ML15287A284

Fort Calhoun Unit 1, Response to NRC Request for Additional Information Re License Amendment Request to Adopt Emergency Action Level Scheme Per NEI 99-01, Rev. 6 (TAC No. MF5466)

ML15287A284
Person / Time
Site:	Fort Calhoun
Issue date:	09/11/2015
From:	Cortopassi L P Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
LIC-15-0102, TAC MF5466
Download: ML15287A284 (154)

Text

{{#Wiki_filter:OhaPubik Power 444 South 1 6Street Mail Omaha, NE 68 102-2247 LIC-1 5-010O2 September 11, 2015 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station, Unit No. 1 Renewed Facility Operating License No. DPR-40 NRC Docket No. 50-285 Fort Calhoun Station Independent Spent Fuel Storage Installation NRC Docket No. 72-054

Subject:

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

References:

1. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk),"License Amendment Request 14-06 to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors,'

dated December 28, 2Q14 (LI C-14-0098) (ML1 4365A1 23)2. Letter from NRC (C. F. Lyon) to OPPD (L. P. Cortopassi), "Fort Calhoun Station, Unit No. 1 -Request for Additional Information Re: License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEl 99-01, Revision 6 (TAC No. MF5466)," dated July 14, 2015 (NRC-15--061) (ML15194A272) The Omaha Public Power District's (OPPD) response to the NRC request for additional information (RAI) (Reference

2) regarding License Amendment Request (LAR) 14-06 (Reference

1) is attached.

LAR 14-06 proposes to revise the Emergency Plan for Fort Calhoun Station to adopt the Nuclear Energy Institute's (NEI's) revised Emergency Action Level (EAL)scheme described in NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors.OPPD also respectfully requests an implementation date of June 30, 2016 in order to coordinate implementation of the proposed changes with the training cycles currently scheduled for the year.Employment with Equal Opportunity CF~11) 7(Z9L)Fc5 Pr-j)q~sL U. S. Nuclear Regulatory Commission LIC-1 5-0102 Page 2 This letter contains no regulatory commitments. If you should have any questions regarding this submittal or require additional information, please contact Mr. Bill R. Hansher, Principal Regulatory Engineer, at 402-533-6894. Respectfully, , ousP*oroas Site Vice President and CNO LPC/EJ P/mole

Enclosure:

OPPD Response to NRC Request for Additional Information Regarding License Amendment Request (LAR) 14-08 Attachment 1.: Front Matter (Pages FC 3-1 through FC 3-10)Attachment 2: Procedure Matrix (Pages FC 3-11 through FC 3-32)Attachment 3: Radiological Analysis, Methodology for Development of Radiological Effluent Emergency Action Levels RA 13-008 Rev. 1 Attachment 4: Emergency Action Level Thresholds for Liquid Release AA1 (RA1)RP-AA-1010 FC-14-004 Rev, C LIC-15-01 02 Enclosure Page 1 OPPD Response to NRC Request for Additional information Regarding License Amendment Request (LAR) 14-06: Adopt Emergency Action Level Scheme Pursuant to NEI 99-013 Revision 6, Development of Emergency Action Levels for Non-Passive Reactors LIC-1 5-010O2 Enclosure Page 2 REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO ADOPT EMERGENCY ACTION LEVEL SCHEME PURSUANT TO NE1 99-01. REVISION 6 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION, UNIT NO. 1 DOCKET NO. 50-285 By letter dated December 26, 2014, Omaha Public Power District (OPPD, the licensee)requested approval for an emergency action level (EAL) scheme change for the Fort Calhoun Station, Unit 1 (FOS) (Agencywide Documents Access and Management System (ADAMS)*Accession No. ML1 4365A1 23). OPPD proposes to revise its current EAL scheme to one based upon Revision 6 to Nuclear Energy Institute (NEI) document NEi 99-01 , "Development of Emergency Action Levels for Non-Passive Reactors," November 2012 (ADAMS Accession No.ML 12326A805), instead of Revision 5.The requests for additional information (RAts) listed below, in regards to Attachment 2, Enclosure 2C, 'Emergency Action Level Basis Document," of the submittal, are needed to support U.S. Nuclear Regulatory Commission (NRC) staff's continued technical review of the proposed EAL scheme change.FC-RAI-01 Section 4.3, "Instrumentation Used for EALs," to NE! 99-01, Revision 6, states, in part, that: "Scheme developers should ensure that specific values used as EAL setpoints are within the calibrated range of the referenced instrumentation ...." Please confirm that all setpoints and indications used in the FCS EAL scheme are within the calibrated range(s)of the stated instrumentation and that the resolution of the instrumentation is appropriate for the selpoint/indication. FC-RAI-01 Resp~onse Fort Calhoun Station (FCS) has confirmed, through review of design documents, calculations and surveillance tests, that all setpoints and indications used in the FCS EAL scheme are within calibrated ranges of stated instrumentation and that resolution of the instrumentation is appropriate for the setpointlindication. FC-RA!-02 Please provide supporting calculations for all Abnormal Rad Levels I Radiological Effluent threshold values or provide a reference to the ADAMS accession number of the document that contains this information. FC-RAI-02 Response FCS radiological threshold calculations RP-AA-1 010 FC-1 5-003 (RAt 3-008) Rev. 1 and RP-AA-101O FC-14-004 Rev. 0 are provided in this response for review as Attachment 3 and Attachment

4.

LI C-1 5-01 02 Enclosure Page 3 FC-RAI-03 Section 4.6, "Basis Document," to NEt 99-01, Revision 6, states, in part, that: "Because the information in a basis document can affect emergency classification decision-making .."The NR~C staff expects that changes to the basis document will be evaluated in accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR)paragraph 50.54(q), "Emergency Please ensure that appropriate information is incorporated as related to how the technical basis doCUment will be maintained in accordance with 10 CFR 50.54(q).

FC-RAI-03 Response EP-FC-120 Emergency Plan Administration states: 4.1.3 Implementing Procedures, Administrative Procedures, and EP Documents 1. EP document changes shall be revised and processed per Attachment 2, EP Document Structure and Revision Process.2. All document changes will receive a §50.54(q) evaluation per EP-F~C-120-1001.

Attachment 2 states: 2.3 Emergency Plan revision process: 1. Prior to implementation of Emergency Plan revisions PERFORM the following: A. A §50.54(q) evaluation per EP-FG-120-1001. FC-RAI-04 Section 4.7, "EAL/Threshold References to AOP (Abnormal Operating Procedure) and EOP [Emergency Operating Procedure] Setpoints/Criteria," to NEI 99-01, Revision 6, states, in part, that: "As reflected in the generic guidance, the criteria/values used in several EALs and fission product barrier thresholds may be drawn from a plant's AOPs and EOPs," The NRC staff expects that changes to AOPs and EOPs will be evaluated in accordance with the provisions of 10 CFR 50.54(q). Please ensure that verify that appropriate information is incorporated that ensures changes to AOPs or EOPs are screened to determine if an evaluation pursuant to 10 CFR 50.54(q) is required, FC-RAIo04 Response All EOP/AOP changes are required to be verified by the EOPIAOP Coordinator using the Verification Review Checklist (SO-G-74, Attachment 1). The checklist asks the following question: Is EOP/AOP change free of modifications, additions and deletions of any conditions in an emergency action level (EAL) indicator or basis? "No" response requires 50.54(q) evaluation by Emergency Preparedness. AOP-O1 Acts of Nature and AOP.07 Evacuation of Control Room are required to have Emergency Preparedness review.FC-RAI-05 Section 4.6, "Basis Document," to NEI 99-01, Revision 6, states, in part, that: "A basis document is an integral part of an emergency classification scheme. The material in this document supports proper emergency classification decision-making by providing informing background and development information in a readily accessible format. It can be referred to in training situations and when making an actual emergency LIC-1 5-0102 Enclosure " Page 4 classification, if necessary.' Emergency Planning implementing Procedure EPIP-OSC-1,"Emergency Classification," was provided for the NRC staff's review as part of the previous NEI 99-01, Revision 5 conversion request dated August 15, 2008 (ADAMS Accession No. ML082320484). Please provide a similar document that includes the addresses the following information:

• A "Purpose" section that reflects the intent of the EAL Basis Document, as provided in NEI 99-01, Revision 6;* A site-specific Definition/Acronyms section that provides information consistent with NEI 99-01, Revision 6, Appendices A and B;* An Operating Mode Applicability section that provides information consistent with NEl 99-01 , Revision 6, Section 3.5;* An implementation guidance section that provides information consistent with NEt 99-01, Revision 6, Section 5; and* A copy of the FCS classification aid used to facilitate event classifications, which is typically referred to as a "Wallboard." FC-RAI-05 Response The above is provided in this response for review as Attachment 1 =Front Matter'~ and as Attachment 2 "Procedure Matrix" job aide.FC-RAI-06 For Initiating Condition (IC) RG1, radiation monitor (RM)-064 was removed from Table RI.RM-064 is included in the currently approved AG1 EAL (ADAMS Accession No.ML13358A327).

A justification for the removal of RM-064 was not provided in Attachment 2, Enclosure 2A, "EAL Comparison Matrix Document." Please provide justification for the removal of RM-064 from the RGI.FC-RAI-06 Response Upon further review FOS has decided to maintain the RM-064 Post Accident Main Steam (Gas)monitor in the RG1 EAL Scheme.FC-RAI-07 For IC RS1, Table R1 has monitors RM-063, RM-052, and RM-043 listed. IC AS1, in Revision 2a of TBD-EPIP-OSC-1A dated December 11, 2013 (ADAMS Accession No. ML 13358A327), and the Revision 5 conversion request dated August 15, 2008, has RM-064 listed in addition to RM-063, but does not include RM-052 and RM-043. These changes are not identified in the Attachment 2, Enclosure 2A, "EAL Comparison Matrix Document." Please provide justification for the removal of monitor RM-064 and the addition of RM-052 and RM-043 to the EAL.FC-RAI-07 Response Upon further review FCS has decided to maintain the RM-064 Post Accident Main Steam (Gas)monitor in the RS1 EAL Scheme. SLIC-15-0102 Enclosure Page 5 The following has been added to the RS1 Comparison Matrix justification column to justify the addition of RM-052 and RM-043 rad monitors to the RSI threshold.

• -*RM-052 and RM-043 were added as they are typical radiological effluent pathway monitors with ranges that c~an detect EAL thresholds at RS1 levels as calculated by site calculation RP-AA-1 010 PC-I15-003 (RA 13-008) Rev. I included in this response as Attachment 3,..FC-RAI-08 For Its RAl and RUl, the RM-057 value for an Alert classification is 1 .79E+08 counts per minute (cpm), while the RM-057 value for an Unusual Event classification is a higher value of 8.82E+08 cpm. Additionally, a note for IC RU1 Table fl3, "Effluent Monitor Thresholds," provides that "1.45E+-08

[cpm] as the upper range of the instrument." Both of these values are above the upper range of the instrument. Please verify that the provided RM-057 values are within the calibrated range of the instrumentation or revise accordingly. PC-RAI-08 Response A review and recalculation of thresholds for RM-057 has resolved the issue with instrument overange, the upper indication of the instrument has been verified to be 1.45 E+08 cpm, the revised values are within this upper indication and have been used to update RAl and RU I thresholds with respect to RM-057. The revised calculation is contained in RP-AA-l1010 FC-1 5-003 (RA 13-008) Rev. 1.FC-RAI-09 For ICe RAl and RU1, Table Rl, "Effluent Monitor Thresholds for Alert Classification," provides values for RM-043, RM-052, and RM-062 that are not significantly higher than the values provided by Table R3, "Effluent Monitor Thresholds for Unusual Event Classification." Please validate all RA1 and RUl threshold values and revise accordingly. This validation should include verification of appropriate separation between Unusual Event, Alert, Site Area Emergency, and General Emergency declarations. FC-RAI-09 Response A review and recalculation of thresholds for RUl and RA1 using the same isotopic mixture for both initiating conditions has resolved the issue with classification escalation, the revised values provide for proper progression between RU1 and RAI and have been used to update RIA1 and RUl. The revised calculation is contained in RP-AA-1010 FC-15-.003 (RA 13-008) Rev. 1.FC-RAJ-1 0 For IC RUI, the proposed EAL 1 uses Table 2, "Effluent Monitor Thresholds," which provides "2X High Alarm set point" as threshold values. Additionally, the proposed EAL 2 uses Table R3, "Effluent Monitor Thresholds," as threshold values. As provided, Table R2 is a subset of Table R3 with Iwo exceptions. T"he exceptions are the thresholds for LIC-1 5-0102 Enclosure Page 6 RM-052 and RM-062 on Table R3, which are significantly higher than the threshold values for RM-052 and RM-062 on Table R2.a. Please justify using two tables that use different values to perform classifications for RU1 or revise accordingly.

b. Please explain the significant difference in the Table R2 and Table R3 threshold values for RM-052 and RM-062, or revise accordingly.

FC-RAI-10 Response Upon review the following changes were made to Table R2 and R3.1. RUI EAL 1 contains effluent monitors that monitor non-continuous batch releases covered by discharge permits at FOS, the applicable effluent monitors are contained within the provided revised Table R2.2. Radiation monitors RM-052 and 62, depending on which may be aligned to the building exhaust stack, are only contained in the revised Table R3. Although these monitors may be used as the Waste Gas Decay Tank Release monitor for batch gas releases they are also the gaseous effluent monitors used for the continuous auxiliary building exhaust stack release, as such the RUl EAL 2 threshold in the revised Table R3 bounds both conditions.

3. RUl EAL 2 contains continuous release .path effluent monitors, the applicable effluent monitors are contained within the provided revised Table R3.FC-RAI-,11 For IC RUI, Table R3 is used to assess EAL #2, which includes both liquid and gaseous radioactivity radiation monitors.

However, the RU1 basis discussion for EAL #2 only discusses gaseous radioactivity releases. Please explain why EAL #2 Basis discussion excludes liquid radioactivity releases.FC-RAI-1 1 Response This has been corrected, RUt EAL #2 basis discussion now addresses both gaseous and liquid radioactivity releases.FC-RAI-1 2 For IC RUl, Table R3 in Attachment 2, Enclosure 2C, "EAL Basis Document,' is different than Table R3 in the Attachment 2, Enclosure 2A, "EAL Comparison Matrix Document"; specifically:

• RM-043, RM-052, RM-062, and RM-057 have different values between the two tables; and*RM-063 is included in Table R3 in the Attachment 2, Enclosure 2A, "EAL Comparison Matrix Document," and Table R3 in Attachment 2, Enclosure 2B, "EAL Red-Line Basis Document, but is not included in Table R3 of EAL RU1 of Attachment 2,, Enclosure 2C, "EAL Basis Document."

LIC-15-0 102 Enclosure Page 7 Please explain the apparent inconsistencies between Attachment 2, Enclosures 2A, 2B, and 2C, or revise accordingly. FC-RlAI-1 2 Response A review has been performed on all attached documents for agreement between RUl Tables R2 and R3 and they have been revised to agree between all of the documents. FC-RAI-1 3 The deviation for the wording in IC RU1 EAL 3 was not justified in the submittal. The addition of "Confirmed" pertains to the timeliness of EAL classification. Please provide justification for this deviation, or revise accordingly consistent with NRC-endorsed guidance.FC-RAI-13 Response Agree, the word "Confirmed" has been removed from IC RU1 EAL 3.FC-RAI-1 4 For lCs RA2, RS2, and RG2, the proposed EALs do not reflect enhanced spent fuel pool level instrumentation. Please provide EALs reflecting the planned installation of enhanced spent fuel pool level instrumentation for NRC pre-approval, or provide justification for not including at this time.FC-RAI-14 Response Revised the sites proposed EALs to contain the associated RG2, RS2 and additional RA2 threshold related to the enhanced SFP level indicators being installed per NRC Order- EA-12-051. These EALs will be incorporated into the site's EAts when the enhanced spent fuel pool level instrumentation is available for use, in accordance with the discussion in Section 1.4, NRC Order EA-1 2-051.FC-RAI-1 5 For IC RU2, the proposed EALs do not include site-specific refueling pathway level indications per NEK 99-01, Revision 6. Please provide site-specific level indications for RU2 that could be used to support timely and accurate assessments, including applicable mode availability for level instrumentation. FC-RAI-15 Response Agree, the applicable refueling pathway instrumentation has been added to EAL RU2.FC-RAI-1 6 For IC RA2, the proposed Basis discussion does not include the NEI 99-01, Revision 6, EAL AA2 guidance stating: "This IC applies to irradiated fuel that is licensed for dry storage up to the point that the loaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss of the CONFINEMENT BOUNDARY is classified in accordance LIC-1 5-0102 Enclosure Page 8 with IC E-HUI." Please justify excluding theNEi 99-01, Revision 8, EAL AA2 guidance that relates to RA2 applicability, or revise accordingly. FC-RAI-1 6 Response Agree, the paragraph has been irncluded in EAL RA2 basis discussion as follows: "This IC applies to irradiated fuel that is licensed for dry storage up to the point that the loaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss of the CONFINEMENT BOUNDARY is classified in accordance with IC E-HU1Y.FC-RAI-1 7 Please provide verification that the areas identified for IC RA3 reflect only those areas required for normal plant operations, cooldown or shutdown, or revise as necessary to support accurate and timely assessment. In addition, the note for the RA3 EAL references Table R4 versus Table R7. Please verify which table should be referenced, and revise accordingly. FC-RAI-1 7 Response A) Amended the sites mode dependent areas Table in RAS to ensure that the stated areas are limited to those where access is required to operate equipment necessary for normal operations, safe shutdown, and cooldown. Areas that do not contain equipment requiring local operation are no longer reflected in these Tables.B) Added the following highlighted words to the RA3 basis section to ensure that the EAL Basis reflects that equipment for normal operation, safe shutdown, and cooldown is the concern of the EAL.uAssuming all plant equipment is operating as designed, normal operation is capable from the Main Control Room (MCR). The plant is also able to transition Into a hot shutdown condition from the MCR. therefore Table R6 is a list of plant rooms or areas with entry-related mode applicability that contain equipment which require a manuaL/local action necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal operating procedures (establish shutdown cooling), where if this action is not completed the plant would not be able to attain and maintain cold shutdown." C) The note for the RA3 EAL now references the correct Table number reference. FC-RAI-1 8 For IC FRU3, please provide justification for including the statement:" ... as determined by laboratory confirmation ... "in the plant-specific basis for declaration of an Unusual Event with elevated coolant activity, or revise accordingly consistent with NRC-endorsed guidance, as this could impact the timeliness of the assessment. LIC-1 5-0102 Enclosure Page 9 FC-RAI-18 Response Agree, the following paragraph has been removed from RU3.*"An Unusual Event is only warranted when actual fuel clad damage is the cause of the elevated coolant sample activity (as determined by laboratory cornlirmatlon). Fuel clad damage should be assumed to be the cause of elevated Reactor Coolant activity unless another cause is known," FC-RAl-i 9 Address the following under IC RC1, Potential Loss: a. The proposed Fission Product Barrier (FPB) Threshold Potential Loss 2 does not reflect steam generator tube leakage, which could impact the ability to perform accurate and timely assessments. Please provide justification for this deviation, or revise accordingly consistent with NRC-endorsed guidance.b. The proposed FPB Threshold Potential Loss 2 deviates from NRC-endorsed guidance in that, "Operation of a standby charging (makeup) pump is required." The licensee proposes the following wording: "> the capacity of one charging pump in the normal mode (greater than 40 gpm [gallons per minute])." Please provide justification for this change, or revise accordingly, as it could imply that operators must determine an actual leak rate of 40 gpm or greater rather than determine that a second charging pump is required due to either an unisolable reactor coolant system (RCS) leak or steam generator tube leakage.c. The proposed FPB Threshold Potential Loss 3 is related to a heat removal challenge and not "UNISOLABLE RCS leakage." Please provide further justification for this deviation, or revise consistent with NRC-endorsed guidance.FC-RAI-19 Response a. Agree, S/G tube leakage is now reflected in RC! Potential Loss threshold

1. 2.b. The following justification has been added to the Comparison Matrix: The words "> the capacity of one charging pump in the normal mode (greater than 40 gpm)" is used since this would beathe earliest time that an additional charging pump could be aligned and discriminates the use Of reduced letdown flow (non-normal mode) to allow for a net increased capacity of a single charging pump as allowing continued operation without EAL declaration.

c. Agree, removed Potential Loss 3 from the RCS /S/G tube leakage sub category for RCS loss.FC-RAI-20 For CT!, the proposed FPB Threshold Loss 1 deviates from NRC-endorsed guidance that, "A leaking or RUPTURED SG [steam generator) is FAULTED outside of containment." The licensee proposes the following wording: "> the capacity of one charging pump in the normal mode (greater than 40 gpm)." Please provide justification for this deviation, or revise consistent with NRC-endorsed guidance, as it implies that operators must determine an actual leak rate of 40 gpm or greater rather than determine that a second charging pump is required for a steam generator tube leak.

L C_-1 15-0102 Enclosure Page 10 FC-RAI-20 Response Agree, revised the wording to UA leaking or RUPTURED SG is FAULTED outside of containment" to be consistent with the endorsed guidance.FC-RAI-21 For CT2, FPB Threshold Potential Loss la. threshold is provided as Tclad > 1550 degrees. Please verify that Tclad can be determined by the operators in a timely manner, or revise accordingly. FC-RAl-21 Response Reviewed and revised to Core Exit Thermocouples, not T clad.FC-RAI-22 For CT4, FPB Threshold Potential Loss 3 includes "and rising." This deviation could impact the timeliness and accuracy of classification. Provide justification for this deviation, or revise accordingly consistent with NRC-endorsed guidance.FC-RAI-22 Response The following justification was added to the comparison matrix:=Adde "and rising" to Potential Loss #3 to distinguish the transient condition where Containment Pressure may have exceeded the design pressure momentarily on a transient but due to containment safety equipment is now being reduced to below the design pressure, this type of condition would not be a potential threat to containment. Whereas exceeding design pressure with an increasing trend would pose a threat to containment." FC-RAI-23 For CT4, FPB Threshold Potential Loss 5 does not include a 15 minute criteria for less than one train of containment spray. Provide additional justification for this deviation or revise accordingly consistent with NRC-endorsed guidance.Fc-RAI-23 Response Agree, "per design for > 15 minutes" has been added to CT4 Potential Loss Threshold

1. 5.FC-RAI-24 For ICs MU3, MA3, and MS3, please justify why the words: "... as indicated by reactor power > 2%," were added to the EALs, or revise accordingly.

Relying solely on a reactor power level of 2 percent is not consistent with EOP criteria as provided by NEt 99-01, Revision 6. LIC-1 5-0102 Enclosure Page 11 FC-RAI-24 Response Revised to add T=and SUR is negative" to the existing reactor power indication to be consistent with guidance provided in EOPs.FC-RAI-25 For IC MA3, please explain why "or manual" was not included in the third paragraph of the Basis discussion when the EAL includes both automatic and manual trips, or revise accordingly. FC-RAI-25 Response Agree, "or manual" has been included in the 3rd paragraph of the Basis discussion. FC-RAI-26 For IC MA4, under Table M2, "Significant Transients," please explain the following or revise accordingly:

a. Why the proposed Table M2 includes "ECCS [Emergency Core Cooling System)Actuationer oscillations

> 10%" versus "ECCS Actuation," as provided by NEi 99-01, Revision 6 and Attachment 2, Enclosure 2A, "EAL Comparison Matrix Document"?

b. Why the proposed Table M2 does not include a manual runback of greater than 25 percent?FC-RAI-26 Response a. Agree and proposed Table M2 corrected to stale "ECCS ActuationD on all enclosures.

b. FCS is not equipped with automatic or manual runback capability.

FC-RAI-27 For IC CU4, please explain why EAL #2 Basis does not include a procedure number, or revise accordingly. FC-RAI-27 Response Agree and procedure number FC-1 188, Event Notification Form, has been added to the basis for CU4 EAL #2.FC-RAI-28 For IC CU5, please explain how the addition of ".... due to the loss of decay heat removal..." to EAL 1 would not result in potential misclassification for an event other than a loss of decay heat removal that leads to an unplanned RCS temperature and/or RCS/reactor pressure vessel (RPV) pressure to rise. Please provide justification, or revise accordingly consistent with NRC-endorsed guidance. LIC-1 5-0102 Enclosure Page 12 FC-RAI-28 Response Agree, the following has been removed from GU5 EAL =. ..due to loss of decay heat removal" And Added the following Note to CU5 to allow for quick reference by the SM / EDO since it will show on the 1 1x17 Procedure Matrix EALs: S"A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when heat removal function is available does not warrant classification" FC-RAI-29 For IC CA5, please explain how the addition of "... due to the loss of decay heat removal ..." to EAL 1 and, "... as a result of temperature rise due to loss of heat removal..." to EAL 2, would not result in potential misclassification for an event other than a loss of decay heat removal that leads to an unplanned RCS temperature and/or RCS/RPV pressure to rise. Please provide justification, or revise accordingly consistent with NRC-endorsed guidance.FC-RAI-29 Response Agree, the following has been removed from CA5 EAL "...due to loss of decay heat removal".And Added the following Note to GA5 to allow for quick reference by the SM / EDO since it will show on the 1lx1 7 Procedure Matrix EALs:* 'A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when heat removal function is available does not warrant classification" FC-RAI-30 For IC CG6, no justification is provided for the difference between the pr;oposed EAL and the guidance of NEi 99-01 Revision 6. Specifically, the endorsed guidance has two EAI~s, whereas the licensee proposes three EALs. [Note: The major difference is the numbering scheme and not the actual content of the EALs.] This change introduces a potentially different logic methodology, which could impact timeliness and accuracy of assessments. Please provide justification that the proposed changes will not impact the timeliness or accuracy of assessment, or revise accordingly consistent with NRC-endorsed guidance.FC-RAI-3D Response Agree and this has been corrected. The EAL now contains EAL 1 and EAL 2 a., b. (with three bullets under it), and c. This coincides with the endorsed NEI 99-01 Rev. 6 CG1 IC. No content has changed. LIC-1 5-0102 Enclosure Page 13 FC-RAI-31 For ICs CU6, CA6, CS6, and CG6, please provide further justification as to why the EALs for Reactor Vessel/Reactor Pressure Vessel Level are not in accordance with the guidance in NEI 99-01, Revision 6, or revise accordingly. The RCS level criterion was changed from "cannot be monitored" to "unknown". This change could impact the start time from the moment when the indication is lost to a judgment as to when RCS level becomes "unknown," which could impact the timeliness of the assessment. FC-RAI-31 Response Agree, wording returned to "cannot be monitored." FC-RAI-32 For IC CS6, please provide verification that FCS has both a Reactor Vessel Level Measurement System (RVLMS), as indicated in EAL #1, and a Reactor Vessel Level Indicating System (RVLIS), as indicated in EAL #2, or revise accordingly. FC-RAI-32 Response Agree, corrected to reflect the FCS RVLMS only.FC-RAI-33 For IC CA6, the Basis for EAL #1 provides "water level below 0 inches on Draindown Level indicator" as an indication that operator actions have not been successful in restoring and maintaining RCS level. Please explain why the basis for EAL #1 refers to a Draindown level indicator, when EAL #1 refers to an RVLMS level, or revise accordingly. FC-RAI-33 Response Agree, CA6 Basis for EAL #1 corrected to reflect 14% RVLMS and now agrees with EAL #1.FC-RAI-34 For IC HG1, the NRC staff is not clear of the intent of the last sentence in the Basis which states: "contained in non-public documents such as the Security Plan." Please revise accordingly to clarify.FC-RAI-34 Response Agree, this sentence has been removed from HGt Basis.FC-RAI-35 For IC HUJ3, the proposed EALs appear to cover a wider range than required by Appendix R. Please provide verification that the areas identified for this EAL are consistent with Appendix R guidance, or revise as necessary to support accurate and timely assessment. LIC-15-0 102 Enclosure Page 14 FC-RAI-35 Response Agree, the table has been reviewed against the Appendix R guidance as well as the NFPA 805 analysis and has been revised to agree with this guidance.FC-RAI-36 For IC HU3, please provide justification for deviation in excluding a fire within the independent spent fuel storage installation, or revise accordingly consistent with NRC-endorsed guidance.FC-RAI-36 Response The Comparison matrix for HU3 now reflects the fact that the ISFSI is within the plant PROTECTED AREA and as such is not specifically contained within EAL #3 and #4.And The following sentence has been added to the basis section of HU3.*"ISFSI is not specifically addressed in EAL #3 and #4 since it is within the plant PROTECTED AREA." FC-RAI-37 For IC H4U4, please verify that the "Strong Motion Seismic Event in Progress" alarm and the event indicator (SMA Control Panel) of an Operating Basis Earthquake are indicated in the Control Room.FC-RAI-37 Response Verified and stated the alarm and event indicator indicate in the Control Room, this information is listed in the comparison matrix under the H-fU4 justifitation column.FC-RAI-38 For IC HA5, please verify the areas identified for this EAL were developed in accordance with the NRC-endorsed guidance and reflect only those areas required for normal plant operations, cooldown or shutdown.FC-RAI-38 Response A) Amended the sites mode dependent areas Table in HA5 to ensure that the stated areas are limited to those where access is required to operate equipment necessary for normal operations, safe shutdown, and cooldown. Areas that do not contain equipment requiring local operation are no longer reflected in these Tables.B) Added the following highlighted words to HA5 basis section to ensure that the EAL Basis reflects that equipment for normal operation, safe shutdown, and cooldown is the concern of the EAL. LIC-1 5-0102 Enclosure Page 15"Assuming all plant equipment is operating as designed, normal operation is capable from the Main Control Room (MCR). The plant is also able to transition into a hot shutdown condition from the MCR, therefore Table H3 is a list of plant rooms or areas with entry-related mode applicability that contain equipment which require a manual/local action necessary to transition the plant from normal plant operation to cooldown and shu~tdown as specified in normal operating procedures (establish shutdown cooling), where if this action is not completed the plant would not be able to attain and maintain cold shutdown." FC-RAI-39 For IC HU6, the EAL #2 Basis discussion on "Manual isolation of power to ..." appears to contradict the information in EAL #2 and is not in accordance with NRC-endorsed guidance. Please provide clarification, or revise accordingly. FC-RAI-39 Response Agree, removed the following from HU6 EAL #2 basis information:

• 1 Manual isolation of power to a SAFETY SYSTEM component as a result of leakage is an event of lesser impact and would be expected to cause small and localized damage. The consequence of this type of event is adequately assessed and addressed in accordance with Technical Specifications."

LIC-1 5-01 02 Enclosure, Attachment 1 Front Matter (Pages FC 3-1 through FC 3-10O)

Ft (P.Ilhm:n PHhl]r I LI I IIlillll8 l imflUbl Irk Section 3: Classification of Emergencies

3.1 General

Section D of the Omaha Public Power District (OPPD) Radiological Emergency Response Plan divides the types of emergencies into four EMERGENCY CLASSIFICATION LEVELS (ECLs). The first four are the UNUSUAL EVENT (UE), ALERT, SITE AREA EMERGENCY (SAE), and GENERAL EMERGENCY (GE). These ECLs are entered by satisfying the Initiating .Condition (IC) through meeting an Emergency Action Level (EAL) of the IC provided in this section of the Annex. The ECLs are escalated from least severe to most severe according to relative threat to the health and safety of the public and emergency workers.UNUSUAL EVENT (UE): Events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.ALERT: Events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.SITE AREA EMERGENCY (SAE): Events are in progress or have occurred which involve an actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; 1) toward site personnel or equipment that could lead to the likely failure of or; 2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.GENERAL EMERGENCY (GE): Events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for, loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.Month 20xx FC 3-1 Mont 2Ox FC3-1EP-XX-XXXX (Revision xx) Ft_ Public Power F l C~lalhnru 5 flms hsi ...................... r~EMERGENCY CLASSIFICATION LEVEL (ECL): One of a set of names or titles established by the US Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to (1) potential or actual effects or consequences, and (2) onsite and offsite response actions. The emergency classification levels, in ascending order of severity, are:* UNUSUAL EVENT (UE)*] ALERT* SITE AREA EMERGENCY (SAE)*] GENERAL EMERGENCY (GE)INITIiATING CONDITION IC):An event or condition that aligns with the definition of one of the four EMERGENCY CLASSIFICATION LEVELS by virtue of the potential or actual effects or consequences. EMERGENCY ACTION LEVEL (EAL)I: A pre-determined, site-specific, observable threshold for an INITIATING CONDITION that, when met or exceeded, places the plant in a given EMERGENCY CLASSIFICATION LEVEL.An emergency is classified by assessing plant conditions .and comparing abnormal conditions to ICs and EALs, based on the designated Operational Condition (MODE). Modes 1 through 5 are defined in the Technical Specifications (T.S). "Defueled" Mode (D) was established for classification purposes to reflect conditions where all fuel has been removed from the Reactor Pressure Vessel.FCS does not use Standard Technical Specifications for CE PWRs. FCS does not use an operating mode for plant conditions with the reactor subcritical, Tcold greater than or equal to 210 °F, and Tavg less than or equal to 515°F, the only difference between FCS Modes 4 and 5 is the reactor coolant boron concentration, and FCS does not have a defueled mode. To ensure the intent of the NEI 99-01 scheme is met, the following stipulation is added that states: "Unless specific criteria are identified in the "Applicable Modes" section of an EAL, the plant shall always assume to be in the higher Operating Mode (numerically lower) during transitions between modes for the purposes of Emergency Classification (i.e., if Tcold is 246°F, the plant is considered to be in Operating Mode 3 if no temperatures are specified)." Month 20xx FC 3-2 Mont 20x FC3-2EP-XX-XXXX (Revision xx) Ft. Calhoun Station Ft. alhon SttionOmaha Public Power District Equivalent Plant Technical Specification Operating Mode Applicability to NEI 99 01 NEI 99 01 PWR Operating Modes FCS Technical Specification Operating Modes Power Operation (1): Reactor Power >5%, Power Operation Condition (Operating Mode 1): Keff>- 0.99 The reactor is in the power operation condition when it is critical and the neutron flux power range instrumentation indicates greater than 2% of rated power.Startup (2): Reactor Power s5%, Keff_> 0.99 Hot Standby Condition (Operating Mode 2): The reactor is considered to be in a hot standby condition if the average temperature of the reactor coolant (TIavg) is greater than 515 °F, the reactor is critical, and the neutron flux power range instrumentation indicates less than 2% of rated power.Hot Standby (3): RCS >_ 350 'F, Keff < 0.99 Hot Shutdown Condition (Operating Mode 3): The reactor is in a hot shutdown condition if the average temperature of the reactor coolant (Tay 9) is greater than 515 °F and the reactor is subcritical by at least the amount defined in Paragraph 2.10.2.Hot Shutdown (4): 200 'F <RCS <350 'F, .None :+~; ; ~'.I:....' ..i Keff < 0.99 Cold Shutdown (5): RCS<200 'F, Keff<O.99 Cold Shutdown Condition (Operating Mode 4): The reactor coolant Toold is less than 210'F and the reactor coolant is >SHUTDOWN BORON CONCENTRATION but <REFUELING BORON CONCENTRATION. Refueling (6): One or more vessel head closure Refueling Shutdown Condition (Operating Mode 5): bolts less than fully tensioned The reactor coolant T,-ofd is less than 210 'F and the reactor coolant is REFUELING BORON CONCENTRATION. reactor pressur evessel. (Full c°oreooad during ! }:'i: l refueling or extended outage) ..... ! !.: i. Hot Matrix -applies in FCS modes (1), (2), (3)Cold Matrix -applies in FCS modes (4), (5), and (D)Month FC 3-3 Mont 2Ox FC3-3EP-XX-XXXX (Revision xx) Am ~ Dm.kIis. Dr~~Ae1a. fltalvii-t

• S WL I *r. U i .&ahll 1*. CUllAlJ
• 1.I5.**lq.

U U1 f1 I5./OLIl11.4 Individuals responsible for the classification of events will refer to the Initiating Condition and EALs on the matrix of this document. This matrix will contain l~s, EALs, Mode Applicability Designators, appropriate EAL numbering system, and additional guidance necessary to classify events, it may be provided as a user aid.The matrix is set up in six Recognition Categories. The first is designated as "R" and relates to Abnormal Radiological Conditions / Abnormal Radiological Effluent Releases. The Second is designated as "F" and relates to Fission Product Barrier Degradation. The third is designated as "M" and relates to hot condition System Malfunctions. The fourth is designated as "CU and relates to Cold Shutdown /Refueling System Malfunctions. The fifth is designated as "H" and relates to Hazards and Other Conditions Affecting Plant Safety. The sixth is designated "E-H" and relates to ISFSI Malfunctions. The matrix is designed to provide an evaluation of the Initiating Conditions from the worst conditions (General Emergencies) on the left to the relatively less severe conditions on the right (Unusual Events). Evaluating conditions from left to right will reduce the possibility that an event will be under classified. All Recognition Categories should be reviewed for applicability prior to classification. The Initiating Conditions are coded with a two letter and one number code. The first letter is the Recognition Category designator, the second letter is the Classification Level, "Un for (NOTIFICATION OF) UNUSUAL EVENT, UA"~ for ALERT, "S"I for SiTE AREA EMERGENCY and "G" for GENERAL EMERGENCY. The EAL number is a sequential number for that Recognition Category series. All ICs that are describing the severity of a common condition (series) will have the same number.The EAL number may then be used to reference a corresponding page(s), which provides the basis information pertaining to the IC:EAL ,, Mode ApplicabilityBasis Classification is not to be made without referencing, comparing and satisfying the specified Emergency Action Levels.A list of definitions is provided as part of this document for terms having specific meaning to the EALs.References are also included to documents that were used to develop the EALs.Month 20xx FC 3-4 Mont 2Ox FC3-4EP-XX-XXXX (Revision xx) Ft. Calhoun Station Omaha Public Power District References to the Emergency Director means the person in Command and Control as defined in the Emergency Plan. Classification of emergencies is a non-delegable responsibility of Command and Control with responsibility assigned to the Shift Manager (Main Control Room), the Control Room Coordinator (Main Control Room), the TSC Site Director (Technical Support Center), or the EOF Emergency Director (Emergency Operations Facility). Although the majority of the EALs provide very specific thresholds, the Emergency Director must remain alert to events or conditions that lead to the conclusion that exceeding the EAL is IMMINENT. If, in the judgment of the Emergency Director, an IMMINENT situation is at hand, the classification should be made as if the EAL has been exceeded. While this is particularly prudent at the higher ECL (as the early classification may provide for more effective implementation of protective measures), it is nonetheless applicable to all ECLs.3.2 Classification, Instrumentation and Transient Events All classifications are to be based upon valid indications, reports or conditions. Indications, reports or conditions are considered valid when they are verified by (1) an instrument channel check, or (2) indications on related or redundant indications, or (3) by direct observation by plant personnel, such that doubt related to the indication's operability, the condition's existence, or the report's accuracy is removed. Implicit in this is the need for timely assessment. Indications used for monitoring and evaluation of plant conditions include the normally used instrumentation, backup or redundant instrumentation, and the use of other parameters that provide information that supports determination if an EAL has been reached. When an EAL refers to a specific instrument or indication that is determined to be inaccurate or unavailable, then alternate indications shall be used to monitor the specified condition. During an event that results in changing parameters trending towards an EAL classification, and instrumentation that was available to monitor this parameter becomes unavailable or the parameter goes off scale, the parameter should be assumed to have been exceeded consistent with the trend and the classification made if there are no other direct or indirect means available to determine if the EAL has not been exceeded.The assessment of some EALs is based on the results of analyses that are necessary to ascertain whether a specific EAL has been exceeded (e.g., dose assessments, chemistry sampling, ROS leak rate calculation, etc.); the EAL andlor the associated basis discussion will identify the necessary analysis. In these cases, the 15-minute declaration period starts with the availability of the analysis results that show the EAL to be exceeded (i.e., this is the time that the EAL information is first available). Month 20xx FC 3-5 Mont 2Ox FC3-5EP-XX-XXXX (Revision xx) Ft. Calhoun Station Ft. alhon SttionOmaha Public Power District Planned evolutions involve preplanning to address the limitations imposed by the condition, the performance of required surveillance testing, and the implementation of specific controls prior to knowingly entering the condition in accordance with the specific requirements of the site's Technical Specifications. Activities which cause the site to operate beyond that allowed by the site's Technical Specifications, planned or unplanned, may result in an EAL being met or exceeded. Planned evolutions to test, manipulate, repair, perform maintenance or modifications to systems and equipment that result in an EAL being met or exceeded are not subject to classification and activation requirements as long as the evolution proceeds as planned and is within the operational limitations imposed by the specific operating ticense. However, these conditions may be subject to the reporting requirements of 10 CFR 50.72.When two or more EAts are determined, declaration will be made on the highest classification level.Concerning ECL Downgrading, OPPD Nuclear policy is that ECts shall no_.t be downgraded to a lower classification. Once declared, the event shall remain in effect until no Classification is warranted. There may be cases in which a plant condition that exceeded an EAL was not recognized at the time of occurrence but is identified well after the condition has occurred (e.g., as a result of routine log or record review), and the condition no longer exists. tn these cases, an emergency Should not be declared. Reporting requirements of 10 CFR 50.72 are applicable, the guidance of NUREG-1022, Event Reporting Guidelines 10 CFR 50.72 and 50.73 and the Reportability Reference Manual, should be applied.3.3 Mode Applicability The plant-operating mode that existed at the time that the event occurred, prior to any protective system or operator action initiated in response to the condition, is compared to the mode applicability of the EALs. If an event occurs, and a lower or higher plant-operating mode is reached before the emergency classification can be made, the declaration shall be based on the mode that existed at the time the event occurred.For events that occur in Cold Shutdown or Refueling, escalation is via EALs that have Cold Shutdown or Refueling for mode applicability, even if Hot Shutdown (or a higher mode) is entered during any subsequent heat-up. In particular, the Fission Product Barrier Matrix EALs are applicable only to events that initiate in Hot Shutdown or higher.If there is a change in Mode following an event declaration, any subsequent events involving EAts outside of the current declaration escalation path will be evaluated on the Mode of the plant at the time the subsequent events occur.Month 20xx FC 3-6 Month2Oxx C 3-6EP-XX-X)(XX (Revision xx) Ft. Calhoun Station Ft. aihon SttionOmaha Public Power District 3.4 Emergency Director Judgment Emergency Director (ED) Judgment EALs are provided in the Hazards and Other Condition Affecting Plant Safety section and on the Fission Product Barrier (FPB)Matrix. Both of the ED Judgment EALs have specific criteria for when they should be applied.The Hazards Section ED Judgment EALs are intended to address unanticipated conditions which are not addressed explicitly by other EALs but warrant declaration of an emergency because conditions exist which are believed by the ED to fall under specific emergency classifications (UE, Alert, SAE or GE).The FPB Matrix ED Judgment EALs are intended to include unanticipated conditions, which are not addressed explicitly by any of the other FPB threshold values, but warrant determination because conditions exist that fall under the broader definition for a significant Loss or Potential Loss of the barrier (equal to or greater than the defined FPB threshold values).3.5 Fission Product Barrier (FPB) Threshold A fission product barrier threshold is a pre-determined, site-specific, observable threshold indicating the loss or potential loss of a fission product barrier.FPB thresholds represent th'reats to the defense in depth design concept that precludes the release of radioactive fission products to the environment. This concept relies on multiple physical barriers, any one of which, if maintained intact, precludes the release of significant amounts of radioactive fission products to the environment, The primary FPBs are: EU Fuel Clad (FC)* Reactor Coolant System (RCS)[] Containment (CT)Upon determination that one or more FPB thresholds have been exceeded, the combination of barrier loss and/or potential loss thresholds is compared to the FPB IC/EAL criteria to 'determine the appropriate ECL.In some accident sequences, the ICs and EALs presented in the Abnormal Radiation Levels/ Radiological Effluent (R) Recognition Category will be exceeded at the same time, or shortly after, the loss of one or more fission product barriers. This redundancy is intentional as the former ICs address radioactivity releases that result in certain offsite doses from Whatever cause, including events that might not be fully encompassed by fission product barriers (e.g., spent fuel pool accidents, design containment leakage following a LOCA, etc.).Month 20xx FC 3-7 Mont 2Ox FC3-7EP-XX-XXXX (Revision xx) Ft. Calhoun Station Omaha Public Power District 3.6 Fission Product Barrier Restoration Fission Product Barriers are not treated the same as EAL threshold values.Conditions warranting declaration of the loss or potential loss of a FPB may occur resulting in a specific classifcation. The condition that caused the loss or potential loss declaration could be rectified as the result of Operator action, automatic actions, or designed plant response. Barriers will be considered re-established when there are direct verifiable indications (containment penetration or open valve has been isolated, coolant sample results, etc) that the barrier has been restored and is capable of mitigating future events.The reestablishment of a FPB does not alter or lower the existing classification. However the reestablishment of the barrier should be considered in determining future classifcations should plant conditions or events change.3.7 Definitions CONTAINMENT CLOSURE: The procedurally defined actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under existing plant conditions. EXPLOSION: A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion. Such events may require a post-event inspection to determine if the attributes of an explosion are present.FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fire.Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.FISSION PRODUCT BARRIER (FPB) THRESHOLD: A preo-determined, site-specific, observable threshold indicating the loss or potential loss of a fission product barrier.HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.Month 20xx FC 3-8 Mont 2Ox FO3-8EP-XX-XXXX (Revision xx) Ft. Calhoun Station Ft Clhou StaionOmaha Public Power District HOSTILE ACTION: An act toward a Nuclear Power Plant (NPP) or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns,' explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTILE FORCE: Any individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction. IMMINENT: The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.NORMAL LEVELS: As applied to radiological IC/EALs, the highest reading in the past twenty-four hours excluding the current peak value.OWNER CONTROLLED AREA (OCA): The property associated with the station and owned by the company. Access is normally limited to persons entering for official business.PROJECTILE: An object directed toward a Nuclear Power Plant (NPP) that could cause concern for its continued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.REFUELING PATHWAY: All the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange.RUPTURED: The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection. SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS.These are typically systems classified as safety-related. SECURITY CONDITION: Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION.Month 20xx FC 3-9 Mont 2Ox FO3-9EP-.XX-XXXX (Revision xx) Ft. Calhoun Station Ft Clhou StaionOmaha Public Power District UNISOLABLE: An open or breached system line that cannot be isolated, remotely or locally.UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.VISIBLE DAMAGE: Damage to a component or structure that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected component or structure. Month 20xx FC 3-10 Mont 2Ox FO -10EP-XX-XXXX (Revision xx) LIC-1 5-010O2 Enclosure, Attachment 2 Procedure Matrix (Pages FC 3-11 through FC 3-32) k-r' (':nlhmm HOT HOT MATRIX Omaha Public Power District 6T l~alhnun Rtetlnn NOT MATRI~d HOT MATRIX Omaha Public Power District IAbnormal Rad Levels I Radiological Effluents A.l Roeleus of gaseous radiocativit [] r resulting In oflsite dose greater hean 1,000 mRem TEDE or 5,000 mRera thyrold CDE.Emreo cion Levels EAL Notes:* The Emergency D rector should declare the event promptly S upon dalermlnirng that the applicable tiwe has been exceeded, S or wilt likely be exceeded.f tan ongoing release is detected and the release utedi time Is unkncwn, assume thrat tire release duration has exceeded 15 minateax.* Clasuification based en effluent reonitor readings sasumes thai a ref ease path to the environment Is established, lIfthe effiuent flow past xn effluent monitor is known to have stopped due to actions to isolate the releasue path, then the effluent i menitor reading in no longer valid for classiticatlon purposes.* The pmo-calculated effluent monitor values presented in EAL ff1 should be used for emergency classificahion assessments until dose assessment resnits are available.

1. Readings on ANY Table Rl Effluent Monitor,>

Table R1 value tor> I5 minutes.2. Dose assessmeat Using actual meteorology indicates doses at or beyond the site boundary of EITHER: -a. > 1000 wRem TEDE OR b. > 5000 mRem COE Thyroid ft.RS1 Release of gaseous radioactivity, :resulting in off uite dose greater than 100 wRem TEDE or 50t mRene thyroid CDE.Emergence Aetlon Levels tEALl::Notes:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or wilt likely be exceeded.* if an ongoing release ia detected and the releuxe etari time in unkrrown, assume that fire release duration thes erroeeded 15 rein utes.* Classification based on ettluent manrlter readirtgs essumes that a releaxe path to the environment Ia estebtished. If the etlluerrt flow past an effluent monitor Is known to have slopped cue to actions to Isolate the release path, then the effluent monitor reading ls-rrotonger valld torclassificatton purposes.o The pre-calcatated effluent monitor values presented in EAL#1 should be used for emergency etassifi cation assessments until dose assessment results are available;

1. Readings on ANY Table R1t Effluent Monitor> Table Rlvalue torn. 15 minutes.ORt 2. Dose assessment using actual meteorology indicates doses at or beyond thle site boundary of EITHER;-x, >,100mwRem TEDE OR.b, >;500 atRem CDEThyroid OR ,", 3. Ffeld survey resufts at or beyond the site boundary indicate EITHER:* i a. Gamma (cosoed window) dose rules >100 mRem are expected to continue lor>s 60 minautes.OR b. Analyses of hield survey samples indicate > 500 m~am COE Thyroid for 60 mrinutee of Inhastation.

HA1 Roeuso o..f guceous or liquid radoesotivity resrrltrrg In otfsute dose greater than 10 mrerm TEDE or 50 wrew thyroid ODE.Emerr-enov Action Levels IEALI : Notes:* The Emergency Direct or should declare the event pmomptly upoa determining that the applicable time baa been exceeded, or will likely be exceeded.I* It an ongoing release is detected and the release start time is i unknown, assume thut the release duration has exceeded 15 i. minutes.* Classilicstlon based on effluent monitor readings assumes that a release path to the environment is established, it the effluent I tiOW paut an effluent monitor ia known to have stepped due to actions to isolate thu release path, than the effluent monitor reading is no longer vatid for classifIcation purposes.* The pre-calcutated effluent rnonitor~vataee presented In EAL f#1 should be used for emergency classification aesse-surents until dose assessment results are available. 1:Readelgs an ANY TSJSe Rt hiffuest Mosilorn. Table Rt value for_> 15:mthnutes..

• OR :, 2." Oweuuse aresetauslng actual muteomlogy.indicates dosessator
• beyond the esit beundury of ErTIT ER;* ..l.>Orur~mTEnlCOR" .." O5b. >50mm COD Thyroid 3. Analyeis al a mlud em auent, samefe indicates ascmncenrtrtion or release rate that eroald result in rtang reeler than EITHER el the tulounetg atbeyonrd the xlte baundur a 10 wRem TEDE tar 55 artnutas ofieuposure OR b. 50 mRem CDE ThyroId far a6 rminutsa at auposure 4. Feld aumey reuolta at ur beyond the nile besedaG indioute EITHER;a .G~amme ctaleed wlndarw) dose raransv 10 are expecrted In cantinue for aff60 minutes.OR h. of huie~ Survey searples indicate>s 50 Rew ClE hylrnirt for S0 ernuteus 01 inhalatiou.

RUl Any release of gaseous or liquid [radioactivity lottie environment greater than 2 tinres thu 0DCM for 60 minutes or longer.EmeroRenoy Action Leanls tEALt}: Notes:* Toe Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.* If an ongoing riexeae is detected and the release start time ls unknown, assume that the release duraffion has exceeded 60 mlnutes.Classification based on effiluest monitor readiongs assumes that a release puth to the environment Is established, If thte effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor readirrg is no longer valid for classification purposes.1. Reading on ANY Table R2 effluent meonltors >2 times alarm senpolnt established by a current radioactive release discharge pen'tif for is 60 minutes.OR 2. Readings on ANY Table R3 Effluent Monitors> Table R3 value for 60 minutes: OR 3:- Samrple analyses for gaseous or liquid releases indicate consentrstloes or releuse rates,> 2 times 00CM Limit with a release duration of is 6 0 munuteas.OR 3. ReId survey results at or beyond the sit a bundary indicate EITHER: a. Gamma (closed window) dose rates >1000 wRem ame expected to continue for > 60 minrates.OR b. Analyses of field survey eareplas indicate ">5000 wRem CDE Thyroid for 60 minutes of inhalation. Mode: 1 -Power Operations 2 -Slartup 3 -Not Standby 4 -HcI iSnutdown 5 -JOad Shitutoowa U -IUehseied Monlter General Ewergenoy [- Site Area Emergency Alert RM-063 AB Stack 3.71 E+0O uCuico 3.71 E-0t uCi/co 3.71 E-02 oCt/co Tal 1 RM-064 (If affected SI'G is not isolated) 5.68 E+01 orm [ 2.28 E+01 cpmN/RM-062 AB Stack ft'A N/A 5.25 E+05 cpm Effluent _____________ _____________ Monitor RM-052 AS Stack N/A 6.23 E+06 cpm 8.23 E+05 opmo Threshtolds RM-04.3 LRWPB Stack N/A 5.44 E+06 cpm 5.44 E+05 cpm RM-057 Condenser Ott-Gas N/A N/bA 1.34 E+08 cpm Month 20XX HOT MATRIX FC 3-11 Mot OX O ARX i -1HOT MATRfX EP-XX-XXXX (Rlevision XX) ~r ~Ih,iB ATDIYIA ATOIY n;.*.=^, Thhla RO FffhInt MonninThrahnlda Effluent Monitor Description J2X High Alarm RM-055 (if discharge not Liquid 28E0 p isolated) Mirimum 1 OW 28E0 p Pump Discharge Header RM-055 (it discharge not isolated) Minimum 2 RW Liquid &O4O p Pump Discharge Header 80EO p Tablte R3 Effluent Monitor Thresholdts Effluent Monitor Description NOUE RM.082, AB Stack (Gas). 3.25 E+04 cpm RM-052 AD Stack (Gas) .. 3.55 E+04 cpm RM-043 LAW PB Stack (Gsa) 3.37 E*04 cpin... M-057 ' Condenser Ott-Gas "* 8.83 Si-06 cpar RM-.054A (it:SG "*blowdown isnot SG blowdown " 9.86E+04 cprn isotated) ____________"__________ RM-0545 (if SO blowdown is not Obwon SG blowdown isolated) S.88E+04 cpm Month 20XX HOT MATRIX FC 3-12 Mot OX HTMARXF -2HOT MATRIX EP-XX-XXXX (Revision XX) It'tT Ms ATmEV CE,.ah D O.hil.. Dnwunr flkrl^5 FT. Calhoun Station HUT WIMAT I I nv ' i~ ......,u J 5'. , Abnornmal Rad Levels/IRadiologicat Effluents r F RG2 Spent fuel pool level cannot be 1[]]restored to at least (site-specific Level 3 description) for 60 minutes or longer.Emergency Action Levels lEAL): Note: The Emergency Director should declare the General Emergency prmmpty upon determining thai the applicable time has been exceeded, or will llkely be exceeded.Spent fuel pool level cannot be restored to at least (site-specific Level 3 value) Ior 60 minutes or longer.I RS2 Spent fuel pool level at-(site-specific Level 3 description).Emergencv Action Level fEA.&L): Lowering of spent fuel pool level to (site-specific Level 3 value).RA2 Significant lowering of water E]level above, or damage to, irradiated fuel.Emergencv Action Levels (EAL) : 1. Uncovery of irradiated feel in the REFUELING PATHWAY.OR 2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by ANY Table R4 Radiation Monitor reading >1000 mRernihr OR 3. Lowering of spent fuel pool level to (site-specific Level 2 value). RU2 Unplanned loss of water level above irradiated fuel.Emergency Action Levels tEAL): f~ll~1. a. UNPLANNED waler level drop in the REFUELING PATHWAY as indicated on ANY of the following:,* LI-06 (Cold Shutdown PZR Level)"* L1-197 (Cold Shtdn RC Level)-L1-199 (sight glees)* LI-2a46 (Spent Fuel Pool Level)AND b. UNPLANNED Area Radiation Monitor reading ries on ANY radiation monitor in Table R4., .:,Table R5- S i Areee Requiring Continuous Occupancy I a, a,"w Main Control Room~i" :': ~!JCentral Alarm Stati6n Radiation levels th~at impede i rc RU3 Reactor coolant activity ]][,access to equipment necessary for normal plant operations. cooldow or shton greater than Technica l Specification allowable limits.Table R4 RadIation Monitors RMS Area Monitored RM-. j Containment Rad Monitor 085M8 Auxiliary fituilding Red Monitor Portable Containment and auxiliary Building near Monto fuel handling areas i ::'Table R6: , Aress with Entry Related Mode Aoo~li~abilltv"A.rea " Entry Related Mode Containment Modes 4, S and 0 Room 6 Modes 4, 5and D Room 13 Modes 4, S and D Room iSA Modes 4, 5 and D Room 21 Modes 4, 5 and D Room 22 Modes 4, 5Sand D Room S6 Modes 4, 5and D RoomS57 Modes 4,S5 nd O Room 89 Modes 4, 5Sand D Emergency Action Levels tEAL) : Note: ilf te equJipment in the room or area listed in Table.RE was already inoperable, or out of aervice, before the event occurred, then no emergency classification is warranted.

1. Dose rate greater than 15 mR/hr in ANY of the areas contained In Table RS.OR 2. An UNPLANNED event results in radiation levels that prevent or significantly impede access to any of the plant rooms in Table RE, EmergencY Action Levels (EAL) : I. Dose rate on Contact" on the primary sample piping immediately adjacent to the Sample Hood (SL-1) is> 4R/htr.OR.............

......... ....2.Sample analysis indicates that: a. Dose Equivalent 1-131 specific coolant activity >1.0 uClI/gn for more than 100 hours during one continuous time interval OR > 60 uClfgm.-.,OR ....b. Activity > 100IE-bar uCl/gm,___________________________________ I _________________________________ +/- _________________________________ a S -rizanup 6-net orariuuy -nut Orutuvwri -uuu OiIUWUW~~ U -Mose: 1 -l-ower (dpemtionsS--- }'10[ -t O -- O;lutuuwn U -- Month 20XX HOT MATRIX FC 3-13 Mth2X HOMTRXF3-3HOT MATRIX EP-XX-XXXX (Revision XX) FG1 Loss of ANY" two barriers AND Loss or Potential Loss of third barrier.(il2l[I~ FIFS Less or Potentlal Loss ot ANY tw(a barrders.I PAl ANY Loss or ANY Potential Loss of either Fuel Clad or RCS[i]21II{.... i p .... --FC -ueal Clad PC -Reactor Coolant System CT -Coneraenmsre Sub-Calegory Less Petenetilt Less LOSS Potenltiel Loss Loss J Potential Less a. UNISOLABLE RC5 ot 5/0 rube Iseakage 511 thepepolly of snea chargitrg pernp 1. Astormatie er easeo ECC$S (SrI) eatntion inlr are ed gelrte is reqeired by EITHER of rhe lellenoxng: 4Op .1.RSe 1 asRVLMS indicates 0.0%. 5. UNItSOiA5LO PCS leakage OR A leaking or R UPTUR ED SG is Leakae1Re rSG ue None OR 0. 0. A transient has osesed 5 raoid RC5 FAULTED outside of containment. I None 5. Stnerm Generator tuba RUPTURE. AND b. PrBesuers ned Temprnarulrs Is shone Attachrnent PC-tb PressureO Tepeatrole Curve.* AND 0. Care Eair Thennaeosyl~e readiNgs 5. Reslc-ratian pracodurea not etfeotive is> 7g5lF , a 15 elanutas.'.Cr s snnoal naiaaO * -eng.lp"O-oHdi OR 2. lnadequrate Heat f" >Cotea-pEl Throoperaig ~. * " aNoie " : ff .OnaTruhC°n'O-OH4i None 2. a. Core sen therraoeouples

• 700 0 F Rerseost s. Onnc-Througr-Ccolino;EOP-2O HR4 irr
• AND el-nnr.. ..1 b. RVLMS Ilnics.teO 0.0%,' :"" :, :.AND* """ I. " a. Rasesbo=ase procedures Ist effeotine in* .. .." 15 rrinlbtes.

RP-0.01 A/E reuing > 5500 RMwl. : ', 3. Containmeel

2. Coolant acrivity >300 ruCulga Cane : Colanrairanna radinean Oron~er.RM-09t Alto Psisrirres I RCS Eqelo~enet r-rr Noane riS.dr > 40 Rlhnr. None .Noese Conrainrment radiation maniro, Rtr-051 r./E A55tivJl a er/h ncnata 3r~e/o reading

• 25,000 PRfhr.30 crane prier/ry" asapre piping edsti~an t o the irod SL-t per CH-SlP-PA.0O07

________F t. Coalaismenl isolatlon Is required and EIThER oi the lOllowisyj a3 cent.inranal Pressure > so pasi ond a. UNPLANNED dmwe0n5 in rislng.aaesraiureenr pressure or rise is O rairriotna moniror readings etO~tide at onainrsilenet Is rrre. 4. Hydrogen Consentrearloa in Coermorn'ent ] [ Emergency' DireCtors iudgreent > Sindioare a eosS at cairainraenl OR 4. Cnerainnnerrre Hn Non ne Nonea None thtegriry.

5. a. Contuiarent nreosure

• 5 poig Integrit or bypass OR AN 5 .UNISOI.AEL5 pathwasy from to. ess tosnan raiful train ci Cenrlornat I rh nearoeoonl Cantalnmest Cooing OR erdsts. Containarent Spray anlulpre~nt iOR operating per design fre > 15 2. Ingleation or POS leakage outside of aringtee..

ontenllnraent. 5 mnergnc 1. Asy Corsdnion in the npiniaa oI rue 2. Asp Condition in Ire opinean ot rale 1. Any Condi~tion in lthe opliion at rho 2. Any Condtone in the opinion athre 1. Any Condition in 1he opinion or the 2. Any Condition in toe cpinioa at the Enrergensy Directar thar incastea LOSS Emergency Direcror that indicares Emergency Director lhar mndicates Lnss Emergency Dirnoer rce tha etleeke Emeergency Cirestor thut indlo.ales Loss Pomeroncla Diester thae iotandiere Director Judgenn at rho Fueal Cla.d Osrner. Poreatlal Less at lhe Pear Crud Sorrier. nf thn RCS Barrier. Potentilr Loan of tene RCS Boarier. 01 nsa Conrainmenr Earrner.PoetaLenn aCnirnt____________ __________________________________________________ ________________________ ________________________ _______________________rt-iarrer Month 20XX HOT MATRIX v - in- riot 4- -Hot oniutcoewn a -uc[ic biaUroOWn FC 3-14-UelUeled HOT MATRIX EP-XX-XXXX (Revision XX) FT. Calhoun Station HOT MATIRIX ...N OT MATRIX Omaha Public Power Distic System Malfunction MG1 Prolonged loss of all otfflte T[]and all onsite AC power to emergency buses.Emeroqency Action Levels (EAL) : Note: The Emergency Director should declare the avant-promptly upon determining that the applicable-time has been exceeded, or will likely be exceeded MS1 Loss of all Off-site and On-Site ,AC power to emergency busses for 15 minutes or longer.!Emeraency Action Levels (EAt.) : I Note: The Emergency Director should declare the event S promptly upon determining that the applicable time i has been exceeded, or wilt likely be exceeded o 3 1. Loss of ALL off site AC power to vital 4160 volt buses t A3 1. Loss of ALL offsite AC Power to vital 4160 volt buses and 1A4. I A iaand1A4." MA1 Loss of all but one AC power F[source to emergency buSes fof 15 minutes or longer.Emergency Action Levels (EAt.) : Note: The Emergency Director should declare the event promnpty upon determining that the applicable lime hss been exceeded, or mill likely be exceeded t. AC power capability to vital 4160 volt buses 1A3 and 1A4 reduced to only one of the following power sources for> 15 minutes.* 1 61- Kv.Circuit ..*.. .EDGOalm i 2. Any additional single power source ilailure mill result in a toes of ALL AC power to SAFETY SYSTEMS.MU1 Loss of eli oft site AC pomer capability to emergency buses for 15 minutes or longer.Emerctencv Action Levels (EAt) : Note: The Emergency Director shOUld declare the event promptly upon determining that the applicable lime has been exceeded, or will likely be exceeded Loss of ALL offsite AC power capability to vital 4160 volt buses 1A3 and 1A4 for > 15 minutes.AND 2. Failure of EDG's DGI and 0G2 to supply power to vital 4160 v0lt buses 1A3 and 1A4.AND 3. EITHER O1 the following:

a. Restoration oi at least one vital 4160 volt bus in< 4 hours is not likely.OR'b. Core exit thermocouples

> 1 550°F.AND 2. Failure ofE.DGas 051 and DG2 to. supply power to vital 4160 V0lt busesl1A3 and 1A4'.. : AND:.* i 3. Failure toe restore power to at least one 60 volt bus ..in < 15 lminutes froma the lime of loss of both offsite and*onsife AC power. -? ,": MG2 Loss of all AC and Vital DC power sources for 15 minutes or longer.Emeroencv Action Levels ('EAL.):;Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded MS2 "Loss of all Vital DC power-for 15 minute~s or longer. j':;Ifr~rI Emeroency Action Levels (EAL} : Note: The Emergency Director shoutd declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded 0 0-U 0, 1. Loss of ALL oftsita AC power to vital 4160 volt buses I A3 and 1A4, Voltage is < 105 VDG on 125 VOC Dual and Bus 2 for> 15 minutes.AND 2. Failure of EDG'a DC 1 and DC-2 to supply power to vital 4160 volt buses 1A3 and 1A4.AND 3. Voltage is < 105 VDC on 125 VDC Bus I end Bue 2.AND 4. ALL AC and Vital DC power sources have been lost for>_ 15 minutes.Mode: t- Power Operations 2 -Stanup 3- Hot Standby 4 -Hot Shutdown 5 -Cold Sul~udown 0 -Defueled Month 2OXX HOT MATRIX FC 3-15 Mot OX HTMARXF -5HOT MATRIX EP-XX-XXXX (Revision XX) IT" HOT HOT MATRIX Dmaha Public Power District FT l~lhn~n Rtatinn IdOT MATRIX HOT MATRIX Omaha Public Power District System Malfunction MSS inability to shutdown the reactor causing a chaflenge to core cooling or RCS heat removal.w MA3 Automatic or manual trip fails to shutdown jf]j, MU3 Automatic or manual trip fails to shutdown the reactor, and subsequent manual actions taken at the the reactor.reactor control consoles are not successful in shutting down i tho ,carqn tTXD!_)0.SEmeroency Action Levels rEAL) : tAutomatic or Manual Trip did no._t shutdown the reactor as indicated by Reactor Power > 2% and SUM is , negative.S AND 2. All manual actions to shutdown the reactor have been unsuccessful as indicated by Reactor Power >2% and SUR is negative.AND 3. EITHER of the following conditions exist: a. Core exit thermocouples > 1550°F.OR'b. RVLMS indicates 0.0%OR o. Once-Through-Cooling, EOP-20 HR4 in : affect.Emerqencv Action Levels rEAL) : i Emerge'ncy Action Levels (EAL) : Note: A manual action is any operator action, or set of Note- A manual action is any operator action, or set of actions, which causes the control rods to be rapidly actions, which causes the control rods to be rapidly inserted into the core, and does not include manually I inserted into the core, and does not include manually driving in control rods or implementation o1 boron drivying in control rods or implementation of boron injection strategies. injection strategies.

1. Automatic or manual Trip did not shutdown the reactor ]. a. Automatic Trip did not shutdown the reactor as as indicated by Reactor Power > 2% and SUR is i Indicated by Reactor Power > 2% and SUR is negative, negative, AND .AND 2. Manual actions taken at the Console Center are no.t successful in" shutting down the reactor as indicated by Reactor Power > 2% and SUR is negative.Center is successful in shutting down the reactor.OR 2. a. Manual Trip did not shutdown the reactor as indicated by ReactOr Power > 2% and SUR Ia negative.AND b. EITHER of the following:

1. Subsequent manual action taken at the Console Center is auccesaful in shutting down the reactor.OR 2. Subsequent automatic Trip is successful in shutting down the reactor.tMA4 UNPLANNED loss of Control Room MU4 UNPLANNED lose of Control Room Tabla li1 Controt Room Parameters Table M2 Signitlcant Transients indications for I15 minutes or longer with a significant indications for 15 minutes or longer.to________________________

transient in progress.0O

• Reactor Power Emergency Action Levels rEALt Emergefncy Action Levels (EALhI* Z ee Electricsl Lead Rejection

>25% lull electrical learl* O rsue*Reactor Trip jNote: The Emergency Director should declare the event Note: The Emergency Director should declare the event__ *RSPesreEC cuto promptly upon determining that the applicable time promptly upon determining that the applicable time SIn CorelCore Eait Temperature

• CSAtainhas been excaeded, or will likely be exceeded has been esceeded, or will likely be esceeded oo ° Level in at least one OTSG. 1. a An UN PLANNED event results In the Inability to An UNPLANNED event results in the inability to monitor*[O *Auxiliary Peed Water Flow monitor ANY Table M1 parameters from within the ANY Table M1 parameters from within the Control Room for IControl Room for> I5 minutaes.

> 15 minutea.r- AND fO b; ANY Table M2 transient in progress.-Power Operations 2 -Startup 3- Hot Standiby 4 -Hot Shutdown 5 -Celdl Shtrdown D) -Derueled Month 20XX HOT MATRIX FC 3-16 Mot OX itT ARXF -6HOT MATRIX EP-XX-XXXX (Revision XX) HOT MATRIX Omaha Public Power District FT. Calhoun Station HOT MATRIX HTMTI mh ulcPwrDsrc LSystem Malfunction i ~~MA5 Hazardous event affecting a SAFETY SYSTEM required for the current operating mode.Emerqency Action Levels ("EAL) : 1, The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)

• EI*Ifra or external floodingevn* High winds or tornado strike (0
• FIRE>"
• EXPLOSION*Other events with similar hazard characterist~ce as CO determined by the Shift Manager* i: : " ~2. E'ITHERof, thea following:

.::'/: ::; :: ... .:"" :'i~ a. Evernt damage has ceased indications ol degraded::; performance in at least one train of a SAFETY., :: : " .:,:: SYSTEM required by Technical Specifications for= , , : .: Current ...operating m'ode...:;:. ,:.':, i::::b. The event has caused VISIBLE DAMAGE to a:: ... .. 'i: :: :::,:::- SAFETY SYSTEM component or structure./.. .:,.-. .,:,, ': : ;' :,:, required by Technical Spapifications for the curret~* :"S .:i '...;: : ... operating mode ,.:..* MU6 RCS leakage for 15 minutes or" longer. E]]-_merqencv Action Levels (EAL) : Note: The Emergency Director should declare the event promptly upon determining that the applicable timehas been esceeded. or will likely be exceeded.-J 1. RCS unidentified or pressure boundary leakage toI> 10gpm for > 15 minutes o I OR 2. ROS identified leakage >25 gpm for > 15 minutes.OR 1 3. Leakage from the ROS to a location outside containment >25 gpm for_> 15 minutes i_ .-. _________________ ________________ Made: 1 -Power Operations 2 -Startup a -i-rt vtanoby 4 -i-Ot Snuteown 5- Cold Shartdown I) -Datueted Month 20XX HOT MATRIX FC 3-17 Mot OX HTMARXF -7HOT MATRIX EP-XX-XXXX (Revision XX) FT ahu tto O ARXHTMTI O-haPuli Poe Ditr j!System Malfunction Table M3 Communications Capablltfv (5 0 (5 C.)C E 0 C)System Onaite Offaite NRC I 800 MHz Radio System X Gai-tronics System X Security Building PABX X X X Training Building PABX X X [ X Commercial X X Telephones .Conference Operations !Network (COP) -_____FTS-ENS ... X IX HPNX X Satellite phones X " MUJ7 Loss of all On-site or Off-site communication capabilities. Emergency Action Levels (EAL) : 1.Loss of ALL Table M30Onsite communications capability affecting the ability to perform routine operations. OR 2. Loss of ALL Table M30Offaite communication capability affecting the ability to perform olfa'ite notifications. OR 3. Loss of ALL Table M3 NRC communication capability affecting the ability to perform NRC notifications. Blair Phone Lineu x I MU8 Failure to isolate containment or lost of containment* pressure control.'~JI~1I~0 0 Mode: t -Power Operations Emergency Action Levels tEAL) : 1. a. Failure of containment to isolate when required by an actuation signal.AND .b. ANY required penetration remains open > 15 minutes of the actuation signal.OR 2. a. Containment pressure>* 5 paig AND b. Less than one full traIn of Containment Cooling OR Containment Spray equipment operating for > 15 minutes.2 -Startup 3 -Hot Standby 4 -Hut Shutdown 5 -Cotrd Sheuttown 0 -Defueated Month 20XX HOT MATRIX FC 3-18 Mnh2X HOMARXC3.8HOT MATRIX EP-XX-XXXX (Revision XX) T.ahonStation NOT MATRIX OTMATRIX Omh ulcPerDtrc Hazads nd Oherconditions Affecting Plant Safety HG1 HOSTILE ACTION resulting in loss of physical control of the facility Emerqency Action Levels (EALlI: 1. A notification from the Security Force that a 1-OSITLE ACTION is occurrng or has occurred within the S PROTECTED AREA.2. a. ANY Table IHl safety function cannt be= controlled or maintained. S OR b. Damage to spent fuel has occurred or is IMMINENT HS1 HOSTILE ACTION within fhe PROTECTED AREA Emerqency Action Levels tEAL) : A notification from the Security Force that a HOSITLE ACTION is occurring or has occurred within the.PROTECTED AREA. -HA1 HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.Emergency Action Levels (EAL): 1. A validated notification from NRC of an aircraft altackr threat < 30 minutes from the site.OR 2. Notification by the Security Force that a HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLED AREA.HUI Confirmed SECURITY CONDITION or threat.~I~II~1E~EmeqecyAction Levels EAL)1, Notification ol a credible security threat directed at the site as determined per SY-AA-10f -132, Security Assessment and Response to Unusual Activities. OR 2. A validated notification from the NRC providing information of an aircraft threat.OR 3. Notification by the Security Force of' a SECURITY CONDITION that does no~t involve a HOSTILE ACTION.I .1 +Table H1 Safety Functions[.Reactivity Control (ability to shut down the reactor and keep it shutdown)Core Cooling (ability to cool the core)RC$ Heat Removal (ability to maintain heat sink)NS2 Inability to control~a key safety function twi outside the Control Room :; !'i:!Emergency Action Levels (EAIL)' i:/;;..Note: Th~e Emergency Director should declare the event prornpty upon determining th~at the applicable time has been exceeded, or will likely be exceeded. i, 1. ( A Control Room evacuation h~as' reulteriri plant control being trannsferred from the Con~trol Room to altemate location ..% .. :* AOP-07 Evacuat ion cit Control Room OR* AOP-O6 Fire Emergency AND 2. Control of ANY Table HI key safety function is no reestablished in <c 15 minutes.' A2 Control Room evacuation renulting in transfer of plant control to alternate locations Emergency Action Levels (EAL): ." A Control Room evacuation has resulted in pf ant contirol being.transferred from the Control Room to alternate. locaions per:": i1-*:' Evacuation of Control ;Room.OR :"" °"AOP-C6 Fire Emergency ..-5 0, a.Mode: I- Power Operations 2 -Startup 3 -Nor Standby 4 -Hot Shutdown S -Cold Shurdown 0 -Datfsalad Month 20XX HOT MATRIX FC 3-19 Mot OX HTMARXF -SHOT MATRIX EP'-XX-XXXX (Revision XX) PT. FT. C~slh~n Ch~finn LIAT MATOIY Hazards and Other conditions Affecting Plant Safety HU3 FIRE potentially degrading the level of satety of the plant.Emergency Action Levels (EAL): Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. A FIRE in ANY Table H-2 area is no extinguishod in< 15 minutes ot ANY of the following FIRE detection indications: Table H2 Vital Areas

• Report from the hield (i.e., visual observation)
• Containment Building
• Receipt of multiple (more than f ) tire alarms or , .oAuxiliary Building *. .,::;' " *Intake ~trocture
• Field verification of aeingle fire alarm...
• Turbitne Building (SSE only) OR*: ". ": Main and Auxiliary Tranrslorrner Yard 2. a. Receipt of a single fire alarm in ANY Table H2.Condensate Storage Tank Area area (i.e., no other indications of a FIRE).i", " " ;. , "AND-!.,.. -.b. The existence of aFIRE isnottverified in <30: " :. " ,minutes of alarm receipt.* -OR" _,..../i~i

.'..,,;ii~ ..3. A FIRE within the plant PROTECTED AREA not" .i:.. 'i....: -extinguished in < 60-minutes of the initial report, alarm: ,:. '. :i :.; '"or indication.

• '" " A FiRE within the plant PROTECTED AREA that" requires tirefighting support by en offaite tire response agency to extijnguish.-

HU4 Seismic event greater than OBE levels Emerqency Action Levels tEAL) : a Seismic event

• Operating Basis Earthquake (OBE) 5s~indicated by oSTRONG MOTION SEISMIC EVENT IN tPROGRESS alarm~OR Event indicator (SMA-3 Control Panel) has changed trom Black to White Mode: 1 -Power Operations 2 -SIarIUp 3 -Hol Standby 4 -Hot Shutdown Col Shutdown 0- Detueled Month 20XX HO'r MATRIX FC 3-20 Mot OX HTMARXF -0HOT MATRIX EP-XX-XXXX (Revision XX) nr ~Ihn,,n a*nyinn wrvr MATLnIY Hazards and Other conditions Affecting Plant Safety Table H3 Areas with Entry Related Mode Applicability a0 Area Entry Related Mode________________

Applicability Containment Modes 4, 5Sand 0 Room 6 Modes 4, S and 0 Room 13 Modes 4, 5 and 0 Room 15A Modes 4, 5 and 0 Room 21 Modes 4, 5 and D Room 22 Modes 4, 5 and D Room 56 Modes 4,,5 and D Room 57 Modest5 Sand 0 Room 69 "- Modes 4, S and 0 HAS Gaseous release impeding access to equipment necessary for nsornmal plant operations, cooldown or shutdown.Emerqenoy Action Levels (EAL) : Note: It the equipment in the listed room or area was already inoperable, or out of service, before the event occurred, then no emergency classification Is warranted.

1. Release of a toxic, corrosive, asphysiant or flammable gas in ANY Table H-3 ares.AND 2. Entry into the room or ares Is prohibited or impeded a w 0*0 a=HUB Hazardous Event r [ Emeruenov Action Levels (,E, tL) : Note:. EAL #4 does not apply to routine traffic impediments such as tog, snow, ice, or vehicle breakdowns or accidents.

1. Tornado strike within the PROTECTED AREA.OR 2. Instemeal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component required by Technical Specifioations for the current operating mode.OR 3. Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spilt or toxic gas release).OR 4. A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing site via personal vehicles.OR i5.Abnormal River level, an indicated by EITHER: a. > 1004 feet MSL elevation (high level)OR 0. < 976 feet, 9 Inches MSL elevation (tow level)Mea 5 'wrUeain MOde: 1- PowerOpemtions 2 -Startup 3 -HOt Standby 4- HOt Shutdown 5 -Cald Shsutdown D0- Delueted Month 20XX HOT MATRIX FC 3-21 Mnh2X HOMARX- F3-1HOT MATRIX EP-XX-XX.XX (Revision XX)

FT. Calhoun Station HOT MATRIX HOT MATRIX Omaha Public Power Di'striet Hazards and Other conditions Affecting Plant Safety HG7 Other conditions exist which in the I-s7 Other conditions exist which in the HA7 Other conditions exist which in the HU7 Other conditions exist which in the judgment ot the Emergency Director wsrrant declaration of a judgment of the Emergency Director warrant declaration of a Ijudgment of the Emergency Director warrant declaration of judgment of the Emergency Director warrant declaration of GENERAL EMERGENCY. SITE AREA EMERGENCY., an ALERT.anUU ALE NT Emerge~ncyAction Levels EAL}: Other condilions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which Involve actual or IMMINENT tiubstantiel core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility.Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offeile for more than the immediate site area.Emerqency Action Levela (EAL): Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the piublic or HOSTILE ACTION that results in intentional damage or maticlous acts, (1) toward site personnel or equipment that could lead to the likely failure of or. (2) that prevent effective access to equipment needed for tho protection of the public.Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure tevets byenotd he site boundary,; .Emerglency Action Levels tEAL) : Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress or have occurred which involve as actual or potential substantial degradation of the level of safety of the plant or a security event that invoices probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to smoall fractions of the EPA Protective Action Guideline exposure levels.Emerqency Action Levels (EAL): Other conditions esist which in the judgment the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring otisite response or monitoring are expected unless further degradation of safety systems occurs.C E 0-s 0 5 5.0 C a a.Iii* , J ....... .. .. ..... ... ...... ... ... L ... .....Mose: 1 -rower uperasons S- w5arrup C-10 HOt Cn~y 4 --1 H~ tUneown b -GOcrd ahetdown D -Deuetsde Month 20XX HOT MATRIX FC 3-22 Mot OX HTMARXF -2HOT MATRIX EP-XX-XXXX (Revision XX) t HOT HOT MATRIX Omaha Public Power HOT MATRIX HOT MATRIX Omaha Public Power District--I ISFSI Malfunctions E-HU1 Damage to a loaded cask i11111l CONFINEMENT BOUNDARY Emeruency Action Levels (EAL)Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading:* > 60mrihr (gamma + neutron) on the top of the spent fuel cask OR* > e00mrlhr (gamma + neutron) on the side of the spent fuel cask, excluding inlet and outlet ducts-I ________________________________________________________ Mode: 1- Power Operations 2 -Startup 3 -Hot Standby 4 -Hot Shutdown 5 -eld Shatdown D -Iletueled Month 20XX NOT MATRIX FC 3-23 Mot OX HTMARXF -3HOT MATRIX EP-XX-XXXX (Revision XX) rl IE:I ILR A'rnlV r'[. I..t]l[]Ql.l[I OluLIgrl U I hi^ gnu i ll,^l nl^ r , It..I.Abnormal Rad Levels I Radiological Effiuents resulting in olfsite dose greater than 1.000 mRem TEDE resufltg in offistie dose greater than 100 ruRem TEDE or SOG00 mRam thyroid COE. or 500 mflem thyroid COE.i Emergency Action Levels tEALt : Emergency Action Levels tEALI Notes: Notes:!* Tme Emergency Director should declare the event promptly

• The Emergency Director should declare the event promptly upon deterrinlnng thet the applicable time hen been exceeded, upon dotermrining that the applicable time has bean exceeded.i owillikely be exceeded.

or will likely be exceeded, anthreassatlies i unknown, assume that the release duration has exceeded 15 unknown, assume that the release duration has exceeded t15 S minutes. minutes.* Classiticetlon based us etifluevt rmonitor readings aS.umes Ciaausitio.atlen based on effluent monitor readings assumes that I- that a release petit to the eunironment is established. It the a release path to hthe environrrvent iv established. if the ettluent S ettluent flow past an ettluent monitor in known to have stopped flew past an effluent monitor is known to have stopped due lv S due to actions to isolate the releuse path, then the effluent acthons to isolate the release path, then the effluent monitor S mnonitor reading Is no longer vaild for elaus,.iticatlue purp.oses. readursg is no longer vaild for Olasxilicatlon purposes,=t° The pre-csslculuted etiluent meaitor values presented In EAL

• The pre-calculated ettiuent monitor values presented in EAL At# shousid be used tot enmergerroy ciassitication assessments

.I1 sihosid be used ior emergency classitication assessments

" until dose assessment results are available.*

until done asess..ment mooults are aveiabteb. 18 1. Readings on ANY Table R1 Eifflueni Monitor > Table R1 value 1. Readings on ANY Tubte RI Effluent Monitor > Table Rlvalue 2 for > 15 minutes., Icr_> 16 minutes.-OR OR' ~2. Dose assessment Using actual meteorology indica~tes doses at 2. Dose assessment using actual meteorology indicates doses at/ or beyoed the site boundary ot EITHER: or beyond the site boundary of EITHER: a. >l000mRemTSDE

a. >100mRemTEDE OR OR S b. > 5000mRem COEThyroid

b. ,Seo0mRem COE Thyrtold OR OR 3. Field survey renults at or beyond Ihe site boundary indicate 3. Field survey reaulls al or beyond the site boundary indicute EITHER:. EITHER: a .Gam,'ma (closed window) dose retes >1000 wRertm a. Gamma (closed window) dose rates >100 mRem ame are expected to continue tar > 60 minut en. expected to continue tot > 60 mInutes.OR OR t. Analyses at Saied survey esampies indicate > 5000 b. Analyses of field eurvey sempies Indicate > 500 mRem , mRerm COE Thgnold tar 60 minutes ci Inhalation.

CDE Thyroid for 60 minutes ot inhalation. 1RA Relase at. fgaseo..s orliquid radioecstvity resulhing In otisite dose greeter than tO rerem TEDE or 50 wrem thyroid DDE.Emergqency Action Levels Notes:* The Emergency Director should declare the event promptiy upon determining that the applicable time bus been exceeried, or wiii likety be excoeeded.

• it an ongoing release is detected and lbs release start time is unknown, assume that the release duraeion has exceeded 15 minutes.* Classificetion baeed on etiluent monitor readings assumes that a releave path to the environment is established.

lifthe effluent 11OW pant as elflsent monitor lu known to have stopped due ts actions to isolate the release path, then the effluent meonitor reading is no lunger valid lor classitlcation purposes.* Thes pmo-catculated etflueni monitor` values presented in E.AL e1 should be used for emorgenoy classitication assessments until dose assessment results are available. I .ReaOineson ANYsTable RI eldoeni Monitors Table R1 selue tora1 mlrnutes.DR 2. Dose es-seosrent usnttg acteri watesrelugy iniccates dasas at er beyond thes boundary o t ErTHER: a. >l10mttoteTsEE OR b. > 50 ia sraC0E Thyreid OR 3. Analysis oeta leis~ etlusent sempte indicates a coricantrarite or release rule thet would tenoJf n ivdunes greater than 611THER Ol tha fl~lowng at at" beyond the site boundary u. 10 m~em TEDE tsrtO 60 mnates at exposure OR 5 .50mrRam COCThywid lor60 einutesoe at axpere 4. Field sumevy results at atr beyond the site boundaryInlcadie EITHER: a. Gamnmn (boned nilndowl dane tales a 10 wRthr ore augeated ro ac~ns~ne let a. 65 minutes.DR 5. Anedynes O1 bald survey osepiss indicate>. 50 mffet Deo Thyroid tar 611 minutes 01 lnhmstion. RUI Any release el gaseous or liquid l tadioactivlty tO the environment greater than 2 times tha DOCM for eo minutes or longer.EmergencY Action Levets tEALI : Notes:* The Emergency Director shonid declare the event promptly upon determining ithot the applicable tima hax been exceeded, or will likely be exceeded.*f lin ongoing release is detected and Ihe releuue salrt tIme iv unknown, assume that the release duration has esceeded 6O minutes.* Classiticeice based on effluenl moenlIto readingo assumes that a release past to the environment is established. It the effluent flow paul as effluent monitor is known lv have stopped due to ustiono to solate the release path, than the effiosnt monitor readlng Is no longer vulid tor clussificatlon purposes.1. Reading on ANY Table R2 eftiuent monitoms a 2 times alarm setpoint estabtebhed by a current radioactive release Olscharge permit for > 60 minutes.OR 2. Readings on ANY Table R3 t-fftuent Monitor a Table R3 value for > 60 minutes: OR 3. Sample analyses for gaseous at liquid releases indicate concentrutivos or release rates > 2 times 0DCM Ltmtt with a release duration ot > 60 minates.Mode: ! -Power Op ratlss- 2 -Sturtup 3 -Hot Standiby 4 -Hot Shutdown 5 -Cold Shutdown D -Detueled 1 Molitor General Emergency S Site Area Emergency Alert Table R1 Effluent Monitor Thresholds RM-053 AS Stack 3.71 E+.O0 uCi/co T 3,71 E-Ot u~i/oc 3.71 E-02 uC~i/c RM-064 (If affected S/0 is not Isolated) 5.68 E+Olcprn i 2.28 E+01 cpms N/A RM-062 AS Stack N/A TN/A 5.25 2405 cpm RM-052 AB Stack N/A 6.23 E+06 cpm 6.23 E+05 opel RM-043 LRWPB Stack N/A 5.44 0+06 cpms 8.44 E+OS cpm RM-057 Condenser Off-Gas N/A N/A 1.34 E+08 cpme Month 20XX COLD SHUTDOWN/REFUELING MATRIX FC 3-22 Mot 2X CL SUDONREULIGMARX O3-2COLD SHUTDOWN/REFUELING MATRIX EP-XX-XXXX (Revision XX) n ILq Cf fl.~Ih..,.. C*a~tnn flAl fl CUIlrnnWM~flCCIICI I~Ifl LA ATDAV Table R2 Effluent Monitor Thresholds Effluent Monitor Description 2X High Alarm RtM-055 (if discharge not Liquid 2SE0 p isolated) Minimum 1 CW 28E0 p Pump Discharge Header OM-O55 (if disoharge not Lqi isolated) Mnimum 2 W Liquid cp Pump Discharge Header Table R3 Effluent Mornitor Thresholds Effluent Monitor Description NOUE RM-062 AS Stack (Gas) 3.25 E+04 cpes RM-052 AS Stacis (Gas) 3.55 E+04 cpm RM-043 LRWPB Stack (Gas) 3.37 E+04 cpm RM-057 Condenser Off-G~s 8.83 E-+-5 cpm RM-054A (if SG blowdown is not SC blowdown 9.56 E+04 cpms isolated)RM-054B (if SG biowdown is not SG biowdown 9.88E+04 cpm i,,olated)- ________I Month 20XX COLD SHUTDOWN/REFUELING MATRIX FC 3-23 Moth2XXCLDSUTONIIEULIGMARX C3-3COLD SHUTDOWNJREFUELING MATRIX EP-XX-XXXX (Revision XX)

COLD SHUTDOWN/REFUELING MATRIX Omaha Public Power District CIN fl RHl1TflflWt4tlD~FtlFl INA SAATRIY COLD SNUTDOWNIREFUELING MATRIX Omaha Public Power Diatrint Abnormal Rad Levels IRadiological Effluents RG2 Spent fuel pool level cannot be RS2 Spent fuel pool level at restored to at least lsite-specific Level 3 (site-specific Level 3 description). description) for 60 minutes or longer.Emergency Action Levels tEAt.:. Emergency Action Level IEALI,, Note: The Emergency Director should declare the iLowering of spent fuel pool level to (site-specific Level 3 General Emergency promptly upon determining that value).the applicable time has been exceeded, or will likely be exceeded.Spent fuel pool level cannot be restored to at leant (sifte-specific. Level 3 value) for 60 minlutes or longsr.RA2 Significanftolweling of water D [II][level above, or damage to, irradiated fuel.Emerqency Action Levels (EALI : 1. Uncovery of irradiated fuel in the REFUELING PATHWAY.OR 2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by ANY Table R4 Radiation Monitor reading >1000 mRers~hr OR 3. Lowering of spent fuel pool level to (site-specitoc Level 2 value).RU2 Unplanned loss of water level above irradiated fuel.Emerqency Actiton Levels (EAL) : WE~JWE~JL~

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

• L1-I0e (Cold Shutdown PZR Level)oL1-197 (Cold Shtdn RC Level)*, L1-199 (sight glass)* LI-2846 (Spent Fuel Pool Level)AND b. UNPLANNED Area Radiation Monitor reading rise on ANY radiation'monitor In Table R4.(a 0 n-Table R4 Radiation Monitors RMS J Area Monitored RM- otaimn a oio 73 Cntinen4Rdonto RM- AuiirT ulin e oio Auiiay5ulinedMnio Portable TContainment and ausiliary Building near Monto f uel handling areas Table R5 Areas Requiring Continuous Occupancy Main Control Room Central Alarm Station (CAS)Tabte RB Areas with Entry Retated Mode Applicability Area Entry Related Mode Area Applicability Containment Modes 4,.5 and D Room 6 Modes 4, 5 and D Room 1.3 Modes 4, 5 and D Room 3.5A Modes 4, S and D Room 21 Modes 4,5S and D Room 22 Modes 4,S5and C Room 56 Modes 4, 5 and D Room 57 Modes 4,S5and D Room 69 Modes 4, 5 and D RA3 Radiation levels that impede [[[access to equipment necessary for normal plant operations, cooldown or shutdown.Emergency ActIon Levels (EAL) +/-Note: If the equipment in the room or area listed in Table R6 was already in~operable, or out of service, before the event occurred, then no emergency ctassification is warranted.

1. Dose rate greater than 15 mR/hr in ANY of the areas contained in Table R5.OR 2. An UNPLANNED event results in radiation levels that prevent or signitlisally ilapede access to any of the plant rooms in Table R6.Mode: 1 -Power Opemlonss 2 -Startup 3 -Hot Standby 4 -Hot Shutdewn 5 -Cold Shutdown 0 -betfueled Month 20XX COLD SHUTDOWN/REFUEUNG MATRIX FC 3-24 Moth2XXCODSIUTONIEUENGMTRX O3-4COLD SHUTDOWN/REFUJELING MATRIX EP-XX-XXXX (Revision XX)

Ft n ING MATRIX COLD SHUTDOWN/REFUELING MATRIX Omaha Public Power District Ft 4~nIho~n ~frtinn CflLfl 5HtITflAWNIREFItFLINE~ MATRIX COLD SHUTDOWN/REFUELING MATRIX Omaha Public Power District Cold Shutdown/IRefueling System Malfunctions CA1 Loss of all oftsile and onsite AC power to emergency busses tor i5 minutes or longer.Emerqency Action Leveis (EALi!: 5)S 0 0~C)"C 0-a Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded 1. Loss ot all otitsite AC power to vital 4160 volt buses lA3 and 1A4.AND 2.Failure of EIJG's DG1 and DG2 to supply power to vital 4160 volt buses 1A3 and 1A4.AND 3.Failure to restore power to at least one vital 4160 volt bus in <i15 minutes tram the lime of loss at both offeite and onsite AC power.CUI Loss at all but one AC power source []" to emergency buses for 15 minutes or longer.Emergency Action Levels tEAL) : Note: The Emergency Director should declare the event prompty upon determining that the applicable time has been exceeded, or will likely be exceeded 1. AC power capability to vital 4160 volt buses 1A3 and 1A4 reduced to only one of the following power sources tar > 15 minutes.* 161 Kr, Circuit* 345 Ky Circuit* EDG DGI* EDG DG2 AND 2. ANY additional single power source failure will result in a loss of ALL AC power to SAFETY SYSTEMS.E ea a.CA2. l-azardoua event affecting -1 SAFETY SYSTEM required for the current operating mode.Emerglency Action Levels (EAL'): 1. The occurrence of ANY at the following hazardous _events:* Seismic event

• Internal or external tlooding event* High winds or tornado stdke"*FIRE* EXPLOSION* Other events with similar hazard characteristics a~s determined by the Shift Manager AND 2. EITHER at the following;

a. Event damage has caused indications ot degraded performance in at leas! one train at a SAFETY SYSTEM required by Technical Specifications tar the current operating mode.OR b. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure required by Technical Specifications for the current operating made.__________________________________________________________

+/- .i~ a Mode: 1 -Power Opewtions 2 -Startup 3-- Hot Standby 4 -Hot Shutdown 5 -Cold Shutdown D0- Defueied Month 20XX COLD SHUTDOWN/REFUELING MA'I'FUX FC 3-25 Mot 2X CL SUDONREUUG ARI C .5COLD SHUTDOWN/REFUELING MATRIX EP-XX-XXXX (Revision XX) C'I"II I'1 Pt"tl lIMP- Coid Shutdown I Refueling System Malfunctions CU3 Loss of Vital DC power for 15 minutes or longer.Emergency Action Levels ~Note: The Emergency Director should declare the event m° promptly upon determining that the applicable time has o bean exceeded, or will likely be exceeded Voltage is <1O5 VOC on required 125 VDC Bus I and Bus 2 for >15 minutes.CU4 Loss of all onsite or otfsite communication I@]lr-di-"Table Cl Communicationls Capability -capabilities. System Onsite Offalte NRC -Emergency Action Levels (EAL'L: SystemzRdi X 1. Loss of ALL Table C10Onsife communications capability Gai-trenics System X affecting thle ability to perform routine operations. Security Building X X X OR PA8X _____- 2. Loss of ALL Table C10Offsite communication capability Training Building X X affecting the ability to perform off site notifications. 0PABX O Commercial O Telephones X X X 3. Loss 01 ALL Table Cl NRC communlcat~on capability Eofeece affecting the ability to perform NRC notifications. 0oOperations Network i X (COP)FTS-ENS __ X X HPN J X Satellite phones x X X Blair Phone Line i X ;Table C2 ROS Heat-up Duration Thresholds -CA5 Inability to maintain plant in cold shutdown CU5 UNPLANNED rise in RCS temperature.

• C otanetCosr e- -p Emergency Action Levels (BALl : Emerg[ency Action Levels rEAL) : Status Status Duration Note:Noe intact Not Applicable 60 minutes' The Emergency Director should declare the event promptiy *The Emergency Director should declare the event promptly Not Intact ' upon determining that the applicable time has been upon determining that the applicable time has been Established I20 minutes" exceeded, or will likely be exceeded.

exceeded, or will likely ha exceeded.. I *A momentary UNPLANNED excursion above the Technical

• -A momentary UNPLANNED excursion above the Technical__________________I Specification cold shutdown temperature limit when heat Specification cold shutdown temperature limit when heat II removal function is available doss not warrant removal function is available does not warrant aclassification, classification.

Reduced Not Established 0 minutes i. UNPLANNED r'ise in ACS temperature > 21 0 0 F.Inventory j .UNPLANNED rise in RCS temperatures>210°F for OR"It an ROS heat removal system as in operation within TalO 2drto.R oso tefloigfr 5mnts OR a. ALL ROS temperature indications --this time frame and lRCS temperature is being reduced, 2. UNPLANNED RCS pressure rise > 10 psig as a result of AND thn..LThehod..tis.t.p.icbl.temperature rise. (This EAL threshold does not apply b. ALL RPV level indications during water- solid plant conditions.) ________________ ______________________________________________________ Macre: Month 20XX 1 -r'ower uperarranS 2 -Star'tup 3 COLD SHUTDOWNIREFUELING MATRIX-HOt Staneey 4 -Hot Shutdown 5 -uOld Sauldcwn D -Oefueled FC 3-26 COLD SHUTDOWNIREFUELING MATRIX EP-XX-XXXX (Revision XX) Ft. Calhoun Station COLD SHUTDOWN/REFUELING MATRIX *COLD SHUTDOWN/REFUELING MATRIX Omaha Public Power District Cold Shutdown I Refueling System Malfunctions COG LOSS of reactor vessel / ROS inventory affecting fuel clad integrity with containment challenged. Emereency Action Levels (EALt: Note: The Emergency Director should declare the event promptly upon determining that the applicable lime has been exceeded, or will likely be exceeded 1. RVLMS indicates 0.0% for >30 minutes.OR 2. a. Reactor Vessel / RCS level cannot be monitored for>__30 minutes.AND b. Core uncovery is indticated by ANY of the following:

• Table C3 indicalions of a sufficient magnitude to indicate core uncovery.OR ,, Erratic Source Range Neutron Monitor indication.

OR* Containment Area Radiation Monitors reudlng> 20 H/hr.AND c. ANY Containment Challenge Indication (Table C4)Table C3 Indications of RCS Leakagle* UNPLANNED Containment Sump level rise** UNPLANNED Auxiliary ffIdg. Sump level rise'- Reactor Coolant Drain Tank level rise'* UNPLANNED Quench Tank level rise'o UNPLANNED Spent Regenerate Tank level rise"* UNPLANNED rise in RCS makeup* Observation of leakage or inventory loss*Riee in level is attributed losa loss of reactor nesseL'RCS inventoly. CS6 Loss of reactor vessel I RCS inventory affecting core decay heat removal capabilities. Emergency Action Levels IEALl;Note: The Emergency Director should declare the promptly upon determining that the applicable has been exceeded, or will likely be exceeder 1. Wilh CONTAINMENT CLOSURE established RVL indicates 0.0%OR 2. With CONTAINMENT CLOSURE no._t established RVLMS _<&80%OR 3. a. Reactor Vessel!/ RCS level cannot be monitors for>30 minutes.AND b. Core uncovery is indicated by ANY of the follow° Table C3 indicat ions olea sufficient magnitude to indicate core uncovery.OR* Erratic Source Range Neutron Monitor indication OR* Containment Area Radiation Monitors weading* 20 R/hr.CA6 Loss of reacfor vessel / RCS inventory CU6 UNPLANNED loss of reactor vessel / RCS inventory for 15 minutes or longer.~If~Ernerqency Action Levels tEAL)Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded 1. Loss of Reactor Vessel / PCS inventory as indicated by RVLMS < 14%OP 2.a. Reactor Vessel/IRCS level cannot be monitored for> 15 minutes.AND b. Loss of Reactor Vessel / RCS inventory per Table C3 indications Emerqency Action Levels /EAL) : Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded 1. UNPLANNED loss of reactor coolant results in the inability to restore and maintain Peactor Vessel I R0S level to> procedurally established lower limit for > 15 minutes.OP 2. a. Reactor Vessel / RCS level cannot be monitored. AND b. Loss of Reactor Vessel / ACS inventory per Table C3 indications. 0 Sre Table C4 Containment Challenge Indications

• Hydrogen Cencentration in Coataewemen

> 3%* UNPLANNED rise in constaimnenl pressure* CONTAINMENT CLOSURE not eslablinhed"*If CONTAINMENT CLOSURE is re-established peer to esceeding the 30-minute core uncovery/time limit, then esoolalien to a General Emergency Is otrequired. +/- _____________________________________________________

4 I _______________________________________________________

1 -Poser Operations 2 -St artup 3 -Hot Standby 4 -Hot Shutdown 5 -Cald Shutdown 0 -Delueted Month 20XX COLD SHUTDOWN/REFUELING MATRIX FC 3-27 Mot 2X OL HUDW/RFEIN ATI C -7COLD SHUTDOWN/REFUELING MATRIX EP-XX-XXXX (Revision XX) Ft. Calhoun Station COLD SHUTDOWN/REFUELING MATRIX m Ft. Calhoun Station COLD SHUTDOWNIREFUELING MATRIX COLD SHUTDOWNIREFUEUNG MATRIX Omaha Public Power tilsirtet-A -A- A A I SHazards amnd Other conditions Affecting Plant Safety HIGI HOSTILE ACTION resulting in loss Jr HSI HOSTILE ACTION within the HA1 HOSTILE ACTION within the HU1 Confirmed SECURITY' CONDITION of physical control of the facility PROTECTED AREA OWNER CONTROLLED AREA or airborne attack threat or threat.within 30 minutes.Emergency Action Levels (EALl:;1. A notification from the Secudty Foice that a HOSITLE Emergency Action Levels tEAL) : ,Emerqency Action Levels tEAL) : Emerqency Action Levels IE.AL): ACTION is occurring or has occurred within the A notification from the Security Force that s HOSITLE 1. A validated notification from NRC of an aircraft attack 1. Notification of a credible security threat directed at the PROTECTED AREA. ACTION is occurring or has occurred within the tra 3 iue rmteStst sdlrie e YA-0-3,Scrt oPROTECTED AREA.thet<3mitefomteitstasdtriepr -A-012.Suiy AND OR Assessment and Response to Unusual Activities.

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

2. Notificetion by the Security Force that a HOSTILE 2. A validated notilication from the NRC providing.... ... ..... ....ACTION is occurring or has occurred within the OWNER information of an aircraft threat.,,rOR .CONTROLED AREA. OR IDmMgeIN sent fulh oure r s. ...... .3. Notification by the Security Force of a SECURITY IMMINENT CONDITION that does no..t involve a HOSTILE ACTION.HS2 Inability to control a key safety HA,2 Control Room evacuation resulting Table Hi Safety Functions functfiont from outside the Control Room in transfer of plant controt to alternate locations*= Reactivity Control EmerQenicv Action Levels tEAL) : Emergency Action Levels (EAt): (ability to shut down the reactor and keep it shutdown)

Note.* The Emergency Director should declare tre'event A Control Room evacuation has resulted in. plant control* Core Cooling (ability to coocithe Core) promptly upon determining that the applicable time being transferred from the Control Room to alternate --* RCS Heat Removal (ability to maintain heat sink) has been exceeded, or mill likely be exceeded, locations per.1. A Control Room evacuation has resulted in plant control *AOP-07 Evacuation of Control Roomn being transferred from the Control Room to altemnate OR " ......Slocations per: .* AOP-O6 Firs Emergency-AOP-07 Evacuation of Control Room *C) .OR ,, AOP-06 Fire Emergency i ~ ~~AND... .2. Control of ANY Table N1 key safety function Is no~~reestablished in < 15 minutes."-ruw, utiaiuii z .ttu ..m ..a .a ii ivuwr ~ Lll atow uae WlOOe: L -- t'df lup O -- nul ordrwuoy -not o -LO]Q U - Month 20XX COLD SHUTDOWN/REFUELING MATRIX FC 3*28 Mot 2X CL SUDONREULIGMARX C3-8COLD SHUTDOWN(REFUELING MATRIX EP-XX-XXXX (Revision XX) 13 MATRIX Omaha Public Power ~* t~k,,,.n QMZn ~AI fl euii~nnw~mneiim I~Jf~ MATOIY (~flI fl ~I4tffflflWNIRFFlIFLING MATRIX Omaha Public Power fll~fri~,t Hazards and Other conditions Affecting Plant Safety HU: FIRE potentially degrading the level -T _________ofsafety _____t__eplant* il ~Emerqency Action Levels lEALi~Note: The Emergency Director should declare the event promptly 'upon determining that the applicable tfme has been exceeded, or will likely be exceeded.t. A FIRE in ANY Table H2 area is no extinguished in._ ..-. * <15 minu~tes of ANY of th~efollowing FIR E-detection:- indications: Table H2 Vital Areas

• Report from the field (i.e., visual 'observation)
• Containment Building *Reoei'pt of multiple (more than 1) fire alarms or* Auxiliary Building indications
• Intake Structure
• , Field verification of a single tire alarrr*Turbine Building (SSE only) OR* Main and Auxiliary Transformer Yard 2. a. Receipt of a single fire alarm in ANY Table H2* Condensate Storage Tank Area area (i.e., no other indications of a FIRE).AND b. The existence of a FIRE is no verified In .5 30 minutes of alarm receipt.OR 3. A FIRE within the plant PROTECTED AREA not extinguished in < 60-minutes of the initial report, alarm or indication.

OR 4. A FIRE within the plant PROTECTED AREA that requires tirefighting Support by an offaile fire response agency to extinguish. levels Emerqency Action Levels (EALI Seismic event > Operating Basis Earthquake (OBE) as a- -.*iae bSTRONG MOTION SEISMIC EVENT IN PROGRESS alarm*Event indicator (SMA-3 Control Panel) has changed from Black to White 1 -Power operations 2 -8tartup 3 -Hot 4 -HOt b -L;Old L) -Ueluelecl Month 20XX COLD SHUTDOWN/REFUELING MATRIX FC 3-29 Mot 2X CL SUDONREULIGMARX C3-gCOLD SHUTDOWN/REFUEUNG MATRIX BP-XX-XXXX (Revision XX) I::l' P(*ll il l1:1 IMP. COLD MATRIX Omaha Public Power tAI h ITfl~nItnI LM(5 5AATDIV COLO RHIJTDOWN/REFll~LtNG MATRIX Omaha Public Power flienrt,,t I -., -I Hazards and Other conditions Affecting Plant Safety 0 0 0 1-Table H3 Areas with Entry Related Mode Applicability Area Entry Related Mode Area Applicability Containment Modes 4, 5 and 0 Room 6 Modes 4,S5and P Room 1.3 Modes 4,5S and D--Room i5A Modes 4, S.and 0 Room 2"1" Modes 4, 5 and D Room 22 Modes 4, 5 and D Room 56 .Modes 4, 5 and 0 Room 57 Modes 4, 5 and D Room 69 Modes 4.5 and D HAS Gaseous release impeding access to equipment necessary tor aormal plant operations, cooldown or shutdown.Eeenov Ation Levels EAL : Note: If the equipment in the listed room or area was already inoperable, or out ot service, betore the event occurred, then no emergency classification is warranted.

1. Release oa a toxic, corrosive, asph yriant or flam~mable.

gas in ANY Table H3 area.AND 2. Entry into the room or area is prohibited or impeded-J +I-- --I HUe Hazardous Event~I~1I~II~C a., Emergency Action Levels tEAL) : Note: EAL #*4 does not apply to routine traffic impedimenta such as fog, snow, ice, or vehicle breakdowns-or accidents.

1. -Tornado strike within the PROTECTED AREA. --*OR 2. Internal room or area Ilooding oi a rnagntitude sufficient to require manual or automatic electrical isolation of a* SAFETY SYSTEM component required by Technical Specifications for the current operating mode.OR.3. Movement of personnel within the PROTECTED AREA is impeded due to an offithe event involving hazardous-.-materials (e.g., an offaite chemical spilt or toxic gas release).-OR -4. A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site vie personal vehicles.OR 5, Abnormal River level, as indicated by EITHER: a. > 1004 feet MSL elevation (high tevel).OR b. < 976 feet, 9 inches MSL elevation (low level)Mode: Month 20XX 1- Power Operations 2 -Startup 3 -Hot Stand'by COLD SHUTDOWN/REFUELING MATRIX 4 -Ilot Shutdown 5 -Cold Shutdo'wn FC 3-30 D0- Oetueted COLD SHUTDOWN/REFUELING MATRIX EP-XX-XXXX (Revision XX)

It, Calhoun Station COLD SHUTDOWN/REFUELING MATRIX COLD SHUTDOWN/REFUELING MATRIX Omaha Public Power District Ft. Calhoun Station COLD SHUTOOWN/REFUELING MATRIX COLD SHUTOOWNIREFUELING MATRIX Omaha Public Power Distract Hazards and Other conditions Affecting Plant Safety HG7 Other conditions exist which in the judgment of the Emergency Director warrant declaration of a IGENERAL EMERGENCY. EmrinyAction Levels (EALI : Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or IMMINENT -substantial core degradation or meltiag with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility.Releases can be reesonebly expected to exceed EPA Protective Action Guideline exposure levets offsite for more than the immediate site area;HS7 Other conditions exist which in the HA7 Other conditions exist which in the judgnmenf of the Emergency Director warrant declaration o! a judgment of the Emergency Director warrant declaration oit SITE AREA EMERGENCY. an ALERT.Emersiency Acitton Levels (EALl Other conditions exist which in lie judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intenfional damage or malidious acts, (1) toward site personnel or equipment that coutd lead to the tikely failure of or, (2) that prevent effective access to equipment needed for the protection of the public.Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.Emerqtency,,Action.Levels (EAL) : Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to silo personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.HUT Other conditions exist which in the 1 j111['1[judgment o[ Ihe Emergency Director warrant declaration of an UNUSUAL EVENT.Emerrtencv Action Levels tEAL'): Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred whnich indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring oftisite response or monitoring are expected unless further degradation of safety systems occurs.0 E or 0 or or E uJ Mode: I- Power Operariors 2- Startup a -Hot Standby 4 -Hot Shutdown 5 -Cole Shutdown D0- Detuested Month 20XX COLD SHUTDOWN/REFUELING MATRIX FC Moth2XXCLDSUTON/EFEIN ATI F -.tCOLD SHUTDOWN/REFUELING MATRIX EP-XX-XXXX (Revision XX) Pt COLD SHUTDOWN/REFUELING MATRIX Omaha Public Power District Ft ~ Ctsllnn roLfl ~HIITflflWtifflFPIIFI ItM~ MATRIX COLD SHUTDOWN/REFUELING MATRIX Omaha Public Power District ISS afucin E-HU1 Damage to a loaded cask CONFINEMENT BOUNDARY Ernerctency Action Levels (EALt : Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading:* > 60mrlbr (gamma + neutron) on tie top of the spent fuel cask OR* > OO0mrIhr (gamma + neutron) on the side of the spent fuel cask, excluding inlet and outdet ducts (a U-Made: I -Power Operatiens MOde: 1 -Power Operations 2 -Starlup 3- Hot Standby 4 -Not Shutdown 5 -Gold Shtdacown 0 -Datuetecd Month 20XX COLD SHUTDOWN/REFUELING MATRIX FC 3-32 Mot 2X OL HUDWIRFEIN ATI C -2COLD SHUTDOWNIREFUJELING MATRIX EP-XX-XXXX (Revision XX) LIC-1 5-01 02 Enclosure, Attachment 3 Radiological Analysis Methodology for Development of Radiological Effluent*Emergency Action ,Levels RA 1 3-008 Rev. 1 RP-AA1O1OFC-15.-003 (RA 13-008)S PAGE 1 OF 74________REV.1By: (date)repared by: (dat*) -By: ~dato)I ZN~AA.EZ~TMj-~2 0 Meth l~ogy for Development of Radiological Efl uent Emergency Action Levels RP-AA-1O010 FC-15-003 (IRA 13-008)PAGE 2 OF 74 REV. 1 This anatysis documnents the methodology for development of effluent emergency action levels (EAL) from the guidance found in NEI 99-01 Rev 6. The process monitor thresholds are to be used to supplement dose assessment during the early phases of a radiological accident. This analysis supersedes all previous versions of RA-03-004. Radkg~jial Analysis RA 13-008 revision 1 is now documented in RP-AA-10a 0 FC-1,5-XXX revision 1 A revised analysis is required, because th .site is implementing a more recent version of NEI 99-01 and therefore the actin levels are being updated to:rmeet the new revision.Revision 1 of this analysis calculates the CEDE from iodine for the thresholds readings indicatng a notificatio of unusual event conditton, These thresholds are now based on a Total Effecve Dose Equivalent for these conditions rather than whole body dose Radiation Monitor readings are also corrected for inst"ument uncertainty and differences for the range of isotopes that could be detected in the effluent (Ref. 4). The th~resholds for RM-0S4 were revised to asstume a release through a lo-pesure steam safety rather than the condenser and change is consistent wit the dose assessment program Unried RASCAL Interface (UJRI).1) The source termn used in this calculation is based on the predominate radlonuclides that effect offite dose. These radlonuclides are and Ir1l and are consistent with the Offsite Dose Calculation Manual (ODCM), The primary calibration of the effluent rad~aton montors uses '=Xe to develop monitor efficencies.

2) The initatng conditions for each EAL is basedion doses at the sit boundary of 0.1, 10, 100, and 1,000 mrern Total Effctv Dose Equivalent

('TEDE-) in one hour forte time periods found in reference (1), or 50. 50d, 5,000-mrern for the thyroid dose_ In accordance with reference (1), NOUE is based on a multtle of the high alarm effluent set point (,4<), wh~idh are approximately equal tn 0.1 mremlyr see Methods section. In the case of action levels for Alert, Site Area and General Emergency a comparison of Total Effective Dos Equ~valent (TEDE) and Committa Dose Equivalent (CDE") to the thyroid are calculte~d (Ref. 1).3) This analysis use annual average meteorology to calcuJte monitor thresholds as defined the ODOM and normal oper'atonal alignments Norm-l alinments are used because EALs are based on the most probable accident scenano Use of average meteorology is cwisnlset wit the guidance in reference (1).4) The mronito indcto is based on a single release pathway. A correction for instrumenet unctinty (15%) an~d a 10% tolerance to account for the differences in detector sensitiviy for the range of isotopes detected. This this correction is con'sisten wihthe O0CM meth~odology.

RP-AA-1 010 FC-15-4003 (RA 13-008)* PAGE 3OF 74REV. 1 5) The Condenser is assumed operatioal durig a Steam

Generator Tube Rupture (SGTR) arnd: t effluent is meonitored by RM-057 or if arigned to Auxiliary Building stad< monitored by RM-063. However, if 1the site loses off-site power, the steam sefetles and atmospheric dump valves Will opens and this; reease path is monitored by RM-064;I otherwise, the evacuation pumps will remain operabional to rnaintain Condenser Vacuum. These EAts should be based on the most probably accident event, however dose assessment pertormed using actual conditions is always the most approp:riate method of classifying (reference 1).5) The radieinde~s used inthe varous process monitrsare assumed to have a relatively fiatI energy response.

The only exception is RM-064 because RM-a64 uses a GM-Detector. However, GM-detectors exhibit a flat energy response above 0.1-MeV and over respond to energies below 0.1-MeV. A Nal detector is in RM-057 and these detectors are very seositive and responses accurately to very low gamma energies. All the other detectors are beta scdintlators, which exhibit flat energy response reference (9). The lowest energy typically measured at a nudlear power plant is approximately .03-MeV, the effective energy of '=Xe. Since tbese process monitors are calibrated using t~Xe, so their response will sllghtky overestimate to the acial count: rate. resultng in a conservative A 10% tolerance is applied to account from these potential difference and is consistent with the ODCM.1) NE! 99-01 Rev. 6. _De~veloomnent of Ermeraencv Action Level for Non.Passive R_.Q[ November 2012.2) FCS Memo' CHP-2003-01. Radiation Monitor ParamTePtrs for EAGLE. January 6, 2003.3) EPA-.400-R-92-001. Manual of Protetv Adion Guides and Prot~ectiv Actions for Nuclear Incidns May 1992.4) CH-ODCM-O001 Rev. 24,.Off-Site Dose Calcuiation Manual. January 15, 2015 5) Technical Data Book ('TDB-lV-7). Pw0cess Monitor Settn,,s. Revisico 223. Juiy 17, 2015. i 6) Engineering Analysis EA13-021. Dete~rmination of romenrstailve samolina orUe oost-acClent main steam-lne nionitor RM-06,. Rev. 0.7) NCRP Report No. 112. Calibration of Survey Insruments used in Radiation Protection for the.Assessetn'u of Ilonzina Radialion Fields Radioactie Surface Conlanination. December 31, 1991. !8) Technical Specifications Seto 5.16(g) Raedioloak/zal Effluent arnd EnvkornmentalProgam,u Page 5,0- Page 14. Amendment N~o, 237.9) Glenn F. Knoll. Radlatbon Dete ctkn and Measurement, Second Edition 1988.10) Engineering Analysi EA-FC-02-019. EAGL.E &.0.. Secondary Side Source Term Rev. 0. November 11, 2003. RP-AA-101O FC-185-003 (RA 13-008)PAGE 4OF 7'4 REV. 1 11) Engineering Analysis FA-FC-02-20. 6.0.0. Source Te~rn Undamaod Core.Rev. 0 November 12, 2003. : 12) Calcuistion FC8073. USAR 11.2 Update -Design Basis Curie Content of the Rawate Building. 9(112013.13) STM-PM Volume 33,/?adlatxio Manffoiiio Rev I9a. February 28, 2013.14) 10 CFR 20. Standards for, .Proectbn. Aaalnist Radia~tion. ht./1 ovf.- w: 15) EC 37873. Subsut Reice t for Radia~tkn Monitr tM-05. Local Ratemetar RM-057-1. and Monif or Elements RE-O57. Rev. 2_ October 17, 2007.1) Annual aver'age abnosphe~c disperslon factor (x'O) used in this analysis is smas defed in Table 4of theODCM reference (4).2)- Sensitivy for RM-043 (LRWPB Stc Gas) used in this analysis is 2,33x10 7 3 wWh a b0ackground count rate of 38 cpm, reference (5).3) Sensi~vtr~ for RM-052 (Auxilary Building Stack Gas) used in this analysis is 2,24x10 7 with a backgrwid count r'ate of 70 cpm. reference (5).4) Sensitivity for RM-062 (Auxiliary Building Stack Gas) used in this analysis is ! .89x10 7 3 with a background count rat of 50 cpm, reference (5).5) Sensitlvity for RM-0$4 (Post Accident Main Stea Gas) used in this analysis i 3 04x10' 3 with a background count rate of 19 cpm, reference (5).6) Sensitivity for RM-057 (Condenser Off-Gas) used in this analysis is 5.94x10h cpm/p.C/crn 3 with a background count rate of 820 cpm, reference (5).7)The DDE dose conversion factors were tak~en from Table 5-3 =~ose Conve,,sion Factors (DCF) and Deri'ved Response Levels (VAL) for Extemal Exiposure Due to Immeso in Contaminated Al, fromt~ reference (3).8) The specific volume used in this analysis is for saturae steam at 222 0 F, (22.568 f/tabrn) fro stan~dard steam ta~bls, per MR-FC.79-I SOC 9) A Main Steam rate of 1.28x10S-4bmr~h is used in this analysis and is equal to th~e design Ilo rate of the 1,00&-PSLA Main Steam Saet and the Steam Driven Auxiliary Feed water Pump (5,328-cfrn), from reference (8).1O} Condenser off-gas stack flow rate dwng nonmal operations (100% power) measured at 320-ftrnin (DFCR 94-0014, MR-FC,-84-155D-T3), Maximum condenser evacuation flwrate is rated at 4.500- tE/min.11) Aux~liary Building stack flo rate of 24,157, reference (4). RP-AA-1O1O FC-15-003 (RA 13-008):PAGE 5OF 74 REV. 1 12) iodine to Noble Gas ratio for a non-degraded core 0.007 for non-steam releases and*0.085 for ste~am releases, reference (2), rfeferenc (10), and reference (1 1), 13) Radwaste Building stack flow rate of reference (4).14) The thyrokd-weighting factor is 0.03 found in 10 CFR 20.1003 "Weigh~ng Factor W9', reference (14).15) The calcuations were performed using commelialty .available software.Spreadsheets vere calculated using EXCEL 2013 and hand calculatins were performed using Mathcad Priso, 3.0.Fort Calhoun must have a formal set of theshold conditions that require plant personnel to take specific actions concerning notifying local governments when olf-orrnai indicators in the effluent monitors are recognized. The level of response and the codtin leading to these responses were evakuaedl and documnentxed NEI 99-01 Rev. 8. These guidelines were developed by NE! and endorsed by the NRC to provide a systematic approach for the basis of tihe revised EALs.In revision 8, it was recognized that the condition described by the radiological initiating conditions (IC) might result In radiological effluenlt values beyond the operating or display range of the insteled effluent monitor. in those cases, revision B provides guidance=... that the EAL values should be determilned with a margin sufficent to ensure that an accurate monitor reading is available. For example, an EAL monitor reading might be set at 90% to 95% of the highest accurate monitor feading. This prov~s~ii notwithstanding, ilf ih eastimatd/calculated monitor reading Is greater than approximately 110% of the highest-accurate monitor reading, then develope, may choose not to include the monitor as an indi'cation and identify an afternate EAL threshoid" (referencel1). The dose consequences from these events start at a small fraction of the EPA PAG e.g., tess th~an 10-millirer to 100-inlilirern TEDE, escalatng to those of the EPA PAG for a General Emergency. The calculatin of these ad~ion levels uses a simprlife approach to TEDE and CDE, which assumes the main radlonudkies are 1=Xe and Site boundary doses are calculated using a Gaussian plume distnbutlon to determine the gross count rate or radioactive concentrations. By using, an action level 'based on a site boundary dose for a given period of time (1 hour) a monitr set point (threshold) is calculated. TEDE is th sum of Intral and external radiation exposure and those isotopes noted above best estimate the major external and internal dose:,.TEDE =EDE.,+ w.CDE, 4: (5.1)The TEDE ( I ) rriem In one hour and can be rerte as folows: RP-AA-1O10 FC-15-003 (RA 13-008),; ' PAGE 6 OF 74: REV. 1 Whomer Q is the gross release rate fromn nobe gas (1and Iodine X/Q is the annual average dispersion ractor. DC;F is the external' and internal dose converson factor (DCF) and w is the thyroid weighting factor reference (14). is the externl dose eonvj5ion facto forj 1~3)e, DCF, is the external dose (EDE) conversion factor for 131 andis tile Ithyroid dose facto (CDE) for The todine release rate can be calculate by using the bdlne to noble gas ratio 0.007 or 0.065 for secondary reeases) and mulptying it by tii noble gas release rate(Qrj.Substituting k 0.Q,= for Q~and Into the TEDE equation, the following formula can be Q the gross release rate (noble gas) corresponding to the action level dlose rate (H) at the site boundary. The process radiation monitors are calibrated using '3wXe. Solvng for Q, the equation is rewritten: > Q(D: ~ oD~WC~] (5 4)The monitor set points for as NOUE is based on 2X the ODOM limit and is based on Technical Specification section 5.16 (g), at 5 times the Imit (0.1-rem/yr for Noble Gases)as set for in 10 CFR 20 for members of the public (note reference (14): 10 CER 20 Appendix B ). Therefore, the dose equivalent equals 500-rn rm/yr (TEDE). The folowing calculation shows the dose in any one hour for a NOUE at2 traes the limit (reference

1) : H 2 x500-rmy 14mrem/(5)

yr Rounding this dose per hour to one slgndiant dlgit the EAL for a NOUE is D.1-mrernihr Calculation of the gross release rate based on the oommitted dose equivalent is done by ,settng the external dose conversion factors to zero (0), the werg.hb0ng factor to 1. and using the CDE thyroid dose EAL for H .Since the FALs for an NOUE are based on 2X the TEDE annual Ilmits (500-mremn/yr) and is Wrchluded in the TEDE calculation of CEDE a specifi thyroid dose is not calculatead (refernce 1)., Q: ,, (5.6)X/Q(k,, The gross count rate on the process monitors-are caclae by the following formula (referece 4)R cck~+ A(7 RP-AA-1 010 FC-1 8-003 (RA 13-008): .PAGE 70F 74~REV I Where R is the monitor threshold count rate (EAL), F is the stack flow rate, ki corrects for monitor uncertainty (0.75), 8 is the monitor efficiency, end Rb is the background count rate.The comredion k2 is only applicable to the accident range monitor RM-.0:64.

and corrects for changes in steam density, however because the dose assessment computer program already correct for this parameters k2 is setel ..., * , The accident range monitor RM-063 measures the gross ionncenfralian in the effluent of: the Atndliary Building stack, and the threshold is calculated by dMdlng the l~imitg release rate by the stc flow rate.Q (5.8)Monitor thresholds eae calculated for each of the emergency ciassiflcations fthat corresponds to the limitng dose for an exposure perxIo of one-hour.The thresholds for'TEDE an CDE are compared and the tower of the two readings are assigned as th EAL threshiolds. Table 1: Parameter List for Radiation Monitors Iodine to Noble Background Efficiency gas ratio (cain) RM--043 0.007 28,750 38 2.33E+07 RM-052 0.007 24,167 70 2.24E+07 RM-067 ,0.085 320 ,820 5.94E+08 RM020.007 24,167 ...50 1.895+07 RM-063 0 .0,07 24,187 RM-064 0.065 320 19 3.04E+01 Table 2: Radiation Monitor Range and Detector Type'Channel .Rarge : Detecter RM-043 101 -10t cpm Beta, Plastic Scant RM-052 I0 -10 7 cpm Beta, Piastic Scint RM-057 10' -1.48x10 8 cpm2 Gamma. Nal' takeni *rom ST-RU Volume 33. RaIm Mwmtaobig Syusen (vu~ien 13)2jppr ra~ga 1lt k~sbIrmmet Lr (15 b l~s uzpperw c if't equ.rnef b RP-AA-01O FC-t15-003 (RA 13--008), PAGE 8 OF 74____ ___ ____ ___ ___ ____ ___ ____ ___ ___REV. 1 RM-062: 10 -10 7 cpm Beta, Plastic Scint.RM-063. 10O pCt/cm 3 Ion Chamber RM-064 i0' -10 7 cpm GM Tube Calculations for each process effluent and accident range mnonitors are In Appendix I Thne results of this calculation are used to establish EAL thresholds to alert plant personnel of abnormal conditons. Table 2: Action Level thresholds based on site boundary dose FALs in one hour Emeraencv Action Level (corn or uCl/cc for RM-0631 Monitor NOUSE ALERT SITE AREA GENERAL RM-043 3.37E+04 5.44E+'05 5.44 E+06 off scale RM-052 3.85E+04 6.23E+05 6.23E+06 off scale RM-057' 8,83E+06 1.34E÷08 off scale off scale RM-062 3.25E.04 5.25E+05 Shift to RM-063 Shift to RM-063 RM-003 -3.71E-02 3.71E-01 3.71E+00 RM-064 -2,28E+01 3 5,&68E+01 Note: The thresholds for RM-063 are in units of pCi/cc. Au other monitor action levels are in units of cpm. Process and accident range monitor action levels are based iodine arid CDE because the thyroid dose Is more limiting.The process effluent monitors are capable of measuring Instantaneous releases of roa~ctiit that correspond to a Notification of and Unusual Event (NOUE) and in some cases a SiTE AREA emergency. When condibons the process effluent monitors will over range, and th high range accident moitors0 wif provide indicatio. The only exception is RM-043 the Radwaste Processilng Building. However, the actual source term In this building is not sfcin to cause a release would require a General emergency reterenre (12).Radiati0n monitor RM-064 is an off-line acoident irange monitor used to monitor the main steam lines and has a low efficec (30.4-cpmn/iCi/cc). Therefore, small changes in count rats will result in Larger measured cocnrain of radioactiiy. For normal levels of reactor coolant this radiation monlor is not good indict~or for cdassifiation and other opeaioa method:s should be cosdee.For Auwilriy Building releases monitor RM.062 is th~e normally aligned monitor and will prov:de indicatio of a stack rees until the monitor exceeds 5x10 8-cpm, when valves flow. ;., ! RP-A-1 010 F'C-15-003(A130) i PAGE 9 OF 74 I REVL 1 My-I, MV-2, MV-3 and MV-.4 ,,ill douse off normal samaple flow and redirect flow to the accident range monitor RM-063. This shif can also be caused if RM-063 exceeds 5x1 Oa jiCi/cm 3.When the radiation level detects decreases to )es the 5x10'3 pCi/crm 3 RM-062 w~il automaticaly return to normal sample flow (reference 13).The monitor count rates or stack concentrations were! calculated using the guidelines foundl in reference (I). For example, a sustained count rote of 3.37x10 4-cpm on RM-043 would correspond to a TEDE dose of 2x500-mrem (i,000-rrem) in one year under average mete~ological conditions,. A Notiiation of Unusual Event (NOUE) addresses a potential or actual decrease inth level of safetyof the plant asinditd by aradlo/lcalreleases thatexceeds regutatory commitments for an extended period. Foat Calhoun has 'incorporated features intenh'ded to conlrol the release of radioactive effluents to the e'nvironment. Further, these are administrative controls established to prevent unintentional releases, or control and monitor intentional releases. These controls are loae In the Offshe Dose Calculatin Manual. The ocourrence of ext~ended, uncontrolled mrad'oective releases to the envimrnment is Indictive of degradation in these features and/or controls.In accordance with reference (1) readitngs that exceed two limes the Technical Speiicto limit and not terminated within 60 mwiutes; th a NOUE shall be declared.This high alarm set point may be associated with a batch release, or a continuous release path. n esler csetpontsetpiti stabll~shed bytie ODCMto wamnof arelease that is not [n compl~ance with RETIS. Indexing the EAL threshold to the 00CM set points in this manoer insures that the E.AL threshold will never be less than the set point esteblished by a specifi discharge permit. Settig the EAL threshold to two times the hIgh alarm set point for a NOUE Is cornse~vatie with respect to an) instantaneous release of O.1-mrerm in any one hour TEDFE .For an ALERT emergency' classfifcation EAL, there exists a potential or actual decrease in the level of safety of the plant as Indicated by ,a releae that exceeds regulatory commitments for an extended period. Therefore, tn accordance with reference (1) a reading on any effluent monitor that exceeds 1Q-norero TEDE or 50-mrem CDE thyroid in one hour for 15 minutes or longer an ALERT s!ait be dclared.The Site Area emergency EA is based on radioactivity releases that result in doses at or beyond the sit boundary that exceed 10% (100-mrernihr TEDE or 500-mrem in one hour CDE) of the EPA .Protective Action Guides (PAGS) for 15-minue. Releases of this magritude are associated with the faiture of plant systems needed for th protection of the public. .. .I The GENERAL' emergency EA is based on releases that result in doses at or beyond the site boundary that meet or exceed the EPA Protective Acio Guides (PAGe). Publi protective actions will be necessary within Releases of this magnitude are associated wih the failure of plant systems needed for the prtcin of the public and rikely invotve fuiel damage.on acual me , wheras te monitor ,u~ EA~s me h resuls rowi heeassessments mosy Indicate that the clasiicto Is not wananted, or may indicate tha a higher classlflaailon Is wa .nte For thi ue~son,euiec Implementing procedwres sh~ould. call for the ftrmely perlonnance of dose actual nmetomlogy and releae informatin. If the results of RP-A-1 010 FC-1 6-003 (RA 13-008); PAGE 10OF74: ~REV7 1doe re available whe,. tte n l, made (e.g., The gross mornior set points are ccnservahely based on TEDE or CDE ca~cuaons r-aher than body, and takes into account the thyroid dose and effect on the body as a The NOUE process monitor EALs are x2 the efiluent Technical Specificaion set points found in reference (8) anid ALERT, SITE AREA and GENERAL EALs are based on percantages of the EPA PAGs reference (3)Recalculation of these monitoraction levels should be performed when calibrations and/or atmosn eic dispesin factors differ by more than 20%..An accur'acy of + 20% is consistent .witI Industry practices for radletln mon, toilrng equipment and follows the guidance found in relerenos (7), which states. .=for projected doses significantly above the dose Ilmis, accuracies of + 20% are recommen~ded." RP-AA-101 0 FCo1 5-003 (RA 13-008)PAGE 11 0F74 RE-V. 1 AppendixI EAL Setpoint (NOUE) for RM-043 process monitor EP-AA-1010 F-C-15-003 (RA-13-008) Rev. 1 Page Constants: Ci:=37.7-l~°BqI0 Bq0.01

• T m~=0.OOl-rerr k 0:=0.007 Iodine to Noble Gas Ratio F:=28750., afto Xovuei-Q .-- .3. lO0-fi01O i-pCi 3 BKG z-"36 -mrin-limit =500. mrevn yr Dose Conversion factors for 133-Xe and 13 1-I a DC .,=2.0 -OI0
• merr m Ci *hTr 3 DCTF 1:=2.2.1O,
• eo w=O.03 k 1:=0.75 Thyroid weighting factor Monitor error correction factor.Calculated 2x the Technical Specification Umit (500-mrem/hr):

/'r/10.11L hr Hz= Round (H,0.1-~T Calculation Page Pag~e ! of 2 EAL Setpolnt (NOUE) for RM-043 process monitor EP-AA-1010 FC-15-003 (RA-13-008) Rev. 1 Page -! Calculate the setpolnt based on a site boundary dose in any one hour Gross release rate: xovr. 0 o. ()XP, +w=.fXEF,)) Monitor SetpoInt: R= (3.367. lO') Calculate appropriate setpoint as the EAL threshold.m-'[IIe II [else -EAL (3.367.1&o) Calculate the Site Boundary Concentration: x = Q. XoverQ Calculation Page Page 2 of 2 EAL Setloint (Aje-t) for IRM-043 process monitor EP-AA-1O1O FC-15-.003 (RA-13-008) Rev. 1 Page -:: of Con..ants: C l'.LBq /_Ci:= 3.7-10" oIq iom;= 0.O1 .Sv wnr crx==.00.1 .rcrn k6=0.007 Iodine to Nobie Gas Ratio F=2875O'.c/m -3 e+/---2.33.°1O 7 o BKG=36 TEDE = 10. mrm ne Dose Conversion factor for 133-Xe and 131-I.!DCFp, z.2.0.10 .eor. DCF 1.:=2.2 .10 e )CFth,==.3° 10 .C i, r C .hrCi, hr w-= 0.03 Thyroid weighting factr~=0.75 Monitor error correction factor.Calculate the setpolnt based on a site boundary dose in any one hour Gross release rate base on TEDE: TEDE xoverQ. (F, + w. 7F,))Q=2.612 .Calculation Page Page 1 of 3 EAL Setpolit (Alert) for RM-043 process monitor EP-AM-101O FC-1S-003 (RA-13-008),Rev. 1_o~Monitor Setpoint (TEDE): R= (3.364. 1o 5) mm-'Gross Release Rate based on (CDE): QCDE Xo,,TQ Ci Quhv= 0, 2 S --MOnit" Setpoint (CDE):.)c 1 + BKG(5.444. io:') m-irJ'Calculate lower setpolnt as the EAL threshold II=IIIfRRu,,' ele.s-(&54.1.&o) mir-'II JjEBAL4-O95sp Actua! l EAL Calculation Page Page 2 of 3 EAL Setpoint (Alert) for RM-043 process monitor EP-AA-I0I0 F-C-15-003 (RA-13-008) Rev. i Page jka'f '" If the EAL is 0 the EAL threshold Is off-scale hlgh and alternate measures are needed.EAL='1 if EA> 10 7 .rrn-'liii A4s-- cta2(5.4.44 -( .1-&) Calculate the Site Boundary Concentration: x.-Q .Xovr Gross TEDE Gross CDE x=(3.395'10-') X,=(5.495 .i0- j _Calculation Page Page 3 of 3 EAL Setpoint (Site Area) for RM-O43 process monitor EP-MA-1010 FC2-15-003 (RA-13-008) Rev, 1 Page Constants: G:-=3.7,10O oq rem:=O.O1I.3v mr~m =0,001 ,Ter/so=0.00 7 Iodine to Noble Gas Ratio F,=28750. ofin XoverQ.= 1.3.10-.O---~ BKG:=36-min- CD'0 -~~TEDE:=1O.............

DE -O--7 ,C hr hr Dose Conversion factors for 133-Xe and 131-I l~ 'no DCF,:=2.2.10 2.* r~ DCF~,&= 1.3-10 .Cefor i hr Ci

• w.=0.03 Thyroid weighting factor/k -=0,75 Monitor error correction factor.Calculate the setpoint based on a site boundary dose In any one hour Gross release rate base on~ TEDE: Q TEDE Calculation Page Page 1 of 3 EAL Setpoint (Site Area) for RM-043 process monitor EP-AA-101O FC-15-003 (RA-13-008)

Rev. I.Monitor Setpoirit (-TEDE): R= (3.364. 1o) mi-1 Gr'os Release Rate based on ((DE): CDE Q,-XoverQ. (k 0Monitor Setpoint (CDE): Calculate lower setlpoint as the EAL threshold II els II Kretr II IIII o9-II else Actua- EAL Calculation Page Page 2 of 3 E.AL Setpoint (Site Area) for RM-043 process monitor EP-AA-1O1O FC-15-003 (RA-13-008) Rev, 1 Page .J~L of _-w-:.t If the EAL is 0 the EAL threshold is off-scale high anid alternate measures are needed.EAL-- I if EAL> II[return EAL Calculate the Site Boundary Concentration: xt=Q.Xcn'e~rQ Gross TEDE uXwr Gross CDE X= (3.395~ -Ci..Calculation Page Page 3 of .3 EA.Stolnt (General) for RM~-043 process monitor EP-AA-1010 F-C-15-003 (RA-13-008) Rev. 1 Constants: Ci:= 3.7d01 0 m. q u0i~=3.7.10t or := .01 .S.v k 0 ,zO.O07 Iodine to Noble Gas Ratio F=28750.cfm 1.3. 10-s--e;=2,33,107.. -BKG=36.mtn-1 TEDE=1O0O. mr~ CD=50 .__LJ2 Dose Converslon factors for 133-Xe and 131-Iemr. -eo LC:=L.& D w =0.0,3 Thyroid weighting factor/.--0.75 Monitor enror correction factor.Calculate the setpoint based on a site boundary dose in anty one hour Gross release rate base on TEDE}E Q TEDE Calculation Page Page 1 of 3 EAL Setpnt (General) for FM-043 process monitor EP-AA-101O FC-15-003 (RA-13--008) Rev. 1 Page MonitJor Stpoint (TEDE): R~=(-9 R= (3.3a4. 108) m-in-Gross iRlease Rate based on (CDE): Q CDE xovr. (ko. DC'F,=)Quy= 4.?.265 Ci Monitor Setpolnt (CDL=): F Th 1= io 7) m.Th-k Calculate lower setpoint as the F.AL threshold rI[ IreALI0u 5 Ii els Acua Calculation Page Page 2 of 3 EAL Setpoint (General) for RN-043 process monitor EP-MA-1OiO FC-15-003 (RAk-13-OOS) Rev. 1 If the EAL is 0 the EAL threshold is off-scale high and alternate measures are needed.EAL.-- I if EAL> I0 -min-4 1]IIEAL+-Omin-' EAL=O min-1 Actu --=(5A7.1f 7 11) mniln-Calculate the Site Boundary Concentration: x:=Q.XoverQ Gross TEDE Qa 1 .Xove'rQ GrossC(DE=- 003o-- x = (5.49)s.'10-) 3;rf a~Calculation Page Page 3 cof 3 EAL Setpolnt (NOUE) for RM-052 process monitor EP-MA-1010 FC-1S-003 (RA-13-008) Rev. 1 Page Z _74 Constants: Ci:=3,7.1O 0 .13 .13q /%=0,007 lodinieto Noble Gas Ratio F~=24167ocfrn 6=- 2.24.107. -_ BKG:--70.mnr -l Limit=5Q0,O- 3 Dose Conversion factors for 133-Xe and 131-I)XTF,, 2o_ I, DFp2.2.102 .-ei l__ C /% :=0,75 Monitor error correction factor Calculated 2x the Technical Specificatdon Uimit (500-mremlhr): day jr J H= 0.114 hr H =Ro0,1(H 0.1.F Calcuiation Page Page 1 of 2 EAL Setpoint (NOUE) for RM-052 process monitor EP-AA-1010 FC-15-003 (RA-13-(008) Rev.,1 Page o, __Caiculate the setpoint based on a site boundary dose in any one hour Gross release rate: H Xoe. + k 0 (DOTF, + =. TF,))Q--o.026 Monitor Setpaint: R = (3.854 .O 1)+ran-Calculate appropriate set~point as the EALtlhreshold "1 IEAL4-o-95"R II else IIJIEAL,,-R Calculate the Site Boundary Concentration: X=(3.395'10 7-) 131 Calculation Page Page 2 of 2 EAL Setpdnt (Adert) for RM-052 process monitor EP-AA-1O10 FC-15-003 (RA-13-008) Page & of "I"i Constant~s: Ci=3.7,101°.Bq 3.7-10' .Eq =0.01o Sv ~ka = {.007 Iodlre to Noble Gas Ratio F:=24167.r caa XoverQ=--1.3, e~22.o 7 BKG =-70() o =I0. :rr~e CD .... flLeCrh, uCi h,r hi',1 Dose Conversion factors for 133-Xe and 131-I DCF, 9 = 2.0o 101o~e( ° DCF:= .2'&* DC~: .34 00 ,.*rem ~Ch DF :2-10 Ci, ]r Ji ohi'w~=O.03 Thyroid weighting factor k 0.75 Monitor error correction factor.Calculate the setpoint based on a site boundary dose in any one hour Gross release rate base on TEDE: Q TEDE" Q =2.612 Calculation Page Page 1. of 3 EAL Setpoint (Alert) for RM-052 process monitor EP-AA-1010 FC-15-003 (RA-13-008) Rev. 1 ., Page ___/! of1:.Monitor Setpoint (TEDE): R= ( 9 "."ki)+ BKG£R= (3.847-10&) rmin-Gross Release Rate based on (CDE): Q CDE Ci0.423 --8 Monitor Setpoint (CDE):--- .s. k,+ BKG Calculate lower setpolnt as the EAL. threshold sp=I[ if R>Thy II sp~a/= ( E2.is mn Cac Eatio Page Pagep 2Oo*m3 EAL Setpoint (Alert) for RM-052 process monitor EP-AA-1010 F'C-15-003 (RA-13-008) Rev.i : , If the EAL is 0 the EAL thresholdl is off-scale high and alternmate measures are needed.EA-if EAL,> 10 .mm-jj I rtr .,.T-u= (6.226.1&o) n,, Acua= (&.26. 1o 6) Calaulate the Site Boundary Concenlmton: x :=Q .Xove'rQ Gross TEDE Xo1,eTQ Gross CDE x=(3.3§5.' +=54.1-), CalcuIation Page Page 3 of 3 EAL Setpoint (Site Area) for RM-052 process monitor EP-AA-101O FC-15-003 (RA-13-008) Page 2 of __Constants:,q Ci.--3.714O -. rcm:=0.01oSiv koz=O.007 Iodine to Noble Gas Ratio F:=24167,cfr , ,-1 z'-2.24,10' .in BKG-=70,.r7n-TEDE.--OO0.

toer CDE,--50O.-rn.

Dose Converson factors for 133-Xe and 131-I 3 I: 3 DCF,~ z_2.0.10'o ~ DCFp ==2.2.10 ye're, or DCFt,:=1,3,10U

• ____,o_Cicohr Ci ohr Ci o hr w'-0.03 Thyroid weighting factor/ic 2=0.75 Monitor error corraecton factor.Calculate the setpoint based on a site boundary dlose in any one hour Gross release rate base on TEDE: XoeQ .-- +~.(DF+~DF)

Calaulation Page Page 1 of 3 1A1 ~ah~ninI" ('~itA Arn~i~ fnr ~M4~) nrvv~ce nin,~iMr S-,-, .... *' .. ......v. ..... EP-AA-1010 FC-1S-003 (RA-13-008) Rev. 1 Page .2. of Monitor Setpoint (TEDE): R=(9 ..-k)+BKC R= (3.&47- 1o) mrin-Gross Release Rate based on (CDE): Q CDE c-Monitor Setpoint (CDE): F(6.226.1I06) mi&-'Calculate lower setpolnt as the EAL threshold sp = (6.226. I0 6) main-lIi II ILO9~EA/.Calculation Page Page 2 of 3 EAL Setpoint (Site Area) for process monitor EP-AM-i0i0 FC-15-003 (RA-13-008) Rev. 1 If the EAL is 0 th EAL threshold is otf-scale high and alternate measures are needed.EAL,-IIif EAL> 10 1 .mn~n-'else V[Ireturn3 A EAL= (6,226 106) wiz-' Achtua = (6.226.10&) mmn-calculate the Site Boutndary Concentration: x= Q .XoverQ Gross TEDE! XoveTQ Gross CDE 3=33~*i~ IL__Calculation Page page 3 of 3 EAL Setpoint (General) for RM-OS'2 process monitor EP-AA-1010 FC-15-003 (RA-13-O08) Rev. I Conlstanlts: Qj:=3.7-.10l Bq /Ci 3.7.- I0 ,ti re'n .O.O1 *Sv mrem0.-=O.1

• rem k 0:=1.007 Iodine to Noble Gas Ratio F--24167.cf'n XoverQ=L3.10--"-RKAGr=70-.mn-'

TEDE= IO00 Dose Conversion factors for 133-Xe and 131-I 3 3 3 rCF =2,-10 m TT F=22.0

• Ta... rew .m w- 0.03 Thyroid weighting factor k 1=0.75 Monitor error crorrect~on factor.Calculate the setpoint based on a site boundary dose in any one hour Gross release rate base on TEDE: TEDE Xovei. ko. (DcF, +weWFC) )Q=261.183

..i Calculation Page Page 1 of 3 EAL Setpolnt (General) for RM-052 process monitor EP-MA-10I0 FC-15-O03 (RA-13-008) Rev. 1 Monitor Set~polnt (TEDE): R= (s.847- 1o3) mam-Gross Release Rate based on (CDE): Q Ci Qmu= 42,.265-S Monitor Setpont (CI)E): R .=-u .t+ K F(6.26.1lo 7) Calculate lower setpolnt as the EMt threshold 5~Dif R>R~v UIelse II -sp=(6.226.10

7) mam l]IIE~ ..Actsai EAt Calculation Page page 2 of 3 EAL Setpoint (General) for RH-052 process monitor FC-15-003 (RA-13-O08)

Rev. 1 Page of If the EAL is 0 the EAL threshold is off-scale high and alternate measures are needed.EALJ---.' if EAL >10 1 .min'-[]II E _ -0. d -"else EAL = 0ari'-1 Ada= (5.914-10 7) -Calculate the Site Boundary Conce~ntration: X:=Q.Xo~e'rQ Gross TEDE x~;= Gross (CDE n=.0 er_ C Calculation Page Page 3 Cl 3 EAL Setpoint (NOUE) for RM-057 process monitor EP-MA-1OI0 FC-15-003 (RA-13-008) Rev. 1 Constants: Ci :=3.7 *10O°.Bq 'C 3..i B m=.1.v 'n'r d.O e Iodine to Noble Gas Ratio PF=32O. fin X-overQ=_1.3.104. s e._=5.94,1~ i0 Ez KG~=820..~m Li- .... .. zr: Dose Conversion factors for 133-Xe and 131-I!DcFI:=2.O.1IO DGF¢z=2.2.lO2 reor DG:Fth:=1.3.10. emr Ci. hr Ci ohr, Ci ohr w=O0.03 Thyroid weighting factor k 1 ~=0.75 Monitor error correctdon factor, Calculated 2)( the Technical Specification Umit (500-mrem/hr): H=0.114 -H:=P~td HO I h )H=0l.1.nv'r hr Calculation Page Page 1 of 2 EAL Setpoint (NOUE) for RM-057 process monitor EP-AA-1010 FC-15-003 (RA-13-008) Calculate the setlpoint baseg on a site boundary dose in any one hour Gross release rate: Q :H Q=O.00 Monitor Setpont: R =(8.833. lob) Calculate appropriate setpint as the EAL threshold II II else-- (a.s3s.ilo') 1 Calculate the Site Boundary Concentration: y :==Qo XoerQ Calculation Page Page 2 of 2 EAL Setpoint (Alert) for RM-057 process monitor FC-15-0003 (RA-13-008) Rev. 1 Page &Li~tof Constnts: Ci-'=3.7.10O -Bq CO{3.7-10O °Bq rm;z= 0,01.S, mrTrn:=IO.OD1.* Trn k 0;=0.065 Iodine to Noble Gas Ratio F= 320., elfm XoverQ:= 1.3 a*:.41

• BKG :=820- TEDE--O 0* rnrrn O _u o Dose Conversion f'actrs for 133-Xe and 131-I w:=O0.3 Thyroid weighting factor/ =0.75 Monitor error correctin factor.Calculate the setpoint based, on a site boundary dose In any one hour Gross release rate base on TEDE: TEDE Calculaion Page Page I of 3 EAL Setpoint (Alert) for RM-057 process monitor EP-AA-010 FC-15-0003 (RA-13-008)

Rev. 1 Monitor Setpoint (TEDE): R= (8.832. ion) mi-(Gross Release Rate based on (CDLE): Q CDE F Calculate lower setpolnt as the EAL threshold sp~sp i-- R>R, V1 else 11II ,-.sp= 1&) mi-1 II Sreturn EA.L A~tUIA stEAL Calculation Page Page 2 of 3 EAt_ Setpoint (Alert) for RH-057 process monitor EP-AA-101O FC-15-0003 (RA-/3-008) Pav1 If the EAL Is 0) the EAL threshold is off-scale high and alternate measures are needed.EA.-,'- if EAL>L4S4&,0 .ral-I 11 I E.kL'- -1 Ieise re[urn --L EA.L-(1.343-10&) m;4 sn- Actuta1= (1.343.10 ~) Calculate the Site Boundary Concentration: x=Q.Xover Gross TEDE Gross CDE"y Calaculation Page Page 3 of 3 EAL_ Setpoint (Site Area) for RM-057 process monitor EP-AA-1010 F'C-15-003 (RA-i3-008) Rev. 1 Conslants: ko=O.065 Iodine to Noble Gas Ratio XoverQ =1.3.10-' " ,-1 g==5.94.1Qu -~ ma BKG:=820.ra~in-TEDE=IO00. CDE,=500. axi r hr Dose Conversion factors for 133-Xe and 131-I DCF320 0 ____ Tern rn em I /F 1 .=2.2 .102 e~

• -.______Ci ° hr Ci, .hr i°h w -=0.03 Thyroid weighting factor:=0.75 Monitor error correction factor.Calculate the setpolnt based on a site boundary dose in any one hour Gross release rate base on 1TEDE: Q TEDE XvQ.(DCF +k~ (DLF,+wI F~)Calculatio Page Page 1 of 3 EAL Setpoint (Site Area) for RM-057 process monitor EP-AA-101O F=C-1-003 (RA-13-O08)

Rev. 1 Monitor _Setpint (TEDE): R:=(9....kI)+BKG R = (8.832. I0°) rr, n-Gross Release Rate based on (CIX): Q ODE Qu,,= .455 c.-_Monitor Setpoint (CDE-): Rum= Q* +BKG F Calculate lower setpoint as the EAL. threshold sp+/-(i.a4. 1o 9) ,min-EAL-isl48O rrmn-II l EAl*--0-95"e' II else I return EAL Actual. EAL Calculation Page*Page 2 of 3 FA! fnr mnnitnr-----I--, F ....wir f'1- ...... f' ........ nw" c .. ......... FC-15-L-O03 R.Page_44 of_..$If the EAL Is C) the EAL threshold is off-scale high and alternate measures are needed.iAL='EAL> 1.48-10O -mird~t-liiiEAL4---0rap EA.,=O 0 mn .Actui= (1.276.1lOD) Calculate the Site Boundary Concentration: X~=Q .Xove-Q Gross TEDE Gross COE Calculation Page Page 3 of 3 EAL Setpoint (General) for RM-057 process monitor EP-AA-1010 FC-15-003 (RA-13-008) Rev. 1 Ci ::_3.7-10 1 o~q jC 437 ,0 .q ~ r~0Oi.S =.O Iodine to Noble Gas Ratio F,--32O. -jm. Xoer~.31*-- .TED., 1O.~-2---~ D 3 50.L2 Dose Conversion facto~rs for 133-Xe and 131-I DC( 2 0.0 Gi °hr Ci htr Ci ,:. hr==0.03 Thyroid weighting factor.--0.75 Monitor error correction factor.Calculate the setpoint based on a site boundary dose in any one hour Grass release rate base on TEDE: Q TEDE XoeQ W, 9+ ko. QX, 'DCF, ) )Q=29.939 Calcuiation Page Page 1 of 3 EAL Setpolnt (General) for RM-057 process monitor EPA-11 FC-15-003 (RA-13-008) Rev.,1 Page 4 of ~Monitor Setpoint (TEDE): R-"(&8.32.10"') rain-Gross Release Rate based on (CDE): CDE c-_S Monitor Setpolnt (CDE):t=- 1 +BKG F~=(.4.z o i-Calculate Jower setpoint as the EAt threshold sp =(1.3434o1'o) mm 1--A u 873rp>1.48-10= mr I[ JEAL i-- .95. sp II else Aci-L=EAL Calcuflation Page Page 2 of 3 EAL Setpoint (General) for RM-057 process monitor ~1I C1-0 R-3O8 Rev:L Page._.<.o -If the EAL is 0 the EAL threshold is off-scale high and alternate measures are needed.EA-T ff AL>L148.10& .mi-1 E-4L =0 m in- Actua- (1.276. IO 0') Calculate the Site Boundary Concentration: x'=Q.XotverQ Gross TE'D Gross CDE X= (3.&92 o !0) 11 fh =(.1. 0 U:; 3 Caiailation Page Page 3 of 3 EAL Setpolnt (NOUE) for RM-062 process monitor EP-AA-010 FC-15-O03 (RA-13-008) Rev.1I...Z Page _ of Constants:tO'1e .L~ 7C==3.7.10 4 dBq mrn ,,=O.OOl,.r rn k~:OO7Iodine to Noble Gas Ratio P=24167. XoierQ r= e1810' BKG r=-50*.a,&. Limri.--O- ,'u rn.Dose Conversion factors for 133-)(e and 131-I DC ~~.O 1... DGF,:= .2,1O °- 1)CFo'-"1.3.1 I -~~w= D.03 Thyroid weighting factor k 1 =0.75 Monitor error correction factor.CailcaGted 2x the Technical Specification LUmr (500-mrern/hr): l 24 6525 -t day yr )H= 0.114 rve~nm H=P~und )Fl=0.1 Calculation Page Page 1 of 2 EAL Setpoint (NOUE) for RM-062 process monitor EP-AA-1O10 FC-15-003 (RA-13-008) Calculate the setpint based on a site boundary dose in any one hour Gross release rate: H~xove. (DCTF, ++/-k°. (WF, + Q=O.026 Monitor Setpolnt: R =(3.251.* rw. -'Calculate appropriate setpoint as the EAL thresold II else Calculate the Site Boun~dary Concentration: x z=Q "XomerQ x =(3.395. io-) !+/-%Calculation Page Page 2 of 2 EALd Setpoint (Alert) for RM-062 process monitor EP-AM-1O1O FC-15-003 (RA-13-O08) Rev. 1 Pae41of L Constants: C: = 3.7.*1O 0.w q -- .7.lO *L rg Sv rrmw .01.rcrn k+/-OO7 Iodine to Noble Gas Ratio F--24167°cfim Xover:= 1.3-10%-.--- (~L9.1 7.KG~=5O~niW' TED=1O--m'hr hr Dose Conversio)n fctors for 133-Xe and 131-i"5 ohr Cy° r n r w=0.03 Thyroid weighting fact~or ks 1=0.75 Monitor error correction factor.Calculate the setpolnt based on a site boundary dose in any one hour Gross release rate base on TED: Xo'vr- ko. (ECF, C~alculatio Page Page 1 of 3 EAL Setpolnt (Alert) for RM-062 Ipracss monitor EPA-M010 FC-15-003 (RA-13-008) Rev. 1, Monitor Setpolnt ("EDE): Rt=(9.e "kl) +BKG R= (3.24g.1o 6) rain-'G;ross Re~ease Rate based on (CDE): CDE Monitor Setpoint (CDE):-(.25. los) min 1 Calculate lower setpolnt as the EAL threshoad sp=II II else s-- I5.253.lo 8) II *95a,-II else Acua =EAL Calculation Page Page 2 of 3 EAL Setpolnt (Alert) for RM-062 proces monitor EP-AM-1010 FC-15-003 (RA-13-008) Rev. 1 .-Page __u of.25If the EAL is 0 the EAL threshold Is off-scale high and altrnate measures are needed.EA~"if RAL> 10T* n.m~n-else_-=(5.253.1O

5) Acta=(5.25.Io&) Calculate the Site Boundary Concentration:

x;=Q.XoverQ Gross TEDE Gross CD)E 3r, r Calculation Page Page :3 of 3 EA. Setpoint (Site Area) for RM-062 process monitor EP-A-1010 FC-1S-O0 (RA-13008) e.Page of i Constants: C =3.7.. 0 .Lq p C{=3.7- I04 oFq .Sv me --t0.001,.rer k 0:=0.007 Iodne to Noble Gas Ratio F.--24167, XoverQ.--

13. mr 621891

• BK:= 5O,. mvm -t TED"= 1O.--L CDE .--500.-Dose Conversion factors for 133-Xe and 131-I 3', 3." ..0 i 2.0.1
• i0 1Xr, 1:= 2.21O. D02 -=1"3.10 Ci .Its C{. hrCi oAr w = 0.03 Thyroid weighting factor k 1=0.75 Monitor error correcton factor.CalcuLate the setpolnt based on a site boundary dose in any one hour Gross release rate base on TEDE: TEDE Xoter. (DCF, + )Calculation Page Page 1 of 3 EAL Set~point Area) for RM-062 process monitor EP-AA-1Ol0 FC-15-003 (RA-13-0O8)

Rev, 1f/Page Monitor Setpoint (TEDE):-[.(Q k)+ a R= (3.246.1O 7) rmin-Gross Release Rate bae on (C:DE):4.227 --S Monitor ,etpoint (C:DE):~ =(5.253.1o8)mn Calculate lower setpoint as the EAL threshodd IIel Il=EAL.p Calculation Page Page 2 of 3 EAL ,Setpoint (Sfte Area) for RN-062 process monitor EP-AA-1010 FC-15-003 (RA-13-008) Rev. 1 Ifthe EAL is 0 the EAL threshold is off-scale high and alternate measures are neededh ,, 3 3L EA=(.23.0 8Atui=(.531O),~~ Calculation Page Page 3 of 3 EAL Setio~nt (General) for RM-062 process monitor EP-MA-1010 F-C-15-003 (RA-13.-008) Rev, 1 Constants: k 0 ,=O.007 Iodine to Noble Gas Ratio F---24167.<f. XoverQ= 1.3.1(-f' e,=1.89.10.

• z BKG:50°o i CDE:=z5000.

mr'm Dose Conversion factors for 133-Xe and 131-I Ci o hr ~Ci oAthirh w =0.03 Thyroid weighting factor k 0.75 Monitor error aorrection factor.Calculate the setpolnt based on a site boundary dose In anty one hour Gross release rate base on TEDE: TEDE Q=26 6 Calculation Page Page 1 of 3 EAL Setpoint (Genieral) for RM-062 pmoces monitor EP-AA-101O FC-15-003 (RA-13-008) M~onito~r (Th-): R= +BKG R= min'-Gross Release Rate bae on (CDE): Q CDE Monitor Se-tpolnt (O)E): Calaulate lower as the EAL threshold II else EAL-z=llif>sp .o 7-*II else Ac-'L =EAL, Calculaton Page Page 2 of 3 EAL Setpoint (General) for RM-062 proces monitor EP-AA-tOlO FC-i5-003 (RA-13-008) Rev.Pane of 7SL If the EAt. Is 0 the EAL threshold is off--s~le high and alternate measures are nede.E~Z=II AfEA.L> 10 mi' n -r 'III ret -O- -A.BA,=O w'= n.Calculate the Site Boundary Concentr"ton: X r=-Q. X(Au'Q Gross TEDE x=O.O 0 3 3m Scri Gross CDE Calculation Page Page 3 of 3 EAL Setpoint (NOUE) for RM-063 process monitor EP-M-1O10 FC-15-003 (RA-13-008) Rev.1 Page .~ of i~-Constants: CL "=3.7 -1010 ,D rem -'-=O. 01 -Sv mrem.' 0.001 .rem/c%,=0.007 Iodine to Noble Gas lRaUo F'= 24167. L3.310~ *-.--m Dose Conversion factors for 133-Xe and 131-I DCF~'= 20. i i. r0 h*DC I=,. 2rem, o~'fl6 Tm.Czo hr iot k 1:=0.75 Thyroid weighting factor Monitor error oxrectlon factor.Calculated 2)( the Technical Specdfication Umit (500-mrernlhr): ___Limrt H="24.2HZ" °385.25.H=0.1U4 m"*'"z H=O.1 Calculaton Page Page 1. of 2 EAL Setpoirt (NOULE) for RM~-063 process monitor EP-AA-1010 FC:-15-003 (RA-I.3-008) Rev. 1 " Calculate monitor concentration and off site con centration: Gross re~ease rate;Q H xo,,e-Q. ko. w.WFc-,.)) Monitor- Concentration: F o = 0.002 i5Li aRM-062 would not have shifted to this mointor becuse the couJnt rate Is < 5E+O06-cpm Calculate the S~te Boundary Concentration: x Q: x= (3.395.io-') 3Calculation Page Page 2 of 2 EAL. Setpaint (Alert) for RM-063 process monitor Costnts: k/%=O.007 Iodine to Noble Gas Ratio TEDF --10 DE -5 o rat EP-AM-1O10 FC-1S-003 (RA-13-008) Rev. 1 w =0.01. *v 001.~F = 24167.c~fa XoVeTQ:= 1.3.10.5Dose Conversin factors for 133-Xe and 131-I S 3 rem~ ... .... rerIe emre.w =0.03 Thyroid weighting factor k 1'=0.75 Monitor error correction f-ctor.Calculate the monitor concentration and oraste concentraton: Gross release rate base on TEDE: Q TEDE Xo, veaQ .k. (WPY,++/-w WFte,) )Q=2.612 Calculation Page Page 1 of 2 ied Uo i[ Od JmuouJIUOW, Siq pe~jqs pjfnoM e~go-Il si U aQUo~ a~ sne :3JOj 1< o'=7Y~UI =...f..I,* ' rruoj~u~ EAL Setpolnt (SAE) for RAM-063 process monitor Constants: Ci:= 3.7- Ol o~ 10 4 -Bq k 0-=O.aO7 Iodine to Noble Gas Ratio TEDE~= I00o -GDI=SOO-- , hr hr EP-AA-1O1O FC-15-003 (RA-13-OO8) Rev. 1-Sv nrm := 0.001. * ;ma F= 24167. XoverQ:---1.3.1O

• .0~a Dose Conversion factors for 133-Xe and 131-I DCF. :=2.0. I0' ."rio____J DYF 7 p= 2.2102 .L2:-_!L DCF =I.3.1o 6.-----tn=0.03 Thyroid weighting factor k% ~=0.75 Monitor error correction factOr.Calculate the monitor concentration and offsit concentration:

Gross release rate base on TEDE: Q TEDE xovr. + k. Calculation Page Page 1 2 EAL Setpoint (SAE) for RfM-063 process monitor FC-4S-003 (RA-13-008) Page. oL51 Monit.r Concet:aion CfEDL=): F Gross R elea.e Rate based on (CDt): C'DEMonitor Concentration (CDE):, FO.3 7.1 SIIELC EAL= 0.371 RN,02 w Caleculate the Site Boundary Concentration: x=Q.Xovr TEDE x (a.96 a o')muse the concentration is >5E-3 Sfhave shifted to this monitoro c Gross CDE Calailation Page Page 2 of 2 EA~L Setpolnt (General) for RM-063 process monitor Constat:=..10 ko~=O.O07 Iodine to Noble Gas Ratio TEDEi= 1O00. m CDE'.=5002o n~re EP-MA-1010 FC-15-003 (RA-13-O08) Rev. Page k,/'of = .OISv e:= 0.001

• F= 24167, wm XoverQ := 1.3.O rn Dose Conversion factors for 133-Xe and 131-I 1X7F,9=2.0.

101

• _DFF22 102 ' TF 3 ;~w+/-=0.03 Thyroid weighting factor k 1 =0.75 Monator error commdon factor.Calculate the monitor concentration and offslt concentration:

Gross release rat base an TEDE: Q TEDE Xoq,eQ. (WXF, + ko.(D rw1YF)Calculation Page Page 1. of 2 EAL Setpoirnt (General) for RM-063 process mnonitor EP-AA-1O1O FC-15-003 (RA-i3-008) Monitor Concentration (-EDLE): F C--22-898 ,u, L 3 Gross Release Rate based on (CDE): Q CDE Q -Xo,,erQ. (ko Monitor Cnncantmtfion (C]DE): F CO=v=3.706 iCj EAL,= II if IL else EAL=3.706-"C KOTh: Because the concetato is >5E-03 /3CRM-062 would have shifted to this monitor Calculate the Site Boundary Concentmatlon: x-= Q.XoverQ GrOss TEDE Gross CDE Calcuaton Page Page 2 of 2 EAL Setpoint (NOUE) for RM--0-,t process monitor EP-AA-1O1O Frc-15-003 (RA-13-008) Rev. 1 .Page Constants: Gi = 3.7.1 -0°.

• Bq r~m ---O.01 o~v /%=0.065 Iodine to Noble Gas Ratio F=5823.c!pm 1.3- 10 .*=.410.' -BKG= 19° 1 Ii=50u0. ,-r-UCL 3 cmf Dose Conversion factors for 133-Xe and 131-I DCF .L2J1on__

DCF:f= 2.2.10 2*____ .fF,=.3 10 fl1?919 hrCio h* 1XiF o h.uw =0.03 Thyroid weighting factor , =0.75 Monltor error cor-ection factor.*=1.0 steam density correcton Calculated 2x the Technical Spedfi"catlon umit (500-rnrem/hr): L d ay yr ).HzO .114 ma hr c~mcr Page 1 of 2 EAL Setpoint (NOUE) for RM-064 process monitor Calculate the setporn based on a site boundary dose in any one hour Gross release rate: Q H Q= o.o03 Monitor Setplnt: R= 19.025 Calculate approprate setpoint as the EAt. threshold EAL:"l f R>10 *msi-i II EP-AA-1010 F-C-15-003 (RA-13-008) Rev.1 ,1 Page k of 1.4= 19.025 rnr'1 NOTE: The reading is slightly, over background and would not provide an adequate value for an EAL threshold Calculate the Site Boundary Concentration: Calouatiaon Page Page 2 of 2 EAL Setpoint (Alert) for RM-064 process monitor EP-AA-1O10 FC-I5-003 (RA-13-008) Rev. 1 Page _.Li_Constants: Xouer,= 13-10 ko =0.065 Iodine to Noble Gas Ratio F~=5823.~r Xove,-=L3.1O t~.4.0 d.z KG:=lgo.min TEDE=IO. "L CDE;=&O. e'hrh'r-1q%Dose Conversion factors for 133-Xe and 131-I LUF, := 2,04 10

• DCF 1._ 2.2. i0 2 .r~mo. JgF : 1.3 I0 eom, w =0.03 Thyroid we.ighting factor , =0.75 Monitor error correction fadnr.1: Steam density correction Calculate the setpolnt based on a site boundary dose in any one hour Gross release rate base on TEDE: Q TEDE Calculation Page Page 1 of 3 EAL Setpoint (Alert) for RM4-O64 process monitor Monitor Setpolnt (TEDE):-( .k 1 .B-*R= 21.484 mmn-Gross Release Rate based on (C.DE): Q CDE Monitor Setpolnt (Q)E'): R,= 19.37S main'Calcul~ate lower setpoirnt as the EML threshold 8p= iif R>Rvq sp =19.378 mmn-EP-AA-iO1O FC-lS-O03 (RA-13-008)

Rev 1 ;EAL=ffsp1O 7 ri-else re~turn AL Actual ---EAL Page Page 2 of 3 EAL Setpoint (Alert) for R1406 process monitor EP-M-1O1O FC-15-003 (RA-13-008) Rev. 1.~ge4~ofi~If the EAt- is 0 the EAt. threshold is off-scale high and alternate measures are needed.EA='If EAL >10 7 -ii EAL= 19.378 n Actul= 19.378 -1 NOTE: The reading is ~0.4-c:pm over background and would not provide an adequate value for an EAL threshold Calcutate the Site BoJndaiy Corncenfration: x'-Q .XovuerQ Gross TEDE Xth Qt, ,. Xove1Q.7 Gross C..E calculatlon Page Page 3 of 3 FEAL Setpoint (Site Area) for RM-064 process monitor E.P-AA-1010 FC-15-003 (RA-13-008) Rev. 1 Constants: /%.--0.065 Iodine to Noble Gas Ratio F=5823.cfmn XoverQ= 1.3'10~ -.----Dose Conversion fadxors for 133-Xe and 131-4 3 3 3 wv =0.3 Thyroid weighting factor k 2%=O.75 Monitor error correction factor.k,= 1 Steam density correction Calculate the based on site boundary dose in any one hour Gross release rate base on TEDE: TEDE Q =2.994 --Calculation Page Page 1 of 3 EAL Setpolnt (Site Area) for RMI-064 process monitor EP-/M-1O1O FC-15-003 (RA-13-008) Re'.l.Monito Setpoint CrEDE):R =43.839 mmi-Gross Rl~ease Rate based on (CDE): Q CDE -_Monitr Setpolnt (CDE): R,,+-" 22.776 mmi 1-Calculate lower setpoint as the EAL threshold II , , II Ie l .-.sp =22..776 mm'+-E...1 1 1f Calculation Page Page 2 of 3 EAL Setpoint (Site Area) for RI'-064 process monitor EP-AA-1010 F-C-15-003 (RA-13-008) Rev. 1*If the EAL Is 0 the EAL threshold is off-scale high and aiternate measures are needed.1]Ii HEAL4-omM'- U enL EAL =22.776 mittir Aet~ua= 22.776 min-i Calculate the Site Boundary ConcentraUon: x:= Q XoverQ Gross TEDE Qu-XemerQ Grass CDEer ?e'Z ra Calculaton Page Page 3 of 3 EAL Setpoint (General) for RM-064 process monitor EP-AA-1010 FC-15-003 (RA-13-O08) Rev, : Page _¶Constants: C3/4 ==3.7.*10° o~3q 1 iCi ' 3.7.*104 0.01 -Sv. .:0.001

• re'j,,r ko-=O.0O5 Iodine to Noble Gas Raijo F7=5823oacf XovoerQ= -.1O *s..-' mv-- BG= TEDE=1000.

mC, DE 1,hr Dose Conversion factors for 133-Xe and 131-I 3 3 ,3 DOF,? .=2.0.10* o )JF = 2.2 .102 .remo.m DCF 1=3.10a ...Ci rCiohr C{ w = .03 Thyroid weIghting factor k 0.75 Monitor error corecio factor.==1 Steam denit correcton Calculate the sepoint based on a site boundary dose in any one hour Gross release rate base on TEDE: Q= ThDE(DCF,+ Q=29.9 3 !.CaluaIon-ag Page 1 of 3 EAt. Sel~oint (General) for RlM-064 process monitor EP-AA-1010 FC-15-003 (RA-13-008) Rev. 1 Monitor Sfetpolnt (TEDE): R=267.391 main-1 Gross Release Rate based on (C:DE): Xo,--exQ. (ko .iXFo)Q0.=4.652 c.9 Monitor Setpont (CDE): R,.:=56.763 mm'-Calculate lower setpofnt as the EALt. breshold sp,: II if R., II else 8p 5 6.7 O 3 mim-Aculj HreturL Calculatio Page Page 2 of 3 EAL Setpoint (General) for RM-O64 process monitor EP-AA-i010 FC-15-003 (RA-13-008) Rev. 1 If the EAL is 0 the EAL thresho~d is off-scale high arnd alternate measures are needed.EL if EAL,> 107 .min-II ~EAL +- 0 orni-Ii else III return EA EAL=--56.763 Aeo= 56.763 -Calculate the Sit Boundary Concenraltion: X = Q.X°Oe' Gross TEDE =QO..XoverQ Gross CDE CakulaUon, Page Page 31 of3 LIC-1 5-0102 Enclosure, Attachment 4 Emergency Action Level Thresholds for Liquid, Release AA1 (RAl)RP-AA-1 010 FC-1 4-004 Rev. 0 (Calculation with Attachment 1 -Pages 1-11)i (Attachment 2: EAL Threshold Calculations based on TEDE -Pages 1-7)(Attachment 3: EAL Threshold Calculations based on Thyroid CDE -Pages 1-7) !F -AA-1 010 FC-1t4-004, Revision 0 I of 11 Emergency Action Level Thresholds for Liquid Release AAI (RAI)Prepared b: (date) Reviewed By date) Apred By {date)1 Problem or Issue Statement This calculation documents the methodology used to determine the Emergency Action Level (EAL) thresholds for the initiating condition (IC) AA 1 as defined in NE] 99-01 Rev. 6 for liquid effluent discharges; a release of liquid radioactivity resulting in offsite dose greater than JO mrem TEDE or SO mi-em thyroid CDE.2 Background or Introduction NE] 99-01 Rev. 6 initiating condition AA I addresses, a release of liquid radioactivity that results in a projected dose greater than and equal to :1% of the Environmental Protection Agency (EPA) Protective Action Guides (PAG). Releases of this magnitude represent an actual or potential substantiai degradation of the level of safety of the plant and exceeds regulatory limits.NEI 99-01 Rev. 6 provides the following generic guidance for selection of thresholds:

• Select the appropriate installed liquid monitorr*The effluent monitor reads should correspond to a dose of 1 0-torero TEDE or 50-* mrem CDE thyroid at the site specific receptor point for one-hour of exposure.* The monitor readings will be calculated using a set of assumed data. Acceptable sources of this data include, but not limited to the RET/ODCM and values used for emergency dose assessment methodology.
• The calculation of readings will also require use of an assumed release isotopic mix: the selected mix should be the same that is employed to calculate monitor readings for IC AS I and AG].*NE! guidance recognized that the conditions described in IC AA I may result in a radiological effluent value beyond the operating display range of the installed effluent monitor. In those cases, EALs should be determined with a sufficient margin sufficient to ensure that an accurate monitor reading is available.

RP-AA-1O1t0 FC-'14-004 Revision 0 Page 2 of 11 3 Discussions The ODCM identifies three pathways for human exposure to liquid releases from Fort Calhoun Station (FCS) to the Missouri Rivern 1) fish, 2) drinking water, and 3) Shoreline deposition. Fish are considered to be taken from the vicinity of the plant discharge. The drinking water for Omaha is located 19 miles downstream from FCS. For this calculation the drinking water pathway is considered because accident releases are acute releases and the emergency action thresholds are based on an acute exposure of one hour as described in the NEI 99-01 Rev.6 (Ref. 8.11), Figyre / Liquid Radioactie /Jischarge Poihwoy.s s/a Au0s 8] WAlER The concentration of radioactive material in the liquid effluents are normally diluted by the circulating water system.4 Methodology .4.1 This analysis develops the model used to estimate of the radion~uclide concentration and radiation monitor count rate from an ac~cidental release into the Missouri river exceeding I 0-mrem TEDE or 50-mirem CDE to the thyroid. This calculation provides a link between the effluent releases and the direct pathway to man from an acute intake of radioactive material from potable water, -A.A;110t FC-14-004.: : Revision 0 iPage 3 of 11 This calculation is based on the use of simple models and is a conservative approach. The effluent is considered small with respect to the receiving water body (Missuri River) arnd rapid mixing will reduce the discharge concentration. The initial dilution process is based on turbulent mixing produced as the effluent is introduced in the stream. This process is assumed to be relatively rapid. Large dilution on the order of 10 to 100 can be achieved (Ref. 8.2). This calculation uses a mixing coefficient of 30.8 for the Metropolitan Utility District (MUD) intake (Ref. 8.1) and is the specific receptor identified in the ODCM, The radionucl ides will undergo radioactive decay as the liquid is transported downstream. , The following equation from Reference 8.1 is used to calculate the TEDE and CDE from an oral intake of rid onuclides (assuming annual water intake of standard man) for a one-hour exposure: H. U Q,.DF&'o (1)Where He, is the effective dose equivalent for radionuclide i in units ofmtrero. U is the adult annual intake of water (730,000 mL), M is the mixing ratio of 30.8 at the point of intake for MUD (unit-less), F is the river flow at the time of discharge in mL/s, Q, is radionuclide release rate in Ci/s, DF, is the ingestion dose factor for the dose equivalent (TEDE) in units of mrem/Ci, L, is the radioactive decay constant in inverse seconds (hri'), and tp is the transit time in hours from the discharge at MUD (Ref. 8.1) intake (site specific receptor point).The transit time tp is calculated by dividing the distance from the discharge to the point of intake (i.e.4 19 miles) (Ref. 8.1) by the river velocity v (mph) (Ref. 8.7): 19 miies t,- v(mph) (2)To calculate the release rate at the site discharge for a 10-torero TEDE or" 50-torero CDE thyroid exposure equation I is solved for Qi the isotopic release rate for an one hour exposure. The isotopic release rate is based on the fraction of the assumed radionuclide mix in the source term (0): Q' uAMvDy,-' (3)The isotopic fraction is calculated by dividing the assumed Ci/MWth for each isotope by the sum of the inventory: , A XA'.,I (4)i The assumed inventory is the accident source term employed by the Universal RASCAL Interface (URI) program; the site dose assessment program. RP-AA-1010 FC-t4-004 Revision 0 Page 4 of 11 Tale I UR?! Accident Source Termn (NUREG-1228) Dose Etiulv Dose Equlv 1-131 1-132 1-133 1-134 1-135 Cs-23 C-137 Sb- 127 Sb-1!9 Te-I2~gm Te -132 Ba-140 Sr-B9 Sr-90 Sr-91 Mo-93 Ru- 10 Ru-106 La- 140 Y-91 C~e-144 N.P-29 Sum FGRft11 FEDE sv/Bq 1.44E-0a 1.S2E-10 2.aOE-09 6.66E-11 6.08E -10 1.98£-O8 3.04E-09 1.3E-OB 1.81E-09 4. 45E-L?.1.57E-10 246E-09 5.95E-OB 25I6E-O9 3. 51E-07 4.49E-10 1.07£-09 42A2-09 1.2.9E-07 1.31E-09 1.32.E-08 5.84E-08 6,78E-1O 6.90E-07 F6 R 11 Thyroid 4.76E-07 3K87E-09 9.10E-08 6.21E-10l 1.79E-08".76E-03 2.7460/.26E-(38 3. 16E-11 4.61E-10 2.a9E-09 4,2.9E-08 2.54E-09 S.2SE-11 4.1GE-10 2,64E-O9 4.08E-11 1.74E-09 5.97E-1O 1.69E-08 1L22E-lO I.IOE-10 1.88E-09 7,62E-12 6.96E-07 CEDE Cs-1_37_Factor_1.OTE+00 1.35E-02 2.07E-01 4.93E-03 4. 50E-02 1.47E+00 2.25E-01 1,00E+O0 1.346-a1 3. 30E-04 1.166-02 4.41E-+00 1.90E-01 8.3OE-01 2.60E+0I 3.33E-02 7.93E-.02 1.79E-O1 9.56E400 9.70E-02 9.78E-01 4.33E+00 5.11E+O1 CDE Thyroid Factor...1.'OOE+OO 8.13E-03 1.91E-01 tL30E-03 3.76E--02 3.70E-02 5.76E-03 2,65E-02 9.68E-04 6.07E-03 5.34E-02 1..10E-04 a74E.-04 S.SSE-03 8,57E-05 3.666-03* l25E-03 3. 55E-02 2,56E-04 2.31E-04 3.95E-03 1.606-05 1.46E+0O SCltMWt 2.67E+04.3.BSE*04 S. 9,8E-40 4.70E-03 1.49E+03 3.25E-+03 2.39E+03 8.68E+O,3 1,68E4.03 5.41E+03 3.816+04 4.76E+04 2,411:+04 2,39E+03, 3.01E+04 5.306*04 4,34E+04 1.55E*04 4.91E+04 3.17E+04 3...4E+04 5,69E4-05 1.206+06 ratio 2,23E-02 3.246-02 4S52E-02 4.99E-02 4. 32E-02 3.92E-03 1.24E-03 2.7J.E-03"1.99E-03 7,24E.-03 1.406-03 4.51.E-03 3. 1,8E-02 3.97E-02 2,026-02 1,99E-0.3 2516-02 4,42E-02 3.62E-02 1.29E-02 4.10E-02 2.G5E-02 2956-02 4.75E-01 1.00E-400 The gross release rate is calculated by summing the isotopic release rates Q,: Qi :ZQ (5)The gross undiluted concentration is calculated by dividing the total flow rate into the gross release rate:.QI (6)The design pump flows for the overboard wastes (wp) is S0-gprnand 1 35-gpm for the Riowdown pumps (270-gpm total) (Ref. 8.1). These .pump flow rates have no effect, i Revision 0 i "Page 8 of 11 because .the circulat~ing water pumps (we) have significantly imore di~lution flow (120,000-gpm).The threshold count rate is calculated by multiplying the radiationl monitor efficiency (cpmn/itCi/mL) by the undiluted concentration Cr and adding the background. R = e*C, + Rb (7)Instrument uncertainties and allocation factors are ignored because this eventis an acute accidental release and the EAL thresholds are not designed to provide! automatic action to prevent a release greater than a regulatory limit.5 Assumptions 5.1 Any noble gases resulting from a radiological accident are assumed released to the atmosphere. Basis: Noble gases are non-reactive gases and the effluent stream is open to the atmosphere at ambient temperatures; so an insignificant fraction of noble gases are assumed entrained in the effluent. In addition, as the effluent is' transported downstream entrained noble gases in the stream would be released via the turbulently river flow.5.2 A river current of 7-mph is assumed in this analysis.Basis: 'Reference

8.7 provides

a range of river velocities between 4 to 7 miles per hour.-The river speed is used :to calculate decay time as the effluent isi transported downstream. A higher transport velocity will result in less decay and a conservative estimate of decay.5.3 The annual oral intake of water is based on the use factor in the 00CM (Ref. 8.1) of 730 L.Basis: The annual intake usage factor for an adult in referencei 8.1 is 730 L which is taken from NRC Regulatory Guide 1.109 (Ref. 8.4). This intake factor is consistent with reference man's intake of~l I L given in ICRP 23 (Ref. 8.8).5.4 Liquid releases through the plants discharge pathways have alarm set paint ealculated based on known isotopic mixtures as measured by isotopic analysis of the liquid. This calculation assumes that the effluent isotopic mixture is unknown and uses the default mix of radionuclides used by the URI dose assessment program.Basis: By definition the EAL threshold values for this IC are for unexpected and unauthorized releases, so the isotopic mix is unknown. In accordance With NE!99-0 1 Rev. 6 developer notes state that the source term should be based the 0DCM or emergency dose methodology. The ODCM is not an emergency release program and therefore the accident source used by the dose assessment program RP-AA-1 010 FC-1 4.004.' ! .Revision 0 Page 6 of 11 provides a reasonable inventory for an acute unknown The inventory used* in the URI dose assessment code in based on NUREG-1228 (Ref. 8.1i2).6Results or Conclusions The results of the calculation show the maximum range of the liquid efflueint radiation monitors are exceeded (>1 10 7 epta). In accordance with NEI 99-01] Rev. 6 alternate methods of assessment or reduction in count rates that provide a reasonable threshold should be employed. With three circula~ting water pumps running the: TEDE threshold is approximately 128% of full range operation (Table 2) and large differences for less dilution flow would occur (Attachment 2).Table 2. Caliculated EAL£ l77rar/dds ([E.DI').Caletulated Effluent Monitor Deseription ____ ___ ___ ___ ___ ___ _ __ ___ ___ ___ ___ ___ __ AL. Threshold (cpm)RM-054A (I CW puamp) Steam Generator Slowdown l.LE-0S RM-054 B (I CW pump) Steam Generator Slowdown 1-. 2E+08 RM-054 A (2 CW pump) Steam Generator Slowdown 5.4E+07 RM-054 B (2 CW pump) Steam Generator Blowdown 5 .4E -07 RM-054 A (3 CW pump) Steam Generator Biowdown 3.6 E+07 RM-054 B (3 CW pump) Steam Generator Slowdownt 3.6 E-07 RM-05S (I CW pump) Liquid Discharge Header RM-055 (1 CW pump) L L~uid Discharge Header 6.1 E-07 RM-055 ( I CW pump) _Lquid Discharge Header 4.0E+07 The CDE thyroid calculations in Attachment 3 are greater than 10 7-cpm, which also supporting alternate methods of indication. In accordance with guidance in NEI 99-01 Rov. 6 (page 35) alternate methods will apply since the expected radiation monitor readings for the EAL thresholds are greater than 1 10%of full scale. These alternate methods may include grab samples from the effluent or field monitoring samples at the MUD intake.A grab sample of from an unauthorized rele~ase of 0.4-l.Ci/cc (e.g.. run off from an uncontrolled release or tank breach) in the effluent stream is an indicator of meeting the ALERT threshold for IC AA 1 (Attachment 2).

7 of 11 7 Calculations

7.1 Inputs

7.1.1 Process

monitor sensitivity for R.M-(J54A '9.84x 101 cpmdiCi/mL, and background 96 cpm (Ref. 8.5)'.7.1!.2 Process monitor sensitivity for R.M-054B 9.84x I07 cpm~xCi/mL, and background 220 cpm (Ref. 8.5).7.1.3 Process monitor sensitivity for RM-055 1.1 lxi cprnlkCi/mL, and background 160 epmo (Ref. 8.5).7.1.4 The mixing ratio (reciprocal of the dilution factor) at the withdrawal point for the Metropolitan Utilities District (MUD), intake is 30.8 (Ref. 8.1), 7.1.5 River current is a range of 4 to 7 miles per hour (Ref. 8.7). Seven (7) mph is used in this analysis.7.1!.6 The dose conversion factors used in this analysis are the effective dose equivalent (l-1)from oral ingestion published in USEPA Federal Guidance Report 11! (Ref., 8,3).7.1 .7 The source term used in the analysis is based on the generic source term used by the URI/RASCA L dose assessment computer code. As noted in the assumptions the noble gases are assumed released to the atmosphere prior to any liquid intake.7.1.8 The distance from Fort Calhoun to the MUD intake is 19-miles (Ref. 8.1).7.1.9 The annual intake for an adult is 730 L(Ref. 8.1).7.I. 10 FCS has three Circulating water pump and each as a design capacity of I120,000-gpm (Ref. 8.1.)7.1],11 Average river flow rate is based on the 16-years of data measured by the USGS at Decatur, Nebraska, just upstream of Fort Calhoun Station (Attachment 1).7.2 See Mathcad calculation in Attachment 2 and Attachment

3.8 References

8. [ CH-ODCM-O0001.

Offsite Dose Calculation ManuaL. Rev. 22. 1/8/2013.8.2 NUREG/CR.-3332 ORNL-5968. Radiological Assessment A Textbook on Environmental Dose Analysis. September 1983,:NOTE: The background for the Blowdown manitors RM-054 A/S is averaged and the average background is used in the calculation (158-cprm). This averaging is consistent with the approach used In the URI dose assessment progrm. Revision 0 8 of 11 8.3 USEPA Federal Guidance Report I1I. Limiting Values of Radionuclide Intake andAir Concentration and Dose Con'ersion Factors for Inhalation. Submersion, and Ingestion. 1 988.8.4 Regulatory Guide I. 109. Calculation of Annual Doses to Man from RoUtine Releases of Reactor Effi uents for (he Purpose of Evaluating Compliance with JO CFR 50 Appendix I.October 1977.8.5 TDB-IV.7. Technical Data Book Process Monitor SetPoints. Rev. 222. 6/04/13.8.6 Regulatory Guide , .183, Alternate Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors. July 2000.8.7 U S Army Corps of Engineers Omaha District. Aerial Photography and Maps of the Missouri River Ponca State Park. Nebraska to Rule, Nebraska. September 2004.8.8 Nucleon Lectern Associates. The Health Physics and Radiological Health Handbook, 1984.8.9 US EPA 400-R-92-001. Manual of Protective Action Guides and Protec'tive Action for Nuclear Incidents. May 1 992.8.1I0 USEPA. Protective Action Guides And Planning Guidance For Radiological Incidents (Draft). March 2013.8.1 NI El 99-01 Revision 6. Development of Emergency Action Levels Jar Non-Passive Reactors. November 2012.8.12 USNRC NUREG- 1228. Source Term Estimation Incident Response to Severe Nuclear Power Plant Accidents. October 1988.9 Attachments 9.1 USGS Average River Flows 9.2 EAL Threshold Calculations based on TEDE 9.3 EAL Threshold Calculations based on Thyroid CDE m A

RP-AA-1 01:0 FC-14-004 Revision 0 Page 9ofi11 Attachment 1: usGS Average River Flows USGS Surface-Water Annual Statistics for Iowa 1) USGS 06601200 Missouri River at Decatur, NE Burr County, Nebraska:Hydrologic Unit Code 10230001 Latitude 42=00'26, Longitude 96014'291, NAD27 Drainage area 316,200 square miles Gage datum 1,010.00 feet above NGVD29 2}r d *. 7 Water Year 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 00060, Discharge, cubic feet per second 1988 1989 1990 1991 1992 25,940 30,390 36,490 46,000 57,440 39,350 39,140 33,320 27,690 24,680 24,670 24,730 29,030 25,470 21,820 21,450 22,240

,,;i .....RP-AA-1 010 FG-14-004 0Page 10 of I1 00060, Discharge, cubic feet per second Water 1988 29,030 Year 1989 25,470.... .1990 .. ...21,820 , 1991 21,450 1992 22,240 2005 21,220 2006 22,400 2007 21,000 2008 19,650 2009 23,970 2010 39,020 2011 80,290 2012 35,170 2013 25,850~* No Incomplete data have been used for statistical calculation

i, 010 FC-'I 4-004.... ..

0

Page 1:1 of 11A~'emg Mi~cwi River Flowe River Flow Year cfs 1988 29030 1989 25470]1990 21820 1991 21450 1992 22240 2001 27690 2002 24680 2003 24670 2004 24730 2005 21220 2006 22400 2007 21O00 2008 19650 2009 23970 2010 39020 2011 80290 2012 35470 2013 25850 Average 28369 RP-AA-1O1O FC-14-004 Revision 0 Page 1 of 7 Attachment 2: E.AL Threshold Calculations based on TEDE Oi'=:3.7.10m.Bq pO{.'= 3.7- I0= ;<:= 0.01 * ~m :0.00I Isotope-=

R~AkDEXCEL (".\ELR.D Spread Sheet. xlsc", '=Liquid Source Term!A5;A28") haiflife:=READEXCEL (".\ELRID Spread Sheet.xlsx" ,"Calculation SheetlE21I

E44") .day Activity =R.EADEXCEL

(".\ELR:D Spread Sheet.xlsx" , "Liquid Source Termn!F5;F28") .0 DF REAOEXCEL (",\ELRD Spread Sheet.xlsx", "Liquid Source TermlB5:B28")-S. Calculate the Isotopic Fraction based on the Ci/MWt from UP.I Source Term f=Activity

2. Activity Isotope ="I-1311I"I--132""1--133""1-135""Cs--134""Cs-l36"'"Sb- 127""Sb-129""'Te- 1 29m""Te--1 31m""re-1 32,'"Ba-140""Sr-89"'"Sr-90""Sr-91""Mo-99""1*u-103" R~u-106""La- "Y-91"",Ce--144,'"Np--239"!2.2282 .10-2]13.2379"10 j!S4.5231.10 I[4.9904- 10 4.3228'10 21 3,9223,0..102 I 2,7122- i0"i 17.2437.10

-1 11.4o2-1o - l-'S3.9723. o-02 2.0112.1o0-L9945. 10 I 2.5119.10-- 4.423*

• 1 -3.6218.10-21 1.2935- 10 "I 4.95.021!2.6454.10 21[4.7484.10 holZflfe=1802 9.7. 10-2 8.7.10-'S3.6.1 0 2 11.3 .10 J1,1"I0'13.85 1.28-1032.7 14.8.10 5 .05 '10" 1.10 2.79 dayl

~dp RP-AA-I 010 FC-1 4-004'= Revision 0 Page 2 of 7 TEDE 1= 0 -rn'i'e L Ur-730.-F~=283869 ft'M:=3fO.8 v :=7-mvh t =2.7143 hr i;=O04..22 Threshold for AMt liquid EAL.Annual intake of water (ODCIV & Regulatory Guide 1.109)Average river flow rate Mixing factor (ODCM)Distance from Fort Calhoun Discharge to MUD (ODCM)Average liyer flow is 4 -7 mph Calculate decay time distance to Intake and current speed Exposure ltime Number of Isotopes in UPI Source Term Sln(2)Calculate the decay constant for each Isotope (f.-E.E Calculate the release rate for each Isotope U. At.M.DF .e[ Q Calculate total release rate Q 2=8.3079 -_. llIIil RP-AA-1 010 FC-14-004 Revision 0 Page 3 of?7 j,= I0,5000.. 12O000 tu' = 120000. gp-Calculate a range of release flow pae Row rate of 1 Circulating Water Pump w =U )~3 QT Calculate the range of concentrations the equal the TDED EAL base on a range of undiluted disch.arge flow rates 1' (j i w,(gm RP-AA-1O10 FC-14-004 Revision 0 Page 4 of 7 RM-05S BKC 1 t :=160 .mran-RMN-054 A/B (Blowdawn)= 9.84.*107 BKC 2 ==158. Calculate a range of Threshold count rates based on discharge flow rate (RNI-055)R 1 (w vi(pn a ~ /~t-A1 RP-AA-1 010 FC-14-004: Revision 0 Page 5 of 7/R~2:= (CT.-e 2)+ BKG, 2 Calculate a range of Threshold count rates based on discharge flow rate (RM-054 A/B)di-I'ft 2 (rnin.'~)to (gpm)As can be seen by the charts above the pump flows have little no effect on the threshold based on the design range of the pumps 50 -270-gpm. RP-AA-1010 FC-14.004 Revision 0 Page 6 of 7 During norami operations 3 dirculating wat~er pumps are running, each at 120,000 gpm.During power reductions or startup one circulator may be running. During outage periods one Raw Water pump may provide dilution flow.EAL thresholds for a 1 circulating water pumps provideing dilution EAL,=(L81.21O10) mmn.EAL 2:= * -- 2+/-+BKG 2 EA_,A_ = (1.0798.10'~) mmn'DF ="5.328 6.734" 0: 1.036

• 2.4642-102 2.2496 "10 7.326.10'I

1. 1248.1I0'4.995.10 6.69r-103 1.6485.1 0 5.809<*10:

9.102.*10: 2.2015 9.472,10&4.144- i0 1.2987.*10 1.6813 *I0 8.954, 4.847- I0 4.884<-10'= 2.1608.10" 2.5086 *10 EAL thresholds for a 2 circulatIng water pumps providelng dilution EAL'=2-(2w 2 6+ BKG, refa~Ci EAL 2=(5.399* 0') %,.g EAL thresholds for a 3 circulating water pumps provideing dilution EAL 1 I=(- L BKG 1 EA,=~(4.o6o3. 1o 7) =(Q.-T.,e+ BKG., EAL 2= (3.5904-10') rr" imiting concentration based on 3 circu[ation waite pump 3 .wr, co=(a.6579. 1&") RP-AA-1O1O FC-1 4-004 Revision 0 Page 7 of 7 RP-AA-l10 FC-14-004:Revision 0 Attachment 3: EAL Threshold Calculations based Thyroid CDE Ci,'3.7.1O 1 0.-Bq jiCi::3.7.10'.Bq mrre~rn:-.0,001-rn, Isotope:= READEXCEL (".\ELR.D Spread "Liquid Source TernalAS:A28"1) halfli~fe "=READEXCEL (".\ELRLD Spread Sheet .xlsx", Sheet!E2I:E44'") =da~y Activity :=READEXCEL (".\ELRD Spread Sheet.,lsx"', Liquid Source Termn!FS'~F28"})GC DF R,-IEADEXCEL Spread Sheet~xlsx?", Liquid Source TermiOS :C28")*Calculate the Isotopic Fraction based on the Ci/MWt from UR.I Source Term._Activity ZActivity [8.02 9.7.10l f "1-431" ro[.02231 8,7.10-'1 "I-132" I 0.03241 3,-1 I 1 "-133" 10.0452I 361 I I 1-134" I 0.0499 28.8 -I0.["1-135" 0.0432175-0 S"Cs-I34" 0.00Q39I 1.3" 10["Os-136" 0.0012' 1.1,10'I "Cs-137' (0.0027 l3.85'["b-2"0.002 I1,83,10-"Te-129mj 10.00141 halflife=I 1.25 day"Te--131m"I .0.0045 I 3.2 Isotope=1 "Te-132"I 1=0.0318 1 (1.28-10.I"Ba-140" 10,03971 ]5.05.-10 uSr-89)" 0,0201 1 I"Sr-90" 1 I0 002 I Ii o 10 .Is -59J1 o 0o251~ 4. o-aMo-99" ~ 0.0442.11,79"R~u-103" 3.0625 .1& -"Rtu-106" 0,01 ] .6 I 0'"La-10" 0,41 I1.68"aY-91" ( 0.0461 15.8'.10 I"Ce--144" I 0.02951]29-0"Np--23 9" L [0.4748 1 2.33 /f10 FC-14-004 Revision 0 Page 2 of 7 CDE := 5O-mrem L U:==730.*y r F:= 28369~ M:30.8 d :=Wt.rnile v :=7,rnph t 2.714,3 hr At := 1.hr i :=0,1..22 Threshold for AA1 liquid EAL Annual Intake of water (ODCM & Regulatory Guide 1,109)Average river flow rate Mixing fadtor (ODCM4)Distance from Fort Calhoun Disdharge to MUD (ODL--M)Average river flow is 4 7 mph Calculate decay time distance to Intake and current speed Exposure Time Number of Isotopes in URI Source Term A-- ln(2) Calculate the decay constant for each Isotope----i=- Calculate the release rate for eacdh Isotope U.-At-M.DF .e Calculate total release rate Q.-(1.30T7. I) c- ~mw~2 RP-AA-1 010 FC-14-004 Revision 0 Page 3 of 7 w = 120000.

• pm j =1Q,5O000,.

120000 Flow rate of 1 Circulating Water Pump Calculate a range of rejlease flow rates in .'=J.gpm CT Calculate the range of concentrations the equal the CDE EAL base on a range of discharge flow rates I-\I ,.,,) a RP-AA-l0iO FC-14-804 Revision 0 Page 4 of 7 R, "= (Cr .e,) + BKG, RM-D54 A/B (Blowdown) £2=98 o17 *rmm 6L, BKG 2 :=l158 rn~in-' a range of Threshold count rates based on discharge flow rates (R.N-O55)R 1 ,(,,.)wL~ (gyir),

RP-AA-1O1O FC-14-004 Revision 0 Page 5 of 7 B =(Cr .E2) + BKG., Calculate a range of Threshold count rates based on discharge flow rates (RM-054 A/B)&, u, (g-m).1 As czn be seen by the charts above the pump flows have little no effect on the threshold based on the design range of the pumps 50 -270-gpm. j-, RP-AA-1O10 FC-14-004 Revision 0 Page 6 of 7 During norami operations 3 circulating water pumps are running, each at 120,000 gpm.During power reductions or startup one circulator may be running. During outage periods one Raw Water pump may provide dilution flow.EAL thresholds for 1 circulating pump provideing dilution EA 1 (Qr. +BG EAL = (1.9175.10&) mmn EAL2 ~.= .2+BKG 2 FAL 2= vmn, I)F=I 1.4319 3.367-10s 2.2977,103 6.623.

• 0 6.5'12 -104 1.0138-10&

4.662.104 1.1692.102 1.0693

• 101 1.5873.10a 1.9425.102 1.5392 .102 9.768.103 1.5096 *.102 6.438.*102 2.2089'* 10a 6.253.* I0 4.514.102 4.07.102 6.956 -2.8194-10 rem Ci EAL thresholds for 2 drculating pump provideing dilution EAL " L +/- 1 EAL 1= (9.5874.10

7) ranm EAL,::::: "

RP-AA-1 010 FC-1 4-004-Revision 0 Page 7 of 7 EAL thresholds for 3 dmulating pump provideing dilution EA =(QT ).c, +BKG 1 EAL = (6.3916.10

7) EAL 2= (5.6661-10

7) Limiting concentration based on 3 circulation water pump C 0=O0.5758}}