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{{#Wiki_filter:ATTACHMENT 7DISCUSSION OF REVISIONTO THERADIOLOGICAL EMERGENCY PLAN ANNEXFORLIMERICK GENERATING STATIONEP-AA-1 008Enclosures* Enclosure 7A -EAL Comparison Matrix Document* Enclosure 7B -EAL Red-Line Basis Document* Enclosure 7C -EAL Basis Document NEI 99-01REVISION 6DEVELOPMENT OF EMERGENCY ACTIONLEVELS FOR NON-PASSIVE REACTORSArrACHMENT 7DISCUSSION OF REVISION TO THE RADIOLOGICALEMERGENCY PLAN ANNEX FORLIMERICK GENERATING STATIONmr Exelon Generation.
0NEI 99-01 Rev 6 Proposed EAL I JustificationAGIInitiating Condition -GENERAL EMERGENCYRelease of gaseous radioactivity resulting in offsite dose greater than 1,000 mremTEDE or 5,000 mrem thyroid CDE.Operating Mode Applicability: AllExample Emergency Action Levels: (1 or 2 or 3)Notes:The Emergency Director should declare the General Emergency promptlyupon determining that the applicable time has been exceeded, or will likely beexceeded.If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.If the effluent flow past an effluent monitor is known to have stopped due toactions to isolate the release path, then the effluent monitor reading is nolonger valid for classification purposes.The pre-calculated effluent monitor values presented in EAL #1 should beused for emergency classification assessments until the results from a doseassessment using actual meteorology are available.1. Reading on any of the following radiation monitors greater than thereading shown for 15 minutes or longer:(site specific monitor list and threshold values)2. Dose assessment actual meteorology indicates doses greater than 1000mrem TEDE or 5000 mrem thyroid CDE at or beyond (site specific dosereceptor point)3. Field survey results indicate EITHER of the following at or beyond (sitespecific dose receptor point):* Closed window dose rates greater than 1000 mR/hr expected tocontinue for 60 minutes or longer.* Analysis of field survey samples indicate thyroid CDE greater than5000 mrem for one hour of inhalation.RGIInitiating Condition:Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mRemTEDE or 5,000 mRem thyroid CDE.Operating Mode Applicability:1,2,3,4,5. DEmergency Action Level (EAL):Notes:* The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release pathto the environment is established. If the effluent flow past an effluent monitor isknown to have stopped due to actions to isolate the release path, then theeffluent monitor reading is no longer valid for classification purposes.The pre-calculated effluent monitor values presented in EAL #1 should beused for emergency classification assessments until the results from a doseassessment using actual meteorology are available.1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for> 15 minutes.OR2. Dose assessment using actual meteorology indicates doses at or beyond thesite boundary of EITHER:a. > 1000 mRem TEDEORb. > 5000 mRem CDE ThyroidOR3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >1000 mR/hr are expected tocontinue for > 60 minutes.ORb. Analyses of field survey samples indicate > 5000 mRem CDEThyroid for 60 minutes of inhalation.Table R1 Effluent Monitor ThresholdsRelease Path General EmergencyNorth Stack (WR Monitor: RIX-26-076-4) 1.92 E+08 uCi/secSouth Stack (Unit 1: RY26-185A-3 I RY26- 2.71 E-01 uCi/sec185-B-3 or Unit 2: RY26-285A-3 / RY26-285-B-3)H No Change F--]Difference I Deviation1) Listed site-specific monitors and threshold values to ensure timely classification.2) Added the following to Notes bullet #3" Classification based on effluent monitorreadings assumes that a release path to the environment is established." In orderto delete the following from the basis "Classification based on effluent monitorreadings assumes that a release path to the environment is established. If theeffluent flow past an effluent monitor is known to have stopped due to actions toisolate the release path, then the effluent monitor reading is no longer valid forclassification purposes." This allows for more timely classification since all thebasis information pertaining to Note bullet 3 will be contained in the IC and thereforreadily available on the 1 lx1 7 procedure matrix used by the SM.Page 1 of66 NEI 99-01 Rev 6 Proposed EAL JustificationASIInitiating Condition -SITE AREA EMERGENCYRelease of gaseous radioactivity resulting in offsite dose greater than 100 mremTEDE or 500 mrem thyroid CDE.Operating Mode Applicability: AllExample Emergency Action Levels: (1 or 2 or 3)Notes:* The Emergency Director should declare the Site Area Emergency promptlyupon determining that the applicable time has been exceeded, or will likely beexceeded.* If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.* If the effluent flow past an effluent monitor is known to have stopped due toactions to isolate the release path, then the effluent monitor reading is nolonger valid for classification purposes.* The pre-calculated effluent monitor values presented in EAL #1 should beused for emergency classification assessments unfit the results from a doseassessment using actual meteorology are available.1. Reading on any of the following radiation monitors greater than thereading shown for 15 minutes or longer:(site specific monitor list and threshold values)2. Dose assessment actual meteorology indicates doses greater than 1000mrem TEDE or 5000 mrem thyroid CDE at or beyond (site specific dosereceptor point)3. Field survey results indicate EITHER of the following at or beyond (sitespecific dose receptor point):* Cloxed window dose rates greater than 100 mRihr expected tocontinue for 60 minutes or longer.* Analysis of field survey samples indicate thyroid CDE greater than500 mrem for one hour of inhalation.RS1Initiating Condition:Release of gaseous radioactivity resulting in offsite dose greater than 100 mRemTEDE or 500 mRem thyroid CDE.Operating Mode Applicability:1,2,3,4,5, DEmergency Action Level (EAL):Notes:* The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release pathto the environment is established. If the effluent flow past an effluent monitor isknown to have stopped due to actions to isolate the release path, then theeffluent monitor reading is no longer valid for classification purposes.The pre-calculated effluent monitor values presented in EAL #1 should be usedfor emergency classification assessments until the results from a doseassessment using actual meteorology are available.I. Readings on ANY Table RI Effluent Monitor > Table RI value for > 15minutes.OR2. Dose assessment using actual meteorology indicates doses at or beyond thesite boundary of EITHER:a. > 100 mRem TEDEORb. > 500 mRem CDE ThyroidOR3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >100 mR/hr are expected tocontinue for> 60 minutes.ORb. Analyses of field survey samples indicate > 500 mRem CDEThyroid for 60 minutes of inhalation.Table R1 Effluent Monitor ThresholdsRelease Path Site Area EmergencyNorth Stack (WR Monitor: RIX-26-076-4) 1.92 E+07 uCi/secSouth Stack (Unit 1: RY26-185A-3 / 2.71 E-02 uCi/secRY26-185-B-3 or Unit 2: RY26-285A-3 IRY26-285-B-3)LI No Change E Difference 1 Deviation1) Listed site-specific monitors and threshold values to ensure timely classification.2) Added the following to Notes bullet #3" Classification based on effluent monitorreadings assumes that a release path to the environment is established." In orderto delete the following from the basis "Classification based on effluent monitorreadings assumes that a release path to the environment is established. If theeffluent flow past an effluent monitor is known to have stopped due to actions toisolate the release path, then the effluent monitor reading is no longer valid forclassification purposes." This allows for more timely classification since all thebasis information pertaining to Note bullet 3 will be contained in the IC and thereforreadily available on the 11x17 procedure matrix used by the SM.Page 2 of 66 NEI 99-01 RevS Proposed EAL JustificationNEI 99-01 Rev 6Proposed EALJustification4 +AA1Initiating Condition -ALERTRelease of gaseous or liquid radioactivity resulting in offsite dose greater than 10mrem TEDE or 50 mrem thyroid ODE.Operating Mode Applicability: AllExample Emergency Action Levels: (1 or 2 or 3)Note:* The Emergency Director should declare the Alert promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.* If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.* If the effluent flow past an effluent monitor is known to have stopped dueto actions to isolate the release path, then the effluent monitor reading isno longer valid for classification purposes.* The pre-calculated effluent monitor values presented in EAL #1 should beused for emergency classification assessments until the results from adose assessment using actual meteorology are available.1. Reading on any of the following radiation monitors greater than thereading shown for 15 minutes or longer:(site-specific monitor list end threshold values)2. Dose assessment actual meteorology indicates doses greater than 10mrem TEDE or 50 mrem thyroid CDE at or beyond (site specific dosereceptor point)3. Analysis of a liquid effluent sample indicates a concentration or releaserate that would result in doses greater than 10 mrem TEDE or 50 mremthyroid CDE at or beyond (site-specific dose receptor point) for one hour ofexposure.4. Field survey results indicate EITHER of the following at or beyond (sitespecific dose receptor point):* Closed window dose rates greater than 10 mR/hr expected tocontinue for 60 minutes or longer.* Analysis of field survey samples indicate thyroid CDE greater than50 mrem for one hour of inhalation.RA1Initiating Condition:Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10mrem TEDE or 50 mrem thyroid CDE.Operating Mode Applicability:1,2, 3,4, 5, DEmergency Action Level (EAL):Notes:* The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assumethat the release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release pathto the environment is established. If the effluent flow past an effluent monitor isknown to have stopped due to actions to isolate the release path, then theeffluent monitor reading is no longer valid for classification purposes.* The pre-calculated effluent monitor values presented in EAL #1 should be usedfor emergency classification assessments until the results from a doseassessment using actual meteorology are available.1. Readings on ANY Table RI Effluent Monitor > Table Ri value for > 15minutes.OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 10 mRem TEDEORb. > 50 mRem CDE ThyroidOR3. Analysis of a liquid effluent sample indicates a concentration or release ratethat would result in doses greater than EITHER of the following at or beyondthe site boundarya. 10 mRem TEDE for 60 minutes of exposureORb. 50 mRem CDE Thyroid for 60 minutes of exposureOR4. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (cdosed window) dose rates > 10 mR/hr areexpected to continue for a 60 minutes.ORb. Analyses of field survey samples indicate > 50 mRemCDE Thyroid for 60 minutes of inhalation.Table RI Effluent Monitor ThresholdsRelease Path AlertNorth Stack (WR Monitor: RIX-26-076-4) 1.92 E+06 uCi/secSouth Stack (Unit 1: RY26-185A-3 / 2.71 E-03 uCi/secRY26-185-B-3 or Unit 2: RY26-285A-3 /RY26-285-B-3)LI No Change E Difference [I] Deviation1) Listed site-specific monitors and threshold values to ensure timely classification.2) Added the following to Notes bullet #3 " Classification based on effluent monitorreadings assumes that a release path to the environment is established." In orderto delete the following from the basis "Classification based on effluent monitorreadings assumes that a release path to the environment is established. If theeffluent flow past an effluent monitor is known to have stopped due to actions toisolate the release path, then the effluent monitor reading is no longer valid forclassification purposes." This allows for more timely classification since all the basisinformation pertaining to Note bullet 3 will be contained in the IC and thereforreadily available on the 1 1x17 procedure matrix used by the SM.3) A calculation was performed, in accordance with (lAW) guidance provided in NEI99-01 revision 6 EAL AA1, to determine the effluent monitor response for aradioactive liquid release via the normal site release pathway. The liquid releasewould contain activity equivalent to provide 10mrem TEDE or 50mrem thyroid CDEat the site boundary. The calculation determined the effluent monitor responsewould be >110% of the instrument maximum range and as such, lAW NEI 99-01Rev 6 guidance, was not included in this EAL.Page 3 of 66 NEI 99-01 Rev 6 1 Proposed EAL JustificationAUIInitiating Condition -UNUSUAL EVENTRelease of gaseous or liquid radioactivity greater than 2 times the (site-specificeffluent release controlling document) limits for 60 minutes or longerOperating Mode Applicability: AllExample Emergency Action Levels: (1 or 2 or 3)Note:" The Emergency Director should declare the Unusual Event promptly upondetermining that 60 minutes has been exceeded, or will likely beexceeded." If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 60 minutes." If the effluent flow past an effluent monitor is known to have stopped,indicating that the release path is isolated, the effluent monitor reading isno longer valid for classification purposes.1. Reading on ANY effluent radiation monitor greater than 2 times the (site-specific effluent release controlling document) limits for 60 minutes orlonger:(site-specific monitor list and threshold values corresponding to 2 timesthe controlling document limits)2. Reading on ANY effluent radiation monitor greater than 2 times thealarm setpoint established by a current radioactivity discharge permit for60 minutes or longer.3. Sample analysis for a gaseous or liquid release indicates a concentrationor release rate greater than 2 times (site-specific effluent releasecontrolling document limits) for 60 minutes or longer.RUIInitiating Condition:Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60minutes or longer.Operating Mode Applicability:1,2, 3,4, 5, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assumethat the release duration has exceeded 60 minutes." Classification based on effluent monitor readings assumes that a release path tothe environment is established. If the effluent flow past an effluent monitor isknown to have stopped due to actions to isolate the release path, then the effluentmonitor reading is no longer valid for classification purposes.1. Reading on ANY of the following effluent monitors > 2 times alarm setpointestablished by a current radioactive release discharge permit for a 60 minutes." Radwaste Discharge Effluent Monitor (RR63-OR001)OR" Discharge Permit specified monitorOR2 Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 60 minutes:Table R1 Effluent Monitor ThresholdsRelease Path Unusual EventNorth Stack (WR Monitor: RIX-26-076-4) 2.20 E+04 uCi/secSouth Stack (Unit 1: RY26-185A-3 / RY26- 3.09 E-05 uCi/sec185-B-3 or Unit 2: RY26-285A-3 / RY26-285-B-3)OR3. Confirmed sample analyses for gaseous or liquid releases indicate concentrationsor release rates > 2 times ODCM Limit with a release duration of > 60 minutes.D:1 No Change 111 Difference F Deviation1) Listed site-specific monitors and threshold values to ensure timelyclassification.2) Added the following to Notes bullet #3" Classification based on effluentmonitor readings assumes that a release path to the environment is established."In order to delete the following from the basis "Classification based on effluentmonitor readings assumes that a release path to the environment is established.If the effluent flow past an effluent monitor is known to have stopped due toactions to isolate the release path, then the effluent monitor reading is no longervalid for classification purposes." This allows for more timely classification sinceall the basis information pertaining to Note bullet 3 will be contained in the IC andtherefor readily available on the 1 1x17 procedure matrix used by the SM.Page 4 of 66 NED 99-01 Rev 6 Proposed EAL JustificationNEI 99-01 Rev 6Proposed EALJustification--- -tAG2Initiating Condition -- GENERAL EMERGENCYSpent fuel pool level cannot be restored to at least (site-specific Level 3description) for 60 minutes or longer.Operating Mode Applicability: AllExample Emergency Action Levels:NOTES: The Emergency Director should declare the General Emergencypromptly upon determining that 60 minutes has been exceeded,or will likely be exceeded1. Spent fuel pool level cannot be restored to at least (site-specific Level 3description) for 60 minutes or longer.RG2D No ChangeE Difference 1 Deviation1) EAL not used in accordance with the discussion in Section 1.4, NRC OrderEA-1 2-051, it is recommended that this EAL be implemented when the enhancedspent fuel pool level instrumentation is available for use per developer noteguidance, The completion of the enhanced SFP level indicators and need for theinclusion of this EAL is being tracked in accordance with Exelon GenerationCompany, LLC's Initial Status Report to March 12, 2012 Commission OrderModifying Licenses with Regard for Reliable Spent Fuel Pool Instrumentation(Order Number EA-12-051) dated October 25,2012.Page 5 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationInitiating Condition -SITE AREA EMERGENCY AS2 RS2 1 No Change FIDifference jJ DeviationSpent fuel pool level cannot be restored to at least (site-specific Level 3description) 1) EAL not used in accordance with the discussion in Section 1.4, NRC OrderEA-1 2-051, it is recommended that this EAL be implemented when the enhancedOperating Mode Applicability: All spent fuel pool level instrumentation is available for use. The completion of theenhanced SFP level indicators and need for the inclusion of this EAL is beingExample Emergency Action Levels: tracked in accordance with Exelon Generation Company, LLC's Initial StatusReport to March 12, 2012 Commission Order Modifying Licenses with Regard for1. Spent fuel pool level cannot be restored to at least (site-specific Level 3 Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) dateddescription) October 25,2012.Page 6 of 66 0NEI 99-01 Rev 6 Proposed EAL JustificationAA2 RA2Initiating Condition -ALERT Initiating Condition: A2 j No Change Difference DeviationSignificant loweing of water level above, or damage to, irradiated fuel. Significant lowering of water level above, or damage to, irradiated fuel. 1) Listed site-specific monitors and threshold values to ensure timely classification.Operating Mode Applicability: All Operating Mode Applicability:2) EAL #3 not used in accordance with the discussion in Section 1.4. NRC Order1. 2, 3, 4, 5, D EA-12-051, it is recommended that this EAL be implemented when the enhancedExample Emergency Action Levels: (1 or 2 or 3) Emergency Action Level (EAL): spent fuel pool level instrumentation is available for use per developer noteguidance. The completion of the enhanced SFP level indicators and need for the1. Uncovery of irradiated fuel in the REFUELING PATHWAY. 1. Uncovery of irradiated fuel in the REFUELING PATHWAY. inclusion of this EAL is being tracked in accordance with Exelon GenerationOR Company, LLC's Initial Status Report to March 12, 2012 Commission Order2. Damage to irradiated fuel resulting in a release of radioactivity from the Modifying Licenses with Regard for Reliable Spent Fuel Pool Instrumentationfuel as indicated by ANY of the following radiation monitors: 2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel (Order Number EA-12-051) dated October 25,2012.as indicated by ANY Table R2 Radiation Monitor reading >1000 mRemlhr.(site-specific listing of radiation monitors, and the associated readings,setpoints and/or alarms)Table R23. Lowering of spent fuel pool level to (site-specific Level 2 value). Refuel Floor ARM's" RIS29-Ml-1(2)K600. Drywell Head Laydown" RIS30-M1-1(2)K600, Dryer / Separator Area" RIS31-M1-1(2)K600, Spent Fuel Pool" RIS32-Ml-1(2)K600, New Fuel storage Vault.RIS33-M1-1(2)K600, Pool Plug LaydownPage 7 of 66 NEI 99-01 Rev 6 [ Proposed EAL [ JustificationAA3Initiating Condition -ALERTRadiation levels that impede access to equipment necessary for normal plantoperations, cooldown or shutdown.Operating Mode Applicability: AllExample Emergency Action Levels: (1 or 2)Note: If the equipment in the listed room or area was already inoperable, or outof service, before the event occurred, then no emergency classification iswarranted1. Dose rate greater than 15 mR/hr in ANY of the following areas:* Control Room* Central Alarm Station* (other site-specific areas/rooms)2. An UNPLANNED event results in radiation levels that prevent orsignificantly impede access to any of the following plant rooms or areas:(site-specific list of plant rooms or areas with entry-related modeapplicability identified)RA3Initiating Condition:Radiation levels that impede access to equipment necessary for normal plantoperations, cooldown or shutdown.Operating Mode Applicability:1,2, 3,4, 5, DEmergency Action Level (EAL):Note:If the equipment in the room or area listed in Table R4 was already inoperable, or outof service, before the event occurred, then no emergency classification is warranted.1-l No Change 1 Difference 1 Deviation1) Listed site specific plant rooms and areas with identified mode applicability toensure timely classification.1 .Dose rate > 15 mR/hr in ANY of the following Table R3 areas:Table R3Areas Requiring Continuous Occupancy" Main Control Room" Central Alarm Station -(by survey)OR2. UNPLANNED event results in radiation levels that prohibit or significantlyimpede access to ANY of the following Table R4 plant rooms or areas:Table R4Areas with Entry Related Mode ApplicabilityArea Entry Related Mode ApplicabilityReactor Enclosure* I Modes 3, 4, and 5*Areas required to establish shutdown coolingPage 9 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationSU3 RU3 I No Change [--j Difference U DeviationInitiating Condition: UNUSUAL EVENT Initiating Condition:Reactor coolant activity greater than Technical Specification allowable limits. Reactor coolant activity greater than Technical Specification allowable limits. 1) Listed site-specific monitor and threshold value to ensure timely classification.Operating Mode Applicability: Operating Mode Applicability: 2) Listed this system category EAL in the radiological category EAL section toPower Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 maintain consistency with current and previous revisions of Exelon EALs. This willExample Emergency Action Levels: Emergency Action Level (EAL): ensure a timely classification since the threshold values are more aligned with theradiological category vice system category.1. (Site-specific radiation monitor) reading greater than (site-specific value). 1. Air Ejector discharge radiation monitor (RISH 26 1(2)K601A, B) Hi-Hi alarm.OR OR2. Sample analysis indicates that a reactor coolant activity value is greater than 2. Specific coolant activity > 4.0 uClIgm Dose Equivalent 1-131.an allowable limit specified in Technical Specifications.Page 10 of 66 NEI 99-01 rev 6 Fission Product Barrier MatrixFisso Product_ _ _ _ _ _ _ _ Barrier_ _ _ _ _ _ Mari _ _ _ _ _ _ _ _ _ _ __ITAEAEMEGECYALRT_ otM_ _FGI Loss of any two barriers AND Loss or Potential Loss of third barrier.1.2,3FSI Loss or Potential Loss of ANY two barriers.1,2,3FAI ANY Loss or ANY Potential Loss of either Fuel Clad or RCS1,2,3FC -Fuel C lad RC -Reactor Coolant System CT -ContainmentSiubo-CategoryLoss Potential Loss Loss Potential Loss Loss Potential Loss1. RCS Activity/ A. UNPLANNED rapid drop in primary A. Primary containment pressure greatercontainment pressure following than (site-specific value)Containment A (Site specific indications that A Primary containment pressure primary containment pressure rise ORCnan nt reactor coolant activity is greater NoneA.PiaycnimetpsurPressure r greater than (site-specific value) None OR B. (site-specific explosive mixture) existsthan 300 uCi/gm dose equivalent due to RCS leakage. inside primary containmentPrimary 1-131) B. Primary containment pressureContainment response not consistent with LOCA ORConditions conditions. C. HCTL exceeded.A. RPV water level cannot be restored A. RPV water level cannot beA. Primary containment flooding and maintained above (site-specific restored and maintained above2. RPV Water required. RPV water level corresponding to (site-specific RPV level None None A. Primary containment flooding required.Level top of active fuel) or cannot be corresponding to the top of activedetermined, fuel) or cannot be determined.A. UNISOLABLE direct downstreampathway to the environment existsafter primary containment isolationsignalORA. UNISOLABLE primary system leakageA. UNISOLABLE break in any of the that results in exceeding EITHER of B. Intentional primary containmentA, RCSOLLeakbraRateany thehe following:EO~3 .R C S Le a k R a te / fo llow ing : ( site -spe c ific syste m s w ith the fo llowi ng : O per tin O R N oneCo tanm e nt None None potential for high-energy line breas) 1.M x N r a p rtn RNoneNettfrgngibaOR Temperature C. UNISOLABLE primary systemIsolation Failure B. Emergency RPV Depressurization OR leakage that results in exceeding2. Max Normal Operating Area EITHER of the following:Radiation Level. 1. Max Safe OperatingTemperature.OR2. Max Safe Operating AreaRadiation Level.4.Primary A. Primary Containment Radiation A. Primary Containment Radiation A. Primary Containment Radiation MonitorContainment Monitor reading greater than None Monitor reading greater than (site- None None reading greater than (site-specificRadiation (site-specific value), specific value). value).5. EmergencyDirector JudgmentA. Any Condition in the opinion ofthe Emergency Director thatindicates Loss of the Fuel CladBarrier.A. Any Condition in the opinion of theEmergency Director that indicatesPotential Loss of the Fuel Clad Barrier.A. ANY Condition in the opinion of the A. Any Condition in the opinion of theEmergency Director that indicates Loss Emergency Director that indicatesof the RCS Barrier. Potential Loss of the RCS Barrier.A. Any Condition in the opinion of theEmergency Director that indicates Lossof the Containment Barrier..A. Any Condition in the opinion of theEmergency Director that indicates PotentialLoss of the Containment Barrier.Page 11 of 66 Proposed Fission Product Barrier MatrixFission_ _ _ _ _ _ _ _ _ _ PrdcIare arxGNRLEEREC IEAE MREC LRProposed Fission Product Barrier MatrixFG1 Loss of any two barriers AND Loss or Potential Loss of third barrier. [FSI Loss or Potential Loss of ANY two barriers. NJ[Ur2 j FAI ANY Loss or ANY Potential Loss of either Fuel Clad or RCS r[]AFC -Fuel Clad RC -Reactor Coolant System CT -ContainmentSub-CategoryLoses Potential Loss Loss Potential Loss Loss Potential LossCoolant activity > 300 uCtigm Dose None None1. RCS Activity Equivalent 1-131. None Nose None2 RPV water level cannot be restored and 1. RPV water level cannot be restored and1. Plant conditions indicate Primary maintained > -161 Inches (TAF) maintained > -161 Inches (TAF) Plant conditions indicate Primary Containment2. RPV Water Containment flooding is required. OR OR None None ftooding is required.Level 3. RPV water level causst be determined. 2. RPV water level cannot be determined.3. Containment pressure s 55 pstg and rising.OR1. UNPLANNED rapid drop in pnmary 4. a Drywell or Suppression Pool Hydrogen1. Drywell pressure >1.68 pslg. containment pressure following primary concentration > 6%.3. Primary AND containment pressure rise. ANDContainment None None 2. Drywell pressure rise is due to RCS None OR b, Drywell or Suppression Pool OxygenPressurelConditions leakage 2. Primary containment pressure response not concentration 5 5%consistent with LOCA conditions. OR5. Heat Capacity Limit (T-102 Curve SP/T-1))exceeded.3. UNISOLABLE primary system leakage that1. UNISOLABLE Main Steam Line (MSL) results in EITHER of the following:HPIC, Feedwater, RWCU, or RCIC hoe a. Secondary Containment areabreak, temperature > T-1031 SAMP, Max4.RCS Leak Rate None None OR Norm Op Value (MNO) None None2. Emergency RPV Depressurization is OR2.remerbre s Secondary Containment area radiationrequired, level > T-lg31 SAMP, Max Norm OpValue (MNO),5.Primary Drywell radiation monitor reading NoneDrywell radiation monitor readingCnanet >19E52RtrNoeDrywetl radiation monitor reading Nrwe NoneinmoiorradnContainment 1.90 E+02 R/hr. > 100R/hr o 4.35 E+O2 R/hrRadiation1. UNISOLABLE direct downstream pathway tothe environment exists after primarycontainment isolation signal.OR2. Intentional Primary Containmentventing/purging per EOPs or SAGs due toaccident conditions.OR6.Primary 3. UNISOLA1BLE primary system leakage thatContainment None NONE None None 3.UIOAL daysse ekg ht NoneIsotation Failure results in EITHER of the following:a Secondary Containment areatemperature T-1 031 SAMP, MaxSafe Op Value fMNO)ORb. Secondary Containment arearadiation level s T-1031 SAMP, MaxSafe Op Value (MNO)1. Any Condition in the opinion of the 2. Any Condition in the opinion of the 1. ANY Condition in the opinion of the 2 Any Condition in the opinion of the 1. Any Condition in the opinion of the 2. Any Condition in the opinion of the Emergency7. Emergency Emergency Director that indicates Loss Emergency Director that indicates Potential Emergency Director that indicates Loss of Emergency Director that indicates Potential Emergency Director that indicates Loss of the Director that indicates Potential Loss of theDirector Judgment of the Fuel Clad Barrier. Loss of the Fuel Clad Barrier. the RCS Barrier. Loss of the RCS Barrier. Containment Barrier. Containment Barrier.Page 12 of 66 NEI 99-01 Rev 6 1 Proposed EAL JustificationFClCategory: Fuel Clad BarrierRCS ActivityOperating Mode Applicability:Power Operation, Startup, Hot Standby, Hot ShutdownFission Product Barrier Threshold:LossA. (Site specific indications that reactor coolant activity is greater than 300 uCi/gmdose equivalent 1-131)FC1Category: Fuel Clad BarrierRCS ActivityOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LossCoolant activity > 300 uCilgm Dose Equivalent 1-131.E No Change 1-] Difference 1:1 Deviation1) Listed site-specific threshold value to ensure timely classification.Page 13 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Fuel Clad Barrier FC2 Category: Fuel Clad BarrierFC No Change Differ DeviationRPV Water Level RCS Activity 1) Listed site-specific threshold value to ensure timely classification.Operating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Loss LossA. Primary containment flooding required- 1. Plant conditions indicate Primary Containment flooding is required.Potential Loss Potential Loss2. RPV water level cannot be restored and maintained > -161 inches (TAF)A. RPV water level cannot be restored and maintained above (site-specific RPV ORwater level corresponding to top of active fuel) or cannot be determined. 3. RPV water level cannot be determined.Page 14 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Fuel Clad Barrier FC4 Category: Fuel Clad BarrierFC No Change Difference DeviationPrimary Containment Radiation Primary Containment Radiation 1) Listed site-specific monitor and threshold value to ensure timely classification.Operating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Loss LossA. Primary Containment Radiation Monitor reading greater than (site-specific Drywell radiation monitor reading > 1 .90 E+02 RJhr.value).Page 15 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Fuel Clad Barrier FC6 Category: Fuel Clad Barrier FC7 No Change Difference DeviationEmergency Director Judgment Emergency Director JudgmentOperating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1.2, 3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Loss LossA. Any Condition in the opinion of the Emergency Director that indicates Loss of 1. Any Condition in the opinion of the Emergency Director that indicates Loss ofthe Fuel Clad Barrier. the Fuel Clad Barrier.Potential Loss Potential LossA. Any Condition in the opinion of the Emergency Director that indicates Potential 2. Any Condition in the opinion of the Emergency Director that indicates PotentialLoss of the Fuel Clad Barrier. Loss of the Fuel Clad Barrier.Page 16 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Reactor Coolant System Barrier Rd Category: Reactor Coolant System Barrier RC3 E No Change Difference DeviationPrimary Containment Pressure Primary Containment Pressure/Conditions 1) Listed site-specific threshold value to ensure timely classification.Operating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Loss LossA. Primary containment pressure greater than (site-specific value) due to RCS 1. Drywell pressure >1.68 pslg.leakage. AND2. Drywell pressure rise is due to RCS leakagePage 17 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Reactor Coolant System Barrier RC2 Category: Reactor Coolant System Barrier RC2 [ No Change Difference DeviationRPV Water Level RPV Water Level 1) Listed site-specific threshold value to ensure timely classification.Operating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Loss LossA. RPV water level cannot be restored and maintained above (site-specific RPV 1. RPV water level cannot be restored and maintained > -161 inches (TAF)level corresponding to the top of active fuel) or cannot be determined. OR2. RPV water level cannot be determined.Page 18 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Reactor Coolant System Barrier RC3 Category: Reactor Coolant System BarrierRC4 No Change Differe DeviationRCS Leak Rate RCS Leak Rate 1) Listed site-specific systems and threshold values to ensure timely classification.Operating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Loss LossA. UNISOLABLE break in any of the following: ( site-specific systems with potential 1. UNISOLABLE Main Steam Line (MSL), HPIC, Feedwater, RWCU, or RCIC linefor high-energy line breas) break.OR ORB. Emergency RPV Depressurization 2. Emergency RPV Depressurization is required.Potential Loss Potential LossA. UNISOLABLE primary system leakage that results in exceeding EITHER of thefollowing: 3. UNISOLABLE primary system leakage that results in EITHER of the following.a. Secondary Containment area temperature > T-1031 SAMP, Max Norm Op1. Max Normal Operating Temperature Value (MNO)OR OR2. Max Normal Operating Area Radiation Level. b. Secondary Containment area radiation level > T-103/ SAMP, Max Norm OpValue (MNO).Page 19 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Reactor Coolant System Barrier RC4 Category: Reactor Coolant System Barrier RC5 E No Change Difference DeviationPrimary Containment Radiation Primary Containment Radiation 1) Listed site-specific monitor and threshold value to ensure timely classification.Operating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Loss LossA. Primary Containment Radiation Monitor reading greater than (site-specific Drywell radiation monitor reading > IO0R/hrvalue).Page 20 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Reactor Coolant System Barrier RC6 Category: Reactor Coolant System Barrier RC7 No Change Derec DeviationEmergency Director Judgment Emergency director JudgmentOperating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Loss LossA. Any Condition in the opinion of the Emergency Director that indicates Loss of 1. ANY Condition in the opinion of the Emergency Director that indicates Loss ofthe RCS Barrier. the RCS Barrier.Potential Loss Potential LossA. Any Condition in the opinion of the Emergency Director that indicates PotentialLoss of the RCS Barrier. 2. Any Condition in the opinion of the Emergency Director that indicates PotentialLoss of the RCS Barrier.Page 21 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Containment Barrier CTI Category: Containment BarrierCT No Change Diffrenc DeviationPrimary Containment Conditions Primary Containment Pressure/Conditions 1) Listed site-specific threshold values to ensure timely classification.Operating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Loss LossC. UNPLANNED rapid drop in primary containment pressure following primary 1. UNPLANNED rapid drop in primary containment pressure following primarycontainment pressure rise containment pressure rise.OR OR2. Primary containment pressure response not consistent with LOCA conditions.B. Primary containment pressure response not consistent with LOCA conditions.Potential Loss Potential LossD. Primary containment pressure greater than (site-specific value) 3. Containment pressure > 55 psig and rising.OR ORE. (site-specific explosive mixture) exists inside primary containment 4. a. Drywell or Suppression Pool Hydrogen concentration > 6%.OR ANDb. Drywell or Suppression Pool Oxygen concentration > 5%B. HCTL exceeded. OR5. Heat Capacity Limit (T-102 Curve SPIT-1)) exceeded.Page 22 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Containment Barrier CT2 Category: Containment Barrier CT2 No Change Diffrenc DeviationRPV Water Level RPV Water LevelOperating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Potential Loss Potential LossA. Primary containment flooding required. Plant conditions indicate Primary Containment flooding is required.Page 23 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Containment Barrier CT3 Category: Containment BarrierT No Change []Difference DeviationPrimary Containment Isolation Failure Primary Containment Isolation Failure 1) Listed site-specific threshold values to ensure timely classification.Operating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Loss LossA. UNISOLABLE direct downstream pathway to the environment exists after 1. UNISOLABLE direct downstream pathway to the environment exists afterprimary containment isolation signal primary containment isolation signal.OR OR2. Intentional Primary Containment venting/purging per EOPs or SAGs due toB. Intentional primary containment venting per EOPs accident conditions.OR ORC. UNISOLABLE primary system leakage that results in exceeding EITHER of the 3. UNISOLABLE primary system leakage that results in EITHER of the following:following: a. Secondary Containment area temperature > T-1031 SAMP, Max Safe OpValue (MNO)1. Max Safe Operating Temperature. OROR b. Secondary Containment area radiation level > T-1031 SAMP, Max Safe2. Max Safe Operating Area Radiation Level. Op Value (MNO)Page 24 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Containment Barrier CT4 Category: Containment Barrier CT5 F] No Change Difference [ DeviationPrimary Containment Radiation Primary Containment Radiation 1) Listed site-specific monitor and threshold value to ensure timely classification.Operating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Potential Loss Potential LossA. Primary Containment Radiation Monitor reading greater than (site-specificvalue). Drywell radiation monitor reading > 4.35 E+02 R/hrPage 25 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Containment Barrier CT6 Category: Containment BarrierT No Change Diffren DeviationEmergency director Judgment Emergency Director JudgmentOperating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Loss LossA. Any Condition in the opinion of the Emergency Director that indicates Loss of 1. Any Condition in the opinion of the Emergency Director that indicates Loss ofthe Containment Barrier. the Containment Barrier.Potential Loss Potential LossA. Any Condition in the opinion of the Emergency Director that indicates Potential 2. Any Condition in the opinion of the Emergency Director that indicates PotentialLoss of the Containment Barrier. Loss of the Containment Barrier.Page 26 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationSG1 MG1 mInitiating Condition: GENERAL EMERGENCY Initiating Condition: L-'X- No Change j Difference U- DeviationProlonged loss of all offsite and all onsite AC power to emergency buses. Prolonged loss of all offsite and all onsite AC power to emergency buses. 1) Listed site specific equipment, site specific time based on station blackoutOperating Mode Applicability: Operating Mode Applicability: coping analysis, and site specific indication to ensure timely classification.Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3Example Emergency Action Levels: Emergency Action Level (EAL):Note: The Emergency Director should declare the General Emergency promptlyupon determining that (site-specific hours) has been exceeded, or will Note:likely be exceeded. The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. a. Loss of ALL offsite and ALL onsite AC power to (site-specificemergency buses).1 Loss of ALL offsite AC power to unit 4 KV Safeguards Buses.AND AND2. Failure of D11(21) and D12(22), D13(23), and D14(24) Emergency Dieselb. EITHER of the following: Generators to supply power to unit 4KV Safeguards Buses.AND" Restoration of at least one emergency bus in less than(site-specific hours) is not likely. 3. EITHER of the following:a. Restoration of at least one unit 4KV safeguards Bus in < 2 hours is not* (Site-specific indication of an inability to adequately likely.remove heat from the core) ORb. RPV water level cannot be determined to be > -186 inches.Page 27 of 66 NEI 99-01 Rev 6 1 Proposed EAL JustificationSS1Initiating Condition: SITE AREA EMERGENCYLoss of all offsite and all onsite AC power to emergency buses for 15 minutes orlonger.Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Site Area Emergencypromptly upon determining that 15 minutes time has been exceeded, orwill likely be exceeded.Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses)for 15 minutes or longer.MS1Initiating Condition:Loss of all offsite and onsite AC power to emergency busses for 15 minutes orlonger.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC Power to unit 4KV Safeguards Buses.AND2. Failure of O11(21), O12(22), D13(23), and D14(24) Emergency DieselGenerators to supply power to unit 4KV Safeguards Buses.AND3. Failure to restore power to at least one unit 4KV Safeguards bus in < 15minutes from the time of loss of both offsite and onsite AC power.F] No Change Difference FIDeviation1) Listed site specific equipment to ensure timely classification.Page 28 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationSA1Initiating Condition: ALERTLoss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Alert promptly upon determiningthat 15 minutes time has been exceeded, or will likely be exceeded.1. a. AC power capability to (site-specific emergency buses) is reduced to asingle power source for 15 minutes or longer.ANDb. Any additional single power source failure will result in loss of all ACpower to SAFETY SYSTEMS.MAIInitiating Condition:Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. AC power capability to unit 4KV Safeguards Buses reduced to only one of thefollowing power sources for > 15 minutes.* 101 Safeguards Transformer* 201 Safeguards TransformerD 011(21) Diesel Generator* D12(22) Diesel Generator* D13(23) Diesel GeneratorD 014(24) Diesel GeneratorAND2. ANY additional single power source failure will result in a loss of all AC powerto SAFETY SYSTEMS.M No Change FIDifference R Deviation1) Listed site specific equipment to ensure timely classification.Page 29 of 66 NEI 99-01 Rev 6 Proposed EAL [ JustificationSulInitiating Condition: UNUSUAL EVENTLoss of all offsite AC power capability to emergency buses for 15 minutes orlonger.Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes has been exceeded, or will likely beexceeded.Loss of ALL offsite AC power capability to (site-specific emergency buses) for 15minutes or longerMU1Initiating Condition:Loss of all offsite AC power capability to emergency buses for 15 minutes orlonger.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.Loss of ALL offsite AC power capability to unit ECCS busses for > 15 minutes.M No Change D Difference 1 Deviation1) Listed site specific equipment to ensure timely classification.Page 30 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationSG8Initiating Condition: GENERAL EMERGENCYLoss of all AC and Vital DC power sources for 15 minutes or longer.Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the General Emergency promptlyupon determining that 15 minutes has been exceeded, or will likely beexceeded.1. Loss of ALL offsite and ALL onsite AC power to (site-specific emergencybuses) for 15 minutes or longer.ANDIndicated voltage is less than (site-specific bus voltage value) on ALL(site-specific vital DC busses) for 15 minutes or longer.MG2Initiating Condition:Loss of all AC and Vital DC power sources for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to unit 4KV safeguards Buses.AND2. Failure of D1 1(21), D12(22), D13(23), and D14(24) Emergency DieselGenerators to supply power to unit 4KV Safeguards Buses.AND3. Voltage is <105 VDC on 125 VDC battery busses 1(2)FA, FB, FC, and FD for>15 minutes.AND4. ALL AC and Vital DC power sources have been lost for > 15 minutes.H No Change M Difference FIDeviation1) Listed site specific equipment to ensure timely classification.2) Removed the word "indicated" this will allow for an indication problem to notcause confusion on the need to declare.Page 31 of 66 NEI 99-01 Rev 6 ] Proposed EAL JustificationSS8Initiating Condition: SITE AREA EMERGENCYLoss of all Vital DC power for 15 minutes or longer.Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Site Area Emergencypromptly upon determining that 15 minutes time has been exceeded, orwill likely be exceeded.Indicated voltage is less than (site-specific bus voltage value) on ALL Vital DCbuses for 15 minutes or longer.MS2Initiating Condition:Loss of all Vital DC power for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.Voltage is < 105 VDC on 125 VDC battery busses 1(2)FA, FB, FC, and FD for > 15minutes.D No Change M Difference -- Deviation1) Listed site specific equipment and site specific value to ensure timelyclassification.2) Removed the word "indicated" this will allow for an indication problem to notcause confusion on the need to declare.Page 32 of 66 NEI 99-01 Rev 6SS5Initiating Condition: SITE AREA EMERGENCYInability to shutdown the reactor causing a challenge to (core cooling [PWR] / RPVwater level [BWR]) or RCS heat removal.Operating Mode Applicability:Power OperationExample Emergency Action Levels:1. a. An automatic (trip [PWR] / scram [BWR]) did not shutdown thereactor.ANDb. All manual actions to shutdown the reactor have been unsuccessful.ANDc. EITHER of the following conditions exist:1. (Site-specific indication of an inability to adequatelyremove heat from the core)OR2. (Site-specific indication of an inability to adequatelyremove heat from the RCS)Proposed EAL I JustificationMS3Initiating Condition:Inability to shutdown the reactor causing a challenge to RPV water level or RCSheat removal.Operating Mode Applicability:1,2Emergency Action Level (EAL):1. Automatic scram did not shutdown the reactor as indicated by Reactor Power> 4%.AND2. ALL manual / ARI actions to shutdown the reactor have been unsuccessful asindicated by Reactor Power > 4%.AND3. EITHER of the following conditions exist:" RPV water level cannot be restored and maintained > -186 inches.OR" Heat Capacity Limit (T-102 Curve SP/T-1) exceeded.D-1 No Change M Difference FIDeviation1) Listed site specific indications to ensure timely classification.2) Mode 2 included in operating mode applicability as per developer notes.3) Added ARI as an equivalent scramPage 33 of 66 NEI 99-01 Rev 6 1 Proposed EAL JustificationSAOInitiating Condition: ALERTAutomatic or manual (trip [PWR] / scram [BWR]) fails to shutdown the reactor, andsubsequent manual actions taken at the reactor control consoles are notsuccessful in shutting down the reactor.Operating Mode Applicability:Power OperationExample Emergency Action Levels:Note: A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.a. An automatic (trip IPWR] I scram [BWR]) did not shutdown thereactor.ANDb. Manual action taken at the reactor control consoles are notsuccessful in shutting down the reactor.MA3Initiating Condition:Automatic or manual scram fails to shutdown the reactor, and subsequent manualactions taken at the reactor control consoles are not successful in shutting downthe reactor.Operating Mode Applicability:1,2Emergency Action Level (EAL):Note:A manual action is any operator action, or set of actions, which causes the controlrods to be rapidly inserted into the core, and does not include manually driving incontrol rods or implementation of boron injection strategies.1. Automatic or manual scram did not shutdown the reactor as indicated byReactor Power > 4%.AND2. Manual / ARI actions taken at the Reactor Console are not successful inshutting down the reactor as indicated by Reactor Power > 4%.D No Change r -] Difference FIDeviation1 ) Listed site specific indications to ensure timely classification.2) Mode 2 included in operating mode applicability as per developer notes.3) Added ARI as an equivalent scramPage 34 of 66 NEI 99-01 Rev 6 ] Proposed EAL JustificationSU5Initiating Condition: UNUSUAL EVENTAutomatic or manual (trip (PWR] / scram [BWR]) fails to shutdown the reactor.Operating Mode Applicability:Power OperationExample Emergency Action Levels: (1 or 2)Note: A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.1. a. An automatic (trip [PWR] / scram [BWRJ) did not shutdown thereactor.ANDb. A subsequent manual action taken at the reactor control consoles issuccessful in shutting down the reactor.2. a. A manual scram ([PWR] / scram [BVVR]) did not shutdown thereactor.ANDb. EITHER of the following:1. A subsequent manual action taken at the reactor control consolesis successful in shutting down the reactor.OR2. A subsequent automatic (trip [PWR] / scram [BWR]) is successfulin shutting down the reactor.MU3Initiating Condition:Automatic or manual scram fails to shutdown the reactor.Operating Mode Applicability:F No Change M Difference Deviation1) Listed site specific indications to ensure timely classification.2) Mode 2 included in operating mode applicability as per developer notes.3) Added ARI as an equivalent scram1,2Emergency Action Level (EAL):Note:A manual action is any operator action, or set of actions, which causes the controlrods to be rapidly inserted into the core, and does not include manually driving incontrol rods or implementation of boron injection strategies.1. a. Automatic scram did not shutdown the reactor as indicated by ReactorPower > 4%.ANDb. Subsequent manual / ARI action taken at the Reactor Console issuccessful in shutting down the reactor.OR2. a. Manual scram did not shutdown the reactor as indicated by ReactorPower > 4%.ANDb. EITHER of the following:1. Subsequent manual / ARI action taken at the Reactor Console issuccessful in shutting down the reactor.OR2. Subsequent automatic scram / ARI is successful in shutting downthe reactor.Page 35 of 66 NEI 99-01 Rev 6 1 Proposed EAL JustificationSA2Initiating Condition: ALERTUNPLANNED loss of Control Room indications for 15 minutes or longer with asignificant transient in progress.Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Alert promptly upondetermining that 15 minutes has been exceeded, or will likely beexceeded.1. a. An UNPLANNED event results in the inability to monitor ANY of thefollowing parameters from within the Control Room for 15 minutes or longer.[see table below]MA4Initiating Condition:UNPLANNED loss of Control Room indications for 15 minutes or longer with asignificant transient in progress.Operating Mode Applicability:1,2.3Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED event results in the inability to monitor ANY Table M1 parameterfrom within the Control Room for >15 minutes.Table M1 Control Room Parameters" Reactor Power" RPV Water Level" RPV Pressure" Drywell Pressure" Suppression Pool Level" Suppression Pool TemperatureAND2. ANY Table M2 transient in progress.M No Change DIDifference 1 Deviation[ BWR parameter list] [ PWR parameter list]Reactor Power Reactor PowerRPV Level RCS LevelRPV Pressure RCS PressurePrimary Containment Pressure In Core/Core Exit TemperatureLevels in at least (site specificSuppression Pool Level number) steam generatorsSu nPool Temperature Steam Generator Auxiliary orSuppression Emergency Feed Water FlowANDb. Any of the following transient events in progress.* Automatic or Manual runback greater than 25% thermal reactor power* Electrical load rejection greater than 25% full electrical load* Reactor Scram [BWR] / trip [PWR]* ECCS (SI) actuation* Thermal power oscillations greater than 10% [BWR]Table M2 Significant Transients* Automatic or Manual Runback >25% thermal reactor power* Electrical Load Rejection >25% full electrical load* Reactor Scram* ECCS Actuation* Thermal Power oscillations > 10%Page 36 of 66 NEI 99-01 Rev 6 1 Proposed EAL I JustificationSU2Initiating Condition: UNUSUAL EVENTUNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes has been exceeded, or will likely beexceeded.An UNPLANNED event results in the inability to monitor ANY of the followingparameters from within the Control Room for 15 minutes or longer.[see table below][ BWR parameter list] [PWR parameter list]Reactor Power Reactor PowerRPV Level RCS LevelRPV Pressure RCS PressurePrimary Containment Pressure In Core/Core Exit TemperatureLevels in at least (site specificSuppression Pool Level number) steam generatorsSteam Generator Auxiliary orSuppression Pool Temperature Emergency Feed Water FlowMU4Initiating Condition:UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.UNPLANNED event results in the inability to monitor ANY Table M1 parametersfrom within the Control Room for > 15 minutes.M No Change 1 Difference FIDeviationTable M1 Control Room Parameters* Reactor Power* RPV Water Level* RPV Pressure* Drywell Pressure* Suppression Pool Level* Suppression Pool TemperaturePage 37 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationSA9Initiating Condition: ALERTHazardous event affecting a SAFETY SYSTEM needed for the current operatingmode.Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:1. a. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)* Internal or external flooding event* High winds or tornado strike* FIRE* EXPLOSION* (site-specific hazards)* Other events with similar hazard characteristics asdetermined by the Shift ManagerANDb. EITHER of the following:1. Event damage has caused indications of degraded performancein at least one train of a SAFETY SYSTEM needed for thecurrent operating mode.OR2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEMcomponent or structure needed for the current operating mode.MA5Initiating Condition: ALERTHazardous event affecting a SAFETY SYSTEM required for the current operatingmode.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):1. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)* Internal or external flooding event* High winds or tornado strike* FIRE* EXPLOSION* Other events with similar hazard characteristics as determinedby the Shift ManagerAND2. EITHER of the following:a. Event damage has caused indications of degradedperformance in at least one train of a SAFETY SYSTEMrequired by Technical Specifications for the currentoperating mode.ORb. The event has caused VISIBLE DAMAGE to a SAFETYSYSTEM component or structure required by TechnicalSpecifications for the current operating mode.F No Change M Difference FIDeviation1) No additional site specific hazard noted2) Changed the word "needed" to "required" in the IC and "required by TechnicalSpecification" in the EAL to be consistent with terminology used by operators andminimize confusion.Page 38 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationSU4Initiating Condition: UNUSUAL EVENTRCS leakage for 15 minutes or longer.Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels: (1 or 2 or 3)Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes has been exceeded, or will likely beexceeded.1. RCS unidentified or pressure boundary leakage greater than (site-specificvalue) for 15 minutes or longer.2. RCS identified leakage greater than (site-specific value) for 15 minutes orlonger3. Leakage from the RCS to a location outside containment greater than 25gpm for 15 minutes or longerMU6Initiating Condition:RCS leakage for 15 minutes or longer.Operating Mode Applicability:1,2,3F No Change i Difference I Deviation1) Listed site specific values to ensure timely classification.2) Changed wording from containment to drywell for clarity to better define theprimary containment structure.3) In EAL #1 and 2 added "into the drywell" to differentiate between EAL #1/2 and#3. Without this wording would have been in EAL #1 or #2 concurrent with #3. Withthe added wording each EAL can be called separately.Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. RCS unidentified or pressure boundary leakage into the drywell > 10 gpm for> 15 minutes.OR2. RCS identified leakage into the drywell >25 gpm for > 16 minutes.OR3. Leakage from the RCS to a location outside the drywell >25 gpm for > 15minutes.Page 39 of 66 NEI 99-01 Rev 6 Proposed EAL I JustificationInitiating Condition: UNUSUAL EVENTLoss of all onsite or offsite communications capabilitiesOperating Mode Applicability:Power Operation, Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels: (1 or 2 or 3)1. Loss of ALL of the following onsite communication methods:(site-specific list of communications method2. Loss of ALL of the following ORO communications s) methods:(site-specific list of communications methods)3. Loss of ALL of the following NRC communications methods:(site-specific list of communications methods)SU6MU7Initiating Condition:Loss of all onsite or offsite communication capabilities.Operating Mode Applicability:1,2,3No Change F1 Difference FIDeviation1) Listed site specific communication methods to ensure timely classification.Emergency Action Level (EAL):1. Loss of all Table M3 Onsite communications capability affecting theability to perform routine operations.OR2. Loss of all Table M3 Offsite communication capability affecting the abilityto perform offsite notifications.OR3. Loss of all Table M3 NRC communication capability affecting the ability toperform NRC notifications.Table M3 Communications CapabilitySystem Onsite Offslte NRCStation Radio XPlant Public Address (PA) XPrelude System X XStation Phones X X XSatellite Phones X X XNARS XHPN X XENS X XPage 40 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCA2Initiating Condition: ALERTLoss of all offsite and all onsite AC power to emergency buses for 15 minutes orlonger.Operating Mode Applicability:Cold Shutdown, Refueling, DefueledExample Emergency Action Levels:Note: The Emergency Director should declare the Alert promptly upondetermining that 15 minutes time has been exceeded, or will likely beexceeded.Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses)for 15 minutes or longer.CAlInitiating Condition:Loss of all offsite and onsite AC power to emergency busses for 15 minutes orlonger.Operating Mode Applicability:4,5, DEmergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. Loss of all offsite AC power to unit 4KV Safeguards Buses.AND2. Failure of Dl1(21), D12(22), D13(23), and D14(24) Emergency DieselGenerators to supply power to unit 4KV Safeguards Buses.AND3. Failure to restore power to at least one unit 4KV Safeguards bus in< 15 minutes from the time of loss of both offsite and onsite AC power.x No Change --' Difference 1: Deviation1) Listed site specific equipment to ensure timely classification.Page 41 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCU2Initiating Condition: UNUSUAL EVENTLoss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:Cold Shutdown, Refueling, DefueledExample Emergency Action Levels:Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes time has been exceeded, or will likely be exceeded.1. a. AC power capability to (site-specific emergency buses) is reduced to asingle power source for 15 minutes or longer.ANDb. Any additional single power source failure will result in loss of all ACpower to SAFETY SYSTEMS.CUIInitiating Condition:Loss of all but one AC power source to emergency buses for 15 minutes orlonger.Operating Mode Applicability:4,5, DEmergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. AC power capability to unit 4KV Safeguards Buses reduced to only oneof the following power sources for > 15 minutes.* 101 Safeguards Transformer* 201 Safeguards Transformer* D11(21) Diesel Generator* D12(22) Diesel Generator* D13(23) Diesel Generator* D14(24) Diesel GeneratorAND2. ANY additional single power source failure will result in a loss of all ACpower to SAFETY SYSTEMS.E No Change 1:] Difference r-1 Deviation1) Listed site specific equipment to ensure timely classification.Page 42 of 66 NEI 99-01 Rev 6 Proposed EAL I JustificationCASInitiating Condition -ALERTHazardous event affecting SAFETY SYSTEM needed for the current operatingmode.Operating Mode Applicability:Cold Shutdown, RefuelingExample Emergency Action Levels:1. a. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)Internal or external flooding eventHigh winds or tornado strike* FIRE* EXPLOSION( (site-specific hazards)Other events with similar hazard characteristics asdetermined by the Shift ManagerANDb. EITHER of the following:1. Event damage has caused indications of degradedperformance in at least one train of a SAFETY SYSTEMneeded for the current operating mode.OR2. The event has caused VISIBLE DAMAGE to a SAFETYSYSTEM component or structure needed for the currentoperating mode.CA2Initiating Condition:Hazardous event affecting SAFETY SYSTEM required for the current operatingmode.Operating Mode Applicability:4,5Emergency Action Level (EAL):1. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)* Internal or external flooding event* High winds or tornado strike* FIRE* EXPLOSION* Other events with similar hazard characteristics asdetermined by the Shift ManagerAND2. EITHER of the following:a. Event damage has caused indications of degradedperformance in at least one train of a SAFETY SYSTEMrequired by Technical Specifications for the currentoperating mode.ORb. The event has caused VISIBLE DAMAGE to a SAFETYSYSTEM component or structure required by TechnicalSpecifications for the current operating mode.H-- No Change F ] Difference F ] Deviation1) No additional site specific hazards noted2) Changed the word needed to required to be consistent with terminologyused by operators i.e. "required by Technical Specifications", and minimizeconfusion.Page 43 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCU4 U3 D No Change D Dfeec eitoInitiating Condition: UNUSUAL EVENT Initiating Condition: LgcLoss of Vital DC power for 15 minutes or longer. Loss of Vital DC power for 15 minutes or longer. 1) Listed site specific voltage and equipment to ensure timely classification.Operating Mode Applicability: Operating Mode Applicability: 2) Removed the word "indicated" this will allow for an indication problem to notCold Shutdown, Refueling 4, 5 cause confusion on the need to declare.Example Emergency Action Levels: Emergency Action Level (EAL):Note: The Emergency Director should declare the Unusual Event promptly upon Note:determining that 15 minutes time has been exceeded, or will likely beexceeded. The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.Indicated voltage is less than (site-specific bus voltage value) on required Vital DCbuses for 15 minutes or longer.Voltage is < 105 VDC on required 125 VDC battery busses 1(2)FA, FB, FC, andFD for > 15 minutes.Page 44 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCU5Initiating Condition: UNUSUAL EVENTLoss of all onsite or offsite communications capabilitiesOperating Mode Applicability:Cold Shutdown, Refueling, DefuledExample Emergency Action Levels: (1 or 2 or 3)1. Loss of ALL of the following onsite communication methods:(site-specific list of communications method2. Loss of ALL of the following ORO communications s) methods:(site-specific list of communications methods)3. Loss of ALL of the following NRC communications methods:(site-specific list of communications methods)CU4Initiating Condition:Loss of all onsite or offsite communication capabilities.Operating Mode Applicability:4,5, DEmergency Action Level (EAL):1. Loss of all Table C1 Onsite communications capability affecting theability to perform routine operations.OR2. Loss of all Table Cl Offsite communication capability affecting theability to perform offsite notifications.OR3. Loss of all Table C1 NRC communication capability affecting the abilityto perform NRC notifications.E No Change 1 Difference 1 Deviation1) Listed site specific communications methods to ensure timely classificationThble Cl Cammunicntion~ C~nahilltvSystem Onsite Offsite NRCStation Radio XPlant Public Address (PA) XPrelude System X XStation Phones X X XSatellite Phones X X XNARS XHPN X XENS X XPage 45 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCA3 CA5 -NChne Dfeec DeitoInitiating Condition: ALERT Initiating Condition: Cl No Change Difference DeviationInability to maintain the plant in cold shutdown. Inability to maintain plant in cold shutdown. 1) Listed site specific Technical Specification cold shutdown temperature limit andOperating Mode Applicability: Operating Mode Applicability: site-specific pressure reading to ensure timely classification.Cold Shutdown, Refueling 4, 5Example Emergency Action Levels: (1 or 2) Emergency Action Level (EAL):Note: The Emergency Director should declare the Alert promptly upon Note:determining that the applicable has been exceeded, or will likely bede exceededThe Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED increase in RCS temperature to greater than (site-specificTechnical Specification cold shutdown temperature limit) for greater thanthe duration specified in the following table. 1. UNPLANNED rise in RCS temperature > 2000F due to loss of decay2. UNPLANNED RCS pressure increase greater than (site-specific pressure heat removal for > Table C2 duration.reading). (This EAL does not apply during water-solid plant conditions.[PWR]) Table C2 RCS Heat-up Duration ThresholdsTable: RCS Heat-up Duration Thresholds RCS Status Containment Closure Heat-up DurationRCS Status Containment Closure Heat-up Duration StatusStatus Intact Not Applicable 60 minutes*Intact (but not Established 20 minutes*RCS Reduced Not Applicable 60 minutes* Not IntactInventory [PWR])Not Intact (or at Established 20 minutes* Not Established 0 minutesreduced inventory[PWR]) Not Established 0 minutes If an RCS heat removal system is in operation within this timeframe and RCS temperature is being reduced, then EAL #1 is notIf an RCS heat removal system is in operation within this time frame and applicable.RCS temperature is being reduced, the EAL is not applicable.OR2. UNPLANNED RPV pressure rise > 10 psig as a result of temperaturerise due to loss of decay heat removal.Page 46 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCU3 CU5 N a DeInitiating Condition: UNUSUAL EVENT Initiating Condition: 1:j No Change Difference DeviationUNPLANNED increase in RCS temperature. UNPLANNED rise in RCS temperature. 1) Listed site specific Technical Specification cold shutdown temperature limitOperating Mode Applicability: Operating Mode Applicability: to ensure timely classification.Cold Shutdown, Refueling 4, 5 2) Changed the word increase to rise in the initiating condition to be consistentExample Emergency Action Levels: (1 or 2) Emergency Action Level (EAL): with operations language and training.Note: The Emergency Director should declare the Unusual Event promptly Note:upon determining that 15 minutes time has been exceeded, or will likely The Emergency Director should declare the event promptly upon determiningbe exceeded.that the applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED increase in RCS temperature to greater than (site-specificTechnical Specification cold shutdown temperature limit).2. Loss of ALL RCS temperature and (reactor vesselIRCS [PIVR] or RPV 1. UNPLANNED rise in RCS temperatureo> 20lF due to loss of decay[614q]) level indication for 15 minutes or longer. heat removal.OR2. Loss of the following for >16 minutes." ALLRCS temperature indicationsAND" ALLRPV water level indicationsPage 47 of 66 NEI 99-01 Rev 6 Proposed EAL I JustificationCG1Initiating Condition: GENERAL EMERGENCYLoss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory affecting fuel cladintegrity with containment challenged.Operating Mode Applicability:Cold Shutdown, RefuelingExample Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the General Emergencypromptly upon determining that 30 minutes time has been exceeded, orwill likely be exceeded.1. a. (Reactor vessel/RCS [PWR] or RPV [BWR]) vessel level less than (site-specific level) for 30 minutes or longer.ANDb. ANY indication from the Containment Challenge Table2. a.. (Reactor vessel/RCS [PWR] or RPV [BWR]) vessel level cannot bemonitored for 30 minutes or longer.ANDb. Core uncovery is indicated by ANY of the following:* (Site-specific radiation monitor) reading greater than (site-specific value)* Erratic source range monitor indication [PWR]* UNPLANNED increase in (site-specific sump and/or tank levels) ofsufficient magnitude to indicate core uncovery* (Other site-specific indications)ANDc. ANY indication from the Containment Challenge Table).CG6Initiating Condition:Loss of reactor RPV inventory affecting fuel clad integrity with containmentchallenged.Operating Mode Applicability:4,5Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining that the applicabletime has been exceeded, or will likely be exceeded.1 a. RPV water level 4 -161 Inches (TAF) flr > 30 minutes.ANDb. ANY Containment Challenge Indication (Table C4)OR2. a. RPV water level unknown for > 30 minutes.ANDb. Core uncovery is indicated by ANY of the following:Table C3 indications of a sufficient magnitude to indicate core uncovery.OR* Table C5 Refuel Floor Area Radiation Monitor >3 Ryhr.ANDc. ANY Containment Challenge Indication (Table C4)H No Change Z Difference D Deviation1) Listed site specific levels, radiation monitors, and sumps and tanks to ensuretimely classification.2) Listed Explosive mixture in the Containment Challenge Table to ensuretimely classification.3) Worded "cannot be monitored" as unknown to ensure clarity for instanceswhen the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Table C3 Indications of RCS LeakageUNPLANNED floor or equipment sump level rise*UNPLANNED Suppression pool level tise'UNPLANNED vessel make up rate riseObservation of leakage or inventory loss'Rise in level is attributed to a loss of RPV inventory.&#xa3; ________Table: Containment Challenge Table" CONTAINMENT CLOSURE not established*" (Explosive mixture) exists inside containment" UNPLANNED increase in containment pressure" Secondary containment radiation monitor reading above (site-specificvalue) [BWR]if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency isnot reouired.Table C4 Containment Challenge IndlcatlonsPrimary Containment Hydrogen Concentration > 6% and Oxygen > 0%UNPLANNED rise in containment pressureCONTAINMENT CLOSURE not established*ANY Secondary Containment radiation monitor , T-1031 SAMP Max Safe Op Value(MSOI.if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncoverytime limit, then escalation to a General Emergency is not required.Table C5Refuel Floor ARM'eRIS29-Mt-1(2)K600, Drywell Head Laydown* RIS30-Mt-1(2)K600, Dryer I Separator AreaRIS31-Mi-I(2)K600, Spent Fuel PoolRIS32-Mt-1(2)K600, New Fuel storage Vault* RIS33-Mlt-l(2)K6D0, Pool Plug LaydownPage 48 of 66 NEI 99-01 Rev 6 [ Proposed EAL I JustificationCS1Initiating Condition: SITE AREA EMERGENCYLoss of (reactor vessel/RCS [PWR] or RPV [BWRJ) inventory affecting coredecay heat removal capability.Operating Mode Applicability:Cold Shutdown, RefuelingExample Emergency Action Levels: (1 or 2 or 3)Note: The Emergency Director should declare the Site Area Emergencypromptly upon determining that 30 minutes time has been exceeded, orwill likely be exceeded.1. a. CONTAINMENT CLOSURE not established.ANDb. (Reactor vessel/RCS [PWR] or RPV [Bl4R]) level less than (site-specific level).2. a. CONTAINMENT CLOSURE established.ANDb. (Reactor vessel/RCS [PWR] or RPV [BWR]) level less than (site-specific level).3. a. (Reactor vessel/RCS [PWR] or RPV [BI4.R]) level cannot bemonitored for 30 minutes or longer.ANDb. Core uncovery is indicated by ANY of the following:* (Site-specific radiation monitor) reading greater than (site-specific value)* Erratic source range monitor indication [PlWR* UNPLANNED increase in (site-specific sump and/or tanklevels) of sufficient magnitude to indicate core uncovery* (Other site-specific indications)CS6Initiating Condition:Loss of RPV inventory affecting core decay heat removal capabilities.Operating Mode Applicability:4,5Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.1. With CONTAINMENT CLOSURE not established, RPV water level < -129 inches.OR2. With CONTAINMENT CLOSURE established, RPV water level < -161inches (TAF)OR3. a. RPV water level unknown for > 30 minutesANDb. Core uncovery is indicated by ANY of the following:* Table C3 indications of a sufficient magnitude to indicate coreuncovery.OR* ANY Table C5 Refuel Floor Area Radiation Monitor >3 R/hr.Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Suppression pool level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.H No Change W Difference 1 Deviation1) Listed site specific values for level, radiation monitors, and sumps and tanksto ensure timely classification.2) Worded "cannot be monitored" as unknown to ensure clarity for instanceswhen the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Table CSRefuel Floor ARM's* RIS29-M1-1(2)K600, Drywell Head Laydown* RIS30-M1-1(2)K600, Dryer / Separator Area* RIS31-M1-1(2)K600, Spent Fuel Pool* RIS32-M1-I(2)K600, New Fuel storage Vault* RIS33-M1-1(2)K600, Pool Plug LaydownPage 49 of 66 NEI 99-01 Rev 6 [ Proposed EAL I JustificationCA1Initiating Condition: ALERTLoss of (reactor vessel/RCS [PWR] or RPV [BI/R]) inventoryOperating Mode Applicability:Cold Shutdown, RefuelingExample Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Alert promptly upondetermining that 15 minutes time has been exceeded, or will likely beexceeded.1. Loss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory asindicated by level less than (site-specific level).2. a. (Reactor vessel/RCS [PWR] or RPV [BWR]) level cannot bemonitored for 15 minutes or longerANDb. UNPLANNED increase in (site-specific sump and/or tank) levels dueto a loss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory.CA6Initiating Condition:Loss of RPV inventoryOperating Mode Applicability:4,5Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.1. Loss of RPV inventory as indicated by level < -38 inches.OR2. a. RPV water level unknown for> 15 minutes.ANDb. Loss of RPV inventory per Table C3 indications.Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Suppression pool level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.H No Change W Difference 1 Deviation1) Listed site specific levels, and sumps and tanks to ensure timelyclassification.2) Worded "cannot be monitored" as unknown to ensure clarity for instanceswhen the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Page 50 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCutInitiating Condition: UNUSUAL EVENTUNPLANNED loss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory for15 minutes or longer.Operating Mode Applicability:Cold Shutdown, RefuelingExample Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes has been exceeded, or will likely beexceeded.1. UNPLANNED loss of reactor coolant results in (reactor vessel/RCS[PWR] or RPV [BWR]) level less than a required lower limit for 15minutes or longer.2. a. (Reactor vessel/RCS [PlR] or RPV [BWR]) level cannot bemonitored.ANDb. UNPLANNED increase in (site-specific sump and/or tank) levels.CU6Initiating Condition:UNPLANNED loss of RPV inventory for 15 minutes or longer.Operating Mode Applicability:4,5Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.UNPLANNED loss of reactor coolant results in the inability to restoreand maintain RPV water level above the procedurally establishedlower limit for > 15 minutes.OR2. a. RPV water level unknownANDb. Loss of RPV inventory per Table C3 indications.D No Change E Difference --- Deviation1) Described "a required lower limit" as a procedurally established lower limit,and listed site specific sumps and tanks to ensure timely classification.2) Worded "cannot be monitored" as unknown to ensure clarity for instanceswhen the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Suppression pool level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.Page 51 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationNEI 99-01 Rev 6Proposed EALJustificationHG1HG1Initiating Condition: GENERAL EMERGENCYHOSTILE ACTION resulting in loss of physical control of the facility.Operating Mode Applicability:AllExample Emergency Action Levels:1. a. A HOSTILE ACTION is occurring or has occurred within the PROTECTEDAREA as reported by the (site-specific security shift supervision).ANDb. EITHER of the following:1. ANY of the following safety functions cannot be controlled ormaintained.Reactivity control* Core cooling [PqR] I RPV water level [BWR]* RCS heat removalOR2. Damage to spent fuel has occurred or is IMMINENTInitiating Condition:HOSTILE ACTION resulting in loss of physical control of the facility.Operating Mode Applicability:1, 2, 3,4, 5, DEmergency Action Level (EAL):1. A notification from the Security Force that a HOSTILE ACTION is occurringor has occurred within the PROTECTED AREA.AND2. a. ANY Table Hi safety function cannot be controlled or maintained.ORb. Damage to spent fuel has occurred or is IMMINENTTable HI Safety Functions" Reactivity Control (ability to shut down the reactor and keep it shutdown)" RPV Water Level (ability to cool the core)" RCS Heat Removal (ability to maintain heat sink)D- No Change FX Difference 1-- Deviation1) List site security shift supervision as Security Force.2) Added descriptors to better explain each safety function and allow for a timelyclassification.Page 52 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationHSIInitiating Condition: SITE AREA EMERGENCYHOSTILE ACTION within the Protected Area.Operating Mode Applicability:AllExample Emergency Action Levels:A HOSITLE ACTION is occurring or has occurred within the PROTECTED AREAas reported by the (site-security shift supervision).HSIInitiating Condition:HOSTILE ACTION within the Protected Area.M No Change 1 Difference I Deviation1) List site security shift supervision as Security Force.Operating Mode Applicability:1,2, 3,4, 5, DEmergency Action Level (EAL):A notification from the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the PROTECTED AREA.Page 53 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationHAI HAIInitiating Condition: ALERT Initiating Condition: F No Change Difference DeviationHOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack 1) List site security shift supervision as Security Force.threat within 30 minutes. threat within 30 minutes.Operating Mode Applicability: Operating Mode Applicability:All 1,2, 3, 4, 5, DExample Emergency Action Levels: (1 or 2) Emergency Action Level (EAL):1. A HOSTILE ACTION is occurring or has occurred within the OWNER 1. A validated notification from NRC of an aircraft attack threat < 30 minutesCONTROLLED AREA as reported by the (site-specific security shift from the site.supervision).2. A validated notification from NRC of an aircraft attack threat within 30 ORminutes of the site.2. Notification by the Security Force that a HOSTILE ACTION is occurring orhas occurred within the OWNER CONTROLED AREA.Page 54 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationHU1 HUl r---] m ifrne eitoInitiating Condition: UNUSUAL EVENT Initiating Condition: LHU No Change M Difference FJ DeviationConfirmed SECURITY CONDITION or threat.Confirmed SECURITY CONDITION or threat. 1) List site security shift supervision as Security Force.Operating Mode Applicablity: Mode Applicability: 2) Further described credible security threat through listing a site specificOperating Mprocedure.All1,2, 3, 4, 5, DExample Emergency Action Levels: (1 or 2 or 3)Emergency Action Level (EAL):1. A SECURITY CONDITION that does not involve a HOSTILE ACTION asreported by the (site-specific security shift supervision). 1. Notification of a credible security threat directed at the site as determined perSY-AA-101-132, Security Assessment and Response to Unusual Activities.2. Notification of a credible security threat directed at the site. OR2. A validated notification from the NRC providing information of an aircraft3. A validated notification from the NRC providing information of an aircraft threat.threat.OR3. Notification by the Security Force of a SECURITY CONDITION that does notinvolve a HOSTILE ACTION.Page 55 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationHS6 HS2 m NoCag m ifrne eitoInitiating Condition: SITE AREA EMERGENCY Initiating Condition: L[ No Change M Difference LJ DeviationInability to control a key safety function from outside the Control Room. Inability to control a key safety function from outside the Control Room. 1) EAL uses the site specific Control Room evacuation procedures to effectivelylist all of the alternate locations, panels, and stations requested by the developernotes. This would be the procedures the Control Room would enter should such anOperating Mode Applicability: Operating Mode Applicability: event occur, this allows for greater clarity as to when this EAL would apply than ifeach panel and station used in alternate shutdown were to be listed,All 1,2, 3,4, 5,0D2) Added descriptors to better explain each safety function and allow for a timelyclassification.Example Emergency Action Levels: (1 and 2) Emergency Action Level (EAL):Note: The Emergency Director should declare the Site Area Emergency promptly Note: 3) Changed "An event" to" A Control Room evacuation" to remove confusion ifupon determining that (site-specific number of minutes) has been partial plant control was transferred to outside the control room with the controlexceeded, or will likely be exceeded. The Emergency Director should declare the event promptly upon determining that room still manned, due to testing or equipment failure.the applicable time has been exceeded, or will likely be exceeded.1. An event has resulted in plant control being transferred from the ControlRoom to (site-specific remote shutdown panels and local control stations). 1. A Control Room evacuation has resulted in plant control being transferredfrom the Control Room to alternate locations per:2. Control of ANY of the following key safety functions is not reestablished .SE-i, Remote Shutdownwithin (site-specific number of minutes). ORSReactivity control .SE-6, Altemate Remote ShutdownCore cooling [PWR] / RPV water level [BWyR] AND* RCS heat removal 2. Control of ANY Table H1 key safety function is not reestablished in < 15minutes.Table HI Safety Functions* Reactivity Control (ability to shut down the reactor and keep it shutdown)* RPV Water Level (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)Page 56 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationHA6 HA2 mFInitiating Condition: ALERT Initiating Condition: LF No Change M -J Difference ']DeviationControl Room evacuation resulting in transfer of plant control to alternate locations. Control Room evacuation resulting in transfer of plant control to alternate locations. 1) EAL uses the site specific Control Room evacuation procedures to effectivelylist all of the alternate locations, panels, and stations requested by the developernotes. This would be the procedures the Control Room would enter should such anOperating Mode Applicability: Operating Mode Applicability: event occur, this allows for greater clarity as to when this EAL would apply than ifeach panel and station used in alternate shutdown were to be listed,All 1, 2, 3, 4, 5, D 2) Changed "An event" to" A Control Room evacuation" to remove confusion ifpartial plant control was transferred to outside the control room with the controlExample Emergency Action Levels: Emergency Action Level (EAL): room still manned, due to testing or equipment failure.An event has resulted in plant control being transferred from the Control Room to A Control Room evacuation has resulted in plant control being transferred from the(site-specific remote shutdown panels and local control stations). Control Room to alternate locations per:" SE-1, Remote ShutdownOR" SE-6, Alternate Remote ShutdownPage 57 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationHU4HU3Initiating Condition: UNUSUAL EVENTFIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:Initiating Condition:FIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:1,2, 3, 4, 5, DI-X- No Change FIDifference FIDeviation1) Listed site specific list of plant rooms or areas that contain SAFETY SYSTEMequipment to ensure timely classification.AllExample Emergency Action Levels: (1 or 2 or 3 or 4)Note: The Emergency Director should declare the Unusual Eventpromptly upon determining that the applicable time has beenexceeded, or will likely be exceeded.1. a. A FIRE is NOT extinguished within 15-minutes of ANY of the followingFIRE detection indications:* Report from the field (i.e., visual observation)* Receipt of multiple (more than 1) fire alarms or indications* Field verification of a single fire alarmANDb. The FIRE is located within ANY of the following plant rooms or areas:(site-specific list of plant rooms or areas)2. a. Receipt of a single fire alarm (i.e., no other indications of a FIRE).ANDb. The FIRE is located within ANY of the following plant rooms or areas:(site-specific list of plant rooms or areas)ANDc. The existence of a FIRE is not verified within 30-minutes of alarm receipt.3. A FIRE within the plant or ISFSI [for plants with an ISFSI outside the plantProtected Area] PROTECTED AREA not extinguished within 60-minutes ofthe initial report, alarm or indication.4. A FIRE within the plant or ISFSI [for plants with an ISFSI outside the plantProtected Area] PROTECTED AREA that requires firefighting support by anoffsite fire response agency to extinguish.Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.1. A FIRE in ANY Table H2 area is not extinguished in < 15-minutes of ANYof the following FIRE detection indications:* Report from the field (i.e., visual observation)* Receipt of multiple (more than 1) fire alarms or indications* Field verification of a single fire alarmTable H2 Vital Areas* Reactor Enclosure (when inerted the drywell is exempt)* Control Enclosure* Diesel Generator Enclosure* Spray Pond Pump House / Spray NetworkOR2. a. Receipt of a single fire alarm in ANY Table H2 area (i.e., no otherindications of a FIRE).ANDb. The existence of a FIRE is not verified in< 30 minutes of alarm receipt.OR3 A FIRE within the plant PROTECTED AREA not extinguished in < 60-minutes of the initial report, alarm or indication.OR4 A FIRE within the plant PROTECTED AREA that requires firefightingsupport by an offsite fire response agency to extinguish.Page 58 of 66 NEI 99-01 Rev 6 j Proposed EAL I JustificationHU2HU4Initiating Condition: UNUSUAL EVENTSeismic event greater than OBE levels.Operating Mode Applicability:Initiating Condition:Seismic event greater than OBE levels.Operating Mode Applicability:1, 2,3, 4, 5, DF' No Change F Difference FIDeviation1) Provided site specific indications to aid in timely classification.AllExample Emergency Action Levels:Seismic event greater than Operating Basis Earthquake (OBE) as indicated by:a. (site-specific indication that a seismic event met or exceeded OBE limits)Emergency Action Level (EAL):Seismic event > Operating Basis Earthquake (OBE) as indicated by:" ARC-MCR-00C693, WINDOW B1, OBE EXCEEDED alarmedOR" OBE red light is lit at panel 00C693Page 59 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationHASInitiating Condition: ALERTGaseous release impeding access to equipment necessary for normal plantoperations, cooldown or shutdown.Operating Mode Applicability:AllExample Emergency Action Levels:Note: If the equipment in the listed room or area was already inoperable, or out ofservice, before the event occurred, then no emergency classification iswarranted.1 .a. Release of a toxic, corrosive, asphyxiant or flammable gas into any ofthe following plant rooms or areas:(site-specific list of plant rooms or areas with entry-related modeapplicability identified)ANDb. Entry into the room or area is prohibited or impeded.HASInitiating Condition:Gaseous release impeding access to equipment necessary for normal plantoperations, cooldown or shutdown.Operating Mode Applicability:1, 2, 3,4, 5, DEmergency Action Level (EAL):Note:If the equipment in the listed room or area was already inoperable, or out ofservice, before the event occurred, then no emergency classification is warranted.1. Release of a toxic, corrosive, asphyxiant or flammable gas in a Table H3 area.Table H3Areas with Entry Related Mode ApplicabilityArea Entry Related Mode ApplicabilityReactor Enclosure* Modes 3, 4, and 5*Areas required to establish shutdown coolingAND2. Entry into the room or area is prohibited or impededH No Change FIDifference FIDeviation1) Listed plant specific rooms and areas with entry related mode applicability toensure timely classification.Page 60 of 66 NEI 99-01 Rev 6 1 Proposed EAL JustificationHU3HU6Initiating Condition: UNUSUAL EVENTHazardous EventInitiating Condition:M No Change F Difference F Deviation1) No site specific list of natural or technological hazard events was noted.Operating Mode Applicability:AllExample Emergency Action Levels: (1 or 2 or 3 or 4)Note: EAL #4 does not apply to routine traffic impediments such as fog, snow,ice, or vehicle breakdowns or accidents.1. A tornado strike within the PROTECTED AREA.2. Internal room or area flooding of a magnitude sufficient to require manualor automatic electrical isolation of a SAFETY SYSTEM component neededfor the current operating mode.3. Movement of personnel within the PROTECTED AREA is impeded due toan offsite event involving hazardous materials (e.g., an offsite chemicalspill or toxic gas release).4. A hazardous event that results in on-site conditions sufficient to prohibitthe plant staff from accessing the site via personal vehicles.5. (Site-specific list of natural or technological hazard events)Hazardous EventOperating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Note:EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, orvehicle breakdowns or accidents.1. Tornado strike within the PROTECTED AREA.OR2. Internal room or area flooding of a magnitude sufficient to require manual orautomatic electrical isolation of a SAFETY SYSTEM component required byTechnical Specifications for the current operating mode.OR3. Movement of personnel within the PROTECTED AREA is impeded due to anoffsite event involving hazardous materials (e.g., an offsite chemical spill ortoxic gas release).OR4. A hazardous event that results in on-site conditions sufficient to prohibit theplant staff from accessing the site via personal vehicles.Page 61 of 66 NEI 99-01 Rev 6 Proposed EAL I JustificationHG7HG7M No Change I Difference FIDeviationInitiating Condition: GENERAL EMERGENCYOther conditions exist which in the judgment of the Emergency Director warrantdeclaration of a General Emergency.Operating Mode Applicability:AllExample Emergency Action Levels:Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve actual or IMMINENTsubstantial core degradation or melting with potential for loss of containmentintegrity or HOSTILE ACTION that results in an actual loss of physical control ofthe facility. Releases can be reasonably expected to exceed EPA Protective ActionGuideline exposure levels off-site for more than the immediate site area.Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a General Emergency.Operating Mode Applicability:1, 2, 3, 4. 5, DEmergency Action Level (EAL):Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve actual or IMMINENTsubstantial core degradation or melting with potential for loss of containmentintegrity or HOSTILE ACTION that results in an actual loss of physical control ofthe facility. Releases can be reasonably expected to exceed EPA ProtectiveAction Guideline exposure levels off-site for more than the immediate site area..Page 62 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationInitiating Condition: SITE AREA EMERGENCY Initiating Condition: LSi No Change [j Difference [j DeviationOther conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a Site Area Emergency. declaration of a Site Area Emergency.Operating Mode Applicability: Operating Mode Applicability:All 1,2, 3,4, 5, DExample Emergency Action Levels: Emergency Action Level (EAL):Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve actual or likely mao Other conditions exist which in the judgment of the Emergency Director indicatel y major that events are in progress or have occurred which involve actual or likely majorfailures of plant functions needed for protection of the public or HOSTILE ACTION failures of plant functions needed for protection of the public or HOSTILE ACTIONthat results in intentional damage or malicious acts; (1) toward site personnel or that results in intentional damage or malicious acts; (1) toward site personnel orequipment that could lead to the likely failure of or; (2) that prevent effective equipment that could lead to the likely failure of or; (2) that prevent effectiveaccess to equipment needed for the protection of the public. Any releases are notexpected to result in exposure levels which exceed EPA Protective Action access to equipment needed for the protection of the public. Any releases are notGuiexp netedtoresultn exposure levels wthextebudEPaPr oexpected to result in exposure levels which exceed EPA Protective ActionGuideline exposure levels beyond the site boundary. Guideline exposure levels beyond the site boundary.Page 63 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationHA7 HA7Initiating Condition: ALERT Initiating Condition: L-M No Change F Difference 1 DeviationOther conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an Alert. declaration of an Alert.Operating Mode Applicability: Operating Mode Applicability:All 1, 2, 3,4, 5, DExample Emergency Action Levels: Emergency Action Level (EAL):Other conditions exist which in the judgment of the Emergency Director indicate Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve an actual or potentialsubstantial degradation of the level of safety of the plant or a security event that that events are in progress or have occurred which involve an actual or potentialinvolves probable life threatening risk to site personnel or damage to site substantial degradation of the level of safety of the plant or a security event thatequipment because of HOSTILE ACTION. Any releases are expected to be involves probable life threatening risk to site personnel or damage to sitelimited to small fractions of the EPA Protective Action Guideline exposure levels, equipment because of HOSTILE ACTION. Any releases are expected to belimited to small fractions of the EPA Protective Action Guideline exposure levels.Page 64 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationHU7 HU7Initiating Condition: UNUSUAL EVENT Initiating Condition: L-i No Change U Difference [j DeviationOther conditions existing which in the judgment of the Emergency director warrantdeclaration of an UNUSUAL EVENT. Other conditions existing which in the judgment of the Emergency director warrantdeclaration of an UNUSUAL EVENT.Operating Mode Applicability:Operating Mode Applicability:All1, 2, 3, 4, 5, DExample Emergency Action Levels: Emergency Action Level (EAL):Other conditions exist which in the judgment of the Emergency Director indicate Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which indicate a potential that events are in progress or have occurred which indicate a potentialdegradation of the level of safety of the plant or indicate a security threat to facility degradation of the level of safety of the plant or indicate a security threat to facilityprotection has been initiated. No releases of radioactive material requiring offsite protection has been initiated. No releases of radioactive material requiring offsiteresponse or monitoring are expected unless further degradation of safety systems response or monitoring are expected unless further degradation of safety systemsoccurs. occurs.Page 65 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationE-HUI E-HUIInitiating Condition: UNUSUAL EVENT Initiating Condition: Li No Change M Difference F DeviationDamage to a loaded cask CONFINEMENT BOUNDARY.Damage to a loaded cask.CONFINEMENT BOUNDARY. 1) Listed 2x the site specific cask specific allowable radiation level as per LimerickGenerating Station ISFS1 1OCFR72.212 Evaluation Rev 6 Attachment 1 certificateOperating Mods Applicability: Operating Mode Applicability: of Compliance evaluation.All 2) Not all technical specification radiation readings were on contact, one is a1, 2, 3, 4, 5, D radiation reading at 3ft required by technical specification. Modified the EAL byremoving the "on the surface" requirement, and required "a radiation reading"Example Emergency Action Levels: allowing for the technical specification 3ft reading to be added to the EAL.Emergency Action Level (EAL):Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than (2 times the site-specific cask specific Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by atechnical specification allowable radiation level) on the surface of the spent fuel radiation reading:cask.* > 1400 mremlhr on the HSM or HSM-H front surface (applicable to type 161BTH DSC only)OR* > 800 mrem/hr at 3 ft from the HSM surface (applicable to 61 BT DSConly)OR* > 200 mremlhr on the HSM or HSM-H door centerlineOR* > 40 mremlhr on the end shield wall exteriorPage 66 of 66 Limerick Generatina Station AnnexExelon NuclearL..m.ri.k.Ge.eratina Statio.AnnexE....nNucle.RECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSARGIInitiating Condition:Release of gaseous radioactivity resulting in offsite dose greater than 1000 mRfem TEDEor 5000 mRfem thyroid CDE.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the General m=F.ergenGy event promptly upon Idetermining that the applicable time has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to theenvironment is established. If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment usingactual meteorology are available.(1) Reading o,; 'n ANY o-f t.he following radiation monitorS greater thaR the reading shownfr15- minute or loner:(site specific monitor list and threshold values)1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15 minutes:Table R1 Effluent Monitor ThresholdsRelease Path General EmergencyNorth Stack (WR Monitor: RIX-26-076-4) 1.92 E+08 uCi/secSouth Stack (Unit 1: RY26-185A-3 / 2.71 E-01 uCi/secRY26-185-B-3 or Unit 2: RY26-285A-3 /RY26-285-B-3)OR2. Dose assessment using actual meteorology indicates doses at or beyond (site-speGifirdc.e rFecoptr point) the site boundary of EITHER:Month 20XXLGS 3-1EP-AA-1008 (Revision XX)
I .imnri,.k (' Znghreafnr -Q*~m;len A nnnvI::v, Inn , ir-l,-arbulllt~i111 1 -V III If I;II ll b4Ul l l*~q u lRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSa. > 1000 mRem TEDEORb. > 5000 mRem CDE ThyroidORr-1810 SUrFe'; reSURS naicate ' .., ,,v, ,, n oWIng a! or DeYA ,cl. e v p,,... Cdose roceptor point):&#xfd;L_ --A ^^^ -#-% It--A _J L L!_ z160 minu-tes- or longer.vu~~vv -ww l V. 1A v i v u .~ v l v v v V l~ .* tHCn1nbW_1 _. MMl NU -VV3 tlV tF- 9106 tf tHC*HV l i de l V t nld H I nfor one hou r of inhalation.3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >1000 mR/hr are expected to continuefor > 60 minutes.ORb. Analyses of field survey samples indicate > 5000 mRem CDE Thyroid for60 minutes of inhalation.Basis:This IC addresses a release of gaseous radioactivity that results in projected or actualoffsite doses greater than or equal to the EPA Protective Action Guides (PAGs). Itincludes both monitored and un-monitored releases. Releases of this magnitude willrequire implementation of protective actions for the public.Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.The TEDE dose is set at the EPA PAG of 1000 mRrem while the 5000 mRfem thyroidCDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE andthyroid CDE.Classification based on efflent maontor readings assumes~ that a releanre path to thenirnent is established. if the effluent flow past an effluent monGitor is known to hav,stopped due to- a-c-tions to ilate the release path, th;n the monitor rAFeadn is no.nAer Valid for cl.assific.ation Du ses.Month 20XXLGS 3-2EP-AA-1008 (Revision XX)
I imarirnk r-anarnting Rt~ation Annex Exellon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSBasis Reference(s):1. NEI 99-01 Rev 6, AG12. LGS ODCM3. EP-EAL-0608 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Limerick Generating Station4. DBD L-S-43, Radiation Monitoring SystemMonth 20XXLGS 3-3EP-AA-1008 (Revision XX)
I im rele9n nofn Q nin n nP:v--Itnn Ik .l-A nrI r~-L tna~* nn~f*nnAn~v... .n .a.se t..r ...,..*.~.RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSARS1Initiating Condition:Release of gaseous radioactivity resulting in offsite dose greater than 100 mRfem TEDEor 500 mRfem thyroid CDE.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the v.it.oArAea event promptlyupon determining that the applicable time has been exceeded, or will likely beexceeded.* If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to theenvironment is established. If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment usingactual meteorology are available.(1) Reading on ANY of the foelowing Fadiation mo~nitors greater than the_ reading shownfo-r 1 5 minlute Or logqer:(Site Specific_ mo-nitor list and threshold ':alue6)(2) Dorse assessment using ac-tual meteorology indicates doses greater than 100QmreAm TEE r, O1500 mr;em; thyroid CDE At Or beyond (site specific dose recepto(3) Field suivey results- iniaeETHEROf the9 folloIwing at Or beyond (Site specificdose rcpOR O;n~" Closed v.'ndow dose rates greater- than 100 mR'hr expected to continufe for- 60 mainuteser- lnger-" Analyses of field survey samples indicate thyroeid CDE greater- than 500 ffrem for- oneh10ur Of ifihala~tio.Month 20XXLGS 3-4EP-AA-1008 (Revision XX)
Ii m rie- ( Zanghaf5inn -Q*a*rnn Anna-wI::y,-I~n RECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15 minutes:Table RI Effluent Monitor ThresholdsRelease Path Site Area EmergencyNorth Stack (WR Monitor: RIX-26-076-4) 1.92 E+07 uCi/secSouth Stack (Unit 1: RY26-185A-3 / 2.71 E-02 uCi/secRY26-185-B-3 or Unit 2: RY26-285A-3 /RY26-285-B-3)OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 100 mRem TEDEORb. > 500 mRem CDE ThyroidOR3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >100 mR/hr are expected to continuefor > 60 minutes.ORb. Analyses of field survey samples indicate > 500 mRem CDE Thyroid for 60minutes of inhalation.Basis:This IC addresses a release of gaseous radioactivity that results in projected or actualoffsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs).It includes both monitored and un-monitored releases. Releases of this magnitude areassociated with the failure of plant systems needed for the protection of the public.Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsMonth 20XXLGS 3-5EP-AA-1008 (Revision XX)
I irngri#-L- f'-gsnghrimfin Qfmfirn AnnghvI::valnn ld, I iy~r.., ~~i~~*hi, Annv vannM~,.azRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSmore fully addresses the spectrum of possible accident events and conditions.The TEDE dose is set at 10% of the EPA PAG of 1000 mRfem while the 500 mRfemthyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDEand thyroid CDE.Classification bassed On fM'unt mnitor rFeadines assumes that a release oath tothe eny.;irnment. ;i. eabise. If th.. flo.., past an effluent monQ.itor is knoWn tohavestoped due to actions, to isolate the release path, then the effluent monitor readinis no loner valid for. classific-atio pupoesEscalation of the emergency classification level would be via IC RAG1.Basis Reference(s):1. NEI 99-01 Rev 6, AS12. LGS ODCM3. EP-EAL-0608 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Limerick Generating Station4. DBD L-S-43, Radiation Monitoring SystemMonth 20XXLGS 3-6EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSARAIInitiating Condition:Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mRremTEDE or 50 mRr-em thyroid CDE.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the Afe44-vent promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to theenvironment is established. If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment usingactual meteorology are available.for: 1 5 minlutes Or longer:(site Specific monitor list and threshold values)(2) Dose assessment using actual mneteorology indicaters dosos6 greater than 10 QmneroTEDE Or 50 mrcrn thyroid OIDE at Or beyond (Site specific dose Freeptor point).(3) Analysis of a liquid effluen;t " amp. e iRdicates- a on-entration Or release rate thatwould result ir doses, greateF than 10 FFFm TEDE Or 50 mnenm thyroid ODE atorbeyond (site specific dose Freeptor point) for one hour Of exposure(4) Field survey Fresults indicate EITHER of the follew.ing at Or beyond (site specificdose... re..,eptor., " Closed vindo dose rates greater- than 10 mR:, expe.ted to continue for 60 minutes or-" Analyses of field sun.'ey samples indicate thyroid CDE greater- than 50 mremn for- oemhourL of inhalation.Month 20XXLGS 3-7EP-AA-1008 (Revision XX)
ExAIon NuclearLimeric~k Generatina Station Annex Exelnn Nuclea~rRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS1. Readings on ANY Table R1 Effluent Monitor > Table RI value for > 15 minutes.Table R1 Effluent Monitor ThresholdsRelease Path AlertNorth Stack (WR Monitor: RIX-26-076-4) 1.92 E+06 uCi/secSouth Stack (Unit 1: RY26-185A-3 / 2.71 E-03 uCi/secRY26-185-B-3 or Unit 2: RY26-285A-3 /RY26-285-B-3)OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 10 mRem TEDEORb. > 50 mRem CDE ThyroidOR3. Analysis of a liquid effluent sample indicates a concentration or release rate thatwould result in doses greater than EITHER of the following at or beyond the siteboundary:a. 10 mRem TEDE for 60 minutes of exposureORb. 50 mRem CDE Thyroid for 60 minutes of exposureOR4. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates > 10 mR/hr are expected tocontinue for > 60 minutes.ORMonth 20XXLGS 3-8EP-AA-1008 (Revision XX)
I imarink fllanamfinn Atntinn AnnaXIExelon NuclearI imrirk (~arninn tatnn An~vExelon Nucla~rRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSb. Analyses of field survey samples indicate > 50 mRem CDEThyroid for 60 minutes of inhalation.Basis:This IC addresses a release of gaseous or liquid radioactivity that results in projected oractual offsite doses greater than or equal to 1% of the EPA Protective Action Guides(PAGs). It includes both monitored and un-monitored releases. Releases of thismagnitude represent an actual or potential substantial degradation of the level of safety ofthe plant as indicated by a radiological release that significantly exceeds regulatory limits(e.g., a significant uncontrolled release).Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.The TEDE dose is set at 1% of the EPA PAG of 1000 mRfem while the 50 mRrem thyroidCDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE andthyroid CDE.Classificaation b-ased- On e-fflue'n t Mon-itor readings assumes. that. a rele9ase path toDthe enVironment is established. if the effluent flow past- an effluent moenitor is known tohave stopped due to actions to iotethe release path, then the effluent moenitor readingisr no longer valid for classificatio pupse-.Escalation of the emergency classification level would be via IC RAS1.Basis Reference(s):1. NEI 99-01 Rev 6, AA12. LGS ODCM3. EP-EAL-0608 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Limerick Generating Station4. L-S-43 Radiation Monitoring System5. ARC-BOP-0AC304 C1 Liquid Radwaste Discharge Rad Monitor Hi Hi6. ARC-MCR-003 El North Stack Hi-Hi Radiation7. ARC-MCR-003 F1 Units 1&2 South Stack Hi-Hi Radiation8. EP-EAL-0615 Revision 0, Limerick Criteria for Choosing Radiological LiquidEffluent EAL Threshold ValuesMonth 20XXLGS 3-9EP-AA-1008 (Revision XX)
I imprink rionarating Station AnnayEXPInn Nuclea~rI im~riv~k (~Anar2tinn ~hatinn Ann~v FvAInn N.ir~Ia~arRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSARUIInitiating Condition:Release of gaseous or liquid radioactivity greater than 2 times the ODCM (site-sperafteffluent .,leae controlling document) limits for 60 minutes or longer.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the Unusual Event event promptly upondetermining that 60 applicable time has been exceeded, or will likely beexceeded." If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 60 minutes." Classification based on effluent monitor readings assumes that a release path to theenvironment is established. If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes.(1) Reading on ANY effluent radiation monitor greater than 2 times the (site specificeffluent release controlling document) limits for 60 lmin utes orlong:(site specific- mo-nitor list and- threshold valuer- corresponding to 2 times thecon~trolling document limits)(2) Reading onI ANY e-fflue-Ant- radi-ation moni~tor greater than 2 times the alaFrm Setponeta-blise a urn rad-ieactivit' discharge peFrmit for 60 minRutes Or Ienger.(3) Sample analysis for a gaseous Or liquid release indicates a concentration orrelease ratle greater than 2 times the (site specific. effluent release centrol~ingdocum~ent) limits6 for 690 Mminutes6 Or longer.1. Reading on ANY of the following effluent monitors > 2 times alarm setpointestablished by a current radioactive release discharge permit for > 60 minutes." Radwaste Discharge Effluent Monitor (RR63-0R001)OR" Discharge Permit specified monitorORMonth 20XXLGS 3-10EP-AA-1008 (Revision XX)
IFvplnn I imgprirk Ganar~afing Stgation AnnexFA~nNIdmRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS2. Readings on ANY Table R1 Effluent Monitor > Table RI value for > 60 minutes:Table R1 Effluent Monitor Thresholds 1Release Path Unusual EventNorth Stack (WR Monitor: RIX-26-076-4) 2.20 E+04 uCi/secSouth Stack (Unit 1: RY26-185A-3 / 3.09 E-05 uCi/secRY26-185-B-3 or Unit 2: RY26-285A-3 /RY26-285-B-3)OR3. Confirmed sample analyses for gaseous or liquid releases indicate concentrationsor release rates > 2 times ODCM Limit with a release duration of > 60 minutes.Basis:This IC addresses a potential decrease in the level of safety of the plant as indicated by alow-level radiological release that exceeds regulatory commitments for an extendedperiod of time (e.g., an uncontrolled release). It includes any gaseous or liquidradiological release, monitored or un-monitored, including those for which a radioactivitydischarge permit is normally prepared.Nuclear power plants incorporate design features intended to control the release ofradioactive effluents to the environment. Further, there are administrative controlsestablished to prevent unintentional releases, and to control and monitor intentionalreleases. The occurrence of an extended, uncontrolled radioactive release to theenvironment is indicative of degradation in these features and/or controls.Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.Classification base-d on effluent Monitor reandings assumes that. a release pathtthe enVironment is established. If the effluent floW past An effluet monitor is knownhave stopped duo to actions to isolate the release path, theni the effluent moneitor Feadingi s no longer valid for classificatiopuos.Releases should not be prorated or averaged. For example, a release exceeding 4 timesrelease limits for 30 minutes does not meet the EAL.EAL #1 Basis:EAL #2 1 This EAL addresses radioactivity releases that cause effluent radiation monitorreadings to exceed 2 times the limit established by a radioactivity discharge permit. ThisMonth 20XXLGS 3-11EP-AA-1008 (Revision XX)
Limerick Generatinq Station AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSEAL will typically be associated with planned batch releases from non-continuous releasepathways (e.g., radwaste, waste gas).The effluent monitors listed are those normally used for planned discharges. If adischarge is performed using a different flowpath or effluent monitor other than thoselisted (e.g., a portable or temporary effluent monitor), then the declaration criteria will bebased on the monitor specified in the Discharge Permit.EAL #2 Basis:&AL-#1-I-This EAL addresses normally occurring continuous radioactivity releases frommonitored gaseous OFIli id-effluent pathways.EAL #3 Basis:EA&-# ---This EAL addresses uncontrolled gaseous or liquid releases that are detectedby sample analyses or environmental surveys, particularly on unmonitored pathways(e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river watersystems, etc.).Escalation of the emergency classification level would be via IC RAA1.Basis Reference(s):1. NEI 99-01 Rev 6, AU12. LGS ODCM3. EP-EAL-0608 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Limerick Generating Station4. L-S-43 Radiation Monitoring System5. ARC-BOP-0AC304 Cl Liquid Radwaste Discharge Rad Monitor Hi Hi6. ARC-MCR-109 A2 1 Service Water Rad Monitor Hi-Hi7. ARC-MCR-01 1 C-4 RHRSW Rad Monitor Hi-Hi8. ARC-MCR-003 El North Stack Hi-Hi Radiation9. ARC-MCR-003 F1 Units 1&2 South Stack HI-Hi RadiationMonth 20XXLGS 3-12EP-AA-1008 (Revision XX)
Limerick Generatinn Station Annex Exeoln NucleI~arRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSARA2Initiating Condition:Significant lowering of water level above, or damage to, irradiated fuel.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):(1) Uncover; Of -rradiated fuel in the REFUELING PATH\AIAY.(2) Damage to ir.adiatod fuel reSUlting in a f radioactivity from the fuel asindicated by ANY Of the followA~ing radiation mon9itors:(site specific listing of radiation monitors, and the associated readings,setpoints and/or alarms)(3) Lowering of spcnt fuel pool level to (site spec-ific. Level1 2 Value). [See DeveI&#xfd;GF1. Uncovery of irradiated fuel in the REFUELING PATHWAY.OR2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel asindicated by ANY Table R2 Radiation Monitor reading >1000 mRemlhrTable R2Refuel Floor ARM's* RIS29-M1-1(2)K600, Drywell Head Laydown" RIS30-Ml-1(2)K600, Dryer / Separator Area" RIS31-M1-1(2)K600, Spent Fuel Pool" RIS32-Ml-1(2)K600, New Fuel storage Vault" RIS33-Ml-1(2)K600, Pool Plug LaydownMonth 20XXLGS 3-13EP-AA-1008 (Revision XX)
I=xelon N.dearLimeric~k Generatinn Station Annex Exelon Nucla~rRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSBasis:REFUELING PATHWAY: all the cavities, tubes, canals and pools through whichirradiated fuel may be moved or stored, but not including the reactor vessel below theflange.IMMINENT: The trajectory of events or conditions is such that an EAL will be met within arelatively short period of time regardless of mitigation or corrective actions.CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask barrier(s) betweenareas containing radioactive substances and the environment.This IC addresses events that have caused IMMINENT or actual damage to an irradiatedfuel assembly., o. a ,igifant of w.ater le...l .,,ithi, th. spent fU.l p99l (,Se.eveloe " 'tes). These events present radiological safety challenges to plantpersonnel and are precursors to a release of radioactivity to the environment. As such,they represent an actual or potential substantial degradation of the level of safety of theplant.This IC applies to irradiated fuel that is licensed for dry storage up to the point that theloaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss ofthe CONFINEMENT BOUNDARY is classified in accordance with IC E-HU1.Escalation of the emergency would be based on either Recognition Category AR or CICs.EAL #1 Basis:This EAL escalates from RAU2 in that the loss of level, in the affected portion of theREFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery ofirradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visualobservation (e.g., reports from personnel or camera images), as well as significantchanges in water and radiation levels, or other plant parameters. Computational aidsmay also be used (e.g., a boil-off curve). Classification of an event using this EAL shouldbe based on the totality of available indications, reports and observations.While an area radiation monitor could detect an iGF-easerise in a dose rate due to alowering of water level in some portion of the REFUELING PATHWAY, the reading maynot be a reliable indication of whether or not the fuel is actually uncovered. To the degreepossible, readings should be considered in combination with other available indications ofinventory loss.A drop in water level above irradiated fuel within the reactor vessel may be classified inaccordance Recognition Category C during the Cold Shutdown and Refueling modes.Month 20XXLGS 3-14EP-AA-1008 (Revision XX)
I imariunk r~anarnfinni At~tinn AnnoyFvalnn Nin~ilcanrRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSEAL #2 Basis:This EAL addresses a release of radioactive material caused by mechanical damage toirradiated fuel. Damaging events may include the dropping, bumping or binding of anassembly, or dropping a heavy load onto an assembly. A rise in readings on radiationmonitors should be considered in conjunction with in-plant reports or observations of apotential fuel damaging event (e.g., a fuel handling accident).Escalation of the emergency would be based on either Recognition Category RA-or CICs.r-AI= .#/Spent fuel pool water IlVel at vValu IVV W ithi thI loWer end of the level rangeneressary to prevet Signifcant dseo c q s- from direct gamma radiation topersonnel performing oprations in the Vicinity Of the Spent fuel pool. ThiA cndiErefle loss of spent fuel p oolwater, inventeor; and thus it is , a to a loss of the ability to adequately GOOl the_ irradiatcAd- fuel A-1ssrem.bles storFed in the polEscalationA of the Femqergeny cl9assification levelI Would be via I~rc As! Or AS2 (seeASDevelop- Notes).Basis Reference(s):1. NEI 99-01 Rev 6, AA22. ON-120 Fuel Handling Problems3. DBD L-S-43, Radiation Monitoring System4. ARC MCR 112-15 Fuel Pool Storage Hi/Lo Level5. DBD L-S-16, Reactor Instrumentation System (RIS)6. DBD L-S-52, Fuel Pool Cooling and Cleanup SystemMonth 20XXLGS 3-15EP-AA-1008 (Revision XX)
I imimri&-I, fI-anPA*;fhin Qa*o;i#n A uimivI:,=dlrn khig-l-nrI..IIUIU~r~~EU E IIh~4~~ E E 1II ~* flU~U*as ~ ~RECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSARU2Initiating Condition:UNPLANNED loss of water level above irradiated fuel.Operating Mode Applicability:1, 2, 3,4, 5, DEmergency Action Level (EAL):(1) a. UNPLANNED water leve el dr OpR the REFUELING PATHWAY as indicatedby ANY of the followwin:(site specifc level indications).b. UNPLANNED rise iea radiation leovel as indicated by ANY of thefooin-14AAg radiation monitors.(site specific list of area radi-ation moenitors)1 .UNPLANNED water level drop in the REFUELING PATHWAY as indicated byANY of the following:" Refueling Cavity water level < 484 inches.OR" Spent Fuel Pool level < 23 feet above seated irradiated fuel.OR* Indication or report of a drop in water level in the REFUELINGPATHWAY.AND2. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors inTable R2.Month 20XXLGS 3-16EP-AA-1008 (Revision XX)
ExAIon Simeric~k Goneartinn Station Annex Exelnn NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSTable R2Refuel Floor ARM's* RIS29-M1-1(2)K600, Drywell Head Laydown" RIS30-Ml-1(2)K600, Dryer / Separator Area* RIS31-M1-1(2)K600, Spent Fuel Pool" RIS32-M1-1(2)K600, New Fuel storage Vault* RIS33-M1-1(2)K600, Pool Plug LaydownBasis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.REFUELING PATHWAY: all the cavities, tubes, canals and pools through whichirradiated fuel may be moved or stored, but not including the reactor vessel below theflange.This IC addresses a dereaseeloss in water level above irradiated fuel sufficient to causeelevated radiation levels. This condition could be a precursor to a more serious eventand is also indicative of a minor loss in the ability to control radiation levels within theplant. It is therefore a potential degradation in the level of safety of the plant.A water level deGrease loss will be primarily determined by indications from available levelinstrumentation. Other sources of level indications may include reports from plantpersonnel (e.g., from a refueling crew) or video camera observations (if available) or fromany other temporarily installed monitoring instrumentation. A significant drop in the waterlevel may also cause a; inAeaserise in the radiation levels of adjacent areas that can bedetected by monitors in those locations.The effects of planned evolutions should be considered. For example, a refueling bridgearea radiation monitor reading may *iR-easerise due to planned evolutions such as liftingof the reactor vessel head or movement of a fuel assembly. Note that this EAL isapplicable only in cases where the elevated reading is due to an UNPLANNED loss ofwater level.A drop in water level above irradiated fuel within the reactor vessel may be classified inaccordance Recognition Category C during the Cold Shutdown and Refueling modes.Escalation of the emergency classification level would be via IC RAA2.Basis Reference(s):Month 20XXLGS 3-17EP-AA-1008 (Revision XX)
I imnrir-L, ('2nnewnfin Qfnfien AnngvIygilen Mm-rlonrI ;~~n~sL (~n~r~1* int $$rn n vFv n mr~a.n .. ... tt***5 *1-. U .RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS1. NEI 99-01 Rev 6, AU22. Technical Specifications 3.9.83. ON-120 Fuel Handling Problems4. DBD L-S-16, Reactor Instrumentation System (RIS)5. DBD L-S-52, Fuel Pool Cooling and Cleanup System6. ARC MCR 112-15 Fuel Pool Storage Hi/Lo Level7. GP-6.1 U/1(2) Shutdown Operations -Refuel Core Alterations & Core Off-loadingMonth 20XXLGS 3-18EP-AA-1008 (Revision XX)
I imprink rpnarafinn Afafinn AnnoyI=xAInn N.nlAarI imrir~ (~n~rzainn tsa~nn An~vExelnn NucledarRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSARA3Initiating Condition:Radiation levels that impede access to equipment necessary for normal plant operations,cooldown or shutdown.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Note: If the equipment in the listed-room or area listed in Table R4 -was alreadyinoperable, or out of service, before the event occurred, then no emergencyclassification is warranted(1) Dose rate greater than 15 mR/hr in ANY of the following areas:b*Centre l -o M nonoR* Central Alarm Station-(ysuvyOR pecific afeas/roomn)(2) An UNPLANNED ev:ent results in radiation levels that prohibit Or impe-de accr-ess oany of the following plant rooms or areas:.(site specific list of plant rooms or areas with cntr,' related moede appliabilitylidentfed)1. Dose rate gFeatefkhaf1> 15 mRlhr in ANY of the areas contained in Table R3:Table R3Areas Requiring Continuous Occupancy" Main Control Room" Central Alarm Station -(by survey)ORMonth 20XXLGS 3-19EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexI=xelon Exelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS2. UNPLANNED event results in radiation levels that prohibit or significantly impedeaccess to ANY of the areas contained in Table R4:Table R4Areas with Entry Related Mode ApplicabilityArea Entry Related ModeApplicabilityReactor Enclosure* Modes 3, 4, and 5*Area required to establish shutdown coolingBasis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.This IC addresses elevated radiation levels in certain plant rooms/areas sufficient topreclude or impede personnel from performing actions necessary to transition the plantfrom normal plant operation to cooldown and shutdown as specified in normal plantproceduresmaintain normal plant operation, Or to a normal plant ansh'-tdew'-. As such, it represents an actual or potential substantial degradation of thelevel of safety of the plant. The Emergency Director should consider the cause of theincreased radiation levels and determine if another IC may be applicable.Table R4 is a list of plant rooms or areas with entry-related mode applicability that containequipment which require a manual/local action necessary to transition the plant fromnormal plant operation to cooldown and shutdown as specified in normal operatingprocedures (establish shutdown cooling), where if this action is not completed the plantwould not be able to attain and maintain cold shutdown.This Table does not include rooms or areas for which entry is required solely to performactions of an administrative or record keeping nature (e.g., normal rounds or routineinspections).Rooms and areas listed in EAL #1 do not need to be included in EAL #2, including theControl Room.For EAL #2, an Alert declaration is warranted if entry into the affected room/area is, ormay be, procedurally required during the plant operating mode in effect and the elevatedradiation levels preclude the ability to place shutdown cooling in serviccat the time of theelevated radiation The emergency classification is not contingent upon whetherentry is actually necessary at the time of the increased radiation levels. Access should beconsidered as impeded if extraordinary measures are necessary to facilitate entry ofMonth 20XXLGS 3-20EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexI=xelon NuclearExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSpersonnel into the affected room/area (e.g., installing temporary shielding beyond thatrequired by procedures, requiring use of non-routine protective equipment, requesting anextension in dose limits beyond normal administrative limits).An emergency declaration is not warranted if any of the following conditions apply." The plant is in an operating mode different than the mode specified for the affectedroom/area (i.e., entry is not required during the operating mode in effect at the time ofthe elevated radiation levels). For example, the plant is in Mode 1 when the radiationie rise occurs, and the procedures used for normal operation, cooldown andshutdown do not require entry into the affected room until Mode 4." The increased radiation levels are a result of a planned activity that includescompensatory measures which address the temporary inaccessibility of a room orarea (e.g., radiography, spent filter or resin transfer, etc.)." The action for which room/area entry is required is of an administrative or recordkeeping nature (e.g., normal rounds or routine inspections)." The access control measures are of a conservative or precautionary nature, andwould not actually prevent or impede a required action.Escalation of the emergency classification level would be via Recognition Category RA, Cor F ICs.Basis Reference(s):1. NEI 99-01 Rev 6, AA32. UFSAR Table 7.7-2, Locations for Area Radiation Monitor Sensors3. SE-1 Remote Shutdown4. SE-6 Alternate Remote Shutdown5. SE-8 Fire6. DBD L-S-43, Radiation Monitoring SystemMonth 20XXLISS 3-21EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearLimerick .en .ra..n Station... Annex.........n.Nuc..e..RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSSRU3Initiating Condition:Reactor coolant activity greater than Technical Specification allowable limits.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):(1) (Site specifc radiation monitor) reading greater than (site 6pecific ':alue).7(2) Sample analysis indicates that a reactor coolant activity value i6 greater than anallo~Wabeiit speciflod- in Tec-hnical Specifications.1. Air Ejector discharge radiation monitor (RISH 26 1(2)K601A, B) Hi-Hi alarm.OR2. Specific coolant activity > 4.0 uCllgm Dose equivalent 1-131.Basis:This IC addresses a reactor coolant activity value that exceeds an allowable limitspecified in Technical Specifications. This condition is a precursor to a more significantevent and represents a potential degradation of the level of safety of the plant.Conditions that cause the specified monitor to alarm that are not related to fuel claddegradation should not result in the declaration of an Unusual Event.This EAL addresses site-specific radiation monitor readings that provide indication of adegradation of fuel clad integrity.An Unusual Event is only warranted when actual fuel clad damage is the cause of theelevated coolant sample activity (as determined by laboratory confirmation). Fuel claddamage should be assumed to be the cause of elevated Reactor Coolant activity unlessanother cause is known.Escalation of the emergency classification level would be via ICs FA1 or the RecognitionCategory RA ICs.Basis Reference(s):1. NEI 99-01 Rev 6, SU32. Technical Specifications 3.4.5, Specific Activity3. Technical Specifications 3.4.5, Basis4. UFSAR Table 11.5-1, Process and Effluent Radiation Monitoring Systems5. DBD L-S-43, Radiation Monitoring System6. ARC MCR 109-G1, Air Ejector Offgas Discharge HI-HI RadiationMonth 20XXLGS 3-22EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFG1Initiating Condition:Loss of ANY Two Barriers AND Loss or Potential Loss of the third barrier.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determinebarrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.At the General Emergency classification level each barrier is weighted equally.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXLGS 3-23EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFS1Initiating Condition:Loss or Potential Loss of ANY two barriers.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determinebarrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.At the Site Area Emergency classification level, each barrier is weighted equally.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXLGS 3-24EP-AA-1008 (Revision XX)
Fxelnn NuclAarLimeric~k Goner~atinn Stsation Annex FEceInn NuicleazrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFA1Initiating Condition:ANY Loss or ANY Potential Loss of either Fuel Clad or RCS.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determinebarrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.At the Alert classification level, Fuel Cladding and RCS barriers are weighted moreheavily than the Containment barrier. Unlike the Containment barrier, loss or potentialloss of either the Fuel Cladding or RCS barrier may result in the relocation of radioactivematerials or degradation of core cooling capability. Note that the loss or potential loss ofContainment barrier in combination with loss or potential loss of either Fuel Cladding orRCS barrier results in declaration of a Site Area Emergency under EAL FS1.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXLGS 3-25EP-AA-1008 (Revision XX)
I imarink ronarnfinn Af2finn AnnoyI=Yalnn NinrlmarI imairit~k (~nn~rntinn ~t2tinn Ann~w Fvalnn fI.ur~Io2rRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC1Initiating Condition:RCS ActivityOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSSA. (Site:Specific ind-ications that reactor coolant activity is greater than 300u~ilgm doseq,,ivaleRt-1 3!)Coolant activity > 300 uCi/gm Dose Equivalent 1-131.Basis:This threshold indicates that RCS radioactivity concentration is greater than 300 I4Ci/gmdose equivalent 1-131. Reactor coolant activity above this level is greater than thatexpected for iodine spikes and corresponds to an approximate range of 2% to 5% fuelclad damage. Since this condition indicates that a significant amount of fuel claddamage has occurred, it represents a loss of the Fuel Clad Barrier.It is recognized that sample collection and analysis of reactor coolant with highlyelevated activity levels could require several hours to complete. Nonetheless, asample-related threshold is included as a backup to other indications.There is no Potential Loss threshold associated with RCS Activity.Basis Reference(s):1 .NEI 99-01 Rev 6, Table 9-F-2Month 20XXLGS 3-26EP-AA-1008 (Revision XX)
I imariek rZonarnfin Atnfinn AnnoyPwi::nn NiAalnrI im~rirk (~nbr2tinn ~t2*inn Ann~v Fv~Inn hi.IuI~2rRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC2Initiating Condition:RPV Water LevelOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSSA-.-1. Plant conditions indicate Primary Crontainment flooding is required.POTENTIAL LOSSA-.2. RPV water level cannot be restored and maintained above (sate .pei..c RPV...ateF level c.r...ponding to the top of ,;,cie fuel)> -161 inches (TAF)Gr-OR3. RPV water level cannot be determined.Basis:Loss 2-AThreshold #1 BasisThe Loss threshold represents the EOP requirement for primary containment flooding.This is identified in the BWROG EPGs/SAGs when the phrase, "Primary ContainmentFlooding Is Required," appears. Since a site-specific RPV water level is not specifiedhere, the Loss threshold phrase, "Primary containment flooding required," alsoaccommodates the EOP need to flood the primary containment when RPV water levelcannot be determined and core damage due to inadequate core cooling is believed tobe occurring.Potential Loss 2-AThreshold #2 and #3 Basis:This water level corresponds to the top of the active fuel and is used in the EOPs toindicate a challenge to core cooling.The RPV water level threshold is the same as RCS baF-ieFBarrier RC2 Loss threshold2-A. Thus, this threshold indicates a Potential Loss of the Fuel Clad barrier and a Lossof the RCS barrier that appropriately escalates the emergency classification level to aSite Area Emergency.This threshold is considered to be exceeded when, as specified in the site-specificEOPs, RPV wate RPV water level cannot be restored and maintained above thespecified level following depressurization of the RPV (either manually, automatically orby failure of the RCS barrier) or when procedural guidance or a lack of low pressureRPV injection sources preclude Emergency RPV depressurization. EOPs allow theoperator a wide choice of RPV injection sources to consider when restoring RPV waterlevel to within prescribed limits. EOPs also specify depressurization of the RPV in orderto facilitate RPV water level control with low-pressure injection sources. In some events,Month 20XXLGS 3-27EP-AA-1008 (Revision XX)
Fvl:YInn iNnelon=rI impriink riona~rsainn Rtfatinn Annaw FidnNt~~mRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONelevated RPV pressure may prevent restoration of RPV water level until pressure dropsbelow the shutoff heads of available injection sources. Therefore, this Fuel Clad barrierPotential Loss is met only after either: 1) the RPV has been depressurized, or requiredemergency RPV depressurization has been attempted, giving the operator anopportunity to assess the capability of low-pressure injection sources to restore RPVwater level or 2) no low pressure RPV injection systems are available, precluding RPVdepressurization in an attempt to minimize loss of RPV inventory.The term "cannot be restored and maintained above" means the value of RPV waterlevel is not able to be brought above the specified limit (top of active fuel). Thedetermination requires an evaluation of system performance and availability in relationto the RPV water level value and trend. A threshold prescribing declaration when athreshold value cannot be restored and maintained above a specified limit does notrequire immediate action simply because the current value is below the top of activefuel, but does not permit extended operation below the limit; the threshold must beconsidered reached as soon as it is apparent that the top of active fuel cannot beattained.Entry into the "Steam Cooling" leg of the EOP's would be an example of an inability to"restore and maintain" level above TAF resulting in this threshold being met.In high-power ATWS/failure to scram events, EOPs may direct the operator todeliberately lower RPV water level to tho top of active fuel- in order to reduce reactorpower. RP"V water leVel c then cotOlod between the top of act,,ive fu,-el, and theMinimum Steam CoolinG RPV I^.Iate R....% .A.. Although such action is achallenge to core cooling and the Fuel Clad barrier, the immediate need to reducereactor power is the higher priority. For such events, ICs SA,-MA3 or SS5-MS3 willdictate the need for emergency classification.Since the loss of ability to determine if adequate core cooling is being provided presentsa significant challenge to the fuel clad barrier, a potential loss of the fuel clad barrier isspecified.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. T-1 11 Level Restoration / Steam Cooling- BASES3. T-1 17 Level/Power Control -BASESMonth 20XXLGS 3-28EP-AA-1008 (Revision XX)
N.clAarSimeric~k fleneratinn Staition Annex Exelnn NuclanrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC5Initiating Condition:Primary Containment RadiationOperating Mode Applicability:1,2,3Fission Product Barler (FPB) Threshold:LOSSA. containment radiation monitor reading greater than (site spocific value)Drywell radiation monitor reading > 1.90 E+02 R/hr.Basis:Less-4.The radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the primary containment, assuming that reactor coolant activityequals 300 jiCi/gm dose equivalent 1-131. Reactor coolant activity above this level isgreater than that expected for iodine spikes and corresponds to an approximate rangeof 2% to 5% fuel clad damage. Since this condition indicates that a significant amountof fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.The radiation monitor reading in this threshold is higher than that specified for RCSBarrier RC5 Loss Tthreshold4A since it indicates a loss of both the Fuel Clad Barrierand the RCS Barrier. Note that a combination of the two monitor readings appropriatelyescalates the emergency classification level to a Site Area Emergency.There is no Fuel Clad Barrier Potential Loss threshold associated with PrimaryContainment Radiation.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. Core Damage Assessment Methodology3. Technical Specifications Table 3.3.7.5-1, Accident Monitoring Instrumentation4. DBD L-S-43, Radiation Monitoring System5. ST-2-026-418-1 Accident Monitoring -Primary Containment Post -LOCARadiation Division III Calibration (RE-26-191A)6. ST-0-026-640-* Alternate Monitoring for Inop Post-LOCA Radiation MonitorsMonth 20XXLGS 3-29EP-AA-1008 (Revision XX)
I imarink rpnarnfinn Atntinn AnnowPynilnn N"Morl=rliI Imgirilli ( Hngr~ inn itmil nn ll Ana FI nn NI urIIoi1RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC7Initiating Condition:Emergency Director Judgment.Operating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSS1A. Any condition in the opinion of the Emergency Director that indicates Loss of theFuel Clad Barrier.POTENTIAL LOSS2A. Any condition in the opinion of the Emergency Director that indicates PotentialLoss of the Fuel Clad Barrier.Basis:Loss Threshold #1 BasisLeSS-"AThis threshold addresses any other factors that are to be used by the EmergencyDirector in determining whether the Fuel Clad Barrier is lost.Potential Loss Threshold #2 BasisPetontial Le. s This threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Fuel Clad Barrier is potentially lost. The Emergency Directorshould also consider whether or not to declare the barrier potentially lost in the eventthat barrier status cannot be monitored.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXLGS 3-30EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC2Initiating Condition:RPV Water LevelOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSS1. RPV water level cannot be restored and maintained above (site .pecific RPV waterlevel ....o..n.i. g to the top of cte fue4)> -161 inches (TAF)Gr-OR2. RPV water level cannot be determined.Basis:Less-2-.This water level corresponds to the Ttop of Aactive Ffuel (TAF) and is used in the EOPsto indicate challenge to core cooling.The RPV water level threshold is the same as Fuel Clad baiieF Barrier FC2 PotentialLoss threshold-2A. Thus, this threshold indicates a Loss of the RCS barrier andPotential Loss of the Fuel Clad barrier and that appropriately escalates the emergencyclassification level to a Site Area Emergency.This threshold is considered to be exceeded when, as specified in the site-specificEOPs, RPV-wateFRPV water level cannot be restored and maintained above thespecified level following depressurization of the RPV (either manually, automatically orby failure of the RCS barrier) or when procedural guidance or a lack of low pressureRPV injection sources preclude Emergency RPV depressurization EOPs allow theoperator a wide choice of RPV injection sources to consider when restoring RPV waterlevel to within prescribed limits. EOPs also specify depressurization of the RPV in orderto facilitate RPV water level control with low-pressure injection sources. In some events,elevated RPV pressure may prevent restoration of RPV water level until pressure dropsbelow the shutoff heads of available injection sources. Therefore, this RCS barrier Lossis met only after either: 1) the RPV has been depressurized, or required emergencyRPV depressurization has been attempted, giving the operator an opportunity to assessthe capability of low-pressure injection sources to restore RPV water level or 2) no lowpressure RPV injection systems are available, precluding RPV depressurization in anattempt to minimize loss of RPV inventory.The term, "cannot be restored and maintained above," means the value of RPV waterlevel is not able to be brought above the specified limit (top of active fuel). Thedetermination requires an evaluation of system performance and availability in relationto the RPV water level value and trend. A threshold prescribing declaration when aMonth 20XXLGS 3-31EP-AA-1008 (Revision XX)
I=xelon NuclearI imarirnk (rancarninn Afntinn Annaxv Exelon NucleanrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONthreshold value cannot be restored and maintained above a specified limit does notrequire immediate action simply because the current value is below the top of activefuel, but does not permit extended operation beyond the limit; the threshold must beconsidered reached as soon as it is apparent that the top of active fuel cannot beattained.Entry into the "Steam Cooling" leg of the EOP's would be an example of an inability to"restore and maintain" level above TAF resulting in this threshold being met.In high-power ATWS/failure to scram events, EOPs may direct the operator todeliberately lower RPV water level to the top of ativ,.-' fuel in order to reduce reactorpower. RPV wAater IoeIe as then coentrolled between the top of active fue-l and thoMinimumA Stoamn Cooling R Water Level (GRVI.A.)-. Although such action is achallenge to core cooling and the Fuel Clad barrier, the immediate need to reducereactor power is the higher priority. For such events, ICs SA5-MA3 or ,S5-MS3 willdictate the need for emergency classification.There is no RCS Potential Loss threshold associated with RPV Water Level.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. T-BAS, TRIPS / SAMPS -Bases3. T 101, RPV Control4. T-1 11, Level Restoration / Steam CoolingMonth 20XXLGS 3-32EP-AA-1008 (Revision XX)
I=xAInn NunlAarI imarirnk ryangarninn Station Annoy Exelnn NucleaIrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC3Initiating Condition:Primary Containment PressureOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSSA. Primar;;F containment pressure greater than (site Specific value) due to RCS leakage.1. Drywell pressure >1.68 psig.AND2. Drywell pressure rise is due to RCS leakageBasis:The (site -p.cific 1.68 psig primary containment pressure is the drywe#Drywellhigh pressure setpoint which indicates a LOCA by automatically initiating the-ECCS-erequivalent makeup system.The second threshold condition focuses the fission product barrier loss threshold on afailure of the RCS instead of the non-LOCA malfunctions that may adversely affectprimary containment pressure. Pressures of this magnitude can be caused by non-LOCA events such as a loss of Drywell cooling or inability to control primarycontainment vent/purge.The release of mass from the RCS due to the as-designed/expected operation of anyrelief valve does not warrant an emergency classification.A stuck-open Safety Relief Valve (SRV) or SRV leakage is not considered eitheridentified or unidentified leakage by Technical Specification and, therefore, is notapplicable to this EAL.There is no Potential Loss threshold associated with Primary Containment Pressure.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. T-101 RPV Control3. T-102 Primary Containment Control -BasesMonth 20XXLGS 3-33EP-AA-1008 (Revision XX)
I imarielt (' Zonaratin Af2finn AnnowIP:valn n N,,r-la~rI i~ri~k ~n~~*nn$ain nvFrI hiimRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC4Initiating Condition:RCS Leak RateOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSSAl. UNISOLABLE Main Steam Line (MSL), HPCI, Feedwater, RWCU, or RCIC linebreak. iA ANY of ;,,,,.ng (it;+ .....f ~ eM ..... poeta .. ..;+,,GF,+;, ...... ;,yOR82. Emergency RPV Depressurization is required.POTENTIAL LOSS3A. UNISOLABLE primary system leakage that results in EITHER of the following:a4. Secondary Containment area temperature > T-103 1 SAMP, Max Norm Op Value(MNO)MA. -Ne Nrm'iaQ .pe.at+;, T e...peFatufe.ORb2. Secondary Containment area radiation level > T-103 I SAMP, Max Norm Op Value(MNO)Max Normal Operating Area Radiation Level.Basis:UNISOLABLE: An open or breached system line that cannot be isolated, remotely orlocally.Classification of a system break over system leakage is based on information availableto the Control Room from the event. Indications that should be considered are:* Reports describing magnitude of steam or water release.* Use of system high flow alarms / indications, if available,* Significant changes in makeup requirements,* Abnormal reactor water level changes in response to the event.The use of the above indications provides the Control Room the bases to determine thatthe on going event is more significant than the indications that would be expected fromsystem leakage and therefore should be considered a system break.Month 20XXLGS 3-34EP-AA-1008 (Revision XX)
I imariek rZonarnfin Afnfinn AnnovF:valnn N~irhlnrI i~rt~kflnaratnn$atn nvFolnMuIrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONLoss Threshold #1 Basis-3.Large high-energy lines that rupture outside primary containment can dischargesignificant amounts of inventory and jeopardize the pressure-retaining capability of theRCS until they are isolated. If it is determined that the ruptured line cannot be promptlyisolated from the Centrol Room, the RCS barrier Loss threshold is met.Loss Threshold #2 Basis-34.BEmergency RPV Depressurization in accordance with the EOPs is indicative of a loss ofthe RCS barrier. If Emergency RPV Depressurization is performed, the plant operatorsare directed to open safety relief valves (SRVs) and keep them open. Even though theRCS is being vented into the suppression pool, a Loss of the RCS barrier exists due tothe diminished effectiveness of the RCS to retain fission products within its boundary.Potential Loss Threshold- #3 Basis 3-.APotential loss of RCS based on primary system leakage outside the primarycontainment is determined from EOP temperature or radiation Max Normal Operatingvalues in areas such as main steam line tunnel, RCIC, HPCI, etc., which indicate adirect path from the RCS to areas outside primary containment.A Max Normal Operating value is the highest value of the identified parameter expectedto occur during normal plant operating conditions with all directly associated supportand control systems functioning properly.The indicators reaching the threshold barriers and confirmed to be caused by RCSleakage from a primary system warrant an Alert classification. A primary system isdefined to be the pipes, valves, and other equipment which connect directly to the RPVsuch that a reduction in RPV pressure will effect a decrease in the steam or water beingdischarged through an unisolated break in the system.In general, multiple indications should be used to determine if a primary system isdischarging outside Primary Containment. For example, a high area radiation conditiondoes not necessarily indicate that a primary system is discharging into the ReactorBuilding since this may be caused by radiation shine from nearby steam lines or themovement of radioactive materials. Conversely, a high area radiation condition inconjunction with other indications (e.g. room flooding, high area temperatures, reports ofsteam in the Reactor Building, an unexpected rise in Feedwater flowrate, or unexpectedMain Turbine Control Valve closure) may indicate that a primary system is discharginginto the Reactor Building.An UNISOLABLE leak which is indicated by Max Normal Operating values escalates toa Site Area Emergency when combined with Containment Barrier CT6 Loss tThreshold#13,A (after a containment isolation) and a General Emergency when the Fuel CladBarrier criteria is also exceeded.Month 20XXLGS 3-35EP-AA-1008 (Revision XX)
I=xelon NuclearI imprirck Genersatinn Sta~tion Annex Exellon NuceIa~rRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONBasis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. SAMP-2, Containment and Radioactivity Release Control3. T-103, Secondary Containment ControlMonth 20XXLGS 3-36EP-AA-1008 (Revision XX)
I lmmri r-L- (-'gingrnfinr Q$f*irin A nnnvF:vgalnn Mime:rlAsrisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC5Initiating Condition:Primary Containment radiationOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSSDrywell radiation monitor reading > lOOR/hr.A. containment radiation reading greater than (Site pc;ificr value).Basis:The radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the primary containment, assuming that reactor coolant activityequals Technical Specification allowable limits. This value is lower than that specifiedfor Fuel Clad Barrier FC5 Loss tThreshold-4A- since it indicates a loss of the RCSBarrier only.There is no RCS Potential Loss threshold associated with Primary ContainmentRadiation.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. EP-EAL-061 1, Criteria for Choosing Containment Radiation Monitor ReadingIndicative of Loss of RCS BarrierMonth 20XXLGS 3-37EP-AA-1008 (Revision XX)
I irngsrio-h- ftdingsr&#xfd;fin Q#!mfien AnngvI::vslrnn f, " glx:rI ~ ~ ~*~4ii~ui A uiv~av Fv~Inn IJ.mrI~nr.~uEE.~3 ~ ~ E~E U~IU E~I ~W5.I~UI 5~~U El E~I~ ----s-s. U ~RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC7Initiating Condition:Emergency Director Judgment.Operating Mode Applicability:1,2,3'Fission Product Barrier (FPB3) Threshold:LOSSAl. Any condition in the opinion of the Emergency Director that indicates Loss of theRCS Barrier.POTENTIAL LOSSA2. Any condition in the opinion of the Emergency Director that indicates PotentialLoss of the RCS Barrier.Basis:Loss &.AThreshold #1 Basis:This threshold addresses any other factors that are to be used by the EmergencyDirector in determining whether the RCS Barrier is lost.Potential Loss 6&AThreshold #2 Basis:This threshold addresses any other factors that may be used by the Emergency Directorin determining whether the RCS Barrier is potentially lost. The Emergency Directorshould also consider whether or not to declare the barrier potentially lost in the eventthat barrier status cannot be monitored.Basis Reference(s):1 .NEI 99-01 Rev 6, Table 9-F-2Month 20XXLGS 3-38EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT2Initiating Condition:RPV Water LevelOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:POTENTIAL LOSSA Plant conditions indicate Primary GContainment flooding is required.Basis:Potential ILarr 2 AThe Potential Loss threshold is identical to the Fuel Clad Barrier FC2 Loss thresholdRPV Water Level. 2-.The Potential Loss requirement for Primary ContainmentFlooding indicates adequate core cooling cannot be restored and maintained and thatcore damage is possible. BWR EPGs/SAGs specify the conditions that require primarycontainment flooding. When primary containment flooding is required, the EPGs areexited and SAGs are entered. Entry into SAGs is a logical escalation in response to theinability to restore and maintain adequate core cooling.PRA studies indicate that the condition of this Potential Loss threshold could be a coremelt sequence which, if not corrected, could lead to RPV failure and increased potentialfor primary containment failure. In conjunction with the RPV water level Loss thresholdsin the Fuel Clad and RCS barrier columns, this threshold results in the declaration of aGeneral Emergency.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. T-BAS (INTRO) Introduction To Trips And Samps -Bases3. T-1 11, Level Restoration / Steam Cooling -Bases4. T-1 16, RPV Flooding -Bases5. T-1 17, Level/Power Control -BasesMonth 20XXLGS 3-39EP-AA-1008 (Revision XX)
F:yAInn N.clAarI imprirnk ranabratinn Station Annex Fxelnn NuleaarRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT3Initiating Condition:Primary Containment ConditionsOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSSAl. UNPLANNED rapid drop in primary containment pressure following primarycontainment pressure rise.OR82. Primary containment pressure response not consistent with LOCA conditions.POTENTIAL LOSSA3. PFima~y GDrywellentainment pressure greater than (site specific value)> 55 psigand rising.OR84. (site Specifc explosive mixtur) exists inside PrimAv;, containment a. Drywell orSuppression Pool Hydrogen concentration > 6%.ANDb. Drywell or Suppression Pool Oxygen concentration > 5%.ORG5. HTLG-Heat Capacity Limit (T-102 Curve SP/T-1) exceeded.Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.Loss I-A.-andJ.-BThreshold #1 and #2 BasisRapid UNPLANNED loss of primary containment pressure (i.e., not attributable tod DyweDrywell spray or condensation effects) following an initial pressure iPi easerise Iindicates a loss of primary containment integrity. Primary containment pressure shouldiireaserise as a result of mass and energy release into the primary containment from aLOCA. Thus, primary containment pressure not increasing under these conditionsindicates a loss of primary containment integrity.These thresholds rely on operator recognition of an unexpected response for thecondition and therefore a specific value is not assigned. The unexpected(UNPLANNED) response is important because it is the indicator for a containmentbypass condition. A pressure suppression bypass path would not be an indication of acontainment breach.Month 20XXLGS 3-40EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearLimerick..Genera..... SIta.ion..Annex..E....on..Nucle..rRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONPotential Loss 4-AThreshold #3 BasisThe threshold pressure is the primary containment internal design pressure. Structuralacceptance testing demonstrates the capability of the primary containment to resistpressures greater than the internal design pressure. A pressure of this magnitude isgreater than those expected to result from any design basis accident and, thus,represent a Potential Loss of the Containment barrier.Potential Loss 4-BThreshold #4 BasisIf hydrogen concentration reaches or exceeds the lower flammability limit, as defined inplant EOPs, in an oxygen rich environment, a potentially explosive mixture exists. If thecombustible mixture ignites inside the primary containment, loss of the Containmentbarrier could occur.Potential Loss 4-,CThreshold #5 BasisThe WHeat Capacity TemperFabture Lim"it (HCTL) is the highest eupr.e;cen peoltemperature fromff Which EmRergencGy RPV Qepr curzation will not raice:* Spprccin haMber temperature above the maximum temperature capability othe~~~ Gupeco hamber and equipment within the supprecciGn cham~ber Whicmay be required to operate when the RPV i,,,.uie,OR*Sppeco cham:ber pressure above Primary Containm~ent Pressure Limnit-Alwhil~e the- r-ate Of energy transf-er fro-m the RPV to the containm~ent is grcater thnthe capacity Of the containment Yent.The HCTL is a function of RPV pressure, suppression pool temperature andsuppression pool water level. It is utilized to preclude failure of the containment andequipment in the containment necessary for the safe shutdown of the plant andtherefore, the inability to maintain plant parameters below the limit constitutes apotential loss of containment.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. UFSAR Section 6.2.13. DBD L-T-12, Design Basis Accidents, Transients and Events4. DBD L-S-25A, Primary Containment Pressure Suppression System5. DBD L-T-02, Containment, Section 3.2.146. T-102 Primary Containment Control -BasesMonth 20XXLGS 3-41EP-AA-1008 (Revision XX)
I imnrif-k I' Znnnrnfin Qfafinn AnnnvF::alnn NnrllarI inp1 fn~~*nn~**in nnv vannM~r222RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT5Initiating Condition:Primary Containment RadiationOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:POTENTIAL LOSSA. Primary containment radiatien monitor reading greater than (sitc cpecifc value)Drywell radiation monitor reading > 4.35 E+02 R/hr.Basis:There is no Loss threshold associated with Primary Containment Radiation.Potential Less 4.,A.The radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the primary containment, assuming that 20% of the fuel cladding hasfailed. This level of fuel clad failure is well above that used to determine the analogousFuel Clad Barrier Loss and RCS Barrier Loss thresholds.NUREG-1 228, Source Estimations During Incident Response to Severe Nuclear PowerPlant Accidents, indicates the fuel clad failure must be greater than approximately 20%in order for there to be a major release of radioactivity requiring offsite protectiveactions. For this condition to exist7 there must already have been a loss of the RCSBarrier and the Fuel Clad Barrier. It is therefore prudent to treat this condition as apotential loss of containment which would then escalate the emergency classificationlevel to a General Emergency.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. Core Damage Assessment Methodology3. Technical Specifications Table 3.3.7.5-14. DBD L-S-43, Radiation Monitoring System5. ST-2-026-418-1 Accident Monitoring -Primary Containment Post -LOCARadiation Division III Calibration (RE-26-191A)6. ST-0-026-640-* Alternate Monitoring for Inop Post-LOCA Radiation MonitorsMonth 20XXLGS 3-42EP-AA-1008 (Revision XX)
I=xelon NuclearLimeric~k Generatina Station Annex Exelon NuclanrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT6Initiating Condition:Primary Containment Isolation FailureOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSSAl. UNISOLABLE direct downstream pathway to the environment exists after primarycontainment isolation signal.ORB2. Intentional Pprimary Ceontainment venting/purging per EOP's or SAGs due toaccident conditions.ORG3. UNISOLABLE primary system leakage that results in EITHER of the following:1-a. Secondary Containment area temperature > T-103 I SAMP, Max Safe OpValue (MSO).Ma F.a. T..empe.atu.eOR2b. Secondary Containment area radiation level > T-103 I SAMP, Max Safe OpValue (MSO)Max Safe Operating Radiation Level.Basis:UNISOLABLE: An open or breached system line that cannot be isolated, remotely orlocally.These thresholds address incomplete containment isolation that allows anUNISOLABLE direct release to the environment.Loss 3AThreshold #1 BasisThe use of the modifier "direct" in defining the release path discriminates againstrelease paths through interfacing liquid systems or minor release pathways, such asinstrument lines, not protected by the Primary Containment Isolation System (PCIS).Leakage into a closed system is to be considered only if the closed system is breachedand thereby creates a significant pathway to the environment. Examples includeunisolable Main Steamline, HPCI or RCIC steamline breaks, unisolable RWCU systembreaks, and unisolable containment atmosphere vent paths.Examples of "downstream pathway to the environment" could be through theTurbine/Condenser, or direct release to the Turbine or Reactor Building.The existence of a filter is not considered in the threshold assessment. Filters do notremove fission product noble gases. In addition, a filter could become ineffective due toiodine and/or particulate loading beyond design limits (i.e., retention ability has beenexceeded) or water saturation from steam/high humidity in the release stream.Month 20XXLGS 3-43EP-AA-1008 (Revision XX)
F=galnn I imaprirk rioarnnrainn tAtninn AnnaY vn mx~c2RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFollowing the leakage of RCS mass into primary containment and a rise in primarycontainment pressure, there may be minor radiological releases associated withallowable primary containment leakage through various penetrations or systemcomponents. Minor releases may also occur if a primary containment isolation valve(s)fails to close but the primary containment atmosphere escapes to an enclosed system.These releases do not constitute a loss or potential loss of primary containment butshould be evaluated using the Recognition Category A-RICs.Loss 3&BThreshold #2 BasisEOPs may direct primary containment isolation valve logic(s) to be intentionallybypassed, even if offsite radioactivity release rate limits will be exceeded. Under theseconditions with a valid primary containment isolation signal, the containment should alsobe considered lost if primary containment venting is actually performed.Intentional venting of primary containment for primary containment pressure orcombustible gas control to the secondary containment and/or the environment is a Lossof the Containment. Venting for primary containment pressure control when not in anaccident situation (e.g., to control pressure below the high pressurescram setpoint) does not meet the threshold condition.Loss 3-,CThreshold #3 BasisThe Max Safe Operating Temperature and the Max Safe Operating Radiation Level areeach the highest value of these parameters at which neither: (1) equipment necessaryfor the safe shutdown of the plant will fail, nor (2) personnel access necessary for thesafe shutdown of the plant will be precluded. EOPs utilize these temperatures andradiation levels to establish conditions under which RPV depressurization is required.The temperatures and radiation levels should be confirmed to be caused by RCSleakage from a primary system. A primary system is defined to be the pipes, valves, andother equipment which connect directly to the RPV such that a reduction in RPVpressure will effect a decrease in the steam or water being discharged through anunisolated break in the system.In general, multiple indications should be used to determine if a primary system isdischarging outside Primary Containment. For example, a high area radiation conditiondoes not necessarily indicate that a primary system is discharging into the ReactorBuilding since this may be caused by radiation shine from nearby steam lines or themovement of radioactive materials. Conversely, a high area radiation condition inconjunction with other indications (e.g. room flooding, high area temperatures, reports ofsteam in the Reactor Building, an unexpected rise in Feedwater flowrate, or unexpectedMain Turbine Control Valve closure) may indicate that a primary system is discharginginto the Reactor Building.In combination with RCS Barrier RC4 pPotential ILoss Threshold #3 3A this thresholdwould result in a Site Area Emergency.There is no Potential Loss threshold associated with Primary Containment IsolationFailure.Month 20XXLGS 3-44EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONBasis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. T-103, Secondary Containment Control3. T-102, Primary Containment Control4. T-200, Primary Containment Emergency Vent Procedure5. T-228, Inerting / Purging Primary ContainmentMonth 20XXLGS 3-45EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT7Initiating Condition:Emergency Director Judgment.Operating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSSAl. Any condition in the opinion of the Emergency Director that indicates Loss of theContainment Barrier.POTENTIAL LOSSA2. Any condition in the opinion of the Emergency Director that indicates PotentialLoss of the Containment Barrier.Basis:Loss "AThreshold #1 Basis:This threshold addresses any other factors that are to be used by the EmergencyDirector in determining whether the Containment Barrier is lost.Potential Loss $OAThreshold #2 Basis:This threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Containment Barrier is potentially lost. The EmergencyDirector should also consider whether or not to declare the barrier potentially lost in theevent that barrier status cannot be monitored.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXLGS 3-46EP-AA-1008 (Revision XX)
NuclAarSimeric~k (Ganeratinn Staition Annex Exelon Nuclea~rRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSG1Initiating Condition:Prolonged loss of all Off-site and all On-Site AC power to emergency busses.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the General EMcgecY -vent promptlyupon determining that (site hours) the applicable time has beenexceeded, or will likely be exceeded.1-a. Loss of ALL offsite :and LL onsi"o AC power to unit (site spe..ft" emergencYbuses)4KV safeguards Buses.AND2. Failure of Dl 1(21), D12(22), D13(23), and D14(24) Emergency Diesel Generatorsto supply power to unit 4KV safeguards Buses.AND3b. EITHER of the following:a. Restoration of at least one unit emeegeAcyAKV Safeguards bu&-Bus -in < 2hours is notves than (site specific hours) is not likely.ORb. RPV water level cannot be restored and maintained > -186 inches.*(Site specific indication of an inability to adequately remove he-at fro-m the core)Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a prolonged loss of all power sources to AC emergency buses. Aloss of all AC power compromises the performance of all SAFETY SYSTEMS requiringelectric power including those necessary for emergency core cooling, containment heatremoval/pressure control, spent fuel heat removal and the ultimate heat sink. Aprolonged loss of these buses will lead to a loss of one or moreany fission productMonth 20XXLGS 3-47EP-AA-1008 (Revision XX)
Simeric~k (GAneratinn Stsation Annex Exelon Nucla~rRECOGNITION CATEGORYSYSTEM MALFUNCTIONSbarriers. In addition, fission product barrier monitoring capabilities may be degradedunder these conditions.The EAL should require declaration of a General Emergency prior to meeting thethresholds for IC FGI. This will allow additional time for implementation of offsiteprotective actions.Escalation of the emergency classification from Site Area Emergency will occur if it isprojected that power cannot be restored to at least one AC emergency bus by the endof the analyzed station blackout coping period. Beyond this time, plant responses andevent trajectory are subject to greater uncertainty, and there is an increased likelihoodof challenges to multiple fission product barriers.The estimate for restoring at least one emergency bus should be based on a realisticappraisal of the situation. Mitigation actions with a low probability of success should notbe used as a basis for delaying a classification upgrade. The goal is to maximize thetime available to prepare for, and implement, protective actions for the public.The EAL will also require a General Emergency declaration if the loss of AC powerresults in parameters that indicate an inability to adequately remove decay heat fromthe core.Basis Reference(s):1. NEI 99-01 Rev 6, SG12. UFSAR Section 8.2, Offsite Power System3. E 10/20 Loss of Offsite Power4. DBD L-S-05, 4KV System5. DBD L-T-03, Electrical Issues6. T-101 RPV ControlMonth 20XXLGS 3-48EP-AA-1008 (Revision XX)
Fvamlnn NimlanrSimernick (Anersatinn Station AnnexEAn N~~AiRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSSIInitiating Condition:Loss of all offsite and all onsite AC power to emergency busses for 15 minutes orlonger.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the Site Area E=..egenyevent promptlyupon determining that the applicable time 415miiwtes-has been exceeded, or willlikely be exceeded.1. Loss of ALL offsite and ALL on;ito AC Power to (site spocific emergency bucc,)unit4KV Safeguards Buses. for 15 minutes or lo.ger.AND2. Failure of Dl 1(21), D12(22), D13(23), and D14(24) Emergency Diesel Generators tosupply power to unit 4KV Safeguards Buses.AND3. Failure to restore power to at least one unit 4KV Safeguards bus in < 15 minutesfrom the time of loss of both offsite and onsite AC powerBasis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a total loss of AC power that compromises the performance of allSAFETY SYSTEMS requiring electric power including those necessary for emergencycore cooling, containment heat removal/pressure control, spent fuel heat removal andthe ultimate heat sink. In addition, fission product barrier monitoring capabilities may bedegraded under these conditions. This IC represents a condition that involves actual orlikely major failures of plant functions needed for the protection of the public.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via ICs RAG1, FG1-er-MSG1,or MG2.Month 20XXLGS 3-49EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSBasis Reference(s):1. NEI 99-01 Rev 6, SS12. UFSAR Section 8.2, Offsite Power System3. E 10/20 Loss of Offsite Power4. DBD L-S-05, 4KV System5. DBD L-T-03, Electrical Issues6. T-101 RPV ControlMonth 20XXLGS 3-50EP-AA-1008 (Revision XX)
FxAInn N.nlAarLimeric~k Ganer~atinn Stzation Annex Exelnn NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSA1Initiating Condition:Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the eventA~e promptly upondetermining that the applicable time 45- iiiutes-has been exceeded, or will likelybe exceeded.1. AC power capability to unit 4KV Safeguards Buses reduced to only one of thefollowing power sources for > 15 minutes.* 101 Safeguards Transformer* 102 Safeguards TransformerSDl 1(21) Diesel Generator* D12(22) Diesel Generator* D13(23) Diesel Generator* D14(24) Diesel Generatora. AG poWer eapabilit' to (Site SpSG~fiG emergencY bUcoc) is reduced to a singlepoW8 e~r ourc fonr I15 m~inutesA o-r longer.AND2b. Any additional single power source failure will result in a loss of -all-ALL AC powerto SAFETY SYSTEMS.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC describes a significant degradation of offsite and onsite AC power sources suchthat any additional single failure would result in a loss of all AC power to SAFETYSYSTEMS. In this condition, the sole AC power source may be powering one, or morethan one, train of safety-related equipment. This IC provides an escalation path from ICMSUl.An "AC power source" is a source recognized in AOPs and EOPs, and capable ofsupplying required power to an emergency bus. Some examples of this condition arepresented below.Month 20XXLGS 3-51EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS" A loss of all offsite power with a concurrent failure of all but one emergency powersource (e.g., an onsite diesel generator)." A loss of all offsite power and loss of all emergency power sources (e.g., onsitediesel generators) with a single train of emergency buses being back-fed from theunit main generator." A loss of emergency power sources (e.g., onsite diesel generators) with a singletrain of emergency buses being back-fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof power.Escalation of the emergency classification level would be via IC MS$1.Basis Reference(s):1. NEI 99-01 Rev 6, SA12. UFSAR Section 8.2, Offsite Power System3. E 10/20 Loss of Offsite Power4. DBD L-S-05, 4KV System5. DBD L-T-03, Electrical IssuesMonth 20XXLGS 3-52EP-AA-1008 (Revision XX)
I imarink rZonarntinn Atntinn AnnayFvplnn NJn.IanrI imoria~k (~~inm2~nn ~t~atinn Ann~&v Fvnlnn MmIv~I~2rRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSU1Initiating Condition:Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the Unusual Event vent promptly upondetermining that the applicable time 15-min4e&-has been exceeded, or will likelybe exceeded.4-.Loss of ALL offsite AC power capability to unit 4KV Safeguards Buses (site-specifi eM.rgency bue ...for > 15 minutes-Ger-eia.Basis:This IC addresses a prolonged loss of offsite power. The loss of offsite power sourcesrenders the plant more vulnerable to a complete loss of power to AC emergency buses.This condition represents a potential reduction in the level of safety of the plant.For emergency classification purposes, "capability" means that an offsite AC powersource(s) is available to the emergency buses, whether or not the buses are poweredfrom it.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof offsite power.Escalation of the emergency classification level would be via IC MSA1.'Basis Reference(s):1. NEI 99-01 Rev 6, SU12. UFSAR Section 8.2, Offsite Power System3. E 10/20 Loss of Offsite Power4. DBD L-S-05, 4KV System5. DBD L-T-03, Electrical IssuesMonth 20XXLGS 3-53EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSG281Initiating Condition:Loss of all AC and Vital DC power sources for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the General E.- ,--gencY vent promptlyupon determining that the applicable time 15-niutes-has been exceeded, or willlikely be exceeded.1. Loss of ALL offsite AC power to unit 4KV Safeguards Buses.AND2. Failure of D11(21), D12(22), D13(23), and D14(24) Emergency Diesel Generatorsto supply power to unit 4KV Safeguards Buses.AND3. Indicated voltage is < 105 VDC on unit 125 VDC battery busses 1(2)FA, FB, FC,and FD.AND4. ALL AC and Vital DC power sources have been lost for > 15 minutes.1. aa Les ofALntt nd m vA nnrm.v
* POve (648 lH G veift e wefv-buses) for 15 Minutes or longer.-ANDb. Indicated voltage is loe6 than (cite Specific bus voltage value) onAL(site specific. Vital DCG busses) for 15 minutes Or longer.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.Month 20XXLGS 3-54EP-AA-1008 (Revision XX)
I=xAIon N.elAarLimeric~k Generzatinn Staition Annex Exelnn NucrlearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSThis IC addresses a concurrent and prolonged loss of both AC and Vital DC power. Aloss of all AC power compromises the performance of all SAFETY SYSTEMS requiringelectric power including those necessary for emergency core cooling, containment heatremoval/pressure control, spent fuel heat removal and the ultimate heat sink. A loss ofVital DC power compromises the ability to monitor and control SAFETY SYSTEMS. Asustained loss of both AC and DC power will lead to multiple challenges to fissionproduct barriers.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses. The 15-minute emergency declaration clock begins at the point when beth-allEAL conditions threshelds-are met.Basis Reference(s):1. NEI 99-01 Rev 6, SG82. UFSAR Section 8.3.2, DC Power Systems3. DBD P-L-01A, 125/250 VDC System4. E-1(2)FA Loss of Division I Safeguard 125/250V DC BUS 1FA5. E-1(2)FB Loss of Division II Safeguard 125/250V DC BUS 1FB6. E-1(2)FC Loss of Division III Safeguard 125/250V DC BUS 1FC7. E-1(2)FD Loss of Division IV Safeguard 125/250V DC BUS IFD8. UFSAR Section 8.2, Offsite Power System9. E 10/20 Loss of Offsite Power10. DBD L-S-05, 4KV System11. DBD L-T-03, Electrical IssuesMonth 20XXLGS 3-55EP-AA-1008 (Revision XX)
NuclearLimeric~k Generatinn Station Annex Exelon NuiclernRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSS28 IInitiating Condition:Loss of all vital DC power for 15 minutes or longer.Operating Mode .1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the Site Area Eme.gency.vent promptlyupon determining that the applicable time 41mintees-has been exceeded, or willlikely be exceeded.is < 105 VDC le's than (site Specfic. bus voltage 'value) on125 VDC battery busses 1(2)FA, FB, FC, and FDALL (sito specific Vital DGbusses) for > 15 minutes-e-F loeF.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a loss of Vital DC power which compromises the ability to monitorand control SAFETY SYSTEMS. In modes above Cold Shutdown, this conditioninvolves a major failure of plant functions needed for the protection of the public.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via ICs RAG1, FG1 orMSG28.Basis Reference(s):1. NEI 99-01 Rev 6, SS82. UFSAR Section 8.3.2, DC Power Systems3. DBD P-L-01A, 125/250 VDC System4. E-1(2)FA Loss of Division I Safeguard 125/250V DC BUS 1FA5. E-1(2)FB Loss of Division II Safeguard 125/250V DC BUS 1FB6. E-1(2)FC Loss of Division III Safeguard 125/250V DC BUS 1FC7. E-1(2)FD Loss of Division IV Safeguard 125/250V DC BUS 1FDMonth 20XXLGS 3-56EP-AA-1008 (Revision XX)
I imarink rZanarnfinn Atnfinn AnnpXExAIon NuclearI imrirk (~~r~inn tatnn An~~Exelnn NucilearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSS361Initiating Condition:Inability to shutdown the reactor causing a challenge to RPV water level or RCS heatremoval.Operating Mode Applicability:1,2Emergency Action Level (EAL):1. Automatic scram did not shutdown the reactor as indicated by Reactor Power > 4%.AND2. All-ALL manual / ARI actions to shutdown the reactor have been unsuccessful asindicated by Reactor Power > 4%.AND3. EITHER of the following conditions exist:* RPV water level cannot be restored and maintained > -186 inchesOR* Heat Capacity Limit (T-102 Curve SP/T-1) exceeded.(Site ntion of an to adequately ,emo'e heat from; the c.re)(Site 6pecific indication of. an ibliyto adequately remove heat fromn the RCS)Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor scram that results in a reactor shutdown, all subsequent operator manualactions, both inside and outside the Control Room including driving in control rods andboron injection~all subsequent operator actionn to manually shutdown the reactor areunsuccessful, and continued power generation is challenging the capability toadequately remove heat from the core and/or the RCS. This condition will lead to fueldamage if additional mitigation actions are unsuccessful and thus warrants thedeclaration of a Site Area Emergency.In some instances, the emergency classification resulting from this IC/EAL may be Ihigher than that resulting from an assessment of the plant responses and symptomsagainst the Recognition Category F ICs/EALs. This is appropriate in that theRecognition Category F ICs/EALs do not address the additional threat posed by afailure to shutdown the reactor. The inclusion of this IC and EAL ensures the timelydeclaration of a Site Area Emergency in response to prolonged failure to shutdown thereactor.Month 20XXLGS 3-57EP-AA-1008 (Revision XX)
I impriuck (GAneraina Stt~ion Annex Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSA reactor shutdown is determined in accordance with applicable Emergency OperatingProcedure criteria.Escalation of the emergency classification level would be via IC RAG1 or FGI.Basis Reference(s):1. NEI 99-01 Rev 6, SS52. T-101 RPV Control -Bases3. T-1 17 Level/Power Control -Bases4. T-102 Primary Containment Control -BasesMonth 20XXLGS 3-58EP-AA-1008 (Revision XX)
I imarit-k (' ganartifin Qf!mfinn AnnavI:'V--I#n K, ,0-I.-orI~a _ _&#xfd;5in 4*&#xfd; An5 *** E t n**l .U t.* tS S*BUuRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSA31Initiating Condition:Automatic or manual scram fails to shutdown the reactor, and subsequent manualactions taken at the reactor control consoles are not successful in shutting down thereactor.Operating Mode Applicability:1,2Emergency Action Level (EAL):Note: A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.1. An-aAutomatic or manual scram did not shutdown the reactor as indicated byReactor Power > 4%.AND2. Manual / ARI actions taken at the reactor Gcntrol cnc,-cl Reactor Console are notsuccessful in shutting down the reactor as indicated by Reactor Power > 4%.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor scram that results in a reactor shutdown, and subsequent operator manualactions taken at the reactor to shutdown the reactor are also Iunsuccessful. This condition represents an actual or potential substantial degradationof the level of safety of the plant. An emergency declaration is required even if thereactor is subsequently shutdown by an action taken away from the reactor Gei* Iconsoles since this event entails a significant failure of the RPS.A manual action at the reactor GntrF#el onsoles is any operator action, or set of actions,which causes the control rods to be rapidly inserted into the core (e.g., initiating amanual reactor scram. This action does not include manually driving in control rods orimplementation of boron injection strategies. If this action(s) is unsuccessful, operatorswould immediately pursue additional manual actions at locations away from the reactorG9,*trl consoles (e.g., locally opening breakers). Actions taken at back-panels or otherlocations within the Control Room, or any location outside the Control Room, are notconsidered to be "at the reactor GOntrMl consoles".Taking the Reactor Mode Switch to SHUTDOWN Shutdown is considered to be amanual scram action.The plant response to the failure of an automatic or manual reactor scram will varybased upon several factors including the reactor power level prior to the event,availability of the condenser, performance of mitigation equipment and actions, otherconcurrent plant conditions, etc. If the failure to shutdown the reactor is prolongedMonth 20XXLGS 3-59EP-AA-1008 (Revision XX)
I FVirndr.i& f(-rsarafinn Q*f$nrin AnnovFvlnn N"Mar*S .Y.I 5
* I w... ~n3 fRECOGNITION CATEGORYSYSTEM MALFUNCTIONSenough to cause a challenge to the RPV water level or RCS heat removal safetyfunctions, the emergency classification level will escalate to a Site Area Emergency viaIC MSS35. Depending upon plant responses and symptoms, escalation is also possiblevia IC FSI. Absent the plant conditions needed to meet either IC MSS35 or FS1, anAlert declaration is appropriate for this event.It is recognized that plant responses or symptoms may also require an Alert declarationin accordance with the Recognition Category F ICs; however, this IC and EAL areincluded to ensure a timely emergency declaration.A reactor shutdown is determined in accordance with applicable Emergency OperatingProcedure criteria.Basis Reference(s):1. NEI 99-01 Rev 6, SA52. T-101 RPV Control -Bases3. T-1 17 Level/Power Control -BasesMonth 20XXLGS 3-60EP-AA-1008 (Revision XX)
I imarif-L- e' A2nA2rtx#in Qftsfirtn AnnnvIRvainn MiulnarI viai.I ~~ir~uj ~~iE nA llV vIrnMi.~nr***** U U*U UUfl UamS*RECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSU31 IInitiating Condition:Automatic or manual scram fails to shutdown the reactor.Operating Mode Applicability:1,2Emergency Action Level (EAL):Note: A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.1. a. An-aAutomatic scram -did not shutdown the reactor as indicated by ReactorPower > 4%..ANDb. A-sSubsequent manual / ARI action taken at the reactor contro!GenselesReactor Console is successful in shutting down the reactor.OR2. a. A-mManual scram -did not shutdown the reactor as indicated by ReactorPower > 4%.ANDb. EITHER of the following:1. A-sSubsequent manual / ARI action taken at the reactor controlGOnseGeeReactor Console is successful in shutting down the reactor.OR2. A-sSubsequent automatic scram / ARI is successful in shutting down thereactor.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor scram that results in a reactor shutdown, and either a subsequent operatormanual action taken at the reactor eetFrI consoles or an automatic scram is successfulin shutting down the reactor. This event is a precursor to a more significant conditionand thus represents a potential degradation of the level of safety of the plant.EAL #1 BasisFollowing the failure on an automatic reactor scram, operators will promptly initiatemanual actions at the reactor Ge,-,tc! onsoles to shutdown the reactor (e.g., initiate amanual reactor scram). If these manual actions are successful in shutting down thereactor, core heat generation will quickly fall to a level within the capabilities of theplant's decay heat removal systems.Month 20XXLGS 3-61EP-AA-1008 (Revision XX)
I=xelon NuclearI imprirnk Gonarating Station Annex Exelnn NuceIa~rRECOGNITION CATEGORYSYSTEM MALFUNCTIONSEAL #2 BasisIf an initial manual reactor trip is unsuccessful, operators will promptly take manualaction at another location(s) on the reactor GeRtrel consoles to shutdown the reactor(e.g., initiate a manual reactor scram/ARI using a different switch). Depending uponseveral factors, the initial or subsequent effort to manually scram the reactor, or aconcurrent plant condition, may lead to the generation of an automatic reactor scramsignal. If a subsequent manual or automatic scram/ARI is successful in shutting downthe reactor, core heat generation will quickly fall to a level within the capabilities of theplant's decay heat removal systems.A manual action at the reactor GG.-.r consoles is any operator action, or set of actions,which causes the control rods to be rapidly inserted into the core (e.g., initiating amanual reactor scram). This action does not include manually driving in control rods orimplementation of boron injection strategies. Actions taken at back-panels or otherlocations within the Control Room, or any location outside the Control Room, are notconsidered to be "at the reactor e,,tr-el consoles".Taking the Reactor Mode Switch to Shutdown is considered to be a manual scramaction.The plant response to the failure of an automatic or manual reactor tscram will varybased upon several factors including the reactor power level prior to the event,availability of the condenser, performance of mitigation equipment and actions, otherconcurrent plant conditions, etc. If subsequent operator manual actions taken at thereactor GGAFGI consoles are also unsuccessful in shutting down the reactor, then theemergency classification level will escalate to an Alert via IC MSA35. Depending uponthe plant response, escalation is also possible via IC FAI. Absent the plant conditionsneeded to meet either IC MA35 or FA1, an Unusual Event declaration is appropriatefor this event.A reactor shutdown is determined in accordance with applicable Emergency OperatingProcedure criteria.Should a reactor scram signal be generated as a result of plant work (e.g., RPS setpointtesting), the following classification guidance should be applied." If the signal generated as a result of plant work causes a plant transient that createsa real condition that should have included an automatic reactor scram and the RPSfails to automatically shutdown the reactor, then this IC and the EALs are applicable,and should be evaluated." If the signal generated as a result of plant work does not cause a plant transient butshould have generated an RPS scram signal and the scram failure is determinedthrough other means (e.g., assessment of test results), then this IC and the EALsare not applicable and no classification is warranted.Basis Refernce(s):Month 20XXLGS 3-62EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexRECOGNITION CATEGORYSYSTEM MALFUNCTIONSExelon Nuclear1.2.3.NEI 99-01 Rev 6, SU5T-101 RPV ControlTechnical Specifications Table 3.3.1.1-1Month 20XXLGS 3-63EP-AA-1008 (Revision XX)
I imariek (Zanarnfinn A#2finn AnnoyIF:lrlnn Nw-lorI im~riaIe (~nor2tinn ~t~tinn Ann~v Fv~Inn hIIIr~Io2rRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSA42Initiating Condition:UNPLANNED loss of Control Room indications for 15 minutes or longer with asignificant transient in progress.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the eventAle4t promptly upondetermining that the applicable time 45 miiutes-has been exceeded, or will likelybe exceeded.1. a:-AA-UNPLANNED event results in the inability to monitor one er-moroANYTable Mlef- the f--llc..wii" parameters from within the Control Room for > 15minutes 9F-l.ngeF.see -belewRRe-actor- Power__________________Table M1 Control Room ParametersRPV Watr- Level , Reactor Power* RPV Water LevelRPV Pressure* Drywell PressurePrimary Containment .Suppression Pool Level........ .Suppression Pool TemperatureSuppression Pool Le.-veSUPPrcssion Pool Tempcrattur-AND2. b--Any-ANY Table M2ef transient events in progress." Automati; or Manual ,1 rubak greate than -250% thoW/1rmal re-actor po pwer" Elec-trical load rejection greater than 25%fuPlltelecrtricali lo2d-Reateto40p---V \V/*V IlMonth 20XXLGS 3-64EP-AA-1008 (Revision XX) l=l(Alnn Limeric~k fleneratinn Staition Annex Exelnn NucleInarRECOGNITION CATEGORYSYSTEM MALFUNCTIONSTable M2 Significant Transients" Automatic or Manual Runback > 25% thermal reactor power" Electrical Load Rejection > 25% full electrical load" Reactor Scram" ECCS Actuation* Thermal Power oscillations > 10%Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses the difficulty associated with monitoring rapidly changing plantconditions during a transient without the ability to obtain SAFETY SYSTEM parametersfrom within the Control Room. During this condition, the margin to a potential fissionproduct barrier challenge is reduced. It thus represents a potential substantialdegradation in the level of safety of the plant.As used in this EAL, an "inability to monitor" means that values for ne er mer-eany of Ithe listed parameters cannot be determined from within the Control Room. Thissituation would require a loss of all of the Control Room sources for the givenparameter(s). For example, the reactor power level cannot be determined from anyanalog, computer point, digital and recorder source within the Control Room.An event involving a loss of plant indications, annunciators and/or display systems isevaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022)to determine if an NRC event report is required. The event would be reported if itsignificantly impaired the capability to perform emergency assessments. In particular,emergency assessments necessary to implement abnormal operating procedures,emergency operating procedures, and emergency plan implementing proceduresaddressing emergency classification, accident assessment, or protective actiondecision-making.This EAL is focused on a selected subset of plant parameters associated with the keysafety functions of reactivity control, RPV-leve!RPV water level and RCS heat removal.Month 20XXLGS 3-65EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSThe loss of the ability to determine oeo r. mereany of these parameters from within theControl Room is considered to be more significant than simply a reportable condition.In addition, if all indication sources for one O-r mreany of the listed parameters are lost,then the ability to determine the values of other SAFETY SYSTEM parameters may beimpacted as well. For example, if the value for RPV water level cannot be determinedfrom the indications and recorders on a main control board, the SPDS or the plantcomputer, the availability of other parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.Escalation of the emergency classification level would be via ICs FS1 or IC RAS1.Basis Reference(s):1. NEI 99-01 Rev 6, SA22. DBD L-T-06, Human Factors, Section 6.1.13. T-101 RPV Control4. T-102 Primary Containment Control5. ON-122, Loss of Main Control Room Annunciators -BasesMonth 20XXLGS 3-66EP-AA-1008 (Revision XX)
I=YAInn Limeric~k (GAneratinn Station Annex Fxuainn Nucler~kRECOGNITION CATEGORYSYSTEM MALFUNCTIONSInitiating Condition:UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):MSU421Note: The Emergency Director should declare the Unusual Event vent promptly upondetermining that the applicable time 1-5 -inutes-has been exceeded, or will likelybe exceeded.a- AR-UNPLANNED event results in the inability to monitor onO or- moeANY Table M1parameters from within the Control Room for > 15 minutes.Table M1 Control Room Parameters* Reactor Power" RPV Water Level* RPV Pressure" Drywell Pressure* Suppression Pool Level* Suppression Pool Temperature* --.t JLL -- t--ll .... !---OT inn milowna nirnmoiornfrom wnnin m alonrlKo ri~mn~EfOF 'Rgef------------------2. [B WR par~mct 3. 142WR parametcr4. Rea.tor Pwe 6. Reactor- Power-8. -RPVN Waterp L" 9. -R CESh L e: IK10-. _RPA -Pressurce 11. RCS PrEessur-e42. P 1a~ 13.In COre/CorcCeetonmentExit TemperatureiI ss~u 014. Suppression Pol5. Ll;'cs in at ....tLeve (site speeil1 6. Supprcssion Poo 17. St-a-m GCenerator-empe,.twe Aui,.tle or-___e___en FeeadI ~ ~ ~ ~ ~ ~ ~ ~ ~ atv YJA,*I Month 20XXLGS 3-67EP-AA-1008 (Revision XX)
I imarink rtanarnfinn Afnfinn AnnoyI imrirk (c~n~ntin ~~tin Anc~~Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSBasis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses the difficulty associated with monitoring normal plant conditionswithout the ability to obtain SAFETY SYSTEM parameters from within the ControlRoom. This condition is a precursor to a more significant event and represents apotential degradation in the level of safety of the plant.As used in this EAL, an "inability to monitor" means that values for eone OFr mereany ofthe listed parameters cannot be determined from within the Control Room. Thissituation would require a loss of all of the Control Room sources for the givenparameter(s). For example, the reactor power level cannot be determined from anyanalog, digital and recorder source within the Control Room.An event involving a loss of plant indications, annunciators and/or display systems isevaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1 022)to determine if an NRC event report is required. The event would be reported if itsignificantly impaired the capability to perform emergency assessments. In particular,emergency assessments necessary to implement abnormal operating procedures,emergency operating procedures, and emergency plan implementing proceduresaddressing emergency classification, accident assessment, or protective actiondecision-making.This EAL is focused on a selected subset of plant parameters associated with the keysafety functions of reactivity control, core cooling and RCS heat removal. The loss ofthe ability to determine eone Or mereany of these parameters from within the ControlRoom is considered to be more significant than simply a reportable condition. Inaddition, if all indication sources for one er-moreany of the listed parameters are lost,then the ability to determine the values of other SAFETY SYSTEM parameters may beimpacted as well. For example, if the value for reactor vessel level cannot bedetermined from the indications and recorders on a main control board, the SPDS or theplant computer, the availability of other parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.Escalation of the emergency classification level would be via IC MSA42-.Month 20XXLGS 3-68EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSBasis Reference(s): .1. NEI 99-01 Rev 6, SU22. DBD L-T-06, Human Factors, Section 6.1.13. T-101 RPV Control4. T-102 Primary Containment Control5. ON-122, Loss of Main Control Room Annunciators -BasesMonth 20XXLGS 3-69EP-AA-1008 (Revision XX)}}

Revision as of 04:21, 28 June 2018

Attachment 7: Discussion of Revision to the Radiological Emergency Plan Annex for Limerick Generating Station. Cover Through Page LGS 3-69
ML14164A068
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 05/30/2014
From:
Exelon Generation Co
To:
NRC/FSME, Office of Nuclear Material Safety and Safeguards
Shared Package
ML14164A053 List:
References
RA-14-032, RS-14-115, TMI-14-046 EO-AA-1008, NEI 99-01, Rev. 6
Download: ML14164A068 (136)
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ATTACHMENT 7DISCUSSION OF REVISIONTO THERADIOLOGICAL EMERGENCY PLAN ANNEXFORLIMERICK GENERATING STATIONEP-AA-1 008Enclosures* Enclosure 7A -EAL Comparison Matrix Document* Enclosure 7B -EAL Red-Line Basis Document* Enclosure 7C -EAL Basis Document NEI 99-01REVISION 6DEVELOPMENT OF EMERGENCY ACTIONLEVELS FOR NON-PASSIVE REACTORSArrACHMENT 7DISCUSSION OF REVISION TO THE RADIOLOGICALEMERGENCY PLAN ANNEX FORLIMERICK GENERATING STATIONmr Exelon Generation.

0NEI 99-01 Rev 6 Proposed EAL I JustificationAGIInitiating Condition -GENERAL EMERGENCYRelease of gaseous radioactivity resulting in offsite dose greater than 1,000 mremTEDE or 5,000 mrem thyroid CDE.Operating Mode Applicability: AllExample Emergency Action Levels: (1 or 2 or 3)Notes:The Emergency Director should declare the General Emergency promptlyupon determining that the applicable time has been exceeded, or will likely beexceeded.If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.If the effluent flow past an effluent monitor is known to have stopped due toactions to isolate the release path, then the effluent monitor reading is nolonger valid for classification purposes.The pre-calculated effluent monitor values presented in EAL #1 should beused for emergency classification assessments until the results from a doseassessment using actual meteorology are available.1. Reading on any of the following radiation monitors greater than thereading shown for 15 minutes or longer:(site specific monitor list and threshold values)2. Dose assessment actual meteorology indicates doses greater than 1000mrem TEDE or 5000 mrem thyroid CDE at or beyond (site specific dosereceptor point)3. Field survey results indicate EITHER of the following at or beyond (sitespecific dose receptor point):* Closed window dose rates greater than 1000 mR/hr expected tocontinue for 60 minutes or longer.* Analysis of field survey samples indicate thyroid CDE greater than5000 mrem for one hour of inhalation.RGIInitiating Condition:Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mRemTEDE or 5,000 mRem thyroid CDE.Operating Mode Applicability:1,2,3,4,5. DEmergency Action Level (EAL):Notes:* The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release pathto the environment is established. If the effluent flow past an effluent monitor isknown to have stopped due to actions to isolate the release path, then theeffluent monitor reading is no longer valid for classification purposes.The pre-calculated effluent monitor values presented in EAL #1 should beused for emergency classification assessments until the results from a doseassessment using actual meteorology are available.1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for> 15 minutes.OR2. Dose assessment using actual meteorology indicates doses at or beyond thesite boundary of EITHER:a. > 1000 mRem TEDEORb. > 5000 mRem CDE ThyroidOR3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >1000 mR/hr are expected tocontinue for > 60 minutes.ORb. Analyses of field survey samples indicate > 5000 mRem CDEThyroid for 60 minutes of inhalation.Table R1 Effluent Monitor ThresholdsRelease Path General EmergencyNorth Stack (WR Monitor: RIX-26-076-4) 1.92 E+08 uCi/secSouth Stack (Unit 1: RY26-185A-3 I RY26- 2.71 E-01 uCi/sec185-B-3 or Unit 2: RY26-285A-3 / RY26-285-B-3)H No Change F--]Difference I Deviation1) Listed site-specific monitors and threshold values to ensure timely classification.2) Added the following to Notes bullet #3" Classification based on effluent monitorreadings assumes that a release path to the environment is established." In orderto delete the following from the basis "Classification based on effluent monitorreadings assumes that a release path to the environment is established. If theeffluent flow past an effluent monitor is known to have stopped due to actions toisolate the release path, then the effluent monitor reading is no longer valid forclassification purposes." This allows for more timely classification since all thebasis information pertaining to Note bullet 3 will be contained in the IC and thereforreadily available on the 1 lx1 7 procedure matrix used by the SM.Page 1 of66 NEI 99-01 Rev 6 Proposed EAL JustificationASIInitiating Condition -SITE AREA EMERGENCYRelease of gaseous radioactivity resulting in offsite dose greater than 100 mremTEDE or 500 mrem thyroid CDE.Operating Mode Applicability: AllExample Emergency Action Levels: (1 or 2 or 3)Notes:* The Emergency Director should declare the Site Area Emergency promptlyupon determining that the applicable time has been exceeded, or will likely beexceeded.* If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.* If the effluent flow past an effluent monitor is known to have stopped due toactions to isolate the release path, then the effluent monitor reading is nolonger valid for classification purposes.* The pre-calculated effluent monitor values presented in EAL #1 should beused for emergency classification assessments unfit the results from a doseassessment using actual meteorology are available.1. Reading on any of the following radiation monitors greater than thereading shown for 15 minutes or longer:(site specific monitor list and threshold values)2. Dose assessment actual meteorology indicates doses greater than 1000mrem TEDE or 5000 mrem thyroid CDE at or beyond (site specific dosereceptor point)3. Field survey results indicate EITHER of the following at or beyond (sitespecific dose receptor point):* Cloxed window dose rates greater than 100 mRihr expected tocontinue for 60 minutes or longer.* Analysis of field survey samples indicate thyroid CDE greater than500 mrem for one hour of inhalation.RS1Initiating Condition:Release of gaseous radioactivity resulting in offsite dose greater than 100 mRemTEDE or 500 mRem thyroid CDE.Operating Mode Applicability:1,2,3,4,5, DEmergency Action Level (EAL):Notes:* The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release pathto the environment is established. If the effluent flow past an effluent monitor isknown to have stopped due to actions to isolate the release path, then theeffluent monitor reading is no longer valid for classification purposes.The pre-calculated effluent monitor values presented in EAL #1 should be usedfor emergency classification assessments until the results from a doseassessment using actual meteorology are available.I. Readings on ANY Table RI Effluent Monitor > Table RI value for > 15minutes.OR2. Dose assessment using actual meteorology indicates doses at or beyond thesite boundary of EITHER:a. > 100 mRem TEDEORb. > 500 mRem CDE ThyroidOR3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >100 mR/hr are expected tocontinue for> 60 minutes.ORb. Analyses of field survey samples indicate > 500 mRem CDEThyroid for 60 minutes of inhalation.Table R1 Effluent Monitor ThresholdsRelease Path Site Area EmergencyNorth Stack (WR Monitor: RIX-26-076-4) 1.92 E+07 uCi/secSouth Stack (Unit 1: RY26-185A-3 / 2.71 E-02 uCi/secRY26-185-B-3 or Unit 2: RY26-285A-3 IRY26-285-B-3)LI No Change E Difference 1 Deviation1) Listed site-specific monitors and threshold values to ensure timely classification.2) Added the following to Notes bullet #3" Classification based on effluent monitorreadings assumes that a release path to the environment is established." In orderto delete the following from the basis "Classification based on effluent monitorreadings assumes that a release path to the environment is established. If theeffluent flow past an effluent monitor is known to have stopped due to actions toisolate the release path, then the effluent monitor reading is no longer valid forclassification purposes." This allows for more timely classification since all thebasis information pertaining to Note bullet 3 will be contained in the IC and thereforreadily available on the 11x17 procedure matrix used by the SM.Page 2 of 66 NEI 99-01 RevS Proposed EAL JustificationNEI 99-01 Rev 6Proposed EALJustification4 +AA1Initiating Condition -ALERTRelease of gaseous or liquid radioactivity resulting in offsite dose greater than 10mrem TEDE or 50 mrem thyroid ODE.Operating Mode Applicability: AllExample Emergency Action Levels: (1 or 2 or 3)Note:* The Emergency Director should declare the Alert promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.* If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.* If the effluent flow past an effluent monitor is known to have stopped dueto actions to isolate the release path, then the effluent monitor reading isno longer valid for classification purposes.* The pre-calculated effluent monitor values presented in EAL #1 should beused for emergency classification assessments until the results from adose assessment using actual meteorology are available.1. Reading on any of the following radiation monitors greater than thereading shown for 15 minutes or longer:(site-specific monitor list end threshold values)2. Dose assessment actual meteorology indicates doses greater than 10mrem TEDE or 50 mrem thyroid CDE at or beyond (site specific dosereceptor point)3. Analysis of a liquid effluent sample indicates a concentration or releaserate that would result in doses greater than 10 mrem TEDE or 50 mremthyroid CDE at or beyond (site-specific dose receptor point) for one hour ofexposure.4. Field survey results indicate EITHER of the following at or beyond (sitespecific dose receptor point):* Closed window dose rates greater than 10 mR/hr expected tocontinue for 60 minutes or longer.* Analysis of field survey samples indicate thyroid CDE greater than50 mrem for one hour of inhalation.RA1Initiating Condition:Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10mrem TEDE or 50 mrem thyroid CDE.Operating Mode Applicability:1,2, 3,4, 5, DEmergency Action Level (EAL):Notes:* The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assumethat the release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release pathto the environment is established. If the effluent flow past an effluent monitor isknown to have stopped due to actions to isolate the release path, then theeffluent monitor reading is no longer valid for classification purposes.* The pre-calculated effluent monitor values presented in EAL #1 should be usedfor emergency classification assessments until the results from a doseassessment using actual meteorology are available.1. Readings on ANY Table RI Effluent Monitor > Table Ri value for > 15minutes.OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 10 mRem TEDEORb. > 50 mRem CDE ThyroidOR3. Analysis of a liquid effluent sample indicates a concentration or release ratethat would result in doses greater than EITHER of the following at or beyondthe site boundarya. 10 mRem TEDE for 60 minutes of exposureORb. 50 mRem CDE Thyroid for 60 minutes of exposureOR4. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (cdosed window) dose rates > 10 mR/hr areexpected to continue for a 60 minutes.ORb. Analyses of field survey samples indicate > 50 mRemCDE Thyroid for 60 minutes of inhalation.Table RI Effluent Monitor ThresholdsRelease Path AlertNorth Stack (WR Monitor: RIX-26-076-4) 1.92 E+06 uCi/secSouth Stack (Unit 1: RY26-185A-3 / 2.71 E-03 uCi/secRY26-185-B-3 or Unit 2: RY26-285A-3 /RY26-285-B-3)LI No Change E Difference [I] Deviation1) Listed site-specific monitors and threshold values to ensure timely classification.2) Added the following to Notes bullet #3 " Classification based on effluent monitorreadings assumes that a release path to the environment is established." In orderto delete the following from the basis "Classification based on effluent monitorreadings assumes that a release path to the environment is established. If theeffluent flow past an effluent monitor is known to have stopped due to actions toisolate the release path, then the effluent monitor reading is no longer valid forclassification purposes." This allows for more timely classification since all the basisinformation pertaining to Note bullet 3 will be contained in the IC and thereforreadily available on the 1 1x17 procedure matrix used by the SM.3) A calculation was performed, in accordance with (lAW) guidance provided in NEI99-01 revision 6 EAL AA1, to determine the effluent monitor response for aradioactive liquid release via the normal site release pathway. The liquid releasewould contain activity equivalent to provide 10mrem TEDE or 50mrem thyroid CDEat the site boundary. The calculation determined the effluent monitor responsewould be >110% of the instrument maximum range and as such, lAW NEI 99-01Rev 6 guidance, was not included in this EAL.Page 3 of 66 NEI 99-01 Rev 6 1 Proposed EAL JustificationAUIInitiating Condition -UNUSUAL EVENTRelease of gaseous or liquid radioactivity greater than 2 times the (site-specificeffluent release controlling document) limits for 60 minutes or longerOperating Mode Applicability: AllExample Emergency Action Levels: (1 or 2 or 3)Note:" The Emergency Director should declare the Unusual Event promptly upondetermining that 60 minutes has been exceeded, or will likely beexceeded." If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 60 minutes." If the effluent flow past an effluent monitor is known to have stopped,indicating that the release path is isolated, the effluent monitor reading isno longer valid for classification purposes.1. Reading on ANY effluent radiation monitor greater than 2 times the (site-specific effluent release controlling document) limits for 60 minutes orlonger:(site-specific monitor list and threshold values corresponding to 2 timesthe controlling document limits)2. Reading on ANY effluent radiation monitor greater than 2 times thealarm setpoint established by a current radioactivity discharge permit for60 minutes or longer.3. Sample analysis for a gaseous or liquid release indicates a concentrationor release rate greater than 2 times (site-specific effluent releasecontrolling document limits) for 60 minutes or longer.RUIInitiating Condition:Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60minutes or longer.Operating Mode Applicability:1,2, 3,4, 5, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assumethat the release duration has exceeded 60 minutes." Classification based on effluent monitor readings assumes that a release path tothe environment is established. If the effluent flow past an effluent monitor isknown to have stopped due to actions to isolate the release path, then the effluentmonitor reading is no longer valid for classification purposes.1. Reading on ANY of the following effluent monitors > 2 times alarm setpointestablished by a current radioactive release discharge permit for a 60 minutes." Radwaste Discharge Effluent Monitor (RR63-OR001)OR" Discharge Permit specified monitorOR2 Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 60 minutes:Table R1 Effluent Monitor ThresholdsRelease Path Unusual EventNorth Stack (WR Monitor: RIX-26-076-4) 2.20 E+04 uCi/secSouth Stack (Unit 1: RY26-185A-3 / RY26- 3.09 E-05 uCi/sec185-B-3 or Unit 2: RY26-285A-3 / RY26-285-B-3)OR3. Confirmed sample analyses for gaseous or liquid releases indicate concentrationsor release rates > 2 times ODCM Limit with a release duration of > 60 minutes.D:1 No Change 111 Difference F Deviation1) Listed site-specific monitors and threshold values to ensure timelyclassification.2) Added the following to Notes bullet #3" Classification based on effluentmonitor readings assumes that a release path to the environment is established."In order to delete the following from the basis "Classification based on effluentmonitor readings assumes that a release path to the environment is established.If the effluent flow past an effluent monitor is known to have stopped due toactions to isolate the release path, then the effluent monitor reading is no longervalid for classification purposes." This allows for more timely classification sinceall the basis information pertaining to Note bullet 3 will be contained in the IC andtherefor readily available on the 1 1x17 procedure matrix used by the SM.Page 4 of 66 NED 99-01 Rev 6 Proposed EAL JustificationNEI 99-01 Rev 6Proposed EALJustification--- -tAG2Initiating Condition -- GENERAL EMERGENCYSpent fuel pool level cannot be restored to at least (site-specific Level 3description) for 60 minutes or longer.Operating Mode Applicability: AllExample Emergency Action Levels:NOTES: The Emergency Director should declare the General Emergencypromptly upon determining that 60 minutes has been exceeded,or will likely be exceeded1. Spent fuel pool level cannot be restored to at least (site-specific Level 3description) for 60 minutes or longer.RG2D No ChangeE Difference 1 Deviation1) EAL not used in accordance with the discussion in Section 1.4, NRC OrderEA-1 2-051, it is recommended that this EAL be implemented when the enhancedspent fuel pool level instrumentation is available for use per developer noteguidance, The completion of the enhanced SFP level indicators and need for theinclusion of this EAL is being tracked in accordance with Exelon GenerationCompany, LLC's Initial Status Report to March 12, 2012 Commission OrderModifying Licenses with Regard for Reliable Spent Fuel Pool Instrumentation(Order Number EA-12-051) dated October 25,2012.Page 5 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationInitiating Condition -SITE AREA EMERGENCY AS2 RS2 1 No Change FIDifference jJ DeviationSpent fuel pool level cannot be restored to at least (site-specific Level 3description) 1) EAL not used in accordance with the discussion in Section 1.4, NRC OrderEA-1 2-051, it is recommended that this EAL be implemented when the enhancedOperating Mode Applicability: All spent fuel pool level instrumentation is available for use. The completion of theenhanced SFP level indicators and need for the inclusion of this EAL is beingExample Emergency Action Levels: tracked in accordance with Exelon Generation Company, LLC's Initial StatusReport to March 12, 2012 Commission Order Modifying Licenses with Regard for1. Spent fuel pool level cannot be restored to at least (site-specific Level 3 Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) dateddescription) October 25,2012.Page 6 of 66 0NEI 99-01 Rev 6 Proposed EAL JustificationAA2 RA2Initiating Condition -ALERT Initiating Condition: A2 j No Change Difference DeviationSignificant loweing of water level above, or damage to, irradiated fuel. Significant lowering of water level above, or damage to, irradiated fuel. 1) Listed site-specific monitors and threshold values to ensure timely classification.Operating Mode Applicability: All Operating Mode Applicability:2) EAL #3 not used in accordance with the discussion in Section 1.4. NRC Order1. 2, 3, 4, 5, D EA-12-051, it is recommended that this EAL be implemented when the enhancedExample Emergency Action Levels: (1 or 2 or 3) Emergency Action Level (EAL): spent fuel pool level instrumentation is available for use per developer noteguidance. The completion of the enhanced SFP level indicators and need for the1. Uncovery of irradiated fuel in the REFUELING PATHWAY. 1. Uncovery of irradiated fuel in the REFUELING PATHWAY. inclusion of this EAL is being tracked in accordance with Exelon GenerationOR Company, LLC's Initial Status Report to March 12, 2012 Commission Order2. Damage to irradiated fuel resulting in a release of radioactivity from the Modifying Licenses with Regard for Reliable Spent Fuel Pool Instrumentationfuel as indicated by ANY of the following radiation monitors: 2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel (Order Number EA-12-051) dated October 25,2012.as indicated by ANY Table R2 Radiation Monitor reading >1000 mRemlhr.(site-specific listing of radiation monitors, and the associated readings,setpoints and/or alarms)Table R23. Lowering of spent fuel pool level to (site-specific Level 2 value). Refuel Floor ARM's" RIS29-Ml-1(2)K600. Drywell Head Laydown" RIS30-M1-1(2)K600, Dryer / Separator Area" RIS31-M1-1(2)K600, Spent Fuel Pool" RIS32-Ml-1(2)K600, New Fuel storage Vault.RIS33-M1-1(2)K600, Pool Plug LaydownPage 7 of 66 NEI 99-01 Rev 6 [ Proposed EAL [ JustificationAA3Initiating Condition -ALERTRadiation levels that impede access to equipment necessary for normal plantoperations, cooldown or shutdown.Operating Mode Applicability: AllExample Emergency Action Levels: (1 or 2)Note: If the equipment in the listed room or area was already inoperable, or outof service, before the event occurred, then no emergency classification iswarranted1. Dose rate greater than 15 mR/hr in ANY of the following areas:* Control Room* Central Alarm Station* (other site-specific areas/rooms)2. An UNPLANNED event results in radiation levels that prevent orsignificantly impede access to any of the following plant rooms or areas:(site-specific list of plant rooms or areas with entry-related modeapplicability identified)RA3Initiating Condition:Radiation levels that impede access to equipment necessary for normal plantoperations, cooldown or shutdown.Operating Mode Applicability:1,2, 3,4, 5, DEmergency Action Level (EAL):Note:If the equipment in the room or area listed in Table R4 was already inoperable, or outof service, before the event occurred, then no emergency classification is warranted.1-l No Change 1 Difference 1 Deviation1) Listed site specific plant rooms and areas with identified mode applicability toensure timely classification.1 .Dose rate > 15 mR/hr in ANY of the following Table R3 areas:Table R3Areas Requiring Continuous Occupancy" Main Control Room" Central Alarm Station -(by survey)OR2. UNPLANNED event results in radiation levels that prohibit or significantlyimpede access to ANY of the following Table R4 plant rooms or areas:Table R4Areas with Entry Related Mode ApplicabilityArea Entry Related Mode ApplicabilityReactor Enclosure* I Modes 3, 4, and 5*Areas required to establish shutdown coolingPage 9 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationSU3 RU3 I No Change [--j Difference U DeviationInitiating Condition: UNUSUAL EVENT Initiating Condition:Reactor coolant activity greater than Technical Specification allowable limits. Reactor coolant activity greater than Technical Specification allowable limits. 1) Listed site-specific monitor and threshold value to ensure timely classification.Operating Mode Applicability: Operating Mode Applicability: 2) Listed this system category EAL in the radiological category EAL section toPower Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 maintain consistency with current and previous revisions of Exelon EALs. This willExample Emergency Action Levels: Emergency Action Level (EAL): ensure a timely classification since the threshold values are more aligned with theradiological category vice system category.1. (Site-specific radiation monitor) reading greater than (site-specific value). 1. Air Ejector discharge radiation monitor (RISH 26 1(2)K601A, B) Hi-Hi alarm.OR OR2. Sample analysis indicates that a reactor coolant activity value is greater than 2. Specific coolant activity > 4.0 uClIgm Dose Equivalent 1-131.an allowable limit specified in Technical Specifications.Page 10 of 66 NEI 99-01 rev 6 Fission Product Barrier MatrixFisso Product_ _ _ _ _ _ _ _ Barrier_ _ _ _ _ _ Mari _ _ _ _ _ _ _ _ _ _ __ITAEAEMEGECYALRT_ otM_ _FGI Loss of any two barriers AND Loss or Potential Loss of third barrier.1.2,3FSI Loss or Potential Loss of ANY two barriers.1,2,3FAI ANY Loss or ANY Potential Loss of either Fuel Clad or RCS1,2,3FC -Fuel C lad RC -Reactor Coolant System CT -ContainmentSiubo-CategoryLoss Potential Loss Loss Potential Loss Loss Potential Loss1. RCS Activity/ A. UNPLANNED rapid drop in primary A. Primary containment pressure greatercontainment pressure following than (site-specific value)Containment A (Site specific indications that A Primary containment pressure primary containment pressure rise ORCnan nt reactor coolant activity is greater NoneA.PiaycnimetpsurPressure r greater than (site-specific value) None OR B. (site-specific explosive mixture) existsthan 300 uCi/gm dose equivalent due to RCS leakage. inside primary containmentPrimary 1-131) B. Primary containment pressureContainment response not consistent with LOCA ORConditions conditions. C. HCTL exceeded.A. RPV water level cannot be restored A. RPV water level cannot beA. Primary containment flooding and maintained above (site-specific restored and maintained above2. RPV Water required. RPV water level corresponding to (site-specific RPV level None None A. Primary containment flooding required.Level top of active fuel) or cannot be corresponding to the top of activedetermined, fuel) or cannot be determined.A. UNISOLABLE direct downstreampathway to the environment existsafter primary containment isolationsignalORA. UNISOLABLE primary system leakageA. UNISOLABLE break in any of the that results in exceeding EITHER of B. Intentional primary containmentA, RCSOLLeakbraRateany thehe following:EO~3 .R C S Le a k R a te / fo llow ing : ( site -spe c ific syste m s w ith the fo llowi ng : O per tin O R N oneCo tanm e nt None None potential for high-energy line breas) 1.M x N r a p rtn RNoneNettfrgngibaOR Temperature C. UNISOLABLE primary systemIsolation Failure B. Emergency RPV Depressurization OR leakage that results in exceeding2. Max Normal Operating Area EITHER of the following:Radiation Level. 1. Max Safe OperatingTemperature.OR2. Max Safe Operating AreaRadiation Level.4.Primary A. Primary Containment Radiation A. Primary Containment Radiation A. Primary Containment Radiation MonitorContainment Monitor reading greater than None Monitor reading greater than (site- None None reading greater than (site-specificRadiation (site-specific value), specific value). value).5. EmergencyDirector JudgmentA. Any Condition in the opinion ofthe Emergency Director thatindicates Loss of the Fuel CladBarrier.A. Any Condition in the opinion of theEmergency Director that indicatesPotential Loss of the Fuel Clad Barrier.A. ANY Condition in the opinion of the A. Any Condition in the opinion of theEmergency Director that indicates Loss Emergency Director that indicatesof the RCS Barrier. Potential Loss of the RCS Barrier.A. Any Condition in the opinion of theEmergency Director that indicates Lossof the Containment Barrier..A. Any Condition in the opinion of theEmergency Director that indicates PotentialLoss of the Containment Barrier.Page 11 of 66 Proposed Fission Product Barrier MatrixFission_ _ _ _ _ _ _ _ _ _ PrdcIare arxGNRLEEREC IEAE MREC LRProposed Fission Product Barrier MatrixFG1 Loss of any two barriers AND Loss or Potential Loss of third barrier. [FSI Loss or Potential Loss of ANY two barriers. NJ[Ur2 j FAI ANY Loss or ANY Potential Loss of either Fuel Clad or RCS r[]AFC -Fuel Clad RC -Reactor Coolant System CT -ContainmentSub-CategoryLoses Potential Loss Loss Potential Loss Loss Potential LossCoolant activity > 300 uCtigm Dose None None1. RCS Activity Equivalent 1-131. None Nose None2 RPV water level cannot be restored and 1. RPV water level cannot be restored and1. Plant conditions indicate Primary maintained > -161 Inches (TAF) maintained > -161 Inches (TAF) Plant conditions indicate Primary Containment2. RPV Water Containment flooding is required. OR OR None None ftooding is required.Level 3. RPV water level causst be determined. 2. RPV water level cannot be determined.3. Containment pressure s 55 pstg and rising.OR1. UNPLANNED rapid drop in pnmary 4. a Drywell or Suppression Pool Hydrogen1. Drywell pressure >1.68 pslg. containment pressure following primary concentration > 6%.3. Primary AND containment pressure rise. ANDContainment None None 2. Drywell pressure rise is due to RCS None OR b, Drywell or Suppression Pool OxygenPressurelConditions leakage 2. Primary containment pressure response not concentration 5 5%consistent with LOCA conditions. OR5. Heat Capacity Limit (T-102 Curve SP/T-1))exceeded.3. UNISOLABLE primary system leakage that1. UNISOLABLE Main Steam Line (MSL) results in EITHER of the following:HPIC, Feedwater, RWCU, or RCIC hoe a. Secondary Containment areabreak, temperature > T-1031 SAMP, Max4.RCS Leak Rate None None OR Norm Op Value (MNO) None None2. Emergency RPV Depressurization is OR2.remerbre s Secondary Containment area radiationrequired, level > T-lg31 SAMP, Max Norm OpValue (MNO),5.Primary Drywell radiation monitor reading NoneDrywell radiation monitor readingCnanet >19E52RtrNoeDrywetl radiation monitor reading Nrwe NoneinmoiorradnContainment 1.90 E+02 R/hr. > 100R/hr o 4.35 E+O2 R/hrRadiation1. UNISOLABLE direct downstream pathway tothe environment exists after primarycontainment isolation signal.OR2. Intentional Primary Containmentventing/purging per EOPs or SAGs due toaccident conditions.OR6.Primary 3. UNISOLA1BLE primary system leakage thatContainment None NONE None None 3.UIOAL daysse ekg ht NoneIsotation Failure results in EITHER of the following:a Secondary Containment areatemperature T-1 031 SAMP, MaxSafe Op Value fMNO)ORb. Secondary Containment arearadiation level s T-1031 SAMP, MaxSafe Op Value (MNO)1. Any Condition in the opinion of the 2. Any Condition in the opinion of the 1. ANY Condition in the opinion of the 2 Any Condition in the opinion of the 1. Any Condition in the opinion of the 2. Any Condition in the opinion of the Emergency7. Emergency Emergency Director that indicates Loss Emergency Director that indicates Potential Emergency Director that indicates Loss of Emergency Director that indicates Potential Emergency Director that indicates Loss of the Director that indicates Potential Loss of theDirector Judgment of the Fuel Clad Barrier. Loss of the Fuel Clad Barrier. the RCS Barrier. Loss of the RCS Barrier. Containment Barrier. Containment Barrier.Page 12 of 66 NEI 99-01 Rev 6 1 Proposed EAL JustificationFClCategory: Fuel Clad BarrierRCS ActivityOperating Mode Applicability:Power Operation, Startup, Hot Standby, Hot ShutdownFission Product Barrier Threshold:LossA. (Site specific indications that reactor coolant activity is greater than 300 uCi/gmdose equivalent 1-131)FC1Category: Fuel Clad BarrierRCS ActivityOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LossCoolant activity > 300 uCilgm Dose Equivalent 1-131.E No Change 1-] Difference 1:1 Deviation1) Listed site-specific threshold value to ensure timely classification.Page 13 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Fuel Clad Barrier FC2 Category: Fuel Clad BarrierFC No Change Differ DeviationRPV Water Level RCS Activity 1) Listed site-specific threshold value to ensure timely classification.Operating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Loss LossA. Primary containment flooding required- 1. Plant conditions indicate Primary Containment flooding is required.Potential Loss Potential Loss2. RPV water level cannot be restored and maintained > -161 inches (TAF)A. RPV water level cannot be restored and maintained above (site-specific RPV ORwater level corresponding to top of active fuel) or cannot be determined. 3. RPV water level cannot be determined.Page 14 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Fuel Clad Barrier FC4 Category: Fuel Clad BarrierFC No Change Difference DeviationPrimary Containment Radiation Primary Containment Radiation 1) Listed site-specific monitor and threshold value to ensure timely classification.Operating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Loss LossA. Primary Containment Radiation Monitor reading greater than (site-specific Drywell radiation monitor reading > 1 .90 E+02 RJhr.value).Page 15 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Fuel Clad Barrier FC6 Category: Fuel Clad Barrier FC7 No Change Difference DeviationEmergency Director Judgment Emergency Director JudgmentOperating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1.2, 3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Loss LossA. Any Condition in the opinion of the Emergency Director that indicates Loss of 1. Any Condition in the opinion of the Emergency Director that indicates Loss ofthe Fuel Clad Barrier. the Fuel Clad Barrier.Potential Loss Potential LossA. Any Condition in the opinion of the Emergency Director that indicates Potential 2. Any Condition in the opinion of the Emergency Director that indicates PotentialLoss of the Fuel Clad Barrier. Loss of the Fuel Clad Barrier.Page 16 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Reactor Coolant System Barrier Rd Category: Reactor Coolant System Barrier RC3 E No Change Difference DeviationPrimary Containment Pressure Primary Containment Pressure/Conditions 1) Listed site-specific threshold value to ensure timely classification.Operating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Loss LossA. Primary containment pressure greater than (site-specific value) due to RCS 1. Drywell pressure >1.68 pslg.leakage. AND2. Drywell pressure rise is due to RCS leakagePage 17 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Reactor Coolant System Barrier RC2 Category: Reactor Coolant System Barrier RC2 [ No Change Difference DeviationRPV Water Level RPV Water Level 1) Listed site-specific threshold value to ensure timely classification.Operating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Loss LossA. RPV water level cannot be restored and maintained above (site-specific RPV 1. RPV water level cannot be restored and maintained > -161 inches (TAF)level corresponding to the top of active fuel) or cannot be determined. OR2. RPV water level cannot be determined.Page 18 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Reactor Coolant System Barrier RC3 Category: Reactor Coolant System BarrierRC4 No Change Differe DeviationRCS Leak Rate RCS Leak Rate 1) Listed site-specific systems and threshold values to ensure timely classification.Operating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Loss LossA. UNISOLABLE break in any of the following: ( site-specific systems with potential 1. UNISOLABLE Main Steam Line (MSL), HPIC, Feedwater, RWCU, or RCIC linefor high-energy line breas) break.OR ORB. Emergency RPV Depressurization 2. Emergency RPV Depressurization is required.Potential Loss Potential LossA. UNISOLABLE primary system leakage that results in exceeding EITHER of thefollowing: 3. UNISOLABLE primary system leakage that results in EITHER of the following.a. Secondary Containment area temperature > T-1031 SAMP, Max Norm Op1. Max Normal Operating Temperature Value (MNO)OR OR2. Max Normal Operating Area Radiation Level. b. Secondary Containment area radiation level > T-103/ SAMP, Max Norm OpValue (MNO).Page 19 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Reactor Coolant System Barrier RC4 Category: Reactor Coolant System Barrier RC5 E No Change Difference DeviationPrimary Containment Radiation Primary Containment Radiation 1) Listed site-specific monitor and threshold value to ensure timely classification.Operating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Loss LossA. Primary Containment Radiation Monitor reading greater than (site-specific Drywell radiation monitor reading > IO0R/hrvalue).Page 20 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Reactor Coolant System Barrier RC6 Category: Reactor Coolant System Barrier RC7 No Change Derec DeviationEmergency Director Judgment Emergency director JudgmentOperating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Loss LossA. Any Condition in the opinion of the Emergency Director that indicates Loss of 1. ANY Condition in the opinion of the Emergency Director that indicates Loss ofthe RCS Barrier. the RCS Barrier.Potential Loss Potential LossA. Any Condition in the opinion of the Emergency Director that indicates PotentialLoss of the RCS Barrier. 2. Any Condition in the opinion of the Emergency Director that indicates PotentialLoss of the RCS Barrier.Page 21 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Containment Barrier CTI Category: Containment BarrierCT No Change Diffrenc DeviationPrimary Containment Conditions Primary Containment Pressure/Conditions 1) Listed site-specific threshold values to ensure timely classification.Operating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Loss LossC. UNPLANNED rapid drop in primary containment pressure following primary 1. UNPLANNED rapid drop in primary containment pressure following primarycontainment pressure rise containment pressure rise.OR OR2. Primary containment pressure response not consistent with LOCA conditions.B. Primary containment pressure response not consistent with LOCA conditions.Potential Loss Potential LossD. Primary containment pressure greater than (site-specific value) 3. Containment pressure > 55 psig and rising.OR ORE. (site-specific explosive mixture) exists inside primary containment 4. a. Drywell or Suppression Pool Hydrogen concentration > 6%.OR ANDb. Drywell or Suppression Pool Oxygen concentration > 5%B. HCTL exceeded. OR5. Heat Capacity Limit (T-102 Curve SPIT-1)) exceeded.Page 22 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Containment Barrier CT2 Category: Containment Barrier CT2 No Change Diffrenc DeviationRPV Water Level RPV Water LevelOperating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Potential Loss Potential LossA. Primary containment flooding required. Plant conditions indicate Primary Containment flooding is required.Page 23 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Containment Barrier CT3 Category: Containment BarrierT No Change []Difference DeviationPrimary Containment Isolation Failure Primary Containment Isolation Failure 1) Listed site-specific threshold values to ensure timely classification.Operating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Loss LossA. UNISOLABLE direct downstream pathway to the environment exists after 1. UNISOLABLE direct downstream pathway to the environment exists afterprimary containment isolation signal primary containment isolation signal.OR OR2. Intentional Primary Containment venting/purging per EOPs or SAGs due toB. Intentional primary containment venting per EOPs accident conditions.OR ORC. UNISOLABLE primary system leakage that results in exceeding EITHER of the 3. UNISOLABLE primary system leakage that results in EITHER of the following:following: a. Secondary Containment area temperature > T-1031 SAMP, Max Safe OpValue (MNO)1. Max Safe Operating Temperature. OROR b. Secondary Containment area radiation level > T-1031 SAMP, Max Safe2. Max Safe Operating Area Radiation Level. Op Value (MNO)Page 24 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Containment Barrier CT4 Category: Containment Barrier CT5 F] No Change Difference [ DeviationPrimary Containment Radiation Primary Containment Radiation 1) Listed site-specific monitor and threshold value to ensure timely classification.Operating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Potential Loss Potential LossA. Primary Containment Radiation Monitor reading greater than (site-specificvalue). Drywell radiation monitor reading > 4.35 E+02 R/hrPage 25 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCategory: Containment Barrier CT6 Category: Containment BarrierT No Change Diffren DeviationEmergency director Judgment Emergency Director JudgmentOperating Mode Applicability: Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3Fission Product Barrier Threshold: Fission Product Barrier (FPB) Threshold:Loss LossA. Any Condition in the opinion of the Emergency Director that indicates Loss of 1. Any Condition in the opinion of the Emergency Director that indicates Loss ofthe Containment Barrier. the Containment Barrier.Potential Loss Potential LossA. Any Condition in the opinion of the Emergency Director that indicates Potential 2. Any Condition in the opinion of the Emergency Director that indicates PotentialLoss of the Containment Barrier. Loss of the Containment Barrier.Page 26 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationSG1 MG1 mInitiating Condition: GENERAL EMERGENCY Initiating Condition: L-'X- No Change j Difference U- DeviationProlonged loss of all offsite and all onsite AC power to emergency buses. Prolonged loss of all offsite and all onsite AC power to emergency buses. 1) Listed site specific equipment, site specific time based on station blackoutOperating Mode Applicability: Operating Mode Applicability: coping analysis, and site specific indication to ensure timely classification.Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3Example Emergency Action Levels: Emergency Action Level (EAL):Note: The Emergency Director should declare the General Emergency promptlyupon determining that (site-specific hours) has been exceeded, or will Note:likely be exceeded. The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. a. Loss of ALL offsite and ALL onsite AC power to (site-specificemergency buses).1 Loss of ALL offsite AC power to unit 4 KV Safeguards Buses.AND AND2. Failure of D11(21) and D12(22), D13(23), and D14(24) Emergency Dieselb. EITHER of the following: Generators to supply power to unit 4KV Safeguards Buses.AND" Restoration of at least one emergency bus in less than(site-specific hours) is not likely. 3. EITHER of the following:a. Restoration of at least one unit 4KV safeguards Bus in < 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> is not* (Site-specific indication of an inability to adequately likely.remove heat from the core) ORb. RPV water level cannot be determined to be > -186 inches.Page 27 of 66 NEI 99-01 Rev 6 1 Proposed EAL JustificationSS1Initiating Condition: SITE AREA EMERGENCYLoss of all offsite and all onsite AC power to emergency buses for 15 minutes orlonger.Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Site Area Emergencypromptly upon determining that 15 minutes time has been exceeded, orwill likely be exceeded.Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses)for 15 minutes or longer.MS1Initiating Condition:Loss of all offsite and onsite AC power to emergency busses for 15 minutes orlonger.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC Power to unit 4KV Safeguards Buses.AND2. Failure of O11(21), O12(22), D13(23), and D14(24) Emergency DieselGenerators to supply power to unit 4KV Safeguards Buses.AND3. Failure to restore power to at least one unit 4KV Safeguards bus in < 15minutes from the time of loss of both offsite and onsite AC power.F] No Change Difference FIDeviation1) Listed site specific equipment to ensure timely classification.Page 28 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationSA1Initiating Condition: ALERTLoss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Alert promptly upon determiningthat 15 minutes time has been exceeded, or will likely be exceeded.1. a. AC power capability to (site-specific emergency buses) is reduced to asingle power source for 15 minutes or longer.ANDb. Any additional single power source failure will result in loss of all ACpower to SAFETY SYSTEMS.MAIInitiating Condition:Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. AC power capability to unit 4KV Safeguards Buses reduced to only one of thefollowing power sources for > 15 minutes.* 101 Safeguards Transformer* 201 Safeguards TransformerD 011(21) Diesel Generator* D12(22) Diesel Generator* D13(23) Diesel GeneratorD 014(24) Diesel GeneratorAND2. ANY additional single power source failure will result in a loss of all AC powerto SAFETY SYSTEMS.M No Change FIDifference R Deviation1) Listed site specific equipment to ensure timely classification.Page 29 of 66 NEI 99-01 Rev 6 Proposed EAL [ JustificationSulInitiating Condition: UNUSUAL EVENTLoss of all offsite AC power capability to emergency buses for 15 minutes orlonger.Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes has been exceeded, or will likely beexceeded.Loss of ALL offsite AC power capability to (site-specific emergency buses) for 15minutes or longerMU1Initiating Condition:Loss of all offsite AC power capability to emergency buses for 15 minutes orlonger.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.Loss of ALL offsite AC power capability to unit ECCS busses for > 15 minutes.M No Change D Difference 1 Deviation1) Listed site specific equipment to ensure timely classification.Page 30 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationSG8Initiating Condition: GENERAL EMERGENCYLoss of all AC and Vital DC power sources for 15 minutes or longer.Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the General Emergency promptlyupon determining that 15 minutes has been exceeded, or will likely beexceeded.1. Loss of ALL offsite and ALL onsite AC power to (site-specific emergencybuses) for 15 minutes or longer.ANDIndicated voltage is less than (site-specific bus voltage value) on ALL(site-specific vital DC busses) for 15 minutes or longer.MG2Initiating Condition:Loss of all AC and Vital DC power sources for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to unit 4KV safeguards Buses.AND2. Failure of D1 1(21), D12(22), D13(23), and D14(24) Emergency DieselGenerators to supply power to unit 4KV Safeguards Buses.AND3. Voltage is <105 VDC on 125 VDC battery busses 1(2)FA, FB, FC, and FD for>15 minutes.AND4. ALL AC and Vital DC power sources have been lost for > 15 minutes.H No Change M Difference FIDeviation1) Listed site specific equipment to ensure timely classification.2) Removed the word "indicated" this will allow for an indication problem to notcause confusion on the need to declare.Page 31 of 66 NEI 99-01 Rev 6 ] Proposed EAL JustificationSS8Initiating Condition: SITE AREA EMERGENCYLoss of all Vital DC power for 15 minutes or longer.Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Site Area Emergencypromptly upon determining that 15 minutes time has been exceeded, orwill likely be exceeded.Indicated voltage is less than (site-specific bus voltage value) on ALL Vital DCbuses for 15 minutes or longer.MS2Initiating Condition:Loss of all Vital DC power for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.Voltage is < 105 VDC on 125 VDC battery busses 1(2)FA, FB, FC, and FD for > 15minutes.D No Change M Difference -- Deviation1) Listed site specific equipment and site specific value to ensure timelyclassification.2) Removed the word "indicated" this will allow for an indication problem to notcause confusion on the need to declare.Page 32 of 66 NEI 99-01 Rev 6SS5Initiating Condition: SITE AREA EMERGENCYInability to shutdown the reactor causing a challenge to (core cooling [PWR] / RPVwater level [BWR]) or RCS heat removal.Operating Mode Applicability:Power OperationExample Emergency Action Levels:1. a. An automatic (trip [PWR] / scram [BWR]) did not shutdown thereactor.ANDb. All manual actions to shutdown the reactor have been unsuccessful.ANDc. EITHER of the following conditions exist:1. (Site-specific indication of an inability to adequatelyremove heat from the core)OR2. (Site-specific indication of an inability to adequatelyremove heat from the RCS)Proposed EAL I JustificationMS3Initiating Condition:Inability to shutdown the reactor causing a challenge to RPV water level or RCSheat removal.Operating Mode Applicability:1,2Emergency Action Level (EAL):1. Automatic scram did not shutdown the reactor as indicated by Reactor Power> 4%.AND2. ALL manual / ARI actions to shutdown the reactor have been unsuccessful asindicated by Reactor Power > 4%.AND3. EITHER of the following conditions exist:" RPV water level cannot be restored and maintained > -186 inches.OR" Heat Capacity Limit (T-102 Curve SP/T-1) exceeded.D-1 No Change M Difference FIDeviation1) Listed site specific indications to ensure timely classification.2) Mode 2 included in operating mode applicability as per developer notes.3) Added ARI as an equivalent scramPage 33 of 66 NEI 99-01 Rev 6 1 Proposed EAL JustificationSAOInitiating Condition: ALERTAutomatic or manual (trip [PWR] / scram [BWR]) fails to shutdown the reactor, andsubsequent manual actions taken at the reactor control consoles are notsuccessful in shutting down the reactor.Operating Mode Applicability:Power OperationExample Emergency Action Levels:Note: A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.a. An automatic (trip IPWR] I scram [BWR]) did not shutdown thereactor.ANDb. Manual action taken at the reactor control consoles are notsuccessful in shutting down the reactor.MA3Initiating Condition:Automatic or manual scram fails to shutdown the reactor, and subsequent manualactions taken at the reactor control consoles are not successful in shutting downthe reactor.Operating Mode Applicability:1,2Emergency Action Level (EAL):Note:A manual action is any operator action, or set of actions, which causes the controlrods to be rapidly inserted into the core, and does not include manually driving incontrol rods or implementation of boron injection strategies.1. Automatic or manual scram did not shutdown the reactor as indicated byReactor Power > 4%.AND2. Manual / ARI actions taken at the Reactor Console are not successful inshutting down the reactor as indicated by Reactor Power > 4%.D No Change r -] Difference FIDeviation1 ) Listed site specific indications to ensure timely classification.2) Mode 2 included in operating mode applicability as per developer notes.3) Added ARI as an equivalent scramPage 34 of 66 NEI 99-01 Rev 6 ] Proposed EAL JustificationSU5Initiating Condition: UNUSUAL EVENTAutomatic or manual (trip (PWR] / scram [BWR]) fails to shutdown the reactor.Operating Mode Applicability:Power OperationExample Emergency Action Levels: (1 or 2)Note: A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.1. a. An automatic (trip [PWR] / scram [BWRJ) did not shutdown thereactor.ANDb. A subsequent manual action taken at the reactor control consoles issuccessful in shutting down the reactor.2. a. A manual scram ([PWR] / scram [BVVR]) did not shutdown thereactor.ANDb. EITHER of the following:1. A subsequent manual action taken at the reactor control consolesis successful in shutting down the reactor.OR2. A subsequent automatic (trip [PWR] / scram [BWR]) is successfulin shutting down the reactor.MU3Initiating Condition:Automatic or manual scram fails to shutdown the reactor.Operating Mode Applicability:F No Change M Difference Deviation1) Listed site specific indications to ensure timely classification.2) Mode 2 included in operating mode applicability as per developer notes.3) Added ARI as an equivalent scram1,2Emergency Action Level (EAL):Note:A manual action is any operator action, or set of actions, which causes the controlrods to be rapidly inserted into the core, and does not include manually driving incontrol rods or implementation of boron injection strategies.1. a. Automatic scram did not shutdown the reactor as indicated by ReactorPower > 4%.ANDb. Subsequent manual / ARI action taken at the Reactor Console issuccessful in shutting down the reactor.OR2. a. Manual scram did not shutdown the reactor as indicated by ReactorPower > 4%.ANDb. EITHER of the following:1. Subsequent manual / ARI action taken at the Reactor Console issuccessful in shutting down the reactor.OR2. Subsequent automatic scram / ARI is successful in shutting downthe reactor.Page 35 of 66 NEI 99-01 Rev 6 1 Proposed EAL JustificationSA2Initiating Condition: ALERTUNPLANNED loss of Control Room indications for 15 minutes or longer with asignificant transient in progress.Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Alert promptly upondetermining that 15 minutes has been exceeded, or will likely beexceeded.1. a. An UNPLANNED event results in the inability to monitor ANY of thefollowing parameters from within the Control Room for 15 minutes or longer.[see table below]MA4Initiating Condition:UNPLANNED loss of Control Room indications for 15 minutes or longer with asignificant transient in progress.Operating Mode Applicability:1,2.3Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED event results in the inability to monitor ANY Table M1 parameterfrom within the Control Room for >15 minutes.Table M1 Control Room Parameters" Reactor Power" RPV Water Level" RPV Pressure" Drywell Pressure" Suppression Pool Level" Suppression Pool TemperatureAND2. ANY Table M2 transient in progress.M No Change DIDifference 1 Deviation[ BWR parameter list] [ PWR parameter list]Reactor Power Reactor PowerRPV Level RCS LevelRPV Pressure RCS PressurePrimary Containment Pressure In Core/Core Exit TemperatureLevels in at least (site specificSuppression Pool Level number) steam generatorsSu nPool Temperature Steam Generator Auxiliary orSuppression Emergency Feed Water FlowANDb. Any of the following transient events in progress.* Automatic or Manual runback greater than 25% thermal reactor power* Electrical load rejection greater than 25% full electrical load* Reactor Scram [BWR] / trip [PWR]* ECCS (SI) actuation* Thermal power oscillations greater than 10% [BWR]Table M2 Significant Transients* Automatic or Manual Runback >25% thermal reactor power* Electrical Load Rejection >25% full electrical load* Reactor Scram* ECCS Actuation* Thermal Power oscillations > 10%Page 36 of 66 NEI 99-01 Rev 6 1 Proposed EAL I JustificationSU2Initiating Condition: UNUSUAL EVENTUNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes has been exceeded, or will likely beexceeded.An UNPLANNED event results in the inability to monitor ANY of the followingparameters from within the Control Room for 15 minutes or longer.[see table below][ BWR parameter list] [PWR parameter list]Reactor Power Reactor PowerRPV Level RCS LevelRPV Pressure RCS PressurePrimary Containment Pressure In Core/Core Exit TemperatureLevels in at least (site specificSuppression Pool Level number) steam generatorsSteam Generator Auxiliary orSuppression Pool Temperature Emergency Feed Water FlowMU4Initiating Condition:UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.UNPLANNED event results in the inability to monitor ANY Table M1 parametersfrom within the Control Room for > 15 minutes.M No Change 1 Difference FIDeviationTable M1 Control Room Parameters* Reactor Power* RPV Water Level* RPV Pressure* Drywell Pressure* Suppression Pool Level* Suppression Pool TemperaturePage 37 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationSA9Initiating Condition: ALERTHazardous event affecting a SAFETY SYSTEM needed for the current operatingmode.Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels:1. a. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)* Internal or external flooding event* High winds or tornado strike* FIRE* EXPLOSION* (site-specific hazards)* Other events with similar hazard characteristics asdetermined by the Shift ManagerANDb. EITHER of the following:1. Event damage has caused indications of degraded performancein at least one train of a SAFETY SYSTEM needed for thecurrent operating mode.OR2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEMcomponent or structure needed for the current operating mode.MA5Initiating Condition: ALERTHazardous event affecting a SAFETY SYSTEM required for the current operatingmode.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):1. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)* Internal or external flooding event* High winds or tornado strike* FIRE* EXPLOSION* Other events with similar hazard characteristics as determinedby the Shift ManagerAND2. EITHER of the following:a. Event damage has caused indications of degradedperformance in at least one train of a SAFETY SYSTEMrequired by Technical Specifications for the currentoperating mode.ORb. The event has caused VISIBLE DAMAGE to a SAFETYSYSTEM component or structure required by TechnicalSpecifications for the current operating mode.F No Change M Difference FIDeviation1) No additional site specific hazard noted2) Changed the word "needed" to "required" in the IC and "required by TechnicalSpecification" in the EAL to be consistent with terminology used by operators andminimize confusion.Page 38 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationSU4Initiating Condition: UNUSUAL EVENTRCS leakage for 15 minutes or longer.Operating Mode Applicability:Power Operation, Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels: (1 or 2 or 3)Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes has been exceeded, or will likely beexceeded.1. RCS unidentified or pressure boundary leakage greater than (site-specificvalue) for 15 minutes or longer.2. RCS identified leakage greater than (site-specific value) for 15 minutes orlonger3. Leakage from the RCS to a location outside containment greater than 25gpm for 15 minutes or longerMU6Initiating Condition:RCS leakage for 15 minutes or longer.Operating Mode Applicability:1,2,3F No Change i Difference I Deviation1) Listed site specific values to ensure timely classification.2) Changed wording from containment to drywell for clarity to better define theprimary containment structure.3) In EAL #1 and 2 added "into the drywell" to differentiate between EAL #1/2 and#3. Without this wording would have been in EAL #1 or #2 concurrent with #3. Withthe added wording each EAL can be called separately.Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. RCS unidentified or pressure boundary leakage into the drywell > 10 gpm for> 15 minutes.OR2. RCS identified leakage into the drywell >25 gpm for > 16 minutes.OR3. Leakage from the RCS to a location outside the drywell >25 gpm for > 15minutes.Page 39 of 66 NEI 99-01 Rev 6 Proposed EAL I JustificationInitiating Condition: UNUSUAL EVENTLoss of all onsite or offsite communications capabilitiesOperating Mode Applicability:Power Operation, Startup, Hot Standby, Hot ShutdownExample Emergency Action Levels: (1 or 2 or 3)1. Loss of ALL of the following onsite communication methods:(site-specific list of communications method2. Loss of ALL of the following ORO communications s) methods:(site-specific list of communications methods)3. Loss of ALL of the following NRC communications methods:(site-specific list of communications methods)SU6MU7Initiating Condition:Loss of all onsite or offsite communication capabilities.Operating Mode Applicability:1,2,3No Change F1 Difference FIDeviation1) Listed site specific communication methods to ensure timely classification.Emergency Action Level (EAL):1. Loss of all Table M3 Onsite communications capability affecting theability to perform routine operations.OR2. Loss of all Table M3 Offsite communication capability affecting the abilityto perform offsite notifications.OR3. Loss of all Table M3 NRC communication capability affecting the ability toperform NRC notifications.Table M3 Communications CapabilitySystem Onsite Offslte NRCStation Radio XPlant Public Address (PA) XPrelude System X XStation Phones X X XSatellite Phones X X XNARS XHPN X XENS X XPage 40 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCA2Initiating Condition: ALERTLoss of all offsite and all onsite AC power to emergency buses for 15 minutes orlonger.Operating Mode Applicability:Cold Shutdown, Refueling, DefueledExample Emergency Action Levels:Note: The Emergency Director should declare the Alert promptly upondetermining that 15 minutes time has been exceeded, or will likely beexceeded.Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses)for 15 minutes or longer.CAlInitiating Condition:Loss of all offsite and onsite AC power to emergency busses for 15 minutes orlonger.Operating Mode Applicability:4,5, DEmergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. Loss of all offsite AC power to unit 4KV Safeguards Buses.AND2. Failure of Dl1(21), D12(22), D13(23), and D14(24) Emergency DieselGenerators to supply power to unit 4KV Safeguards Buses.AND3. Failure to restore power to at least one unit 4KV Safeguards bus in< 15 minutes from the time of loss of both offsite and onsite AC power.x No Change --' Difference 1: Deviation1) Listed site specific equipment to ensure timely classification.Page 41 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCU2Initiating Condition: UNUSUAL EVENTLoss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:Cold Shutdown, Refueling, DefueledExample Emergency Action Levels:Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes time has been exceeded, or will likely be exceeded.1. a. AC power capability to (site-specific emergency buses) is reduced to asingle power source for 15 minutes or longer.ANDb. Any additional single power source failure will result in loss of all ACpower to SAFETY SYSTEMS.CUIInitiating Condition:Loss of all but one AC power source to emergency buses for 15 minutes orlonger.Operating Mode Applicability:4,5, DEmergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. AC power capability to unit 4KV Safeguards Buses reduced to only oneof the following power sources for > 15 minutes.* 101 Safeguards Transformer* 201 Safeguards Transformer* D11(21) Diesel Generator* D12(22) Diesel Generator* D13(23) Diesel Generator* D14(24) Diesel GeneratorAND2. ANY additional single power source failure will result in a loss of all ACpower to SAFETY SYSTEMS.E No Change 1:] Difference r-1 Deviation1) Listed site specific equipment to ensure timely classification.Page 42 of 66 NEI 99-01 Rev 6 Proposed EAL I JustificationCASInitiating Condition -ALERTHazardous event affecting SAFETY SYSTEM needed for the current operatingmode.Operating Mode Applicability:Cold Shutdown, RefuelingExample Emergency Action Levels:1. a. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)Internal or external flooding eventHigh winds or tornado strike* FIRE* EXPLOSION( (site-specific hazards)Other events with similar hazard characteristics asdetermined by the Shift ManagerANDb. EITHER of the following:1. Event damage has caused indications of degradedperformance in at least one train of a SAFETY SYSTEMneeded for the current operating mode.OR2. The event has caused VISIBLE DAMAGE to a SAFETYSYSTEM component or structure needed for the currentoperating mode.CA2Initiating Condition:Hazardous event affecting SAFETY SYSTEM required for the current operatingmode.Operating Mode Applicability:4,5Emergency Action Level (EAL):1. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)* Internal or external flooding event* High winds or tornado strike* FIRE* EXPLOSION* Other events with similar hazard characteristics asdetermined by the Shift ManagerAND2. EITHER of the following:a. Event damage has caused indications of degradedperformance in at least one train of a SAFETY SYSTEMrequired by Technical Specifications for the currentoperating mode.ORb. The event has caused VISIBLE DAMAGE to a SAFETYSYSTEM component or structure required by TechnicalSpecifications for the current operating mode.H-- No Change F ] Difference F ] Deviation1) No additional site specific hazards noted2) Changed the word needed to required to be consistent with terminologyused by operators i.e. "required by Technical Specifications", and minimizeconfusion.Page 43 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCU4 U3 D No Change D Dfeec eitoInitiating Condition: UNUSUAL EVENT Initiating Condition: LgcLoss of Vital DC power for 15 minutes or longer. Loss of Vital DC power for 15 minutes or longer. 1) Listed site specific voltage and equipment to ensure timely classification.Operating Mode Applicability: Operating Mode Applicability: 2) Removed the word "indicated" this will allow for an indication problem to notCold Shutdown, Refueling 4, 5 cause confusion on the need to declare.Example Emergency Action Levels: Emergency Action Level (EAL):Note: The Emergency Director should declare the Unusual Event promptly upon Note:determining that 15 minutes time has been exceeded, or will likely beexceeded. The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.Indicated voltage is less than (site-specific bus voltage value) on required Vital DCbuses for 15 minutes or longer.Voltage is < 105 VDC on required 125 VDC battery busses 1(2)FA, FB, FC, andFD for > 15 minutes.Page 44 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCU5Initiating Condition: UNUSUAL EVENTLoss of all onsite or offsite communications capabilitiesOperating Mode Applicability:Cold Shutdown, Refueling, DefuledExample Emergency Action Levels: (1 or 2 or 3)1. Loss of ALL of the following onsite communication methods:(site-specific list of communications method2. Loss of ALL of the following ORO communications s) methods:(site-specific list of communications methods)3. Loss of ALL of the following NRC communications methods:(site-specific list of communications methods)CU4Initiating Condition:Loss of all onsite or offsite communication capabilities.Operating Mode Applicability:4,5, DEmergency Action Level (EAL):1. Loss of all Table C1 Onsite communications capability affecting theability to perform routine operations.OR2. Loss of all Table Cl Offsite communication capability affecting theability to perform offsite notifications.OR3. Loss of all Table C1 NRC communication capability affecting the abilityto perform NRC notifications.E No Change 1 Difference 1 Deviation1) Listed site specific communications methods to ensure timely classificationThble Cl Cammunicntion~ C~nahilltvSystem Onsite Offsite NRCStation Radio XPlant Public Address (PA) XPrelude System X XStation Phones X X XSatellite Phones X X XNARS XHPN X XENS X XPage 45 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCA3 CA5 -NChne Dfeec DeitoInitiating Condition: ALERT Initiating Condition: Cl No Change Difference DeviationInability to maintain the plant in cold shutdown. Inability to maintain plant in cold shutdown. 1) Listed site specific Technical Specification cold shutdown temperature limit andOperating Mode Applicability: Operating Mode Applicability: site-specific pressure reading to ensure timely classification.Cold Shutdown, Refueling 4, 5Example Emergency Action Levels: (1 or 2) Emergency Action Level (EAL):Note: The Emergency Director should declare the Alert promptly upon Note:determining that the applicable has been exceeded, or will likely bede exceededThe Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED increase in RCS temperature to greater than (site-specificTechnical Specification cold shutdown temperature limit) for greater thanthe duration specified in the following table. 1. UNPLANNED rise in RCS temperature > 2000F due to loss of decay2. UNPLANNED RCS pressure increase greater than (site-specific pressure heat removal for > Table C2 duration.reading). (This EAL does not apply during water-solid plant conditions.[PWR]) Table C2 RCS Heat-up Duration ThresholdsTable: RCS Heat-up Duration Thresholds RCS Status Containment Closure Heat-up DurationRCS Status Containment Closure Heat-up Duration StatusStatus Intact Not Applicable 60 minutes*Intact (but not Established 20 minutes*RCS Reduced Not Applicable 60 minutes* Not IntactInventory [PWR])Not Intact (or at Established 20 minutes* Not Established 0 minutesreduced inventory[PWR]) Not Established 0 minutes If an RCS heat removal system is in operation within this timeframe and RCS temperature is being reduced, then EAL #1 is notIf an RCS heat removal system is in operation within this time frame and applicable.RCS temperature is being reduced, the EAL is not applicable.OR2. UNPLANNED RPV pressure rise > 10 psig as a result of temperaturerise due to loss of decay heat removal.Page 46 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCU3 CU5 N a DeInitiating Condition: UNUSUAL EVENT Initiating Condition: 1:j No Change Difference DeviationUNPLANNED increase in RCS temperature. UNPLANNED rise in RCS temperature. 1) Listed site specific Technical Specification cold shutdown temperature limitOperating Mode Applicability: Operating Mode Applicability: to ensure timely classification.Cold Shutdown, Refueling 4, 5 2) Changed the word increase to rise in the initiating condition to be consistentExample Emergency Action Levels: (1 or 2) Emergency Action Level (EAL): with operations language and training.Note: The Emergency Director should declare the Unusual Event promptly Note:upon determining that 15 minutes time has been exceeded, or will likely The Emergency Director should declare the event promptly upon determiningbe exceeded.that the applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED increase in RCS temperature to greater than (site-specificTechnical Specification cold shutdown temperature limit).2. Loss of ALL RCS temperature and (reactor vesselIRCS [PIVR] or RPV 1. UNPLANNED rise in RCS temperatureo> 20lF due to loss of decay[614q]) level indication for 15 minutes or longer. heat removal.OR2. Loss of the following for >16 minutes." ALLRCS temperature indicationsAND" ALLRPV water level indicationsPage 47 of 66 NEI 99-01 Rev 6 Proposed EAL I JustificationCG1Initiating Condition: GENERAL EMERGENCYLoss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory affecting fuel cladintegrity with containment challenged.Operating Mode Applicability:Cold Shutdown, RefuelingExample Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the General Emergencypromptly upon determining that 30 minutes time has been exceeded, orwill likely be exceeded.1. a. (Reactor vessel/RCS [PWR] or RPV [BWR]) vessel level less than (site-specific level) for 30 minutes or longer.ANDb. ANY indication from the Containment Challenge Table2. a.. (Reactor vessel/RCS [PWR] or RPV [BWR]) vessel level cannot bemonitored for 30 minutes or longer.ANDb. Core uncovery is indicated by ANY of the following:* (Site-specific radiation monitor) reading greater than (site-specific value)* Erratic source range monitor indication [PWR]* UNPLANNED increase in (site-specific sump and/or tank levels) ofsufficient magnitude to indicate core uncovery* (Other site-specific indications)ANDc. ANY indication from the Containment Challenge Table).CG6Initiating Condition:Loss of reactor RPV inventory affecting fuel clad integrity with containmentchallenged.Operating Mode Applicability:4,5Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining that the applicabletime has been exceeded, or will likely be exceeded.1 a. RPV water level 4 -161 Inches (TAF) flr > 30 minutes.ANDb. ANY Containment Challenge Indication (Table C4)OR2. a. RPV water level unknown for > 30 minutes.ANDb. Core uncovery is indicated by ANY of the following:Table C3 indications of a sufficient magnitude to indicate core uncovery.OR* Table C5 Refuel Floor Area Radiation Monitor >3 Ryhr.ANDc. ANY Containment Challenge Indication (Table C4)H No Change Z Difference D Deviation1) Listed site specific levels, radiation monitors, and sumps and tanks to ensuretimely classification.2) Listed Explosive mixture in the Containment Challenge Table to ensuretimely classification.3) Worded "cannot be monitored" as unknown to ensure clarity for instanceswhen the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Table C3 Indications of RCS LeakageUNPLANNED floor or equipment sump level rise*UNPLANNED Suppression pool level tise'UNPLANNED vessel make up rate riseObservation of leakage or inventory loss'Rise in level is attributed to a loss of RPV inventory.£ ________Table: Containment Challenge Table" CONTAINMENT CLOSURE not established*" (Explosive mixture) exists inside containment" UNPLANNED increase in containment pressure" Secondary containment radiation monitor reading above (site-specificvalue) [BWR]if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency isnot reouired.Table C4 Containment Challenge IndlcatlonsPrimary Containment Hydrogen Concentration > 6% and Oxygen > 0%UNPLANNED rise in containment pressureCONTAINMENT CLOSURE not established*ANY Secondary Containment radiation monitor , T-1031 SAMP Max Safe Op Value(MSOI.if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncoverytime limit, then escalation to a General Emergency is not required.Table C5Refuel Floor ARM'eRIS29-Mt-1(2)K600, Drywell Head Laydown* RIS30-Mt-1(2)K600, Dryer I Separator AreaRIS31-Mi-I(2)K600, Spent Fuel PoolRIS32-Mt-1(2)K600, New Fuel storage Vault* RIS33-Mlt-l(2)K6D0, Pool Plug LaydownPage 48 of 66 NEI 99-01 Rev 6 [ Proposed EAL I JustificationCS1Initiating Condition: SITE AREA EMERGENCYLoss of (reactor vessel/RCS [PWR] or RPV [BWRJ) inventory affecting coredecay heat removal capability.Operating Mode Applicability:Cold Shutdown, RefuelingExample Emergency Action Levels: (1 or 2 or 3)Note: The Emergency Director should declare the Site Area Emergencypromptly upon determining that 30 minutes time has been exceeded, orwill likely be exceeded.1. a. CONTAINMENT CLOSURE not established.ANDb. (Reactor vessel/RCS [PWR] or RPV [Bl4R]) level less than (site-specific level).2. a. CONTAINMENT CLOSURE established.ANDb. (Reactor vessel/RCS [PWR] or RPV [BWR]) level less than (site-specific level).3. a. (Reactor vessel/RCS [PWR] or RPV [BI4.R]) level cannot bemonitored for 30 minutes or longer.ANDb. Core uncovery is indicated by ANY of the following:* (Site-specific radiation monitor) reading greater than (site-specific value)* Erratic source range monitor indication [PlWR* UNPLANNED increase in (site-specific sump and/or tanklevels) of sufficient magnitude to indicate core uncovery* (Other site-specific indications)CS6Initiating Condition:Loss of RPV inventory affecting core decay heat removal capabilities.Operating Mode Applicability:4,5Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.1. With CONTAINMENT CLOSURE not established, RPV water level < -129 inches.OR2. With CONTAINMENT CLOSURE established, RPV water level < -161inches (TAF)OR3. a. RPV water level unknown for > 30 minutesANDb. Core uncovery is indicated by ANY of the following:* Table C3 indications of a sufficient magnitude to indicate coreuncovery.OR* ANY Table C5 Refuel Floor Area Radiation Monitor >3 R/hr.Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Suppression pool level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.H No Change W Difference 1 Deviation1) Listed site specific values for level, radiation monitors, and sumps and tanksto ensure timely classification.2) Worded "cannot be monitored" as unknown to ensure clarity for instanceswhen the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Table CSRefuel Floor ARM's* RIS29-M1-1(2)K600, Drywell Head Laydown* RIS30-M1-1(2)K600, Dryer / Separator Area* RIS31-M1-1(2)K600, Spent Fuel Pool* RIS32-M1-I(2)K600, New Fuel storage Vault* RIS33-M1-1(2)K600, Pool Plug LaydownPage 49 of 66 NEI 99-01 Rev 6 [ Proposed EAL I JustificationCA1Initiating Condition: ALERTLoss of (reactor vessel/RCS [PWR] or RPV [BI/R]) inventoryOperating Mode Applicability:Cold Shutdown, RefuelingExample Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Alert promptly upondetermining that 15 minutes time has been exceeded, or will likely beexceeded.1. Loss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory asindicated by level less than (site-specific level).2. a. (Reactor vessel/RCS [PWR] or RPV [BWR]) level cannot bemonitored for 15 minutes or longerANDb. UNPLANNED increase in (site-specific sump and/or tank) levels dueto a loss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory.CA6Initiating Condition:Loss of RPV inventoryOperating Mode Applicability:4,5Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.1. Loss of RPV inventory as indicated by level < -38 inches.OR2. a. RPV water level unknown for> 15 minutes.ANDb. Loss of RPV inventory per Table C3 indications.Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Suppression pool level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.H No Change W Difference 1 Deviation1) Listed site specific levels, and sumps and tanks to ensure timelyclassification.2) Worded "cannot be monitored" as unknown to ensure clarity for instanceswhen the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Page 50 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationCutInitiating Condition: UNUSUAL EVENTUNPLANNED loss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory for15 minutes or longer.Operating Mode Applicability:Cold Shutdown, RefuelingExample Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Unusual Event promptly upondetermining that 15 minutes has been exceeded, or will likely beexceeded.1. UNPLANNED loss of reactor coolant results in (reactor vessel/RCS[PWR] or RPV [BWR]) level less than a required lower limit for 15minutes or longer.2. a. (Reactor vessel/RCS [PlR] or RPV [BWR]) level cannot bemonitored.ANDb. UNPLANNED increase in (site-specific sump and/or tank) levels.CU6Initiating Condition:UNPLANNED loss of RPV inventory for 15 minutes or longer.Operating Mode Applicability:4,5Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded.UNPLANNED loss of reactor coolant results in the inability to restoreand maintain RPV water level above the procedurally establishedlower limit for > 15 minutes.OR2. a. RPV water level unknownANDb. Loss of RPV inventory per Table C3 indications.D No Change E Difference --- Deviation1) Described "a required lower limit" as a procedurally established lower limit,and listed site specific sumps and tanks to ensure timely classification.2) Worded "cannot be monitored" as unknown to ensure clarity for instanceswhen the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Suppression pool level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.Page 51 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationNEI 99-01 Rev 6Proposed EALJustificationHG1HG1Initiating Condition: GENERAL EMERGENCYHOSTILE ACTION resulting in loss of physical control of the facility.Operating Mode Applicability:AllExample Emergency Action Levels:1. a. A HOSTILE ACTION is occurring or has occurred within the PROTECTEDAREA as reported by the (site-specific security shift supervision).ANDb. EITHER of the following:1. ANY of the following safety functions cannot be controlled ormaintained.Reactivity control* Core cooling [PqR] I RPV water level [BWR]* RCS heat removalOR2. Damage to spent fuel has occurred or is IMMINENTInitiating Condition:HOSTILE ACTION resulting in loss of physical control of the facility.Operating Mode Applicability:1, 2, 3,4, 5, DEmergency Action Level (EAL):1. A notification from the Security Force that a HOSTILE ACTION is occurringor has occurred within the PROTECTED AREA.AND2. a. ANY Table Hi safety function cannot be controlled or maintained.ORb. Damage to spent fuel has occurred or is IMMINENTTable HI Safety Functions" Reactivity Control (ability to shut down the reactor and keep it shutdown)" RPV Water Level (ability to cool the core)" RCS Heat Removal (ability to maintain heat sink)D- No Change FX Difference 1-- Deviation1) List site security shift supervision as Security Force.2) Added descriptors to better explain each safety function and allow for a timelyclassification.Page 52 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationHSIInitiating Condition: SITE AREA EMERGENCYHOSTILE ACTION within the Protected Area.Operating Mode Applicability:AllExample Emergency Action Levels:A HOSITLE ACTION is occurring or has occurred within the PROTECTED AREAas reported by the (site-security shift supervision).HSIInitiating Condition:HOSTILE ACTION within the Protected Area.M No Change 1 Difference I Deviation1) List site security shift supervision as Security Force.Operating Mode Applicability:1,2, 3,4, 5, DEmergency Action Level (EAL):A notification from the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the PROTECTED AREA.Page 53 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationHAI HAIInitiating Condition: ALERT Initiating Condition: F No Change Difference DeviationHOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack 1) List site security shift supervision as Security Force.threat within 30 minutes. threat within 30 minutes.Operating Mode Applicability: Operating Mode Applicability:All 1,2, 3, 4, 5, DExample Emergency Action Levels: (1 or 2) Emergency Action Level (EAL):1. A HOSTILE ACTION is occurring or has occurred within the OWNER 1. A validated notification from NRC of an aircraft attack threat < 30 minutesCONTROLLED AREA as reported by the (site-specific security shift from the site.supervision).2. A validated notification from NRC of an aircraft attack threat within 30 ORminutes of the site.2. Notification by the Security Force that a HOSTILE ACTION is occurring orhas occurred within the OWNER CONTROLED AREA.Page 54 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationHU1 HUl r---] m ifrne eitoInitiating Condition: UNUSUAL EVENT Initiating Condition: LHU No Change M Difference FJ DeviationConfirmed SECURITY CONDITION or threat.Confirmed SECURITY CONDITION or threat. 1) List site security shift supervision as Security Force.Operating Mode Applicablity: Mode Applicability: 2) Further described credible security threat through listing a site specificOperating Mprocedure.All1,2, 3, 4, 5, DExample Emergency Action Levels: (1 or 2 or 3)Emergency Action Level (EAL):1. A SECURITY CONDITION that does not involve a HOSTILE ACTION asreported by the (site-specific security shift supervision). 1. Notification of a credible security threat directed at the site as determined perSY-AA-101-132, Security Assessment and Response to Unusual Activities.2. Notification of a credible security threat directed at the site. OR2. A validated notification from the NRC providing information of an aircraft3. A validated notification from the NRC providing information of an aircraft threat.threat.OR3. Notification by the Security Force of a SECURITY CONDITION that does notinvolve a HOSTILE ACTION.Page 55 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationHS6 HS2 m NoCag m ifrne eitoInitiating Condition: SITE AREA EMERGENCY Initiating Condition: L[ No Change M Difference LJ DeviationInability to control a key safety function from outside the Control Room. Inability to control a key safety function from outside the Control Room. 1) EAL uses the site specific Control Room evacuation procedures to effectivelylist all of the alternate locations, panels, and stations requested by the developernotes. This would be the procedures the Control Room would enter should such anOperating Mode Applicability: Operating Mode Applicability: event occur, this allows for greater clarity as to when this EAL would apply than ifeach panel and station used in alternate shutdown were to be listed,All 1,2, 3,4, 5,0D2) Added descriptors to better explain each safety function and allow for a timelyclassification.Example Emergency Action Levels: (1 and 2) Emergency Action Level (EAL):Note: The Emergency Director should declare the Site Area Emergency promptly Note: 3) Changed "An event" to" A Control Room evacuation" to remove confusion ifupon determining that (site-specific number of minutes) has been partial plant control was transferred to outside the control room with the controlexceeded, or will likely be exceeded. The Emergency Director should declare the event promptly upon determining that room still manned, due to testing or equipment failure.the applicable time has been exceeded, or will likely be exceeded.1. An event has resulted in plant control being transferred from the ControlRoom to (site-specific remote shutdown panels and local control stations). 1. A Control Room evacuation has resulted in plant control being transferredfrom the Control Room to alternate locations per:2. Control of ANY of the following key safety functions is not reestablished .SE-i, Remote Shutdownwithin (site-specific number of minutes). ORSReactivity control .SE-6, Altemate Remote ShutdownCore cooling [PWR] / RPV water level [BWyR] AND* RCS heat removal 2. Control of ANY Table H1 key safety function is not reestablished in < 15minutes.Table HI Safety Functions* Reactivity Control (ability to shut down the reactor and keep it shutdown)* RPV Water Level (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)Page 56 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationHA6 HA2 mFInitiating Condition: ALERT Initiating Condition: LF No Change M -J Difference ']DeviationControl Room evacuation resulting in transfer of plant control to alternate locations. Control Room evacuation resulting in transfer of plant control to alternate locations. 1) EAL uses the site specific Control Room evacuation procedures to effectivelylist all of the alternate locations, panels, and stations requested by the developernotes. This would be the procedures the Control Room would enter should such anOperating Mode Applicability: Operating Mode Applicability: event occur, this allows for greater clarity as to when this EAL would apply than ifeach panel and station used in alternate shutdown were to be listed,All 1, 2, 3, 4, 5, D 2) Changed "An event" to" A Control Room evacuation" to remove confusion ifpartial plant control was transferred to outside the control room with the controlExample Emergency Action Levels: Emergency Action Level (EAL): room still manned, due to testing or equipment failure.An event has resulted in plant control being transferred from the Control Room to A Control Room evacuation has resulted in plant control being transferred from the(site-specific remote shutdown panels and local control stations). Control Room to alternate locations per:" SE-1, Remote ShutdownOR" SE-6, Alternate Remote ShutdownPage 57 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationHU4HU3Initiating Condition: UNUSUAL EVENTFIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:Initiating Condition:FIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:1,2, 3, 4, 5, DI-X- No Change FIDifference FIDeviation1) Listed site specific list of plant rooms or areas that contain SAFETY SYSTEMequipment to ensure timely classification.AllExample Emergency Action Levels: (1 or 2 or 3 or 4)Note: The Emergency Director should declare the Unusual Eventpromptly upon determining that the applicable time has beenexceeded, or will likely be exceeded.1. a. A FIRE is NOT extinguished within 15-minutes of ANY of the followingFIRE detection indications:* Report from the field (i.e., visual observation)* Receipt of multiple (more than 1) fire alarms or indications* Field verification of a single fire alarmANDb. The FIRE is located within ANY of the following plant rooms or areas:(site-specific list of plant rooms or areas)2. a. Receipt of a single fire alarm (i.e., no other indications of a FIRE).ANDb. The FIRE is located within ANY of the following plant rooms or areas:(site-specific list of plant rooms or areas)ANDc. The existence of a FIRE is not verified within 30-minutes of alarm receipt.3. A FIRE within the plant or ISFSI [for plants with an ISFSI outside the plantProtected Area] PROTECTED AREA not extinguished within 60-minutes ofthe initial report, alarm or indication.4. A FIRE within the plant or ISFSI [for plants with an ISFSI outside the plantProtected Area] PROTECTED AREA that requires firefighting support by anoffsite fire response agency to extinguish.Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.1. A FIRE in ANY Table H2 area is not extinguished in < 15-minutes of ANYof the following FIRE detection indications:* Report from the field (i.e., visual observation)* Receipt of multiple (more than 1) fire alarms or indications* Field verification of a single fire alarmTable H2 Vital Areas* Reactor Enclosure (when inerted the drywell is exempt)* Control Enclosure* Diesel Generator Enclosure* Spray Pond Pump House / Spray NetworkOR2. a. Receipt of a single fire alarm in ANY Table H2 area (i.e., no otherindications of a FIRE).ANDb. The existence of a FIRE is not verified in< 30 minutes of alarm receipt.OR3 A FIRE within the plant PROTECTED AREA not extinguished in < 60-minutes of the initial report, alarm or indication.OR4 A FIRE within the plant PROTECTED AREA that requires firefightingsupport by an offsite fire response agency to extinguish.Page 58 of 66 NEI 99-01 Rev 6 j Proposed EAL I JustificationHU2HU4Initiating Condition: UNUSUAL EVENTSeismic event greater than OBE levels.Operating Mode Applicability:Initiating Condition:Seismic event greater than OBE levels.Operating Mode Applicability:1, 2,3, 4, 5, DF' No Change F Difference FIDeviation1) Provided site specific indications to aid in timely classification.AllExample Emergency Action Levels:Seismic event greater than Operating Basis Earthquake (OBE) as indicated by:a. (site-specific indication that a seismic event met or exceeded OBE limits)Emergency Action Level (EAL):Seismic event > Operating Basis Earthquake (OBE) as indicated by:" ARC-MCR-00C693, WINDOW B1, OBE EXCEEDED alarmedOR" OBE red light is lit at panel 00C693Page 59 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationHASInitiating Condition: ALERTGaseous release impeding access to equipment necessary for normal plantoperations, cooldown or shutdown.Operating Mode Applicability:AllExample Emergency Action Levels:Note: If the equipment in the listed room or area was already inoperable, or out ofservice, before the event occurred, then no emergency classification iswarranted.1 .a. Release of a toxic, corrosive, asphyxiant or flammable gas into any ofthe following plant rooms or areas:(site-specific list of plant rooms or areas with entry-related modeapplicability identified)ANDb. Entry into the room or area is prohibited or impeded.HASInitiating Condition:Gaseous release impeding access to equipment necessary for normal plantoperations, cooldown or shutdown.Operating Mode Applicability:1, 2, 3,4, 5, DEmergency Action Level (EAL):Note:If the equipment in the listed room or area was already inoperable, or out ofservice, before the event occurred, then no emergency classification is warranted.1. Release of a toxic, corrosive, asphyxiant or flammable gas in a Table H3 area.Table H3Areas with Entry Related Mode ApplicabilityArea Entry Related Mode ApplicabilityReactor Enclosure* Modes 3, 4, and 5*Areas required to establish shutdown coolingAND2. Entry into the room or area is prohibited or impededH No Change FIDifference FIDeviation1) Listed plant specific rooms and areas with entry related mode applicability toensure timely classification.Page 60 of 66 NEI 99-01 Rev 6 1 Proposed EAL JustificationHU3HU6Initiating Condition: UNUSUAL EVENTHazardous EventInitiating Condition:M No Change F Difference F Deviation1) No site specific list of natural or technological hazard events was noted.Operating Mode Applicability:AllExample Emergency Action Levels: (1 or 2 or 3 or 4)Note: EAL #4 does not apply to routine traffic impediments such as fog, snow,ice, or vehicle breakdowns or accidents.1. A tornado strike within the PROTECTED AREA.2. Internal room or area flooding of a magnitude sufficient to require manualor automatic electrical isolation of a SAFETY SYSTEM component neededfor the current operating mode.3. Movement of personnel within the PROTECTED AREA is impeded due toan offsite event involving hazardous materials (e.g., an offsite chemicalspill or toxic gas release).4. A hazardous event that results in on-site conditions sufficient to prohibitthe plant staff from accessing the site via personal vehicles.5. (Site-specific list of natural or technological hazard events)Hazardous EventOperating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Note:EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, orvehicle breakdowns or accidents.1. Tornado strike within the PROTECTED AREA.OR2. Internal room or area flooding of a magnitude sufficient to require manual orautomatic electrical isolation of a SAFETY SYSTEM component required byTechnical Specifications for the current operating mode.OR3. Movement of personnel within the PROTECTED AREA is impeded due to anoffsite event involving hazardous materials (e.g., an offsite chemical spill ortoxic gas release).OR4. A hazardous event that results in on-site conditions sufficient to prohibit theplant staff from accessing the site via personal vehicles.Page 61 of 66 NEI 99-01 Rev 6 Proposed EAL I JustificationHG7HG7M No Change I Difference FIDeviationInitiating Condition: GENERAL EMERGENCYOther conditions exist which in the judgment of the Emergency Director warrantdeclaration of a General Emergency.Operating Mode Applicability:AllExample Emergency Action Levels:Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve actual or IMMINENTsubstantial core degradation or melting with potential for loss of containmentintegrity or HOSTILE ACTION that results in an actual loss of physical control ofthe facility. Releases can be reasonably expected to exceed EPA Protective ActionGuideline exposure levels off-site for more than the immediate site area.Initiating Condition:Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a General Emergency.Operating Mode Applicability:1, 2, 3, 4. 5, DEmergency Action Level (EAL):Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve actual or IMMINENTsubstantial core degradation or melting with potential for loss of containmentintegrity or HOSTILE ACTION that results in an actual loss of physical control ofthe facility. Releases can be reasonably expected to exceed EPA ProtectiveAction Guideline exposure levels off-site for more than the immediate site area..Page 62 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationInitiating Condition: SITE AREA EMERGENCY Initiating Condition: LSi No Change [j Difference [j DeviationOther conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a Site Area Emergency. declaration of a Site Area Emergency.Operating Mode Applicability: Operating Mode Applicability:All 1,2, 3,4, 5, DExample Emergency Action Levels: Emergency Action Level (EAL):Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve actual or likely mao Other conditions exist which in the judgment of the Emergency Director indicatel y major that events are in progress or have occurred which involve actual or likely majorfailures of plant functions needed for protection of the public or HOSTILE ACTION failures of plant functions needed for protection of the public or HOSTILE ACTIONthat results in intentional damage or malicious acts; (1) toward site personnel or that results in intentional damage or malicious acts; (1) toward site personnel orequipment that could lead to the likely failure of or; (2) that prevent effective equipment that could lead to the likely failure of or; (2) that prevent effectiveaccess to equipment needed for the protection of the public. Any releases are notexpected to result in exposure levels which exceed EPA Protective Action access to equipment needed for the protection of the public. Any releases are notGuiexp netedtoresultn exposure levels wthextebudEPaPr oexpected to result in exposure levels which exceed EPA Protective ActionGuideline exposure levels beyond the site boundary. Guideline exposure levels beyond the site boundary.Page 63 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationHA7 HA7Initiating Condition: ALERT Initiating Condition: L-M No Change F Difference 1 DeviationOther conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an Alert. declaration of an Alert.Operating Mode Applicability: Operating Mode Applicability:All 1, 2, 3,4, 5, DExample Emergency Action Levels: Emergency Action Level (EAL):Other conditions exist which in the judgment of the Emergency Director indicate Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve an actual or potentialsubstantial degradation of the level of safety of the plant or a security event that that events are in progress or have occurred which involve an actual or potentialinvolves probable life threatening risk to site personnel or damage to site substantial degradation of the level of safety of the plant or a security event thatequipment because of HOSTILE ACTION. Any releases are expected to be involves probable life threatening risk to site personnel or damage to sitelimited to small fractions of the EPA Protective Action Guideline exposure levels, equipment because of HOSTILE ACTION. Any releases are expected to belimited to small fractions of the EPA Protective Action Guideline exposure levels.Page 64 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationHU7 HU7Initiating Condition: UNUSUAL EVENT Initiating Condition: L-i No Change U Difference [j DeviationOther conditions existing which in the judgment of the Emergency director warrantdeclaration of an UNUSUAL EVENT. Other conditions existing which in the judgment of the Emergency director warrantdeclaration of an UNUSUAL EVENT.Operating Mode Applicability:Operating Mode Applicability:All1, 2, 3, 4, 5, DExample Emergency Action Levels: Emergency Action Level (EAL):Other conditions exist which in the judgment of the Emergency Director indicate Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which indicate a potential that events are in progress or have occurred which indicate a potentialdegradation of the level of safety of the plant or indicate a security threat to facility degradation of the level of safety of the plant or indicate a security threat to facilityprotection has been initiated. No releases of radioactive material requiring offsite protection has been initiated. No releases of radioactive material requiring offsiteresponse or monitoring are expected unless further degradation of safety systems response or monitoring are expected unless further degradation of safety systemsoccurs. occurs.Page 65 of 66 NEI 99-01 Rev 6 Proposed EAL JustificationE-HUI E-HUIInitiating Condition: UNUSUAL EVENT Initiating Condition: Li No Change M Difference F DeviationDamage to a loaded cask CONFINEMENT BOUNDARY.Damage to a loaded cask.CONFINEMENT BOUNDARY. 1) Listed 2x the site specific cask specific allowable radiation level as per LimerickGenerating Station ISFS1 1OCFR72.212 Evaluation Rev 6 Attachment 1 certificateOperating Mods Applicability: Operating Mode Applicability: of Compliance evaluation.All 2) Not all technical specification radiation readings were on contact, one is a1, 2, 3, 4, 5, D radiation reading at 3ft required by technical specification. Modified the EAL byremoving the "on the surface" requirement, and required "a radiation reading"Example Emergency Action Levels: allowing for the technical specification 3ft reading to be added to the EAL.Emergency Action Level (EAL):Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than (2 times the site-specific cask specific Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by atechnical specification allowable radiation level) on the surface of the spent fuel radiation reading:cask.* > 1400 mremlhr on the HSM or HSM-H front surface (applicable to type 161BTH DSC only)OR* > 800 mrem/hr at 3 ft from the HSM surface (applicable to 61 BT DSConly)OR* > 200 mremlhr on the HSM or HSM-H door centerlineOR* > 40 mremlhr on the end shield wall exteriorPage 66 of 66 Limerick Generatina Station AnnexExelon NuclearL..m.ri.k.Ge.eratina Statio.AnnexE....nNucle.RECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSARGIInitiating Condition:Release of gaseous radioactivity resulting in offsite dose greater than 1000 mRfem TEDEor 5000 mRfem thyroid CDE.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the General m=F.ergenGy event promptly upon Idetermining that the applicable time has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to theenvironment is established. If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment usingactual meteorology are available.(1) Reading o,; 'n ANY o-f t.he following radiation monitorS greater thaR the reading shownfr15- minute or loner:(site specific monitor list and threshold values)1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15 minutes:Table R1 Effluent Monitor ThresholdsRelease Path General EmergencyNorth Stack (WR Monitor: RIX-26-076-4) 1.92 E+08 uCi/secSouth Stack (Unit 1: RY26-185A-3 / 2.71 E-01 uCi/secRY26-185-B-3 or Unit 2: RY26-285A-3 /RY26-285-B-3)OR2. Dose assessment using actual meteorology indicates doses at or beyond (site-speGifirdc.e rFecoptr point) the site boundary of EITHER:Month 20XXLGS 3-1EP-AA-1008 (Revision XX)

I .imnri,.k (' Znghreafnr -Q*~m;len A nnnvI::v, Inn , ir-l,-arbulllt~i111 1 -V III If I;II ll b4Ul l l*~q u lRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSa. > 1000 mRem TEDEORb. > 5000 mRem CDE ThyroidORr-1810 SUrFe'; reSURS naicate ' .., ,,v, ,, n oWIng a! or DeYA ,cl. e v p,,... Cdose roceptor point):ýL_ --A ^^^ -#-% It--A _J L L!_ z160 minu-tes- or longer.vu~~vv -ww l V. 1A v i v u .~ v l v v v V l~ .* tHCn1nbW_1 _. MMl NU -VV3 tlV tF- 9106 tf tHC*HV l i de l V t nld H I nfor one hou r of inhalation.3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >1000 mR/hr are expected to continuefor > 60 minutes.ORb. Analyses of field survey samples indicate > 5000 mRem CDE Thyroid for60 minutes of inhalation.Basis:This IC addresses a release of gaseous radioactivity that results in projected or actualoffsite doses greater than or equal to the EPA Protective Action Guides (PAGs). Itincludes both monitored and un-monitored releases. Releases of this magnitude willrequire implementation of protective actions for the public.Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.The TEDE dose is set at the EPA PAG of 1000 mRrem while the 5000 mRfem thyroidCDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE andthyroid CDE.Classification based on efflent maontor readings assumes~ that a releanre path to thenirnent is established. if the effluent flow past an effluent monGitor is known to hav,stopped due to- a-c-tions to ilate the release path, th;n the monitor rAFeadn is no.nAer Valid for cl.assific.ation Du ses.Month 20XXLGS 3-2EP-AA-1008 (Revision XX)

I imarirnk r-anarnting Rt~ation Annex Exellon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSBasis Reference(s):1. NEI 99-01 Rev 6, AG12. LGS ODCM3. EP-EAL-0608 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Limerick Generating Station4. DBD L-S-43, Radiation Monitoring SystemMonth 20XXLGS 3-3EP-AA-1008 (Revision XX)

I im rele9n nofn Q nin n nP:v--Itnn Ik .l-A nrI r~-L tna~* nn~f*nnAn~v... .n .a.se t..r ...,..*.~.RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSARS1Initiating Condition:Release of gaseous radioactivity resulting in offsite dose greater than 100 mRfem TEDEor 500 mRfem thyroid CDE.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the v.it.oArAea event promptlyupon determining that the applicable time has been exceeded, or will likely beexceeded.* If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to theenvironment is established. If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment usingactual meteorology are available.(1) Reading on ANY of the foelowing Fadiation mo~nitors greater than the_ reading shownfo-r 1 5 minlute Or logqer:(Site Specific_ mo-nitor list and threshold ':alue6)(2) Dorse assessment using ac-tual meteorology indicates doses greater than 100QmreAm TEE r, O1500 mr;em; thyroid CDE At Or beyond (site specific dose recepto(3) Field suivey results- iniaeETHEROf the9 folloIwing at Or beyond (Site specificdose rcpOR O;n~" Closed v.'ndow dose rates greater- than 100 mR'hr expected to continufe for- 60 mainuteser- lnger-" Analyses of field survey samples indicate thyroeid CDE greater- than 500 ffrem for- oneh10ur Of ifihala~tio.Month 20XXLGS 3-4EP-AA-1008 (Revision XX)

Ii m rie- ( Zanghaf5inn -Q*a*rnn Anna-wI::y,-I~n RECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15 minutes:Table RI Effluent Monitor ThresholdsRelease Path Site Area EmergencyNorth Stack (WR Monitor: RIX-26-076-4) 1.92 E+07 uCi/secSouth Stack (Unit 1: RY26-185A-3 / 2.71 E-02 uCi/secRY26-185-B-3 or Unit 2: RY26-285A-3 /RY26-285-B-3)OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 100 mRem TEDEORb. > 500 mRem CDE ThyroidOR3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >100 mR/hr are expected to continuefor > 60 minutes.ORb. Analyses of field survey samples indicate > 500 mRem CDE Thyroid for 60minutes of inhalation.Basis:This IC addresses a release of gaseous radioactivity that results in projected or actualoffsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs).It includes both monitored and un-monitored releases. Releases of this magnitude areassociated with the failure of plant systems needed for the protection of the public.Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsMonth 20XXLGS 3-5EP-AA-1008 (Revision XX)

I irngri#-L- f'-gsnghrimfin Qfmfirn AnnghvI::valnn ld, I iy~r.., ~~i~~*hi, Annv vannM~,.azRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSmore fully addresses the spectrum of possible accident events and conditions.The TEDE dose is set at 10% of the EPA PAG of 1000 mRfem while the 500 mRfemthyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDEand thyroid CDE.Classification bassed On fM'unt mnitor rFeadines assumes that a release oath tothe eny.;irnment. ;i. eabise. If th.. flo.., past an effluent monQ.itor is knoWn tohavestoped due to actions, to isolate the release path, then the effluent monitor readinis no loner valid for. classific-atio pupoesEscalation of the emergency classification level would be via IC RAG1.Basis Reference(s):1. NEI 99-01 Rev 6, AS12. LGS ODCM3. EP-EAL-0608 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Limerick Generating Station4. DBD L-S-43, Radiation Monitoring SystemMonth 20XXLGS 3-6EP-AA-1008 (Revision XX)

Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSARAIInitiating Condition:Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mRremTEDE or 50 mRr-em thyroid CDE.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the Afe44-vent promptly upon determiningthat the applicable time has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to theenvironment is established. If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment usingactual meteorology are available.for: 1 5 minlutes Or longer:(site Specific monitor list and threshold values)(2) Dose assessment using actual mneteorology indicaters dosos6 greater than 10 QmneroTEDE Or 50 mrcrn thyroid OIDE at Or beyond (Site specific dose Freeptor point).(3) Analysis of a liquid effluen;t " amp. e iRdicates- a on-entration Or release rate thatwould result ir doses, greateF than 10 FFFm TEDE Or 50 mnenm thyroid ODE atorbeyond (site specific dose Freeptor point) for one hour Of exposure(4) Field survey Fresults indicate EITHER of the follew.ing at Or beyond (site specificdose... re..,eptor., " Closed vindo dose rates greater- than 10 mR:, expe.ted to continue for 60 minutes or-" Analyses of field sun.'ey samples indicate thyroid CDE greater- than 50 mremn for- oemhourL of inhalation.Month 20XXLGS 3-7EP-AA-1008 (Revision XX)

ExAIon NuclearLimeric~k Generatina Station Annex Exelnn Nuclea~rRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS1. Readings on ANY Table R1 Effluent Monitor > Table RI value for > 15 minutes.Table R1 Effluent Monitor ThresholdsRelease Path AlertNorth Stack (WR Monitor: RIX-26-076-4) 1.92 E+06 uCi/secSouth Stack (Unit 1: RY26-185A-3 / 2.71 E-03 uCi/secRY26-185-B-3 or Unit 2: RY26-285A-3 /RY26-285-B-3)OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 10 mRem TEDEORb. > 50 mRem CDE ThyroidOR3. Analysis of a liquid effluent sample indicates a concentration or release rate thatwould result in doses greater than EITHER of the following at or beyond the siteboundary:a. 10 mRem TEDE for 60 minutes of exposureORb. 50 mRem CDE Thyroid for 60 minutes of exposureOR4. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates > 10 mR/hr are expected tocontinue for > 60 minutes.ORMonth 20XXLGS 3-8EP-AA-1008 (Revision XX)

I imarink fllanamfinn Atntinn AnnaXIExelon NuclearI imrirk (~arninn tatnn An~vExelon Nucla~rRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSb. Analyses of field survey samples indicate > 50 mRem CDEThyroid for 60 minutes of inhalation.Basis:This IC addresses a release of gaseous or liquid radioactivity that results in projected oractual offsite doses greater than or equal to 1% of the EPA Protective Action Guides(PAGs). It includes both monitored and un-monitored releases. Releases of thismagnitude represent an actual or potential substantial degradation of the level of safety ofthe plant as indicated by a radiological release that significantly exceeds regulatory limits(e.g., a significant uncontrolled release).Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.The TEDE dose is set at 1% of the EPA PAG of 1000 mRfem while the 50 mRrem thyroidCDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE andthyroid CDE.Classificaation b-ased- On e-fflue'n t Mon-itor readings assumes. that. a rele9ase path toDthe enVironment is established. if the effluent flow past- an effluent moenitor is known tohave stopped due to actions to iotethe release path, then the effluent moenitor readingisr no longer valid for classificatio pupse-.Escalation of the emergency classification level would be via IC RAS1.Basis Reference(s):1. NEI 99-01 Rev 6, AA12. LGS ODCM3. EP-EAL-0608 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Limerick Generating Station4. L-S-43 Radiation Monitoring System5. ARC-BOP-0AC304 C1 Liquid Radwaste Discharge Rad Monitor Hi Hi6. ARC-MCR-003 El North Stack Hi-Hi Radiation7. ARC-MCR-003 F1 Units 1&2 South Stack Hi-Hi Radiation8. EP-EAL-0615 Revision 0, Limerick Criteria for Choosing Radiological LiquidEffluent EAL Threshold ValuesMonth 20XXLGS 3-9EP-AA-1008 (Revision XX)

I imprink rionarating Station AnnayEXPInn Nuclea~rI im~riv~k (~Anar2tinn ~hatinn Ann~v FvAInn N.ir~Ia~arRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSARUIInitiating Condition:Release of gaseous or liquid radioactivity greater than 2 times the ODCM (site-sperafteffluent .,leae controlling document) limits for 60 minutes or longer.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the Unusual Event event promptly upondetermining that 60 applicable time has been exceeded, or will likely beexceeded." If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 60 minutes." Classification based on effluent monitor readings assumes that a release path to theenvironment is established. If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes.(1) Reading on ANY effluent radiation monitor greater than 2 times the (site specificeffluent release controlling document) limits for 60 lmin utes orlong:(site specific- mo-nitor list and- threshold valuer- corresponding to 2 times thecon~trolling document limits)(2) Reading onI ANY e-fflue-Ant- radi-ation moni~tor greater than 2 times the alaFrm Setponeta-blise a urn rad-ieactivit' discharge peFrmit for 60 minRutes Or Ienger.(3) Sample analysis for a gaseous Or liquid release indicates a concentration orrelease ratle greater than 2 times the (site specific. effluent release centrol~ingdocum~ent) limits6 for 690 Mminutes6 Or longer.1. Reading on ANY of the following effluent monitors > 2 times alarm setpointestablished by a current radioactive release discharge permit for > 60 minutes." Radwaste Discharge Effluent Monitor (RR63-0R001)OR" Discharge Permit specified monitorORMonth 20XXLGS 3-10EP-AA-1008 (Revision XX)

IFvplnn I imgprirk Ganar~afing Stgation AnnexFA~nNIdmRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS2. Readings on ANY Table R1 Effluent Monitor > Table RI value for > 60 minutes:Table R1 Effluent Monitor Thresholds 1Release Path Unusual EventNorth Stack (WR Monitor: RIX-26-076-4) 2.20 E+04 uCi/secSouth Stack (Unit 1: RY26-185A-3 / 3.09 E-05 uCi/secRY26-185-B-3 or Unit 2: RY26-285A-3 /RY26-285-B-3)OR3. Confirmed sample analyses for gaseous or liquid releases indicate concentrationsor release rates > 2 times ODCM Limit with a release duration of > 60 minutes.Basis:This IC addresses a potential decrease in the level of safety of the plant as indicated by alow-level radiological release that exceeds regulatory commitments for an extendedperiod of time (e.g., an uncontrolled release). It includes any gaseous or liquidradiological release, monitored or un-monitored, including those for which a radioactivitydischarge permit is normally prepared.Nuclear power plants incorporate design features intended to control the release ofradioactive effluents to the environment. Further, there are administrative controlsestablished to prevent unintentional releases, and to control and monitor intentionalreleases. The occurrence of an extended, uncontrolled radioactive release to theenvironment is indicative of degradation in these features and/or controls.Radiological effluent EALs are also included to provide a basis for classifying events andconditions that cannot be readily or appropriately classified on the basis of plantconditions alone. The inclusion of both plant condition and radiological effluent EALsmore fully addresses the spectrum of possible accident events and conditions.Classification base-d on effluent Monitor reandings assumes that. a release pathtthe enVironment is established. If the effluent floW past An effluet monitor is knownhave stopped duo to actions to isolate the release path, theni the effluent moneitor Feadingi s no longer valid for classificatiopuos.Releases should not be prorated or averaged. For example, a release exceeding 4 timesrelease limits for 30 minutes does not meet the EAL.EAL #1 Basis:EAL #2 1 This EAL addresses radioactivity releases that cause effluent radiation monitorreadings to exceed 2 times the limit established by a radioactivity discharge permit. ThisMonth 20XXLGS 3-11EP-AA-1008 (Revision XX)

Limerick Generatinq Station AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSEAL will typically be associated with planned batch releases from non-continuous releasepathways (e.g., radwaste, waste gas).The effluent monitors listed are those normally used for planned discharges. If adischarge is performed using a different flowpath or effluent monitor other than thoselisted (e.g., a portable or temporary effluent monitor), then the declaration criteria will bebased on the monitor specified in the Discharge Permit.EAL #2 Basis:&AL-#1-I-This EAL addresses normally occurring continuous radioactivity releases frommonitored gaseous OFIli id-effluent pathways.EAL #3 Basis:EA&-# ---This EAL addresses uncontrolled gaseous or liquid releases that are detectedby sample analyses or environmental surveys, particularly on unmonitored pathways(e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river watersystems, etc.).Escalation of the emergency classification level would be via IC RAA1.Basis Reference(s):1. NEI 99-01 Rev 6, AU12. LGS ODCM3. EP-EAL-0608 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Limerick Generating Station4. L-S-43 Radiation Monitoring System5. ARC-BOP-0AC304 Cl Liquid Radwaste Discharge Rad Monitor Hi Hi6. ARC-MCR-109 A2 1 Service Water Rad Monitor Hi-Hi7. ARC-MCR-01 1 C-4 RHRSW Rad Monitor Hi-Hi8. ARC-MCR-003 El North Stack Hi-Hi Radiation9. ARC-MCR-003 F1 Units 1&2 South Stack HI-Hi RadiationMonth 20XXLGS 3-12EP-AA-1008 (Revision XX)

Limerick Generatinn Station Annex Exeoln NucleI~arRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSARA2Initiating Condition:Significant lowering of water level above, or damage to, irradiated fuel.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):(1) Uncover; Of -rradiated fuel in the REFUELING PATH\AIAY.(2) Damage to ir.adiatod fuel reSUlting in a f radioactivity from the fuel asindicated by ANY Of the followA~ing radiation mon9itors:(site specific listing of radiation monitors, and the associated readings,setpoints and/or alarms)(3) Lowering of spcnt fuel pool level to (site spec-ific. Level1 2 Value). [See DeveIýGF1. Uncovery of irradiated fuel in the REFUELING PATHWAY.OR2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel asindicated by ANY Table R2 Radiation Monitor reading >1000 mRemlhrTable R2Refuel Floor ARM's* RIS29-M1-1(2)K600, Drywell Head Laydown" RIS30-Ml-1(2)K600, Dryer / Separator Area" RIS31-M1-1(2)K600, Spent Fuel Pool" RIS32-Ml-1(2)K600, New Fuel storage Vault" RIS33-Ml-1(2)K600, Pool Plug LaydownMonth 20XXLGS 3-13EP-AA-1008 (Revision XX)

I=xelon N.dearLimeric~k Generatinn Station Annex Exelon Nucla~rRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSBasis:REFUELING PATHWAY: all the cavities, tubes, canals and pools through whichirradiated fuel may be moved or stored, but not including the reactor vessel below theflange.IMMINENT: The trajectory of events or conditions is such that an EAL will be met within arelatively short period of time regardless of mitigation or corrective actions.CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask barrier(s) betweenareas containing radioactive substances and the environment.This IC addresses events that have caused IMMINENT or actual damage to an irradiatedfuel assembly., o. a ,igifant of w.ater le...l .,,ithi, th. spent fU.l p99l (,Se.eveloe " 'tes). These events present radiological safety challenges to plantpersonnel and are precursors to a release of radioactivity to the environment. As such,they represent an actual or potential substantial degradation of the level of safety of theplant.This IC applies to irradiated fuel that is licensed for dry storage up to the point that theloaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss ofthe CONFINEMENT BOUNDARY is classified in accordance with IC E-HU1.Escalation of the emergency would be based on either Recognition Category AR or CICs.EAL #1 Basis:This EAL escalates from RAU2 in that the loss of level, in the affected portion of theREFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery ofirradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visualobservation (e.g., reports from personnel or camera images), as well as significantchanges in water and radiation levels, or other plant parameters. Computational aidsmay also be used (e.g., a boil-off curve). Classification of an event using this EAL shouldbe based on the totality of available indications, reports and observations.While an area radiation monitor could detect an iGF-easerise in a dose rate due to alowering of water level in some portion of the REFUELING PATHWAY, the reading maynot be a reliable indication of whether or not the fuel is actually uncovered. To the degreepossible, readings should be considered in combination with other available indications ofinventory loss.A drop in water level above irradiated fuel within the reactor vessel may be classified inaccordance Recognition Category C during the Cold Shutdown and Refueling modes.Month 20XXLGS 3-14EP-AA-1008 (Revision XX)

I imariunk r~anarnfinni At~tinn AnnoyFvalnn Nin~ilcanrRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSEAL #2 Basis:This EAL addresses a release of radioactive material caused by mechanical damage toirradiated fuel. Damaging events may include the dropping, bumping or binding of anassembly, or dropping a heavy load onto an assembly. A rise in readings on radiationmonitors should be considered in conjunction with in-plant reports or observations of apotential fuel damaging event (e.g., a fuel handling accident).Escalation of the emergency would be based on either Recognition Category RA-or CICs.r-AI= .#/Spent fuel pool water IlVel at vValu IVV W ithi thI loWer end of the level rangeneressary to prevet Signifcant dseo c q s- from direct gamma radiation topersonnel performing oprations in the Vicinity Of the Spent fuel pool. ThiA cndiErefle loss of spent fuel p oolwater, inventeor; and thus it is , a to a loss of the ability to adequately GOOl the_ irradiatcAd- fuel A-1ssrem.bles storFed in the polEscalationA of the Femqergeny cl9assification levelI Would be via I~rc As! Or AS2 (seeASDevelop- Notes).Basis Reference(s):1. NEI 99-01 Rev 6, AA22. ON-120 Fuel Handling Problems3. DBD L-S-43, Radiation Monitoring System4. ARC MCR 112-15 Fuel Pool Storage Hi/Lo Level5. DBD L-S-16, Reactor Instrumentation System (RIS)6. DBD L-S-52, Fuel Pool Cooling and Cleanup SystemMonth 20XXLGS 3-15EP-AA-1008 (Revision XX)

I imimri&-I, fI-anPA*;fhin Qa*o;i#n A uimivI:,=dlrn khig-l-nrI..IIUIU~r~~EU E IIh~4~~ E E 1II ~* flU~U*as ~ ~RECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSARU2Initiating Condition:UNPLANNED loss of water level above irradiated fuel.Operating Mode Applicability:1, 2, 3,4, 5, DEmergency Action Level (EAL):(1) a. UNPLANNED water leve el dr OpR the REFUELING PATHWAY as indicatedby ANY of the followwin:(site specifc level indications).b. UNPLANNED rise iea radiation leovel as indicated by ANY of thefooin-14AAg radiation monitors.(site specific list of area radi-ation moenitors)1 .UNPLANNED water level drop in the REFUELING PATHWAY as indicated byANY of the following:" Refueling Cavity water level < 484 inches.OR" Spent Fuel Pool level < 23 feet above seated irradiated fuel.OR* Indication or report of a drop in water level in the REFUELINGPATHWAY.AND2. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors inTable R2.Month 20XXLGS 3-16EP-AA-1008 (Revision XX)

ExAIon Simeric~k Goneartinn Station Annex Exelnn NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSTable R2Refuel Floor ARM's* RIS29-M1-1(2)K600, Drywell Head Laydown" RIS30-Ml-1(2)K600, Dryer / Separator Area* RIS31-M1-1(2)K600, Spent Fuel Pool" RIS32-M1-1(2)K600, New Fuel storage Vault* RIS33-M1-1(2)K600, Pool Plug LaydownBasis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.REFUELING PATHWAY: all the cavities, tubes, canals and pools through whichirradiated fuel may be moved or stored, but not including the reactor vessel below theflange.This IC addresses a dereaseeloss in water level above irradiated fuel sufficient to causeelevated radiation levels. This condition could be a precursor to a more serious eventand is also indicative of a minor loss in the ability to control radiation levels within theplant. It is therefore a potential degradation in the level of safety of the plant.A water level deGrease loss will be primarily determined by indications from available levelinstrumentation. Other sources of level indications may include reports from plantpersonnel (e.g., from a refueling crew) or video camera observations (if available) or fromany other temporarily installed monitoring instrumentation. A significant drop in the waterlevel may also cause a; inAeaserise in the radiation levels of adjacent areas that can bedetected by monitors in those locations.The effects of planned evolutions should be considered. For example, a refueling bridgearea radiation monitor reading may *iR-easerise due to planned evolutions such as liftingof the reactor vessel head or movement of a fuel assembly. Note that this EAL isapplicable only in cases where the elevated reading is due to an UNPLANNED loss ofwater level.A drop in water level above irradiated fuel within the reactor vessel may be classified inaccordance Recognition Category C during the Cold Shutdown and Refueling modes.Escalation of the emergency classification level would be via IC RAA2.Basis Reference(s):Month 20XXLGS 3-17EP-AA-1008 (Revision XX)

I imnrir-L, ('2nnewnfin Qfnfien AnngvIygilen Mm-rlonrI ;~~n~sL (~n~r~1* int $$rn n vFv n mr~a.n .. ... tt***5 *1-. U .RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS1. NEI 99-01 Rev 6, AU22. Technical Specifications 3.9.83. ON-120 Fuel Handling Problems4. DBD L-S-16, Reactor Instrumentation System (RIS)5. DBD L-S-52, Fuel Pool Cooling and Cleanup System6. ARC MCR 112-15 Fuel Pool Storage Hi/Lo Level7. GP-6.1 U/1(2) Shutdown Operations -Refuel Core Alterations & Core Off-loadingMonth 20XXLGS 3-18EP-AA-1008 (Revision XX)

I imprink rpnarafinn Afafinn AnnoyI=xAInn N.nlAarI imrir~ (~n~rzainn tsa~nn An~vExelnn NucledarRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSARA3Initiating Condition:Radiation levels that impede access to equipment necessary for normal plant operations,cooldown or shutdown.Operating Mode Applicability:1, 2, 3, 4, 5, DEmergency Action Level (EAL):Note: If the equipment in the listed-room or area listed in Table R4 -was alreadyinoperable, or out of service, before the event occurred, then no emergencyclassification is warranted(1) Dose rate greater than 15 mR/hr in ANY of the following areas:b*Centre l -o M nonoR* Central Alarm Station-(ysuvyOR pecific afeas/roomn)(2) An UNPLANNED ev:ent results in radiation levels that prohibit Or impe-de accr-ess oany of the following plant rooms or areas:.(site specific list of plant rooms or areas with cntr,' related moede appliabilitylidentfed)1. Dose rate gFeatefkhaf1> 15 mRlhr in ANY of the areas contained in Table R3:Table R3Areas Requiring Continuous Occupancy" Main Control Room" Central Alarm Station -(by survey)ORMonth 20XXLGS 3-19EP-AA-1008 (Revision XX)

Limerick Generating Station AnnexI=xelon Exelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS2. UNPLANNED event results in radiation levels that prohibit or significantly impedeaccess to ANY of the areas contained in Table R4:Table R4Areas with Entry Related Mode ApplicabilityArea Entry Related ModeApplicabilityReactor Enclosure* Modes 3, 4, and 5*Area required to establish shutdown coolingBasis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.This IC addresses elevated radiation levels in certain plant rooms/areas sufficient topreclude or impede personnel from performing actions necessary to transition the plantfrom normal plant operation to cooldown and shutdown as specified in normal plantproceduresmaintain normal plant operation, Or to a normal plant ansh'-tdew'-. As such, it represents an actual or potential substantial degradation of thelevel of safety of the plant. The Emergency Director should consider the cause of theincreased radiation levels and determine if another IC may be applicable.Table R4 is a list of plant rooms or areas with entry-related mode applicability that containequipment which require a manual/local action necessary to transition the plant fromnormal plant operation to cooldown and shutdown as specified in normal operatingprocedures (establish shutdown cooling), where if this action is not completed the plantwould not be able to attain and maintain cold shutdown.This Table does not include rooms or areas for which entry is required solely to performactions of an administrative or record keeping nature (e.g., normal rounds or routineinspections).Rooms and areas listed in EAL #1 do not need to be included in EAL #2, including theControl Room.For EAL #2, an Alert declaration is warranted if entry into the affected room/area is, ormay be, procedurally required during the plant operating mode in effect and the elevatedradiation levels preclude the ability to place shutdown cooling in serviccat the time of theelevated radiation The emergency classification is not contingent upon whetherentry is actually necessary at the time of the increased radiation levels. Access should beconsidered as impeded if extraordinary measures are necessary to facilitate entry ofMonth 20XXLGS 3-20EP-AA-1008 (Revision XX)

Limerick Generating Station AnnexI=xelon NuclearExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTSpersonnel into the affected room/area (e.g., installing temporary shielding beyond thatrequired by procedures, requiring use of non-routine protective equipment, requesting anextension in dose limits beyond normal administrative limits).An emergency declaration is not warranted if any of the following conditions apply." The plant is in an operating mode different than the mode specified for the affectedroom/area (i.e., entry is not required during the operating mode in effect at the time ofthe elevated radiation levels). For example, the plant is in Mode 1 when the radiationie rise occurs, and the procedures used for normal operation, cooldown andshutdown do not require entry into the affected room until Mode 4." The increased radiation levels are a result of a planned activity that includescompensatory measures which address the temporary inaccessibility of a room orarea (e.g., radiography, spent filter or resin transfer, etc.)." The action for which room/area entry is required is of an administrative or recordkeeping nature (e.g., normal rounds or routine inspections)." The access control measures are of a conservative or precautionary nature, andwould not actually prevent or impede a required action.Escalation of the emergency classification level would be via Recognition Category RA, Cor F ICs.Basis Reference(s):1. NEI 99-01 Rev 6, AA32. UFSAR Table 7.7-2, Locations for Area Radiation Monitor Sensors3. SE-1 Remote Shutdown4. SE-6 Alternate Remote Shutdown5. SE-8 Fire6. DBD L-S-43, Radiation Monitoring SystemMonth 20XXLISS 3-21EP-AA-1008 (Revision XX)

Limerick Generatina Station AnnexExelon NuclearLimerick .en .ra..n Station... Annex.........n.Nuc..e..RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTSSRU3Initiating Condition:Reactor coolant activity greater than Technical Specification allowable limits.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):(1) (Site specifc radiation monitor) reading greater than (site 6pecific ':alue).7(2) Sample analysis indicates that a reactor coolant activity value i6 greater than anallo~Wabeiit speciflod- in Tec-hnical Specifications.1. Air Ejector discharge radiation monitor (RISH 26 1(2)K601A, B) Hi-Hi alarm.OR2. Specific coolant activity > 4.0 uCllgm Dose equivalent 1-131.Basis:This IC addresses a reactor coolant activity value that exceeds an allowable limitspecified in Technical Specifications. This condition is a precursor to a more significantevent and represents a potential degradation of the level of safety of the plant.Conditions that cause the specified monitor to alarm that are not related to fuel claddegradation should not result in the declaration of an Unusual Event.This EAL addresses site-specific radiation monitor readings that provide indication of adegradation of fuel clad integrity.An Unusual Event is only warranted when actual fuel clad damage is the cause of theelevated coolant sample activity (as determined by laboratory confirmation). Fuel claddamage should be assumed to be the cause of elevated Reactor Coolant activity unlessanother cause is known.Escalation of the emergency classification level would be via ICs FA1 or the RecognitionCategory RA ICs.Basis Reference(s):1. NEI 99-01 Rev 6, SU32. Technical Specifications 3.4.5, Specific Activity3. Technical Specifications 3.4.5, Basis4. UFSAR Table 11.5-1, Process and Effluent Radiation Monitoring Systems5. DBD L-S-43, Radiation Monitoring System6. ARC MCR 109-G1, Air Ejector Offgas Discharge HI-HI RadiationMonth 20XXLGS 3-22EP-AA-1008 (Revision XX)

Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFG1Initiating Condition:Loss of ANY Two Barriers AND Loss or Potential Loss of the third barrier.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determinebarrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.At the General Emergency classification level each barrier is weighted equally.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXLGS 3-23EP-AA-1008 (Revision XX)

Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFS1Initiating Condition:Loss or Potential Loss of ANY two barriers.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determinebarrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.At the Site Area Emergency classification level, each barrier is weighted equally.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXLGS 3-24EP-AA-1008 (Revision XX)

Fxelnn NuclAarLimeric~k Goner~atinn Stsation Annex FEceInn NuicleazrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFA1Initiating Condition:ANY Loss or ANY Potential Loss of either Fuel Clad or RCS.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Refer to Fission Product Barrier Loss and Potential Loss threshold values to determinebarrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.At the Alert classification level, Fuel Cladding and RCS barriers are weighted moreheavily than the Containment barrier. Unlike the Containment barrier, loss or potentialloss of either the Fuel Cladding or RCS barrier may result in the relocation of radioactivematerials or degradation of core cooling capability. Note that the loss or potential loss ofContainment barrier in combination with loss or potential loss of either Fuel Cladding orRCS barrier results in declaration of a Site Area Emergency under EAL FS1.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXLGS 3-25EP-AA-1008 (Revision XX)

I imarink ronarnfinn Af2finn AnnoyI=Yalnn NinrlmarI imairit~k (~nn~rntinn ~t2tinn Ann~w Fvalnn fI.ur~Io2rRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC1Initiating Condition:RCS ActivityOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSSA. (Site:Specific ind-ications that reactor coolant activity is greater than 300u~ilgm doseq,,ivaleRt-1 3!)Coolant activity > 300 uCi/gm Dose Equivalent 1-131.Basis:This threshold indicates that RCS radioactivity concentration is greater than 300 I4Ci/gmdose equivalent 1-131. Reactor coolant activity above this level is greater than thatexpected for iodine spikes and corresponds to an approximate range of 2% to 5% fuelclad damage. Since this condition indicates that a significant amount of fuel claddamage has occurred, it represents a loss of the Fuel Clad Barrier.It is recognized that sample collection and analysis of reactor coolant with highlyelevated activity levels could require several hours to complete. Nonetheless, asample-related threshold is included as a backup to other indications.There is no Potential Loss threshold associated with RCS Activity.Basis Reference(s):1 .NEI 99-01 Rev 6, Table 9-F-2Month 20XXLGS 3-26EP-AA-1008 (Revision XX)

I imariek rZonarnfin Atnfinn AnnoyPwi::nn NiAalnrI im~rirk (~nbr2tinn ~t2*inn Ann~v Fv~Inn hi.IuI~2rRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC2Initiating Condition:RPV Water LevelOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSSA-.-1. Plant conditions indicate Primary Crontainment flooding is required.POTENTIAL LOSSA-.2. RPV water level cannot be restored and maintained above (sate .pei..c RPV...ateF level c.r...ponding to the top of ,;,cie fuel)> -161 inches (TAF)Gr-OR3. RPV water level cannot be determined.Basis:Loss 2-AThreshold #1 BasisThe Loss threshold represents the EOP requirement for primary containment flooding.This is identified in the BWROG EPGs/SAGs when the phrase, "Primary ContainmentFlooding Is Required," appears. Since a site-specific RPV water level is not specifiedhere, the Loss threshold phrase, "Primary containment flooding required," alsoaccommodates the EOP need to flood the primary containment when RPV water levelcannot be determined and core damage due to inadequate core cooling is believed tobe occurring.Potential Loss 2-AThreshold #2 and #3 Basis:This water level corresponds to the top of the active fuel and is used in the EOPs toindicate a challenge to core cooling.The RPV water level threshold is the same as RCS baF-ieFBarrier RC2 Loss threshold2-A. Thus, this threshold indicates a Potential Loss of the Fuel Clad barrier and a Lossof the RCS barrier that appropriately escalates the emergency classification level to aSite Area Emergency.This threshold is considered to be exceeded when, as specified in the site-specificEOPs, RPV wate RPV water level cannot be restored and maintained above thespecified level following depressurization of the RPV (either manually, automatically orby failure of the RCS barrier) or when procedural guidance or a lack of low pressureRPV injection sources preclude Emergency RPV depressurization. EOPs allow theoperator a wide choice of RPV injection sources to consider when restoring RPV waterlevel to within prescribed limits. EOPs also specify depressurization of the RPV in orderto facilitate RPV water level control with low-pressure injection sources. In some events,Month 20XXLGS 3-27EP-AA-1008 (Revision XX)

Fvl:YInn iNnelon=rI impriink riona~rsainn Rtfatinn Annaw FidnNt~~mRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONelevated RPV pressure may prevent restoration of RPV water level until pressure dropsbelow the shutoff heads of available injection sources. Therefore, this Fuel Clad barrierPotential Loss is met only after either: 1) the RPV has been depressurized, or requiredemergency RPV depressurization has been attempted, giving the operator anopportunity to assess the capability of low-pressure injection sources to restore RPVwater level or 2) no low pressure RPV injection systems are available, precluding RPVdepressurization in an attempt to minimize loss of RPV inventory.The term "cannot be restored and maintained above" means the value of RPV waterlevel is not able to be brought above the specified limit (top of active fuel). Thedetermination requires an evaluation of system performance and availability in relationto the RPV water level value and trend. A threshold prescribing declaration when athreshold value cannot be restored and maintained above a specified limit does notrequire immediate action simply because the current value is below the top of activefuel, but does not permit extended operation below the limit; the threshold must beconsidered reached as soon as it is apparent that the top of active fuel cannot beattained.Entry into the "Steam Cooling" leg of the EOP's would be an example of an inability to"restore and maintain" level above TAF resulting in this threshold being met.In high-power ATWS/failure to scram events, EOPs may direct the operator todeliberately lower RPV water level to tho top of active fuel- in order to reduce reactorpower. RP"V water leVel c then cotOlod between the top of act,,ive fu,-el, and theMinimum Steam CoolinG RPV I^.Iate R....% .A.. Although such action is achallenge to core cooling and the Fuel Clad barrier, the immediate need to reducereactor power is the higher priority. For such events, ICs SA,-MA3 or SS5-MS3 willdictate the need for emergency classification.Since the loss of ability to determine if adequate core cooling is being provided presentsa significant challenge to the fuel clad barrier, a potential loss of the fuel clad barrier isspecified.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. T-1 11 Level Restoration / Steam Cooling- BASES3. T-1 17 Level/Power Control -BASESMonth 20XXLGS 3-28EP-AA-1008 (Revision XX)

N.clAarSimeric~k fleneratinn Staition Annex Exelnn NuclanrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC5Initiating Condition:Primary Containment RadiationOperating Mode Applicability:1,2,3Fission Product Barler (FPB) Threshold:LOSSA. containment radiation monitor reading greater than (site spocific value)Drywell radiation monitor reading > 1.90 E+02 R/hr.Basis:Less-4.The radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the primary containment, assuming that reactor coolant activityequals 300 jiCi/gm dose equivalent 1-131. Reactor coolant activity above this level isgreater than that expected for iodine spikes and corresponds to an approximate rangeof 2% to 5% fuel clad damage. Since this condition indicates that a significant amountof fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.The radiation monitor reading in this threshold is higher than that specified for RCSBarrier RC5 Loss Tthreshold4A since it indicates a loss of both the Fuel Clad Barrierand the RCS Barrier. Note that a combination of the two monitor readings appropriatelyescalates the emergency classification level to a Site Area Emergency.There is no Fuel Clad Barrier Potential Loss threshold associated with PrimaryContainment Radiation.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. Core Damage Assessment Methodology3. Technical Specifications Table 3.3.7.5-1, Accident Monitoring Instrumentation4. DBD L-S-43, Radiation Monitoring System5. ST-2-026-418-1 Accident Monitoring -Primary Containment Post -LOCARadiation Division III Calibration (RE-26-191A)6. ST-0-026-640-* Alternate Monitoring for Inop Post-LOCA Radiation MonitorsMonth 20XXLGS 3-29EP-AA-1008 (Revision XX)

I imarink rpnarnfinn Atntinn AnnowPynilnn N"Morl=rliI Imgirilli ( Hngr~ inn itmil nn ll Ana FI nn NI urIIoi1RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFC7Initiating Condition:Emergency Director Judgment.Operating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSS1A. Any condition in the opinion of the Emergency Director that indicates Loss of theFuel Clad Barrier.POTENTIAL LOSS2A. Any condition in the opinion of the Emergency Director that indicates PotentialLoss of the Fuel Clad Barrier.Basis:Loss Threshold #1 BasisLeSS-"AThis threshold addresses any other factors that are to be used by the EmergencyDirector in determining whether the Fuel Clad Barrier is lost.Potential Loss Threshold #2 BasisPetontial Le. s This threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Fuel Clad Barrier is potentially lost. The Emergency Directorshould also consider whether or not to declare the barrier potentially lost in the eventthat barrier status cannot be monitored.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXLGS 3-30EP-AA-1008 (Revision XX)

Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC2Initiating Condition:RPV Water LevelOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSS1. RPV water level cannot be restored and maintained above (site .pecific RPV waterlevel ....o..n.i. g to the top of cte fue4)> -161 inches (TAF)Gr-OR2. RPV water level cannot be determined.Basis:Less-2-.This water level corresponds to the Ttop of Aactive Ffuel (TAF) and is used in the EOPsto indicate challenge to core cooling.The RPV water level threshold is the same as Fuel Clad baiieF Barrier FC2 PotentialLoss threshold-2A. Thus, this threshold indicates a Loss of the RCS barrier andPotential Loss of the Fuel Clad barrier and that appropriately escalates the emergencyclassification level to a Site Area Emergency.This threshold is considered to be exceeded when, as specified in the site-specificEOPs, RPV-wateFRPV water level cannot be restored and maintained above thespecified level following depressurization of the RPV (either manually, automatically orby failure of the RCS barrier) or when procedural guidance or a lack of low pressureRPV injection sources preclude Emergency RPV depressurization EOPs allow theoperator a wide choice of RPV injection sources to consider when restoring RPV waterlevel to within prescribed limits. EOPs also specify depressurization of the RPV in orderto facilitate RPV water level control with low-pressure injection sources. In some events,elevated RPV pressure may prevent restoration of RPV water level until pressure dropsbelow the shutoff heads of available injection sources. Therefore, this RCS barrier Lossis met only after either: 1) the RPV has been depressurized, or required emergencyRPV depressurization has been attempted, giving the operator an opportunity to assessthe capability of low-pressure injection sources to restore RPV water level or 2) no lowpressure RPV injection systems are available, precluding RPV depressurization in anattempt to minimize loss of RPV inventory.The term, "cannot be restored and maintained above," means the value of RPV waterlevel is not able to be brought above the specified limit (top of active fuel). Thedetermination requires an evaluation of system performance and availability in relationto the RPV water level value and trend. A threshold prescribing declaration when aMonth 20XXLGS 3-31EP-AA-1008 (Revision XX)

I=xelon NuclearI imarirnk (rancarninn Afntinn Annaxv Exelon NucleanrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONthreshold value cannot be restored and maintained above a specified limit does notrequire immediate action simply because the current value is below the top of activefuel, but does not permit extended operation beyond the limit; the threshold must beconsidered reached as soon as it is apparent that the top of active fuel cannot beattained.Entry into the "Steam Cooling" leg of the EOP's would be an example of an inability to"restore and maintain" level above TAF resulting in this threshold being met.In high-power ATWS/failure to scram events, EOPs may direct the operator todeliberately lower RPV water level to the top of ativ,.-' fuel in order to reduce reactorpower. RPV wAater IoeIe as then coentrolled between the top of active fue-l and thoMinimumA Stoamn Cooling R Water Level (GRVI.A.)-. Although such action is achallenge to core cooling and the Fuel Clad barrier, the immediate need to reducereactor power is the higher priority. For such events, ICs SA5-MA3 or ,S5-MS3 willdictate the need for emergency classification.There is no RCS Potential Loss threshold associated with RPV Water Level.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. T-BAS, TRIPS / SAMPS -Bases3. T 101, RPV Control4. T-1 11, Level Restoration / Steam CoolingMonth 20XXLGS 3-32EP-AA-1008 (Revision XX)

I=xAInn NunlAarI imarirnk ryangarninn Station Annoy Exelnn NucleaIrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC3Initiating Condition:Primary Containment PressureOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSSA. Primar;;F containment pressure greater than (site Specific value) due to RCS leakage.1. Drywell pressure >1.68 psig.AND2. Drywell pressure rise is due to RCS leakageBasis:The (site -p.cific 1.68 psig primary containment pressure is the drywe#Drywellhigh pressure setpoint which indicates a LOCA by automatically initiating the-ECCS-erequivalent makeup system.The second threshold condition focuses the fission product barrier loss threshold on afailure of the RCS instead of the non-LOCA malfunctions that may adversely affectprimary containment pressure. Pressures of this magnitude can be caused by non-LOCA events such as a loss of Drywell cooling or inability to control primarycontainment vent/purge.The release of mass from the RCS due to the as-designed/expected operation of anyrelief valve does not warrant an emergency classification.A stuck-open Safety Relief Valve (SRV) or SRV leakage is not considered eitheridentified or unidentified leakage by Technical Specification and, therefore, is notapplicable to this EAL.There is no Potential Loss threshold associated with Primary Containment Pressure.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. T-101 RPV Control3. T-102 Primary Containment Control -BasesMonth 20XXLGS 3-33EP-AA-1008 (Revision XX)

I imarielt (' Zonaratin Af2finn AnnowIP:valn n N,,r-la~rI i~ri~k ~n~~*nn$ain nvFrI hiimRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC4Initiating Condition:RCS Leak RateOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSSAl. UNISOLABLE Main Steam Line (MSL), HPCI, Feedwater, RWCU, or RCIC linebreak. iA ANY of ;,,,,.ng (it;+ .....f ~ eM ..... poeta .. ..;+,,GF,+;, ...... ;,yOR82. Emergency RPV Depressurization is required.POTENTIAL LOSS3A. UNISOLABLE primary system leakage that results in EITHER of the following:a4. Secondary Containment area temperature > T-103 1 SAMP, Max Norm Op Value(MNO)MA. -Ne Nrm'iaQ .pe.at+;, T e...peFatufe.ORb2. Secondary Containment area radiation level > T-103 I SAMP, Max Norm Op Value(MNO)Max Normal Operating Area Radiation Level.Basis:UNISOLABLE: An open or breached system line that cannot be isolated, remotely orlocally.Classification of a system break over system leakage is based on information availableto the Control Room from the event. Indications that should be considered are:* Reports describing magnitude of steam or water release.* Use of system high flow alarms / indications, if available,* Significant changes in makeup requirements,* Abnormal reactor water level changes in response to the event.The use of the above indications provides the Control Room the bases to determine thatthe on going event is more significant than the indications that would be expected fromsystem leakage and therefore should be considered a system break.Month 20XXLGS 3-34EP-AA-1008 (Revision XX)

I imariek rZonarnfin Afnfinn AnnovF:valnn N~irhlnrI i~rt~kflnaratnn$atn nvFolnMuIrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONLoss Threshold #1 Basis-3.Large high-energy lines that rupture outside primary containment can dischargesignificant amounts of inventory and jeopardize the pressure-retaining capability of theRCS until they are isolated. If it is determined that the ruptured line cannot be promptlyisolated from the Centrol Room, the RCS barrier Loss threshold is met.Loss Threshold #2 Basis-34.BEmergency RPV Depressurization in accordance with the EOPs is indicative of a loss ofthe RCS barrier. If Emergency RPV Depressurization is performed, the plant operatorsare directed to open safety relief valves (SRVs) and keep them open. Even though theRCS is being vented into the suppression pool, a Loss of the RCS barrier exists due tothe diminished effectiveness of the RCS to retain fission products within its boundary.Potential Loss Threshold- #3 Basis 3-.APotential loss of RCS based on primary system leakage outside the primarycontainment is determined from EOP temperature or radiation Max Normal Operatingvalues in areas such as main steam line tunnel, RCIC, HPCI, etc., which indicate adirect path from the RCS to areas outside primary containment.A Max Normal Operating value is the highest value of the identified parameter expectedto occur during normal plant operating conditions with all directly associated supportand control systems functioning properly.The indicators reaching the threshold barriers and confirmed to be caused by RCSleakage from a primary system warrant an Alert classification. A primary system isdefined to be the pipes, valves, and other equipment which connect directly to the RPVsuch that a reduction in RPV pressure will effect a decrease in the steam or water beingdischarged through an unisolated break in the system.In general, multiple indications should be used to determine if a primary system isdischarging outside Primary Containment. For example, a high area radiation conditiondoes not necessarily indicate that a primary system is discharging into the ReactorBuilding since this may be caused by radiation shine from nearby steam lines or themovement of radioactive materials. Conversely, a high area radiation condition inconjunction with other indications (e.g. room flooding, high area temperatures, reports ofsteam in the Reactor Building, an unexpected rise in Feedwater flowrate, or unexpectedMain Turbine Control Valve closure) may indicate that a primary system is discharginginto the Reactor Building.An UNISOLABLE leak which is indicated by Max Normal Operating values escalates toa Site Area Emergency when combined with Containment Barrier CT6 Loss tThreshold#13,A (after a containment isolation) and a General Emergency when the Fuel CladBarrier criteria is also exceeded.Month 20XXLGS 3-35EP-AA-1008 (Revision XX)

I=xelon NuclearI imprirck Genersatinn Sta~tion Annex Exellon NuceIa~rRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONBasis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. SAMP-2, Containment and Radioactivity Release Control3. T-103, Secondary Containment ControlMonth 20XXLGS 3-36EP-AA-1008 (Revision XX)

I lmmri r-L- (-'gingrnfinr Q$f*irin A nnnvF:vgalnn Mime:rlAsrisRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC5Initiating Condition:Primary Containment radiationOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSSDrywell radiation monitor reading > lOOR/hr.A. containment radiation reading greater than (Site pc;ificr value).Basis:The radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the primary containment, assuming that reactor coolant activityequals Technical Specification allowable limits. This value is lower than that specifiedfor Fuel Clad Barrier FC5 Loss tThreshold-4A- since it indicates a loss of the RCSBarrier only.There is no RCS Potential Loss threshold associated with Primary ContainmentRadiation.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. EP-EAL-061 1, Criteria for Choosing Containment Radiation Monitor ReadingIndicative of Loss of RCS BarrierMonth 20XXLGS 3-37EP-AA-1008 (Revision XX)

I irngsrio-h- ftdingsrýfin Q#!mfien AnngvI::vslrnn f, " glx:rI ~ ~ ~*~4ii~ui A uiv~av Fv~Inn IJ.mrI~nr.~uEE.~3 ~ ~ E~E U~IU E~I ~W5.I~UI 5~~U El E~I~ ----s-s. U ~RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONRC7Initiating Condition:Emergency Director Judgment.Operating Mode Applicability:1,2,3'Fission Product Barrier (FPB3) Threshold:LOSSAl. Any condition in the opinion of the Emergency Director that indicates Loss of theRCS Barrier.POTENTIAL LOSSA2. Any condition in the opinion of the Emergency Director that indicates PotentialLoss of the RCS Barrier.Basis:Loss &.AThreshold #1 Basis:This threshold addresses any other factors that are to be used by the EmergencyDirector in determining whether the RCS Barrier is lost.Potential Loss 6&AThreshold #2 Basis:This threshold addresses any other factors that may be used by the Emergency Directorin determining whether the RCS Barrier is potentially lost. The Emergency Directorshould also consider whether or not to declare the barrier potentially lost in the eventthat barrier status cannot be monitored.Basis Reference(s):1 .NEI 99-01 Rev 6, Table 9-F-2Month 20XXLGS 3-38EP-AA-1008 (Revision XX)

Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT2Initiating Condition:RPV Water LevelOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:POTENTIAL LOSSA Plant conditions indicate Primary GContainment flooding is required.Basis:Potential ILarr 2 AThe Potential Loss threshold is identical to the Fuel Clad Barrier FC2 Loss thresholdRPV Water Level. 2-.The Potential Loss requirement for Primary ContainmentFlooding indicates adequate core cooling cannot be restored and maintained and thatcore damage is possible. BWR EPGs/SAGs specify the conditions that require primarycontainment flooding. When primary containment flooding is required, the EPGs areexited and SAGs are entered. Entry into SAGs is a logical escalation in response to theinability to restore and maintain adequate core cooling.PRA studies indicate that the condition of this Potential Loss threshold could be a coremelt sequence which, if not corrected, could lead to RPV failure and increased potentialfor primary containment failure. In conjunction with the RPV water level Loss thresholdsin the Fuel Clad and RCS barrier columns, this threshold results in the declaration of aGeneral Emergency.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. T-BAS (INTRO) Introduction To Trips And Samps -Bases3. T-1 11, Level Restoration / Steam Cooling -Bases4. T-1 16, RPV Flooding -Bases5. T-1 17, Level/Power Control -BasesMonth 20XXLGS 3-39EP-AA-1008 (Revision XX)

F:yAInn N.clAarI imprirnk ranabratinn Station Annex Fxelnn NuleaarRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT3Initiating Condition:Primary Containment ConditionsOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSSAl. UNPLANNED rapid drop in primary containment pressure following primarycontainment pressure rise.OR82. Primary containment pressure response not consistent with LOCA conditions.POTENTIAL LOSSA3. PFima~y GDrywellentainment pressure greater than (site specific value)> 55 psigand rising.OR84. (site Specifc explosive mixtur) exists inside PrimAv;, containment a. Drywell orSuppression Pool Hydrogen concentration > 6%.ANDb. Drywell or Suppression Pool Oxygen concentration > 5%.ORG5. HTLG-Heat Capacity Limit (T-102 Curve SP/T-1) exceeded.Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.Loss I-A.-andJ.-BThreshold #1 and #2 BasisRapid UNPLANNED loss of primary containment pressure (i.e., not attributable tod DyweDrywell spray or condensation effects) following an initial pressure iPi easerise Iindicates a loss of primary containment integrity. Primary containment pressure shouldiireaserise as a result of mass and energy release into the primary containment from aLOCA. Thus, primary containment pressure not increasing under these conditionsindicates a loss of primary containment integrity.These thresholds rely on operator recognition of an unexpected response for thecondition and therefore a specific value is not assigned. The unexpected(UNPLANNED) response is important because it is the indicator for a containmentbypass condition. A pressure suppression bypass path would not be an indication of acontainment breach.Month 20XXLGS 3-40EP-AA-1008 (Revision XX)

Limerick Generatina Station AnnexExelon NuclearLimerick..Genera..... SIta.ion..Annex..E....on..Nucle..rRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONPotential Loss 4-AThreshold #3 BasisThe threshold pressure is the primary containment internal design pressure. Structuralacceptance testing demonstrates the capability of the primary containment to resistpressures greater than the internal design pressure. A pressure of this magnitude isgreater than those expected to result from any design basis accident and, thus,represent a Potential Loss of the Containment barrier.Potential Loss 4-BThreshold #4 BasisIf hydrogen concentration reaches or exceeds the lower flammability limit, as defined inplant EOPs, in an oxygen rich environment, a potentially explosive mixture exists. If thecombustible mixture ignites inside the primary containment, loss of the Containmentbarrier could occur.Potential Loss 4-,CThreshold #5 BasisThe WHeat Capacity TemperFabture Lim"it (HCTL) is the highest eupr.e;cen peoltemperature fromff Which EmRergencGy RPV Qepr curzation will not raice:* Spprccin haMber temperature above the maximum temperature capability othe~~~ Gupeco hamber and equipment within the supprecciGn cham~ber Whicmay be required to operate when the RPV i,,,.uie,OR*Sppeco cham:ber pressure above Primary Containm~ent Pressure Limnit-Alwhil~e the- r-ate Of energy transf-er fro-m the RPV to the containm~ent is grcater thnthe capacity Of the containment Yent.The HCTL is a function of RPV pressure, suppression pool temperature andsuppression pool water level. It is utilized to preclude failure of the containment andequipment in the containment necessary for the safe shutdown of the plant andtherefore, the inability to maintain plant parameters below the limit constitutes apotential loss of containment.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. UFSAR Section 6.2.13. DBD L-T-12, Design Basis Accidents, Transients and Events4. DBD L-S-25A, Primary Containment Pressure Suppression System5. DBD L-T-02, Containment, Section 3.2.146. T-102 Primary Containment Control -BasesMonth 20XXLGS 3-41EP-AA-1008 (Revision XX)

I imnrif-k I' Znnnrnfin Qfafinn AnnnvF::alnn NnrllarI inp1 fn~~*nn~**in nnv vannM~r222RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT5Initiating Condition:Primary Containment RadiationOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:POTENTIAL LOSSA. Primary containment radiatien monitor reading greater than (sitc cpecifc value)Drywell radiation monitor reading > 4.35 E+02 R/hr.Basis:There is no Loss threshold associated with Primary Containment Radiation.Potential Less 4.,A.The radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the primary containment, assuming that 20% of the fuel cladding hasfailed. This level of fuel clad failure is well above that used to determine the analogousFuel Clad Barrier Loss and RCS Barrier Loss thresholds.NUREG-1 228, Source Estimations During Incident Response to Severe Nuclear PowerPlant Accidents, indicates the fuel clad failure must be greater than approximately 20%in order for there to be a major release of radioactivity requiring offsite protectiveactions. For this condition to exist7 there must already have been a loss of the RCSBarrier and the Fuel Clad Barrier. It is therefore prudent to treat this condition as apotential loss of containment which would then escalate the emergency classificationlevel to a General Emergency.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. Core Damage Assessment Methodology3. Technical Specifications Table 3.3.7.5-14. DBD L-S-43, Radiation Monitoring System5. ST-2-026-418-1 Accident Monitoring -Primary Containment Post -LOCARadiation Division III Calibration (RE-26-191A)6. ST-0-026-640-* Alternate Monitoring for Inop Post-LOCA Radiation MonitorsMonth 20XXLGS 3-42EP-AA-1008 (Revision XX)

I=xelon NuclearLimeric~k Generatina Station Annex Exelon NuclanrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT6Initiating Condition:Primary Containment Isolation FailureOperating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSSAl. UNISOLABLE direct downstream pathway to the environment exists after primarycontainment isolation signal.ORB2. Intentional Pprimary Ceontainment venting/purging per EOP's or SAGs due toaccident conditions.ORG3. UNISOLABLE primary system leakage that results in EITHER of the following:1-a. Secondary Containment area temperature > T-103 I SAMP, Max Safe OpValue (MSO).Ma F.a. T..empe.atu.eOR2b. Secondary Containment area radiation level > T-103 I SAMP, Max Safe OpValue (MSO)Max Safe Operating Radiation Level.Basis:UNISOLABLE: An open or breached system line that cannot be isolated, remotely orlocally.These thresholds address incomplete containment isolation that allows anUNISOLABLE direct release to the environment.Loss 3AThreshold #1 BasisThe use of the modifier "direct" in defining the release path discriminates againstrelease paths through interfacing liquid systems or minor release pathways, such asinstrument lines, not protected by the Primary Containment Isolation System (PCIS).Leakage into a closed system is to be considered only if the closed system is breachedand thereby creates a significant pathway to the environment. Examples includeunisolable Main Steamline, HPCI or RCIC steamline breaks, unisolable RWCU systembreaks, and unisolable containment atmosphere vent paths.Examples of "downstream pathway to the environment" could be through theTurbine/Condenser, or direct release to the Turbine or Reactor Building.The existence of a filter is not considered in the threshold assessment. Filters do notremove fission product noble gases. In addition, a filter could become ineffective due toiodine and/or particulate loading beyond design limits (i.e., retention ability has beenexceeded) or water saturation from steam/high humidity in the release stream.Month 20XXLGS 3-43EP-AA-1008 (Revision XX)

F=galnn I imaprirk rioarnnrainn tAtninn AnnaY vn mx~c2RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONFollowing the leakage of RCS mass into primary containment and a rise in primarycontainment pressure, there may be minor radiological releases associated withallowable primary containment leakage through various penetrations or systemcomponents. Minor releases may also occur if a primary containment isolation valve(s)fails to close but the primary containment atmosphere escapes to an enclosed system.These releases do not constitute a loss or potential loss of primary containment butshould be evaluated using the Recognition Category A-RICs.Loss 3&BThreshold #2 BasisEOPs may direct primary containment isolation valve logic(s) to be intentionallybypassed, even if offsite radioactivity release rate limits will be exceeded. Under theseconditions with a valid primary containment isolation signal, the containment should alsobe considered lost if primary containment venting is actually performed.Intentional venting of primary containment for primary containment pressure orcombustible gas control to the secondary containment and/or the environment is a Lossof the Containment. Venting for primary containment pressure control when not in anaccident situation (e.g., to control pressure below the high pressurescram setpoint) does not meet the threshold condition.Loss 3-,CThreshold #3 BasisThe Max Safe Operating Temperature and the Max Safe Operating Radiation Level areeach the highest value of these parameters at which neither: (1) equipment necessaryfor the safe shutdown of the plant will fail, nor (2) personnel access necessary for thesafe shutdown of the plant will be precluded. EOPs utilize these temperatures andradiation levels to establish conditions under which RPV depressurization is required.The temperatures and radiation levels should be confirmed to be caused by RCSleakage from a primary system. A primary system is defined to be the pipes, valves, andother equipment which connect directly to the RPV such that a reduction in RPVpressure will effect a decrease in the steam or water being discharged through anunisolated break in the system.In general, multiple indications should be used to determine if a primary system isdischarging outside Primary Containment. For example, a high area radiation conditiondoes not necessarily indicate that a primary system is discharging into the ReactorBuilding since this may be caused by radiation shine from nearby steam lines or themovement of radioactive materials. Conversely, a high area radiation condition inconjunction with other indications (e.g. room flooding, high area temperatures, reports ofsteam in the Reactor Building, an unexpected rise in Feedwater flowrate, or unexpectedMain Turbine Control Valve closure) may indicate that a primary system is discharginginto the Reactor Building.In combination with RCS Barrier RC4 pPotential ILoss Threshold #3 3A this thresholdwould result in a Site Area Emergency.There is no Potential Loss threshold associated with Primary Containment IsolationFailure.Month 20XXLGS 3-44EP-AA-1008 (Revision XX)

Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONBasis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-22. T-103, Secondary Containment Control3. T-102, Primary Containment Control4. T-200, Primary Containment Emergency Vent Procedure5. T-228, Inerting / Purging Primary ContainmentMonth 20XXLGS 3-45EP-AA-1008 (Revision XX)

Limerick Generating Station AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATIONCT7Initiating Condition:Emergency Director Judgment.Operating Mode Applicability:1,2,3Fission Product Barrier (FPB) Threshold:LOSSAl. Any condition in the opinion of the Emergency Director that indicates Loss of theContainment Barrier.POTENTIAL LOSSA2. Any condition in the opinion of the Emergency Director that indicates PotentialLoss of the Containment Barrier.Basis:Loss "AThreshold #1 Basis:This threshold addresses any other factors that are to be used by the EmergencyDirector in determining whether the Containment Barrier is lost.Potential Loss $OAThreshold #2 Basis:This threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Containment Barrier is potentially lost. The EmergencyDirector should also consider whether or not to declare the barrier potentially lost in theevent that barrier status cannot be monitored.Basis Reference(s):1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXLGS 3-46EP-AA-1008 (Revision XX)

NuclAarSimeric~k (Ganeratinn Staition Annex Exelon Nuclea~rRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSG1Initiating Condition:Prolonged loss of all Off-site and all On-Site AC power to emergency busses.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the General EMcgecY -vent promptlyupon determining that (site hours) the applicable time has beenexceeded, or will likely be exceeded.1-a. Loss of ALL offsite :and LL onsi"o AC power to unit (site spe..ft" emergencYbuses)4KV safeguards Buses.AND2. Failure of Dl 1(21), D12(22), D13(23), and D14(24) Emergency Diesel Generatorsto supply power to unit 4KV safeguards Buses.AND3b. EITHER of the following:a. Restoration of at least one unit emeegeAcyAKV Safeguards bu&-Bus -in < 2hours is notves than (site specific hours) is not likely.ORb. RPV water level cannot be restored and maintained > -186 inches.*(Site specific indication of an inability to adequately remove he-at fro-m the core)Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a prolonged loss of all power sources to AC emergency buses. Aloss of all AC power compromises the performance of all SAFETY SYSTEMS requiringelectric power including those necessary for emergency core cooling, containment heatremoval/pressure control, spent fuel heat removal and the ultimate heat sink. Aprolonged loss of these buses will lead to a loss of one or moreany fission productMonth 20XXLGS 3-47EP-AA-1008 (Revision XX)

Simeric~k (GAneratinn Stsation Annex Exelon Nucla~rRECOGNITION CATEGORYSYSTEM MALFUNCTIONSbarriers. In addition, fission product barrier monitoring capabilities may be degradedunder these conditions.The EAL should require declaration of a General Emergency prior to meeting thethresholds for IC FGI. This will allow additional time for implementation of offsiteprotective actions.Escalation of the emergency classification from Site Area Emergency will occur if it isprojected that power cannot be restored to at least one AC emergency bus by the endof the analyzed station blackout coping period. Beyond this time, plant responses andevent trajectory are subject to greater uncertainty, and there is an increased likelihoodof challenges to multiple fission product barriers.The estimate for restoring at least one emergency bus should be based on a realisticappraisal of the situation. Mitigation actions with a low probability of success should notbe used as a basis for delaying a classification upgrade. The goal is to maximize thetime available to prepare for, and implement, protective actions for the public.The EAL will also require a General Emergency declaration if the loss of AC powerresults in parameters that indicate an inability to adequately remove decay heat fromthe core.Basis Reference(s):1. NEI 99-01 Rev 6, SG12. UFSAR Section 8.2, Offsite Power System3. E 10/20 Loss of Offsite Power4. DBD L-S-05, 4KV System5. DBD L-T-03, Electrical Issues6. T-101 RPV ControlMonth 20XXLGS 3-48EP-AA-1008 (Revision XX)

Fvamlnn NimlanrSimernick (Anersatinn Station AnnexEAn N~~AiRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSSIInitiating Condition:Loss of all offsite and all onsite AC power to emergency busses for 15 minutes orlonger.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the Site Area E=..egenyevent promptlyupon determining that the applicable time 415miiwtes-has been exceeded, or willlikely be exceeded.1. Loss of ALL offsite and ALL on;ito AC Power to (site spocific emergency bucc,)unit4KV Safeguards Buses. for 15 minutes or lo.ger.AND2. Failure of Dl 1(21), D12(22), D13(23), and D14(24) Emergency Diesel Generators tosupply power to unit 4KV Safeguards Buses.AND3. Failure to restore power to at least one unit 4KV Safeguards bus in < 15 minutesfrom the time of loss of both offsite and onsite AC powerBasis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a total loss of AC power that compromises the performance of allSAFETY SYSTEMS requiring electric power including those necessary for emergencycore cooling, containment heat removal/pressure control, spent fuel heat removal andthe ultimate heat sink. In addition, fission product barrier monitoring capabilities may bedegraded under these conditions. This IC represents a condition that involves actual orlikely major failures of plant functions needed for the protection of the public.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via ICs RAG1, FG1-er-MSG1,or MG2.Month 20XXLGS 3-49EP-AA-1008 (Revision XX)

Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSBasis Reference(s):1. NEI 99-01 Rev 6, SS12. UFSAR Section 8.2, Offsite Power System3. E 10/20 Loss of Offsite Power4. DBD L-S-05, 4KV System5. DBD L-T-03, Electrical Issues6. T-101 RPV ControlMonth 20XXLGS 3-50EP-AA-1008 (Revision XX)

FxAInn N.nlAarLimeric~k Ganer~atinn Stzation Annex Exelnn NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSA1Initiating Condition:Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the eventA~e promptly upondetermining that the applicable time 45- iiiutes-has been exceeded, or will likelybe exceeded.1. AC power capability to unit 4KV Safeguards Buses reduced to only one of thefollowing power sources for > 15 minutes.* 101 Safeguards Transformer* 102 Safeguards TransformerSDl 1(21) Diesel Generator* D12(22) Diesel Generator* D13(23) Diesel Generator* D14(24) Diesel Generatora. AG poWer eapabilit' to (Site SpSG~fiG emergencY bUcoc) is reduced to a singlepoW8 e~r ourc fonr I15 m~inutesA o-r longer.AND2b. Any additional single power source failure will result in a loss of -all-ALL AC powerto SAFETY SYSTEMS.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC describes a significant degradation of offsite and onsite AC power sources suchthat any additional single failure would result in a loss of all AC power to SAFETYSYSTEMS. In this condition, the sole AC power source may be powering one, or morethan one, train of safety-related equipment. This IC provides an escalation path from ICMSUl.An "AC power source" is a source recognized in AOPs and EOPs, and capable ofsupplying required power to an emergency bus. Some examples of this condition arepresented below.Month 20XXLGS 3-51EP-AA-1008 (Revision XX)

Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS" A loss of all offsite power with a concurrent failure of all but one emergency powersource (e.g., an onsite diesel generator)." A loss of all offsite power and loss of all emergency power sources (e.g., onsitediesel generators) with a single train of emergency buses being back-fed from theunit main generator." A loss of emergency power sources (e.g., onsite diesel generators) with a singletrain of emergency buses being back-fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof power.Escalation of the emergency classification level would be via IC MS$1.Basis Reference(s):1. NEI 99-01 Rev 6, SA12. UFSAR Section 8.2, Offsite Power System3. E 10/20 Loss of Offsite Power4. DBD L-S-05, 4KV System5. DBD L-T-03, Electrical IssuesMonth 20XXLGS 3-52EP-AA-1008 (Revision XX)

I imarink rZonarntinn Atntinn AnnayFvplnn NJn.IanrI imoria~k (~~inm2~nn ~t~atinn Ann~&v Fvnlnn MmIv~I~2rRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSU1Initiating Condition:Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the Unusual Event vent promptly upondetermining that the applicable time 15-min4e&-has been exceeded, or will likelybe exceeded.4-.Loss of ALL offsite AC power capability to unit 4KV Safeguards Buses (site-specifi eM.rgency bue ...for > 15 minutes-Ger-eia.Basis:This IC addresses a prolonged loss of offsite power. The loss of offsite power sourcesrenders the plant more vulnerable to a complete loss of power to AC emergency buses.This condition represents a potential reduction in the level of safety of the plant.For emergency classification purposes, "capability" means that an offsite AC powersource(s) is available to the emergency buses, whether or not the buses are poweredfrom it.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof offsite power.Escalation of the emergency classification level would be via IC MSA1.'Basis Reference(s):1. NEI 99-01 Rev 6, SU12. UFSAR Section 8.2, Offsite Power System3. E 10/20 Loss of Offsite Power4. DBD L-S-05, 4KV System5. DBD L-T-03, Electrical IssuesMonth 20XXLGS 3-53EP-AA-1008 (Revision XX)

Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSG281Initiating Condition:Loss of all AC and Vital DC power sources for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the General E.- ,--gencY vent promptlyupon determining that the applicable time 15-niutes-has been exceeded, or willlikely be exceeded.1. Loss of ALL offsite AC power to unit 4KV Safeguards Buses.AND2. Failure of D11(21), D12(22), D13(23), and D14(24) Emergency Diesel Generatorsto supply power to unit 4KV Safeguards Buses.AND3. Indicated voltage is < 105 VDC on unit 125 VDC battery busses 1(2)FA, FB, FC,and FD.AND4. ALL AC and Vital DC power sources have been lost for > 15 minutes.1. aa Les ofALntt nd m vA nnrm.v

  • POve (648 lH G veift e wefv-buses) for 15 Minutes or longer.-ANDb. Indicated voltage is loe6 than (cite Specific bus voltage value) onAL(site specific. Vital DCG busses) for 15 minutes Or longer.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.Month 20XXLGS 3-54EP-AA-1008 (Revision XX)

I=xAIon N.elAarLimeric~k Generzatinn Staition Annex Exelnn NucrlearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSThis IC addresses a concurrent and prolonged loss of both AC and Vital DC power. Aloss of all AC power compromises the performance of all SAFETY SYSTEMS requiringelectric power including those necessary for emergency core cooling, containment heatremoval/pressure control, spent fuel heat removal and the ultimate heat sink. A loss ofVital DC power compromises the ability to monitor and control SAFETY SYSTEMS. Asustained loss of both AC and DC power will lead to multiple challenges to fissionproduct barriers.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses. The 15-minute emergency declaration clock begins at the point when beth-allEAL conditions threshelds-are met.Basis Reference(s):1. NEI 99-01 Rev 6, SG82. UFSAR Section 8.3.2, DC Power Systems3. DBD P-L-01A, 125/250 VDC System4. E-1(2)FA Loss of Division I Safeguard 125/250V DC BUS 1FA5. E-1(2)FB Loss of Division II Safeguard 125/250V DC BUS 1FB6. E-1(2)FC Loss of Division III Safeguard 125/250V DC BUS 1FC7. E-1(2)FD Loss of Division IV Safeguard 125/250V DC BUS IFD8. UFSAR Section 8.2, Offsite Power System9. E 10/20 Loss of Offsite Power10. DBD L-S-05, 4KV System11. DBD L-T-03, Electrical IssuesMonth 20XXLGS 3-55EP-AA-1008 (Revision XX)

NuclearLimeric~k Generatinn Station Annex Exelon NuiclernRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSS28 IInitiating Condition:Loss of all vital DC power for 15 minutes or longer.Operating Mode .1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the Site Area Eme.gency.vent promptlyupon determining that the applicable time 41mintees-has been exceeded, or willlikely be exceeded.is < 105 VDC le's than (site Specfic. bus voltage 'value) on125 VDC battery busses 1(2)FA, FB, FC, and FDALL (sito specific Vital DGbusses) for > 15 minutes-e-F loeF.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses a loss of Vital DC power which compromises the ability to monitorand control SAFETY SYSTEMS. In modes above Cold Shutdown, this conditioninvolves a major failure of plant functions needed for the protection of the public.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via ICs RAG1, FG1 orMSG28.Basis Reference(s):1. NEI 99-01 Rev 6, SS82. UFSAR Section 8.3.2, DC Power Systems3. DBD P-L-01A, 125/250 VDC System4. E-1(2)FA Loss of Division I Safeguard 125/250V DC BUS 1FA5. E-1(2)FB Loss of Division II Safeguard 125/250V DC BUS 1FB6. E-1(2)FC Loss of Division III Safeguard 125/250V DC BUS 1FC7. E-1(2)FD Loss of Division IV Safeguard 125/250V DC BUS 1FDMonth 20XXLGS 3-56EP-AA-1008 (Revision XX)

I imarink rZanarnfinn Atnfinn AnnpXExAIon NuclearI imrirk (~~r~inn tatnn An~~Exelnn NucilearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSS361Initiating Condition:Inability to shutdown the reactor causing a challenge to RPV water level or RCS heatremoval.Operating Mode Applicability:1,2Emergency Action Level (EAL):1. Automatic scram did not shutdown the reactor as indicated by Reactor Power > 4%.AND2. All-ALL manual / ARI actions to shutdown the reactor have been unsuccessful asindicated by Reactor Power > 4%.AND3. EITHER of the following conditions exist:* RPV water level cannot be restored and maintained > -186 inchesOR* Heat Capacity Limit (T-102 Curve SP/T-1) exceeded.(Site ntion of an to adequately ,emo'e heat from; the c.re)(Site 6pecific indication of. an ibliyto adequately remove heat fromn the RCS)Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor scram that results in a reactor shutdown, all subsequent operator manualactions, both inside and outside the Control Room including driving in control rods andboron injection~all subsequent operator actionn to manually shutdown the reactor areunsuccessful, and continued power generation is challenging the capability toadequately remove heat from the core and/or the RCS. This condition will lead to fueldamage if additional mitigation actions are unsuccessful and thus warrants thedeclaration of a Site Area Emergency.In some instances, the emergency classification resulting from this IC/EAL may be Ihigher than that resulting from an assessment of the plant responses and symptomsagainst the Recognition Category F ICs/EALs. This is appropriate in that theRecognition Category F ICs/EALs do not address the additional threat posed by afailure to shutdown the reactor. The inclusion of this IC and EAL ensures the timelydeclaration of a Site Area Emergency in response to prolonged failure to shutdown thereactor.Month 20XXLGS 3-57EP-AA-1008 (Revision XX)

I impriuck (GAneraina Stt~ion Annex Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSA reactor shutdown is determined in accordance with applicable Emergency OperatingProcedure criteria.Escalation of the emergency classification level would be via IC RAG1 or FGI.Basis Reference(s):1. NEI 99-01 Rev 6, SS52. T-101 RPV Control -Bases3. T-1 17 Level/Power Control -Bases4. T-102 Primary Containment Control -BasesMonth 20XXLGS 3-58EP-AA-1008 (Revision XX)

I imarit-k (' ganartifin Qf!mfinn AnnavI:'V--I#n K, ,0-I.-orI~a _ _ý5in 4*ý An5 *** E t n**l .U t.* tS S*BUuRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSA31Initiating Condition:Automatic or manual scram fails to shutdown the reactor, and subsequent manualactions taken at the reactor control consoles are not successful in shutting down thereactor.Operating Mode Applicability:1,2Emergency Action Level (EAL):Note: A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.1. An-aAutomatic or manual scram did not shutdown the reactor as indicated byReactor Power > 4%.AND2. Manual / ARI actions taken at the reactor Gcntrol cnc,-cl Reactor Console are notsuccessful in shutting down the reactor as indicated by Reactor Power > 4%.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor scram that results in a reactor shutdown, and subsequent operator manualactions taken at the reactor to shutdown the reactor are also Iunsuccessful. This condition represents an actual or potential substantial degradationof the level of safety of the plant. An emergency declaration is required even if thereactor is subsequently shutdown by an action taken away from the reactor Gei* Iconsoles since this event entails a significant failure of the RPS.A manual action at the reactor GntrF#el onsoles is any operator action, or set of actions,which causes the control rods to be rapidly inserted into the core (e.g., initiating amanual reactor scram. This action does not include manually driving in control rods orimplementation of boron injection strategies. If this action(s) is unsuccessful, operatorswould immediately pursue additional manual actions at locations away from the reactorG9,*trl consoles (e.g., locally opening breakers). Actions taken at back-panels or otherlocations within the Control Room, or any location outside the Control Room, are notconsidered to be "at the reactor GOntrMl consoles".Taking the Reactor Mode Switch to SHUTDOWN Shutdown is considered to be amanual scram action.The plant response to the failure of an automatic or manual reactor scram will varybased upon several factors including the reactor power level prior to the event,availability of the condenser, performance of mitigation equipment and actions, otherconcurrent plant conditions, etc. If the failure to shutdown the reactor is prolongedMonth 20XXLGS 3-59EP-AA-1008 (Revision XX)

I FVirndr.i& f(-rsarafinn Q*f$nrin AnnovFvlnn N"Mar*S .Y.I 5

  • I w... ~n3 fRECOGNITION CATEGORYSYSTEM MALFUNCTIONSenough to cause a challenge to the RPV water level or RCS heat removal safetyfunctions, the emergency classification level will escalate to a Site Area Emergency viaIC MSS35. Depending upon plant responses and symptoms, escalation is also possiblevia IC FSI. Absent the plant conditions needed to meet either IC MSS35 or FS1, anAlert declaration is appropriate for this event.It is recognized that plant responses or symptoms may also require an Alert declarationin accordance with the Recognition Category F ICs; however, this IC and EAL areincluded to ensure a timely emergency declaration.A reactor shutdown is determined in accordance with applicable Emergency OperatingProcedure criteria.Basis Reference(s):1. NEI 99-01 Rev 6, SA52. T-101 RPV Control -Bases3. T-1 17 Level/Power Control -BasesMonth 20XXLGS 3-60EP-AA-1008 (Revision XX)

I imarif-L- e' A2nA2rtx#in Qftsfirtn AnnnvIRvainn MiulnarI viai.I ~~ir~uj ~~iE nA llV vIrnMi.~nr***** U U*U UUfl UamS*RECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSU31 IInitiating Condition:Automatic or manual scram fails to shutdown the reactor.Operating Mode Applicability:1,2Emergency Action Level (EAL):Note: A manual action is any operator action, or set of actions, which causes thecontrol rods to be rapidly inserted into the core, and does not include manuallydriving in control rods or implementation of boron injection strategies.1. a. An-aAutomatic scram -did not shutdown the reactor as indicated by ReactorPower > 4%..ANDb. A-sSubsequent manual / ARI action taken at the reactor contro!GenselesReactor Console is successful in shutting down the reactor.OR2. a. A-mManual scram -did not shutdown the reactor as indicated by ReactorPower > 4%.ANDb. EITHER of the following:1. A-sSubsequent manual / ARI action taken at the reactor controlGOnseGeeReactor Console is successful in shutting down the reactor.OR2. A-sSubsequent automatic scram / ARI is successful in shutting down thereactor.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor scram that results in a reactor shutdown, and either a subsequent operatormanual action taken at the reactor eetFrI consoles or an automatic scram is successfulin shutting down the reactor. This event is a precursor to a more significant conditionand thus represents a potential degradation of the level of safety of the plant.EAL #1 BasisFollowing the failure on an automatic reactor scram, operators will promptly initiatemanual actions at the reactor Ge,-,tc! onsoles to shutdown the reactor (e.g., initiate amanual reactor scram). If these manual actions are successful in shutting down thereactor, core heat generation will quickly fall to a level within the capabilities of theplant's decay heat removal systems.Month 20XXLGS 3-61EP-AA-1008 (Revision XX)

I=xelon NuclearI imprirnk Gonarating Station Annex Exelnn NuceIa~rRECOGNITION CATEGORYSYSTEM MALFUNCTIONSEAL #2 BasisIf an initial manual reactor trip is unsuccessful, operators will promptly take manualaction at another location(s) on the reactor GeRtrel consoles to shutdown the reactor(e.g., initiate a manual reactor scram/ARI using a different switch). Depending uponseveral factors, the initial or subsequent effort to manually scram the reactor, or aconcurrent plant condition, may lead to the generation of an automatic reactor scramsignal. If a subsequent manual or automatic scram/ARI is successful in shutting downthe reactor, core heat generation will quickly fall to a level within the capabilities of theplant's decay heat removal systems.A manual action at the reactor GG.-.r consoles is any operator action, or set of actions,which causes the control rods to be rapidly inserted into the core (e.g., initiating amanual reactor scram). This action does not include manually driving in control rods orimplementation of boron injection strategies. Actions taken at back-panels or otherlocations within the Control Room, or any location outside the Control Room, are notconsidered to be "at the reactor e,,tr-el consoles".Taking the Reactor Mode Switch to Shutdown is considered to be a manual scramaction.The plant response to the failure of an automatic or manual reactor tscram will varybased upon several factors including the reactor power level prior to the event,availability of the condenser, performance of mitigation equipment and actions, otherconcurrent plant conditions, etc. If subsequent operator manual actions taken at thereactor GGAFGI consoles are also unsuccessful in shutting down the reactor, then theemergency classification level will escalate to an Alert via IC MSA35. Depending uponthe plant response, escalation is also possible via IC FAI. Absent the plant conditionsneeded to meet either IC MA35 or FA1, an Unusual Event declaration is appropriatefor this event.A reactor shutdown is determined in accordance with applicable Emergency OperatingProcedure criteria.Should a reactor scram signal be generated as a result of plant work (e.g., RPS setpointtesting), the following classification guidance should be applied." If the signal generated as a result of plant work causes a plant transient that createsa real condition that should have included an automatic reactor scram and the RPSfails to automatically shutdown the reactor, then this IC and the EALs are applicable,and should be evaluated." If the signal generated as a result of plant work does not cause a plant transient butshould have generated an RPS scram signal and the scram failure is determinedthrough other means (e.g., assessment of test results), then this IC and the EALsare not applicable and no classification is warranted.Basis Refernce(s):Month 20XXLGS 3-62EP-AA-1008 (Revision XX)

Limerick Generating Station AnnexRECOGNITION CATEGORYSYSTEM MALFUNCTIONSExelon Nuclear1.2.3.NEI 99-01 Rev 6, SU5T-101 RPV ControlTechnical Specifications Table 3.3.1.1-1Month 20XXLGS 3-63EP-AA-1008 (Revision XX)

I imariek (Zanarnfinn A#2finn AnnoyIF:lrlnn Nw-lorI im~riaIe (~nor2tinn ~t~tinn Ann~v Fv~Inn hIIIr~Io2rRECOGNITION CATEGORYSYSTEM MALFUNCTIONSMSA42Initiating Condition:UNPLANNED loss of Control Room indications for 15 minutes or longer with asignificant transient in progress.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the eventAle4t promptly upondetermining that the applicable time 45 miiutes-has been exceeded, or will likelybe exceeded.1. a:-AA-UNPLANNED event results in the inability to monitor one er-moroANYTable Mlef- the f--llc..wii" parameters from within the Control Room for > 15minutes 9F-l.ngeF.see -belewRRe-actor- Power__________________Table M1 Control Room ParametersRPV Watr- Level , Reactor Power* RPV Water LevelRPV Pressure* Drywell PressurePrimary Containment .Suppression Pool Level........ .Suppression Pool TemperatureSuppression Pool Le.-veSUPPrcssion Pool Tempcrattur-AND2. b--Any-ANY Table M2ef transient events in progress." Automati; or Manual ,1 rubak greate than -250% thoW/1rmal re-actor po pwer" Elec-trical load rejection greater than 25%fuPlltelecrtricali lo2d-Reateto40p---V \V/*V IlMonth 20XXLGS 3-64EP-AA-1008 (Revision XX) l=l(Alnn Limeric~k fleneratinn Staition Annex Exelnn NucleInarRECOGNITION CATEGORYSYSTEM MALFUNCTIONSTable M2 Significant Transients" Automatic or Manual Runback > 25% thermal reactor power" Electrical Load Rejection > 25% full electrical load" Reactor Scram" ECCS Actuation* Thermal Power oscillations > 10%Basis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses the difficulty associated with monitoring rapidly changing plantconditions during a transient without the ability to obtain SAFETY SYSTEM parametersfrom within the Control Room. During this condition, the margin to a potential fissionproduct barrier challenge is reduced. It thus represents a potential substantialdegradation in the level of safety of the plant.As used in this EAL, an "inability to monitor" means that values for ne er mer-eany of Ithe listed parameters cannot be determined from within the Control Room. Thissituation would require a loss of all of the Control Room sources for the givenparameter(s). For example, the reactor power level cannot be determined from anyanalog, computer point, digital and recorder source within the Control Room.An event involving a loss of plant indications, annunciators and/or display systems isevaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022)to determine if an NRC event report is required. The event would be reported if itsignificantly impaired the capability to perform emergency assessments. In particular,emergency assessments necessary to implement abnormal operating procedures,emergency operating procedures, and emergency plan implementing proceduresaddressing emergency classification, accident assessment, or protective actiondecision-making.This EAL is focused on a selected subset of plant parameters associated with the keysafety functions of reactivity control, RPV-leve!RPV water level and RCS heat removal.Month 20XXLGS 3-65EP-AA-1008 (Revision XX)

Limerick Generating Station AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSThe loss of the ability to determine oeo r. mereany of these parameters from within theControl Room is considered to be more significant than simply a reportable condition.In addition, if all indication sources for one O-r mreany of the listed parameters are lost,then the ability to determine the values of other SAFETY SYSTEM parameters may beimpacted as well. For example, if the value for RPV water level cannot be determinedfrom the indications and recorders on a main control board, the SPDS or the plantcomputer, the availability of other parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.Escalation of the emergency classification level would be via ICs FS1 or IC RAS1.Basis Reference(s):1. NEI 99-01 Rev 6, SA22. DBD L-T-06, Human Factors, Section 6.1.13. T-101 RPV Control4. T-102 Primary Containment Control5. ON-122, Loss of Main Control Room Annunciators -BasesMonth 20XXLGS 3-66EP-AA-1008 (Revision XX)

I=YAInn Limeric~k (GAneratinn Station Annex Fxuainn Nucler~kRECOGNITION CATEGORYSYSTEM MALFUNCTIONSInitiating Condition:UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:1,2,3Emergency Action Level (EAL):MSU421Note: The Emergency Director should declare the Unusual Event vent promptly upondetermining that the applicable time 1-5 -inutes-has been exceeded, or will likelybe exceeded.a- AR-UNPLANNED event results in the inability to monitor onO or- moeANY Table M1parameters from within the Control Room for > 15 minutes.Table M1 Control Room Parameters* Reactor Power" RPV Water Level* RPV Pressure" Drywell Pressure* Suppression Pool Level* Suppression Pool Temperature* --.t JLL -- t--ll .... !---OT inn milowna nirnmoiornfrom wnnin m alonrlKo ri~mn~EfOF 'Rgef------------------2. [B WR par~mct 3. 142WR parametcr4. Rea.tor Pwe 6. Reactor- Power-8. -RPVN Waterp L" 9. -R CESh L e: IK10-. _RPA -Pressurce 11. RCS PrEessur-e42. P 1a~ 13.In COre/CorcCeetonmentExit TemperatureiI ss~u 014. Suppression Pol5. Ll;'cs in at ....tLeve (site speeil1 6. Supprcssion Poo 17. St-a-m GCenerator-empe,.twe Aui,.tle or-___e___en FeeadI ~ ~ ~ ~ ~ ~ ~ ~ ~ atv YJA,*I Month 20XXLGS 3-67EP-AA-1008 (Revision XX)

I imarink rtanarnfinn Afnfinn AnnoyI imrirk (c~n~ntin ~~tin Anc~~Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSBasis:UNPLANNED: A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient. The cause of the parameterchange or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.This IC addresses the difficulty associated with monitoring normal plant conditionswithout the ability to obtain SAFETY SYSTEM parameters from within the ControlRoom. This condition is a precursor to a more significant event and represents apotential degradation in the level of safety of the plant.As used in this EAL, an "inability to monitor" means that values for eone OFr mereany ofthe listed parameters cannot be determined from within the Control Room. Thissituation would require a loss of all of the Control Room sources for the givenparameter(s). For example, the reactor power level cannot be determined from anyanalog, digital and recorder source within the Control Room.An event involving a loss of plant indications, annunciators and/or display systems isevaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1 022)to determine if an NRC event report is required. The event would be reported if itsignificantly impaired the capability to perform emergency assessments. In particular,emergency assessments necessary to implement abnormal operating procedures,emergency operating procedures, and emergency plan implementing proceduresaddressing emergency classification, accident assessment, or protective actiondecision-making.This EAL is focused on a selected subset of plant parameters associated with the keysafety functions of reactivity control, core cooling and RCS heat removal. The loss ofthe ability to determine eone Or mereany of these parameters from within the ControlRoom is considered to be more significant than simply a reportable condition. Inaddition, if all indication sources for one er-moreany of the listed parameters are lost,then the ability to determine the values of other SAFETY SYSTEM parameters may beimpacted as well. For example, if the value for reactor vessel level cannot bedetermined from the indications and recorders on a main control board, the SPDS or theplant computer, the availability of other parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.Escalation of the emergency classification level would be via IC MSA42-.Month 20XXLGS 3-68EP-AA-1008 (Revision XX)

Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONSBasis Reference(s): .1. NEI 99-01 Rev 6, SU22. DBD L-T-06, Human Factors, Section 6.1.13. T-101 RPV Control4. T-102 Primary Containment Control5. ON-122, Loss of Main Control Room Annunciators -BasesMonth 20XXLGS 3-69EP-AA-1008 (Revision XX)

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