Text

License Amendment Request (TSCR-192): Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan and Emergency Action Level Scheme
	ML21179A286
Person / Time
Site:	Duane Arnold
Issue date:	06/28/2021
From:	Hansen P; NextEra Energy Duane Arnold
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
	NG-21-0010
	Download: ML21179A286 (81)
	v • d • e

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OUAll E ARNO LD June 28, 2021 NG-21-0010 10 CFR 50.90 10 CFR 50.54(q)(4)

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-192): Independent Spent Fuel Storage Installation (ISFSI)

Emergency Plan and Emergency Action Level Scheme Pursuant to 10 CFR 50.90, NextEra Energy Duane Arnold, LLC (NEDA) hereby requests a license amendment to revise the Duane Arnold Energy Center (DAEC) Emergency Plan. The proposed change will implement an Independent Spent Fuel Storage Installation (ISFSI)

Emergency Plan and an associated Emergency Action Level (EAL) Scheme that are commensurate with a facility configuration where all spent nuclear fuel is in dry storage within the ISFSI.

The Enclosure provides a description and assessment of the proposed changes. Attachment 1 of the Enclosure contains the proposed ISFSl-Only Emergency Plan (IOEP). Attachment 2 contains t.he ISFSl-Only Emergency Action Level and Technical Bases Document. Attachment 3 contains an analysis of the consequences of a radioactive waste handling event.

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.

NEDA requests review and approval of the amendment by May 2, 2022 . NEDA requests that the approved amendment become effective after all spent fuel has been removed from the spent fuel pool and placed in dry storage within the DAEC site-controlled ISFSI, with a 30-day implementation period.

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.

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

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

NG-21-0010 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on June 28, 2021 .

Paul Hansen Decommissioning Director, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC Enclosure cc: Administrator, Region Ill, USNRC Project Manager, USNRC, Duane Arnold Energy Center Inspector, USNRC, Duane Arnold Energy Center State of Iowa

NextEra Energy Duane Arnold, LLC NG-21-001 O Enclosure Page 1 of 16 ENCLOSURE Description and Assessment of the Proposed Changes

Subject:

License Amendment Request (TSCR-192): Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan and Emergency Action Level Scheme

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION 2.1 Introduction 2.2 Reason for the Proposed Changes 2.3 Description of the Proposed Changes

3. TECHNICAL EVALUATION 3.1 Radiological Consequences of Design Basis Events 3.2 Radiological Consequences of Postulated Events

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. ISFSl-Only Emergency Plan (IOEP)

2. ISFSl-Only Emergency Action Level and Technical Bases Document

3. DAEC Calculation CAL-R21-001

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Page 2of16

1.

SUMMARY

DESCRIPTION The proposed ISFSl-Only Emergency Plan (IOEP) is related to the operation of the ISFSI and would be implemented after all spent fuel has been removed from the spent fuel pool (SFP) and placed in dry storage within the DAEC site controlled ISFSI. Implementation of the proposed IOEP would involve the establishment of administrative controls for radiological source term accumulation limits and methods to control the accidental dispersal of the radiological source.

2. DETAILED DESCRIPTION 2.1 Introduction By letter dated October 12, 2020 (Reference 1), NextEra Energy Duane Arnold (NEDA) provided certification of the permanent removal of fuel from the reactor vessel to the Nuclear Regulatory Commission (NRC) in accordance with 10 CFR Part 50.82(a)(1 )(i) and (ii).

Therefore, the Duane Arnold Energy Center (DAEC) 10 CFR Part 50 license no longer permits operation of the reactor or emplacement or retention of fuel in the reactor vessel in accordance with 10 CFR Part 50.82(a)(2).

By letter dated April 13, 2021 (Reference 2), the NRC approved exemptions from certain emergency planning requirements for the DAEC. The proposed IOEP continues to rely on these exemptions as the basis for them has not changed and remains in effect.

By letter dated April 28, 2021 (Reference 3), the NRC issued License Amendment No. 313 to the DAEC Renewed Facility Operating License No. DPR-49 approving the DAEC Permanently Defueled Emergency Plan (PDEP) and associated Permanently Defueled Emergency Action Levels (EALs).

The DAEC Post Shutdown Decommissioning Activities Report (PSDAR), Revision 1 (Reference 4), outlines NEDA's plans to transfer all spent fuel to the Independent Spent Fuel Storage Facility (ISFSI). Currently, NEDA expects all fuel to be transferred to the ISFSI in 2022. To comport with the reduced scope of potential radiological accidents with all spent fuel in dry cask storage, NEDA determined that implementation of the IOEP and the ISFSl-Only EAL Technical Bases Document will be warranted.

The proposed amendment would modify the DAEC license by replacing the existing PDEP and the associated EAL scheme with the IOEP and the ISFSl-Only EAL scheme to reflect the storage of all spent fuel at the ISFSI. The proposed EAL scheme continues to be based on NEI 99-01, Revision 6, as appropriate. The proposed changes reduce the scope of onsite emergency planning requirements to reflect the reduced scope of potential radiological accidents and to maintain the effectiveness of the emergency plan.

2.2 Reason for the Proposed Changes After all spent fuel is in dry cask storage within the ISFSI, the number and severity of potential radiological accidents possible at DAEC are substantially lower. There continues to be no need for offsite emergency response plans for DAEC because no postulated design basis accident or reasonably conceivable beyond design basis accident can result in a radioactive release that exceeds Environmental Protection Agency (EPA) Protective Action Guides (PAGs) beyond the "site boundary, as described in EPA's PAG Manual "Protective Action Guides and Planning Guidance for Radiological Incidents" dated January 2017 (EPA PAG Manual) (Reference 5).

NextEra Energy Duane Arnold, LLC NG-21-001 O Enclosure Page 3of16 The robust nature and high integrity of the spent fuel storage system selected for use at the ISFSI is designed to prevent the release of radioactivity in the event of an accident, including environmental phenomena (e.g., earthquake and flooding). As a result of the high integrity dry shielded canisters' design and the substantial protection afforded the canisters, leakage of fission products from a canister is not considered to be a credible event.

The radioactive source term for an accidental release at the defueled reactor site is reduced by radioactive decay and transfer of spent fuel from the SFP to the ISFSI. Administrative radiological source term accumulation limits are in place to ensure that if a radiological release were to occur, it would not exceed two times the Defueled Offsite Dose Assessment Manual (DODAM) limits (two (2) times 1500 millirem/year) at the site boundary for sixty (60) minutes (and therefore not result in doses to the public above EPA PAGs beyond the controlled area boundary). In addition to administrative limits on radioactive source term accumulation, administrative controls will be in place to limit the dispersal of radioactive material. These administrative limits and dispersal controls are in addition to the requirements already specified in the DODAM for control of effluent releases.

2.3 Description of the Proposed Changes Replacement of the DAEC PDEP and associated EAL Technical Bases Document with the IOEP and the ISFSl-Only EAL Technical Bases Document involves the following major changes to the Emergency Plan:

Removal of the various emergency actions related to the SFP,

Removal of non-ISFSl-related emergency event types,

Clarifying definitions for security EALs,

Revision of the Emergency Response Organization (ERO), and

Identification of the "ISFSI Shift Supervisor" (ISS) title as the position that assumes the Emergency Director responsibilities following an emergency declaration.

The off-normal events and accidents addressed in the IOEP are related to the dry storage of spent nuclear fuel within the ISFSI and include only the off-normal, accident, natural phenomena, and hypothetical events and consequences presented in the Updated Final Safety Analysis Report (UFSAR), NUH-003, "Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel," (Reference 6). After all fuel is removed from the DAEC SFP, there will no longer be any potential for the accidents previously described in the DAEC Emergency Plan that would increase risk to the health and safety of the public. These accidents included events specifically related to the storage of the spent fuel in the SFP. After the transfer of the spent fuel from the SFP to the ISFSI, the spent fuel storage and handling systems will be removed from operation.

Elimination of SFP Initiating Conditions and EALs The Initiating Conditions (ICs) and EALs associated with emergency classification are based on NEI 99-01, Revision 6. Specifically, Appendix C of NEI 99-01 contains a set of ICs and EALs for permanently defueled nuclear power plants that had previously operated under a 10 CFR Part 50 license and have permanently ceased power operations. After all spent fuel has been transferred from the SFP to dry storage within the ISFSI, the NEI 99-01, Appendix C ICs and

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Page 4of16 EALs that are specifically associated with the SFP are no longer required to be in the emergency plan. Additionally, certain ICs and EALs, the primary function of which is not associated with the SFP, are also no longer required to be in the emergency plan when administrative controls are established to limit source term accumulation and the offsite consequences of uncontrolled effluent releases. Therefore, the ICs listed in Table 1, below, are proposed for elimination and are not included in the IOEP or its associated EAL scheme.

Table 1- Emergency Plan Initiating Conditions Being Changed or Deleted Unusual Event Alert pg RlH Release of gaseol::ls OF lit1bliEI pg RA~ Release of gaseol::ls OF lit1l::liEI FaElioaetivity gFeateF tFlaA ~ times tF!e GQAM FaElioaetivity Fesl::lltiAg iA offsite Elose gFeateF limits foF 60 miAl::ltes OF loAgeF. tFlaA 1O mFem TEQE OF 50 mFem tFiyrniEI

~

pg RU2 UNPLANNEQ Fise iA plaAt FaEliatioA pg RA2 blNPLANNEQ Fise iA plaAt FaEliatioA levels. levels tFiat impeEles plaAt aeeess Fet1l::liFeEI to maiAtaiA speAt fl::lel iAtegFity.

PD-HU1 Confirmed SECURITY CONDITION PD-HA1 HOSTILE ACTION within the or threat at the ISFSI. OWNER CONTROLLED AREA OF aiFbome attaek: tFIFeat 1NitRiA d0 miAl::ltes.

pg HU2 l=lai!:aFElol::ls eveAt a#eetiAg et1blipmeAt AeeessaFy foF speAt fblel eooliAg. 4 pg SU~ UNPLANNEQ speAt fl::lel pool tempeFatl::lFe Fise.

1 For a facility in which all spent fuel is stored in the ISFSI, the condition addressed by PD-HU2 remains fully addressed by IC E-HU 1.

The ICs being deleted include all ICs associated with the categories of abnormal radioactive release and system malfunction associated with the SFP as well as security conditions associated with aircraft. These categories apply to the storage of spent fuel in the SFP and are not necessary or appropriate for a facility in which all spent fuel is stored in the ISFSI.

The ICs listed in Table 2, below, are being retained. The ICs being retained in the IOEP and associated EAL scheme are1 appropriate to address the condition of a facility in which all spent fuel is stored in the ISFSI.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Page 5of16 Table 2 - ISFSl-Only Emergency Plan Initiating Conditions Unusual Event Alert Independent Spent Fuel Storage Installation E-HU1 Damage to a loaded cask CONFINEMENT BOUNDARY.

Hazards and Other Conditions PD-HU1 Confirmed SECURITY CONDITION PD-HA1 HOSTILE ACTION within the or threat at the ISFSI. OWNER CONTROLLED AREA.

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

Emergency Response Organization Revision The current DAEC PDEP provides for two (2) ERO augmented positions: Technical and Engineering Supervisor and Site Radiation Protection Coordinator. The PDEP requires the ERO to be activated at an Alert classification (can be activated in part or in whole at the discretion of the Emergency Director for an Unusual Event) with the goal of the ERO to augment the on-shift staff within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of an Alert classification. The proposed DAEC IOEP replaces these positions with a Resource Manager and an individual trained in radiological monitoring and assessment.

The Resource Manager is provided to assist in assessing the event and obtaining needed resources. The Resource Manager is required to be in contact with the Emergency Director within two (2) hours of declaration of an Unusual Event or an Alert. Entry into the IOEP would result from an extreme natural phenomenon (beyond-design-basis) or a security condition, either of which would negatively impact or restrict the ability of responding personnel to access to the site.

The Resource Manager augments the Emergency Director by assisting in assessing the emergency condition and coordinating the required resources, including serving as the public information interface. Services provided to the Emergency Director by the Resource Manager can be provided remotely and do not necessitate an onsite response by the Resource Manager.

By responding remotely, the actual response time is decreased (as compared to the ERO response required by the PDEP as described above) with no negative impact to services and functional responsibilities provided by the Resource Manager. The Resource Manager's functional responsibilities could be performed in a timely manner either by reporting to the site or performing the function remotely in the specified timeframe.

In addition, NEDA proposes that a minimum of one person trained in radiological monitoring and assessment will report to the ISFSI within four (4) hours of an emergency declaration for an event involving radiological consequences.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Page 6of16 The proposed DAEC IOEP also provides that additional personnel resources may be directed to report to the ISFSI to provide support as needed to assess radiological conditions, support maintenance and repair activities, develop and implement corrective action plans, and assist with recovery actions. The augmentation personnel are available from DAEC staff and can be requested from various contractors.

Replacement of the "Shift Manager" with the "ISFSI Shift Supervisor" The current DAEC PDEP assigns the authority and responsibility for command and control of emergencies to the Shift Manager. If an emergency condition develops, the Shift Manager assumes the role of Emergency Director. The proposed DAEC IOEP replaces the Shift Manager position with an ISFSI Shift Supervisor (ISS).

The ISS is an on-shift position at the DAEC site on a continuous, 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day basis, and is the senior management position during off-hours. This position is responsible for monitoring ISFSI conditions and managing the activities at the DAEC ISFSI. This position assumes overall command and control of the response as the Emergency Director and is responsible for monitoring conditions and approving all onsite activities. The IOEP clearly identifies non-delegable responsibilities, along with other designated tasks assigned to the ISS.

ISFSl-Only Emergency Plan The IOEP describes DAEC's plan for responding to emergencies while all spent fuel is in dry cask storage within the ISFSI. The IOEP is provided in Attachment 1 of this submittal for NRC review and approval. The IOEP addresses the applicable regulations stipulated in 10 CFR 50.47, "Emergency Plans" and 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities" (as previously exempted), and is consistent with regulations in 10 CFR 72.32 and applicable guidelines established in NUREG-0654/FEMA-REP-1, Revision 1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants" (Reference 7).

The DAEC IOEP conservatively provides that the emergency planning zone for the ISFSI is the area within the Site Boundary. The Site Boundary establishes the perimeter of the Owner Controlled Area. The Site Boundary completely encompasses the ISFSl-controlled area. The ISFSl-controlled area, as defined in 10 CFR 72.3, "Definitions," means the area immediately surrounding the ISFSI for which DAEC exercises authority over its use and within which ISFSI operations are performed.

The ISFSl-controlled area is established to limit dose to the public during normal operations, anticipated occurrences and Design Basis Accidents (DBAs) in accordance with the requirements of 10 CFR 72.104, "Criteria for Radioactive Materials in Effluents and Direct Radiation from an ISFSI or MRS," and 10 CFR 72.106, "Controlled Area of an ISFSI or MRS."

DAEC's analysis of the radiological impact of potential accidents at the ISFSI concluded that any releases beyond the ISFSl-controlled area are expected to be less than the EPA PAGs.

The ISFSl-controlled area is completely enclosed within the Site Boundary. Thus, any radiological releases beyond the Site Boundary will also be less than the EPA PAGs.

Based on the reduced number and consequences of potential radiological events with all spent fuel in dry storage within the ISGSI, the current offsite comprehensive emergency management

NextEra Energy Duane Arnold, LLC NG-21-001 O Enclosure Page 7of16 plan (CEMP) approach will continue to be an effective method to protect the health and safety of the public. Additionally, the scope of the onsite emergency response organization and corresponding requirements in the emergency plan may be reduced without an undue risk to the public health and safety. The current DAEC PDEP describes interfaces with the State of Iowa, including notifications of emergency declarations and annual review of DAEC's emergency classification system with appropriate State representatives. The proposed IOEP maintains these interfaces.

The analysis of the potential radiological impact of an accident in a condition with all irradiated fuel stored in the ISFSI indicates that any releases beyond the Site Boundary are below the EPA PAG exposure levels detailed in Reference 5. Exposure levels, which warrant pre-planned response measures, are limited to onsite areas. For this reason, radiological emergency planning remains focused onsite.

ISFSl-Only Emergency Action Levels to this submittal provides the DAEC ISFSl-Only EAL and Technical Bases Document. The current EAL Scheme was approved by the NRC on April 28, 2021 (Reference 3). The proposed ISFSI EAL Scheme would be implemented with the proposed IOEP.

Deletions from the currently approved EAL Scheme are identified in Table 1, "Emergency Plan Initiating Conditions Being Deleted," above.

Operating Modes and Applicability The proposed ISFSI EAL Scheme is only applicable after all spent nuclear fuel has been transferred out of the SFP and placed in dry storage within the ISFSI.

State and Local Government Review of Proposed Changes State and local emergency management officials are advised of EAL changes that are implemented. Prior to implementation of this License Amendment Request, DAEC will provide an overview of the new classification scheme to State and local emergency management officials in accordance with 10 CFR 50, Appendix E, Section IV.B.1.

3. TECHNICAL EVALUATION 3.1 Radiological Consequences of Design Basis Events The DAEC site is located on the western side of a north-south reach of the Cedar River, approximately 2.5 miles north-northeast of the village of Palo, Iowa. The closest city is Cedar Rapids, Iowa with its outer boundary being 8 miles to the southeast. The site is approximately 500 acres owned by NEDA and all site activities are under the control of NEDA. The ISFSI is located within a Protected Area on the site.

Chapter 6 of the DAEC Defueled Safety Analysis Report (DSAR) describes the only OBA scenario that is applicable to DAEC with fuel stored in the SFP. This OBA scenario is a postulated fuel handling accident (FHA) associated with fuel movement. After transfer of all irradiated fuel from the SFP to dry storage within the ISFSI, an FHA is no longer possible.

NextEra Energy Duane Arnold, LLC NG-21-001 O Enclosure Page 8of16 The robust design and construction of the spent fuel storage system selected for use at the ISFSI prevents the release of radioactivity in the event of an off-normal or accident event as described in the NU HOMS UFSAR. Leakage of fission products from a canister confinement boundary breach is not considered to be a credible event, given the high integrity nature of the canister's design and the additional protection afforded by the storage casks.

DAEC's PSDAR documents the decommissioning strategy selected for DAEC. Systems that are not required to support the spent fuel, HVAC, Emergency Plan, or site security will be drained, de-energized, and secured and the plant will remain in a stable condition until final decontamination and dismantlement activities begin. The PSDAR documents the time period that NEDA expects to have all spent fuel transferred to the ISFSI. After the fuel transfer is completed, the SFP and associated systems will be drained and de-energized.

After all the spent fuel has been removed from the SFP, the estimated radiological inventory (non-fuel) that remains at the reactor facility is primarily attributable to activated reactor components and structural materials. There are no credible accident scenarios that can mobilize a significant portion of this inventory for release. As a result, the potential accidents that could occur during decommissioning of the reactor facility have negligible offsite and onsite radiological consequences.

With all spent nuclear fuel in dry storage within the ISFSI, the radiological status of the facility required for implementing this proposed IOEP is summarized as follows:

The remaining radiological source term at DAEC will not create an unplanned/unanticipated increase in radiation or in liquid or airborne radioactivity levels that would result in doses to the public above EPA PAG limits at the site boundary.

Source term accumulation from activities during decontamination and dismantlement of radioactive systems, structures, and components are administratively controlled at a level that would preclude declaring an Unusual Event.

Necessary radiological support personnel will be administratively required to be onsite during active decontamination and dismantlement of radioactive systems, structures and components.

The IOEP, and certain ICs and EALs for which administrative controls to limit possible effluent releases will be established, do not apply to the decontamination and dismantlement of radioactive systems, structures and components.

NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities," (NUREG-0586) (Reference 8) supports this conclusion in the following statement:

"The staff has reviewed activities associated with decommissioning and determined that many decommissioning activities not involving spent fuel that are likely to result in radiological accidents are similar to activities conducted during the period of reactor operations. The radiological releases from potential accidents associated with these activities may be detectible. However, work procedures are designed to minimize the likelihood of an accident and the consequences of an accident, should one

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Page 9of16 occur, and procedures will remain in place to protect health and safety while the possibility of significant radiological accident exists."

NUREG-0586 also includes the following statement:

"The staff has considered available information, including comments received on the draft of Supplement 1 of NUREG-0586, concerning the potential impacts of non-spent fuel related radiological accidents resulting from decommissioning. This information indicates that with the mitigation procedures in place, the impacts of radiological accidents are neither detectible nor destabilizing. Therefore, the staff makes the generic conclusion that impacts of non-spent fuel related radiological accidents are SMALL. The staff has considered mitigation and concludes that no additional measures are likely to be sufficiently beneficial to be warranted."

Accordingly, administrative controls that are designed to minimize the likelihood and consequence of off-normal or accident events would be implemented when decontamination or dismantling activities involving radioactive systems, structures, or components are being performed.

Implementation of the IOEP would involve DAEC establishing administrative controls for radiological source term accumulation limits and methods to control the accidental dispersal of the radiological source. Examples of radiological source term accumulation limits are based on:

Radioactive materials collected on filter media and resins (dose rate limit)

Contaminated materials collected in shipping containers (dose rate limit)

Surface or fixed contamination on work areas that may create airborne radioactive material (activity limits)

Radioactive liquid storage tank(s) (activity concentration limits)

An example of a method to control accidental dispersal of the radiological source term is limitation on dispersal mechanisms that may cause a fire (e.g., limits on combustible material loading, use of fire watch to preclude fire, etc.), or placement of a berm around a radioactive liquid storage tank. If the dispersal control fails, the limits on source term would preclude exceeding the site boundary source term limit.

As discussed in the previously requested exemptions from various emergency planning requirements contained in 10 CFR 50.47 and 10 CFR 50, Appendix E, an analysis of the potential radiological impact of a design basis accident at DAEC in a permanently defueled condition indicates that any releases beyond the site boundary are below EPA PAG exposure levels. The basis for these exemptions has not changed and remains in effect for the proposed IOEP.

3.2 Radiological Consequences of Postulated Events Although the limited scope of postulated accidents that remain applicable to the DAEC facility justifies a reduction in the necessary scope of emergency response capabilities, NEDA also assessed beyond design basis events using past industry precedence, including

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Page 10of16 information contained in Appendix I, "Radiological Accidents," of NUREG-0586.

With spent fuel stored within the SFP, the most severe postulated beyond design basis event involved a highly unlikely sequence of events that causes heat-up of the spent fuel, postulated to occur without any heat transfer, such that the zircaloy fuel cladding reaches ignition temperature (adiabatic heat up). The resultant zircaloy fire could lead to the release of large quantities of fission products to the atmosphere. However, after removal of the spent fuel from the SFP, the configuration of the spent fuel stored in dry storage precludes the possibility of such a scenario.

With this previously limiting beyond design basis scenario no longer possible, NEDA assessed the following beyond design basis events associated with performance of decommissioning activities with all irradiated fuel stored in the ISFSI. A summary of the assessments is provided below:

1. Cask Drop Event (Fuel-Related Event)

NEDA is the holder of a general license for the storage of spent fuel in an ISFSI at power sites in accordance with the provisions of 10 CFR 72.210 and 10 CFR 72.212. The generally licensed ISFSI at DAEC is used for interim onsite dry storage of spent nuclear fuel assemblies in the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, (Certificate of Compliance (CoC) 1004).

As documented in the NU HOMS UFSAR, NUH-003, analysis of the normal events, including drop events, determined that canister drops can be sustained without breaching the confinement boundary, preventing removal of spent fuel assemblies, or creating a criticality accident. There are no evaluated normal conditions or off-normal or accident events that result in damage to the canister producing a breach in the confinement boundary. Neither normal conditions of operation or off-normal events preclude retrieval of the fuel for transport and ultimate disposal.

The dry spent fuel storage casks used at DAEC are approved for storage of spent fuel per 10 CFR 72.214; and, as such, are in compliance with the requirements of 10 CFR 72.24 and 10 CFR 72.122 for off-normal and accident events to ensure that they will provide safe storage of spent fuel during all analyzed off-normal and accident events. Therefore, no radiological release beyond the site boundary would be expected to occur.

2. Radioactive Waste Handling Event (Resin Liner Drop)

The limiting non-fuel related event involves the release of radioactive material from a concentrated source, such as filters, resins, and shipping containers (as discussed in NUREG-0586, Appendix I). The initiator to these events could be a fire, explosion, or a handling event (resin liner drop). DAEC Calculation CAL-R21-001, "Decommissioned Radiological Release Dose Calculation for EAL Determination," (Attachment 3) evaluates damage to a resin liner containing reactor water cleanup resin, which is the highest activity waste at the facility. The calculation postulates that a facility fire damages a resin liner and causes release of 120.3 cubic feet of radioactive material. The resulting dose rate is 53.5 mrem/year, which is below the Technical Specifications limit of 1500 millirem/year.

The results of the above assessment indicate that the projected radiological doses at the controlled area boundary are less than the EPA PAGs.

NextEra Energy Duane Arnold, LLC NG-21-001 O Enclosure Page 11of16

3. Accidents Initiated by External Events The effects of external events, such as fires, floods, wind (including tornados), earthquakes, lightning, and physical security breaches on the ISFSI remain unchanged from the effects that were considered under the proposed PDEP. Externally initiated events are addressed by the proposed ISFSI EALs.

In summary, there continues to be a low likelihood of any postulated event resulting in radiological releases requiring offsite protective measures, and there is no credible radioactive material event (non-fuel related) resulting in radiological releases requiring declaration of an emergency.

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria NEDA was previously granted exemptions from portions of 10 CFR 50.47(b), 10 CFR 50.47(c)(2) and 10 CFR 50, Appendix E, Section IV (Reference 2). The bases for these exemptions have not changed and remain in effect for the emergency plan changes requested in this document. Considering the previously granted exemptions, the proposed ISFSl-Only Emergency Plan will continue to meet the remaining applicable requirements in 10 CFR 50, Appendix E and the remaining applicable planning standards of 10 CFR 50.47(b).

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."

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 (as exempted) requires that a licensee's emergency response plan contains 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.

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

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Page 12 of 16 Section IV.B.2 of Appendix Estates, in part: "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 (as exempted) 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.

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 fifing 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)."

In November 2012, NEI published NEI 99-01, Revision 6 (Reference 9). The EAL scheme being requested herein is based on Revision 6 to NEI 99-01. The NRC endorsed NEI 99-01, Revision 6, by letter dated March 28, 2013 (Reference 10). The proposed changes are conservatively being considered as a change to the EAL scheme development methodology.

Security-based ICs and EALs were provided to licensees in NRC Bulletin 2005-02, "Emergency Preparedness and Response Action for Security Based Events," dated July 18, 2005 (Reference 11). Bulletin 2005-02 was addressed to all holders of operating licenses for nuclear power reactors, except those who had permanently ceased power operation and had certified that fuel had been removed from the reactor vessel.

In 2009, the NRC amended its security regulations and added new security requirements pertaining to nuclear power reactors. This rulemaking established and updated generically applicable security requirements, similar to those previously imposed by Commission orders issued after the terrorist attacks of September 11, 2001. In the Statements of Consideration (SOC) for the Final Rule for Power Reactor Security Requirements (7 4 Federal Register (FR) 13926; March 27, 2009), the Commission stated, in part:

Current reactor licensees comply with these requirements through the use of the following 14 strategies that have been required through an operating license condition.

These strategies fall into the three general areas identified by 10 CFR 50.54(hh)(2)(i), (ii),

and (iii). The firefighting response strategy reflected in 10 CFR 50.54(hh)(2) encompasses the following elements:

7. Spent fuel pool mitigation measures

NextEra Energy Duane Arnold, LLC NG-21-001 O Enclosure Page 13of16 As such, the staff maintained EALs for potential or actual aircraft threats for facilities transitioning into decommissioning with spent fuel stored in a SFP, in addition to maintaining the mitigative strategies license conditions required by NRC Order, EA-02-026, "Interim Compensatory Measures (ICM) Order, issued February 25, 2002 (67 FR 9792; March 4, 2002).

The SOC further stated that the NRC believes it is inappropriate that 10 CFR 50.54(hh) should apply to a permanently shutdown and defueled reactor where the fuel was removed from the site or moved to an ISFSI.

Therefore, the ICs proposed for deletion also include those associated with the mitigative strategies and response procedures for potential or actual aircraft attack procedures as the spent fuel will have been removed from the SFP and stored in the ISFSI prior to the implementation of the changes requested herein.

4.2 Precedent The proposed changes to the DAEC Emergency Plan and associated EAL scheme are consistent with NRG-approved changes to emergency plans and EALs for plants that have transferred all fuel from the SFP to dry cask storage in the ISFSI, including Kewaunee Power Station (ML16195A323), Crystal River Unit 3 Nuclear Generating Plant (ML17048A474),

Vermont Yankee Nuclear Power Station (ML18053A111) and Fort Calhoun Station Unit No. 1 (ML19346D682).

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 shut down and defueled facility that has transferred all spent fuel from the SFP to dry cask storage in the ISFSI.

NEDA has evaluated whether 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 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 proposed amendment would have no effect on any of the previously evaluated accidents in the DAEC Defueled Safety Analysis Report (DSAR) or the NU HOMS Final Safety Analysis Report (FSAR) for all dry casks to be stored in the ISFSI.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Page 14of16 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 that has transferred all spent fuel from the SFP to dry cask storage in the ISFSI. The proposed changes do not involve installation of new equipment or modification of existing equipment, so 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, and therefore could not result 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.

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.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Page 15of16

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 D. Curtland (NextEra Energy Duane Arnold, LLC) to USN RC, "Certification of Permanent Removal of Fuel from the Reactor Vessel for Duane Arnold Energy Center," NG-20-0090, dated October 12, 2020 (ML20286A317)

2. Letter from USNRC to D. Moul (NextEra Energy Duane Arnold, LLC), "Exemptions from Certain Emergency Planning Requirements and Related Safety Evaluation," dated April 13, 2021 (ML21097A141)

3. Letter from USNRC to D. Moul (NextEra Energy Duane Arnold, LLC), "Issuance of Amendment No. 313 Regarding Changes to the Emergency Plan to Reflect the Permanently Defueled Condition and Make Changes to the Emergency Action Level Scheme (EPID L-2020-LLA-0113)," dated April 28, 2021, ML21098A166

4. Letter from P. Hansen (NextEra Energy Duane Arnold, LLC) to USN RC, "Response to Request for Additional Information Related to Post Shutdown Decommissioning Activities Report," NG-21-0004, dated February 5, 2021 (ML21036A160)

NextEra Energy Duane Arnold, LLC NG-21-001 O Enclosure Page16of16

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

6. NUH-003, "Updated Final Safety Analysis Report (UFSAR) for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel," Revision 18, dated January 2019 (ML19028A061)

7. 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, November 1980

8. NUREG-0586, "Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities," Supplement 1, Volume 1, November 2002

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

10. Letter from USNRC 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)

11. NRC Bulletin 2005-02, "Emergency Preparedness and Response Actions for Security Based Events," dated July 18, 2005 (ML051740058)

NEXTERA ENERGY DUANE ARNOLD, LLC DUANE ARNOLD ENERGY CENTER LICENSE AMENDMENT REQUEST (TSCR-192)

ATTACHMENT 1 ISFSl-ONLY EMERGENCY PLAN 28 pages follow

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 1of28 Table of Contents Introduction ............................................................................................................................... 3 1.1 Overview of the ISFSl-Only 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 .......................................................................................................... 7 Section C Emergency Response Support and Resources .................................................. 8 1.1 Support Provided by Local Organizations ........................................................................... 9 Section D Emergency Classification System ...................................................................... 9 1.1 Classification of Emergencies ............................................................................................. 9 1.2 Postulated Accidents ........................................................................................................ 1O 1.3 Emergency Classification System Review ........................................................................ 10 Section E Notification Methods and Procedures ............................................................... 1O 1.1 Notification and Activation ................................................................................................ 11 Section F Emergency Communications ............................................................................ 12 1.1 Communications Systems ................................................................................................ 12 Section G Public Information ............................................................................................ 12 Section H Emergency Facilities and Equipment ............................................................... 13 1.1 Emergency Response Facility (ERF) ................................................................................ 13 1.2 Emergency Equipment and Supplies ................................................................................ 13 1.3 First Aid Facilities ............................................................................................................. 14 Section I Accident Assessment ....................................................................................... 14 Section J Protective Actions ............................................................................................ 14 1.1 Accountability ................................................................................................................... 14 1.2 Site Egress Control Methods ............................................................................................ 15 Section K Radiological Exposure Control ......................................................................... 15 1.1 Radiological Control Areas ............................................................................................... 15 1.2 Exposure Control .............................................................................................................. 15

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 2 of 28 1.3 Personnel Contamination Control ..................................................................................... 16 Section L Medical and Health Support ............................................................................. 17 Section M Recovery ......................................................................................................... 17 Section N Exercises and Drills .......................................................................................... 18 1.1 Exercises .......................................................................................................................... 18 1.2 Drills ................................................................................................................................ 18 1.3 Scenarios ......................................................................................................................... 19 1.4 Critique/Evaluation ........................................................................................................... 19 Section 0 Radiological Emergency Response Training .................................................... 20 1.1 Emergency Response Training ......................................................................................... 20 1.2 Documentation of Training ................................................................................................ 21 Section P Responsibility for the Planning/Review and Distribution of Emergency Plans ... 21 1.1 Document Maintenance .................................................................................................... 21 1.2 Inventory and Maintenance of Emergency Equipment. ..................................................... 22 Appendix 1 - Cross Reference Table ...................................................................................... 23 Appendix 2 - Letters of Agreement.. ....................................................................................... 24 Appendix 3 - ISFSl-Only Emergency Plan Implementing Procedures ..................................... 25 Appendix 4 - Definitions and Acronyms .................................................................................. 26 1.0 Definitions ............................................................................................................... 26 2.0 Acronyms ................................................................................................................ 27

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 3 of 28 Introduction The ISFSl-Only Emergency Plan (IOEP) describes the plan for responding to emergencies that may arise at The Duane Arnold Energy Center (DAEC) with all fuel transferred to the Independent Spent Fuel Storage Installation ( ISFSI). DAEC has provided certification to the U.S. Nuclear Regulatory Commission (NRC) required by 10 Code of Federal Regulation (CFR) 50.82(a)(1 )(i) and (ii) that DAEC has permanently ceased power operations, and all fuel has been transferred to dry storage at the DAEC ISFSI site.

The IOEP adequately addresses the risks associated with DAEC's current conditions.

The NUHOMS Updated Final Safety Analysis Report (UFSAR) describes the Design Basis Accidents (DBAs) applicable to the DAEC ISFSI along with the radiological dose calculation results. As provided in the NU HOMS UFSAR, the analyses of the potential radiological impacts of postulated off-normal, natural phenomena, and accident events involving the ISFSI indicate that any releases would result in a dose to the public below those limits established in 10 CFR 72.106(b). Exposure levels, which warrant pre-planned response measures, are generally limited to the ISFSI and immediate vicinity, and for this reason, radiological emergency planning is focused on this area.

1.1 Overview of the ISFSl-Only 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 ISFSI Shift Supervisor (ISS) upon identification of an emergency situation based upon the Emergency Action Level (EAL) criteria. The ISS acts as the Emergency Director (ED) 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 ED.

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 Final rule - 10 CFR Part 72, "Emergency Planning Licensing Requirements for Independent Spent Fuel Storage Facilities (ISFSI) and Monitored Retrievable Storage Facilities (MRS)," (ML072910459), the Commission responded to comments concerning offsite emergency planning for an ISFSI or an MRS and concluded

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 4 of 28 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 IOEP 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 IOEP are reviewed in accordance with 10 CFR 50.54(q).

1.1.2 Scope The IOEP 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;

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 5 of 28

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 and significance of any uncontrolled release of radioactive material;

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

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

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

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

8) 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). Further, all fuel has been transferred to the on-site ISFSI for dry storage. All fuel has been removed from the Spent Fuel Pool.

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"). A paved county road provides access to the site.

Section A Organizational Responsibility Responsibility for emergency response lies with the Emergency Director. The ISS 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 position. The ERO is activated at the Alert declaration or at the discretion of the Emergency Director. 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.

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

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 6 of 28 Section 8 Emergency Response Organization The ERO shall be activated at the Alert classification. 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 DAEC maintains on-shift personnel capable of providing the initial response to an off-normal, natural phenomenon, or accident event on a 24-hour per day basis. Members of the on-shift organization are trained on their responsibilities and duties in the event of a declared emergency and are capable of performing all necessary response actions until any necessary augmenting staff arrives or the event is terminated. The on-shift staffing assignments include the roles and responsibilities for their emergency response functions.

1.1.1 ISFSI Shift Supervisor/Emergency Director The ISS 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

Coordination of Security activities

Termination of the emergency condition when appropriate

Performance of initial radiological assessment

Maintenance of records of event activities

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 7 of 28 1.1.2 Security Force Security is administered in accordance with the Security Plan. The Security Force will report to the Emergency Director when implementing the IOEP.

1.2 Emergency Response Organization Augmentation DAEC maintains the necessary personnel and resources to support the DAEC ISFSI Emergency Director in responding to an emergency. In addition to the resources listed below, additional personnel resources may be directed to report to the DAEC ISFSI by the Emergency Director to provide support as needed to assess radiological conditions, support maintenance and repair activities, develop and implement corrective action plans, and assist with recovery actions. The augmentation personnel are available from DAEC or corporate staff and can be requested from various contractors.

1.2.1 Resource Manager The Resource Manager will be in contact with the Emergency Director within two (2) hours of an emergency declaration. The Resource Manager will augment the Emergency Director by assisting in the assessment of the emergency condition and coordinating any required resources, including serving as the public information interface. The Resource Manager does not need to physically report to DAEC to perform the assigned responsibilities.

1.2.2. Augmented Responder For a declared emergency involving radiological consequences, a minimum of one person trained in radiological monitoring and assessment will report to the DAEC ISFSI within four (4) hours of the emergency declaration.

1.3 Offsite Organizations Offsite organizations are available to respond to an emergency at DAEC. The details of their responsibilities are described in Section C Emergency Response Support and Resources of this Plan.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 8 of 28 Table 8.1 On-Shift and Staff Augmentation Assignments Augmented Functional Area Location On-Shift Staff

Response

Assessment of Condition Emergency Emergency Resource Manager (Emergency Declaration) Response Facility Director Emergency Direction and Emergency Emergency Control Response Facility Director Emergency Emergency Notifications/Communications ---

Response Facility Director Resource Manager Radiological Accident Emergency Emergency Assessment and Protective Response Director Augmented Actions Facility/On Scene Responder*

Emergency Emergency Corrective Actions Response ---

Director Facility/On Scene Offsite Response Fire Fighting On Scene Per Fire Plan Organization Offsite Response Rescue and First Aid On Scene **

Organization Site Access Control and Per ISFSI Security Security Personnel ---

Accountability Plan

For a declared emergency involving radiological consequences, a minimum of (1) person trained in radiological monitoring and assessment will report to the ERF within four (4) hours of the emergency declaration.

- Provided by on-shift personnel assigned other functions Section C Emergency Response Support and Resources Arrangements for requesting and utilizing resources have been made and other organizations capable of augmenting the planned response have been identified. 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 at DAEC.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 9 of 28 1.1 Support Provided by Local Organizations 1.1.1 LawEnforcement The Linn County Sheriffs 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 has trained personnel and detailed procedures for handling radioactively contaminated patients from DAEC.

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 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 ISFSl-Only 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

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 10 of 28 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 ISFSl-Only 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 Defueled Safety Analysis Report (DSAR) 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.

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.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 11of28 1.1 Notification and Activation The ISS 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 IS F SI Protected Area and, if required, outside the Protected Area are notified by Site Security personnel.

1.1.1 Emergency Response Organization Activation 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.

Follow-up emergency messages incorporate elements as determined necessary by the State of Iowa. These messages are transmitted by telephone or electronically. 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 provided the status of the event has not changed.

1.1.3 NRC 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.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 12 of 28 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 E of this plan. Provisions for activating DAEC ERO personnel are also discussed in Section E of this plan. Provisions for periodic testing of the emergency communications system are described in Section N of this plan.

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

1.1.1 Telephone System The commercial telephone system (see Section E1 .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.

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.

Wireless communications serve as the backup means of communication.

1.1.2 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.

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

Section G Public Information The function of providing public information will be performed by the Resource Manager or Communications personnel. The Emergency Director or Resource Manager will notify the Communications staff of an emergency declaration.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 13 of 28 The Communications staff 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 Communications staff 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.

Section H Emergency Facilities and Equipment Adequate emergency facilities and equipment to support emergency response are provided and maintained.

1.1 Emergency Response Facility (ERF)

During an emergency, command and control functions are managed within the ERF. From this location, the Emergency Director (or other personnel, as directed) can assess ISFSI conditions; evaluate the magnitude and potential consequences of abnormal conditions; initiate preventative and corrective actions; and perform emergency notifications.

The ERF is staffed in accordance with Section B of this Plan. The facility provides sufficient space to accommodate anticipated response personnel and provides 24-hour availability of the communications systems specified in Section F.

Radiological condition resulting from the design basis accidents specified in the ISFSI UFSAR do not inhibit staffing of the ERF.

1.2 Emergency Equipment and Supplies This section describes the monitoring instruments used to initiate emergency measures and provide continuing assessments of conditions.

1.2.1 Portable Radiation and Contamination Monitoring Instruments Portable radiation and contamination monitoring equipment necessary for monitoring the conditions of the DAEC ISFSI are utilized and maintained by radiation monitoring personnel and are available for emergency use.

1.2.2 Communication Systems Communications systems providing for 24-hour per day onsite and offsite communications capabilities are identified and tested as described in Section N.

1.2.3 Emergency Supplies Emergency equipment and supplies necessary to carry out the provisions of the IOEP and support procedures are maintained at the ERF.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 14 of 28 1.3 First Aid Facilities First aid supplies and equipment are located at the ERF. Qualified personnel are available 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day to provide medical treatment referenced in Section L.

Radiological wound monitoring onsite is performed using an appropriate instrument. If severity of the wound restricts decontamination by Radiation Protection Personnel, the patient will be referred to offsite medial services or transported to an offsite medical facility for treatment and decontamination.

Section I Accident Assessment The activation of the IOEP 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.

The assessment activities required to evaluate a particular emergency depend on the specific nature and classification of the emergency. The Emergency Director is responsible for the initial measurement of ISFSI dose rates after off-normal, natural phenomena, or accident events. The EALs identify the parameter value to determine the emergency condition.

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

If the measured ISFSI dose rates exceed the EAL threshold, the Emergency Director ensures a radioactive release assessment in the vicinity of the affected storage module or cask is performed. After the assessment is complete, the Emergency Director contacts the Resource Manager for assistance in interpreting the results of the radioactive release assessment.

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 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.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 15 of 28 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 relocated 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 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 Emergency Director will ensure Radiological Control Areas (RCAs) are established in response to the event. The Emergency Director will limit access to all RCAs except for immediate access required 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 an 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 exposure criteria, which is consistent with the, "Emergency Worker Guidelines," provided in the EPA PAG Manual.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 16 of 28 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 for emergency response. Monitoring and issue of respiratory protection equipment will be conducted in accordance with facility procedures.

Table K.1 Emergency Worker Guidelines (Refer to Note 1)

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

Monitoring available to project or measure dose.

>25 rem Lifesaving or protection of All conditions above and only large populations for people fully aware of the risks involved.

1 Reference for this table is Table 3-1 of EPA PAG Manual, January 2017.

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.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 17 of 28 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

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

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 18 of 28 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 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.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 19 of 28 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 ERO notification is performed. 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. Commercial Telephone System ii. Portable Radios 1.3 Scenarios A scenario package for exercises is assembled 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.

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.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 20 of 28 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.

SectionO 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 IOEP.

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

1.1.1 Emergency Response Organization Training ISSs, Resource Managers and Augmented Responders 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 Radioactive Release Assessment Federal, State, and local notification procedures ERO Augmentation Emergency Exposure Control Recovery DAEC personnel available during emergencies to perform emergency response activities as an extension of their normal duties receive duty specific training. Personnel assigned the responsibility of on-shift first aid shall attend first aid training.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 21of28 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 inttial training and are requalified on an annual basis. This training includes 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 ofTraining DAEC procedures outline the process to document training of the DAEC Emergency Response Organization. Annually, Offsite organization's training offered 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 IOEP and the EPIPs and for maintaining an effective ERO staff.

Senior plant leadership is responsible for the final approval of IOEP and the EPIPs used for emergency classification, and for maintaining an effective emergency response capability at DAEC.

Senior plant leadership is responsible for the development, administration and maintenance of the IOEP, 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 IOEP and EPIPs The DAEC IOEP, ISFSl-Only EAL Technical Bases, and the EPIPs included in Appendix 3 are reviewed on an 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 IOEP.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 22 of 28 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 annually.

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.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 23 of 28 Appendix 1 - Cross Reference Table Cross-Reference Between the IOEP, 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 (10 CFR 50.47)* IOEP 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) Exempt G H (b)(8) E; G H I (b)(9) A.4; B.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

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 24 of 28 Appendix 2 - Letters of Agreement NextEra Energy Duane Arnold has agreements established with the agencies listed below that support implementation of the ISFSl-Only Emergency Plan.

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

Mercy Medical Center Hiawatha Fire and Rescue

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 25 of 28 Appendix 3 - ISFSl-Only Emergency Plan Implementing Procedures EPIP 1.1 Determination of Emergency Action Levels 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 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 IOEAL-01 ISFSl-Only Emergency Action Levels - DAEC

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 26 of 28 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.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 27 of 28 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 protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

Onsite-Theareawithinthe 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 Duane Arnold Energy Center FTS Federal Telecommunications System

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 1 Page 28 of 28 IC Initiating Condition IOEP ISFSl-Only Emergency Plan 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 PAG Protective Action Guide RCA Radiological Control Area SFP Spent Fuel Pool

NEXTERA ENERGY DUANE ARNOLD, LLC DUANE ARNOLD ENERGY CENTER LICENSE AMENDMENT REQUEST (TSCR-192)

ATTACHMENT 2 ISFSI ONLY EMERGENCY ACTION LEVEL AND TECHNICAL BASES DOCUMENT 20 pages follow

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 2 Page 1of20 TABLE OF CONTENTS 1.0 PURPOSE ...................................................................................................... 2 2.0 DISCUSSION .................................................................................................................. 2 2.1 Permanently Defueled Station .................................................................................... 2 2.2 Independent Spent Fuel Storage Installation ............................................................... 3 3.0 KEY TERMINOLOGY USED .............................................................................. 3 3.1 Emergency Classification Levels ................................................................................. 3 3.2 Initiating Condition ...................................................................................................... 4 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 .......................................................... 6 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 ......................................................................................... 8 6.1 Acronyms ................................................................................................................... 8 6.2 Definitions ................................................................................................................... 9 7.0 ATTACHMENTS ........................................................................................................... 10 ........................................................................................................... 11 ........................................................................................................... 18

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 2 Page 2 of 20 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 with all fuel transferred to the ISFSI 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 ISFSI Only EALs, provide historical documentation for future reference and serve as a resource for training. Decision-makers responsible for implementation of the ISFSl-Only Emergency Plan (IOEP) 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).

The NRC has approved specific exemptions to Emergency Planning regulations for DAEC confirming that no credible event can result in a significant radiological release beyond the site boundary. There is no source term and motive force available in the permanently defueled condition 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.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 2 Page 3 of 20 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.

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:

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.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 2 Page 4 of 20 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.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 2 Page 5 of 20 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.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 2 Page 6 of 20 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 ECLs, this approach is particularly important at the higher ECL since it provides additional time for implementation of protective measures.

4.5 Emergency Classification Level Upgrading and Termination An ECL may be terminated when the event or condition that meets the IC and EAL no longer exists. Events will not be downgraded.

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 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.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 2 Page 7 of 20 4.8 After-the-Fact Discovery of an Emergency Event or Condition In some cases, an EAL may be met but the emergency classification was not made at the time of the event or condition. This situation can occur when personnel discover that an event or condition existed which met an EAL, but no emergency was declared, and the event or condition no longer exists at the time of discovery. This may be due to the event or condition not being recognized at the time or an error that was made in the emergency classification process.

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

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

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 NRC 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

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 2 Page 8 of 20 5.2 Implementing 5.2.1 ISFSl-Only Emergency Plan 5.2.2 EALs and Bases 5.3 Commitments None 6.0 ACRONYMS & DEFINITIONS 6.1 Acronyms AOP ..................................................................................Abnormal Operating Procedure COE ....................................................................................... Committed Dose Equivalent CFR. ..................................................................................... Code of Federal Regulations cpm ...................................................................................................... Counts per Minute DSAR ............................................................................ .Defueled Safety Analysis Report DODAM ........................................................ Defueled Off-site Dose Assessment Manual 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 ORO ................................................................................ Off-site Response Organization PAG .............................................................................................. Protective Action Guide

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 2 Page 9 of 20 PD .................................................................................................. Permanently Defueled rem ........................................................................................... Roentgen Equivalent Man TEDE. ...............................................................................Total Effective Dose Equivalent 6.2 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 threshold for an Initiating Condition that, when met or exceeded, places the plant in a given ECL.

Emergency Classification Level (ECL): Refer to Section 3.1 Initiating Condition (IC): Refer to Section 3.2 CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask barrier(s) between areas containing radioactive substances and the environment.

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).

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 2 Page 10 of 20 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 ATTACHMENTS 7 .1 Attachment 1, Recognition Category PD EAL Bases 7.2 Attachment 2, Recognition Category E EAL Basis

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 2 Page 11of20 Attachment 1 Recognition Category PD EAL Bases

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 2 Page 12 of 20 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 all fuel is stored in the site ISFSI. Further, the licensee intends to store the spent fuel within the permanently defueled plant for some period of time.

DAEC received 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 storage relative to reactor at-power operation. Source terms and accident analyses associated with plausible accidents are documented in the ISFSI Final Safety Analysis Report (ISFSI FSAR) and site Decommissioning Safety Analysis Report (DSAR). As a result, DAEC has developed a plant-specific emergency classification scheme using the NRC-approved exemptions, revised source terms, and revised accident analyses.

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 where all fuel has been relocated to the ISFSI is essentially a spent fuel storage facility. The ISFSI relies on passive decay heat removal and passive shielding further reducing the potential for events.

In NEI 99-01, Rev. 6, appropriate ICs and EALs from Recognition Category H were modified and included in Recognition Category PD to address a spectrum of the events that may affect an ISFSI.

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-HU1 Confirmed SECURITY CONDITION PD-HA1 HOSTILE ACTION within the or threat. OWNER CONTROLLED AREA is occurring or has occurred.

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

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 2 Page 13 of 20 PD- HU1 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.

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 personnel or the ISFSI 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 !Cs PD-HA 1.

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.

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

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 2 Page 14 of 20 PD-HA1 ECL: Alert Initiating Condition: HOSTILE ACTION within the OWNER CONTROLLED AREA is occurring or has occurred.

Emergency Action Levels:

PD-HA1 .1 A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the DAEC Security Shift Supervision.

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.

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.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 2 Page 15 of 20 PD-HA1 This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc.

Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR 73.71or10 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.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 2 Page 16 of 20 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 facility 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.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 2 Page 17 of 20 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.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 2 Page 18 of 20 Attachment 2 Recognition Category E EAL Bases

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 2 Page 19 of 20 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 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.

NextEra Energy Duane Arnold, LLC NG-21-0010 Enclosure Attachment 2 Page 20 of 20 E-HU1 EGL: 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 61 BT DSC (HSM-01 throuah HM-20) 61 BTH DSC (HSM-21 through HSM-30) 3 feet from HSM surface Outside 800 mrem/hr HSM Front Bird Screen 400 mrem/hr HSM Door - Centerline of DSC Outside HSM Door - Centerline of 200 mrem/hr Outside HSM Door - 200 mrem/hr DSC Centerline of DSC 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-192)

ATTACHMENT 3 CAL-R21-001, "Decommissioned Radiological Release Dose Calculation for EAL Determination" 12 pages follow

CALCULATION COVER SHEET (Page 1of1)

Document Information:

Calculation (Doc) No: CAL-R21-001 I Controlled Documents Revision: 0

Title:

Decommissioned Radiological Release Dose Calculation for EAL Determination Type: CALC Sub-Type: CALC Discipline: RP/Chemistry Facility: PDA I Unit: 1 Safety Class: D SR ~Quality Related D Non-Nuclear Safety D Important to Safety D Not Important to Safety Special Codes: D Safeguards D Proprietary Vendor Doc No: NIA I Vendor Name or Code: NIA Executive Summary (optional):

Review and Approval:

Associated EC Number: EC-296400 EC Revision: 0 ARI Other Document Number:

Description of Calculation Revision: EC Document Revision:

(print name)

Reviewed by: -"""""--___,,q_---==--- - C ~2"'c ~ Date: o{, / 2 2 / 20 2 f (print name)

Type of Review: ~ Design Verification D Review D Owner Acceptance Review EN-AA-100-1004-F01, Revision 0

CALCULATION REVISION

SUMMARY

SHEET (Page 1 of 1)

Calculation Number: CAL-R21-001 Rev. Affected PaQes Reason for Revision 0 All Original Issue EN-AA-100-1004-F02, Revision 1

Decommissioned Radiological Release Dose Calculation for EAL Determination Purpose The purpose of this evaluation is to determine whether a radiological release would cause a dose at the exclusion area boundary to exceed two times the Technical Specification limit of 1500 mrem/yr to any organ from particulate and iodine dose, using the dose calculation methodology described in the Defueled Offsite Dose Assessment Manual {DODAM). Therefore, the purpose of the evaluation is to demonstrate a dose rate less than 3000 mrem/yr can be achieved.

While the DODAM specifies an adult being the primary receptor, dose rates for the teen, child and infant were calculated as well. No dose calculation from the Offgas Stack was performed as releases from the Offgas Stack have been terminated.

Inputs

Respirable airborne release from a full Energy Solutions L8-120 resin liner

Nuclides use for the calculation is based on Reactor Water Cleanup (RWCU) resin Part 61 analysis.

Assumptions

A resin liner is filled with Reactor Water Cleanup (RWCU) resin, 120.3 ft 3 *

A facility fire completely damages resin liner and RWCU ion exchange resin contents causing airborne contamination within an hour.

Damage to resin liner is 100%.

Fraction of radionuclides released based on NU REG 1940, Table 3-11.

No ventilation or filtration is credited for reducing radionuclide release.

Airborne material release was a "puff" during the event releasing all radioactive material over an hour.

Tc-99 and Ni-63 were not included in the dose calculations as both nuclides do not have Dose Transfer Factors {DTF) listed in the DODAM and are a small fraction of overall activity, Ni-63 at 1.5% and Tc-99 at 0.001%.

Resin density is estimated to be 1.1-1.4 grams per cc according to SDS. 1.2 grams per cc is used for calculations.

No dose rate calculations were made from the offgas stack as releases from the stack have been terminated.

Page 1of5 CAL-R21-001 Revision 0

Nuclide Source Term A recent resin liner containing RWCU ion exchange resin was sampled and analyzed by GEL Laboratories. While the liner contained 94 ft 3, calculations assumed a full liner of 120 ft 3 of ion exchange resin. The following provides the basic liner and resin content information.

Liner Information Liner PL8-120 Volume, ft 3 120 3

ft to cc Conversion Factor 2.83E+04 Volume, cc 3.40E+06 I ion Exchange Resin Density, g/cc 1.2 I Liner Ion Exchange Resin Mass, g 4.08E+06 Resin Nuclide Information The laboratory analysis provided the following activity information. From the activity and resin liner information, Nuclide Sample Fraction and total liner uCi were calculated.

Nulcide Activity, uCi/g Nuclide Fraction,% Total Liner uCi H-3 1.62E-03 0.001% 6.62 E+03 C-14 4.96E-03 0.004% 2.03E+04 Fe-55 1.14E+02 85.3% 4.66E+08 Ni-63 2.06E+OO 1.5% 8.42E+06 Sr-90 1.76E-03 0.001% 7.19E+03 Tc-99 1.llE-03 0.001% 4.53E+03 Mn-54 1.04E+OO 0.8% 4.25E+06 Co-60 1.64E+01 12.3% 6.70E+07 Zn-65 1.40E-01 0.1% 5.72E+05 Cs-137 1.27E-02 0.010% 5.19E+04 Totals 1.34E+02 100.000% 5.46E+08 As the table shows, Ni-63 and Tc-99 are small fractions of total uCi content. Also note, Fe-55 and Co-60 comprise 97.6% of the sample and Liner nuclide activity.

Material Fraction Released NU REG 1940 provides guidance for determining fraction of material released during a fire.

Because the compound material is known, resin, release fractions from NU REG 1940, Table 3-11 may be considered. As resin would be a non-volatile solid, the non-volatile solid release Page2of5 CAL-R21-001 Revision 0

fraction would be 0.0001. NU REG 1940, Table 3-11 is shown below. The release fraction was applied during the dose calculations, multiplying the quantity of radioactive material in the resin by the release fraction.

Table 3-11 Fire Release Fractions by Compound Formk FORM OF COMPOUND RELEASE FRACTIOH Nobte gas 1.0 Very mobile form 1.0 Volatile or combustfble compound 0.5 Carbon 0.01 Semivo~atife compound 0.01 Nonvolatile compound 0.001 Uranium and plutonium metal 0.001 Nonvolatile rn a flammable tiquid 0.005 Nonvolatile in a nonflammable liquid 0.001 Nonvolatile solid 0.0001

source: Table F-2 in NUR.EG/BR-0150 (McKenna et al., 1996).

Site Boundary The DODAM X/Q values are based on the maximum exposed individual 1260 meters NNW of the Station. The DODAM states the maximum site boundary X/Q value is located toward the SSE sector, 620 meters from the plant. The X/Q and D/Q values determined for the SSE sector, 620 meters from plant are, 3.787E-6 sec/m 3 for X/Q and 1.886E-08 1/m 2 for D/Q Dose Calculations The methodology used to calculate organ dose rate is defined DODAM, Section 3.5.2.1 and shown below. Only the dose associated with a vent release is calculated as stack discharges have been terminated.

The organ dose rate is calculated with the following equations:

Daill' 8.766E-3 TE - TB ~ ~ Qikv TAtmi (X)

Qv where Da/IV =dose equivalent rate from a vent discharge (mrem/yr)

Page3of5 CAL-R21-001 Revision 0

Q ikv = quantity of radionuclide i released in a given effluent stream based on analysis k (µCi}

during discharged time increment TB to TE (hr) of interest TAa,,; =factor converting airborne concentration of radionuclide i to dose commitment to organ n of a person in age group a where exposure is directly to airborne material mre111

( ( Ci sec ) I 3 J

111 (X/O)v =atmospheric dispersion from vent, to ground level at location of interest (sec/m 3 } or 3.787E-6 sec/m 3 determined for the site boundary SSE sector.

8.766E-03 = Conversion (1 Ci/1E6 µCi}(8766 hr/yr)

TE - TB= Time period in which release occurred in hours, which for the purpose of the calculation is assumed to be one hour.

Based on the equations above, each of the receptors, Adult, Teen, Child and Infant doses rates (mrem/yr) were calculated. The table below shows the calculation results.

Receptor Receptor Receptor - Path Maximum Adult Adult - Inhalation 4.63E+Ol Teen Teen - Inhalation 6.85E+Ol Child Child - Inhalation 5.60E+Ol Infant Infant - Inhalation 3.66E+Ol From the table, the maximum calculated dose rate is the Teen at 68.5 mrem/year.

Conclusion Based on DODAM methodology, the dose rate for a fire releasing 120.3 cubic ft of radioactive material from RWCU resin, the calculated dose of 68.5 mrem/year is less than the Technical Specification limit of 1500 mrem/year.

Page 4 of 5 CAL-R21-001 Revision 0

References

1. Technical Specification 5.5.4, Radioactive Effluent Controls Program, Item 2.g

2. Defueled Offsite Dose Assessment Manual Gaseous and Liquid Effluents, Duane Arnold Energy Center, Revision 1

3. POWDEX PCH Cation exchange resin MSDS

4. POWDEX PAO Anion exchange resin MSDS

5. Case Narrative for NEXTEra Energy, Duane Arnold NPP SDG: 538445 (Part 61 Resin Analysis)

6. EnergySolutions HIC and Liner Specifications Rev. 2

7. Mark Abrams Memo for Determining Site Boundary X/Q and D/Q values

8. NUREG-1940, Rascal 4: Description of Models and Methods. December 2012 Page5of5 CAL-R21-001 Revision 0

CAL-R21-001 ATIACHMENT A Organ Dose Rate Calculation Summary Revision 0 Total number of pages in Attachment A: 5 (including cover sheet)

Appendix A, Page 1 of 5 CAL-R21-001 Revision 0

Adult-Inhalation:

X/Q 3.79E-06 1.14E+04 8.SlE-05 TOTAL Gl-LLI BONE LIVER KIDNEY THYROID LUNG SKIN BODY Release 3 TOTAL (mrem m )/(Ci sec) GI-LU BONE LIVER KIDNEY THYROID LUNG SKIN Fraction BODY H-3 6. 62E+03 0. 0001 H 3 2.28E+01 2.28E+01 O.OOE+OO 2.28E+01 2.28E+01 2.28E+01 2.28E+01 2.28E+01 5.72E-05 5.72E-05 0.00E+OO 5.72E-05 5.72E-05 5.72E-05 5.72E-05 5.72E-05 C-14 2.03E+04 0.0001 C 14 1.08E+02 1.08E+02 5.76E+02 1.08E+02 1.08E+02 1.08E+02 1.08E+02 O.OOE+OO 8.30E-04 8.30E-04 4.43E-03 8.30E-04 8.30E-04 8.30E-04 8.30E-04 O.OOE+OO AR41 O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO KR83m O.OOE+OO 0.00E+OO O.OOE+OO O.OOE+OO 0.00E+OO 0.00E+OO 0.00E+OO 0.00E+OO KR85m 0.00E+OO 0.00E+OO 0.00E+OO 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO KR85 O.OOE+OO 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO KR 87 0.00E+OO 0.00E+OO 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO KR88 O.OOE+OO 0.00E+OO 0.00E+OO O.OOE+OO 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO KR 89 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO O.OOE+OO O.OOE+OO KR 90 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO XE131m 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO XE133m O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO 0.00E+OO 0.00E+OO O.OOE+OO XE133 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO XE135m O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO 0.00E+OO 0.00E+OO 0.00E+OO O.OOE+OO XE135 0.00E+OO 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO 0.00E+OO XE137 O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO XE138 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO O.OOE+OO CR51 3.17E+OO 1.05E+02 O.OOE+OO O.OOE+OO 7.23E+01 1.89E+OO 4.56E+02 O.OOE+OO Mn-54 4.25E+06 0.0001 MN 54 2.00E+02 2.45E+03 0.00E+OO 1.25E+03 3.12E+02 O.OOE+OO 4.44E+04 O.OOE+OO 3.22E-01 3.94E+OO 0.00E+OO 2.0lE+OO 5.02E-01 O.OOE+OO 7.15E+Ol O.OOE+OO Fe-55 4.66E+08 0.0001 FE 55 1.25E+02 1.91E+02 7.81E+02 5.38E+02 O.OOE+OO 0.00E+OO 2.29E+03 O.OOE+OO 2.21E+Ol 3.37E+Ol l.38E+02 9.49E+Ol O.OOE+OO O.OOE+OO 4.04E+02 O.OOE+OO FE 59 3.36E+02 5.96E+03 3.74E+02 8.81E+02 O.OOE+OO O.OOE+OO 3.23E+04 O.OOE+OO C058 6.56E+01 3.36E+03 O.OOE+OO 5.01E+01 0.00E+OO 0.00E+OO 2.94E+04 O.OOE+OO Co-60 6. 70E+07 0.0001 CO 60 4.69E+02 9.03E+03 0.00E+OO 3.64E+02 O.OOE+OO O.OOE+OO 1.89E+05 O.OOE+OO 1.19E+Ol 2.29E+02 0.00E+OO 9.24E+OO O.OOE+OO O.OOE+OO 4.80E+03 O.OOE+OO Zn-65 5. 72E+05 0.0001 ZN 65 1.48E+03 1.70E+03 1.03E+03 3.26E+03 2.19E+03 O.OOE+OO 2.74E+04 O.OOE+OO 3.21E-01 3.68E-01 2.23E-01 7.06E-01 4.74E-01 O.OOE+OO 5.94E+OO O.OOE+OO SR89 2.76E+02 1.11 E+04 9.63E+03 O.OOE+OO O.OOE+OO O.OOE+OO 4.44E+04 0.00E+OO Sr-90 7.19E+03 0.0001 SR 90 1.83E+04 2.29E+04 9.1 OE+05 0.00E+OO O.OOE+OO O.OOE+OO 3.04E+05 0.00E+OO 4.98E-02 6.24E-02 2.48E+OO O.OOE+OO O.OOE+OO O.OOE+OO 8.28E-01 O.OOE+OO ZR95 7.38E+02 4.75E+03 3.39E+03 1.09E+03 1.72E+03 O.OOE+OO 5.61E+04 O.OOE+OO SB124 3.93E+02 1.29E+04 9.89E+02 1.87E+01 O.OOE+OO 2.40E+OO 7.86E+04 O.OOE+OO CS134 2.31E+04 3.30E+02 1.18E+04 2.69E+04 9.10E+03 O.OOE+OO 3.09E+03 0.00E+OO CS136 3.49E+03 3.71 E+02 1.24E+03 4.63E+03 2.71 E+03 O.OOE+OO 3.80E+02 O.OOE+OO Cs-137 5.19E+04 0.0001 CS137 1.36E+04 2.66E+02 1.52E+04 1.97E+04 7.07E+03 0.00E+OO 2.38E+03 O.OOE+OO 2.67E-01 5.23E-03 2.99E-01 3.87E-01 1.39E-01 O.OOE+OO 4.68E-02 O.OOE+OO BA140 8.14E+01 6.91E+03 1.24E+03 1.56E+OO 5.29E+01 0.00E+OO 4.02E+04 0.00E+OO CE141 4.85E+01 3.80E+03 6.31E+02 4.28E+02 1.99E+02 O.OOE+OO 1.15E+04 O.OOE+OO CE144 5.83E+03 2.59E+04 1.09E+05 4.53E+04 2.69E+04 O.OOE+OO 2.47E+05 O.OOE+OO 1131 6.50E+02 1.99E+02 7.99E+02 1.13E+03 1.94E+03 3.77E+05 0.00E+OO O.OOE+OO 1133 1.43E+02 2.81 E+02 2.7 4E+02 4.69E+02 8.21 E+02 6.81 E+04 O.OOE+OO O.OOE+OO 3.49E+Ol 2.67E+02 l.41E+02 l.07E+02 1.12E+OO 8.87E-04 5.28E+03 5.72E-05 Total 3.0GE-01 2.34E+OO 1.23E+OO 9.40E-01 9.79E-03 7.78E-06 4.63E+01 5.0lE-07 Appendix A, Page 2 of 5 CAL-R21-001 Revision 0

Teen-Inhalation:

X/Q 3.79E-06 PATHWA y INHALATION TOTAL BODY GI-LU BONE LIVER KIDNEY THYROID LUNG SKIN (mrem m 3)/(Ci sec)

Release TOTAL TOTAL GI-ill BONE LNER KIDNEY THYROID LUNG SKIN GI-LU BONE LIVER KIDNEY THYROID LUNG SKIN Fraction BODY BODY H-3 6. 62E+03 0. 0001 H 3 2.30E+01 2.30E+01 0.00E+OO 2.30E+01 2.30E+01 2.30E+01 2.30E+01 2.30E+01 5.77E-05 5.77E-05 0.00E+OO 5.77E-05 5.77E-05 5.77E-05 5.77E-05 5.77E-05 C-14 2.03E+04 0.0001 C 14 1.54E+02 1.54E+02 8.24E+02 1.54E+02 1.54E+02 1.54E+02 1.54E+02 O.OOE+OO 1.18E-03 1.18E-03 6.33E-03 1.18E-03 1.18E-03 1.18E-03 1.18E-03 O.OOE+OO AR 41 O.OOE+OO 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO O.OOE+OO KR 83m 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO O.OOE+OO O.OOE+OO 0.00E+OO KR 85m O.OOE+OO 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO KR 85 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO O.OOE+OO O.OOE+OO KR 87 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO 0.00E+OO O.OOE+OO KR 88 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO KR 89 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO 0.00E+OO 0.00E+OO 0.00E+OO O.OOE+OO KR 90 0.00E+OO 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO 0.00E+OO 0.00E+OO O.OOE+OO XE131m O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO XE133m 0.00E+OO 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO 0.00E+OO XE133 O.OOE+OO O.OOE+OO 0.00E+OO 0.00E+OO 0.00E+OO O.OOE+OO 0.00E+OO 0.00E+OO XE135m 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO XE135 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO XE137 O.OOE+OO O.OOE+OO 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO XE138 O.OOE+OO O.OOE+OO 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO CR51 4.28E+OO 9.51 E+01 0.00E+OO O.OOE+OO 9.73E+01 2.38E+OO 6.65E+02 O.OOE+OO Mn-54 4.25E+06 0.0001 MN 54 2.66E+02 2.12E+03 O.OOE+OO 1.62E+03 4.02E+02 O.OOE+OO 6.27E+04 O.OOE+OO 4.28E-01 3.41E+OO O.OOE+OO 2.61E+OO 6.47E-01 O.OOE+OO 1.01E+02 O.OOE+OO Fe-55 4.66E+08 0.0001 FE 55 1.75E+02 2.02E+02 1.06E+03 7.55E+02 O.OOE+OO 0.00E+OO 3.94E+03 O.OOE+OO 3.09E+01 3.56E+01 1.87E+02 1.33E+02 O.OOE+OO O.OOE+OO 6.95E+02 0.00E+OO FE 59 4.53E+02 5.64E+03 5.04E+02 1.17E+03 0.00E+OO 0.00E+OO 4.85E+04 O.OOE+OO C058 8.81 E+01 3.02E+03 O.OOE+OO 6.56E+01 0.00E+OO O.OOE+OO 4.25E+04 O.OOE+OO Co-60 6. 70E+07 0.0001 CO 60 6.27E+02 8.21E+03 0.00E+OO 4.79E+02 O.OOE+OO 0.00E+OO 2.76E+05 O.OOE+OO 1.59E+Ol 2.08E+02 O.OOE+OO 1.22E+Ol O.OOE+OO O.OOE+OO 7.00E+03 O.OOE+OO Zn-65 5. 72E+05 0.0001 ZN 65 1.98E+03 1.48E+03 1.22E+03 4.25E+03 2.74E+03 0.00E+OO 3.93E+04 O.OOE+OO 4.29E-01 3.21E-01 2.64E-01 9.21E-01 5.94E-01 O.OOE+OO 8.51E+OO O.OOE+OO SR 89 3.96E+02 1.18E+04 1.38E+04 O.OOE+OO O.OOE+OO O.OOE+OO 7.67E+04 O.OOE+OO Sr-90 7.19E+03 0.0001 SR 90 2.11 E+04 2.42E+04 1.05E+06 O.OOE+OO O.OOE+OO 0.00E+OO 5.23E+05 0.00E+OO 5.75E-02 6.59E-02 2.86E+OO O.OOE+OO O.OOE+OO O.OOE+OO 1.42E+OO O.OOE+OO ZR 95 9.98E+02 4.72E+03 4.63E+03 1.45E+03 2.14E+03 0.00E+OO 8.52E+04 O.OOE+OO SB124 5.32E+02 1.26E+04 1.37E+03 2.52E+01 O.OOE+OO 3.09E+OO 1.22E+05 0.00E+OO CS134 1.74E+04 3.09E+02 1.59E+04 3.58E+04 1.19E+04 O.OOE+OO 4.63E+03 0.00E+OO CS136 4.34E+03 3.45E+02 1.63E+03 6.15E+03 3.49E+03 0.00E+OO 5.64E+02 0.00E+OO Cs-137 5.19E+04 0.0001 CS137 9.86E+03 2.69E+02 2.13E+04 2.69E+04 9.63E+03 O.OOE+OO 3.83E+03 O.OOE+OO 1.94E-01 5.29E-03 4.19E-01 5.29E-01 1.89E-01 O.OOE+OO 7.53E-02 O.OOE+OO BA140 1.12E+02 7.26E+03 1.73E+03 2.13E+OO 7.23E+01 O.OOE+OO 6.43E+04 0.00E+OO CE141 6.88E+01 3.99E+03 9.00E+02 6.02E+02 2.81 E+02 O.OOE+OO 1.95E+04 O.OOE+OO CE144 8.33E+03 2.74E+04 1.55E+05 6.40E+04 3.83E+04 0.00E+OO 4.25E+05 0.00E+OO 1131 8.37E+02 2.06E+02 1.12E+03 1.56E+03 2.66E+03 4.63E+05 O.OOE+OO O.OOE+OO 1133 1.97E+02 3.26E+02 3.87E+02 6.50E+02 1.14E+03 9.25E+04 O.OOE+OO O.OOE+OO 4.79E+Ol 2.48E+02 1.91E+02 1.49E+02 l.43E+OO 1.24E-03 7.81E+03 5.77E-05 Total 4.20E-01 2.17E+o0 1.67E+OO 1.31E+OD l.2SE-02 l.09E-OS 6.SSE+ol S.OSE-07 Appendix A, Page 3 of 5 CAL-R21-001 Revision 0

Child-Inhalation:

X/Q 3.79E-06 PATHWAY INHALAllON TOTAL BODY GI-LU BONE LIVER KIDNEY THYROID LUNG SKIN 3

(mrem m )/(Ci sec)

Release TOTAL TOTAL GI-LL! BONE LIVER KIDNEY THYROID LUNG SKIN GI-LU BONE LIVER KIDNEY THYROID LUNG SKIN Fraction BODY BODY H-3 6.62E+03 0.0001 H 3 2.03E+01 2.03E+01 O.OOE+OO 2.03E+01 2.03E+01 2.03E+01 2.03E+01 2.03E+01 5.09E-05 5.09E-05 O.OOE+OO 5.09E-05 5.09E-05 5.09E-05 5.09E-05 5.09E-05 C-14 2.03E+04 0.0001 C 14 2.13E+02 2.13E+02 1.14E+03 2.13E+02 2.13E+02 2.13E+02 2.13E+02 O.OOE+OO 1.64E-03 1.64E-03 8.76E-03 1.64E-03 1.64E-03 1.64E-03 1.64E-03 O.OOE+OO AR41 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO KR 83m O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO 0.00E+OO O.OOE+OO KR 85m O.OOE+OO 0.00E+OO O.OOE+OO 0.00E+OO 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO KR 85 0.00E+OO O.OOE+OO O.OOE+OO 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO KR 87 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO KR 88 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO 0.00E+OO 0.00E+OO KR 89 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO KR 90 O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO XE131m O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO XE133m O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO XE133 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO O.OOE+OO 0.00E+OO 0.00E+OO XE135m 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO 0.00E+OO XE135 O.OOE+OO O.OOE+OO 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO XE137 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO O.OOE+OO 0.00E+OO O.OOE+OO XE138 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO CR 51 4.88E+OO 3.42E+01 0.00E+OO O.OOE+OO 7.70E+01 2.71 E+OO 5.39E+02 0.00E+OO Mn-54 4.25E+06 0.0001 MN 54 3.01E+02 7.26E+02 O.OOE+OO 1.36E+03 3.17E+02 0.00E+OO 5.01E+04 O.OOE+OO 4.84E-01 1.17E+OO O.OOE+OO 2.19E+OO 5.lOE-01 O.OOE+OO 8.06E+Ol 0.00E+OO Fe-55 4.66E+08 0.0001 FE 55 2.46E+02 9.09E+02 1.50E+03 7.97E+02 O.OOE+OO O.OOE+OO 3.52E+03 O.OOE+OO 4.34E+Ol l.60E+02 2.65E+02 l.41E+02 O.OOE+OO O.OOE+OO 6.21E+02 O.OOE+OO FE 59 5.29E+02 2.24E+03 6.56E+02 1.06E+03 O.OOE+OO O.OOE+OO 4.02E+04 0.00E+OO CO 58 1.00E+02 1.09E+03 0.00E+OO 5.61 E+01 0.00E+OO O.OOE+OO 3.52E+04 0.00E+OO Co-60 6. 70E+07 0.0001 CO 60 7.19E+02 3.05E+03 O.OOE+OO 4.15E+02 O.OOE+OO 0.00E+OO 2.24E+05 O.OOE+OO 1.82E+Ol 7.74E+01 O.OOE+OO 1.05E+Ol O.OOE+OO O.OOE+OO 5.68E+03 O.OOE+OO Zn-65 5.72E+05 0.0001 ZN 65 2.23E+03 5.17E+02 1.35E+03 3.58E+03 2.26E+03 O.OOE+OO 3.16E+04 O.OOE+OO 4.83E-01 l.12E-Ol 2.92E-01 7.75E-01 4.90E-01 O.OOE+OO 6.85E+OO O.OOE+OO SR 89 5.45E+02 5.29E+03 1.90E+04 O.OOE+OO O.OOE+OO O.OOE+OO 6.85E+04 O.OOE+OO Sr-90 7.19E+03 0.0001 SR 90 2.43E+04 1.09E+04 1.22E+06 0.00E+OO O.OOE+OO O.OOE+OO 4.69E+05 0.00E+OO 6.62E-02 2.97E-02 3.32E+OO O.OOE+OO O.OOE+OO O.OOE+OO 1.28E+OO O.OOE+OO ZR 95 1.17E+03 1.94E+03 6.02E+03 1.32E+03 1.89E+03 O.OOE+OO 7.07E+04 O.OOE+OO SB124 6.34E+02 5.20E+03 1.82E+03 2.35E+01 O.OOE+OO 3.99E+OO 1.03E+05 O.OOE+OO CS134 7 .13E+03 1.22E+02 2.06E+04 3.20E+04 1.05E+04 O.OOE+OO 3.83E+03 O.OOE+OO CS136 3.68E+03 1.32E+02 2.06E+03 5.42E+03 3.03E+03 O.OOE+OO 4.60E+02 0.00E+OO Cs-137 5.19E+04 0.0001 CS137 4.06E+03 1.15E+02 2.87E+04 2.61E+04 8.94E+03 O.OOE+OO 3.30E+03 0.00E+OO 7.98E-02 2.26E-03 5.64E-01 5.13E-01 l.76E-01 O.OOE+OO 6.49E-02 O.OOE+OO BA140 1.37E+02 3.23E+03 2.35E+03 2.05E+OO 6.69E+01 0.00E+OO 5.51E+04 O.OOE+OO CE141 9.19E+01 1.79E+03 1.24E+03 6.18E+02 2.71E+02 O.OOE+OO 1.72E+04 O.OOE+OO CE144 1.15E+04 1.23E+04 2.15E+05 6.72E+04 3.71E+04 0.00E+OO 3.80E+05 0.00E+OO 1131 8.65E+02 9.00E+01 1.52E+03 1.52E+03 2.50E+03 5.17E+05 O.OOE+OO O.OOE+OO 1133 2.44E+02 1.74E+02 5.26E+02 6.43E+02 1.07E+03 1.22E+05 O.OOE+OO O.OOE+OO 6.28E+01 2.39E+02 2.69E+02 1.55E+02 l.18E+OO 1.69E-03 6.39E+03 5.09E-05 Total 5.50E-01 2.lOE+OO 2.36E+OO 1.36E+OO 1.03E-02 1.48E-05 5.60E+Ol 4.46E-07 Appendix A, Page 4 of 5 CAL-R21-001 Revision 0

Infant-Inhalation:

X/Q 3.79E-06 PATHWAY= INHALATION TOTAL BODY LIVER KIDNEY THYROID LUNG SKIN (mrem ~~/(Ci sec)

Release TOTAL TOTAL GI-LL! BONE LIVER KIDNEY THYROID LUNG SKIN Gl-LLI BONE LIVER KIDNEY THYROID LUNG SKIN Fraction BODY BODY H-3 6.62E+03 0.0001 H 3 1.17E+01 1.17E+01 O.OOE+OO 1.17E+01 1.17E+01 1.17E+01 1.17E+01 1.17E+01 2.93E-05 2.93E-05 O.OOE+OO 2.93E-05 2.93E-05 2.93E-05 2.93E-05 2.93E-05 C-14 2.03E+04 0.0001 C 14 1.68E+02 1.68E+02 8.39E+02 1.68E+02 1.68E+02 1.68E+02 1.68E+02 O.OOE+OO 1.29E-03 1.29E-03 6.45E-03 1.29E-03 1.29E-03 1.29E-03 1.29E-03 O.OOE+OO AR41 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO KR83m O.OOE+OO O.OOE+OO 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO KR85m O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO 0.00E+OO 0.00E+OO O.OOE+OO KR 85 O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO KR 87 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO O.OOE+OO O.OOE+OO KR 88 O.OOE+OO 0.00E+OO 0.00E+OO 0.00E+OO 0.00E+OO O.OOE+OO 0.00E+OO 0.00E+OO KR 89 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO KR 90 O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO O.OOE+OO 0.00E+OO 0.00E+OO O.OOE+OO XE131m O.OOE+OO 0.00E+OO 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO XE133m O.OOE+OO O.OOE+OO 0.00E+OO 0.00E+OO 0.00E+OO 0.00E+OO O.OOE+OO O.OOE+OO XE133 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO XE135m O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO O.OOE+OO 0.00E+OO 0.00E+OO 0.00E+OO XE135 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO XE137 O.OOE+OO 0.00E+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO 0.00E+OO O.OOE+OO XE138 O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO O.OOE+OO CR 51 2.84E+OO 1.13E+01 O.OOE+OO O.OOE+OO 4.18E+01 1.83E+OO 4.06E+02 0.00E+OO Mn-54 4.25E+06 0.0001 MN 54 1.58E+02 2.24E+02 0.00E+OO 8.05E+02 1.58E+02 O.OOE+OO 3.17E+04 0.00E+OO 2.54E-01 3.61E-01 O.OOE+OO 1.30E+OO 2.54E-01 O.OOE+OO 5.lOE+Ol O.OOE+OO Fe-55 4.66E+08 0.0001 FE 55 1.05E+02 3.47E+01 6.27E+02 3.72E+02 O.OOE+OO O.OOE+OO 2.77E+03 O.OOE+OO 1.85E+Dl 6.12E+OO 1.11E+02 6.56E+Ol O.OOE+OO 0.00E+DO 4.89E+02 O.OOE+OO FE 59 3.00E+02 7.86E+02 4.31E+02 7.45E+02 O.OOE+OO O.OOE+OO 3.23E+04 O.OOE+OO COSS 5.77E+01 3.52E+02 O.OOE+OO 3.87E+01 O.OOE+OO O.OOE+OO 2.46E+04 0.00E+OO Co-60 6. 70E+07 0. 0001 co 60 3.74E+02 1.01 E+03 O.OOE+OO 2.54E+02 O.OOE+OO O.OOE+OO 1.43E+05 O.OOE+OO 9.49E+OO 2.56E+01 0.00E+OO 6.44E+OO O.OOE+OO 0.00E+OO 3.63E+03 O.OOE+OO Zn-65 5. 72E+05 0.0001 ZN 65 9.86E+02 1.63E+03 6.12E+02 1.98E+03 1.03E+03 O.OOE+OO 2.05E+04 0.00E+OO 2.14E-01 3.53E-01 1.33E-01 4.29E-01 2.23E-01 O.OOE+OO 4.44E+OO O.OOE+OO SR 89 3.61 E+02 2.03E+03 1.26E+04 O.OOE+OO O.OOE+OO O.OOE+OO 6.43E+04 O.OOE+OO Sr-90 7.19E+03 0.0001 SR 90 9.89E+03 4.15E+03 4.91E+05 O.OOE+OO O.OOE+OO O.OOE+OO 3.55E+05 0.00E+OO 2.69E-02 1.13E-02 1.34E+OO O.OOE+OO O.OOE+OO O.OOE+OO 9.67E-01 O.OOE+OO ZR 95 6.43E+02 6.88E+02 3.64E+03 8.84E+02 9.86E+02 O.OOE+OO 5.55E+04 O.OOE+OO SB124 3.80E+02 1.87E+03 1.20E+03 1.76E+01 0.00E+OO 3.20E+OO 8.40E+04 0.00E+OO CS134 2.36E+03 4.21 E+01 1.25E+04 2.23E+04 6.02E+03 O.OOE+OO 2.53E+03 O.OOE+OO CS136 1.68E+03 4.53E+01 1.53E+03 4.28E+03 1.79E+03 O.OOE+OO 3.7 4E+02 O.OOE+OO Cs-137 5.19E+04 0.0001 CS137 1.44E+03 4.21E+01 1.74E+04 1.94E+04 5.45E+03 O.OOE+OO 2.26E+03 0.00E+OO 2.83E-02 8.27E-04 3.42E-01 3.SlE-01 1.07E-01 O.OOE+OO 4.44E-02 O.OOE+OO BA140 9.19E+01 1.22E+03 1.77E+03 1.77E+OO 4.25E+01 O.OOE+OO 5.07E+04 O.OOE+OO CE141 6.31 E+01 6.85E+02 8.78E+02 5.29E+02 1.66E+02 0.00E+OO 1.64E+04 0.00E+OO CE144 5.58E+03 4.69E+03 1.01E+05 3.83E+04 1.70E+04 O.OOE+OO 3.12E+05 O.OOE+OO 1131 6.21E+02 3.36E+01 1.20E+03 1.41E+03 1.64E+03 4.69E+05 O.OOE+OO 0.00E+OO 1133 1.77E+02 6.85E+01 4.18E+02 6.08E+02 7.10E+02 1.13E+05 O.OOE+OO O.OOE+OO 2.85E+01 3.25E+01 1.12E+02 7.42E+Ol 5.86E-01 1.32E-03 4.17E+D3 2.93E-05 Total 2.50E-01 2.SSE-01 9.86E-01 6.50E-Ol 5.14E-03 l.16E-05 3.66E+Ol 2.57E-07 Appendix A, Page 5 of 5 CAL-R21-001 Revision 0

v t e Letter Sequence Request
EPID:L-2021-LLA-0021, License Amendment Request to Approve Pilgrim Nuclear Power Station Independent Spent Fuel Storage Installation Only Emergency Plan (Approved, Closed)
Initiation Request, Request, Request, Request, Request, Request, Request, Request, Request, Request Acceptance Supplement Administration Questions 28 June 2021 9 July 2021 16 August 2021 16 August 2021 26 August 2021 15 September 2021 15 September 2021 1 December 2021 1 December 2021 Answers 29 July 2021 7 September 2021 Results Approval, Approval, Approval Other: ML21251A173, ML21265A303
MONTHYEAR2021-06-24 [Table View]

NG-21-0010, License Amendment Request (TSCR-192): Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan and Emergency Action Level Scheme

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NG-21-0010, License Amendment Request (TSCR-192): Independent Spent Fuel Storage Installation (ISFSI) Emergency Plan and Emergency Action Level Scheme

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