JAFP-17-0050, Exigent License Amendment Request to Revise Emergency Action Level HU1.5

Exigent License Amendment Request to Revise Emergency Action Level HU1.5

ML17139C739
Person / Time
Site:	Nine Mile Point, FitzPatrick
Issue date:	05/19/2017
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-17-0050, NMP1L3153
Download: ML17139C739 (61)

Text

Exelon Generation 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.54(q) 10 CFR 50.90 10 CFR 50.91 (a)(6)

NMP1L3153 JAFP-17-0050 May 19, 2017 U.S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 20555-0001 Nine Mile Point Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-63 NRC Docket No. 50-220 Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License No. NPF-69 NRC Docket No. 50-410 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333

SUBJECT:

Exigent License Amendment Request - Revise Emergency Action Level HU1.5 In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," and pursuant to 10 CFR 50.54(q), "Emergency Plans," Exelon Generation Company, LLC (Exelon) requests amendments to the licenses for the facilities listed above. The proposed changes are being requested on an exigent basis pursuant to 10 CFR 50.91 (a)(6).

Specifically, the proposed changes involve revising the Emergency Plans for the affected facilities to revise Emergency Action Level (EAL) HU1 .5 (equivalent NEI 99-01 Rev 5 IC HU1 .5, NEI 99-01 Rev 6 IC HU3.4).

Exelon has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92, "Issuance of amendments."

The proposed changes have been reviewed by the Nine Mile Point Plant Operations Review Committee and the James A. FitzPatrick On-Site Safety Review Committee in accordance with the requirements of the Exelon Quality Assurance Program.

Exigent License Amendment Request Revise EAL HU1 .5 NRG Docket Nos. 50-220, 50-41 O, and 50-333 May 19, 2017 Page 2 This exigent LAA contains no regulatory commitments.

Attachments 1 and 2 provide the evaluation of the proposed changes and justification for the need for the exigent LAA per 10 CFR 50.91 (a)(6) for the Nine Mile Point Site and James A. FitzPatrick Nuclear Power Plant, respectively. Attachments 3 and 4 provide the marked up EAL pages that reflect the proposed changes for the Nine Mile Point Site and James A. FitzPatrick Nuclear Power Plant, respectively, and Attachments 5 and 6 provide the clean EAL pages for the Nine Mile Point Site and James A. FitzPatrick Nuclear Power Plant, respectively. Attachment 7 provides weekly and monthly lake levels furnished by the Army Corps of Engineers.

Exelon requests approval of this exigent LAA by June 2, 2017, to support the predicted rise in lake level.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), Exelon is notifying the State of New York of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official.

If you have any questions or require additional information, please contact Ron Reynolds at (61 O) 765-5247.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 19th day of May 2017.

Respectfully, A/~ J / L J r--=tr7' Jim Barstow Director, Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. Evaluation of Proposed Changes for NMP1 and 2

2. Evaluation of Proposed Changes for JAF 3 Markup of Proposed Emergency Action Level Pages for NMP1 and 2

4. Markup of Proposed Emergency Action Level Pages for JAF

5. Clean Emergency Action Level Pages for NMP 1 and 2

6. Clean Emergency Action Level Pages for JAF

7. Army Corps of Engineers Weekly Great Lakes Water Level Update cc: Regional Administrator - NRG Region I w/ attachments NRG Senior Resident Inspector - NMP NRG Senior Resident Inspector - JAF NAG Project Manager, NRA - NMP NRG Project Manager, NRA - JAF A.L. Peterson, NYSERDA

ATTACHMENT 1 Exigent License Amendment Request Nine Mile Point (NMP) Units 1 and 2 NRC Docket Nos. 50-220, 50-410 EVALUATION OF PROPOSED CHANGES for NMP1and2

Subject:

Exigent License Amendment Request - Revise Emergency Action Level HU1.5 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

5.0 REGULATORY EVALUATION

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

7.0 REFERENCES

Exigent License Amendment Request Attachment 1 Revise EAL HU1 .5 N RC Docket Nos. 50-220 and 50-41 O Page 1 of 13 May 19, 2017 Evaluation of Proposed Changes 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.54(q), "Emergency Plans," Exelon Generation Company, LLC (Exelon) is requesting approval for proposed changes to the Emergency Action Level (EAL) of Renewed Facility Operating License Nos. DPR-63 and NPF-69 for Nine Mile Point Nuclear Station, Unit 1 (NMP1) and Unit 2 (NMP2). The proposed changes are being requested on an exigent basis pursuant to 10 CFR 50.91 (a)(6) and submitted pursuant to 10 CFR 50.90. The reason that this License Amendment Request (LAA) is being submitted on an exigent basis and the justification why this situation could not be avoided is further discussed in Section 3 below.

The proposed change revises the Emergency Action Level (EAL) HU1 .5 for NMP1 and NMP2 (NMP Site). Specifically, the phrase "Lake water level >249.3Ft" is removed from HU1 .5 for NMP1 and NMP2, and it is replaced with "A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles."

Exelon requests approval of this exigent license amendment request by June 2nd, 2017, to support the predicted rise in lake level. Due to a combination of unusually wet weather and with the recent changes in lake authority strategy for controlling lake level implemented this spring, the threshold for declaring an Unusual Event (UE) is a high potential to be exceeded.

2.0 DETAILED DESCRIPTION 2.1 Proposed Emergency Action Level Changes:

Exelon proposes to change the NMP EALs (EPIP-EPP-01-EAL and EPIP-EPP-02-EAL) and bases documents (EP-AA-1013, Addendum 3 and Addendum 4) to revise Unusual Event (UE) EAL HU1 .5, "Natural or Destructive Phenomena," affecting the Protected Area. Specifically, the proposed change removes the UE High Lake Level numerical threshold and replaces it with "a hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles." The EALs revision is provided below (see Attachment 3 for markups of the EAL and the EAL Bases). The wording is consistent with NEI 99-01, Rev. 6 for the equivalent UE declaration.

The following represent the changes made to the affected EALs:

NMP Unit 1 HU1 .5 Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 1 - Natural or Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting the PROTECTED AREA

Exigent License Amendment Request Attachment 1 Revise EAL HU1 .5 NRC Docket Nos. 50-220 and 50-410 Page 2 of 13 May 19, 2017 Evaluation of Proposed Changes EAL: HU1 .5 Unusual Event Lake water !eve! > 249. 3 ft A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles OR Intake bay water level< 238.8 ft NMP Unit 2 HU1 .5 Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 1 - Natural or Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting the PROTECTED AREA EAL: HU1 .5 Unusual Event Lake water ifwe! > 249.3 ft A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles OR Intake bay water level < 237 ft 2.2 Reason for the Proposed Changes Lake Ontario, the easternmost of the Great Lakes, is an international body of water forming part of the border between the United States and Canada. The lake is 193 miles long and 53 miles wide at its largest points, and has a surface area of 7,340 square miles.

It has a maximum depth of 802 feet, an average depth of approximately 283 feet, and a volume of 393 cubic miles. Dams on the St. Lawrence River, under the authority of the International Lake Ontario - St. Lawrence River Board, are used to regulate the lake level.

The Boundary Waters Treaty of 1909 (BWT) established the International Joint Commission (IJC) as a cornerstone of United States - Canada relations in the boundary region (ref. www.ijc.org). Under the BWT, the IJC licenses and regulates certain water resource projects along the border that affect levels and flows on the other side. The IJC also alerts the governments to emerging issues that might have negative impacts on the quality or quantity of boundary waters.

A Supplementary Order issued on December 8, 2016, pursuant to the BWT directed establishment of trigger values at which actions to prevent lake level from getting too high or low are to be taken. These values are intended to maintain the regulated monthly mean regulated Lake Ontario within specified limits. The high limits vary by month and are 248.03 feet (April), 248.46 feet (May), 248.33 feet (June), and 248.13 feet (July). The International Lake Ontario - St. Lawrence River Board ensures compliance with the provisions of the Order relating to water levels.

Exigent License Amendment Request Attachment 1 Revise EAL HU1 .5 NRC Docket Nos. 50-220 and 50-41 O Page 3 of 13 May 19, 2017 Evaluation of Proposed Changes As a result of the changes in lake level water management, planned and purposeful regulating of lake level under the BWT, in conjunction with the unusual weather related conditions resulting in unexpected rise in lake water level, results in an increased probability to enter Emergency Classifications under EAL HU1 .5, Hazards and Other Conditions Affecting Plant Safety. Lake Ontario levels are managed at higher levels and current projections by the US Army Corps of Engineers (USAGE) in 2017 forecast lake levels to exceed the current UE setpoints.

This proposed change provided the basis that the Lake Ontario level-based EALs may be revised without impact to station operation or without affecting the level of health and safety to the public.

2.3 Supporting Information Flood Protection At NMP1, a rock dike 1000-ft long at the shoreline protects the Station from lake wave action or possible ice accumulation. The dike is two feet higher than yard grade (elevation 261 feet) and is constructed of rock from the Station excavation. Large rocks face the lake side of the dike and have proven very effective in wave damping and as a barrier to floating ice.

At NMP2, all safety-related facilities except the intake structure are protected from flooding by a revetment ditch system. The system is constructed along the lakeshore in front of NMP2. The top of the revetment is at an elevation of 263 feet and prevents possible plant flooding due to lake-level wave action. All safety-related facilities, systems, and equipment are protected against flood damage resulting from the probable maximum storm and historical maximum lake level, historical maximum precipitation and probable maximum lake level and surge with wind-wave action from Probable Maximum Wind Surge (PMWS). All personnel entrances to Category I structures are at elevation 261 feet or higher. The revetment ditch system was approved by the NRC in a December 1977 letter. The offshore intake structures are designed for the critical wave forces under different combinations of lake levels and wave heights. For example, the maximum horizontal wave force of 350 kips is calculated for the PMWS water level of elevation 254 feet and a maximum sustainable nonbreaking wave of 10.1 feet.

Lake Level Determination Lake level determination at the NMP site is performed by accessing a website maintained by the National Oceanic and Atmospheric Administration (NOAA). Current lake level in Oswego, NY is calculated by adding the "Observed Height" to 243.3 feet (International Great Lakes Datum of 1985 (IGLD85)). Note that IGLD85 is a reference elevation system used to define water levels within the Great Lakes-St. Lawrence River system.

Exigent License Amendment Request Attachment 1 Revise EAL HU1 .5 NRG Docket Nos. 50-220 and 50-41 O Page 4 of 13 May 19, 2017 Evaluation of Proposed Changes NMP Emergency Plan Background Currently, the EAL scheme used at NMP1 and NMP2 are based on the guidance provided in NEI 99-01, Revision 5. The NEI 99-01, Revision 5 EAL scheme was approved by the NRG on April 12, 2012, (ML120990003) and implemented on March 1, 2013.

3.0 BACKGROUND

The Boundary Waters Treaty of 1909 (BWT) established the International Joint Commission (IJC) as a cornerstone of United States - Canada relations in the boundary region. Under the BWT, the IJC licenses and regulates certain water resource projects along the border that affect levels and flows on the other side. The IJC also alerts the governments to emerging issues that might have negative impacts on the quality or quantity of boundary waters.

On December 8, 2016, a Supplementary Order was issued. The Order required the regulated monthly mean level of Lake Ontario not to exceed monthly values which have occurred between 1900 and 2008. Trigger levels were established for actions to prevent lake level from exceeding too high or too low from predetermined lake levels.

There was a change in water management strategy of Lake Ontario instituted by a Supplemental Order which was issued in December 2016 under the provisions of the BWT between the U.S. and Canada. The Order required the regulated monthly mean level of Lake Ontario not to exceed monthly values and action levels were established to prevent lake level from exceeding too high or too low from predetermined lake levels.

Under the current water management strategy mandated by the Order, certain action levels will allow the lake level to be managed above the threshold for the UE condition for NMP1 and NMP2.

Accordingly, Exelon is requesting to revise EAL HU1 .5 for NMP1 and NMP2.

Reason the Amendment is Requested on an Exigent Basis The water level regulatory plan implementing the December 8, 2016, Supplementary Order and unexpected conditions in the Lake Ontario and Ottawa River drainage basins have resulted in Lake Ontario water level being managed at values higher than historic norms. The Moses-Saunders Power Dam is used to control the water level in Lake Ontario, maintain water level for shipping, and prevent downstream flooding. The strategy for control set higher trigger points for the dam operator to take action to lower lake level, but they balance it with downstream water levels.

This has resulted in Lake Ontario water level being at its highest level in the past 19-years. The Ottawa River enjoins the St. Lawrence River downstream from the dam and is currently experiencing all time high levels and severe flooding. The Ottawa River peaked on Monday (May 8th) and began to decline but will likely take months to return to normal. The Ottawa River flow is causing flooding downstream from the Moses-Saunders

Exigent License Amendment Request Attachment 1 Revise EAL HU1 .5 NRC Docket Nos. 50-220 and 50-41 O Page 5 of 13 May 19, 2017 Evaluation of Proposed Changes Dam forcing the dam operator to limit flow through the Moses-Saunders Dam in order to prevent increased flooding in Lake Saint Louis. As Ottawa River flow declines, the dam operator increases flow from the Moses-Saunders Dam in an attempt to control Lake Ontario levels.

As of May 17, 2017, the current level of Lake Ontario is approximately 248.9 feet as measured by NMP using NOAA website for Oswego, NY Station ID 9052030. The USACE projects continue level increase such that by June 12, 2017, based on forecasted level management by the St. Lawrence control structures, the projected lake Ontario level may exceed the UE threshold of 249.3 feet for HU1 .5.

Reason Exigent Situation Has Occurred An abnormally wet spring season and recent heavy rains results in an increased water level in Lake Ontario. The current lake reading is approximately 248.9 feet as measured at the NMP site. The USACE projects additional rise in lake level based on forecasted level management by the St. Lawrence control structures. The projected increase is forecasted to exceed the high water level defined in the NMP1 UFSAR and NMP2 USAR by one to three inches. The UFSAR and USAR high lake level is a threshold for EAL HU1 .5. Once the threshold is exceeded, the plants are required to declare a UE in accordance with HU1 .5. This lake level can possibly be further exceeded due to unforeseen environmental factors to potentially the "Alert" threshold. Therefore, the NMP site may unnecessarily enter a UE for a prolonged period of time which would compound existing public stress and concern caused by the local environmental conditions. This UE would remain in place until the water level recedes back to normal level, which could be weeks or longer.

Reason the Situation Could Not Have Been Avoided Prior to mid to end of March, 2017, the lake levels have been comparable to level seen in previous years. Based on lake level predictions in April, 2017, Exelon proactively pursued increasing the EAL threshold to a value above the predicted level but with added conservatism to maintain the effectiveness of the Plan as required by 10 CFR 50.54(q) that was within the Licensee's control without need for NRC approval.

Currently, the USACE predicts the water level in Lake Ontario will rise from 248.69 feet to 249.02 feet on or before June 12th. While this value is below the current UE threshold for HU1 .5, there is little margin for error in the prediction (0.28 feet for NMP site) due to localized water level variations. As of May 12, 2017, the forecasted levels for Lake Ontario exceeded the average by 31 inches with additional level increases expected.

The USAGE lake level estimates have an inherent margin of error. The chart from the USACE website provides Lake Ontario water level predictions has water level peaking in May, but the margin of error could delay the peak until June (See Attachment 7). The green line is the prediction, but the red hash marks represent the prediction margin of error. Using the May 12, 2017, USACE Weekly Great lakes water level update, the April 12, 2017 lake level was 18 inches above average. The May 12, 2017 lake level was 28 inches above average. The 28 inches above average was above the projected level, and

Exigent License Amendment Request Attachment 1 Revise EAL HU1 .5 NRG Docket Nos. 50-220 and 50-41 O Page 6 of 13 May 19, 2017 Evaluation of Proposed Changes at the high end of the prediction margin when plotted on the 3 year level chart for May 2017. This demonstrates that actual lake levels can be higher than the USAGE predictions by about 6 inches (0.5 feet) for May 12, 2017. If this pattern continues, the UE level will be exceeded by June 12th, if not by the end of May. The basis for the unpredictable nature of the forecast is based on the weather, combined with political decisions to control flooding in New York State and areas of Canada adjacent to Lake Ontario and areas downstream along the St. Lawrence River.

Exelon has proactively taken all reasonable and prudent actions to mitigate the impact of this water level increase to the site within regulatory guidance, and without NRG relief.

Exelon fully expected the lake water level to subside and return to normal levels in accordance with the standard practices of the BWT. However, Lake Ontario level continues to increase and is predicted by the USAGE to rise to abnormal and unprecedented heights. In addition, the lake level prediction by the USAGE in April 2017 was underestimated with higher than predicted levels recorded. Therefore, without prompt NRG approval, Exelon is required to enter an unnecessary UE on, or before, June 12, 2017, without a net safety gain to the public or plant personnel as required by the Emergency Plan when lake levels exceed the current EAL threshold.

4.0 TECHNICAL EVALUATION

4.1 Deletion of the Lake Level Unusual Event Threshold Exelon proposes to revise the UE EAL HU1 .5, to remove the specific lake level numerical value and replace it with a descriptive threshold which states "A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles." The HU1 .5 intake bay water level threshold is not changed.

The high Lake level EAL threshold for NMP Units 1 and Unit 2 is currently set at 249.3 feet. At a lake level of 249.3 feet, there is no impact to plant equipment or station operation at NMP Units 1 or 2. There is no threat to engineered safeguards systems, such as the Emergency Core Cooling Systems. Additionally, there is no impact to plant personnel access to the station. Consistent with the guidance of NEI 99-01, Rev 5, the NMP EAL Bases states the UE lake level set point is established to provide a precursor to more serious events at the station.

Note that the HA1 .5 "Alert" EAL for High Lake Level is set at 254 feet for Unit 1 and Unit 2.

The Lake Level "Alert" EAL threshold remains in place and will continue to require implementation of the NMP Emergency Plan at the "Alert" level prior to any direct operational impact at the station.

With the "Alert" EAL HA 1.5 in place, the impact of removing the numerical lake level threshold at the UE level is inconsequential with respect to the Emergency Plan. There is no operational or safety system equipment impact to the station until lake water level exceeds the top of the station revetment ditch at 263 feet.

Exigent License Amendment Request Attachment 1 Revise EAL HU1 .5 NRC Docket Nos. 50-220 and 50-41 O Page 7 of 13 May 19, 2017 Evaluation of Proposed Changes As discussed in the NMP Unit 2 USAR, all safety-related facilities, except the intake structure, are protected from flooding by a revetment ditch system. The system is constructed along the lakeshore in front of NMP2. The top of the revetment is at an elevation of 263 feet and prevents possible plant flooding due to lake-level wave action.

All safety-related facilities, systems, and equipment are protected against flood damage resulting from the "probable maximum storm" and "historical maximum lake level",

"historical maximum precipitation", and probable maximum lake level and surge with wind-wave action from Probable Maximum Wind Surge (PMWS). Additionally, the offshore submerged intake structures are designed for the critical wave forces under different combinations of lake levels and wave heights.

For NMP1, a rock dike 1000-ft long at the shoreline protects the Station from lake wave action or possible ice accumulation. The dike is two feet higher than yard grade (elevation 261 feet) and is constructed of rock from the Station excavation. Large rocks face the lake side of the dike and have proven very effective in wave damping and as a barrier to floating ice.

4.2 Revision to EAL HU1 .5 Threshold A new threshold is added in place of the Lake level numerical threshold. Specifically, a threshold stating "A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles" is added to the NMP EAL scheme.

The EAL takes into consideration hazardous events that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles. This EAL is consistent with NEI 99-01, Revision 6, EAL HU3.4.

The addition of this EAL to the NMP Unit 1 and 2 EAL scheme compensates for the removal of EAL HU1 .5 numerical threshold with respect to personnel access. Existing EALs under the NMP NEI 99-01, Rev 5, based scheme address the impact to safety-related plant systems and equipment for high lake level and low intake bay levels; however, there are no existing EALs that address the impact of rising lake levels on station access by plant personnel.

The revision of the EAL has no adverse impact on the existing EAL scheme for NMP Units 1 and 2.

4.3 Defense in Depth In conjunction with the station Emergency Plan, a defense in depth posture remains in place at NMP with respect to high lake level.

Exigent License Amendment Request Attachment 1 Revise EAL HU1 .5 NRC Docket Nos. 50-220 and 50-41 O Page 8 of 13 May 19, 2017 Evaluation of Proposed Changes Generally, flooding at the station is addressed first through station Technical Specifications. The station Technical Specifications are available to assess and address the consequences of flooding events on plant equipment, specifically, operational issues regarding station safety related equipment.

The "Alert" EAL HA 1.5 for lake level remains in place to ensure appropriate actions under the station Emergency Plan are implemented. The "Alert" EAL ensures required communications are made to the NRC and State regarding emergency conditions at the station and more appropriate for public awareness and protection.

Impact to the station Emergency Response (including escalation of EAL classification) continues to be addressed through existing station EAL scheme. Specifically, the ability to escalate to higher emergency classification levels as an event deteriorates is maintained.

The response includes Initiating Conditions (ICs) in the following EAL Recognition Categories:

• Abnormal Rad Levels I Radiological Effluent

• Fission Product Barrier Degradation

• System Malfunction

• Cold Shutdown I Refueling System Malfunction Considering existing TS actions, existing EALs for internal flooding, and the revised HU1 .5 EAL addressing plant access, the removal of the High Lake Level EAL from the HU1 .5 EAL scheme continues to provide appropriate actions to protect the general health and safety of the public under the NMP Emergency Plan.

4.4 Emergency Preparedness Functional Evaluation The NMP Radiological Emergency Plan establishes the concepts, evaluation and assessment criteria, and protective actions that are necessary in order to limit and mitigate the consequences of potential or actual radiological emergencies. It has been prepared to establish the procedures and practices for management control over unplanned or emergency events that may occur at NMP.

10 CFR 50.47(b)(4) states "A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee." 10CFR Part 50, Appendix E further states "The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring."

EAL classifications implement actions to be taken in the event of a condition that may impact the health and safety of the general public or station employees. The philosophy that guides the development of the EALs is the protection of the health and safety of the general public in the communities around the nuclear power stations and the personnel who work at the plant.

Exigent License Amendment Request Attachment 1 Revise EAL HU1 .5 NRG Docket Nos. 50-220 and 50-41 O Page 9 of 13 May 19, 2017 Evaluation of Proposed Changes Exelon is revising the NMP U1 and NMP U2 EAL HU1 .5, "Natural or Destructive Phenomena affecting the Protected Area." Specifically, the lake water level high threshold is being removed and replaced with a threshold which states "A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles" is added to the NMP EAL scheme.

The high lake level of 249.3 feet poses no specific and is a premature concern under the Emergency Plan with regards to protection of the health and safety of the general public and personnel who work at the plant. The high lake level is primarily an operational condition handled more effectively by station Operating Procedures and Technical Specifications.

NMP site utilizes Operating Procedures to monitor the lake level. Changes to lake level occur incrementally and large changes occur over extended periods of time. Observed changes/trends are immediately communicated to Station Management for review and appropriate actions. Station Management is alerted and has opportunity to evaluate trends as the "Alert" EAL threshold is approached.

Given the gradual rate at which significant lake level changes occur, the approximate 6 feet difference between the UE and Alert threshold noted above, provides little value in being a precursor to the "Alert" classification under the Emergency Plan. Considering there is no operational impact to the station until after the 254 feet "Alert" level, the UE threshold is not necessary considering the frequent monitoring performed by station Operations. UE declarations would be declared unnecessarily with little association or correlation to providing protection to the health and safety of the public under the Emergency Plan and would be in effect for unnecessary prolonged periods of time.

The new EAL HU1 .5 threshold is established to identify hazardous events that result in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles. The addition of this threshold modifies the Hazards EAL to consider high lake levels that may not impact station equipment, but may impede access to the station by plant personnel.

4.5 Conclusion Based on the above, the proposed changes provide an EAL scheme that continues to meet the requirements in Appendix E to 10 CFR Part 50 and the planning standards of 10 CFR 50.47(b). The change does not adversely impact radiological safety at NMP. The revision of the Lake level numerical threshold and replacing it with a specific threshold addressing plant access maintains the intent and effectiveness of the Emergency Plan EAL scheme. From an operational perspective, the station remains capable of addressing rising lake level through operating procedures and TS.

The revision to the HU1 .5 EAL threshold continues to provide radiological protection and continues to protect the health and safety of the public and plant personnel under the EAL scheme.

Exigent License Amendment Request Attachment 1 Revise EAL HU1 .5 NRC Docket Nos. 50-220 and 50-410 Page 10 of 13 May 19, 2017 Evaluation of Proposed Changes

5.0 REGULATORY EVALUATION

5.1 Applicable Regulatory Requirements/Criteria The following regulatory requirements have been considered:

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 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.

5.2 Precedent There is no known precedent for submitting an exigent EAL change request.

Exigent License Amendment Request Attachment 1 Revise EAL HU1 .5 N RC Docket Nos. 50-220 and 50-41 o Page 11 of 13 May 19, 2017 Evaluation of Proposed Changes 5.3 No Significant Hazards Consideration Exelon has determined that changing the Emergency Action Level (EAL) HU1 .5 for NMP Site to remove the phrase "Lake water level >249.3Ft" and replace it with "A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles" does not involve a significant hazards consideration.

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

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

Response: No.

The proposed changes to EAL HU1 .5 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 Exelon's 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 EAL HU1 .5 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 vel}l 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, Exelon 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 plants are 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

Exigent License Amendment Request Attachment 1 Revise EAL HU1.5 NRG Docket Nos. 50-220 and 50-41 O Page 12 of 13 May 19, 2017 Evaluation of Proposed Changes 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 EAL HU1 .5 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 equipment beyond its normal functional capabilities. All Exelon 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 EAL HU1 .5 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 changes. 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. 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 Conclusion 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 EAL HU1 .5; 2) the changes will be in compliance with the NRC's regulations; and 3) the issuance of the amendments 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 amendment would change requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 because the amendment approves an acceptable EAL change which is required for operation of the facility. Exelon has evaluated the proposed change and has determined

Exigent License Amendment Request Attachment 1 Revise EAL HU1.5 NRC Docket Nos. 50-220 and 50-41 O Page 13 of 13 May 19, 2017 Evaluation of Proposed Changes that the change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51 .22(b) no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 REFERENCES

None

ATTACHMENT 2 Exigent License Amendment Request James A. FitzPatrick (JAF) Nuclear Power Plant NRC Docket No. 50-333 EVALUATION OF PROPOSED CHANGES for JAF

Subject:

Exigent License Amendment Request - Revise Emergency Action Level HU1.5 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

5.0 REGULATORY EVALUATION

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

7.0 REFERENCES

Exigent License Amendment Request Attachment 2 Revise EAL HU1 .5 NRC Docket No. 50-333 Page 1 of 13 May 19, 2017 Evaluation of Proposed Changes 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.54(q), "Emergency Plans," Exelon Generation Company, LLC (Exelon) is requesting approval for proposed changes to the Emergency Action Level (EAL) of Renewed Facility Operating License No. DPR-59 for James A. FitzPatrick Nuclear Power Plant (JAF). The proposed changes are being requested on an exigent basis pursuant to 10 CFR 50.91 (a)(6) and submitted pursuant to 10 CFR 50.90. The reason that this License Amendment Request (LAR) is being submitted on an exigent basis and the justification why this situation could not be avoided is further discussed in Section 3 below.

The proposed change revises the Emergency Action Level (EAL) HU1 .5 for JAF.

Specifically, the phrase "lake water level >249.2 feet" is removed from HU1 .5 and it is replaced with "A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles."

Exelon requests approval of this exigent license amendment request by June 2nd, 2017, to support the predicted rise in lake level. Due to a combination of unusually wet weather and with the recent changes in lake authority strategy for controlling lake level implemented this spring, the threshold for declaring an Unusual Event (UE) is a high potential to be exceeded.

2.0 DETAILED DESCRIPTION 2.1 Proposed Emergency Action Level Changes:

Exelon proposes to change the JAF EAL HU1 .5 and IAP-2 (to revise Unusual Event (UE)

EAL HU1 .5, "Natural or Destructive Phenomena," affecting the Protected Area.

Specifically, the proposed change removes the UE High Lake Level numerical threshold and replaces it with "a hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles." The EALs revision is provided below (see Attachment 3 for markups of the EAL and the EAL Bases). The wording is consistent with NEI 99-01, Rev. 6 for the equivalent UE declaration.

The following represent the changes made to the affected EALs:

JAFHU1.5 Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 1 - Natural or Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting the Protected Area EAL: HU1 .5 Unusual Event Lake v;ater love! > 249.2 # A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles. (Note 7)

Exigent License Amendment Request Attachment 2 Revise EAL HU1 .5 NRG Docket No. 50-333 Page 2 of 13 May 19, 2017 Evaluation of Proposed Changes OR ESW Intake bay water level < 237 ft Note 7: A hazardous event does not apply to routine traffic impediments such as fog, snow, ice or vehicle breakdowns or accidents.

2.2 Reason for the Proposed Changes Lake Ontario, the easternmost of the Great Lakes, is an international body of water forming part of the border between the United States and Canada. The lake is 193 miles long and 53 miles wide at its largest points, and has a surface area of 7,340 square miles.

It has a maximum depth of 802 feet, an average depth of approximately 283 feet, and a volume of 393 cubic miles. Dams on the St. Lawrence River, under the authority of the International Lake Ontario - St. Lawrence River Board, are used to regulate the lake level.

The Boundary Waters Treaty of 1909 (BWT) established the International Joint Commission (IJC) as a cornerstone of United States - Canada relations in the boundary region (ref. www.ijc.org). Under the BWT, the IJC licenses and regulates certain water resource projects along the border that affect levels and flows on the other side. The IJC also alerts the governments to emerging issues that might have negative impacts on the quality or quantity of boundary waters.

A Supplementary Order issued on December 8, 2016, pursuant to the BWT directed establishment of trigger values at which actions to prevent lake level from getting too high or low are to be taken. These values are intended to maintain the regulated monthly mean regulated Lake Ontario within specified limits. The high limits vary by month and are 248.03 feet (April), 248.46 feet (May), 248.33 feet (June), and 248.13 feet (July). The International Lake Ontario - St. Lawrence River Board ensures compliance with the provisions of the Order relating to water levels.

As a result of the changes in lake level water management, planned and purposeful regulating of lake level under the BWT, in conjunction with the unusual weather related conditions resulting in unexpected rise in lake water level results in an increased probability to enter Emergency Classifications under EAL HU1 .5, Hazards and Other Conditions Affecting Plant Safety.

This proposed change demonstrates that the Lake Ontario level-based EALs may be revised without impact to station operation or without affecting the level of health and safety to the public.

Exigent License Amendment Request Attachment 2 Revise EAL HU1 .5 N RC Docket No. 50-333 Page 3 of 13 May 19, 2017 Evaluation of Proposed Changes 2.3 Supporting Information Flood Protection Excerpt from the JAF Final Safety Analysis Report (FSAR), Section 2.4.3.7, Implication of the Maximum and Minimum Lake Levels on Power Station:

The average ground elevation outside the screenhouse is 272.0 ft. Concerning the flooding of the exterior access of the power plant, the maximum wave runup of 7.5 ft, the maximum wind setup of 4. 1 ft, and the maximum rainfall of 0. 35 ft were added to the previous maximum controlled still water level of 248 ft resulting in a maximum probable flood level of el. 260 at the JAF site.

The grade elevation of the power plant, 272.0 ft, is well above the probable coincident maximum flood level of 260 ft at the power plant site with a freeboard of 12 ft.

Consideration of a maximum lake level of el. 250 ft (which is above the current maximum controlled mean monthly still water level of 249. 17 ft) would still result in approximately 1O ft. of freeboard.

The original design basis maximum flood level in the screenhouse was determined as el. 252.5. Since the intake screenhouse top deck ceiling is at el. 253.0, which is 0.5 ft above maximum probable flood level in the screenhouse, no damage from flooding would be expected. The revised design basis flood level of el. 255 coincides with the floor level in the screenwell. Any uplift forces on the floor slab resulting from this higher floor level are more than offset by the weight of the slab. Again, no damage from flooding is expected. All seismic Class I equipment in the screenwell area is mounted at or above el. 255.

The effect of waves in the lake on the performance of the circulating water system is negligible and no loss of cooling water resulting from surging in the intake conduit could occur.

Lake Level Determination Normal lake level monitoring is done through a Main Control Room process computer indication. This computer point is driven from a level indicator which is located in the JAF common bay where the station cooling water pumps take suction. This bay is downstream of our intake screens. Additionally, if the computer indication fails, there are two separate local intake level indicators. One of these indicators is directly upstream of our intake screens and one is downstream of the intake screens within the bay. Intake bay water level and other elevations at the JAF site are referenced to the US Lake Survey Datum of 1935. Lake Ontario water levels provided by the US Army Corp of Engineers (USAGE), National Oceanic and Atmospheric Administration and other outside sources are referenced to the International Great Lakes Datum of 1985.

Exigent License Amendment Request Attachment 2 Revise EAL HU1 .5 NRC Docket No. 50-333 Page 4 of 13 May 19, 2017 Evaluation of Proposed Changes JAF Emergency Plan Background Currently, the EAL scheme used at JAF is based on the guidance provided in NEI 99-01, Revision 5. The NEI 99-01, Revision 5 EAL scheme was approved by the NRC on April 20, 2011 (ML11069A001) and implemented on October 20, 2011.

3.0 BACKGROUND

The Boundary Waters Treaty of 1909 (BWT) established the International Joint Commission (IJC) as a cornerstone of United States - Canada relations in the boundary region. Under the BWT, the IJC licenses and regulates certain water resource projects along the border that affect levels and flows on the other side. The IJC also alerts the governments to emerging issues that might have negative impacts on the quality or quantity of boundary waters.

On December 8, 2016, a Supplementary Order was issued. The Order required the regulated monthly mean level of Lake Ontario not to exceed monthly values which have occurred between 1900 and 2008. Trigger levels were established for actions to prevent lake level from exceeding too high or too low from predetermined lake levels.

There was a change in water management strategy of Lake Ontario instituted by a Supplemental Order which was issued in December 2016 under the provisions of the BWT between the U.S. and Canada. The Order required the regulated monthly mean level of Lake Ontario not to exceed monthly values and action levels were established to prevent lake level from exceeding too high or too low from predetermined lake levels.

Under the current water management strategy mandated by the Order, certain action levels will allow the lake level to be managed above the threshold for the UE condition for JAF.

Accordingly, Exelon is requesting to revise EAL HU1 .5 for JAF.

Reason the Amendment is Requested on an Exigent Basis The water level regulatory plan implementing the December 8, 2016, Supplementary Order and unexpected conditions in the Lake Ontario and Ottawa River drainage basins have resulted in Lake Ontario water level being managed at values higher than historic norms. The Moses-Saunders Power Dam is used to control the water level in Lake Ontario, maintain water level for shipping, and prevent downstream flooding. The strategy for control set higher trigger points for the dam operator to take action to lower lake level, but they balance it with downstream water levels.

This has resulted in Lake Ontario water level being at its highest level in the past 19-years. The Ottawa River enjoins the St. Lawrence River downstream from the dam and is currently experiencing all time high levels and severe flooding. The Ottawa River peaked on Monday (May 8th) and began to decline but will likely take months to return to normal. The Ottawa River flow is causing flooding downstream from the Moses-Saunders

Exigent License Amendment Request Attachment 2 Revise EAL HU1 .5 NRG Docket No. 50-333 Page 5 of 13 May 19, 2017 Evaluation of Proposed Changes Dam forcing the dam operator to limit flow through the Moses-Saunders Dam in order to prevent increased flooding in Lake Saint Louis. As Ottawa River flow declines, the dam operator increases flow from the Moses-Saunders Dam in an attempt to control Lake Ontario levels.

As of May 16, 2017, the current level of Lake Ontario is approximately 248.2 feet as measured at JAF. The USAGE projects continued level increase such that by June 12, 2017, based on forecasted level management by the St. Lawrence control structures, the projected lake Ontario level may exceed the high water level UE threshold of 249.2 feet for HU1.5.

Reason Exigent Situation Has Occurred An abnormally wet spring season and recent heavy rains results in an increased water level in Lake Ontario. The current lake reading is approximately 248.2 feet as measured at JAF site. The USAGE projects additional rise in lake level based on forecasted level management by the St. Lawrence control structures. The projected increase has a high probability to exceed the high water level defined in the JAF FSAR by one to three inches.

The FSAR high lake level is a threshold for EAL HU 1.5. Once the threshold is exceeded, the plant is required to declare a UE in accordance with HU1 .5. This lake level can possibly be further exceeded due to unforeseen environmental factors to potentially the "Alert" threshold. Therefore, JAF may unnecessarily enter a UE for a prolonged period of time which would compound existing public stress and concern caused by the local environmental conditions. This UE would remain in place until the water level recedes back to normal level, which could be weeks or longer.

Reason the Situation Could Not Have Been Avoided Prior to mid to end of March, 2017, the lake levels have been comparable to level seen in previous years. Based on lake level predictions in April, 2017, Exelon proactively pursued increasing the EAL threshold to a value above the predicted level but with added conservatism to maintain the effectiveness of the Plan as required by 10 CFR 50.54{q) that was within the Licensee's control without need for NRG approval.

Currently, the USAGE predicts the water level in Lake Ontario will rise from 248.69 feet to 249.02 feet on or before June 12th. While this value is below the current UE threshold for HU1 .5, there is little margin for error in the prediction (0.18 feet for JAF) due to localized water level variations. As of May 12, 2017, the forecasted levels for Lake Ontario exceeded the average by 31 inches with additional level increases expected.

The USAGE lake level estimates have an inherent margin of error. The chart from the USAGE website provides Lake Ontario water level predictions has water level peaking in May, but the margin of error could delay the peak until June (See Attachment 7). The green line is the prediction, but the red hash marks represent the prediction margin of error. Using the May 12, 2017, USAGE Weekly Great lakes water level update, the April 12, 2017 lake level was 18 inches above average. The May 12, 2017 lake level was 28 inches above average. The 28 inches above average was above the projected level, and at the high end of the prediction margin when plotted on the 3 year level chart for May

Exigent License Amendment Request Attachment 2 Revise EAL HU1 .5 NRC Docket No. 50-333 Page 6 of 13 May 19, 2017 Evaluation of Proposed Changes 2017. This demonstrates that actual lake levels can be higher than the USAGE predictions by about 6 inches (0.5 feet) for May 12, 2017. If this pattern continues, the UE level will be exceeded by June 12th, if not by the end of May. The basis for the unpredictable nature of the forecast is based on the weather, combined with political decisions to control flooding in New York State and areas of Canada adjacent to Lake Ontario and areas downstream along the St. Lawrence River.

Exelon has proactively taken all reasonable and prudent actions to mitigate the impact of this water level increase to the site within regulatory guidance, and without NRC relief.

Exelon fully expected the lake water level to subside and return to normal levels in accordance with the standard practices of the BWT. However, Lake Ontario level continues to increase and is predicted by the USAGE to rise to abnormal and unprecedented heights. In addition, the lake level prediction by the USAGE in April 2017 was underestimated with higher than predicted levels recorded. Therefore, without prompt NRC approval, Exelon is required to enter an unnecessary UE on, or before, June 12, 2017, without a net safety gain to the public or plant personnel as required by the Emergency Plan when lake levels exceed the current EAL threshold.

4.0 TECHNICAL EVALUATION

4.1 Deletion of the Lake Level Unusual Event Threshold Exelon proposes to revise the UE EAL HU1 .5, to remove the specific lake level numerical value and replace it with a descriptive threshold which states "A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles." The HU1 .5 intake bay low water level threshold is not changed.

The high lake level EAL threshold for JAF is currently set at 249.2 feet. At a lake level of 249.2 feet there is no impact to plant equipment or station operation at JAF. There is no threat to engineered safeguards systems, such as the Emergency Core Cooling Systems.

Additionally, there is no impact to plant personnel access to the station. Consistent with the guidance of NEI 99-01, Rev 5, the JAF EAL Basis states the UE lake level set point is established to provide a precursor to more serious events at the station.

Note that the HA 1.6 "Alert" EAL for high lake level is set at 255 feet. The Lake Level "Alert" EAL threshold remains in place and will continue to require implementation of the JAF Emergency Plan at the "Alert" level prior to any direct operational impact at the station.

With the "Alert" EAL HA 1.6 in place, the impact of removing the numerical lake level threshold at the UE level is inconsequential with respect to the Emergency Plan. There is no operational or safety system equipment impact to the station until lake water level exceeds the "Alert" level. As discussed in the JAF FSAR, all safety-related facilities, systems, and equipment are protected against flood damage up to the "Alert" level of 255 feet. The FSAR states "The grade elevation of the power plant, 272.0 ft, is well above the probable coincident maximum flood level of 260 ft at the power plant site with a freeboard of 12 ft. ... The original design basis maximum flood level in the screenhouse

Exigent License Amendment Request Attachment 2 Revise EAL HU1 .5 NRC Docket No. 50-333 Page 7 of 13 May 19, 2017 Evaluation of Proposed Changes was determined as el. 252.5. Since the intake screenhouse top deck ceiling is at el.

253.0, which is 0.5 ft above maximum probable flood level in the screenhouse, no damage from flooding would be expected. The revised design basis flood level of el. 255 coincides with the floor level in the screenwell."

4.2 Revision to EAL HU1 .5 Threshold A new threshold is added in place of the Lake level numerical threshold. Specifically, a threshold stating "A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles" is added to the JAF EAL scheme.

The EAL takes into consideration hazardous events that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles. This EAL is consistent with NEI 99-01, Revision 6, EAL HU3.4.

The addition of this EAL to the JAF EAL scheme compensates for the removal of EAL HU1 .5 numerical threshold with respect to personnel access. Existing EALs under the JAF NEI 99-01 Rev 5 based scheme address the impact to safety-related plant systems and equipment for high lake level and low intake bay levels; however, there are no existing EALs that address the impact of rising lake levels on station access by plant personnel.

The revision of the EAL has no adverse impact on the existing EAL scheme for JAF.

4.3 Defense in Depth In conjunction with the station Emergency Plan, a defense in depth posture remains in place at JAF with respect to high lake level.

Abnormal lake levels at JAF are addressed through a combination of TS requirements, Emergency Action Levels, Operating Procedures, and Abnormal Operating Procedures.

These requirements are coordinated to take increasingly stringent actions as lake level exceeds pre-determined setpoints. This coordinated approach ensures that the plant remains in a safe condition prior to equipment being rendered inoperable.

The "Alert" EAL HA 1.6 for lake level remains in place to ensure appropriate actions under the station Emergency Plan are implemented. The "Alert" EAL ensures required communications are made to the NRC and State regarding emergency conditions at the station and more appropriate for public awareness and protection.

Impact to the station Emergency Response (including escalation of EAL classification) continues to be addressed through the existing station EAL scheme. Specifically, the ability to escalate to higher emergency classification levels as an event deteriorates is maintained. The response includes Initiating Conditions (ICs) in the following EAL Recognition Categories:

Exigent License Amendment Request Attachment 2 Revise EAL HU1 .5 NRC Docket No. 50-333 Page 8 of 13 May 19, 2017 Evaluation of Proposed Changes

• Abnormal Rad Levels I Radiological Effluent

• Hazards

• Fission Product Barrier Degradation

• System Malfunction

• Cold Shutdown I Refueling System Malfunction Considering existing TS actions, Operating Procedures, and Abnormal Operating Procedures, existing EALs for internal flooding, and the revised HU1 .5 EAL addressing plant access, the removal of the High Lake Level EAL from the HU1 .5 EAL scheme continues to provide appropriate actions to protect the general health and safety of the public under the JAF Emergency Plan and do not reduce the effectiveness of the Emergency Plan.

4.4 Emergency Preparedness Functional Evaluation The JAF Radiological Emergency Plan establishes the concepts, evaluation and assessment criteria, and protective actions that are necessary in order to limit and mitigate the consequences of potential or actual radiological emergencies. It has been prepared to establish the procedures and practices for management control over unplanned or emergency events that may occur at JAF.

10 CFR 50.47(b)(4) states "A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee." 10CFR Part 50, Appendix E further states "The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring."

EAL classifications implement actions to be taken in the event of a condition that may impact the health and safety of the general public or station employees. The philosophy that guides the development of the EALs is the protection of the health and safety of the general public in the communities around the nuclear power stations and the personnel who work at the plant.

Exelon is revising the JAF EAL HU1 .5, "Natural or destructive phenomena affecting the Protected Area." Specifically, the lake water level high threshold is being removed and replaced with a threshold which states "A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles" is added to the JAF EAL scheme.

The high lake level of 249.2 feet poses no specific and is a premature concern under the Emergency Plan with regards to protection of the health and safety of the general public and personnel who work at the plant. The high lake level is primarily an operational condition handled more effectively by station Operating Procedures and Technical Specifications.

Exigent License Amendment Request Attachment 2 Revise EAL HU1 .5 NRG Docket No. 50-333 Page 9 of 13 May 19, 2017 Evaluation of Proposed Changes JAF continually monitors level in the intake structure utilizing the plant process computer, and records level periodically per required surveillance testing. Changes to lake still water level occur incrementally and large changes occur over extended periods of time (i.e.,

days/weeks). Observed changes/trends are immediately communicated to Station Management for review and appropriate actions. Station Management is alerted and has opportunity to evaluate trends as the "Alert" EAL threshold is approached.

Given the gradual rate at which significant lake level changes occur, the approximate 6 feet difference between the UE and "Alert" threshold noted above, provides little value in being a precursor to the "Alert" classification under the Emergency Plan. Considering there is no operational impact to the station until after the 255 feet "Alert" level, the UE threshold is not necessary considering the frequent monitoring performed by station Operations. UE declarations would be declared unnecessarily with little association or correlation to providing protection to the health and safety of the public under the Emergency Plan and would be in effect for unnecessary prolonged periods of time.

The new EAL HU1 .5 threshold is established to identify hazardous events that result in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles. The addition of this threshold modifies the Hazards EAL to consider high lake levels that may not impact station equipment, but may impede access to the station by plant personnel.

4.5 Conclusion Based on the above, the proposed changes provide an EAL scheme that continues to meet the requirements in Appendix E to 10 CFR Part 50 and the planning standards of 10 CFR 50.47(b). The change does not adversely impact radiological safety at JAF. The revision of the lake level numerical threshold and replacing it with a specific threshold addressing plant access maintains the intent and effectiveness of the Emergency Plan EAL scheme. From an operational perspective, the station remains capable of addressing rising lake level through operating procedures and TS.

The revision to the HU1 .5 EAL threshold continues to provide radiological protection and continues to protect the health and safety of the public and plant personnel under the EAL scheme.

5.0 REGULATORY EVALUATION

5.1 Applicable Regulatory Requirements/Criteria The following regulatory requirements have been considered:

The proposed changes have been evaluated to determine whether applicable regulations and requirements continue to be met.

Exigent License Amendment Request Attachment 2 Revise EAL HU1 .5 NRC Docket No. 50-333 Page 10 of 13 May 19, 2017 Evaluation of Proposed Changes 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 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.

5.2 Precedent There is no known precedent for submitting an exigent EAL change request.

5.3 No Significant Hazards Consideration Exelon has determined that changing the Emergency Action Level (EAL) HU1 .5 for JAF to remove the phrase "Lake water level >249.2 ft" and replace it with "A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles" does not involve a significant hazards consideration.

Exigent License Amendment Request Attachment 2 Revise EAL HU1 .5 NRC Docket No. 50-333 Page 11 of 13 May 19, 2017 Evaluation of Proposed Changes Exelon has evaluated whether or not a significant hazards consideration is involved with the proposed amendment request by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No.

The proposed changes to EAL HU1 .5 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 Exelon's 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 EAL HU1 .5 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, Exelon 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 plants are 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.

Exigent License Amendment Request Attachment 2 Revise EAL HU1 .5 NRG Docket No. 50-333 Page 12 of 13 May 19, 2017 Evaluation of Proposed Changes

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 EAL HU1 .5 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 equipment beyond its normal functional capabilities. All Exelon 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 EAL HU1 .5 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 changes. 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. 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 Conclusion 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 EAL HU1 .5; 2) the changes will be in compliance with the NRC's regulations; and 3) the issuance of the amendments 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 amendment would change requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 because the amendment approves an acceptable EAL change which is required for operation of the facility. Exelon has evaluated the proposed change and has determined that the change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluent that may be

Exigent License Amendment Request Attachment 2 Revise EAL HU1 .5 NRC Docket No. 50-333 Page 13 of 13 May 19, 2017 Evaluation of Proposed Changes released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 REFERENCES

None

ATTACHMENT 3 Exigent License Amendment Request Nine Mile Point (NMP) Units 1 and 2 Revise Emergency Action Level HU1.5 NRC Docket Nos. 50-220, 50-410 MARKUP OF PROPOSED EMERGENCY ACTION LEVEL PAGES FOR NMP1 AND 2 NMP1 EAL Pages 74 75 NMP1 EAL Matrix Pages 1

2 NMP2 EAL Pages 81 82 NMP2 EAL Matrix Pages 1

2

UNIT 1 EMERGENCY CLASSIFICATION TECHNICAL BASES EP-AA-1013 Addendum 3 Revision X Page 7 4 of 246 Attachment 1, Emergency Action Level Technical Bases (Continued)

Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 1 - Natural or Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting the PROTECTED AREA EAL:

HU1.5 Unusual Event

- - - A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.Lake 'Nater level > 249.a ft OR Intake water level < 238.8 ft.

Note: A hazardous event does not apply to routine traffic impediments such as fog , snow, ice, or vehicle breakdowns or accidents.

Mode Applicability:

All Basis:

Plant-Specific This threshold addresses a hazardous condition that could impede normal plant staffing~ and low bay water level conditions that could be a precursor of more serious events (ref. 1, 2).

The high lake level is based 1:1pon the FAaxiFAuFA attainable uncontrolled lake water le1.iel as specified in the NMP 2 USAR. Dams on the St. Lawrence River, under the aut1=1ority of the International St.

Lawrence River Board of Control, are nm\' used to regulate the lake level. The low limit is set for el 74 .37 m (244 f:t) on /l,pril 1 anEl is ffiaintained at or abo*.ie that elevation during the entire navi§ation season (April 1 to ~Joveffiber 30). The upper liffiit of the lake level is el 75.59 ffi (248 .2 ft) (ref. 3).

The low level is based on intake forebay level and corresponds to the minimum intake water level for operability of Emergency Service Water, Emergency Diesel Generator cooling water, Containment Spray Raw Water and Diesel and Electric FIRE Pump (ref. 4-9).

During planned evolutions such as intake water gate manipulation for reverse flow operations in which continuous monitoring of the intake level is being accomplished, entry into this EAL would not be warranted unless UNPLANNED /unexpected conditions and/or indications occur.

UNIT 1 EMERGENCY CLASSIFICATION TECHNICAL BASES EP-AA-1013 Addendum 3 Revision X Page 75 of 246 Attachment 1, Emergency Action Level Technical Bases (Continued)

HU1 .5 Unusual Event (Continued)

Generic This EAL 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 .

This EAL is categorized on the basis of the occurrence of an event of sufficient magnitude to be of concern to plant operators.

This EAL addresses other site specific phenomena that can also be precursors of more serious events.

NMP1 Basis Reference(s):

1. USAR Section 111-F Screenhouse, Intake and Discharge Tunnels

2. USAR Section X-F Service Water System

3. NMP 2 USAR Section 2.4.11.2

4. N1-ARP-H2 Annunciator H2-1-3

5. N1-SOP-18.1 Service Water Failure/Low Intake Level

6. S13.1-100F003

7. S 14-93F003

8. S16.9NPSHAM002

9. Cale No. S14-93-F007

10. NEI 99-01 Revision 6 IC HU3.4 11G. NEI 99-01 IC HU1

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UNIT 2 EMERGENCY CLASSIFICATION TECHNICAL BASES EP-AA-1013 Addendum 4 Revision X Page 81 of 265 Attachment 1, Emergency Action Level Technical Bases {Continued)

Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 1 - Natural or Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting the PROTECTED AREA EAL:

HU1.5 Unusual Event

- - - A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles . Lake water le*1el > 24Q.3 ft OR Intake water level< 237 ft.

Note: A hazardous event does not apply to routine traffic impediments such as fog , snow, ice, or vehicle breakdowns or accidents .

Mode Applicability:

All Basis:

Plant-Specific This threshold addresses a hazardous condition that could impede normal plant staffing ~ and low lake water level conditions that could be a precursor of more serious events .

.+REHllgh lake level is based upon the maxiRu1m attainable uncontrolled lake water level as specified in the USAR DaFRs on tl:le St. Lawrence River, under the authority of tl'le International St. Lawrence River Board of Control, are now used to regulate the lake level. The low limit is set for el 74 .37 FR (244 ft) on April 1 and is maintained at or above tt:iat elevation auring the entire na*1igation season (April 1 to November 30) . The upper liFRit of tho lake level is el 76 .98 m (249.3 ft) (ref. 1 ).

The low level is based on intake water level and corresponds to the design minimum lake level. The probable minimum low water level of Lake Ontario at the site has been determined to be 72.0 m (236.3 ft) resulting from a setdown caused by a Probable Maximum Wind Storm concurrent with the lowest probable lake level. (ref. 2)

Generic This EAL 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 .

UNIT 2 EMERGENCY CLASSIFICATION TECHNICAL BASES EP-AA-1013 Addendum 4 Revision X Page 82 of 265 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.

This EAL is categorized on the basis of the occurrence of an event of sufficient magnitude to be of concern to plant operators.

This EAL addresses other site specific phenomena that can also be precursors of more serious events.

NMP2 Basis Reference(s):

1. USAR Section 2.4.1.2

2. USAR Section 2.4.11 .2

3. N2-0SP-LOG-W001, Weekly Checks

~ . NEI 99-01 Revision 6 IC HU3.4

54. NEI 99-01 IC HU1

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ATTACHMENT 4 Exigent License Amendment Request James A. FitzPatrick (JAF) Nuclear Power Plant NRC Docket No. 50-333 MARKUP OF PROPOSED EMERGENCY ACTION LEVEL PAGES FOR JAF JAF EAL Page 130 131 JAF EAL Matrix Pages IAP-2 Figure IAP-2.1 [Hot]

IAP-2 Figure IAP-2.1 [Cold]

CLASSIFICATION OF EMERGENCY CONDITIONS IAP-2 ATTACHMENT 3 - EAL BASES Category: H - Hazards Subcategory: 1 - Natural & Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting the Protected Area EAL:

HUl.5 Unusual Event A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles. (Note 7)

Lake water level > 249.2 ft OR ESW intake bay water level < 237 ft Note 7: A hazardous event does not apply to routine traffic impediments such as fog. snow. ice, or vehicle breakdowns or accidents.

Mode Applicability:

ALL NEI 99-01 Basis:

This EAL 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, heayy 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.

This EAL is categorized on the basis of the occurrence of an event of sufficient magnitude to be of concern to plant operators.

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

JAFNPP Basis:

Rev. No. 3 54-:A: Page 130 of 313

CLASSIFICATION OF EMERGENCY CONDITIONS IAP-2 ATTACHMENT 3 - EAL BASES The high lake level is based upon the ma:>cimum attainable controlled l ake i:;mter level as specified in the FSAR (ref . 1) . The low level is based on ESW intake bay water level and corresponds to the design minimum lake level (ref. 2).

JAFNPP Basis Reference(s):

1. FSAR Section 2.4.3NEI 99-01 Revision 6 IC HU3.4

2. Safety Evaluation JAF-SE-93-034 "Evaluation of Maximum and Minimum Water Levels at Screenwell for Safe Operation of Class I Equipment" Rev. No. 3 54-A: Page 131 of 313

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ATTACHMENT 5 Exigent License Amendment Request Nine Mile Point (NMP) Units 1 and 2 Revise Emergency Action Level HU1 .5 NRC Docket Nos. 50-220, 50-410 CLEAN EMERGENCY ACTION LEVEL PAGES FOR NMP1 AND 2 NMP1 EAL Page 74 75 NMP1 EAL Matrix Pages 1

2 NMP2 EAL Page 81 82 NMP2 EAL Matrix Pages 1

2

UNIT 1 EMERGENCY CLASSIFICATION TECHNICAL BASES EP-AA-1013 Addendum 3 Revision X Page 7 4 of 246 Attachment 1, Emergency Action Level Technical Bases (Continued)

Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 1 - Natural or Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting the PROTECTED AREA EAL:

HU1.5 Unusual Event A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.

OR Intake water level< 238.8 ft.

Note: A hazardous event does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.

Mode Applicability:

All Basis:

Plant-Specific This threshold addresses a hazardous condition that could impede normal plant staffing and low bay water level conditions that could be a precursor of more serious events (ref. 1, 2).

The low level is based on intake forebay level and corresponds to the minimum intake water level for operability of Emergency Service Water, Emergency Diesel Generator cooling water, Containment Spray Raw Water and Diesel and Electric FIRE Pump (ref. 4-9) .

During planned evolutions such as intake water gate manipulation for reverse flow operations in which continuous monitoring of the intake level is being accomplished, entry into this EAL would not be warranted unless UNPLANNED /unexpected conditions and/or indications occur.

Generic This EAL 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.

UNIT 1 EMERGENCY CLASSIFICATION TECHNICAL BASES EP-AA-1013 Addendum 3 Revision X Page 75 of 246 Attachment 1, Emergency Action Level Technical Bases (Continued)

HU1 .5 Unusual Event (Continued)

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.

This EAL is categorized on the basis of the occurrence of an event of sufficient magnitude to be of concern to plant operators.

This EAL addresses other site specific phenomena that can also be precursors of more serious events.

NMP1 Basis Reference(s):

1. USAR Section 111-F Screenhouse, Intake and Discharge Tunnels

2. USAR Section X-F Service Water System

3. NMP 2 USAR Section 2.4.11.2

4. N1-ARP-H2 Annunciator H2-1-3

5. N1-SOP-18.1 Service Water Failure/Low Intake Level

6. S13.1-100F003

7. S14-93F003

8. S16.9NPSHAM002

9. Cale No. S14-93-F007

10. NEI 99-01 Revision 6 IC HU3.4

11. NEI 99-01 IC HU1

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UNIT 2 EMERGENCY CLASSIFICATION TECHNICAL BASES EP-AA-1013 Addendum 4 Revision X Page 81 of 265 Attachment 1, Emergency Action Level Technical Bases (Continued)

Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 1 - Natural or Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting the PROTECTED AREA EAL:

HU1.5 Unusual Event A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.

OR Intake water level < 237 ft.

Note: A hazardous event does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.

Mode Applicability:

All Basis:

Plant-Specific This threshold addresses a hazardous condition that could impede normal plant staffing and low lake water level conditions that could be a precursor of more serious events.

The low level is based on intake water level and corresponds to the design minimum lake level. The probable minimum low water level of Lake Ontario at the site has been determined to be 72.0 m (236.3 ft) resulting from a setdown caused by a Probable Maximum Wind Storm concurrent with the lowest probable lake level. (ref. 2)

Generic This EAL 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 .

This EAL is categorized on the basis of the occurrence of an event of sufficient magnitude to be of concern to plant operators.

UNIT 2 EMERGENCY CLASSIFICATION TECHNICAL BASES EP-AA-1013 Addendum 4 Revision X Page 82 of 265 This EAL addresses other site specific phenomena that can also be precursors of more serious events.

NMP2 Basis Reference(s):

1. USAR Section 2.4.1.2

2. USAR Section 2.4.11 .2

3. N2-0SP-LOG-W001, Weekly Checks

4. NEI 99-01 Revision 6 IC HU3.4

5. NEI 99-01 IC HU1

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ATTACHMENT 6 Exigent License Amendment Request James A. FitzPatrick (JAF) Nuclear Power Plant NRC Docket No. 50-333 CLEAN EMERGENCY ACTION LEVEL PAGES FOR JAF JAF EAL Pages 126 127 JAF EAL Matrix Pages IAP-2 Figure IAP-2.1 [Hot]

IAP-2 Figure IAP-2.1 [Cold]

CLASSIFICATION OF EMERGENCY CONDITIONS IAP-2 ATTACHMENT 3 - EAL BASES Category: H - Hazards Subcategory: 1 - Natural & Destructive Phenomena Initiating Condition: Natural or destructive phenomena affecting the Protected Area EAL:

HUl.S Unusual Event A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles. (Note 7)

OR ESW intake bay water level < 237 ft Note 7: A hazardous event does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.

Mode Applicability:

ALL NEI 99-01 Basis:

This EAL 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.

This EAL is categorized on the basis of the occurrence of an event of sufficient magnitude to be of concern to plant operators.

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

JAFNPP Basis:

Rev. No. -1.2._ Page 126 of 309

CLASSIFICATION OF EMERGENCY CONDITIONS IAP-2 ATTACHMENT 3 - EAL BASES The low level is based on ESW intake bay water level and corresponds to the design minimum lake level (ref. 2).

JAFNPP Basis Reference(s}:

1. NEI 99-01 Revision 6 IC HU3.4

2. Safety Evaluation JAF-SE-93-034 "Evaluation of Maximum and Minimum Water Levels at Screenwell for Safe Operation of Class I Equipment" Rev. No. --1...2._ Page 127 of 309

~:-::._*":;~;;, GENERAL EMERGENCY ISITE AREA EMERGENcYI ALERT I YNusuAL EVENT ~ ~ENERAL EMERGENCY ISITE AREA EMERGENCY I ALERT I UNUSUAL EVENT

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ATTACHMENT 7 Exigent License Amendment Request Army Corps of Engineers Weekly/Monthly Great Lakes Water Level Update (Two Pages)

Exigent License Amendment Request Army Corps of Engineers Weekly/Monthly Great Lakes Water Level Update Page 1of2 ARMY CORPS OF ENGINEERS WEEKLY GREAT LAKES WATER LEVEL UPDATE May 12, 2017 WEATHER CONDITIONS Precipitation was well above average over Lakes Erie and Ontario at the start of May. Preliminary estimates indicate I that total rainfall over the Lake Ontario basin exceeded the lake's long term average May precipitation after only the first week of the month. Temperatures over the last week were below normal for this time of year. A low pressure system is expected to move up the coast resulting in some rainfall this weekend over parts of the Lake Ontario basin. Over the next 7 days, the forecast calls for up to 1 inch of precipitation across the basin, with highest amounts over eastern Lake Ontario and western Lake Superior. Temperatures are forecast to increase into the weekend, reaching the low 70s in the southern ortions of the basin, continuin into the workweek.

All lakes are at higher levels than one month ago. Lakes Superior and Michigan-Huron have risen 6 inches and Lakes St. Clair and Erie have risen 9 inches. Very wet conditions and large inflow from the Niagara River have contributed to an 18 inch rise over the last 30 days on Lake Ontario. Lake Ontario's projected 12 May level is 28 inches above its level of one year ago. All lakes are above their long term average May levels. Lake Ontario's daily level projected for 12 May is 3 inches above the maximum May monthly mean level; however, it should be noted that daily levels can vary significantly from the monthly mean. Over the next 30 days, Lakes Superior and Michigan-Huron are forecast to continue I their seasonal rise, climbing 3 inches before 12 June. Lake Ontario is forecast to end this 30-day period at 4 inches above the 12 May level. Lakes St. Clair and Erie, on the other hand, are expected to begin their seasonal fall, dropping 1 3 and 2 inches, respectively over the next 30 days. See our Daily Levels web page for more water level information.

FORECASTED MONTHLY OUTFLOWS/CHANNEL CONDITIONS Lake Superior's outflow through the St. Mary's River is projected to be below average in May. Lake Michigan-Huron's outflow into the St. Clair River, and Lake St. Clair's outflow through the Detroit River are predicted to be above average.

Lake Erie's outflow into the Niagara River is forecasted to be above average, and outflow of Lake Ontario into the St.

Lawrence River is projected to be above average for the month of May as well.

ALERTS Official records are based on monthly average water levels and not daily water levels. Users of the Great Lakes, connecting channels and St. Lawrence River should keep informed of current conditions before undertaking any activities that could be affected by changing water levels. Mariners should utilize navigation charts and refer to current water level readings. Ice information can be found at the National Ice Center's website .

SUPERIOR MICH-HURON ST. CLAIR ERIE ONTARIO Forecasted Water Level for May 12, 602.13 580.02 576.41 573.72 248.69 2017 (feet)

Chart Datum (feet) 601.10 577.50 572.30 569.20 243.30 Difference from chart datum

+12 +30 +49 +54 +65 (Inches)

Difference from average water level

+6 +6 +9 +9 +18 for Apr 12, 2017 (Inches*)

Difference from average water level

+1 -1 +7 +8 +28 for May 12, 2016 (Inches*)

Difference from long-term monthly

+7 +12 +22 +22 +31 average of May (Inches)

Difference from highest monthly

-8 -19 -6 -4 +3 average of record for May (Inches)

Year of highest recorded monthly 1986 1986 1986 1986 1973 mean Difference from lowest monthly 30 41 50 56 67 average of record for May (Inches)

Year of lowest recorded monthly 1926 1964 1934 1934 1935 mean Projected change In levels by Jun

+3 +3 -3 -2 +4 12, 2017 (Inches)

ALL DATA SHOWN IN THIS

SUMMARY

ARE REFERENCED TO IGLD 1985

• VALUES FOR SPECIFIC DAY ARE BASED ON 3-DAY DAILY AVERAGE AROUND SPECIFIED DATE LONG TERM AVERAGE PERIOD OF RECORD, 1918-2016 FORECASTED INFORMATION PROVIDED RECORDED DATA (1918-present) FOR MORE INFORMATION VISIT Department of the Army provided by Ds;:trQi! Di~trig §rs:i!t 6i!ks;:~ HQmS:Qi!K!:

Detroit District, Corps of Engineers NQAA, §rs;:2t Li!k!:~ Onlins;: lnt~rnati2n2I Joint Commi~~ion Detroit Distrig H2me (301) 713-9596 §rs;:i!t Laks;:~ lnformj!tion N~tw2rk 1-888-694-8318 ext. 1

Exigent License Amendment Request Anny Corps of Engineers Weakly/Monthly Great Lakes Water Level Update Page 2 of2 LAKE ONTARIO WATER LEVELS - MAY 2017 2015 2016 2017 Ft . MAY JUN JUL AUG SEP OCT NOV DEC JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC JAN FEB MAR APR MAY JUN JUL AUG SEP OCT M.

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