LIC-14-0098, License Amendment Request 14-06 to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors

License Amendment Request 14-06 to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors

ML14365A123
Person / Time
Site:	Fort Calhoun
Issue date:	12/26/2014
From:	Cortopassi L Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
LIC-14-0098, NEI 99-01, Rev 6
Download: ML14365A123 (349)

Text

th 444 South 16 Street Mall Omaha, NE 68102-2247 LIC-14-0098 10 CFR 50.90 10 CFR 50, Appendix E 10 CFR 50.4 December 26, 2014 U. S. Nuclear Regular Commission Document Control Desk Washington, DC 20555 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285 Fort Calhoun Station Independent Spent Fuel Storage Installation NRC Docket No.72-054

Subject:

License Amendment Request 14-06 to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors"

References:

1. Letter from Mark Thaggard (U.S. Nuclear Regulatory Commission) to Susan Perkins-Grew (Nuclear Energy Institute) - U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 6, November 2012, dated March 28, 2013

2. NRC Regulatory Issue Summary (RIS) 2005-02, Revision 1, "Clarifying the Process for Making Emergency Plan Changes," dated August 19, 2011 In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Omaha Public Power District (OPPD) requests an amendment to the license for Fort Calhoun Station, Unit No. 1.

Specifically, the proposed change involves revising the Emergency Plan for Fort Calhoun Station to adopt the Nuclear Energy Institute's (NEI's) revised Emergency Action Level (EAL) scheme described in NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, which have been endorsed by the Nuclear Regulatory Commission (NRC) as documented in Reference 1.

10 CFR 50, Appendix E, Section IV.B.2 stipulates that a licensee desiring to change its entire EAL scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change. Regulatory Issue Summary 2005-02, Revision 1 (Reference 2) also indicates that a revision to an entire EAL scheme, from NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, to another NRC-endorsed EAL scheme, must be submitted for prior NRC approval as specified in Section IV.B of Appendix E to 10 CFR 50.

Employment with Equal Opportunity

U.S. Nuclear Regulatory Commission LlC-14-0098 Page 2 Therefore, pursuant to 10 CFR 50.90, OPPD hereby requests NRC review and approval of revisions to Emergency Plan EALs for Fort Calhoun Station, Unit No.1.

OPPD's currently approved Emergency Plan EAL scheme is based on the guidance established in NEI 99-01, Revision 5, "Methodology for Development of Emergency Action Levels." OPPD is proposing to adopt an EAL scheme based on the latest NRC-endorsed guidance, which is described in NEI 99-01, Revision 6. provides an evaluation of the proposed changes. Attachment 2 provides additional supporting information related to the Fort Calhoun Station Radiological Emergency Plan Annex. The information contained in Attachment 2 includes the following:

• EAL Comparison Matrix Document

• EAL Red-Line Basis Document

• EAL Basis Document The proposed changes contained in this submittal have been reviewed by the Fort Calhoun Station Plant Review Committee (PRC).

OPPD requests approval of the proposed changes by January 1, 2016, with an implementation period of 90 days. There are no regulatory commitments contained in this submittal.

Pursuant to 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b),

OPPD is notifying the State of Nebraska of this application for license amendment by transmitting a copy of this letter and its supporting attachments to the designated state official.

If you have any questions concerning this submittal, please contact Mr. Eric Plautz at (402) 533-7308.

I declare under penalty of perjury that the foregoing is true and correct. Executed on December 26, 2014.

Respectfully, Louis P. Cortopassi Site Vice President and CNO Attachments: 1. Evaluation of Proposed Changes

2. Discussion of Revision to the Radiological Emergency Plan Annex for Fort Calhoun Station

• Enclosure 2A - EAL Comparison Matrix Document

• Enclosure 2B - EAL Red-Line Basis Document

• Enclosure 2C - EAL Basis Document c: M. L. Dapas, NRC Regional Administrator, Region IV C. F. Lyon, NRC Senior Project Manager S. M. Schneider, NRC Senior Resident Inspector Director of Consumer Health Services, Department of Regulation and Licensure, Nebraska Health and Human Services, State of Nebraska

LIC-14-0098 Page 1 EVALUATION OF PROPOSED CHANGES

Subject:

License Amendment Request 14-06 to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors 1.0

SUMMARY

DESCRIPTION

2.0 BACKGROUND

3.0 DETAILED DESCRIPTION

5.0 REGULATORY EVALUATION

5.1 Applicable Regulatory Requirements/Criteria 5.2 Precedent 5.3 No Significant Hazards Consideration 5.4 Conclusions

7.0 REFERENCES

LIC-14-0098 Page 2 1.0

SUMMARY

DESCRIPTION The Omaha Public Power District (OPPD) is requesting an amendment to Renewed Facility Operating License No. DPR-40 for Fort Calhoun Station, Unit No. 1.

The proposed change involves revising OPPDs currently approved Emergency Plan, Emergency Action Level (EAL) scheme, which is based on the Nuclear Energy Institute's (NEI's) guidance established in NEI 99-01, Revision 5, Methodology for Development of Emergency Action Levels.

OPPD is proposing to adopt an EAL scheme based on the guidance provided in NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, (Reference 3),

which has been endorsed by the NRC (Reference 1).

The proposed EAL changes were reviewed considering the requirements of 10 CFR 50.54(q),

paragraph (b) of 10 CFR 50.47, Emergency plans, 10 CFR 50 Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, Regulatory Issue Summary (RIS) 2003-18, Use of NEI 99-01, Methodology for Development of Emergency Action Levels (including supporting supplements), and RIS 2005-02, Revision 1, Clarifying the Process for Making Emergency Plan Changes. The proposed changes to the EAL scheme contained in this submittal do not reduce the capability to meet the applicable emergency planning requirements established in 10 CFR 50.47 and 10 CFR 50, Appendix E. Adopting NEI 99-01, Revision 6 will continue to provide consistent emergency classifications.

10 CFR 50, Appendix E, Section IV.B.2 requires prior NRC approval when a licensee is changing from one NRC-approved EAL scheme to another EAL scheme.

2.0 BACKGROUND

NEI 99-01, Revision 6 addresses lessons-learned since the implementation of NEI 99-01, Revision 5. In February 2008, NEI published NEI 99-01, Revision 5, in order to clarify the development guidance for numerous EALs, and enhance the guidance associated with the development of security-related EALs. In November 2012, NEI published NEI 99-01, Revision

6. The NRC formally endorsed the NEI 99-01, Revision 6, guidance as documented in a letter dated March 28, 2013 (Reference 1).

NEI 99-01, Revision 6, represents the most recently accepted EAL methodology endorsed by the NRC. The latest revision addresses changes recommended by the NRC in a letter to NEI on October 12, 2010, along with many enhancements identified by the industry during implementation of Revision 5. These enhancements include:

1. Revising EAL Basis format (Sections 5.5 through 5.11) to separate Developer Notes from Technical Basis Information.

2. Revising EAL Basis (under proposed Developer Notes) to clarify how specific instrumentation, alarms, or readings should be developed.

3. Clarifying where site-specific definitions are required (e.g., CONTAINMENT CLOSURE).

4. Clarifying or proposing alternatives on the seismic and fire EALs for licensees where licensees may not have adequate instrumentation to ensure timely classification from within the Control Room.

LIC-14-0098 Page 3

5. Revising NEI 99-01 guidance information to include a section for development of EALs applicable to new "non-passive" designs (e.g., digital instrument and controls, etc.).

6. Revising front sections of the NEI 99-01 document to eliminate redundancy and inconsistency and to clearly differentiate between information that is useful for understanding how the document was put together and information that is expected to be carried over into a licensees technical basis document.

7. Conducting a review of all Unusual Events (UEs) to determine if they should be revised/eliminated or added to include a discussion of any revision proposals for the corresponding Alerts. (Note: this is primarily for events that are based upon situations where emergency response organization activation is the goal rather than a precursor to escalated EALs.)

3.0 DETAILED DESCRIPTION The proposed changes involve revising OPPDs EAL scheme that is currently based on NEI 99-01, Revision 5, to a scheme based on NEI 99-01, Revision 6, which has been endorsed by the NRC (Reference 1). Enhancements over earlier revision guidance (i.e., NEI 99-01, Revision 5) include:

1. Clarifying numerous EALs that have been typically misinterpreted by the industry in the development of their site-specific EAL scheme.

2. Clarifying the intent of EALs that have been historically misclassified.

3. Incorporating lessons-learned from industry events (i.e., Fukushima and others) and NUREG/CR-7154, Risk Informing Emergency Preparedness Oversight: Evaluation of Emergency Action Levels - A Pilot Study of Peach Bottom, Surry and Sequoyah.

4. Performing a detailed review of the guidance to re-validate that the EALs are appropriate and are at the necessary emergency classification level based upon 32 years of industry and NRC experience with EAL scheme development and implementation.

Comparison Matrix A Comparison Matrix has been developed that provides a tabular format of the Initiating Conditions (ICs), Mode Applicability, and EALs (Threshold Values) in NEI 99-01, Revision 6 along with the proposed EALs. The matrix provides a means of assessing the proposed EAL in terms of Differences and Deviations from the NRC-endorsed guidance provided in NEI 99-01, Revision

6. The Comparison Matrix for Fort Calhoun Station is included in Attachment 2, Enclosure 2A.

The proposed EAL changes were evaluated in accordance with applicable regulatory requirements (e.g., 10 CFR 50.54(q) and Appendix E,Section IV.B.1). The evaluation assessed the conformance of the proposed EAL changes to those described in the NEI 99-01, Revision 6 guidance. The evaluation determined if the proposed EAL wording change resulted in No Change to the guidance, a Difference in the wording provided, or a Deviation from the NEI guidance contained in Revision 6.

Any items considered to be Differences or Deviations were based on the definitions provided in RIS 2003-18, Use of NEI 99-01, Methodology for Development of Emergency Action Levels, and

LIC-14-0098 Page 4 supporting supplements (References 4, 5, and 6). The RIS and supporting supplements were issued to clarify technical positions regarding the revision of EALs. Specifically, the RIS documentation provides clarification on the level of detail licensees need to provide to support proposed changes to EALs. The RIS documents suggest that specific information be included with the EAL revision submittal to help facilitate the review process. The RIS information defines an EAL Difference and Deviation as follows:

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

A Deviation is an EAL change where the basis scheme guidance differs in wording and is altered in meaning or intent, such that classification of the event could be different between the basis scheme guidance and the site-specific proposed EAL. Examples of Deviations include the use of altered mode applicability, altering key words or time limits, or changing words of physical reference (protected area, safety-related equipment, etc.).

Any Differences identified between the NEI 99-01, Revision 6 EALs as approved by the NRC and the proposed EALs being developed by OPPD in accordance with NEI 99-01, Revision 6, have been identified and are listed in the Comparison Matrix (Attachment 2, Enclosure 2A) as well as the Global Differences listed below.

Global Differences The following Differences apply throughout the set of EALs and are not specifically identified as Differences in the Comparison Matrix:

1. The NEI phrase Notification of Unusual Event has been changed to Unusual Event to sustain common OPPD terminology.

2. To the extent possible, IC and EAL identification numbering has been retained from the existing EALs.

3. The following phrases were changed in EAL threshold values for brevity:

Greater Than is presented symbolically as: >

Less Than is presented symbolically as: <

Greater Than or Equal To is presented symbolically as:

Less Than or Equal To is presented symbolically as:

4. Numerical values, signs, and key words of Threshold Values may be bolded for emphasis.

5. NEI ICs and EALs (Fission Product Barrier Threshold) which contain and/or connectors are separated into logic statements AND, OR, or EITHER where appropriate to be consistent with the applicable stations EAL presentation scheme.

6. NEI utilizes Notes related to EALs that contain a time qualifier:

Example:

Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.

LIC-14-0098 Page 5 The Notes used would apply to the various types of events (i.e., General Emergency, Site Area Emergency, Alert, or Unusual Event) and would delineate the time qualifier for the specific EALs.

The applicable Notes have been revised for clarity as follows:

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

The rewording for clarity did not alter or change the intent of the Note.

OPPD determined that these Differences do not result in a reduction in effectiveness or change the intent of the new NEI 99-01, Revision 6 EALs.

Any plant EAL (IC or Threshold Value) that does not meet the intent of the NEI 99-01, Revision 6 guidance, or may result in an event being classified differently from the guidance, would be identified as a Deviation. The evaluation determined that there are no Deviations in converting from the existing EALs based on NEI 99-01, Revision 5 as currently approved, to an EAL scheme based on the NEI 99-01, Revision 6 guidance.

The Fort Calhoun Station Emergency Plan Annex contains the stations EALs. The proposed EAL changes are discussed in Attachment 2.

4.0 TECHNICAL EVALUATION

The proposed changes have been evaluated to determine whether applicable regulations and requirements continue to be met. NEI 99-01 guidance methodology includes many years of development along with use and implementation. The guidance has been subject to NRC reviews and approval. The OPPD EAL scheme currently in place for Fort Calhoun Station is based on the EAL methodology outlined in NEI 99-01, Revision 5. NEI 99-01, Revision 6 is the latest guidance endorsed by the NRC and provides guidance to nuclear power plant operators for the development of a site-specific emergency classification scheme.

10 CFR 50.47(b)(4) stipulates that Emergency Plans include a standard emergency classification and action level scheme. This scheme is a fundamental component of an Emergency Plan, in that it provides the defined thresholds that will allow site personnel to rapidly implement a range of pre-planned emergency response measures. An emergency classification scheme also facilitates timely decision-making by an Offsite Response Organization (ORO) concerning the implementation of precautionary or protective actions for the public.

NEI 99-01, Revision 6 contains a set of generic ICs, EALs, and fission product barrier status thresholds. It also includes supporting technical basis information, developer notes, and recommended classification instructions for users. The methodology described in this document is consistent with NRC requirements and guidance. In particular, this methodology was specifically endorsed by the NRC as documented in a March 28, 2013, letter (Reference 1) and determined to provide an acceptable approach in meeting the requirements of 10 CFR 50.47(b)(4), applicable requirements of 10 CFR 50, Appendix E, and the associated planning standard evaluation elements established in NUREG-0654/ FEMA-REP-1, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, dated November 1980.

10 CFR 50, Appendix E, Section IV.B.2 stipulates that a licensee desiring to change its entire EAL scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change. RIS 2005-02, Revision 1 (Reference 2) also

LIC-14-0098 Page 6 indicates that a revision to an entire EAL scheme, from NUREG-0654, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, to another NRC-endorsed EAL scheme, must be submitted for prior NRC approval as specified in Section IV.B of Appendix E to 10 CFR 50.

The proposed changes to the EAL scheme for adopting the NEI 99-01, Revision 6 guidance do not reduce the capability to meet the applicable emergency planning requirements established in 10 CFR 50.47 and 10 CFR 50, Appendix E.

The proposed changes to adopt the NEI 99-01, Revision 6, EAL scheme will continue to provide consistent emergency classifications. Changes to OPPD's Emergency Plan for Fort Calhoun Station, and procedures resulting from implementation of revised EALs will be evaluated in accordance with the requirements of 10CFR 50.54(q), subsequent to NRC approval.

Accordingly, pursuant to the requirements of 10 CFR 50, Appendix E, Section IV.B.2, OPPD requests NRC review and approval of the proposed changes to the EAL scheme as a license amendment request for Fort Calhoun Station and Renewed Facility Operating License No.

DPR-40 in accordance with 10 CFR 50.90.

5.0 REGULATORY EVALUATION

5.1 Applicable Regulatory Requirements/Criteria The proposed changes have been evaluated to determine whether applicable regulations and requirements continue to be met.

The regulations in 10 CFR 50.54(q) provide direction to licensees seeking to revise their Emergency Plan. The requirements related to nuclear power plant Emergency Plans are given in the standards in 10 CFR 50.47, Emergency plans, and the requirements of Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, to 10 CFR 50.

Paragraph (a)(1) to 10 CFR 50.47 states that no operating license for a nuclear power reactor will be issued unless a finding is made by the NRC that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.

Section 50.47 establishes standards that onsite and offsite emergency response plans must meet for the NRC staff to make a positive finding that there is reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.

One of these standards, 10 CFR 50.47(b)(4), stipulates that Emergency Plans include a standard emergency classification and action level scheme.

Section IV.B, Assessment Actions, to 10 CFR 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities, stipulates that Emergency Plans include EALs, which are to be used as criteria for determining the need for notification and participation of local and State agencies, and for determining when and what type of protective measures should be considered to protect the health and safety of individuals both onsite and offsite.

EALs are to be based on plant conditions and instrumentation, as well as onsite and offsite radiological monitoring.Section IV.B of Appendix E provides that initial EALs shall be discussed and agreed on by the applicant and State and local authorities, be approved by the NRC, and reviewed annually thereafter with State and local authorities. Therefore, a revision will require NRC approval prior to implementation if it involves: 1) changing from one EAL scheme to another, such as from an EAL scheme based on NUREG-0654/FEMA-REP-1 to one based on

LIC-14-0098 Page 7 NUMARC/NESP-007 or NEI 99-01; 2) the licensee is proposing an alternate method for complying with the regulations; or 3) the EAL revision proposed by the licensee decreases the effectiveness of the Emergency Plan.

NRC RIS 2005-02, Revision 1, Clarifying the Process for Making Emergency Plan Changes, (Reference 2) issued in August 2009, also discusses that a change in an EAL scheme to incorporate the improvements provided in NUMARC/NESP-007 or NEI 99-01 would not decrease the overall effectiveness of the EP and would not expand a licensees operating authority beyond that previously authorized by NRC. However, due to the potential safety significance of the change, the change needs prior NRC review and approval. This approval would be granted via an NRC letter and supporting Safety Evaluation Report (SER).

Fort Calhoun Station was licensed for construction prior to May 21, 1971, and at that time committed to the draft General Design Criteria (GDC), which are described in Appendix G of the Updated Safety Analysis Report (USAR). OPPD has determined that the proposed changes do not require any exemptions or relief from regulatory requirements and do not affect conformance with the draft GDC.

5.2 Precedent Many licensees have adopted NEI guidance. On May 30, 2014, Exelon Generation Company submitted a request (Reference 7) to adopt NEI 99-01, Revision 6 guidance for their plants. In December 2012, Beaver Valley Power Station received approval (Reference 8) for an EAL scheme transition from NUMARC/ NESP-007 to NEI 99-01, Revision 5 guidance.

5.3 No Significant Hazards Consideration In accordance with 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit, the Omaha Public Power District (OPPD) requests an amendment to Renewed Facility Operating License No. DPR-40 for Fort Calhoun Station, Unit No. 1 to support the adoption of an Emergency Action Level (EAL) scheme based on NEI 99-01, Revision 6, which has been endorsed by the NRC as documented in a letter dated March 28, 2013 (Reference 1).

The proposed changes to OPPDs EAL scheme to adopt the guidance in NEI 99-01, Revision 6 does not reduce the capability to meet the emergency planning requirements established in 10 CFR 50.47 and 10 CFR 50, Appendix E. The proposed changes do not reduce the functionality, performance, or capability of OPPDs Emergency Response Organization (ERO) to respond in mitigating the consequences of accidents. All OPPD ERO functions will continue to be performed as required.

The proposed changes have been reviewed considering the applicable requirements of 10 CFR 50.47, 10 CFR 50, Appendix E, and other applicable NRC documents. OPPD has evaluated the proposed changes to the Fort Calhoun Station, Unit No. 1 Emergency Plan and determined that the changes do not involve a Significant Hazards Consideration. In support of this determination, an evaluation of each of the three (3) standards, set forth in 10 CFR 50.92, Issuance of amendment, is provided below.

LIC-14-0098 Page 8

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

Response: No.

The proposed changes to OPPDs EAL scheme to adopt the NRC-endorsed guidance in NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, do not reduce the capability to meet the emergency planning requirements established in 10 CFR 50.47 and 10 CFR 50, Appendix E. The proposed changes do not reduce the functionality, performance, or capability of OPPDs ERO to respond in mitigating the consequences of any design basis accident.

The probability of a reactor accident requiring implementation of Emergency Plan EALs has no relevance in determining whether the proposed changes to the EALs reduce the effectiveness of the Emergency Plans. As discussed in Section D, Planning Basis, of NUREG-0654, Revision 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants; The overall objective of emergency response plans is to provide dose savings (and in some cases immediate life saving) for a spectrum of accidents that could produce offsite doses in excess of Protective Action Guides (PAGs). No single specific accident sequence should be isolated as the one for which to plan because each accident could have different consequences, both in nature and degree. Further, the range of possible selection for a planning basis is very large, starting with a zero point of requiring no planning at all because significant offsite radiological accident consequences are unlikely to occur, to planning for the worst possible accident, regardless of its extremely low likelihood Therefore, OPPD did not consider the risk insights regarding any specific accident initiation or progression in evaluating the proposed changes.

The proposed changes do not involve any physical changes to plant equipment or systems, nor do they alter the assumptions of any accident analyses. The proposed changes do not adversely affect accident initiators or precursors nor do they alter the design assumptions, conditions, and configuration or the manner in which the plant is operated and maintained.

The proposed changes do not adversely affect the ability of Structures, Systems, or Components (SSCs) to perform their intended safety functions in mitigating the consequences of an initiating event within the assumed acceptance limits.

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

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

Response: No.

The proposed changes to OPPDs EAL scheme to adopt the NRC-endorsed guidance in NEI 99-01, Revision 6, do not involve any physical changes to plant systems or equipment.

The proposed changes do not involve the addition of any new plant equipment. The proposed changes will not alter the design configuration, or method of operation of plant

LIC-14-0098 Page 9 equipment beyond its normal functional capabilities. All OPPD ERO functions will continue to be performed as required. The proposed changes do not create any new credible failure mechanisms, malfunctions, or accident initiators.

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

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

Response: No.

The proposed changes to OPPDs EAL scheme to adopt the NRC-endorsed guidance in NEI 99-01, Revision 6, do not alter or exceed a design basis or safety limit. There is no change being made to safety analysis assumptions, safety limits, or limiting safety system settings that would adversely affect plant safety as a result of the proposed change. There are no changes to setpoints or environmental conditions of any SSC or the manner in which any SSC is operated. Margins of safety are unaffected by the proposed changes to adopt the NEI 99-01, Revision 6, EAL scheme guidance. The applicable requirements of 10 CFR 50.47 and 10 CFR 50, Appendix E will continue to be met.

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

5.4 Conclusions In conclusion, and based on the considerations discussed above: (1) there is reasonable assurance that the health and safety of the public will not be endangered by the proposed changes to adopt the EAL scheme established in NEI 99-01, Revision 6, as endorsed by the U.S. Nuclear Regulatory Commission (NRC); (2) the changes will be in compliance with the NRCs 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.

6.0 ENVIRONMENTAL CONSIDERATION

The proposed changes are applicable to emergency planning requirements involving the proposed adoption of NRC-approved EAL guidance as described in NEI- 99-01, Revision 6 and do not reduce the capability to meet the emergency planning standards established in 10 CFR 50.47 and 10 CFR 50, Appendix E. The proposed changes do 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 the individual or cumulative occupational radiation exposure. Accordingly, the proposed changes meet 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 change.

7.0 REFERENCES

1) Letter from Mark Thaggard (U.S. Nuclear Regulatory Commission) to Susan Perkins-Grew (Nuclear Energy Institute) - U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 6, November 2012, dated March 28, 2013

LIC-14-0098 Page 10

7.0 REFERENCES

(Continued)

2) RIS 2005-02, Revision 1, Clarifying the Process for Making Emergency Plan Changes, dated August 19, 2011

3) NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, dated November 2012

4) RIS 2003-18, Use of NEI 99-01, Methodology for Development of Emergency Action Levels, dated October 8, 2003

5) RIS 2003-18, Supplement 1, Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels, dated July 13, 2004

6) RIS 2003-18, Supplement 2, Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels, dated December 12, 2005

7) Letter from Exelon (J. Barstow) to NRC (Document Control Desk), License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors, dated May 30, 2014 (ML14164A054)

8) Beaver Valley Power Station, Unit Nos. 1 and 2 - Approval of Emergency Action Level Scheme Change to a Scheme Based On Nuclear Energy Institute 99-01, Revision 5 (TAC Nos. ME7823 AND ME7824) dated December 4, 2012 (ML12313A340)

LIC-14-0098 Page 1 DISCUSSION OF REVISION TO THE RADIOLOGICAL EMERGENCY PLAN ANNEX FOR FORT CALHOUN STATION EP-FC-1001

Enclosures:

A - EAL Comparison Matrix Document B - EAL Red-Line Basis Document C - EAL Basis Document

LIC-14-0098 A EAL Comparison Matrix Document

NEI 99-01 Rev 6 Proposed EAL Justification AG1 RG1 No Change X Difference Deviation Initiating Condition - GENERAL EMERGENCY Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mRem TEDE or 1) Listed site-specific monitors and Threshold values to ensure timely 1,000 mrem TEDE or 5,000 mrem thyroid CDE. 5,000 mRem thyroid CDE. classification.

Operating Mode Applicability: All Operating Mode Applicability:

2) Added "Classification based on effluent monitor readings assumes that a 1, 2, 3, 4, 5, D release path to the environment is established." To the third bullet in order to Example Emergency Action Levels: (1 or 2 or 3) Emergency Action Levels (EAL) : delete the following from the basis section " Classification based on effluent monitor readings assumes that a release path to the environment is Notes: Notes: established. If the effluent flow past an effluent monitor is known to have The Emergency Director should declare the General Emergency The Emergency Director should declare the event promptly upon determining that the stopped due to actions to isolate the release path, then the effluent monitor promptly upon determining that the applicable time has been applicable time has been exceeded, or will likely be exceeded. reading is no longer valid for classification purposes." This allows for more exceeded, or will likely be exceeded. timely classification since all the basis information pertaining to Note bullet 3 If an ongoing release is detected and the release start time is unknown, assume that the will be contained in the IC and therefor readily available on the 11x17 If an ongoing release is detected and the release start time is release duration has exceeded 15 minutes. procedure matrix used by the SM.

unknown, assume that the release duration has exceeded 15 Classification based on effluent monitor readings assumes that a release path to the minutes.

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

reading is no longer valid for classification purposes.

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

results from a dose assessment using actual meteorology are available.

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

1. Reading on any of the following radiation monitors greater than OR the reading shown for 15 minutes or longer: 2. Dose assessment Using actual meteorology indicates doses at or beyond the site boundary of EITHER:

(site specific monitor list and threshold values) a. > 1000 mRem TEDE OR

2. Dose assessment actual meteorology indicates doses greater b. > 5000 mRem CDE Thyroid than 1000 mrem TEDE or 5000 mrem thyroid CDE at or beyond OR (site specific dose receptor point)

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

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

3. Field survey results indicate EITHER of the following at or 60 minutes.

beyond (site specific dose receptor point):

OR Closed window dose rates greater than 1000 mR/hr expected to continue for 60 minutes or longer. b. Analyses of field survey samples indicate > 5000 mRem CDE Thyroid for 60 minutes of inhalation.

Analysis of field survey samples indicate thyroid CDE greater than 5000 mrem for one hour of inhalation. Table R1 Effluent Monitor Thresholds Effluent Monitor Description General Emergency RM-063 AB Stack 3.71E+00 uCi/cc (Post Accident Gas)

Page 1 of 67

NEI 99-01 Rev 6 Proposed EAL Justification AS1 RS1 No Change X Difference Deviation Initiating Condition - SITE AREA EMERGENCY Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 1) Listed site-specific monitors and Threshold values to ensure timely classification.

100 mrem TEDE or 500 mrem thyroid CDE. Release of gaseous radioactivity resulting in offsite dose greater than 100 mRem TEDE or 500 mRem thyroid CDE.

Operating Mode Applicability: All Operating Mode Applicability: 2) Added "Classification based on effluent monitor readings assumes that a release path to the environment is established." To the third bullet in order to delete the 1, 2, 3, 4, 5, D following from the basis section " Classification based on effluent monitor readings Example Emergency Action Levels: (1 or 2 or 3)

Emergency Action Levels (EAL) : assumes that a release path to the environment is established. If the effluent flow past Notes: an effluent monitor is known to have stopped due to actions to isolate the release Notes: path, then the effluent monitor reading is no longer valid for classification purposes."

The Emergency Director should declare the General Emergency promptly upon determining that the applicable time has been The Emergency Director should declare the event promptly upon determining that the This allows for more timely classification since all the basis information pertaining to exceeded, or will likely be exceeded. applicable time has been exceeded, or will likely be exceeded. Note bullet 3 will be contained in the IC and therefor readily available on the 11x17 procedure matrix used by the SM.

If an ongoing release is detected and the release start time is If an ongoing release is detected and the release start time is unknown, assume that unknown, assume that the release duration has exceeded 15 the release duration has exceeded 15 minutes.

minutes.

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

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

available.

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

OR

1. .Reading on any of the following radiation monitors greater than 2. Dose assessment using actual meteorology indicates doses at or beyond the site the reading shown for 15 minutes or longer: boundary of EITHER:

a. > 100 mRem TEDE OR (site specific monitor list and threshold values) b. > 500 mRem CDE Thyroid OR

2. Dose assessment actual meteorology indicates doses greater 3. Field survey results at or beyond the site boundary indicate EITHER:

than 1000 mrem TEDE or 5000 mrem thyroid CDE at or beyond a. Gamma (closed window) dose rates >100 mR/hr are expected to (site specific dose receptor point) continue for > 60 minutes.

OR

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

3. Field survey results indicate EITHER of the following at or 60 minutes of inhalation.

beyond (site specific dose receptor point): Table R1 Effluent Monitor Thresholds Closed window dose rates greater than 100 mR/hr Effluent Monitor Description Site Area Emergency expected to continue for 60 minutes or longer.

3.70E-01 uCi/cc RM-063 AB Stack (Post Accident Gas)

Analysis of field survey samples indicate thyroid CDE greater than 500 mrem for one hour of inhalation.

RM-052 AB Stack (Gas) 8.30E+06 cpm RM-043 LRWPB Stack (Gas) 7.26E+06 cpm Page 2 of 67

NEI 99-01 Rev 6 Proposed EAL Justification AA1 RA1 No Change X Difference Deviation Initiating Condition - ALERT Initiating Condition:

Release of gaseous or liquid radioactivity resulting in offsite dose greater Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem 1) Listed site-specific monitors and Threshold values to ensure timely classification.

than 10 mrem TEDE or 50 mrem thyroid CDE. TEDE or 50 mrem thyroid CDE.

Operating Mode Applicability: All Operating Mode Applicability: 2) Added "Classification based on effluent monitor readings assumes that a release path to the environment is established." To the third bullet in order to delete the 1, 2, 3, 4, 5, D following from the basis section "Classification based on effluent monitor readings Example Emergency Action Levels: (1 or 2 or 3) Emergency Action Levels (EAL) : assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, Note: Note: then the effluent monitor reading is no longer valid for classification purposes." This The Emergency Director should declare the event promptly upon determining that the allows for more timely classification since all the basis information pertaining to Note The Emergency Director should declare the Alert promptly upon applicable time has been exceeded, or will likely be exceeded. bullet 3 will be contained in the IC and therefor readily available on the 11x17 determining that the applicable time has been exceeded, or will procedure matrix used by the SM.

likely be exceeded. If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.

If an ongoing release is detected and the release start time is 3) Calculations were performed, in accordance with (IAW) guidance provided in NEI unknown, assume that the release duration has exceeded 15 Classification based on effluent monitor readings assumes that a release path to the 99-01 revision 6 EAL AA1, to determine the effluent monitor response for a radioactive minutes. environment is established. If the effluent flow past an effluent monitor is known to have liquid release and a WGDT release via the normal site release pathway. The release stopped due to actions to isolate the release path, then the effluent monitor reading is no If the effluent flow past an effluent monitor is known to have would contain activity equivalent to provide 10mrem TEDE or 50mrem thyroid CDE at longer valid for classification purposes.

stopped due to actions to isolate the release path, then the the site boundary. The calculation determined the effluent monitor responses would be effluent monitor reading is no longer valid for classification The pre-calculated effluent monitor values presented in EAL #1 should be used for >110% of the instruments maximum range and as such, IAW NEI 99-01 Rev 6 emergency classification assessments until the results from a dose assessment using guidance, was not included in this EAL.

purposes. actual meteorology are available.

The pre-calculated effluent monitor values presented in EAL #1 1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15 minutes.

should be used for emergency classification assessments until OR the results from a dose assessment using actual meteorology are 2. Dose assessment using actual meteorology indicates doses at or beyond the site available. boundary of EITHER:

a. > 10 mRem TEDE OR

1. Reading on any of the following radiation monitors greater than b. > 50 mRem CDE Thyroid the reading shown for 15 minutes or longer: OR

3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than EITHER of the following at or beyond the site boundary (site-specific monitor list and threshold values) a. 10 mRem TEDE for 60 minutes of exposure OR

b. 50 mRem CDE Thyroid for 60 minutes of exposure

2. Dose assessment actual meteorology indicates doses greater OR than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond (site specific dose receptor point) 4. Field survey results at or beyond the site boundary indicate EITHER:

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

3. Analysis of a liquid effluent sample indicates a concentration or 60 minutes.

release rate that would result in doses greater than 10 mrem OR TEDE or 50 mrem thyroid CDE at or beyond (site-specific doseb. b. Analyses of field survey samples indicate > 50 mRem CDE Thyroid for receptor point) for one hour of exposure. 60 minutes of inhalation.

4. Field survey results indicate EITHER of the following at or Table R1 Effluent Monitor Thresholds beyond (site specific dose receptor point):

Effluent Monitor Description Alert Closed window dose rates greater than 10 mR/hr expected to continue for 60 minutes or longer. RM-063 AB Stack (Post Accident Gas) 4.00E -02 uCi/cc Analysis of field survey samples indicate thyroid CDE RM-062 AB Stack (Gas) 7.00E+05 cpm greater than 50 mrem for one hour of inhalation.

RM-052 AB Stack (Gas) 8.30E+05 cpm RM-043 LRWPB Stack (Gas) 7.26E+05 cpm RM-057 Condenser Off-Gas 1.79E+08 cpm Page 3 of 67

NEI 99-01 Rev 6 Proposed EAL Justification AU1 RU1 No Change X Difference Deviation Initiating Condition - UNUSUAL EVENT Initiating Condition:

Release of gaseous or liquid radioactivity greater than 2 times the (site- Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 1) Listed site-specific monitors and Threshold values to ensure timely classification.

specific effluent release controlling document) limits for 60 minutes or minutes or longer.

longer 2) Added "Classification based on effluent monitor readings assumes that a release Operating Mode Applicability:

Operating Mode Applicability: All path to the environment is established." To the third bullet in order to delete the 1, 2, 3, 4, 5, D following from the basis section "Classification based on effluent monitor readings Emergency Action Levels (EAL) : assumes that a release path to the environment is established. If the effluent flow past Example Emergency Action Levels: (1 or 2 or 3 ) an effluent monitor is known to have stopped due to actions to isolate the release path, Note: then the effluent monitor reading is no longer valid for classification purposes." This Note: allows for more timely classification since all the basis information pertaining to Note The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded. bullet 3 will be contained in the IC and therefor readily available on the 11x17 The Emergency Director should declare the Alert promptly upon determining that 60 minutes has been exceeded, or will likely be procedure matrix used by the SM.

If an ongoing release is detected and the release start time is unknown, assume exceeded.

that the release duration has exceeded 60 minutes.

If an ongoing release is detected and the release start time is Classification based on effluent monitor readings assumes that a release path to unknown, assume that the release duration has exceeded 60 the environment is established. If the effluent flow past an effluent monitor is minutes.

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

stopped, indicating that the release path is isolated, the effluent monitor reading is no longer valid for classification purposes.

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

1. Reading on ANY effluent radiation monitor greater than 2 times 60 minutes.

the (site-specific effluent release controlling document) limits for 60 minutes or longer: OR (site-specific monitor list and threshold values corresponding 2. Readings on ANY Effluent Monitor > Table R3 value for > 60 minutes.

to 2 times the controlling document limits) OR

3. Confirmed sample analyses for gaseous or liquid releases indicate

2. Reading on ANY effluent radiation monitor greater than 2 times concentrations or release rates > 2 times ODCM Limit with a release duration of the alarm setpoint established by a current radioactivity > 60 minutes.

discharge permit for 60 minutes or longer.

3. Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times (site-specific effluent release controlling document limits) for 60 minutes or longer.

Page 4 of 67

Table R2 Effluent Monitor Thresholds Effluent Monitor Description 2X High Alarm RM-052 (aligned to Aux AB Stack (gas) 7.82E+04 cpm Building stack)

RM-062 AB Stack (gas) 6.60E+04 cpm RM-054A (if SG blowdown is not SG blowdown 9.86E+04 cpm isolated)

RM-054B (if SG blowdown is not SG blowdown 9.88E+04 cpm isolated)

RM-055 (if discharge not Liquid isolated) Minimum 1 CW 2.80E+06 cpm Discharge Header Pump RM-055 (if discharge not Liquid isolated) Minimum 2 RW 8.00E+05 cpm Discharge Header Pump Table R3 Effluent Monitor Thresholds Description Effluent Monitor Unusual Event RM-043 LRWPB Stack (gas) 6.60E+5 cpm RM-052 (aligned to Aux AB Stack (gas) 7.04E+05 cpm Building stack)

RM-062 AB Stack (gas) 6.37E+05 cpm RM-063 AB Stack (post accident 2.29E-03 uCi/cc gas)

RM-057** Condenser Off-gas 1.45E+08 cpm RM-054A SG Blowdown (if SG blowdown is not 9.86E+04 cpm isolated)

RM-054B SG Blowdown (if SG blowdown is not 9.88E+04 cpm isolated)

RM- 055 (if discharge is not Liquid Discharge isolated) Minimum 1CW Header 2.80E+06 cpm Pump RM-055 (if discharge is not Liquid Discharge isolated) Minimum 2 RW Header 8.00E+05 cpm Pump

• • 1.45E+08 is the upper range of the instrument Page 5 of 67

NEI 99-01 Rev 6 Proposed EAL Justification AG2 RG2 No Change X Difference Deviation Initiating Condition -- GENERAL EMERGENCY Spent fuel pool level cannot be restored to at least (site-specific Level 3 description) for 60 minutes or longer .

1) EAL not used in accordance with the discussion in Section 1.4, NRC Order EA-Operating Mode Applicability: All 12-051, it is recommended that this EAL be implemented when the enhanced spent fuel pool level instrumentation is available for use. The completion of the Example Emergency Action Levels: enhanced SFP level indicators and need for the inclusion of this EAL is being tracked in accordance with the Omaha Public Power Districts Initial Status Report NOTES: The Emergency Director should declare the General to March 12, 2012 Commission Order Modifying Licenses with Regard for Emergency promptly upon determining that 60 minutes has Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) dated been exceeded, or will likely be exceeded October 27, 2012.

1. Spent fuel pool level cannot be restored to at least (site-specific Level 3 description) for 60 minutes or longer.

Page 6 of 67

NEI 99-01 Rev 6 Proposed EAL Justification AS2 RS2 No Change X Difference Deviation Initiating Condition - SITE AREA EMERGENCY Spent fuel pool level cannot be restored to at least (site-specific Level 3 description) 1) EAL not used in accordance with the discussion in Section 1.4, NRC Order EA-12-051, it is recommended that this EAL be implemented when the enhanced Operating Mode Applicability: All spent fuel pool level instrumentation is available for use. The completion of the enhanced SFP level indicators and need for the inclusion of this EAL is being Example Emergency Action Levels: tracked in accordance with the Omaha Public Power Districts Initial Status Report to March 12, 2012 Commission Order Modifying Licenses with Regard for

1. Spent fuel pool level cannot be restored to at least (site-specific Level 3 Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) dated description) October 27, 2012.

Page 7 of 67

NEI 99-01 Rev 6 Proposed EAL Justification AA2 RA2 Initiating Condition - ALERT No Change X Difference Deviation Initiating Condition:

Significant lowering of water level above, or damage to, irradiated fuel.

Significant lowering of water level above, or damage to, irradiated fuel. 1) Listed site-specific monitors and Threshold values to ensure timely classification.

Operating Mode Applicability: All Operating Mode Applicability:

2) EAL #3 not used in accordance with the discussion in Section 1.4, NRC Order 1, 2, 3, 4, 5, D EA-12-051, it is recommended that this EAL be implemented when the enhanced Example Emergency Action Levels: (1 or 2 or 3 ) Emergency Action Levels (EAL) : spent fuel pool level instrumentation is available for use. The completion of the enhanced SFP level indicators and need for the inclusion of this EAL is being

1. Uncovery of irradiated fuel in the REFUELING PATHWAY. 1. Uncovery of irradiated fuel in the REFUELING PATHWAY. tracked in accordance with the Omaha Public Power Districts Initial Status Report OR to March 12, 2012 Commission Order Modifying Licenses with Regard for Reliable

2. Damage to irradiated fuel resulting in a release of radioactivity from the Spent Fuel Pool Instrumentation (Order Number EA-12-051) dated October 27, fuel as indicated by ANY of the following radiation monitors: 2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel 2012.

as indicated by ANY Table R4 Radiation Monitor reading >1000 mRem/hr (site-specific listing of radiation monitors, and the associated readings, setpoints and/or alarms)

Table R4 Radiation Monitors

3. Lowering of spent fuel pool level to (site-specific Level 2 value).

RMS Area Monitored RM-Containment Rad Monitor 73,74,75 RM-Auxiliary Building Rad Monitor 085,87 Portable Containment and auxiliary Building near Rad fuel handling areas Monitor Page 8 of 67

NEI 99-01 Rev 6 Proposed EAL Justification AU2 RU2 X No Change Difference Deviation Initiating Condition: UNUSUAL EVENT Initiating Condition:

UNPLANNED loss of water level above irradiated fuel UNPLANNED loss of water level above irradiated fuel

1) Listed site-specific level indication and monitors to ensure timely classification.

Operating Mode Applicability: All Operating Mode Applicability:

1, 2, 3, 4, 5, D Example Emergency Action Levels: Emergency Action Levels (EAL) :

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

1. a. UNPLANNED water level drop in the REFUELING PATHWAY.

AND (site-specific level indications).

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

AND Table R4 Radiation Monitors

b. UNPLANNED rise in area radiation levels as indicated by ANY of the RMS Area Monitored following radiation monitors.

RM-Containment Rad Monitor 73,74,75 (site-specific list of area radiation monitors)

RM-Auxiliary Building Rad Monitor 085,87 Portable Containment and auxiliary Building near Rad fuel handling areas Monitor Page 9 of 67

NEI 99-01 Rev 6 Proposed EAL Justification AA3 RA3 X No Change Difference Deviation Initiating Condition - ALERT Initiating Condition:

Radiation levels that impede access to equipment necessary for normal plant Radiation levels that impede access to equipment necessary for normal plant 1) Listed site specific plant rooms and areas with identified mode applicability to operations, cooldown or shutdown. operations, cooldown or shutdown. ensure timely classification.

Operating Mode Applicability: All Operating Mode Applicability:

1, 2, 3, 4, 5, D Example Emergency Action Levels: (1 or 2) Emergency Action Levels (EAL) :

Note: If the equipment in the listed room or area was already inoperable, or out Note: If the equipment in the room or area listed in Table R7 was already inoperable, of service, before the event occurred, then no emergency classification is or out of service, before the event occurred, then no emergency classification is warranted warranted

1. Dose rate greater than 15 mR/hr in ANY of the following areas: 1. Dose rate greater than 15 mR/hr in ANY of the areas contained in Table R6:

• Control Room

• Central Alarm Station Table R6

• (other site-specific areas/rooms)

Areas Requiring Continuous Occupancy

2. An UNPLANNED event results in radiation levels that prevent or Main Control Room significantly impede access to any of the following plant rooms or areas: Central Alarm Station (CAS)

(site-specific list of plant rooms or areas with entry-related mode applicability identified)

OR

2. UNPLANNED event results in radiation levels that prohibit or significantly impede access to any of the following Table R7 plant rooms or areas:

Table R7 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Containment* Modes 3 through 4, and 5 Auxiliary Building* Modes 3 through 4, and 5

• Areas required to establish shutdown cooling Page 10 of 67

NEI 99-01 Rev 6 Proposed EAL Justification SU3 RU3 No Change X Difference Deviation Initiating Condition: UNUSUAL EVENT Initiating Condition:

Reactor coolant activity greater than Technical Specification allowable limits. Reactor coolant activity greater than Technical Specification allowable limits. 1) Listed site-specific monitor and threshold value to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability:

2) Listed this system category EAL in the radiological category EAL section to Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 maintain consistency with previous revisions of OPPD EALs. This will ensure a timely classification since the threshold values are more aligned with the Example Emergency Action Levels: Emergency Action Levels (EAL):

radiological category vice system category.

1. (Site-specific radiation monitor) reading greater than (site-specific value). 1. Dose rate on Contact on the primary sample piping immediately adjacent to the Sample Hood (SL-1) is > 4R/hr.

OR OR

2. Sample analysis indicates that a reactor coolant activity value is greater than an allowable limit specified in Technical Specifications. 2. Sample analysis indicates that:

a. Dose Equivalent I-131 specific coolant activity > 1.0 uCi/gm for more than 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> during one continuous time interval OR >

60 uCi/gm.

OR

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

Page 11 of 67

NEI 99-01 rev 6 Fission Product Barrier Matrix Fission Product Barrier Matrix Hot Matrix GENERAL EMERGENCY SITE AREA EMERGENCY ALERT FG1 Loss of any two barriers AND Loss or Potential Loss of third barrier. 1,2,3 FS1 Loss or Potential Loss of ANY two barriers. 1,2,3 FA1 ANY Loss or ANY Potential Loss of either Fuel Clad or RCS 1,2,3 FC - Fuel C lad RC - Reactor Coolant System CT - Containment Sub-Category Loss Potential Loss Loss Potential Loss Loss Potential Loss A. Operation of a standby charging (makeup) pump is required by EITHER of the following:

A. An automatic or manual ECCS (SI)

a. UNISOLABLE RCS leakage actuation is required by EITHER of the A. RCS/reactor vessel level less OR

1. RCS or SG following: A leaking or RUPTURED SG is None than (site-specific level). b. SG tube leakage. None Tube Leakage a. UNISOLABLE RCS leakage FAULTED outside of containment.

OR OR B. RCS cooldown rate greater than

b. SG tube RUPTURE.

(site specific pressurized thermal shock criteria/limits defined by site specific indications)

A. Core exit thermocouple readings greater than (site specific A. 1. (site specific criteria for entry into A. Core exit thermocouple temperature value)

A. Inadequate RCS heat removal core cooling restoration procedure)

2. Inadequate readings greater than (site OR None capability via steam generators as None AND Heat Removal specific temperature value)

B. Inadequate RCS heat removal indicated by (site specific indications).

2. Functional Restoration Procedures capability via steam generators not effective in < 15 minutes.

as indicated by (site specific indications).

A. Containment radiation monitor reading greater than (site specific 3.RCS Activity/ value) A. Containment radiation monitor A. Containment radiation monitor reading Containment OR None reading greater than (site specific value) None None greater than (site specific value)

Radiation B. (Site specific indications that reactor coolant activity is greater than 300 uCi/gm dose equivalent I-131).

A.Containment isolation is required AND A. Containment pressure greater than (site EITHER of the following: specific value)

1. Containment integrity has been OR lost based on Emergency Director B. Explosive mixture exists inside judgement. containment.

4.Containment OR None None OR Integrity or None None Bypass 2. UNISOLABLE pathway from C. 1. Containment pressure greater than containment to the environment (site specific value) exists.

AND OR

2. Less than one full train of (site B Indication of RCS leakage outside of specific equipment) is operating containment per design for >15 minutes.

A. Any Condition in the opinion of the A. Any Condition in the opinion of the A. ANY Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the Emergency

5. Emergency Emergency Director that indicates Potential Emergency Director that indicates Loss Emergency Director that indicates Potential Emergency Director that indicates Loss of Emergency Director that indicates Loss of the Director that indicates Potential Loss of the Director Judgment Loss of the RCS Barrier.

of the Fuel Clad Barrier. Loss of the Fuel Clad Barrier. the RCS Barrier. Containment Barrier. Containment Barrier.

Page 12 of 67

Proposed Fission Product Barrier Matrix Fission Product Barrier Matrix Hot Matrix GENERAL EMERGENCY SITE AREA EMERGENCY ALERT FG1 Loss of any two barriers AND Loss or Potential Loss of third barrier. 1 2 3 FS1 Loss or Potential Loss of ANY two barriers. 1 2 3 FA1 ANY Loss or ANY Potential Loss of either Fuel Clad or RCS 1 2 3 FC - Fuel Clad RC - Reactor Coolant System CT - Containment Sub-Category Loss Potential Loss Loss Potential Loss Loss Potential Loss

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

1. Automatic or manual ECCS (SI) actuation OR

1. SG tube leakage > the capacity of one is required by EITHER of the following: 3. Once-Through-Cooling, EOP-20 HR4 in charging pump in the normal charging

a. UNISOLABLE RCS leakage effect. mode (greater than 40 gpm).

1. RCS or SG Tube RVLMS indicates 0.0%.

None OR AND None Leakage OR

4. a. A transient has caused a rapid RCS

b. Steam Generator tube RUPTURE. 2. SG is FAULTED outside of containment.

cooldown.

AND

b. Pressure and Temperature is above Attachment PC-12 Pressure Temperature Curve.

1. a. Tclad > 1550°F.

AND

2. Core Exit Thermocouple readings b. Restoration procedures not effective

> 700°F in < 15 minutes.

1. Core Exit Thermocouple readings OR

2. Inadequate Heat OR Once-Through-Cooling, EOP-20 HR4 in

> 1550°F None None 2. a. Core exit thermocouples > 700 ºF Removal effect.

3. Once-Through-Cooling, EOP-20 HR4 in AND effect. b. RVLMS indicates 0.0%

AND

c. Restoration procedures not effective in < 15 minutes.

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

OR Containment radiation monitor

3. Containment 2. Coolant activity > 180 uCi/gm Dose Containment radiation monitor Radiation / RCS None RM-091 A/B reading > 40 R/hr. None None Equivalent I-131 RM-091 A/B reading > 26,000 R/hr.

Activity OR

3. 12.1 Rem/hr on contact or 33 mRem/hr at 30 cm on primary sample piping adjacent to the hood SL-1 per CH-SMP-PA-0007

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

3. Containment Pressure > 60 psig and

a. UNPLANNED lowering in containment pressure or rise in rising.

radiation monitor readings OR outside of containment in the 4. Hydrogen Concentration in Containment Emergency Directors judgment > 3%.

indicate a loss of containment OR

4. Containment None None None None integrity.

Integrity or Bypass 5. a. Containment pressure > 5 psig OR AND

b. UNISOLABLE pathway from containment to the environment b. Less than one full train of exists. Containment Cooling OR OR Containment Spray equipment operating.

2. Indication of RCS leakage outside of containment.

2. Any Condition in the opinion of the 2. Any Condition in the opinion of the

1. Any Condition in the opinion of the 2. Any Condition in the opinion of the 1. Any Condition in the opinion of the 1. Any Condition in the opinion of the

5. Emergency Emergency Director that indicates Emergency Director that indicates Emergency Director that indicates Loss Emergency Director that indicates Emergency Director that indicates Loss Emergency Director that indicates Loss Director Judgment Potential Loss of the RCS Barrier. Potential Loss of the Containment of the Fuel Clad Barrier. Potential Loss of the Fuel Clad Barrier. of the RCS Barrier. of the Containment Barrier.

Barrier.

Page 13 of 67

NEI 99-01 Rev 6 Proposed EAL Justification FC1 FC1 X No Change Difference Deviation Category: Fuel Clad Barrier Category: Fuel Clad Barrier RCS or SG tube leakage RCS or SG tube leakage 1) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:

Potential Loss POTENTIAL LOSS A. RCS/reactor vessel level less than (site-specific level). RVLMS indicates 0.0%.

Page 14 of 67

NEI 99-01 Rev 6 Proposed EAL Justification FC2 FC2 X No Change Difference Deviation Category: Fuel Clad Barrier Category: Fuel Clad Barrier Inadequate Heat Removal Inadequate Heat Removal 1) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability:

2) Potential Loss #3, The initiation of Once-Through-Cooling, EOP-20 HR4 Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 creates a controlled opening of the RCS to the containment by an open PORV.

This is indicative of the steam generators inability to remove heat from the RCS Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:

and represents a potential challenge to the FC barrier and is considered a potential Loss LOSS loss.

A. Core exit thermocouple readings greater than (site-specific temperature value). 1. Core Exit Thermocouple readings > 1550°F Potential Loss POTENTIAL LOSS A. Core exit thermocouple readings greater than (site-specific temperature value). 2. Core Exit Thermocouple readings > 700°F OR OR B. Inadequate RCS heat removal capability via steam generators as indicated by

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

(site-specific indications).

Page 15 of 67

NEI 99-01 Rev 6 Proposed EAL Justification FC3 FC3 No Change X Difference Deviation Category: Fuel Clad Barrier Category: Fuel Clad Barrier Containment Radiation / RCS Activity Containment Radiation / RCS Activity 1) Listed site-specific monitor and threshold value to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability:

The coolant activity corresponds to 5% core damage, based on the size of the core Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 at FCS this is indicated by 180uCi/gm Dose Equivalent I-131 vice 300 uCi/gm.

Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:

Loss LOSS A. Containment radiation monitor reading greater than (site-specific value). 1. Containment radiation monitor RM-091 A/B reading > 6500 R/hr.

OR OR B. (Site-specific indications that reactor coolant activity is greater than 300 Ci/gm 2. Coolant activity > 180 uCi/gm Dose Equivalent I-131 dose equivalent I-131).

OR

3. 12.1 Rem/hr on contact or 33 mRem/hr at 30 cm on primary sample piping adjacent to the hood SL-1 per CH-SMP-PA-0007 Page 16 of 67

NEI 99-01 Rev 6 Proposed EAL Justification FC6 FC5 X No Change Difference Deviation Category: Fuel Clad Barrier Category: Fuel Clad Barrier Emergency Director Judgment Emergency Director Judgment Operating Mode Applicability: Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:

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

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

Page 17 of 67

NEI 99-01 Rev 6 Proposed EAL Justification RC1 RC1 No Change X Difference Deviation Category: Reactor Coolant System Barrier Category: Reactor Coolant System Barrier RCS or SG Tube Leakage RCS or SG Tube Leakage 1) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability:

2) Potential Loss #3, The initiation of Once-Through-Cooling, EOP-20 HR4 creates Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 a controlled opening of the RCS to the containment by an open PORV. The opening of the RCS represents a potential challenge to the RCS barrier and is Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:

considered a potential loss.

Loss LOSS A. An automatic or manual ECCS (SI) actuation is required by EITHER of the 1. Automatic or manual ECCS (SI) actuation is required by EITHER of the following: following:

1. UNISOLABLE RCS leakage

a. UNISOLABLE RCS leakage OR OR

2. SG tube RUPTURE.

b. Steam Generator tube RUPTURE.

Potential Loss POTENTIAL LOSS A. Operation of a standby charging (makeup) pump is required by EITHER of the following: 2. UNISOLABLE RCS leakage > the capacity of one charging pump in the

1. UNISOLABLE RCS leakage normal mode (greater than 40gpm).

OR OR

2. SG tube leakage.

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

OR OR B. RCS cooldown rate greater than (site-specific pressurized thermal shock

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

criteria/limits defined by site-specific indications).

AND

b. Pressure and Temperature is above Attachment PC-12 Pressure Temperature Curve.

Page 18 of 67

NEI 99-01 Rev 6 Proposed EAL Justification RC2 RC2 X No Change Difference Deviation Category: Reactor Coolant System Barrier Category: Reactor Coolant System Barrier Inadequate Heat Removal Inadequate Heat Removal 1) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability:

2) The initiation of Once-Through-Cooling, EOP-20 HR4 creates a controlled Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 opening of the RCS to the containment by an open PORV. The opening of the RCS represents a potential challenge to the RCS barrier and is considered a Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:

potential loss.

Potential Loss POTENTIAL LOSS A. Inadequate RCS heat removal capability via steam generators as indicated by Once-Through-Cooling, EOP-20 HR4 in effect.

(site-specific indications).

Page 19 of 67

NEI 99-01 Rev 6 Proposed EAL Justification RC3 RC3 X No Change Difference Deviation Category: Reactor Coolant System Barrier Category: Reactor Coolant System Barrier Containment Radiation / RCS Activity Containment Radiation / RCS Activity 1) Listed site-specific systems and threshold values to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:

Loss LOSS A. Containment radiation monitor reading greater than (site-specific value). Containment radiation monitor RM-091 A/B reading > 40 R/hr.

Page 20 of 67

NEI 99-01 Rev 6 Proposed EAL Justification RC6 RC5 X No Change Difference Deviation Category: Reactor Coolant System Barrier Category: Reactor Coolant System Barrier Emergency Director Judgment Emergency Director Judgment Operating Mode Applicability: Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:

Loss Loss A. Any Condition in the opinion of the Emergency Director that indicates Loss of 1. ANY Condition in the opinion of the Emergency Director that indicates Loss of the RCS Barrier. the RCS Barrier.

Potential Loss Potential Loss A. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier. 2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.

Page 21 of 67

NEI 99-01 Rev 6 Proposed EAL Justification CT1 CT1 X No Change Difference Deviation Category: Containment Barrier Category: Containment Barrier RCS or SG Tube Leakage RCS or SG Tube Leakage 1) Listed site-specific threshold values to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:

Loss LOSS A. A leaking or RUPTURED SG is FAULTED outside of containment. 1. SG tube leakage > the capacity of one charging pump in the normal charging mode (greater than 40 gpm).

AND

2. SG is FAULTED outside of containment.

Page 22 of 67

NEI 99-01 Rev 6 Proposed EAL Justification CT2 CT2 X No Change Difference Deviation Category: Containment Barrier Category: Containment Barrier Inadequate Heat Removal Inadequate Heat Removal 1) Listed site-specific threshold values to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:

Potential Loss POTENTIAL LOSS A. 1. (Site-specific criteria for entry into core cooling restoration procedure) 1. a. Tclad > 1550°F.

AND AND

2. Restoration procedure not effective within 15 minutes. b. Restoration procedures not effective in < 15 minutes.

OR

2. a. Core exit thermocouples > 700 ºF AND

b. RVLMS indicates 0.0%

AND

c. Restoration procedures not effective in < 15 minutes.

Page 23 of 67

NEI 99-01 Rev 6 Proposed EAL Justification CT3 CT3 X No Change Difference Deviation Category: Containment Barrier Category: Containment Barrier Containment Radiation / RCS Activity Containment Radiation / RCS Activity 1) Listed site-specific threshold values to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:

Potential Loss POTENTIAL LOSS A. Containment radiation monitor reading greater than (site-specific value). Containment radiation monitor RM-091 A/B reading > 26,000 R/hr.

Page 24 of 67

NEI 99-01 Rev 6 Proposed EAL Justification CT4 CT4 X No Change Difference Deviation Category: Containment Barrier Category: Containment Barrier Containment Integrity or Bypass Containment Integrity or Bypass 1) Listed site-specific monitor and threshold value to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:

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

AND a. UNPLANNED lowering in containment pressure or rise in radiation EITHER of the following: monitor readings outside of containment in the Emergency Directors

1. Containment integrity has been lost based on Emergency Director judgment indicate a loss of containment integrity.

judgment.

OR OR

b. UNISOLABLE pathway from containment to the environment exists.

2. UNISOLABLE pathway from the containment to the environment exists.

OR OR B. Indications of RCS leakage outside of containment. 2. Indication of RCS leakage outside of containment POTENTIAL LOSS Potential Loss 3. Containment Pressure > 60 psig and rising.

A. Containment pressure greater than (site-specific value) OR OR 4. Hydrogen Concentration in Containment > 3%.

B. Explosive mixture exists inside containment OR OR

5. a. Containment pressure > 5 psig C. 1. Containment pressure greater than (site-specific pressure setpoint)

AND AND

b. Less than one full train of Containment Cooling OR Containment Spray

2. Less than one full train of (site-specific system or equipment) is operating equipment operating.

per design for 15 minutes or longer.

Page 25 of 67

NEI 99-01 Rev 6 Proposed EAL Justification CT6 CT5 X No Change Difference Deviation Category: Containment Barrier Category: Containment Barrier Emergency Director Judgment Emergency Director Judgment Operating Mode Applicability: Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:

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

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

Page 26 of 67

NEI 99-01 Rev 6 Proposed EAL Justification SG1 MG1 Initiating Condition: GENERAL EMERGENCY Initiating Condition:

X No Change Difference Deviation Prolonged loss of all offsite and all onsite AC power to emergency buses.

Prolonged loss of all offsite and all onsite AC power to emergency buses.

1) Listed site specific equipment, site specific time based on station blackout Operating Mode Applicability: coping analysis, and site specific indication to ensure timely classification.

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Example Emergency Action Levels:

Emergency Action Levels (EAL):

Note: The Emergency Director should declare the General Emergency promptly upon determining that (site-specific hours) has been exceeded, or will likely be exceeded. Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

1. a. Loss of ALL offsite and ALL onsite AC power to (site-specific emergency buses). 1. Loss of ALL offsite AC power to vital 4160 volt buses 1A3 and 1A4.

AND AND 2. Failure of EDGs DG1 and DG2 to supply power to vital 4160 volt buses 1A3 and 1A4.

b. EITHER of the following:

AND Restoration of at least one emergency bus in less than 3. EITHER of the following:

(site-specific hours) is not likely. a. Restoration of at least one vital 4160 volt bus in < 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is not likely.

OR (Site-specific indication of an inability to adequately remove heat from the core) b. Core exit thermocouples > 1550°F.

Page 27 of 67

NEI 99-01 Rev 6 Proposed EAL Justification SS1 MS1 Initiating Condition: SITE AREA EMERGENCY Initiating Condition:

X No Change Difference Deviation Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or longer. 1) Listed site specific equipment to ensure timely classification.

Loss of all offsite and onsite AC power to emergency busses for 15 minutes or longer.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Example Emergency Action Levels:

Emergency Action Levels (EAL):

Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded. Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses) for 15 minutes or longer. 1. Loss of ALL offsite AC Power to vital 4160 volt buses 1A3 and 1A4.

AND

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

AND

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

Page 28 of 67

NEI 99-01 Rev 6 Proposed EAL Justification SA1 MA1 Initiating Condition: ALERT Initiating Condition:

X No Change Difference Deviation Loss of all but one AC power source to emergency buses for 15 minutes or longer.

Loss of all but one AC power source to emergency buses for 15 minutes or longer.

1) Listed site specific equipment to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Example Emergency Action Levels:

Emergency Action Levels (EAL):

Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded. Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be

1. a. AC power capability to (site-specific emergency buses) is reduced to a exceeded.

single power source for 15 minutes or longer.

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

b. Any additional single power source failure will result in loss of all AC 161 Kv Circuit power to SAFETY SYSTEMS.

345 Kv Circuit EDG DG1 EDG DG2 AND

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

Page 29 of 67

NEI 99-01 Rev 6 Proposed EAL Justification SU1 MU1 Initiating Condition: UNUSUAL EVENT Initiating Condition:

X No Change Difference Deviation Loss of all offsite AC power capability to emergency buses for 15 minutes or longer. Loss of all offsite AC power capability to emergency buses for 15 minutes or longer. 1) Listed site specific equipment to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Example Emergency Action Levels:

Emergency Action Levels (EAL):

Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be Note: The Emergency Director should declare the event promptly upon exceeded. determining that the applicable time has been exceeded, or will likely be exceeded.

Loss of ALL offsite AC power capability to (site-specific emergency buses) for 15 minutes or longer Loss of ALL offsite AC power capability to vital 4160 volt buses 1A3 and 1A4 for

> 15 minutes.

Page 30 of 67

NEI 99-01 Rev 6 Proposed EAL Justification SG8 MG2 Initiating Condition: GENERAL EMERGENCY Initiating Condition: No Change X Difference Deviation Loss of all AC and Vital DC power sources for 15 minutes or longer.

Loss of all AC and Vital DC power sources for 15 minutes or longer.

1) Listed site specific voltage and equipment to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability: 2) Removed the word "indicated" this will allow for an indication problem to not Power Operation, Startup, Hot Standby, Hot Shutdown cause confusion on the need to declare.

1, 2, 3 Example Emergency Action Levels:

Emergency Action Levels (EAL):

Note: The Emergency Director should declare the General Emergency promptly upon determining that 15 minutes has been exceeded, or will likely be Note: The Emergency Director should declare the event promptly upon exceeded. determining that the applicable time has been exceeded, or will likely be exceeded.

1. Loss of ALL offsite and ALL onsite AC power to (site-specific emergency buses) for 15 minutes or longer. 1. Loss of ALL offsite AC power to vital 4160 volt buses 1A3 and 1A4.

AND AND

2. Failure of EDGs DG1 and DG2 to supply power to vital 4160 volt buses 1A3 Indicated voltage is less than (site-specific bus voltage value) on ALL and 1A4.

(site-specific vital DC busses) for 15 minutes or longer.

AND

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

AND

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

Page 31 of 67

NEI 99-01 Rev 6 Proposed EAL Justification SS8 MS2 Initiating Condition: SITE AREA EMERGENCY Initiating Condition: No Change X Difference Deviation Loss of all Vital DC power for 15 minutes or longer.

Loss of all Vital DC power for 15 minutes or longer.

1) Listed site specific voltage and equipment to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability: 2) Removed the word "indicated" this will allow for an indication problem to not Power Operation, Startup, Hot Standby, Hot Shutdown cause confusion on the need to declare.

1, 2, 3 Example Emergency Action Levels:

Emergency Action Levels (EAL):

Note: The Emergency Director should declare the Site Area Emergency promptly upon determining that 15 minutes time has been exceeded, or Note: The Emergency Director should declare the event promptly upon will likely be exceeded. determining that the applicable time has been exceeded, or will likely be exceeded.

Indicated voltage is less than (site-specific bus voltage value) on ALL Vital DC buses for 15 minutes or longer. Voltage is < 105 VDC on 125 VDC Bus1and Bus 2 for > 15 minutes.

Page 32 of 67

NEI 99-01 Rev 6 Proposed EAL Justification SS5 MS3 Initiating Condition: SITE AREA EMERGENCY Initiating Condition: No Change X Difference Deviation Inability to shutdown the reactor causing a challenge to (core cooling [PWR] / RPV water level [BWR]) or RCS heat removal. Inability to shutdown the reactor causing a challenge to core cooling or RCS heat removal. 1) Listed site specific indications to ensure timely classification.

Operating Mode Applicability: 2) Mode 2 included in operating mode applicability as per developer notes.

Operating Mode Applicability:

3) The initiation of Once-Through-Cooling, EOP-20 HR4 creates a controlled Power Operation 1,2 opening of the RCS to the containment by an open PORV. This is indicative of the steam generators inability to remove heat from the RCS.

Example Emergency Action Levels:

Emergency Action Levels (EAL):

1. a. An automatic (trip [PWR] / scram [BWR]) did not shutdown the reactor. 1. Automatic or Manual Trip did not shutdown the reactor as indicated by Reactor Power > 2%.

AND AND

b. All manual actions to shutdown the reactor have been unsuccessful. 2. All manual actions to shutdown the reactor have been unsuccessful as indicated by Reactor Power > 2%.

AND AND

c. EITHER of the following conditions exist: 3. EITHER of the following conditions exist:

a. Core exit thermocouples > 1550°F.

1. (Site-specific indication of an inability to adequately remove heat from the core) OR

b. RVLMS indicates 0.0%

OR OR

2. (Site-specific indication of an inability to adequately c. Once-Through-Cooling, EOP-20 HR4 in effect.

remove heat from the RCS)

Page 33 of 67

NEI 99-01 Rev 6 Proposed EAL Justification SA5 MA3 Initiating Condition: ALERT Initiating Condition: No Change X Difference Deviation Automatic or manual (trip [PWR] / scram [BWR]) fails to shutdown the reactor, and subsequent manual actions taken at the reactor control consoles are not Automatic or manual trip fails to shutdown the reactor, and subsequent manual actions taken at the reactor control consoles are not successful in shutting down 1) Listed site specific indications to ensure timely classification.

successful in shutting down the reactor.

the reactor.

2) Mode 2 included in operating mode applicability as per developer notes.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation 1,2 Example Emergency Action Levels:

Emergency Action Levels (EAL):

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

1. a. An automatic (trip [PWR] / scram [BWR]) did not shutdown the reactor. 1. Automatic or manual Trip did not shutdown the reactor as indicated by Reactor Power > 2%.

AND AND

2. Manual actions taken at the Console Center are not successful in shutting

b. Manual action taken at the reactor control consoles are not down the reactor as indicated by Reactor Power > 2%.

successful in shutting down the reactor.

Page 34 of 67

NEI 99-01 Rev 6 Proposed EAL Justification SU5 MU3 Initiating Condition: UNUSUAL EVENT Initiating Condition: No Change X Difference Deviation Automatic or manual (trip [PWR] / scram [BWR]) fails to shutdown the reactor.

Automatic or manual trip fails to shutdown the reactor.

1) Listed site specific indications to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability: 2) Mode 2 included in operating mode applicability as per developer notes.

Power Operation 1,2 Example Emergency Action Levels: (1 or 2)

Emergency Action Levels (EAL):

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

1. a. An automatic (trip [PWR] / scram [BWR]) did not shutdown the reactor. 1. a. Automatic Trip did not shutdown the reactor as indicated by Reactor Power > 2%.

AND AND

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

b. A subsequent manual action taken at the reactor control consoles is shutting down the reactor.

successful in shutting down the reactor.

OR

2. a. Manual Trip did not shutdown the reactor as indicated by Reactor Power

2. a. A manual trip ([PWR] / scram [BWR]) did not shutdown the reactor. > 2%.

AND AND

b. EITHER of the following:

b. EITHER of the following: 1. Subsequent manual action taken at the Console Center is successful in shutting down the reactor.

1. A subsequent manual action taken at the reactor control consoles OR is successful in shutting down the reactor.

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

OR

2. A subsequent automatic (trip [PWR] / scram [BWR]) is successful in shutting down the reactor.

Page 35 of 67

NEI 99-01 Rev 6 Proposed EAL Justification SA2 MA4 Initiating Condition: ALERT X Initiating Condition: No Change Difference Deviation UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress. UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress. 1) Listed site specific number of steam generators to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability: 2) Removed automatic runback from list since OPPD Ft Calhoun plant does not have this function.

Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Example Emergency Action Levels:

Note: The Emergency Director should declare the Alert promptly upon determining that Emergency Action Levels (EAL):

15 minutes has been exceeded, or will likely be exceeded.

Note: The Emergency Director should declare the event promptly upon

1. a. An UNPLANNED event results in the inability to monitor one or more of the following determining that the applicable time has been exceeded, or will likely be parameters from within the Control Room for 15 minutes or longer. exceeded.

[see table below]

1. a An UNPLANNED event results in the inability to monitor ANY Table M1

[ BWR parameter list] [ PWR parameter list] parameters from within the Control Room for > 15 minutes.

Reactor Power Reactor Power Table M1 Control Room Parameters RPV Level RCS Level Reactor Power PZR Level RPV Pressure RCS Pressure RCS Pressure In Core/Core Exit Temperature Primary Containment Pressure In Core/Core Exit Temperature Level in at least one SG.

Levels in at least (site specific number) Auxiliary Feed Water Flow Suppression Pool Level steam generators Steam Generator Auxiliary or Suppression Pool Temperature AND Emergency Feed Water Flow AND b. ANY Table M2 transient in progress.

b. Any of the following transient events in progress.

Table M2 Significant Transients Automatic or Manual runback greater than 25% thermal reactor power Electrical load rejection greater than 25% full electrical load Electrical Load Rejection >25% full electrical load Reactor Scram [BWR] / trip [PWR]

Reactor Trip ECCS (SI) actuation Thermal power oscillations greater than 10% [BWR] ECCS Actuation Page 36 of 67

NEI 99-01 Rev 6 Proposed EAL Justification SU2 MU4 Initiating Condition: UNUSUAL EVENT Initiating Condition:

X No Change Difference Deviation UNPLANNED loss of Control Room indications for 15 minutes or longer.

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

1) Listed site specific number of steam generators to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Example Emergency Action Levels:

Note: The Emergency Director should declare the Unusual Event promptly upon Emergency Action Levels (EAL):

determining that 15 minutes has been exceeded, or will likely be exceeded. Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be An UNPLANNED event results in the inability to monitor one or more of the exceeded.

following parameters from within the Control Room for 15 minutes or longer.

[see table below] UNPLANNED event results in the inability to monitor ANY Table M1 parameters from within the Control Room for > 15 minutes.

[ BWR parameter list] [ PWR parameter list]

Table M1 Control Room Parameters Reactor Power Reactor Power Reactor Power RPV Level RCS Level PZR Level RCS Pressure RPV Pressure RCS Pressure In Core/Core Exit Temperature Primary Containment Pressure In Core/Core Exit Temperature Level in at least one SG.

Auxiliary Feed Water Flow Levels in at least (site specific Suppression Pool Level number) steam generators Steam Generator Auxiliary or Suppression Pool Temperature Emergency Feed Water Flow Page 37 of 67

NEI 99-01 Rev 6 Proposed EAL Justification SA9 MA5 Initiating Condition: ALERT Initiating Condition: No Change X Difference Deviation Hazardous event affecting a SAFETY SYSTEM needed for the current Hazardous event affecting a SAFETY SYSTEM required for the current operating mode. operating mode. 1) No additional site specific hazards noted Operating Mode Applicability: Operating Mode Applicability: 2) Changed the word "needed" to "required" in the IC and "required by Technical Specification" in the EAL to be consistent with terminology used by operators and Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 minimize confusion.

Example Emergency Action Levels: Emergency Action Levels (EAL):

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

Seismic event (earthquake) Seismic event (earthquake)

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

2. EITHER of the following:

b. EITHER of the following:

a. Event damage has caused indications of degraded performance in

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

current operating mode.

OR OR

b. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM

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

Page 38 of 67

NEI 99-01 Rev 6 Proposed EAL Justification SU4 MU6 Initiating Condition: UNUSUAL EVENT Initiating Condition:

X No Change Difference Deviation RCS leakage for 15 minutes or longer.

RCS leakage for 15 minutes or longer.

1) Listed site specific values to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Example Emergency Action Levels: (1 or 2 or 3)

Emergency Action Levels (EAL):

Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be Note: The Emergency Director should declare the event promptly upon exceeded. determining that the applicable time has been exceeded, or will likely be exceeded.

1. RCS unidentified or pressure boundary leakage greater than (site-specific value) for 15 minutes or longer. 1. RCS unidentified or pressure boundary leakage > 10 gpm for > 15 minutes

2. RCS identified leakage greater than (site-specific value) for 15 minutes or OR longer

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

3. Leakage from the RCS to a location outside containment greater than 25 OR gpm for 15 minutes or longer

3. Leakage from the RCS to a location outside containment >25 gpm for

> 15 minutes Page 39 of 67

NEI 99-01 Rev 6 Proposed EAL Justification SU6 MU7 Initiating Condition: UNUSUAL EVENT Initiating Condition:

X No Change Difference Deviation Loss of all onsite or offsite communications capabilities Loss of all onsite or offsite communication capabilities.

Operating Mode Applicability:

1) Listed site specific communication methods to ensure timely classification.

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Example Emergency Action Levels: (1 or 2 or 3)

Emergency Action Levels (EAL):

1. Loss of ALL of the following onsite communication methods:

1. Loss of ALL Table M3 Onsite communications capability affecting the (site-specific list of communications method ability to perform routine operations.

2. Loss of ALL of the following ORO communications s) methods: OR (site-specific list of communications methods) 2. Loss of ALL Table M3 Offsite communication capability affecting the ability to perform offsite notifications.

3. Loss of ALL of the following NRC communications methods:

OR (site-specific list of communications methods)

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

Table M3 Communications Capability System Onsite Offsite NRC 800 MHz Radio System X Gai-tronics System X Security Building PABX X X X Training Building PABX X X X Commercial Telephones X X X Conference Operations X

Network (COP)

FTS-ENS X X HPN X X Satellite phones X X Blair Phone Line X Page 40 of 67

NEI 99-01 Rev 6 Proposed EAL Justification SU7 MU8 Initiating Condition: UNUSUAL EVENT Initiating Condition: No Change X Difference Deviation Failure to isolate containment or loss of containment pressure control. [PWR]

Failure to isolate containment or loss of containment pressure control.

1) Listed site specific indications to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

2) Reworded EAL 1.b to be a positive statement Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Example Emergency Action Levels: (1 or 2)

Emergency Action Levels (EAL):

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

AND AND

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

b. ALL required penetrations are not closed within 15 minutes of the signal.

actuation signal. OR

2. a. Containment pressure > 5 psig

2. a. Containment pressure greater than (site-specific pressure).

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

b. Less than one full train of (site-specific system or equipment) is operating per design for 15 minutes or longer.

Page 41 of 67

NEI 99-01 Rev 6 Proposed EAL Justification CA2 CA1 X No Change Difference Deviation Initiating Condition: ALERT Initiating Condition:

Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or Loss of all offsite and onsite AC power to emergency busses for 15 minutes or 1) Listed site specific equipment to ensure timely classification.

longer. longer.

Operating Mode Applicability: Operating Mode Applicability:

Cold Shutdown, Refueling, Defueled 4, 5, D Example Emergency Action Levels: Emergency Action Levels (EAL):

Note: The Emergency Director should declare the Unusual Event promptly upon Note: The Emergency Director should declare the event promptly upon determining determining that 15 minutes time has been exceeded, or will likely be that the applicable time has been exceeded, or will likely be exceeded.

exceeded.

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

Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses)

AND for 15 minutes or longer.

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

AND

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

Page 42 of 67

NEI 99-01 Rev 6 Proposed EAL Justification CU2 CU1 X No Change Difference Deviation Initiating Condition: UNUSUAL EVENT Initiating Condition:

Loss of all but one AC power source to emergency buses for 15 minutes or longer. Loss of all but one AC power source to emergency buses for 15 minutes or longer. 1) Listed site specific equipment to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Cold Shutdown, Refueling, Defueled 4, 5, D Example Emergency Action Levels:

Emergency Action Levels (EAL):

Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded. Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be

1. a. AC power capability to (site-specific emergency buses) is reduced to a exceeded.

single power source for 15 minutes or longer.

AND

1. AC power capability to vital 4160 volt buses 1A3 and 1A4 reduced to

b. Any additional single power source failure will result in loss of all AC only one of the following power sources for > 15 minutes.

power to SAFETY SYSTEMS.

161 Kv Circuit 345 Kv Circuit EDG DG1 EDG DG2 AND

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

Page 43 of 67

NEI 99-01 Rev 6 Proposed EAL Justification CA6 CA2 No Change X Difference Deviation Initiating Condition - ALERT Initiating Condition:

Hazardous event affecting SAFETY SYSTEM needed for the current operating Hazardous event affecting SAFETY SYSTEM required for the current operating mode. mode. 1) No additional site specific hazards noted Operating Mode Applicability: Operating Mode Applicability:

2) Changed the word "needed" to "required" in the IC and "required by Cold Shutdown, Refueling 4, 5 Technical Specification" in the EAL to be consistent with terminology used by Example Emergency Action Levels: Emergency Action Levels (EAL): operators and minimize confusion.

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

Seismic event (earthquake) Seismic event (earthquake)

Internal or external flooding event Internal or external flooding event High winds or tornado strike High winds or tornado strike FIRE FIRE EXPLOSION EXPLOSION (site-specific hazards) Other events with similar hazard characteristics as determined by the Shift Manager Other events with similar hazard characteristics as determined by the Shift Manager AND AND 2. EITHER of the following:

b. EITHER of the following: a. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM

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

needed for the current operating mode.

OR OR

b. The event has caused VISIBLE DAMAGE to a SAFETY

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

operating mode.

Page 44 of 67

NEI 99-01 Rev 6 Proposed EAL Justification CU4 CU3 No Change X Difference Deviation Initiating Condition: UNUSUAL EVENT Initiating Condition:

Loss of Vital DC power for 15 minutes or longer. Loss of Vital DC power for 15 minutes or longer.

Operating Mode Applicability: Operating Mode Applicability: 1) Listed site specific voltage and equipment to ensure timely classification.

Cold Shutdown, Refueling 4, 5 2) Removed the word "indicated" this will allow for an indication problem to not Example Emergency Action Levels: Emergency Action Levels (EAL): cause confusion on the need to declare.

Note: The Emergency Director should declare the Unusual Event promptly upon Note: The Emergency Director should declare the event promptly upon determining that 15 minutes time has been exceeded, or will likely be determining that the applicable time has been exceeded, or will likely be exceeded. exceeded.

Indicated voltage is less than (site-specific bus voltage value) on required Vital DC Voltage is <105 VDC on required 125 VDC Bus 1 and Bus 2 for >15 minutes.

buses for 15 minutes or longer.

Page 45 of 67

NEI 99-01 Rev 6 Proposed EAL Justification CU5 CU4 X No Change Difference Deviation Initiating Condition: UNUSUAL EVENT Initiating Condition:

Loss of all onsite or offsite communications capabilities Loss of all onsite or offsite communication capabilities.

1) Listed site specific communications methods to ensure timely classification Operating Mode Applicability: Operating Mode Applicability:

Cold Shutdown, Refueling, Defueled 4, 5, D Example Emergency Action Levels: (1 or 2 or 3) Emergency Action Levels (EAL):

1. Loss of ALL of the following onsite communication methods: 1. Loss of ALL Table C1 Onsite communications capability affecting the ability to perform routine operations.

(site-specific list of communications method OR

2. Loss of ALL of the following ORO communications s) methods:

2. Loss of ALL Table C1 Offsite communication capability affecting the (site-specific list of communications methods) ability to perform offsite notifications.

3. Loss of ALL of the following NRC communications methods:

OR (site-specific list of communications methods)

3. Loss of ALL Table C1 NRC communication capability affecting the ability to perform NRC notifications.

Table C1 Communications Capability System Onsite Offsite NRC 800 MHz Radio System X Gai-tronics System X Security Building PABX X X X Training Building PABX X X X Commercial Telephones X X X Conference Operations Network X (COP)

FTS-ENS X X HPN X X Satellite phones X X Blair Phone Line X Page 46 of 67

NEI 99-01 Rev 6 Proposed EAL Justification CA3 CA5 No Change X Difference Deviation Initiating Condition: ALERT Initiating Condition:

Inability to maintain the plant in cold shutdown. Inability to maintain plant in cold shutdown.

1) Listed site specific Technical Specification cold shutdown temperature limit to Operating Mode Applicability: Operating Mode Applicability:

ensure timely classification.

Cold Shutdown, Refueling 4, 5

2) Listed site specific pressure reading to enhance timely classification.

Example Emergency Action Levels: (1 or 2) Emergency Action Levels (EAL):

Note: The Emergency Director should declare the Alert promptly upon Note: The Emergency Director should declare the event promptly upon 3) Added wording relating the temp and press rise to a loss of decay heat removal determining that the applicable has been exceeded, or will likely be determining that the applicable time has been exceeded, or will likely be capability as per the developer notes for PWRs exceeded. exceeded.

1. UNPLANNED increase in RCS temperature to greater than (site-specific 1. UNPLANNED rise in RCS temperature > 210ºF due to loss of decay Technical Specification cold shutdown temperature limit) for greater than heat removal for > Table C2 duration.

the duration specified in the following table.

OR

2. UNPLANNED RCS pressure increase greater than (site-specific pressure

2. UNPLANNED RCS pressure rise > 10 psig as a result of temperature reading). (This EAL does not apply during water-solid plant conditions.

rise due to loss of decay heat removal. (This EAL does not apply during

[PWR])

water- solid plant conditions.)

Table: RCS Heat-up Duration Thresholds Table C2 RCS Heat-up Duration Thresholds RCS Status Containment Closure Heat-up Duration RCS Status Containment Closure Heat-up Duration Status Status Intact (but not Intact Not Applicable 60 minutes*

RCS Reduced Not Applicable 60 minutes*

Inventory [PWR]) Not Intact Not Intact (or at Established 20 minutes* Established 20 minutes*

reduced inventory OR

[PWR]) Not Established 0 minutes

• If an RCS heat removal system is in operation within this time frame and Reduced RCS temperature is being reduced, the EAL is not applicable. Not Established 0 minutes Inventory

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

Page 47 of 67

NEI 99-01 Rev 6 Proposed EAL Justification CU3 CU5 No Change X Difference Deviation Initiating Condition: UNUSUAL EVENT Initiating Condition:

UNPLANNED increase in RCS temperature. UNPLANNED rise in RCS temperature. 1) Listed site specific Technical Specification cold shutdown temperature limit to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability:

Cold Shutdown, Refueling 4, 5 2) Changed the word increase to rise in the initiating condition to be consistent with operations language and training.

Example Emergency Action Levels: (1 or 2) Emergency Action Levels (EAL):

Note: The Emergency Director should declare the Unusual Event promptly Note: The Emergency Director should declare the event promptly upon upon determining that 15 minutes time has been exceeded, or will likely determining that the applicable time has been exceeded, or will likely be exceeded. be exceeded.

1. UNPLANNED increase in RCS temperature to greater than (site-specific 1. UNPLANNED rise in RCS temperature > 210ºF due to loss of decay Technical Specification cold shutdown temperature limit). heat removal.

2. Loss of ALL RCS temperature and (reactor vessel/RCS [PWR] or RPV OR

[BWR]) level indication for 15 minutes or longer.

2. Loss of the following for > 15 minutes.

ALL RCS temperature indications AND ALL RCS level indications Page 48 of 67

NEI 99-01 Rev 6 Proposed EAL Justification CG1 CG6 No Change X Difference Deviation Initiating Condition: GENERAL EMERGENCY Initiating Condition:

Loss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory affecting fuel clad Loss of reactor vessel / RCS inventory affecting fuel clad integrity with integrity with containment challenged. containment challenged.

1) Listed site specific radiation monitors to ensure timely classification Operating Mode Applicability: Operating Mode Applicability:

Cold Shutdown, Refueling 4, 5 2) Listed site specific sumps and tanks to ensure timely classification Example Emergency Action Levels: (1 or 2) Emergency Action Levels (EAL):

3) Listed Explosive mixture in the Containment Challenge Table to ensure Note: The Emergency Director should declare the Unusual Event promptly Note: The Emergency Director should declare the event promptly upon timely classification upon determining that 30 minutes time has been exceeded, or will likely determining that the applicable time has been exceeded, or will likely be be exceeded. exceeded. 4) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged.

1. a. (Reactor vessel/RCS [PWR] or RPV [BWR]) vessel level less than (site- 1. RVLMS indicates 0.0% for > 30 minutes.

specific level) for 30 minutes or longer. OR AND 2. a. Reactor Vessel / RCS level unknown for > 30 minutes.

AND

b. ANY indication from the Containment Challenge Table

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

2. a.. (Reactor vessel/RCS [PWR] or RPV [BWR]) vessel level cannot be Table C3 indications of a sufficient magnitude to indicate core monitored for 30 minutes or longer. uncovery.

AND OR

b. Core uncovery is indicated by ANY of the following: Erratic Source Range Neutron Monitor indication.

OR (Site-specific radiation monitor) reading greater than (site-specific value)

Containment Area Radiation Monitors reading > 20 R/hr.

Erratic source range monitor indication [PWR] AND UNPLANNED increase in (site-specific sump and/or tank levels) of 3. ANY Containment Challenge Indication (Table C4) sufficient magnitude to indicate core uncovery (Other site-specific indications)

Table C3 Indications of RCS Leakage AND

c. ANY indication from the Containment Challenge Table). UNPLANNED Containment Sump level rise*

UNPLANNED Auxiliary Bldg. Sump level rise*

Table: Containment Challenge Table UNPLANNED Reactor Coolant Drain Tank level rise*

CONTAINMENT CLOSURE not established* UNPLANNED Quench Tank level rise*

(Explosive mixture) exists inside containment UNPLANNED Spent Regenerate Tank level rise*

UNPLANNED increase in containment pressure UNPLANNED rise in RCS makeup Secondary containment radiation monitor reading above (site-specific Observation of leakage or inventory loss value) [BWR]

• if CONTAINMENT CLOSURE is re-established prior to exceeding the 30- *Rise in level is attributed to a loss of reactor vessel/RCS inventory.

minute core uncovery time limit, then escalation to a General Emergency is not required. Table C4 Containment Challenge Indications Hydrogen Concentration in Containment > 3%

UNPLANNED rise in containment pressure CONTAINMENT CLOSURE not established*

• if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency is not required.

Page 49 of 67

NEI 99-01 Rev 6 Proposed EAL Justification CS1 CS6 No Change X Difference Deviation Initiating Condition: SITE AREA EMERGENCY Initiating Condition:

Loss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory affecting core Loss of reactor vessel / RCS inventory affecting core decay heat removal decay heat removal capability. capabilities. 1) Listed site specific radiation monitors to ensure timely classification Operating Mode Applicability: Operating Mode Applicability:

2) Listed site specific sumps and tanks to ensure timely classification Cold Shutdown, Refueling 4, 5

3) Worded "cannot be monitored" as unknown to ensure clarity for instances Example Emergency Action Levels: (1 or 2 or 3) Emergency Action Levels (EAL):

when the indicator is working but is over/under ranged.

Note: The Emergency Director should declare the Unusual Event promptly Note: The Emergency Director should declare the event promptly upon upon determining that 30 minutes time has been exceeded, or will likely determining that the applicable time has been exceeded, or will likely be exceeded. be exceeded.

1. a. CONTAINMENT CLOSURE not established. 1. With CONTAINMENT CLOSURE established RVLMS indicates 0.0%

AND OR

2. With CONTAINMENT CLOSURE not established RVLIS < 8.0%

b. (Reactor vessel/RCS [PWR] or RPV [BWR]) level less than (site-specific level). OR

2. a. CONTAINMENT CLOSURE established. 3. a. Reactor Vessel / RCS level unknown for >30 minutes.

AND AND

b. (Reactor vessel/RCS [PWR] or RPV [BWR]) level less than (site- b. Core uncovery is indicated by ANY of the following:

specific level). Table C3 indications of a sufficient magnitude to indicate core

3. a. (Reactor vessel/RCS [PWR] or RPV [BWR]) level cannot be uncovery.

monitored for 30 minutes or longer. OR AND Erratic Source Range Neutron Monitor indication.

b. Core uncovery is indicated by ANY of the following: OR (Site-specific radiation monitor) reading greater than (site- Containment Area Radiation Monitors reading > 20 R/hr.

specific value)

Erratic source range monitor indication [PWR]

Table C3 Indications of RCS Leakage UNPLANNED increase in (site-specific sump and/or tank levels) of sufficient magnitude to indicate core uncovery UNPLANNED Containment Sump level rise*

(Other site-specific indications) UNPLANNED Auxiliary Bldg. Sump level rise*

UNPLANNED Reactor Coolant Drain Tank level rise*

UNPLANNED Quench Tank level rise*

UNPLANNED Spent Regenerate Tank level rise*

UNPLANNED rise in RCS makeup Observation of leakage or inventory loss

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

Page 50 of 67

NEI 99-01 Rev 6 Proposed EAL Justification CA1 CA6 No Change X Difference Deviation Initiating Condition: ALERT Initiating Condition:

Loss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory Loss of reactor vessel / RCS inventory

1) Listed site specific levels to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability:

Cold Shutdown, Refueling 4, 5 2) Listed site specific sumps and tanks to ensure timely classification.

Example Emergency Action Levels: (1 or 2) Emergency Action Levels (EAL):

3) Worded "cannot be monitored" as unknown to ensure clarity for instances Note: The Emergency Director should declare the Unusual Event promptly Note: The Emergency Director should declare the event promptly upon when the indicator is working but is over/under ranged.

upon determining that 15 minutes time has been exceeded, or will likely determining that the applicable time has been exceeded, or will likely be exceeded. be exceeded.

1. Loss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory as 1. Loss of Reactor Vessel / RCS inventory as indicated by RVLMS < 14%

indicated by level less than (site-specific level).

OR

2. a. (Reactor vessel/RCS [PWR] or RPV [BWR]) level cannot be

2. a. Reactor Vessel / RCS level unknown for > 15 minutes.

monitored for 15 minutes or longer AND AND

b. Loss of Reactor Vessel / RCS inventory per Table C3 indications.

b. UNPLANNED increase in (site-specific sump and/or tank) levels due to a loss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory.

Table C3 Indications of RCS Leakage UNPLANNED Containment Sump level rise*

UNPLANNED Auxiliary Bldg. Sump level rise*

UNPLANNED Reactor Coolant Drain Tank level rise*

UNPLANNED Quench Tank level rise*

UNPLANNED Spent Regenerate Tank level rise*

UNPLANNED rise in RCS makeup Observation of leakage or inventory loss

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

Page 51 of 67

NEI 99-01 Rev 6 Proposed EAL Justification CU1 CU6 No Change X Difference Deviation Initiating Condition: UNUSUAL EVENT Initiating Condition:

UNPLANNED loss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory for UNPLANNED loss of reactor vessel / RCS inventory for 15 minutes or longer.

15 minutes or longer. 1) Described a required lower limit as a procedurally established lower limit, Operating Mode Applicability:

Operating Mode Applicability: and listed site specific sumps and tanks to ensure timely classification.

4, 5 Cold Shutdown, Refueling 2) Worded "cannot be monitored" as unknown to ensure clarity for instances Emergency Action Levels (EAL):

Example Emergency Action Levels: (1 or 2) when the indicator is working but is over/under ranged.

Note: The Emergency Director should declare the event promptly upon Note: The Emergency Director should declare the Unusual Event promptly upon determining that the applicable time has been exceeded, or will likely be determining that 15 minutes has been exceeded, or will likely be exceeded.

exceeded.

1. UNPLANNED loss of reactor coolant results in the inability to restore

1. UNPLANNED loss of reactor coolant results in (reactor vessel/RCS and maintain Reactor Vessel / RCS level to > procedurally

[PWR] or RPV [BWR]) level less than a required lower limit for 15 established lower limit for > 15 minutes.

minutes or longer.

OR

2. a. (Reactor vessel/RCS [PWR] or RPV [BWR]) level cannot be

2. a. Reactor Vessel / RCS level unknown.

monitored.

AND AND

b. Loss of Reactor Vessel / RCS inventory per Table C3 indications.

b. UNPLANNED increase in (site-specific sump and/or tank) levels.

Table C3 Indications of RCS Leakage UNPLANNED Containment Sump level rise*

UNPLANNED Auxiliary Bldg. Sump level rise*

UNPLANNED Reactor Coolant Drain Tank level rise*

UNPLANNED Quench Tank level rise*

UNPLANNED Spent Regenerate Tank level rise*

UNPLANNED rise in RCS makeup Observation of leakage or inventory loss

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

Page 52 of 67

NEI 99-01 Rev 6 Proposed EAL Justification HG1 HG1 Initiating Condition: GENERAL EMERGENCY Initiating Condition: No Change X Difference Deviation HOSTILE ACTION resulting in loss of physical control of the facility. HOSTILE ACTION resulting in loss of physical control of the facility. 1) List site security shift supervision as Security Force.

2) Added descriptors to better explain each safety function and allow for a Operating Mode Applicability: Operating Mode Applicability: timely classification.

All 1, 2, 3, 4, 5, D Example Emergency Action Levels: Emergency Action Levels (EAL):

1. a. A HOSTILE ACTION is occurring or has occurred within the 1. A notification from the Security Force that a HOSTILE ACTION is occurring or has PROTECTED AREA as reported by the (site-specific security shift occurred within the PROTECTED AREA.

supervision).

AND AND

2. a. ANY Table H1 safety function cannot be controlled or maintained.

b. EITHER of the following:

1. ANY of the following safety functions cannot be controlled or OR maintained.

b. Damage to spent fuel has occurred or is IMMINENT Reactivity control Core cooling [PWR] / RPV water level [BWR]

RCS heat removal Table H1 Safety Functions OR Reactivity Control (ability to shut down the reactor and keep it shutdown)

2. Damage to spent fuel has occurred or is IMMINENT Core Cooling (ability to cool the core)

RCS Heat Removal (ability to maintain heat sink)

Page 53 of 67

NEI 99-01 Rev 6 Proposed EAL Justification HS1 HS1 Initiating Condition: SITE AREA EMERGENCY Initiating Condition:

X No Change Difference Deviation HOSTILE ACTION within the Protected Area. HOSTILE ACTION within the Protected Area.

1) List site security shift supervision as Security Force.

Operating Mode Applicability: Operating Mode Applicability:

All 1, 2, 3, 4, 5, D Example Emergency Action Levels: Emergency Action Levels (EAL):

A HOSITLE ACTION is occurring or has occurred within the PROTECTED AREA A notification from the Security Force that a HOSTILE ACTION is occurring or has as reported by the (site-security shift supervision). occurred within the PROTECTED AREA.

Page 54 of 67

NEI 99-01 Rev 6 Proposed EAL Justification HA1 HA1 Initiating Condition: ALERT Initiating Condition:

X No Change Difference Deviation HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes. threat within 30 minutes. 1)List site security shift supervision as Security Force.

Operating Mode Applicability: Operating Mode Applicability:

All 1, 2, 3, 4, 5, D Example Emergency Action Levels: (1 or 2) Emergency Action Levels (EAL):

1. A HOSTILE ACTION is occurring or has occurred within the OWNER 1. A validated notification from NRC of an aircraft attack threat < 30 minutes CONTROLLED AREA as reported by the (site-specific security shift from the site.

supervision).

OR

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

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

Page 55 of 67

NEI 99-01 Rev 6 Proposed EAL Justification HU1 HU1 Initiating Condition: UNUSUAL EVENT Initiating Condition: No Change X Difference Deviation Confirmed SECURITY CONDITION or threat.

Confirmed SECURITY CONDITION or threat.

1) List site security shift supervision as Security Force.

Operating Mode Applicability:

Operating Mode Applicability:

2) Further described credible security threat through listing a site specific All procedure.

1, 2, 3, 4, 5, D Example Emergency Action Levels: (1 or 2 or 3)

Emergency Action Levels (EAL):

1. A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the (site-specific security shift supervision). 1. Notification of a credible security threat directed at the site as determined per SY-AA-101-132, Security Assessment and Response to Unusual Activities.

OR

2. Notification of a credible security threat directed at the site.

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

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

OR

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

Page 56 of 67

NEI 99-01 Rev 6 Proposed EAL Justification HS6 HS2 Initiating Condition: SITE AREA EMERGENCY Initiating Condition: No Change X Difference Deviation Inability to control a key safety function from outside the Control Room. Inability to control a key safety function from outside the Control Room.

1) EAL uses the site specific Control Room evacuation procedures to effectively list all of the alternate locations, panels, and stations requested by Operating Mode Applicability: Operating Mode Applicability: the developer notes. This would be the procedures the Control Room would enter should such an event occur, this allows for greater clarity as to when All 1, 2, 3, 4, 5, D this EAL would apply than if each panel and station used in alternate shutdown were to be listed, Example Emergency Action Levels: (1 and 2) Emergency Action Levels (EAL): 2) Added descriptors to better explain each safety function and allow for a Note: The Emergency Director should declare the event promptly upon Note: The Emergency Director should declare the event promptly upon determining timely classification.

determining that (site-specific number of minutes) has been exceeded, or that the applicable time has been exceeded, or will likely be exceeded.

will likely be exceeded. 3) Changed "An event" to" A Control Room evacuation" to remove confusion if partial plant control was transferred to outside the control room with the control

1. A Control Room evacuation has resulted in plant control being transferred from the room still manned, due to testing or equipment failure.

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

Room to (site-specific remote shutdown panels and local control stations).

AOP-07 Evacuation of Control Room

2. Control of ANY of the following key safety functions is not reestablished OR within (site-specific number of minutes). AOP-06 Fire Emergency AND Reactivity control

2. Control of ANY Table H1 key safety function is not reestablished in < 15 minutes.

Core cooling [PWR] / RPV water level [BWR]

RCS heat removal Table H1 Safety Functions Reactivity Control (ability to shut down the reactor and keep it shutdown)

Core Cooling (ability to cool the core)

RCS Heat Removal (ability to maintain heat sink)

Page 57 of 67

NEI 99-01 Rev 6 Proposed EAL Justification HA6 HA2 Initiating Condition: ALERT Initiating Condition: No Change X Difference Deviation Control Room evacuation resulting in transfer of plant control to alternate locations. Control Room evacuation resulting in transfer of plant control to alternate locations.

1) EAL uses the site specific Control Room evacuation procedures to effectively list all of the alternate locations, panels, and stations requested by the developer Operating Mode Applicability: Operating Mode Applicability: notes. This would be the procedures the Control Room would enter should such an event occur, this allows for greater clarity as to when this EAL would apply than if All 1, 2, 3, 4, 5, D each panel and station used in alternate shutdown were to be listed,

2) Changed "An event" to" A Control Room evacuation" to remove confusion if Example Emergency Action Levels: Emergency Action Levels (EAL): partial plant control was transferred to outside the control room with the control An event has resulted in plant control being transferred from the Control Room to room still manned, due to testing or equipment failure.

(site-specific remote shutdown panels and local control stations). A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per:

AOP-07 Evacuation of Control Room OR AOP-06 Fire Emergency Page 58 of 67

NEI 99-01 Rev 6 Proposed EAL Justification HU4 HU3 Initiating Condition: UNUSUAL EVENT Initiating Condition:

X No Change Difference Deviation FIRE potentially degrading the level of safety of the plant.

FIRE potentially degrading the level of safety of the plant.

1) Listed site specific list of plant rooms or areas that contain SAFETY SYSTEM Operating Mode Applicability: equipment to ensure timely classification.

Operating Mode Applicability:

All 1, 2, 3, 4, 5, D Example Emergency Action Levels: (1 or 2 or 3 or 4)

Emergency Action Levels (EAL):

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

1. a. A FIRE is NOT extinguished within 15-minutes of ANY of the following FIRE detection indications: 1. a. A FIRE in any Table H2 area is not extinguished in <15-minutes of ANY Report from the field (i.e., visual observation) of the following FIRE detection indications:

Receipt of multiple (more than 1) fire alarms or indications Report from the field (i.e., visual observation)

Field verification of a single fire alarm Receipt of multiple (more than 1) fire alarms or indications AND Field verification of a single fire alarm

b. The FIRE is located within ANY of the following plant rooms or areas: OR (site-specific list of plant rooms or areas) 2. a. Receipt of a single fire alarm in any Table H2 area (i.e., no other indications of a FIRE).

2. a. Receipt of a single fire alarm (i.e., no other indications of a FIRE). AND AND b. The existence of a FIRE is not verified in <30-minutes of alarm receipt.

b. The FIRE is located within ANY of the following plant rooms or areas: OR (site-specific list of plant rooms or areas) 3. A FIRE within the plant PROTECTED AREA not extinguished in <60-minutes of the initial report, alarm or indication.

AND OR

c. The existence of a FIRE is not verified within 30-minutes of alarm receipt.

4. A FIRE within the plant PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.

3. A FIRE within the plant or ISFSI [for plants with an ISFSI outside the plant Protected Area] PROTECTED AREA not extinguished within 60-minutes of the initial report, alarm or indication. Table H2 Vital Areas Containment Building

4. A FIRE within the plant or ISFSI [for plants with an ISFSI outside the plant Auxiliary Building Protected Area] PROTECTED AREA that requires firefighting support by an Intake Structure offsite fire response agency to extinguish.

SIRWT Turbine Building (SSE only)

Main and Auxiliary Transformer Yard Condensate Storage Tank Page 59 of 67

NEI 99-01 Rev 6 Proposed EAL Justification HU2 HU4 Initiating Condition: UNUSUAL EVENT Initiating Condition:

X No Change Difference Deviation Seismic event greater than OBE levels.

Seismic event greater than OBE levels.

1) Listed site specific indication to determining OBE limits have been met or Operating Mode Applicability: exceeded to ensure timely classification.

Operating Mode Applicability:

All 1, 2, 3, 4, 5, D Example Emergency Action Levels:

Emergency Action Levels (EAL):

Seismic event greater than Operating Basis Earthquake (OBE) as indicated by:

a. (site-specific indication that a seismic event met or exceeded OBE limits) Seismic event > Operating Basis Earthquake (OBE) as indicated by STRONG MOTION SEISMIC EVENT IN PROGRESS alarm OR Event indicator (SMA-3 Control Panel) has changed from Black to White Page 60 of 67

NEI 99-01 Rev 6 Proposed EAL Justification HA5 HA5 Initiating Condition: ALERT Initiating Condition:

X No Change Difference Deviation Gaseous release impeding access to equipment necessary for normal plant Gaseous release impeding access to equipment necessary for normal plant operations, operations, cooldown or shutdown. cooldown or shutdown. 1) Listed plant specific rooms and areas with entry related mode applicability to ensure timely classification.

Operating Mode Applicability: Operating Mode Applicability:

All 1, 2, 3, 4, 5, D Example Emergency Action Levels: Emergency Action Levels (EAL):

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

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

of the following plant rooms or areas:

(site-specific list of plant rooms or areas with entry-related mode applicability identified)

Table H3 Areas with Entry Related Mode Applicability AND Area Entry Related Mode Applicability

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

Containment* Modes 3 through 4, and 5 Auxiliary Building* Modes 3 through 4, and 5

• Areas required to establish shutdown cooling AND

2. Entry into the room or area is prohibited or impeded Page 61 of 67

NEI 99-01 Rev 6 Proposed EAL Justification HU3 HU6 Initiating Condition: UNUSUAL EVENT Initiating Condition: No Change X Difference Deviation Hazardous Event Hazardous Event

1) Included river water level as part of the site-specific list of natural or Operating Mode Applicability: technological hazard events. The EAL values selected are the current Approved Operating Mode Applicability: UE EAL values.

All 1, 2, 3, 4, 5, D

2) Changed the word "needed" to "required by Technical Specifications" in the EAL Example Emergency Action Levels: (1 or 2 or 3 or 4) to be consistent with terminology used by operators and minimize confusion.

Emergency Action Levels (EAL):

Note: EAL #3 does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents. Note: EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.

1. A tornado strike within the PROTECTED AREA.

2. Internal room or area flooding of a magnitude sufficient to require manual 1. Tornado strike within the PROTECTED AREA.

or automatic electrical isolation of a SAFETY SYSTEM component needed for the current operating mode. OR

2. Internal room or area flooding of a magnitude sufficient to require manual or

3. Movement of personnel within the PROTECTED AREA is impeded due to automatic electrical isolation of a SAFETY SYSTEM component required by an offsite event involving hazardous materials (e.g., an offsite chemical Technical Specifications for the current operating mode.

spill or toxic gas release).

OR

4. A hazardous event that results in on-site conditions sufficient to prohibit 3. Movement of personnel within the PROTECTED AREA is impeded due to an the plant staff from accessing the site via personal vehicles. offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).

5. (Site-specific list of natural or technological hazard events)

OR

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

OR

5. Abnormal River level, as indicated by EITHER:

a. > 1004 feet MSL elevation (high level)

OR

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

Page 62 of 67

NEI 99-01 Rev 6 Proposed EAL Justification HG8 HG7 Initiating Condition: GENERAL EMERGENCY Initiating Condition:

X No Change Difference Deviation Other conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrant declaration of a General Emergency. declaration of a General Emergency.

Operating Mode Applicability: Operating Mode Applicability:

All 1, 2, 3, 4, 5, D Example Emergency Action Levels: Emergency Action Levels (EAL):

Other conditions exist which in the judgment of the Emergency Director indicate Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or IMMINENT that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment 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 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 the facility. Releases can be reasonably expected to exceed EPA Protective Guideline exposure levels off-site for more than the immediate site area. Action Guideline exposure levels off-site for more than the immediate site area..

Page 63 of 67

NEI 99-01 Rev 6 Proposed EAL Justification HS8 HS7 Initiating Condition: SITE AREA EMERGENCY Initiating Condition:

X No Change Difference Deviation Other conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrant declaration of a Site Area Emergency. declaration of a Site Area Emergency.

Operating Mode Applicability: Operating Mode Applicability:

All 1, 2, 3, 4, 5, D Example Emergency Action Levels: Emergency Action Levels (EAL):

Other conditions exist which in the judgment of the Emergency Director indicate Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION 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 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 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 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 expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary. Guideline exposure levels beyond the site boundary.

Page 64 of 67

NEI 99-01 Rev 6 Proposed EAL Justification HA6 HA7 Initiating Condition: ALERT Initiating Condition:

X No Change Difference Deviation Other conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert. declaration of an Alert.

Operating Mode Applicability: Operating Mode Applicability:

All 1, 2, 3, 4, 5, D Example Emergency Action Levels: Emergency Action Levels (EAL):

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

Page 65 of 67

NEI 99-01 Rev 6 Proposed EAL Justification HU7 HU7 Initiating Condition: UNUSUAL EVENT Initiating Condition:

X No Change Difference Deviation Other conditions existing which in the judgment of the Emergency Director warrant declaration of an UNUSUAL EVENT. Other conditions existing which in the judgment of the Emergency Director warrant declaration of an UNUSUAL EVENT.

Operating Mode Applicability:

Operating Mode Applicability:

All 1, 2, 3, 4, 5, D Example Emergency Action Levels:

Other conditions exist which in the judgment of the Emergency Director indicate Emergency Action Levels (EAL):

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

Page 66 of 67

NEI 99-01 Rev 6 Proposed EAL Justification E-HU1 E-HU1 Initiating Condition: UNUSUAL EVENT Initiating Condition: UNUSUAL EVENT X No Change Difference Deviation Damage to a loaded cask CONFINEMENT BOUNDARY. Damage to a loaded cask CONFINEMENT BOUNDARY.

Operating Mode Applicability: Operating Mode Applicability:

All 1, 2, 3, 4, 5, D Example Emergency Action Levels: Emergency Action Levels (EALs):

Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on- Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than (2 times the site-specific cask specific contact radiation reading:

technical specification allowable radiation level) on the surface of the spent fuel cask. > 60mr/hr (gamma + neutron) on the top of the spent fuel cask OR

> 600mr/hr (gamma + neutron) on the side of the spent fuel cask, excluding inlet and outlet ducts Page 67 of 67

LIC-14-0098 B EAL Red-Line Basis Document Change Format:

Strikeout = deleted information Redline = information replacing deleted information Underline = new information

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARG1 Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 1000 mRrem TEDE or 5000 mRrem thyroid CDE.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

Notes:

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

If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.

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

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

(1) Reading on ANY of the following radiation monitors greater than the reading shown for 15 minutes or longer:

(site-specific monitor list and threshold values)

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

OR

2. Dose assessment Using actual meteorology indicates doses at or beyond (site-specific dose receptor point) the site boundary of EITHER:

a. > 1000 mRem TEDE OR

b. > 5000 mRem CDE Thyroid OR Month 20XX FC 3-1 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Field survey results indicate EITHER of the following at or beyond (site-specific dose receptor point):

Closed window dose rates greater than 1,000 mR/hr expected to continue for 60 minutes or longer.

Analyses of field survey samples indicate thyroid CDE greater than 5,000 mrem for one hour of inhalation.

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

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

OR

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

Table R1 Effluent Monitor Thresholds Effluent Monitor Description General Emergency RM-063 AB Stack 3.71E+00 uCi/cc (Post Accident Gas)

Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude will require implementation of protective actions for the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at the EPA PAG of 1000 mRrem while the 5000 mRrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

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

Basis Reference(s):

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

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS

1. NEI 99-01 Rev 6, AG1 Month 20XX FC 3-3 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARS1 Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 100 mRrem TEDE or 500 mRrem thyroid CDE.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

Notes:

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

If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.

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

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

(1) Reading on ANY of the following radiation monitors greater than the reading shown for 15 minutes or longer:

(site-specific monitor list and threshold values)

(2) Dose assessment using actual meteorology indicates doses greater than 100 mrem TEDE or 500 mrem thyroid CDE at or beyond (site-specific dose receptor point).

(3) Field survey results indicate EITHER of the following at or beyond (site-specific dose receptor point):

Closed window dose rates greater than 100 mR/hr expected to continue for 60 minutes or longer.

Analyses of field survey samples indicate thyroid CDE greater than 500 mrem for one hour of inhalation.

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

OR Month 20XX FC 3-4 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS

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

a. > 100 mRem TEDE OR

b. > 500 mRem CDE Thyroid OR

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

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

OR

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

Table R1 Effluent Monitor Thresholds Effluent Monitor Description Site Area Emergency AB Stack RM-063 3.70E-01 uCi/cc (Post Accident Gas)

RM-052 AB Stack (Gas) 8.30E+06 cpm RM-043 LRWPB Stack (Gas) 7.26E+06 cpm Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs).

It includes both monitored and un-monitored releases. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 10% of the EPA PAG of 1000 mRrem while the 500 mRrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE Month 20XX FC 3-5 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS and thyroid CDE.

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

Escalation of the emergency classification level would be via IC RAG1.

Basis Reference(s):

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

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARA1 Initiating Condition:

Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mRrem TEDE or 50 mRrem thyroid CDE.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

Notes:

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

If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.

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

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

(1) Reading on ANY of the following radiation monitors greater than the reading shown for 15 minutes or longer:

(site-specific monitor list and threshold values)

(2) Dose assessment using actual meteorology indicates doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond (site-specific dose receptor point).

(3) Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond (site-specific dose receptor point) for one hour of exposure.

(4) Field survey results indicate EITHER of the following at or beyond (site-specific dose receptor point):

Closed window dose rates greater than 10 mR/hr expected to continue for 60 minutes or longer.

Analyses of field survey samples indicate thyroid CDE greater than 50 mrem for one hour of inhalation.

Month 20XX FC 3-7 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS

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

OR

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

a. > 10 mRem TEDE OR

b. > 50 mRem CDE Thyroid OR

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

a. 10 mRem TEDE for 60 minutes of exposure OR

b. 50 mRem CDE Thyroid for 60 minutes of exposure OR

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

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

OR

b. Analyses of field survey s a m p l e s i n d i c a t e > 50 mRem CDE Thyroid for 60 minutes of inhalation.

Month 20XX FC 3-8 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Table R1 Effluent Monitor Thresholds Effluent Monitor Description Alert RM-063 AB Stack(Post Accident Gas) 4.0E -02 uCi/cc RM-062 AB Stack (Gas) 7.00E+05 cpm RM-052 AB Stack (Gas) 8.30E+05 cpm RM-043 LRWPB Stack (Gas) 7.26E+05 cpm RM-057 Condenser Off-Gas 1.79E+08 cpm Basis:

This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1000 mRrem while the 50 mRrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

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

Escalation of the emergency classification level would be via IC RAS1.

Basis Reference(s):

1. NEI 99-01 Rev 6, AA1 Month 20XX FC 3-9 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARU1 Initiating Condition:

Release of gaseous or liquid radioactivity greater than 2 times the ODCM (site-specific effluent release controlling document) limits for 60 minutes or longer.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

Notes:

The Emergency Director should declare the Unusual Event event promptly upon determining that 60 minutesthe applicable time has been exceeded, or will likely be exceeded.

If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes.

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

(1) Reading on ANY effluent radiation monitor greater than 2 times the (site-specific effluent release controlling document) limits for 60 minutes or longer:

(site-specific monitor list and threshold values corresponding to 2 times the controlling document limits)

(2) Reading on ANY effluent radiation monitor greater than 2 times the alarm setpoint established by a current radioactivity discharge permit for 60 minutes or longer.

(3) Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times the (site-specific effluent release controlling document) limits for 60 minutes or longer.

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

OR

2. Readings on ANY Table R1 Effluent Monitor > Table R3 value for > 60 minutes.

OR

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

Month 20XX FC 3-10 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Table R2 Effluent Monitor Thresholds Effluent Monitor Description 2X High Alarm RM-052 (aligned to Aux Building AB Stack (gas) 7.82E+04 cpm stack)

RM-062 AB Stack (gas) 6.60E+04 cpm RM-054A (if SG blowdown is SG blowdown 9.86E+04 cpm not isolated)

RM-054B (if SG blowdown is SG blowdown 9.88E+04 cpm not isolated)

RM-055 (if discharge not Liquid Discharge Header 2.80E+06 cpm isolated) Minimum 1 CW Pump RM-055 (if discharge not isolated) Minimum 2 RW Liquid Discharge Header 8.00E+05 cpm Pump Table R3 Effluent Monitor Thresholds Effluent Monitor Description Unusual Event RM-043 LRWPB Stack (gas) 6.60E+5 cpm RM-052 (aligned to Aux Building AB Stack (gas) 7.04E+05 cpm stack)

RM-062 AB Stack (gas) 6.37E+05 cpm RM-063 AB Stack (post accident gas) 2.29E-03 uCi/cc RM-057** Condenser Off-gas 1.45E+08 cpm RM-054A SG Blowdown 9.86E+04 cpm (if SG blowdown is not isolated)

RM-054B SG Blowdown 9.88E+04 cpm (if SG blowdown is not isolated)

RM- 055 (if discharge is not Liquid Discharge Header 2.80E+06 cpm isolated) Minimum 1CW Pump RM-055 (if discharge is not Liquid Discharge Header 8.00E+05 cpm isolated) Minimum 2 RW Pump Month 20XX FC 3-11 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Basis:

This IC addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release). It includes any gaseous or liquid radiological release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared.

Nuclear power plants incorporate design features intended to control the release of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases. The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

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

Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.

EAL #1 Basis:

EAL #2 - This EAL addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This EAL will typically be associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas).

The effluent monitors listed are those normally used for planned discharges. If a discharge is performed using a different flowpath or effluent monitor other than those listed (e.g., a portable or temporary effluent monitor), then the declaration criteria will be based on the monitor specified in the Discharge Permit.

EAL #2 Basis:

EAL #1 - This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous or liquid effluent pathways.

EAL #2 Basis:

EAL #3 - This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).

Month 20XX FC 3-12 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Escalation of the emergency classification level would be via IC RAA1.

Basis Reference(s):

1. NEI 99-01 Rev 6, AU1 Month 20XX FC 3-13 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARA2 Initiating Condition:

Significant lowering of water level above, or damage to, irradiated fuel.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

(1) Uncovery of irradiated fuel in the REFUELING PATHWAY.

(2) Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by ANY of the following radiation monitors:

(site-specific listing of radiation monitors, and the associated readings, setpoints and/or alarms)

(3) Lowering of spent fuel pool level to (site-specific Level 2 value). [See Developer Notes]

1. Uncovery of irradiated fuel in the REFUELING PATHWAY.

OR

2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by ANY Table R4 Radiation Monitor reading >1000 mRem/hr Table R4 Radiation Monitors RMS Area Monitored RM-73,74,75 Containment Rad Monitor RM-085,87 Auxiliary Building Rad Monitor Portable Rad Containment and auxiliary Building near fuel handling areas Monitor Basis:

REFUELING PATHWAY: all the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange.

Month 20XX FC 3-14 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS IMMINENT: The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly., or a significant lowering of water level within the spent fuel pool (see Developer Notes). These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment. As such, they represent an actual or potential substantial degradation of the level of safety of the plant.

This IC applies to irradiated fuel that is licensed for dry storage up to the point that the loaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss of the CONFINEMENT BOUNDARY is classified in accordance with IC E-HU1.

Escalation of the emergency would be based on either Recognition Category A or C ICs.

EAL #1 Basis:

EAL #1 This EAL escalates from RAU2 in that the loss of level, in the affected portion of the REFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery of irradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visual observation (e.g., reports from personnel or camera images), as well as significant changes in water and radiation levels, or other plant parameters. Computational aids may also be used (e.g., a boil-off curve). Classification of an event using this EAL should be based on the totality of available indications, reports and observations.

While an area radiation monitor could detect an increaserise in a dose rate due to a lowering of water level in some portion of the REFUELING PATHWAY, the reading may not be a reliable indication of whether or not the fuel is actually uncovered. To the degree possible, readings should be considered in combination with other available indications of inventory loss.

A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.

EAL #2 Basis:

EAL #2 This EAL addresses a release of radioactive material caused by mechanical damage to irradiated fuel. Damaging events may include the dropping, bumping or binding of an assembly, or dropping a heavy load onto an assembly. A rise in readings on radiation monitors should be considered in conjunction with in-plant reports or observations of a potential fuel damaging event (e.g., a fuel handling accident).

Month 20XX FC 3-15 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Escalation of the emergency would be based on either Recognition Category R A or C ICs.

EAL #3 Spent fuel pool water level at this value is within the lower end of the level range necessary to prevent significant dose consequences from direct gamma radiation to personnel performing operations in the vicinity of the spent fuel pool. This condition reflects a significant loss of spent fuel pool water inventory and thus it is also a precursor to a loss of the ability to adequately cool the irradiated fuel assembles stored in the pool.

Escalation of the emergency classification level would be via ICs AS1 or AS2 (see AS2 Developer Notes).

Basis Reference(s):

1. NEI 99-01 Rev 6, AA2 Month 20XX FC 3-16 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARU2 Initiating Condition:

UNPLANNED loss of water level above irradiated fuel.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

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

(site-specific level indications).

AND

b. UNPLANNED rise in area radiation levels as indicated by ANY of the following radiation monitors.

(site-specific list of area radiation monitors)

1. a. UNPLANNED water level drop in the REFUELING PATHWAY.

AND

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

Table R4 Radiation Monitors RMS Area Monitored RM-73,74,75 Containment Rad Monitor RM-085,87 Auxiliary Building Rad Monitor Portable Rad Containment and auxiliary Building near fuel handling areas Monitor Basis:

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

Month 20XX FC 3-17 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS REFUELING PATHWAY: all the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange.

This IC addresses a decrease loss in water level above irradiated fuel sufficient to cause elevated radiation levels. This condition could be a precursor to a more serious event and is also indicative of a minor loss in the ability to control radiation levels within the plant. It is therefore a potential degradation in the level of safety of the plant.

A water level decrease loss will be primarily determined by indications from available level instrumentation. Other sources of level indications may include reports from plant personnel (e.g., from a refueling crew) or video camera observations (if available) or from any other temporarily installed monitoring instrumentation. A significant drop in the water level may also cause an increaserise in the radiation levels of adjacent areas that can be detected by monitors in those locations.

The effects of planned evolutions should be considered. For example, a refueling bridge area radiation monitor reading may increaserise due to planned evolutions such as lifting of the reactor vessel head or movement of a fuel assembly. Note that this EAL is applicable only in cases where the elevated reading is due to an UNPLANNED loss of water level.

A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.

Escalation of the emergency classification level would be via IC RAA2.

Basis Reference(s):

1. NEI 99-01 Rev 6, AU2 Month 20XX FC 3-18 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARA3 Initiating Condition:

Radiation levels that impede access to equipment necessary for normal plant operations, cooldown or shutdown.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

Note: If the equipment in the listed room or area listed in Table R4 was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted (1) Dose rate greater than 15 mR/hr in ANY of the following areas:

Control Room Central Alarm Station (other site-specific areas/rooms)

(2) An UNPLANNED event results in radiation levels that prohibit or impede access to any of the following plant rooms or areas:

(site-specific list of plant rooms or areas with entry-related mode applicability identified)

1. Dose rate greater than> 15 mR/hr in ANY of the areas contained in Table R6:

Table R6 Areas Requiring Continuous Occupancy Main Control Room Central Alarm Station (CAS)

OR Month 20XX FC 3-19 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS

2. UNPLANNED event results in radiation levels that prohibit or significantly impede access to any of the following Table R7 plant rooms or areas:

Table R7 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Containment* Modes 3 through 4, and 5 Auxiliary Building* Modes 3 through 4, and 5

• Areas required to establish shutdown cooling Basis:

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

This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or impede personnel from performing actions necessary to maintain normal plant operation, or to perform a normal plant cooldown and shutdown. As such, it represents an actual or potential substantial degradation of the level of safety of the plant.

The Emergency Director should consider the cause of the increased radiation levels and determine if another IC may be applicable.

Table R4 is a list of plant rooms or areas with entry-related mode applicability that contain equipment which require a manual/local action necessary to transition the plant from normal plant operation, cooldown and shutdown as specified in normal operating procedures, where if this action is not completed the plant would not be able to attain and maintain cold shutdown. This Table does not include rooms or areas for which entry is required solely to perform actions of an administrative or record keeping nature (e.g.,

normal rounds or routine inspections).

Rooms and areas listed in EAL #1 do not need to be included in EAL #2, including the Control Room.

For EAL #2, an Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time of the elevated radiation levels. The emergency classification is not contingent upon whether entry is actually necessary at the time of the increased radiation levels. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., installing temporary shielding beyond that required by procedures, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits).

An emergency declaration is not warranted if any of the following conditions apply.

Month 20XX FC 3-20 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the elevated radiation levels). For example, the plant is in Mode 1 when the radiation increaserise occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.

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

The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.

Escalation of the emergency classification level would be via Recognition Category RA, C or F ICs.

Basis Reference(s):

1. NEI 99-01 Rev 6, AA3 Month 20XX FC 3-21 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS SRU3 Initiating Condition:

Reactor coolant activity greater than Technical Specification allowable limits.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

(1) (Site-specific radiation monitor) reading greater than (site-specific value).

(2) Sample analysis indicates that a reactor coolant activity value is greater than an allowable limit specified in Technical Specifications.

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

OR

2. Sample analysis indicates that:

a. Dose Equivalent I-131 specific coolant activity > 1.0 uCi/gm for more than 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> during one continuous time interval OR > 60 uCi/gm.

OR

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

Basis:

This IC addresses a reactor coolant activity value that exceeds an allowable limit specified in Technical Specifications. This condition is a precursor to a more significant event and represents a potential degradation of the level of safety of the plant.

Conditions that cause the specified monitor to alarm that are not related to fuel clad degradation should not result in the declaration of an Unusual Event.

This EAL addresses site-specific radiation monitor readings that provide indication of a degradation of fuel clad integrity.

An Unusual Event is only warranted when actual fuel clad damage is the cause of the elevated coolant sample activity (as determined by laboratory confirmation). Fuel clad damage should be assumed to be the cause of elevated Reactor Coolant activity unless another cause is known.

Escalation of the emergency classification level would be via ICs FA1 or the Recognition Category RA ICs.

Month 20XX FC 3-22 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Basis Reference(s):

1. NEI 99-01 Rev 6, SU3 Month 20XX FC 3-23 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FG1 Initiating Condition:

Loss of ANY Two Barriers AND Loss or Potential Loss of the third barrier.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.

Basis:

Fuel Cladding, RCS and Containment comprise the fission product barriers.

At the General Emergency classification level each barrier is weighted equally.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-24 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FS1 Initiating Condition:

Loss or Potential Loss of ANY two barriers.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.

Basis:

Fuel Cladding, RCS and Containment comprise the fission product barriers.

At the Site Area Emergency classification level, each barrier is weighted equally.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-25 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FA1 Initiating Condition:

ANY Loss or ANY Potential Loss of either Fuel Clad or RCS.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.

Basis:

Fuel Cladding, RCS and Containment comprise the fission product barriers.

At the Alert classification level, Fuel Cladding and RCS barriers are weighted more heavily than the Containment barrier. Unlike the Containment barrier, loss or potential loss of either the Fuel Cladding or RCS barrier may result in the relocation of radioactive materials or degradation of core cooling capability. Note that the loss or potential loss of Containment barrier in combination with loss or potential loss of either Fuel Cladding or RCS barrier results in declaration of a Site Area Emergency under EAL FS1.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-26 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC1 Initiating Condition:

RCS or SG Tube Leakage Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

POTENTIAL LOSS A. RCS/reactor vessel level less than (site specific value).

RVLMS indicates 0.0%.

Basis:

There is no Loss threshold associated with RCS or SG Tube Leakage.

Potential Loss Threshold Basis:

This reading indicates a reduction in reactor vessel water level sufficient to allow the onset of heat-induced cladding damage.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-27 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC2 Initiating Condition:

Inadequate Heat Removal Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

LOSS A. Core Exit Thermocouple readings greater than (site specific temperature value)

1. Core Exit Thermocouple readings > 1550°F Potential Loss A. Core exit thermocouple readings greater than (site specific temperature value).

B. Inadequate RCS heat removal capability via steam generators as indicated by (site specific indications).

2. Core Exit Thermocouple readings > 700°F OR

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

Basis:

Loss Threshold #1 Basis Loss 2.A This reading iIndicates temperatures within the core are sufficient to cause significant superheating of reactor coolant.

Potential Loss Threshold #2 Basis Potential Loss 2.A This reading iIndicates temperatures within the core are sufficient to allow the onset of heat-induced cladding damage.

Potential Loss Threshold #3 Basis Potential Loss 2.B This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the Fuel Clad Barrier. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators; during these conditions, classification using threshold is not warranted.

Month 20XX FC 3-28 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Meeting this threshold results in a Site Area Emergency because this threshold is identical to RCS Barrier RC2 Potential Loss threshold 2.A; both will be met. This condition warrants a Site Area Emergency declaration because inadequate RCS heat removal may result in fuel heat-up sufficient to damage the cladding and increaseraise RCS pressure to the point where mass will be lost from the system.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-29 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC3 Initiating Condition:

Containment Radiation / RCS Activity Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

LOSS 1A. Containment radiation monitor RM-091 A/B readingContainment radiation monitor reading greater than (site specific value) > 6500 R/hr.

OR 2B. (Site-specific indications that reactor coolant activity is greater than 300uCi/gm dose equivalent I-131) Coolant activity as sampled > 180 uCi/gm Dose Equivalent I-131 OR

3. 12.1 Rem/hr on contact or 33 mRem/hr at 30 cm on primary sample piping adjacent to the hood SL-1 per CH-SMP-PA-0007 Basis:

Loss Threshold #1 Basis Loss 3.A The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that reactor coolant activity equals 300180 Ci/gm dose equivalent I-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.

The radiation monitor reading in this threshold is higher than that specified for RCS Barrier RC3 Loss Tthreshold 3.A since it indicates a loss of both the Fuel Clad Barrier and the RCS Barrier. Note that a combination of the two monitor readings appropriately escalates the emergency classification level to a Site Area Emergency.

Loss Threshold #2 Basis Loss 3.B This threshold indicates that RCS radioactivity concentration is greater than 300 180 Ci/gm dose equivalent I-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5%

fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.

Month 20XX FC 3-30 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION It is recognized that sample collection and analysis of reactor coolant with highly elevated activity levels could require several hours to complete. Nonetheless, a sample-related threshold is included as a backup to other indications There is no Fuel Clad Barrier Potential Loss threshold associated with RCS Activity /

Containment Radiation.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-31 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC56 Initiating Condition:

Emergency Director Judgment.

Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

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

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

Basis:

Loss Threshold #1 Basis Loss 6.A This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Fuel Clad Barrier is lost.

Potential Loss Threshold #2 Basis Potential Loss 6.A This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Fuel Clad Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-32 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC1 Initiating Condition:

RCS or SG Tube Leakage Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

LOSS A. An Aautomatic or manual ECCS (SI) actuation is required by EITHER of the following:

a1. UNISOLABLE RCS leakage OR b2. Steam Generator tube RUPTURE.

POTENTIAL LOSS

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

OR

1. Once-Through-Cooling, HR4 in effect.

OR

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

AND

b. Pressure and Temperature is above Attachment PC-12 Pressure Temperature Curve.

Operation of a standby charging (makeup) pump is required by EITHER of the following:1. UNISOLABLE RCS leakage OR SG tube leakage.

B. . RCS cooldown rate greater than (site specific pressurized thermal shock citeria/limits defined by site specific indications)

Month 20XX FC 3-33 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION

3. RCS Integrity Red entry conditions met.

Basis:

UNISOLABLE: An open or breached system line that cannot be isolated, remotely or locally.

RUPTURE(D): The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection.

FAULTED: The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

Loss Threshold #1 Basis Loss 1.A This threshold is based on an UNISOLABLE RCS leak of sufficient size to require an automatic or manual actuation of the Emergency Core Cooling System (ECCS). This condition clearly represents a loss of the RCS Barrier.

This threshold is applicable to unidentified and pressure boundary leakage, as well as identified leakage. It is also applicable to UNISOLABLE RCS leakage through an interfacing system. The mass loss may be into any location - inside containment, to the secondary-side (i.e., steam generator tube leakage) or outside of containment.

A steam generator with primary-to-secondary leakage of sufficient magnitude to require a safety injection is considered to be RUPTURED. If a RUPTURED steam generator is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier CT1 Loss threshold 1.A will also be met.

Potential Loss Threshold #2 Basis Potential Loss 1.A This threshold is based on an UNISOLABLE RCS leak that results in the inability to maintain pressurizer level within specified limits by operation of a normally used charging (makeup) pump, but an ECCS (SI) actuation has not occurred. The threshold is met when an operating procedure, or operating crew supervision, directs that a standby charging (makeup) pump be placed in service to restore and maintain pressurizer level.

Month 20XX FC 3-34 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION This threshold is applicable to unidentified and pressure boundary leakage, as well as identified leakage. It is also applicable to UNISOLABLE RCS leakage through an interfacing system. The mass loss may be into any location - inside containment, to the secondary-side (i.e., steam generator tube leakage) or outside of containment.

If a leaking steam generator is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier Loss threshold CT1.A will also be met.

Potential Loss Threshold #3 Basis The initiation of Once-Through-Cooling, HR4 creates a controlled opening of the RCS to the containment by an open PORV. The opening of the RCS represents a potential challenge to the RCS barrier and is considered a potential loss.

Potential Loss Threshold #4 Basis Potential Loss 1.B This condition indicates an extreme challenge to the integrity of the RCS pressure boundary due to pressurized thermal shock - a transient that causes rapid RCS cooldown while the RCS is in Mode 3 or higher (i.e., hot and pressurized).

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-35 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC2 Initiating Condition:

Inadequate Heat Removal Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

POTENTIAL LOSS A.

Once-Through-Cooling, HR4 in effect.

Inadequate RCS heat removal capability via steam generators as indicated by (site specific indications)

Basis:

There is no Loss threshold associated with Inadequate Heat Removal.

Potential Loss Threshold Basis Potential Loss 2.A Once-Through-Cooling, HR4 in effect indicates a Lack of Primary to Secondary Heat Transfer capability.

This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the RCS Barrier. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators; during these conditions, classification using threshold is not warranted.

Meeting this threshold results in a Site Area Emergency because this threshold is identical to Fuel Clad Barrier FC2 Potential Loss Tthreshold 2.B#3; both will be met.

This condition warrants a Site Area Emergency declaration because inadequate RCS heat removal may result in fuel heat-up sufficient to damage the cladding and increaseraise RCS pressure to the point where mass will be lost from the system.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-36 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC3 Initiating Condition:

Containment Radiation / RCS Activity Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

LOSS A. Containment radiation monitor RM-091 A/B readingContainment radiation monitor reading greater than > 40 R/hr.

(site specific value).

Basis:

Loss Threshold Basis Loss 3.A The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that reactor coolant activity equals Technical Specification allowable limits. This value is lower than that specified for Fuel Clad Barrier FC3 Loss Tthreshold 3.A#1 since it indicates a loss of the RCS Barrier only.

There is no RCS Potential Loss threshold associated with RCS Activity / Containment Radiation.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-37 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC56 Initiating Condition:

Emergency Director Judgment.

Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

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

POTENTIAL LOSS 2B. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.

Basis:

Loss Threshold #1 Basis Loss 6.A This threshold addresses any other factors that may be used by the Emergency Director in determining whether the RCS Barrier is lost.

Potential Loss Threshold #2 Basis Potential Loss 6.A This threshold addresses any other factors that may be used by the Emergency Director in determining whether the RCS Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-38 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT1 Initiating Condition:

RCS or SG Tube Leakage Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

LOSS A. A leaking or RUPTURED SG is FAULTED outside of containment.

1. SG tube leakage > the capacity of one charging pump in the normal charging mode (greater than 40 gpm).

AND

2. SG is FAULTED outside of containment.

Basis:

FAULTED: The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

RUPTURE(D): The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection.

Loss Threshold Basis Loss 1.A This threshold addresses a leaking or RUPTURED Steam Generator (SG) that is also FAULTED outside of containment. The condition of the SG, whether leaking or RUPTURED, is determined in accordance with the thresholds for RCS Barrier RC1 Potential Loss Threshold 2.b 1.A and Loss Threshold 1.b.A, respectively. This condition represents a bypass of the containment barrier.

FAULTED is a defined term within the NEI 99-01 methodology; this determination is not necessarily dependent upon entry into, or diagnostic steps within, an EOP. For example, if the pressure in a steam generator is decreasing uncontrollably [part of the FAULTED definition] and the faulted steam generator isolation procedure is not entered because EOP user rules are dictating implementation of another procedure to address a higher priority condition, the steam generator is still considered FAULTED for emergency classification purposes.

The FAULTED criterion establishes an appropriate lower bound on the size of a steam release that may require an emergency classification. Steam releases of this size are readily observable with normal Control Room indications. The lower bound for this aspect of the containment barrier is analogous to the lower bound criteria specified in IC RSU3 for the fuel clad barrier (i.e., RCS activity values) and IC MSU64 for the RCS barrier (i.e., RCS leak rate values).

Month 20XX FC 3-39 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION This threshold also applies to prolonged steam releases necessitated by operational considerations such as the forced steaming of a leaking or RUPTURED steam generator directly to atmosphere to cooldown the plant, or to drive an auxiliary (emergency) feed water pump. These types of conditions will result in a significant and sustained release of radioactive steam to the environment (and are thus similar to a FAULTED condition). The inability to isolate the steam flow without an adverse effect on plant cooldown meets the intent of a loss of containment.

Steam releases associated with the expected operation of a SG power operated relief valve or safety relief valve do not meet the intent of this threshold. Such releases may occur intermittently for a short period of time following a reactor trip as operators process through emergency operating procedures to bring the plant to a stable condition and prepare to initiate a plant cooldown. Steam releases associated with the unexpected operation of a valve (e.g., a stuck-open safety valve) do meets this threshold.

Following an SG tube leak or rupture, there may be minor radiological releases through a secondary-side system component (e.g., air ejectors, glad seal exhausters, valve packing, etc.). These types of releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category RA ICs.

The emergency classification levels resulting from primary-to-secondary leakage, with or without a steam release from the FAULTED SG, are summarized below.

Month 20XX FC 3-40 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Affected SG is FAULTED Outside of Containment?

P-to-S Leak Rate Yes No Less than or equal to 25 No classification No classification gpm (or other value per SU4 Developer Notes)

Greater than 25 gpm (or Unusual Event per Unusual Event per other value per SU4 SU4MU6 SU4MU6 Developer Notes)

The capacity of one charging pump in the normal charging mode (greater than 40 gpm) is Site Area Emergency Alert per FA1 exceeded Requires per FS1 operation of a standby charging (makeup) pump (RCS Barrier Potential Loss)

Requires an automatic or Site Area Emergency Alert per FA1 manual ECCS (SI) actuation per FS1 (RCS Barrier Loss)

There is no Potential Loss threshold associated with RCS or SG Tube Leakage.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-41 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT2 Initiating Condition:

Inadequate Heat Removal Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

POTENTIAL LOSS A. 1. (Site specific criteria for entry into core cooling restoration procedure)

AND

2. Restoration procedure not effective within 15 minutes.

1. a. Tclad > 1550°F.

AND

b. Restoration procedures not effective in < 15 minutes.

OR

2. a. Core exit thermocouples > 700 ºF AND

b. RVLMS indicates 0.0%

AND

c. Restoration procedures not effective in < 15 minutes.

Basis:

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

There is no Loss threshold associated with Inadequate Heat Removal.

Potential Loss Threshold Basis Potential Loss 2.A This condition represents an IMMINENT core melt sequence which, if not corrected, could lead to vessel failure and an increased potential for containment failure. For this condition to occur, there must already have been a loss of the RCS Barrier and the Fuel Clad Barrier. If implementation of a procedure(s) to restore adequate core cooling is not effective (successful) within 15 minutes, it is assumed that the event trajectory will likely lead to core melting and a subsequent challenge of the Containment Barrier.

The restoration procedure is considered effective if core exit thermocouple readings are decreasing and/or if reactor vessel level is increasing. Whether or not the procedure(s) will be effective should be apparent within 15 minutes. The Emergency Month 20XX FC 3-42 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Director should escalate the emergency classification level as soon as it is determined that the procedure(s) will not be effective.

Severe accident analyses (e.g., NUREG-1150) have concluded that function restoration procedures can arrest core degradation in a significant fraction of core damage scenarios, and that the likelihood of containment failure is very small in these events.

Given this, it is appropriate to provide 15 minutes beyond the required entry point to determine if procedural actions can reverse the core melt sequence.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-43 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT3 Initiating Condition:

Containment Radiation / RCS Activity Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

POTENTIAL LOSS A. Containment radiation monitor RM-091 A/B reading Containment radiation monitor reading greater than > 26,000 R/hr.(site specific value).

Basis:

There is no Loss threshold associated with RCS Activity / Containment Radiation.

Potential Loss Threshold Basis Potential Loss 3.A The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that 20% of the fuel cladding has failed.

This level of fuel clad failure is well above that used to determine the analogous Fuel Clad Barrier Loss and RCS Barrier Loss thresholds.

NUREG-1228, Source Estimations During Incident Response to Severe Nuclear Power Plant Accidents, indicates the fuel clad failure must be greater than approximately 20%

in order for there to be a major release of radioactivity requiring offsite protective actions. For this condition to exist, there must already have been a loss of the RCS Barrier and the Fuel Clad Barrier. It is therefore prudent to treat this condition as a potential loss of containment which would then escalate the emergency classification level to a General Emergency.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-44 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT4 Initiating Condition:

Containment Integrity or Bypass Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

LOSS 1A. Containment isolation is required AND EITHER of the following:

a1. UNPLANNED decrease lowering in containment pressure or rise in radiation monitor readings outside of containment in the Emergency Directors judgment that indicate a loss of containment integrity.

OR b2. UNISOLABLE pathway from containment to the environment exists.

OR 2B. Indication of RCS leakage outside of containment POTENTIAL LOSS 3A. Containment Red entry conditions met Containment Pressure > 60 psig and rising.

OR 4B. Explosive mixture exists inside containment.Hydrogen Concentration in Containment > 3%.

OR 5C. a1. Containment pressure greater than (site specific pressure setpoint)> 5 psig AND b2. Less than one full train of (site specific system or equipment) is operating per design for 15 minutes or longer.Containment Cooling OR Containment Spray equipment operating.

Basis:

FAULTED: The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

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

UNISOLABLE: An open or breached system line that cannot be isolated, remotely or locally.

Month 20XX FC 3-45 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION LossThreshold #1 Basis:

Loss 4.A These thresholds address a situation where containment isolation is required and one of two conditions exists as discussed below. Users are reminded that there may be accident and release conditions that simultaneously meet both loss thresholds 1.a4.A.1 and 1.b4.A.2.

1.a4.A.1 - Containment integrity has been lost, i.e., the actual containment atmospheric leak rate likely exceeds that associated with allowable leakage (or sometimes referred to as design leakage). Following the release of RCS mass into containment, containment pressure will fluctuate based on a variety of factors; a loss of containment integrity condition may (or may not) be accompanied by a noticeable drop in containment pressure. Recognizing the inherent difficulties in determining a containment leak rate during accident conditions, it is expected that the Emergency Director will assess this threshold using judgment, and with due consideration given to current plant conditions, and available operational and radiological data (e.g.,

containment pressure, readings on radiation monitors outside containment, operating status of containment pressure control equipment, etc.).

Refer to the middle piping run of Figure 9-F-4. Two simplified examples are provided.

One is leakage from a penetration and the other is leakage from an in-service system valve. Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure.

Another example would be a loss or potential loss of the RCS barrier, and the simultaneous occurrence of two FAULTED locations on a steam generator where one fault is located inside containment (e.g., on a steam or feedwater line) and the other outside of containment. In this case, the associated steam line provides a pathway for the containment atmosphere to escape to an area outside the containment.

Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable (design) containment leakage through various penetrations or system components. These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category RA ICs.

1.b4.A.2 - Conditions are such that there is an UNISOLABLE pathway for the migration of radioactive material from the containment atmosphere to the environment. As used here, the term environment includes the atmosphere of a room or area, outside the containment, that may, in turn, communicate with the outside-the-plant atmosphere (e.g., through discharge of a ventilation system or atmospheric leakage). Depending upon a variety of factors, this condition may or may not be accompanied by a noticeable drop in containment pressure.

Refer to the top piping run of Figure 9-F-4. In this simplified example, the inboard and outboard isolation valves remained open after a containment isolation was required (i.e.,

Month 20XX FC 3-46 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION containment isolation was not successful). There is now an UNISOLABLE pathway from the containment to the environment.

The existence of a filter is not considered in the threshold assessment. Filters do not remove fission product noble gases. In addition, a filter could become ineffective due to iodine and/or particulate loading beyond design limits (i.e., retention ability has been exceeded) or water saturation from steam/high humidity in the release stream.

Leakage between two interfacing liquid systems, by itself, does not meet this threshold.

Refer to the bottom piping run of Figure 9-F-4. In this simplified example, leakage in an RCP seal cooler is allowing radioactive material to enter the Auxiliary Building. The radioactivity would be detected by the Process Monitor. If there is no leakage from the closed water cooling system to the Auxiliary Building, then no threshold has been met.

If the pump or system piping developed a leak that allowed steam/water to enter the Auxiliary Building, then loss threshold 24.B would be met. Depending upon radiation monitor locations and sensitivities, this leakage could be detected by any of the four monitors depicted in the figure and cause threshold 1.a4.A.1 to be met as well.

Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable (design) containment leakage through various penetrations or system components. Minor releases may also occur if a containment isolation valve(s) fails to close but the containment atmosphere escapes to a closed system. These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category RA ICs.

The status of the containment barrier during an event involving steam generator tube leakage is assessed using Containment Barrier CT1 Loss Tthreshold 1.A.

Loss Threshold #2 Basis:

Loss 4.B Containment sump, temperature, pressure and/or radiation levels will increaserise if reactor coolant mass is leaking into the containment. If these parameters have not increased, then the reactor coolant mass may be leaking outside of containment (i.e., a containment bypass sequence). IncreaseRaises in sump, temperature, pressure, flow and/or radiation level readings outside of the containment may indicate that the RCS mass is being lost outside of containment.

Unexpected elevated readings and alarms on radiation monitors with detectors outside containment should be corroborated with other available indications to confirm that the source is a loss of RCS mass outside of containment. If the fuel clad barrier has not been lost, radiation monitor readings outside of containment may not increaserise significantly; however, other unexpected changes in sump levels, area temperatures or pressures, flow rates, etc. should be sufficient to determine if RCS mass is being lost outside of the containment.

Month 20XX FC 3-47 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Refer to the middle piping run of Figure 9-F-4. In this simplified example, a leak has occurred at a reducer on a pipe carrying reactor coolant in the Auxiliary Building.

Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure and cause loss threshold 1.a4.A.1 to be met as well.

To ensure proper escalation of the emergency classification, the RCS leakage outside of containment must be related to the mass loss that is causing the RCS Barrier RC1 Loss Threshold 1.a and/or Potential Loss threshold 2.a1.A to be met.

Potential Loss Threshold #3 Basis Potential Loss 4.A If containment pressure exceeds the design pressure, there exists a potential to lose the Containment Barrier. To reach this level, there must be an inadequate core cooling condition for an extended period of time; therefore, the RCS and Fuel Clad barriers would already be lost. Thus, this threshold is a discriminator between a Site Area Emergency and General Emergency since there is now a potential to lose the third barrier.

Potential Loss Threshold #4 Basis Potential Loss 4.B The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a potential loss of the Containment Barrier.

Potential Loss Threshold #5 Basis Potential Loss 4.C This threshold describes a condition where containment pressure is greater than the setpoint at which containment energy (heat) removal systems are designed to automatically actuate, and less than one full train of equipment is capable of operating per design. The 15-minute criterion is included to allow operators time to manually start equipment that may not have automatically started, if possible. This threshold represents a potential loss of containment in that containment heat removal/depressurization systems (e.g., containment sprays, ice condenser fans, etc.,

but not including containment venting strategies) are either lost or performing in a degraded manner Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-48 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Figure 9-F-4: PWR Containment Integrity or Bypass Examples 4.A.21.b -

Effluent Airborne release from Inside Auxiliary Building Monitor Vent pathway Containment Damper Filter Area Monitor Open valve Open valve Damper 4.A.11.a -

Airborne Penetration release from valve Airborne Monitor Open valve Open valve 4.B2. - RCS 4.A.11.a - leakage Interface leakage Airborne outside point release from CNMT penetration Process Monitor Closed Cooling Water Open valve Open valve Pump System RCP Seal Cooling Month 20XX FC 3-49 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT56 Initiating Condition:

Emergency Director Judgment.

Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

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

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

Basis:

Loss Threshold #1 Basis Loss 6.A This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Containment Barrier is lost.

Potential Loss Threshold #2 Basis Potential Loss 6.A This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Containment Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-50 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSG1 Initiating Condition:

Prolonged loss of all Off-site and all On-Site AC power to emergency busses.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

Note: The Emergency Director should declare the General Emergencyevent promptly upon determining that (site-specific hours) the applicable time has been exceeded, or will likely be exceeded.

1 a. Loss of ALL offsite and ALL onsite AC power to (site-specific emergency buses) vital 4160 volt buses 1A3 and 1A4.

AND

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

AND 3b. EITHER of the following:

a. Restoration of at least one emergency vital 4160 volt bus in < 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is notless than (site-specific hours) is not likely.

OR

b. Core exit thermocouples > 1550°F.

(Site-specific indication of an inability to adequately remove heat from the core)

Basis:

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses a prolonged loss of all power sources to AC emergency buses. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. A prolonged loss of these buses will lead to a loss of one or moreany fission product Month 20XX FC 3-51 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS barriers. In addition, fission product barrier monitoring capabilities may be degraded under these conditions.

The EAL should require declaration of a General Emergency prior to meeting the thresholds for IC FG1. This will allow additional time for implementation of offsite protective actions.

Escalation of the emergency classification from Site Area Emergency will occur if it is projected that power cannot be restored to at least one AC emergency bus by the end of the analyzed station blackout coping period. Beyond this time, plant responses and event trajectory are subject to greater uncertainty, and there is an increased likelihood of challenges to multiple fission product barriers.

The estimate for restoring at least one emergency bus should be based on a realistic appraisal of the situation. Mitigation actions with a low probability of success should not be used as a basis for delaying a classification upgrade. The goal is to maximize the time available to prepare for, and implement, protective actions for the public.

The EAL will also require a General Emergency declaration if the loss of AC power results in parameters that indicate an inability to adequately remove decay heat from the core.

Basis Reference(s):

1. NEI 99-01 Rev 6, SG1 Month 20XX FC 3-52 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSS1 Initiating Condition:

Loss of all offsite and all onsite AC power to emergency busses for 15 minutes or longer.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

Note: The Emergency Director should declare the Site Area Emergencyevent promptly upon determining that the applicable time 15 minutes has been exceeded, or will likely be exceeded.

1. Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses) vital 4160 volt buses 1A3 and 1A4 for 15 minutes or longer.

AND

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

AND

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

Basis:

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. In addition, fission product barrier monitoring capabilities may be degraded under these conditions. This IC represents a condition that involves actual or likely major failures of plant functions needed for the protection of the public.

The emergency busses of the affected unit can be powered from the unaffected unit through the crosstie breakers. Unit crosstie is considered an adequate source of offsite power when evaluating this EAL.

Month 20XX FC 3-53 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Escalation of the emergency classification level would be via ICs RAG1, FG1, or MSG1, or MG2.

Basis Reference(s):

1. NEI 99-01 Rev 6, SS1 Month 20XX FC 3-54 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSA1 Initiating Condition:

Loss of all but one AC power source to emergency buses for 15 minutes or longer.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

Note: The Emergency Director should declare the eventAlert promptly upon determining that the applicable time 15 minutes has been exceeded, or will likely be exceeded.

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

161 Kv Circuit 345 Kv Circuit EDG DG1 EDG DG2

a. AC power capability to (site-specific emergency buses) is reduced to a single power source for 15 minutes or longer.

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

Basis:

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment. This IC provides an escalation path from IC MSU1.

An AC power source is a source recognized in AOPs and EOPs, and capable of supplying required power to an emergency bus. Some examples of this condition are presented below.

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

Month 20XX FC 3-55 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS A loss of all offsite power and loss of all emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from the unit main generator.

A loss of emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from an offsite power source.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.

Escalation of the emergency classification level would be via IC MSS1.

Basis Reference(s):

1. NEI 99-01 Rev 6, SA1 Month 20XX FC 3-56 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSU1 Initiating Condition:

Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

Note: The Emergency Director should declare the Unusual Eventevent promptly upon determining that the applicable time 15 minutes has been exceeded, or will likely be exceeded.

1. Loss of ALL offsite AC power capability to vital 4160 volt buses 1A3 and 1A4 (site-specific emergency buses) for > 15 minutes or longer.

Basis:

This IC addresses a prolonged loss of offsite power. The loss of offsite power sources renders the plant more vulnerable to a complete loss of power to AC emergency buses.

This condition represents a potential reduction in the level of safety of the plant.

For emergency classification purposes, capability means that an offsite AC power source(s) is available to the emergency buses, whether or not the buses are powered from it.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of offsite power.

Escalation of the emergency classification level would be via IC MSA1.

Basis Reference(s):

1. NEI 99-01 Rev 6, SU1 Month 20XX FC 3-57 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSG28 Initiating Condition:

Loss of all AC and Vital DC power sources for 15 minutes or longer.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

Note: The Emergency Director should declare the General Emergencyevent promptly upon determining that the applicable time 15 minutes has been exceeded, or will likely be exceeded.

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

AND

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

AND

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

AND

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

1. a. Loss of ALL offsite and ALL onsite AC power to (site-specific emergency buses) for 15 minutes or longer.

AND

b. Indicated voltage is less than (site-specific bus voltage value) on ALL (site-specific Vital DC busses) for 15 minutes or longer.

Basis:

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

Month 20XX FC 3-58 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS This IC addresses a concurrent and prolonged loss of both AC and Vital DC power. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. A loss of Vital DC power compromises the ability to monitor and control SAFETY SYSTEMS. A sustained loss of both AC and DC power will lead to multiple challenges to fission product barriers.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. The 15-minute emergency declaration clock begins at the point when both all EALs thresholds are met.

Basis Reference(s):

1. NEI 99-01 Rev 6, SG8 Month 20XX FC 3-59 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSS28 Initiating Condition:

Loss of all vital DC power for 15 minutes or longer.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

Note: The Emergency Director should declare the Site Area Emergencyevent promptly upon determining that the applicable time 15 minutes has been exceeded, or will likely be exceeded.

Indicated vVoltage is < 105 VDC less than (site-specific bus voltage value) on 125 VDC Bus1and Bus 2ALL (site-specific Vital DC busses) for >15 minutes or longer.

Basis:

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses a loss of Vital DC power which compromises the ability to monitor and control SAFETY SYSTEMS. In modes above Cold Shutdown, this condition involves a major failure of plant functions needed for the protection of the public.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Escalation of the emergency classification level would be via ICs RAG1, FG1 or MSG38.

Basis Reference(s):

1. NEI 99-01 Rev 6, SS8 Month 20XX FC 3-60 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSS35 Initiating Condition:

Inability to shutdown the reactor causing a challenge to core cooling or RCS heat removal.

Operating Mode Applicability:

1, 2 Emergency Action Level (EAL):

1. Automatic or Manual Ttrip did not shutdown the reactor as indicated by Reactor Power > 2%.

AND

2. All ALL manual actions to shutdown the reactor have been unsuccessful as indicated by Reactor Power > 2%.

AND

3. EITHER of the following conditions exist:

a. Core exit thermocouples > 1550°F.

OR

b. RVLMS indicates 0.0%

OR

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

a. (Site-specific indication of an inability to adequately remove heat from the core)

OR

b. (Site-specific indication of an inability to adequately remove heat from the RCS)

Basis:

This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, all subsequent operator manual actions, both inside and outside the Control Room including driving in control rods and boron Month 20XX FC 3-61 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS injection,all subsequent operator actions to manually shutdown the reactor are unsuccessful, and continued power generation is challenging the capability to adequately remove heat from the core and/or the RCS. This condition will lead to fuel damage if additional mitigation actions are unsuccessful and thus warrants the declaration of a Site Area Emergency.

In some instances, the emergency classification resulting from this IC/EAL may be higher than that resulting from an assessment of the plant responses and symptoms against the Recognition Category F ICs/EALs. This is appropriate in that the Recognition Category F ICs/EALs do not address the additional threat posed by a failure to shutdown the reactor. The inclusion of this IC and EAL ensures the timely declaration of a Site Area Emergency in response to prolonged failure to shutdown the reactor.

A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.

Escalation of the emergency classification level would be via IC RAG1 or FG1.

Basis Reference(s):

1. NEI 99-01 Rev 6, SS5 Month 20XX FC 3-62 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSA35 Initiating Condition:

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

Operating Mode Applicability:

1, 2 Emergency Action Level (EAL):

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

1. An aAutomatic or manual Ttrip did not shutdown the reactor as indicated by Reactor Power > 2%.

AND

2. Manual actions taken at the reactor control consolesConsole Center are not successful in shutting down the reactor as indicated by Reactor Power > 2%.

Basis:

This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, and subsequent operator manual actions taken at the Console Center reactor control consoles to shutdown the reactor are also unsuccessful. This condition represents an actual or potential substantial degradation of the level of safety of the plant. An emergency declaration is required even if the reactor is subsequently shutdown by an action taken away from the reactor control consoles since this event entails a significant failure of the RPS.

A manual action at the Console Center reactor control consoles is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g.,

initiating a manual reactor trip. This action does not include manually driving in control rods or implementation of boron injection strategies. If this action(s) is unsuccessful, operators would immediately pursue additional manual actions at locations away from the Console Center reactor control consoles (e.g., locally opening breakers). Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be at the Console Centerreactor control consoles.

The plant response to the failure of an automatic or manual reactor trip will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If the failure to shutdown the reactor is prolonged enough to cause a challenge to the core cooling or RCS heat removal safety functions, the emergency Month 20XX FC 3-63 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS classification level will escalate to a Site Area Emergency via IC MSS35. Depending upon plant responses and symptoms, escalation is also possible via IC FS1. Absent the plant conditions needed to meet either IC MSS35 or FS1, an Alert declaration is appropriate for this event.

It is recognized that plant responses or symptoms may also require an Alert declaration in accordance with the Recognition Category F ICs; however, this IC and EAL are included to ensure a timely emergency declaration.

A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.

Basis Reference(s):

1. NEI 99-01 Rev 6, SA5 Month 20XX FC 3-64 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSU35 Initiating Condition:

Automatic or manual trip fails to shutdown the reactor.

Operating Mode Applicability:

1, 2 Emergency Action Level (EAL):

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

1. a. An aAutomatic Ttrip did not shutdown the reactor as indicated by Reactor Power > 2%.

AND

b. A sSubsequent manual action taken at the reactor control consolesConsole Center is successful in shutting down the reactor.

OR

2. a. A mManual Ttrip did not shutdown the reactor as indicated by Reactor Power > 2%.

AND

b. EITHER of the following:

1. A subsequent manual action taken at the reactor control consoles is successful in shutting down the reactor.

OR

2. A sSubsequent automatic Ttrip is successful in shutting down the reactor.

Basis:

This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, and either a subsequent operator manual Month 20XX FC 3-65 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS action taken at the Console Center reactor control consoles or an automatic trip is successful in shutting down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.

EAL #1 Basis Following the failure on an automatic reactor trip, operators will promptly initiate manual actions at the Console Center reactor control consoles to shutdown the reactor (e.g.,

initiate a manual reactor trip). If these manual actions are successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plants decay heat removal systems.

EAL #2 Basis If an initial manual reactor trip is unsuccessful, operators will promptly take manual action at another location(s) on the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor trip using a different switch). Depending upon several factors, the initial or subsequent effort to manually trip the reactor, or a concurrent plant condition, may lead to the generation of an automatic reactor trip signal. If a subsequent manual or automatic trip is successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plants decay heat removal systems.

A manual action at the Console Center reactor control consoles is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g.,

initiating a manual reactor trip). This action does not include manually driving in control rods or implementation of boron injection strategies. Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be at the Console Center reactor control consoles.

The plant response to the failure of an automatic or manual reactor trip will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If subsequent operator manual actions taken at the Console Center reactor control consoles are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC MSA35. Depending upon the plant response, escalation is also possible via IC FA1. Absent the plant conditions needed to meet either IC MSA35 or FA1, an Unusual Event declaration is appropriate for this event.

A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.

Should a reactor trip signal be generated as a result of plant work (e.g., RPS setpoint testing), the following classification guidance should be applied.

Month 20XX FC 3-66 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS If the signal generated as a result of plant work causes a plant transient that created a real condition that should have included an automatic reactor trip and the RPS fails to automatically shutdown the reactor, then this IC and the EALs are applicable, and should be evaluated.

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

Basis Reference(s):

1. NEI 99-01 Rev 6, SU5 Month 20XX FC 3-67 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSA42 Initiating Condition:

UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

Note: The Emergency Director should declare the eventAlert promptly upon determining that the applicable time 15 minutes has been exceeded, or will likely be exceeded.

1. a. An UNPLANNED event results in the inability to monitor ANYone or more Table M1of the following parameters from within the Control Room for >15 minutes or longer.

[see table below]

[ PWR parameter list]

Table M1 Control Room Parameters Reactor Power Reactor Power RCS Level PZR Level RCS Pressure RCS Pressure In Core/Core Exit In Core/Core Exit Temperature Temperature Level in at least one Steam Levels in at least (site specific Generator number) steam generators Steam Generator Auxiliary or Auxiliary Feed Water Flow Emergency Feed Water Flow AND

b. Any Table M2of the following transient events in progress.

Automatic or Manual runback greater than 25% thermal reactor power Electrical load rejection greater than 25% full electrical load Reactor trip ECCS (SI) actuation Month 20XX FC 3-68 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Table M2 Significant Transients Electrical Load Rejection >25% full electrical load Reactor Trip ECCS Actuation Basis:

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

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses the difficulty associated with monitoring rapidly changing plant conditions during a transient without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. During this condition, the margin to a potential fission product barrier challenge is reduced. It thus represents a potential substantial degradation in the level of safety of the plant.

As used in this EAL, an inability to monitor means that values for one or moreany of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s). For example, the reactor power level cannot be determined from any analog, computer point, digital and recorder source within the Control Room.

An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required. The event would be reported if it significantly impaired the capability to perform emergency assessments. In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making.

Month 20XX FC 3-69 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling and RCS heat removal. The loss of the ability to determine one or moreany of these parameters from within the Control Room is considered to be more significant than simply a reportable condition. In addition, if all indication sources for one or moreany of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.

Escalation of the emergency classification level would be via ICs FS1 or IC RAS1.

Basis Reference(s):

1. NEI 99-01 Rev 6, SA2 Month 20XX FC 3-70 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSU42 Initiating Condition:

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

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

Note: The Emergency Director should declare the Unusual Eventevent promptly upon determining that the applicable time 15 minutes has been exceeded, or will likely be exceeded.

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

Table M1 Control Room Parameters Reactor Power PZR Level RCS Pressure In Core/Core Exit Temperature Level in at least one Steam Generator Auxiliary Feed Water Flow

1. of the following parameters from within the Control Room for 15 minutes or longer.

Month 20XX FC 3-71 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS

2. [BWR parameter 3. [PWR parameter list] list]

4. Reactor Power 6. Reactor Power

5. 7.

8. RPV Water Level 9. RCS Level

10. RPV Pressure 11. RCS Pressure

12. Primary 13. In-Core/Core Containment Exit Temperature Pressure

14. Suppression Pool 15. Levels in at least Level (site-specific number) steam generators

16. Suppression Pool 17. Steam Generator Temperature Auxiliary or Emergency Feed Water Flow Month 20XX FC 3-72 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Basis:

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

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses the difficulty associated with monitoring normal plant conditions without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. This condition is a precursor to a more significant event and represents a potential degradation in the level of safety of the plant.

As used in this EAL, an inability to monitor means that values for one or moreany of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s). For example, the reactor power level cannot be determined from any analog, digital and recorder source within the Control Room.

An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required. The event would be reported if it significantly impaired the capability to perform emergency assessments. In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making.

This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling and RCS heat removal. The loss of the ability to determine one or moreany of these parameters from within the Control Room is considered to be more significant than simply a reportable condition. In addition, if all indication sources for one or moreany of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.

Escalation of the emergency classification level would be via IC MSA42.

Month 20XX FC 3-73 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Basis Reference(s):

1. NEI 99-01 Rev 6, SU2 Month 20XX FC 3-74 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSA59 Initiating Condition:

Hazardous event affecting a SAFETY SYSTEM needed required for the current operating mode.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

(1) 1. a. The occurrence of ANY of the following hazardous events:

Seismic event (earthquake)

Internal or external flooding event High winds or tornado strike FIRE EXPLOSION (site-specific hazards)

Other events with similar hazard characteristics as determined by the Shift Manager AND 2.b. EITHER of the following:

a.1. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM needed required by Technical Specifications for the current operating mode.

OR b.2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure neededrequired by Technical Specifications for the current operating mode.

Basis:

FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.

EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion. Such Month 20XX FC 3-75 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS events may require a post-event inspection to determine if the attributes of an explosion are present.

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

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

This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or a structure containing SAFETY SYSTEM components, needed required for the current operating mode, "required", i.e. required to be operable by Technical Specifications for the current operating mode. This condition significantly reduces the margin to a loss or potential loss of a fission product barrier, and therefore represents an actual or potential substantial degradation of the level of safety of the plant. Manual or automatic electrical isolation of safety equipment due to flooding, in and of itself, does not constitute degraded performance and is classified under HU6.

EAL 1.b.1#2.a Basis This EAL addresses damage to a SAFETY SYSTEM train that is required to be operable by Technical Specifications for the current operating mode, and is in service/operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

EAL 1.b.2#2.b Basis This EAL addresses damage to a SAFETY SYSTEM component that is required to be operable by Technical Specifications for the current operating mode, and is not in service/operation or readily apparent through indications alone, or as well as damage to a structure containing SAFETY SYSTEM components. Operators will make this determination based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.

Escalation of the emergency classification level would be via IC FS1 or RAS1.

If the EAL conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.

Basis Reference(s):

1. NEI 99-01, Rev 6 SA9 Month 20XX FC 3-76 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSU64 Initiating Condition:

RCS leakage for 15 minutes or longer.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

Note: The Emergency Director should declare the Unusual Eventevent promptly upon determining that the applicable time 15 minutes has been exceeded, or will likely be exceeded.

1. RCS unidentified or pressure boundary leakage greater than

> 10 gpm for > 15 minutes. (site-specific value) for 15 minutes or longer.

OR

2. RCS identified leakage greater than >25 gpm for > 15 minutes.(site-specific value) for 15 minutes or longer.

OR

3. Leakage from the RCS to a location outside containment >25 gpm for > 15 minutes.

greater than 25 gpm for 15 minutes or longer.

Basis:

UNISOLABLE: An open or breached system line that cannot be isolated, remotely or locally.

This IC addresses RCS leakage which may be a precursor to a more significant event.

In this case, RCS leakage has been detected and operators, following applicable procedures, have been unable to promptly isolate the leak. This condition is considered to be a potential degradation of the level of safety of the plant.

EAL #1 and EAL #2 Basis These EALs are focused on a loss of mass from the RCS due to unidentified leakage",

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

EAL #3 Basis This EAL addresses a RCS mass loss caused by an UNISOLABLE leak through an interfacing system.

These EALs thus apply to leakage into the containment, a secondary-side system (e.g.,

steam generator tube leakage) or a location outside of containment.

Month 20XX FC 3-77 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS The leak rate values for each EAL were selected because they are usually observable with normal Control Room indications. Lesser values typically require time-consuming calculations to determine (e.g., a mass balance calculation). EAL #1 uses a lower value that reflects the greater significance of unidentified or pressure boundary leakage.

The release of mass from the RCS due to the as-designed/expected operation of a relief valve does not warrant an emergency classification. An emergency classification would be required if a mass loss is caused by a relief valve that is not functioning as designed/expected (e.g., a relief valve sticks open and the line flow cannot be isolated).

The 15-minute threshold duration allows sufficient time for prompt operator actions to isolate the leakage, if possible.

Escalation of the emergency classification level would be via ICs of Recognition Category RA or F.

Basis Reference(s):

1. NEI 99-01 Rev 6, SU4 Month 20XX FC 3-78 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSU76 Initiating Condition:

Loss of all On-site or Off-site communications capabilities.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

1. Loss of ALL Table M3 Onsite communications capability affecting the ability to perform routine operations.

OR

2. Loss of ALL Table M3 Offsite communication capability affecting the ability to perform offsite notifications.

OR

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

Table M3 Communications Capability System Onsite Offsite NRC 800 MHz Radio System X Gai-tronics System X Security Building PABX X X X Training Building PABX X X X Commercial Telephones X X X Conference Operations X

Network (COP)

FTS-ENS X X HPN? X X Satellite phones X X Blair Phone Line X

1. Loss of ALL of the following onsite communication methods:

(site-specific list of communications method Month 20XX FC 3-79 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS

2. Loss of ALL of the following ORO communications s) methods:

(site-specific list of communications methods)

3. Loss of ALL of the following NRC communications methods:

(site-specific list of communications methods)

Basis:

This IC addresses a significant loss of on-site , offsite, or NRC or offsite communications capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.

This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).

EAL #1 Basis aAddresses a total loss of the communications methods used in support of routine plant operations.

EAL #2 Basis aAddresses a total loss of the communications methods used to notify all OROs of an emergency declaration. The OROs referred to here are listed in procedure EP-MA-114-100-F-01, State / Local Event Notification Form. (see Developer Notes).

EAL #3 basis aAddresses a total loss of the communications methods used to notify the NRC of an emergency declaration.

Basis Reference(s):

1. NEI 99-01 Rev 6, SU6 Month 20XX FC 3-80 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSU87 Initiating Condition:

Failure to isolate containment or loss of containment pressure control.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

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

AND

b. ANY required penetration remains open > 15 minutes of the actuation signal.ALL required penetrations are not closed within 15 minutes of the actuation signal.

OR

2. a. Containment pressure > 5 psig AND

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

. a. Containment pressure greater than (site-specific pressure).

AND

b. Less than one full train of (site-specific system or equipment) is operating per design for 15 minutes or longer.

Basis:

This IC addresses a failure of one or moreany containment penetrations to automatically isolate (close) when required by an actuation signal. It also addresses an event that results in high containment pressure with a concurrent failure of containment pressure control systems. Absent challenges to another fission product barrier, either condition represents potential degradation of the level of safety of the plant.

For EAL #1Basis

, tThe containment isolation signal must be generated as the result on an off-normal/accident condition (e.g., a safety injection or high containment pressure); a failure resulting from testing or maintenance does not warrant classification. The determination of containment and penetration status - isolated or not isolated - should Month 20XX FC 3-81 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS be made in accordance with the appropriate criteria contained in the plant AOPs and EOPs. The 15-minute criterion is included to allow operators time to manually isolate the required penetrations, if possible.

EAL #2 Basis aAddresses a condition where containment pressure is greater than the setpoint at which containment energy (heat) removal systems are designed to automatically actuate, and less than one full train of equipment is capable of operating per design.

The 15-minute criterion is included to allow operators time to manually start equipment that may not have automatically started, if possible. The inability to start the required equipment indicates that containment heat removal/depressurization systems (e.g.,

containment sprays or ice condenser fans) are either lost or performing in a degraded manner.

This event would escalate to a Site Area Emergency in accordance with IC FS1 if there were a concurrent loss or potential loss of either the Fuel Clad or RCS fission product barriers.

Basis Reference(s):

1. NEI 99-01 Rev 6, SU7 Month 20XX FC 3-82 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA12 Initiating Condition:

Loss of all offsite and all onsite AC power to emergency busses for 15 minutes or longer.

Operating Mode Applicability:

4, 5, D Emergency Action Level (EAL):

Note: The Emergency Director should declare the Alert event promptly upon determining that the applicable time 15 minutes time has been exceeded, or will likely be exceeded.

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

AND

2. Failure of EDGs DG1 and DG2 to supply power to vital 4160 volt busses 1A3 and 1A4.

AND

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

Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses) for 15 minutes or longer.

Basis:

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink.

When in the cold shutdown, refueling, or defueled mode, this condition is not classified as a Site Area Emergency because of the increased time available to restore an emergency bus to service. Additional time is available due to the reduced core decay Month 20XX FC 3-83 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition represents an actual or potential substantial degradation of the level of safety of the plant.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Escalation of the emergency classification level would be via IC CS61 or RAS1.

Basis Reference(s):

1. NEI 99-01 Rev 6, CA2 Month 20XX FC 3-84 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU12 Initiating Condition:

Loss of all but one AC power source to emergency buses for 15 minutes or longer.

Operating Mode Applicability:

4, 5, D Emergency Action Level (EAL):

Note: The Emergency Director should declare the Unusual Eventevent promptly upon determining that the applicable time 15 minutes has been exceeded, or will likely be exceeded.

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

161 Kv Circuit 345 Kv Circuit EDG DG1 EDG DG2 AND

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

a. AC power capability to (site-specific emergency buses) is reduced to a single power source for 15 minutes or longer.

AND

b. Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS.

Basis:

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment.

Month 20XX FC 3-85 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS When in the cold shutdown, refueling, or defueled mode, this condition is not classified as an Alert because of the increased time available to restore another power source to service. Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition is considered to be a potential degradation of the level of safety of the plant.

An AC power source is a source recognized in AOPs and EOPs, and capable of supplying required power to an emergency bus. Some examples of this condition are presented below.

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

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

A loss of emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from an offsite power source.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.

The subsequent loss of the remaining single power source would escalate the event to an Alert in accordance with IC CA12.

Basis Reference(s):

1. NEI 99-01 Rev 6 CU2 Month 20XX FC 3-86 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA26 Initiating Condition:

Hazardous event affecting SAFETY SYSTEM needed required for the current operating mode.

Operating Mode Applicability:

4, 5 Emergency Action Level (EAL):

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

Seismic event (earthquake)

Internal or external flooding event High winds or tornado strike FIRE EXPLOSION (site-specific hazards)

Other events with similar hazard characteristics as determined by the Shift Manager AND 2.b. EITHER of the following:

a.1. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM needed required by Technical Specifications for the current operating mode.

OR b.2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure needed required by Technical Specifications for the current operating mode.

Basis:

FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.

EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion. Such Month 20XX FC 3-87 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS events may require a post-event inspection to determine if the attributes of an explosion are present.

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

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

This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or a structure containing SAFETY SYSTEM components, neededrequired for the current operating mode, "required", i.e. required to be operable by Technical Specifications for the current operating mode. This condition significantly reduces the margin to a loss or potential loss of a fission product barrier, and therefore represents an actual or potential substantial degradation of the level of safety of the plant. Manual or automatic electrical isolation of safety equipment due to flooding, in and of itself, does not constitute degraded performance and is classified under HU6.

EAL 1.b.12.a Basis aAddresses damage to a SAFETY SYSTEM train that is required to be operable by Technical Specifications for the current operating mode, and is in service/operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

EAL 1.b.22.b Basis aAddresses damage to a SAFETY SYSTEM component that is required to be operable by Technical Specifications for the current operating mode, and is not in service/operation or readily apparent through indications alone, or to a structure containing SAFETY SYSTEM components. Operators will make this determination based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.

Escalation of the emergency classification level would be via IC CS61 or RAS1.

If the EAL conditions of CA2 are not met then assess the event via HU3, HU4, or HU6.

Basis Reference(s):

1. NEI 99-01 Rev 6, CA6 Month 20XX FC 3-88 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU34 Initiating Condition:

Loss of Vital DC power for 15 minutes or longer.

Operating Mode Applicability:

4, 5 Emergency Action Level (EAL):

Note: The Emergency Director should declare the Unusual Eventevent promptly upon determining that the applicable time 15 minutes time has been exceeded, or will likely be exceeded.

Voltage is < 105 VDC on required 125 VDC Bus 1 and Bus 2 for > 15 minutes.

Indicated voltage is less than (site-specific bus voltage value) on required Vital DC buses for 15 minutes or longer.

Basis:

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses a loss of Vital DC power which compromises the ability to monitor and control operable SAFETY SYSTEMS when the plant is in the cold shutdown or refueling mode. In these modes, the core decay heat load has been significantly reduced, and coolant system temperatures and pressures are lower; these conditions increaseraise the time available to restore a vital DC bus to service. Thus, this condition is considered to be a potential degradation of the level of safety of the plant.

As used in this EAL, required means the Vital DC buses necessary to support operation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment.

For example, if Train A is out-of-service (inoperable) for scheduled outage maintenance work and Train B is in-service (operable), then a loss of Vital DC power affecting Train B would require the declaration of an Unusual Event. A loss of Vital DC power to Train A would not warrant an emergency classification.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Depending upon the event, escalation of the emergency classification level would be via IC CA61 or CA53, or an IC in Recognition Category RA.

Month 20XX FC 3-89 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS Basis Reference(s):

1. NEI 99-01 Rev 6, CU4 Month 20XX FC 3-90 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU45 Initiating Condition:

Loss of all onsite or offsite communications capabilities.

Operating Mode Applicability:

4, 5, D Emergency Action Level (EAL):

1. Loss of ALL Table C1 Onsite communications capability affecting the ability to perform routine operations.

OR

2. Loss of ALL Table C1 Offsite communication capability affecting the ability to perform offsite notifications.

OR

3. Loss of ALL Table C1 NRC communication capability affecting the ability to perform NRC notifications.

Table C1 - Communications Capability System Onsite Offsite NRC 800 MHz Radio System X Gai-tronics System X Security Building PABX X X X Training Building PABX X X X Commercial Telephones X X X Conference Operations X X Network (COP)

FTS-ENS X X HPN X X Satellite phones? X X Blair Phone Line X

1. Loss of ALL of the following onsite communication methods:

(site-specific list of communications methods)

Month 20XX FC 3-91 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS

2. Loss of ALL of the following ORO communications methods:

(site-specific list of communications methods)

3. Loss of ALL of the following NRC communications methods:

(site-specific list of communications methods)

Basis:

This IC addresses a significant loss of on-site , offsite, or NRC or offsite communications capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.

This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).

EAL #1 Basis aAddresses a total loss of the communications methods used in support of routine plant operations.

EAL #2 Basis aAddresses a total loss of the communications methods used to notify all OROs of an emergency declaration. The OROs referred to here are listed in procedure ??? Event Notification Form. (see Developer Notes).

EAL #3 Basis aAddresses a total loss of the communications methods used to notify the NRC of an emergency declaration.

Basis Reference(s):

1. NEI 99-01 Rev 6, CU5 Month 20XX FC 3-92 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA53 Initiating Condition:

Inability to maintain the plant in cold shutdown.

Operating Mode Applicability:

4, 5 Emergency Action Level (EAL):

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

1. UNPLANNED rise in RCS temperature > 210ºF due to loss of decay heat removal for > Table C2 duration.

Table C2 RCS Heat-up Duration Thresholds RCS Containment Closure Heat-up Status Status Duration Intact Not Applicable 60 minutes*

Not Intact Established 20 minutes*

OR Reduced Not Established 0 minutes Inventory

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

OR

2. UNPLANNED RCS pressure rise > 10 psig as a result of temperature rise due to loss of decay heat removal. (This EAL does not apply in solid plant conditions.)

1. UNPLANNED increase in RCS temperature to greater than (site-specific Technical Specification cold shutdown temperature limit) for greater than the duration specified in the following table.

Month 20XX FC 3-93 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS Table: RCS Heat-up Duration Thresholds Containment Closure RCS Status Heat-up Duration Status Intact (but not at reduced inventory Not applicable 60 minutes*

[PWR])

Not intact (or at reduced Established 20 minutes*

inventory [PWR]) Not Established 0 minutes

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

2. UNPLANNED RCS pressure increase greater than (site-specific pressure reading). (This EAL does not apply during water-solid plant conditions.

[PWR])

Basis:

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

CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

RCS is intact when the RCS pressure boundary is in its normal condition for the Cold Shutdown mode of operation (e.g. no freeze seals, etc.).

This IC addresses conditions involving a loss of decay heat removal capability or an addition of heat to the RCS in excess of that which can currently be removed. Either condition represents an actual or potential substantial degradation of the level of safety of the plant.

A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.

The RCS Heat-up Duration Thresholds table addresses an increaserise in RCS temperature when CONTAINMENT CLOSURE is established but the RCS is not intact, or RCS inventory is reduced (e.g., mid-loop operation in PWRs). The 20-minute criterion was included to allow time for operator action to address the temperature increaserise.

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

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS The RCS Heat-up Duration Thresholds table also addresses an increaserise in RCS temperature with the RCS intact. The status of CONTAINMENT CLOSURE is not crucial in this condition since the intact RCS is providing a high pressure barrier to a fission product release. The 60-minute time frame should allow sufficient time to address the temperature increaserise without a substantial degradation in plant safety.

Finally, in the case where there is an increaserise in RCS temperature, the RCS is not intact or is at reduced inventory [PWR], and CONTAINMENT CLOSURE is not established, no heat-up duration is allowed (i.e., 0 minutes). This is because 1) the evaporated reactor coolant may be released directly into the Containment atmosphere and subsequently to the environment, and 2) there is reduced reactor coolant inventory above the top of irradiated fuel.

EAL #2 Basis pProvides a pressure-based indication of RCS heat-up.

Escalation of the emergency classification level would be via IC CS61 or RAS1.

Basis Reference(s):

1. NEI 99-01 Rev 6, CA3 Month 20XX FC 3-95 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU53 Initiating Condition:

UNPLANNED increase rise in RCS temperature Operating Mode Applicability:

4, 5 Emergency Action Level (EAL):

Note: The Emergency Director should declare the Unusual Eventevent promptly upon determining that the applicable time 15 minutes has been exceeded, or will likely be exceeded.

1. UNPLANNED rise in RCS temperature > 210ºF due to loss of decay heat removal.

OR

2. Loss of the following for > 15 minutes.

ALL RCS temperature indications AND ALL RCS level indications

1. UNPLANNED increase in RCS temperature to greater than (site-specific Technical Specification cold shutdown temperature limit).

2. Loss of ALL RCS temperature and reactor vessel/RCS level indication for 15 minutes or longer.

Basis:

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

CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

This IC addresses an UNPLANNED increaserise in RCS temperature above the Technical Specification cold shutdown temperature limit, or the inability to determine Month 20XX FC 3-96 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS RCS temperature and level, represents a potential degradation of the level of safety of the plant. If the RCS is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency Director should also refer to IC CA53.

RCS is intact when the RCS pressure boundary is in its normal condition for the Cold Shutdown mode of operation (e.g. no freeze seals, etc.).

A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.

EAL #1 Basis iInvolves a loss of decay heat removal capability, or an addition of heat to the RCS in excess of that which can currently be removed, such that reactor coolant temperature cannot be maintained below the cold shutdown temperature limit specified in Technical Specifications. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.

During an outage, the level in the reactor vessel will normally be maintained above the reactor vessel flange. Refueling evolutions that lower water level below the reactor vessel flange are carefully planned and controlled. A loss of forced decay heat removal at reduced inventory may result in a rapid increaserise in reactor coolant temperature depending on the time after shutdown.

EAL #2 Basis rReflects a condition where there has been a significant loss of instrumentation capability necessary to monitor RCS conditions and operators would be unable to monitor key parameters necessary to assure core decay heat removal. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.

Escalation to Alert would be via IC CA61 based on an inventory loss or IC CA53 based on exceeding plant configuration-specific time criteria.

Month 20XX FC 3-97 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS Basis Reference(s):

1. NEI 99-01 Rev 6, CU3 Month 20XX FC 3-98 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CG61 Initiating Condition:

Loss of reactor vessel/RCS inventory affecting fuel clad integrity with containment challenged.

Operating Mode Applicability:

5, 6 Emergency Action Level (EAL):

Note: The Emergency Director should declare the General Emergencyevent promptly upon determining that the applicable time 30 minutes has been exceeded, or will likely be exceeded.

1. RVLMS indicates 0.0% for > 30 minutes.

OR

2. a. Reactor Vessel / RCS level unknown for > 30 minutes.

AND

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

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

OR Erratic Source Range Neutron Monitor indication.

OR Containment Area Radiation Monitors reading > 20 R/hr.

AND

3. ANY Containment Challenge Indication (Table C4)

Table C3 Indications of RCS Leakage UNPLANNED Containment Sump level rise*

UNPLANNED Auxiliary Bldg. Sump level rise*

UNPLANNED Reactor Coolant Drain Tank level rise*

UNPLANNED Quench Tank level rise*

UNPLANNED Spent Regenerate Tank level rise*

UNPLANNED rise in RCS makeup Observation of leakage or inventory loss

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

Month 20XX FC 3-99 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS Table C4 Containment Challenge Indications Hydrogen Concentration in Containment > 3%

UNPLANNED rise in containment pressure CONTAINMENT CLOSURE not established*

• if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency is not required.

1. a. (Reactor vessel/RCS level less than (site-specific level) for 30 minutes or longer.

AND

b. ANY indication from the Containment Challenge Table (see below).

2. a. Reactor vessel/RCS level cannot be monitored for 30 minutes or longer.

AND

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

(Site-specific radiation monitor) reading greater than (site-specific value)

Erratic source range monitor indication UNPLANNED increase in (site-specific sump and/or tank) levels of sufficient magnitude to indicate core uncovery (Other site-specific indications)

AND

c. ANY indication from the Containment Challenge Table (see below).

Containment Challenge Table CONTAINMENT CLOSURE not established*

(Explosive mixture) exists inside containment UNPLANNED increase in containment pressure Month 20XX FC 3-100 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS

• If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.

Basis:

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

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

CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

This IC addresses the inability to restore and maintain reactor vessel level above the top of active fuel with containment challenged. This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed EPA Protective Action Guidelines (PAG) exposure levels offsite for more than the immediate site area.

Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.

With CONTAINMENT CLOSURE not established, there is a high potential for a direct and unmonitored release of radioactivity to the environment. If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.

The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a challenge to Containment integrity.

In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a core uncovery could result in an explosive gas mixture in containment. If all installed hydrogen gas monitors are out-of-service during an event leading to fuel cladding damage, it may not be possible to obtain a containment hydrogen gas concentration reading as ambient conditions within the containment will preclude personnel access.

During periods when installed containment hydrogen gas monitors are out-of-service, operators may use the other listed indications to assess whether or not containment is challenged.

Month 20XX FC 3-101 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS In EAL 2.b, Tthe 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.

The inability to monitor reactor vessel/RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the reactor vessel/RCS.

These EALs address concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Basis Reference(s):

1. NEI 99-01 Rev 6, CG1 Month 20XX FC 3-102 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CS61 Initiating Condition:

Loss of reactor vessel/RCS inventory affecting core decay heat removal capability.

Operating Mode Applicability:

4, 5 Emergency Action Level (EAL):

Note: The Emergency Director should declare the Site Area Emergencyevent promptly upon determining that the applicable time 30 minutes has been exceeded, or will likely be exceeded.

1. With CONTAINMENT CLOSURE established RVLMS indicates 0.0%

OR

2. With CONTAINMENT CLOSURE not established RVLIS < 8.0%

OR

3. a. Reactor vessel/RCS level unknown for >30 minutes.

AND

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

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

OR Erratic Source Range Neutron Monitor indication.

OR Containment Area Radiation Monitors reading > 20 R/hr.

Table C3 Indications of RCS Leakage UNPLANNED Containment Sump level rise*

UNPLANNED Auxiliary Bldg. Sump level rise*

UNPLANNED Reactor Coolant Drain Tank level rise*

UNPLANNED Quench Tank level rise*

UNPLANNED Spent Regenerate Tank level rise*

UNPLANNED rise in RCS makeup Observation of leakage or inventory loss

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

Month 20XX FC 3-103 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS

1. a. CONTAINMENT CLOSURE not established.

AND

b. (Reactor vessel/RCS [PWR] or RPV [BWR]) level less than (site-specific level).

2. a. CONTAINMENT CLOSURE established.

AND

b. (Reactor vessel/RCS [PWR] or RPV [BWR]) level less than (site-specific level).

3. a. (Reactor vessel/RCS [PWR] or RPV [BWR]) level cannot be monitored for 30 minutes or longer.

AND

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

(Site-specific radiation monitor) reading greater than (site-specific value)

Erratic source range monitor indication [PWR]

UNPLANNED increase in (site-specific sump and/or tank) levels of sufficient magnitude to indicate core uncovery (Other site-specific indications)

Basis:

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

CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

Month 20XX FC 3-104 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS This IC addresses a significant and prolonged loss of reactor vessel/RCS inventory control and makeup capability leading to IMMINENT fuel damage. The lost inventory may be due to a RCS component failure, a loss of configuration control or prolonged boiling of reactor coolant. These conditions entail major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.

Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.

Outage/shutdown contingency plans typically provide for re-establishing or verifying CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory control functions. The difference in the specified RCS/reactor vessel levels of EALs 1.b and 2.b reflect the fact that with CONTAINMENT CLOSURE established, there is a lower probability of a fission product release to the environment.

In EAL 3.a, tThe 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.

The inability to monitor reactor vessel/RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the reactor vessel/RCS.

These EALs address concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Escalation of the emergency classification level would be via IC CG16 or ARG1.

Month 20XX FC 3-105 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS Basis Reference(s):

1. NEI 99-01 Rev 6, CS1 Month 20XX FC 3-106 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA61 Initiating Condition:

Loss of reactor vessel/RCS inventory.

Operating Mode Applicability:

4, 5 Emergency Action Level (EAL):

Note: The Emergency Director should declare the event Alert promptly upon determining that the applicable time 15 minutes has been exceeded, or will likely be exceeded.

1. Loss of reactor vessel / RCS inventory as indicated by RVLMS < 14%

OR

2. a. Reactor vessel / RCS level unknown for > 15 minutes.

AND

b. Loss of reactor vessel / RCS inventory per Table C3 indications.

Table C3 Indications of RCS Leakage UNPLANNED Containment Sump level rise*

UNPLANNED Auxiliary Bldg. Sump level rise*

UNPLANNED Reactor Coolant Drain Tank level rise*

UNPLANNED Quench Tank level rise*

UNPLANNED Spent Regenerate Tank level rise*

UNPLANNED rise in RCS makeup Observation of leakage or inventory loss

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

1. Loss of reactor vessel/RCS inventory as indicated by level less than (site-specific level).

2. a. Reactor vessel/RCS level cannot be monitored for 15 minutes or longer AND Month 20XX FC 3-107 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS

b. UNPLANNED increase in (site-specific sump and/or tank) levels due to a loss of reactor vessel/RCS inventory.

Basis:

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

This IC addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier).

This condition represents a potential substantial reduction in the level of plant safety.

EAL #1 Basis For EAL , aA lowering of water level below 0 inches on Draindown Level indicator (site-specific level) indicates that operator actions have not been successful in restoring and maintaining reactor vessel/RCS water level. The heat-up rate of the coolant will increaserise as the available water inventory is reduced. A continuing decrease drop in water level will lead to core uncovery.

Although related, EAL #1 is concerned with the loss of RCS inventory and not the potential concurrent effects on systems needed for decay heat removal (e.g., loss of a Residual Heat Removal suction point). An increaserise in RCS temperature caused by a loss of decay heat removal capability is evaluated under IC CA53.

EAL #2 Basis For EAL , tThe inability to monitor reactor vessel/RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels.

Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the reactor vessel/RCS.

The 15-minute duration for the loss of level indication was chosen because it is half of the EAL duration specified in IC CS61 If the reactor vessel/RCS inventory level continues to lower, then escalation to Site Area Emergency would be via IC CS61.

Month 20XX FC 3-108 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS Basis Reference(s):

1. NEI 99-01 Rev 6, CA1 Month 20XX FC 3-109 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU61 Initiating Condition:

UNPLANNED loss of reactor vessel/RCS inventory for 15 minutes or longer.

Operating Mode Applicability:

4, 5 Emergency Action Level (EAL):

Note: The Emergency Director should declare the Unusual Eventevent promptly upon determining that the applicable time 15 minutes has been exceeded, or will likely be exceeded.

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

OR

2. a. Reactor vessel / RCS level unknown AND

b. Loss of reactor vessel / RCS inventory per Table C3 indications.

Table C3 Indications of RCS Leakage UNPLANNED Containment Sump level rise*

UNPLANNED Auxiliary Bldg. Sump level rise*

UNPLANNED Reactor Coolant Drain Tank level rise*

UNPLANNED Quench Tank level rise*

UNPLANNED Spent Regenerate Tank level rise*

UNPLANNED rise in RCS makeup Observation of leakage or inventory loss

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

1. UNPLANNED loss of reactor coolant results in reactor vessel/RCS level less than a required lower limit for 15 minutes or longer.

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

Month 20XX FC 3-110 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS AND

b. UNPLANNED increase in (site-specific sump and/or tank) levels.

Basis:

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

This IC addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor reactor vessel/RCS level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant.

The procedurally established lower limit is not an operational band established above the procedural limit to allow for operator action prior to exceeding the procedural limit, but it is the procedurally established lower limit.

Refueling evolutions that decrease lower RCS water inventory are carefully planned and controlled. An UNPLANNED event that results in water level decreasing below a procedurally required limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered.

EAL #1Basis rRecognizes that the minimum required reactor vessel/RCS level can change several times during the course of a refueling outage as different plant configurations and system lineups are implemented. This EAL is met if the minimum level, specified for the current plant conditions, cannot be maintained for 15 minutes or longer. The minimum level is typically specified in the applicable operating procedure but may be specified in another controlling document.

The 15-minute threshold duration allows sufficient time for prompt operator actions to restore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level.

EAL #2 Basis aAddresses a condition where all means to determine reactor vessel/RCS level have been lost. In this condition, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the reactor vessel/RCS.

Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA61 or CA53.

Month 20XX FC 3-111 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS Basis Reference(s):

1. NEI 99-01, Rev. 6 CU1

2. Technical Specification 3.1.6. Leakage

3. OP-TM-220-251 RCS Leak Rate Determination Using PPC

4. OP-TM-220-252, Primary - To - Secondary Leakrate Determination (OTSG Leakage): Normal Operations

5. OP-TM-MAP-C0105 RCS Draindown LVL HI/LO

6. OP-TM-PRF1-0405 RB Sump Level HI

7. UFSAR 6.4.3, Bases of Leakage Estimate

8. 1103-11 RCS Water Level Control

9. OP-TM-EOP-030, Loss of Decay Heat Removal Month 20XX FC 3-112 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY 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 (EAL):

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

AND

2. a. ANY Table H1 safety function cannot be controlled or maintained.

OR

b. Damage to spent fuel has occurred or is IMMINENT Table H1 Safety Functions Reactivity Control (ability to shut down the reactor and keep it shutdown)

Core Cooling (ability to cool the core)

RCS Heat Removal (ability to maintain heat sink)

1. a. A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the (site-specific security shift supervision).

AND

b. EITHER of the following has occurred:

1. ANY of the following safety functions cannot be controlled or maintained.

Reactivity control Core cooling RCS heat removal OR Month 20XX FC 3-113 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY

2. Damage to spent fuel has occurred or is IMMINENT.

Basis:

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

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

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

PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.

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

HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

This IC addresses an event in which a HOSTILE FORCE has taken physical control of the facility to the extent that the plant staff can no longer operate equipment necessary to maintain key safety functions. It also addresses a HOSTILE ACTION leading to a loss of physical control that results in actual or IMMINENT damage to spent fuel due to

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

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.

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

Month 20XX FC 3-114 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan.

Basis Reference(s):

1. NEI 99-01, Rev. 6 HG1 Month 20XX FC 3-115 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS1 Initiating Condition:

HOSTILE ACTION within the PROTECTED AREA.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

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

1. A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the (site-specific security shift supervision).

Basis:

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

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

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

PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.

HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

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

This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTED AREA. This event will require rapid response and assistance due to the possibility for damage to plant equipment.

Month 20XX FC 3-116 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.

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

As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The Site Area Emergency declaration will mobilize ORO resources and have them available to develop and implement public protective actions in the unlikely event that the attack is successful in impairing multiple safety functions.

This IC does not apply to a HOSTILE ACTION directed at an ISFSI PROTECTED AREA located outside the plant PROTECTED AREA; such an attack should be assessed using IC HA1. It also does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR

§ 50.72.

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan.

Escalation of the emergency classification level would be via IC HG1.

Basis Reference(s):

1. NEI 99-01 Rev 6, HS1 Month 20XX FC 3-117 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA1 Initiating Condition:

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

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

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

1. A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the (site-specific security shift supervision).

OR

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

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

Basis:

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

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

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

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

Month 20XX FC 3-118 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.

HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the plant and staff for a potential aircraft impact.

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.

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

As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The Alert declaration will also heighten the awareness of Offsite Response Organizations, allowing them to be better prepared should it be necessary to consider further actions.

This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE.

Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.

EAL #1 addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in a heightened state of readiness. This EAL is met when the threat-related information has been validated in accordance with AOP-37.

EAL #21 is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action directed against an ISFSI that is located outside the plant PROTECTED AREA.

Month 20XX FC 3-119 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY EAL #2 addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in a heightened state of readiness. This EAL is met when the threat-related information has been validated in accordance with (site-specific procedure).

The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may be provided by NORAD through the NRC.

In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan.

Escalation of the emergency classification level would be via IC HS1.

Basis Reference(s):

1. NEI 99-01 Rev 6, HA1 Month 20XX FC 3-120 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU1 Initiating Condition:

Confirmed SECURITY CONDITION or threat.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

1. Notification of a credible security threat directed at the site as determined per SY-AA-101-132, Security Assessment and Response to Unusual Activities.

1. A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the (site-specific security shift supervision).

OR

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

2. Notification of a credible security threat directed at the site.

OR

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

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

Basis:

SECURITY CONDITION: Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

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

Month 20XX FC 3-121 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.

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

This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, and thus represent a potential degradation in the level of plant safety.

Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs HA1, HS1 and HG1.

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.

Classification of these events will initiate appropriate threat-related notifications to plant personnel and OROs.

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

EAL #1 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with SY-AA-101-132. references (site specific security shift supervision) because these are the individuals trained to confirm that a security event is occurring or has occurred. Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR § 2.39 information.

EAL #2 addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may also be provided by NORAD through the NRC. Validation of the threat is performed in accordance with AOP-37.

(site-specific procedure).addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with (site-specific procedure).

EAL #3 references Security Force(site-specific security shift supervision) because these are the individuals trained to confirm that a security event is occurring or has occurred. Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR § 2.39 information.addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may also be provided by NORAD through the NRC. Validation of the threat is performed in accordance with (site specific procedure).

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a Month 20XX FC 3-122 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the Security Plan.

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

Basis Reference(s):

1. NEI 99-01 Rev 6, HU1 Month 20XX FC 3-123 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS26 Initiating Condition:

Inability to control a key safety function from outside the Control Room.

Operating Mode Applicability:

1, 2, 3, 4, 5, 6, D Emergency Action Level (EAL):

Note: The Emergency Director should declare the Site Area Emergencyevent promptly upon determining that (site-specific number the applicable timeof minutes) has been exceeded, or will likely be exceeded.

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

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

2. Control of ANY Table H1 key safety function is not reestablished in < 15 minutes.

Table H1 Safety Functions Reactivity Control (ability to shut down the reactor and keep it shutdown)

Core Cooling (ability to cool the core)

RCS Heat Removal (ability to maintain heat sink)

1. a. An event has resulted in plant control being transferred panels and local control stations). from the Control Room to (site-specific remote shutdown AND

b. Control of ANY of the following key safety functions is not reestablished within (site-specific number of minutes).

Reactivity control Core cooling [PWR] / RPV water level [BWR]

RCS heat removal Month 20XX FC 3-124 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Basis:

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

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

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

This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations, and the control of a key safety function cannot be reestablished in a timely manner. The failure to gain control of a key safety function following a transfer of plan control to alternate locations is a precursor to a challenge to one or moreany fission product barriers within a relatively short period of time.

The determination of whether or not control is established at the remote safe shutdown location(s) is based on Emergency Director judgment. The Emergency Director is expected to make a reasonable, informed judgment within (the site-specific time for transfer) 15 minutes whether or not the operating staff has control of key safety functions from the remote safe shutdown location(s).

Escalation of the emergency classification level would be via IC FG1 or CG61.

Basis Reference(s):

1. NEI 99-01, Rev 6 HS6 Month 20XX FC 3-125 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA26 Initiating Condition:

Control Room evacuation resulting in transfer of plant control to alternate locations.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

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

AOP-07 Evacuation of Control Room OR AOP-06 Fire Emergency An event has resulted in plant control being transferred from the Control Room to (site-specific remote shutdown panels and local control stations).

Basis:

This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations outside the Control Room. The loss of the ability to control the plant from the Control Room is considered to be a potential substantial degradation in the level of plant safety.

Following a Control Room evacuation, control of the plant will be transferred to alternate shutdown locations. The necessity to control a plant shutdown from outside the Control Room, in addition to responding to the event that required the evacuation of the Control Room, will present challenges to plant operators and other on-shift personnel.

Activation of the ERO and emergency response facilities will assist in responding to these challenges.

Escalation of the emergency classification level would be via IC HS26.

Basis Reference(s):

1. NEI 99-01, Rev 6 HA6 Month 20XX FC 3-126 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU34 Initiating Condition:

FIRE potentially degrading the level of safety of the plant.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

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

1. A FIRE in ANY Table H2 area is not extinguished in < 15-minutes of ANY of the following FIRE detection indications:

Report from the field (i.e., visual observation)

Receipt of multiple (more than 1) fire alarms or indications Field verification of a single fire alarm OR

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

AND

b. The existence of a FIRE is not verified in < 30 minutes of alarm receipt.

OR 3 A FIRE within the plant PROTECTED AREA not extinguished in < 60-minutes of the initial report, alarm or indication.

OR 4 A FIRE within the plant PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.

Month 20XX FC 3-127 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Table H2 Vital Areas Containment Building Auxiliary Building Intake Structure SIRWT Turbine Building (SSE only)

Main and Auxiliary Transformer Yard Condensate Storage Tank (1) a. A FIRE is NOT extinguished within 15-minutes of ANY of the following FIRE detection indications:

Report from the field (i.e., visual observation)

Receipt of multiple (more than 1) fire alarms or indications Field verification of a single fire alarm AND

b. The FIRE is located within ANY of the following plant rooms or areas:

(site-specific list of plant rooms or areas)

(2) a. Receipt of a single fire alarm (i.e., no other indications of a FIRE).

AND

b. The FIRE is located within ANY of the following plant rooms or areas:

(site-specific list of plant rooms or areas)

AND

c. The existence of a FIRE is not verified within 30-minutes of alarm receipt.

(3) A FIRE within the plant or ISFSI [for plants with an ISFSI outside the plant Protected Area] PROTECTED AREA not extinguished within 60-minutes of the initial report, alarm or indication.

(4) A FIRE within the plant or ISFSI [for plants with an ISFSI outside the plant Protected Area] PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish Month 20XX FC 3-128 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Basis:

FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.

PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.

This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.

EAL #1 Basis The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE could be a drop in fire main pressure, automatic activation of a suppression system, etc.

Upon receipt, operators will take prompt actions to confirm the validity of an initial fire alarm, indication, or report. For EAL assessment purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and not the time that a subsequent verification action was performed. Similarly, the fire duration clock also starts at the time of receipt of the initial alarms, indication or report.

EAL #2 Basis This EAL aAddresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will take prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed.

A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional time is allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress.

If an actual FIRE is verified by a report from the field, then EAL #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a Month 20XX FC 3-129 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted.

EAL #3 Basis In addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety. This basis extends to a FIRE occurring within the PROTECTED AREA of an ISFSI located outside the plant PROTECTED AREA.

[Sentence for plants with an ISFSI outside the plant Protected Area]

EAL #4 Basis If a FIRE within the plant or ISFSI [for plants with an ISFSI outside the plant Protected Area] PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded. The dispatch of an offsite firefighting agency to the site requires an emergency declaration only if it is needed to actively support firefighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish. Declaration is not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.

Basis-Related Requirements from Appendix R Appendix R to 10 CFR 50, states in part:

Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions."

When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.

Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.

In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety Month 20XX FC 3-130 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY circuits of one redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify a single alarm is well within this worst-case 1-hour time period.

Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA26 or MA5SA9.

Basis Reference(s):

1. NEI 99-01, Rev 6 HU4 Month 20XX FC 3-131 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU42 Initiating Condition:

Seismic event greater than OBE levels.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

Seismic event > Operating Basis Earthquake (OBE) as indicated by STRONG MOTION SEISMIC EVENT IN PROGRESS alarm OR Event indicator (SMA-3 Control Panel) has changed from Black to White Seismic event greater than Operating Basis Earthquake (OBE) as indicated by:

a. (site-specific indication that a seismic event met or exceeded OBE limits)

Basis:

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

Event verification with external sources should not be necessary during or following an OBE. Earthquakes of this magnitude should be readily felt by on-site personnel and recognized as a seismic event (e.g., typical lateral accelerations are in excess of 0.08g).

The Shift Manager or Emergency Director may seek external verification if deemed appropriate (e.g., a call to the USGS, check internet news sources, etc.); however, the verification action must not preclude a timely emergency declaration.

Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA26 or HA5SA9.

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

2 An SSE is vibratory ground motion for which certain (generally, safety-related) structures, systems, and components must be designed to remain functional.

Month 20XX FC 3-132 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Basis Reference(s):

1. NEI 99-01, Rev 6 HU2 Month 20XX FC 3-133 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA5 Initiating Condition:

Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

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

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

Table H3 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Containment* Modes 3 through 4, and 5 Auxiliary Building* Modes 3 through 4, and 5

• Areas required to establish shutdown cooling AND

2. Entry into the room or area is prohibited or impeded Note: If the equipment in the listed room or area was already inoperable or out-of-service before the event occurred, then no emergency classification is warranted.

(1) a. Release of a toxic, corrosive, asphyxiant or flammable gas into any of the following plant rooms or areas:

(site-specific list of plant rooms or areas with entry-related mode applicability identified)

AND

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

Month 20XX FC 3-134 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Basis:

This IC addresses an event involving a release of a hazardous gas that precludes or impedes access to equipment necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal plant proceduresmaintain normal plant operation, or required for a normal plant cooldown and shutdown. This condition represents an actual or potential substantial degradation of the level of safety of the plant.

Table H3 is a list of plant rooms or areas with entry-related mode applicability that contain equipment which require a manual/local action necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal operating procedures, where if this action is not completed the plant would not be able to attain and maintain cold shutdown.

This Table does not include rooms or areas for which entry is required solely to perform actions of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

This Table does not include the Control Room since adequate engineered safety/design features are in place to preclude a Control Room evacuation due to the release of a hazardous gas.

An Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time of the gaseous release. The emergency classification is not contingent upon whether entry is actually necessary at the time of the release.

Evaluation of the IC and EAL do not require atmospheric sampling; it only requires the Emergency Directors judgment that the gas concentration in the affected room/area is sufficient to preclude or significantly impede procedurally required access. This judgment may be based on a variety of factors including an existing job hazard analysis, report of ill effects on personnel, advice from a subject matter expert or operating experience with the same or similar hazards. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

An emergency declaration is not warranted if any of the following conditions apply.

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

Month 20XX FC 3-135 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY The gas release is a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., fire suppression system testing).

The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.

An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment. This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.

This EAL does not apply to firefighting activities that generate smoke or that automatically or manually activate a fire suppression system in an area.

Escalation of the emergency classification level would be via Recognition Category RA, C or F ICs.

Basis Reference(s):

1. NEI 99-01, Rev 6 HA5 Month 20XX FC 3-136 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU63 Initiating Condition:

Hazardous Event Operating Mode Applicability:

1, 2, 3, 4, 5, 6, D Emergency Action Level (EAL):

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

1. Tornado strike within the PROTECTED AREA.

OR

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

OR

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

OR

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

OR

5. Abnormal River level, as indicated by EITHER:

a. > 1004 feet MSL elevation (high level)

OR

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

Note: EAL #3 does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.

(1) A tornado strike within the PROTECTED AREA.

Month 20XX FC 3-137 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY (2) Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component needed for the current operating mode.

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

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

(5) (Site-specific list of natural or technological hazard events)

Basis:

PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.

EAL #1 Basis aAddresses a tornado striking (touching down) within the Protected Area.

EAL #2 Basis aAddresses flooding of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns.

Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode. Manual isolation of power to a SAFETY SYSTEM component as a result of leakage is an event of lesser impact and would be expected to cause small and localized damage. The consequence of this type of event is adequately assessed and addressed in accordance with Technical Specifications.

EAL #3 Basis aAddresses a hazardous materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel within the PROTECTED AREA.

Month 20XX FC 3-138 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY EAL #4 Basis aAddresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles. Examples of such an event include site flooding caused by a hurricane, heavy rains, up-river water releases, dam failure, etc., or an on-site train derailment blocking the access road.

This EAL is not intended to apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the flooding around the Cooper Station during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in 2011.

EAL #5 addresses (site-specific description).

EAL #5 Basis The minimum level of 976 feet 9 inches provides adequate suction to the pumps for cooling plant components. The minimum elevation of the raw water pump suction is 973 feet 9 inches. High river level of 1004 feet is based on elevation of the plant site and Security Building Floor and on Technical Specification 2.16 indicating that the flooding plan to protect the plant will be instituted at 1004.2 feet and rising.

Escalation of the emergency classification level would be based on ICs in Recognition Categories RA, F, MS, H or C.

Basis Reference(s):

1. NEI 99-01, Rev 6 HU3 Month 20XX FC 3-139 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG7 Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of a GENERAL EMERGENCY.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

(1) Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility.

Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.

Basis:

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

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

HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE: An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.

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

Basis Reference(s):

1. NEI 99-01, Rev 6 HG7 Month 20XX FC 3-140 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS7 Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of a SITE AREA EMERGENCY.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

(1) Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts, (1) toward site personnel or equipment that could lead to the likely failure of or, (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

Basis:

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

HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE: An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.

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

Basis Reference(s):

1. NEI 99-01, Rev 6 HS7 Month 20XX FC 3-141 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA7 Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of an ALERT Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

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

Basis:

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

HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE: An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.

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

Basis Reference(s):

1. NEI 99-01, Rev 6 HA7 Month 20XX FC 3-142 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU7 Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of an (NO)UEUNUSUAL EVENT.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

(1) Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to 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 IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an NOUEUNUSUAL EVENT.

Basis Reference(s):

1. NEI 99-01, Rev 6 HU7 Month 20XX FC 3-143 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ISFSI MALFUNCTIONS E-HU1 Initiating Condition Damage to a loaded cask CONFINEMENT BOUNDARY.

Operating Mode Applicability:

1, 2, 3, 4, 5, 6, D Emergency Action Level (EAL):

Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading:

> 60mr/hr (gamma + neutron) on the top of the spent fuel cask OR

> 600mr/hr (gamma + neutron) on the side of the spent fuel cask, excluding inlet and outlet ducts (1) Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than (2 times the site-specific cask specific technical specification allowable radiation level) on the surface of the spent fuel cask.

Basis:

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

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

This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage cask is sealed. The word cask, as used in this EAL, refers to the storage container in use at the site for dry storage of irradiated fuel. The issues of concern are the creation of a potential or actual release path to the environment, degradation of one or moreany fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the cask or fuel from storage.

The existence of damage is determined by radiological survey. The technical specification multiple of 2 times, which is also used in Recognition Category A R IC AU1, is used here to distinguish between non-emergency and emergency conditions.

The emphasis for this classification is the degradation in the level of safety of the spent fuel cask and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the fact that the on-contact dose Month 20XX FC 3-144 EP-XX-XXXX(Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ISFSI MALFUNCTIONS rate limit is exceeded may be determined based on measurement of a dose rate at some distance from the cask.

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

Basis Reference(s):

1. NEI 99-01, Rev 6 E-HU1

2. Certificate of Compliance No. 1014 Appendix A Section 5.7 Month 20XX FC 3-145 EP-XX-XXXX(Revision XX)

LIC-14-0098 C EAL Basis Document

Ft. Calhoun Station ___Omaha Public Power District Emergency Action Level Technical Basis Page Index General Site Area Alert Unusual Event EAL Pg. EAL Pg. EAL Pg. EAL Pg.

RG1 3-1 RS1 3-3 RA1 3-5 RU1 3-8 RA2 3-12 RU2 3-14 RA3 3-16 RU3 3-19 FG1 3-20 FS1 3-21 FA1 3-22 Fuel Clad RCS Containment FC1 3-23 RC1 3-28 CT1 3-33 FC2 3-24 RC2 3-30 CT2 3-36 FC3 3-26 RC3 3-31 CT3 3-38 CT4 3-39 FC5 3-27 RC5 3-32 CT5 3-44 MG1 3-45 MS1 3-47 MA1 3-48 MU1 3-50 MG2 3-51 MS2 3-52 MS3 3-53 MA3 3-55 MU3 3-57 MA4 3-59 MU4 3-61 MA5 3-63 MU6 3-65 MU7 3-67 MU8 3-69 CA1 3-71 CU1 3-72 CA2 3-74 CU3 3-76 CU4 3-77 CA5 3-79 CU5 3-81 CG6 3-83 CS6 3-86 CA6 3-88 CU6 3-90 HG1 3-92 HS1 3-94 HA1 3-96 HU1 3-99 HS2 3-101 HA2 3-103 HU3 3-104 HU4 3-108 HA5 3-109 HU6 3-112 HG7 3-115 HS7 3-116 HA7 3-117 HU7 3-118 Month 20XX EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RG1 Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 1000 mRem TEDE or 5000 mRem thyroid CDE.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

Notes:

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

If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.

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

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

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

OR

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

a. > 1000 mRem TEDE OR

b. > 5000 mRem CDE Thyroid OR

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

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

OR

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

Month 20XX FC 3-1 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RG1 (cont)

Emergency Action Level (EAL) (cont):

Table R1 Effluent Monitor Thresholds Effluent Monitor Description General Emergency RM-063 AB Stack 3.71E+00 uCi/cc (Post Accident Gas)

Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude will require implementation of protective actions for the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at the EPA PAG of 1000 mRem while the 5000 mRem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Basis Reference(s):

1. NEI 99-01 Rev 6, AG1 Month 20XX FC 3-2 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RS1 Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 100 mRem TEDE or 500 mRem thyroid CDE.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

Notes:

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

If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.

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

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

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

OR

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

a. > 100 mRem TEDE OR

b. > 500 mRem CDE Thyroid OR

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

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

OR

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

Month 20XX FC 3-3 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RS1 (cont)

Emergency Action Level (EAL) (cont):

Table R1 Effluent Monitor Thresholds Effluent Monitor Description Site Area Emergency AB Stack RM-063 3.70E-01 uCi/cc (Post Accident Gas)

RM-052 AB Stack (Gas) 8.30E+06 cpm RM-043 LRWPB Stack (Gas) 7.26E+06 cpm Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs).

It includes both monitored and un-monitored releases. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 10% of the EPA PAG of 1000 mRem while the 500 mRem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Escalation of the emergency classification level would be via IC RG1.

Basis Reference(s):

1. NEI 99-01 Rev 6, AS1 Month 20XX FC 3-4 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA1 Initiating Condition:

Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mRem TEDE or 50 mRem thyroid CDE.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

Notes:

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

If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.

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

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

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

OR

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

a. > 10 mRem TEDE OR

b. > 50 mRem CDE Thyroid OR

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

a. 10 mRem TEDE for 60 minutes of exposure OR

b. 50 mRem CDE Thyroid for 60 minutes of exposure OR Month 20XX FC 3-5 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA1 (cont)

Emergency Action Level (EAL) (cont):

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

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

OR

b. Analyses of field survey s a m p le s in d i ca t e > 50 mRem CDE Thyroid for 60 minutes of inhalation.

Table R1 Effluent Monitor Thresholds Effluent Monitor Description Alert RM-063 AB Stack(Post Accident Gas) 4.0E -02 uCi/cc RM-062 AB Stack (Gas) 7.00E+05 cpm RM-052 AB Stack (Gas) 8.30E+05 cpm RM-043 LRWPB Stack (Gas) 7.26E+05 cpm RM-057 Condenser Off-Gas 1.79E+08 cpm Basis:

This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1000 mRem while the 50 mRem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Escalation of the emergency classification level would be via IC RS1.

Month 20XX FC 3-6 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA1 (cont)

Basis Reference(s):

1. NEI 99-01 Rev 6, AA1 Month 20XX FC 3-7 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU1 Initiating Condition:

Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

Notes:

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

If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes.

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

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

OR

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

OR

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

Month 20XX FC 3-8 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU1 (cont)

Emergency Action Level (EAL) (cont):

Table R2 Effluent Monitor Thresholds Effluent Monitor Description 2X High Alarm RM-052 (aligned to Aux Building AB Stack (gas) 7.82E+04 cpm stack)

RM-062 AB Stack (gas) 6.60E+04 cpm RM-054A (if SG blowdown is SG blowdown 9.86E+04 cpm not isolated)

RM-054B (if SG blowdown is SG blowdown 9.88E+04 cpm not isolated)

RM-055 (if discharge not Liquid Discharge Header 2.80E+06 cpm isolated) Minimum 1 CW Pump RM-055 (if discharge not isolated) Minimum 2 RW Liquid Discharge Header 8.00E+05 cpm Pump Table R3 Effluent Monitor Thresholds Effluent Monitor Description Unusual Event RM-043 LRWPB Stack (gas) 6.13E+5 cpm RM-052 (aligned to Aux Building AB Stack (gas) 7.01E+05 cpm stack)

RM-062 AB Stack (gas) 5.92E+05 cpm RM-057** Condenser Off-gas 8.82E+08 cpm RM-054A SG Blowdown 9.86E+04 cpm (if SG blowdown is not isolated)

RM-054B SG Blowdown 9.88E+04 cpm (if SG blowdown is not isolated)

RM- 055 (if discharge is not Liquid Discharge Header 2.80E+06 cpm isolated) Minimum 1CW Pump RM-055 (if discharge is not Liquid Discharge Header 8.00E+05 cpm isolated) Minimum 2 RW Pump

• • 1.45E+08 is the upper range of the instrument Month 20XX FC 3-9 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU1 (cont)

Basis:

This IC addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release). It includes any gaseous or liquid radiological release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared.

Nuclear power plants incorporate design features intended to control the release of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases. The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.

EAL #1 Basis This EAL addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This EAL will typically be associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas).

The effluent monitors listed are those normally used for planned discharges. If a discharge is performed using a different flowpath or effluent monitor other than those listed (e.g., a portable or temporary effluent monitor), then the declaration criteria will be based on the monitor specified in the Discharge Permit.

EAL #2 Basis This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous effluent pathways.

EAL #3 Basis This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).

Escalation of the emergency classification level would be via IC RA1.

Month 20XX FC 3-10 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU1 (cont)

Basis Reference(s):

1. NEI 99-01 Rev 6, AU1 Month 20XX FC 3-11 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA2 Initiating Condition:

Significant lowering of water level above, or damage to, irradiated fuel.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

1. Uncovery of irradiated fuel in the REFUELING PATHWAY.

OR

2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by ANY Table R4 Radiation Monitor reading >1000 mRem/hr Table R4 Radiation Monitors RMS Area Monitored RM-73,74,75 Containment Rad Monitor RM-085,87 Auxiliary Building Rad Monitor Portable Rad Containment and auxiliary Building near fuel handling areas Monitor Basis:

REFUELING PATHWAY: all the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange.

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

This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly. These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment. As such, they represent an actual or potential substantial degradation of the level of safety of the plant.

Month 20XX FC 3-12 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA2 (cont)

Basis (cont):

EAL #1 Basis:

This EAL escalates from RU2 in that the loss of level, in the affected portion of the REFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery of irradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visual observation (e.g., reports from personnel or camera images), as well as significant changes in water and radiation levels, or other plant parameters. Computational aids may also be used (e.g., a boil-off curve). Classification of an event using this EAL should be based on the totality of available indications, reports and observations.

While an area radiation monitor could detect a rise in a dose rate due to a lowering of water level in some portion of the REFUELING PATHWAY, the reading may not be a reliable indication of whether or not the fuel is actually uncovered. To the degree possible, readings should be considered in combination with other available indications of inventory loss.

A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.

EAL #2 Basis:

This EAL addresses a release of radioactive material caused by mechanical damage to irradiated fuel. Damaging events may include the dropping, bumping or binding of an assembly, or dropping a heavy load onto an assembly. A rise in readings on radiation monitors should be considered in conjunction with in-plant reports or observations of a potential fuel damaging event (e.g., a fuel handling accident).

Escalation of the emergency would be based on either Recognition Category R or C ICs.

Basis Reference(s):

1. NEI 99-01 Rev 6, AA2 Month 20XX FC 3-13 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU2 Initiating Condition:

UNPLANNED loss of water level above irradiated fuel.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

1. a. UNPLANNED water level drop in the REFUELING PATHWAY.

AND

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

Table R4 Radiation Monitors RMS Area Monitored RM-73,74,75 Containment Rad Monitor RM-085,87 Auxiliary Building Rad Monitor Portable Rad Containment and auxiliary Building near fuel handling areas Monitor Basis:

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

REFUELING PATHWAY: all the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange.

This IC addresses a loss in water level above irradiated fuel sufficient to cause elevated radiation levels. This condition could be a precursor to a more serious event and is also indicative of a minor loss in the ability to control radiation levels within the plant. It is therefore a potential degradation in the level of safety of the plant.

A water level loss will be primarily determined by indications from available level instrumentation. Other sources of level indications may include reports from plant personnel (e.g., from a refueling crew) or video camera observations (if available) or from any other temporarily installed monitoring instrumentation. A significant drop in the water level may also cause a rise in the radiation levels of adjacent areas that can be detected by monitors in those locations.

Month 20XX FC 3-14 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU2 (cont)

Basis (cont):

The effects of planned evolutions should be considered. For example, a refueling bridge area radiation monitor reading may rise due to planned evolutions such as lifting of the reactor vessel head or movement of a fuel assembly. Note that this EAL is applicable only in cases where the elevated reading is due to an UNPLANNED loss of water level.

A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.

Escalation of the emergency classification level would be via IC RA2.

Basis Reference(s):

1. NEI 99-01 Rev 6, AU2 Month 20XX FC 3-15 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA3 Initiating Condition:

Radiation levels that impede access to equipment necessary for normal plant operations, cooldown or shutdown.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

Note: If the equipment in the room or area listed in Table R4 was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted.

1. Dose rate > 15 mR/hr in ANY of the areas contained in Table R6:

Table R6 Areas Requiring Continuous Occupancy Main Control Room Central Alarm Station (CAS)

OR

2. UNPLANNED event results in radiation levels that prohibit or significantly impede access to ANY of the following Table R7 plant rooms or areas:

Table R7 Areas with Entry Related Mode Applicability Entry Related Mode Area Applicability Containment* Modes 3 through 4, and 5 Auxiliary Building* Modes 3 through 4, and 5

• Areas required to establish shutdown cooling Month 20XX FC 3-16 EP-XX-XXXX (Revision XX)

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

Basis:

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

This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or impede personnel from performing actions necessary to maintain normal plant operation, or to perform a normal plant cooldown and shutdown. As such, it represents an actual or potential substantial degradation of the level of safety of the plant.

The Emergency Director should consider the cause of the increased radiation levels and determine if another IC may be applicable.

Table R7 is a list of plant rooms or areas with entry-related mode applicability that contain equipment which require a manual/local action necessary to transition the plant from normal plant operation, cooldown and shutdown as specified in normal operating procedures, where if this action is not completed the plant would not be able to attain and maintain cold shutdown. This Table does not include rooms or areas for which entry is required solely to perform actions of an administrative or record keeping nature (e.g.,

normal rounds or routine inspections).

Rooms and areas listed in EAL #1 do not need to be included in EAL #2, including the Control Room.

For EAL #2, an Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time of the elevated radiation levels. The emergency classification is not contingent upon whether entry is actually necessary at the time of the increased radiation levels. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., installing temporary shielding beyond that required by procedures, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits).

An emergency declaration is not warranted if any of the following conditions apply.

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

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

The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

Month 20XX FC 3-17 EP-XX-XXXX (Revision XX)

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

Basis (cont):

The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.

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

Basis Reference(s):

1. NEI 99-01 Rev 6, AA3 Month 20XX FC 3-18 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU3 Initiating Condition:

Reactor coolant activity greater than Technical Specification allowable limits.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

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

OR

2. Sample analysis indicates that:

a. Dose Equivalent I-131 specific coolant activity > 1.0 uCi/gm for more than 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> during one continuous time interval OR > 60 uCi/gm.

OR

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

Basis:

This IC addresses a reactor coolant activity value that exceeds an allowable limit specified in Technical Specifications. This condition is a precursor to a more significant event and represents a potential degradation of the level of safety of the plant.

Conditions that cause the specified monitor to alarm that are not related to fuel clad degradation should not result in the declaration of an Unusual Event.

This EAL addresses site-specific radiation monitor readings that provide indication of a degradation of fuel clad integrity.

An Unusual Event is only warranted when actual fuel clad damage is the cause of the elevated coolant sample activity (as determined by laboratory confirmation). Fuel clad damage should be assumed to be the cause of elevated Reactor Coolant activity unless another cause is known.

Escalation of the emergency classification level would be via ICs FA1 or the Recognition Category R ICs.

Basis Reference(s):

1. NEI 99-01 Rev 6, SU3 Month 20XX FC 3-19 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FG1 Initiating Condition:

Loss of ANY Two Barriers AND Loss or Potential Loss of the third barrier.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.

Basis:

Fuel Cladding, RCS and Containment comprise the fission product barriers.

At the General Emergency classification level each barrier is weighted equally.

Basis Reference(s):

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

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FS1 Initiating Condition:

Loss or Potential Loss of ANY two barriers.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.

Basis:

Fuel Cladding, RCS and Containment comprise the fission product barriers.

At the Site Area Emergency classification level, each barrier is weighted equally.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-21 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FA1 Initiating Condition:

ANY Loss or ANY Potential Loss of either Fuel Clad or RCS.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.

Basis:

Fuel Cladding, RCS and Containment comprise the fission product barriers.

At the Alert classification level, Fuel Cladding and RCS barriers are weighted more heavily than the Containment barrier. Unlike the Containment barrier, loss or potential loss of either the Fuel Cladding or RCS barrier may result in the relocation of radioactive materials or degradation of core cooling capability. Note that the loss or potential loss of Containment barrier in combination with loss or potential loss of either Fuel Cladding or RCS barrier results in declaration of a Site Area Emergency under EAL FS1.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-22 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC1 Initiating Condition:

RCS or SG Tube Leakage Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

POTENTIAL LOSS RVLMS indicates 0.0%.

Basis:

There is no Loss threshold associated with RCS or SG Tube Leakage.

Potential Loss Threshold Basis:

This reading indicates a reduction in reactor vessel water level sufficient to allow the onset of heat-induced cladding damage.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-23 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC2 Initiating Condition:

Inadequate Heat Removal Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

LOSS

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

2. Core Exit Thermocouple readings > 700°F OR

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

Basis:

Loss Threshold #1 Basis This reading indicates temperatures within the core are sufficient to cause significant superheating of reactor coolant.

Potential Loss Threshold #2 Basis This reading indicates temperatures within the core are sufficient to allow the onset of heat-induced cladding damage.

Potential Loss Threshold #3 Basis This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the Fuel Clad Barrier. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators; during these conditions, classification using threshold is not warranted.

Month 20XX FC 3-24 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC2 (cont)

Basis (cont)):

Meeting this threshold results in a Site Area Emergency because this threshold is identical to RCS Barrier RC2 Potential Loss threshold; both will be met. This condition warrants a Site Area Emergency declaration because inadequate RCS heat removal may result in fuel heat-up sufficient to damage the cladding and raise RCS pressure to the point where mass will be lost from the system.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-25 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC3 Initiating Condition:

Containment Radiation / RCS Activity Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

LOSS

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

OR

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

3. 12.1 Rem/hr on contact or 33 mRem/hr at 30 cm on primary sample piping adjacent to the hood SL-1 per CH-SMP-PA-0007 Basis:

Loss Threshold #1 Basis:

The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that reactor coolant activity equals 180 Ci/gm dose equivalent I-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.

The radiation monitor reading in this threshold is higher than that specified for RCS Barrier RC3 Loss Threshold since it indicates a loss of both the Fuel Clad Barrier and the RCS Barrier. Note that a combination of the two monitor readings appropriately escalates the emergency classification level to a Site Area Emergency.

Loss Threshold #2 Basis:

This threshold indicates that RCS radioactivity concentration is greater than 180 Ci/gm dose equivalent I-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.

It is recognized that sample collection and analysis of reactor coolant with highly elevated activity levels could require several hours to complete. Nonetheless, a sample-related threshold is included as a backup to other indications There is no Fuel Clad Barrier Potential Loss threshold associated with RCS Activity /

Containment Radiation.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-26 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC5 Initiating Condition:

Emergency Director Judgment.

Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

LOSS

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

POTENTIAL LOSS

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

Basis:

Loss Threshold #1 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Fuel Clad Barrier is lost.

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

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-27 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC1 Initiating Condition:

RCS or SG Tube Leakage Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

LOSS

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

a. UNISOLABLE RCS leakage OR

b. Steam Generator tube RUPTURE.

POTENTIAL LOSS

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

OR

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

OR

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

AND

b. Pressure and Temperature is above Attachment PC-12 Pressure Temperature Curve.

Basis:

UNISOLABLE: An open or breached system line that cannot be isolated, remotely or locally.

RUPTURE(D): The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection.

FAULTED: The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

Loss Threshold #1 Basis This threshold is based on an UNISOLABLE RCS leak of sufficient size to require an automatic or manual actuation of the Emergency Core Cooling System (ECCS). This condition clearly represents a loss of the RCS Barrier.

Month 20XX FC 3-28 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC1 (cont)

Basis (cont):

This threshold is applicable to unidentified and pressure boundary leakage, as well as identified leakage. It is also applicable to UNISOLABLE RCS leakage through an interfacing system. The mass loss may be into any location - inside containment, to the secondary-side (i.e., steam generator tube leakage) or outside of containment.

A steam generator with primary-to-secondary leakage of sufficient magnitude to require a safety injection is considered to be RUPTURED. If a RUPTURED steam generator is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier CT1Loss threshold will also be met.

Potential Loss Threshold #2 Basis This threshold is based on an UNISOLABLE RCS leak that results in the inability to maintain pressurizer level within specified limits by operation of a normally used charging (makeup) pump, but an ECCS (SI) actuation has not occurred. The threshold is met when an operating procedure, or operating crew supervision, directs that a standby charging (makeup) pump be placed in service to restore and maintain pressurizer level.

This threshold is applicable to unidentified and pressure boundary leakage, as well as identified leakage. It is also applicable to UNISOLABLE RCS leakage through an interfacing system. The mass loss may be into any location - inside containment, to the secondary-side (i.e., steam generator tube leakage) or outside of containment.

If a leaking steam generator is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier CT1 Loss Threshold

1. 1 will also be met.

Potential Loss Threshold #3 Basis The initiation of Once-Through-Cooling, EOP-20 HR4 creates a controlled opening of the RCS to the containment by an open PORV. The opening of the RCS represents a potential challenge to the RCS barrier and is considered a potential loss.

Potential Loss Threshold #4 Basis This condition indicates an extreme challenge to the integrity of the RCS pressure boundary due to pressurized thermal shock - a transient that causes rapid RCS cooldown while the RCS is in Mode 3 or higher (i.e., hot and pressurized).

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-29 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC2 Initiating Condition:

Inadequate Heat Removal Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

POTENTIAL LOSS Once-Through-Cooling, EOP-20 HR4 in effect.

Basis:

There is no Loss threshold associated with Inadequate Heat Removal.

Potential Loss Threshold Basis Once-Through-Cooling, EOP-20 HR4 in effect indicates a Lack of Primary to Secondary Heat Transfer capability.

This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the RCS Barrier. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators; during these conditions, classification using threshold is not warranted.

Meeting this threshold results in a Site Area Emergency because this threshold is identical to Fuel Clad Barrier FC2 Potential Loss Threshold #3; both will be met. This condition warrants a Site Area Emergency declaration because inadequate RCS heat removal may result in fuel heat-up sufficient to damage the cladding and raise RCS pressure to the point where mass will be lost from the system.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-30 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC3 Initiating Condition:

Containment Radiation / RCS Activity Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

LOSS Containment radiation monitor RM-091 A/B reading > 40 R/hr.

Basis:

Loss Threshold Basis The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that reactor coolant activity equals Technical Specification allowable limits. This value is lower than that specified for Fuel Clad Barrier FC3 Loss threshold #1 since it indicates a loss of the RCS Barrier only.

There is no RCS Potential Loss threshold associated with RCS Activity / Containment Radiation.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-31 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC5 Initiating Condition:

Emergency Director Judgment.

Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

LOSS

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

POTENTIAL LOSS

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

Basis:

Loss Threshold #1 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the RCS Barrier is lost.

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

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-32 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT1 Initiating Condition:

RCS or SG Tube Leakage Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

LOSS

1. SG tube leakage > the capacity of one charging pump in the normal charging mode (greater than 40 gpm).

AND

2. SG is FAULTED outside of containment.

Basis:

FAULTED: The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

RUPTURE(D): The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection.

Loss Threshold Basis This threshold addresses a leaking or RUPTURED Steam Generator (SG) that is also FAULTED outside of containment. The condition of the SG, whether leaking or RUPTURED, is determined in accordance with the thresholds for RCS Barrier RC1 Potential Loss Threshold 2 and Loss Threshold 1.b, respectively. This condition represents a bypass of the containment barrier.

FAULTED is a defined term within the NEI 99-01 methodology; this determination is not necessarily dependent upon entry into, or diagnostic steps within, an EOP. For example, if the pressure in a steam generator is decreasing uncontrollably [part of the FAULTED definition] and the faulted steam generator isolation procedure is not entered because EOP user rules are dictating implementation of another procedure to address a higher priority condition, the steam generator is still considered FAULTED for emergency classification purposes.

The FAULTED criterion establishes an appropriate lower bound on the size of a steam release that may require an emergency classification. Steam releases of this size are readily observable with normal Control Room indications. The lower bound for this aspect of the containment barrier is analogous to the lower bound criteria specified in IC RU3 for the fuel clad barrier (i.e., RCS activity values) and IC MU6 for the RCS barrier (i.e., RCS leak rate values).

This threshold also applies to prolonged steam releases necessitated by operational considerations such as the forced steaming of a leaking or RUPTURED steam Month 20XX FC 3-33 EP-XX-XXXX (Revision XX)

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

Basis (cont):

generator directly to atmosphere to cooldown the plant, or to drive an auxiliary (emergency) feed water pump. These types of conditions will result in a significant and sustained release of radioactive steam to the environment (and are thus similar to a FAULTED condition). The inability to isolate the steam flow without an adverse effect on plant cooldown meets the intent of a loss of containment.

Steam releases associated with the expected operation of a SG power operated relief valve or safety relief valve do not meet the intent of this threshold. Such releases may occur intermittently for a short period of time following a reactor trip as operators process through emergency operating procedures to bring the plant to a stable condition and prepare to initiate a plant cooldown. Steam releases associated with the unexpected operation of a valve (e.g., a stuck-open safety valve) meets this threshold.

Following an SG tube leak or rupture, there may be minor radiological releases through a secondary-side system component (e.g., air ejectors, glad seal exhausters, valve packing, etc.). These types of releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category R ICs.

The emergency classification levels resulting from primary-to-secondary leakage, with or without a steam release from the FAULTED SG, are summarized below.

Affected SG is FAULTED Outside of Containment?

Primary to Secondary Yes No Leak Rate Less than or equal to 25 No classification No classification gpm Greater than 25 gpm Unusual Event per Unusual Event per MU6 MU6 The capacity of one charging pump in the Site Area Emergency normal charging mode Alert per FA1 per FS1 (greater than 40 gpm) is exceeded (RCS Barrier Potential Loss)

Requires an automatic or Site Area Emergency Alert per FA1 manual ECCS actuation per FS1 (RCS Barrier Loss)

There is no Potential Loss threshold associated with RCS or SG Tube Leakage.

Month 20XX FC 3-34 EP-XX-XXXX (Revision XX)

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

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-35 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT2 Initiating Condition:

Inadequate Heat Removal Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

POTENTIAL LOSS

1. a. Tclad > 1550°F.

AND

b. Restoration procedures not effective in < 15 minutes.

OR

2. a. Core exit thermocouples > 700ºF AND

b. RVLMS indicates 0.0%

AND

c. Restoration procedures not effective in < 15 minutes.

Basis:

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

There is no Loss threshold associated with Inadequate Heat Removal.

Potential Loss Threshold Basis This condition represents an IMMINENT core melt sequence which, if not corrected, could lead to vessel failure and an increased potential for containment failure. For this condition to occur, there must already have been a loss of the RCS Barrier and the Fuel Clad Barrier. If implementation of a procedure(s) to restore adequate core cooling is not effective (successful) within 15 minutes, it is assumed that the event trajectory will likely lead to core melting and a subsequent challenge of the Containment Barrier.

The restoration procedure is considered effective if core exit thermocouple readings are decreasing and/or if reactor vessel level is increasing. Whether or not the procedure(s) will be effective should be apparent within 15 minutes. The Emergency Director should escalate the emergency classification level as soon as it is determined that the procedure(s) will not be effective.

Severe accident analyses (e.g., NUREG-1150) have concluded that function restoration procedures can arrest core degradation in a significant fraction of core damage scenarios, and that the likelihood of containment failure is very small in these events.

Given this, it is appropriate to provide 15 minutes beyond the required entry point to determine if procedural actions can reverse the core melt sequence.

Month 20XX FC 3-36 EP-XX-XXXX (Revision XX)

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

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-37 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT3 Initiating Condition:

Containment Radiation / RCS Activity Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

POTENTIAL LOSS Containment radiation monitor RM-091 A/B reading > 26,000 R/hr.

Basis:

There is no Loss threshold associated with RCS Activity / Containment Radiation.

Potential Loss Threshold Basis The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that 20% of the fuel cladding has failed.

This level of fuel clad failure is well above that used to determine the analogous Fuel Clad Barrier Loss and RCS Barrier Loss thresholds.

NUREG-1228, Source Estimations During Incident Response to Severe Nuclear Power Plant Accidents, indicates the fuel clad failure must be greater than approximately 20%

in order for there to be a major release of radioactivity requiring offsite protective actions. For this condition to exist, there must already have been a loss of the RCS Barrier and the Fuel Clad Barrier. It is therefore prudent to treat this condition as a potential loss of containment which would then escalate the emergency classification level to a General Emergency.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-38 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT4 Initiating Condition:

Containment Integrity or Bypass Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

LOSS

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

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

OR

b. UNISOLABLE pathway from containment to the environment exists.

OR

2. Indication of RCS leakage outside of containment POTENTIAL LOSS

3. Containment Pressure > 60 psig and rising.

OR

4. Hydrogen Concentration in Containment > 3%.

OR

5. a. Containment pressure > 5 psig AND

b. Less than one full train of Containment Cooling OR Containment Spray equipment operating.

Basis:

FAULTED: The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

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

UNISOLABLE: An open or breached system line that cannot be isolated, remotely or locally.

Month 20XX FC 3-39 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT4 (cont)

Basis (cont):

Loss Threshold #1 Basis These thresholds address a situation where containment isolation is required and one of two conditions exists as discussed below. Users are reminded that there may be accident and release conditions that simultaneously meet both loss thresholds 1.a and 1.b.

1.a - Containment integrity has been lost, i.e., the actual containment atmospheric leak rate likely exceeds that associated with allowable leakage (or sometimes referred to as design leakage). Following the release of RCS mass into containment, containment pressure will fluctuate based on a variety of factors; a loss of containment integrity condition may (or may not) be accompanied by a noticeable drop in containment pressure. Recognizing the inherent difficulties in determining a containment leak rate during accident conditions, it is expected that the Emergency Director will assess this threshold using judgment, and with due consideration given to current plant conditions, and available operational and radiological data (e.g., containment pressure, readings on radiation monitors outside containment, operating status of containment pressure control equipment, etc.).

Refer to the middle piping run of Figure 3-F-1. Two simplified examples are provided.

One is leakage from a penetration and the other is leakage from an in-service system valve. Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure.

Another example would be a loss or potential loss of the RCS barrier, and the simultaneous occurrence of two FAULTED locations on a steam generator where one fault is located inside containment (e.g., on a steam or feedwater line) and the other outside of containment. In this case, the associated steam line provides a pathway for the containment atmosphere to escape to an area outside the containment.

Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable (design) containment leakage through various penetrations or system components. These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category R ICs.

1.b - Conditions are such that there is an UNISOLABLE pathway for the migration of radioactive material from the containment atmosphere to the environment. As used here, the term environment includes the atmosphere of a room or area, outside the containment, that may, in turn, communicate with the outside-the-plant atmosphere (e.g., through discharge of a ventilation system or atmospheric leakage). Depending upon a variety of factors, this condition may or may not be accompanied by a noticeable drop in containment pressure.

Month 20XX FC 3-40 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT4 (cont)

Basis (cont):

Refer to the top piping run of Figure 3-F-1. In this simplified example, the inboard and outboard isolation valves remained open after a containment isolation was required (i.e.,

containment isolation was not successful). There is now an UNISOLABLE pathway from the containment to the environment.

The existence of a filter is not considered in the threshold assessment. Filters do not remove fission product noble gases. In addition, a filter could become ineffective due to iodine and/or particulate loading beyond design limits (i.e., retention ability has been exceeded) or water saturation from steam/high humidity in the release stream.

Leakage between two interfacing liquid systems, by itself, does not meet this threshold.

Refer to the bottom piping run of Figure 3-F-1. In this simplified example, leakage in an RCP seal cooler is allowing radioactive material to enter the Auxiliary Building. The radioactivity would be detected by the Process Monitor. If there is no leakage from the closed water cooling system to the Auxiliary Building, then no threshold has been met.

If the pump or system piping developed a leak that allowed steam/water to enter the Auxiliary Building, then loss threshold 2 would be met. Depending upon radiation monitor locations and sensitivities, this leakage could be detected by any of the four monitors depicted in the figure and cause threshold 1.a to be met as well.

Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable (design) containment leakage through various penetrations or system components. Minor releases may also occur if a containment isolation valve(s) fails to close but the containment atmosphere escapes to a closed system. These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category R ICs.

The status of the containment barrier during an event involving steam generator tube leakage is assessed using Containment Barrier CT1Loss threshold.

Loss Threshold #2 Basis Containment sump, temperature, pressure and/or radiation levels will rise if reactor coolant mass is leaking into the containment. If these parameters have not increased, then the reactor coolant mass may be leaking outside of containment (i.e., a containment bypass sequence). Raises in sump, temperature, pressure, flow and/or radiation level readings outside of the containment may indicate that the RCS mass is being lost outside of containment.

Unexpected elevated readings and alarms on radiation monitors with detectors outside containment should be corroborated with other available indications to confirm that the source is a loss of RCS mass outside of containment. If the fuel clad barrier has not been lost, radiation monitor readings outside of containment may not rise significantly; however, other unexpected changes in sump levels, area temperatures or pressures, flow rates, etc. should be sufficient to determine if RCS mass is being lost outside of the containment.

Month 20XX FC 3-41 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT4 (cont)

Basis (cont):

Refer to the middle piping run of Figure 3-F-1. In this simplified example, a leak has occurred at a reducer on a pipe carrying reactor coolant in the Auxiliary Building.

Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure and cause loss threshold 1.a to be met as well. To ensure proper escalation of the emergency classification, the RCS leakage outside of containment must be related to the mass loss that is causing the RCS Barrier RC1 Loss Threshold 1.a and/or Potential Loss threshold 2.a to be met.

Potential Loss Threshold #3 Basis If containment pressure exceeds the design pressure, there exists a potential to lose the Containment Barrier. To reach this level, there must be an inadequate core cooling condition for an extended period of time; therefore, the RCS and Fuel Clad barriers would already be lost. Thus, this threshold is a discriminator between a Site Area Emergency and General Emergency since there is now a potential to lose the third barrier.

Potential Loss Threshold #4 Basis The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a potential loss of the Containment Barrier.

Potential Loss Threshold #5 Basis This threshold describes a condition where containment pressure is greater than the set point at which containment energy (heat) removal systems are designed to automatically actuate, and less than one full train of equipment is capable of operating per design. The 15-minute criterion is included to allow operators time to manually start equipment that may not have automatically started, if possible. This threshold represents a potential loss of containment in that containment heat removal/depressurization systems (e.g., containment sprays, ice condenser fans, etc.,

but not including containment venting strategies) are either lost or performing in a degraded manner.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-42 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Figure 3-F-1: PWR Containment Integrity or Bypass Examples 1.b - Airborne Effluent release from pathway Inside Auxiliary Building Monitor Containment Vent Damper Filter Area Monitor Open valve Open valve Damper 1.a -

Airborne Penetration release from valve Airborne Monitor Open valve Open valve 2 - RCS 1.a - leakage Interface leakage Airborne outside point release from CNMT penetration Process Monitor Closed Cooling Water Open valve Open valve Pump System RCP Seal Cooling Month 20XX FC 3-43 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT5 Initiating Condition:

Emergency Director Judgment.

Operating Mode Applicability:

1, 2, 3 Fission Product Barrier (FPB) Threshold:

LOSS

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

POTENTIAL LOSS

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

Basis:

Loss Threshold #1 Basis This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Containment Barrier is lost.

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

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-3 Month 20XX FC 3-44 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG1 Initiating Condition:

Prolonged loss of all offsite and all onsite AC power to emergency busses.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

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

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

AND

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

AND

3. EITHER of the following:

a. Restoration of at least one vital 4160 volt bus in < 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is not likely.

OR

b. Core exit thermocouples > 1550°F.

Basis:

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses a prolonged loss of all power sources to AC emergency buses. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. A prolonged loss of these buses will lead to a loss of any fission product barriers. In addition, fission product barrier monitoring capabilities may be degraded under these conditions.

The EAL should require declaration of a General Emergency prior to meeting the thresholds for IC FG1. This will allow additional time for implementation of offsite protective actions.

Escalation of the emergency classification from Site Area Emergency will occur if it is projected that power cannot be restored to at least one AC emergency bus by the end of the analyzed station blackout coping period. Beyond this time, plant responses and Month 20XX FC 3-45 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG1 (cont)

Basis (cont):

event trajectory are subject to greater uncertainty, and there is an increased likelihood of challenges to multiple fission product barriers.

The estimate for restoring at least one emergency bus should be based on a realistic appraisal of the situation. Mitigation actions with a low probability of success should not be used as a basis for delaying a classification upgrade. The goal is to maximize the time available to prepare for, and implement, protective actions for the public.

The EAL will also require a General Emergency declaration if the loss of AC power results in parameters that indicate an inability to adequately remove decay heat from the core.

Basis Reference(s):

1. NEI 99-01 Rev 6, SG1 Month 20XX FC 3-46 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS1 Initiating Condition:

Loss of all offsite and all onsite AC power to emergency busses for 15 minutes or longer.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

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

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

AND

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

AND

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

Basis:

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. In addition, fission product barrier monitoring capabilities may be degraded under these conditions. This IC represents a condition that involves actual or likely major failures of plant functions needed for the protection of the public.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Escalation of the emergency classification level would be via ICs RG1, FG1, MG1, or MG2.

Basis Reference(s):

1. NEI 99-01 Rev 6, SS1 Month 20XX FC 3-47 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA1 Initiating Condition:

Loss of all but one AC power source to emergency buses for 15 minutes or longer.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

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

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

161 Kv Circuit 345 Kv Circuit EDG DG1 EDG DG2 AND

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

Basis:

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment. This IC provides an escalation path from IC MU1.

An AC power source is a source recognized in AOPs and EOPs, and capable of supplying required power to an emergency bus. Some examples of this condition are presented below.

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

Month 20XX FC 3-48 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA1 (cont)

Basis (cont):

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

A loss of emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from an offsite power source.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.

Escalation of the emergency classification level would be via IC MS1.

Basis Reference(s):

1. NEI 99-01 Rev 6, SA1 Month 20XX FC 3-49 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU1 Initiating Condition:

Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

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

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

> 15 minutes.

Basis:

This IC addresses a prolonged loss of offsite power. The loss of offsite power sources renders the plant more vulnerable to a complete loss of power to AC emergency buses.

This condition represents a potential reduction in the level of safety of the plant.

For emergency classification purposes, capability means that an offsite AC power source(s) is available to the emergency buses, whether or not the buses are powered from it.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of offsite power.

Escalation of the emergency classification level would be via IC MA1.

Basis Reference(s):

1. NEI 99-01 Rev 6, SU1 Month 20XX FC 3-50 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG2 Initiating Condition:

Loss of all AC and Vital DC power sources for 15 minutes or longer.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

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

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

AND

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

AND

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

AND

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

Basis:

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses a concurrent and prolonged loss of both AC and Vital DC power. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. A loss of Vital DC power compromises the ability to monitor and control SAFETY SYSTEMS. A sustained loss of both AC and DC power will lead to multiple challenges to fission product barriers.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. The 15-minute emergency declaration clock begins at the point when all EALs are met.

Basis Reference(s):

1. NEI 99-01 Rev 6, SG8 Month 20XX FC 3-51 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS2 Initiating Condition:

Loss of all vital DC power for 15 minutes or longer.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

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

Voltage is < 105 VDC on 125 VDC Bus1and Bus 2 for > 15 minutes.

Basis:

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses a loss of Vital DC power which compromises the ability to monitor and control SAFETY SYSTEMS. In modes above Cold Shutdown, this condition involves a major failure of plant functions needed for the protection of the public.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Escalation of the emergency classification level would be via ICs RG1, FG1 or MG3.

Basis Reference(s):

1. NEI 99-01 Rev 6, SS8 Month 20XX FC 3-52 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS3 Initiating Condition:

Inability to shutdown the reactor causing a challenge to core cooling or RCS heat removal.

Operating Mode Applicability:

1, 2 Emergency Action Level (EAL):

1. Automatic or Manual Trip did not shutdown the reactor as indicated by Reactor Power > 2%.

AND

2. All manual actions to shutdown the reactor have been unsuccessful as indicated by Reactor Power > 2%.

AND

3. EITHER of the following conditions exist:

a. Core exit thermocouples > 1550°F.

OR

b. RVLMS indicates 0.0%

OR

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

Basis:

This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, all subsequent operator manual actions, both inside and outside the Control Room including driving in control rods and boron injection, are unsuccessful, and continued power generation is challenging the capability to adequately remove heat from the core and/or the RCS. This condition will lead to fuel damage if additional mitigation actions are unsuccessful and thus warrants the declaration of a Site Area Emergency.

In some instances, the emergency classification resulting from this IC/EAL may be higher than that resulting from an assessment of the plant responses and symptoms against the Recognition Category F ICs/EALs. This is appropriate in that the Recognition Category F ICs/EALs do not address the additional threat posed by a failure to shutdown the reactor. The inclusion of this IC and EAL ensures the timely declaration of a Site Area Emergency in response to prolonged failure to shutdown the reactor.

A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.

Month 20XX FC 3-53 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS3 (cont)

Basis (cont):

Escalation of the emergency classification level would be via IC RG1 or FG1.

Basis Reference(s):

1. NEI 99-01 Rev 6, SS5 Month 20XX FC 3-54 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA3 Initiating Condition:

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

Operating Mode Applicability:

1, 2 Emergency Action Level (EAL):

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

1. Automatic or manual Trip did not shutdown the reactor as indicated by Reactor Power > 2%.

AND

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

Basis:

This IC addresses a failure of the RPS to initiate or complete an automatic reactor trip that results in a reactor shutdown, and subsequent operator manual actions taken at the Console Center to shutdown the reactor are also unsuccessful. This condition represents an actual or potential substantial degradation of the level of safety of the plant. An emergency declaration is required even if the reactor is subsequently shutdown by an action taken away from the Console Center since this event entails a significant failure of the RPS.

A manual action at the Console Center is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor trip. This action does not include manually driving in control rods or implementation of boron injection strategies. If this action(s) is unsuccessful, operators would immediately pursue additional manual actions at locations away from the Console Center (e.g., locally opening breakers). Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be at the Console Center.

The plant response to the failure of an automatic reactor trip will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If the failure to shutdown the reactor is prolonged enough to cause a challenge to the core cooling or RCS heat removal safety functions, the emergency Month 20XX FC 3-55 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA3 (cont)

Basis (cont):

classification level will escalate to a Site Area Emergency via IC MS3. Depending upon plant responses and symptoms, escalation is also possible via IC FS1. Absent the plant conditions needed to meet either IC MS3 or FS1, an Alert declaration is appropriate for this event.

It is recognized that plant responses or symptoms may also require an Alert declaration in accordance with the Recognition Category F ICs; however, this IC and EAL are included to ensure a timely emergency declaration.

A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.

Basis Reference(s):

1. NEI 99-01 Rev 6, SA5 Month 20XX FC 3-56 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU3 Initiating Condition:

Automatic or manual trip fails to shutdown the reactor.

Operating Mode Applicability:

1, 2 Emergency Action Level (EAL):

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

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

> 2%.

AND

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

OR

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

AND

b. EITHER of the following:

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

OR

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

Basis:

This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor trip that results in a reactor shutdown, and either a subsequent operator manual action taken at the Console Center or an automatic trip is successful in shutting down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.

EAL #1 Basis Following the failure on an automatic reactor trip, operators will promptly initiate manual actions at the Console Center to shutdown the reactor (e.g., initiate a manual reactor trip). If these manual actions are successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plants decay heat removal systems.

Month 20XX FC 3-57 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU3 (cont)

Basis (cont):

EAL #2 Basis If an initial manual reactor trip is unsuccessful, a concurrent plant condition, may lead to the generation of an automatic reactor trip signal. If a subsequent automatic trip is successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plants decay heat removal systems.

A manual action at the Console Center is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor trip). This action does not include manually driving in control rods or implementation of boron injection strategies. Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be at the Console Center.

The plant response to the failure of an automatic or manual reactor trip will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If subsequent operator manual actions taken at the Console Center are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC MA3. Depending upon the plant response, escalation is also possible via IC FA1. Absent the plant conditions needed to meet either IC MA3 or FA1, an Unusual Event declaration is appropriate for this event.

A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.

Should a reactor trip signal be generated as a result of plant work (e.g., RPS setpoint testing), the following classification guidance should be applied.

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

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

Basis Reference(s):

1. NEI 99-01 Rev 6, SU5 Month 20XX FC 3-58 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA4 Initiating Condition:

UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

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

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

Table M1 Control Room Parameters Reactor Power PZR Level RCS Pressure In Core/Core Exit Temperature Level in at least one Steam Generator Auxiliary Feed Water Flow AND

b. ANY Table M2 transient in progress.

Table M2 Significant Transients Electrical Load Rejection >25% full electrical load Reactor Trip ECCS Actuationer oscillations > 10%

Month 20XX FC 3-59 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA4 (cont)

Basis:

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

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses the difficulty associated with monitoring rapidly changing plant conditions during a transient without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. During this condition, the margin to a potential fission product barrier challenge is reduced. It thus represents a potential substantial degradation in the level of safety of the plant.

As used in this EAL, an inability to monitor means that values for any of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s). For example, the reactor power level cannot be determined from any analog, computer point, digital and recorder source within the Control Room.

An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required. The event would be reported if it significantly impaired the capability to perform emergency assessments. In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making.

This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling and RCS heat removal. The loss of the ability to determine any of these parameters from within the Control Room is considered to be more significant than simply a reportable condition. In addition, if all indication sources for any of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.

Escalation of the emergency classification level would be via ICs FS1 or IC RS1.

Basis Reference(s):

1. NEI 99-01 Rev 6, SA2 Month 20XX FC 3-60 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU4 Initiating Condition:

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

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

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

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

Table M1 Control Room Parameters Reactor Power PZR Level RCS Pressure In Core/Core Exit Temperature Level in at least one Steam Generator Auxiliary Feed Water Flow Basis:

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

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses the difficulty associated with monitoring normal plant conditions without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. This condition is a precursor to a more significant event and represents a potential degradation in the level of safety of the plant.

As used in this EAL, an inability to monitor means that values for any of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s). For example, the reactor power level cannot be determined from any analog, digital and recorder source within the Control Room. An event involving a loss of plant indications, Month 20XX FC 3-61 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU4 (cont)

Basis (cont):

annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required. The event would be reported if it significantly impaired the capability to perform emergency assessments. In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making.

This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling and RCS heat removal. The loss of the ability to determine any of these parameters from within the Control Room is considered to be more significant than simply a reportable condition. In addition, if all indication sources for any of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.

Escalation of the emergency classification level would be via IC MA4.

Basis Reference(s):

1. NEI 99-01 Rev 6, SU2 Month 20XX FC 3-62 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA5 Initiating Condition:

Hazardous event affecting a SAFETY SYSTEM required for the current operating mode.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

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

Seismic event (earthquake)

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

2. EITHER of the following:

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

OR

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

Basis:

FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.

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

Month 20XX FC 3-63 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA5 (cont)

Basis (cont):

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

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

This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or a structure containing SAFETY SYSTEM components, required for the current operating mode, "required", i.e. required to be operable by Technical Specifications for the current operating mode. This condition significantly reduces the margin to a loss or potential loss of a fission product barrier, and therefore represents an actual or potential substantial degradation of the level of safety of the plant. Manual or automatic electrical isolation of safety equipment due to flooding, in and of itself, does not constitute degraded performance and is classified under HU6.

EAL #2.a Basis This EAL addresses damage to a SAFETY SYSTEM train that is required to be operable by Technical Specifications for the current operating mode, and is in operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

EAL #2.b Basis This EAL addresses damage to a SAFETY SYSTEM component that is required to be operable by Technical Specifications for the current operating mode, and is not in operation or readily apparent through indications alone, as well as damage to a structure containing SAFETY SYSTEM components. Operators will make this determination based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.

Escalation of the emergency classification level would be via IC FS1 or RS1.

If the EAL conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.

Basis Reference(s):

1. NEI 99-01, Rev 6 SA9 Month 20XX FC 3-64 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU6 Initiating Condition:

RCS leakage for 15 minutes or longer.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

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

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

OR

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

OR

3. Leakage from the RCS to a location outside containment >25 gpm for > 15 minutes.

Basis:

UNISOLABLE: An open or breached system line that cannot be isolated, remotely or locally.

This IC addresses RCS leakage which may be a precursor to a more significant event.

In this case, RCS leakage has been detected and operators, following applicable procedures, have been unable to promptly isolate the leak. This condition is considered to be a potential degradation of the level of safety of the plant.

EAL #1 and EAL #2 Basis These EALs are focused on a loss of mass from the RCS due to unidentified leakage",

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

EAL #3 Basis This EAL addresses a RCS mass loss caused by an UNISOLABLE leak through an interfacing system. These EALs thus apply to leakage into the containment, a secondary-side system (e.g., steam generator tube leakage) or a location outside of containment.

The leak rate values for each EAL were selected because they are usually observable with normal Control Room indications. Lesser values typically require time-consuming calculations to determine (e.g., a mass balance calculation). EAL #1 uses a lower value that reflects the greater significance of unidentified or pressure boundary leakage.

Month 20XX FC 3-65 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU6 (cont)

Basis (cont):

The release of mass from the RCS due to the as-designed/expected operation of a relief valve does not warrant an emergency classification. An emergency classification would be required if a mass loss is caused by a relief valve that is not functioning as designed/expected (e.g., a relief valve sticks open and the line flow cannot be isolated).

The 15-minute threshold duration allows sufficient time for prompt operator actions to isolate the leakage, if possible.

Escalation of the emergency classification level would be via ICs of Recognition Category R or F.

Basis Reference(s):

1. NEI 99-01 Rev 6, SU4 Month 20XX FC 3-66 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU7 Initiating Condition:

Loss of all On-site or Off-site communications capabilities.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

1. Loss of ALL Table M3 Onsite communications capability affecting the ability to perform routine operations.

OR

2. Loss of ALL Table M3 Offsite communication capability affecting the ability to perform offsite notifications.

OR

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

Table M3 Communications Capability System Onsite Offsite NRC 800 MHz Radio System X Gai-tronics System X Security Building PABX X X X Training Building PABX X X X Commercial Telephones X X X Conference Operations X

Network (COP)

FTS-ENS X X HPN X X Satellite phones X X Blair Phone Line X Basis:

This IC addresses a significant loss of on-site, offsite, or NRC communications capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.

This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).

Month 20XX FC 3-67 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU7 (cont)

Basis (cont):

EAL #1 Basis Addresses a total loss of the communications methods used in support of routine plant operations.

EAL #2 Basis Addresses a total loss of the communications methods used to notify all OROs of an emergency declaration. The OROs referred to here are listed in procedure EP-MA-114-100-F-01, State / Local Event Notification Form.

EAL #3 Basis Addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.

Basis Reference(s):

1. NEI 99-01 Rev 6, SU6 Month 20XX FC 3-68 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU8 Initiating Condition:

Failure to isolate containment or loss of containment pressure control.

Operating Mode Applicability:

1, 2, 3 Emergency Action Level (EAL):

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

AND

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

OR

2. a. Containment pressure > 5 psig AND

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

Basis:

This IC addresses a failure of any containment penetrations to automatically isolate (close) when required by an actuation signal. It also addresses an event that results in high containment pressure with a concurrent failure of containment pressure control systems. Absent challenges to another fission product barrier, either condition represents potential degradation of the level of safety of the plant.

EAL #1 Basis The containment isolation signal must be generated as the result on an off-normal/accident condition (e.g., a safety injection or high containment pressure); a failure resulting from testing or maintenance does not warrant classification. The determination of containment and penetration status - isolated or not isolated - should be made in accordance with the appropriate criteria contained in the plant AOPs and EOPs. The 15-minute criterion is included to allow operators time to manually isolate the required penetrations, if possible.

Month 20XX FC 3-69 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU8 (cont)

Basis (cont):

EAL #2 Basis Addresses a condition where containment pressure is greater than the setpoint at which containment energy (heat) removal systems are designed to automatically actuate, and less than one full train of equipment is capable of operating per design. The 15-minute criterion is included to allow operators time to manually start equipment that may not have automatically started, if possible. The inability to start the required equipment indicates that containment heat removal/depressurization systems (e.g., containment sprays or ice condenser fans) are either lost or performing in a degraded manner.

This event would escalate to a Site Area Emergency in accordance with IC FS1 if there were a concurrent loss or potential loss of either the Fuel Clad or RCS fission product barriers.

Basis Reference(s):

1. NEI 99-01 Rev 6, SU7 Month 20XX FC 3-70 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA1 Initiating Condition:

Loss of all offsite and all onsite AC power to emergency busses for 15 minutes or longer.

Operating Mode Applicability:

4, 5, D Emergency Action Level (EAL):

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

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

AND

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

AND

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

Basis:

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink.

When in the cold shutdown, refueling, or defueled mode, this condition is not classified as a Site Area Emergency because of the increased time available to restore an emergency bus to service. Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition represents an actual or potential substantial degradation of the level of safety of the plant.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Escalation of the emergency classification level would be via IC CS6 or RS1.

Basis Reference(s):

1. NEI 99-01 Rev 6, CA2 Month 20XX FC 3-71 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU1 Initiating Condition:

Loss of all but one AC power source to emergency buses for 15 minutes or longer.

Operating Mode Applicability:

4, 5, D Emergency Action Level (EAL):

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

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

161 Kv Circuit 345 Kv Circuit EDG DG1 EDG DG2 AND

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

Basis:

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment.

When in the cold shutdown, refueling, or defueled mode, this condition is not classified as an Alert because of the increased time available to restore another power source to service. Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition is considered to be a potential degradation of the level of safety of the plant.

Month 20XX FC 3-72 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU1 (cont)

Basis (cont):

An AC power source is a source recognized in AOPs and EOPs, and capable of supplying required power to an emergency bus. Some examples of this condition are presented below.

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

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

A loss of emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from an offsite power source.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.

The subsequent loss of the remaining single power source would escalate the event to an Alert in accordance with IC CA1.

Basis Reference(s):

1. NEI 99-01 Rev 6 CU2 Month 20XX FC 3-73 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA2 Initiating Condition:

Hazardous event affecting SAFETY SYSTEM required for the current operating mode.

Operating Mode Applicability:

4, 5 Emergency Action Level (EAL):

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

Seismic event (earthquake)

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

2. EITHER of the following:

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

OR

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

Basis:

FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.

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

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

Month 20XX FC 3-74 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA2 (cont)

Basis (cont):

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

This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or a structure containing SAFETY SYSTEM components, required for the current operating mode, "required", i.e. required to be operable by Technical Specifications for the current operating mode. This condition significantly reduces the margin to a loss or potential loss of a fission product barrier, and therefore represents an actual or potential substantial degradation of the level of safety of the plant. Manual or automatic electrical isolation of safety equipment due to flooding, in and of itself, does not constitute degraded performance and is classified under HU6.

EAL #2.a Basis Addresses damage to a SAFETY SYSTEM train that is required to be operable by Technical Specifications for the current operating mode, and is in operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

EAL #2.b Basis Addresses damage to a SAFETY SYSTEM component that is required to be operable by Technical Specifications for the current operating mode, and is not in operation or readily apparent through indications alone, or to a structure containing SAFETY SYSTEM components. Operators will make this determination based on the totality of available event and damage report information. This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.

Escalation of the emergency classification level would be via IC CS6 or RS1.

If the EAL conditions of CA2 are not met then assess the event via HU3, HU4, or HU6.

Basis Reference(s):

1. NEI 99-01 Rev 6, CA6 Month 20XX FC 3-75 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU3 Initiating Condition:

Loss of Vital DC power for 15 minutes or longer.

Operating Mode Applicability:

4, 5 Emergency Action Level (EAL):

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

Voltage is <105 VDC on required 125 VDC Bus 1 and Bus 2 for >15 minutes.

Basis:

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses a loss of Vital DC power which compromises the ability to monitor and control operable SAFETY SYSTEMS when the plant is in the cold shutdown or refueling mode. In these modes, the core decay heat load has been significantly reduced, and coolant system temperatures and pressures are lower; these conditions raise the time available to restore a vital DC bus to service. Thus, this condition is considered to be a potential degradation of the level of safety of the plant.

As used in this EAL, required means the Vital DC buses necessary to support operation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment.

For example, if Train A is out-of-service (inoperable) for scheduled outage maintenance work and Train B is in-service (operable), then a loss of Vital DC power affecting Train B would require the declaration of an Unusual Event. A loss of Vital DC power to Train A would not warrant an emergency classification.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Depending upon the event, escalation of the emergency classification level would be via IC CA6 or CA5, or an IC in Recognition Category R.

Basis Reference(s):

1. NEI 99-01 Rev 6, CU4 Month 20XX FC 3-76 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU4 Initiating Condition:

Loss of all onsite or offsite communications capabilities.

Operating Mode Applicability:

4, 5, D Emergency Action Level (EAL):

1. Loss of ALL Table C1 Onsite communications capability affecting the ability to perform routine operations.

OR

2. Loss of ALL Table C1 Offsite communication capability affecting the ability to perform offsite notifications.

OR

3. Loss of ALL Table C1 NRC communication capability affecting the ability to perform NRC notifications.

Table C1 - Communications Capability System Onsite Offsite NRC 800 MHz Radio System X Gai-tronics System X Security Building PABX X X X Training Building PABX X X X Commercial Telephones X X X Conference Operations X

Network (COP)

FTS-ENS X X HPN X X Satellite phones X X Blair Phone Line X Basis:

This IC addresses a significant loss of on-site, offsite, or NRC communications capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.

This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).

Month 20XX FC 3-77 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU4 (cont)

Basis (cont):

EAL #1 Basis Addresses a total loss of the communications methods used in support of routine plant operations.

EAL #2 Basis Addresses a total loss of the communications methods used to notify all OROs of an emergency declaration. The OROs referred to here are listed in procedure ??? Event Notification Form.

EAL #3 Basis Addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.

Basis Reference(s):

1. NEI 99-01 Rev 6, CU5 Month 20XX FC 3-78 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA5 Initiating Condition:

Inability to maintain the plant in cold shutdown.

Operating Mode Applicability:

4, 5 Emergency Action Level (EAL):

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

1. UNPLANNED rise in RCS temperature > 210ºF due to loss of decay heat removal for > Table C2 duration.

Table C2 RCS Heat-up Duration Thresholds RCS Status Containment Closure Heat-up Status Duration Intact Not Applicable 60 minutes*

Not Intact Established 20 minutes*

OR Not Established 0 minutes Reduced Inventory

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

OR

2. UNPLANNED RCS pressure rise > 10 psig as a result of temperature rise due to loss of decay heat removal. (This EAL does not apply in solid plant conditions.)

Month 20XX FC 3-79 EP-XX-XXXX (Revision XX)

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

Basis:

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

CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

RCS is intact when the RCS pressure boundary is in its normal condition for the Cold Shutdown mode of operation (e.g. no freeze seals, etc.).

This IC addresses conditions involving a loss of decay heat removal capability or an addition of heat to the RCS in excess of that which can currently be removed. Either condition represents an actual or potential substantial degradation of the level of safety of the plant.

A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.

The RCS Heat-up Duration Thresholds table addresses a rise in RCS temperature when CONTAINMENT CLOSURE is established but the RCS is not intact, or RCS inventory is reduced (e.g., mid-loop operation in PWRs). The 20-minute criterion was included to allow time for operator action to address the temperature rise.

The RCS Heat-up Duration Thresholds table also addresses a rise in RCS temperature with the RCS intact. The status of CONTAINMENT CLOSURE is not crucial in this condition since the intact RCS is providing a high pressure barrier to a fission product release. The 60-minute time frame should allow sufficient time to address the temperature rise without a substantial degradation in plant safety.

Finally, in the case where there is a rise in RCS temperature, the RCS is not intact or is at reduced inventory, and CONTAINMENT CLOSURE is not established, no heat-up duration is allowed (i.e., 0 minutes). This is because 1) the evaporated reactor coolant may be released directly into the Containment atmosphere and subsequently to the environment, and 2) there is reduced reactor coolant inventory above the top of irradiated fuel.

EAL #2 Basis Provides a pressure-based indication of RCS heat-up.

Escalation of the emergency classification level would be via IC CS6 or RS1.

Basis Reference(s):

1. NEI 99-01 Rev 6, CA3 Month 20XX FC 3-80 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU5 Initiating Condition:

UNPLANNED rise in RCS temperature Operating Mode Applicability:

4, 5 Emergency Action Level (EAL):

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

1. UNPLANNED rise in RCS temperature > 210ºF due to loss of decay heat removal.

OR

2. Loss of the following for >15 minutes.

ALL RCS temperature indications AND ALL RCS level indications Basis:

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

CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

This IC addresses an UNPLANNED rise in RCS temperature above the Technical Specification cold shutdown temperature limit, or the inability to determine RCS temperature and level, represents a potential degradation of the level of safety of the plant. If the RCS is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency Director should also refer to IC CA5.

RCS is intact when the RCS pressure boundary is in its normal condition for the Cold Shutdown mode of operation (e.g. no freeze seals, etc.).

A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.

Month 20XX FC 3-81 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU5 (cont)

Basis (cont):

EAL #1 Basis Involves a loss of decay heat removal capability, or an addition of heat to the RCS in excess of that which can currently be removed, such that reactor coolant temperature cannot be maintained below the cold shutdown temperature limit specified in Technical Specifications. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.

During an outage, the level in the reactor vessel will normally be maintained above the reactor vessel flange. Refueling evolutions that lower water level below the reactor vessel flange are carefully planned and controlled. A loss of forced decay heat removal at reduced inventory may result in a rapid rise in reactor coolant temperature depending on the time after shutdown.

EAL #2 reflects a condition where there has been a significant loss of instrumentation capability necessary to monitor RCS conditions and operators would be unable to monitor key parameters necessary to assure core decay heat removal. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.

Escalation to Alert would be via IC CA6 based on an inventory loss or IC CA5 based on exceeding plant configuration-specific time criteria.

Basis Reference(s):

1. NEI 99-01 Rev 6, CU3 Month 20XX FC 3-82 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CG6 Initiating Condition:

Loss of reactor vessel/RCS inventory affecting fuel clad integrity with containment challenged.

Operating Mode Applicability:

4, 5 Emergency Action Level (EAL):

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

1. RVLMS indicates 0.0% for > 30 minutes.

OR

2. a. Reactor Vessel / RCS level unknown for > 30 minutes.

AND

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

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

OR Erratic Source Range Neutron Monitor indication.

OR Containment Area Radiation Monitors reading > 20 R/hr.

AND

3. ANY Containment Challenge Indication (Table C4)

Table C3 Indications of RCS Leakage UNPLANNED Containment Sump level rise*

UNPLANNED Auxiliary Bldg. Sump level rise*

UNPLANNED Reactor Coolant Drain Tank level rise*

UNPLANNED Quench Tank level rise*

UNPLANNED Spent Regenerate Tank level rise*

UNPLANNED rise in RCS makeup Observation of leakage or inventory loss

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

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

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CG6 (cont)

Emergency Action Level (EAL) (cont):

Table C4 Containment Challenge Indications Hydrogen Concentration in Containment > 3%

UNPLANNED rise in containment pressure CONTAINMENT CLOSURE not established*

• if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency is not required.

Basis:

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

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

CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

This IC addresses the inability to restore and maintain reactor vessel level above the top of active fuel with containment challenged. This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed EPA Protective Action Guidelines (PAG) exposure levels offsite for more than the immediate site area.

Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.

With CONTAINMENT CLOSURE not established, there is a high potential for a direct and unmonitored release of radioactivity to the environment. If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.

Month 20XX FC 3-84 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CG6 (cont)

Basis (cont):

The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a challenge to Containment integrity.

In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a core uncovery could result in an explosive gas mixture in containment. If all installed hydrogen gas monitors are out-of-service during an event leading to fuel cladding damage, it may not be possible to obtain a containment hydrogen gas concentration reading as ambient conditions within the containment will preclude personnel access.

During periods when installed containment hydrogen gas monitors are out-of-service, operators may use the other listed indications to assess whether or not containment is challenged.

The 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.

The inability to monitor reactor vessel/RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the reactor vessel/RCS.

These EALs address concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Basis Reference(s):

1. NEI 99-01 Rev 6, CG1 Month 20XX FC 3-85 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CS6 Initiating Condition:

Loss of reactor vessel/RCS inventory affecting core decay heat removal capability.

Operating Mode Applicability:

4, 5 Emergency Action Level (EAL):

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

1. With CONTAINMENT CLOSURE established RVLMS indicates 0.0%

OR

2. With CONTAINMENT CLOSURE not established RVLIS < 8.0%

OR

3. a. Reactor Vessel / RCS level unknown for >30 minutes.

AND

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

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

OR Erratic Source Range Neutron Monitor indication.

OR Containment Area Radiation Monitors reading > 20 R/hr.

Table C3 Indications of RCS Leakage UNPLANNED Containment Sump level rise*

UNPLANNED Auxiliary Bldg. Sump level rise*

UNPLANNED Reactor Coolant Drain Tank level rise*

UNPLANNED Quench Tank level rise*

UNPLANNED Spent Regenerate Tank level rise*

UNPLANNED rise in RCS makeup Observation of leakage or inventory loss

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

Month 20XX FC 3-86 EP-XX-XXXX (Revision XX)

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

Basis:

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

CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

The lost inventory may be due to a RCS component failure, a loss of configuration control or prolonged boiling of reactor coolant. These conditions entail major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.

Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.

Outage/shutdown contingency plans typically provide for re-establishing or verifying CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory control functions.

The 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.

The inability to monitor reactor vessel/RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the reactor vessel/RCS.

These EALs address concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Escalation of the emergency classification level would be via IC CG6 or RG1.

Basis Reference(s):

1. NEI 99-01 Rev 6, CS1 Month 20XX FC 3-87 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA6 Initiating Condition:

Loss of reactor vessel/RCS inventory.

Operating Mode Applicability:

4, 5 Emergency Action Level (EAL):

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

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

OR

2. a. Reactor Vessel / RCS level unknown for > 15 minutes.

AND

b. Loss of Reactor Vessel / RCS inventory per Table C3 indications.

Table C3 Indications of RCS Leakage UNPLANNED Containment Sump level rise*

UNPLANNED Auxiliary Bldg. Sump level rise*

UNPLANNED Reactor Coolant Drain Tank level rise*

UNPLANNED Quench Tank level rise*

UNPLANNED Spent Regenerate Tank level rise*

UNPLANNED rise in RCS makeup Observation of leakage or inventory loss

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

Month 20XX FC 3-88 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA6 (cont)

Basis:

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

This IC addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier). This condition represents a potential substantial reduction in the level of plant safety.

EAL #1 Basis A lowering of water level below 0 inches on Draindown Level indicator indicates that operator actions have not been successful in restoring and maintaining reactor vessel/RCS water level. The heat-up rate of the coolant will rise as the available water inventory is reduced. A continuing drop in water level will lead to core uncovery.

Although related, EAL #1 is concerned with the loss of RCS inventory and not the potential concurrent effects on systems needed for decay heat removal (e.g., loss of a Residual Heat Removal suction point). A rise in RCS temperature caused by a loss of decay heat removal capability is evaluated under IC CA5.

EAL #2 Basis The inability to monitor reactor vessel/RCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the reactor vessel/RCS.

The 15-minute duration for the loss of level indication was chosen because it is half of the EAL duration specified in IC CS6 If the reactor vessel/RCS inventory level continues to lower, then escalation to Site Area Emergency would be via IC CS6.

Basis Reference(s):

1. NEI 99-01 Rev 6, CA1 Month 20XX FC 3-89 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU6 Initiating Condition:

UNPLANNED loss of reactor vessel/RCS inventory for 15 minutes or longer.

Operating Mode Applicability:

4, 5 Emergency Action Level (EAL):

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

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

OR

2. a. Reactor Vessel / RCS level unknown.

AND

b. Loss of Reactor Vessel / RCS inventory per Table C3 indications.

Table C3 Indications of RCS Leakage UNPLANNED Containment Sump level rise*

UNPLANNED Auxiliary Bldg. Sump level rise*

UNPLANNED Reactor Coolant Drain Tank level rise*

UNPLANNED Quench Tank level rise*

UNPLANNED Spent Regenerate Tank level rise*

UNPLANNED rise in RCS makeup Observation of leakage or inventory loss

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

Basis:

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

This IC addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor reactor vessel/RCS level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant.

Month 20XX FC 3-90 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU6 (cont)

Basis (cont):

The procedurally established lower limit is not an operational band established above the procedural limit to allow for operator action prior to exceeding the procedural limit, but it is the procedurally established lower limit.

Refueling evolutions that lower RCS water inventory are carefully planned and controlled. An UNPLANNED event that results in water level decreasing below a procedurally required limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered.

EAL #1 Basis Recognizes that the minimum required reactor vessel/RCS level can change several times during the course of a refueling outage as different plant configurations and system lineups are implemented. This EAL is met if the minimum level, specified for the current plant conditions, cannot be maintained for 15 minutes or longer. The minimum level is typically specified in the applicable operating procedure but may be specified in another controlling document.

The 15-minute threshold duration allows sufficient time for prompt operator actions to restore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level.

EAL #2 Basis Addresses a condition where all means to determine reactor vessel/RCS level have been lost. In this condition, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the reactor vessel/RCS.

Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA6 or CA5.

Basis Reference(s):

1. NEI 99-01, Rev. 6 CU1 Month 20XX FC 3-91 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY 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 (EAL):

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

AND

2. a. ANY Table H1 safety function cannot be controlled or maintained.

OR

b. Damage to spent fuel has occurred or is IMMINENT Table H1 Safety Functions Reactivity Control (ability to shut down the reactor and keep it shutdown)

Core Cooling (ability to cool the core)

RCS Heat Removal (ability to maintain heat sink)

Basis:

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

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

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

PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.

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

Month 20XX FC 3-92 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG1 (cont)

Basis (cont):

HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

This IC addresses an event in which a HOSTILE FORCE has taken physical control of the facility to the extent that the plant staff can no longer operate equipment necessary to maintain key safety functions. It also addresses a HOSTILE ACTION leading to a loss of physical control that results in actual or IMMINENT damage to spent fuel due to

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

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.

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

contained in non-public documents such as the Security Plan.

Basis Reference(s):

1. NEI 99-01, Rev. 6 HG1 Month 20XX FC 3-93 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS1 Initiating Condition:

HOSTILE ACTION within the PROTECTED AREA.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

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

Basis:

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

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

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

PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.

HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

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

This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTED AREA. This event will require rapid response and assistance due to the possibility for damage to plant equipment.

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.

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

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS1 (cont)

Basis (cont):

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

As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The Site Area Emergency declaration will mobilize ORO resources and have them available to develop and implement public protective actions in the unlikely event that the attack is successful in impairing multiple safety functions.

This IC does not apply to a HOSTILE ACTION directed at an ISFSI PROTECTED AREA located outside the plant PROTECTED AREA; such an attack should be assessed using IC HA1. It also does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR

§ 50.72.

Escalation of the emergency classification level would be via IC HG1.

Basis Reference(s):

1. NEI 99-01 Rev 6, HS1 Month 20XX FC 3-95 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA1 Initiating Condition:

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

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

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

OR

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

Basis:

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

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

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

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

PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.

HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the Month 20XX FC 3-96 EP-XX-XXXX (Revision XX)

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

Basis (cont):

This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the plant and staff for a potential aircraft impact. Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.

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

As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The Alert declaration will also heighten the awareness of Offsite Response Organizations, allowing them to be better prepared should it be necessary to consider further actions.

This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE.

Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.

EAL #1 addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in a heightened state of readiness. This EAL is met when the threat-related information has been validated in accordance with AOP-37.

EAL #2 is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action directed against an ISFSI that is located outside the plant PROTECTED AREA.

The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may be provided by NORAD through the NRC.

In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.

Escalation of the emergency classification level would be via IC HS1.

Month 20XX FC 3-97 EP-XX-XXXX (Revision XX)

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

Basis Reference(s):

1. NEI 99-01 Rev 6, HA1 Month 20XX FC 3-98 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU1 Initiating Condition:

Confirmed SECURITY CONDITION or threat.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

1. Notification of a credible security threat directed at the site as determined per SY-AA-101-132, Security Assessment and Response to Unusual Activities.

OR

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

OR

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

Basis:

SECURITY CONDITION: Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

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

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

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

Month 20XX FC 3-99 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU1 (cont)

Basis (cont):

This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, and thus represent a potential degradation in the level of plant safety.

Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs HA1, HS1 and HG1.

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.

Classification of these events will initiate appropriate threat-related notifications to plant personnel and OROs.

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

EAL #1 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with SY-AA-101-132, Security Assessment and Response to Unusual Activities.

EAL #2 addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may also be provided by NORAD through the NRC. Validation of the threat is performed in accordance with AOP-37.

EAL #3 references Security Force because these are the individuals trained to confirm that a security event is occurring or has occurred. Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR

§ 2.39 information.

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

Basis Reference(s):

1. NEI 99-01 Rev 6, HU1 Month 20XX FC 3-100 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS2 Initiating Condition:

Inability to control a key safety function from outside the Control Room.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

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

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

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

2. Control of ANY Table H1 key safety function is not reestablished in < 15 minutes.

Table H1 Safety Functions Reactivity Control (ability to shut down the reactor and keep it shutdown)

Core Cooling (ability to cool the core)

RCS Heat Removal (ability to maintain heat sink)

Basis:

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

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

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

This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations, and the control of a key safety function cannot be reestablished in a timely manner. The failure to gain control of a key safety function following a transfer of plan control to alternate locations is a precursor to a challenge to any fission product barriers within a relatively short period of time.

Month 20XX FC 3-101 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS2 (cont)

Basis (cont):

The determination of whether or not control is established at the remote safe shutdown location(s) is based on Emergency Director judgment. The Emergency Director is expected to make a reasonable, informed judgment within 15 minutes whether or not the operating staff has control of key safety functions from the remote safe shutdown location(s).

Escalation of the emergency classification level would be via IC FG1 or CG6.

Basis Reference(s):

1. NEI 99-01, Rev 6 HS6 Month 20XX FC 3-102 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA2 Initiating Condition:

Control Room evacuation resulting in transfer of plant control to alternate locations.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

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

AOP-07 Evacuation of Control Room OR AOP-06 Fire Emergency Basis:

This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations outside the Control Room. The loss of the ability to control the plant from the Control Room is considered to be a potential substantial degradation in the level of plant safety.

Following a Control Room evacuation, control of the plant will be transferred to alternate shutdown locations. The necessity to control a plant shutdown from outside the Control Room, in addition to responding to the event that required the evacuation of the Control Room, will present challenges to plant operators and other on-shift personnel.

Activation of the ERO and emergency response facilities will assist in responding to these challenges.

Escalation of the emergency classification level would be via IC HS2.

Basis Reference(s):

1. NEI 99-01, Rev 6 HA6 Month 20XX FC 3-103 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 Initiating Condition:

FIRE potentially degrading the level of safety of the plant.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

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

1. A FIRE in ANY Table H2 area is not extinguished in < 15-minutes of ANY of the following FIRE detection indications:

Report from the field (i.e., visual observation)

Receipt of multiple (more than 1) fire alarms or indications Field verification of a single fire alarm OR

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

AND

b. The existence of a FIRE is not verified in < 30 minutes of alarm receipt.

OR

3. A FIRE within the plant PROTECTED AREA not extinguished in < 60-minutes of the initial report, alarm or indication.

OR

4. A FIRE within the plant PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.

Month 20XX FC 3-104 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 (cont)

Emergency Action Level (EAL) (cont):

Table H2 Vital Areas Containment Building Auxiliary Building Intake Structure SIRWT Turbine Building (SSE only)

Main and Auxiliary Transformer Yard Condensate Storage Tank Basis:

FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.

PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.

This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.

EAL #1 Basis The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE could be a drop in fire main pressure, automatic activation of a suppression system, etc.

Upon receipt, operators will take prompt actions to confirm the validity of an initial fire alarm, indication, or report. For EAL assessment purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and not the time that a subsequent verification action was performed. Similarly, the fire duration clock also starts at the time of receipt of the initial alarms, indication or report.

EAL #2 Basis Addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e.,

proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will take prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed.

Month 20XX FC 3-105 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 (cont)

Basis (cont):

A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional time is allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress.

If an actual FIRE is verified by a report from the field, then EAL #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted.

EAL #3 Basis In addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety.

EAL #4 Basis If a FIRE within the plant PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded. The dispatch of an offsite firefighting agency to the site requires an emergency declaration only if it is needed to actively support firefighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish.

Declaration is not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.

Basis-Related Requirements from Appendix R Appendix R to 10 CFR 50, states in part:

Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions."

When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.

Month 20XX FC 3-106 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 (cont)

Basis (cont):

Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.

In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify a single alarm is well within this worst-case 1-hour time period.

Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA2 or MA5.

Basis Reference(s):

1. NEI 99-01, Rev 6 HU4 Month 20XX FC 3-107 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU4 Initiating Condition:

Seismic event greater than OBE levels.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

Seismic event > Operating Basis Earthquake (OBE) as indicated by STRONG MOTION SEISMIC EVENT IN PROGRESS alarm OR Event indicator (SMA-3 Control Panel) has changed from Black to White Basis:

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

Event verification with external sources should not be necessary during or following an OBE. Earthquakes of this magnitude should be readily felt by on-site personnel and recognized as a seismic event (e.g., typical lateral accelerations are in excess of 0.08g).

The Shift Manager or Emergency Director may seek external verification if deemed appropriate (e.g., a call to the USGS, check internet news sources, etc.); however, the verification action must not preclude a timely emergency declaration.

Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA2 or MA5.

Basis Reference(s):

1. NEI 99-01, Rev 6 HU2 1

An OBE is vibratory ground motion for which those features of a nuclear power plant necessary for continued operation without undue risk to the health and safety of the public will remain functional.

2 An SSE is vibratory ground motion for which certain (generally, safety-related) structures, systems, and components must be designed to remain functional.

Month 20XX FC 3-108 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA5 Initiating Condition:

Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

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

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

Table H3 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Containment* Modes 3 through 4, and 5 Auxiliary Building* Modes 3 through 4, and 5

• Areas required to establish shutdown cooling AND

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

This IC addresses an event involving a release of a hazardous gas that precludes or impedes access to equipment necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal plant procedures. This condition represents an actual or potential substantial degradation of the level of safety of the plant.

Table H3 is a list of plant rooms or areas with entry-related mode applicability that contain equipment which require a manual/local action necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal operating procedures, where if this action is not completed the plant would not be able to attain and maintain cold shutdown.

Month 20XX FC 3-109 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA5 (cont)

Basis (cont):

This Table does not include rooms or areas for which entry is required solely to perform actions of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

This Table does not include the Control Room since adequate engineered safety/design features are in place to preclude a Control Room evacuation due to the release of a hazardous gas.

An Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time of the gaseous release. The emergency classification is not contingent upon whether entry is actually necessary at the time of the release.

Evaluation of the IC and EAL do not require atmospheric sampling; it only requires the Emergency Directors judgment that the gas concentration in the affected room/area is sufficient to preclude or significantly impede procedurally required access. This judgment may be based on a variety of factors including an existing job hazard analysis, report of ill effects on personnel, advice from a subject matter expert or operating experience with the same or similar hazards. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

An emergency declaration is not warranted if any of the following conditions apply.

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

The gas release is a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., fire suppression system testing).

The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.

An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment. This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.

Month 20XX FC 3-110 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA5 (cont)

Basis (cont):

This EAL does not apply to firefighting activities that generate smoke or that automatically or manually activate a fire suppression system in an area.

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

Basis Reference(s):

1. NEI 99-01, Rev 6 HA5 Month 20XX FC 3-111 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 Initiating Condition:

Hazardous Event Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

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

1. Tornado strike within the PROTECTED AREA.

OR

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

OR

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

OR

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

OR

5. Abnormal River level, as indicated by EITHER:

a. > 1004 feet MSL elevation (high level)

OR

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

Basis:

PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.

SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

Month 20XX FC 3-112 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 (cont)

Basis (cont):

This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.

EAL 1 Basis Addresses a tornado striking (touching down) within the Protected Area.

EAL #2 Basis Addresses flooding of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns.

Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode. Manual isolation of power to a SAFETY SYSTEM component as a result of is an event of lesser impact and would be expected to cause small and localized damage. The consequence of this type of event is adequately assessed and addressed in accordance with Technical Specifications.

EAL #3 Basis Addresses a hazardous materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel within the PROTECTED AREA.

EAL #4 Basis Addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles. Examples of such an event include site flooding caused by a hurricane, heavy rains, up-river water releases, dam failure, etc., or an on-site train derailment blocking the access road.

This EAL is not intended to apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the flooding around the Cooper Station during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in 2011.

EAL #5 Basis The minimum level of 976 feet 9 inches provides adequate suction to the pumps for cooling plant components. The minimum elevation of the raw water pump suction is 973 feet 9 inches. High river level of 1004 feet is based on elevation of the plant site and Security Building Floor and on Technical Specification 2.16 indicating that the flooding plan to protect the plant will be instituted at 1004.2 feet and rising.

Escalation of the emergency classification level would be based on ICs in Recognition Categories R, F, M, H or C.

Month 20XX FC 3-113 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 (cont)

Basis Reference(s):

1. NEI 99-01, Rev 6 HU3 Month 20XX FC 3-114 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG7 Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of a GENERAL EMERGENCY.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.

Basis:

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

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

HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE: An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.

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

Basis Reference(s):

1. NEI 99-01, Rev 6 HG7 Month 20XX FC 3-115 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS7 Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of a SITE AREA EMERGENCY.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts, (1) toward site personnel or equipment that could lead to the likely failure of or, (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

Basis:

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

HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE: An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.

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

Basis Reference(s):

1. NEI 99-01, Rev 6 HS7 Month 20XX FC 3-116 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA7 Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of an ALERT.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

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

Basis:

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

HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE: An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.

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

Basis Reference(s):

1. NEI 99-01, Rev 6 HA7 Month 20XX FC 3-117 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU7 Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of an UNUSUAL EVENT.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

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

Basis:

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

Basis Reference(s):

1. NEI 99-01, Rev 6 HU7 Month 20XX FC 3-118 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ISFSI MALFUNCTIONS E-HU1 Initiating Condition Damage to a loaded cask CONFINEMENT BOUNDARY.

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL):

Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading:

> 60mr/hr (gamma + neutron) on the top of the spent fuel cask OR

> 600mr/hr (gamma + neutron) on the side of the spent fuel cask, excluding inlet and outlet ducts Basis:

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

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

This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage cask is sealed. The word cask, as used in this EAL, refers to the storage container in use at the site for dry storage of irradiated fuel. The issues of concern are the creation of a potential or actual release path to the environment, degradation of one or more fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the cask or fuel from storage.

The existence of damage is determined by radiological survey. The technical specification multiple of 2 times, which is also used in Recognition Category R IC RU1, is used here to distinguish between non-emergency and emergency conditions. The emphasis for this classification is the degradation in the level of safety of the spent fuel cask and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the fact that the on-contact dose rate limit is exceeded may be determined based on measurement of a dose rate at some distance from the cask.

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

Month 20XX FC 3-119 EP-XX-XXXX (Revision XX)

Ft. Calhoun Station ___Omaha Public Power District RECOGNITION CATEGORY ISFSI MALFUNCTIONS E-HU1 (cont)

Basis Reference(s):

1. NEI 99-01, Rev 6 E-HU1 Month 20XX FC 3-120 EP-XX-XXXX (Revision XX)