed for a 10 CFR 50.47 emergency plan (e.g., no emergency technical support function).

3.0 KEY TERMINOLOGY USED There are several key terms that appear throughout the NEI 99-01, Rev. 6 methodology. These terms are introduced in this section to support understanding of subsequent material. As an aid to the reader, the following table is provided as an overview to illustrate the relationship of the terms to each other.

Emergency Classification Level Unusual Event I Alert Initiating Condition Initiating Condition Permanently Defueled Emergency Permanently Defueled Emergency Action Level 1 Action Level 1

Notes

Notes

Basis

Basis 1When making an emergency classification, the Shift Manager/Emergency Director must consider all information having a bearing on the proper assessment of an Initiating Condition. This includes the PD and E EALs, Notes and the Basis information.

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

Unusual Event

Alert 3.1.1 Unusual Event Events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to plant protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

Purpose:

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

3.1.2 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 Environmental Protection Agency (EPA) Protective Action Guides (PAG) exposure levels.

Purpose:

The purpose of this classification is to assure that emergency personnel are readily available to respond if the situation becomes more serious or to perform confirmatory radiation monitoring if required, and provide offsite authorities current information on plant status and parameters.

3.2 Initiating Condition An event or condition that aligns with the definition of one of the two EC Ls by virtue of the potential or actual effects or consequences.

Discussion: An Initiating Condition (IC) describes an event or condition, the severity or consequences of which meets the definition of an ECL. An IC can be expressed as

a continuous, measurable parameter (e.g., radiation monitor readings) or an event (e.g., an earthquake).

Appendix 1 of NUREG-0654 does not contain example EALs for each ECL, but rather ICs (i.e., conditions that indicate that a radiological emergency, or events that could lead to a radiological emergency, have occurred). NUREG-0654 states that the ICs form the basis for establishment by a licensee of the specific plant instrumentation readings (as applicable) which, if exceeded, would initiate the emergency classification. Thus, it is the specific instrument readings that would be the EALs.

3.3 Emergency Action Level A pre-determined, site-specific, observable threshold for an IC that, when met or exceeded, places the plant in a given ECL.

Discussion: EAL statements may utilize a variety of criteria including instrument readings and status indications, observable events, results of calculations and analyses, entry into particular procedures, and the occurrence of natural phenomena.

4.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS 4.1 General Considerations When making an emergency classification, the Emergency Director must consider all information having a bearing on the proper assessment of an IC. This includes the EAL plus Notes and the informing Basis information.

All emergency classification assessments should be based upon valid indications, reports or conditions. A valid indication, report, or condition, is one that has been verified through appropriate means such that there is no doubt regarding the indicator's operability, the condition's existence, or the report's accuracy. For example, validation could be accomplished through an instrument channel check, response on related or redundant indicators, or direct observation by personnel. The validation of indications should be completed in a manner that supports timely emergency declaration.

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

A planned work activity that results in an expected event or condition which meets or exceeds an EAL does not warrant an emergency declaration provided that 1) the activity proceeds as planned and 2) the plant remains within the limits imposed by the operating license. Such activities include planned work to test, manipulate, repair, maintain, or modify a system or component. In these cases, the controls associated with the planning, preparation, and execution of the work will ensure that compliance is

maintained with all aspects of the operating license provided that the activity proceeds and concludes as expected. Events or conditions of this type may be subject to the reporting requirements of 10 CFR 50.72.

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

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

4.2 Classification Methodology To make an emergency classification, the user will compare an event or condition (i.e.,

the relevant plant indications and reports) to an EAL(s) and determine if the EAL has been met or exceeded. The evaluation of an EAL(s) must be consistent with the Notes.

If an EAL has been met or exceeded, then the IC is considered met and the associated ECL is declared in accordance with plant procedures.

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

4.3 Classification of Multiple Events and Conditions When multiple emergency events or conditions are present, the user will identify all met or exceeded EALs. The highest applicable ECL identified during this review is declared.

For example:

If an Unusual Event EAL and an Alert EAL are met, an Alert should be declared.

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

If two Unusual Event EALs are met, an Unusual Event should be declared.

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

4.4 Classification of Imminent Conditions Although EALs provide specific thresholds, the Emergency Director must remain alert to events or conditions that could lead to meeting or exceeding an EAL within a relatively short period of time (i.e., a change in the ECL is IMMINENT). If, in the judgment of the Emergency Director, meeting an EAL is IMMINENT, the emergency classification should be made as if the EAL has been met. While applicable to all EC Ls, this approach is particularly important at the higher ECL since it provides additional time for implementation of protective measures.

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

As noted above, guidance concerning classification of rapidly escalating events or conditions is provided in RIS 2007-02.

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

4. 7 Classification of Transient Conditions Several of the ICs and/or EALs contained in this document employ time-based criteria.

These criteria will require that the IC/EAL conditions be present for a defined period of time before an emergency declaration is warranted. In cases where no time-based criterion is specified, it is recognized that some transient conditions may cause an EAL to be met for a brief period of time (e.g., a few seconds to a few minutes). The following guidance should be applied to the classification of these conditions.

EAL momentarily met during expected plant response - In instances where an EAL is briefly met during an expected (normal) plant response, an emergency declaration is not warranted provided that associated systems and components are operating as expected, and operator actions are performed in accordance with procedures.

EAL momentarily met but the condition is corrected prior to an emergency declaration -

If an operator takes prompt manual action to address a condition, and the action is successful in correcting the condition prior to the emergency declaration, then the applicable EAL is not considered met and the associated emergency declaration is not required.

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

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

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

4.9 Retraction of an Emergency Declaration Guidance on the retraction of an emergency declaration reported to the NRG is discussed in NUREG-1022.

5.0 REFERENCES

5.1 Developmental 5.1.1 NEI 99-01 Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, November 2012 5.1.2 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities 5.1.3 RIS 2007-02, Clarification of NRG Guidance for Emergency Notifications During Quickly Changing Events, February 2007 5.1.4 NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73 5.1.5 10 CFR 50.72, Immediate Notification Requirements for Operating Nuclear Power Reactors 5.1.6 NUREG-0654/FEMA-REP-1, Rev. 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants 5.1.7 10 CFR 72.32, Emergency Plan 5.1.8 NUREG-1567, Spent Fuel Dry Storage Facilities 5.1.9 10 CFR 50.47, Emergency Plans 5.1.10 NUREG-1140, A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees 5.2 Implementing 5.2.1 Permanently Defueled Emergency Plan 5.2.2 EAL Comparison Matrix 5.2.3 EAL Classification Matrix 5.3 Commitments None

6.1 ACRONYMS & DEFINITIONS 6.2 Acronyms AOP ..................................................................................Abnormal Operating Procedure COE. ...................................................................................... Committed Dose Equivalent CFR. .....................................................................................Code of Federal Regulations cpm ...................................................................................................... Counts per Minute EAL ............................................................................................. Emergency Action Level ECL ................................................................................... Emergency Classification Level EPA .............................................................................. Environmental Protection Agency FAA .................................................................................. Federal Aviation Administration FBl. ................................................................................... Federal Bureau of Investigation FEMA .............................................................. Federal Emergency Management Agency HSM ........................................................................................ Horizontal Storage Module ISFSI ............................................................. Independent Spent Fuel Storage Installation IC .................................................................................................................lnitiating Condition mRem ................................................................................milli-Roentgen Equivalent Man MSL ......................................................................................................... Mean Sea Level NEI .............................................................................................. Nuclear Energy Institute NORAD ................................................... North American Aerospace Defense Command NRC ............................................................................... Nuclear Regulatory Commission ODAM ........................................................................... Off-site Dose Calculation Manual ORO ........................................................ .'....................... Off-site Response Organization PAG .............................................................................................. Protective Action Guide PD .................................................................................................. Permanently Defueled rem ........................................................................................... Roentgen Equivalent Man TEDE. ...............................................................................Total Effective Dose Equivalent UFSAR ...................................................................Updated Final Safety Analysis Report

6.1 Definitions The following definitions are taken from Title 10 CFR, and related regulatory guidance documents.

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 PAG exposure levels.

Unusual Event Events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to plant protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

The following key terms are necessary for overall understanding the NEI 99-01 emergency classification scheme.

Emergency Action Level (EAL): A pre-determined, site-specific, observable thresh o Id for an Initiating Condition that, when met or exceeded, places the plant in a given ECL.

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

Unusual Event

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

Selected terms used in IC and EAL statements are set in all capital letters (e.g., ALL CAPS). These words are defined terms that have specific meanings as used in this document. The definitions of these terms are provided below.

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

EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or over pressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion. Such events may require a post-event inspection to determine if the attributes of an explosion are present.

FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES.

Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.

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

HOSTILE ACTION: An act toward a plant or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the plant. Non-terrorism-based EALs should be used to address such activities, (i.e., this may include violent acts between individuals in the owner controlled area).

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.

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

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

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

OWNER CONTROLLED AREA (OCA): The property associated with the plant and owned by the licensee. Access is normally limited to persons entering for official business.

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

PROTECTED AREA: The area normally within the plant security fence designated to implement the security requirements of 10 CFR 73.

SECURITY CONDITION: Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION.

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

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

7 .0 DAEC-TO-NEI 99-01 EAL CROSS-REFERENCE The following cross-reference table is provided to facilitate association and location of a DAEC EAL within the NEI 99-01, Rev. 6 IC/EAL identification scheme. Further information regarding the development of the DAEC EALs based on the NEI guidance can be found in the EAL Comparison Matrix (Reference 5.2.2).

NEI 99-01, Rev. 6, Appendix C -

DAEC Permanently Defueled Permanently Defueled Station IC/EALs ICs/ EA Ls PD-RU1 PD-AU1 PD-RA1 PD-AA1 PD-RU2 PD-AU2 PD-RA2 PD-AA2 PD-HU1 PD-HU1 PD-HA1 PD-HA1 PD-HU2 PD-HU2 PD-HU3 PD-HU3 PD-HA3 PD-HA3 PD-SU1 PD-SU1 NEI 99-01, Rev. 6, Section 8 -

DAEC ISFSI ICs/EAL ISFSI ICs/ EALs E-HU1 E-HU1

8.0 ATTACHMENTS 8.1 Attachment 1, Recognition Category PD EAL Bases 8.2 Attachment 2, Recognition Category E EAL Basis

Attachment 1 Recognition Category PD EAL Bases

Recognition Category PD EAL Bases Recognition Category PD (Permanently Defueled) provides a stand-alone set of ICs/EALs for a permanently defueled plant to consider for use in developing a site-specific emergency classification scheme. For development, it was assumed that the plant had operated under a 10 CFR Part 50 license and that the licensee has permanently ceased power operations and removed fuel from the reactor vessel.

Further, the licensee intends to store the spent fuel within the permanently defueled plant for some period of time.

When in a permanently defueled condition, the licensee typically receives approval from the NRC for exemptions from specific emergency planning requirements. These exemptions reflect the reduced radiological source term and risks associated with spent fuel pool storage relative to reactor at-power operation. Source terms and accident analyses associated with plausible accidents are documented in the facilities' Final Safety Analysis Report as Updated (USAR). As a result, FCS has developed a plant- specific emergency classification scheme using the NRG-approved exemptions, revised source terms, and revised accident analyses as documented in the station's USAR.

Recognition Category PD uses the same ECLs as operating reactors; however, the source term and accident analyses typically limit the ECLs to an Unusual Event and an Alert. The Unusual Event ICs provide for an increased awareness of abnormal conditions while the Alert ICs are specific to actual or potential impacts to spent fuel.

The source terms and release motive forces associated with a permanently defueled plant would not be sufficient to require declaration of a Site Area Emergency or General Emergency.

A permanently defueled station is essentially a spent fuel storage plant with the spent fuel stored in a pool of water that serves as both a cooling medium (i.e., removal of decay heat) and shield from direct radiation. These primary functions of the spent fuel storage pool are the focus of the Recognition Category PD ICs and EALs.

Radiological effluent ICs and EALs were included to provide a basis for classifying events that cannot be readily classified based on an observable events or plant conditions alone.

Appropriate ICs and EALs from Recognition Categories A, C, F, H, and S of NEI 99-01 were modified and included in Recognition Category PD to address a spectrum of the events that may affect a spent fuel pool. The Recognition Category PD ICs and EALs reflect the relevant guidance in NEI 99-01, Rev. 6 (e.g., the importance of avoiding both over-classification and under-classification). Nonetheless, FCS has developed its emergency classification scheme using the NRG-approved exemptions, and the source terms and accident analyses specific to FCS. Security-related events are also considered.

The following table, Table PD-1: Recognition Category "PD" Initiating Condition Matrix, provides a summary of ICs associated with Recognition Category PD.

Table PD-1: Recognition Category "PD" Initiating Condition Matrix UNUSUAL EVENT ALERT PD-RU1 Release of gaseous or liquid PD-RA 1 Release of gaseous or liquid radioactivity greater than 2 times the radioactivity resulting in offsite dose ODAM limits for 60 minutes or longer. greater than 10 mrem TEDE or 50 mrem thyroid COE.

PD-RU2 UNPLANNED rise in plant PD-RA2 UNPLANNED rise in plant radiation levels. radiation levels that impedes plant access required to maintain spent fuel integrity.

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

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

PD-HU3 Other conditions exist which in PD-HA3 Other conditions exist which in the judgment of the Emergency Director the judgment of the Emergency Director warrant declaration of an Unusual Event. warrant declaration of an Alert.

PD-SU1 UNPLANNED spent fuel pool temperature rise.

PD-RU1 ECL: Notification of Unusual Event Initiating Condition: Release of gaseous or liquid radioactivity greater than 2 times the ODAM limits for 60 minutes or longer.

Emergency Action Levels:

Notes:

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

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

PD-RU1 .1 Reading on ANY effluent radiation monitor greater than 2 times the alarm setpoint established by a current radioactivity discharge permit for 60 minutes or longer.

PD-RU1 .2 Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times the ODAM limits for 60 minutes or longer.

Definitions: None Basis:

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

DAEC incorporates design features intended to control the release of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases. The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.

PD-RUl Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.

EAL PD-RU1 .1 - This EAL addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This EAL will typically be associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas).

EAL PD-RU1 .2 - This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analysis or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).

Escalation of the emergency classification level would be via IC PD-RA 1.

PD-RAl ECL: Alert Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid COE.

Emergency Action Levels:

Notes:

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

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

The pre-calculated effluent monitor values presented in Table R-1 should only be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

PD-RA 1.1 Reading on ANY Table R-1 effluent radiation monitor greater than column "Alert" for 15 minutes or longer:

Table R Effluent Monitor Classification Thresholds Monitor Alert Reactor Building ventilation

(/) 1.1E-02 uci/cc

l rad monitor (Kaman 3/4, 5/6, 0 718)

Cl)

(/)

C1l LLRPSF rad monitor 1 .4E-02 uci/cc

(.9 (Kaman 12)

GSW rad monitor 1.7E+04 cps (RIS-4767)

RHRSW & ESW rad monitor 1.2E+04 cps (RM-1997)

RHRSW & ESW Rupture 1.8E+04 cps Disc rad monitor (RM-4268)

PD-RA 1.2 Dose assessment using actual meteorology indicates doses greater than 10 mrem TEDE or 50 mrem thyroid COE at or beyond SITE BOUNDARY(Preferred).

PD-RAl PD-RA 1.3 Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than 10 mrem TEDE or 50 mrem thyroid COE at or beyond the SITE BOUNDARY for one hour of exposure.

PD-RA 1.4 Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:

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

Analyses of field survey samples indicate thyroid COE greater than 50 mrem for one hour of inhalation.

Definitions:

SITE BOUNDARY: That line beyond which the land is neither owned, nor leased, nor otherwise controlled by the licensee.

Basis:

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

This IC is modified by a note that EAL RA 1.1 is only assessed for emergency classification until a qualified dose assessor is performing assessments using dose projection software incorporating actual meteorological data and current radiological conditions.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

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

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

PD-RU2 ECL: Notification of Unusual Event Initiating Condition: UNPLANNED rise in plant radiation levels Emergency Action Levels:

PD-RU2.1 a. UNPLANNED water level drop in the spent fuel pool as indicated by ANY of the following:

Report to control room (visual observation)

Fuel pool level indication (Ll-3413) less than 36 feet and lowering AND

b. UNPLANNED rise in area radiation levels as indicated by ANY of the following radiation monitors:

Spent Fuel Pool Area, Rl-9178

North Refuel Floor, Rl-9163

New Fuel Vault Area, Rl-9153

South Refuel Floor, Rl-9164 PD-RU2.2 Area radiation monitor reading or survey result indicates an UNPLANNED rise of 25 mR/hr over NORMAL LEVELS Definitions:

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

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

Basis:

This IC addresses elevated plant radiation levels caused by a decrease in water level above irradiated (spent) fuel or other UNPLANNED events. The increased radiation levels are indicative of a minor loss in the ability to control radiation levels within the plant or radioactive materials. Either condition is a potential degradation in the level of safety of the plant.

A water level decrease will be primarily determined by indications from available level instrumentation. Other sources of level indications may include reports from plant personnel or video camera observations (if available). A significant drop in the water

PD-RU2 level may also cause an increase in the radiation levels of adjacent areas that can be detected by monitors in those locations.

The effects of planned evolutions should be considered. For example, a refueling bridge area radiation monitor reading may increase due to planned evolutions such as movement of a fuel assembly. Note that this RU2.1 is applicable only in cases where the elevated reading is due to an UNPLANNED water level drop. RU2.2 excludes radiation level increases that result from planned activities such as use of radiographic sources and movement of radioactive waste materials.

DAEC Technical Specifications require a minimum of 36 feet of water in the spent fuel pool. The spent fuel pool level indicator LI- 3413 is used to monitor refueling water level.

Procedures require that a normal refueling water level be maintained at 37 feet 5 inches. A low level alarm actuates when spent fuel pool level drops below 37 feet 1 inch. Symptoms of inventory loss at DAEC include visual observation of decreasing water levels in the spent fuel storage pool, Reactor Building (RB) fuel storage pool radiation monitor or refueling area radiation monitor alarms, observation of a decreasing trend on the spent fuel pool water level indicator, and actuation of the spent fuel pool low water level alarm. To eliminate minor level perturbations from concern, DAEC uses Ll-3413 indicated water level below 36 feet and lowering.

Escalation of the emergency classification level would be via IC PD-RA 1 and PD-RA2.

PD-RA2 ECL: Alert Initiating Condition: UNPLANNED rise in plant radiation levels that impedes plant access required to maintain spent fuel integrity.

Emergency Action Levels:

PD-RA2.1 UNPLANNED dose rate greater than 15 mR/hr in ANY of the following areas requiring continuous occupancy to maintain control of radioactive material or operation of systems needed to maintain spent fuel integrity:

Control Room (RM-9162)

Central Alarm Station (by survey)

PD-RA2.2 UNPLANNED Area Radiation Monitor readings or survey results indicate a rise by 100 mR/hr over NORMAL LEVELS that impedes access to ANY of the following areas needed to maintain control of radioactive material or operation of systems needed to maintain spent fuel integrity.

Spent fuel pool pump area (by survey)

Definitions:

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

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

Basis:

This IC addresses increased radiation levels that impede necessary access to areas containing equipment that must be operated manually or that requires local monitoring, in order to maintain systems needed to maintain spent fuel integrity. As used here,

'impede' includes hindering or interfering, provided that the interference or delay is sufficient to significantly threaten necessary plant access. It is this impaired access that results in the actual or potential substantial degradation of the level of safety of the plant.

This IC does not apply to anticipated temporary increases due to planned events.

PD-HUl ECL: Notification of Unusual Event Initiating Condition: Confirmed SECURITY CONDITION or threat.

Emergency Action Levels:

PD-HU1 .1 A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by DAEC Security Shift Supervision.

PD-HU1 .2 Notification of a credible security threat directed at DAEC.

PD-HU1 .3 A validated notification from the NRG providing information of an aircraft threat.

Definitions:

SECURITY CONDITION: Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION.

HOSTILE ACTION: An act toward DAEC or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the nuclear power plant. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).

Basis:

This IC addresses events that pose a threat to plant personnel or the equipment necessary to maintain cooling of spent fuel, and thus represent a potential degradation in the level of plant safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR 73.71 or 10 CFR 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs HA 1.

Timely and accurate communications between DAEC Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.

Classification of these events will initiate appropriate threat-related notifications to plant personnel and offsite response organizations.

PD-HUl Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

EAL PD-HU1 .1 references DAEC Security Shift Supervision because these are the individuals trained to confirm that a security event is occurring or has occurred. Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR § 2.390 information.

EAL PD-HU1 .2 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with Abnormal Operating Procedure (AOP) 914, Security Events.

EAL PD-HU1 .3 addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may also be provided by NORAD through the NRC. Validation of the threat is performed in accordance with Abnormal Operating Procedure (AOP) 914, Security Events.

Emergency plans and implementing procedures are public documents; therefore, EALs do not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information is contained in the Security Plan.

Escalation of the emergency classification level would be via IC PD-HA 1.

PD-HAl ECL: Alert Initiating Condition: HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.

Emergency Action Levels:

PD-HA 1.1 A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the DAEC Security Shift Supervision.

PD-HA 1.2 A validated notification from NRG of an aircraft attack threat within 30 minutes of the site.

Definitions:

HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION: An act toward DAEC or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the nuclear power plant. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).

OWNER CONTROLLED AREA: The site property owned by or otherwise under the control of the licensee.

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

Basis:

This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the plant and staff for a potential aircraft impact.

PD-HAl Timely and accurate communications between DAEC Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.

Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The Alert declaration will also heighten the awareness of Offsite Response Organizations, allowing them to be better prepared should it be necessary to consider further actions.

This IC does not apply to incidents that are accidental ~vents, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE.

Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR 73.71or10 CFR 50.72.

EAL PD-HA 1.1 is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action directed against the ISFSI which is located outside the plant PROTECTED AREA.

EAL PD-HA 1.2 addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and offsite response organizations are in a heightened state of readiness. This EAL is met when the threat-related information has been validated in accordance with Abnormal Operating Procedure (AOP) 914, Security Events.

The NRG Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may be provided by NORAD through the NRG.

In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRG. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.

PD-HAl Emergency plans and implementing procedures are public documents; therefore, EALs do not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information is contained in the Security Plan.

PD-HU2 ECL: Notification of Unusual Event Initiating Condition: Hazardous event affecting equipment necessary for spent fuel cooling.

Emergency Action Levels:

PD-HU 2.1 a. The occurrence of ANY of the Table H-1 hazardous events:

Table H-1 Hazardous Events

Seismic Event (earthquake)

Internal or external flooding event

High winds of tornado strike

FIRE

EXPLOSION

Other events with similar hazard characteristics as determined by the Shift Manager or Emergency Director AND

b. The event has damaged at least one train of a system needed for spent fuel cooling.

AND

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

Indications of degraded performance

VISIBLE DAMAGE Definitions:

EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due to cor:nbustion, chemical reaction, or overpressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion.

Such events may require a post-event inspection to determine if the attributes of an explosion are present.

FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of

PD-HU2 flame is preferred but is NOT required if large quantities of smoke and heat are observed.

VISIBLE DAMAGE: Damage to a component or structure that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected component or structure. Damage resulting from an equipment failure and limited to the failed component (i.e., the failure did not cause damage to a structure or any other equipment) is not VISIBLE DAMAGE.

Basis:

This IC addresses a hazardous event that causes damage to at least one train of a system needed for spent fuel cooling. The damage must be of sufficient magnitude that the system(s) train cannot, or potentially cannot, perform its intended function. This condition reduces the margin to a loss or potential loss of the fuel clad barrier, and therefore, represents a potential degradation of the level of safety of the plant.

For EAL PD-HU2.1 c., the first bullet addresses damage to equipment that is in service/operation since indications for it will be readily available.

For EAL PD-HU2.1 c., the second bullet addresses damage to equipment that is not in service/operation or readily apparent through indications alone. Operators will make this determination based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.

Escalation of the emergency classification level could, depending on the event, be based on any of the Alert ICs; PD-RA 1, PD-RA2, PD-HA 1 or PD-HA3.

PD-HU3 ECL: Notification of Unusual Event Initiating Condition: Other conditions exist which in the judgment of the Emergency Director warrant declaration of a NOUE.

Emergency Action Levels:

PD-HU3.1 Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to plant protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of systems needed to maintain spent fuel cooling occurs.

Definitions: none Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a NOUE.

PD-HA3 ECL: Alert Initiating Condition: Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert.

Emergency Action Level:

PD-HA3.1 Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the 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.

Definitions:

HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION: An act toward DAEC or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the nuclear power plant. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).

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

Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an Alert.

PD-SUl ECL: Notification of Unusual Event Initiating Condition: UNPLANNED spent fuel pool temperature rise.

Emergency Action Level:

PD-SU1 .1 UNPLANNED spent fuel pool temperature rise to greater than 150°F.

Definitions:

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

Basis:

This IC addresses a condition that is a precursor to a more serious event and represents a potential degradation in the level of safety of the plant. If uncorrected, boiling in the pool will occur and result in a loss of pool level and increased radiation levels.

Escalation of the emergency classification level would be via IC PD-RA 1 or PD-RA2.

Attachment 2 Recognition Category E EAL Bases

Recognition Category E EAL Bases Recognition Category E provides a set of ICs/EALs for an ISFSI. An ISFSI is a complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage. A significant amount of the radioactive material contained within a cask must escape its packaging and enter the atmosphere for there to be a significant environmental effect resulting from an accident involving the dry storage of spent nuclear fuel. Formal offsite planning is not required because the postulated worst-case accident involving an ISFSI has insignificant consequences to the public health and safety.

An Unusual Event is declared on the basis of the occurrence of an event of sufficient magnitude that a loaded cask confinement boundary is damaged or violated. This includes classification based on a loaded fuel storage cask confinement boundary loss 1 leading to the degradation of the fuel during storage or posing an operational safety problem with respect to its removal from storage.

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

E-HUl ECL: Notification of Unusual Event Initiating Condition: Damage to a loaded cask CONFINEMENT BOUNDARY.

Emergency Action Levels:

E-HU1 .1 Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by a radiation reading greater than the values shown on Table E-1 on the spent fuel cask.

Table E-1 Cask Dose Rates 61BT DSC (HSM-01 through HSM-20) 61BTH DSC (HSM-21 through HSM-30) 3 feet from HSM Surface 800 mrem/hr HSM Front Bird Screen 400 mrem/hr Outside HSM Door - Centerline of DSC 200 mrem/hr Outside HSM Door - Centerline of DSC 200 mrem/hr End Shield Wall Exterior 40 mrem/hr End Shield Wall Exterior 30 rem/hr Definition:

CONFINEMENT BOUNDARY: The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage.

Basis:

This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage cask is sealed. The issues of concern are the creation of a potential or actual release path to the environment, degradation of one or more fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the cask or fuel from storage.

The existence of "damage" is determined by radiological survey. The technical specification multiple of "2 times" is used here to distinguish between non-emergency and emergency conditions. The emphasis for this classification is the degradation in the level of safety of the spent fuel cask and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the fact that the "on-contact" dose rate limit is exceeded may be determined based on measurement of a dose rate at some distance from the cask.

Security-related events for ISFSls are covered under ICs PD-HU1 and PD-HA 1

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

ATTACHMENT 4 PERMANENTLY DEFUELED EMERGENCY ACTION LEVEL SCHEME 2 pages follow

111 ALERT Release of gaseous or llquld radioactivity resulting In offslte dose greater than 10 mrem TEDE or 50 mrem thyroid COE UNUSUAL EVENT Release of gaseous or llquld radioactivity greater than 2 time the ODAM llmlts for 60 minutes or longer a PD-RA1 .1 (Notes 1, 2, 3,4) a PD-RU1 .1 (Note 1,2)

Reading on ANY Table R-1 effluent radiation monilor Reading on ANY effluent radiation monitor grea ter th an 2 ti mes the greater than column "Alert" for 15 minutes or longer. alarm setpoint established by a current radioactivity discharge permit for 60 minu tes or longer.

a PD*RA1 .1 (Note 4)

Dose assessment using actual meteorology indicates doses a PD-RU1 .2 (N otes 1, 2) greater than 1O mrem TEDE or 50 mrem thyroid CDE at or beyond Sample analysis for a gaseous or liquid release indicates a the SITE BOUNDARY. [Preferred) concentrat ion or release rate greater than 2 times the ODAM limits for 60 minutes or longer.

,:{ PD-RA1 .3 (Notes 1, 2) 1 Analysis of a liquid effluent sample indicates a concentra tion or release rate that wo uld resul t in doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the SITE BOUNDARY for Table R-1 Effluent Monitor Classlflcatlon Thresholds Effluent Monitor Alert NOUE one hour of exposure.

Radiation ~ Reactor Building vent rad monitor a PD* RA1 .4 (Notes 1, 2) "0 (Kaman 3/4, 5/6, 7/8) 1.lE-02 µci/cc 8.0E-04 µci/cc Field survey results indicate EITHER of the followi ng at or beyond ~

1.4E-02 µci/cc 1.2E-03 µci/cc llRPSF rad monitor the SITE BOUNDARY:

R GSW rad monitor l.7Et-04cps 1.SE+03cps Closed window dose rates greater than 10 mrem/hr expected Abnormal to continue for 60 minutes or longer. 'D RHRSW & ESW rad moni tor Rad Analyses of field survey samples indicate thyro id CDE *g. (RM-1997) 1.2E+o4cps 8.4E+02cps Levels grealer lhan 50 mrem for one hour of inhalation.

RHRSW & ESW Rupture Disc rad 1.8E+-04cps l.OE+03 cps monitor (RM-4268)

Rad Effluent UNPLANNED rise In faclllty radiation levels that Impedes faclllty UNPLANNED rise In faclllty rad iation levels access required to maintain spent fuel Integrity a PD* RA2.1 a PD-RU2.1 Dose rate grealer than 15 mR/hr in ANY of the followi ng areas:

Control Room (RM-9162)

Central Alarm Station (by survey)

a. UNPLAN NED wate r level drop in lhe spenl fu el pool as indicated by AN Y of the followi ng:

Report to control room (visual observation) 2 a PD*RA2.1 AND Fuel pool level indication (Ll-34 13) less th an 36 feet and loweri ng Plant Rad UNPLANNED area radiation monitor readings or survey resuts b. UNPLANNED ri se in area radia tion levels as indicated Levels indicate a rise by 100mR/hr over NORMAL LEVELS that impedes access to ANY of the fo llowing areas needed to main tain spent fuel ..

by ANY of the following radiation monitors.

Spent Fuel Pool Area, Rl-9178 integrity:

Spent fuel pool pump area (by survey) .

North Refu el Floor, Rl-9163 New Fuel VatJ t Area, Rl-9153 South Refue l Floor, Rl-9164 a PD-RU2.2 Area radia ti on monitor reading or survey resu lt indicates an UNPLANNED rise of 25 mR/hr over NORMAL LEVELS UNPLANNED spent fuel pool temperature ri se.

s Syst em Malfunction NONE a PD-SU1 .1 UNPLANNED spent fuel pool tempe rature rise to greater tha n 150° F Damage to a loaded cask CONFINEMENT BOU NDARY a E-HU1 .1 Damage to a loaded cask CONFI NEMENT BOUNDARY as indicated by a radiation reading greater than values shown in E T able E-1 on the spent fu el cask.

lib~ E-l Call OoseRll~

ISFSI NONE 61011& IHSM-01~IOO.\h111mo 6181H I& 1~11-11 llvoo:,h1111.BJ) lfetlf1001H~.lstrllce ~rrtenitt 111/,lhdbid~~en 400rrteniti Outsilfe1111,ldoct*cerMrtofl& 100rrtenitt Outside 1111~ doct *ce~elirt of I& 100irrenit1 loollield111llmeri<< 40rrtinit1 Eoollie~111lle.lleri<< ))rrreniti

HOSTILE ACTION within the OWNER CONTROLLER AREA or Confirmed SECURITY CONDITION or threat airborne attack threat within 30 minutes o PD* HA1 .1 o PD-HU1.1 A SECURITY CONDITION that does not involve a HOSTILE 1 A HOSTILE ACTI ON is occurring or has occurred wilhi n lhe OWNER CONTROLLED AR EA as reported by the DAEC Security Sh~t Supervi sion.

ACTION as reported by DAEC Security Shift Supervision.

Security o PD-HU1 .2 o PD-HA1.2 Notification of a credible security lhreat directed at DAEC.

A va lida ted notification fro m NRC of an aircraft attack threat withi n 30 minutes of th e site. o PD-HU1 .3 A validated notifica tion from lhe NRC providing inform ati on of an aircraft threa t.

Hazardous event affecting equipm ent necessary for spent fuel cooling.

o PD-HU2.1

a. Th e occurrence of ANY of lhe Ta bl e H-1 hazardous events:

AND

b. The event has damaged at least one train of a system needed for spen t fu el cooling H 2 AND

c. Th e damaged equipment ca nnot, or potentially cannot Hazards Natural and perform its design function on EITH ER:

Destructive

lndicaUons of degraded performance Phenom ena

VI SIBLE DAMAG E NONE rp;;;;;;;;..._ _ _

I

-===---=====:;,I Table H-1 Huardout !vents

Seismic event (eart hquake)

Internal or external Hooding event

High winds or torn ado strike

FIRE

EXPLOS ION

Other events with similar hazard cha racteristics as determined by the Shift Manager or Emerg ency Director other conditions exist which In the judgment of the Emergency Other conditions exist which In th e judgment of the Emergency Director warrant declaration of an Alert. Director warrant declaration of a NOUE o PD-HAJ.1 o PD-HUJ.1 3 Other conditions exist w hich, in the judgment of lhe Emergency Director, indicate that events are in prog ress or have occurred which invo lve an actual or potential substantial degrada tion of the Other co nditions exist wh ich in lhe j udgment of the Emerg ency Director indicate that events are in prog ress or have occurred w hich indicate a potenti al degradation of the level of sa fety of the plant or Judgment level of sa fety of the plant or a security event that invo lves probabl e indicate a security lhreat to faci lity protection has been initiated. No l~e threatening risk to site personnel or damage to site equipment releases of radioactive material requiring offsite response or because of HOSTILE AC TION. Any releases are expected to be monitoring are expected unless further degradation of systems limited to sm all fracUons of lhe EPA Protective Action Guideline needed to maintain spent fuel coo ling occurs.

exposure levels.

NOTES Note 1: The Emergency Director should declare the event prompUy upon determining lhat lhe PERMANENTLY appli ca ble time has been exceeded, or wi ll likely be exce eded.

Note 2: If an ongoing release is detected an d lhe release start ti me is unknown, assume that the DEFUELED CONDITIONS rel ease duration has exceeded the specttied time limit.

NextEra Energy

Duane Arnold Energy Center Note 3: If the efflu ent fl ow past an effluent monitor is known to have stopped due to actions to isolate lhe release path, lhen lhe ernuent monitor readi ng is no longer vali d fo r cl ass~ ica t io n Emergency Action Level Matrix purposes.

Note 4: The pre-calculated ernuent m onitor val ues prese nted in Tabl e R-1 should only be used for emergency classifi cati on assessments until th e res ults from a dose assessment using actu al me teorology are available.

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

ATTACHMENT 5 LETTER OF CONSULTATION AND CONCURRENCE FROM OFFSITE RESPONSE ORGANIZATIONS 1 page follows

ACKNOWLEDGEMENT OF OPPORTUNITY TO REVIEW, AND CONCURRENCE WITH, PROPOSED CHANGES TO THE NEXTERA ENERGY DUANE ARNOLD L.L.C. EMERGENCY PLAN AND EMERGENCY ACTION LEVELS, BEING SUBMITTED TO THE NUCLEAR REGULATOR COMMISSION The proposed changes would revise the DAEC E-Plan and Emergency Action Level scheme to support the permanent cessation of power operations and permanent removal of fuel, and reflect the Permanent Defueled Emergency Plan (PDEP)and Permanently Defueled EAL (PD-EAL) scheme.

Representatives from the NextEra Energy Duane Arnold, L.L.C. (DAEC) Emergency Preparedness and Licensing Departments provided a briefing to the Benton County Emergency Management Agency, the Linn County Emergency Management Agency, the Iowa Homeland Security and Emergency Management Department, and the Iowa Department of Public Health Bureau of Radiological Health (the Partners) on April 23, 2020. The briefing outlined the proposed license amendment request (LAR) to the Nuclear Regulatory Commission (NRC) that seeks to revise the DAEC E-Plan and Emergency Action Level scheme to reflect the Permanent Defueled Emergency Plan (PDEP) and a Permanently Defueled EAL (PD-EAL) scheme. DAEC has also discussed decommissioning-related updates and plan submlttals with the Partners since DAEC notified the NRC of their Intent to permanently cease power operations.

Transition to the PDEP and the PD-EAL scheme are commensurate with the significantly reduced spectrum of creditable accidents that can occur In the station's permanently defueled condition.

Therefore, an Emergency Planning Zone (EPZ) will no longer be needed and a new PD-EAL scheme has been developed. The PD-EAL scheme and other PDEP changes needing offslte coordination were generally captured In a briefing paper and discussed at the Aprll meeting.

Based upon the Information provided, the Partners acknowledge and concur with the proposed changes.

Steve onel<, Coordinator Linn County Emergency Management JeQ,;%gram Manager Iowa Departme of Homeland Security and Emergency Date 1 '

Managemen 4/29/2020 Angela Le , ur C lef of Radiological Health Date Iowa Department o P lie Health

v t e Letter Sequence Request
EPID:L-2020-LLA-0113, License Amendment Request (TSCR-185): Application to Revise Operating License to Remove Cyber Security Plan Requirements (Open)
Initiation Request, Request Acceptance... Supplement Administration Questions 10 November 2020 Answers 1 December 2020 Results Approval... Other: ML21098A166, SECY-21-0006, SRM-SECY-21-0006: Request by Nextera Energy Duane Arnold, LLC for Exemptions from Certain Emergency Planning Requirements for the Duane Arnold Energy Center
MONTHYEAR2020-12-01 [Table View]

NG-20-0028, License Amendment Request (TSCR-187): Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme

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NG-20-0028, License Amendment Request (TSCR-187): Proposed Permanently Defueled Emergency Plan and Permanently Defueled Emergency Action Level Scheme

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