Text

ISFSI - Supplemental OPPD Response to NRC Request for Additional Information License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6
	ML15308A095
Person / Time
Site:	Fort Calhoun
Issue date:	11/02/2015
From:	Cortopassi L; Omaha Public Power District
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
	LIC-15-0121, TAC MF5466
	Download: ML15308A095 (166)
	v • d • e

{{#Wiki_filter:Omaha Public Power Districi 444 South 1 6th Street Mall Omaha, NE 68102-224 7 LIC-1 5-0121 November 2, 2015 U.S. Nuclear Reguiatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285 Fort Calhoun Station Independent Spent Fuel Storage Installation NRC Docket No. 72-054

Subject:

Supplemental OPPD Response to NRC Request for Additional Information RE: License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6 (TAC No. MF5466)

References:

1. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk),

                          "License Amendment Request 14-06 to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors," dated December 26, 2014 (LIC-1 4-0098) (ML14365A123)

2. Letter from NRC (C. F. Lyon) to OPPD (L. P. Cortopassi), "Fort Calhoun Station, Unit No. 1 -Request for Additional Information Re: License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6 (TAC No. MF5466)," dated July 14, 2015 (NRC-i5-061 ) (ML15194A272)

3. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk),

                          "OPPD Response to NRC Request for Additional Information RE: License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6 (TAC No. MF5466)," dated September 11, 2015 (LIC-15-0 102)

Following a teleconference with NRC Staff on October 1, 2015, the Omaha Public Power District (OPPD) is supplementing its Reference 3 response to the Reference 2 NRC request for additional information (RAI) regarding License Amendment Request (LAR) 14-06 (Reference 1). LAR 14-06 proposes to revise the Emergency Plan for Fort Calhoun Station to adopt the Nuclear Energy Institute's (NEI's) revised Emergency Action Level (EAL) scheme described in NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors. Axes Employment with Equal Opportunity

U. S. Nuclear Regulatory Commission LIC-1 5-0121 Page 2 OPPD has revised its position and is electing to remove the post-accident main steam (gas) monitor (RM-064) from Initiating Condition (IC) RG1 and RS1 Emergency Action Level (EAL) schemes. As such, Enclosure 1 contains a revised response to RAIs No. 6 and 7 with a revision bar in the right margin to denote the location of new information. Enclosure 2 contains a revised procedure matrix reflecting the removal of RM-064 from RG1 and RSI. RAI No. 14 regarding reliable spent fuel pool (SFP) instrumentation required by NRC Order EA-12-051 was also discussed during the teleconference. The date for completing the installation of this instrumentation and placing it into service is the 2 nd quarte rof 2016. Thus, Enclosure 3 is the EAL Basis Document with IC RA2 marked "PRE MODIFICATION per NRC ORDER EA 051,." Following installation of the SFP instrumentation, the EAL Basis Document will incorporate IC RG2, RS2, and RA2 contained in Enclosure 4 whose pages are marked "POST MODIFICATION per NRC ORDER EA-12-051 ." As noted in Reference 3, OPPD continues to request an implementation date of June 30, 2016 in order to coordinate implementation of the proposed changes with the training cycles currently scheduled for the year. This letter contains no regulatory commitments. If you should have any questions regarding this submittal or require additional information, please contact Mr. Bill R. Hansher, Principal Regulatory Engineer, at 402-533-6894. Respectfully, Louis P. Cortopassi Site Vice President and CNO LPC/EJ P/inle

Enclosures:

1. Revised OPPD Response to NRC RAIs 6 and 7 Regarding License Amendment Request (LAR) 14-06 *

2. Procedure Matrix

3. EAL Basis Document

4. IC RG2, RS2, and RA2 Pages Marked "POST MODIFICATION per NRC ORDER EA-12-051" c: M. L. Dapas, NRC Regional Administrator, Region IV (w/o Enclosures 2, 3, 4)

C. F. Lyon, NRC Senior Project Manager S. M. Schneider, NRC Senior Resident Inspector (w/o Enclosures 2, 3, 4) Manager Radiation Control Program, Nebraska Health & Human Services, R & L Public Health Assurance, State of Nebraska (w/o Enclosures 2, 3, 4)

LIC-1 5-01 21 Page 1 Revised OPPD Response to NRC RAts 6 and 7 Regarding License Amendment Request (LAR) 14-06

LIC-15-0121 Enclosure 1 Page 2 REQU EST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO ADOPT EMERGENCY ACTION LEVEL SCHEME PURSUANT TO NEl 99-01. REVISION 6 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION, UNIT NO. 1 DOCKET NO. 50-285 By letter dated December 26, 2014, Omaha Public Power District (OPPD, the licensee) requested approval for an emergency action level (EAL) scheme change for the Fort Calhoun Station, Unit 1 (FCS) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14365A123). OPPD proposes to revise its current EAL scheme to one based upon Revision 6 to Nuclear Energy Institute (NEI) document NEI 99-01 , "Development of Emergency Action Levels for Non-Passive Reactors," November 2012 (ADAMS Accession No. ML12326A805), instead of Revision 5. The requests for additional information (RAIs) listed below, in regards to Attachment 2, Enclosure 2C, "Emergency Action Level Basis Document," of the submittal, are needed to support U.S. Nuclear Regulatory Commission (NRC) staff's continued technical review of the proposed EAL scheme change. FC-RAI-06 For Initiating Condition (IC) RG1, radiation monitor (RM)-064 was removed from Table RI. RM-064 is included in the currently approved AG1 EAL (ADAMS Accession No. ML13358A327). A justification for the removal of RM-064 was not provided in Attachment 2, Enclosure 2A "EAL Comparison Matrix Document." Please provide justification for the removal of RM-064 from the RG1. FC-RAI-06 Response (REVISED) A revision to EPIP-EOF-6, "Offsite Dose Assessment using the Unified RASCAL Interface" is in process (EC 67069) to require the use of OI-CE-1, "Condenser Evacuation System Normal Operation," to align condenser off-gas to the auxiliary building (AB) stack. OPPD's document change process tracks changes to emergency plan implementing procedures (EPIPs); OPPD anticipates that the revision to EPIP-EOF-6 will be issued no later than mid-December 2015. On the occurrence of a primary to secondary leak, radiation monitor (RM) RM-057 (condenser off gas radiation monitor) is the effluent monitor for this release path. When RM-057 detects 1 E+07 counts per minute (cpm) and prior to radiation levels reaching the RM-063 (AB stack radiation monitor) Site Area Emergency (SAE) threshold, the revision to Procedure EPIP-EOF-6 noted above will require condenser off gas to be manually lined up to the AB Stack by Operators outside the control room. The line-up takes approximately 20 minutes to accomplish. When the alignment is complete, RM-063 is the effluent monitor for this release path. In the event of a primary to secondary leak, with a steam generator safety valve open, dose assessment would be used for the determination and magnitude of the release. Therefore, the RM-064 (post-accident main steam line RM) is not used in this EAL scheme. FC-RAI-07 For IC RS1, Table R1 has monitors RM-063, RM-052, and RM-043 listed. IC AS1, in Revision 2a of TBD-EPIP-OSC-1A dated December 11, 2013 (ADAMS Accession No. ML

LIC-1 5-01 21 Page 3 13358A327), and the Revision 5 conversion request dated August 15, 2008, has RM-064 listed in addition to RM-063, but does not include RM-052 and RM-043. These changes are not identified in the Attachment 2, Enclosure 2A, "EAL Comparison Matrix Document." Please provide justification for the removal of monitor RM-064 and the addition of RM-052 and RM-043 to the EAL. FC-RAI-07 Response (REVISED) A revision to EPIP-EOF-6, "Offsite Dose Assessment using the Unified RASCAL Interface" is in process (EC 67069) to require the use of OI-CE-1, "Condenser Evacuation System Normal Operation," to align condenser off-gas to the AB stack. OPPD's document change process tracks changes to EPIPs; OPPD anticipates that revision to EPIP-EOF-6 will be issued no later than mid-December 2015. On the occurrence of a primary to secondary leak, RM-057 (condenser off gas radiation monitor) is the effluent monitor for this release path. When RM-057 detects 1 E+07 counts per minute (cpm) and prior to radiation levels reaching the RM-063 (AB stack radiation monitor) SAE threshold, the revision to Procedure EPIP-EOF-6 noted above will require condenser off gas to be manually lined up to the AB stack by Operators outside the control room. The line-up takes approximately 20 minutes to accomplish. When the alignment is complete, RM-063 is the effluent monitor for this release path. In the event of a primary to secondary leak, with a steam generator safety valve open, dose assessment would be used for the determination and magnitude of the release. Therefore, the RM-064 (post-accident main steam line RM) is not used in this EAL scheme. The following has been added to the RS1 Comparison Matrix justification column to justify the addition of RM-052 and RM-043 rad monitors to the RS1 threshold.

     *RM-052 and RM-043 were added as they are typical radiological effluent pathway monitors with ranges that can detect EAL thresholds at RS1 levels as calculated by site calculation RP-AA-1010 FC-15-003 (RA 13-008) Rev. 1 included in OPPD letter LIC         0102 dated September 11, 2015 as Attachment 3.

LIC-1 5-01 21 Page 1 Procedure Matrix (Pages FC 3-11 through FC 3-32)

LIC-1 5-0121 Enclosure 3 Page 1 EAL Basis Document' 1 IC RA2 Pages Marked "PRE MODIFICATION per NRC ORDER EA-12-051"

Ft. Calhoun Station Omaha Public Power District Emergency Action Level Technical Basis Page Index General Site Area Alert Unusual Event EAL Pg. EAL Pg. EAL Pg. EAL Pg. RG1 3-34 RS1 3-36 RA1 3-38 RU1 3-41 _____RA2 3-45 RU2 3-47 ___________ ________ __ _ RA3 3-49 RU3 3-52 EG1 3-53 FS1 3-54 FA1 3-55 _________ Fuel Clad RCS Containment ECl 3-56 R~l 3-61 GT1 3-66 FG2 3-57 RG2 3-63 GT2 3-69 FG3 3-58 RG3 3-64 GT3 3-71 GT4 3-72 FG5 3-60 RC5 3-65 GT5 3-78 MG1 3-79 MS1 3-81 MA1 3-83 MU1 3-85 MG2 3-86 MS2 3-88 MS3 3-89 MA3 3-91 MU3 3-93 MA4 3-96 MU4 3-98 MA5 3-100 ____ MU6 3-102 MU7 3-104 ___ ______ ______ ___ MU8 3-106 GAl 3-108 GUi 3-110 _______ ______ CA2 3-'112 _ _ _ GU3 3-114 __ ___CU4 _ 3-116 GAS 3-118 GUs 3-121 GG6 3-123 GS6 3-127 CA6 3-130 GU6 3-132 HG1 3-134 HS1 3-136 HAl 3-138 HU1 3-141 HS2 3-143 HA2 3-145 HU3 3-146 HU4 3-150 ___ ___ ___ HAS 3-151 ___HU6 ___ 3-154 HG7 3-157 HS7 3-158 HA7 3-159 HU7 3-160 ______E-HU1 3-161 Month 20XX FC 3-33 Mont 2OX FG -33EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS RG1 Release of gaseous radioactivity resulting in offsite dose greater than 1000 mRem TEDE or 5000 mRem thyroid ODE. 1,2, 3, 4,5, D Notes:

 *The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
 *If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.
 *Classification based on effluent monitor readings assumes that a release path to the environment is established. Ifthe effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

1. Readings on ANY Table R1 Effluent Monitor > Table Ri value for_> 15 minutes.

OR

2. Dose assessment Using actual meteorology indicates doses at or beyond the site boundary of EITHER:

a. > 1000 mRem TEDE OR

b. > 5000 mRem CDE Thyroid OR

3. Field survey results at or beyond the site boundary indicate EITHER:

a. Gamma (closed window) dose rates >1000 mR/hr are expected to continue for _> 60 minutes.

OR

b. Analyses of field survey samples indicate > 5000 mRem CDE Thyroid for 60 minutes of inhalation.

Month 20XX FC 3-34 Mont 2OX FO -34EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS/IRADIOLOGICAL EFFLUENTS RG1 (cont) Table R1 Effluent Monitor Thresholds Effluent Monitor Description General Emergency RM-063 AB Stack(Post Accident Gas) 3.71 E+OO uCi/cc Basis: - ** !* i :, ii?*iii

                           -      :ii.*i!i*i*:!*  ** ! TI*T**!:i:?  *:!iii*:-*:~*  ii::~ iiii* ~ i*:;:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude will require implementation of protective actions for the public. Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions. The TEDE dose is set at the EPA PAG of 1000 mRem while the 5000 mRem thyroid ODE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid ODE.

1. NEI 99-01 Rev 6, AG1 Month 20XX FC 3-35 Mont 2OX FO

                                                                                   -35EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Ft Calhoun Station Omaha Public Public Power Power District District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RS1 Ilnitiatin*g!Condlition:i..iii!, i,.:r;iii :411'1 i*" Release of gaseous radioactivity resulting in offsite dose greater than 100 mRem TEDE or 500 mRem thyroid CDE. 1,2, 3,4, 5, D Em ergency Action Level (EAL):* ...... ........... '...... .. .... ..... . : Notes:

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
If an ongoing release is detected and the release start time is unknown, assume that:

the release duration has exceeded 15 minutes. "

 *Classification based on effluent monitor readings assumes that a release path to the' environment is established. If the effluent flow past an effluent monitor is known to ,

have stopped due to actions to isolate the release path, then the effluent monitor ::i reading is no longer valid for classification purposes.

 *The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

1. Readings on ANY Table Ri Effluent Monitor > Table RI value for_> 15 minutes.

OR

2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER:

a. > 100 mRem TEDE OR

b. > 500 mRem CDE Thyroid OR

3. Field survey results at or beyond the site boundary indicate EITHER:

a. Gamma (closed window) dose rates >100 mR/hr are expected to continue for > 60 minutes.

OR

b. Analyses of field survey samples indicate > 500 mRem CDE Thyroid for 60 minutes of inhalation.

Month 20XX FC 3-36 Mont 2OX FO-36EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Ft. Calhoun Station Omaha Public Public Power District Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RS1 (cont) Table RI Effluent Monitor Thresholds Effluent Monitor Description Site Area Emergency AB Stack RM-063 3.71 E-01 uCi/co (Post Accident Gas) RM-052 AB Stack (Gas) 6.23 E+06 cpm RM-043 LRWPB Stack (Gas) 5.44 E+'06 cpm This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public. Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions. The TEDE dose is set at 10% of the EPA PAG of 1000 mRem while the 500 mRem thyroid ODE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid ODE. Escalation of the emergency classification level would be via IC RGI.

1. NEI 99-01 Rev 6, AS1 Month 20XX FC 3-37 Mont 2OX FO-37EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS RA1 ,initiating Condition: . ... . .... . . Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mRem TEDE or 50 mRem thyroid CDE. ,Operating Mode Applicabilityi: :* **-..i"*ii*": i ... 1, 2, 3,4,5, D Emergency Action Level (EAL): .... _- :- ..... ,' Notes:

 *The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
 *If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.
 *Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.
 *The pre-calculated effluent monitor values presented in EAL #1 should, be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for>_ 15 minutes.

OR

2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER:

a. >I10mRem TEDE OR

b. > 50 mRem CDE Thyroid OR

3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than EITHER of the following at or beyond the site boundary

a. 10 mRem TEDE for 60 minutes of exposure OR

b. 50 mRem CDE Thyroid for 60 minutes of exposure OR Month 20XX FC 3-38 Mont 2OX FC

                                                                              -38EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA1 (cont) Emergency Action- LeVel (EAL) (cont)i: .,i .. ,i71:,* ::i, ,* _,

4. Field survey results at or beyond the site boundary indicate EITHER:

a. Gamma (closed window) dose rates > 10 mR/hr are expected to continue for > 60 minutes.

OR

b. Analyses of field survey samples indicate > 50 mRem CDE Thyroid for 60 minutes of inhalation.

Table RI Effluent Monitor Thresholds Effluent Monitor Description Alert RM-063 AB Stack(Post Accident Gas) 3.71 E-02 uCi/cc RM-062 AB Stack (Gas) 5.25 E+05 cpm RM-052 AB Stack (Gas) 6.23E+05 cpm RM-043 LRWPB Stack (Gas) 5.44 E+05 cpm RM-057 Condenser Off-Gas 1.34 E+08 cpm Basis:.. . . . , . , .. . . ..... 4 , This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release). Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions. The TEDE dose is set at 1% of the EPA PAG of 1000 mRem while the 50 mRem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid ODE. Escalation of the emergency classification level would be via IC RS1. Month 20XX FC 3-39 Mont 2OX FC-39EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA1 (cont) Basis Reference fe e c s):,,ii:i~~~~i iii., , i iii-~

_i *, i* :,:i:,i*ii,,i iiiiiiiiiii ,iii~ ,

1. NEI 99-01 Rev 6, AA1 Month 20XX FC 3-40 Mont 2OX FO -40EP-XX-XXXX (Revision XX)

Ft_ Cnlhoun Rtntinn *mnhn PHhliP. Pnw*_r l'}i_*trint Ft OI lhni jnB t tinvn fVl m~hm P*mjhIirV P Vuu~r flktr RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU1

initiatingi Co~ndition:i~i*ii~i*i **:ii****!iil- i* **i:iii* *ii Release of gaseous or liquid radioactivity greater than 2 times the ODOM limits for 60 minutes or longer.

1,2,3,4,5, D Notes:

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
Ifan ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes.

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

1. Reading on ANY Table R2 effluent monitors > 2 times alarm setpoint established by a current radioactive release discharge permit for _>60 minutes.

OR

2. Readings on ANY Table R3 Effluent Monitor > Table R3 value for_> 60 minutes.

OR

3. Sample analyses for gaseous or liquid releases indicate concentrations or release rates > 2 times ODCM Limit with a release duration of _>60 minutes.

Month 20XX FC 3-41 Mont 2OX FO -41EP-XX-XXXX (Revision XX)

Ft. Calhoun Station F.....lh..n........n Omnhn Aslmiah PHhlir_

                                                                                     * **hvi Pnw*_r
                                                                                              *Pnmwvm~

ni_*trirt flktrirv RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RUl (cont) Emergency Action Level (EAL) (cant): Table R2 Effluent Monitor Thresholds Effluent Monitor Description 2X High Alarm RM-055 (if discharge not Liquid 28E0 p isolated) Minimum 1 CW 28E0 p Pump Discharge Header RM-055 (if discharge not Lqi isolated) Minimum 2 RW iqi 8.OOE+05 cpm Pump Discharge Header Table R3 Effluent Monitor Thresholds Effluent Monitor Description NOUE RM-062 AB Stack (Gas) 3.25 E+04 cpm RM-052 AB Stack (Gas) 3.85 E+04 cpm RM-043 LRWPB Stack (Gas) 3.37 E+04 cpm RM-057 Condenser Off-Gas 8.83 E+06 cpm RM-054A (if SG blowdown is not isolated) SG biowdown 9.86E+04 cpm RM-054B (if SG blowdown is not isolated) S lwon98E0 p Month 20XX FC 3-42 Mont 2OX FO -42EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS RU1 (cont) {B asis-:! :7 : !: 1i *i;:J : ** *:* °ii : 7 ! * *:: :;! r: : * :,ii: ! i* This 1(3 addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release). It includes any gaseous or liquid radiological release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared. Nuclear power plants incorporate design features intended to control the release of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases. The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls. Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions. Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL. EAL #1 Basis This EAL addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This EAL will typically be associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas). The effluent monitors listed are those normally used for planned discharges. If a discharge is performed using a different flowpath or effluent monitor other than those listed (e.g., a portable or temporary effluent monitor), then the declaration criteria will be based on the monitor specified in the Discharge Permit. EAL #2 Basis This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous and liquid effluent pathways. EAL #3 Basis This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.). Escalation of the emergency classification level would be via 1(C RAl. Month 20XX FC 3-43 Mont 2OX FO

                                                                              -43EP-XX-XXXX (Revision XX)

Omaha Public Power District Ft. Calhoun StationOmhPulcowrDsit RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS RU1 (cont) Basis Referencei~ii.iii*,!.~* fe iii.-.*i.,i* i*.i.i ,~~i*, ,,.*ii i~i,,iiii.... *.i.,s):.-*i iii.*iil

1. NEI 99-01 Rev 6, AU1 Month 20XX FC 3-44 Mont 2OX FO -44EP-XX-XXXX (Revision XX)

PRE MODIFICATION per NRC ORDER Ft. Calhoun Station EA-12-051 Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA2 Significant lowering of water level above, or damage to, irradiated fuel. 1,2,3,4,5, D Emergency, Action Level.(EAL): *-' ' -::.- -* *.= -**.!*;* : -,**** ,* i** ::,*** :*

1. Uncovery of irradiated fuel in the REFUELING PATHWAY.

OR

2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by ANY Table R4 Radiation Monitor reading >1000 mRem/hr Table R4

___________ (Radiation Monitors RMS Area Monitored RM-73,74,75 Containment Rad Monitor RM-085,87 Auxiliary Building Rad Monitor PortbleRadContainment and auxiliary Building near fuel handling areas Monitor REFUELING PATHWAY: all the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange. 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. This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly. These. events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment. As such, they represent an actual or potential substantial degradation of the level of safety of the plant. This IC applies to irradiated fuel that is licensed for dry storage up to the point that the loaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss of the CONFINEMENT BOUNDARY is classified in accordance with IC E-HUI. Month 20XX FC 3-45 Mont 2OX FC -45EP-XX-XXXX (Revision XX)

PRE MODIFICATION per NRC ORDER EA-12-051 Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS RA2 (cont) Beasis i(co t),)i** i!i~*ii ~i **-i - -i!i~i !*!

                                                                -!i~i*i*i                   iI!*i*iiii i ;iii EAL #1 Basis:

This EAL escalates from RU2 in that the loss of level, in the affected portion of the REFUELING PATHWAY, is of sufficient magnitude to have resuited in uncovery of irradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visual observation (e.g., reports from personnel or camera images), as well as significant changes in water and radiation levels, or other plant parameters. Computational aids may also be used (e.g., a boil-off curve). Classification of an event using this EAL should be based on the totality of available indications, reports and observations. While an area radiation monitor could detect a rise in a dose rate due to a lowering of water level in some portion of the REFUELING PATHWAY, the reading may not be a reliable indication of whether or not the fuel is actually uncovered. To the degree possible, readings should be considered in combination with other available indications of inventory loss. A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C3 during the Cold Shutdown and Refueling modes. EAL #2 Basis: This EAL addresses a release of radioactive material caused by mechanical damage to irradiated fuel. Damaging events may include the dropping, bumping or binding of an assembly, or dropping a heavy load onto an assembly. A rise in readings on radiation monitors should be considered in conjunction with in-plant reports or observations of a potential fuel damaging event (e.g., a fuel handling accident). Escalation of the emergency would be based on either Recognition Category R or C ICs. Basis Reference s):**::iix*:*!

                     .i'i ~,,i!j:i.:        ::i i*:: i!*!*

i: ~i!** .*:*** */i**:i

1. NEI 99-01 Rev 6, AA2 Month 20XX FC 3-46 Mont 2OX FC -46EP-XX-XXXX (Revision XX)

Ft. Calhoun StationOmhPulcowrDsit Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS __RU2 UNPLANNED loss of water level above irradiated fuel. 1, 2,3, 4, 5, D

1. a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated on ANY of the following:

LI-i106 (Cold Shutdown PZR Level)
L1-197 (Cold Shtdn RC Level)
L1-199 (sight glass)
LI-2846 (Spent Fuel Pool Level)

AND

b. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors in Table R4.

Table R4 ___________Radiation Monitors RMS Area Monitored RM-73,74,75 Containment Rad Monitor RM-085,87 Auxiliary Building Rad Monitor Portabe RadContainment and auxiliary Building near fuel handling areas Monitor ___________________________ 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. REFUELING PATHWAY: all the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange. This IC addresses a loss in water level above irradiated fuel sufficient to cause elevated radiation levels. This condition could be a precursor to a more serious event and is also indicative of a minor loss in the ability to control radiation levels within the plant. It is therefore a potential degradation in the level of safety of the plant. Month 20XX FC 3-47 Mont 2OX FC

                                                                                  -47EP-XX-XXXX (Revision XX)

Ft. Calhoun StationOmhPulcowrDsit Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS _RU2 (cont) A water level loss will be primarily determined by indications from available level instrumentation. Other sources of level indications may include reports from plant personnel (e.g., from a refueling crew) or video camera observations (if available) or from any other temporarily installed monitoring instrumentation. A significant drop in the water level may also cause a rise in the radiation levels of adjacent areas that can be detected by monitors in those locations. The effects of planned evolutions should be considered. For example, a refueling bridge area radiation monitor reading may rise due to planned evolutions such as lifting of the reactor vessel head or movement of a fuel assembly. Note that this EAL is applicable only in cases where the elevated reading is due to an UNPLANNED loss of water level. A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes. Escalation of the emergency classification level would be via IC RA2.

1. NEI 99-01 Rev 6, AU2 Month 20XX FC 3-48 Mont 2OX FC-48EP-XX-XXXX (Revision XX)

Ft_ C:nlhnun Rtntion Omnhn Puhli* Power District

    ~i Ftm (~hi~n  etsVWtinn                                             OmBi*B hs iP.,hmie  PewI   Diivtrk RECOGNITION CATEGORY ABNORMAL RAD LEVELS/IRADIOLOGICAL EFFLUENTS RA3 Radiation levels that impede access to equipment necessary for normal plant operations, cooldown or shutdown.

1,2, 3,4, 5, D Note:

     *If the equipment in the room or area listed in Table R6 was already inoperable, or out of service, before the event occurred, then no emergency, classification is warranted.

1. Dose rate > 15 mRlhr in ANY of the areas contained in Table R5:

Table R5 Areas Requiringl Continuous Occupancy

Main Control Room
Central Alarm Station (CAS)

OR

2. UNPLANNED event results in radiation levels that prohibit or significantly impede access to ANY of the following Table R6 plant rooms or areas:

Table R6 Areas with Entry Related Mode Applicability Area Entry Related Mode Area Applicability Containment Modes 4, 5 and D Room 6 Modes 4, 5 and D Room 13 Modes 4, 5 and D Room 15A Modes 4, 5 and D Room 21 Modes 4, 5 and D Room 22 Modes 4, 5 and D Room 56 Modes 4, 5 and D Room 57 Modes 4, 5 and D Room 69 Modes 4, 5 and D Month 20XX FC 3-49 Mont 2OX EC-49EP-XX-XXXX (Revision XX)

Ft. Calhoun StationOmhPulcowrDsit Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA3 (cont) 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. This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or impede personnel from performing actions necessary to maintain normal plant operation, or to perform a normal plant cooldown and shutdown. As such, it represents an actual or potential substantial degradation of the level of safety of the plant. The Emergency Director should consider the cause of the increased radiation levels and determine if another IC may be applicable. Assuming all plant equipment is operating as designed, normal operation is capable from the Main Control Room (MCR). The plant is also able to transition into a hot shutdown condition from the MCR, therefore Table R6 is a list of plant rooms or areas with entry-related mode applicability that contain equipment which require a manual/local action necessary to transition the plant from normal plant operation, cooldown and shutdown as specified in normal operating procedures, where if this action is not completed the plant would not be able to attain and maintain cold shutdown. This Table does not include rooms or areas for which entry is required solely to perform actions of an administrative or record keeping nature (e.g., normal rounds or routine inspections). Rooms and areas listed in EAL #1 do not need to be included in EAL #2, including the Control Room. For EAL #2, an Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time of the elevated radiation levels. The emergency classification is not contingent upon whether entry is actually necessary at the time of the increased radiation levels. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., installing temporary shielding beyond that required by procedures, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits). An emergency declaration is not warranted if any of the following conditions apply.

 *The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the elevated radiation levels). For example, the plant is in Mode 1 when the radiation rise occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.

The increased radiation levels are a result of a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., radiography, spent filter or resin transfer, etc.).

Month 20XX FC 3-50 Mont 2OX FO

                                                                             -50EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS RA3 (cont)

The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).
The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.

Escalation of the emergency classification level would be via Recognition Category R, C or F l~s.

1. NEI 99-01 Rev 6, AA3 Month 20XX FC 3-51 (Revision XX)

                                                                       -51EP-XX-XXXX Mont 2OX FO

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU3 Reactor coolant activity greater than Technical Specification allowable limits. 1,2,3

1. "Dose rate on Contact" on the primary sample piping immediately adjacent to the Sample Hood (SL-1) is > 4R/hr.

OR

2. Sample analysis indicates that:

a. Dose Equivalent 1-131 specific coolant activity > 1.0 uCilgm for more than 100 hours during one continuous time interval OR > 60 u~i/gm.

OR

b. Activity > 100IE-bar uCi/gm.

This IC addresses a reactor coolant activity value that exceeds an allowable limit specified in Technical Specifications. This condition is a precursor to a more significant event and represents a potential degradation of the level of safety of the plant. Conditions that cause the specified monitor to alarm that are not related to fuel clad degradation should not result in the declaration of an Unusual Event. This EAL addresses site-specific radiation monitor readings that provide indication of a degradation of fuel clad integrity. Escalation of the emergency classification level would be via l~s FA1 or the Recognition Category R ICs.

1. NEI 99-01 Rev 6, SU3 Month 20XX FC 3-52 Mont 2OX FC-52EP-XX-XXXX (Revision XX)

Ft. C*lhn.n fitntinn *mnhn Pllhli* Pnw*r niQtri*t Ft Cl1 Tal.V ni t, inn AKVh III I llllkI . DnwVI IlitmrIrtV RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Initatin Conitio: -FG1 Loss of ANY Two Barriers AND Loss or Potential Loss of the third barrier. 1,2,3 Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status. Fuel Cladding, ROS and Containment comprise the fission product barriers. At the General Emergency classification level each barrier is weighted equally. iBas~is Rfrne):!Li lli~II i i I! ,il~. ili

                                               ,..       .]

1. NE1 99-01 Rev 6, Table 9-F-3 Month 20XX FC 353 Mont 2OX FC -53EP-XX-XXXX (Revision XX)

I*t *lhnnm .*t*tlnn CIm*h* P,,hlir I:)*z***r Ni*trirt Ftl VC*IhIIVmIn VttHIVni VIIm.h11 P. uhfll Dr VVVah f~llkatl RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FS1 Loss or Potential Loss of ANY two barriers. 1,2,3 Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status. Fuel Cladding, RCS and Containment comprise the fission product barriers. At the Site Area Emergency classification level, each barrier is weighted equally.

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-54 Mont 2OX FC -54EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FA1 ANY Loss or ANY Potential Loss of either Fuel Clad or ROS. 1,2,3 Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status. Fuel Cladding, RCS and Containment comprise the fission product barriers. At the Alert classification level, Fuel Cladding and RCS barriers are weighted more heavily than the Containment barrier. Unlike the Containment barrier, loss or potential loss of either the Fuel Cladding or RCS barrier may result in the relocation of radioactive materials or degradation of core cooling capability. Note that the loss or potential loss of Containment barrier in combination with loss or potential loss of either Fuel Cladding or RCS barrier results in declaration of a Site Area Emergency under EAL FSI.

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-55 Mont 2OX FC-55EP-XX-XXXX (Revision XX)

I:t P.*lhnnnn .*fntinn l*m*h* Pnnhlir Pnw=r niQtriq-t Ft tl V n~lll ~tliVmtnIIVniII AmM~ iuh Drlirfl~ietrLaIr i RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FCl RCS or SG Tube Leakage 1,2,3 POTENTIAL LOSS RVLMS indicates 0.0%. There is no Loss threshold associated with RCS or SG Tube Leakage. Potential Loss Threshold Basis: This reading indicates a reduction in reactor vessel water level sufficient to allow the. onset of heat-induced cladding damage.

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-56 Mont 2OX FO -56EP-XX-XXXX (Revision XX)

Ft. Calhoun *tatinn OmAhn PHhlin Pnw@_r 13i_*triP.t RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC2 Initiatin C ondition:*:**:*

!:'**":::,** *'7*****:"*"*-: ' *:** :* ** "' + '3'*; -*; - 7 ;:,*:7:***:* ::***: ' :' *: ': ;;"

Inadequate Heat Removal 1,2,3 LOSS

1. Core Exit Thermocouple readings > 1550°F POTENTIAL LOSS

2. Core Exit Thermocouple readings > 700°F OR

3. Once-Through-Cooling, EOP-20 HR4 in effect.

Loss Threshold #1 Basis This reading indicates temperatures within the core are sufficient to cause significant superheating of reactor coolant. Potential Loss Threshold #2 Basis This reading indicates temperatures within the core are sufficient to allow the onset of heat-induced cladding damage. Potential Loss Threshold #3 Basis This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the Fuel Clad Barrier. In accordance with EOPs, there may be unusual accident conditions during' which operators intentionally reduce the heat removal capability of the steam generators; during these conditions, classification using threshold is not warranted. Meeting this threshold results in a Site Area Emergency because this threshold is identical to RCS Barrier RC2 Potential Loss threshold; both will be met. This condition warrants a Site Area Emergency declaration because inadequate RCS heat removal may result in fuel heat-up sufficient to damage the cladding and raise RCS pressure to the point where mass will be lost from the system.

1. NE1 99-01 Rev 6, Table 9F-3 Month 20XX FC 3-57 Mont 2OX FC -57EP-XX-XXXX (Revision XX)

I:t P_,*lhnlm _*t*tinn Amrn-ahi iki,,h D,~war fli~trir,t RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC3 Containment Radiation / RCS Activity 1,2,3 LOSS

1. Containment radiation monitor RM-091 A/B reading > 6500 R/hr.

OR

2. Coolant activity > 180 uCi/gm Dose Equivalent 1-131 OR

3. 12.1 Rem/hr on contact or 33 mRem/hr at 30 cm on primary sample piping adjacent

  *to the hood SL-1 per CH-SMP-PA-0007 Loss Threshold #1 Basis:

The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that reactor coolant activity equals 300p*Ci/gm dose equivalent 1-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier. The radiation monitor reading in this threshold is higher than that specified for ROS Barrier RC3 Loss Threshold since it indicates a loss of both the Fuel Clad Barrier and the RCS Barrier. Note that a combination of the two monitor readings appropriately escalates the emergency classification level to a Site Area Emergency. Loss Threshold #2 Basis: This threshold indicates that RCS radioactivity concentration is greater than 300 jiCi/gm dose equivalent 1-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier. It is recognized that sample collection and analysis of reactor coolant with highly elevated activity levels could require several hours to complete. Nonetheless, a sample-related threshold is included as a backup to other indications There is no Fuel Clad Barrier Potential Loss threshold associated with RCS Activity / Containment Radiation. Month 2()XX FC 3-58 Mont 2OX FC -58EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC3 (cont) Basis.. Reference i i . i,* .. i~** ,. i.i*ii i - i,. .!._* ...-*iii.*iiii._* 'i.... .!.s):..ii .ii . ~*

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-59 Mont 2OX FO -59EP-XX-XXXX (Revision XX)

Ft_' Ftl

     *.*lhnun   fitatinn VHiIh~nin 5Vt~tiVnnVBiII

(')mnh* Plhlir flmh~ iiu Pnw*r ni_*triPt

VDnuI.0n flhetnrnr RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC5 Emergency Director Judgment.

1,2,3 LOSS

1. Any condition in the opinion of the Emergency Director that indicates Loss of the Fuel Clad Barrier.

POTENTIAL LOSS

2. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.

Loss Threshold #1 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Fuel Clad Barrier is lost. Potential Loss Threshold #2 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Fuel Clad Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

1. NEI 99-01 Rev 6, Table 9-F-S Month 20XX FC 3-60 Mont 2OX FC

                                                                           -60EP-XX-XXXX (Revision XX)

Ft. C*lhoun Station Omaha Puhlie PnwPr District Ft ClV*.......ho unm fmh ~m Ptjhmii Itto PowIr DBiVtrir RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC1 Iitiating Condi. ion:. .. . ... . .. .. . . . RCS or SG Tube Leakage

Operating Mode-Applicability:.. .. . . . . . . . ....

1,2,3 iFission Product Barrier (FPB) Thr~eshold:r....J: .... " "..... LOSS

1. Automatic or manual EGGS (SI) actuation is required by EITHER of the following:

a. UNISOLABLE RCS leakage OR

b. Steam Generator tube RUPTURE.

POTENTIAL LOSS

2. UNISOLABLE RCS or S/G Tube leakage > the capacity of one charging pump in the normal mode (greater than 40gpm).

OR

3. a. A transient has caused a rapid RCS cooldown.

AND

b. Pressure and Tempoerature is above Attachment P0-12 Pressure Temperature Curve.

Basis: .. .i. . i ..... . . : .. . . . .UNISOLABLE: An open or breached system line that cannot be isolated, remotely or locally. RUPTURE(D): The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection. FAULTED: The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized. Loss Threshold #1 Basis This threshold is based on an UNISOLABLE RCS leak of sufficient size to require an automatic or manual actuation of the Emergency Core Cooling System (EGGS). This condition clearly represents a loss of the RCS Barrier. Month 20XX FC 3-61 Mont 2OX FG-61EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RCl (cont) This threshold is applicable to unidentified and pressure boundary leakage, as well as identified leakage. It is also applicable to UNISOLABLE RCS leakage through an interfacing system. The mass loss may be into any location - inside containment, to the secondary-side (i.e., steam generator tube leakage) or outside of containment. A steam generator with primary-to-secondary leakage of sufficient magnitude to require a safety injection is considered to be RUPTURED. If a RUPTURED steam generator is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier CT1 Loss threshold will also be met. Potential Loss Threshold #2 Basis This threshold is based on an UNISOLABLE RCS leak that results in the inability to maintain pressurizer level within specified limits by operation of a normally used charging (makeup) pump, but an EGOS (SI) actuation has not occurred. The threshold is met when an operating procedure, or operating crew supervision, directs that a standby charging (makeup) pump be placed in service to restore and maintain pressurizer level. This threshold is applicable to unidentified and pressure boundary leakage, as well as identified leakage. It is also applicable to UNISOLABLE RCS leakage through an interfacing system. The mass loss may be into any location - inside containment, to the secondary-side (i.e., steam generator tube leakage) or outside of containment. If a leaking steam generator is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier CT1 Loss Threshold

1 will also be met.

Potential Loss Threshold #3 Basis The initiation of Once-Through-Cooling, EOP-20 HR4 creates a controlled opening of the RCS to the containment by an open PORV. The opening of the RCS represents a potential challenge to the RCS barrier and is considered a potential loss. Potential Loss Threshold #4 Basis This condition indicates an extreme challenge to the integrity of the RCS pressure boundary due to pressurized thermal shock - a transient that causes rapid RCS cooldown while the RCS is in Mode 3 or higher (i.e., hot and pressurized).

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-62 Mont 2OX EC-62EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC2 Inadequate Heat Removal 1,2,3,4 Fi!*ssion Prouc't :Barrie ri* !(FPB+) Thrsh~oldii771!i~*iii ::~i *~ **~~:iii _!i i**7I**,11: POTENTIAL LOSS Once-Through-Cooling, EOP-20 HR4 in effect. There is no Loss threshold associated with Inadequate Heat Removal. Potential Loss Threshold Basis Once-Through-Cooling, EOP-20 HR4 in effect indicates a Lack of Primary to Secondary Heat Transfer capability. This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the RCS Barrier. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators; during these conditions, classification using thresh'old is not warranted. Meeting this threshold results in a Site Area Emergency because this threshold is identical to Fuel Clad Barrier FC2 Potential Loss Threshold #3; both will be met. This condition warrants a Site Area Emergency declaration because inadequate ROS heat removal may result in fuel heat-up sufficient to damage the cladding and raise RCS pressure to the point where mass will be lost from the system.

1. NEI 99-0 1 Rev 6, Table 9-F-3 Month 20XX FC 3-63 Mont 2OX FO -63EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Initatig Coditon:RC3 Containment Radiation / RCS Activity 1,2,3 LOSS Containment radiation monitor RM-091 A/B reading >40 R/hr. Basi s: . ... . * ......... .. :, , .: ....... * . . ... .. ....... .. ., * ... .. .. . , . , : ... .,. ..,.. . ....... .. . . ... Loss Threshold Basis The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that reactor coolant activity equals Technical Specification allowable limits. This value is lower than that specified for Fuel Clad Barrier FC3 Loss threshold #1 since it indicates a loss of the RCS Barrier only. There is no ROS Potential Loss threshold associated with ROS Activity / Containment Radiation.

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-64 Mont 2OX FC -64EP-XX-XXXX (Revision XX)

Ft_ F t Cnlhnlm v( mmmvum=

                 .qtntinn
                   ~t~mti=n                                                       *Imnhn Pi nhlie_ Pnw*r ni*triet Ammmannh  Diannli-   vnwiv fm~l, mmvr RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC5 Initiatin g C o nd ntion: *** ...... ,*....    ..... *........ *.... ..*..... ...

Emergency Director Judgment. 1, 2,3 LOSS

1. Any condition in the opinion of the Emergency Director that indicates Loss of the RCS Barrier.

POTENTIAL LOSS

2. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the ROS Barrier.

Loss Threshold #1 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the ROS Barrier is lost. Potential Loss Threshold #2 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the RCS Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

1. NEl 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-65 Mont 2OX FO

                                                                                                -65EP-XX-XXXX (Revision XX)

I=f *mlhc. m _*tmti*n ('11m*h* Plhlir Pnw*r I'*i*tri*f Ft f~I, v . nll*.a Q,. tir*L nm vam~hm.lll* D mnkli, Dnwcr. fluetrlvr RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Initatig Cnditon:- - - -CT1 RCS or SG Tube Leakage 1,2,3 LOSS A leaking or RUPTURED SG is FAULTED outside of containment. FAULTED: The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized. RUPTURE(D): The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection. Loss Threshold Basis This threshold addresses a leaking or RUPTURED Steam Generator (SG) that is also FAULTED outside of containment. The condition of the SG, whether leaking or RUPTURED, is determined in accordance with the thresholds for RCS Barrier RC1 Potential Loss Threshold 2 and Loss Threshold 1l.b, respectively. This condition represents a bypass of the containment barrier. FAULTED is a defined term within the NE! 99-01 methodology; this determination is not necessarily dependent upon entry into, or diagnostic steps within, an EOP. For example, if the pressure in a steam generator is decreasing uncontrollably [part of the FAULTED definition] and the faulted steam generator isolation procedure is not entered because EOP user rules are dictating implementation of another procedure to address a higher priority condition, the steam generator is still considered FAULTED for emergency classification purposes. The FAULTED criterion establishes an appropriate lower bound on the size of a steam release that may require an emergency classification. Steam releases of this size are readily observable with normal Control Room indications. The lower bound for this aspect of the containment barrier is analogous to the lower bound criteria specified in IC RU3 for the fuel clad barrier (i.e., RCS activity values) and IC MU6 for the RCS barrier (i.e., RCS leak rate values). This threshold also applies to prolonged steam releases necessitated by operational considerations such as the forced steaming of a leaking or RUPTURED steam Month 20XX FC 3-66 Mont 2OX FC -66EP-XX-XXXX (Revision XX)

Ft_ C*lhoun Rtgtinn OmRhR Puhli* Pow*_r District Ft Ol Vm Ihnu mt tinn~ A ml h~ P* i *irV P Vwlr Dltrir m RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT1 (cont) iBas *,is(conh)*i!! (e nl **i;.l i!*!*'~i ;.~*ii ;i*i J

ii*i..ii/i*.~*i**ii"i_:;!

                                                                -       :*.!iiiiii!i! !.ii*!i!.! ..*:* ;_;!! ~l ii "**iii
                                                                              -~ii,            -

generator directly to atmosphere to cooldown the plant, or to drive an auxiliary (emergency) feed water pump. These types of conditions will result in a significant and sustained release of radioactive steam to the environment (and are thus similar to a FAULTED condition). The inability to isolate the steam flow without an adverse effect on plant cooldown meets the intent of a loss of containment. Steam releases associated with the expected operation of a SG power operated relief valve or safety relief valve do not meet the intent of this threshold. Such releases may occur intermittently for a short period of time following a reactor trip as operators process through emergency operating procedures to bring the plant to a stable condition and prepare to initiate a plant cooldown. Steam releases associated with the unexpected operation of a valve (e.g., a stuck-open safety valve) meets this threshold. Following an SG tube leak or rupture, there may be minor radiological releases through a secondary-side system component (e.g., air ejectors, glad seal exhausters, valve packing, etc.). These types of releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category R l~s. The emergency classification levels resulting from primary-to-secondary leakage, with or without a steam release from the FAULTED SG, are summarized below. Affected SG is FAULTED Outside of Containment? Primary to Secondary Yes No Leak Rate Less than or equal to 25 No classification No classification gpm Greater than 25 gpm Unusual Event per Unusual Event per MU6 MU6 The capacity of one charging pump in the Site Area Emergency normal charging mode Alert per FA1 per FS1 (greater than 40 gpm) is exceeded (RCS Barrier PotentialLoss) Requires an automatic or Site Area Emergency Alert per FA1 manual ECOS actuation per FS1 (RCS BarrierLoss) There is no Potential Loss threshold associated with ROS or SG Tube Leakage. Month 20XX FC 3-67 Mont 2OX FO-67EP-XX-XXXX (Revision XX)

Ft. Calhoun StationOmhPulcowrDsit Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT1 (cont)

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-68 Mont 2OX FO

                                                           -68EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT2 I!nitiatjing Condition :I : .* ,:-_ :." _* i ". . :._' .,* !. _.-. i,!,.*, * :; Inadequate Heat Removal Operating Mode Applicability:. . * * : - : iI , /; 1,2,3 'Fission Product Barrier (FPB) ThreShold: !,* i : .Lii::* _! i ; POTENTIAL LOSS

1. a. Core exit thermocouples > 1 5500 F AND

b. Restoration procedures not effective in < 15 minutes.

OR

2. a. Core exit thermocouples > 700 °F AND

b. RVLMS indicates 0.0%

AND

c. Restoration procedures no__t effective in < 15 minutes.

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. There is no Loss threshold associated with Inadequate Heat Removal. Potential Loss Threshold Basis This condition represents an IMMINENT core melt sequence which, if not corrected, could lead to vessel failure and an increased potential for containment failure. For this condition to occur, there must already have been a loss of the RCS Barrier and the Fuel Clad Barrier. If implementation of a procedure(s) to restore adequate core cooling is not effective (successful) within 15 minutes, it is assumed that the event trajectory will likely lead to core melting and a subsequent challenge of the Containment Barrier. The restoration procedure is considered "effective" if core exit thermocouple readings are decreasing and/or if reactor vessel level is increasing. Whether or not the procedure(s) will be effective should be apparent within 15 minutes. The Emergency Director should escalate the emergency classification level as soon as it is determined that the procedure(s) will not be effective. Severe accident analyses (e.g., NUREG-1 150) have concluded that function restoration procedures can arrest core degradation in a significant fraction of core damage scenarios, and that the likelihood of containment failure is very small in these events. Given this, it is appropriate to provide 15 minutes beyond the required entry point to determine if procedural actions can reverse the core melt sequence. Month 20XX FC 3-69 Mont 2OX FC -69EP-XX-XXXX (Revision XX)

Ft. Calhoun StationOmhPulcowrDsit Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT2 (cont)

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-70 Mont 2OX FO

                                                           -70EP-XX-XXXX (Revision XX)

I:::t t*.alhn, ln _*t*tinn A'm~h-a DkIu)~hl Irj*R,or Iliafrirt RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Initatig Coditon:CT3 Containment Radiation / RCS Activity 1,2,3 POTENTIAL LOSS Containment radiation monitor RM-091 A/B reading > 26,000 R/hr. There is no Loss threshold associated with ROS Activity / Containment Radiation. Potential Loss Threshold Basis The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that 20% of the fuel cladding has failed. This level of fuel clad failure is well above that used to determine the analogous Fuel Clad Barrier Loss and ROS Barrier Loss thresholds. NUREG-1 228, Source Estimations During Incident Response to Severe Nuclear Power Plant Accidents, indicates the fuel clad failure must be greater than approximately 20% in order for there to be a major release of radioactivity requiring offsite protective actions. For this condition to exist, there must already have been a loss of the RCS Barrier and the Fuel Clad Barrier. It is therefore prudent to treat this condition as a potential loss of containment which would then escalate the emergency classification level to a General Emergency.

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-71 Mont 2OX FC-71EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT4 Containment Integrity or Bypass iOperatingi M-ode iApplicabilityiii': *I. !iii-,~ :: ;*i,*ii.:o*ii, !! *:~**iir"*i:,i"'* 1,2,3 LOSS

1. Containment isolation is required and EITHER of the following:

a. UNPLANNED lowering in containment pressure or rise in radiation monitor readings outside of containment in the Emergency Directors judgment indicate a loss of containment integrity.

OR

b. UNISOLABLE pathway from containment to the environment exists.

OR

2. Indication of RCS leakage outside of containment POTENTIAL LOSS

3. Containment Pressure > 60 psi9 and rising.

OR

4. Hydrogen Concentration in Containment > 3%

OR

5. a. Containment pressure > 5 psi9 AND

b. Less than one full train of Containment Cooling OR Containment Spray equipment operating per design for > 15 minutes.

FAULTED: The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized. 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. UNISOLABLE: An open or breached system line that cannot be isolated, remotely or locally. Month 20XX FC 3-72 Mont 2OX FC-72EP-XX-XXXX (Revision XX)

Ft. Calhnun *tgtion Omnhn Pghlin Pnw*r DiRtrict

     ~m FtI Chnin~   B  t tiflf                                       O lm~hR P*i *irV PowIr Dltrir m RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT4 (cont)

Loss Threshold #1 Basis These thresholds address a situation where containment isolation is required and one of two conditions exists as discussed below. Users are reminded that there may be accident and release conditions that simultaneously meet both loss thresholds l.a and l.b. l .a - Containment integrity has been lost, i.e., the actual containment atmospheric leak rate likely exceeds that associated with allowable leakage (or sometimes referred to as design leakage). Following the release of RCS mass into containment, containment pressure will fluctuate based on a variety of factors; a loss of containment integrity condition may (or may not) be accompanied by a noticeable drop in containment pressure. Recognizing the inherent difficulties in determining a containment leak rate during accident conditions, it is expected that the Emergency Director will assess this threshold using judgment, and with due consideration given to current plant conditions, and available operational and radiological data (e.g., containment pressure, readings on radiation monitors outside containment, operating status of containment pressure control equipment, etc.). Refer to the middle piping run of Figure 3-F-i. Two simplified examples are provided. One is leakage from a penetration and the other is leakage from an in-service system valve. Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure. Another example would be a loss or potential loss of the RCS barrier, and the simultaneous occurrence of two FAULTED locations on a steam generator where one fault is located inside containment (e.g., on a steam or feedwater line) and the other outside of containment. In this case, the associated steam line provides a pathway for the containment atmosphere to escape to an area outside the containment. Following the leakage of ROS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable (design) containment leakage through various penetrations or system components. These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category R ICs. 1 .b - Conditions are such that there is an UNISOLABLE pathway for the migration of radioactive material from the containment atmosphere to the environment. As used here, the term "environment" includes the atmosphere of a room or area, outside the containment, that may, in turn, communicate with the outside-the-plant atmosphere (e.g., through discharge of a ventilation system or atmospheric leakage). Depending upon a variety of factors, this condition may or may not be accompanied by a noticeable drop in containment pressure. Month 20XX FC 3-73 Mont 2OX FC -73EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT4 (cont) Ba is(an) !!ii iii ii~ iiiii

                         -       -i Refer to the top piping run of Figure 3-F-i. In this simplified example, the inboard and outboard isolation valves remained open after a containment isolation was required (i.e.,

containment isolation was not successful). There is now an UNISOLABLE pathway from the containment to the environment. The existence of a filter is not considered in the threshold assessment. Filters do not remove fission product noble gases. In addition, a filter could become ineffective dlue to iodine and/or particulate loading beyond design limits (i.e., retention ability has been exceeded) or water saturation from steam/high humidity in the release stream. Leakage between two interfacing liquid systems, by itself, does not meet this threshold. Refer to the bottom piping run of Figure 3-F-i. In this simplified example, leakage in an RCP seal cooler is allowing radioactive material to enter the Auxiliary Building. The radioactivity would be detected by the Process Monitor. If there is no leakage from the closed water cooling system to the Auxiliary Building, then no threshold has been met. If the pump or system piping developed a leak that allowed steam/water to enter the Auxiliary Building, then loss threshold 2 would be met. Depending upon radiation monitor locations and sensitivities, this leakage could be detected by any of the four monitors depicted in the figure and cause threshold l .a to be met as well. Following the leakage of ROS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable (design) containment leakage through' various penetrations or system components. Minor releases may also occur if a containment isolation valve(s) fails to close but the containment atmosphere escapes to a closed system. These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category R I~s. The status of the containment barrier during an event involving steam generator tube leakage is assessed using Containment Barrier CT1 Loss threshold. Loss Threshold #2 Basis Containment sump, temperature, pressure and/or radiation levels will rise if reactor coolant mass is leaking into the containment. Ifthese parameters have not increased, then the reactor coolant mass may be leaking outside of containment (i.e., a containment bypass sequence). Raises in sump, temperature, pressure, flow and/or radiation level readings outside of the containment may indicate that the RCS mass is being lost outside of containment. Unexpected elevated readings and alarms on radiation monitors with detectors outside containment should be corroborated with other available indications to confirm that the source is a loss of RCS mass outside of containment. If the fuel clad barrier has not been lost, radiation monitor readings outside of containment may not rise significantly; however, other unexpected changes in sump levels, area temperatures or pressures, flow rates, etc. should be sufficient to determine if RCS mass is being lost outside of the containment. Month 20XX FC 3-74 Mont 2OX FC-74EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT4 (cont) Basis (cont):i ., .,~i.*ii *i:.*.,i.. . *.iiiii . ,* *.* _i. . .i . *. *,,.,..i* *ii.,,**,. ii*.,i i°,,i ~ Refer to the middle piping run of Figure 3-F-i. In this simplified example, a leak has occurred at a reducer on a pipe carrying reactor coolant in the Auxiliary Building. Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure and cause loss threshold 1 .a to be met as well. To ensure proper escalation of the emergency classification, the RCS leakage outside of containment must be related to the mass loss that is causing the RCS Barrier RC1 Loss Threshold l .a and/or Potential Loss threshold 2.a to be met. Potential Loss Threshold #3 Basis Ifcontainment pressure exceeds the design pressure, there exists a potential to lose the Containment Barrier. To reach this level, there must be an inadequate core cooling condition for an extended period of time; therefore, the ROS and Fuel Clad barriers would already be lost. Thus, this threshold is a discriminator between a Site Area Emergency and General Emergency since there is now a potential to lose the third barrier. Potential Loss Threshold #4 Basis The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a potential loss of the Containment Barrier. Potential Loss Threshold #5 Basis This threshold describes a condition where containment pressure is greater than the set point at which containment energy (heat) removal systems are designed to automatically actuate, and less than one full train of equipment is capable of operating per design. The 15-minute criterion is included to allow operators time to manually start equipment that may not have automatically started, if possible. This threshold represents a potential loss of containment in that containment heat removal/depressurization systems (e.g., containment sprays, ice condenser fans, etc., but not including containment venting strategies) are either lost or performing in a .degraded manner. Month 20XX FC 3-75 Mont 2OX FO -75EP-XX-XXXX (Revision XX)

I:t *lhr*lin .*t*finn *lm*h*l P,,hlir Pr.M*r rli*trirt Ft Cm u*hmni~a VLt mitin Aniuahu l mnHmm- DniVi cr f~l iltrm L RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT4 (cont) Basis R eference. .i .... *,.. .. ..i ... *_ . .. .... .-.. ...ii .i......i.....is):: . .,....

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-76 Mont 2OX FO (Revision XX)

                                                                                     -76EP-XX-XXXX

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Figure 3-F-i: PWR Containment Integrity or Bypass Examples release fro Anuideiary Building "MonitorO Containment '-........ Vent

                                                                ......    .....                                                 M onitor:,

Damper l .a - . Penetration t rlae

                                                                                               *L                              ~Airborne',

Open alve* " Opnvalv ' Monitor Interface leakage Airborne leaag

i. release from.*

Open valve Open valve Pump System Seal Cooling Month 20XX FC 3-77 Mont 2OX EC -77EP-XX-XXXX (Revision XX)

Ft. Calhoun StationOmhPulcowrDsit Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT5 Emergency Director Judgment. 1,2,3 LOSS

1. Any condition in the opinion of the Emergency Director that indicates Loss of the Containment Barrier.

POTENTIAL LOSS

2. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.

Loss Threshold #1 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Containment Barrier is lost. Potential Loss Threshold #2 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Containment Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored. Basis, Reference(s),....

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-78 Mont 2OX FC

                                                                       -78EP-XX-XXXX (Revision XX)

Ft_ CAIhnun Rt*tinn t*m*h* PlhliP_ Pnw*_r Ni_*triP.t RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG1 Initi ating Condition *!iJ ii:Si::i* **:;~ ~i?** ,!:i:!ii~! **'!*!:* !~~!,il :-,::*!**:*.* :*i**: i': iii,*!:~* !i*!i:** Prolonged loss of all offsite and all onsite AC power to emergency busses. 1,2,3 Note:

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

1. Loss of ALL offsite AC power to vital 4160 volt buses 1A3 and 1A4.

AND

2. Failure of EDG's DG1 and DG2 to supply power to vital 4160 volt buses 1A3 and 1A4.

AND

3. EITHER of the following:

a. Restoration of at least one vital 4160 volt bus in < 4 hours is no.tt likely.

OR

b. Core exit thermocouples > 1550°F.

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. This IC addresses a prolonged loss of all power sources to AC emergency buses. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. A prolonged loss of these buses will lead to a loss of any fission product barriers. In addition, fission product barrier monitoring capabilities may be degraded under these conditions. The EAL should require declaration of a General Emergency prior to meeting the thresholds for IC FGI. This will allow additional time for implementation of offsite protective actions. Escalation of the emergency classification from Site Area Emergency will occur if it is projected that power cannot be restored to at least one AC emergency bus by the end of the analyzed station blackout coping period. Beyond this time, plant responses and Month 20XX FC 3-79 Mont 2OX FC-79EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS M~G1 (cont) event trajectory are subject to greater uncertainty, and there is an increased likelihood of challenges to multiple fission product barriers. The estimate for restoring at least one emergency bus should be based on a realistic appraisal of the situation. Mitigation actions with a low probability of success should not be used as a basis for delaying a classification upgrade. The goal is to maximize the time available to prepare for, and implement, protective actions for the public. The EAL will also require a General Emergency declaration if the loss of AC power results in parameters that indicate an inability to adequately remove decay heat from the core.

1. NEI 99-01 Rev 6, SG1 Month 20XX FC 3-80 Mont 2OX FC

                                                                          -80EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS1 Loss of all offsite and all onsite AC power to emergency busses for 15 minutes or longer. 1,2,3 Note:

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

1. Loss of ALL offsite AC Power to vital 4160 volt buses 1A3 and 1A4.

AND

2. Failure of EDG's DG1 and DG2 to supply power to vital 4160 volt buses 1A3 and 1A4.

AND

3. Failure to restore power to at least one vital 4160 volt bus in < 15 minutes from the time of loss of both offsite and onsite AC power.

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the EGGS. These are typically systems classified as safety-related. This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. In addition, fission product barrier monitoring capabilities may be degraded under these conditions. This IC represents a condition that involves actual or likely major failures of plant functions needed for the protection of the public. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. Escalation of the emergency classification level would be via l~s RG1, FG1, MG1, or MG2. Month 20XX FC 3-81 Mont 2OX FC-81EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Ft. alhon SttionOmaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS1 (cont)

1. NEI199-01 Rev 6,SSl Month 20XX FC 3-82 Mont 2OX FO-82EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Puhli* Pnw*r Di.*tri*t F...C.lhoun..S..a.ion O...*h. Pih. r Pnw* r fliv. rvi.w RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA1 Loss of all but one AC power source to emergency buses for 15 minutes or longer. 1,2,3 Note:

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

1. AC power capability to vital 4160 volt buses 1A3 and 1A4 reduced to only one of the following power sources for > 15 minutes.

161 Kv Circuit
345 Ky Circuit
EDG DG1
EDG DG2 AND

2. Any additional single power source failure will result in a loss of ALL AC power to SAFETY SYSTEMS.

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment. This IC provides an escalation path from IC MUI. An "AC power source" is a source recognized in AOPs and EOPs, and capable of supplying required power to an emergency bus. Some examples of this condition are presented below.

A loss of all offsite power with a concurrent failure of all but one emergency power source (e.g., an onsite diesel generator).

Month 20XX FC 3-83 Mont 2OX FC-83EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MAl (cont) Basis (cont): con l ii:ii/ *i**i: iiiiii:1 *: i: i::i fi:*i!: ii:~'i:i ~i:*i: i *:* i ~ii i

A loss of all offsite power and loss of all emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from the unit main generator.
A loss of emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from an off site power source.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power. Escalation of the emergency classification level would be via 1IC MS1.

1. NEl 99-01 Rev 6, SA1 Month 20XX FC 3-84 Mont 2OX FO-84EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU1 Loss of all offsite AC power capability to emergency buses for 15 minutes or longer. 1,2,3 Note:

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

Loss of ALL offsite AC power capability to vital 4160 volt buses 1A3 and 1A4 for > 15 minutes. Bai s: ii)) :I iI- ] -l -IIi i iii~*] i*ii i Y Iiiii*I ]

i*L

                                                                                  -i  LI -

This IC addresses a prolonged loss of offsite power. The loss of offsite power sources renders the plant more vulnerable to a complete loss of power to AC emergency buses. This condition represents a potential reduction in the level of safety of the plant. For emergency classification purposes, "capability" means that an offsite AC power source(s) is available to the emergency buses, whether or not the buses are powered from it. Fifteen minutes was selected as a threshold to exclude transient or momentary losses of offsite power. Escalation of the emergency classification level would be via IC MAI.

1. NEI 99-01 Rev 6, SU1 Month 20XX FC 3-85 Mont 2OX FC-85EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Initatig Coditon:MG2 Loss of all AC and Vital DC power sources for 15 minutes or longer. 1,2,3 Note:

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

1. Loss of ALL offsite AC power to vital 4160 volt buses 1A3 and 1A4.

AND

2. Failure of EDG's DG1 and DG2 to supply power to vital 4160 volt buses 1A3 and 1A4.

AND

3. Voltage is < 105 VDC on 125 VDC Bus 1 and Bus 2.

AND

4. ALL AG and Vital DC power sources have been lost for > 15 minutes.

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the EGGS. These are typically systems classified as safety-related. This IC addresses a concurrent and prolonged loss of both AG and Vital DC power. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. A loss of Vital DC power compromises the ability to monitor and control SAFETY SYSTEMS. A sustained loss of both AG and DC power will lead to multiple challenges to fission product barriers. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. The 15-minute emergency declaration clock begins at the point when all EALs are met. Month 20XX FC 3-86 Mont 2OX FO

                                                                        -86EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG2 (cont)

1. NEI199-01 Rev 6, SG8 Month 20XX FC 3-87 Mont 2OX FO

                                                          -87EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District District Ft. Calhoun Station Omaha Public Power RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS2 Loss of all vital DC power for 15 minutes or longer. 1,2,3 Note: the applicable time has been exceeded, or will likely be exceeded. Voltage is < 105 VDC on 125 VDC Busl and Bus 2 for_> 15 minutes. Bais SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the EGOS. These are typically systems classified as safety-related. This IC addresses a loss of Vital DC power which compromises the ability to monitor and control SAFETY SYSTEMS. In modes above Cold Shutdown, this condition involves a major failure of plant functions needed for the protection of the public. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. Escalation of the emergency classification level would be via l~s RG1, FG1 or MG3.

1. NEI 99-01 Rev 6, SS8 Month 20XX FC 3-88 Mont 2OX FC-88EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Initatig Cnditon:I - MS3 Inability to shutdown the reactor causing a challenge to core cooling or RCS heat removal. 1,2

1. Automatic or Manual Trip did no__t shutdown the reactor as indicated by Reactor Power > 2% and SUR is negative.

AND

2. All manual actions to shutdown the reactor have been unsuccessful as indicated by Reactor Power _>2% and SUR is negative.

AND

3. EITHER of the following conditions exist:

a. Core exit thermocouples > 1550°F.

OR

b. RVLMS indicates 0.0%

OR

c. Once-Through-Cooling, EOP-20 HR4 in effect.

This IC addresses a failure of the RPS to initiate or complete an automatic or manual* reactor trip that results in a reactor shutdown, all subsequent operator manual actions, both inside and outside the Control Room including driving in control rods and boron injection, are unsuccessful, and continued power generation is challenging the capability to adequately remove heat from the core and/or the RCS. This condition will lead to fuel damage if additional mitigation actions are unsuccessful and thus warrants the declaration of a Site Area Emergency. In some instances, the emergency classification resulting from this IC/EAL may be higher than that resulting from an assessment of the plant responses and symptoms against the Recognition Category F ICs/EALs. This is appropriate in that the Recognition Category F ICs/EALs do not address the additional threat posed by a failure to shutdown the reactor. The inclusion of this IC and EAL ensures the timely declaration of a Site Area Emergency in response to prolonged failure to shutdown the reactor. A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria. Month 20XX FC 3-89 Mont 2OX FC-89EP-XX-XXXX (Revision XX)

F~t C*%ulhnnin 5Rtntinn hl VHIH iUHIi VbHIIVi I C1mnhn Pnnhlin Pnw*r Ni_*triP.t VIIIHIiH i H*IIV l V II V VI 511 5 RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS3 (cont) Escalation of the emergency classification level would be via 1(C RG1 or FGI. B asis Reference(s): =

i . . - ,i . .i. i.iiii.:: =i i .- *......

1. NEI 99-01 Rev 6, SS5 Month 20XX FC 3-90 Mont 2OX FO -90EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Initatin Coditin:

                            --                                                 -     MA3 Automatic or manual trip fails to shutdown the reactor, and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor.

1,2 Note:

     *A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

1. Automatic or manual Trip did nott shutdown the reactor as indicated by Reactor Power > 2% and SUR is negative.

AND

2. Manual actions taken at the Console Center are not successful in shutting down the reactor as indicated by Reactor Power > 2% and SUR is negative.

This IC addresses a failure of the RPS to initiate or complete an automatic reactor trip that results in a reactor shutdown, and subsequent operator manual actions taken at the Console Center to shutdown the reactor are also unsuccessful. This condition represents an actual or potential substantial degradation of the level of safety of the plant. An emergency declaration is required even if the reactor is subsequently shutdown by an action taken away from the Console Center since this event entails a significant failure of the RPS. A manual action at the Console Center is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor trip. This action does not include manually driving in control rods or implementation of boron injection strategies. Ifthis action(s) is unsuccessful, operators would immediately pursue additional manual actions at locations away from the Console Center (e.g., locally opening breakers). Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be "at the Console Center". The plant response to the failure of an automatic or manual reactor trip will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If the failure to shutdown the reactor is prolonged enough to cause a challenge to the core cooling or RCS heat removal safety functions, the emergency Month 20XX FC 3-91 Mont 2OX FC-91EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Omaha Public Power Power District District Ft. Calhoun Station RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA3 (cont) Bai ~ s(con~t):. * ! *!*~! ! i'! ****i!i!!***ii!

                         -,**!i~                       *'*~i* iii****!!* **  ~~i**iii***  i* !    'iii *i    !

classification level will escalate to a Site Area Emergency via IC MS3. Depending upon plant responses and symptoms, escalation is also possible via IC FS1. Absent the plant conditions needed to meet either IC MS3 or ESi, an Alert declaration is appropriate for this event. It is recognized that plant responses or symptoms may also require an Alert declaration in accordance with the Recognition Category F l~s; however, this IC3 and EAL are included to ensure a timely emergency declaration. A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.

1. NEI 99-01 Rev 6, SA5 Month 20XX FC 3-92 Mont 2OX FC-92EP-XX-XXXX (Revision XX)

I:t P.*lhnum .:;t*tinn (*mnhn Pnhlir Pnw*r ni=trirt Ftk V'~alhnumnl VlHatinl Ama nlnll~ *Dmihe/Ely Pn Vii Ifl~l irvl RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU3 I!niti~ating Condition*:i.iii.. *ii-.o -i. !*iii-!,_!i*ii ! ii_ !i, ii ii ,i i Automatic or manual trip fails to shutdown the reactor. 1,2 Note:

       *A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

1. a. Automatic Trip did not shutdown the reactor as indicated by Reactor Power

            > 2% and SUR is negative.

AND

b. Subsequent manual action taken at the Console Center is successful in shutting down the reactor.

OR

2. a. Manual Trip did not shutdown the reactor as indicated by Reactor Power_> 2%

and SUP is negative. AND

b. EITHER of the following:

1. Subsequent manual action taken at the Console Center is successful in shutting down the reactor.

OR

2. Subsequent automatic Trip is successful in shutting down the reactor.

This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, and either a subsequent operator manual action taken at the Console Center or an automatic trip is successful in shutting down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant. EAL #1 Basis Following the failure on an automatic reactor trip, operators will promptly initiate manual actions at the Console Center to shutdown the reactor (e.g., initiate a manual reactor trip). If these manual actions are successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plant's decay heat removal systems. Month 20XX FC 3-93 Mont 2OX FC -93EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omnhn PuhliP. Pnw*_r I*i_*trirt Ft. Calhoun Station OmAha PiihIir~ Pnu~wr fli~trir~t RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU3 (cont) Basisi (cont!i*:. W <K

         *~ )**~!i*.*i.**  ,i:**!*,!**ii*~~!*~!i*!:**i*ii*
                                    -          -*!             *,ii ,iii .,i .!* *- *.,i*!i *ii!i**         1 i,.* ,-1.i!!,,i !

EAL #2 Basis If an initial manual reactor trip is unsuccessful, a concurrent plant condition, may lead to the generation of an automatic reactor trip signal. If a subsequent automatic trip is successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plant's decay heat removal systems. A manual action at the Console Center is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor trip). This action does not include manually driving in control rods or implementation of boron injection strategies. Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be "at the Console Center". The plant response to the failure of an automatic or manual reactor trip will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If subsequent operator manual actions taken at the Console Center are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC MA3. Depending upon the plant response, escalation is also possible via IC FAI. Absent the plant conditions needed to meet either IC MA3 or FA1, an Unusual Event declaration is appropriate for this event. A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria. Should a reactor trip signal be generated as a result of plant work (e.g., RPS setpoint testing), the following classification guida~nce should be applied.

If the signal generated as a result of plant work causes a plant transient that creates a real condition that should have included an automatic reactor trip and the RPS fails to automatically shutdown the reactor, then this IC and the EALs are applicable, and should be evaluated.

  *If the signal generated as a result of plant work does not cause a plant transient but should have generated an RPS trip signal and the trip failure is determined through other means (e.g., assessment of test results), then this IC and the EALs are not applicable and no classification is warranted.

Month 20XX FC 3-94 Mont 2OX FC-94EP-XX-XXXX (Revision XX)

Ft. Calhoun StationOmhPuicowrDsit Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU3 (cont)

Basis Reference(s):* _ .. . ."i. ...... i .. ... . .- ...

1. NEI 99-01 Rev 6, SU5 Month 20XX FC 3-95 Mont 2OX FC -95EP-XX-XXXX (Revision XX)

I*t *_alhn,,n _*tmtinn Ammahm PDihkll Dnwugr flietrir~t I I, vlllll4 nlB lLblfl*l n Vljg* ,ll* l I *il/l - WEII/

I- I lvlt RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA4 UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress.

1,2,3 Note:

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

1. a. UNPLANNED event results in the inability to monitor ANY Table M1 parameters from within the Control Room for > 15 minutes.

Table M1 Control Room Parameters

Reactor Power
PZR Level
RCS Pressure
In Core/Core Exit Temperature
Level in at least one Steam Generator
Auxiliary Feed Water Flow AND

b. ANY Table M2 transient in progress.

Table M2 Significant Transients

Electrical Load Rejection >25% full electrical load
Reactor Trip
ECCS Actuation Month 20XX FC 3-96 Mont 2OX FC -96EP-XX-XXXX (Revision XX)

I:t *.*lhn=nn _*t*tinn (3m*h* Pnhlir_ Pnw*r ni*trirt Ft C=qa*uuhntinul *Lftatm uuu Aummw*mauk,,

ibuh~mm Duu l,rfm mhl,nnut*ri RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA4 (cont)

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. SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the EGGS. These are typically systems classified as safety-related. This IC addresses the difficulty associated with monitoring rapidly changing plant conditions during a transient without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. During this condition, the margin to a potential fission product barrier challenge is reduced. It thus represents a potential substantial degradation in the level of safety of the plant. As used in this EAL, an "inability to monitor" means that values for any of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s). For example, the reactor power level cannot be determined from any analog, computer point, digital and recorder source within the Control Room. An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1 022) to determine if an NRC event report is required. The event would be reported if it significantly impaired the capability to perform emergency assessments. In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making. This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling and RCS heat removal. The loss of the ability to determine any of these parameters from within the Control Room is considered to be more significant than simply a reportable condition. In addition, if all indication sources for any of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well. Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication. Escalation of the emergency classification level would be via l~s FS1 or IC RSI.

1. NEI 99-01 Rev 6, SA2 Month 20XX FC 3-97 Mont 2OX FO (Revision XX)

                                                                                -97EP-XX-XXXX

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Initatin~ondtion

                                 ~             .MU4 UNPLANNED loss of Control Room indications for 15 minutes or longer.

1,2,3 Note:

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

UNPLANNED event results inthe inability to monitor ANY Table M1 parameters from within the Control Room for > 15 minutes. Table M1 Control Room Parameters

Reactor Power
PZR Level
RCS Pressure
InCore/Core Exit Temperature
Level inat least one Steam Generator
Auxiliary Feed Water Flow 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.

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the EGOS. These are typically systems classified as safety-related. This ICaddresses the difficulty associated with monitoring normal plant conditions without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. This condition is a precursor to a more significant event and represents a potential degradation inthe level of safety of the plant. As used in this EAL, an "inability to monitor" means that values for any of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s). For example, the reactor power level cannot be determined from any analog, digital and recorder source within the Control Room. An event involving a loss of plant indications, Month 20XX FC 3-98 Mont 2OX FC

                                                                        -98EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU4 (cont) annunciators and/or display systems is evaluated in accordance with 10 CER 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required. The event would be reported if it significantly impaired the capability to perform emergency assessments. In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making. This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling and ROS heat removal. The loss of the ability to determine any of these parameters from within the Control Room is considered to be more significant than simply a reportable condition. In addition, if all indication sources for any of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well. Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication. Escalation of the emergency classification level would be via IC MA4. Ba i R-*;....* eferen ce*'*

                 -: *"T-*.'*--.'**t.'*- -*. *-:,- -.-- :"*: T*"**'-*'°**,"*: . *****" '*"*T'*'-s):* *", : ':* "* :* *** -*"**T

1. NEI 99-01 Rev6, SU2 Month 20XX FC 3-99 Mont 2OX FC -99EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Inititing~- -~MA5 Hazardous event affecting a SAFETY SYSTEM required for the current operating mode. 1,2,3

1. The occurrence of ANY of the following hazardous events:

Seismic event (earthquake)
Internal or external flooding event
High winds or tornado strike
FIRE
EXPLOSION
Other events with similar hazard characteristics as determined by the Shift Manager AND

2. EITHER of the following:

a. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.

OR

b. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure required by Technical Specifications for the current operating mode.

FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed. EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion. Such events may require a post-event inspection to determine if the attributes of an explosion are present. Month 20XX FC 3-100 Mont 2OX FO -100EP-XX-XXXX (Revision XX)

Ft. C*lhoun Station OmAhA Puhlin Pnw*_r DiRtriet

..........       .... vt=i
                         .                                   Oms.mh,* Pih* r Pnw=vr Dkdrir~v°° RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA5 (cont)

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the EGGS. These are typically systems classified as safety-related. 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. This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or a structure containing SAFETY SYSTEM components, required for the current operating mode, "required22 , i.e. required to be operable by Technical Specifications for the current operating mode. This condition significantly reduces the margin to a loss or potential loss of a fission product barrier, and therefore represents an actual or potential substantial degradation of the level of safety of the plant. Manual or automatic electrical isolation of safety equipment due to flooding, in and of itself, does not constitute degraded performance and is classified under HU6. EAL #2.a Basis This EAL addresses damage to a SAFETY SYSTEM train that is required to be operable by Technical Specifications for the current operating mode, and is in operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train. EAL #2.b Basis This EAL addresses damage to a SAFETY SYSTEM component that is required to be operable by Technical Specifications for the current operating mode, and is not in operation or readily apparent through indications alone, as well as damage to a structure containing SAFETY SYSTEM components. Operators will make this determination based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage. Escalation of the emergency classification level would be via IC FS1 or RSI. Ifthe EAL conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.

1. NEI 99-01, Rev 6SA9 Month 20XX FC 3-101 Mont 2OX FO -101EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU6 RCS leakage for 15 minutes or longer. 1,2,3 Note:

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

1. RCS unidentified or pressure boundary leakage > 10 gpm for > 15 minutes.

OR

2. RCS identified leakage >25 gpm for > 15 minutes.

OR

3. Leakage from the RCS to a location outside containment >25 gpm for > 15 minutes, UNISOLABLE: An open or breached system line that cannot be isolated, remotely or locally.

This IC addresses RCS leakage which may be a precursor to a more significant event. In this case, RCS leakage has been detected and operators, following applicable procedures, have been unable to promptly isolate the leak. This condition is considered to be a potential degradation of the level of safety of the plant. EAL #1 and EAL #2 Basis These EALs are focused on a loss of mass from the ROS due to "unidentified leakage",

"pressure boundary leakage or identified leakage (as these leakage types are defined in the plant Technical Specifications).

EAL #3 Basis This EAL addresses a ROS mass loss caused by an UNISOLABLE leak through an interfacing system. These EALs thus apply to leakage into the containment, a secondary-side system (e.g., steam generator tube leakage) or a location outside of containment. The leak rate values for each EAL were selected because they are usually observable with normal Control Room indications. Lesser values typically require time-consuming calculations to determine (e.g., a mass balance calculation). EAL #1 uses a lower value that reflects the greater significance of unidentified or pressure boundary leakage. Month 20XX FC 3-102 Mont 2OX FO-102EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU6 (cont) The release of mass from the RCS due to the as-designed/expected operation of a relief valve does not warrant an emergency classification. An emergency classification would be required if a mass loss is caused by a relief valve that is not functioning as designed/expected (e.g., a relief valve sticks open and the line flow cannot be isolated). The 15-minute threshold duration allows sufficient time for prompt operator actions to isolate the leakage, if possible. Escalation of the emergency classification level would be via l~s of Recognition Category R or F.

1. NEI 99-01 Rev 6, SU4 Month 20XX FC 3-103 Mont 2OX FO-103EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS atin Coditin:

                                 .                              .MU7 Lsofall On-site or Off-site communications capabilities.

1,2,3

1. Loss of ALL Table M30Onsite communications capability affecting the ability to perform routine operations.

OR

2. Loss of ALL Table M30Offsite communication capability affecting the ability to perform off site notifications.

OR

3. Loss of ALL Table M3 NRC communication capability affecting the ability to perform NRC notifications.

Table M3 Communications Capability____ System Onsite Offsite NRC 800 MHz Radio System X Gai-tronics System X Security Building PABX X X X Training Building PABX X X X Commercial Telephones X X X Conference OperationsX Network (COP) FTS-ENS _ ___ X X HPN X X Satellite phones X X Blair Phone Line _ ___ X ___ This IC addresses a significant loss of on-site, offsite, or NRC communications capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to Offsite Response Organizations (ORes) and the NRC. This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.). Month 20XX FC 3-104 Mont 2OX FC -104EP-XX-XXXX (Revision XX)

Ft. Calhoun StationOmhPulcowrDsit Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU7 (cont) Ba iasis) (cont): i i.i i*.i*i**'**ii-~.- .i-i !i. i. ii i * ~_.i*Ii.*i i-*i!** .i.iii...i. * . . EAL #1 Basis Addresses a total loss of the communications methods used in support of routine plant operations. EAL #2 Basis Addresses a total loss of the communications methods used to notify all OROs of an emergency declaration. The OROs referred to here are listed in procedure EP-MA-1 14-100- F-01, State / Local Event Notification Form. EAL #3 Basis Addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.

1. NEI 99-01 Rev 6, SU6 Month 20XX FC 3-105 Mont 2OX FC -105EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU8 Failure to isolate containment or loss of containment pressure control. 1,2,3 Eme"- rgency-' Ac .io '(EA"L)

        *; :":"*-:--    Level ...... - ,-* *;"-: ---- :           ' *!'i
                                                        -*'*"**,:"*        ! *,'"-- * *;:*.--***i:*i-"".-{

1. a. Failure of containment to isolate when required by an actuation signal.

AND

b. ANY required penetration remains open > 15 minutes of the actuation signal.

OR

2. a. Containment pressure > 5 psig AND

b. Less than one full train of Containment Cooling OR Containment Spray equipment operating for_>15 minutes.

This IC addresses a failure of any containment penetrations to automatically isolate (close) when required by an actuation signal. It also addresses an event that results in high containment pressure with a concurrent failure of containment pressure control systems. Absent challenges to another fission product barrier, either condition represents potential degradation of the level of safety of the plant. EAL #1 Basis The containment isolation signal must be generated as the result on an off-normal/accident condition (e.g., a safety injection or high containment pressure); a failure resulting from testing or maintenance does not warrant classification. The determination of containment and penetration status - isolated or not isolated - should be made in accordance with the appropriate criteria contained in the plant AOPs and EOPs. The 15-minute criterion is included to allow operators time to manually isolate the required penetrations, if possible. Month 20XX FC 3-106 Mont 2OX FC -106EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omnhn Public Pnw*_r Di*trint RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU8 (cont) EAL #2 Basis Addresses a condition where containment pressure is greater than the setpoint at which containment energy (heat) removal systems are designed to automatically actuate, and less than one full train of equipment is capable of operating per design. The 15-minute criterion is included to allow operators time to manually start equipment that may not have automatically started, if possible. The inability to start the required equipment indicates that containment heat removal/depressurization systems (e.g., containment sprays or ice condenser fans) are either lost or performing in a degraded manner. This event would escalate to a Site Area Emergency in accordance with IC FS1 if there were a concurrent loss or potential loss of either the Fuel Clad or RCS fission product barriers.

1. NEl 99-01 Rev 6, SU7 Month 20XX FC 3-107 Mont 2OX FO

                                                                       -107EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA1 Loss of all offsite and all onsite AC power to emergency busses for 15 minutes or longer. 4,5, 0 Note:

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

1. Loss of all offsite AC power to vital 4160 volt buses 1A3 and 1A4, AND

2. Failure of EDG's DG1 and DG2 to supply power to vital 4160 volt buses 1A3 and 1A4.

AND

3. Failure to restore power to at least one vital 4160 volt bus in < 15 minutes from the time of loss of both offsite and onsite AC power.

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the FCCS. These are typically systems classified as safety-related This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. When in the cold shutdown, refueling, or defueled mode, this condition is not classified as a Site Area Emergency because of the increased time available to restore an emergency bus to service. Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition represents an actual or potential substantial degradation of the level of safety of the plant. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. Escalation of the emergency classification level would be via IC CS6 or RSI. Month 20XX FC 3-108 Mont 2OX FO -108EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Power District Omaha Public Power Ft Calhoun Station RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CA1 (cont)

1. NEI199-01 Rev 6,0CA2 Month 20XX FC 3-109 Mont 2OX FC

                                                           -109EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU1 Loss of all but one AC power source to emergency buses for 15 minutes or longer. 4,5, D Note:

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

1. AC power capability to vital 4160 volt buses 1A3 and 1A4 reduced to only one of the following power sources for_> 15 minutes.

161 Kv Circuit
345 Ky Circuit
EDG DG1
EDG DG2 AND

2. ANY additional single power source failure will result in a loss of ALL AC power to SAFETY SYSTEMS.

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment. When in the cold shutdown, refueling, or defueled mode, this condition is not classified as an Alert because of the increased time available to restore another power source to service. Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition is considered to be a potential degradation of the level of safety of the plant. Month 20XX FC 3-110 Mont 2OX FC3110EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CU1 (cont) An "AC power source" is a source recognized in AOPs and EOPs, and capable of supplying required power to an emergency bus. Some examples of this condition are presented below.

 *A loss of all offsite power with a concurrent failure of all but one emergency power source (e.g., an~onsite diesel generator).
 *A loss of all offsite power and loss of all emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from the unit main generator.
 *A loss of emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from an off site power source.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power. The subsequent loss of the remaining single power source would escalate the event to an Alert in accordance with IC CAl.

1. NEI 99-01 Rev 6 CU2 Month 20XX FC 3-111 Mont 2OX FC3l~lEP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA2 Hazardous event affecting SAFETY SYSTEM required for the current operating mode. 4, 5

1. The occurrence of ANY of the following hazardous events:

Seismic event (earthquake)

              *. Internal or external flooding event

High winds or tornado strike
FIRE
EXPLOSION
Other events with similar hazard characteristics as determined by the Shift Manager AND

2. EITHER of the following:

a. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.

OR

b. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure required by Technical Specifications for the current operating mode.

FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed. EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion. Such events may require a post-event inspection to determine if the attributes of an explosion are present. SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. Month 20XX FC 3-112 Mont 2OX FC3112EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Puhli* Power District

........ un
            ........                                        flVmm h~i P*ijh*irv PnwI r Dmmim it RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA2 (cont)

Bas~is,(cot: 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. This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or a structure containing SAFETY SYSTEM components, required for the current operating mode, "required", i.e. required to be operable by Technical Specifications for the current operating mode. This condition significantly reduces the margin to a loss or potential loss of a fission product barrier, and therefore represents an actual or potential substantial degradation of the level of safety of the plant. Manual or automatic electrical isolation of safety equipment due to flooding, in and of itself, does not constitute degraded performance and is classified under HU6. EAL #2.a Basis Addresses damage to a SAFETY SYSTEM train that is required to be operable by Technical Specifications for the current operating mode, and is in operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train. EAL #2.b Basis Addresses damage to a SAFETY SYSTEM component that is required to be operable by Technical Specifications for the current operating mode, and is not in operation or readily apparent through indications alone, or to a structure containing SAFETY SYSTEM components. Operators will make this determination based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage. Escalation of the emergency classification level would be via IC 056 or RS1. Ifthe EAL conditions of CA2 are not met then assess the event via HU3, HU4, or HU6.

1. NEI 99-01 Rev 6, CA6 Month 20XX FC 3-113 Mont 2OX FC3113EP-XX-XXXX (Revision XX)

Ft. Calhoun StationOmhPulcowrDsit Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU3 lnitiating* i on:

              *,- , l* -:*~ i** *! .nditi-. . .  . .  .   .   . _ii.**i*!*_*.:
                                                                   . . . . .i* . *.:-
                                                                                    . . i~~,,
                                                                                            . ii*i*
                                                                                               . .-._*!~i**~. i!*!!*!~~i
                                                                                                                 . .-          i~i*i*

Loss of Vital DC power for 15 minutes or longer. O perating M ode App ~.*-ii!y ~l~**i*ii iiiiil i:*,:iiiiiiil*. licabi!*iii ii*iiiii*ii ii!!* !i *i!I i ~~'* : ....

                                                                                                             *:*i*i i i*iiiiiility:i~i 4, 5 Note:

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

Voltage is <105 VDC on required 125 VDC Bus 1 and Bus 2 for_>15 minutes. SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. This IC addresses a loss of Vital DC power which compromises the ability to monitor and control operable SAFETY SYSTEMS when the plant is in the cold shutdown or refueling mode. In these modes, the core decay heat load has been significantly reduced, and coolant system temperatures and pressures are lower; these conditions raise the time available to restore a vital DC bus to service. Thus, this condition is considered to be a potential degradation of the level of safety of the plant. As used in this EAL, "required" means the Vital-DC buses necessary to support operation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment. For example, if Train A is out-of-service (inoperable) for scheduled outage maintenance work and Train B is in-service (operable), then a toss of Vital DC power affecting Train B would require the declaration of an Unusual Event. A loss of Vital DC power to Train A would not warrant an emergency classification. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. Depending upon the event, escalation of the emergency classification level would be via IC CA6 or GA5, or an IC in Recognition Category R. Month 20XX FC 3-114 Mont 2OX FC3114EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU3 (cont) Bass Reference s):) i:* **ii_ _i*..i....i*-i~ : :. i.. i,::-. .*.*i

                                                  -.                  ..-  - ~.: ....i:!.ii-.* :. .!:i:-,ii~

1. NEI 99-01 Rev 6, CU4 Month 20XX FC 3-115 Mont 2OX FC3115EP-XX-XXXX (Revision XX)

m IJ v*mm mv*m i vl*lmvm J Omaha Public Power District Omaha Public Ft CRihoun ~t~tinn RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU4 Loss of all onsite or offsite communications capabilities. 4,5, D

1. Loss of ALL Table C10Onsite communications capability affecting the ability tc) perform routine operations.

OR

2. Loss of ALL Table Cl Offsite communication capability affecting the ability to perform off site notifications.

OR

3. Loss of ALL Table Cl NRC communication capability affecting the ability to perform NRC notifications.

Table C1 - Communications Capability____ System Onsite Offsite NRC 800 MHz Radio System X Gai-tronics System X _________ Security Building PABX X X X Training Building PABX X X X Commercial Telephones X X X Conference OperationsX Network (COP) _________ FTS-ENS ____ X X HPN ____ X X Satellite phones _ _ X X Blair Phone Line _ _ __ X _ _ _ This IC addresses a significant loss of on-site, offsite, or NRC communications capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to Offsite Response Organizations (OROs) and the NRC. This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to off site locations, etc.). Month 20XX FC 3-116 Mont 2OX FC3l16EP-XX-XXXX (Revision XX)

I=t *lhnlm *t*tinn *Im*h* Pllhlir Pl-lw*r rliQtrlrf

FtI tHIIIV.II VtHaIm ll VIIIUIha Di kI ir Bn /i hfli lIrIri RECOGNITION CATEGORY COLD SHUTDOWN/IREFUELING SYSTEM MALFUNCTIONS CU4 (cont)

EAL #1 Basis Addresses a total loss of the communications methods used in support of routine plant operations, EAL #2 Basis Addresses a total loss of the communications methods used to notify all OROs of an emergency declaration. The OROs referred to here are listed in procedure FC-1 188 Event Notification Form. EAL #3 Basis Addresses a total loss of the communications methods used to notify, the NRC of an emergency declaration.

1. NEI 99-01 Rev 6, CU5 Month 20XX FC 3-117 Mont 2OX FC3117EP-XX-XXXX (Revision XX)

Ft. Calhoun StationOmhPulcowrDsit Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CA5 Inability to maintain the plant in cold shutdown. 4, 5 Note:

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when heat removal function is available does not warrant classification.

1. UNPLANNED rise in RCS temperature > 210°F for > Table C2 duration.

OR

2. UNPLANNED RCS pressure rise > 10 psi9 as a result of temperature rise. (This EAL does not apply in solid plant conditions.)

Table C2 RCS Heat-up Duration Thresholds RCS Status Containment Closure Heat-up Status Duration Intact Not Applicable 60 minutes* Not Intact Established 20 minutes* OR Reduced Inventory Not Established 0 minutes

If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, then EAL #1 is not applicable.

Month 20XX FC 3-118 Mont 2OX F03118EP-XX-XXXX (Revision XX)

I:t Ft*lhnnm .:;tAtinn ('*m*h* Plhlir Pnw,*r Ni*trirt IV I inmVt~innAmha ukiDnuriiet RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA5 (cont) B. is:. . . . . ... . . . . . . .. . ... .. . ... .. .. . - -' '* * "* * . .. 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. CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions. RCS is intact when the RCS pressure boundary is in its normal condition for the Cold Shutdown mode of operation (e.g. no freeze seals, etc.). This IC addresses conditions involving a loss of decay heat removal capability or an addition of heat to the ROS in excess of that which can currently be removed. Either condition represents an actual or potential substantial degradation of the level of safety of the plant. A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification. The RCS Heat-up Duration Thresholds table addresses a rise in RCS temperature when CONTAINMENT CLOSURE is established but the ROS is not intact, or ROS inventory is reduced (e.g., mid-loop operation in PWRs). The 20-minute criterion was included to allow time for operator action to address the temperature rise. The ROS Heat-up Duration Thresholds table also addresses a rise in ROS temperature with the RCS intact. The status of CONTAINMENT CLOSURE is not crucial in this condition since the intact RCS is providing a high pressure barrier to a fission product release. The 60-minute time frame should allow sufficient time to address the temperature rise without a substantial degradation in plant safety. Finally, in the case where there is a rise in RCS temperature, the RCS is not intact or is at reduced inventory, and CONTAINMENT CLOSURE is not established, no heat-up duration is allowed (i.e., 0 minutes). This is because 1) the evaporated reactor coolant may be released directly into the Containment atmosphere and subsequently to the environment, and 2) there is reduced reactor coolant inventory above the top of irradiated fuel. EAL #2 Basis Provides a pressure-based indication of RCS heat-up. Escalation of the emergency classification level would be via IC CS6 or RS1. Month 20XX FC 3-119 Mont 2OX FC3119EP-XX-XXXX(Revision XX)

Ft. Calhoun Station Ft. alhon SttionOmaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA5 (cont)

1. NEI 99-01 Rev 6, CA3 Month 20XX FC 3-120 Mont 2OX FO-120EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CU5 Init -tniating Condition: :r : ::*~~i::i*(*::::* i! :i* :*::::!!*;**,:i!: i::* :/:!,:***!i:*::i :: *,:*': UNPLANNED rise in RCS temperature 4, 5 Note:

The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when heat removal function is available does not warrant classification.

1. UNPLANNED rise in RCS temperature > 210°F.

OR

2. Loss of the following for >_15 minutes.

ALL ROS temperature indications AND
ALL RCS level indications 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.

CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions. This IC addresses an UNPLANNED rise in RCS temperature above the Technical Specification cold shutdown temperature limit, or the inability to determine RCS temperature and level, represents a potential degradation of the level of safety of the plant. Ifthe RCS is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency Director should als0 refer to IC CA5. RCS is intact when the RCS pressure boundary is in its normal condition for the Cold Shutdown mode of operation (e.g. no freeze seals, etc.). A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification. Month 20XX FC 3-121 Mont 2OX FC -121EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU5 (cont) EAL #1 Basis Involves a loss of decay heat removal capability, or an addition of heat to the RCS in excess of that which can currently be removed, such that reactor coolant temperature cannot be maintained below the cold shutdown temperature limit specified in Technical Specifications. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation. During an outage, the level in the reactor vessel will normally be maintained above the reactor vessel flange. Refueling evolutions that lower water level below the reactor vessel flange are carefully planned and controlled. A loss of forced decay heat removal at reduced inventory may result in a rapid rise in reactor coolant temperature depending on the time after shutdown. EAL #2 reflects a condition where there has been a significant loss of instrumentation capability necessary to monitor RCS conditions and operators would be unable to monitor key parameters necessary to assure core decay heat removal. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation. Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication. Escalation to Alert would be via IC CA6 based on an inventory loss or IC CA5 based on exceeding plant configuration-specific time criteria.

1. NEI 99-01 Rev 6, CU3 Month 20XX FC 3-122 Mont 2OX FC -122EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CG6 Loss of reactor vessel/RCS inventory affecting fuel clad integrity with containment challenged. 4, 5 Note:

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

1. RVLMS indicates 0.0% for > 30 minutes.

OR

2. a. Reactor Vessel / RCS level cannot be monitored for > 30 minutes.

AND

b. Core uncovery is indicated by ANY of the following:

Table 03 indications of a sufficient magnitude to indicate core uncovery.

OR

Erratic Source Range Neutron Monitor indication.

OR

Containment Area Radiation Monitors reading > 20 R/hr.

AND

c. ANY Containment Challenge Indication (Table C4)

Table C3 Indications of RCS Leakage

UNPLANNED Containment Sump level rise*
UNPLANNED Auxiliary Bldg. Sump level rise*
UNPLANNED Reactor Coolant Drain Tank level rise*
UNPLANNED Quench Tank level rise*
UNPLANNED Spent Regenerate Tank level rise*
UNPLANNED rise in ROS makeup
Observation of leakage or inventory loss

          *Rise in level is attributed to a loss of reactor vessel/RCS inventory.

Month 20XX FC 3-123 Mont 2OX FC

                                                                           -123EP-XX-XXXX (Revision XX)

Ft. Ftwn CnlhnHn Rtntinn ilhnnvn 5VtzainV (')rnnhn Punhlir. Pnw*r ni*trirt OmVIahAI P ihIIV~ Pn Vwir fl*I IVu COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CG6 (cont) Table C4 Containment Challenge Indications

Hydrogen Concentration in Containment > 3%
UNPLANNED rise in containment pressure
CONTAINMENT CLOSURE not established*
if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency isnot required.

iBasis- TII-i* i***i****~**i!

                   -~i                     *   **i/: ~i***~i iii!? i*.-T* !I::~ ** :*

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.

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. CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions. This IC addresses the inability to restore and maintain reactor vessel level above the top of active fuel with containment challenged. This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed EPA Protective Action Guidelines (PAG) exposure levels offsite for more than the immediate site area. Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable. With CONTAINMENT CLOSURE not established, there is a high potential for a direct and unmonitored release of radioactivity to the environment. If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required. Month 20XX FC 3-124 Mont 2OX FC -124EP-XX-XXXX (Revision XX)

Ft. C*lhoun RtRtinn OmAh* Puhli* P*w*_r District Ft CRmmhnun m Vtinn O mmmhl Pi ih*irv P nwIr Dkl~tmir RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CG6 (cont) The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a challenge to Containment integrity. In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a core uncovery could result in an explosive gas mixture in containment. If all installed hydrogen gas monitors are out-of-service during an event leading to fuel cladding damage, it may not be possible to obtain a containment hydrogen gas concentration reading as ambient conditions within the containment will preclude personnel access. During periods when installed containment hydrogen gas monitors are out-of-service, operators may use the other listed indications to assess whether or not containment is challenged. The 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring. The inability to monitor reactor vessel/ROS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the reactor vessel/ROS. These EALs address concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management. Month 20XX FC 3-125 Mont 2OX FC -125EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CG6 (cont) B aSiS R eference(s); : ;., ; ;- * ; ',;,;::; * : ;. ;.. . i .i:;

                                                             -i;. -     -*::.:, ..      .- ..'  r.'L'

1. NEI199-01 Rev 6, CG1 Month 20XX FC 3-126 Mont 2OX FO

                                                                                    -126EP-XX-XXXX (Revision XX)

Ft. Calhoun StationOmhPulcowrDsit Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CS6 Loss of reactor vessel/ROS inventory affecting core decay heat removal capability. 4, 5 Note:

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

1. With CONTAINMENT CLOSURE established RVLMS indicates 0.0%

OR

2. With CONTAINMENT CLOSURE no.tt established RVLMS _<8.0%

OR

3. a. Reactor Vessel / RCS level cannot be monitored for >30 minutes.

AND

b. Core uncovery is indicated by ANY of the following:

Table C3 indications of a sufficient magnitude to indicate core uncovery.

OR

Erratic Source Range Neutron Monitor indication.

OR S Containment Area Radiation Monitors reading > 20 R/hr. Table C3 Indications of RCS Leakage

UNPLANNED Containment Sump level rise*
UNPLANNED Auxiliary Bldg. Sump level rise*
UNPLANNED Reactor Coolant Drain Tank level rise*
UNPLANNED Quench Tank level rise*
UNPLANNED Spent Regenerate Tank level rise*
UNPLANNED rise in RCS makeup
Observation of leakage or inventory loss

         *Rise in level is attributed to a loss of reactor vessel/RCS inventory.

Month 20XX FC 3-127 Mont 2OX FC

                                                                          -127EP-XX-XXXX (Revision XX)

Ft_ C*lhnun RtAtinn OmAhR PHhlic P*w*_r DiRtri*t Ft C~Ihniin ~tatinn OmAhA Plihik PnwAr fliAtrit~tI RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CS6 (cont) 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. CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions. The lost inventory may be due to a RCS component failure, a loss of configuration control or prolonged boiling of reactor coolant. These conditions entail major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration. Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling 'and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable. Outage/shutdown contingency plans typically provide for re-establishing or verifying CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory control functions. The 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring. The inability to monitor reactor vessel/RCS level may be caused by instrumentation and/or power failures, or water level dropping below ,the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the reactor vessel/RCS. These EALs address concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management. Escalation of the emergency classification level would be via IC CG6 or RGI. Month 20XX FC 3-128 Mont 2OX FC (Revision XX)

                                                                         -128EP-XX-XXXX

Ft. Calhoun Station omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CS6 (cont)

1. NEI 99-01 Rev 6, CS1 Month 20XX FC 3-129 Mont 2OX FO

                                                           -129EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA6 I~nitiating Condition:i .. .. . ... *- . "- . . ..... .. . . Loss of reactor vessel/RCS inventory. Operating.Mode ApplicabilitY:i ....- / . .i,: .-. i, "- . ---- ... -- ' 4, 5 Emergency Action Level (EAL): * *.i **- **i...:i". !ii ~_ .:. i i. Note:

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

1. Loss of Reactor Vessel / RCS inventory as indicated by RVLMS < 14%

OR

2. a. Reactor Vessel /RCS level cannot be monitored for_> 15 minutes.

AND

b. Loss of Reactor Vessel / RCS inventory per Table 03 indications.

Table C3 Indications of RCS Leakage

UNPLANNED Containment Sump level rise*
UNPLANNED Auxiliary Bldg. Sump level rise*
UNPLANNED Reactor Coolant Drain Tank level rise*
UNPLANNED Quench Tank level rise*
UNPLANNED Spent Regenerate Tank level rise*
UNPLANNED rise in RCS makeup
Observation of leakage or inventory loss

          **Rise in level is attributed to a loss of reactor vessel/RCS inventory.

Month 20XX FC 3-130 Mont 2OX FO-130EP-XX-XXXX (Revision XX)

Ft. Calhoun Station OmRhR PHhlin Pnwmrr Di_*tri*t

...............          ti.n                                                                            O maha P*mjhWirV PAWI                   flilltrktv RECOGNITION CATEGORY COLD SHUTDOWN/IREFUELING SYSTEM MALFUNCTIONS CA6 (cont)

UN PLAN NED: 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. This IC addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier). This condition represents a potential substantial reduction in the level of plant safety. EAL #1 Basis A lowering of water level below 14% on RVLMS indicates that operator actions have not been successful in restoring and maintaining reactor vessel/ROS water level. The heat-up rate of the coolant will rise as the available water inventory is reduced. A continuing drop in water level will lead to core uncovery. Although related, EAL #1 is concerned with the loss of RCS inventory and not the potential concurrent effects on systems needed for decay heat removal (e.g., loss of a Residual Heat Removal suction point). A rise in ROS temperature caused by a loss of decay heat removal capability is evaluated under IC CA5. EAL #2 Basis The inability to monitor reactor vessel/ROS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the reactor vessel/ROS. The 15-minute duration for the loss of level indication was chosen because it is half of the EAL duration specified in IC CS6 If the reactor vessel/ROS inventory level continues to lower, then escalation to Site Area Emergency would be via IC CS6. Basis Re rference ii i:::*!*,!!!ii :ii ;!*!il ! l;i!i*i~i.i!;;i; i,:ii iii~ii!~~i .ii!~ ;i' *:**iiii:i::' ii!!i *!*i!li* i!!!~:;s):!

i~i!ii '~ii !i:ii

1. NEI 99-01 Rev 6, CA1 Month 20XX FC 3-131 Mont 2OX FC-131EP-XX-XXXX (Revision XX)

Ft. Calhoun StationOmhPulcowrDsit Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CU6 UNPLANNED loss of reactor vessel/RCS inventory for 15 minutes or longer. 4, 5 Note:

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

1. UNPLANNED loss of reactor coolant results in the inability to restore and maintain Reactor Vessel / ROS level to > procedurally established lower limit for > 15 minutes.

OR

2. a. Reactor Vessel / RCS level cannot be monitored.

AND

b. Loss of Reactor Vessel / RCS inventory per Table 03 indications.

Table C3 Indications of RCS Leakage

UNPLANNED Containment Sump level rise*
UNPLANNED Auxiliary Bldg. Sump level rise*
UNPLANNED Reactor Coolant Drain Tank level rise*
UNPLANNED Quench Tank level rise*
UNPLANNED Spent Regenerate Tank level rise*
UNPLANNED rise in RCS makeup
Observation of leakage or inventory loss

           *Rise in level is attributed to a loss of reactor vessel/RCS inventory.

Basis: - i*i!i- :!!**i ! '!! :'! i;* *::I'***'! ~! *:'*!*** :*:i*;:ii*** :i*i:** ;*:i 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. This IC addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor reactor vessel/RCS level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant. Month 20XX FC 3-132 Mont 2OX FC -132EP-XX-XXXX (Revision XX)

Ft. CAlhoun Rtntinn Ft= Os~alnutiu v~ttnvn (*mnhn A~mah*N. PHhlin Pnw*_r ni_*trint Piuhir PnuueUr fliUtri rV RECOGNITION CATEGORY COLD SHUTDOWN/IREFUELING SYSTEM MALFUNCTIONS Basi (cat):.CU 6 (cont) The procedurally established lower limit is not an operational band established above the procedural limit to allow for operator action prior to exceeding the procedural limit, but it is the procedurally established lower limit. Refueling evolutions that lower RCS water inventory are carefully planned and controlled. An UNPLANNED event that results in water level decreasing below a procedurally required limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered. EAL #1 Basis Recognizes that the minimum required reactor vessel/ROS level can change several times during the course of a refueling outage as different plant configurations and system lineups are implemented. This EAL is met if the minimum level, specified for the current plant conditions, cannot be maintained for 15 minutes or longer. The minimum level is typically specified in the applicable operating procedure but may be specified in another controlling document. The 15-minute threshold duration allows sufficient time for prompt operator actions to restore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level. EAL #2 Basis Addresses a condition where all means to determine reactor vessel/ROS level have been lost. In this condition, operators may determine that an inventory loss is occurring by observing changes in. sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the reactor vessel/RCS. Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA6 or GA5. Biasis R~efe-rence*(s)-::r**!*:*:::':i:i*!:*:- :"j*:i::.:: :i:-::'ii*::':i*:i:*

1. NEl 99-01, Rev. 6 CU1 Month 20XX FC 3-133 Mont 2OX FO -133EP-XX-XXXX (Revision XX)

Ft_ *Alhnlm Rt*tinn (*m*hn Pinhlir_ Pnw*r Ni*trirt Ftmv(vihnmin umvm flum vninin *kvn lPmihnar

vnul,* fNIleNtrV RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG1 HOSTILE ACTION resulting in loss of physical control of the facility.

1, 2, 3, 4,5, D

1. A notification from the Security Force that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA.

AND

2. a. ANY Table Hi safety function cannot be controlled or maintained.

OR

b. Damage to spent fuel has occurred or is IMMINENT Table Hi Safety Functions

Reactivity Control (ability to shut down the reactor and keep it shutdown)
Core Cooling (ability to cool the core)
RCS Heat Removal (ability to maintain heat sink)

Basis: **iii III!L i- i*!ii~iii:

                                        -        i~ i*!i~i*i*ii:i:*ii ~ i*iiiii i i~~ ~~ **iii!i~         i* !* !i ii*
                                                                                                   -i~i!~i*!iii~il HOSTILE ACTION: An act toward a NPP 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 NPP. 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).

HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. PROJECTILE: An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety. PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence. 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. Month 20XX FC 3-134 Mont 2OX FC -134EP-XX-XXXX (Revision XX)

I=t I*_*lhn,,n _*t*tlnn /'tm*h= D..hl;r, i:)nIM*-r n;*tr;,-*t f~* t* r*lll * ** U I i/~ll l VllEillI I I rLIIJllI* I VVV*I ~I.lLI~tw RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG1 (cont) Basis (cant):.~! i..i**iiii ~i~i: ~ !.!ii. :*~i!i!*i*!,ii* HOSTILE FORCE: Any 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. This IC addresses an event in which a HOSTILE FORCE has taken physical control of the facility to the extent that the plant staff can no longer operate equipment necessary to maintain key safety functions. It also addresses a HOSTILE ACTION leading to a loss of physical control that results in actual or IMMINENT damage to spent fuel due to

1) damage to a spent fuel pool cooling system (e.g., pumps, heat exchangers, controls, etc.) or, 2) loss of spent fuel pool integrity such that sufficient water level cannot be maintained.

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program]. !Ba~sis*Refer~ence* ):'!i**!*I*I** i :** ? :*~ i*:i*!i!*** i !~**iiiii*i~ ii i:*

ii'i!i!

1. NEI 99-01, Rev. 6 HG1 Month 20XX FC 3-135 Mont 2OX FC -135EP-XX-XXXX (Revision XX)

I*+ t*_*lhc*nnn *tati*n *lm=h* Dnnhlit* Dt*c*r NiQtrlrt I* fLVIIIibiln Qtat,IhI VllmIIM I uihIII DnVn,ar@ Ifl*tr ir RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS1 HOSTILE ACTION within the PROTECTED AREA. Operating Mode o Applicability:l iia :i.!.:.- --

iiii*i*i: :.i...i.:,i~ ii ... i . .. ....

1, 2, 3, 4,5, D A notification from the Security Force that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA. HOSTILE ACTION: An act toward a NPP 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 NPP. 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). HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. PROJECTILE: An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety. PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence. HOSTILE FORCE: Any 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. 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. This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTED AREA. This event will require rapid response and assistance due to the possibility for damage to plant equipment. Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Month 20XX FC 3-136 Mont 2OX FC -136EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HSl (cont) Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and QualificationPlan, Safeguards Contingency Plan fand Independent Spent Fuel Storage InstallationSecurity 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 Site Area Emergency declaration will mobilize ORO resources and have them available to develop and implement public protective actions in the unlikely event that the attack is successful in impairing multiple safety functions. This. IC does not apply to a HOSTILE ACTION directed at an ISFSI PROTECTED AREA located outside the plant PROTECTED AREA; such an attack should be assessed using IC HAl. It also 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 § 73.71 or 10 CFR § 50.72. Escalation of the emergency classification level would be via IC HG1.

1. NEI 99-01 Rev 6, HS1 Month 20XX FC 3-137 Mont 2OX FC -137EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA1 HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes. 1,2, 3,4, 5, D

1. A validated notification from NRC of an aircraft attack threat < 30 minutes from the site.

OR

2. Notification by the Security Force that a HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLED AREA.

HOSTILE ACTION: An act toward a NPP 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 NPP. 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). HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. PROJECTILE: An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety. OWNER CONTROLLED AREA (OCA): The property associated with the station and owned by the company. Access is normally limited to persons entering for official business. PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence. HOSTILE FORCE: Any 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. 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 Month 20XX FC 3-138 Mont 2OX FC -138EP-XX-XXXX (Revision XX)

I:t l*.*lhnim *tmH*n CIm*h* P, lhllr Pnw*r I'H*trirt Ft* n vC511iv,1mi fV,*Iti,~ IImI V hIL DIkIr

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RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA1 (cont) 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. Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program]. As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The Alert declaration will also heighten the awareness of Offsite Response Organizations, allowing them to be better prepared should it be necessary to consider further actions. This IC does not apply to incidents that are accidental 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 § 73.71 or 10 CFR § 50.72. EAL #1 addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in a heightened state of readiness. This EAL is met when the threat-related information has been validated in accordance with AOP-37. EAL #2 is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action directed against an ISESI that is located outside the plant PROTECTED AREA. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may be provided by NORAD through the NRC. In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency. Escalation of the emergency classification level would be via IC HSI. Month 20XX FC 3-139 Mont 2OX FC -139EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA1 (cont)

1. NEI 99-O1 Rev 6, HA1 Month 20XX FC 3-140 Mont 2OX FO

                                                          -140EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU1 Initiating C ondition: i* .. ."

i *- . i *i ... . .......

Confirmed SECURITY CONDITION or threat. 1, 2, 3, 4,5, D

1. Notification of a credible security threat directed at the site as determined per SY-AA-1 01-132, Security Assessment and Response to Unusual Activities.

OR

2. A validated notification from the NRC providing information of an aircraft threat.

OR

3. Notification by the Security Force of a SECURITY CONDITION that does not involve a HOSTILE ACTION.

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 SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. HOSTILE ACTION: An act toward a NPP 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 NPP. 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). HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station. PROJECTILE: An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety. Month 20XX FC 3-141 Mont 2OX FC-141EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omah* Puhlin Pnw*_r Di.qtriet RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU1 (cont) 'Basis (cant): o *:*!ii:i i~ilii:* i~!**i *:i~**i~i*i~!:i*i:*i.ii~iii: !:*il' *:~ i**ii* !ii~ ,*!i~ i:;!i~iiiiii:ii~ili_ This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, 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 I~s HA1, HS1 and HGI. Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to plant personnel and OROs. 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 #1 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with SY-AA-1 01-132, Security Assessment and Response to Unusual Activities. EAL #2 addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may also be provided by NORAD through the NRC. Validation of the threat is performed in accordance with AOP-37. EAL #3 references Security Force 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 § 2.39 information. Escalation of the emergency classification level would be via IC HAl.

1. NEI 99-01 Rev 6, HU1 Month 20XX FC 3-142 Mont 2OX FC -142EP-XX-XXXX (Revision XX)

I=t i*.mlhnlm _*tmtinn rlm--h* Plhlit, Prtl^r,-r I'liQtrlr-t Stl (lIhnIIIlnl Vltkt;I~n Am~l.alr., Dumi.,~i~l* DrhVllJI fr.atrul i RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS2 Inability to control a key safety function from outside the Control Room. 1, 2,3, 4, 5,6, D Note:

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

1. A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per:

AOP-07 Evacuation of Control Room OR
AOP-06 Fire Emergency AND

2. Control of ANY Table Hi key safety function is not reestablished in < 15 minutes.

Table Hi Safety Functions

Reactivity Control (ability to shut down the reactor and keep it shutdown)
Core Cooling (ability to cool the core)
RCS Heat Removal (ability to maintain heat sink)

The time period to establish control of the plant starts when either:

a. Control of the plant is no longer maintained in the Main Control Room OR

b. The last Operator has left the Main Control Room.

This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations, and the control of a key safety function cannot be reestablished in a timely manner. The failure to gain control of a key safety function following a transfer of plan control to alternate locations is a precursor to a challenge to any fission product barriers within a relatively short period of time. Month 20XX FC 3-143 Mont 2OX FC -143EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS2 (cont) The determination of whether or not "control" is established at the remote safe shutdown location(s) is based on Emergency Director judgment. The Emergency Director is expected to make a reasonable, informed judgment within 15 minutes whether or not the operating staff has control of key safety functions from the remote safe shutdown location(s). Escalation of the emergency classification level would be via IC EGi or 0G6.

1. NEI 99-01,RFev 6HS6 Month 20XX FC 3-144 Mont 2OX FO-144EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA2 Control Room evacuation resulting in transfer of plant control to alternate locations. 1,2, 3,4, 5, D A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per:

AOP-07 Evacuation of Control Room OR
AOP-06 Fire Emergency B asis:';;*:"::: ;:::T :; ": :".', :.:* : -:*:* * - *: :: "*."',.*." .:.:::!'"*.*.*.:: ** / *'!:.:{: : -** ::.:* '

This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations outside the Control Room. The loss of the ability to control the plant from the Control Room is considered to be a potential substantial degradation in the level of plant safety. Following a Control Room evacuation, control of the plant will be transferred to alternate shutdown locations. The necessity to control a plant shutdown from outside the Control Room, in addition to responding to the event that required the evacuation of the Control Room, will present challenges to plant operators and other on-shift personnel. Activation of the ERO and emergency response facilities will assist in responding to these challenges. Escalation of the emergency classification level would be via IC HS2.

1. NEI 99-01, Rev 6HA6 Month 20XX FC 3-145 Mont 2OX FC -145EP-XX-XXXX (Revision XX)

I=t_ *lhn, m .:;t*tinn r*mnhn Pllhli* Pnw*r niqtrirt FtV i IIhn, Ltain VII m h ,~Pn~rfI trir RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 FIRE potentially degrading the level of safety of the plant. 1,2, 3, 4,5, D

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

1. A FIRE in ANY Table H2 area is no* extinguished in < 15-minutes of ANY of the following FIRE detection indications:

Report from the field (i.e., visual observation)
Receipt of multiple (more than 1) fire alarms or indications
Field verification of a single fire alarm OR

2. a. Receipt of a single fire alarm in ANY Table H2 area (i.e., no other indications of a FIRE).

AND

b. The existence of a FIRE is no..t verified in < 30 minutes of alarm receipt.

OR 3 A FIRE within the plant PROTECTED AREA not extinguished in < 60-minutes of the initial report, alarm or indication. OR 4 A FIRE within the plant PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish. Table H2 Vital Areas

Containment Building
Auxiliary Building
Intake Structure
Turbine Building (SSE only)
Main and Auxiliary Transformer Yard
Condensate Storage Tank Area Month 20XX FC 3-146 Mont 2OX FC-146EP-XX-XXXX (Revision XX)

Ft. Calhoun StationOmhPulcowrDsit Omaha Public Power District HAZARDS AND OTHER RECOGNITION CONDITIONS CATEGORY AFFECTING PLANT SAFETY HU3 (cont) FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed. PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence. This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant. EAL #1 Basis The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE could be a drop in fire main pressure, automatic activation of a suppression system, etc. Upon receipt, operators will take prompt actions to confirm the validity of an initial fire alarm, indication, or report. For EAL assessment purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and not the time that a subsequent verification action was performed. Similarly, the fire duration clock also starts at the time of receipt of the initial alarms, indication or report. EAL #2 Basis Addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will take prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed. A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional time is allow\ed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress. If an actual FIRE is verified by a report from the field, then EAL #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted. Month 20XX FC 3-147 Mont 2OX FC -147EP-XX-XXXX (Revision XX)

Ft_ Cnlhnun fitntinnI (Imnhn Pihlir_ Pnw*r ni=trirt Fti OzilhnVInI Vtinil mIIhBI P iihIir PnuiwVV flhetrIa RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 (cont) EAL #3 Basis In addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety. EAL #4 Basis If a FIRE within the plant PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded. The dispatch of an offsite firefighting agency to the site requires an emergency declaration only if it is needed to actively support firefighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish. Declaration is not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions. The ISFSI is not specifically addressed in EAL #3 and #4 since it is within the plant PROTECTED AREA. Basis-Related Requirements from Appendix R Appendix R to 10 CFR 50, states in part: Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions." When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off. Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents. Month 20XX FC 3-148 Mont 2OX FC -148EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 (cont) In addition, Appendix R to 10 CER 50, requires, among other considerations, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify a single alarm is well within this worst-case 1-hour time period. Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC 0A2 or MA5.

1. NEI 99-01, Rev 6HU4 Month 20XX FC 3-149 Mont 2OX FO

                                                                       -149EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU4 IitiaJitin6g nitin Seismic event greater than OBE levels. O'peratin-gMode- Applicabilityi:!i"._:;i! - !i-i :i i *"I;:, : Y i ! i : :/;i 1,2, 3, 4,5,0D Seismic event > Operating Basis Earthquake (OBE) as indicated by

STRONG MOTION SEISMIC EVENT IN PROGRESS alarm OR
Event indicator (SMA-3 Control Panel) has changed from Black to White This IC addresses a seismic event that results in accelerations at the plant site greater than those specified for an Operating Basis Earthquake (OBE)1 . An earthquake greater than an OBE but less than a Safe Shutdown Earthquake (SSE)2 should have no significant impact on safety-related systems, structures and components; however, some time may be required for the plant staff to ascertain the actual post-event condition of the plant (e.g., performs walk-downs and post-event inspections). Given the time necessary to perform walk-downs and inspections, and fully understand any impacts, this event represents a potential degradation of the level of safety of the plant.

Event verification with external sources should not be necessary during or following an OBE. Earthquakes of this magnitude should be readily felt by on-site personnel and recognized as a seismic event (e.g., typical lateral accelerations are in excess of 0.08g). The Shift Manager or Emergency Director may seek external verification if deemed appropriate (e.g., a call to the USGS, check internet news sources, etc.); however, the verification action must not preclude a timely emergency declaration. Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA2 or MA5.

1. NEI 99-01, Rev 6HU2 1An OBE is vibratory ground motion for which those features of a nuclear power plant necessary for continued operation without undue risk to the health and safety of the public will remain functional.

An SSE is vibratory ground motion for which certain (generally, safety-related) structures, systems, and components must be designed to remain functional. Month 20XX FC 3-150 EP-XX-XXXX (Revision XX)

Ft. OCIhnijn 5Rt~tinn (*mnhn PHhlir_ Pnw*_r ni_*trirt RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA5 Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown. 1,2, 3, 4,5, D Note:

If the equipment in the listed room or area was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted.

1. Release of a toxic, corrosive, asphyxiant or flammable gas in ANY Table H3 area.

Area with Entry Tablaed Mode Applicability 1 Area Entry Related Mode ______________Applicability Containment Modes 4, 5 and D Room 6 Modes 4, 5and D Room 13 Modes 4, 5 and D Room i5A Modes 4, 5 and D Room 21 Modes 4, 5 and D Room 22 Modes 4, 5 and D Room 56 Modes 4, 5 and D Room 57 Modes 4, 5 and D Room 69 Modes 4, 5 and D AND

2. Entry into the room or area is prohibited or impeded.

This IC addresses an event involving a release of a hazardous gas that precludes or impedes access to equipment necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal plant procedures. This condition represents an actual or potential substantial degradation of the level of safety of the plant. Assuming all plant equipment is operating as designed, normal operation is capable from the Main Control Room (MCR). The plant is also able to transition into a hot shutdown condition from the MCR, therefore Table H3 is a list of plant rooms or areas with entry-related mode applicability that contain equipment which require a manual/local action necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal operating procedures, where if this action is not completed the plant would not be able to attain and maintain cold shutdown. Month 20XX FC 3-151 Mont 2OX FC

                                                                                    -151EP-XX-XXXX (Revision XX)

I:t *lhnnm .*t*tinn (*m*h* Pnnhl;*- P*r,*r ni*tri,-t Ft5 VHIIhn I In *t~iqinvnn VA ilah5411t

u,, ii VV ar D,,nh~mm,, l *ll, ivI, RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA5 (cont)

Basi (cnt) This Table does not include rooms or areas for which entry is required solely to perform actions of an administrative or record keeping nature (e.g., normal rounds or routine inspections). This Table does not include the Control Room since adequate engineered safety/design features are in place to preclude a Control Room evacuation due to the release of a hazardous gas. An Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time of the gaseous release. The emergency classification is not contingent upon whether entry is actually necessary at the time of the release. Evaluation of the IC and EAL do not require atmospheric sampling; it only requires the Emergency Director's judgment that the gas concentration in the affected room/area is sufficient to preclude or significantly impede procedurally required access. This judgment may be based on a variety of factors including an existing job hazard analysis, report of ill effects on personnel, advice from a subject matter expert or operating experience with the same or similar hazards. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed). An emergency declaration is not warranted if any of the following conditions apply.

  *The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the gaseous release). For example, the plant is in Mode 1 when the gaseous release occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.

The gas release is a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., fire suppression system testing).
The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).
The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.

An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment. This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death. Month 20XX FC 3-152 Mont 2OX FC -152EP-XX-XXXX (Revision XX)

Ft_ Cnlhn.n *tntinn (*mnhn P.hlir_ Pnw*r ni_*trirt RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA5 (cont) This EAL does not apply to firefighting activities that generate smoke or that automatically or manually activate a fire suppression system in an area. Escalation of the emergency classification level would be via Recognition Category R, C or F I~s. Basis~i!* * *

iiilii !!i ili~i*iii ii:!eference~*ii !ii!!~i~iiiiiiiiii!*!iii~iii ~ii

                                                                                   -   iii ~i i~iis):ill**i ~ ii!ii**ii**~i~

1. NEI 99-01, Rev 6 HA5 Month 20XX FC 3-153 Mont 2OX FC

                                                                                                 -153EP-XX-XXXX (Revision XX)

Ft. Calhoun StationOmhPulcowrDsit Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 Hazardous Event 1, 2, 3,4, 5, D Em ergency Action Level XEAL}, ...*:* **: *;* b:'"£ [:'":'3::** ... "*:"#"" ":' Note:

EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.

1. Tornado strike within the PROTECTED AREA.

OR

2. Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component required by Technical Specifications for the current operating mode.

OR

3. Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).

OR

4. A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.

OR

5. Abnormal River level, as indicated by EITHER:

a. > 1004 feet MSL elevation (high level)

OR

b. < 976 feet, 9 inches MSL elevation (low level)

PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence. SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related. Month 20XX FC 3-154 Mont 2OX FC -154EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 (cont) This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant. EAL 1 Basis Addresses a tornado striking (touching down) within the Protected Area. EAL #2 Basis Addresses flooding of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns. Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode. EAL #3 Basis Addresses a hazardous materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel within the PROTECTED AREA. EAL #4 Basis Addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles. Examples of such an event include site flooding caused by a hurricane, heavy rains, up-river water releases, dam failure, etc., or an on-site train derailment blocking the access road. This EAL is not intended to apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the flooding around the Cooper Station during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in 2011. EAL #5 Basis The minimum level of 976 feet 9 inches provides adequate suction to the pumps for cooling plant components. The minimum elevation of the raw water pump suction is 973 feet 9 inches. High river level of 1004 feet is based on elevation of the plant site and Security Building Floor and on Technical Specification 2.16 indicating that the flooding plan to protect the plant will be instituted at 1004.2 feet and rising. Escalation of the emergency classification level would be based on ICs in Recognition Categories R, F, M, H or C. Month 20XX FC 3-155 Mont 2OX FC -155EP-XX-XXXX (Revision XX)

I:t P_-Jih*= in _*t*'l'inn A'makha I:..klik IDnuirr fI'Htriet-RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 (cont)

1. NEI 99-01, Rev 6HU3 Month 20XX FC 3-156 Mont 2OX EQ (Revision XX)

                                                              -156EP-XX-XXXX

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Initatig Coditon:HG7 Other conditions exist which in the judgment of the Emergency Director warrant declaration of a GENERAL EMERGENCY. Operat*ing Mode ApplicabJ ~i i!:i:iiili,, ii;i: iiii;!:;:!i ,!i:i: !:~i~l* 1;v :i:i*:ii*:i::! ii!~ iii::i: ii*ilty:i~ 1,2, 3, 4,5, D Emier*gency Action cto Level* (EAL!i~i~~i: ( )iii : !i:! ii ii **i:***ii iiiiiiiii! -i! iii!*: Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area. 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. HOSTILE ACTION: An act toward a NPP 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 NPP. 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). HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE: An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety. 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 General Emergency.

1. NEI 99-01, Rev 6HG7 Month 20XX FC 3-157 Mont 2OX FC-157EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS7 Initiating* ,, * **:-*,' C ondition*iy/'*"'

                           "';" :','     *r":' * * '**'/ !** *=:*' °,/* S ' ***i *'*   : "*':' ?//          *='  '

Other conditions exist which in the judgment of the Emergency Director warrant declaration of a SITE AREA EMERGENCY. 1, 2, 3, 4,5, D Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts, (1) toward site personnel or equipment that could lead to the likely failure of or, (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary. HOSTILE ACTION: An act toward a NPP 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 NPP. 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). HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE: An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety. 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 Site Area Emergency.

1. NEI 99-01, Rev 6HS7 Month 20XX FC 3-158 Mont 2OX FC -158EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA7 initiating,cond~ition:* " -. ... ~ i: .i!i*:i* "i:. ,., _:- *. -. . Other conditions exist which in the judgment of the Emergency Director warrant declaration of an ALERT. 1,2, 3, 4,5, D 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. HOSTILE ACTION: An act toward a NPP 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 NPP. 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). HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE: An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety. 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.

1. NEI 99-01, Rev 6 HA7 Month 20XX FC 3-159 Mont 2OX FC-159EP-XX-XXXX (Revision XX)

Ft. Calhoun StationOmhPulcowrDsit Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU7 Other conditions exist which in the judgment of the Emergency Director warrant declaration of an UNUSUAL EVENT. 1,2, 3, 4,5, D Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs. Basis:..*.*'*::';:,*;*:7; -*!: J :* **:*G : *:- T:'*; -:'i':;*- *.::** *:. ::

                                                                      -       - ,- **',:.;*    '3 ;,? "::,**:';::i*;.*** '**,*':*;' * '*i:

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 UNUSUAL EVENT.

Basis: "': Reference(s); 1. "NEI 99-01,Rev 6HU7 Month 20XX FC 3-160 Mont 2OX FC -160EP-XX-XXXX (Revision XX)

I:t *.=lhn,,n _*tntinn l*mmhm Palhlir P*luAr rliQtrirt FtE VLaihlnudl VEtEIVin VIIIahIiI iBiik

VulVI flietu.i it RECOGNITION CATEGORY ISFSI MALFUNCTIONS E-HU1 Damage to a loaded cask CONFINEMENT BOUNDARY.

1,2, 3, 4,5, D Emergency Action el* i**aLevel(E E L) I*Y 1!:*! il*~Giii*i'**!*i; **:i*i~~~*i~iII 3*;ii:*.ii!iii*i;i**i: Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading:

60mrlhr (gamma + neutron) on the top of the spent fuel cask OR
600mr/hr (gamma + neutron) on the side of the spent fuel cask, excluding inlet and outlet ducts CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask barrier(s) between areas containing radioactive substances and the environment.

INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSl)

A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.

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 word cask, as used in this EAL, refers to the storage container in use at the site for dry storage of irradiated fuel. 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", which is also used in Recognition Category R IC RU1, 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 HU1 and HA1. Month 20XX FC 3-161 Mont 2OX FC -161EP-XX-XXXX (Revision XX)

rAmnhn P..hlir_ Pnui,~r ni_*trir~t RECOGNITION CATEGORY ISFSI MALFUNCTIONS E-HU1 (cont)

1. NEI 99-01, Rev 6 E-HU1 Month 20XX FC 3-162 Mont 2OX EC-162EP-XX-XXXX (Revision XX)

LIC-1 5-0121 Page 1 IC RG2, RS2, and RA2 Pages Marked "POST MODIFICATION per NRC ORDER EA-12-051"

POST MODIFICATION per NRC ORDER EA-12-051 Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RG2 Initiatin -Condition: Spent fuel pool level cannot be restored to at least (site-specific Level 3 description) for 60 minutes or longer. OQPerating Mode Applicability: rl.. ."*" ... ........ . . 1,2, 3, 4,5, D iEmergency Action Level (EAL):. ........... .. : Note: The Emergency Director should declare the General Emergency promptly upon determining that the applicable time has been exceeded, or will likely be exceeded. Spent fuel pool level cannot be restored to at least Level 3 value for 60 minutes or longer. Basis: This IC addresses a significant loss of spent fuel pool inventory control and makeup capability leading to a prolonged uncovery of spent fuel. This condition will lead to fuel damage and a radiological release to the environment. It is recognized that this IC would likely not be met until well after another General Emergency IC was met; however, it is included to provide classification diversity. Basis Reference(s): .. =

1. NEI 99-01 Rev 6, AG2 Month 20XX FC 3-XX Mont 20)X FC3-XXEP-XX-XXXX (Revision XX)

POST MODIFICATION per NRC ORDER EA-12-051 Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS RS2 Initiating Cond ition--: i < i,.. -

i -- *i .. .::... -i*- : i** .. _ _

Spent fuel pool level at (site-specific Level 3 description). Operating Mode Applicab~ility; _... 1, 2, 3, 4,5, D !Emergency Action LevelI(EAL):I .. '- i i.".. ... Lowering of spent fuel pool level to Level 3 value. B as is: - ".. . . " - :... ... ... . . . . ..... ...- . ".. This IC addresses a significant loss of spent fuel pool inventory control and makeup capability leading to IMMINENT fuel damage. This condition entails major failures of plant functions needed for protection of the public and thus warrant a Site Area . Emergency declaration. It is recognized that this IC would likely not be met until well after another Site Area Emergency IC was met; however, it is included to provide classification diversity. Escalation of the emergency classification level would be via IC RG1 or RG2. Basis Reference(s): ' i..... . .

1. NEI 99-01 Rev 6, AS2 Month 20XX FC 3-XX Mont 2OX FC

                                                                                              -XXEP-XX-XXXX (Revision XX)

POST MODIFICATION per NRC ORDER Ft. Calhoun Station EA-12-051 Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA2 Initiating Condition:i..., Significant lowering of water level above, or damage to, irradiated fuel. Operating Mode Applicability:. 1,2, 3,4, 5, D Emergency Action Level (EAL):

1. Uncovery of irradiated fuel in the REFUELING PATHWAY.

OR

2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by ANY Table R4 Radiation Monitor reading >1000 mRem/hr OR-

3. Lowering of spent fuel pool level to Level 2 value.

I Table R4 Radiation Monitors RMS Area Monitored RM-73,74,75 Containment Rad Monitor RM-085,87 Auxiliary Building Rad Monitor PortbleRad Containment and auxiliary Building near fuel handling areas Monitor Basis: REFUELING PATHWAY: all the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange. 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. This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly. These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment. As such, they represent an actual or potential substantial degradation of the level of safety of the plant. This IC applies to irradiated fuel that is licensed for dry storage up to the point that the loaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss of the CONFINEMENT BOUNDARY is classified in accordance with IC E-HUI. Month 20XX FC 3-XX Mont 2OX FC

                                                                            -XXEP-XX-XXXX (Revision XX)

POST MODIFICATION per NRC ORDER EA-12-051 Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS RA2 (cont) Basis (cont*): :i i !ii i : ... * . i * -*. i, : :: EAL #1 Basis: This EAL escalates from RU2 in that the loss of level, in the affected portion of the REFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery of irradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visual observation (e.g., reports from personnel or camera images), as well as significant changes in water and radiation levels, or other plant parameters. Computational aids may also be used (e.g., a boil-off curve). Classification of an event using this EAL should be based on the totality of available indications, reports and observations. While an area radiation monitor could detect a rise in a dose rate due to a lowering of water level in some portion of the REFUELING PATHWAY, the reading may not be a reliable indication of whether or not the fuel is actually uncovered. To the degree possible, readings should be considered in combination with other available indications of inventory loss. A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes. EAL #2 Basis: This EAL addresses a release of radioactive material caused by mechanical damage to irradiated fuel. Damaging events may include the dropping, bumping or binding of an assembly, or dropping a heavy load onto an assembly. A rise in readings on radiation monitors should be considered in conjunction with in-plant reports or observations of a potential fuel damaging event (,e.g., a fuel handling accident). EAL #3 Basis: Spent fuel pool water level at this value is within the lower end of the level range necessary to prevent significant dose consequences from direct gamma radiation to personnel performing operations in the vicinity of the spent fuel pool. This condition reflects a significant loss of spent fuel pool water inventory and thus it is also a precursor to a loss of the ability to adequately cool the irradiated fuel assembles stored in the pool. Escalation of the emergency would be based on either Recognition Category R or C ICs. .Basis Referen Ce(s): i *..! ...i ; ,* , .. ..." " ..

1. NEI 99-01 Rev 6, AA2 Month 20XX FC 3-XX Mont 20)X FC3-XXEP-XX-XXXX (Revision XX)}}

v t e Letter Sequence Supplement
TAC:MF5466, (Open)
Initiation Request, Request Acceptance Supplement, Supplement Administration Questions 14 July 2015 Answers 11 September 2015 Results Approval... Other:
MONTHYEAR2015-12-08 [Table View]

LIC-15-0121, ISFSI - Supplemental OPPD Response to NRC Request for Additional Information License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6

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LIC-15-0121, ISFSI - Supplemental OPPD Response to NRC Request for Additional Information License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6

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