LIC-12-0056, License Amendment Request (LAR) 12-03, Proposed Change to Revise Operating Requirements for Technical Specification 2.16, River Level, & Establish Emergency Action Level Classification Criteria for External Flooding Events Under the Radi

License Amendment Request (LAR) 12-03, Proposed Change to Revise Operating Requirements for Technical Specification 2.16, River Level, & Establish Emergency Action Level Classification Criteria for External Flooding Events Under the Radiolo

ML12121A565
Person / Time
Site:	Fort Calhoun
Issue date:	04/27/2012
From:	Bannister D Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-12-0056, TAC ME5431
Download: ML12121A565 (100)

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Omahalk Power Disti ct 444 South 16'h Street Mall Omaha, NE 68102-2247 LIC-12-0056 April 27, 2012 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

References:

1. Docket No. 50-285

2. Letter from NRC (Document Control Desk) to OPPD (D. J. Bannister), "Fort Calhoun Station, Unit No.1- Conversion of Emergency Action Levels Based on Nuclear Energy Institute (NEI) 99-01, "Methodology for Development of Emergency Action Levels (TAC NO. MD5431)," dated October 3, 2008 (NRC-08-0094)(ML082670196)

3. NEI 99-01, "Methodology for Development of Emergency Action Levels,"

Revision 5, dated February 2008 (ML080450149)

4. SECY-1 1-0053, "Final Rule: Enhancements to Emergency Preparedness Regulations (10 CFR Part 50 and 10 CFR Part 52) (RIN-3150-AI10)," dated April 8, 2011

5. Regulatory Issue Summary 2005-02, Revision 1, "Clarifying the Process for Making Emergency Plan Changes," dated April 19, 2011 (ML100340545)

6. NUREG-0212, "Standard Technical Specifications for Combustion Engineering Pressurized Water Reactors," Revision 2, issued Fall 1980

7. Letter from OPPD (D. J. Bannister) to NRC (Document Control Desk),

"Retraction of License Amendment Request (LAR) 10-06," dated January 4, 2012 (LIC-1 1-0127)

8. Letter from NRC (J. A. Clark) to OPPD (D. J. Bannister), "Fort Calhoun -NRC Integrated Inspection Report 05000285/2010003," dated July 26, 2010 (NRC-10-0060) (ML102080231)

SUBJECT:

License Amendment Request (LAR) 12-03, Proposed Change to Revise Operating Requirements for Technical Specification 2.16, River Level, and Establish Emergency Action Level Classification Criteria for External Flooding Events under the Radiological Emergency Response Plan for Fort Calhoun Station As committed to in Reference 7, the Omaha Public Power District (OPPD) is submitting this license amendment request (LAR) to address a non-cited violation of 10 CFR 50.36(c)(2)(ii)(B) identified in Reference 8, which identified that limiting condition for operation (LCO) 2.16 of the Fort Calhoun Station (FCS) Technical Specifications (TS) is inadequate should the Missouri River exceed 1009 feet mean sea level (msl).

AcS

U. S. Nuclear Regulatory Commission LIC-12-0056 Page 2 Pursuant to 10 CFR 50.90, OPPD hereby requests an amendment to the Renewed Facility Operating License No. DPR-40 for FCS, Unit No. 1, TS LCO 2.16, River Level, and to TS surveillance requirement (SR) 3.2, Equipment and Sampling Tests, Table 3-5, Minimum Frequencies for Equipment Tests. In addition, OPPD requests to amend the FCS Radiological Emergency Response Plan (RERP) declaration procedure as licensed in the Reference 2 safety evaluation report (SER) for conversion of the emergency action levels (EALs).

Specifically, this proposed change revises the LCO requirements when the Missouri River level reaches elevation 1004 feet msl, the reactor will be in a HOT SHUTDOWN condition in accordance with the applicable abnormal operating procedure (AOP) and will be placed in COLD SHUTDOWN within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> following entry into HOT SHUTDOWN. This proposed change also revises the LCO requirement for when the Missouri River level is less than 976 feet 9 inches msl, the reactor shall be placed in HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWN within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A third LCO requirement is being added such that at Missouri River levels less than 980 feet or greater than 1002 feet msl, a continuous watch will be maintained to monitor river levels to assure no sudden loss of water supply occurs on low river level and provide adequate response time for rising river levels.

In addition, a new TS SR 3.2, Table 3-5, Item 25, is added for taking river level measurements on a daily basis to determine if the river water level is within its required limits (i.e., less than 1004 feet msl and greater than or equal to 976 feet 9 inches msl). The proposed changes to the FCS TS LCO 2.16 and TS SR 3.2 for flood protection model NUREG-0212, Revision 2, Standard Technical Specifications for Combustion Engineering Pressurized Water Reactors, Sections 3/4.7.6, Flood Protection(Reference 6).

This proposed change also establishes the EAL for the Alert and Notification of Unusual Event (NOUE) classifications for external flooding. OPPD personnel concluded that flooding levels which require full implementation of the Emergency Plan (EP) procedures and personnel to protect the vital areas of the station warranted escalation from a NOUE to an ALERT. Based on the guidance provided in RIS 2005-02 (Reference 5), revising the elevation at which time the EP procedures and personnel protect the vital areas of the station from a NOUE to an ALERT is considered a decrease in effectiveness and warrants prior NRC approval. The elevation at which these actions are required is 1007 feet msl.

Therefore, the proposed EAL change revises the high river level entry for initiating condition (IC)

HA1, EAL 6 from 1009 feet msl elevation to 1007 feet msl elevation and also changes the bounding condition (upper limit) of the NOUE classification for flooding (IC HU1, EAL 5) from 1009 feet msl to 1007 feet msl. These revisions will result in the ICs and EALs being more closely aligned with Nuclear Energy Institute (NEI) 99-01, Revision 5 (Reference 3). In addition, the associated basis for Recognition Category H (Hazardsand Other Conditions Affecting Plant Safety) is being modified to reflect the proposed flooding level changes. The emergency planning portion of this LAR is being submitted per the NRC guidance provided in References 4 and 5.

The associated Bases for TS 2.16 and 3.2 are also being modified to reflect the proposed river level LCO and SR for river level operability. These TS Bases Changes (TSBCs) are included for information and will be processed in accordance with TS 5.20, TS Bases Control Program.

U. S. Nuclear Regulatory Commission LIC-12-0056 Page 3 OPPD concludes that the proposed LAR presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this amendment.

The enclosure contains OPPD's evaluation of the proposed changes, including the supporting technical evaluation, and the significant hazards consideration determination. Attachment 1 provides the existing TS and TS Bases pages marked-up to show the proposed changes to TS 2.16 and TS 3.2. Attachment 2 provides the associated retyped (clean) TS and TS Bases pages. of the enclosure provides the existing EAL procedure, TBD-EPIP-OSC-1H, Recognition Category H - Hazards.and Other Conditions Affecting Plant Safety, marked-up to show the proposed changes. Attachment 4 of the enclosure provides the retyped (clean) version of TBD-EPIP-OSC-1 H.

OPPD requests approval of the proposed amendment by April 27, 2013. Once approved, the amendment shall be implemented within 120 days.

Should FCS begin power operations before an amendment is implemented, OPPD will utilize existing guidance contained in AOP-1, "Acts of Nature," and shut the plant down if river level is expected to rise to 1004 feet msl. Administrative controls such as this are an acceptable short-term corrective action as noted in NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications that are Insufficient to Assure Plant Safety."

There are no regulatory commitments associated with this proposed change.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated State of Nebraska official.

If you should have any questions regarding this submittal or require additional information, please contact Mr. Bill R. Hansher, Supervisor-Nuclear Licensing, at 402-533-6894 or Mr. Allen Berck, Manager - Emergency Planning and Administrative Services, at 402-533-6064.

I declare under penalty of perjury that the foregoing is true and correct. Executed on April 27, 2012.

D. J. Bannister Site Vice President and CNO

Enclosure:

OPPD's Evaluation of the Proposed Change(s) c: E. E. Collins, Jr., NRC Regional Administrator, Region IV L. E. Wilkins, NRC Project Manager J. C. Kirkland, NRC Senior Resident Inspector Manager Radiation Control Program, Nebraska Health & Human Services, R & L Public Health Assurance, State of Nebraska

LIC-12-0056 Enclosure Page 1 OPPD's Evaluation of the Proposed Change(s)

License Amendment Request (LAR) 12-03, Proposed Change to Revise Operating Requirements for Technical Specification 2.16, River Level, and Establish Emergency Action Level Classification Criteria for External Flooding Events under the Radiological Emergency Response Plan for Fort Calhoun Station 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 Significant Hazards Consideration 4.4 Conclusions

6.0 REFERENCES

ATTACHMENTS:

1. Technical Specification and Information Only Bases Pages Markups

2. Retyped ("Clean") Technical Specifications and Information Only Bases Pages

3. EAL TBD-EPIP-OSC-1 H, Recognition Category H - Hazards and Other Conditions Affecting Plant Safety, [Mark-up Pages]

4. EAL TBD-EPIP-OSC-1 H, Recognition Category H - Hazards and Other Conditions Affecting Plant Safety, [Retyped ("Clean") Pages]

LIC-12-0056 Enclosure Page 2 1.0

SUMMARY

DESCRIPTION The Omaha Public Power District (OPPD) proposes a change to the Renewed Facility Operating License No. DPR-40 for Fort Calhoun Station (FCS), Unit No. 1, Technical Specification (TS) limiting condition for operation (LCO) 2.16, River Level; TS surveillance requirement (SR) 3.2, Equipment and Sampling Tests, Table 3-5, Minimum Frequencies for Equipment Tests; and, revises the FCS Radiological Emergency Response Plan (RERP) declaration procedure as licensed in the safety evaluation report (SER) for conversion of the emergency action levels (EALs)

(Reference 6.1). As committed to in Reference 6.21, OPPD is submitting this license amendment request (LAR) to address a non-cited violation of 10 CFR 50.36(c)(2)(ii)(B) identified in Reference 6.22, which identified that LCO 2.16 of the FCS TS is inadequate should the Missouri River exceed 1009 feet mean sea level (msl).

Specifically, this proposed change revises the LCO requirements when the Missouri River level reaches elevation 1004 feet msl, the reactor will be in a HOT SHUTDOWN condition in accordance with the applicable abnormal operating procedure and will be placed in COLD SHUTDOWN within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> following entry into HOT SHUTDOWN.

This proposed change also revises the LCO requirement for when the Missouri River level is less than 976 feet 9 inches msl, the reactor shall be placed in HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWN within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. A third LCO requirement is being added such that at Missouri River levels less than 980 feet or greater than 1002 feet msl, a continuous watch will be maintained to monitor river levels to assure no sudden loss of water supply occurs on low river level and provide adequate response time for rising river levels. (Note that all elevations represented in the FCS design basis are referenced to the National Geodetic Vertical Datum of 1929 (NGVD 1929) datum.)

In addition, a new TS SR 3.2, Table 3-5, Item 25, is added for taking river level measurements on a daily basis to determine if the river water level is within its required limits (i.e., river level is less than 1004 feet msl and greater than or equal to 976 feet 9 inches msl).

These proposed changes to the FCS TS LCO 2.16 and TS SR 3.2 for high river level model NUREG-0212, Revision 2, Standard Technical Specifications for Combustion Engineering Pressurized Water Reactors, issued Fall 1980, Sections 3/4.7.6.

(Reference 6.2) In addition, this proposed change administratively reformats columns by adding the column header to TS 3.2, Table 3-5, Items 17 through 25, for consistency.

The proposed EAL change revises the high river level entry for initiating condition (IC)

HA1, EAL 6 from 1009 feet msl elevation to 1007 feet msl elevation and also changes the bounding condition (upper limit) of the notification of unusual event (NOUE) classification for flooding (IC HU1, EAL 5) from 1009 feet msl to 1007 feet msl. These revisions will result in the ICs and EALs being more closely aligned with Nuclear Energy Institute (NEI) 99-01, Revision 5 (Reference 6.19). In addition, the associated basis- for Recognition Category H (Hazards and Other Conditions Affecting Plant

LIC-1 2-0056 Enclosure Page 3 Safety) is being modified to reflect the proposed flooding level changes. The emergency planning portion of this license amendment request (LAR) is being submitted per the NRC guidance provided in References 6.18 and 6.20.

The associated TS Bases for TS 2.16 and 3.2, which are provided for information purposes, are also being revised in accordance with TS 5.20, TS Bases Control Program.

2.0 DETAILED DESCRIPTION The proposed TS changes for LAR 12-03 are as follows:

TS LCO 2.16, River Level

" Applicability statement is being revised to "At all times."

Applicability Aple to Mi;6uuu Rie lee as measured at th intake structure at Foert Calhoun Station.

"At all times."

" Objective is being revised to add "as measured at the intake structure.

Obiective "To specify maximum and minimum Missouri River levels as measured at the intake structure which must be present to assure safe reactor operation."

" "Specifications" are being deleted in their entirety and replaced with new "Specifications" which are modeled after NUREG-0212, Revision 2.

Specifications

'The water level of the Missouri River shall remain less than 1004 feet mean sea level and greater than or equal to 976 feet 9 inches mean sea level as measured at the intake structure."

1) if the Missouri River level execods 1009(1) feet the reactor will be placed i cold shutdo*wn cndition. using normal operating proedures*. When the river level reaches elevationi 1004.2 feet and rising, the emergency plan to protect the pl-ant Mill beP instituted.

(2) if the Missouri River level is less thani 976 feet 9 incehes the reactor will b placed in; a Gold rshutdown condition usn noma operating procedueres.A river levels less than 980 feet a continuou atch will be maintained -to assure no sudden lossr of wlfater supplyGoccurs.

LIC-12-0056 Enclosure Page 4 Add "Required Actions" statements:

Required Actions (1) When the Missouri River level reaches elevation 1004 feet mean sea level, the reactor shall be in a HOT SHUTDOWN condition and in COLD SHUTDOWN within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> following entry into HOT SHUTDOWN; and (2) If the Missouri River level is less than 976 feet 9 inches mean sea level, the reactor shall be placed in HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWN within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />; and, (3) At Missouri River levels less than 980 feet or greater than 1002 feet mean sea level, a continuous watch will be maintained to monitor river levels to assure no sudden loss of water supply occurs on low river level and provide adequate response time for rising river levels.

These proposed changes to the FCS TS LCO 2.16 for flood protection model NUREG-0212, Revision 2, Standard Technical Specifications for Combustion Engineering Pressurized Water Reactors, issued Fall 1980, Section 3.7.6. (Reference 6.2)

Required Actions (2) and (3) are not new TS required actions; they are just renumbered and reworded versions of the existing TS 2.16 Specification (2).

TS Surveillance Requirement 3.2, Equipment and Sampling Tests Table 3-5, Minimum Frequenciesfor Equipment Tests, is being revised as follows:

" Item 25, River Level, is being added to Table 3-5 to verify the Missouri River water level is within in its required limits. Measurements will be taken daily to determine if river level is less than 1004 feet msl and greater than or equal to 976 feet 9 inches msl. Currently, there is no TS required SR for river level; therefore, this SR is being added to Table 3-5.

" Table 3-5 is also being reformatted such that the column entitled "USAR Section Reference" is added for items 17 through 25. As a result, for these same items, under the column entitled "Frequency," the text is being "wrapped" to the next line(s) as appropriate, to ensure the text fits in the allotted column space for proper tabular formatting. These are administrative corrections which make Table 3-5 grammatically consistent throughout.

The proposed SR models the river level measurement SR delineated in NUREG-0212, Revision 2 (Reference 6.2, Section 4.7.6).

The associated TS Bases Changes (TSBCs) for TS 2.16 and 3.2 proposed by this LAR are to provide clarification for the river level operability LCO and SR specific to the Missouri River level. The proposed TSBCs are provided for information purposes and will be processed in accordance with TS 5.20 as part of the amendment implementation.

LIC-12-0056 Enclosure Page 5 Proposed Emergency Action Level Changes:

The proposed EP changes for the EALs delineated in procedure TBD-EPIP-OSC-1 H, Recognition Category H - Hazards and Other Conditions Affecting Plant Safety, for LAR 12-03 are provided below.

IC HU1, EAL 5:

The NOUE initiating condition (IC) HU1, EAL 5 flooding (high water level) entry condition is changed to "River level is greater than 1004 feet MSL, but less than or equal to 1007 feet MSL elevation" as follows:

"5. Any of the following occurrences affecting the PROTECTED AREA.

River level is greater than 1004 feet MSL, but less than or equal to 4-1O91007 feet MSL elevation."

The Basis for EAL 5 is also being changed to note that a river level greater than 1007 feet would meet the initiating conditions for the Alert classification, IC HA1, EAL 6.

EAL #5 [NOUE 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 and its associated Basis indicating th+at the flooding plan to protet* the plant ,,,wIil!

be ipmt prior to 1-004.2-feeindicating that the FCS emergency plan will be implemented during expected high river level conditions (i.e., prior to reaching 1004 feet) to protect the plant. A river level greater than 1007 feet would meet the initiating conditions for HA1, EAL 6.

IC HA1, EAL 6:

The ALERT IC HA1, EAL 6 flooding level entry condition is changed to "River level is greater than 1007 feet MSL elevation" as follows:

6. Any of the following occurrences resulting in VISIBLE DAMAGE to plant structures containing equipment necessary for safe shutdown, or has caused damage as evidenced by control room indication of degraded performance of those systems.

• "River level is greater than 001007feet MSL elevation."

The Basis for EAL 6 is also being changed to note that a river level of greater than 1007 feet is based on the elevation at which passive protection is provided at the station due to the fact that vital areas are elevated to that point.

LIC-1 2-0056 Enclosure Page 6 EAL #6 [ALERT Basis]:

EAL #6 covers other site-specific phenomena such as flood and low river level. The river level of greater than 10091007 feet is based on the elevation at which passive protection is provided at the station due to the fact that vital areas are elevated to that point. the installed flood gates w'ill potoct the plant The river level of 973 feet, 9 inches is based on the minimum elevation of the Raw Water Pump suction. These EALs can also be precursors of more serious events.

3.0 TECHNICAL EVALUATION

The Missouri River provides a heat sink for processing and operating heat from safety related components during a design basis accident (DBA) or transient, as well as during normal operation. Thus, two of the principal functions of the Missouri River at FCS are the dissipation of residual heat after reactor shut down and dissipation of residual heat after an accident. At FCS, this is accomplished utilizing the raw water (RW) system and the component cooling water (CCW) System.

Raw Water and Component Cooling Water Systems:

Heat removed by the CCW system is transferred to the RW system by the CCW heat exchangers. The RW system is a once through system operating with screened river water. Redundancy has been provided in the CCW and RW systems to provide for both normal and emergency operation with pumping and heat exchange equipment out of service. Further, the system arrangement permits the raw water to be circulated through portions of the CCW system piping to provide direct cooling of vital engineered safeguards components in the unlikely event of all of the component cooling pumps and heat exchangers being unavailable to fulfill their design function. (Reference 6.11, Section 1.2.8.3)

Four RW pumps are installed in the intake structure pump house to provide screened river water to the CCW heat exchangers. The pump discharge piping is arranged as two headers which are interconnected and valved at the pumps and in the auxiliary building. Each header was designed to accommodate sufficient flow to the CCW heat exchangers to support normal modes of plant operation. System pressures, flows and valve positions are displayed in the control room. Water level instrumentation in the intake structure will alarm in the control room if water from any source should endanger the RW pumps. A majority of the system operational and control functions can be performed from the control room. (Reference 6.14, Section 9.8.2)

Circulating Water (CW) System:

The circulating water for the condenser is taken from the Missouri River, pumped through the condenser tubes, and discharged to the Missouri River. Three CW pumps are provided in the intake structure. During normal operations, two or three CW pumps provide CW to the main condensers. The number of pumps required is dependent on system load and river temperature. Provision is made to control surface

LIC-12-0056 Enclosure Page 7 and frazil ice by recirculating the discharge water and the surface sluice piping. Motor driven traveling screens are installed ahead of the pump suction. The debris and refuse picked up by the screens are removed by water supplied from motor driven spray pumps integral to each screen. (Reference 6.15, Section 10.2.3).

Design Basis Flood - Defined The design basis flood is defined for FCS in engineering analysis (EA)10-032, Revision 1 (Reference 6.3).

The requirement to protect the plant from flooding conditions came from the 70 Draft Design Criteria (GDC), Criterion 2 as stated in the FCS USAR Appendix G (Ref. 6.4)

Those systems and components of reactor facilities which are essential to the prevention of accidents which could affect public health and safety or to mitigation of their consequences shall be designed, fabricated, and erected to performance standards that will enable the facility to withstand, without loss of the capability to protect the public, the additional forces that might be, imposed by natural phenomena such as earthquakes, tornadoes, flooding conditions, winds, ice and other local site effects. The design bases so established shall reflect: (a)

Appropriate consideration for the most severe of these natural phenomena that have been recorded for the site and the surrounding area and (b) an appropriate margin for withstanding forces greater than those recorded to reflect uncertainties about the historicaldata and their suitabilityas a basis for design.

USAR Appendix G, Criterion 2 establishes the design basis function for Class I structures (i.e., structures containing safety related equipment must be designed to withstand external flooding conditions). Criterion 2 also gives guidance, items (a) and (b), on establishing the design bases values that must be used as the controlling parameters to ensure that USAR Appendix G, Criterion 2 is satisfied.

Importantly noted is that the design basis value established as the controlling parameter for the external flooding design basis must be "an elevation." Other parameters that are used to determine/describe the design flood such as flow rate, precipitation, runoff fraction, return period, etc., cannot be controlled by the plant designers and, therefore, cannot be established as the design basis value as defined by 10 CFR 50.2 and NEI 97-04 (Reference 6.5). Parameters other than elevation may be termed as supporting design information or design inputs as determined by NEI 97-04 (Reference 6.5).

OPPD and Gibbs, Hill, Durham and Richardson (GHD&R), the structural designers, with cooperation from the United States Army Corps of Engineers (USACE) established the design basis value for flood elevation using probabilistic methods known as flood frequency analysis (FFA). Table 1 summarizes the information received from the USACE in February of 1967. (Reference 6.3)

LIC-12-0056 Enclosure Page 8 Table 1 - USACE Supplied Flood Elevations.

Flood Frequency Elevation (ft) Application 1% (100 yr.) 1001.3 None 0.1% (1000 yr.) 1004.2 Site grade selection 1952 Actual Flood of 1007 Top of water tight Record foundations The flood of 1952 occurred before all but one of the Missouri River main stem dams were completed (Fort Peck was completed in 1940; see USAR Figure 2.7-1 for a graphic of the Missouri River system (Reference 6.6)). The USACE stated that the 1952 flood should not be repeated because of better controls on the Missouri River (Reference 6.7). The 0.1% probability flood was determined by extrapolating data used to calculate the 1.0% probability flood. The 1.0% probability flood was calculated assuming that all of the Missouri River main stem dams had been in service between 1898 and 1966 and then applying historical high water conditions to the altered watershed. (Reference 6.8)

In a conference held February 15 and 16, 1967, between OPPD and GHD&R, the design flood parameters were established (Reference 6.7). The Memorandum of Conference states, in part:

It is recommended that based on Corps of Engineers' letter dated February 7, 1967, and the Flood Data presented by them that the finished grade site elevation could safely be set at 1004 feet since the 0. 1%

• probability flood is in this range.

However, although the Corps of Engineers have stated that the flood should not be repeated because of better flood controls on the Missouri River, it is prudent to set the plant sill elevation at 1007 feet as this was the high water mark according to local eyewitnesses at the Fort Calhoun site during this 1952 flood.

Therefore, 1007 feet is the design basis value chosen for the controlling parameter (elevation) established as the reference bound required to meet the design basis functional requirement (i.e., the requirement laid out in Draft GDC 2).

It is clear from the context of the statement above and the response to flooding questions provided in PSAR Supplement No. 2 (Reference 6.9) that selection of 1007 feet as the design flood protection elevation was intended to meet both items (a) and (b) of GDC 2.

The FCS PSAR, Supplement No. 2 states, in part:

"All accesses to the primary and secondary plants and the river water intake structure, which houses the fire water pump, are at least 2.8 feet above the 0. 1 %

probability flood peak stage of 1004.2 feet except the railroadaccess to the reactor auxiliary building and truck access to the secondarybuilding. In these locations the access areas are in depressed wells with adjacent floor levels located at least 2.8 feet above the 0. 1% probability flood peak stage of 1004.2 feet; thus limiting any flooding to the railroadtrackage area in the reactorauxiliary building and the truck access area in the secondaryplant. "

LIC-1 2-0056 Enclosure Page 9 Per the statement above, the plant was designed to provide passive protection to an elevation of 1007 feet msl. Passive protection to elevation 1007 feet insl was provided in Class I structures by placing the sill elevations at or above 1007 feet msl and providing water tight foundations below this elevation. Evidence of this design is evident in current plant design drawings in which it can be seen that penetrations into the auxiliary building were placed above 1007 feet msl to preclude the possibility of water entering the structure from floods up to that elevation.

Latest Data on River Level Peaking at FCS The latest data on river level peaking for the Missouri River includes peak conditions recorded during the summer 2011 flood event and the most recent flow frequency evaluation performed by the USACE (published in January 2004). The peak river level for the 2011 flood event was approximately 1006 feet 11 inches msl. This elevation is below the entry point elevation for buildings containing safety related equipment.

Although historic, there is no indication that this event would draw the licensing basis elevation of 1014 feet into question. The 2004 USACE report concluded that the 100-year or 1% flood at Blair, Nebraska, increased from 1007.1 feet msl to 1008.6 feet msl based on statistical analysis of current river level data. The report does not attempt to estimate return frequencies beyond 500 years due to the high degree of error implied by the extrapolation. The 500-year flood based on this report is approximately 1011 feet mnsl which agrees well (within statistical error band) with the 1009-foot value used in 1970 when establishing the design basis for FCS. In addition, comparison of the predicted river elevation of 1008 feet for a river flow of 150,000 cubic feet per second (cfs) to actual elevation of 1006.7 feet msl for a flow of 200,000 cfs indicates that the USACE report overestimates the elevation; thereby confirming the conservative nature of the values used during the original development of the design basis.

During the 2011 Missouri River flood event, all flood barriers required to maintain operability of safety related equipment at FCS were installed or available as required.

There were no challenges to equipment required to maintain safe shutdown capabilities as a result of the 2011 flood event at FCS.

With the installation of flood barriers (flood gates and sandbags) in accordance with approved procedures, all equipment required to achieve and maintain safe shutdown is protected with a river level of 1014 feet msl. Abnormal operating procedure AOP-01 conservatively directs that the plant be shut down if the river level is expected to reach 1004 feet or higher. The latest data on river level had no impact on the design basis or the plant's ability to maintain safe shutdown. There is also an administrative requirement in AOP-01 which directs that CW pumps be secured and isolated if river level is expected to reach 1004 feet msl.

River Stage and Flow There are six dams upstream of the plant site that control the river flow (see USAR Figure 2.7-1, Reference 6.6). These structures are listed in Reference 6.12, Table 2.7-1 in the order from the nearest to FCS (Gavins Point) to the most distant (Fort Peck).

LIC-12-0056 Enclosure Page 10 The USACE has made a preliminary estimate of the maximum probable flood resulting from the runoff from a maximum probable rain storm over the area below the Gavins Point dam. This flood yields a peak discharge of 550,000 cfs at the plant site. The discharge includes an assumed out-flow of 50,000 cfs from the Gavins Point reservoir also caused by the maximum probable rain storm. The flood peak stage at the site is estimated to be approximately 1009.3 feet msl. (Reference 6.12)

The flood resulting from failure of either the Oahe dam or the Fort Randall dam has been estimated by the USACE. The hydrological events resulting in the failure of one of these dams concurrent with the events giving rise to a maximum probable flood described above yields a peak discharge of approximately 1,200,000 cfs at the plant site and a flood elevation of about 1,013 to 1,014 feet msl. (Reference 6.12)

It is estimated that the large flows would take about two days to travel from Gavins Point to FCS. Thus, many hours, and possibly a day's warning would be available before the effects would be felt at the site. Moreover, a watch is maintained by the U.S. Weather Bureau to warn of rising levels in the tributary streams below Gavins Point. Arrangements were made with the U.S. Weather Bureau to warn the plant operating staff of any expected rises in Missouri River level. Rainfall sufficient to cause an appreciable flood would have to be heavy and occur over an extensive area.

Flood Protection Flooding protection for safety related structures other than containment is provided using a three tiered approach. The basis for the three separated flood elevations are discussed below along with protections required for each elevation: Along with the protections discussed below, sandbagging in key areas is used to supplement flood protection strategies.

1,007 Feet Passive protection is provided to a flood elevation of 1,007 feet. Passive protection is accomplished by placing openings to portions of these structures containing safety related equipment above 1,007 feet. Below 1,007 feet, portions of these structures containing safety related equipment are constructed of sealed concrete.

Although the USACE have stated that the 1952 flood should not be repeated because of better flood controls on the Missouri River, it is prudent to set the plant sill elevation at 1,007 feet as this was the high water mark according to local eye-witnesses at the Fort Calhoun site during this 1952 flood.

1,009.3 Feet The USACE "preliminary estimate" of probable maximum flood that might occur as a result of runoff from a probable maximum rainstorm over the area below Gavins Point coupled with an assumed outflow of 50,000 cfs from Gavins Point reservoir is 1,009.3 feet. (Reference 6.12)

LIC-1 2-0056 Enclosure Page 11 Flooding protection against the 1,009.3-foot flood in the auxiliary building is provided by removable flood barriers which extend to 1014 feet. When required, these flood barriers are installed in openings leading to safety related equipment on the 1,007-foot floor elevation.

Flooding protection against the 1,009.3-foot flood in the intake structure is provided by removable flood barriers which extend to at least 1014 feet and intake cell level control maintained by the raw water pumps. When required, these flood barriers are installed in all exterior openings on the operating level of the intake structure. In addition, a flood barrier is installed at the outlet of the screen wash discharge trough at the south end of the traveling screens. The intake cell level will be maintained below 1,007.5 feet by adjusting the exterior sluice gates to severely restrict flow into the cells and then varying the raw water pump output to remove the inlet flow.

1,014 Feet The USACE estimate of the flood level that might result from the failure of Oahe or Fort Randall dams coincident with the probable maximum flood that produces the 1,009.3-foot flood is 1,014 feet.

Flooding protection against the 1,014-foot flood in the auxiliary building is provided by removable flood barriers and sandbagging. When required, these flood barriers are installed in openings leading to safety related equipment on the 1,007-foot and 1,011-foot floor elevations. Sandbagging is required at the 1,013-foot elevation of the equipment hatch room (Room 66).

Flooding protection in the intake structure against the 1,014-foot flood is accomplished in the same manner as it is for the 1,009.3-foot flood. (Reference 6.12, Section 2.7.1.2)

Basis for Plant Shutdown at 1004 Feet The intake structure can be protected from Missouri River floods using removable flood gates on doorways and the screen wash discharge trough. The water level inside the intake cells can be controlled by positioning the exterior sluice gates to restrict the flow into the cells.

The position of the exterior sluice gates must be verified by manual actuation, which required access to the intake structure veranda. Access to the veranda is lost when the east doors to the intake structure are blocked by installing the flood barriers which must be installed prior to a river level of 1004 feet in order to allow egress to the north.

This requires the station to be shutdown prior to 1004 feet. The 36-hour allowance to cold shutdown allows for cool down by steaming to atmosphere, if desired. If the station desires to cool down by steaming to the condenser, shutdown cooling must be initiated prior to 1004 feet so that actions verifying sluice gate position can be completed before access to the veranda is lost. This requires that FCS be shut down and CW pumps be secured prior to closing the gates and installing the flood barriers.

LIC-12-0056 Enclosure Page 12 The auxiliary building can be protected to 1014 feet with the installation of removable flood barriers and sandbagging at the 1013-foot elevation of the equipment hatch room (Room 66).

A continuous watch will be established at 1002 feet msl to provide adequate response time for rising river levels in accordance with the abnormal operating procedure. The FCS emergency plan will be implemented during the high and low river level conditions to protect the plant.

Low River Level The minimum river level is based on the minimum level assumed in the USAR.

The elevation of the CW pump suction bells is 974 feet 1 inch msl and the center line of discharge is 979 feet 0 inches msl. A continuous watch is established at a river level of 980 feet 0 inches per TS 2.16 and AOP-1. (Reference 6.12) At this level, hourly cell level measurements will be taken to ensure satisfactory RW pump submergence. The elevation of RW pump suction bells is 973 feet 9 inches and the required submergence above the bottom of the suction bell is 3 foot 0 inches, or an elevation of 976 feet 9 inches minimum submergence level. For the CW pumps to operate properly, the required submergence above the center line of discharge must be 4 foot 0 inches or an elevation of 983 feet 0 inches msl. (Reference 6.12, Section 2.7.1.2)

The elevation of raw water pump suction bells is 973 feet 9 inches and the required submergence above the bottom of the suction bell is 3 foot 0 inches, or an elevation of 976 feet 9 inches msl. Actual low water levels at Blair, Nebraska (approximately four miles upstream from the plant site) due to icing conditions have been recorded as low as 987.4 feet msl. These conditions are transient in nature and would not jeopardize suction of the raw water pumps. (Reference 6.12, Section 2.7.1.2)

With respect to low river flow at the site, the release from Gavins Point is 12,000'cfs as a normal minimum depending largely on availability of water. Flows during the non-navigation season will range from 12,000 cfs to 18,000 cfs. In years when an extended period of drought has depleted storage reserves, release flows may periodically run as low as 6,000 cfs, this according to the USACE's published annual operating plan. An ice jam formation can temporarily reduce low flows to even lower values but such partial stream blockages rarely occur and several methods have been developed to quickly nullify their effects. (Reference 6.12, Section 2.7.1.2)

The USACE adjusts winter releases from Gavins Point as necessary to accommodate the needs of all Missouri River water users. Normally, the water level is maintained higher than 983.0 feet. Although agreement between OPPD and the USACE to maintain minimum river water levels has not been formalized, the USACE does cooperate with OPPD in these matters and would provide additional flow from upstream dams if such conditions would be impending. The time required for severe ice blockage of the river to occur extends into many hours and the weather conditions which would cause blockage would be evident over a period of a few days. Even

LIC-12-0056 Enclosure Page 13 lower river water levels would not be detrimental to plant safety since the minimum submergence level on the RW pumps is 976 feet 9 inches or more than six feet below the controlled minimum river water level.

At low river levels, debris and/or ice on the traveling screens and/or trash racks can cause significant head loss potentially reducing intake cell levels below the RW pump mean sea level of 976 feet 9 inches. As a precaution, the level of the river and the intake cells is continuously monitored when river level is below 980 feet.

Intake cell levels are also adversely affected by the flows associated with the non-safety related CW pumps since the large flow rates associated with the CW pumps create significant head losses even with relatively clean intake cell conditions.

However, the CW pumps have a much higher msl requirement (983 feet 0 inches) and would become unstable and trip or be manually shut down well before intake cell levels decrease to the RW pump msl. The head loss associated with CW pump flow would then be recovered and intake cell levels would rise. (Reference 6.12, Section 2.7.1.2)

Based on the above, adequate cooling water will be available to meet plant requirements.

10 CFR Part 50.36 Criteria:

10 CFR 50.36(c)(2)(ii) states that "A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria:

(A) Criterion 1 - Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

(B) Criterion 2 - A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

(C) Criterion 3 - A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

(D) Criterion 4 - A structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety."

LIC-1 2-0056 Enclosure Page 14 Reference 6.17, Final Commission Statement on Technical Specifications for Nuclear Power Reactors, dated July 22, 1993, concluded that those existing TS requirements, which do not satisfy the screening criteria specified in regulation 10 CFR 50.36 above, may be deleted from the TS, and the requirements established in licensee-controlled documents, subject to the controls of 10 CFR 50.59. Type A instruments provide the primary information required to permit the control room operator to take specific manually controlled actions, for which no automatic control is provided, and that are required for safety systems to accomplish their safety functions for design basis accident (DBA) events. Category 1 instruments are designed for full qualification redundancy, continuous real-time display, and onsite (standby) power.

NRC-approved NUREG-1432, Standard Technical Specifications, Combustion Engineering Plants, Revision 3 (Reference 6.16), identifies an improved TS that was developed based on the screening criteria in the Commission's Final Policy Statement (Reference 6.17) and subsequently codified in 10 CFR 50.36.

The instrumentation for detecting high river level is not necessary for indicating a significant abnormal degradation of the RCS pressure boundary considered by Criterion 1. This is consistent with the Commission's Final Policy Statement (Reference 6.17) which indicated that the first criterion was intended to assure that the TS controlled those instruments specifically installed to detect reactor coolant leakage but not to include instrumentation to identify the source of actual leakage (e.g., valve position indication).

However, TS LCO 2.16 for high river level does meet the requirements of 10 CFR 50.36(c)(2)(ii)(D) Criterion 4 which states, "a structure, system, or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety." The proposed change would make no physical changes to the SSCs required for high or low river levels. However, due to recent operating experience at FCS, this TS LCO is being revised to model NUREG-0212, Revision 2 (Reference 6.2) to specify maximum and minimum Missouri River levels which must be present at the FCS intake structure to assure safe reactor operation and provide the necessary associated required actions.

River Level Instrumentation River level is the water level as measured at the FCS intake structure by non-safety related loop L-2000. The intake structure is considered part of the power block and is located within a short walking distance from the Control Room. The L-2000 instrumentation will be backed up by the existing river level instrumentation, non-safety related loop L-1 900. Both instrumentation loops are expected to be in service prior to exiting the 2011 refueling outage.

L-2000, which is based upon radar measurement technology, is a recent addition to FCS. Vendor data and operating experience for L-2000 are provided below:

LIC-12-0056 Enclosure Page 15 Accuracy Rosemount 5401 Radar Level Transmitter Range: 115 feet Accuracy: +/- 0.4 inches Repeatability: +/- 0.04 inches Resolution: 0.04 inches Industry Experience The following was excerpted from the engineering change (EC) 35741, Traveling Screen Replacement, modification package:

"EPIX and OER database review for "Rosemount Radar Level Sensors" and variants provided no relevant information to the installation of the equipment under this EC.

Rosemount has indicated that the model 5402 radar probes have been installed at the Oyster Creek nuclear power station. Oyster Creek currently uses the 5400 series radar probes to measu're levels within their spent resin tanks. The probes are set up to measure from 1-12 feet down from the top of the tank using a 3 in.

process cone. Only one instance of concern occurred at Oyster Creek with this model of radar probe. One of the spent resin tank probes failed after 2 years of service. Other than the aforementioned incident, Oyster Creek has indicated the probes work well.

An EPIX database review was conducted for the Rosemount 5401 radar level transmitter and yielded no results.

[OPPD's] North Omaha Station utilizes a non-contacting radar system for measuring river water levels as well as water levels within the Intake Structure.

Systems engineering and maintenance have indicated the radar probes work well in this free air application. Detailed information was gathered on the use of the radar probe for river level measurement. North Omaha Station uses a swinging arm apparatus to place the river probe in service above the water level. The river level probe used in their application uses a 6 GHz transmission signal and a rod antenna. Icing of the river probe has not been an issue. A similar design has been implemented for the Fort Calhoun radar probe, specifically the use of a swing arm apparatus and a 6 GHz radar probe with rod antenna.

DC Cook Station utilizes a radar level measurement system for measuring intake water levels. OPPD has benchmarked the performance of the instrumentation installed at DC Cook. Operating experience from DC Cook indicates the radar system works well for the intake water level measurement application."

Existing river level loop, L-1 900, is based upon bubbler technology where river depth is proportional to measured pressure. The associated instrumentation is being updated to improve loop accuracy.

LIC-12-0056 Enclosure Page 16 L-1900 and L-2000 measurements are independently available on distributed control system (DOS) and Emergency Response Facility Computer System (ERFCS) displays in the Control Room. For control and alarm purposes, L-1900 will automatically be substituted for L-2000 should a failure of L-2000 be detected. The operator will also be able to manually select L-1 900 for alarm and control purposes in lieu of L-2000. An alarm is provided in the event there is a significant difference between river level as measured by L-1 900 and L-2000.

The accuracies and uncertainties of L-2000 and revised L-1900 are similar. These accuracies and uncertainties are documented in FCS calculation FC07868, River Level and Temperature Uncertainty. The uncertainties are calculated using ANSI/ISA-67.04 methods. The uncertainty for both loops is bounded by +/-1 foot. This uncertainty

(+/-1 foot) is applied to the river level alarm setpoints associated with entry conditions to AOP-01 (983 feet and 1000 feet msl) to provide operators sufficient margin to preserve design limit requirements. These alarms will be provided by the DOS. The surveillance test that implements the proposed TS SR for the river level will encompass the river level loop uncertainties.

In addition to L-2000 and L-1 900, manual sounding or indication are available methods for determining river level. Continuous watches will be implemented at high river levels and low river levels, Continuous watches and cross channel checks will reduce instrument measurement uncertainties for the level instrumentation to within three (3) inches.

FCS Technical Specifications The current FCS Technical Specifications do not explicitly state when the TS 2.16 LCO is applicable. The proposed TS change will add the applicability "at all times" which models NUREG-0212, Revision 2 (Reference 6.2), as this LCO will be applicable at all times.

The TS currently requires that the reactor be placed in a COLD SHUTDOWN condition using normal operating procedures to exit the condition (e.g., low river level).

Therefore, by doing so, OPPD is explicitly stating when this TS LCO is applicable, which models NUREG 1432. However, the TS 2.16 LCO does not explicitly state the time allowed to enter COLD SHUTDOWN conditions. This LAR proposes that the plant be in a HOT SHUTDOWN condition when the plant reaches 1004 feet msl and COLD SHUTDOWN within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> following entry into HOT SHUTDOWN for high river level conditions. In addition, this LAR proposes that the reactor shall be placed in HOT SHUTDOWN in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWN within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> for low river level conditions. The allowed outage times are aligned with the existing FOS TS allowed outage times, including TS 2.0.1, General Requirements.

The proposed TS LCO for low river level is 976 feet 9 inches, which is based on the minimum level assumed in the USAR. The minimum river level of 976 feet 9 inches provides adequate suction to the RW pumps for cooling plant components. The minimum elevation of the RW pump suction is 973 feet 9 inches. An intake cell level of 976 feet 9 inches is required for RW pump minimum submergence level. The

LIC-12-0056 Enclosure Page 17 partial loss of this supply is considered highly unlikely. However, provisions for low water levels during winter and spring ice conditions are considered necessary. When river level is low, head loss from debris and/or ice on the traveling screens and/or trash racks could reduce intake cell level such that the required RW pump minimum submergence level is not achieved. This could lead to pump degradation from the formation of vortices at the free water surface. Thus, when the continuous watch requirement is in effect at 980 feet msl, in addition to monitoring the river level to assure no sudden loss of water supply occurs, the level of the intake cells is also monitored.

In addition to the proposed changes to TS LCO 2.16 applicability and required actions, precedent for revising the TS 2.16 LCO requirement for river water level models NUREG-0212, Revision 2, LCO 3.7.6, Flood Protection (Reference 6.2).

Providing a TS SR for measurement of the river water level provides verification that the Missouri River water level is within in its required limits. Measurements will be taken daily to determine if river water level is less than 1004 feet msl and greater than or equal to 976 feet, 9 inches msl. Table 3-5, Item 25 verifies adequate measurements are taken to ensure that facility protective actions will be taken (and power operation will be terminated) in the event of high and/or low river level conditions. The limit of less than 1004 feet msl is based on the maximum elevation at which facility flood control measures provide protection to safety related equipment (i.e., due to restricted access/egress to the intake structure veranda once the flood barriers are installed prior to river level reaching 1004 feet msl). The specified river level SR also ensures sufficient net positive suction head is available for operating the RW pumps.

The surveillance frequency of "Daily" is a reasonable interval and models guidance provided in NUREG-0212, Revision 2 (Reference 6.2, Section 4.7.6). This SR verifies that the Missouri River water level is maintained at a level greater than or equal to 976 feet 9 inches msl. This coincides with the current TS 2.16 requirement for establishing a continuous watch at 980 feet msl.

Emergency Action Level OPPD and Gibbs, Hill, Durham and Richardson (GHDR), the FCS structural designers, with cooperation from the United States Army Corps of Engineers (USACE) attempted to establish the design basis value for flood elevation using probabilistic methods known as flood frequency analysis (FFA). (Reference 6.3)

FFA and probable maximum flood (PMF) are developed fundamentally differently for the same drainage basin. FFA extrapolates historic hydrologic data collected on a river system using standard statistical distributions. The results of FFA are usually reported as an average return period such as "the 100-year flood" (i.e., a flood that has a 1%

chance of occurrence in any one year). The time period over which hydrologic data is available greatly affects the predicted floods and the confidence that the return period is accurate. Predicted flood elevations using the FFA method are: 1% (100-year

LIC-12-0056 Enclosure Page 18 frequency) = 1001.3 feet mean sea level and 0.1% (1000-year frequency) = 1004.2 feet mean sea level.

PMF studies use a more deterministic method to predict flood elevations that do not have a corresponding return period/frequency. PMF studies apply inputs such as probable maximum precipitation (PMP), maximum snow pack, dam failure, etc., to the drainage characteristics of a given basin to determine a hypothetical maximum flood.

The PMF approach was officially endorsed by the NRC in Regulatory Guide 1.59.

This approach for FCS includes the following inputs: probable maximum rainstorm and runoff downstream from Gavins Point, maximum outflow from Gavins Point resulting from a probable maximum rainstorm and runoff upstream from Gavins Point, and sudden failure of the worst case dam (assumed to be Oahe or Fort Randall dam).

This approach yielded that the PMF at FCS from an input of all three factors would be between 1013 and 1014 feet msl.

The current station flood criterion for ALERT classification is 1009 feet msl. This was based on the fact that "permanently installed barriers" were installed to protect to this elevation. Changes in design and protection strategies being implemented at this time remove the reliance on the 1009 feet flood barriers and they are replaced with flood barriers to protect safe shutdown equipment to an elevation of 1014 feet msl. The station's flooding mitigation and protection strategy consists of installation of flood protection doors, gates, and sandbags. These measures are designed to protect the station in the event of rising water from the Missouri River which exceeds 1004 feet msl up to a level of 1014 feet msl.

Passive flooding protection to an elevation of 1007 feet msl was accomplished by placing the openings of structures containing safety related equipment above this elevation. Active strategies are employed by station procedures to provide protection to these facilities (auxiliary building and intake structure) to install removable flood barriers (consisting of flood plates and sandbags) in openings above 1007 feet msl.

These barriers extend to 1014 feet msl. Additionally, flood protection is accomplished within the intake structure by manually controlling intake level suction below 1007.5 feet msl. (Reference 6.12, USAR 2.7, Section 2.7.1)

The EP classification scheme is based on the NRC-endorsed Nuclear Energy Institute (NEI) guidance publication NEI 99-01, Revision 5, Methodology for Development of Emergency Action Levels (Reference 6.19). In this scheme, the definition of the Alert classification is the basis for this change. Alert is defined as follows:

"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 releasesare expected to be limited to small fractions of the EPA PAG exposure levels."

LIC-12-0056 Enclosure Page 19 "Discussion: Rather than discussing the distinguishing features of 'potential degradation'and 'potentialsubstantialdegradation,'a comparative approach would be to determine whether increased monitoring of plant functions is warrantedat the Alert level as a result of safety system degradation. This addresses the operations staff's need for help, independent of whether an actual decrease in plant safety is determined. This increased monitoring can then be used to better determine the actual plant safety state, whether escalation to a higher emergency classification level is warranted, or whether de-escalation or termination of the emergency classification level declaration is warranted. Dose consequences from these events are small fractions of the EPA PAG plume exposure levels."

Through review of NEI 99-01, OPPD personnel concluded that flooding levels which require full implementation of the EP procedures and personnel to protect the vital areas of the station warranted escalation from a NOUE to an ALERT. The elevation at which these actions are required is 1007 feet msl.

Based on the guidance provided in RIS 2005-02 (Reference 6.18), revising the elevation at which time the EP procedures and personnel protect the vital areas of the station from a NOUE to an ALERT is considered a decrease in effectiveness and warrants prior NRC approval.

According to the guidance provided in Reference 6.18, for proposed changes to individual EALs, a decrease in effectiveness will occur in the following cases:

(a) The proposed change to the EAL would potentially cause an under classification (e.g., what was considered an ALERT in the approved emergency plan would now be considered an Unusual Event or not classified at all).

(b) The proposed change to the EAL would potentially cause an over classification (e.g., what was considered a Site Area Emergency in the approved emergency plan would now be considered a General Emergency with potential consequences for public health and safety).

(c) If the proposed change to the EAL is to change an Initiating Condition setpoint (or threshold) without a commensurate change in the regulatory basis for the EAL Initiating Condition setpoint (or threshold).

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.1.1 Regulations Code of Federal Regulations Part 50:

10 CFR 50.36, Technical Specifications: 10 CFR 50.36(c)(2) states, "When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met."

LIC-1 2-0056 Enclosure Page 20 The revised actions continue to meet the requirements of this regulation.

10 CFR 50.36(c)(3) criteria states that "surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." Reliability centered inspections and maintenance overhauls, while important, do not meet the requirements set forth in 10 CFR 50.36 for incorporation into the TS, and are not activities that are generally used to demonstrate component operability. The addition of a river water level surveillance requirement is acceptable as it will ensure the limitation on river levels is monitored to facilitate adequate protective measures in the event of high and/or low river levels.

10 CFR 50.47, Emergency Plans: 10 CFR 50.47(b)(4) states, "A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures." The revised EAL criteria continue to meet the requirements of this regulation.

10 CFR 50.54, Domestic Licensing of Production and Utilization Facilities: 10 CFR 50.54(q) states, "A holder of a nuclear power reactor operating license under this part ... shall follow and maintain in effect emergency plans which meet the requirements in Appendix E of this part.... Proposed changes that decrease the effectiveness of the approved emergency plans may not be implemented without application to and approval by the Commission. The licensee shall submit, as specified in §50.4, a report of each proposed change for approval ..

This LAR for revising the EAL is being submitted in accordance with this regulation.

10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants: The overall objective of this performance-based rule is to ensure that nuclear power plant structures, systems, and components (SSCs) will be maintained so that they will perform their intended function when required. The revised actions continue to meet the requirements of this regulation.

10 CFR Part 50, Appendix E, Emergency Planningand Preparednessfor Production and Utilization Facilities,Section IV.B states, "emergency plans are to include EALs, which are to be used as criteria for determining the need for notification and participation of State and local agencies, the NRC and other Federal agencies. ...." The revised actions continue to meet the requirements of this regulation.

LIC-12-0056 Enclosure Page 21 General Design Criteria:

FCS Unit No. 1 was licensed for construction prior to May 21, 1971, and is committed to the draft General Design Criteria (GDC) published for comment in the Federal Register on July 11, 1967 (32 FR 10213) in lieu of 10 CFR 50, Appendix A. Appendix G of the FCS Updated Safety Analysis Report (USAR) shows that draft GDC 2 and 12 are most applicable to the proposed amendment. It should be noted that draft GDC 12 precedes the requirements of NUREG-0578 and NUREG-0737.

CRITERION 2 - PERFORMANCE STANDARDS Those systems and components of reactor facilities which are essential to the prevention of accidents which could affect public health and safety or to mitigation of their consequences shall be designed, fabricated,and erected to performance standards that will enable the facility to withstand, without loss of the capability to protect the public, the additional forces that might be imposed by natural phenomena such as earthquakes, tornadoes, flooding conditions, winds, ice and other local site effects. The design bases so established shall reflect: (a)

Appropriate consideration for the most severe of these natural phenomena that have been recorded for the site and the surrounding area and (b) an appropriatemargin for withstanding forces greater than those recorded to reflect uncertainties about the historical data and their suitabilityas a basis for design.

This criterion is met. The systems and components of the Fort Calhoun Station, Unit No. 1 reactor facility that are essential to the prevention or mitigation of accidents that could affect public health and safety are designed, fabricated, and erected to withstand without loss of capability to protect the public, the additional forces that might be imposed by natural phenomena such as earthquakes, tornadoes, floods, winds, ice and other local site effects.

The containment will be designed for simultaneous stresses produced by the dead load, by 60 psig internal pressure at the associated design temperature, and by the application of forces resulting from an earthquake whose ground motion is 0.08g horizontally and 0.053g vertically. Further, the containment structure will be designed to withstand a sustained wind velocity of 90 mph in combination with the dead load and design internal pressure and temperature conditions. The wind load is based on the highest velocity wind at the site location for 100-year period or recurrence: 90 mph base wind at 30 feet above ground level. Other Class I structures will be designed similarly except that no internal pressure loading is applicable. Class I systems will be designed for their normal operating loads acting concurrently with the earthquake describedabove.

LIC-12-0056 Enclosure Page 22 The containment structure is predicted to withstand without loss of function the simultaneous stresses produced by the dead load, by 75 psig internalpressure and temperatureassociatedwith this pressure and by an earthquake whose ground motion is 0. 10 horizontally and 0.07 vertically.

The containment structure is predicted to withstand without loss of function 125% of the force correspondingto a 90 mph wind impinging on the building concurrently with the stresses associatedwith the dead load and 75 psig internalpressure.

With no earthquake or wind acting, the structure is predicted to withstand 90 psig internalpressure without loss of function.

Under each of these conditions, stresses in the structuralmembers will not exceed 0. 95 yield.

The facility is designed so that the plant can be safely shutdown and maintained in a safe shutdown condition during a tornado. Design considerations associated with tornadoes are further explained in Section 5.4.7 of the USAR.

Floodingof Fort Calhoun Station, Unit No. 1 is consideredhighly unlikely.

Furtherinformation is available in USAR Section 2.7.1.2.

Plant openings into functional areas are at 1007 feet msl or higher whereas the 0.1% peak flood stage is 1004.2 feet msl. (Reference 6.12, Section 2.7.1.2) The proposed LAR provides for revision of the river level elevation for entry conditions into the LCO to less than 1004 feet msl, addition of a river level surveillance requirement, as well as provides for changes to the EP classification EAL entry criteria for high river level at 1007 feet msl. No physical changes are being made to the plant or the RW, CW or CCW systems as a result of this LAR. This criterion will continue to be met.

CRITERION 12 - INSTRUMENTATION AND CONTROL SYSTEMS Instrumentation and controls shall be provided as required to monitor and maintain variables within prescribedoperatingranges.

This criterion is met. Instrumentation is provided for continuous measurement of all significant process variables. Controls are provided for the purpose of maintainingthese variables within the limits prescribed for safe operation. The instrumentationconforms to applicable Institute of Electricaland Electronics Engineers (IEEE) standards.

LIC-1 2-0056 Enclosure Page 23 The principalprocess variables monitored include neutron level (reactor power); reactor coolant temperature, flow, and pressure; pressurizer liquid level; and steam generator level. In addition, instrumentation is provided for continuous automatic monitoring of radiation level. The instrumentation and control systems are described in detail in USAR Section 7.

The proposed LAR provides for revision of the river level elevation for entry conditions into the LCO, addition of a river level surveillance requirement, as well as provides for changes to the EP classification EAL entry criteria for high river level. No physical changes are being made to the plant or the RW, CW or CCW systems as a result of this LAR. This criterion will continue to be met.

4.1.2 Design Basis There are no USAR accident analyses which are impacted by the revision to the river level at which the reactor will be shut down because USAR Chapter 14 accident analyses assume availability of the Missouri River water (heat sink) based on the required availability of RW pumps.

The design basis flood elevation identified in the USAR is 1014 feet msl NGVD 1929 and that basis is not changed as a result of this TS change or EAL entry condition.

4.1.3 Approved Methodologies There are no new specific approved methodologies associated with this proposed LAR.

4.1.4 Analysis No new analyses were performed or needed in support of this proposed LAR.

4.2 Precedent As noted in Section 3.0 above, precedent for revising the TS LCOs and SRs for river level model NUREG-0212, Revision 2; however, no plant-specific precedence is cited for this LAR. Also, as noted in Section 3.0 above, precedent for revising the EP classification EAL entry criteria for high river level is consistent with the definition section of NEI 99-01, Revision 5; however, no plant-specific precedence is cited for this LAR.

4.3 Significant Hazards Consideration The proposed change modifies Technical Specification (TS) 2.16, River Level, limiting condition for operation (LCO) for high and low river level conditions; and adds surveillance requirement (SR) 3.2, Equipment and Sampling Tests, Table 3-5, Minimum Frequencies for Equipment Tests, Item 25, to allow the provision for the Missouri River water level measurement. These proposed changes

LIC-12-0056 Enclosure Page 24 model NUREG-0212, Standard Technical Specifications for Combustion Engineering Pressurized Water Reactors, Revision 2. This license amendment request (LAR) also provides changes to the emergency plan (EP) classification emergency action level (EAL) entry criteria for high river level. This change would affect the Bases for the Alert and the notice of unusual event (NOUE) classifications. These EAL changes are aligned with the Definitions section of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels, Revision 5.

In addition, administrative changes are being made to SR Table 3-5, Items 17 through 24, in that they are being reformatted for tabular column consistency to provide appropriate space for the text and column header.

The Omaha Public Power District (OPPD) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No.

The proposed changes would revise the river level limiting condition for operation (LCO) and surveillance requirement (SR) to the Fort Calhoun Station (FCS) Technical Specifications (TS) and the emergency plan (EP) emergency action level (EAL) entry condition. The proposed TS and EAL changes do not alter the physical design of the intake structure or any other plant structure, system or component (SSC) at FCS. As such, the change does not increase the probability of an accident.

In addition to the previous method of detecting river level (bubblers), radar sounding units that will give a more accurate indication of river level are being added for providing river level. The river level bubblers currently provide indications for EAL classifications, specifically initiating conditions (ICs) HU1 and HAl. Using the radar sounding units for river level measurements increases the reliability and accuracy of the indications for classifying these events. Also, the operators will have river level indication available in the control room.

The proposed TS changes for river level model NUREG-0212, Standard Technical Specifications for Combustion Engineering Pressurized Water Reactors, Revision 2. The proposed changes to the EAL conform to the NRC's regulatory guidance regarding the content of emergency plans as identified in NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, and Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels, Revision 5, dated February 2008.

LIC-1 2-0056 Enclosure Page 25 Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

The proposed TS and EAL changes do not alter the physical design, safety limits, or safety analysis assumptions associated with the operation of the plant. Hence, the proposed changes do not introduce any new accident initiators, nor do they reduce or adversely affect the capabilities of any plant structure or system in the performance of their safety function.

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

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

Response: No.

The proposed TS LCO requirements ensure there is adequate river level present to assure safe reactor operation and are necessary to ensure safety systems accomplish their safety function for design basis accident events.

Adding an additional (SR) to the FCS TS for taking river level measurements on a daily frequency will not adversely impact any margin of safety. These proposed TS changes for the river level requirements model those provided in NUREG-0212, Revision 2.

The proposed EAL changes ensure there is adequate protection provided for the health and safety of the public and the employees of OPPD. These proposed changes will result in classification of the ALERT level at an earlier (lower) flood level than in the original EAL.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

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

LIC-1 2-0056 Enclosure Page 26 4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

6.1 Letter from NRC (Document Control Desk) to OPPD (D. J. Bannister), "Fort Calhoun Station, Unit No.1- Conversion of Emergency Action Levels Based on Nuclear Energy Institute (NEI) 99-01, "Methodology for Development of Emergency Action Levels (TAC NO. MD5431)," dated October 3, 2008 (NRC 0094) (ML082670196) 6.2 NUREG-0212, "Standard Technical Specifications for Combustion Engineering Pressurized Water Reactors," Revision 2, issued Fall 1980 6.3 Engineering Analysis EA10-032, External Flooding Design Basis, Revision 1, dated February 16, 2011 (EC 51632) 6.4 Updated Safety Analysis Report (USAR) Appendix G, Responses to 70 Criteria, Revision 21, December 1, 2011 6.5 NEI 97-04, Revised Appendix B, Guidance and Examples for Identifying 10 CFR 50.2, Design Basis, November 2000 6.6 USAR Figure 2.7-1, Upper Missouri River Basin, Revision 0 (File No. 36047) 6.7 Memorandum of Conference, Among OPPD, GHD&R, 2/15/1967 & 2/16/67 (Reference 3.3.5 of EA10-032, External Flooding Design Basis, Revision 1, dated February 16, 2011, Appendix D)

LIC-12-0056 Enclosure Page 27

6.0 REFERENCES

(continued) 6.8 Memorandum of Meeting, Among OPPD, USACE and GHD&R, 12/28/1966 (Reference 3.3.1 of EA10-032, External Flooding Design Basis, Revision 1, dated February 16, 2011, Appendix D) 6.9 Ft. Calhoun Facility Description and Safety Analysis Report (PSAR) Supplement No. 2, dated September 18, 1967 (Reference 3.3.20 of EA10-032, External Flooding Design Basis, Revision 1, dated February 16, 2011, Appendix D, 3.3.20) 6.10 Abnormal Operating Procedure, AOP-01, Acts of Nature, Revision 30 6.11 USAR Section 1.2, Summary and Plant Description, Component Cooling and Raw Water Systems, Revision 36, dated April 15, 2011 6.12 USAR Section 2.7, Site and Environs, Hydrology, Revision 11, dated April 29, 2011 6.13 USAR Section 9.7, Auxiliary Systems, Component Cooling Water System, Revision 15, dated July 31, 2008 6.14 USAR Section 9.8, Raw Water System, Revision 29, dated August 23, 2011 6.15 USAR Section 10.2, Steam and Power Conversion Systems, System Design and Operation, Revision 10, dated July 18, 2011 6.16 NUREG-1432, Standard Technical Specifications, Combustion Engineering Plants, Revision 3, June 2004 6.17 NRC Final Commission Statement on Technical Specifications for Nuclear Power Reactors, dated July 22, 1993 6.18 Regulatory Issue Summary 2005-02, Revision 1, "Clarifying the Process for Making Emergency Plan Changes," dated April 19, 2011 (ML100340545) 6.19 NEI 99-01, "Methodology for Development of Emergency Action Levels,"

Revision 5, dated February 2008 (ML080450149) 6.20 SECY-1 1-0053, "Final Rule: Enhancements to Emergency Preparedness Regulations (10 CFR Part 50 and 10 CFR Part 52) (RIN-3150-AI10)," dated April 8, 2011 6.21 Letter from OPPD (D. J. Bannister) to NRC (Document Control Desk), "Retraction of License Amendment Request (LAR) 10-06," dated January 4, 2012 (LIC 0127) 6.22 Letter from NRC (J. A. Clark) to OPPD (D. J. Bannister), "Fort Calhoun -NRC Integrated Inspection Report 05000285/2010003," dated July 26, 2010 (NRC 0060) (ML102080231)

LIC-1 2-0056 Enclosure, Attachment 1 Page 1 Technical Specifications (TS) and Information Only Bases Pages Markups

[Note: The pages are provided in numerical order]

TS 2.16 - Page 1 (includes TS 2.16 Bases - Information only)

TS 2.16 - Page 2 (TS 2.16 Bases - Information only)

TS 3.2 Basis - Page 5 (Information only)

TS 3.2 - Pages 14 and 15 Total Attached Pages - 5

[Word-processormark-ups using "redline/strikeout"feature for "new text/deleted text," respectively.]

TECHNICAL SPECIFICATIONS 2.0 LIMITING CONDITIONS FOR OPERATION 2.16 River Level Applicability At all times. Applied to Mismsourfi River level as m.. ur.d.at the nt..truct at the Fot*CGahoun Objective To specify maximum and minimum Missouri River levels as measured at the intake structure which must be present to assure safe reactor operation.

1)e Iater tho f l Missouri Ro cte pooeet plac! wina leeladgeter (2)S it1166catGictiR"BA theMissouri River level leslss than 976 9feet A ho reactor l lnchesaceld na ciOd shn ondit*i ng no COLD proedrs Atrir lehelsfoilossn ntha 08 in cotinuus atch will bmanindto assur no8 foota sudenSGG loss1 of wtrspl occurs.

Specification The water level of the Missouri River shall remain less than 1004 feet mean sea level and greater than or equal to 976 feet 9 inches mean sea level as measured at the intake structure.

Reauired Actions (1) W~hen the Missouri River level reaches elevation 1004 feet mean sea level, the reactor shall be in a HOT SHUTDOWN condition and. in COLD SHUTDOWN within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> following entry into HOT SHUTDOWN; and (2) Ifthe Missouri River level is less than 976 feet 9 inches mean sea level, the reactor shall be placed in HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWN within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />; and, (3) At Missouri River levels less than 980 feet or greater than 1002 feet mean sea level, a continuous watch will be maintained to monitor river levels to assure no sudden loss of water supply occurs on low river level and provide adequate response time for rising river levels.

Basis At the Fort Calhoun Station (FCS) site, the probable maximum flood that might occur as a result of runoff from a probable maximum rainstorm over the area below the Gavins Point dam coupled with an assumed outflow of 50,000 cubic feet per second from Gavins Point reservoir is 1009.3 feet. In the unlikely event that the Oahe or Fort Randall dams fail at tpat time, the Corps of Engineers has estimated that the flood level could be as high as 1014 feet'".

The intake structure can be protected from these Missouri River floods using removable flood gates on doorways and the screen wash discharge trough. The water level inside the intake cells can be controlled by positioning the exterior sluice gates to restrict the flow into the cells.

The position of the exterior sluice gates must be verified by manual actuation, which requires access to the intake structure veranda. Access to the veranda is lost when the east doors to the intake structure are blocked by installing the flood barriers which must be installed prior to a river level of 1004 feet in order to allow egress to the north. This requires the station to be shutdown prior to 1004 feet. The 36-hour allowance to cold shutdown following hot shutdown entry allows for cool down by steaming to atmosphere, if desired. Ifthe station desires to cool down by steaming to the condenser, shutdown cooling must be initiated prior to 1004 feet so that actions verifying sluice gate position can be completed betor access to the veranda is lost. A continuous watch will be established at 1002 feet msl to provide adequate response time for rising river levels in accordance with the abnormal operating procedure. The FCS emergency plan will be implemented during these hi h and low river level conditions to protect the plant. The auxiliary building can be protected to inte f. P. .t" 1014 feet .eqU'.es with the installation of (Room 66).flood barriers and sandbagging 2.16 removable at he 1013 foot elevation of the equipment hatch room

- Page 1 Amendment No., TSBC-TSBC-07-002-0, TSBC-1 0-001-0, TSBC-1 0-003-0

TECHNICAL SPECIFICATIONS LIMITING CONDITIONS FOR OPERATION 2.16 River Level (Continued)

Basis (Continued)

The minimum river level of 976 feet 9 inches provides adequate suction to the raw water (RW) pumps for cooling plant components. The minimum elevation of the RW pump suction is 973 feet 9 inches. An intake cell level of 976 feet 9 inches is required for RW pump minimum submergence level (MSL)(2). The partial loss of this supply is considered highly unlikely.

However, provisions for low water levels during winter and spring ice conditions are considered necessary. When river level is low, head loss from debris and/or ice on the traveling screens and/or trash racks could reduce intake cell levels such that the required RW pump MSL is not achieved. This could lead to pump degradation from the formation of vortices at the free water surface. Thus, when the continuous watch requirement is in effect, in addition to monitoring river level to assure no sudden loss of water supply occurs, the level of the intake cells is monitored.

Intake cell levels are also adversely affected by the flows associated with the non-safety related circulating water (CW) pumps since the large flow rates associated with the CW pumps create significant head losses even with relatively clean intake cell conditions.

However, the CW pumps have a much higher MSL requirement (983 feet 0 inches) and would become unstable and trip or be manually shutdown well before intake cell levels decrease to the RW pump MSL. The head loss associated with CW pump flow would then be recovered and intake cell levels would rise.

References (1) USAR, Section 2.7.1.2 (2) USAR, Section 9.8 2.16 - Page 2 Amendment No.

TSBC-TSBC-07-002-0

TECHNICAL SPECIFICATIONS 3.0 SURVEILLANCE REQUIREMENTS 3.2 Equipment and Sampling Tests (continued)

Table 3-5, Item 8b verifies that primary to secondary LEAKAGE is less or equal to 150 gallons per day through any one SG. Satisfying the primary to secondary LEAKAGE limit ensures that the operational LEAKAGE performance criterion in the Steam Generator Program is met. Ifthis surveillance requirement is not met, compliance with LCO 3.17, "Steam Generator Tube Integrity," should be evaluated. The 150 gallons per day limit is measured at room temperature as described in Reference 5. The operational LEAKAGE rate limit applies to LEAKAGE through any one SG. If it is not practical to assign the LEAKAGE to an individual SG, all the primary to secondary LEAKAGE should be conservatively assumed to be from one SG.

The Surveillance is modified by a Note which states that the Surveillance is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation. For RCS primary to secondary LEAKAGE determination, steady state is defined as stable RCS pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows.

The Surveillance Frequency of daily is a reasonable interval to trend primary to secondary LEAKAGE and recognizes the importance of early leakage detection in the prevention of accidents. The primary to secondary LEAKAGE is determined using continuous process radiation monitors or radiochemical grab sampling in accordance with the EPRI guidelines (Ref. 5).

Table 3-5, Item 25 verifies adequate measurements are taken to ensure that facility protective actions will be taken (and power operation will be terminated) in the event of high and/or low river level conditions. The high river level limit of less than 1004 feet mean sea level is based on the maximum elevation at which facility flood control measures provide protection to safety related equipment (i.e., due to restricted access/egress to the intake structure veranda once the flood barriers are installed prior to river level reaching 1004 feet msl). A continuous watch will be established at 1002 feet mean sea level to provide adequate response time for rising river levels in accordance with the abnormal operating procedure. The river level surveillance requirement specified also ensures sufficient net positive suction head is available for operating the RW pumps. The minimum river level of 976 feet 9 inches provides adequate suction to the RW pumps for cooling plant components.

The surveillance frequency of "Daily' is a reasonable interval and models guidance provided in NUREG-0212, Revision 2, "Standard Technical Specifications for Combustion Engineering Pressurized Water Reactors," Secfion 4.7.6. This surveillance requirement verifies that the Missouri River water level is maintained at a level greater than or equal to 976 feet 9 inches mean sea level. A continuous watch is established to monitor the river level when the river level reaches 980 feet mean sea level to assure no sudden loss of water supply occurs.

References

1) USAR, Section 9.10

2) ASTM D4057, ASTM D975, ASTM D4176, ASTM D2622, ASTM D287, ASTM 6217, ASTM D2709

3) ASTM D975, Table 1

4) Regulatory Guide 1.137

5) EPRI, "Pressurized Water Reactor Primary-to-Secondary Leak Guidelines."

3.2 - Page 5 Amendment No. 22,246, 257 TSBC-TSBC-09-003-0

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS USAR Section Test Frequency Refwence

17. DELETED

18. Shutdown Cooling 1. Verify required shutdown cooling loops are S (when shutdown cooling is OPERABLE and one shutdown cooling loop is IN required by TS 2.8).

OPERATION.

2. Verify correct breaker alignment and indicated W (when shutdown cooling is power is available to the required shutdown cooling required by TS 2.8).

pump that is not IN OPERATION.

3.2 - Page 14 Amendment No. 138,160,188, 246,250, 24-7

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS USAR Section Test Frequency Reference

19. Refueling Water Level Verify refueling water level is > 23 ft. above Prior to commencing, and daily during the top of the reactor vessel flange. CORE ALTERATIONS and/or REFUELING OPERATIONS inside containment.

20. Spent Fuel Pool Level Verify spent fuel pool water level is > 23 ft. Prior to commencing, and weekly during above the top of irradiated fuel assemblies seated REFUELING OPERATIONS in the spent in the storage racks. fuel pool.

21. Containment Penetrations Verify each required containment penetration is Prior to commencing, and weekly during in the required status. CORE ALTERATIONS and/or REFUELING OPERATIONS in containment.

22. Spent Fuel Assembly Verify by administrative means that initial Prior to storing the fuel assembly in Storage enrichment and burnup of the fuel assembly is in Region 2 (including peripheral cells).

accordance with Figure 2-10.

23. P-T Limit Curve Verify RCS Pressure, RCS temperature, and This test is only required during RCS RCS heatup and cooldown rates are within heatup and cooldown operations and RCS the limits specified by the P-T limit Figure(s) inservice leak and hydrostatic testing.

shown in the PTLR. While these operations are occurring, this test shall be performed every 30 minutes.

24. Spent Fuel Cask Loading Verify by administrative means that initial Prior to placing the fuel assembly in enrichment and burnup of the fuel assembly a spent fuel cask in the spent fuel pool.

is in accordance with Figure 2-11.

25. River Level Verify water level is within limits by measurement D 9.8 at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, when the water level is less than 1004 feet and greater than or equal to 976 feet 9 inches above mean sea level.

3.2 - Page 15 Amendment No. 188, 221, 239,246,247

LIC-1 2-0056 Enclosure, Attachment 2 Page 1 Retyped ("Clean")

Technical Specifications and Information Only Bases Pages

[Note: The pages are provided in numerical order]

TS 2.16 - Page 1 TS Bases 2.16 - Pages 1 and 2 (Information only)

TS Basis 3.2 - Page 5 (Information only)

TS 3.2 - Pages 14 and 15 Total Pages - 5

TECHNICAL SPECIFICATIONS 2.0 LIMITING CONDITIONS FOR OPERATION 2.16 River Level Applicability At all times.

Obiective To specify maximum and minimum Missouri River levels as measured at the intake structure which must be present to assure safe reactor operation.

Specification The water level of the Missouri River shall remain less than 1004 feet mean sea level and greater than or equal to 976 feet 9 inches mean sea level as measured at the intake structure.

Required Actions (1) When the Missouri River level reaches elevation 1004 feet mean sea level, the reactor shall be in a HOT SHUTDOWN condition and in COLD SHUTDOWN within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> following entry into HOT SHUTDOWN; and (2) Ifthe Missouri River level is less than 976 feet 9 inches mean sea level, the reactor shall be placed in HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWN within the following 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />; and, (3) At Missouri River levels less than 980 feet or greater than 1002 feet mean sea level, a continuous watch will be maintained to monitor river levels to assure no sudden loss of water supply occurs on low river level and provide adequate response time for rising river levels.

Basis At the Fort Calhoun Station (FCS) site, the probable maximum flood that might occur as a result of runoff from a probable maximum rainstorm over the area below the Gavins Point dam coupled with an assumed outflow of 50,000 cubic feet per second from Gavins Point reservoir is 1009.3 feet. In the unlikely event that the Oahe or Fort Randall dams fail athat time, the Corps of Engineers has estimated that the flood level could be as high as 1014 feet .

The intake structure can be protected from these Missouri River floods using removable flood gates on doorways and the screen wash discharge trough. The water level inside the intake cells can be controlled by positioning the exterior sluice gates to restrict the flow into the cells. The position of the exterior sluice gates must be verified by manual actuation, which requires access to the intake structure veranda. Access to the veranda is lost when the east doors to the intake structure are blocked by installing the flood barriers which must be installed prior to a river level of 1004 feet in order to allow egress to the north. This requires the station to be shutdown prior to 1004 feet. The 36-hour allowance to cold shutdown following hot shutdown entry allows for cool down by steaming to atmosphere, if desired. Ifthe station desires to cool down by steaming to the condenser, shutdown cooling must be initiated prior to 1004 feet so that actions verifying sluice gate position can be completed before access to the veranda is lost. A continuous watch will be established at 1002 feet msl to provide adequate response time for rising river levels in accordance with the abnormal operating procedure. The FCS emergency plan will be implemented during these high and low river level conditions to protect the plant. The auxiliary building can be protected to 1014 feet with the installation of removable flood barriers and sandbagging at the 1013 foot elevation of the equipment hatch room (Room 66).

2.16 - Page 1 Amendment No.

TSBC-TSBC-07-002-0 TSBC-10-001-0 TSBC-1 0-003-0

TECHNICAL SPECIFICATIONS LIMITING CONDITIONS FOR OPERATION 2.16 River Level (Continued)

Basis (Continued)

The minimum river level of 976 feet 9 inches provides adequate suction to the raw water (RW) pumps for cooling plant components. The minimum elevation of the RW pump suction is 973 feet 9 inches. An intake cell level of 976 feet 9 inches is required for RW pump minimum submergence level (MSL)(2). The partial loss of this supply is considered highly unlikely.

However, provisions for low water levels during winter and spring ice conditions are considered necessary. When river level is low, head loss from debris and/or ice on the traveling screens and/or trash racks could reduce intake cell levels such that the required RW pump MSL is not achieved. This could lead to pump degradation from the formation of vortices at the free water surface. Thus, when the continuous watch requirement is in effect, in addition to monitoring river level to assure no sudden loss of water supply occurs, the level of the intake cells is monitored. I Intake cell levels are also adversely affected by the flows associated with the non-safety related circulating water (CW) pumps since the large flow rates associated with the CW pumps create significant head losses even with relatively clean intake cell conditions.

However, the CW pumps have a much higher MSL requirement (983 feet 0 inches) and would become unstable and trip or be manually shutdown well before intake cell levels decrease to the RW pump MSL. The head loss associated with CW pump flow would then be recovered and intake cell levels would rise.

References (1) USAR, Section 2.7.1.2 (2) USAR, Section 9.8 2.16 - Page 2 Amendment No.

TSBC-TSBC-07-002-0

TECHNICAL SPECIFICATIONS 3.0 SURVEILLANCE REQUIREMENTS 3.2 Equipment and Sampling Tests (continued)

Table 3-5, Item 8b verifies that primary to secondary LEAKAGE is less or equal to 150 gallons per day through any one SG. Satisfying the primary to secondary LEAKAGE limit ensures that the operational LEAKAGE performance criterion in the Steam Generator Program is met. If this surveillance requirement is not met, compliance with LCO 3.17, "Steam Generator Tube Integrity," should be evaluated. The 150 gallons per day limit is measured at room temperature as described in Reference 5. The operational LEAKAGE rate limit applies to LEAKAGE through any one SG. If it is not practical to assign the LEAKAGE to an individual SG, all the primary to secondary LEAKAGE should be conservatively assumed to be from one SG.

The Surveillance is modified by a Note which states that the Surveillance is not required to be performed until 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after establishment of steady state operation. For RCS primary to secondary LEAKAGE determination, steady state is defined as stable RCS pressure, temperature, power level, pressurizer and makeup tank levels, makeup and letdown, and RCP seal injection and return flows.

The Surveillance Frequency of daily is a reasonable interval to trend primary to secondary LEAKAGE and recognizes the importance of early leakage detection in the prevention of accidents. The primary to secondary LEAKAGE is determined using continuous process radiation monitors or radiochemical grab sampling in accordance with the EPRI guidelines (Ref. 5).

Table 3-5, Item 25 verifies adequate measurements are taken to ensure that facility protective actions will be taken (and power operation will be terminated) in the event of high and/or low river level conditions. The high river level limit of less than 1004 feet mean sea level is based on the maximum elevation at which facility flood control measures provide protection to safety related equipment (i.e., due to restricted access/egress to the intake structure veranda once the flood barriers are installed prior to river level reaching 1004 feet msl). A continuous watch will be established at 1002 feet mean sea level to provide adequate response time for rising river levels in accordance with the abnormal operating procedure. The river level surveillance requirement specified also ensures sufficient net positive suction head is available for operating the RW pumps. The minimum river level of 976 feet 9 inches provides adequate suction to the RW pumps for cooling plant components. The surveillance frequency of "Daily" is a reasonable interval and models guidance provided in NUREG-0212, Revision 2, "Standard Technical Specifications for Combustion Engineering Pressurized Water Reactors," Section 4.7.6. This surveillance requirement verifies that the Missouri River water level is maintained at a level greater than or equal to 976 feet 9 inches mean sea level. A continuous watch is established to monitor the river level when the river level reaches 980 feet mean sea level to assure no sudden loss of water supply occurs.

References

1) USAR, Section 9.10

2) ASTM D4057, ASTM D975, ASTM D4176, ASTM D2622, ASTM D287, ASTM 6217, ASTM D2709

3) ASTM D975, Table 1

4) Regulatory Guide 1.137

5) EPRI, "Pressurized Water Reactor Primary-to-Secondary Leak Guidelines."

3.2 - Page 5 Amendment No. 2-2-246, 257 TSBC-TSBC-09-003-0

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS USAR Section Test Frequency Reference

17. DELETED

18. Shutdown Cooling 1. Verify required shutdown cooling loops are S (when shutdown cooling is OPERABLE and one shutdown cooling loop is IN required by TS 2.8).

OPERATION.

2. Verify correct breaker alignment and indicated W (when shutdown cooling is power is available to the required shutdown cooling required by TS 2.8).

pump that is not IN OPERATION.

3.2 - Page 14 Amendment No. 138,169,188, 246,250, 2--W

TECHNICAL SPECIFICATIONS TABLE 3-5 MINIMUM FREQUENCIES FOR EQUIPMENT TESTS USAR Section Test Frequency Reference

19. Refueling Water Level Verify refueling water level is > 23 ft. above Prior to commencing, and daily during the top of the reactor vessel flange. CORE ALTERATIONS and/or REFUELING OPERATIONS inside containment.

20. Spent Fuel Pool Level Verify spent fuel pool water level is > 23 ft. Prior to commencing, and weekly during above the top of irradiated fuel assemblies seated REFUELING OPERATIONS in the spent in the storage racks. fuel pool.

21. Containment Penetrations Verify each required containment penetration is Prior to commencing, and weekly during in the required status. CORE ALTERATIONS and/or REFUELING OPERATIONS in containment.

22. Spent Fuel Assembly Verify by administrative means that initial Prior to storing the fuel assembly in Storage enrichment and burnup of the fuel assembly is in Region 2 (including peripheral cells).

accordance with Figure 2-10.

23. P-T Limit Curve Verify RCS Pressure, RCS temperature, and This test is only required during RCS RCS heatup and cooldown rates are within heatup and cooldown operations and RCS the limits specified by the P-T limit Figure(s) inservice leak and hydrostatic testing.

shown in the PTLR. While these operations are occurring, this test shall be performed every 30 minutes.

24. Spent Fuel Cask Loading Verify by administrative means that initial Prior to placing the fuel assembly in enrichment and burnup of the fuel assembly a spent fuel cask in the spent fuel pool.

is in accordance with Figure 2-11.

25. River Level Verify water level is within limits by measurement D 9.8 at least once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, when the water level is less than 1004 feet and greater than or equal to 976 feet 9 inches above mean sea level.

3.2 -Page 15 Amendment No. 188, 221, 239,246,2 LIC-1 2-0056 Enclosure, Attachment 3 Page 1 Emergency Action Level (EAL)

TBD-EPIP-OSC-1 H Recognition Category H - Hazards and Other Conditions Affecting Plant Safety Mark-up Pages

[Word-processormark-ups using "redline/strikeout"feature for "newtext/deleted text" respectively.]

Page 1 of 28 I TBD-EPIP-OSC-1 H Recognition Category H - Hazards and Other Conditions Affecting Plant Safety Rev 1 Safety Classification: Usage Level:

li Non-Safety I I1 Reference Change No.: EG 4677--EC 51690 Reason for Change: Based classi*fiatoon schemo on NEI,99,01,4

-.... ... . ci.. L..els. Enti." rc-'rite, no

• c',,ioin lines pcr FCSG-8. Revise HA1 EAL6 and basis for HAI to change Initiating Condition for high river level from 1009 feet MSL elevation to 1007 feet MSL elevation. The current station flood criterion for ALERT classification is being changed from 1009 feet to 1014 feet due to changes in design and protection strategies. The station is passively protected to 1007 feet because vital areas are elevated to this point. Therefore; it is concluded that changing the EAL criteria from 1009 foot to 1007 foot would be appropriate. HU1 EAL 5 is also being revised to bound the NOUE as a result of this change.

-Preparer: R Hank .

Sponsor: Simmos-A. Berck Editorial Correction (a) EC 46843 All pages (08-06-09)

Issued: 05-14-09 3:00.pm Fort Calhoun Station

TBD-EPIP-OSC-1H Reference Use Page 2 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety Recognition Category H - Hazards and Other Conditions Affecting Plant Safety INITIATING CONDITION MATRIX NOUE ALERT SITE AREA EMERGENCY GENERAL EMERGENCY Natural or destructive Natural or destructive phenomena HUl phenomena affecting the HA1 affecting VITAL AREAs.

IPROTECTED

'11 21 31 4 1 SF1D AREA.

II1 1314451 l FIRE within PROTECTED AREA FIRE or EXPLOSION affecting boundary not extinguished within the operability of plant safety HU2 15 minutes of detection OR HA2 systems required to establish or EXPLOSION within the maintain safe shutdown.

PROTECTED I11 21131 4 151AREA.DI1 1 1 1 1 1" Access to a VITAL AREA is Release of toxic, corrosive, prohibited due to toxic, corrosive, asphyxiant or flammable gases asphyxiant or flammable gases HU3 deemed detrimental to NORMAL HA3 which jeopardize operation of PLANT OPERATIONS. operable equipment required to maintain safe operations or safely shutdown the reactor.

I 11 21 31 41 51 __

HOSTILE ACTION resulting in Confirmed SECURITY HOSTILE ACTION within the loss of physical control of the CONDITION or threat which HOSTILE ACTION within the L+/-I+/-ltW1 HA4 OWNER CONTROLLED AREA or HS4 PROTECTED AREA. HG1 HU4 indicates a potential degradation airborne attack threat.

in theh21etlevel In h plant.

leve ofofsafety ofofthe plant.1 I 112 1 31 4 1 51 D1 I 1 1 2 1 31 4 1 51 DI Other conditions exist which in Other conditions exist which in Other conditions exist which in Other conditions exist which inthe thejudg tiof thehComman thejudg tiof t commn the judgment of the Command judgment of the Command and the judgment of the Command the judgment of the Command HU5 and Control position warrant HA6 Control position warrant HS3 and Control position warrant HG2 and Control position warrant declaration of a Site Area declaration of General declaration of a NOUE.

I~~ ~ ~ declaration 11~ 14 of ~an10IAlert.~ ~ ~ ~ LEmeraency.

11112111I 41 51 °D 131 I Emergency.

21 14 l° Control Room evacuation has Control Room evacuation has HA5 been initiated, HS2 been initiated and plant control I 1s = 3 4 - Icannot 11 2 1 3be1 4established.

1 5 1 01

TBD-EPIP-OSC-1 H Reference Use Page 3 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY NOUE HUI Initiating Condition --

Natural or destructive phenomena affecting the PROTECTED AREA.

Operating Mode Applicability:

1 2 3 4 5 D I Emergency Action Levels: 1 OR 2 OR 3 OR 4 OR 5

1. Seismic event identified by any two of the following:

" STRONG MOTION SEISMIC EVENT IN PROGRESS alarm

• Event indicator (SMA-3 Control Panel) has changed from Black to White

" Earthquake felt by the Control Room Operators

• National Earthquake Information Center

2. Tornado is reported by plant personnel (touching down) within the PROTECTED AREA or High Wind Speeds greater than 90 mph are indicated on site weather tower.

3. Uncontrolled flooding in Vital Areas of the plant that has the potential to affect safety related equipment required by Technical Specifications for the current operating mode.

4. Report of Main Turbine failure resulting in casing penetration or damage to turbine or generator seals.

5. Any of the following occurrences affecting the PROTECTED AREA.

• River level is greater than 1004 feet MSL, but less than or equal to 40W 1007 feet MSL elevation.

• River level is less than 976 feet 9 inches and greater than or equal to 973 feet 9 inches MSL elevation.

Basis:

These EALs are categorized on the basis of the occurrence of an event of sufficient magnitude to be of concern to plant operators.

Continued on Next Page

TBD-EPIP-OSC-1 H Reference Use Page 4 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY NOUE HUI Basis: (continued)

EAL #1 Damage may be caused to some portions of the site, but should not affect ability of safety functions to operate.

As defined in the EPRI-sponsored Guidelines for Nuclear Plant Response to an Earthquake, dated October 1989, a "felt earthquake" is: An earthquake of sufficient intensity such that: (a) the vibratory ground motion is felt at the nuclear plant site and recognized as an earthquake based on a consensus of control room operators on duty at the time, and (b) for plants with operable seismic instrumentation, the seismic switches of the plant are activated.

The National Earthquake Center can confirm if an earthquake has occurred in the area of the plant.

EAL #2 This EAL is based on a tornado striking (touching down) or high winds within the PROTECTED AREA.

The high wind site specific value in EAL#2 is based on "The fastest mile of wind at the site location for a 100 year period of recurrence is a 90 mph basic wind at 30 feet above ground level (USAR Section 5.4)." The site weather tower is located outside of the Protected Area on Owner Controlled Area and is assumed to be an indication of meteorological information for the Protected Area.

Escalation of this emergency classification level, if appropriate, would be based on VISIBLE DAMAGE, or by other in plant conditions, via HA1.

EAL #3 This EAL addresses the effect of internal flooding caused by events such as component failures, equipment misalignment, or outage activity mishaps.

Vital Areas include those areas that contain systems required for safe shutdown of the plant, which are not designed to be partially or fully submerged.

Escalation of this emergency classification level, if appropriate, would be based VISIBLE DAMAGE via HA1, or by other plant conditions.

I ~Continued on Next PageI

TBD-EPIP-OSC-1 H Reference Use Page 5 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY NOUE HU1 Basis: (continued)

EAL #4 This EAL addresses main turbine rotating component failures of sufficient magnitude to cause observable damage to the turbine casing or to the seals of the turbine generator. Generator seal damage observed after generator purge does not meet the intent of this EAL because it did not impact normal operation of the plant.

Of major concern is the potential for leakage of combustible fluids (lubricating oils) and gases (hydrogen cooling) to the plant environs. Actual FIRES and flammable gas build up are appropriately classified via HU2 and HU3.

This EAL is consistent with the definition of a NOUE while maintaining the anticipatory nature desired and recognizing the risk to non-safety related equipment.

Escalation of this emergency classification level, if appropriate, would be to HA1 based on damage done by PROJECTILES generated by the failure or in conjunction with a steam generator tube rupture. These latter events would be classified by the radiological ICs or Fission Product Barrier ICs.

EAL #5 This EAL addresses other site specific phenomena such as hurricane, flood, or seiche that can also be precursors of more serious events.

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 and its associated Basis indicating that the flooding plan to protect the plant will be instituted at 1900.2 feet and rising indicating that the FCS emergency plan will be implemented during expected high river level conditions (i.e., prior to reaching 1004 feet) to protect the plant. A river level greater than 1007 feet would meet the initiating conditions for HA1 EAL 6.

TBD-EPIP-OSC-1 H Reference Use Page 6 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY NOUE HU2 Initiating Condition --

FIRE Within PROTECTED AREA boundary not extinguished within 15 minutes of detection OR EXPLOSION within the PROTECTED AREA.

Operating Mode Applicability:

1 2 3 4 5 D Emergency Action Levels: 1 OR2 NOTE The Command and Control position should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.

1. FIRE not extinguished within 15 minutes of control room notification or verification of a control room FIRE alarm in any of the following areas:

• Containment Building

• Auxiliary Building

" Turbine Building

" Intake Structure

" Main and Auxiliary Transformer Yard

2. EXPLOSION within the PROTECTED AREA.

Basis:

This EAL addresses the magnitude and extent of FIRES or EXPLOSIONS that may be potentially significant precursors of damage to safety systems. It addresses the FIRE / EXPLOSION, and not the degradation in performance of affected systems that may result.

As used here, detection is visual observation and report by plant personnel or sensor alarm indication.

I Continued on Next Page

TBD-EPIP-OSC-1 H Reference Use Page 7 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY NOUE HU2 Basis: (continued)

EAL #1 The 15 minute time period begins with a credible notification that a FIRE is occurring, or indication of a fire detection system alarm/actuation. Verification of a fire detection system alarm/actuation includes actions that can be taken within the control room or other nearby site specific location to ensure that it is not spurious. An alarm is assumed to be an indication of a FIRE unless it is disproved within the 15 minute period by personnel dispatched to the scene. In other words, a personnel report from the scene may be used to disprove a sensor alarm if received within 15 minutes of the alarm, but shall not be required to verify the alarm.

The intent of this 15 minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket).

The site specific list applies to buildings and areas in actual contact with or immediately adjacent to VITAL AREAS or other significant buildings or areas. The Main and Auxiliary Transformer Yard is included in this EAL due to its close proximity to the air intake of the Diesel Generator rooms, and FO-1 Diesel Engine Fuel Oil Storage Tank fill connection. The intent of this EAL is not to include buildings (i.e., warehouses) or areas that are not in actual contact with or immediately adjacent to VITAL AREAS. This excludes FIRES within administration buildings, waste-basket FIRES, and other small FIRES of no safety consequence. Immediately adjacent implies that the area immediately adjacent contains or may contain equipment or cabling that could impact equipment located in VITAL AREAS or the fire could damage equipment inside VITAL AREAS or that precludes access to VITAL AREAS.

EAL #2 This EAL addresses only those EXPLOSIONS of sufficient force to damage permanent structures or equipment within the PROTECTED AREA.

No attempt is made to assess the actual magnitude of the damage. The occurrence of the EXPLOSION is sufficient for declaration.

The Command and Control position also needs to consider any security aspects of the EXPLOSION, if applicable.

Escalation of this emergency classification level, if appropriate, would be based on HA2.

TBD-EPIP-OSC-1 H Reference Use Page 8 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY NOUE HU3 Initiating Condition -

Release of toxic, corrosive, asphyxiant or flammable gases deemed detrimental to NORMAL PLANT OPERATIONS.

Operating Mode Applicability:

1 2 3 4 5 D Emergency Action Levels: 1 OR2

1. Toxic, corrosive, asphyxiant or flammable gases in amounts that have or could adversely affect NORMAL PLANT OPERATIONS.

2. Report by Local, County or State Officials for evacuation or sheltering of site personnel based on an offsite event.

Basis:

This EAL is based on the release of toxic, corrosive, asphyxiant or flammable gases of sufficient quantity to affect NORMAL PLANT OPERATIONS.

The fact that SCBA may be worn does not eliminate the need to declare the event.

This IC is not intended to require significant assessment or quantification. It assumes an uncontrolled process that has the potential to affect plant operations. This would preclude small or incidental releases, or releases that do not impact structures needed for plant operation.

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.

Escalation of this emergency classification level, if appropriate, would be based on HA3.

TBD-EPIP-OSC-1 H Reference Use Page 9 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY NOUE HU4 Initiating Condition -

Confirmed SECURITY CONDITION or threat which indicates a potential degradation in the level of safety of the plant.

Operating Mode Applicability:

I1 2 3 4 5 D Emergency Action Levels: 1 OR2OR3

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

2. A credible site specific security threat notification.

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

Basis:

Note: Timely and accurate communication between Shift Security Supervisor and the Control Room is crucial for the implementation of effective security EALs.

Security events which do not represent a potential degradation in the level of safety of the plant are reported under 10 CFR 73.71 or in some cases under 10 CFR 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under HA4, HS4 and HG1.

A higher initial classification could be made based upon the nature and timing of the security threat and potential consequences. Consider upgrading the emergency response status and emergency classification level in accordance with the site's Security Contingency Plan and Emergency Plan.

EAL #1 Reference is made to Shift Security Supervisor because these individuals are the designated personnel on-site qualified and trained to confirm that a security event is occurring or has occurred.

Training on security event classification confirmation is closely controlled due to the strict secrecy controls placed on the plant Security Contingency Plan.

Continued on Next Page I

TBD-EPIP-OSC-1 H Reference Use Page 10 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY NOUE HU4 BASIS: (continued)

EAL #2 This threshold is included to ensure that appropriate notifications for the security threat are made in a timely manner. This includes information of a credible threat. Only the plant to which the specific threat is made need declare the Notification of an Unusual Event.

The determination of "credible" is made through use of information found in the FCS Security Contingency Plan.

EAL #3 The intent of this EAL is to ensure that notifications for the aircraft threat are made in a timely manner and that Off-site Response Organizations and plant personnel are at a state of heightened awareness regarding the credible threat. It is not the intent of this EAL to replace existing non-hostile related EALs involving aircraft.

This EAL is met when FCS receives information regarding an aircraft threat from NRC. Validation is performed by calling the NRC or by other approved methods of authentication. Only the plant to which the specific threat is made need declare the Unusual Event.

The NRC Headquarters Operations Officer (HOO) will communicate to FCS if the threat involves an airliner (airliner is meant to be a large aircraft with the potential for causing significant damage to the plant). The status and size of the plane may be provided by NORAD through the NRC.

Escalation to Alert emergency classification level would be via HA4 would be appropriate if the threat involves an airliner within 30 minutes of the plant.

TBD-EPIP-OSC-1 H Reference Use Page 11 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY NOUE HU5 Initiating Condition -

Other conditions exist which in the judgment of the Command and Control position warrant declaration of a NOUE.

Operating Mode Applicability:

1 2 3 4 5 D I Emergency Action Levels: 1

1. Other conditions exist which in the judgment of the Command and Control position indicate that events are in process or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

Basis:

This EAL is intended to address unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Command and Control position to fall under the NOUE emergency class.

From a broad perspective, one area that may warrant Command and Control position judgment is related to likely or actual breakdown of site-specific event mitigating actions. Examples to consider include inadequate emergency response procedures, transient response either unexpected or not understood, failure or unavailability of emergency systems during an accident in excess of that assumed in accident analysis, or insufficient availability of equipment and/or support personnel.

TBD-EPIP-OSC-1 H Reference Use Page 12 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HAI Initiating Condition --

Natural or destructive phenomena affecting VITAL AREAs.

Operating Mode Applicability:

1 2 3 4 5 D Emergency Action Levels: 1 0R2OR3OR4OR5OR6

1. Felt Earthquake greater than Operating Basis Earthquake (0.08g acting in the horizontal direction and 0.053 g acting in the vertical direction) is validated by the following:

a. National Earthquake Information Center OR

b. Control Room indication of degraded system response or performance of the following VITAL AREA structures, Safe Shutdown Systems or Safe Shutdown Equipment (SSE):

• Containment

• Intake Structure " Auxiliary Building

• Turbine Building (SSE only)

• SIRWT " Condensate Storage Tank

2. Tornado within the PROTECTED AREA boundary or High Winds greater than 90 mph are indicated on site weather tower resulting in VISIBLE DAMAGE to following plant VITAL AREA structures / Safe Shutdown Equipment (SSE) or Control Room indication of degraded performance of Safe Shutdown Systems or Safe Shutdown Equipment.

" Containment " Intake Structure " Auxiliary Building

" Turbine Building (SSE only)

• SIRWT

• Condensate Storage Tank

3. Internal flooding in any of the following plant VITAL AREA structures resulting in an electrical shock hazard that precludes access to operate or monitor safety equipment OR control room indication of degraded performance of Safe Shutdown Systems or Safe Shutdown Equipment.

• Containment " Intake Structure

• Auxiliary Building

" Turbine Building (SSE only)

• SIRWT e Condensate Storage Tank Continued on Next Page 11

TBD-EPIP-OSC-1 H Reference Use Page 13 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HAI

4. Main Turbine failure generates PROJECTILES resulting in VISIBLE DAMAGE to or penetration of any of the following plant VITAL AREA structures or equipment therein or Control Room indication of degraded performance of Safe Shutdown Systems or Safe Shutdown Equipment.

e Containment

• Intake Structure e Auxiliary Building

• Turbine Building (SSE only)

• SIRWT 9 Condensate Storage Tank

5. Vehicle crash resulting in VISIBLE DAMAGE to any of the following plant VITAL AREA structures or equipment therein or Control Room indication of degraded performance of Safe Shutdown Systems or Safe Shutdown Equipment.

" Containment 9 Intake Structure

• Auxiliary Building

" Turbine Building (SSE only)

• SIRWT

• Condensate Storage Tank

6. Any of the following occurrences resulting in VISIBLE DAMAGE to plant structures containing equipment necessary for safe shutdown, or has caused damage as evidenced by control, room indication of degraded performance of those systems.

" River level is greater than 49 feet MSL elevation.

" River level is less than 973 feet, 9 inches MSL elevation.

Basis:

The EALs in this IC escalate from the NOUE EALs in HU1 in that the occurrence of the event has resulted in VISIBLE DAMAGE to plant structures or areas containing equipment necessary for a safe shutdown, or has caused damage to the safety systems in those structures evidenced by control indications of degraded system response or performance. The occurrence of VISIBLE DAMAGE and/or degraded system response is intended to discriminate against lesser events. The initial "report" should not be interpreted as mandating a lengthy-damage assessment prior to classification. No attempt is made in this EAL to assess the actual magnitude of the damage. The significance here is not that a particular system or structure was damaged, but rather, that the event was of sufficient magnitude to cause this degradation.

Escalation to higher classifications occurs on the basis of other ICs (e.g., System Malfunction).

EAL #1 is based on indications of a felt earthquake greater than the Operating Basis Earthquake (OBE) that results in damage or potential damage to plant VITAL AREA structures, Safe Shutdown Equipment, or Safe Shutdown Systems. Data from seismic instrumentation is II Continued on Next Page

TBD-EPIP-OSC-1 H Reference Use Page 14 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HAI BASIS: (continued) not immediately available, thus confirmation on the severity of a seismic disturbance is obtained by Control Room indications of degraded performance of plant VITAL AREA structures, Safe Shutdown Systems or Safe Shutdown Equipment, or by contacting the National Earthquake Information Center, Denver, Colorado, 1-303-273-8500 (normal hours), or 1-303-273-8428 (off normal hours). If the information given is in spectral displacement (Richter Scale value), an earthquake greater than 6.5 has the potential to exceed the Operating Basis Earthquake values.

For the Taft Earthquake of 1952 on which FCS Seismic analysis is based (FCS Updated Safety Analysis Report Appendix F), the maximum acceleration was 1.89g.(SOURCE: CA Institute of Technology, "Analysis of the Taft Accelerogram of the Earthquake of 21 July 1952," by G.W Housner) The Fort Calhoun Station OBE is 0.08g or 23.63 times less than the Taft Earthquake.

Acceleration is directly proportional to energy. Using the Richter Scale to compare intensities (energy), a 6.5 Magnitude earthquake is 31.62 times less than the 7.5 Magnitude Taft Earthquake.

Therefore, 6.5 is the Magnitude value to be used when contacting the National Earthquake Information Center. The Center cannot provide data in acceleration, only in Magnitude, immediately following the earthquake.

EAL #2 is based on a tornado touching down in the Protected Area or winds exceeding 90 mph as indicated on the weather tower. The discriminator between a NOUE and the Alert is VISIBLE DAMAGE to plant VITAL AREA structures / Safe Shutdown Equipment (SSE) or Control Room indication of degraded performance of Safe Shutdown Systems or Safe Shutdown Equipment.

Wind loads of this magnitude (90 mph) can cause damage to safety functions.

EAL #s 2, 3, 4, 5 - Visible Damage to plant VITAL AREA structures / Safe Shutdown Equipment (SSE) or Control Room indication of degraded performance of Safe Shutdown Systems or Safe Shutdown Equipment is used to discriminate for the ALERT classification.

EAL #3 addresses the effect of internal flooding caused by events such as component failures, equipment misalignment, or outage activity mishaps. It is based on the degraded performance of systems, or has created industrial safety hazards (e.g., electrical shock) that preclude necessary access to operate or monitor safety equipment. The inability to access, operate or monitor safety equipment represents an actual or substantial potential degradation of the level of safety of the plant.

Flooding as used in this EAL describes a condition where water is entering the room faster than installed equipment is capable of removal, resulting in a rise of water level within the room.

Classification of this EAL should not be delayed while corrective actions are being taken to isolate the water source.

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TBD-EPIP-OSC-1 H Reference Use Page 15 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HAI BASIS: (continued)

EAL #4 is intended to address the threat to safety related equipment imposed by missiles generated by main turbine rotating component failures. These areas include plant VITAL AREA structures / Safe Shutdown Equipment (SSE) or Control Room indication of degraded performance of Safe Shutdown Systems or Safe Shutdown Equipment. This EAL is, therefore, consistent with the definition of an ALERT in that if missiles have damaged or penetrated areas containing safety-related equipment the potential exists for substantial degradation of the level of safety of the plant.

EAL #5 is intended to address crashes of vehicle types large enough to cause significant damage to plant structures containing functions and systems required for safe shutdown of the plant.

EAL #6 covers other site-specific phenomena such as flood, and low river level. The river level of greater than 4DQ9 1007 feet is based on the elevation at which passive protection is provided at the station due to the fact that vital areas are elevated to that point. the installed flood gates will p'-eteGt-the plaR- The river level of 973 feet, 9 inches is based on the minimum elevation of the Raw Water Pump suction. These EALs can also be precursors of more serious events.

TBD-EPIP-OSC-1 H Reference Use Page 16 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HA2 Initiating Condition --

FIRE or EXPLOSION affecting the operability of plant safety systems required to establish or maintain safe shutdown.

Operating Mode Applicability:

1 2 3 4 5 D Emergency Action Level: 1

1. FIRE or EXPLOSION resulting in VISIBLE DAMAGE to any of the following structures containing safety systems or components OR control room indication of degraded performance of those safety systems:

" Containment

• Intake Structure " Auxiliary Building

• Turbine Building (SSE only)

• SIRWT " Condensate Storage Tank

• Main and Auxiliary Transformer Yard Basis:

VISIBLE DAMAGE is used to identify the magnitude of the FIRE or EXPLOSION and to discriminate against minor FIREs and EXPLOSIONs.

The reference to structures containing safety systems or components is included to discriminate against FIREs or EXPLOSIONs in areas having a low probability of affecting safe operation. The significance here is not that a safety system was degraded but the fact that the FIRE or EXPLOSION was large enough to cause damage to these systems.

Site-specific areas containing functions and systems required for the safe shutdown of the plant are specified in AOP-6, Fire Emergency. The Main and Auxiliary Transformer area is included because of the potential to cause grounds on the 22Kv and 4160 Volt distribution systems. Site-Specific Safe Shutdown Analysis should be consulted for equipment and plant areas required to establish or maintain safe shutdown. The use of AOP-6 makes it easier to determine if the FIRE or EXPLOSION is potentially affecting one or more redundant trains of safety systems.

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TBD-EPIP-OSC-1 H Reference Use Page 17 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HA2 BASIS: (continued)

The inclusion of a "report of VISIBLE DAMAGE" should not be interpreted as mandating a lengthy damage assessment prior to classification. The declaration of an ALERT and the activation of the Technical Support Center will provide the Command and Control position with the resources needed to perform these damage assessments.

The Command and Control position also needs to consider any security aspects of the EXPLOSIONs, if applicable.

Escalation to a higher emergency class, if appropriate, will be based on System Malfunction, Fission Product Barrier Degradation, Abnormal Rad Levels / Radiological Effluent, or Command and Control Position Judgment ICs.

TBD-EPIP-OSC-1 H Reference Use Page 18 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HA3 Initiating Condition -

Access to a VITAL AREA is prohibited due to toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of operable equipment required to maintain safe operations or safely shutdown the reactor.

Operating Mode Applicability:

1 2 3 4 5 D Emergency Action Level: 1 i ~NOTEi If the equipment in the stated area was already inoperable, or out of service, before the event occurred, then this EAL should not be declared as it will have no adverse impact on the ability of the plant to safely operate or safely shutdown beyond that already allowed by Technical Specifications at the time of the event.

1. Access to a one or more of the following VITAL AREAS is prohibited due to toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of systems required to maintain safe operations or safely shutdown the reactor.

• Containment Building

• Auxiliary Building

• Radwaste Building

" CARP Building

" Turbine Building

• Intake Structure

" Main and Auxiliary Transformer Yard Basis:

Gases in a VITAL AREA can affect the ability to safely operate or safely shutdown the reactor.

The fact that SCBA may be worn does not eliminate the need to declare the event.

II Continued on Next Page

TBD-EPIP-OSC-1 H Reference Use Page 19 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HA3 BASIS: (continued)

Declaration should not be delayed for confirmation from atmospheric testing if the atmosphere poses an immediate threat to life and health or an immediate threat of severe exposure to gases.

This could be based upon documented analysis, indication of personal ill effects from exposure, or operating experience with the hazards.

If the equipment in the stated area was already inoperable, or out of service, before the event occurred, then this EAL should not be declared as it will have no adverse impact on the ability of the plant to safely operate or safely shutdown beyond that already allowed by Technical Specifications at the time of the event.

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.

An uncontrolled release of flammable gasses within a facility structure has the potential to affect safe operation of the plant by limiting either operator or equipment operations due to the potential for ignition and resulting equipment damage/personnel injury. Flammable gasses, such as hydrogen and acetylene, are routinely used to maintain plant systems (hydrogen) or to repair equipment/components (acetylene - used in welding). This EAL assumes concentrations of flammable gasses which can ignite/support combustion.

Escalation of this emergency classification level, if appropriate, will be based on System Malfunctions, Fission Product Barrier Degradation or Abnormal Rad Levels / Radioactive Effluent ICs.

TBD-EPIP-OSC-1 H Reference Use Page 20 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HA4 Initiating Condition --

HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat.

Operating Mode Applicability:

1 2 3 4 5 D Emergency Action Level: 10R213

1. A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the Shift Security Supervisor.

2. A validated notification from NRC of an airliner attack threat within 30 minutes of the site.

Basis:

Timely and accurate communication between the Shift I Security Supervisor implementation and theSecurity of effective Control Room EALs. is crucial for the II These EALs address the contingency for a very rapid progression of events, such as that experienced on September 11, 2001. They are not premised solely on the potential for a radiological release. Rather the issue includes the need for rapid assistance due to the possibility for significant and indeterminate damage from additional air, land or water attack elements.

The fact that the site is under serious attack or is an identified attack target with minimal time available for further preparation or additional assistance to arrive requires a heightened state of readiness and implementation of protective measures that can be effective (such as on-site evacuation, dispersal or sheltering).

II Continued on Next Page

TBD-EPIP-OSC-1 H Reference Use Page 21 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HA4 BASIS: (continued)

EAL #1 This EAL addresses the potential for a very rapid progression of events due to a HOSTILE ACTION. It is not intended to address incidents that are accidental events or acts of civil disobedience, such as small aircraft impact, hunters, or physical disputes between employees within the OCA. Those events are adequately addressed by other EALs.

Note that this EAL is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA.

Although nuclear plant security officers are well trained and prepared to protect against HOSTILE ACTION, it is appropriate for Off-site Response Organizations (OROs) to be notified and encouraged to begin activation (if they do not normally) to be better prepared should it be necessary to consider further actions.

EAL #2 This EAL addresses the immediacy of an expected threat arrival or impact on the site within a relatively short time.

The intent of this EAL is to ensure that notifications for the airliner attack threat are made in a timely manner and that OROs and plant personnel are at a state of heightened awareness regarding the credible threat. Airliner is meant to be a large aircraft with the potential for causing significant damage to the plant.

This EAL is met when a plant receives information regarding an airliner attack threat from NRC and the airliner is within 30 minutes of the plant. Only the plant to which the specific threat is made need declare the ALERT.

The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an airliner (airliner is meant to be a large aircraft with the potential for causing significant damage to the plant). The status and size of the plane may be provided by.NORAD through the NRC.

If not previously notified by the NRC that the airborne HOSTILE ACTION was intentional, then it would be expected, although not certain, that notification by an appropriate Federal agency would follow. In this case, appropriate federal agency is intended to be NORAD, FBI, FAA or NRC.

However, the declaration should not be unduly delayed awaiting Federal notification.

TBD-EPIP-OSC-1 H Reference Use Page 22 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HA5 Initiating Condition --

Control Room evacuation has been initiated.

Operating Mode Applicability:

1 2 3 4 5 D I Emergency Action Level: 1

1. Entry into AOP-6,Section II, ControlRoom Evacuation, OR AOP-7, Evacuation of Control Room, for control room evacuation.

Basis:

With the control room evacuated, additional support, monitoring and direction through the Technical Support Center and/or other emergency response facility is necessary. Inability to establish plant control from outside the control room will escalate this event to a Site Area Emergency.

TBD-EPIP-OSC-1 H Reference Use Page 23 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HA6 Initiating Condition -

Other conditions exist which in the judgment of the Command and Control position warrant declaration of an ALERT.

Operating Mode Applicability:

1 2 3 4 5 I D II Emergency Action Level: I

1. Other conditions exist which in the judgment of the Command and Control position indicate that events are in process or have occurred which involve actual or likely 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.

Basis:

This EAL is intended to address unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Command and Control position to fall under the ALERT emergency class.

TBD-EPIP-OSC-1 H Reference Use Page 24 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY SITE AREA EMERGENCY HS2 Initiating Condition -

Control Room evacuation has been initiated and plant control cannot be established.

Operating Mode Applicability:

12 3 4 5 D SEmergency Action Level:

1. a. Control room evacuation has been initiated.

AND

b. Control of the plant cannot be established per AOP-6,Section II, Control Room Evacuation, or AOP-7, Evacuation of ControlRoom, within 15 minutes.

Basis:

The intent of this IC is to capture those events where control of the plant cannot be reestablished in a timely manner. In this case, expeditious transfer of control of safety systems has not occurred (although fission product barrier damage may not yet be indicated).

The intent of the EAL is to establish control of important plant equipment and knowledge of important plant parameters in a timely manner. Primary emphasis should be placed on those components and instruments that supply protection for and information about safety functions.

These safety functions are reactivity control, RCS inventory, and RCS and Core Heat Removal.

The determination of whether or not control is established at the remote shutdown panel is based on Command and Control position judgment. The Command and Control position is expected to make a reasonable, informed judgment within the site-specific time for transfer that the licensee has control of the plant from the remote shutdown panel.

Site-specific time for transfer is based on analysis or assessments as to how quickly control must be reestablished without core uncovering and/or core damage. This time should not exceed 15 minutes without additional justification.

Escalation of this event, if appropriate, would be by Fission Product Barrier Degradation, Abnormal Rad Levels/Radiological Effluent, or Command and Control Position Judgment ICs.

TBD-EPIP-OSC-1 H Reference Use Page 25 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY SITE AREA EMERGENCY HS3 Initiating Condition -

Other conditions exist which in the judgment of the Command and Control position warrant declaration of a Site Area Emergency.

Operating Mode Applicability:

1 2 3 4 5 D Emergency Action Level: 1

1. Other conditions exist which in the judgment of the Command and Control position indicate that events are in process 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.

Basis:

This EAL is intended to address unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Command and Control position to fall under the emergency class description for Site Area Emergency.

TBD-EPIP-OSC-1 H Reference Use Page 26 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY SITE AREA EMERGENCY HS4 Initiating Condition -

HOSTILE ACTION within the PROTECTED AREA.

Operating Mode Applicability:

1 2 3 4 I D I.Emergency Action Level: 1

1. A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the Shift Security Supervisor.

Basis:

This condition represents an escalated threat to plant safety above that contained in the ALERT in that a HOSTILE FORCE has progressed from the OWNER CONTROLLED AREA to the PROTECTED AREA.

This includes the ISFSI located within the PROTECTED AREA.

This EAL addresses the contingency for a very rapid progression of events, such as that experienced on September 11, 2001. It is not premised solely on the potential for a radiological release. Rather the issue includes the need for rapid assistance due to the possibility for significant and indeterminate damage from additional air, land or water attack elements.

The fact that the site is under serious attack with minimal time available for further preparation or additional assistance to arrive requires Off-site Response Organization readiness and preparation for the implementation of protective measures.

This EAL addresses the potential for a very rapid progression of events due to a HOSTILE ACTION. It is not intended to address incidents that are accidental events or acts of civil disobedience, such as small aircraft impact, hunters, or physical disputes between employees within the PROTECTED AREA. Those events are adequately addressed by other EALs.

Although nuclear plant security officers are well trained and prepared to protect against HOSTILE ACTION, it is appropriate for Off-site Response Organizations to be notified and encouraged to begin preparations for public protective actions (if they do not normally) to be better prepared should it be necessary to consider further actions.

If not previously notified by NRC that the airborne HOSTILE ACTION was intentional, then it would be expected, although not certain, that notification by an appropriate Federal agency would follow. In this case, appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. However, the declaration should not be unduly delayed awaiting Federal notification.

Escalation of this emergency classification level, if appropriate. would be based on actual plant status after impact or progression of attack.

TBD-EPIP-OSC-1 H Reference Use Page 27 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONSAFFECTING PLANT SAFETY GENERAL EMERGENCY HG1 Initiating Condition -

HOSTILE ACTION resulting in loss of physical control of the facility.

Operating Mode Applicability:

1 2 3 4 5 D I Emergency Action Level: 1OR2

1. A HOSTILE ACTION has occurred such that plant personnel are unable to operate equipment required to maintain safety functions.

2. A HOSTILE ACTION has caused failure of Spent Fuel Cooling Systems and IMMINENT fuel damage is likely for a freshly off-loaded reactor core in pool.

Basis:

EAL #1 encompasses conditions under which a HOSTILE FORCE has taken physical control of VITAL AREAs (containing vital equipment or controls of vital equipment) required to maintain safety functions and control of that equipment cannot be transferred to and operated from another location. These safety functions are reactivity control, RCS inventory, and RCS and Core Heat Removal. If control of the plant equipment necessary to maintain safety functions can be transferred to another location, then the above initiating condition is not met.

Loss of physical control of the control room or remote shutdown capability alone may not prevent the ability to maintain safety functions per se. Design of the remote shutdown capability and the location of the transfer switches should be taken into account. If control of the plant equipment necessary to maintain safety functions can be transferred to another location, then the threshold is not met.

EAL #2 addresses failure of spent fuel cooling systems as a result of HOSTILE ACTION if IMMINENT fuel damage is likely, such as when a freshly off-loaded reactor core is in the spent fuel pool.

A freshly off-loaded reactor core is defined as fuel that has been discharged within the previous 365 days. This definition is from RE-AD-0006.

TBD-EPIP-OSC-1 H Reference Use Page 28 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY GENERAL EMERGENCY HG2 Initiating Condition -

Other conditions exist which in the judgment of the Command and Control position warrant declaration of General Emergency.

Operating Mode Applicability:

1 2 3 4 D5 Emergency Action Level: 1 I

1. Other conditions exist which in the judgment of the Command and Control position indicate that events are in process 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.

Basis:

This EAL is intended to address unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Command and Control position to fall under the General Emergency class.

LIC-12-0056 Enclosure, Attachment 4 Page 1 Emergency Action Level (EAL)

TBD-EPIP-OSC-1 H Recognition Category H - Hazards and Other Conditions. Affecting Plant Safety Retyped "Clean" Pages

Page 1 of 28 1I TBD-EPIP-OSC-1 H I Recognition Category H - Hazards and Other Conditions Affecting Plant Safety Rev 1 Safety Classification: Usage Level:

II Non-Safety II II Reference Change No.: EC 51690 Reason for Change: Revise HA1 EAL6 and basis for HA1 to change Initiating Condition for high river level from 1009 feet MSL elevation to 1007 feet MSL elevation. The current station flood criterion for ALERT classification is being changed from 1009 feet to 1014 feet due to changes in design and protection strategies. The station is passively protected to 1007 feet because vital areas are elevated to this point.

Therefore; it is concluded that changing the EAL criteria from 1009 foot to 1007 foot would be appropriate. HUI EAL 5 is also being revised to bound the NOUE as a result of this change.

Preparer:

Sponsor: A. Berck Editorial Correction (a) EC 46843 All pages Issued:

Fort Calhoun Station

TBD-EPIP-OSC-1H Reference Use Page 2 of 28 I Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety Recognition Category H - Hazards and Other Conditions Affecting Plant Safety INITIATING CONDITION MATRIX NOUE ALERT SITE AREA EMERGENCY GENERAL EMERGENCY Natural or destructive Natural or destructive phenomena HU1 phenomena affecting the HA1 affecting VITAL AREAs.

PROTECTED AREA. 11 21 31 451DI FIRE within PROTECTED AREA notEexthin guishECTED win FIRE or EXPLOSION affecting boundary not extinguished within the operability of plant safety HU2 15 minutes of detection OR HA2 systems required to establish or EXPLOSION within the maintain safe shutdown.

PROTECTED I'll 21 31 41 51FAREA.

1ID1J

• 1 1 Access to a VITAL AREA is Release of toxic, corrosive, prohibited due to toxic, corrosive, asphyxiant or flammable gases asphyxiant or flammable gases HU3 deemed detrimental to NORMAL HA3 which jeopardize operation of PLANT OPERATIONS. operable equipment required to maintain shutdown safe the operations reactor. or safely

__1_1_41 -51 __

HOSTILE ACTION resulting in Confirmed SECURITY HOSTILE ACTION within the loss of physical control of the CONDITION or threat which HOSTILE ACTION within the facility.

HU4 indicates a potential degradation HA4 OWNER CONTROLLED AREA or HS4 PROTECTED AREA. HG1 I 11 2 1 3I 41 11 o T4r, -l 15safety of the plant.

1 21 level of Iin1the I1 e a I3 4 1o t 11 2 1 31 4 5c1 Other conditions exist which in Other conditions exist which in Other conditions exist Which in Other conditions exist which in the the judgment of the Command the judgment of the Command the judgment of the Command judgment of the Command and HU5 and Control position warrant HA6 Control position warrant HS3 and Control position warrant HG2 and Control position warrant declaration of a NOUE. declaration of an Alert. Eeonv of a Site Area declaration declaration of General 1 1DEmergency. Emergency.

S11 11 21 31 4 1 5_ 1D 1 1/3_1 4_1 5 ol Control Room evacuation has Control Room evacuation has HA5 been initiated. HS2 been initiated and plant control I 1 = 3 4151olI 3 141

'11 2=1be cannot 1 01 established.

TBD-EPIP-OSC-1 H Reference Use Page 3 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY NOUE HUI Initiating Condition --

Natural or destructive phenomena affecting the PROTECTED AREA.

Operating Mode Applicability:

1 2 3 4 5 D Emergency Action Levels: 1 OR2OR3OR4OR5

1. Seismic event identified by any two of the following:

• STRONG MOTION SEISMIC EVENT IN PROGRESS alarm

• Event indicator (SMA-3 Control Panel) has changed from Black to White

" Earthquake felt by the Control Room Operators

" National Earthquake Information Center

2. Tornado is reported by plant personnel (touching down) within the PROTECTED AREA or High Wind Speeds greater than 90 mph are indicated on site weather tower.

3. Uncontrolled flooding in Vital Areas of the plant that has the potential to affect safety related equipment required by Technical Specifications for the current operating mode.

4. Report of Main Turbine failure resulting in casing penetration or damage to turbine or generator seals.

5. Any of the following occurrences affecting the PROTECTED AREA.

River level is greater than 1004 feet MSL, but less than or equal to 1007 feet MSL elevation.

River level is less than 976 feet 9 inches and greater than or equal to 973 feet 9 inches MSL elevation.

Basis:

These EALs are categorized on the basis of the occurrence of an event of sufficient magnitude to be of concern to plant operators.

I Continued on Next Page I

TBD-EPIP-OSC-1 H Reference Use Page 4 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY NOUE HU1 Basis: (continued)

EAL #1 Damage may be caused to some portions of the site, but should not affect ability of safety functions to operate.

As defined in the EPRI-sponsored Guidelines for Nuclear Plant Response to an Earthquake, dated October 1989, a "felt earthquake" is: An earthquake of sufficient intensity such that: (a) the vibratory ground motion is felt at the nuclear plant site and recognized as an earthquake based on a consensus of control room operators on duty at the time, and (b) for plants with operable seismic instrumentation, the seismic switches of the plant are activated.

The National Earthquake Center can confirm if an earthquake has occurred in the area of the plant.

EAL #2 This EAL is based on a tornado striking (touching down) or high winds within the PROTECTED AREA.

The high wind site specific value in EAL#2 is based on "The fastest mile of wind at the site location for a 100 year period of recurrence is a 90 mph basic wind at 30 feet above ground level (USAR Section 5.4)." The site weather tower is located outside of the Protected Area on Owner Controlled Area and is assumed to be an indication of meteorological information for the Protected Area.

Escalation of this emergency classification level, if appropriate, would be based on VISIBLE DAMAGE, or by other in plant conditions, via HAl.

EAL #3 This EAL addresses the effect of internal flooding caused by events such as component failures, equipment misalignment, or outage activity mishaps.

Vital Areas include those areas that contain systems required for safe shutdown of the plant, which are not designed to be partially or fully submerged.

Escalation of this emergency classification level, if appropriate, would be based VISIBLE DAMAGE via HA1, or by other plant conditions.

II Continued on Next Page

TBD-EPIP-OSC-1 H Reference Use Page 5 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY NOUE HUI Basis: (continued)

EAL #4 This EAL addresses main turbine rotating component failures of sufficient magnitude to cause observable damage to the turbine casing or to the seals of the turbine generator. Generator seal damage observed after generator purge does not meet the intent of this EAL because it did not impact normal operation of the plant.

Of major concern is the potential for leakage of combustible fluids (lubricating oils) and gases (hydrogen cooling) to the plant environs. Actual FIRES and flammable gas build up are appropriately classified via HU2 and HU3.

This EAL is consistent with the definition of a NOUE while maintaining the anticipatory nature desired and recognizing the risk to non-safety related equipment.

Escalation of this emergency classification level, if appropriate, would be to HA1 based on damage done by PROJECTILES generated by the failure or in conjunction with a steam generator tube rupture. These latter events would be classified by the radiological ICs or Fission Product Barrier ICs.

EAL #5 This EAL addresses other site specific phenomena such as hurricane, flood, or seiche that can also be precursors of more serious events.

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 and its associated Basis indicating that the FCS emergency plan will be implemented during expected high river level conditions (i.e., prior to reaching 1004 feet) to protect the plant. A river level greater than 1007 feet would meet the initiating conditions for HAI EAL 6.

TBD-EPIP-OSC-1 H Reference Use Page 6 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY NOUE HU2 Initiating Condition --

FIRE Within PROTECTED AREA boundary not extinguished within 15 minutes of detection OR EXPLOSION within the PROTECTED AREA.

Operating Mode Applicability:

1 2 3 4 5 D Emergency Action Levels: 1 OR2 i NOTE The Command and Control position should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition will likely exceed the applicable time.

1. FIRE not extinguished within 15 minutes of control room notification or verification of a control room FIRE alarm in any of the following areas:

" Containment Building

• Auxiliary Building

" Turbine Building

" Intake Structure

• Main and Auxiliary Transformer Yard

2. EXPLOSION within the PROTECTED AREA.

Basis:

This EAL addresses the magnitude and extent of FIRES or EXPLOSIONS that may be potentially significant precursors of damage to safety systems. It addresses the FIRE / EXPLOSION, and not the degradation in performance of affected systems that may result.

As used here, detection is visual observation and report by plant personnel or sensor alarm indication.

Continued on Next Page

TBD-EPIP-OSC-1 H Reference Use Page 7 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY NOUE HU2 Basis: (continued)

EAL #1 The 15 minute time period begins with a credible notification that a FIRE is occurring, or indication of a fire detection system alarm/actuation. Verification of a fire detection system alarm/actuation includes actions that can be taken within the control room or other nearby site specific location to ensure that it is not spurious. An alarm is assumed to be an indication of a FIRE unless it is disproved within the 15 minute period by personnel dispatched to the scene. In other words, a personnel report from the scene may be used to disprove a sensor alarm if received within 15 minutes of the alarm, but shall not be required to verify the alarm.

The intent of this 15 minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket).

The site specific list applies to buildings and areas in actual contact with or immediately adjacent to VITAL AREAS or other significant buildings or areas. The Main and Auxiliary Transformer Yard is included in this EAL due to its close proximity to the air intake of the Diesel Generator rooms, and FO-1 Diesel Engine Fuel Oil Storage Tank fill connection. The intent of this EAL is not to include buildings (i.e., warehouses) or areas that are not in actual contact with or immediately adjacent to VITAL AREAS. This excludes FIRES within administration buildings, waste-basket FIRES, and other small FIRES of no safety consequence. Immediately adjacent implies that the area immediately adjacent contains or may contain equipment or cabling that could impact equipment located in VITAL AREAS or the fire could damage equipment inside VITAL AREAS or that precludes access to VITAL AREAS.

EAL #2 This EAL addresses only those EXPLOSIONS of sufficient force to damage permanent structures or equipment within the PROTECTED AREA.

No attempt is made to assess the actual magnitude of the damage. The occurrence of the EXPLOSION is sufficient for declaration.

The Command and Control position also needs to consider any security aspects of the EXPLOSION, if applicable.

Escalation of this emergency classification level, if appropriate, would be based on HA2.

TBD-EPIP-OSC-1 H Reference Use Page 8 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY NOUE HU3 Initiating Condition -

Release of toxic, corrosive, asphyxiant or flammable gases deemed detrimental to NORMAL PLANT OPERATIONS.

Operating Mode Applicability:

1 2 3 4 5 D I Emergency Action Levels: 1 OR2

1. Toxic, corrosive, asphyxiant or flammable gases in amounts that have or could adversely affect NORMAL PLANT OPERATIONS.

2. Report by Local, County or State Officials for evacuation or sheltering of site personnel based on an offsite event.

Basis:

This EAL is based on the release of toxic, corrosive, asphyxiant or flammable gases of sufficient quantity to affect NORMAL PLANT OPERATIONS.

The fact that SCBA may be worn does not eliminate the need to declare the event.

This IC is not intended to require significant assessment or quantification. It assumes an uncontrolled process that has the potential to affect plant operations. This would preclude small or incidental releases, or releases that do not impact structures needed for plant operation.

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.

Escalation of this emergency classification level, if appropriate, would be based on HA3.

TBD-EPIP-OSC-1 H Reference Use Page 9 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY NOUE HU4 Initiating Condition -

Confirmed SECURITY CONDITION or threat which indicates a potential degradation in the level of safety of the plant.

Operating Mode Applicability:

1 2 3 4 5 D IEmergency Action Levels: 1 OR2OR3

2. A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the Shift Security Supervisor.

2. A credible site specific security threat notification.

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

Basis:

Note: Timely and accurate communication between Shift Security Supervisor and the Control Room is crucial for the implementation of effective security EALs.

Security events which do not represent a potential degradation in the level of safety of the plant are reported under 10 CFR 73.71 or in some cases under 10 CFR 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under HA4, HS4 and HG1.

A higher initial classification could be made based upon the nature and timing of the security threat and potential consequences. Consider upgrading the emergency response status and emergency classification level in accordance with the site's Security Contingency Plan and Emergency Plan.

EAL #1 Reference is made to Shift Security Supervisor because these individuals are the designated personnel on-site qualified and trained to confirm that a security event is occurring or has occurred.

Training on security event classification confirmation is closely controlled due to the strict secrecy controls placed on the plant Security Contingency Plan.

II Continued on Next Page

TBD-EPIP-OSC-1 H Reference Use Page 10 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY NOUE HU4 BASIS: (continued)

EAL #2 This threshold is included to ensure that appropriate notifications for the security threat are made in a timely manner. This includes information of a credible threat. Only the plant to which the specific threat is made need declare the Notification of an Unusual Event.

The determination of "credible" is made through use of information found in the FCS Security Contingency Plan.

EAL #3 The intent of this EAL is to ensure that notifications for the aircraft threat are made in a timely manner and that Off-site Response Organizations and plant personnel are at a state of heightened awareness regarding the credible threat. It is not the intent of this EAL to replace existing non-hostile related EALs involving aircraft.

This EAL is met when FCS receives information regarding an aircraft threat from NRC. Validation is performed by calling the NRC or by other approved methods of authentication. Only the plant to which the specific threat is made need declare the Unusual Event.

The NRC Headquarters Operations Officer (HOO) will communicate to FCS if the threat involves an airliner (airliner is meant to be a large aircraft with the potential for causing significant damage to the plant). The status and size of the plane may be provided by NORAD through the NRC.

Escalation to ALERT emergency classification level would be via HA4 would be appropriate if the threat involves an airliner within 30 minutes of the plant.

TBD-EPIP-OSC-1 H Reference Use Page 11 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY NOUE HU5 Initiating Condition -

Other conditions exist which in the judgment of the Command and Control position warrant declaration of a NOUE.

Operating Mode Applicability:

1 2 3 4 5 D I Emergency Action Levels: 1

1. Other conditions exist which in the judgment of the Command and Control position indicate that events are in process or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

Basis:

This EAL is intended to address unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Command and Control position to fall under the NOUE emergency class.

From a broad perspective, one area that may warrant Command and Control position judgment is related to likely or actual breakdown of site-specific event mitigating actions. Examples to consider include inadequate emergency response procedures, transient response either unexpected or not understood, failure or unavailability of emergency systems during an accident in excess of that assumed in accident analysis, or insufficient availability of equipment and/or support personnel.

TBD-EPIP-OSC-1 H Reference Use Page 12 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HAI Initiating Condition --

Natural or destructive phenomena affecting VITAL AREAs.

Operating Mode Applicability:

1 2 3 4 5 0 Emergency Action Levels: 1 OR 2 OR 3 OR 4 OR 5 OR 6

1. Felt Earthquake greater than Operating Basis Earthquake (0.08g acting in the horizontal direction and 0.053 g acting in the vertical direction) is validated by the following:

c. National Earthquake Information Center OR

d. Control Room indication of degraded system response or performance of the following VITAL AREA structures, Safe Shutdown Systems or Safe Shutdown Equipment (SSE):

" Containment

• Intake Structure " Auxiliary Building

" Turbine Building (SSE only) " SIRWT " Condensate Storage Tank

2. Tornado within the PROTECTED AREA boundary or High Winds greater than 90 mph are indicated on site weather tower resulting in VISIBLE DAMAGE to following plant VITAL AREA structures / Safe Shutdown Equipment (SSE) or Control Room indication of degraded performance of Safe Shutdown Systems or Safe Shutdown Equipment.

• Containment " Intake Structure " Auxiliary Building

• Turbine Building (SSE only) " SIRWT " Condensate Storage Tank

3. Internal flooding in any of the following plant VITAL AREA structures resulting in an electrical shock hazard that precludes access to operate or monitor safety equipment OR control room indication of degraded performance of Safe Shutdown Systems or Safe Shutdown Equipment.

• Containment " Intake Structure " Auxiliary Building

• Turbine Building (SSE only) " SIRWT " Condensate Storage Tank Continued on Next Page I

TBD-EPIP-OSC-1 H Reference Use Page 13 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HAI

4. Main Turbine failure generates PROJECTILES resulting in VISIBLE DAMAGE to or penetration of any of the following plant VITAL AREA structures or equipment therein or Control Room indication of degraded performance of Safe Shutdown Systems or Safe Shutdown Equipment.

" Containment

• Intake Structure

• Auxiliary Building

• Turbine Building (SSE only)

• SIRWT

• Condensate Storage Tank

5. Vehicle crash resulting in VISIBLE DAMAGE to any of the following plant VITAL AREA structures or equipment therein or Control Room indication of degraded performance of Safe Shutdown Systems or Safe Shutdown Equipment.

" Containment 0 Intake Structure 9 Auxiliary Building

" Turbine Building (SSE only)

• SIRWT

• Condensate Storage Tank

6. Any of the following occurrences resulting in VISIBLE DAMAGE to plant structures containing equipment necessary for safe shutdown, or has caused damage as evidenced by control room indication of degraded performance of those systems.

• River level is greater than 1007 feet MSL elevation.

• River level is less than 973 feet, 9 inches MSL elevation.

Basis:

The EALs in this IC escalate from the NOUE EALs in HU1 in that the occurrence of the event has resulted in VISIBLE DAMAGE to plant structures or areas containing equipment necessary for a safe shutdown, or has caused damage to the safety systems in those structures evidenced by control indications of degraded system response or performance. The occurrence of VISIBLE DAMAGE and/or degraded system response is intended to discriminate against lesser events. The initial "report" should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in this EAL to assess the actual magnitude of the damage. The significance here is not that a particular system or structure was damaged, but rather, that the event was of sufficient magnitude to cause this degradation.

Escalation to higher classifications occurs on the basis of other ICs (e.g., System Malfunction).

EAL #1 is based on indications of a felt earthquake greater than the Operating Basis Earthquake (OBE) that results in damage or potential damage to plant VITAL AREA structures, Safe Shutdown Equipment, or Safe Shutdown Systems. Data from seismic instrumentation is II Continued on Next Page I

TBD-EPIP-OSC-1 H Reference Use Page 14 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HAI BASIS: (continued) not immediately available, thus confirmation on the severity of a seismic disturbance is obtained by Control Room indications of degraded performance of plant VITAL AREA structures, Safe Shutdown Systems or Safe Shutdown Equipment, or by contacting the National Earthquake Information Center, Denver, Colorado, 1-303-273-8500 (normal hours), or 1-303-273-8428 (off normal hours). If the information given is in spectral displacement (Richter Scale value), an earthquake greater than 6.5 has the potential to exceed the Operating Basis Earthquake values.

For the Taft Earthquake of 1952 on which FCS Seismic analysis is based (FCS Updated Safety Analysis Report Appendix F), the maximum acceleration was 1.89g.(SOURCE: CA Institute of Technology, "Analysis of the Taft Accelerogram of the Earthquake of 21 July 1952," by G.W Housner) The Fort Calhoun Station OBE is 0.08g or 23.63 times less than the Taft Earthquake.

Acceleration is directly proportional to energy. Using the Richter Scale to compare intensities (energy), a 6.5 Magnitude earthquake is 31.62 times less than the 7.5 Magnitude Taft Earthquake.

Therefore, 6.5 is the Magnitude value to be used when contacting the National Earthquake Information Center. The Center cannot provide data in acceleration, only in Magnitude, immediately following the earthquake.

EAL #2 is based on a tornado touching down in the Protected Area or winds exceeding 90 mph as indicated on the weather tower. The discriminator between a NOUE and the Alert is VISIBLE DAMAGE to plant VITAL AREA structures / Safe Shutdown Equipment (SSE) or Control Room indication of degraded performance of Safe Shutdown Systems or Safe Shutdown Equipment.

Wind loads of this magnitude (90 mph) can cause damage to safety functions.

EAL #s 2, 3, 4, 5 - Visible Damage to plant VITAL AREA structures / Safe Shutdown Equipment (SSE) or Control Room indication of degraded performance of Safe Shutdown Systems or Safe Shutdown Equipment is used to discriminate for the Alert classification.

EAL #3 addresses the effect of internal flooding caused by events such as component failures, equipment misalignment, or outage activity mishaps. It is based on the degraded performance of systems, or has created industrial safety hazards (e.g., electrical shock) that preclude necessary access to operate or monitor safety equipment. The inability to access, operate or monitor safety equipment represents an actual or substantial potential degradation of the level of safety of the plant.

Flooding as used in this EAL describes a condition where water is entering the room faster than installed equipment is capable of removal, resulting in a rise of water level within the room.

Classification of this EAL should not be delayed while corrective actions are being taken to isolate the water source. -

Continued on Next Page I

TBD-EPIP-OSC-1 H Reference Use Page 15 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HAI BASIS: (continued)

EAL #4 is intended to address the threat to safety related equipment imposed by missiles generated by main turbine rotating component failures. These areas include plant VITAL AREA structures / Safe Shutdown Equipment (SSE) or Control Room indication of degraded performance of Safe Shutdown Systems or Safe Shutdown Equipment. This EAL is, therefore, consistent with the definition of an ALERT in that if missiles have damaged or penetrated areas containing safety-related equipment the potential exists for substantial degradation of the level of safety of the plant.

EAL #5 is intended to address crashes of vehicle types large enough to cause significant damage to plant structures containing functions and systems required for safe shutdown of the plant.

EAL #6 covers other site-specific phenomena such as flood, and low river level. The river level of greater than 1007 feet is based on the elevation at which passive protection is provided at the station due to the fact that vital areas are elevated to that point. The river level of 973 feet, 9 inches is based on the minimum elevation of the Raw Water Pump suction. These EALs can also be precursors of more serious events.

TBD-EPIP-OSC-1 H Reference Use Page 16 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HA2 Initiating Condition --

FIRE or EXPLOSION affecting the operability of plant safety systems required to establish or maintain safe shutdown.

Operating Mode Applicability:

1 2 3 4 5 D

[I Emergency Action Level: 1

1. FIRE or EXPLOSION resulting in VISIBLE DAMAGE to any of the following structures containing safety systems or components OR control room indication of degraded performance of those safety systems:

• Containment

• Intake Structure " Auxiliary Building

" Turbine Building (SSE only)

• SIRWT " Condensate Storage Tank

" Main and Auxiliary Transformer Yard Basis:,

VISIBLE DAMAGE is used to identify the magnitude of the FIRE or EXPLOSION and to discriminate against minor FIREs and EXPLOSIONs.

The reference to structures containing safety systems or components is included to discriminate against FIREs or EXPLOSIONs in areas having a low probability of affecting safe operation. The significance here is not that a safety system was degraded but the fact that the FIRE or EXPLOSION was large enough to cause damage to these systems.

Site-specific areas containing functions and systems required for the safe shutdown of the plant are specified in AOP-6, Fire Emergency. The Main and Auxiliary Transformer area is included because of the potential to cause grounds on the 22Kv and 4160 Volt distribution systems. Site-Specific Safe Shutdown Analysis should be consulted for equipment and plant areas required to establish or maintain safe shutdown. The use of AOP-6 makes it easier to determine if the FIRE or EXPLOSION is potentially affecting one or more redundant trains of safety systems.

I Continued on Next Page

TBD-EPIP-OSC-1 H Reference Use Page 17 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HA2 BASIS: (continued)

The inclusion of a "report of VISIBLE DAMAGE" should not be interpreted as mandating a lengthy damage assessment prior to classification. The declaration of an Alert and the activation of the Technical Support Center will provide the Command and Control position with the resources needed to perform these damage assessments.

The Command and Control position also needs to consider any security aspects of the EXPLOSIONs, if applicable.

Escalation to a higher emergency class, if appropriate, will be based on System Malfunction, Fission Product Barrier Degradation, Abnormal Rad Levels / Radiological Effluent, or Command and Control Position Judgment ICs.

TBD-EPIP-OSC-1 H Reference Use Page 18 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HA3 Initiating Condition -

Access to a VITAL AREA is prohibited due to toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of operable equipment required to maintain safe operations or safely shutdown the reactor.

Operating Mode Applicability:

1 2 3 4 I D Emergency Action Level: I

• NOTE If the equipment in the stated area was already inoperable, or out of service, before the event occurred, then this EAL should not be declared as it will have no adverse impact on the ability of the plant to safely operate or safely shutdown beyond that already I allowed by Technical Specifications at the time of the event.

1. Access to a one or more of the following VITAL AREAS is prohibited due to toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of systems required to maintain safe operations or safely shutdown the reactor.

" Containment Building

" Auxiliary Building

" Radwaste Building

" CARP Building

" Turbine Building

" Intake Structure

" Main and Auxiliary Transformer Yard Basis:

Gases in a VITAL AREA can affect the ability to safely operate or safely shutdown the reactor.

The fact that SCBA may be worn does not eliminate the need to declare the event.

II Continued on Next Page I

TBD-EPIP-OSC-1 H Reference Use Page 19 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HA3 BASIS: (continued)

Declaration should not be delayed for confirmation from atmospheric testing if the atmosphere poses an immediate threat to life and health or an immediate threat of severe exposure to gases.

This could be based upon documented analysis, indication of personal ill effects from exposure, or operating experience with the hazards.

If the equipment in the stated area was already inoperable, or out of service, before the event occurred, then this EAL should not be declared as it will have no adverse impact on the ability of the plant to safely operate or safely shutdown beyond that already allowed by Technical Specifications at the time of the event.

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.

An uncontrolled release of flammable gasses within a facility structure has the potential to affect safe operation of the plant by limiting either operator or equipment operations due to the potential for ignition and resulting equipment damage/personnel injury. Flammable gasses, such as hydrogen and acetylene, are routinely used to maintain plant systems (hydrogen) or to repair equipment/components (acetylene - used in welding). This EAL assumes concentrations of flammable gasses which can ignite/support combustion.

Escalation of this emergency classification level, if appropriate, will be based on System Malfunctions, Fission Product Barrier Degradation or Abnormal Rad Levels / Radioactive Effluent ICs.

TBD-EPIP-OSC-1 H Reference Use Page 20 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HA4 Initiating Condition --

HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat.

Operating Mode Applicability:

1 2 3 4 5 D Emergency Action Level: 1 OR 2

1. A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the Shift Security Supervisor.

2. A validated notification from NRC of an airliner attack threat within 30 minutes of the site.

Basis:

I

• NOTE i

Timely and accurate communication between the Shift I Security Supervisor implementation and theSecurity of effective EALs. is crucial for the Control Room II These EALs address the contingency for a very rapid progression of events, such as that experienced on September 11, 2001. They are not premised solely on the potential for a radiological release. Rather the issue includes the need for rapid assistance due to the possibility for significant and indeterminate damage from additional air, land or water attack elements.

The fact that the site is under serious attack or is an identified attack target with minimal time available for further preparation or additional assistance to arrive requires a heightened state of readiness and implementation of protective measures that can be effective (such as on-site evacuation, dispersal or sheltering).

I Continued on Next Page I

TBD-EPIP-OSC-1 H Reference Use Page 21 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HA4 BASIS: (continued)

EAL #1 This EAL addresses the potential for a very rapid progression of events due to a HOSTILE ACTION. It is not intended to address incidents that are accidental events or acts of civil disobedience, such as small aircraft impact, hunters, or physical disputes between employees within the OCA. Those events are adequately addressed by other EALs.

Note that this EAL is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA.

Although nuclear plant security officers are well trained and prepared to protect against HOSTILE ACTION, it is appropriate for Off-site Response Organizations (OROs) to be notified and encouraged to begin activation (if they do not normally) to be better prepared should it be necessary to consider further actions.

EAL #2 This EAL addresses the immediacy of an expected threat arrival or impact on the site within a relatively short time.

The intent of this EAL is to ensure that notifications for the airliner attack threat are made in a timely manner and that OROs and plant personnel are at a state of heightened awareness regarding the credible threat. Airliner is meant to be a large aircraft with the potential for causing significant damage to the plant.

This EAL is met when a plant receives information regarding an airliner attack threat from NRC and the airliner is within 30 minutes of the plant. Only the plant to which the specific threat is made need declare the Alert.

The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an airliner (airliner is meant to be a large aircraft with the potential for causing significant damage to the plant). The status and size of the plane may be provided by NORAD through the NRC.

If not previously notified by the NRC that the airborne HOSTILE ACTION was intentional, then it would be expected, although not certain, that notification by an appropriate Federal agency would follow. In this case, appropriate federal agency is intended to be NORAD, FBI, FAA or NRC.

However, the declaration should not be unduly delayed awaiting Federal notification.

TBD-EPIP-OSC-1 H Reference Use Page 22 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HA5 Initiating Condition --

Control Room evacuation has been initiated.

Operating Mode Applicability:

1 2 3 4 D5 I Emergency Action Level: 1

1. Entry into AOP-6,Section II, Control Room Evacuation, OR AOP-7, Evacuation of Control Room, for control room evacuation.

Basis:

With the control room evacuated, additional support, monitoring and direction through the Technical Support Center and/or other emergency response facility is necessary. Inability to establish plant control from outside the control room will escalate this event to a Site Area Emergency.

TBD-EPIP-OSC-1 H Reference Use Page 23 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ALERT HA6 Initiating Condition --

Other conditions exist which in the judgment of the Command and Control position warrant declaration of an Alert.

Operating Mode Applicability:

1 2 3 4 5 D Emergency Action Level: 1

1. Other conditions exist which in the judgment of the Command and Control position indicate that events are in process or have occurred which involve actual or likely 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.

Basis:

This EAL is intended to address unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Command and Control position to fall under the Alert emergency class.

TBD-EPIP-OSC-1 H Reference Use Page 24 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY SITE AREA EMERGENCY HS2 Initiating Condition -

Control Room evacuation has been initiated and plant control cannot be established.

Operating Mode Applicability:

1 2 3 4 5 D Emergency Action Level: 1

1. a. Control room evacuation has been initiated.

AND

b. Control of the plant cannot be established per AOP-6,Section II, ControlRoom Evacuation,or AOP-7, Evacuation of Control Room, within 15 minutes.

Basis:

The intent of this IC is to capture those events where control of the plant cannot be reestablished in a timely manner. In this case, expeditious transfer of control of safety systems has not occurred (although fission product barrier damage may not yet be indicated).

The intent of the EAL is to establish control of important plant equipment and knowledge of important plant parameters in a timely manner. Primary emphasis should be placed on those components and instruments that supply protection for and information about safety functions.

These safety functions are reactivity control, RCS inventory, and RCS and Core Heat Removal.

The determination of whether or not control is established at the remote shutdown panel is based on Command and Control position judgment. The Command and Control position is expected to make a reasonable, informed judgment within the site-specific time for transfer that the licensee has control of the plant from the remote shutdown panel.

Site-specific time for transfer is based on analysis or assessments as to how quickly control must be reestablished without core uncovering and/or core damage. This time should not exceed 15 minutes without additional justification.

Escalation of this event, if appropriate, would be by Fission Product Barrier Degradation, Abnormal Rad Levels/Radiological Effluent, or Command and Control Position Judgment ICs.

TBD-EPIP-OSC-1 H Reference Use Page 25 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY SITE AREA EMERGENCY HS3 Initiating Condition -

Other conditions exist which in the judgment of the Command and Control position warrant declaration of a Site Area Emergency.

Operating Mode Applicability:

1 2 3 4 5 D I Emergency Action Level: 1

1. Other conditions exist which in the judgment of the Command and Control position indicate that events are in process 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.

Basis:

This EAL is intended to address unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Command and Control position to fall under the emergency class description for Site Area Emergency.

TBD-EPIP-OSC-1 H Reference Use Page 26 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY SITE AREA EMERGENCY HS4 Initiating Condition -

HOSTILE ACTION within the PROTECTED AREA.

Operating Mode Applicability:

1 2 3 4 5 D I Emergency Action Level: 1

1. A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the Shift Security Supervisor.

Basis:

This condition represents an escalated threat to plant safety above that contained in the Alert in that a HOSTILE FORCE has progressed from the OWNER CONTROLLED AREA to the PROTECTED AREA.

This includes the ISFSI located within the PROTECTED AREA.

This EAL addresses the contingency for a very rapid progression of events, such as that experienced on September 11, 2001. It is not premised solely on the potential for a radiological release. Rather the issue includes the need for rapid assistance due to the possibility for significant and indeterminate damage from additional air, land or water attack elements.

The fact that the site is under serious attack with minimal time available for further preparation or additional assistance to arrive requires Off-site'Response Organization readiness and preparation for the implementation of protective measures.

This EAL addresses the potential for a very rapid progression of events due to a HOSTILE ACTION. It is not intended to address incidents that are accidental events or acts of civil disobedience, such as small aircraft impact, hunters, or physical disputes between employees within the PROTECTED AREA. Those events are adequately addressed by other EALs.

Although nuclear plant security officers are well trained and prepared to protect against HOSTILE ACTION, it is appropriate for Off-site Response Organizations to be notified and encouraged to begin preparations for public protective actions (if they do not normally) to be better prepared should it be necessary to consider further actions.

If not previously notified by NRC that the airborne HOSTILE ACTION was intentional, then it would be expected, although not certain, that notification by an appropriate Federal agency would follow. In this case, appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. However, the declaration should not be unduly delayed awaiting Federal notification.

Escalation of this emergency classification level, if appropriate, would be based on actual plant status after impact or progression of attack.

TBD-EPIP-OSC-1 H Reference Use Page 27 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONSAFFECTING PLANT SAFETY GENERAL EMERGENCY HG1 Initiating Condition -

HOSTILE ACTION resulting in loss of physical control of the facility.

Operating Mode Applicability:

1 2 3 4 5 D Emergency Action Level: 1OR2 I

1. A HOSTILE ACTION has occurred such that plant personnel are unable to operate equipment required to maintain safety functions.

2. A HOSTILE ACTION has caused failure of Spent Fuel Cooling Systems and IMMINENT fuel damage is likely for a freshly off-loaded reactor core in pool.

Basis:

EAL #1 encompasses conditions under which a HOSTILE FORCE has taken physical control of VITAL AREAs (containing vital equipment or controls of vital equipment) required to maintain safety functions and control of that equipment cannot be transferred to and operated from another location. These safety functions are reactivity control, RCS inventory, and RCS and Core Heat Removal. If control of the plant equipment necessary to maintain safety functions can be transferred to another location, then the above initiating condition is not met.

Loss of physical control of the control room or remote shutdown capability alone may not prevent the ability to maintain safety functions per se. Design of the remote shutdown capability and the location of the transfer switches should be taken into account. If control of the plant equipment necessary to maintain safety functions can be transferred to another location, then the threshold is not met.

EAL #2 addresses failure of spent fuel cooling systems as a result of HOSTILE ACTION if IMMINENT fuel damage is likely, such as when a freshly off-loaded reactor core is in the spent fuel pool.

A freshly off-loaded reactor core is defined as fuel that has been discharged within the previous 365 days. This definition is from RE-AD-0006.

TBD-EPIP-OSC-1 H Reference Use Page 28 of 28 Recognition Category H - Hazards and Other Rev. 1 Conditions Affecting Plant Safety HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY GENERAL EMERGENCY HG2 Initiating Condition -

Other conditions exist which in the judgment of the Command and Control position warrant declaration of General Emergency.

Operating Mode Applicability:

1 2 3 4 5 D II Emergency Action Level: 1

1. Other conditions exist which in the judgment of the Command and Control position indicate that events are in process 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.

Basis:

This EAL is intended to address unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Command and Control position to fall under the General Emergency class.