ML14164A064: Difference between revisions

From kanterella
Jump to navigation Jump to search
(Created page by program invented by StriderTol)
(Created page by program invented by StriderTol)
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:}}
{{#Wiki_filter:ATTACHMENT 5DISCUSSION OF REVISIONTO THERADIOLOGICAL EMERGENCY PLAN ANNEXFORDRESDEN NUCLEAR POWER STATIONEP-AA-1004 Enclosures S0SEnclosure 5A -EAL Comparison Matrix DocumentEnclosure 5B -EAL Red-Line Basis DocumentEnclosure 5C -EAL Basis Document NEI 99-01REVISION 6DEVELOPMENT OF EMERGENCY ACTIONLEVELS FOR NON-PASSIVE REACTORSAIrrACHMENT 5DISCUSSION OF REVISION TO THE RADIOLOGICAL EMERGENCY PLAN ANNEX FORDRESDEN STATIONExelon Generation.
00NEI 99-01 Rev 6 1 Proposed EAL I Justification AGIInitiating Condition
-GENERAL EMERGENCY Release 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 1,000mRem TEDE or 5,000 mRem thyroid CDE.Operating Mode Applicability:
1,2,3.4,5,D Emergency Action Level (EAL):Notes:The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.Classification based on effluent monitor readings assumes that a release 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. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs >7.90 E+09 uCilsec for > 15 minutes (as determined by DOP 1700-10 orPPDS -Total Noble Gas Release Rate).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 mRihr are expected tocontinue for > 60 minutes.ORb. Analyses of field survey samples indicate
> 5000 mRem CDEThyroid for 60 minutes of inhalation.
H: No Change 111 Difference FIDeviation
: 1) Listed site-specific monitors and Threshold values to ensure timelyclassification.
: 2) Added the following to 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 1 of66 0NEI 99-01 Rev 6 1 Proposed EAL Justification ASIInitiating Condition
-SITE AREA EMERGENCY Release 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 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 100 mR/hr 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,D Emergency Action Level (EAL):Notes:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
I 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.
: 1. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs> 7.90 E+08 uCilsec for > 15 minutes (as determined by DOP 1700-10 orPPDS -Total Noble Gas Release Rate).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.
No Change FIDifference I-1 Deviation
: 1) Listed site-specific monitors and Threshold values to ensure timelyclassification.
: 2) Added the following to 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 1x17 procedure matrix used by the SM.Page 2 of 66 NEI 99-01 Rev 6 [ Proposed EAL [ Justification AA1Initiating Condition
-ALERTRelease of gaseous or liquid radioactivity resulting in offsite dose greater than 10mrem TEDE or 50 mrem thyroid CDE.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 EALt #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 and 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 determining that the applicable time has been exceeded, or will likely be exceeded.
If an ongoing release is detected and the release start time is unknown, 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. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs> 7.90 E+07 uCi/sec for_> 15 minutes (as determined by DOP 1700-10 orPPDS -Total Noble Gas Release Rate).OR2. Dose assessment using actual meteorology indicates doses at or beyond thesite boundary of EITHER:a. > 10 mRemTEDEORb. > 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 (closed window) dose rates > 10 mR/hr areexpected to continue for> 60 minutes.ORb. Analyses of field survey samples indicate
> 50 mRemCDE Thyroid for 60 minutes of inhalation.
D-- No Change 1-- Difference
[I] Deviation
: 1) Listed site-specific monitors and Threshold values to ensure timely classification.
: 2) Added the following to 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 11x17 procedure matrix used by the SM.3) A calculation was performed, in accordance with (IAV) 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 [ Proposed EAL Justification AU1Initiating Condition
-UNUSUAL EVENTRelease of gaseous or liquid radioactivity greater than 2 times the (site-specific effluent 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 selpoint established by a current radioactivity discharge permit for60 minutes or longer.3. Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times (site-specific effluent releasecontrolling document limits) for 60 minutes or longer.RU1Initiating Condition:
Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for60 minutes 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 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, assumethat the release duration has exceeded 60 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.
: 1. Reading on ANY of the following effluent monitors
> 2 times alarmsetpoint established by a current radioactive release discharge permitfor ? 60 minutes.* Radwaste Effluent Monitor 213-2001-948 OR* Discharge Permit specified monitorOR2. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs> 9.02 E+05 uCi/sec for > 60 minutes (as determined by DOP 1700-10 orPPDS -Total Noble Gas Release Rate).OR3. Confirmed sample analyses for gaseous or liquid releases indicateconcentrations or release rates > 2 times ODCM Limit with a releaseduration of > 60 minutes.D No Change E Difference
[I] Deviation
: 1) Listed site-specific monitors and Threshold values to ensure timely classification.
: 2) Added the following to 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 lx17 procedure matrix used by the SM.Page 4 of 66 NEI 99-01 Rev 6 Proposed EAL Justification AG2 RG2DANo ChangeDifference
--]Deviatton Initiating Condition
-GENERAL EMERGENCY 1 No ChangeSpent fuel pool level cannot be restored to at least (site-specific Level 3description) for 60 minutes or longer.1) EAL not used in accordance with the discussion in Section 1.4, NRC OrderOperating Mode Applicability:
All EA-12-051, it is recommended that this EAL be implemented when the enhancedspent fuel pool level instrumentation is available for use. The completion of theExample Emergency Action Levels: enhanced SFP level indicators and need for the inclusion of this EAL is beingtracked in accordance with Exelon Generation
: Company, LLC's Initial StatusNOTES: The Emergency Director should declare the General Emergency Report to March 12, 2012 Commission Order Modifying Licenses with Regard forpromptly upon determining that 60 minutes has been exceeded, Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) datedor will likely be exceeded October 25,2012.1. Spent fuel pool level cannot be restored to at least (site-specific Level 3description) for 60 minutes or longer.Page 5 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition
-SITE AREA EMERGENCY No Change Difference Deviation Spent 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-12-051, it is recommended that this EAL be implemented when the enhancedOperating Mode Applicability:
Al 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 NEI 99-01 Rev 6 Proposed EAL Justification AA2RAInitiating Condition
-ALERT gRA2 F No Change Difference Deviation Significant lowering of water level above, or damage to, irradiated fuel. Significant lowering of water level above, or damage to, irradiated fuel. 1) Listed site-specific monitors and Threshold values t0 ensure timely classification.
Operating Mode Applicability:
Ail 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-1 2-051, 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. The completion of theenhanced SFP level indicators and need for the inclusion of this EAL is being1. Uncovery of irradiated fuel in the REFUELING PATHWAY.
: 1. Uncovery of irradiated fuel in the REFUELING PATHWAY.
tracked in accordance with Exelon Generation
: Company, LLC's Initial StatusOR Report to March 12, 2012 Commission Order Modifying Licenses with Regard for2. Damage to irradiated fuel resulting in a release of radioactivity from the Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) datedfuel as indicated by ANY of the following radiation monitors:
: 2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel October 25,2012.as indicated by ANY Table R1 Radiation Monitor reading >1000 mRemlhr.(site-specific listing of radiation
: monitors, and the associated
: readings, Table RIsetpoints and/or alarms) Fuel Handling Incident Radiation Monitors3. Lowering of spent fuel pool level to (site-specific Level 2 value).
* Refuel Floor High Range ARM Station #2(4).Fuel Pool Radiation MonitorPage 7 of 66 NEI 99-01 Rev 6 Proposed EAL Justification AU2Initiating Condition:
UNUSUAL EVENTUNPLANNED loss of water level above irradiated fuel.Operating Mode Applicability:
AllExample Emergency Action Levels:1. a. UNPLANNED water level drop in the REFUELING PATHWAY asindicated by ANY of the following:
(site-specific level indications).
ANDb. UNPLANNED rise in area radiation levels as indicated by ANY of thefollowing radiation monitors.
(site-specific list of area radiation monitors)
RU2Initiating 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 level drop in the REFUELING PATHWAY as indicated byANY of the following:
" Refueling Cavity water level < 466 in. (Refuel Outage ReactorVessel and Cavity Level Instrument LI 2(3)-263-114)
OR" Spent Fuel Pool water level < 19 ft. above the fuel (< 33 ft. 9 in.indicated level).OR" Indication or report of a drop in water level in the REFUELING PATHWAY.ANDb. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors inTable R1.E No Change [: Difference
[: Deviation
: 1) Listed site specific level indication and monitors to ensure timelyclassification.
Table RIFuel Handling Incident Radiation MonitorsI* Refuel Floor High Range ARM Station #2(4).Fuel Pool Radiation MonitorIPage 8 of 66 NEI 99-01 Rev 6 1 Proposed EAL [ Justification AA3Initiating 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 iswarranted
: 1. Dose rate greater than 15 mR/hr in ANY of the following areas:* Control Room* Central Alarm Station* (other site-specific areas/rooms)
: 2. An UNPLANNED event results in radiation levels that 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 R3 was already inoperable, or outof service, before the event occurred, then no emergency classification is warranted.
: 1. Dose rate> 15 mR/hr in ANY of the following Table R2 areas:E No Change D:1 Difference 1 Deviation
: 1) Listed site specific plant rooms and areas with identified mode applicability toensure timely classification.
Table R2Areas Requiring Continuous Occupancy
" Main Control Room (Unit 2 ARM Station #22)" Central Alarm Station -(by survey)OR2. UNPLANNED event results in radiation levels that prohibit or significantly impede access to ANY of the following Table R3 plant rooms or areas:Table R3Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Reactor Building*
Modes 3, 4, and 5*Areas required to establish shutdown coolingPage 9 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SU3RU3 I-- No Change Difference U Deviation Initiating Condition:
UNUSUAL EVENT Initiating Condition:
Reactor coolant activity greater than Technical Specification allowable limits. Reactor coolant activity greater than Technical Specification allowable limits. 1) Listed site-specific monitor and threshold value to ensure timely classification.
Operating Mode Applicability:
Operating Mode Applicability:
: 2) Listed this system category EAL in the radiological category EAL section 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. Offgas system radiation monitor HI-HI alarm.OR OR2. Sample analysis indicates that a reactor coolant activity value is greater than 2. Specific coolant activity
> 4.0 uCilgm Dose equivalent 1-131.an allowable limit specified in Technical Specifications.
Page 10 of 66 0 0 0NEI 99-01 rev 6 Fission Product Barrier Matrix_________________
Prdc Barrier________
Mari Hot__________
MaFGI Loss of any two barriers AND Loss or Potential Loss of third barrier.1,2,3FSI Loss or Potential Loss of ANY two barriers.
1,2,3FAl ANY Loss or ANY Potential Loss of either Fuel Clad or RCS1.2,3FC -Fuel Clad RC -Reactor Coolant System CT -Containment Sub-Category Loss Potential Loss Loss Potential Losa Loss Potential Loss1. RCS Activity
/ A. UNPLANNED rapid drop in primary A. Primary containment pressure greater1.imar RCS (Sie scontainment pressure following than (site-specific value)Containment A. Primary containment Pressure primary containment pressure rise ORPressure
/ reator coolant activity is greater None greater than (site-specific value) None OR B. (site-specific explosive mixture) existsthan 300 uCilgm dose equivalent due to RCS leakage.
inside primary containment Prmr -3)B. Primary containment pressure isd rmr otimnContainment 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 water 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 downstream pathway to the environment existsafter primary containment isolation signalORA. UNISOLABLE primary system leakageA. UNISOLABLE break in any of the that results in exceeding EITHER of .Intentional primary containment 3.RCS Leak Rate/ following:
( site-specific systems with the following:
venting per EOPsPrimary None None potential for high-energy line breas) 1. Max Normal Operating OR NoneContainment OR Temperature C. UNISOLABLE primary systemIsolation Failure B. Emergency RPV DepressuizationOR leakage that results in exceeding
: 2. Max Normal Operating Area EITHER of the following:
Radiation Level. 1. Max Safe Operating Temperature.
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-specific Radiation (site-specific value), specific value). value).A. Any Condition in the opinion of A Any Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the5. Emergency the Emergency Director that Emergency Director that indicates Emergency Director that indicates Loss Emergency Director the iniofte A.rAny Coedton in at indicates Loss Emergency Director that indicates Potential Director Judgment indicates Loss of the Fuel Clad Potential Loss of the Fuel Clad Barrier.
of the RCS Barrier.
Potential Loss of the RCS Barrier.
of the Containment Barrier.
Loss of the Containment Barrier.Barrier.Page 11 of 66 Proposed Fission Product Barrier MatrixFission~~
ProducBarrirMatixHotMatri FGI Loss of any two barriers AND Loss or Potential Loss of third barrier.(1[]91A I FSS Loss or Potential Loss of ANY two barriers.
E1IgA I PAl ANY Loss or ANY Potential Loss of either Fuel Clad or RCS 19]9FC -Fuel Clad RC -Reactor Coolant System CT -Containment Sub-Categery Loss Potential Loss Loss Potential Lose Loss Potential LossCoolant activity 300 uCligm Dose None NoneI RCS Activity Equivalent 1-131. None None None2. RPV water level cannot be restored and 1. RPV water level cannot be restored and1. Primary containment flooding is maintained
, .143 inches (TAF) maintained
> -143 Inches (TAF) Prmary containment flooding is required.
: 2. RPV Waler required OR OR None Noneeve 3. RPV water level cannot be determined.
: 2. RPV water level cannot be determined.
: 3. Drywell pressure
_ 62 pslg and nsing.OR1. Drywell pressure
>2.0 psig. 1. UNPLANNED rapid drop in Drywell 4. a. Drywall or tows hydrogen concentration
: 3. Primary AND pressure following Drywell pressure rise &#xfd; 6%.Contaiment NnD OR ANDon tainment None None 2. Drywall pressure rise is due to RCS None 2. Drywall pressure response not consistent
: b. Drywell or tows oxygen concentration Prssure/Conditions leakage with LOCA conditions.
_5%.OR5. Heat Capacity Limit (DEOP 200-1, Fig.M)exceeded.
: 3. UNISOLABLE primary system leakage that1. UNISOLABLE Main Steam Line results in EITHER of the following:
(MSL),Isolation Condenser, HPCI. a. Secondary Containment areaFeedweter, or RWCU line break. temperature 0 DEOP 300-1 Maximum4.RCS Leak Rate None None OR Normal operating levels. Nose NoneORRS eNonateNneNoeoRneO
: 2. Emergency RPV Depressuedzaon is b. Secondary Containment radiation levelrequired.
> DEOP 300-1 Maximum Normaloperating level.5,Primary Drywell radiation monitor reading Drywell radiation monitor reading Drywell radiation monitor readingContainment 0 6.70 E+02 R/hr (670 RIhr). None > 100R/hr (>1.00 E+02 R/hr). None None > 1.60 E+03 R/hr (1600 R/hr)Radiation
: 1. UNISOLABLE direct downstream pathway tothe environment exists after primarycontainment isolation signal.OR2. Intentional Primary Containment venting/purging per EOPs or SAGs due toaccident conditions.
ORC. Primary 3. UNISOLABLE primary system leakage thatCnanet None None Nose None UNSLEENone sontainmen results in EITHER of the following:
ation Failure a. Secondary Containment areatemperature s DEOP 300-1,Maximum Safe operating levels.ORb. Secondary Containment arearadiation level s DEOP 300-1,Maximum Safe operating levels.7. Emergency A. Any Condition in the opinion of the A. Any Condition in the opinion of the A. ANY Condition in the opinion of the A. Any Condition in the opinion of the A Any Condition in the opinion of the A. Any Condition in the opinion of the Emergency 7.Eergen 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 Barrer. Loss of the RCS Barrier.
Containment Barrier.
Containment Banrer.Page 12 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:
Fuel Clad Barrier FCi Category:
Fuel Clad BarrierC No Change Diffence Deviation RCS Activity 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. (Site specific indications that reactor coolant activity is greater than 300 uCi/gm Coolant activity
> 300 uCllgm Dose Equivalent 1-131.dose equivalent 1-131)Page 13 of 66 NEI 99-01 Rev 6 Proposed EAL Justification FC2Category:
Fuel Clad BarrierRPV Water LevelOperating Mode Applicability:
Power Operation,
: Startup, Hot Standby, Hot ShutdownFission Product Barrier Threshold:
LossA. Primary containment flooding required.
Potential LossA. RPV water level cannot be restored and maintained above (site-specific RPVwater level corresponding to top of active fuel) or cannot be determined.
Category:
Fuel Clad BarrierRCS ActivityOperating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
Loss1. Plant conditions indicate Primary Containment flooding is required.
Potential Loss2. RPV water level cannot be restored and maintained
> -143 inches (TAF)OR4. RPV water level cannot be determined.
FC2[fl No Change 1 Difference 1 Deviation
: 1) Listed site-specific threshold value to ensure timely classification.
Page 14 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:
Fuel Clad Barrier FC4 Category:
Fuel Clad Barrier FC5 E No Change Difference Deviation Primary 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 > 6.70 E+02 RWhr (670 R/hr).value).Page 15 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:
Fuel Clad Barrier FC6 Category:
Fuel Clad Barrier FC7 No Change Differene
[ Deviation Emergency 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.Poteritial 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 Potential Loss of the Fuel Clad Barrier.
Loss of the Fuel Clad Barrier.Page 16 of 66 NEI 99-01 Rev 6 Proposed EAL Justification NEI 99-01Rev 6Proposed EALJustification iRCICategory:
Reactor Coolant System BarrierPrimary Containment PressureOperating Mode Applicability:
Power Operation,
: Startup, Hot Standby, Hot ShutdownFission Product Barrier Threshold:
LossA. Primary containment pressure greater than (site-specific value) due to RCSleakage.RC3Category:
Reactor Coolant System BarrierPrimary Containment Pressure/Conditions Operating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
Loss1. Drywell pressure
>2.0 psig.AND2. Drywell pressure rise is due to RCS leakage.E No Change 1 Difference 1 Deviation
: 1) Listed site-specific threshold value to ensure timely classification.
Page 17 of 66 NEI 99-01 Rev 6RC2Category:
Reactor Coolant System BarrierRPV Water LevelOperating Mode Applicability:
Power Operation,
: Startup, Hot Standby, Hot ShutdownFission Product Barrier Threshold:
LossA. RPV water level cannot be restored and maintained above (site-specific RPVlevel corresponding to the top of active fuel) or cannot be determined.
Proposed EALJustification RC2Category:
Reactor Coolant System BarrierRPV Water LevelOperating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
Loss1. RPV water level cannot be restored and maintained
> -143 inches (TAF).OR2. RPV water level cannot be determined.
No Change --' Difference 1 Deviation
: 1) Listed site-specific threshold value to ensure timely classification.
Page 18 of 66 NEI 99-01 Rev 6 Proposed EAL Justification RC R4l-Xi- NO Change II Difference II Deviation Category:
Reactor Coolant System Barrier Category:
Reactor Coolant System Barrier LECD.eiRCS 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), Isolation Condenser, HPCI, Feedwater, for high-energy line breas) or RWCU line break.OR ORB. Emergency RPV Depressurization
: 2. Emergency RPV Depressurization is required.
Potential LossA. UNISOLABLE primary system leakage that results in exceeding EITHER of the Potential Lossfollowing:
: 1. Max Normal Operating Temperature.
: 3. UNISOLABLE primary system leakage that results in EITHER of the following:
OR a. Secondary Containment area temperature
> DEOP 300-1 Maximum2. Max Normal Operating Area Radiation Level. Normal operating levels.ORb. Secondary Containment area radiation level > DEOP 300-1 MaximumNormal operating levels.Page 19 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:
Reactor Coolant System Barrier RC4 Category:
Reactor Coolant System Barrier RC5 E No Change Difference Deviation Primary 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 > 100 R/hr (>1.00E+02 R/hr).value).Page 20 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:
Reactor Coolant System Barrier RC6 Category:
Reactor Coolant System Barrier RC7 No Change Difference Deviation Emergency 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 Potential Loss of the RCS Barrier.
: 2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.Page 21 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:
Containment Barrier CTI Category:
Containment BarrierC No Change Difference Deviation Primary Containment Conditions Primary Containment Pressure/Conditions 1 ) Listed site-specific threshold values to ensure timely classification.
Operating Mode Applicability:
Operating Mode Applicability:
: 2) The words "and rising" were added to account for the momentary spike inPower Operation,
: Startup, Hot Standby, Hot Shutdown 1,2,3 pressure where pressure is now lowering, the risk of a potential loss ofcontainment is no longer present, this wording is also consistent with present EALFission Product Barrier Threshold:
Fission Product Barrier (FPB) Threshold, wording.Loss LossC. UNPLANNED rapid drop in primary containment pressure following primary 1. UNPLANNED rapid drop in Drywell pressure following Drywell pressure rise.containment pressure rise OROR2. Drywell pressure response no._t 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)OR 3. Containment pressure
> 62 pslg and rising.E. (site-specific explosive mixture) exists inside primary containment OROR 4. a. Drywell or torus Hydrogen concentration
> 6%.3. HCTL exceeded.
ANDb. Drywell or torus Oxygen concentration
> 5%.OR5. Heat Capacity Limit (DEOP 200-1, Fig. M) exceeded.
Page 22 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:
Containment Barrier CT2 Category:
Containment Barrier CT2 No Change Difference
[-1 Deviation RPV 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 Ccontainment flooding is required.
Page 23 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CT3 CTS IN hne [ ifeec eitoCategory:
Containment Barrier Category:
Containment Barrier C No Change Difference Deviation Primary 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 ORB. Intentional primary containment venting per EOPs 2. Intentional Primary Containment venting/purging per EOPs or SAMGs due toOR accident conditions.
C. UNISOLABLE primary system leakage that results in exceeding EITHER of the ORfollowing:
: 3. UNISOLABLE primary system leakage that results in EITHER of the following:
: 1. Max Safe Operating Temperature.
: a. Secondary Containment area temperature
> DEOP 300-1, MaximumOR Safe operating levels.2. Max Safe Operating Area Radiation Level. ORb. Secondary Containment area radiation level > DEOP 300-1, MaximumSafe operating levels.Page 24 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:
Containment Barrier CT4 Category:
Containment Barrier CT5 E No Change Difference Deviation Primary 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-specific value). Drywall radiation monitor reading > 1.60 E+03 R/hr (1600 R/hr).Page 25 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:
Containment Barrier CTS Category:
Containment Barrier CT7 No Change Difference
[] Deviation Emergency 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 Loss of the Containment Barrier.
: 2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.Page 26 of 66 NEI 99-01 Rev 6 Proposed EAL Justification 301 MG1 lInitiating Condition:
GENERAL EMERGENCY Initiating Condition:
[Gj No Change LJ Difference
[j Deviation Prolonged loss of all offsite and all onsite AC power to emergency buses. Prolonged loss of all offsite and all onsite AC power to emergency buses.1) Listed site specific equipment, site specific time based on station 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-specific emergency buses).1 Loss of ALL offsite AC power to unit ECCS buses.AND AND2. Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency dieselb. EITHER of the following:
generators to supply power to unit ECCS 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 ECCS bus in < 4 hours is not likely." (Site-specific indication of an inability to adequately ORremove heat from the core)b. RPV water level cannot be restored and maintained
> -164 inches.Page 27 of 66 0NE199-01 Rev 6 Proposed EAL [Justification Initiating Condition:
SITE AREA EMERGENCY Loss 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 Emergency promptly 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 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.
: 1. Loss of ALL offsite AC Power to unit ECCS buses.AND2. Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency dieselgenerators to supply power to unit ECCS buses.AND3. Failure to restore power to at least one ECCS bus in < 15 minutes from the timeof loss of both offsite and onsite AC power.M No Change FIDifference 1 Deviation
: 1) Listed site specific equipment to ensure timely classification.
Page 28 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification SA1IInitiating 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 determining 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.MA1IInitiating 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 ECCS buses reduced to only one of the following power sources for > 15 minutes.* Reserve auxiliary Transformer TR-22 (TR-32)* Unit auxiliary transformer TR-21 (TR&#xfd;31)* Unit Emergency Diesel Generator DG 2(3)* Shared Emergency Diesel Generator DG 2/3* Station Blackout Diesel Generator DG 2(3)* Unit crosstie breakersAND2. ANY additional single power source failure will result in a loss of ALL AC powerto SAFETY SYSTEMS.M No Change ] Difference FIDeviation
: 1) Listed site specific equipment to ensure timely classification.
Page 29 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification Su1Initiating 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 longerMUlInitiating 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 buses for > 15 minutes.F No Change -Difference 7 Deviation
: 1) Listed site specific equipment to ensure timely classification.
Page 30 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SG8Initiating Condition:
GENERAL EMERGENCY Loss 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 emergency buses) for 15 minutes or longer.ANDIndicated voltage is less than (site-specific bus voltage value) on ALL(site-specific vital DC buses) 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 ECCS buses.AND2. Failure of DG 2(3), shared DG 2(3) and SBO DG 2(3) emergency dieselgenerators to supply power to vital buses.AND3. Voltage is < 105 VDC on 125 VDC battery buses #2 and #3.AND4. ALL AC and Vital DC power sources have been lost for> 15 minutes.1 '1 No Change M Difference 1-- Deviation
: 1) 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 Justification SS8Initiating Condition:
SITE AREA EMERGENCY Loss 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 Emergency promptly 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:
1,2,3D] No Change F Difference FIDeviation
: 1) 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.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.
Voltage is < 105 VDC on 125 VDC battery buses #2 and #3 for >15 minutes.Page 32 of 66 NEI 99-01 Rev 6 [ Proposed EAL I Justification SS5Initiating Condition:
SITE AREA EMERGENCY Inability to shutdown the reactor causing a challenge to (core cooling [PWR] / RPVwater level [BWR]) or RCS heat removal.Operating Mode Applicability:
Power Operation Example Emergency Action Levels:1. a. An automatic (trip [PVVRj / scram [BVVR]) 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 adequately remove heat from the core)OR2. (Site-specific indication of an inability to adequately remove heat from the RCS)MS3Initiating 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> 6%.AND2. ALL manual / ARI actions to shutdown the reactor have been unsuccessful asindicated by Reactor Power > 6%.AND3. EITHER of the following conditions exist:" RPV water level cannot be restored and maintained
> -164 inches.OR" Heat Capacity Limit (DEOP 200-1, Fig. M) exceeded.
D- No Change M Difference D Deviation
: 1) 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 Proposed EAL Justification SA5Initiating 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 Operation Example 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.
I. a. An automatic (trip [PWR] / 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 > 6%.AND2. Manual I ARI actions taken at the reactor control consoles are not successful in shutting down the reactor as indicated by Reactor Power > 6%.D- No Change FIDifference 1'1 Deviation
: 1) 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 1 Proposed EAL I Justification SU5Initiating Condition:
UNUSUAL EVENTAutomatic or manual (trip [PWR] / scram [BWR]) fails to shutdown the reactor.Operating Mode Applicability:
Power Operation Example 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 [BWR]) 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 [BWR]) 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 successful in shutting down the reactor.MU3Initiating Condition:
Automatic or manual scram fails to shutdown the reactor.Operating Mode Applicability:
FH No Change M Difference 1 Deviation 1 ) 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 > 6%..ANDb. Subsequent manual / ARI action taken at the reactor control consoles issuccessful in shutting down the reactor.OR2. a. Manual scram did not shutdown the reactor as indicated by ReactorPower > 6%.ANDb. EITHER of the following:
: 1. Subsequent manual / ARI action taken at the reactor controlconsoles is successful in shutting down the reactor.OR2. Subsequent automatic scram / ARI is successful in shutting down thereactor.Page 35 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SA2MA4Initiating 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 one or more of thefollowing parameters from within the Control Room for 15 minutes or longer.[see table below][ SWR parameter list] [PWR parameter list]Initiating 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 MI parameter from within the Control Room for >15 minutes.M No Change FIDifference FIDeviation Reactor Power Reactor PowerRPV Level RCS LevelRPV Pressure RCS PressurePrimary Containment Pressure In Core/Core Exit Temperature Levels in at least (site specificSuppression Pool Level number) steam generators Steam Generator Auxiliary orSuppression Pool Temperature Emergency Feed Water FlowTable M1 Control Room Parameters
" Reactor Power" RPV Water Level* RPV Pressure* Primary Containment Pressure* Torus Level* Torus Temperature AND 12. ANY Table M2 transient in progress.
ANDb. 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
" Turbine Trip" Reactor Scram" ECCS Activation
" Recirc. Runback > 25% Reactor Power Change" Thermal Power oscillations
> 10% Reactor Power ChangePage 36 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SU2Initiating 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 one or more of thefollowing parameters 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 Temperature Levels in at least (site specificSuppression Pool Level number) steam generators Steam 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 parameter from within the Control Room for > 15 minutes.F] No Change FIDifference FIDeviation Table M1 Control Room Parameters
* Reactor Power* RPV Water Level* RPV Pressure* Primary Containment Pressure* Torus LevelTorus Temperature Page 37 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SA9MA6Initiating Condition:
ALERTInitiating Condition:
ALERTIF1 No Change FX Difference F] Deviation Hazardous event affecting a SAFETY SYSTEM needed for the current operating mode.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 performance in 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.Hazardous event affecting a SAFETY SYSTEM required for the current operating mode.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 determined 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 Specification for the currentoperating mode.ORb. The event has caused VISIBLE DAMAGE to a SAFETYSYSTEM component or structure required by Technical Specification for the current operating mode.1) No additional site specific hazard noted2) Changed the word "needed" to "required" in the IC and to "required by Technical Specification" in the EAL, to be consistent with terminology used by operators andminimize confusion.
Page 38 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification SU4Initiating 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-specific value) 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:
1,2,3Emergency 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. RCS unidentified or pressure boundary leakage in the Drywell > 10 gpm for> 15 minutes.OR2. RCS identified leakage in the Drywell >25 gpm for> 15 minutes.OR3. Leakage from the RCS to a location outside the Drywell >25 gpm for> 15 minutes.F-H No Change F IDifference FIDeviation 1 ) 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.
Page 39 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification SUBInitiating Condition:
UNUSUAL EVENTLoss of all onsite or offsite communications capabilities Operating 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)MU7Initiating Condition:
Loss of all onsite or offsite communication capabilities.
Operating Mode Applicability:
1,2,3H No Change F Difference F Deviation
: 1) Listed site specific communication methods to ensure timely classification.
Emergency Action Level (EAL):1. Loss of ALLTable M3 Onsite communications capability affecting theability to perform routine operations.
OR2. Loss of ALL Table M3 Offsite communication capability affecting theability to perform offsite notifications.
OR3. Loss of ALL Table M3 NRC communication capability affecting the abilityto perform NRC notifications.
Table M3 Communications Capability System Onsite Offsite NRCPlant Radio XPlant Page XSound Powered Phones XAll telephone Lines (Commercial and X X Xmicrowave)
ENS X XHPN X XSatellite Phones X XPage 40 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CA2Initiating 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.CAIInitiating Condition:
Loss of all offsite and onsite AC power to emergency buses for 15 minutes or longer.Operating Mode Applicability:
4,5, DEmergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining that theapplicable time has been exceeded, or will likely be exceeded.
: 1. Loss of ALL offsite AC power to unit ECCS buses.AND2. Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency dieselgenerators to supply power to unit ECCS buses.AND3. Failure to restore power to at least one unit ECCS bus in < 15 minutes fromthe time of loss of both offsite and onsite AC power.No Change 1 Difference 1 Deviation
: 1) Listed site specific equipment to ensure timely classification.
Page 41 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CU2 CU1 -oCag -ifrne F- eitoInitiating Condition:
UNUSUAL EVENT Initang Condition:No Change Difference Deviation Loss of all but one AC power source to emergency buses for 15 minutes or longer. Loss of all but one AC power source to emergency buses for 15 minutes or 1) Listed site specific equipment to ensure timely classification.
Operating Mode Applicability:
longer.Cold Shutdown, Refueling, Defueled Operating Mode Applicability:
Example Emergency Action Levels: 4,5, DNote: The Emergency Director should declare the Unusual Event promptly upon Emergency Action Level (EAL):determining that 15 minutes time has been exceeded, or will likely be exceeded.
Note:1. a. AC power capability to (site-specific emergency buses) is reduced to a The Emergency Director should declare the event promptly upon determining thatsingle power source for 15 minutes or longer, the applicable time has been exceeded, or will likely be exceeded.
AND 1. AC power capability to unit ECCS buses reduced to only one of theb. Any additional single power source failure will result in loss of all AC following power sources for > 15 minutes.power to SAFETY SYSTEMS.
* Reserve auxiliary Transformer TR-22 (TR-32)* Unit auxiliary transformer TR-21 (TR-31)* Unit Emergency Diesel Generator DG 2(3)* Shared Emergency Diesel Generator DG 2/3* Station Blackout Diesel Generator DG 2(3)* Unit crosstie breakersAND2. ANY additional single power source failure will result in a loss of ALL ACpower to SAFETY SYSTEMS.Page 42 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CASInitiating Condition
-ALERTHazardous event affecting SAFETY SYSTEM needed for the current operating mode.Operating Mode Applicability:
Cold Shutdown, Refueling Example 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 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 operating mode.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 Technical Specifications for the current operating mode.D No Change E Difference Deviation
: 1) No additional site specific hazard noted2) Changed the word "needed" to "required" in the IC and to "required byTechnical Specification" in the EAL, to be consistent with terminology used byoperators and minimize confusion.
Page 43 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:
UNUSUAL EVENT Initiating Condition:
CU1 No Change Difference Deviation Loss 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 be The Emergency Director should declare the event promptly upon determining thatexceeded, the 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 buses #2 and #3for> 15 minutes.Page 44 of 66 NEI 99-01 Rev 6 1 Proposed EAL I Justification CU5Initiating Condition:
UNUSUAL EVENTLoss of all onsite or offsite communications capabilities Operating 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 C1 Offsite communication capability affecting theability to perform offsite notifications.
OR3. Loss of ALL Table C1 NRC communication capability affecting theability to perform NRC notifications.
Table Cl Communications Capability System Onsite Offsite NRCPlant Radio XPlant Page XSound Powered Phones XAll telephone Lines (Commercial and X X Xmicrowave)
ENS X XHPN X XSatellite Phones X XE No Change D ] Difference 1 Deviation
: 1) Listed site specific communications methods to ensure timely classification Page 45 of 66 0NEI 99-01 Rev 6 Proposed EAL Justification CA3 CABInitiating Condition:
ALERT Initiating Condition:
E No Change Difference Deviation Inability to maintain the plant in cold shutdown.
Inability to maintain plant in cold shutdown.
: 1) Listed site specific Technical Specification cold shutdown temperature limit 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 beexceeded.
The 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-specific Technical Specification cold shutdown temperature limit) for greater thanthe duration specified in the following table. 1. UNPLANNED rise in RCS temperature>
212rF 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.
[PWRJ) Table C2 RCS Heat-up Duration Thresholds Table: 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 Established 0 minutesNot 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 not* If 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 temperature rise due to loss of decay heat removal.Page 46 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:
UNUSUAL EVENT CU3 Initiating Condition:
CU5 No Change Difference Deviation UNPLANNED 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 consistent Example 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 determining be exceeded.
that the applicable time has been exceeded, or will likely be exceeded.
: 1. UNPLANNED increase in RCS temperature to greater than (site-specific Technical Specification cold shutdown temperature limit).2. Loss of ALL RCS temperature and (reactor vessel/RCS
[PWR] or RPV 1. UNPLANNED rise in RCS temperaturem>
212F due to loss of decay[BWR]) level indication for 15 minutes or longer. heat removal.OR2. Loss of the following for >15 minutes." ALL RCS temperature indications AND" ALL RPV water level indications Page 47 of 66 0NEI 9941 Rev 6 ] Proposed EAL Justification CGaInitiating Condition:
GENERAL EMERGENCY Loss of (reactor vessel/RCS
[PWR] or RPV [BWR]) inventory affecting fuel cladintegrity with containment challenged.
Operating Mode Applicability:
Cold Shutdown.
Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the General Emergency promptly upon determining that 30 minutes time has been exceeded, orwill likely be exceeded.
: 1. a. (Reactor vessel/RCS
[P/R] 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 [BW4R) 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
[P/R]* 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 RPV inventory affecting fuel clad integrity with containment challenged.
Operating Mode Applicability:
4,5Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
: 1. a. RPV water level < -143 inches (TAF) for > 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 coreuncovery.
OR* Refuel Floor Hi Range ARM >3000 mR/hr.ANDc. ANY Containment Challenge Indication (Table C4)LI No Change E Difference I: Deviation
: 1) 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 instances when 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 Torus level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory lossTable: Containment Challenge Table* CONTAINMENT CLOSURE not established*
* (Explosive mixture) exists inside containment
* UNPLANNED increase in containment pressure* Secondary containment radiation monitor reading above (site-specific value) [BWR]if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency isnot required.
*Rise in level is attributed to a loss of RPV inventory.
Table C4 Containment Challenge Indications
* Primary Containment Hydrogen Concentration
> 6% and Oxygen >5%* UNPLANNED rise in containment pressure* CONTAINMENT CLOSURE not established*
* ANY Secondary Containment radiation monitor > DEOP 300-1Maximum Safe operating level.if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency isnot required.
Page 48 of 66 NEI 9901 Rev 6 Proposed EAL Justification CSIInitiating Condition:
SITE AREA EMERGENCY Loss of (reactor vessel/RCS
[PWR] or RPV [BWR]) inventory affecting coredecay heat removal capability.
Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2 or 3)Note: The Emergency Director should declare the Site Area Emergency promptly upon determining that 30 minutes time has been exceeded, orwill likely be exceeded.
: 1. a. CONTAINMENT CLOSURE not established.
ANDb. (Reactor vessel/RCS
[PIVR] or RPV [BWR]) level less than (site-specific level).2. a. CONTAINMENT CLOSURE established.
ANDb. (Reactor vessel/RCS
[PVAR] or RPV [BWR]) level less than (site-specific level).3. a. (Reactor vessel/RCS
[PWR] or RPV [BWR]) 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 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 determining that the applicable time has been exceeded, or will likely be exceeded.
: 1. With CONTAINMENT CLOSURE not established, RPV water level<-60 inchesOR2. With CONTAINMENT CLOSURE established, RPV water level < -143inches (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" Refueling Floor Hi Range ARM >3000 mR/hr.Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Torus 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.
D No Change E Difference 1 Deviation
: 1) Listed site specific values for level, radiation
: monitors, and sumps and tanksto ensure timely classification.
: 2) EAL #1 Dresden Station does not have a low, low, low RPV water level valuestated within their Technical Specifications, all ESF functions come from thelow, low value of -54 inches, NEI 99-01 rev 6 developer notes for CS1 requestthe developer to use the low, low, low value for declaration of a SAE whenContainment Closure is not established, as such an RPV water level -60 incheswas selected as the threshold value since it is substantially above TAF RPVwater level of -143 inches and substantially below the low low value of -54.15clearly indicating a worsening of the condition and the need to escalate theemergency from an Alert condition,
: 3) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Page 49 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification CA1Initiating Condition:
ALERTLoss of (reactor vessel/RCS
[PWR] or RPV [BWRJ) inventory Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Alert promptly upondetermining that 15 minutes time has been exceeded, or witl 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 [BVVR]) 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 inventory Operating Mode Applicability:
4,5Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
: 1. Loss of RPV inventory as indicated by level < -54 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 Torus 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.
D- No Change E Difference El Deviation
: 1) Listed site specific levels, and sumps and tanks to ensure timelyclassification.
: 2) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Page 50 of 66 0NEI 99-01 Rev 6 Proposed EAL Justification Cu1Initiating Condition:
UNUSUAL EVENTUNPLANNED loss of (reactor vessel/RCS
[PWR] or RPV [BWR]) inventory for15 minutes or longer.Operating Mode Applicability:
Cold Shutdown, Refueling Example 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
[PIAR] 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 determining that the applicable time has been exceeded, or will likely be exceeded.
: 1. UNPLANNED loss of reactor coolant results in the inability to restore andmaintain RPV water level above the procedurally established lower limitfor > 15 minutes.OR2. a. RPV water level unknownANDb. Loss of RPV inventory per Table C3 indications.
Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Torus 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.
D No Change f Difference 1: Deviation
: 1) Described "a required lower limit" as a procedurally established lower limit,andlisted site specific sumps and tanks to ensure timely classification.
: 2) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Page 51 of66 NEI 99-01 Rev 6Proposed EALJustification NEI 99-01 Rev 6 Proposed EAL Justification 1 -1HG1HG1Initiating Condition:
GENERAL EMERGENCY HOSTILE 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 PROTECTED AREA 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 [PWR] / 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 occurring or has occurred within the PROTECTED AREA.AND2. a. ANY Table H1 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)F No Change M Difference 1 Deviation
: 1) 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 NEI199-01 Rev 6Proposed EALJustification NEI 99-01 Rev 6 Proposed EAL Justification HS1HSIInitiating Condition:
SITE AREA EMERGENCY HOSTILE ACTION within the Protected Area.Operating Mode Applicability:
Initiating Condition:
HOSTILE ACTION within the Protected Area.Operating Mode Applicability:
1, 2, 3,4, 5, DNo Change FIDifference
[IDeviation
: 1) List site security shift supervision as Security Force.AllExample Emergency Action Levels:A HOSITLE ACTION is occurring or has occurred within the PROTECTED AREAas reported by the (site-security shift supervision).
Emergency 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 1 Proposed EAL Justification HA1Initiating Condition:
ALERTHOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attackthreat within 30 minutes.Operating Mode Applicability:
AllExample Emergency Action Levels: (1 or 2)1. A HOSTILE ACTION is occurring or has occurred within the OWNERCONTROLLED AREA as reported by the (site-specific security shiftsupervision).
: 2. A validated notification from NRC of an aircraft attack threat within 30minutes of the site.HA1Initiating Condition:
HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attackthreat within 30 minutes.Operating Mode Applicability:
1,2,3,4,5,D Emergency Action Level (EAL):1. A validated notification from NRC of an aircraft attack threat < 30 minutesfrom the site.OR2. Notification by the Security Force that a HOSTILE ACTION is occurring orhas occurred within the OWNER CONTROLED AREA.No Change -Difference
-Deviation
: 1) List site security shift supervision as Security Force.Page 54 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HUI HUItInitiating Condition:
UNUSUAL EVENT Initiating Condition:
HUI No Change [j- Difference
[ Deviation Confirmed SECURITY CONDITION or threat.Confirmed SECURITY CONDITION or threat. 1) List site security shift supervision as Security Force.Operating 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-101-1 32, Security Assessment and Response to Unusual Activities.
: 2. Notification of a credible security threat directed at the site.OR3. A validated notification from the NRC providing information of an aircraft
: 2. A validated notification from the NRC providing information of an aircraftthreat, 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 Justification HS6 HS2Initiating Condition:
SITE AREA EMERGENCY Initiating Condition:
H No Change I Difference FIDeviation Inability to control a key safety function from outside the Control Room. Inability to control a key safety function from outside the Control Room. 1) EAL uses the site specific Control Room evacuation procedure to effectively list all of the alternate locations, panels, and stations requested by thedeveloper notes. This would be the procedure the Control Room would enterOperating Mode Applicability:
Operating Mode Applicability:
should such an event occur, this allows for greater clarity as to when this EALwould apply than if each panel and station used in alternate shutdown were toAll 1,2, 3, 4, 5, D be listed,2) Added descriptors to better explain each safety function and allow for aExample Emergency Action Levels: (1 and 2) Emergency Action Level (EAL): timely classification.
Note: The Emergency Director should declare the Site Area Emergency Note:promptly upon determining that (site-specific number of minutes) has 3) Changed "An event" to" A Control Room evacuation" to remove confusion ifbeen exceeded, or will likely be exceeded.
The Emergency Director should declare the event promptly upon determining that the partial plant control was transferred to outside the control room with the controlapplicable time has been exceeded, or will likely be exceeded.
room still staffed, due to testing or equipment failure.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 transferred from theControl Room to alternate locations per DSSP 0100-CR, Hot Shutdown Procedure
-2. Control of ANY of the following key safety functions is not reestablished Control Room Evacuation.
within (site-specific number of minutes).
AND* Reactivity control 2. Control of ANY Table H 1 key safety function is not reestablished in < 15 minutes.Core cooling [PWtR] / RPV water level [BWR]* RCS heat removalTable 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 Justification HA6 HA2Initiating Condition:
ALERT Initiating Condition:
F No Change M Difference L-J Deviation Control Room evacuation resulting in transfer of plant control to alternate locations.
Control Room evacuation resulting in transfer of plant control to alternate locations.
: 1) EAL uses the site specific Control Room evacuation procedure to effectively listall of the alternate locations, panels, and stations requested by the developer notes. This would be the procedure 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) 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 staffed, 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(site-specific remote shutdown panels and local control stations).
the Control Room to alternate locations per DSSP 0100-CR, Hot ShutdownProcedure
-Control Room Evacuation.
Page 57 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HU4Initiating Condition:
UNUSUAL EVENTFIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:
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 thefollowing 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 alarmANDb. The FIRE is located within ANY of the following plant rooms orareas:(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 orareas:(site-specific list of plant rooms or areas)ANDc. The existence of a FIRE is not verified within 30-minutes of alarmreceipt.3. A FIRE within the plant or ISFSI [for plants with an ISFSI outside theplant Protected Area] PROTECTED AREA not extinguished within 60-minutes of the initial report, alarm or indication.
: 4. A FIRE within the plant or ISFSI [for plants with an ISFSI outside theplant Protected Area] PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.
HU3Initiating Condition:
M No Change I Difference I Deviation Listed site specific list of plant rooms or areas that contain SAFETYSYSTEM equipment to ensure timely classification.
FIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:
1,2.3,4, 5, DEmergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining that theapplicable time has been exceeded, or will likely be exceeded.
: 1. A FIRE in ANY Table H2 area is not extinguished in < 15-minutes of ANY of thefollowing 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 Building (when inerted the Drywell is exempt)* Aux Electric Room* Control Room* Unit and Shared Emergency Diesel Generator Rooms* 4KV ECCS Switchgear Area (includes Bus 23, 24, 33and 34 only)* CRD & CCSW Pump Rooms* Turbine Building Cable Tunnel* Turbine Building Safe Shutdown Areas as follows:* B- Train Control Room HVAC Room* Battery Rooms and DC Distribution Areas1) U2 Battery Room (includes DC switchgear, 125V, and 250V battery rooms)2) U3 Battery Room, Battery Cage area, andU3 Battery Charger Room (all on U3 TB538)* Crib HouseOR2. a. Receipt of a single fire alarm in ANY Table H2 area (i.e., no other indications of aFIRE).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 theinitial report, alarm or indication.
OR4. A FIRE within the plant PROTECTED AREA that requires firefighting support by anoffsite fire response agency to extinguish.
Page 58 of 66 0NEI 99.01 Rev 6 Proposed EAL Justification Initiating Condition:
UNUSUAL EVENT HU2 Initiating Condition:
HU4 D No Change M Difference F Deviation Seismic event greater than OBE levels. Seismic event greater than OBE levels. 1) Used Alternate developer notes allowed wording since specific Control Roomindication of a seismic event > OBE is not available.
Operating Mode Applicability:
Operating Mode Applicability:
All1, 2, 3, 4, 5, DExample Emergency Action Levels:Emergency Action Level (EAL):Seismic event greater than Operating Basis Earthquake (OBE) as indicated by:a. (site-specific indication that a seismic event met or exceeded OBE limits) 1. Control Room personnel feel an actual or potential seismic event.AND2. The occurrence of a seismic event is confirmed in a manner deemedappropriate by the Shift Manager or Emergency Director.
Page 59 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HA5 HAmInitiating Condition:
ALERT Initiating Condition:
LFI No Change [-1 Difference
[:1 Deviation Gaseous release impeding access to equipment necessary for normal plant Gaseous release impeding access to equipment necessary for normal plant operations,
: 1) Listed plant specific rooms and areas with entry related mode applicability tooperations, cooldown or shutdown.
cooldown or shutdown, ensure timely classification.
Operating Mode Applicability:
Operating Mode Applicability:
All 1,2,3,4, 5, DExample Emergency Action Levels: Emergency Action Level (EAL):Note: If the equipment in the listed room or area was already inoperable, or out Note'of service, before the event occurred, then no emergency classification iswarranted.
If the equipment in the listed room or area was already inoperable, or out of service,before the event occurred, then no emergency classification is warranted.
: 1. a. Release of a toxic, corrosive, asphyxiant or flammable gas into anyof the following plant rooms or areas: 1. Release of a toxic, corrosive, asphyxiant or flammable gas in a Table H3 area.(site-specific list of plant rooms or areas with entry-related modeapplicability identified)
Table H3Areas with Entry Related Mode Applicability AND Area Entry Related Mode Applicability
: b. Entry into the room or area is prohibited or impeded.
Reactor Building*
Modes 3, 4, and 5*Areas required to establish shutdown coolingAND2. Entry into the room or area is prohibited or impededPage 60 of 66 S0NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:
UNUSUAL EVENTHazardous EventOperating Mode Applicability:
HU3AllExample 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.
I. A tornado strike within the PROTECTED AREA.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)HU6Initiating Condition:
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.
OR5. Abnormal River level, as indicated by EITHER:a. High river level > 509 ft.ORb. Low river level < 501 ft. 6 inches.F] No Change FIDifference
[- Deviation
: 1) Added Abnormal River level to list of natural or technological hazard events.The high river level of 509 ft was selected since it is the lowest opening leading tosafety related equipment, and the love river level of 501 ft 6 in was selected sincethis is the most limiting pump suction requirement(CCSW pumps)2) Changed the word "needed" to "required by Technical Specifications" in the EALto be consistent with terminology used by operators and minimize confusion.
Page 61 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HG7 HG7 -Initiating Condition:
GENERAL EMERGENCY Initiating Condition:
LhI No Change LJ Difference FIDeviation Other 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 General Emergency.
declaration of a General 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 IMMINENT Other conditions exist which in the judgment of the Emergency Director indicatesubstantial core degradation or melting with potential for loss of containment that events are in progress or have occurred which involve actual or IMMINENTintegrity or HOSTILE ACTION that results in an actual loss of physical control of substantial core degradation or melting with potential for loss of containment the facility.
Releases can be reasonably expected to exceed EPA Protective Action integrity or HOSTILE ACTION that results in an actual loss of physical control ofGuideline exposure levels off-site for more than the immediate site area. the facility.
Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels off-site for more than the immediate site area..Page 62 of 66 NEI 99-01 Rev 6 Proposed EAL Justification H37 HS7 mmInitiating Condition:
SITE AREA EMERGENCY
' Initiating Condition:
[Sj No Change [j Difference Li Deviation Other 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 major Other conditions exist which in the judgment of the Emergency Director indicatefailures of plant functions needed for protection of the public or HOSTILE ACTION that events are in progress or have occurred which involve actual or likely majorthat results in intentional damage or malicious acts; (1) toward site or failures of plant functions needed for protection of the public or HOSTILE ACTIONequipment that could lead to the likely failure of or; (2) that prevent effective that results in intentional damage or malicious acts; (1) toward site personnel oraccess to equipment needed for the protection of the public. Any releases are not equipment that could lead to the likely failure of or; (2) that prevent effective expected to result in exposure levels which exceed EPA Protective Action access to equipment needed for the protection of the public. Any releases are notGuideline exposure levels beyond the site boundary o expected to result in exposure levels which exceed EPA Protective ActionGuideline exposure levels beyond the site boundary.
Page 63 of 66 NEt 99-01 Rev 6 Proposed EAL Justification HA? HA7Initiating Condition:
ALERT Initiating Condition:
L7 E No Change LJ1 Difference
[J Deviation Other 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 potential that evnts e in phe ourred wh e an actor pntialsubstantial 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 potential involves 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 Justification HU7 HU7 mmFInitiating Condition:
UNUSUAL EVENT Initiating Condition:
[Uj No Change [j Difference
[j Deviation Other 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:Other conditions exist which in the judgment of the Emergency Director indicate Emergency Action Level (EAL):that events are in progress or have occurred which indicate a potential Other conditions exist which in the judgment of the Emergency Director indicatedegradation of the level of safety of the plant or indicate a security threat to facility that events are in progress or have occurred which indicate a potential protection has been initiated.
No releases of radioactive material requiring offsite degradation of the level of safety of the plant or indicate a security threat to facilityresponse or monitoring are expected unless further degradation of safety systems protection has been initiated.
No releases of radioactive material requiring offsiteoccurs. response or monitoring are expected unless further degradation of safety systemsoccurs.Page 65 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:
UNUSUAL EVENT E-HUI Initiating Condition:
E-HUI H No Change F Difference FIDeviation Damage 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 perOperating Mode Applicability:
Certificate of Compliance No. 1014 Appendix A, Section 5.7 (WEST HI-STORM),
Operating Mode Applicability:
Certificate of Compliance No. 1014 Appendix A, Section 3.2.3 (EAST HI-STORM),
and Certificate of Compliance No. 1008 Appendix A, Amendment 2, SectionAll 1 2.2.1 (EAST HI-STAR)1, 2,3,4, 5, DExample Emergency Action Levels: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 an on-technical specification allowable radiation level) on the surface of the spent fuel contact radiation reading:cask.1. EAST HI-STAR:* > 160 mrem/hr (neutron
+ gamma) on the top of the OverpackOR* > 250 mremlhr (neutron+
gamma) on the side of the OverpackOR2. EAST HI-STORM:
* > 20 mremlhr (neutron+
gamma) on the top of the OverpackOR* >100 mremlhr (neutron+
gamma) on the side of the OverpackOR* > 45 mremlhr (neutron+
gamma) at the inlet and outlet vent ducts of theOverpackOR3. WEST HI-STORM:
* > 40 mrem/hr (neutron+
gamma) on the top of the OverpackOR* >100 mremnhr (neutron+
gamma) on the side of the Overpack, excluding inlet and outlet ductsPage 66 of 66 Dresden Annex Exelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARG1Initiating Condition:
Release of gaseous radioactivity resulting in offsite dose greater than 1000 mRremn TEDEor 5000 mRfem thyroid CDE.Operating Mode Applicability:
1,2,3, 4,5, DEmergency Action Level (EAL):Notes:* The Emeraency Director should declare the event promptly upon determining that theapplicable time has been exceeded, or will likely be exceeded.
* Tho Em......Y r-ocr..e-shnould dlar the 9Vr-t prom.ptly uponae9torm.
1Inng atM Me appnc~a~Io mime has seen oXceepep, Or Will Wieiy me oxcocaca.
" 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.
I
* 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 following radiation monito-s greater than the reading Shownfo.r 15 minutes , o longeir(site-specific monitor list and threshold v:alues)1. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs > 7.90E+09 uCi/sec for > 15 minutes (as determined by DOP 1700-10 or PPDS -TotalNoble Gas Release Rate).OR2. Dose assessment using actual meteorology indicates doses at or beyond (Site-sf08fiG dose rec.Ptor voint) the site boundary of EITHER:a. > 1000 mRem TEDEORb. > 5000 mRem CDE Thvroid.. .................
... * ....Month 20XXDR 3-1EP-AA-1004 (Revision XX)
Dresden Annex Exelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS OR/'%1 -- -- J __ --I .... =JI ...... L--AL ---- d ----IJ't L---CAesed windew dese Fates weafeF !RaA JWWW FnKERF eXPeGlecl 19 GGRURUe-fGF 60t m **tesr. a.. nmrtrr- &L--- ff tff%for AMo hour of inhalaion.
: 3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >1000 mRlhr 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 mR-em while the 5000 mRfem thyroidCDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE andthyroid CDE.enviroenment is, ostablished.
If thc Afflucnt.
floW past an effluent monitor is known to havstopped due to Wcions to iselate the roleaso path, thenA the efletmoio eading is nolonger valid for class-ification purposes-.
Month 20XXDR 3-2EP-AA-1004 (Revision XX)
NuclearDresden AnnexA Exellnn Nuclea~rRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Basis Reference(s):
: 1. NE1 99-01 Rev 6, AG12. EP-AA-1 12-500 Emergency Environmental Monitoring
: 3. ODCM Section 12.4 Gaseous Effluents and Total Dose4. DOP 1700-10, Obtaining And Calculating A Gaseous Release Rate From the Unit2/3 Chimney, Unit 1 Chimney and Unit 2/3 combined Reactor Vent Using theEberline Control Terminal5. EP-EAL-0604 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Dresden Station6. DEOP 300-2, Radioactivity Release ControlMonth 20XXDR 3-3EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARS1Initiating Condition:
Release of gaseous radioactivity resulting in offsite dose greater than 100 mR-em TEDEor 500 mRem thyroid CDE.Operating Mode Applicability:
1,2,3,4,5, DEmergency Action Level (EAL):Notes:9 The Emergency Director should declare the event promptly upon determining that theapplicable time has been exceeded, or will likely be exceeded.
II I I l l9 no immcr1Aonc WIrccoF cnouiaI aociare the Site Area EmoreAon even; or-oAmplV d !I roll I*1 I II m s I iI a al la I I ew I Iiinnn ru~tnrmininn Tn~t mA ~nnhlr~flIA timn flap flnfln nYr'nnCinri nr w'n IlkAl'.!
nn-........-....--
I-.E-,..---.-..-----..-~~------,-....
e xGeeded." 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.
14 E3. .4;A r AK $V a &#xfd;' $ka aI a. nn A;a a .n4artnaaa.
ka k a naka.it-et " "" ....W. .. M M-M-W". M.W. -_. -_ ._. .- .__1 10 01 MrvvrlI -"IMI-1 1117tbutti buldrdaimu WHWHOtidF Hbt dwou twMiUbMAU YtHutot"(2) Dose ass.essmnt using actumial meteorology dos.... greater than 100mrcm~ TEDE Or 600 FArom thyroi cl DE, at or beyond (sito spocific dote recepto(3) Field cun.'oy results ind-icate EITHER Of the folloWing at Or beyond (sito specific_
doe r..et point).:" Closed window dose rates greater-than 100 ffd4A expected to continue for 60 fpnutesor- longer-" Analyses of field survey samples indieate thyroid CDE greater-than 500 mrwem for- onehour of inhalation.
Month 20XXDR 3-4EP-AA-1004 (Revision XX)
Dresden AnnexExellon NuclearDresden Annex Exelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS
: 3. 1. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs > 7.90E_.8 uCi/sec for > 15 minutes (as determined by DOP 1700-10 or PPDS -TotalNoble Gas Release Rate).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 EALsmore fully addresses the spectrum of possible accident events and conditions.
The TEDE dose is set at 10% of the EPA PAG of 1000 mR-em while the 500 mR-emthyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDEand thyroid CDE.Claccification based on offluent moneitor reading~s assumos that. a release path ttho enyirnment is ,stablished.
if the effu,,t flo past an effluent
.m"noter is known tohave stopped due to actions to isolate the release path, then the effluent moni;tor readingis no lonecr valid fo classificatio' uossMonth 20XXDR 3-5EP-AA-1004 (Revision XX)
Dresden AnnexExellon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Escalation of the emergency classification level would be via IC RAG1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, AS12. EP-AA-1 12-500 Emergency Environmental Monitoring
: 3. ODCM Section 12.4 Gaseous Effluents and Total Dose4. DOP 1700-10, Obtaining And Calculating A Gaseous Release Rate From the Unit2/3 Chimney, Unit 1 Chimney and Unit 2/3 combined Reactor Vent Using theEberline Control Terminal5. EP-EAL-0604 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Dresden Station6. DEOP 300-2, Radioactivity Release ControlMonth 20XXDR 3-6EP-AA-1004 (Revision XX)
Dresden Annex Exelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARA1Initiating Condition:
Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mRfermTEDE or 50 mRem thyroid CDE.Operating Mode Applicability:
1,2, 3, 4,5, DEmergency Action Level (EAL):Notes:" The Emerqency Director should declare the event promptly upon determining that theapplicable time has been exceeded, or will likely be exceeded.
" Tho Emnergency Diroctor should declare tho Alert event promptly upon detormining that the applicab-le ti~me h-as boon oxceoedod, Or Will likely be exne-ed-ed-.
" 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 15 mninutesO or loger:(site-specific_
monitor list and threshold
'..aluois)
(2) Dose assessment using actual mcetoorolegy indicates doses greater than 1 OmromTEDE or 50 mrom thyroid CDE at Or beyond (cite. c..ific dose reecptor DnOW).(3) A~naly'sis of a liquid effluent sample indicates, a Goncentrtien or release rate thatwould result in doses greater than 10 Qmem TEDE Sor 50 rnrorn thyroid ODE atobeyond (site-spocific dose receptor point) for one hour of exposure(4) Field sur.'oy results indicate EITHER of the following atGorbeyond (site spccificdose receptor point):-*l*.e.. wind. w c.ose .ate. greater-thant L0 .. ..expected to continue or o6 .miutes orlongefn* .o* Analyses et field sur.'ey samulies indicate thyroidI CDE ercater-than ;)U mfemn tor onhour- of inhalation.
Month 20XXDR 3-7EP-AA-1 004 (Revision XX)
AnnexI:xAIon NuclearDrescln Annex Exelon NulewIarRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS
: 1. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs> 7.90 E+07 uCi/sec for > 15 minutes (as determined by DOP 1700-10 or PPDS -Total Noble Gas Release Rate).OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 10 mRem TEDEORb. > 50 mRem CDE ThwroidOR3. 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 siteboundarya. 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.ORb. Analyses of field survey samples indicate
> 50 mRem CDEThyroid for 60 minutes of inhalation.
Month 20XXDR 3-8EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearDresden Annex Exelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS 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 mRrem while the 50 mR-erm thyroidCDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE andthyroid CDE.Classification based on effluent mnonitor readings assumes that a roloaso path tthe enyironmont.
is- establoishecd.
If t~he efflu-ent flowA patafflluent mon8itor is known thavestoped duo to- act~ionsn to soat the release path, then the effluent monitor readingis no longer valid for classificatio pupoesEscalation of the emergency classification level would be via IC RASi.Basis Reference(s):
1 .NEI 99-01 Rev 6, AA12. ODOM Section 12.3 Liquid Effluents
: 3. ODCM Section 12.4 Gaseous Effluents
: 4. DOP 1700-10, Obtaining And Calculating A Gaseous Release Rate From the Unit2/3 Chimney, Unit 1 Chimney and Unit 2/3 combined Reactor Vent Using theEberline Control Terminal5. UNIT 2/3 DAN 2223-6 A-12 "2/3 RADWASTE DISCHARGE HIGH RADIATION"
: 6. UNIT 2/3 DOP 2000-110, Radioactive Waste Discharge to River With the Off-Stream Liquid Effluent Monitor Operable7. UNIT 2/3 DOP 2000-109, Waste Surge Tank Batching for a Radwaste RiverDischarge
: 8. Structural Drawing B-01A Composite Site Plan Dresden Station Units 1, 2 & 39. EP-EAL-0604 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Dresden Station10. DEOP 300-2, Radioactivity Release Control11. EP-EAL-0620 Revision 0, Dresden Criteria for Choosing Radiological LiquidEffluent EAL Threshold ValuesMonth 20XXDR 3-9EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARMlInitiating Condition:
Release of gaseous or liquid radioactivity greater than 2 times the ODOM (eite-speGifie effluent rolcase conroll1ing document) limits for 60 minutes or longer.Operating Mode Applicability:
1, 2,3,4,5, DEmergency Action Level (EAL):Notes:0The Emeraencv Director should declare the event D~romotlv upon determining that theappIlicable time has been exceeded, or will likely be exceeded.
0 noe LmorA8ency wirector GAnoula aciare mne unusual tyeni event prompily upon-j- j--- :11 1:1-1.. --A* 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 mon;itor gr-eater than 2 times the (site speciific effluent release conroll1ing documnent) limitS for 60 mninuter, or longer:.(site-specific-monitor list and thre~shold-vsalues corresponding to 2 timer, thecontrolling document limtits)(2) Reading on ANY effluent radiation moni~tor greater than 2 times the alarm setponestablished by a current radioactivity disch-arge oormit for 60 minutes Or 'OgR.'% rn ^ ^ n ^ C- 11 ^ r 1&#xfd; -ARIagZaUR er I i r^ A" ARIAR &#xfd; fn f%jqLqgq rrpip -pfiq rgq+gr +knn 0 Crypp, +km !,,O+r%-,-
pe,;f 6, pff h i^n+ ^rAn+rplion docu montl lomite for 60 min-utAR~
or lonnoerzi1. Readina on any of the followina effluent monitors
> 2 times alarm setoointestablished by a current radioactive release discharge permit for 2t 60 minutes." Radwaste Effluent Monitor 2/3-2001-948 OR" Discharae Permit Soecified monitorORMonth 20XXDR 3-10Mont 2OX DR -10EP-AA-1 004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS
: 2. The sum of readings on the Unit 2/3 Rx BIdg and Unit 2/3 Chimney SPINGs > 9.02E+05 uCi/sec for > 60 minutes (as determined by DOP 1700-10 or PPDS -TotalNoble Gas Release Rate).HVAC and SGTS- Radiation Moitr-rs;.1706 (1.17 ntro-l roomPanels -OR3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or 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 radioactivity discharge 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 intentional releases.
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.
Claaessific-atione.
basoed on effluent monitor roadingc assumes that a reloase pathtthe onvironment is established.
If. the effluont flow past an effluent monitor is. known~ tohave stopped due to actions to isolate tho roloaso path, then the effluent monitor readingis no Inger valid for clai purp9seG-.
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 BasisEAL-#2--
This EAL addresses radioactivity releases that cause effluent radiation monitorreadings to exceed 2 times the limit established by a radioactivity discharge permit. ThisEAL will typically be associated with planned batch releases from non-continuous releasepathwavs (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 BasisMonth 20XXDR 3-11EP-AA-1004 (Revision XX)
 
N.nlAarflmpaitn Annpx ExelInn Nnnvlasar RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS EAL-#1----This EAL addresses normally occurring continuous radioactivity releases frommonitored gaseous e,-iq;id
-effluent pathways.
EAL #3 BasisEAL--#3---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. ODCM Section 12.3 Liquid Effluents
: 3. ODCM Section 12.4 Gaseous Effluents
: 4. DOP 1700-10, Obtaining And Calculating A Gaseous Release Rate From the Unit2/3 Chimney, Unit 1 Chimney and Unit 2/3 combined Reactor Vent Using theEberline Control Terminal5. UNIT 2/3 DAN 2223-6 A-12 "2/3 RADWASTE DISCHARGE HIGH RADIATION"
: 6. UNIT 2/3 DOP 2000-110, Radioactive Waste Discharge to River With the Off-Stream Liquid Effluent Monitor Operable7. UNIT 2/3 DOP 2000-109, Waste Surge Tank Batching for a Radwaste RiverDischarge
: 8. EP-EAL-0604 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Dresden Station9. DEOP 300-2, Radioactivity Release ControlMonth 20XXDR 3-12EP-AA-1004 (Revision XX) nroarhn AnnovPIrglr~n khio RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARA2Initiating 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) Unco'voy of irr-adi-iatd fuel in the REFUELING PATHWAY.(2) Damage to irradiated fuel resultiRg in a roloaso of radI-o-activity fro-R the ;in;ated by ANY of th lin ation monirs:(sito spocific, listing of radiation moenito-rs, and tho associatod
: readings, setpoints andwor alarmsA)(3) LowriI ng of spent fuel pool love! to Levol 2 value). [See Developei e Uncovery of irradiated fuel in the REFUELING PATHWAY.OR* Damage to irradiated fuel resulting in a release of radioactivity from the fuel asindicated by ANY Table R1 Radiation Monitor readinq >1000 mRem/hrTable R1Fuel Handling Incident Radiation Monitors" Refuel Floor High Range ARM Station #2(4)" Fuel Pool Radiation MonitorBasis: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 traiectorv 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 containina radioactive substances and the environment.
Month 20XXDR 3-13EP-AA-1004 (Revision XX)
AnnAYFyAInn frpqripn Annpx Fvplnn Nmir-Iapar RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly.,
or- a ig. .niiant l.o.ing of wat.r lovel w.,hin the spent fu,, pool (scoDov...r.
.Notes). -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.~eea4at~onOTm oogooywui O aoaonotnr1-ocgito iaoqr;: o IcVvEAL #1 BasisEAL-#1This 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 significant changes 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 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.EAL #2 BasisEAL-#2This 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.
Soent fuel uncovery represents amaior ALARA concern in that radiation levels could exceed 10,000 R/hr on the refuelbridge when fuel uncovery begins. The value of 1000 mR/hr was conservatively chosenfor classification purposes.
A rise in readings on radiation monitors should be considered in conjunction with in-plant reports or observations of a potential fuel damaging event(e.g., a fuel handling accident).
Escalation of the emergency would be based on either Recognition Category RA-or CICs.Month 20XXDR 3-14EP-AA-1004 (Revision XX)
Dresden Annex Exelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS 9AL #3Spent ful. pool water l at this value Or, wthin the lower end of the level Fangnecossary to prevent significant dose conseguoncos, from dierect gamma radiation toporsonnei porferming operatione in the Vicinit,'
Of the spent fuel pool. This conditioroflects a significant loss of spent fuel pool water invontory and thus it. iss alsoe a precurFso to a less of the ability to adequately cool the ifradiate" fu1l asese~mblcc Mtore d in the pool.Er.calation of the emergency classification level would be '.ia I~s AS! Or AS2 (see ASDovelopr-ANoes).Basis Reference(s):
1 .NEI 99-01 Rev 6, AA22. DAN 902(3)-3 C-1 6(E-1 6) Reactor Building Fuel Pool Hi Radiation
: 3. DAN 902(3)-3 B-i Refuel Floor Hi Radiation
: 4. DAN 902(3)-3 A-3(F-1 4) Reactor building Vent Hi-Hi Radiation
: 5. UFSAR 9.16. DAN 902(3)-4 D-24 Fuel Peel Skimmer Tank Level Lo7. DIP 0260-01 Refuel Outage Reactor Vessel and Cavity Level Instrumentation
: 8. DFP 0850-01 Water Level Loss in SEP or Cavity9. DOP 1900-03 Reactor Cavity, Dryer/Separator Storage Pit and Fuel Pool LevelControlMonth 20XXDR 3-15EP-AA-1004 (Revision XX)
Dry.dAn AnnexDrvvden Annex Evelon Nule IasrRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARU2Initiating Condition:
UNPLANNED loss of water level above irradiated fuel.Operating Mode Applicability:
1,2, 3, 4, 5, DEmergency Action Level (EAL):I14\ I INIDI I~ I ,-v, , .~ lrr ;n skn D~rl:I I1:I INt"f- DATI.JIAIAV n- I; teby ANY of the followinei:v(sitoe-socific level indications).
ANDb. U1 IPI-AN.'NE'6 D io in as o rdiation lovls. ;as indicated by ANY of the_ !--I .. .... !1_ __\(Rtsn-pd1 RDOII unof area radatiaon mrontirel
'-...- r" ...... ... ..... ..1. a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated by ANYof the following:
" Refueling Cavity water level < 466 in._(Refuel Outage Reactor Vesseland Cavity Level Instrument LI 2(3)-263-114)
OR* Spent Fuel Pool water level < 19 ft. above the fuel (< 33 ft. 9 in.indicated level).OR" Indication or report of a drop in water level in the REFUELING PATHWAY.ANDb. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors inTable RI.Table R1Fuel Handling Incident Radiation Monitors" Refule Floor High Range ARMStation #2(4)* Fuel Pool Radiation MonitorMonth 20XXDR 3-16EP-AA-1004 (Revision XX) nroadon AnnoyE=xalnn flm~dAn Ann~v Fv~Inn Nsir~I~~ar RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS 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 parameter change or event may be known or unknown.REFUELING PATHWAY:
all the cavities, tubes, canals and pools throuqh whichirradiated fuel may be moved or stored, but not including the reactor vessel below theflange.This IC addresses a deeeease-loss 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.I 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 aa iner-easerise 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 inereaserise 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):
: 1. NEI 99-01 Rev 6, AU22. RP-AA-203 Exposure Control and Authorization
: 3. Technical Specifications 3.7.84. Technical Specifications 3.9.65. UFSAR 9.16. DAN 902(3)-4 D-24 Fuel Pool Skimmer Tank Level Lo7. DIP 0260-01 Refuel Outage Reactor Vessel and Cavity Level Instrumentation
: 8. DFP 0850-01 Water Level Loss in SFP or CavityMonth 20XXDR 3-17EP-AA-1004 (Revision XX)
Dresden AnnexExellon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS
: 9. DOP 1900-03 Reactor Cavity, Dryer/Separator Storage Pit and Fuel Pool LevelControl10. DGP 02-02, Reactor Vessel Slow Fill11. DAN 902(3)-3 C-1 6(E-1 6) Reactor Building Fuel Pool Hi Radiation
: 12. DAN 902(3)-3 B-1 Refuel Floor Hi Radiation
: 13. DAN 902(3)-3 A-3(F-14)
Reactor building Vent Hi-Hi Radiation Month 20XXDR 3-18EP-AA-1 004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARA3Initiating 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:9 If the equipment in the listed-room or area listed in Table R3 was alreadyinoperable, or out of service, before the event occurred, then no emergency classification is warranted
/IN ^^o% r&#xa3;1r% re% +^r fk., 1 A rnr2/%r On AIlV +kA U ,r. .\ ' I ,--v,.,v
, to ---.-W" Cntrol Room." Central A4arm Statiea" (other- site specific afeask/rooms)OAhd ;i MR UNPr6ANIM eventL iU.uIlt II Fin aIRIIiIIR
.lev 11Ui AFOIUKILI O[ UIMM99U aGUeL ;9Iany of the following plant roome6 Or aroac:-;J[:-- --J[--I----x
.......isne speemTI liiT of DIflT F9oomS OF Warc WI1!RenR:
reF0aioo monoe aooiicantii ideRtified)
...... I" ..............
------------..~... 1....... I- r-.. .Je Dose rate than> 15 mR/hr in ANY of the followina areas:Table R2Areas Requiring Continuous Occupancy
* Main Control Room (Unit 2 ARM Station #22)* Central Alarm Station -(by survey)OR* UNPLANNED event results in radiation levels that prohibit or significantly impedeaccess to any of the following plant rooms or areas:Month 20XXDR 3-19EP-AA-1004 (Revision XX)
I=yAIon Nuelmarrnmnden Annex Exelon NuclarwRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS Table R3Areas with Entry Related Mode Applicability Area Entry Related ModeApplicability Reactor Building*
Modes 3, 4, and 5*Areas 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 parameter change 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 perFo-m a normal plant .o.ldown andh,-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 R3 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 operating procedures (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 includerooms or areas for which entry is required solely to perform actions of an administrative orrecord keeping nature (e.g., normal rounds or routine inspections).
Rooms and areas listed in EAL #1 do not need to be included in EAL #2, including 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 serviceat the time of thoolo'eatod radiation levols. 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 ofpersonnel into the affected room/area (e.g., installing temporary shielding beyond thatrequired by procedure, 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.Month 20XXDR 3-20EP-AA-1004 (Revision XX) l=yRlnn frmaidan Annex Exelnn NucleanrRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS
" 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 radiation inereaserise 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. DOP 1800-01 Area Radiation Monitors3. FSAR Section 3.2 Classification of Structures, Components and Systems4. General Arrangement Drawings M-3, M-4, M-4A, M-5 and M-105. DEOP 300-2, Radioactivity Release ControlMonth 20XXDR 3-21EP-AA-1 004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS SRU3Initiating Condition:
Reactor coolant activity greater than Technical Specification allowable limits.Operating Mode Applicability:
1,2,3Emergency Action Level (EAL):(-1-)-- (Sitoe-pocific radiatio moitr)rading groator than (cite-s9*
vpcfc'a4o)-.
(2) Sample analysis indicatoc that a reactor coolant activity valueo ia greater than anallowable limit specified in Tcc~hnical Specifiations.
: 1. Offgas system radiation monitor HI-HI alarm.OR2. Specific coolant activity
> 4.0 uCll/m 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 significant event and represents a potential degradation of the level of safety of the plant.Conditions that cause the specified monitor to alarm that are not related to fuel 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 Recognition Category RA ICs.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SU32. Technical Specifications 3.4.6, RCS Specific Activity3. DAN 902(3)-3 C-2(D-2)
Off Gas Rad Monitor Hi-Hi4. Technical Specifications 3.7.6, Main Condenser Offgas5. DGA 16 Coolant High Activity/Fuel Element FailureMonth 20XXDR 3-22EP-AA-1 004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FG1Initiating 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 determine barrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.
At the General Emergency classification level each barrier is weighted equally.Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXDR 3-23EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FS1Initiating 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 determine barrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.
At the Site Area Emergency classification level, each barrier is weighted equally.Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXDR 3-24EP-AA-1004 (Revision XX)
Exelon Nuclearrlrsden Annex Ex.lon Nulela. rRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FA1Initiating 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 determine barrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.
At the Alert classification level, Fuel Cladding and RCS barriers are weighted moreheavily than the Containment barrier.
Unlike the Containment
: barrier, loss or potential loss of either the Fuel Cladding or RCS barrier may result in the relocation of radioactive materials or degradation of core cooling capability.
Note that the loss or potential loss 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 20XXDR 3-25EP-AA-1004 (Revision XX)
Dresden Annex Exelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC1Initiating Condition:
RCS ActivityOperating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
LOSSA. (Sito Spocific indications that rcactor coolant actiVity is groater than 30Q0uGi~gm doc 3.)Coolant activity
> 300 uCilcm Dose Equivalent 1-131.Basis:This threshold indicates that RCS radioactivity concentration is greater than 300 gCi/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-22. DGA-1 6, Coolant High Activity
/ Fuel Element FailureMonth 20XXDR 3-26EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearDresden Annex Exelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC2Initiating Condition:
RPV Water LevelOperating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
LOSSA-.1. Plant conditions indicate Primary GContainment flooding is required.
POTENTIAL LOSSA-.2. RPV water level cannot be restored and maintained abovo (site specific RPV.at.. level ,..Or...pnding to top of acti'. ful)> -143 inches (TAF)9 RPV water level cannot be determined.
Basis:RPV values are actual levels, not indicated levels. Therefore, they may need levelcompensation depending on conditions.
Compensated values may be used inaccordance with the Technical Support Guidelines.
Loss 2-AThreshold
#1 BasisThe Loss threshold represents the EOP requirement for primary containment flooding.
This is identified in the BWROG EPGs/SAGSAMGs when the phrase, "PrimaryContainment Flooding Is Required,"
appears.
Since a site-specific RPV water level isnot specified here, the Loss threshold phrase, "Primary containment flooding required,"
also accommodates the EOP need to flood the primary containment when RPV waterlevel cannot be determined and core damage due to inadequate core cooling isbelieved to be occurring.
Potential Loss 2AThreshold
#2 and #3 BasisThis 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 baIieF-Barrier RC2 Loss threshold 2-.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-specific EOPs, RPV-waterRPV 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 pressureMonth 20XXDR 3-27EP-AA-1004 (Revision XX)
DrAsden Annex.r..d.n Annex Exelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RPV 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 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 act--ieve order to reduce reactorpower. RPV ..at..r le"vl is then contro.lled btwoon tho top of active fuol tho Steanm Cooling RPV Water Loeveol 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 SS-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. DEOP 100 RPV Control3. DEOP 400-5 Failure to Scram4. DEOP 400-1 RPV Flooding5. DEOP 0010-00 Guidelines for Use of Dresden Emergency Operating Procedures and Severe Accident Management Guidelines
: 6. Technical Support Guidelines Month 20XXDR 3-28EP-AA-1 004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION Month 20XXDR 3-29EP-AA-1004 (Revision XX)
Annoyfras~eIan Annexv FYAlnn NucleasrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC5Initiating Condition:
Primary Containment Radiation Operating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
LOSSA. Primary containment radiation monitor reading greater than (site-cpecific value)Drywell radiation monitor reading > 6.70 E+02 R/hr (670 R/hr).Basis:L~ess4.AThe radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the primary containment, assuming that reactor coolant activityequals 300 gCi/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 tThreshold 47A-since it indicates a loss of both the Fuel Clad Barrierand the RCS Barrier.
Note that a combination of the two monitor readings appropriately escalates the emergency classification level to a Site Area Emergency.
I 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 Methodology (CDAM)Month 20XXDR 3-30EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC7Initiating Condition:
Emergency Director Judgment.
Operating Mode Applicability:
1,2,3EAL Threshold Values: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 Potential Loss of the Fuel Clad Barrier.Basis:Loss Threshold
#1 BasisThis threshold addresses any other factors that are to be used by the Emergency Director in determining whether the Fuel Clad Barrier is lost.Potential Loss Threshold
#2 BasisPotential Loec 6.AThis 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 20XXDR 3-31EP-AA-1004 (Revision XX)
Exelon NuclearDresden Annex Eeo ulaRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC2Initiating Condition:
RPV Water LevelOperating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
LOSS1. RPV water level cannot be restored and maintained above (.ite.specific RPV waterll corr to the top of acti'..., -143 inches (TAF)R-OR2. RPV water level cannot be determined.
Basis:Less-2-RPV values are actual levels, not indicated levels. Therefore, they may need levelcompensation depending on conditions.
Compensated values may be used inaccordance with the Technical Support Guidelines.
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 baFi8F Barrier FC2 Potential Loss threshold  .A. Thus, this threshold indicates a Loss of the RCS barrier andPotential Loss of the Fuel Clad barrier and that appropriately escalates the emergency classification level to a Site Area Emergency.
This threshold is considered to be exceeded when, as specified in the site-specific EOPs, RPV-waterRPV 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 emergency RPV 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.
Month 20XXDR 3-32EP-AA-1004 (Revision XX)
Dresden Annex Exellon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION 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 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 act*ve fuel in order to reduce reactorpower. RPV Wator level is then controlled betowen the top Of actiVe fuel and theMinimu.m Steam Coolin;g W^.Atr L ev.el (MSCR'A'W).
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 SS-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. DEOP100 RPV Control3. DEOP 0010-00 Guidelines for Use of Dresden Emergency Operating Procedures and Severe Accident Management Guidelines
: 4. Technical Support Guidelines Month 20XXDR 3-33EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC3Initiating Condition:
Primary Containment PressureOperating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
LOSSA. Primar,'
containment pre6Suro greater than (site specific value) duo to RCS loakag.1. Drywell pressure
>2.0 psig.AND2. Drywell pressure rise is due to RCS leakageBasis:Less4-7AThe (.ite
...
2.0 psia primary containment pressure is the high pressure setpoint which indicates a LOCA by automatically initiating the-ECCS-GF equivalent mrakeup 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 affectpdmary containment pressure.
Pressures of this magnitude can be caused by non-LOCA events such as a loss of Drvwell 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 Electromatic relief valve (ERV)/Target Rock SRV or ERV/ Target RockSRV leakage is not considered either identified or unidentified leakage by Technical Specifications and, therefore, is not applicable 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. Technical Specifications Table 3.3.5.1-1
: 3. DAN 902(3)-5 D-1 14. DEOP 100 RPV Control5. DEOP 200-1 Primary Containment ControlMonth 20XXDR 3-34EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC4Initiating Condition:
RCS Leak RateOperating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
LOSSAl. UNISOLABLE Main Steam Line (MSL), Isolation Condenser, HPCI, Feedwater, orRWCU line break. in ANY of the foI.wing:. .... fc Systems with potential for highenorgyImbra)
ORB2. Emergency RPV Depressurization is required.
POTENTIAL LOSS3A. UNISOLABLE primary system leakage that results in EITHER of the following:
al-. Secondary Containment area temperature
> DEOP 300-1 MaximumMax NormalOoperating T-emperaturelevels.
ORb2. Secondary Containment area radiation level > DEOP 300-1 Maximum Max-Normal Ooperating A^-p 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 available to 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 20XXDR 3-35EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearDresden Annex Exelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION Loss Threshold
#1 Basis-&ALarge high-energy lines that rupture outside primary containment can discharge significant 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 fr"m :the Co-,ntrol Room, the RCS barrier Loss threshold is met.Loss Threshold
#2 Basis3.Emergency RPV Depressurization in accordance with the EOPs is indicative of a loss ofthe RCS barrier.
If Emergency RPV Depressurization is performed, the plant operators are directed to open safety relief valves (SRVs) and keep them open. Even though theRCS is being vented into the Torus, a Loss of the RCS barrier exists due to thediminished effectiveness of the RCS to retain fission products within its boundary.
Potential Loss Threshold-
#3 Basis 3.Potential loss of RCS based on primary system leakage outside the primarycontainment is determined from EOP temperature or radiation Max Normal Operating values in areas such as main steam line tunnel, RGIG,-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 condition does 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 unexpected Main Turbine Control Valve closure) may indicate that a primary system is discharging into 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 20XXDR 3-36EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-22. M-12, M-345, Main steam piping3. Technical Specifications 3.4.4 RCS Operational LEAKAGE4. Technical Specifications Section 3.4.5, RCS Leakage Detection Instrumentation
: 5. DAN 902(3)-4 A-17 DRWAELLDRYWELL EQUIP SUMP LVL HI-HI6. DAN 902(3)-4 H-18 DRY-AWELLDRYWELL FLOOR DRN SUMP LVL HI-HI7. DOA 0040-01 SLOW LEAK8. DOP 2000-24 DRYWELLDRYWELL SUMP OPERATION
: 9. DEOP 300-1, Secondary Containment Control10. UFSAR Section 5.2.5Month 20XXDR 3-37EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC5Initiating Condition:
Primary Containment radiation Operating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
LOSS1. Drywell radiation monitor reading > 100PRhr (>1.00 E+02 R/hr).A. Pdmary containment radiation roading groator than (site spociflc 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 specified for Fuel Clad Barrier FC5 Loss Tthreshold 4-A-since it indicates a loss of the RCSBarrier only.I There is no RCS Potential Loss threshold associated with Primary Containment Radiation.
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 the RCS Barrier.Month 20XXDR 3-38EP-AA-1004 (Revision XX)
AnnAyI=xAIon Nuclearflmsden Annex Exelon NucleasrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC7Initiating 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 theRCS Barrier.POTENTIAL LOSSA2. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.Basis:Loss SAThreshold
#1 BasisThis threshold addresses any other factors that are to be used by the Emergency Director in determining whether the RCS Barrier is lost.Potential Loss 6,AThreshold
#2 BasisThis 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 20XXDR 3-39EP-AA-1004 (Revision XX)
ExAIon Dresden Annex ExeIon NuclasrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT2Initiating Condition:
RPV Water LevelOperating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
POTENTIAL LOSSX. Plant conditions indicate PrimaryGContainment flooding is required.
Basis:Potential Lo h -2.AThe Potential Loss threshold is identical to the Fuel Clad Barrier -RC2 Loss threshold, RPV Water Level thFroheldA.
The Potential Loss requirement for PrimaryContainment Flooding indicates adequate core cooling cannot be restored andmaintained and that core damage is possible.
BWR EPGs/SAGSAMGs specify theconditions that require primary containment flooding.
When primary containment flooding is required, the EPGs are exited and SAGSAMGs are entered.
Entry intoSAQSAMGs is a logical escalation in response to the inability to restore and maintainadequate 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 potential for primary containment failure.
In conjunction with the RPV water level Loss thresholds in 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. Severe Accident Management Guidelines
: 3. DEOP 0100, RPV Control4. DEOP 0400-01, RPV Flooding5. DEOP 0400-05, Failure to ScramMonth 20XXDR 3-40EP-AA-1004 (Revision XX)
NuelAarDresden Annex Exelon Nucle~arRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT3Initiating Condition:
Primary Containment Conditions Operating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
LOSSAl. UNPLANNED rapid drop in prma.' contai.montDrvwell pressure following p~4mryeeitairmnetDrywell pressure rise.ORI 82. Prim.ary c ..tainmen.
D-..,. pressure response not consistent with LOCAconditions.
POTENTIAL LOSSA3. Primary -.ntainmcP..lwD=ll pressure gr.ator than (site specific.
value)> 62 DsiQand rising.OR84. specific explosive mi.ture) exists Inside pr.mar; containmen.
: a. Drywell ortorus hydrogen concentration
> 6%.ANDb. Drvwell or torus oxygen concentration
> 5%.ORG5. HT-LGHeat Capacity Limit (DEOP 200-1, Fig.M) 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 parameter change or event may be known or unknown.Loss !.A and4-BThreshold
#1 and #2 BasisRapid UNPLANNED loss of primary containment pressure (i.e., not attributable toI dFyweADrywell spray or condensation effects) following an initial pressure kdseindicates a loss of primary containment integrity.
Primary containment pressure shouldi i eris__ee as a result of mass and energy release into the primary containment from aLOCA. Thus, primary containment pressure not increasing under these conditions indicates 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 containment Month 20XXDR 3-41EP-AA-1004 (Revision XX) rmcdpn AnnpvI=yplnn N.nlpnrflrn~d.n AnnAYExueInn NunivparRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION bypass condition.
A pressure suppression bypass path would not be an indication of acontainment breach.Potential Loss ".AThreshold
#3 BasisThe threshold pressure is the primary containment internal design pressure.
Structural acceptance 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 1-.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 Containment barrier could occur.Potential Loss GThreshold
#5 BasisThe Heat To-mperatue Limit (HCTI) is the highest Tr.us temperature fromwhich Emerg RPV will not raise:equipment within t.he u which may be .cqui.ed to operate when the RP12i.ORTOM p~ssm aoveP~ma~
ontainment Pressure Limit A., while theFatecRegy transfer froM the RPV to the containment is greater than the capacityo the ontak;nmeRnt vent.The HCTL is a function of RPV pressure, Torus temperature and Torus water level. It isutilized to preclude failure of the containment and equipment in the containment necessary for the safe shutdown of the plant and therefore, the inability to maintainplant parameters below the limit constitutes a potential loss of containment.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-22. UFSAR 6.2.1.3.2.1
: 3. UFSAR Table 6.2-34. UFSAR 15.6.55. UFSAR 6.2.1.16. DEOP 200-1 Primary Containment Control7. DEOP 200-2 Hydrogen ControlMonth 20XXDR 3-42EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT5Initiating Condition:
Primary Containment Radiation Operating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
POTENTIAL LOSSA. PrimAa,'
containment I adiation monGito0r eading greater than (Iit i pecific value)1. Drywell radiation monitor reading > 1.60 E+03 RPhr (1600 R/hr).Basis:There is no Loss threshold associated with Primary Containment Radiation.
Potential Lessl.,AThe 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 analogous Fuel Clad Barrier Loss and RCS Barrier Loss thresholds.
NUREG-1228, 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 protective actions.
For this condition to exist- 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 classification level to a General Emergency.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-22. Core Damage Assessment Methodology (CDAM)Month 20XXDR 3-43EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearDresden Annex Exelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT6Initiating 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.OR82. Intentional Pprimary CgGontainment venting/Durainc per EOP's or SAMGs due toaccident conditions.
ORG3. UNISOLABLE primary system leakage that results in EITHER of the following:
4-a. Secondary Containment area temperature
> DEOP 300-1. MaximumMax Safe OQperating TemrpeFatulevels.
OR2b. Secondary Containment area radiation level > DEOP 300-1. MaximumMax Safe Qoperating Radiatien-Llevels.
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 &AThreshold
#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 steamline breaks, unisolable RWCU system breaks.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 20XXDR 3-44EP-AA-1004 (Revision XX) nroadon AnnoyI=Yplnn Exelon NurlosarRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION Following 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 "BThreshold
#2 BasisEOPs may direct primary containment isolation valve logic(s) to be intentionally
: bypassed, 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 djywWDrywell high pressurescram setpoint) does not meet the threshold condition.
Loss 3TCThreshold
#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 necessary for 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 Prmary Containment.
For example, a high area radiation condition does 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 inconiunction with other indications (e.g. room flooding, high area temperatures, reports ofsteam in the Reactor Building, an unexpected rise in Feedwater
: flowrate, or unexpected Main Turbine Control Valve closure) may indicate that a primary system is discharging into the Reactor Building.
In combination with RCS Barrier RC4 Ppotential LI-oss Threshold-
#3,3A_this threshold would result in a Site Area Emergency.
There is no Potential Loss threshold associated with Primary Containment Isolation I Failure.Month 20XXDR 3-45EP-AA-1004 (Revision XX)
Dresden NuclearDlresden Annex Exellnn NucleAarRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-22. DEOP 200-1 Primary Containment Control3. DEOP 200-2 Hydrogen Control4. DEOP 500-4 Containment Venting5. DEOP 300-1 Secondary Containment ControlMonth 20XXDR 3-46EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT7Initiating Condition:
Emergency Director Judgment.
Operating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
LOSSI Aj. Any condition in the opinion of the Emergency Director that indicates Loss of theContainment Barrier.POTENTIAL LOSSI A2. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.Basis:Loss GAThreshold
#1 BasisThis threshold addresses any other factors that are to be used by the Emergency Director in determining whether the Containment Barrier is lost.Potential Loss 6AThreshold
#2 BasisThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Containment Barrier is potentially lost. The Emergency Director 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 20XXDR 3-47EP-AA-1004 (Revision XX) roadan AnnoyI=Yalnn Nu nazlirflrnerI~n Annv Fv.Inn M.ir~Iu~ar RECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSG1Initiating Condition:
Prolonged loss of all Off-site and all On-Site AC power to emergency busesesbuses.
Operating Mode Applicability:
1,2,3Emergency Acton Level (EAL):Note:9 The Emeraencv Director should declare the event promptlv upon determinina thatthe applicable time has been exceeded, or will likely be exceeded.
Th maai Smta ahul dina t.. .. ... ..nun a= ano aszt i aamndtW yi i: t1iI I III LI LI IVThe EamergencY Director should declare the Gonreal Emorgency promnptly upon that (ito-specific has bcen Or will likely be exceeded.
1-a-. Loss of ALL offsite and ALL oncite AC power to (site specific emergency buses)unit ECCS buses.AND2. Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency diesel generators to supply power to unit ECCS buses.AND3b. EITHER of the following:
: a. Restoration of at least one emeigeR~yunit ECCS bus in < 4 hours is notlessthan+ s .pific hours) is Rot likely.ORb. RPV water level cannot be restored and maintained
> -164 inches.I Site 6-e-ecific-indic-ation of an inability to adeauatelY remove heat froem the core')dl JBasis:SAFETY SYSTEM: A system reauired for safe plant operation.
coolina down the piantand/or placing it in the cold shutdown condition, including the EGGS. These aretypically systems classified as safety-related.
Month 20XXDR 3-48EP-AA-1004 (Revision XX)
Dresden AnnexExellon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS I 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 requiring electric 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 oAn Or moeany fission productbarriers.
In addition, fission product barrier monitoring capabilities may be degradedunder these conditions.
RPV values are actual levels, not indicated levels. Therefore, they may need levelcompensation depending on conditions.
The EAL should require declaration of a General Emergency prior to meeting thethresholds for IC FG1. 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 likelihood of challenges to multiple fission product barriers.
The estimate for restoring at least one emergency bus should be based on a realistic appraisal of the situation.
Mitigation actions with a low probability of success should 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 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138-kV System and 345-kV Alternate Supply Failure5. DOA 6500-01 4-KV Bus Failure6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout Generator Ties to Plant Auxiliary Electric System7. UFSAR 9.5.98. DOP 6620-05, Powering Unit 2(3) 4-KV Busses via the SBO D/G 2(3)9. DGA-12 Partial or Complete Loss of AC Power10. DEOP100 RPV ControlMonth 20XXDR 3-49EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS
: 11. DEOP 0010-00 Guidelines for Use of Dresden Emergency Operating Procedures and Severe Accident Management Guidelines Month 20XXDR 3-50EP-AA-1004 (Revision XX)
Dry.dAn AnnAy Dresden An nex Exelnn Nucler~I~
RECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSS1Initiating Condition:
Loss of all offsite and all onsite AC power to emergency busesbuses for 15 minutes orlonger.Operating Mode Applicability:
1,2,3Emergency Acton Level (EAL):Note:I* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.
*Tk~ a 11rk%..~
+k^ a;+^ A r~ mrrr1!~'r, r^r, Mv+r4I1 I.~dot.. ..n.na thv, t 1I nu F%- h .......A......t
..n ..c. .d. or will bo ..ood. ." "1. Loss of ALL offsite and ALL "e-it+ AC Power to (site ..peif ic omergency ECCS buses for 15 ""minute" or 'on. .Ib, nitAND2. Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency diesel generators tosupply power to unit ECCS buses.AND3. Failure to restore power to at least one ECCS bus in < 15 minutes from the time ofloss 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 emergency core 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.Month 20XXDR 3-51EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS Escalation of the emergency classification level would be via ICs RAG1, FG1,_-eqM._SG 1, or MG2.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SS12. UFSAR 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138-kV System and 345-kV Alternate Supply Failure5. DOA 6500-01 4KV Bus Failure6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout Generator Ties to Plant Auxiliary Electric System7. UFSAR 9.5.98. DOP 6620-05, Powering Unit 2(3) 4KV Busses via the SBO D/G 2(3)9. DGA-12 Partial or Complete Loss of AC PowerMonth 20XXDR 3-52EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSA1Initiating Condition:
Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:
1,2,3Emergency Acton Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.
The Emnergency Dierccto should declaro the Alo~t proemptly upon dotormining that 15min*utoc hac boon oxcooded, or will likely be cxccedod1. AC power capability to unit ECCS buses reduced to only one of the following powersources for > 15 minutes." Reserve auxiliary Transformer TR-22 (TR-32)" Unit auxiliary transformer TR-21 (TR-31)" Unit Emergency Diesel Generator DG 2(3)" Shared Emergency Diesel Generator DG 2/3" Station Blackout Diesel Generator DG 2(3)* Unit crosstie breakersa. AC powor capability to (cite-spccific omergency buses) is rcduccd to a singlcnowemr nowanep for 15 mninutpe or longeFVAND2b. Any additional single power source failure will result in a loss of ALLa# AC power toSAFETY 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 aretvDicallv 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 ICMSU1.Month 20XXDR 3-53EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS I 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.j _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 baGk-fed from theunit main generator.
" A loss of emergency power sources (e.g., onsite diesel generators) with a singletrain of emergency buses being baek-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 MSS1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SA12. UFSAR 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138 KV System and 345 KV Alternate Supply Failure5. DOA 6500-01 4KV Bus Failure6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout Generator Ties to Plant Auxiliary Electric System7. UFSAR 9.5.9 Station Blackout System8. DOP 6620-05, Powering Unit 2(3) 4KV Busses via the SBO D/G 2(3)9. DGA-1 2 Partial or Complete Loss of AC PowerMonth 20XXDR 3-54EP-AA-1004 (Revision XX)
Annexresden Annex Exelnn Nucl~easr RECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSU1Initiating Condition:
Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.Operating Mode Applicability:
1,2,3Emergency Acton Level (EAL):Note:* The Emergency Director should declare the event Promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.
The Emergency Director ehould doclaro the Unusual Event prom~ptly upondetermining that 1 6 ute, has been ev-edod,or Oi,;ll likely be eXveeded.
--.Loss of ALL offsite AC power capability to unit ECOS buses (;.ite...epific em.ergency
> 15 minutes-e-r-loPWe.
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. (e.g. unit cross-tie breakers)
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 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138 kV System and 345 kV Alternate Supply Failure5. DOA 6500-01 4kV Bus Failure6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout Generator Ties to Plant Auxiliary Electric System7. UFSAR 9.5.98. DOP 6620-05, Powering Unit 2(3) 4kV Busses via the SBO D/G 2(3)Month 20XXDR 3-55EP-AA-1004 (Revision XX)
Dresden AnnexExellon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS
: 9. DGA-12 Partial or Complete Loss of AC PowerMonth 20XXDR 3-56EP-AA-1004 (Revision XX)
Dry.dAn AnnAxNuclearfrw dwn Annex Exelvn NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSG28Initiating Condition:
Loss of all AC and Vital DC power sources for 15 minutes or longer.Operating Mode Applicability:
1,2,3Emergency Acton Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.
The E-morgncY Dir;ctAOr shuld dlclare the GoAn-ciral promptly upnRdotermining that 15 minutos h-as boon excocdcd, Or Will likoly bo oXccoded.
: 1. Loss of ALL offsite AC power to unit ECCS buses.AND2. Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency diesel generators to supply power to vital buses.AND3. Voltage is < 105 VDC on 125 VDC battery buses #2 and #3.AND4. ALL AC and Vital DC power sources have been lost for > 15 minutes.1 .a. Loss of ALL offtet and ALL ensito AC powor to (site-Specific.
cmcrgcncy buses) f-r 15 m;nt,- or I6,nger.ANMb. indicatod v.oltage is loss than (sito specific bus voltage value) on ALL(site spocific Vital DC u- suss o 5 iue o ogrBasis:SAFETY SYSTEM: A svstem reguired for safe plant operation, cooling down the plantand/or Dlacina it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.
Month 20XXDR 3-57EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS This 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 requiring electric 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 all EALconditionse are met.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SG82. UFSAR 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138-kV System and 345-kV Alternate Supply Failure5. DOA 6500-01 4KV Bus Failure6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout Generator Ties to Plant Auxiliary Electric System7. UFSAR 9.5.98. DOP 6620-05, Powering Unit 2(3) 4KV Busses via the SBO D/G 2(3)9. DGA-1 2 Partial or Complete Loss of AC Power10. UFSAR 8.3.211. DOA 6900-02(3)
Failure of Unit 2(3) 125 VDC Power Supply12. Technical Specification B.3.8.4, DC Power Sources -Operating Month 20XXDR 3-58EP-AA-1 004 (Revision XX)
I=yplnn rflmrtdpn Annex ExelInn NucleIair RECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSS28Initiating Condition:
Loss of all vital DC power for 15 minutes or longer.Operating Mode Applicability:
1,2,3Emergency Acton Level (EAL):Note:* The Emerqency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.
The .Emergency Dirovtv 6h1u4d0d-caro thoSit.e Are. n EmergencY promptly upondotormining that 15 minutes ha6 boon eXcoodod, or Will likely be excccded.
,,diGated--Voltage is < 105 VDC Iere" than (c..ite bus voltage value) "on125 VDC battery buses #2 and #3ALL (cite -pci..c; Vital DG bu.. ..uses4 for>15 minutes-OF-.eRge 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 condition involves a major failure of plant functions needed for the protection of the public.I 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 8.3.23. DOA 6900-02(3)
Failure of Unit 2(3) 125 VDC Power Supply4. Technical Specification B.3.8.4, DC Power Sources -Operating Month 20XXDR 3-59EP-AA-1 004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSS3,Initiating Condition:
Inability to shutdown the reactor causing a challenge to RPV water level or RCS heatremoval.Operating Mode Applicability:
1,2Emergency Acton Level (EAL):1. Automatic scram did not shutdown the reactor as indicated by Reactor Power > 6%.AND2. ALLA. manual / ARI actions to shutdown the reactor have been unsuccessful asindicated by Reactor Power > 6%.AND3. EITHER of the following conditions exist:" RPV water level cannot be restored and maintained
> -164 inchesOR" Heat Capacity Limit (DEOP 200-1. Fig. M) exceeded.
(Site specific indication of.an ia to adequately emove heat fFrom the core)(Site specific indication of an nblt to adequatcly 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 ,ubsequent operator actions to manually shutdown the reaGcto 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 behigher 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 theI reactor.Month 20XXDR 3-60EP-AA-1004 (Revision XX)
Nr=dmnn AnnavJ=vainn Nl io-larflrnc~rI~n Ann~ir FvmLnn Mm mr~Ia~rRECOGNITION CATEGORYSYSTEM MALFUNCTIONS RPV values are actual levels, not indicated levels. Therefore, they may need levelcompensation dependingq on conditions.
A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.
Escalation of the emergency classification level would be via IC RAG1 or FG1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SS52. DEOP 100 RPV Control3. DEOP 400-5 Failure to Scram4. DEOP 200-1 Primary Containment Control5. Technical Support Guidelines Month 20XXDR 3-61EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearDresden Annex Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSA35Initiating 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 Acton 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,-aAutomatic or manual scram did not shutdown the reactor as indicated byReactor Power > 6%.AND2. Manual / ARI actions taken at the reactor control consoles are not successful inshutting down the reactor as indicated by Reactor Power > 6%.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 control consoles to shutdown the reactor are alsounsuccessful.
This condition represents an actual or potential substantial degradation of 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 controlconsoles since this event entails a significant failure of the RPS.A manual action at the reactor control consoles is any operator action, or set of actions,which causes the control rods to be rapidly inserted into the core (e.g., initiating amanual reactor scram. This action does not include manually driving in control rods orimplementation of boron injection strategies.
If this action(s) is unsuccessful, operators would immediately pursue additional manual actions at locations away from the reactorcontrol 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 control 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, otherMonth 20XXDR 3-62EP-AA-1004 (Revision XX)
Dresden Annex Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS concurrent plant conditions, etc. If the failure to shutdown the reactor is prolonged enough 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 MSS36. Depending upon plant responses and symptoms, escalation is also possiblevia IC FSi. Absent the plant conditions needed to meet either IC MSS_3 or FS1, anAlert declaration is appropriate for this event.It is recognized that plant responses or symptoms may also require an Alert declaration in accordance with the Recognition Category F l1s; however, this IC and EAL areincluded to ensure a timely emergency declaration.
i A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, SA52. DEOP 100 RPV Control3. DEOP 400-5 Failure to Scram4. DEOP 200-1 Primary Containment ControlMonth 20XXDR 3-63EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSU36Initiating Condition:
Automatic or manual scram fails to shutdown the reactor.Operating Mode Applicability:
1,2Emergency Acton 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. Ap,-aAutomatic scram_-did not shutdown the reactor as indicated by ReactorPower > 6%..ANDb. A-sSubsequent manual / ARI action taken at the reactor control consoles issuccessful in shutting down the reactor.OR2. a. A-nManual scram-did not shutdown the reactor as indicated by ReactorPower > 6%.ANDb. EITHER of the following:
: 1. A-,Subsequent manual / ARI action taken at the reactor control consolesis 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 control consoles or an automatic scram is successful in shutting down the reactor.
This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.EAL #1 BasisFollowing the failure on an automatic reactor scram, operators will promptly initiatemanual actions at the reactor control consoles to shutdown the reactor (e.g., initiate amanual reactor scram). If these manual actions are successful in shutting down theMonth 20XXDR 3-64EP-AA-1004 (Revision XX)
AnnoyNuclearfr&AQdJn AnnAY Exellon NuclasrRECOGNITION CATEGORYSYSTEM MALFUNCTIONS
: reactor, core heat generation will quickly fall to a level within the capabilities of theplant's decay heat removal systems.EAL #2 BasisIf an initial manual reactor trip is unsuccessful, operators will promptly take manualaction at another location(s) on the reactor control 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 control consoles is any operator action, or set of actions,which causes the control rods to be rapidly inserted into the core (e.g., initiating 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 control 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 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 subsequent operator manual actions taken at thereactor control consoles are also unsuccessful in shutting down the reactor, then theI emergency classification level will escalate to an Alert via IC MSA36. Depending uponthe plant response, escalation is also possible via IC FA1. Absent the plant conditions I needed to meet either IC MSA35 or FA1, an Unusual Event declaration is appropriate for this event.I A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.
I 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 determined through other means (e.g., assessment of test results),
then this IC and the EALsMonth 20XXDR 3-65EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS are not applicable and no classification is warranted.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, SU52. Technical Specifications Table 3.3.1.1-1
: 3. DEOP 100 RPV Control4. DEOP 400-5 Failure to ScramMonth 20XXDR 3-66EP-AA-1004 (Revision XX)
AnnAxNuelAarDresden Annex Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSA42Initiating Condition:
UNPLANNED loss of Control Room indications for 15 minutes or longer with asignificant transient in progress.
Operating Mode Applicability:
1,2,3Emergency Acton Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.
Tho E=m...goncy Diocto , should do.laro the Aler promptly upon determining that 15min*utes has boon exceoded, Or Will likely be exceeded-.
: 1. a.
event results in the inability to monitor oneo Or Table MWet th f",e,.-ewi parameters from within the Control Room for >15minutes Or--lene
.[B 14ZR pammDm, Ust]Reactor Po9wer___________________
Table MI Control Room Parameters RP, ..vel , Reactor Power* RPV Water LevelRtP
.RPV Pressure* Primary Containment PressurePria- .. .t.i-m. .* Torus Level....... e. Torus Temperature Suppression Pool LevelSuppression Pool Temperature ANDb. Any Table M2Wft the-
, transient events in progress.
" Automatic Or Manual Dunback gratcr than 26% the P-al reactor pRevwEloc~etrical load rejection greator than 25% full electrical loadMonth 2OXX DR 3-67 EP-AA-1004 (Revision XX)
AnnexNuelAarn1 VVweln Annex Exilin NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS ECCGS (SI) actuation Table M2 Significant Transients
" Turbine Trip" Reactor Scram* ECCS Activation
* Recirc. Runback > 25% Reactor Power Change* Thermal Power oscillations
> 10% Reactor Power ChangeBasis: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 parameter change or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or olacin it in the cold shutdown condition.
includina 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 parameters from within the Control Room. During this condition, the margin to a potential fissionproduct barrier challenge is reduced.
It thus represents a potential substantial degradation in the level of safety of the plant.As used in this EAL, an "inability to monitor" means that values for one mereanv 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, 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 procedures Month 20XXDR 3-68EP-AA-1004 (Revision XX)
AnnoyN urJparflr.~e4.
Annv FvInn Nmir-Ipnr RECOGNITION CATEGORYSYSTEM MALFUNCTIONS addressing 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-IeveIRPV water level and RCS heat removal.The loss of the ability to determine one Or 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 or mroany 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 determined from 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.I 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 RASI.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SA2Month 20XXDR 3-69EP-AA-1004 (Revision XX)
NuelAArVlmlden Anne E xeIon Nuc.IeVar RECOGNITION CATEGORYSYSTEM MALFUNCTIONS IMSU42Initiating Condition:
UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:
1,2,3Emergency Acton Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.J I 0 Iroll l lnoT. iTr&#xfd;nrV=
uirnn.or1
&#xfd;VHF wr~noiiici anctar.0 i-Tflf E W Mictiai 1 &flf= nrrn 5 UnM.onW n crmf-%I g IV mlflant 1 R =inir.o hoo hann awaaandnd or wall likalu ha narnandnd a AR-UNPLANNED event results in the inability to monitor onoe Or mooANY Table M1parameter from within the Control Room for > 15 minutes.Table M1 Control Room Parameters
* Reactor Power" RPV Water Level" RPV Pressure" Primary Containment Pressure* Torus Level" Torus Temperature
: 1. of the following paramctcrs from within the Control Room for 15 minutes2. [BWVR parmctc 3. [PWR Paramctcfr-
: 4. Reaetor Power 6. Reactor-Power-8.RVWater Lcvcl9 &RGS LeveI10. URPV1 Press,,c
: 11. RCS Pr-essure 1-2.Pr-muw
: 13. in Cor-e/Cor-e
: 14. Suppression Pol15. Levels in at leastLevel (site speeienumber) tam16. Supp sion Poo.17..Ste am lnrTempematur-e AuxilayeMonth 20XXDR 3-70EP-AA-1004 (Revision XX)
AnnAyNuelAarfrPAQd1n Annex Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS
: 2. [BWIR parawter-
: 3. WIW-Rparameter 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 parameter change 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 conditions without 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 nAe-O rmorFany 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-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 procedures addressing 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 one OrFmor-any of these parameters from within the ControlRoom is considered to be more significant than simply a reportable condition.
InI addition, if all indication sources for eeo r- merany 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.I Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.
I Escalation of the emergency classification level would be via IC MSA42.Month 20XXDR 3-71EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS Basis Reference(s):
: 1. NEI 99-01 Rev 6, SU2Month 20XXDR 3-72EP-AA-1 004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSA59Initiating Condition:
Hazardous event affecting a SAFETY SYSTEM needd -reauired for the currentoperating mode.Operating Mode Applicability:
1,2,3Emergency Acton Level (EAL):(44 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 e (sito specific hazards)* Other events with similar hazard characteristics as determined by theShift ManagerAND2.b, EITHER of the following:Event damage has caused indications of degraded performance inat least one train of a SAFETY SYSTEM needed-required byTechnical Specification for the current operating mode.ORb._ 2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEMcomponent or structure needed-required by Technical Specification for the current operating mode.Basis:FIRE: Combustion characterized by heat and light. Sources of smoke such as slippingdrive belts or overheated electrical equipment do not constitute FIRES. Observation offlame is preferred but is NOT required if large quantities of smoke and heat areobserved.
EXPLOSION:
A rapid, violent and catastrophic failure of a piece of equipment due tocombustion, chemical reaction or overpressurization.
A release of steam (from highenergy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion.
Suchevents may require a post-event inspection to determine if the attributes of an explosion are present.Month 20XXDR 3-73EP-AA-1 004 (Revision XX) nroHarn AnnoyI=yalnn Nielalrn rncrI~n Ann~v Fv~Inn Nit urI~~rRECOGNITION CATEGORYSYSTEM MALFUNCTIONS SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the EGGS. These aretypically systems classified as safety-related.
VISIBLE DAMAGE: Damage to a component or structure that is readily observable without measurements,
: testing, or analysis.
The visual impact of the damage issufficient to cause concern regarding the operability or reliability of the affectedcomponent or structure.
This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or astructure containing SAFETY SYSTEM components, needed-required for the currentoperating mode, "required",
i.e. required to be operable by Technical Specifications forthe current operating mode. This condition significantly reduces the margin to a loss orpotential loss of a fission product barrier, and therefore represents an actual or potential substantial degradation of the level of safety of the plant. Manual or automatic electrical isolation of safety equipment due to flooding, in and of itself, does not constitute degraded performance and is classified under HU6.EAL 41-b#.a Basis-This EAL addresses damage to a SAFETY SYSTEM train that is required to beoperable by Technical Specifications for the current operating mode, and is inseeAieoperation since indications for it will be readily available.
The indications ofdegraded performance should be significant enough to cause concern regarding theoperability or reliability of the SAFETY SYSTEM train.EAL 44.2.b BasisThis EAL -addresses damage to a SAFETY SYSTEM component that is- required to beoperable by Technical Specifications for the current operating mode, and is not insepeGvoperation or readily apparent through indications alone, er-as well as damage toa structure containing SAFETY SYSTEM components.
Operators will make thisdetermination based on the totality of available event and damage report information.
This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level would be via IC FS1 or RAS1.If the EAL conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.Basis Reference(s):
: 1. NEI 99-01, Rev 6 SA9Month 20XXDR 3-74EP-AA-1004 (Revision XX)
Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSU64Initiating Condition:
RCS leakage for 15 minutes or longer.Operating Mode Applicability:
1,2,3Emergency Acton Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.
The Emrgncy Diroct,-r shonulId4 the Unusual Event promptly upondtrig that 15 mninute has been eXceeded, Or Will likely be oxcevdod.
: 1. RCS unidentified or pressure boundary leakage in the Drywell ..eatef-"ha
> 10 apm for> 15 minutes ..(..t spcific value) for 15 m.inutes Or lon.ger..
OR2. RCS identified leakage in the Drvwell qreateF than-5amfo>1 iuts(ies*pecific value) for 15 mninutec or longer.OR3. Leakage from the RCS to a location outside Drvwell >25 gpm for >15 minutes .greater than 25 gpm. fo 16 minutes or longer.Basis:UNISOLABLE:
An open or breached system line that cannot be isolated, remotely orlocally.This IC addresses RCS leakage which may be a precursor to a more significant event.In this case, RCS leakage has been detected and operators, following applicable procedures, have been unable to promptly isolate the leak. This condition is considered to be a potential degradation of the level of safety of the plant.EAL #1 and EAL #2 BasisThese EALs are focused on a loss of mass from the RCS due to "unidentified leakage",
"pressure boundary leakage" or "identified leakage" (as these leakage types are definedin the plant Technical Specifications).
EAL #3 BasisThis EAL addresses a RCS mass loss caused by an UNISOLABLE leak through aninterfacing system.Month 20XXDR 3-75EP-AA-1004 (Revision XX)
AnnexI=xelon Nuclearfresden Annex Exelnn NucleanrRECOGNITION CATEGORYSYSTEM MALFUNCTIONS These EALs thus apply to leakage into the containment, a secondary-side system (e-g-.,steam gene.r.ato..
r tube,, leakage in a PWR) or a location outside of containment.
The leak rate values for each EAL were selected because they are usually observable with normal Control Room indications.
Lesser values typically require time-consuming calculations to determine (e.g., a mass balance calculation).
EAL #1 uses a lower valuethat reflects the greater significance of unidentified or pressure boundary leakage.The release of mass from the RCS due to the as-designed/expected operation of anyrelief valve does not warrant an emergency classification.
A stuck-onen Electromatic relief valve (ERV)/Taroet Rock SRV or ERV Target RockSRV leakage is not considered either identified or unidentified leakage by Technical Specifications and, therefore, is not applicable to this EAL.The rel.aso of mass from the RCS due to the as designed.expeted operation of..relief valve does not warrant an omorgoncy classification.
r-.. BWR's, aA stuck- penSafety Rolief Valve, (SRV) or, SR'' leakage is not conSidered
+ithe, identified OFunlonintifled leaage by I ifaiation and, tnlo4retro, is not applin lAio to tn"sThe 15-minute threshold duration allows sufficient time for prompt operator actions toisolate the leakage, if possible.
Escalation of the emergency classification level would be via ICs of Recognition Category BA or F.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SU42. Technical Specification 3.4.4, RCS Operational Leakage3. UFSAR 5.2.5, Detection of Leakage through Reactor Coolant Pressure Boundary4. Technical Specifications 3.4.55. Unit 2(3) Appendix A Unit NSO Daily Surveillance Log6. DAN 902(3)-4 A-17 Equip Sump Lvl HI-HI7. DAN 902(3)-4 H-18 DQywaeDy~well Floor Drn Sump Lvl HI-HI8. DOA 0040-01 Slow Leak9. DOP 2000-24 DQywellDrywell Sump Operation
: 10. DGP 02-02 Reactor Vessel Slow FillMonth 20XXDR 3-76EP-AA-1004 (Revision XX)}}

Revision as of 14:03, 1 July 2018

Dresden, Units 2 & 3, Attachment 5, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1004, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 5A and 5B, Cover - Dr 3-76
ML14164A064
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 05/30/2014
From:
Exelon Generation Co
To:
NRC/FSME, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML14164A053 List:
References
NEI 99-01, Rev 6, RA-14-032, RS-14-115, TMI-14-046 EP-AA-1004
Download: ML14164A064 (144)
v • d • e


Text

ATTACHMENT 5DISCUSSION OF REVISIONTO THERADIOLOGICAL EMERGENCY PLAN ANNEXFORDRESDEN NUCLEAR POWER STATIONEP-AA-1004 Enclosures S0SEnclosure 5A -EAL Comparison Matrix DocumentEnclosure 5B -EAL Red-Line Basis DocumentEnclosure 5C -EAL Basis Document NEI 99-01REVISION 6DEVELOPMENT OF EMERGENCY ACTIONLEVELS FOR NON-PASSIVE REACTORSAIrrACHMENT 5DISCUSSION OF REVISION TO THE RADIOLOGICAL EMERGENCY PLAN ANNEX FORDRESDEN STATIONExelon Generation.

00NEI 99-01 Rev 6 1 Proposed EAL I Justification AGIInitiating Condition

-GENERAL EMERGENCY Release 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 1,000mRem TEDE or 5,000 mRem thyroid CDE.Operating Mode Applicability:

1,2,3.4,5,D Emergency Action Level (EAL):Notes:The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

If an ongoing release is detected and the release start time is unknown,assume that the release duration has exceeded 15 minutes.Classification based on effluent monitor readings assumes that a release 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. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs >7.90 E+09 uCilsec for > 15 minutes (as determined by DOP 1700-10 orPPDS -Total Noble Gas Release Rate).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 mRihr are expected tocontinue for > 60 minutes.ORb. Analyses of field survey samples indicate

> 5000 mRem CDEThyroid for 60 minutes of inhalation.

H: No Change 111 Difference FIDeviation

1) Listed site-specific monitors and Threshold values to ensure timelyclassification.
2) Added the following to 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 1 of66 0NEI 99-01 Rev 6 1 Proposed EAL Justification ASIInitiating Condition

-SITE AREA EMERGENCY Release 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 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 100 mR/hr 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,D Emergency Action Level (EAL):Notes:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

I 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.

1. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs> 7.90 E+08 uCilsec for > 15 minutes (as determined by DOP 1700-10 orPPDS -Total Noble Gas Release Rate).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.

No Change FIDifference I-1 Deviation

1) Listed site-specific monitors and Threshold values to ensure timelyclassification.
2) Added the following to 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 1x17 procedure matrix used by the SM.Page 2 of 66 NEI 99-01 Rev 6 [ Proposed EAL [ Justification AA1Initiating Condition

-ALERTRelease of gaseous or liquid radioactivity resulting in offsite dose greater than 10mrem TEDE or 50 mrem thyroid CDE.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 EALt #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 and 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 determining that the applicable time has been exceeded, or will likely be exceeded.

If an ongoing release is detected and the release start time is unknown, 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. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs> 7.90 E+07 uCi/sec for_> 15 minutes (as determined by DOP 1700-10 orPPDS -Total Noble Gas Release Rate).OR2. Dose assessment using actual meteorology indicates doses at or beyond thesite boundary of EITHER:a. > 10 mRemTEDEORb. > 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 (closed window) dose rates > 10 mR/hr areexpected to continue for> 60 minutes.ORb. Analyses of field survey samples indicate

> 50 mRemCDE Thyroid for 60 minutes of inhalation.

D-- No Change 1-- Difference

[I] Deviation

1) Listed site-specific monitors and Threshold values to ensure timely classification.
2) Added the following to 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 11x17 procedure matrix used by the SM.3) A calculation was performed, in accordance with (IAV) 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 [ Proposed EAL Justification AU1Initiating Condition

-UNUSUAL EVENTRelease of gaseous or liquid radioactivity greater than 2 times the (site-specific effluent 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 selpoint established by a current radioactivity discharge permit for60 minutes or longer.3. Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times (site-specific effluent releasecontrolling document limits) for 60 minutes or longer.RU1Initiating Condition:

Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for60 minutes 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 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, assumethat the release duration has exceeded 60 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.

1. Reading on ANY of the following effluent monitors

> 2 times alarmsetpoint established by a current radioactive release discharge permitfor ? 60 minutes.* Radwaste Effluent Monitor 213-2001-948 OR* Discharge Permit specified monitorOR2. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs> 9.02 E+05 uCi/sec for > 60 minutes (as determined by DOP 1700-10 orPPDS -Total Noble Gas Release Rate).OR3. Confirmed sample analyses for gaseous or liquid releases indicateconcentrations or release rates > 2 times ODCM Limit with a releaseduration of > 60 minutes.D No Change E Difference

[I] Deviation

1) Listed site-specific monitors and Threshold values to ensure timely classification.
2) Added the following to 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 lx17 procedure matrix used by the SM.Page 4 of 66 NEI 99-01 Rev 6 Proposed EAL Justification AG2 RG2DANo ChangeDifference

--]Deviatton Initiating Condition

-GENERAL EMERGENCY 1 No ChangeSpent fuel pool level cannot be restored to at least (site-specific Level 3description) for 60 minutes or longer.1) EAL not used in accordance with the discussion in Section 1.4, NRC OrderOperating Mode Applicability:

All EA-12-051, it is recommended that this EAL be implemented when the enhancedspent fuel pool level instrumentation is available for use. The completion of theExample Emergency Action Levels: enhanced SFP level indicators and need for the inclusion of this EAL is beingtracked in accordance with Exelon Generation

Company, LLC's Initial StatusNOTES: The Emergency Director should declare the General Emergency Report to March 12, 2012 Commission Order Modifying Licenses with Regard forpromptly upon determining that 60 minutes has been exceeded, Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) datedor will likely be exceeded October 25,2012.1. Spent fuel pool level cannot be restored to at least (site-specific Level 3description) for 60 minutes or longer.Page 5 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition

-SITE AREA EMERGENCY No Change Difference Deviation Spent 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-12-051, it is recommended that this EAL be implemented when the enhancedOperating Mode Applicability:

Al 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 NEI 99-01 Rev 6 Proposed EAL Justification AA2RAInitiating Condition

-ALERT gRA2 F No Change Difference Deviation Significant lowering of water level above, or damage to, irradiated fuel. Significant lowering of water level above, or damage to, irradiated fuel. 1) Listed site-specific monitors and Threshold values t0 ensure timely classification.

Operating Mode Applicability:

Ail 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-1 2-051, 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. The completion of theenhanced SFP level indicators and need for the inclusion of this EAL is being1. Uncovery of irradiated fuel in the REFUELING PATHWAY.
1. Uncovery of irradiated fuel in the REFUELING PATHWAY.

tracked in accordance with Exelon Generation

Company, LLC's Initial StatusOR Report to March 12, 2012 Commission Order Modifying Licenses with Regard for2. Damage to irradiated fuel resulting in a release of radioactivity from the Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) datedfuel as indicated by ANY of the following radiation monitors:
2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel October 25,2012.as indicated by ANY Table R1 Radiation Monitor reading >1000 mRemlhr.(site-specific listing of radiation
monitors, and the associated
readings, Table RIsetpoints and/or alarms) Fuel Handling Incident Radiation Monitors3. Lowering of spent fuel pool level to (site-specific Level 2 value).
  • Refuel Floor High Range ARM Station #2(4).Fuel Pool Radiation MonitorPage 7 of 66 NEI 99-01 Rev 6 Proposed EAL Justification AU2Initiating Condition:

UNUSUAL EVENTUNPLANNED loss of water level above irradiated fuel.Operating Mode Applicability:

AllExample Emergency Action Levels:1. a. UNPLANNED water level drop in the REFUELING PATHWAY asindicated by ANY of the following:

(site-specific level indications).

ANDb. UNPLANNED rise in area radiation levels as indicated by ANY of thefollowing radiation monitors.

(site-specific list of area radiation monitors)

RU2Initiating 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 level drop in the REFUELING PATHWAY as indicated byANY of the following:

" Refueling Cavity water level < 466 in. (Refuel Outage ReactorVessel and Cavity Level Instrument LI 2(3)-263-114)

OR" Spent Fuel Pool water level < 19 ft. above the fuel (< 33 ft. 9 in.indicated level).OR" Indication or report of a drop in water level in the REFUELING PATHWAY.ANDb. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors inTable R1.E No Change [: Difference

[: Deviation

1) Listed site specific level indication and monitors to ensure timelyclassification.

Table RIFuel Handling Incident Radiation MonitorsI* Refuel Floor High Range ARM Station #2(4).Fuel Pool Radiation MonitorIPage 8 of 66 NEI 99-01 Rev 6 1 Proposed EAL [ Justification AA3Initiating 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 iswarranted

1. Dose rate greater than 15 mR/hr in ANY of the following areas:* Control Room* Central Alarm Station* (other site-specific areas/rooms)
2. An UNPLANNED event results in radiation levels that 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 R3 was already inoperable, or outof service, before the event occurred, then no emergency classification is warranted.

1. Dose rate> 15 mR/hr in ANY of the following Table R2 areas:E No Change D:1 Difference 1 Deviation
1) Listed site specific plant rooms and areas with identified mode applicability toensure timely classification.

Table R2Areas Requiring Continuous Occupancy

" Main Control Room (Unit 2 ARM Station #22)" Central Alarm Station -(by survey)OR2. UNPLANNED event results in radiation levels that prohibit or significantly impede access to ANY of the following Table R3 plant rooms or areas:Table R3Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Reactor Building*

Modes 3, 4, and 5*Areas required to establish shutdown coolingPage 9 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SU3RU3 I-- No Change Difference U Deviation Initiating Condition:

UNUSUAL EVENT Initiating Condition:

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

Operating Mode Applicability:

Operating Mode Applicability:

2) Listed this system category EAL in the radiological category EAL section 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. Offgas system radiation monitor HI-HI alarm.OR OR2. Sample analysis indicates that a reactor coolant activity value is greater than 2. Specific coolant activity

> 4.0 uCilgm Dose equivalent 1-131.an allowable limit specified in Technical Specifications.

Page 10 of 66 0 0 0NEI 99-01 rev 6 Fission Product Barrier Matrix_________________

Prdc Barrier________

Mari Hot__________

MaFGI Loss of any two barriers AND Loss or Potential Loss of third barrier.1,2,3FSI Loss or Potential Loss of ANY two barriers.

1,2,3FAl ANY Loss or ANY Potential Loss of either Fuel Clad or RCS1.2,3FC -Fuel Clad RC -Reactor Coolant System CT -Containment Sub-Category Loss Potential Loss Loss Potential Losa Loss Potential Loss1. RCS Activity

/ A. UNPLANNED rapid drop in primary A. Primary containment pressure greater1.imar RCS (Sie scontainment pressure following than (site-specific value)Containment A. Primary containment Pressure primary containment pressure rise ORPressure

/ reator coolant activity is greater None greater than (site-specific value) None OR B. (site-specific explosive mixture) existsthan 300 uCilgm dose equivalent due to RCS leakage.

inside primary containment Prmr -3)B. Primary containment pressure isd rmr otimnContainment 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 water 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 downstream pathway to the environment existsafter primary containment isolation signalORA. UNISOLABLE primary system leakageA. UNISOLABLE break in any of the that results in exceeding EITHER of .Intentional primary containment 3.RCS Leak Rate/ following:

( site-specific systems with the following:

venting per EOPsPrimary None None potential for high-energy line breas) 1. Max Normal Operating OR NoneContainment OR Temperature C. UNISOLABLE primary systemIsolation Failure B. Emergency RPV DepressuizationOR leakage that results in exceeding

2. Max Normal Operating Area EITHER of the following:

Radiation Level. 1. Max Safe Operating Temperature.

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-specific Radiation (site-specific value), specific value). value).A. Any Condition in the opinion of A Any Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the5. Emergency the Emergency Director that Emergency Director that indicates Emergency Director that indicates Loss Emergency Director the iniofte A.rAny Coedton in at indicates Loss Emergency Director that indicates Potential Director Judgment indicates Loss of the Fuel Clad Potential Loss of the Fuel Clad Barrier.

of the RCS Barrier.

Potential Loss of the RCS Barrier.

of the Containment Barrier.

Loss of the Containment Barrier.Barrier.Page 11 of 66 Proposed Fission Product Barrier MatrixFission~~

ProducBarrirMatixHotMatri FGI Loss of any two barriers AND Loss or Potential Loss of third barrier.(1[]91A I FSS Loss or Potential Loss of ANY two barriers.

E1IgA I PAl ANY Loss or ANY Potential Loss of either Fuel Clad or RCS 19]9FC -Fuel Clad RC -Reactor Coolant System CT -Containment Sub-Categery Loss Potential Loss Loss Potential Lose Loss Potential LossCoolant activity 300 uCligm Dose None NoneI RCS Activity Equivalent 1-131. None None None2. RPV water level cannot be restored and 1. RPV water level cannot be restored and1. Primary containment flooding is maintained

, .143 inches (TAF) maintained

> -143 Inches (TAF) Prmary containment flooding is required.

2. RPV Waler required OR OR None Noneeve 3. RPV water level cannot be determined.
2. RPV water level cannot be determined.
3. Drywell pressure

_ 62 pslg and nsing.OR1. Drywell pressure

>2.0 psig. 1. UNPLANNED rapid drop in Drywell 4. a. Drywall or tows hydrogen concentration

3. Primary AND pressure following Drywell pressure rise ý 6%.Contaiment NnD OR ANDon tainment None None 2. Drywall pressure rise is due to RCS None 2. Drywall pressure response not consistent
b. Drywell or tows oxygen concentration Prssure/Conditions leakage with LOCA conditions.

_5%.OR5. Heat Capacity Limit (DEOP 200-1, Fig.M)exceeded.

3. UNISOLABLE primary system leakage that1. UNISOLABLE Main Steam Line results in EITHER of the following:

(MSL),Isolation Condenser, HPCI. a. Secondary Containment areaFeedweter, or RWCU line break. temperature 0 DEOP 300-1 Maximum4.RCS Leak Rate None None OR Normal operating levels. Nose NoneORRS eNonateNneNoeoRneO

2. Emergency RPV Depressuedzaon is b. Secondary Containment radiation levelrequired.

> DEOP 300-1 Maximum Normaloperating level.5,Primary Drywell radiation monitor reading Drywell radiation monitor reading Drywell radiation monitor readingContainment 0 6.70 E+02 R/hr (670 RIhr). None > 100R/hr (>1.00 E+02 R/hr). None None > 1.60 E+03 R/hr (1600 R/hr)Radiation

1. UNISOLABLE direct downstream pathway tothe environment exists after primarycontainment isolation signal.OR2. Intentional Primary Containment venting/purging per EOPs or SAGs due toaccident conditions.

ORC. Primary 3. UNISOLABLE primary system leakage thatCnanet None None Nose None UNSLEENone sontainmen results in EITHER of the following:

ation Failure a. Secondary Containment areatemperature s DEOP 300-1,Maximum Safe operating levels.ORb. Secondary Containment arearadiation level s DEOP 300-1,Maximum Safe operating levels.7. Emergency A. Any Condition in the opinion of the A. Any Condition in the opinion of the A. ANY Condition in the opinion of the A. Any Condition in the opinion of the A Any Condition in the opinion of the A. Any Condition in the opinion of the Emergency 7.Eergen 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 Barrer. Loss of the RCS Barrier.

Containment Barrier.

Containment Banrer.Page 12 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Fuel Clad Barrier FCi Category:

Fuel Clad BarrierC No Change Diffence Deviation RCS Activity 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. (Site specific indications that reactor coolant activity is greater than 300 uCi/gm Coolant activity

> 300 uCllgm Dose Equivalent 1-131.dose equivalent 1-131)Page 13 of 66 NEI 99-01 Rev 6 Proposed EAL Justification FC2Category:

Fuel Clad BarrierRPV Water LevelOperating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot ShutdownFission Product Barrier Threshold:

LossA. Primary containment flooding required.

Potential LossA. RPV water level cannot be restored and maintained above (site-specific RPVwater level corresponding to top of active fuel) or cannot be determined.

Category:

Fuel Clad BarrierRCS ActivityOperating Mode Applicability:

1,2,3Fission Product Barrier (FPB) Threshold:

Loss1. Plant conditions indicate Primary Containment flooding is required.

Potential Loss2. RPV water level cannot be restored and maintained

> -143 inches (TAF)OR4. RPV water level cannot be determined.

FC2[fl No Change 1 Difference 1 Deviation

1) Listed site-specific threshold value to ensure timely classification.

Page 14 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Fuel Clad Barrier FC4 Category:

Fuel Clad Barrier FC5 E No Change Difference Deviation Primary 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 > 6.70 E+02 RWhr (670 R/hr).value).Page 15 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Fuel Clad Barrier FC6 Category:

Fuel Clad Barrier FC7 No Change Differene

[ Deviation Emergency 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.Poteritial 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 Potential Loss of the Fuel Clad Barrier.

Loss of the Fuel Clad Barrier.Page 16 of 66 NEI 99-01 Rev 6 Proposed EAL Justification NEI 99-01Rev 6Proposed EALJustification iRCICategory:

Reactor Coolant System BarrierPrimary Containment PressureOperating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot ShutdownFission Product Barrier Threshold:

LossA. Primary containment pressure greater than (site-specific value) due to RCSleakage.RC3Category:

Reactor Coolant System BarrierPrimary Containment Pressure/Conditions Operating Mode Applicability:

1,2,3Fission Product Barrier (FPB) Threshold:

Loss1. Drywell pressure

>2.0 psig.AND2. Drywell pressure rise is due to RCS leakage.E No Change 1 Difference 1 Deviation

1) Listed site-specific threshold value to ensure timely classification.

Page 17 of 66 NEI 99-01 Rev 6RC2Category:

Reactor Coolant System BarrierRPV Water LevelOperating Mode Applicability:

Power Operation,

Startup, Hot Standby, Hot ShutdownFission Product Barrier Threshold:

LossA. RPV water level cannot be restored and maintained above (site-specific RPVlevel corresponding to the top of active fuel) or cannot be determined.

Proposed EALJustification RC2Category:

Reactor Coolant System BarrierRPV Water LevelOperating Mode Applicability:

1,2,3Fission Product Barrier (FPB) Threshold:

Loss1. RPV water level cannot be restored and maintained

> -143 inches (TAF).OR2. RPV water level cannot be determined.

No Change --' Difference 1 Deviation

1) Listed site-specific threshold value to ensure timely classification.

Page 18 of 66 NEI 99-01 Rev 6 Proposed EAL Justification RC R4l-Xi- NO Change II Difference II Deviation Category:

Reactor Coolant System Barrier Category:

Reactor Coolant System Barrier LECD.eiRCS 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), Isolation Condenser, HPCI, Feedwater, for high-energy line breas) or RWCU line break.OR ORB. Emergency RPV Depressurization
2. Emergency RPV Depressurization is required.

Potential LossA. UNISOLABLE primary system leakage that results in exceeding EITHER of the Potential Lossfollowing:

1. Max Normal Operating Temperature.
3. UNISOLABLE primary system leakage that results in EITHER of the following:

OR a. Secondary Containment area temperature

> DEOP 300-1 Maximum2. Max Normal Operating Area Radiation Level. Normal operating levels.ORb. Secondary Containment area radiation level > DEOP 300-1 MaximumNormal operating levels.Page 19 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Reactor Coolant System Barrier RC4 Category:

Reactor Coolant System Barrier RC5 E No Change Difference Deviation Primary 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 > 100 R/hr (>1.00E+02 R/hr).value).Page 20 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Reactor Coolant System Barrier RC6 Category:

Reactor Coolant System Barrier RC7 No Change Difference Deviation Emergency 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 Potential Loss of the RCS Barrier.

2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.Page 21 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CTI Category:

Containment BarrierC No Change Difference Deviation Primary Containment Conditions Primary Containment Pressure/Conditions 1 ) Listed site-specific threshold values to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

2) The words "and rising" were added to account for the momentary spike inPower Operation,
Startup, Hot Standby, Hot Shutdown 1,2,3 pressure where pressure is now lowering, the risk of a potential loss ofcontainment is no longer present, this wording is also consistent with present EALFission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold, wording.Loss LossC. UNPLANNED rapid drop in primary containment pressure following primary 1. UNPLANNED rapid drop in Drywell pressure following Drywell pressure rise.containment pressure rise OROR2. Drywell pressure response no._t 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)OR 3. Containment pressure

> 62 pslg and rising.E. (site-specific explosive mixture) exists inside primary containment OROR 4. a. Drywell or torus Hydrogen concentration

> 6%.3. HCTL exceeded.

ANDb. Drywell or torus Oxygen concentration

> 5%.OR5. Heat Capacity Limit (DEOP 200-1, Fig. M) exceeded.

Page 22 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CT2 Category:

Containment Barrier CT2 No Change Difference

[-1 Deviation RPV 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 Ccontainment flooding is required.

Page 23 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CT3 CTS IN hne [ ifeec eitoCategory:

Containment Barrier Category:

Containment Barrier C No Change Difference Deviation Primary 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 ORB. Intentional primary containment venting per EOPs 2. Intentional Primary Containment venting/purging per EOPs or SAMGs due toOR accident conditions.

C. UNISOLABLE primary system leakage that results in exceeding EITHER of the ORfollowing:

3. UNISOLABLE primary system leakage that results in EITHER of the following:
1. Max Safe Operating Temperature.
a. Secondary Containment area temperature

> DEOP 300-1, MaximumOR Safe operating levels.2. Max Safe Operating Area Radiation Level. ORb. Secondary Containment area radiation level > DEOP 300-1, MaximumSafe operating levels.Page 24 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CT4 Category:

Containment Barrier CT5 E No Change Difference Deviation Primary 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-specific value). Drywall radiation monitor reading > 1.60 E+03 R/hr (1600 R/hr).Page 25 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CTS Category:

Containment Barrier CT7 No Change Difference

[] Deviation Emergency 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 Loss of the Containment Barrier.

2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.Page 26 of 66 NEI 99-01 Rev 6 Proposed EAL Justification 301 MG1 lInitiating Condition:

GENERAL EMERGENCY Initiating Condition:

[Gj No Change LJ Difference

[j Deviation Prolonged loss of all offsite and all onsite AC power to emergency buses. Prolonged loss of all offsite and all onsite AC power to emergency buses.1) Listed site specific equipment, site specific time based on station 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-specific emergency buses).1 Loss of ALL offsite AC power to unit ECCS buses.AND AND2. Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency dieselb. EITHER of the following:

generators to supply power to unit ECCS 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 ECCS bus in < 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is not likely." (Site-specific indication of an inability to adequately ORremove heat from the core)b. RPV water level cannot be restored and maintained

> -164 inches.Page 27 of 66 0NE199-01 Rev 6 Proposed EAL [Justification Initiating Condition:

SITE AREA EMERGENCY Loss 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 Emergency promptly 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 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.

1. Loss of ALL offsite AC Power to unit ECCS buses.AND2. Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency dieselgenerators to supply power to unit ECCS buses.AND3. Failure to restore power to at least one ECCS bus in < 15 minutes from the timeof loss of both offsite and onsite AC power.M No Change FIDifference 1 Deviation
1) Listed site specific equipment to ensure timely classification.

Page 28 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification SA1IInitiating 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 determining 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.MA1IInitiating 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 ECCS buses reduced to only one of the following power sources for > 15 minutes.* Reserve auxiliary Transformer TR-22 (TR-32)* Unit auxiliary transformer TR-21 (TRý31)* Unit Emergency Diesel Generator DG 2(3)* Shared Emergency Diesel Generator DG 2/3* Station Blackout Diesel Generator DG 2(3)* Unit crosstie breakersAND2. ANY additional single power source failure will result in a loss of ALL AC powerto SAFETY SYSTEMS.M No Change ] Difference FIDeviation
1) Listed site specific equipment to ensure timely classification.

Page 29 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification Su1Initiating 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 longerMUlInitiating 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 buses for > 15 minutes.F No Change -Difference 7 Deviation

1) Listed site specific equipment to ensure timely classification.

Page 30 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SG8Initiating Condition:

GENERAL EMERGENCY Loss 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 emergency buses) for 15 minutes or longer.ANDIndicated voltage is less than (site-specific bus voltage value) on ALL(site-specific vital DC buses) 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 ECCS buses.AND2. Failure of DG 2(3), shared DG 2(3) and SBO DG 2(3) emergency dieselgenerators to supply power to vital buses.AND3. Voltage is < 105 VDC on 125 VDC battery buses #2 and #3.AND4. ALL AC and Vital DC power sources have been lost for> 15 minutes.1 '1 No Change M Difference 1-- Deviation
1) 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 Justification SS8Initiating Condition:

SITE AREA EMERGENCY Loss 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 Emergency promptly 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:

1,2,3D] No Change F Difference FIDeviation

1) 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.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.

Voltage is < 105 VDC on 125 VDC battery buses #2 and #3 for >15 minutes.Page 32 of 66 NEI 99-01 Rev 6 [ Proposed EAL I Justification SS5Initiating Condition:

SITE AREA EMERGENCY Inability to shutdown the reactor causing a challenge to (core cooling [PWR] / RPVwater level [BWR]) or RCS heat removal.Operating Mode Applicability:

Power Operation Example Emergency Action Levels:1. a. An automatic (trip [PVVRj / scram [BVVR]) 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 adequately remove heat from the core)OR2. (Site-specific indication of an inability to adequately remove heat from the RCS)MS3Initiating 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> 6%.AND2. ALL manual / ARI actions to shutdown the reactor have been unsuccessful asindicated by Reactor Power > 6%.AND3. EITHER of the following conditions exist:" RPV water level cannot be restored and maintained

> -164 inches.OR" Heat Capacity Limit (DEOP 200-1, Fig. M) exceeded.

D- No Change M Difference D Deviation

1) 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 Proposed EAL Justification SA5Initiating 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 Operation Example 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.

I. a. An automatic (trip [PWR] / 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 > 6%.AND2. Manual I ARI actions taken at the reactor control consoles are not successful in shutting down the reactor as indicated by Reactor Power > 6%.D- No Change FIDifference 1'1 Deviation
1) 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 1 Proposed EAL I Justification SU5Initiating Condition:

UNUSUAL EVENTAutomatic or manual (trip [PWR] / scram [BWR]) fails to shutdown the reactor.Operating Mode Applicability:

Power Operation Example 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 [BWR]) 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 [BWR]) 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 successful in shutting down the reactor.MU3Initiating Condition:

Automatic or manual scram fails to shutdown the reactor.Operating Mode Applicability:

FH No Change M Difference 1 Deviation 1 ) 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 > 6%..ANDb. Subsequent manual / ARI action taken at the reactor control consoles issuccessful in shutting down the reactor.OR2. a. Manual scram did not shutdown the reactor as indicated by ReactorPower > 6%.ANDb. EITHER of the following:
1. Subsequent manual / ARI action taken at the reactor controlconsoles is successful in shutting down the reactor.OR2. Subsequent automatic scram / ARI is successful in shutting down thereactor.Page 35 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SA2MA4Initiating 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 one or more of thefollowing parameters from within the Control Room for 15 minutes or longer.[see table below][ SWR parameter list] [PWR parameter list]Initiating 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 MI parameter from within the Control Room for >15 minutes.M No Change FIDifference FIDeviation Reactor Power Reactor PowerRPV Level RCS LevelRPV Pressure RCS PressurePrimary Containment Pressure In Core/Core Exit Temperature Levels in at least (site specificSuppression Pool Level number) steam generators Steam Generator Auxiliary orSuppression Pool Temperature Emergency Feed Water FlowTable M1 Control Room Parameters

" Reactor Power" RPV Water Level* RPV Pressure* Primary Containment Pressure* Torus Level* Torus Temperature AND 12. ANY Table M2 transient in progress.

ANDb. 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

" Turbine Trip" Reactor Scram" ECCS Activation

" Recirc. Runback > 25% Reactor Power Change" Thermal Power oscillations

> 10% Reactor Power ChangePage 36 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SU2Initiating 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 one or more of thefollowing parameters 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 Temperature Levels in at least (site specificSuppression Pool Level number) steam generators Steam 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 parameter from within the Control Room for > 15 minutes.F] No Change FIDifference FIDeviation Table M1 Control Room Parameters

  • Reactor Power* RPV Water Level* RPV Pressure* Primary Containment Pressure* Torus LevelTorus Temperature Page 37 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SA9MA6Initiating Condition:

ALERTInitiating Condition:

ALERTIF1 No Change FX Difference F] Deviation Hazardous event affecting a SAFETY SYSTEM needed for the current operating mode.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 performance in 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.Hazardous event affecting a SAFETY SYSTEM required for the current operating mode.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 determined 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 Specification for the currentoperating mode.ORb. The event has caused VISIBLE DAMAGE to a SAFETYSYSTEM component or structure required by Technical Specification for the current operating mode.1) No additional site specific hazard noted2) Changed the word "needed" to "required" in the IC and to "required by Technical Specification" in the EAL, to be consistent with terminology used by operators andminimize confusion.

Page 38 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification SU4Initiating 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-specific value) 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:

1,2,3Emergency 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. RCS unidentified or pressure boundary leakage in the Drywell > 10 gpm for> 15 minutes.OR2. RCS identified leakage in the Drywell >25 gpm for> 15 minutes.OR3. Leakage from the RCS to a location outside the Drywell >25 gpm for> 15 minutes.F-H No Change F IDifference FIDeviation 1 ) 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.

Page 39 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification SUBInitiating Condition:

UNUSUAL EVENTLoss of all onsite or offsite communications capabilities Operating 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)MU7Initiating Condition:

Loss of all onsite or offsite communication capabilities.

Operating Mode Applicability:

1,2,3H No Change F Difference F Deviation

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

Emergency Action Level (EAL):1. Loss of ALLTable M3 Onsite communications capability affecting theability to perform routine operations.

OR2. Loss of ALL Table M3 Offsite communication capability affecting theability to perform offsite notifications.

OR3. Loss of ALL Table M3 NRC communication capability affecting the abilityto perform NRC notifications.

Table M3 Communications Capability System Onsite Offsite NRCPlant Radio XPlant Page XSound Powered Phones XAll telephone Lines (Commercial and X X Xmicrowave)

ENS X XHPN X XSatellite Phones X XPage 40 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CA2Initiating 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.CAIInitiating Condition:

Loss of all offsite and onsite AC power to emergency buses for 15 minutes or longer.Operating Mode Applicability:

4,5, DEmergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining that theapplicable time has been exceeded, or will likely be exceeded.

1. Loss of ALL offsite AC power to unit ECCS buses.AND2. Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency dieselgenerators to supply power to unit ECCS buses.AND3. Failure to restore power to at least one unit ECCS bus in < 15 minutes fromthe time of loss of both offsite and onsite AC power.No Change 1 Difference 1 Deviation
1) Listed site specific equipment to ensure timely classification.

Page 41 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CU2 CU1 -oCag -ifrne F- eitoInitiating Condition:

UNUSUAL EVENT Initang Condition:No Change Difference Deviation Loss of all but one AC power source to emergency buses for 15 minutes or longer. Loss of all but one AC power source to emergency buses for 15 minutes or 1) Listed site specific equipment to ensure timely classification.

Operating Mode Applicability:

longer.Cold Shutdown, Refueling, Defueled Operating Mode Applicability:

Example Emergency Action Levels: 4,5, DNote: The Emergency Director should declare the Unusual Event promptly upon Emergency Action Level (EAL):determining that 15 minutes time has been exceeded, or will likely be exceeded.

Note:1. a. AC power capability to (site-specific emergency buses) is reduced to a The Emergency Director should declare the event promptly upon determining thatsingle power source for 15 minutes or longer, the applicable time has been exceeded, or will likely be exceeded.

AND 1. AC power capability to unit ECCS buses reduced to only one of theb. Any additional single power source failure will result in loss of all AC following power sources for > 15 minutes.power to SAFETY SYSTEMS.

  • Reserve auxiliary Transformer TR-22 (TR-32)* Unit auxiliary transformer TR-21 (TR-31)* Unit Emergency Diesel Generator DG 2(3)* Shared Emergency Diesel Generator DG 2/3* Station Blackout Diesel Generator DG 2(3)* Unit crosstie breakersAND2. ANY additional single power source failure will result in a loss of ALL ACpower to SAFETY SYSTEMS.Page 42 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CASInitiating Condition

-ALERTHazardous event affecting SAFETY SYSTEM needed for the current operating mode.Operating Mode Applicability:

Cold Shutdown, Refueling Example 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 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 operating mode.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 Technical Specifications for the current operating mode.D No Change E Difference Deviation
1) No additional site specific hazard noted2) Changed the word "needed" to "required" in the IC and to "required byTechnical Specification" in the EAL, to be consistent with terminology used byoperators and minimize confusion.

Page 43 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:

UNUSUAL EVENT Initiating Condition:

CU1 No Change Difference Deviation Loss 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 be The Emergency Director should declare the event promptly upon determining thatexceeded, the 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 buses #2 and #3for> 15 minutes.Page 44 of 66 NEI 99-01 Rev 6 1 Proposed EAL I Justification CU5Initiating Condition:

UNUSUAL EVENTLoss of all onsite or offsite communications capabilities Operating 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 C1 Offsite communication capability affecting theability to perform offsite notifications.

OR3. Loss of ALL Table C1 NRC communication capability affecting theability to perform NRC notifications.

Table Cl Communications Capability System Onsite Offsite NRCPlant Radio XPlant Page XSound Powered Phones XAll telephone Lines (Commercial and X X Xmicrowave)

ENS X XHPN X XSatellite Phones X XE No Change D ] Difference 1 Deviation

1) Listed site specific communications methods to ensure timely classification Page 45 of 66 0NEI 99-01 Rev 6 Proposed EAL Justification CA3 CABInitiating Condition:

ALERT Initiating Condition:

E No Change Difference Deviation Inability to maintain the plant in cold shutdown.

Inability to maintain plant in cold shutdown.

1) Listed site specific Technical Specification cold shutdown temperature limit 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 beexceeded.

The 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-specific Technical Specification cold shutdown temperature limit) for greater thanthe duration specified in the following table. 1. UNPLANNED rise in RCS temperature>

212rF 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.

[PWRJ) Table C2 RCS Heat-up Duration Thresholds Table: 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 Established 0 minutesNot 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 not* If 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 temperature rise due to loss of decay heat removal.Page 46 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:

UNUSUAL EVENT CU3 Initiating Condition:

CU5 No Change Difference Deviation UNPLANNED 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 consistent Example 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 determining be exceeded.

that the applicable time has been exceeded, or will likely be exceeded.

1. UNPLANNED increase in RCS temperature to greater than (site-specific Technical Specification cold shutdown temperature limit).2. Loss of ALL RCS temperature and (reactor vessel/RCS

[PWR] or RPV 1. UNPLANNED rise in RCS temperaturem>

212F due to loss of decay[BWR]) level indication for 15 minutes or longer. heat removal.OR2. Loss of the following for >15 minutes." ALL RCS temperature indications AND" ALL RPV water level indications Page 47 of 66 0NEI 9941 Rev 6 ] Proposed EAL Justification CGaInitiating Condition:

GENERAL EMERGENCY Loss of (reactor vessel/RCS

[PWR] or RPV [BWR]) inventory affecting fuel cladintegrity with containment challenged.

Operating Mode Applicability:

Cold Shutdown.

Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the General Emergency promptly upon determining that 30 minutes time has been exceeded, orwill likely be exceeded.

1. a. (Reactor vessel/RCS

[P/R] 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 [BW4R) 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

[P/R]* 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 RPV inventory affecting fuel clad integrity with containment challenged.

Operating Mode Applicability:

4,5Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

1. a. RPV water level < -143 inches (TAF) for > 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 coreuncovery.

OR* Refuel Floor Hi Range ARM >3000 mR/hr.ANDc. ANY Containment Challenge Indication (Table C4)LI No Change E Difference I: Deviation

1) 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 instances when 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 Torus level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory lossTable: Containment Challenge Table* CONTAINMENT CLOSURE not established*
  • (Explosive mixture) exists inside containment
  • UNPLANNED increase in containment pressure* Secondary containment radiation monitor reading above (site-specific value) [BWR]if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency isnot required.
  • Rise in level is attributed to a loss of RPV inventory.

Table C4 Containment Challenge Indications

> 6% and Oxygen >5%* UNPLANNED rise in containment pressure* CONTAINMENT CLOSURE not established*

  • ANY Secondary Containment radiation monitor > DEOP 300-1Maximum Safe operating level.if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency isnot required.

Page 48 of 66 NEI 9901 Rev 6 Proposed EAL Justification CSIInitiating Condition:

SITE AREA EMERGENCY Loss of (reactor vessel/RCS

[PWR] or RPV [BWR]) inventory affecting coredecay heat removal capability.

Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2 or 3)Note: The Emergency Director should declare the Site Area Emergency promptly upon determining that 30 minutes time has been exceeded, orwill likely be exceeded.

1. a. CONTAINMENT CLOSURE not established.

ANDb. (Reactor vessel/RCS

[PIVR] or RPV [BWR]) level less than (site-specific level).2. a. CONTAINMENT CLOSURE established.

ANDb. (Reactor vessel/RCS

[PVAR] or RPV [BWR]) level less than (site-specific level).3. a. (Reactor vessel/RCS

[PWR] or RPV [BWR]) 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 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 determining that the applicable time has been exceeded, or will likely be exceeded.

1. With CONTAINMENT CLOSURE not established, RPV water level<-60 inchesOR2. With CONTAINMENT CLOSURE established, RPV water level < -143inches (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" Refueling Floor Hi Range ARM >3000 mR/hr.Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Torus 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.

D No Change E Difference 1 Deviation

1) Listed site specific values for level, radiation
monitors, and sumps and tanksto ensure timely classification.
2) EAL #1 Dresden Station does not have a low, low, low RPV water level valuestated within their Technical Specifications, all ESF functions come from thelow, low value of -54 inches, NEI 99-01 rev 6 developer notes for CS1 requestthe developer to use the low, low, low value for declaration of a SAE whenContainment Closure is not established, as such an RPV water level -60 incheswas selected as the threshold value since it is substantially above TAF RPVwater level of -143 inches and substantially below the low low value of -54.15clearly indicating a worsening of the condition and the need to escalate theemergency from an Alert condition,
3) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Page 49 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification CA1Initiating Condition:

ALERTLoss of (reactor vessel/RCS

[PWR] or RPV [BWRJ) inventory Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Alert promptly upondetermining that 15 minutes time has been exceeded, or witl 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 [BVVR]) 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 inventory Operating Mode Applicability:

4,5Emergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

1. Loss of RPV inventory as indicated by level < -54 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 Torus 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.

D- No Change E Difference El Deviation

1) Listed site specific levels, and sumps and tanks to ensure timelyclassification.
2) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Page 50 of 66 0NEI 99-01 Rev 6 Proposed EAL Justification Cu1Initiating Condition:

UNUSUAL EVENTUNPLANNED loss of (reactor vessel/RCS

[PWR] or RPV [BWR]) inventory for15 minutes or longer.Operating Mode Applicability:

Cold Shutdown, Refueling Example 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

[PIAR] 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 determining that the applicable time has been exceeded, or will likely be exceeded.

1. UNPLANNED loss of reactor coolant results in the inability to restore andmaintain RPV water level above the procedurally established lower limitfor > 15 minutes.OR2. a. RPV water level unknownANDb. Loss of RPV inventory per Table C3 indications.

Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Torus 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.

D No Change f Difference 1: Deviation

1) Described "a required lower limit" as a procedurally established lower limit,andlisted site specific sumps and tanks to ensure timely classification.
2) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keepingwith current EAL wording.Page 51 of66 NEI 99-01 Rev 6Proposed EALJustification NEI 99-01 Rev 6 Proposed EAL Justification 1 -1HG1HG1Initiating Condition:

GENERAL EMERGENCY HOSTILE 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 PROTECTED AREA 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 [PWR] / 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 occurring or has occurred within the PROTECTED AREA.AND2. a. ANY Table H1 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)F No Change M Difference 1 Deviation
1) 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 NEI199-01 Rev 6Proposed EALJustification NEI 99-01 Rev 6 Proposed EAL Justification HS1HSIInitiating Condition:

SITE AREA EMERGENCY HOSTILE ACTION within the Protected Area.Operating Mode Applicability:

Initiating Condition:

HOSTILE ACTION within the Protected Area.Operating Mode Applicability:

1, 2, 3,4, 5, DNo Change FIDifference

[IDeviation

1) List site security shift supervision as Security Force.AllExample Emergency Action Levels:A HOSITLE ACTION is occurring or has occurred within the PROTECTED AREAas reported by the (site-security shift supervision).

Emergency 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 1 Proposed EAL Justification HA1Initiating Condition:

ALERTHOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attackthreat within 30 minutes.Operating Mode Applicability:

AllExample Emergency Action Levels: (1 or 2)1. A HOSTILE ACTION is occurring or has occurred within the OWNERCONTROLLED AREA as reported by the (site-specific security shiftsupervision).

2. A validated notification from NRC of an aircraft attack threat within 30minutes of the site.HA1Initiating Condition:

HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attackthreat within 30 minutes.Operating Mode Applicability:

1,2,3,4,5,D Emergency Action Level (EAL):1. A validated notification from NRC of an aircraft attack threat < 30 minutesfrom the site.OR2. Notification by the Security Force that a HOSTILE ACTION is occurring orhas occurred within the OWNER CONTROLED AREA.No Change -Difference

-Deviation

1) List site security shift supervision as Security Force.Page 54 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HUI HUItInitiating Condition:

UNUSUAL EVENT Initiating Condition:

HUI No Change [j- Difference

[ Deviation Confirmed SECURITY CONDITION or threat.Confirmed SECURITY CONDITION or threat. 1) List site security shift supervision as Security Force.Operating 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-101-1 32, Security Assessment and Response to Unusual Activities.
2. Notification of a credible security threat directed at the site.OR3. A validated notification from the NRC providing information of an aircraft
2. A validated notification from the NRC providing information of an aircraftthreat, 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 Justification HS6 HS2Initiating Condition:

SITE AREA EMERGENCY Initiating Condition:

H No Change I Difference FIDeviation Inability to control a key safety function from outside the Control Room. Inability to control a key safety function from outside the Control Room. 1) EAL uses the site specific Control Room evacuation procedure to effectively list all of the alternate locations, panels, and stations requested by thedeveloper notes. This would be the procedure the Control Room would enterOperating Mode Applicability:

Operating Mode Applicability:

should such an event occur, this allows for greater clarity as to when this EALwould apply than if each panel and station used in alternate shutdown were toAll 1,2, 3, 4, 5, D be listed,2) Added descriptors to better explain each safety function and allow for aExample Emergency Action Levels: (1 and 2) Emergency Action Level (EAL): timely classification.

Note: The Emergency Director should declare the Site Area Emergency Note:promptly upon determining that (site-specific number of minutes) has 3) Changed "An event" to" A Control Room evacuation" to remove confusion ifbeen exceeded, or will likely be exceeded.

The Emergency Director should declare the event promptly upon determining that the partial plant control was transferred to outside the control room with the controlapplicable time has been exceeded, or will likely be exceeded.

room still staffed, due to testing or equipment failure.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 transferred from theControl Room to alternate locations per DSSP 0100-CR, Hot Shutdown Procedure

-2. Control of ANY of the following key safety functions is not reestablished Control Room Evacuation.

within (site-specific number of minutes).

AND* Reactivity control 2. Control of ANY Table H 1 key safety function is not reestablished in < 15 minutes.Core cooling [PWtR] / RPV water level [BWR]* RCS heat removalTable 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 Justification HA6 HA2Initiating Condition:

ALERT Initiating Condition:

F No Change M Difference L-J Deviation Control Room evacuation resulting in transfer of plant control to alternate locations.

Control Room evacuation resulting in transfer of plant control to alternate locations.

1) EAL uses the site specific Control Room evacuation procedure to effectively listall of the alternate locations, panels, and stations requested by the developer notes. This would be the procedure 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) 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 staffed, 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(site-specific remote shutdown panels and local control stations).

the Control Room to alternate locations per DSSP 0100-CR, Hot ShutdownProcedure

-Control Room Evacuation.

Page 57 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HU4Initiating Condition:

UNUSUAL EVENTFIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:

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 thefollowing 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 alarmANDb. The FIRE is located within ANY of the following plant rooms orareas:(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 orareas:(site-specific list of plant rooms or areas)ANDc. The existence of a FIRE is not verified within 30-minutes of alarmreceipt.3. A FIRE within the plant or ISFSI [for plants with an ISFSI outside theplant Protected Area] PROTECTED AREA not extinguished within 60-minutes of the initial report, alarm or indication.
4. A FIRE within the plant or ISFSI [for plants with an ISFSI outside theplant Protected Area] PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.

HU3Initiating Condition:

M No Change I Difference I Deviation Listed site specific list of plant rooms or areas that contain SAFETYSYSTEM equipment to ensure timely classification.

FIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:

1,2.3,4, 5, DEmergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining that theapplicable time has been exceeded, or will likely be exceeded.

1. A FIRE in ANY Table H2 area is not extinguished in < 15-minutes of ANY of thefollowing 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 Building (when inerted the Drywell is exempt)* Aux Electric Room* Control Room* Unit and Shared Emergency Diesel Generator Rooms* 4KV ECCS Switchgear Area (includes Bus 23, 24, 33and 34 only)* CRD & CCSW Pump Rooms* Turbine Building Cable Tunnel* Turbine Building Safe Shutdown Areas as follows:* B- Train Control Room HVAC Room* Battery Rooms and DC Distribution Areas1) U2 Battery Room (includes DC switchgear, 125V, and 250V battery rooms)2) U3 Battery Room, Battery Cage area, andU3 Battery Charger Room (all on U3 TB538)* Crib HouseOR2. a. Receipt of a single fire alarm in ANY Table H2 area (i.e., no other indications of aFIRE).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 theinitial report, alarm or indication.

OR4. A FIRE within the plant PROTECTED AREA that requires firefighting support by anoffsite fire response agency to extinguish.

Page 58 of 66 0NEI 99.01 Rev 6 Proposed EAL Justification Initiating Condition:

UNUSUAL EVENT HU2 Initiating Condition:

HU4 D No Change M Difference F Deviation Seismic event greater than OBE levels. Seismic event greater than OBE levels. 1) Used Alternate developer notes allowed wording since specific Control Roomindication of a seismic event > OBE is not available.

Operating Mode Applicability:

Operating Mode Applicability:

All1, 2, 3, 4, 5, DExample Emergency Action Levels:Emergency Action Level (EAL):Seismic event greater than Operating Basis Earthquake (OBE) as indicated by:a. (site-specific indication that a seismic event met or exceeded OBE limits) 1. Control Room personnel feel an actual or potential seismic event.AND2. The occurrence of a seismic event is confirmed in a manner deemedappropriate by the Shift Manager or Emergency Director.

Page 59 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HA5 HAmInitiating Condition:

ALERT Initiating Condition:

LFI No Change [-1 Difference

[:1 Deviation Gaseous release impeding access to equipment necessary for normal plant Gaseous release impeding access to equipment necessary for normal plant operations,

1) Listed plant specific rooms and areas with entry related mode applicability tooperations, cooldown or shutdown.

cooldown or shutdown, ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

All 1,2,3,4, 5, DExample Emergency Action Levels: Emergency Action Level (EAL):Note: If the equipment in the listed room or area was already inoperable, or out Note'of service, before the event occurred, then no emergency classification iswarranted.

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

1. a. Release of a toxic, corrosive, asphyxiant or flammable gas into anyof the following plant rooms or areas: 1. Release of a toxic, corrosive, asphyxiant or flammable gas in a Table H3 area.(site-specific list of plant rooms or areas with entry-related modeapplicability identified)

Table H3Areas with Entry Related Mode Applicability AND Area Entry Related Mode Applicability

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

Reactor Building*

Modes 3, 4, and 5*Areas required to establish shutdown coolingAND2. Entry into the room or area is prohibited or impededPage 60 of 66 S0NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:

UNUSUAL EVENTHazardous EventOperating Mode Applicability:

HU3AllExample 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.

I. A tornado strike within the PROTECTED AREA.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)HU6Initiating Condition:

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.

OR5. Abnormal River level, as indicated by EITHER:a. High river level > 509 ft.ORb. Low river level < 501 ft. 6 inches.F] No Change FIDifference

[- Deviation

1) Added Abnormal River level to list of natural or technological hazard events.The high river level of 509 ft was selected since it is the lowest opening leading tosafety related equipment, and the love river level of 501 ft 6 in was selected sincethis is the most limiting pump suction requirement(CCSW pumps)2) Changed the word "needed" to "required by Technical Specifications" in the EALto be consistent with terminology used by operators and minimize confusion.

Page 61 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HG7 HG7 -Initiating Condition:

GENERAL EMERGENCY Initiating Condition:

LhI No Change LJ Difference FIDeviation Other 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 General Emergency.

declaration of a General 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 IMMINENT Other conditions exist which in the judgment of the Emergency Director indicatesubstantial core degradation or melting with potential for loss of containment that events are in progress or have occurred which involve actual or IMMINENTintegrity or HOSTILE ACTION that results in an actual loss of physical control of substantial core degradation or melting with potential for loss of containment the facility.

Releases can be reasonably expected to exceed EPA Protective Action integrity or HOSTILE ACTION that results in an actual loss of physical control ofGuideline exposure levels off-site for more than the immediate site area. the facility.

Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels off-site for more than the immediate site area..Page 62 of 66 NEI 99-01 Rev 6 Proposed EAL Justification H37 HS7 mmInitiating Condition:

SITE AREA EMERGENCY

' Initiating Condition:

[Sj No Change [j Difference Li Deviation Other 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 major Other conditions exist which in the judgment of the Emergency Director indicatefailures of plant functions needed for protection of the public or HOSTILE ACTION that events are in progress or have occurred which involve actual or likely majorthat results in intentional damage or malicious acts; (1) toward site or failures of plant functions needed for protection of the public or HOSTILE ACTIONequipment that could lead to the likely failure of or; (2) that prevent effective that results in intentional damage or malicious acts; (1) toward site personnel oraccess to equipment needed for the protection of the public. Any releases are not equipment that could lead to the likely failure of or; (2) that prevent effective expected to result in exposure levels which exceed EPA Protective Action access to equipment needed for the protection of the public. Any releases are notGuideline exposure levels beyond the site boundary o expected to result in exposure levels which exceed EPA Protective ActionGuideline exposure levels beyond the site boundary.

Page 63 of 66 NEt 99-01 Rev 6 Proposed EAL Justification HA? HA7Initiating Condition:

ALERT Initiating Condition:

L7 E No Change LJ1 Difference

[J Deviation Other 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 potential that evnts e in phe ourred wh e an actor pntialsubstantial 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 potential involves 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 Justification HU7 HU7 mmFInitiating Condition:

UNUSUAL EVENT Initiating Condition:

[Uj No Change [j Difference

[j Deviation Other 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:Other conditions exist which in the judgment of the Emergency Director indicate Emergency Action Level (EAL):that events are in progress or have occurred which indicate a potential Other conditions exist which in the judgment of the Emergency Director indicatedegradation of the level of safety of the plant or indicate a security threat to facility that events are in progress or have occurred which indicate a potential protection has been initiated.

No releases of radioactive material requiring offsite degradation of the level of safety of the plant or indicate a security threat to facilityresponse or monitoring are expected unless further degradation of safety systems protection has been initiated.

No releases of radioactive material requiring offsiteoccurs. response or monitoring are expected unless further degradation of safety systemsoccurs.Page 65 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:

UNUSUAL EVENT E-HUI Initiating Condition:

E-HUI H No Change F Difference FIDeviation Damage 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 perOperating Mode Applicability:

Certificate of Compliance No. 1014 Appendix A, Section 5.7 (WEST HI-STORM),

Operating Mode Applicability:

Certificate of Compliance No. 1014 Appendix A, Section 3.2.3 (EAST HI-STORM),

and Certificate of Compliance No. 1008 Appendix A, Amendment 2, SectionAll 1 2.2.1 (EAST HI-STAR)1, 2,3,4, 5, DExample Emergency Action Levels: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 an on-technical specification allowable radiation level) on the surface of the spent fuel contact radiation reading:cask.1. EAST HI-STAR:* > 160 mrem/hr (neutron

+ gamma) on the top of the OverpackOR* > 250 mremlhr (neutron+

gamma) on the side of the OverpackOR2. EAST HI-STORM:

  • > 20 mremlhr (neutron+

gamma) on the top of the OverpackOR* >100 mremlhr (neutron+

gamma) on the side of the OverpackOR* > 45 mremlhr (neutron+

gamma) at the inlet and outlet vent ducts of theOverpackOR3. WEST HI-STORM:

  • > 40 mrem/hr (neutron+

gamma) on the top of the OverpackOR* >100 mremnhr (neutron+

gamma) on the side of the Overpack, excluding inlet and outlet ductsPage 66 of 66 Dresden Annex Exelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARG1Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 1000 mRremn TEDEor 5000 mRfem thyroid CDE.Operating Mode Applicability:

1,2,3, 4,5, DEmergency Action Level (EAL):Notes:* The Emeraency Director should declare the event promptly upon determining that theapplicable time has been exceeded, or will likely be exceeded.

  • Tho Em......Y r-ocr..e-shnould dlar the 9Vr-t prom.ptly uponae9torm.

1Inng atM Me appnc~a~Io mime has seen oXceepep, Or Will Wieiy me oxcocaca.

" 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.

I

  • 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 following radiation monito-s greater than the reading Shownfo.r 15 minutes , o longeir(site-specific monitor list and threshold v:alues)1. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs > 7.90E+09 uCi/sec for > 15 minutes (as determined by DOP 1700-10 or PPDS -TotalNoble Gas Release Rate).OR2. Dose assessment using actual meteorology indicates doses at or beyond (Site-sf08fiG dose rec.Ptor voint) the site boundary of EITHER:a. > 1000 mRem TEDEORb. > 5000 mRem CDE Thvroid.. .................

... * ....Month 20XXDR 3-1EP-AA-1004 (Revision XX)

Dresden Annex Exelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS OR/'%1 -- -- J __ --I .... =JI ...... L--AL ---- d ----IJ't L---CAesed windew dese Fates weafeF !RaA JWWW FnKERF eXPeGlecl 19 GGRURUe-fGF 60t m **tesr. a.. nmrtrr- &L--- ff tff%for AMo hour of inhalaion.

3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >1000 mRlhr 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 mR-em while the 5000 mRfem thyroidCDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE andthyroid CDE.enviroenment is, ostablished.

If thc Afflucnt.

floW past an effluent monitor is known to havstopped due to Wcions to iselate the roleaso path, thenA the efletmoio eading is nolonger valid for class-ification purposes-.

Month 20XXDR 3-2EP-AA-1004 (Revision XX)

NuclearDresden AnnexA Exellnn Nuclea~rRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Basis Reference(s):

1. NE1 99-01 Rev 6, AG12. EP-AA-1 12-500 Emergency Environmental Monitoring
3. ODCM Section 12.4 Gaseous Effluents and Total Dose4. DOP 1700-10, Obtaining And Calculating A Gaseous Release Rate From the Unit2/3 Chimney, Unit 1 Chimney and Unit 2/3 combined Reactor Vent Using theEberline Control Terminal5. EP-EAL-0604 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Dresden Station6. DEOP 300-2, Radioactivity Release ControlMonth 20XXDR 3-3EP-AA-1004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARS1Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 100 mR-em TEDEor 500 mRem thyroid CDE.Operating Mode Applicability:

1,2,3,4,5, DEmergency Action Level (EAL):Notes:9 The Emergency Director should declare the event promptly upon determining that theapplicable time has been exceeded, or will likely be exceeded.

II I I l l9 no immcr1Aonc WIrccoF cnouiaI aociare the Site Area EmoreAon even; or-oAmplV d !I roll I*1 I II m s I iI a al la I I ew I Iiinnn ru~tnrmininn Tn~t mA ~nnhlr~flIA timn flap flnfln nYr'nnCinri nr w'n IlkAl'.!

nn-........-....--

I-.E-,..---.-..-----..-~~------,-....

e xGeeded." 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.

14 E3. .4;A r AK $V a ý' $ka aI a. nn A;a a .n4artnaaa.

ka k a naka.it-et " "" ....W. .. M M-M-W". M.W. -_. -_ ._. .- .__1 10 01 MrvvrlI -"IMI-1 1117tbutti buldrdaimu WHWHOtidF Hbt dwou twMiUbMAU YtHutot"(2) Dose ass.essmnt using actumial meteorology dos.... greater than 100mrcm~ TEDE Or 600 FArom thyroi cl DE, at or beyond (sito spocific dote recepto(3) Field cun.'oy results ind-icate EITHER Of the folloWing at Or beyond (sito specific_

doe r..et point).:" Closed window dose rates greater-than 100 ffd4A expected to continue for 60 fpnutesor- longer-" Analyses of field survey samples indieate thyroid CDE greater-than 500 mrwem for- onehour of inhalation.

Month 20XXDR 3-4EP-AA-1004 (Revision XX)

Dresden AnnexExellon NuclearDresden Annex Exelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS

3. 1. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs > 7.90E_.8 uCi/sec for > 15 minutes (as determined by DOP 1700-10 or PPDS -TotalNoble Gas Release Rate).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 EALsmore fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 10% of the EPA PAG of 1000 mR-em while the 500 mR-emthyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDEand thyroid CDE.Claccification based on offluent moneitor reading~s assumos that. a release path ttho enyirnment is ,stablished.

if the effu,,t flo past an effluent

.m"noter is known tohave stopped due to actions to isolate the release path, then the effluent moni;tor readingis no lonecr valid fo classificatio' uossMonth 20XXDR 3-5EP-AA-1004 (Revision XX)

Dresden AnnexExellon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Escalation of the emergency classification level would be via IC RAG1.Basis Reference(s):

1. NEI 99-01 Rev 6, AS12. EP-AA-1 12-500 Emergency Environmental Monitoring
3. ODCM Section 12.4 Gaseous Effluents and Total Dose4. DOP 1700-10, Obtaining And Calculating A Gaseous Release Rate From the Unit2/3 Chimney, Unit 1 Chimney and Unit 2/3 combined Reactor Vent Using theEberline Control Terminal5. EP-EAL-0604 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Dresden Station6. DEOP 300-2, Radioactivity Release ControlMonth 20XXDR 3-6EP-AA-1004 (Revision XX)

Dresden Annex Exelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARA1Initiating Condition:

Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mRfermTEDE or 50 mRem thyroid CDE.Operating Mode Applicability:

1,2, 3, 4,5, DEmergency Action Level (EAL):Notes:" The Emerqency Director should declare the event promptly upon determining that theapplicable time has been exceeded, or will likely be exceeded.

" Tho Emnergency Diroctor should declare tho Alert event promptly upon detormining that the applicab-le ti~me h-as boon oxceoedod, Or Will likely be exne-ed-ed-.

" 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 15 mninutesO or loger:(site-specific_

monitor list and threshold

'..aluois)

(2) Dose assessment using actual mcetoorolegy indicates doses greater than 1 OmromTEDE or 50 mrom thyroid CDE at Or beyond (cite. c..ific dose reecptor DnOW).(3) A~naly'sis of a liquid effluent sample indicates, a Goncentrtien or release rate thatwould result in doses greater than 10 Qmem TEDE Sor 50 rnrorn thyroid ODE atobeyond (site-spocific dose receptor point) for one hour of exposure(4) Field sur.'oy results indicate EITHER of the following atGorbeyond (site spccificdose receptor point):-*l*.e.. wind. w c.ose .ate. greater-thant L0 .. ..expected to continue or o6 .miutes orlongefn* .o* Analyses et field sur.'ey samulies indicate thyroidI CDE ercater-than ;)U mfemn tor onhour- of inhalation.

Month 20XXDR 3-7EP-AA-1 004 (Revision XX)

AnnexI:xAIon NuclearDrescln Annex Exelon NulewIarRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS

1. The sum of readings on the Unit 2/3 Rx Bldg and Unit 2/3 Chimney SPINGs> 7.90 E+07 uCi/sec for > 15 minutes (as determined by DOP 1700-10 or PPDS -Total Noble Gas Release Rate).OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 10 mRem TEDEORb. > 50 mRem CDE ThwroidOR3. 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 siteboundarya. 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.ORb. Analyses of field survey samples indicate

> 50 mRem CDEThyroid for 60 minutes of inhalation.

Month 20XXDR 3-8EP-AA-1004 (Revision XX)

Dresden AnnexExelon NuclearDresden Annex Exelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS 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 mRrem while the 50 mR-erm thyroidCDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE andthyroid CDE.Classification based on effluent mnonitor readings assumes that a roloaso path tthe enyironmont.

is- establoishecd.

If t~he efflu-ent flowA patafflluent mon8itor is known thavestoped duo to- act~ionsn to soat the release path, then the effluent monitor readingis no longer valid for classificatio pupoesEscalation of the emergency classification level would be via IC RASi.Basis Reference(s):

1 .NEI 99-01 Rev 6, AA12. ODOM Section 12.3 Liquid Effluents

3. ODCM Section 12.4 Gaseous Effluents
4. DOP 1700-10, Obtaining And Calculating A Gaseous Release Rate From the Unit2/3 Chimney, Unit 1 Chimney and Unit 2/3 combined Reactor Vent Using theEberline Control Terminal5. UNIT 2/3 DAN 2223-6 A-12 "2/3 RADWASTE DISCHARGE HIGH RADIATION"
6. UNIT 2/3 DOP 2000-110, Radioactive Waste Discharge to River With the Off-Stream Liquid Effluent Monitor Operable7. UNIT 2/3 DOP 2000-109, Waste Surge Tank Batching for a Radwaste RiverDischarge
8. Structural Drawing B-01A Composite Site Plan Dresden Station Units 1, 2 & 39. EP-EAL-0604 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Dresden Station10. DEOP 300-2, Radioactivity Release Control11. EP-EAL-0620 Revision 0, Dresden Criteria for Choosing Radiological LiquidEffluent EAL Threshold ValuesMonth 20XXDR 3-9EP-AA-1004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARMlInitiating Condition:

Release of gaseous or liquid radioactivity greater than 2 times the ODOM (eite-speGifie effluent rolcase conroll1ing document) limits for 60 minutes or longer.Operating Mode Applicability:

1, 2,3,4,5, DEmergency Action Level (EAL):Notes:0The Emeraencv Director should declare the event D~romotlv upon determining that theappIlicable time has been exceeded, or will likely be exceeded.

0 noe LmorA8ency wirector GAnoula aciare mne unusual tyeni event prompily upon-j- j--- :11 1:1-1.. --A* 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 mon;itor gr-eater than 2 times the (site speciific effluent release conroll1ing documnent) limitS for 60 mninuter, or longer:.(site-specific-monitor list and thre~shold-vsalues corresponding to 2 timer, thecontrolling document limtits)(2) Reading on ANY effluent radiation moni~tor greater than 2 times the alarm setponestablished by a current radioactivity disch-arge oormit for 60 minutes Or 'OgR.'% rn ^ ^ n ^ C- 11 ^ r 1ý -ARIagZaUR er I i r^ A" ARIAR ý fn f%jqLqgq rrpip -pfiq rgq+gr +knn 0 Crypp, +km !,,O+r%-,-

pe,;f 6, pff h i^n+ ^rAn+rplion docu montl lomite for 60 min-utAR~

or lonnoerzi1. Readina on any of the followina effluent monitors

> 2 times alarm setoointestablished by a current radioactive release discharge permit for 2t 60 minutes." Radwaste Effluent Monitor 2/3-2001-948 OR" Discharae Permit Soecified monitorORMonth 20XXDR 3-10Mont 2OX DR -10EP-AA-1 004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS

2. The sum of readings on the Unit 2/3 Rx BIdg and Unit 2/3 Chimney SPINGs > 9.02E+05 uCi/sec for > 60 minutes (as determined by DOP 1700-10 or PPDS -TotalNoble Gas Release Rate).HVAC and SGTS- Radiation Moitr-rs;.1706 (1.17 ntro-l roomPanels -OR3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or 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 radioactivity discharge 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 intentional releases.

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.

Claaessific-atione.

basoed on effluent monitor roadingc assumes that a reloase pathtthe onvironment is established.

If. the effluont flow past an effluent monitor is. known~ tohave stopped due to actions to isolate tho roloaso path, then the effluent monitor readingis no Inger valid for clai purp9seG-.

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 BasisEAL-#2--

This EAL addresses radioactivity releases that cause effluent radiation monitorreadings to exceed 2 times the limit established by a radioactivity discharge permit. ThisEAL will typically be associated with planned batch releases from non-continuous releasepathwavs (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 BasisMonth 20XXDR 3-11EP-AA-1004 (Revision XX)

N.nlAarflmpaitn Annpx ExelInn Nnnvlasar RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS EAL-#1----This EAL addresses normally occurring continuous radioactivity releases frommonitored gaseous e,-iq;id

-effluent pathways.

EAL #3 BasisEAL--#3---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. ODCM Section 12.3 Liquid Effluents
3. ODCM Section 12.4 Gaseous Effluents
4. DOP 1700-10, Obtaining And Calculating A Gaseous Release Rate From the Unit2/3 Chimney, Unit 1 Chimney and Unit 2/3 combined Reactor Vent Using theEberline Control Terminal5. UNIT 2/3 DAN 2223-6 A-12 "2/3 RADWASTE DISCHARGE HIGH RADIATION"
6. UNIT 2/3 DOP 2000-110, Radioactive Waste Discharge to River With the Off-Stream Liquid Effluent Monitor Operable7. UNIT 2/3 DOP 2000-109, Waste Surge Tank Batching for a Radwaste RiverDischarge
8. EP-EAL-0604 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Dresden Station9. DEOP 300-2, Radioactivity Release ControlMonth 20XXDR 3-12EP-AA-1004 (Revision XX) nroarhn AnnovPIrglr~n khio RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARA2Initiating 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) Unco'voy of irr-adi-iatd fuel in the REFUELING PATHWAY.(2) Damage to irradiated fuel resultiRg in a roloaso of radI-o-activity fro-R the ;in;ated by ANY of th lin ation monirs:(sito spocific, listing of radiation moenito-rs, and tho associatod

readings, setpoints andwor alarmsA)(3) LowriI ng of spent fuel pool love! to Levol 2 value). [See Developei e Uncovery of irradiated fuel in the REFUELING PATHWAY.OR* Damage to irradiated fuel resulting in a release of radioactivity from the fuel asindicated by ANY Table R1 Radiation Monitor readinq >1000 mRem/hrTable R1Fuel Handling Incident Radiation Monitors" Refuel Floor High Range ARM Station #2(4)" Fuel Pool Radiation MonitorBasis: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 traiectorv 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 containina radioactive substances and the environment.

Month 20XXDR 3-13EP-AA-1004 (Revision XX)

AnnAYFyAInn frpqripn Annpx Fvplnn Nmir-Iapar RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly.,

or- a ig. .niiant l.o.ing of wat.r lovel w.,hin the spent fu,, pool (scoDov...r.

.Notes). -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.~eea4at~onOTm oogooywui O aoaonotnr1-ocgito iaoqr;: o IcVvEAL #1 BasisEAL-#1This 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 significant changes 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 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.EAL #2 BasisEAL-#2This 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.

Soent fuel uncovery represents amaior ALARA concern in that radiation levels could exceed 10,000 R/hr on the refuelbridge when fuel uncovery begins. The value of 1000 mR/hr was conservatively chosenfor classification purposes.

A rise in readings on radiation monitors should be considered in conjunction with in-plant reports or observations of a potential fuel damaging event(e.g., a fuel handling accident).

Escalation of the emergency would be based on either Recognition Category RA-or CICs.Month 20XXDR 3-14EP-AA-1004 (Revision XX)

Dresden Annex Exelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS 9AL #3Spent ful. pool water l at this value Or, wthin the lower end of the level Fangnecossary to prevent significant dose conseguoncos, from dierect gamma radiation toporsonnei porferming operatione in the Vicinit,'

Of the spent fuel pool. This conditioroflects a significant loss of spent fuel pool water invontory and thus it. iss alsoe a precurFso to a less of the ability to adequately cool the ifradiate" fu1l asese~mblcc Mtore d in the pool.Er.calation of the emergency classification level would be '.ia I~s AS! Or AS2 (see ASDovelopr-ANoes).Basis Reference(s):

1 .NEI 99-01 Rev 6, AA22. DAN 902(3)-3 C-1 6(E-1 6) Reactor Building Fuel Pool Hi Radiation

3. DAN 902(3)-3 B-i Refuel Floor Hi Radiation
4. DAN 902(3)-3 A-3(F-1 4) Reactor building Vent Hi-Hi Radiation
5. UFSAR 9.16. DAN 902(3)-4 D-24 Fuel Peel Skimmer Tank Level Lo7. DIP 0260-01 Refuel Outage Reactor Vessel and Cavity Level Instrumentation
8. DFP 0850-01 Water Level Loss in SEP or Cavity9. DOP 1900-03 Reactor Cavity, Dryer/Separator Storage Pit and Fuel Pool LevelControlMonth 20XXDR 3-15EP-AA-1004 (Revision XX)

Dry.dAn AnnexDrvvden Annex Evelon Nule IasrRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARU2Initiating Condition:

UNPLANNED loss of water level above irradiated fuel.Operating Mode Applicability:

1,2, 3, 4, 5, DEmergency Action Level (EAL):I14\ I INIDI I~ I ,-v, , .~ lrr ;n skn D~rl:I I1:I INt"f- DATI.JIAIAV n- I; teby ANY of the followinei:v(sitoe-socific level indications).

ANDb. U1 IPI-AN.'NE'6 D io in as o rdiation lovls. ;as indicated by ANY of the_ !--I .. .... !1_ __\(Rtsn-pd1 RDOII unof area radatiaon mrontirel

'-...- r" ...... ... ..... ..1. a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated by ANYof the following:

" Refueling Cavity water level < 466 in._(Refuel Outage Reactor Vesseland Cavity Level Instrument LI 2(3)-263-114)

OR* Spent Fuel Pool water level < 19 ft. above the fuel (< 33 ft. 9 in.indicated level).OR" Indication or report of a drop in water level in the REFUELING PATHWAY.ANDb. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors inTable RI.Table R1Fuel Handling Incident Radiation Monitors" Refule Floor High Range ARMStation #2(4)* Fuel Pool Radiation MonitorMonth 20XXDR 3-16EP-AA-1004 (Revision XX) nroadon AnnoyE=xalnn flm~dAn Ann~v Fv~Inn Nsir~I~~ar RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS 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 parameter change or event may be known or unknown.REFUELING PATHWAY:

all the cavities, tubes, canals and pools throuqh whichirradiated fuel may be moved or stored, but not including the reactor vessel below theflange.This IC addresses a deeeease-loss 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.I 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 aa iner-easerise 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 inereaserise 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):

1. NEI 99-01 Rev 6, AU22. RP-AA-203 Exposure Control and Authorization
3. Technical Specifications 3.7.84. Technical Specifications 3.9.65. UFSAR 9.16. DAN 902(3)-4 D-24 Fuel Pool Skimmer Tank Level Lo7. DIP 0260-01 Refuel Outage Reactor Vessel and Cavity Level Instrumentation
8. DFP 0850-01 Water Level Loss in SFP or CavityMonth 20XXDR 3-17EP-AA-1004 (Revision XX)

Dresden AnnexExellon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS

9. DOP 1900-03 Reactor Cavity, Dryer/Separator Storage Pit and Fuel Pool LevelControl10. DGP 02-02, Reactor Vessel Slow Fill11. DAN 902(3)-3 C-1 6(E-1 6) Reactor Building Fuel Pool Hi Radiation
12. DAN 902(3)-3 B-1 Refuel Floor Hi Radiation
13. DAN 902(3)-3 A-3(F-14)

Reactor building Vent Hi-Hi Radiation Month 20XXDR 3-18EP-AA-1 004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARA3Initiating 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:9 If the equipment in the listed-room or area listed in Table R3 was alreadyinoperable, or out of service, before the event occurred, then no emergency classification is warranted

/IN ^^o% r£1r% re% +^r fk., 1 A rnr2/%r On AIlV +kA U ,r. .\ ' I ,--v,.,v

, to ---.-W" Cntrol Room." Central A4arm Statiea" (other- site specific afeask/rooms)OAhd ;i MR UNPr6ANIM eventL iU.uIlt II Fin aIRIIiIIR

.lev 11Ui AFOIUKILI O[ UIMM99U aGUeL ;9Iany of the following plant roome6 Or aroac:-;J[:-- --J[--I----x

.......isne speemTI liiT of DIflT F9oomS OF Warc WI1!RenR:

reF0aioo monoe aooiicantii ideRtified)

...... I" ..............

..~... 1....... I- r-.. .Je Dose rate than> 15 mR/hr in ANY of the followina areas:Table R2Areas Requiring Continuous Occupancy

  • Main Control Room (Unit 2 ARM Station #22)* Central Alarm Station -(by survey)OR* UNPLANNED event results in radiation levels that prohibit or significantly impedeaccess to any of the following plant rooms or areas:Month 20XXDR 3-19EP-AA-1004 (Revision XX)

I=yAIon Nuelmarrnmnden Annex Exelon NuclarwRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS Table R3Areas with Entry Related Mode Applicability Area Entry Related ModeApplicability Reactor Building*

Modes 3, 4, and 5*Areas 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 parameter change 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 perFo-m a normal plant .o.ldown andh,-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 R3 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 operating procedures (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 includerooms or areas for which entry is required solely to perform actions of an administrative orrecord keeping nature (e.g., normal rounds or routine inspections).

Rooms and areas listed in EAL #1 do not need to be included in EAL #2, including 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 serviceat the time of thoolo'eatod radiation levols. 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 ofpersonnel into the affected room/area (e.g., installing temporary shielding beyond thatrequired by procedure, 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.Month 20XXDR 3-20EP-AA-1004 (Revision XX) l=yRlnn frmaidan Annex Exelnn NucleanrRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS

" 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 radiation inereaserise 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. DOP 1800-01 Area Radiation Monitors3. FSAR Section 3.2 Classification of Structures, Components and Systems4. General Arrangement Drawings M-3, M-4, M-4A, M-5 and M-105. DEOP 300-2, Radioactivity Release ControlMonth 20XXDR 3-21EP-AA-1 004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS SRU3Initiating Condition:

Reactor coolant activity greater than Technical Specification allowable limits.Operating Mode Applicability:

1,2,3Emergency Action Level (EAL):(-1-)-- (Sitoe-pocific radiatio moitr)rading groator than (cite-s9*

vpcfc'a4o)-.

(2) Sample analysis indicatoc that a reactor coolant activity valueo ia greater than anallowable limit specified in Tcc~hnical Specifiations.

1. Offgas system radiation monitor HI-HI alarm.OR2. Specific coolant activity

> 4.0 uCll/m 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 significant event and represents a potential degradation of the level of safety of the plant.Conditions that cause the specified monitor to alarm that are not related to fuel 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 Recognition Category RA ICs.Basis Reference(s):

1. NEI 99-01 Rev 6, SU32. Technical Specifications 3.4.6, RCS Specific Activity3. DAN 902(3)-3 C-2(D-2)

Off Gas Rad Monitor Hi-Hi4. Technical Specifications 3.7.6, Main Condenser Offgas5. DGA 16 Coolant High Activity/Fuel Element FailureMonth 20XXDR 3-22EP-AA-1 004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FG1Initiating 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 determine barrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.

At the General Emergency classification level each barrier is weighted equally.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXDR 3-23EP-AA-1004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FS1Initiating 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 determine barrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.

At the Site Area Emergency classification level, each barrier is weighted equally.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXDR 3-24EP-AA-1004 (Revision XX)

Exelon Nuclearrlrsden Annex Ex.lon Nulela. rRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FA1Initiating 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 determine barrier status.Basis:Fuel Cladding, RCS and Containment comprise the fission product barriers.

At the Alert classification level, Fuel Cladding and RCS barriers are weighted moreheavily than the Containment barrier.

Unlike the Containment

barrier, loss or potential loss of either the Fuel Cladding or RCS barrier may result in the relocation of radioactive materials or degradation of core cooling capability.

Note that the loss or potential loss 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 20XXDR 3-25EP-AA-1004 (Revision XX)

Dresden Annex Exelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC1Initiating Condition:

RCS ActivityOperating Mode Applicability:

1,2,3Fission Product Barrier (FPB) Threshold:

LOSSA. (Sito Spocific indications that rcactor coolant actiVity is groater than 30Q0uGi~gm doc 3.)Coolant activity

> 300 uCilcm Dose Equivalent 1-131.Basis:This threshold indicates that RCS radioactivity concentration is greater than 300 gCi/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-22. DGA-1 6, Coolant High Activity

/ Fuel Element FailureMonth 20XXDR 3-26EP-AA-1004 (Revision XX)

Dresden AnnexExelon NuclearDresden Annex Exelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC2Initiating Condition:

RPV Water LevelOperating Mode Applicability:

1,2,3Fission Product Barrier (FPB) Threshold:

LOSSA-.1. Plant conditions indicate Primary GContainment flooding is required.

POTENTIAL LOSSA-.2. RPV water level cannot be restored and maintained abovo (site specific RPV.at.. level ,..Or...pnding to top of acti'. ful)> -143 inches (TAF)9 RPV water level cannot be determined.

Basis:RPV values are actual levels, not indicated levels. Therefore, they may need levelcompensation depending on conditions.

Compensated values may be used inaccordance with the Technical Support Guidelines.

Loss 2-AThreshold

  1. 1 BasisThe Loss threshold represents the EOP requirement for primary containment flooding.

This is identified in the BWROG EPGs/SAGSAMGs when the phrase, "PrimaryContainment Flooding Is Required,"

appears.

Since a site-specific RPV water level isnot specified here, the Loss threshold phrase, "Primary containment flooding required,"

also accommodates the EOP need to flood the primary containment when RPV waterlevel cannot be determined and core damage due to inadequate core cooling isbelieved to be occurring.

Potential Loss 2AThreshold

  1. 2 and #3 BasisThis 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 baIieF-Barrier RC2 Loss threshold 2-.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-specific EOPs, RPV-waterRPV 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 pressureMonth 20XXDR 3-27EP-AA-1004 (Revision XX)

DrAsden Annex.r..d.n Annex Exelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RPV 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 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 act--ieve order to reduce reactorpower. RPV ..at..r le"vl is then contro.lled btwoon tho top of active fuol tho Steanm Cooling RPV Water Loeveol 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 SS-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. DEOP 100 RPV Control3. DEOP 400-5 Failure to Scram4. DEOP 400-1 RPV Flooding5. DEOP 0010-00 Guidelines for Use of Dresden Emergency Operating Procedures and Severe Accident Management Guidelines
6. Technical Support Guidelines Month 20XXDR 3-28EP-AA-1 004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION Month 20XXDR 3-29EP-AA-1004 (Revision XX)

Annoyfras~eIan Annexv FYAlnn NucleasrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC5Initiating Condition:

Primary Containment Radiation Operating Mode Applicability:

1,2,3Fission Product Barrier (FPB) Threshold:

LOSSA. Primary containment radiation monitor reading greater than (site-cpecific value)Drywell radiation monitor reading > 6.70 E+02 R/hr (670 R/hr).Basis:L~ess4.AThe radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the primary containment, assuming that reactor coolant activityequals 300 gCi/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 tThreshold 47A-since it indicates a loss of both the Fuel Clad Barrierand the RCS Barrier.

Note that a combination of the two monitor readings appropriately escalates the emergency classification level to a Site Area Emergency.

I 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 Methodology (CDAM)Month 20XXDR 3-30EP-AA-1004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC7Initiating Condition:

Emergency Director Judgment.

Operating Mode Applicability:

1,2,3EAL Threshold Values: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 Potential Loss of the Fuel Clad Barrier.Basis:Loss Threshold

  1. 1 BasisThis threshold addresses any other factors that are to be used by the Emergency Director in determining whether the Fuel Clad Barrier is lost.Potential Loss Threshold
  1. 2 BasisPotential Loec 6.AThis 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 20XXDR 3-31EP-AA-1004 (Revision XX)

Exelon NuclearDresden Annex Eeo ulaRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC2Initiating Condition:

RPV Water LevelOperating Mode Applicability:

1,2,3Fission Product Barrier (FPB) Threshold:

LOSS1. RPV water level cannot be restored and maintained above (.ite.specific RPV waterll corr to the top of acti'..., -143 inches (TAF)R-OR2. RPV water level cannot be determined.

Basis:Less-2-RPV values are actual levels, not indicated levels. Therefore, they may need levelcompensation depending on conditions.

Compensated values may be used inaccordance with the Technical Support Guidelines.

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 baFi8F Barrier FC2 Potential Loss threshold .A. Thus, this threshold indicates a Loss of the RCS barrier andPotential Loss of the Fuel Clad barrier and that appropriately escalates the emergency classification level to a Site Area Emergency.

This threshold is considered to be exceeded when, as specified in the site-specific EOPs, RPV-waterRPV 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 emergency RPV 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.

Month 20XXDR 3-32EP-AA-1004 (Revision XX)

Dresden Annex Exellon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION 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 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 act*ve fuel in order to reduce reactorpower. RPV Wator level is then controlled betowen the top Of actiVe fuel and theMinimu.m Steam Coolin;g W^.Atr L ev.el (MSCR'A'W).

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 SS-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. DEOP100 RPV Control3. DEOP 0010-00 Guidelines for Use of Dresden Emergency Operating Procedures and Severe Accident Management Guidelines
4. Technical Support Guidelines Month 20XXDR 3-33EP-AA-1004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC3Initiating Condition:

Primary Containment PressureOperating Mode Applicability:

1,2,3Fission Product Barrier (FPB) Threshold:

LOSSA. Primar,'

containment pre6Suro greater than (site specific value) duo to RCS loakag.1. Drywell pressure

>2.0 psig.AND2. Drywell pressure rise is due to RCS leakageBasis:Less4-7AThe (.ite

...

2.0 psia primary containment pressure is the high pressure setpoint which indicates a LOCA by automatically initiating the-ECCS-GF equivalent mrakeup 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 affectpdmary containment pressure.

Pressures of this magnitude can be caused by non-LOCA events such as a loss of Drvwell 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 Electromatic relief valve (ERV)/Target Rock SRV or ERV/ Target RockSRV leakage is not considered either identified or unidentified leakage by Technical Specifications and, therefore, is not applicable 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. Technical Specifications Table 3.3.5.1-1
3. DAN 902(3)-5 D-1 14. DEOP 100 RPV Control5. DEOP 200-1 Primary Containment ControlMonth 20XXDR 3-34EP-AA-1004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC4Initiating Condition:

RCS Leak RateOperating Mode Applicability:

1,2,3Fission Product Barrier (FPB) Threshold:

LOSSAl. UNISOLABLE Main Steam Line (MSL), Isolation Condenser, HPCI, Feedwater, orRWCU line break. in ANY of the foI.wing:. .... fc Systems with potential for highenorgyImbra)

ORB2. Emergency RPV Depressurization is required.

POTENTIAL LOSS3A. UNISOLABLE primary system leakage that results in EITHER of the following:

al-. Secondary Containment area temperature

> DEOP 300-1 MaximumMax NormalOoperating T-emperaturelevels.

ORb2. Secondary Containment area radiation level > DEOP 300-1 Maximum Max-Normal Ooperating A^-p 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 available to 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 20XXDR 3-35EP-AA-1004 (Revision XX)

Dresden AnnexExelon NuclearDresden Annex Exelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION Loss Threshold

  1. 1 Basis-&ALarge high-energy lines that rupture outside primary containment can discharge significant 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 fr"m :the Co-,ntrol Room, the RCS barrier Loss threshold is met.Loss Threshold

  1. 2 Basis3.Emergency RPV Depressurization in accordance with the EOPs is indicative of a loss ofthe RCS barrier.

If Emergency RPV Depressurization is performed, the plant operators are directed to open safety relief valves (SRVs) and keep them open. Even though theRCS is being vented into the Torus, a Loss of the RCS barrier exists due to thediminished effectiveness of the RCS to retain fission products within its boundary.

Potential Loss Threshold-

  1. 3 Basis 3.Potential loss of RCS based on primary system leakage outside the primarycontainment is determined from EOP temperature or radiation Max Normal Operating values in areas such as main steam line tunnel, RGIG,-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 condition does 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 unexpected Main Turbine Control Valve closure) may indicate that a primary system is discharging into 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

  1. 13&A (after a containment isolation) and a General Emergency when the Fuel CladBarrier criteria is also exceeded.

Month 20XXDR 3-36EP-AA-1004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-22. M-12, M-345, Main steam piping3. Technical Specifications 3.4.4 RCS Operational LEAKAGE4. Technical Specifications Section 3.4.5, RCS Leakage Detection Instrumentation
5. DAN 902(3)-4 A-17 DRWAELLDRYWELL EQUIP SUMP LVL HI-HI6. DAN 902(3)-4 H-18 DRY-AWELLDRYWELL FLOOR DRN SUMP LVL HI-HI7. DOA 0040-01 SLOW LEAK8. DOP 2000-24 DRYWELLDRYWELL SUMP OPERATION
9. DEOP 300-1, Secondary Containment Control10. UFSAR Section 5.2.5Month 20XXDR 3-37EP-AA-1004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC5Initiating Condition:

Primary Containment radiation Operating Mode Applicability:

1,2,3Fission Product Barrier (FPB) Threshold:

LOSS1. Drywell radiation monitor reading > 100PRhr (>1.00 E+02 R/hr).A. Pdmary containment radiation roading groator than (site spociflc 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 specified for Fuel Clad Barrier FC5 Loss Tthreshold 4-A-since it indicates a loss of the RCSBarrier only.I There is no RCS Potential Loss threshold associated with Primary Containment Radiation.

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 the RCS Barrier.Month 20XXDR 3-38EP-AA-1004 (Revision XX)

AnnAyI=xAIon Nuclearflmsden Annex Exelon NucleasrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC7Initiating 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 theRCS Barrier.POTENTIAL LOSSA2. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.Basis:Loss SAThreshold

  1. 1 BasisThis threshold addresses any other factors that are to be used by the Emergency Director in determining whether the RCS Barrier is lost.Potential Loss 6,AThreshold
  1. 2 BasisThis 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 20XXDR 3-39EP-AA-1004 (Revision XX)

ExAIon Dresden Annex ExeIon NuclasrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT2Initiating Condition:

RPV Water LevelOperating Mode Applicability:

1,2,3Fission Product Barrier (FPB) Threshold:

POTENTIAL LOSSX. Plant conditions indicate PrimaryGContainment flooding is required.

Basis:Potential Lo h -2.AThe Potential Loss threshold is identical to the Fuel Clad Barrier -RC2 Loss threshold, RPV Water Level thFroheldA.

The Potential Loss requirement for PrimaryContainment Flooding indicates adequate core cooling cannot be restored andmaintained and that core damage is possible.

BWR EPGs/SAGSAMGs specify theconditions that require primary containment flooding.

When primary containment flooding is required, the EPGs are exited and SAGSAMGs are entered.

Entry intoSAQSAMGs is a logical escalation in response to the inability to restore and maintainadequate 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 potential for primary containment failure.

In conjunction with the RPV water level Loss thresholds in 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. Severe Accident Management Guidelines
3. DEOP 0100, RPV Control4. DEOP 0400-01, RPV Flooding5. DEOP 0400-05, Failure to ScramMonth 20XXDR 3-40EP-AA-1004 (Revision XX)

NuelAarDresden Annex Exelon Nucle~arRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT3Initiating Condition:

Primary Containment Conditions Operating Mode Applicability:

1,2,3Fission Product Barrier (FPB) Threshold:

LOSSAl. UNPLANNED rapid drop in prma.' contai.montDrvwell pressure following p~4mryeeitairmnetDrywell pressure rise.ORI 82. Prim.ary c ..tainmen.

D-..,. pressure response not consistent with LOCAconditions.

POTENTIAL LOSSA3. Primary -.ntainmcP..lwD=ll pressure gr.ator than (site specific.

value)> 62 DsiQand rising.OR84. specific explosive mi.ture) exists Inside pr.mar; containmen.

a. Drywell ortorus hydrogen concentration

> 6%.ANDb. Drvwell or torus oxygen concentration

> 5%.ORG5. HT-LGHeat Capacity Limit (DEOP 200-1, Fig.M) 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 parameter change or event may be known or unknown.Loss !.A and4-BThreshold

  1. 1 and #2 BasisRapid UNPLANNED loss of primary containment pressure (i.e., not attributable toI dFyweADrywell spray or condensation effects) following an initial pressure kdseindicates a loss of primary containment integrity.

Primary containment pressure shouldi i eris__ee as a result of mass and energy release into the primary containment from aLOCA. Thus, primary containment pressure not increasing under these conditions indicates 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 containment Month 20XXDR 3-41EP-AA-1004 (Revision XX) rmcdpn AnnpvI=yplnn N.nlpnrflrn~d.n AnnAYExueInn NunivparRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION bypass condition.

A pressure suppression bypass path would not be an indication of acontainment breach.Potential Loss ".AThreshold

  1. 3 BasisThe threshold pressure is the primary containment internal design pressure.

Structural acceptance 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 1-.BThreshold

  1. 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 Containment barrier could occur.Potential Loss GThreshold
  1. 5 BasisThe Heat To-mperatue Limit (HCTI) is the highest Tr.us temperature fromwhich Emerg RPV will not raise:equipment within t.he u which may be .cqui.ed to operate when the RP12i.ORTOM p~ssm aoveP~ma~

ontainment Pressure Limit A., while theFatecRegy transfer froM the RPV to the containment is greater than the capacityo the ontak;nmeRnt vent.The HCTL is a function of RPV pressure, Torus temperature and Torus water level. It isutilized to preclude failure of the containment and equipment in the containment necessary for the safe shutdown of the plant and therefore, the inability to maintainplant parameters below the limit constitutes a potential loss of containment.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-22. UFSAR 6.2.1.3.2.1
3. UFSAR Table 6.2-34. UFSAR 15.6.55. UFSAR 6.2.1.16. DEOP 200-1 Primary Containment Control7. DEOP 200-2 Hydrogen ControlMonth 20XXDR 3-42EP-AA-1004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT5Initiating Condition:

Primary Containment Radiation Operating Mode Applicability:

1,2,3Fission Product Barrier (FPB) Threshold:

POTENTIAL LOSSA. PrimAa,'

containment I adiation monGito0r eading greater than (Iit i pecific value)1. Drywell radiation monitor reading > 1.60 E+03 RPhr (1600 R/hr).Basis:There is no Loss threshold associated with Primary Containment Radiation.

Potential Lessl.,AThe 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 analogous Fuel Clad Barrier Loss and RCS Barrier Loss thresholds.

NUREG-1228, 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 protective actions.

For this condition to exist- 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 classification level to a General Emergency.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-22. Core Damage Assessment Methodology (CDAM)Month 20XXDR 3-43EP-AA-1004 (Revision XX)

Dresden AnnexExelon NuclearDresden Annex Exelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT6Initiating 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.OR82. Intentional Pprimary CgGontainment venting/Durainc per EOP's or SAMGs due toaccident conditions.

ORG3. UNISOLABLE primary system leakage that results in EITHER of the following:

4-a. Secondary Containment area temperature

> DEOP 300-1. MaximumMax Safe OQperating TemrpeFatulevels.

OR2b. Secondary Containment area radiation level > DEOP 300-1. MaximumMax Safe Qoperating Radiatien-Llevels.

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 &AThreshold

  1. 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 steamline breaks, unisolable RWCU system breaks.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 20XXDR 3-44EP-AA-1004 (Revision XX) nroadon AnnoyI=Yplnn Exelon NurlosarRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION Following 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 "BThreshold

  1. 2 BasisEOPs may direct primary containment isolation valve logic(s) to be intentionally
bypassed, 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 djywWDrywell high pressurescram setpoint) does not meet the threshold condition.

Loss 3TCThreshold

  1. 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 necessary for 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 Prmary Containment.

For example, a high area radiation condition does 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 inconiunction with other indications (e.g. room flooding, high area temperatures, reports ofsteam in the Reactor Building, an unexpected rise in Feedwater

flowrate, or unexpected Main Turbine Control Valve closure) may indicate that a primary system is discharging into the Reactor Building.

In combination with RCS Barrier RC4 Ppotential LI-oss Threshold-

  1. 3,3A_this threshold would result in a Site Area Emergency.

There is no Potential Loss threshold associated with Primary Containment Isolation I Failure.Month 20XXDR 3-45EP-AA-1004 (Revision XX)

Dresden NuclearDlresden Annex Exellnn NucleAarRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-22. DEOP 200-1 Primary Containment Control3. DEOP 200-2 Hydrogen Control4. DEOP 500-4 Containment Venting5. DEOP 300-1 Secondary Containment ControlMonth 20XXDR 3-46EP-AA-1004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT7Initiating Condition:

Emergency Director Judgment.

Operating Mode Applicability:

1,2,3Fission Product Barrier (FPB) Threshold:

LOSSI Aj. Any condition in the opinion of the Emergency Director that indicates Loss of theContainment Barrier.POTENTIAL LOSSI A2. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.Basis:Loss GAThreshold

  1. 1 BasisThis threshold addresses any other factors that are to be used by the Emergency Director in determining whether the Containment Barrier is lost.Potential Loss 6AThreshold
  1. 2 BasisThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Containment Barrier is potentially lost. The Emergency Director 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 20XXDR 3-47EP-AA-1004 (Revision XX) roadan AnnoyI=Yalnn Nu nazlirflrnerI~n Annv Fv.Inn M.ir~Iu~ar RECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSG1Initiating Condition:

Prolonged loss of all Off-site and all On-Site AC power to emergency busesesbuses.

Operating Mode Applicability:

1,2,3Emergency Acton Level (EAL):Note:9 The Emeraencv Director should declare the event promptlv upon determinina thatthe applicable time has been exceeded, or will likely be exceeded.

Th maai Smta ahul dina t.. .. ... ..nun a= ano aszt i aamndtW yi i: t1iI I III LI LI IVThe EamergencY Director should declare the Gonreal Emorgency promnptly upon that (ito-specific has bcen Or will likely be exceeded.

1-a-. Loss of ALL offsite and ALL oncite AC power to (site specific emergency buses)unit ECCS buses.AND2. Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency diesel generators to supply power to unit ECCS buses.AND3b. EITHER of the following:

a. Restoration of at least one emeigeR~yunit ECCS bus in < 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is notlessthan+ s .pific hours) is Rot likely.ORb. RPV water level cannot be restored and maintained

> -164 inches.I Site 6-e-ecific-indic-ation of an inability to adeauatelY remove heat froem the core')dl JBasis:SAFETY SYSTEM: A system reauired for safe plant operation.

coolina down the piantand/or placing it in the cold shutdown condition, including the EGGS. These aretypically systems classified as safety-related.

Month 20XXDR 3-48EP-AA-1004 (Revision XX)

Dresden AnnexExellon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS I 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 requiring electric 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 oAn Or moeany fission productbarriers.

In addition, fission product barrier monitoring capabilities may be degradedunder these conditions.

RPV values are actual levels, not indicated levels. Therefore, they may need levelcompensation depending on conditions.

The EAL should require declaration of a General Emergency prior to meeting thethresholds for IC FG1. 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 likelihood of challenges to multiple fission product barriers.

The estimate for restoring at least one emergency bus should be based on a realistic appraisal of the situation.

Mitigation actions with a low probability of success should 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 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138-kV System and 345-kV Alternate Supply Failure5. DOA 6500-01 4-KV Bus Failure6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout Generator Ties to Plant Auxiliary Electric System7. UFSAR 9.5.98. DOP 6620-05, Powering Unit 2(3) 4-KV Busses via the SBO D/G 2(3)9. DGA-12 Partial or Complete Loss of AC Power10. DEOP100 RPV ControlMonth 20XXDR 3-49EP-AA-1004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS

11. DEOP 0010-00 Guidelines for Use of Dresden Emergency Operating Procedures and Severe Accident Management Guidelines Month 20XXDR 3-50EP-AA-1004 (Revision XX)

Dry.dAn AnnAy Dresden An nex Exelnn Nucler~I~

RECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSS1Initiating Condition:

Loss of all offsite and all onsite AC power to emergency busesbuses for 15 minutes orlonger.Operating Mode Applicability:

1,2,3Emergency Acton Level (EAL):Note:I* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.

  • Tk~ a 11rk%..~

+k^ a;+^ A r~ mrrr1!~'r, r^r, Mv+r4I1 I.~dot.. ..n.na thv, t 1I nu F%- h .......A......t

..n ..c. .d. or will bo ..ood. ." "1. Loss of ALL offsite and ALL "e-it+ AC Power to (site ..peif ic omergency ECCS buses for 15 ""minute" or 'on. .Ib, nitAND2. Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency diesel generators tosupply power to unit ECCS buses.AND3. Failure to restore power to at least one ECCS bus in < 15 minutes from the time ofloss 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 emergency core 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.Month 20XXDR 3-51EP-AA-1004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS Escalation of the emergency classification level would be via ICs RAG1, FG1,_-eqM._SG 1, or MG2.Basis Reference(s):

1. NEI 99-01 Rev 6, SS12. UFSAR 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138-kV System and 345-kV Alternate Supply Failure5. DOA 6500-01 4KV Bus Failure6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout Generator Ties to Plant Auxiliary Electric System7. UFSAR 9.5.98. DOP 6620-05, Powering Unit 2(3) 4KV Busses via the SBO D/G 2(3)9. DGA-12 Partial or Complete Loss of AC PowerMonth 20XXDR 3-52EP-AA-1004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSA1Initiating Condition:

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

1,2,3Emergency Acton Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.

The Emnergency Dierccto should declaro the Alo~t proemptly upon dotormining that 15min*utoc hac boon oxcooded, or will likely be cxccedod1. AC power capability to unit ECCS buses reduced to only one of the following powersources for > 15 minutes." Reserve auxiliary Transformer TR-22 (TR-32)" Unit auxiliary transformer TR-21 (TR-31)" Unit Emergency Diesel Generator DG 2(3)" Shared Emergency Diesel Generator DG 2/3" Station Blackout Diesel Generator DG 2(3)* Unit crosstie breakersa. AC powor capability to (cite-spccific omergency buses) is rcduccd to a singlcnowemr nowanep for 15 mninutpe or longeFVAND2b. Any additional single power source failure will result in a loss of ALLa# AC power toSAFETY 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 aretvDicallv 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 ICMSU1.Month 20XXDR 3-53EP-AA-1004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS I 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.j _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 baGk-fed from theunit main generator.

" A loss of emergency power sources (e.g., onsite diesel generators) with a singletrain of emergency buses being baek-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 MSS1.Basis Reference(s):

1. NEI 99-01 Rev 6, SA12. UFSAR 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138 KV System and 345 KV Alternate Supply Failure5. DOA 6500-01 4KV Bus Failure6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout Generator Ties to Plant Auxiliary Electric System7. UFSAR 9.5.9 Station Blackout System8. DOP 6620-05, Powering Unit 2(3) 4KV Busses via the SBO D/G 2(3)9. DGA-1 2 Partial or Complete Loss of AC PowerMonth 20XXDR 3-54EP-AA-1004 (Revision XX)

Annexresden Annex Exelnn Nucl~easr RECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSU1Initiating Condition:

Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.Operating Mode Applicability:

1,2,3Emergency Acton Level (EAL):Note:* The Emergency Director should declare the event Promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.

The Emergency Director ehould doclaro the Unusual Event prom~ptly upondetermining that 1 6 ute, has been ev-edod,or Oi,;ll likely be eXveeded.

--.Loss of ALL offsite AC power capability to unit ECOS buses (;.ite...epific em.ergency

> 15 minutes-e-r-loPWe.

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. (e.g. unit cross-tie breakers)

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 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138 kV System and 345 kV Alternate Supply Failure5. DOA 6500-01 4kV Bus Failure6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout Generator Ties to Plant Auxiliary Electric System7. UFSAR 9.5.98. DOP 6620-05, Powering Unit 2(3) 4kV Busses via the SBO D/G 2(3)Month 20XXDR 3-55EP-AA-1004 (Revision XX)

Dresden AnnexExellon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS

9. DGA-12 Partial or Complete Loss of AC PowerMonth 20XXDR 3-56EP-AA-1004 (Revision XX)

Dry.dAn AnnAxNuclearfrw dwn Annex Exelvn NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSG28Initiating Condition:

Loss of all AC and Vital DC power sources for 15 minutes or longer.Operating Mode Applicability:

1,2,3Emergency Acton Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.

The E-morgncY Dir;ctAOr shuld dlclare the GoAn-ciral promptly upnRdotermining that 15 minutos h-as boon excocdcd, Or Will likoly bo oXccoded.

1. Loss of ALL offsite AC power to unit ECCS buses.AND2. Failure of DG 2(3), shared DG 2/3 and SBO DG 2(3) emergency diesel generators to supply power to vital buses.AND3. Voltage is < 105 VDC on 125 VDC battery buses #2 and #3.AND4. ALL AC and Vital DC power sources have been lost for > 15 minutes.1 .a. Loss of ALL offtet and ALL ensito AC powor to (site-Specific.

cmcrgcncy buses) f-r 15 m;nt,- or I6,nger.ANMb. indicatod v.oltage is loss than (sito specific bus voltage value) on ALL(site spocific Vital DC u- suss o 5 iue o ogrBasis:SAFETY SYSTEM: A svstem reguired for safe plant operation, cooling down the plantand/or Dlacina it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.

Month 20XXDR 3-57EP-AA-1004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS This 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 requiring electric 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 all EALconditionse are met.Basis Reference(s):

1. NEI 99-01 Rev 6, SG82. UFSAR 8.33. 12E-2302A, Station Key Diagram 4160V and 480V Switchgears Part 14. DOA-6400-01, 138-kV System and 345-kV Alternate Supply Failure5. DOA 6500-01 4KV Bus Failure6. UFSAR Fig. 9.5-14 Single-Line Electrical Diagram of Station Blackout Generator Ties to Plant Auxiliary Electric System7. UFSAR 9.5.98. DOP 6620-05, Powering Unit 2(3) 4KV Busses via the SBO D/G 2(3)9. DGA-1 2 Partial or Complete Loss of AC Power10. UFSAR 8.3.211. DOA 6900-02(3)

Failure of Unit 2(3) 125 VDC Power Supply12. Technical Specification B.3.8.4, DC Power Sources -Operating Month 20XXDR 3-58EP-AA-1 004 (Revision XX)

I=yplnn rflmrtdpn Annex ExelInn NucleIair RECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSS28Initiating Condition:

Loss of all vital DC power for 15 minutes or longer.Operating Mode Applicability:

1,2,3Emergency Acton Level (EAL):Note:* The Emerqency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.

The .Emergency Dirovtv 6h1u4d0d-caro thoSit.e Are. n EmergencY promptly upondotormining that 15 minutes ha6 boon eXcoodod, or Will likely be excccded.

,,diGated--Voltage is < 105 VDC Iere" than (c..ite bus voltage value) "on125 VDC battery buses #2 and #3ALL (cite -pci..c; Vital DG bu.. ..uses4 for>15 minutes-OF-.eRge 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 condition involves a major failure of plant functions needed for the protection of the public.I 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 8.3.23. DOA 6900-02(3)

Failure of Unit 2(3) 125 VDC Power Supply4. Technical Specification B.3.8.4, DC Power Sources -Operating Month 20XXDR 3-59EP-AA-1 004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSS3,Initiating Condition:

Inability to shutdown the reactor causing a challenge to RPV water level or RCS heatremoval.Operating Mode Applicability:

1,2Emergency Acton Level (EAL):1. Automatic scram did not shutdown the reactor as indicated by Reactor Power > 6%.AND2. ALLA. manual / ARI actions to shutdown the reactor have been unsuccessful asindicated by Reactor Power > 6%.AND3. EITHER of the following conditions exist:" RPV water level cannot be restored and maintained

> -164 inchesOR" Heat Capacity Limit (DEOP 200-1. Fig. M) exceeded.

(Site specific indication of.an ia to adequately emove heat fFrom the core)(Site specific indication of an nblt to adequatcly 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 ,ubsequent operator actions to manually shutdown the reaGcto 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 behigher 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 theI reactor.Month 20XXDR 3-60EP-AA-1004 (Revision XX)

Nr=dmnn AnnavJ=vainn Nl io-larflrnc~rI~n Ann~ir FvmLnn Mm mr~Ia~rRECOGNITION CATEGORYSYSTEM MALFUNCTIONS RPV values are actual levels, not indicated levels. Therefore, they may need levelcompensation dependingq on conditions.

A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.

Escalation of the emergency classification level would be via IC RAG1 or FG1.Basis Reference(s):

1. NEI 99-01 Rev 6, SS52. DEOP 100 RPV Control3. DEOP 400-5 Failure to Scram4. DEOP 200-1 Primary Containment Control5. Technical Support Guidelines Month 20XXDR 3-61EP-AA-1004 (Revision XX)

Dresden AnnexExelon NuclearDresden Annex Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSA35Initiating 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 Acton 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,-aAutomatic or manual scram did not shutdown the reactor as indicated byReactor Power > 6%.AND2. Manual / ARI actions taken at the reactor control consoles are not successful inshutting down the reactor as indicated by Reactor Power > 6%.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 control consoles to shutdown the reactor are alsounsuccessful.

This condition represents an actual or potential substantial degradation of 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 controlconsoles since this event entails a significant failure of the RPS.A manual action at the reactor control consoles is any operator action, or set of actions,which causes the control rods to be rapidly inserted into the core (e.g., initiating amanual reactor scram. This action does not include manually driving in control rods orimplementation of boron injection strategies.

If this action(s) is unsuccessful, operators would immediately pursue additional manual actions at locations away from the reactorcontrol 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 control 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, otherMonth 20XXDR 3-62EP-AA-1004 (Revision XX)

Dresden Annex Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS concurrent plant conditions, etc. If the failure to shutdown the reactor is prolonged enough 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 MSS36. Depending upon plant responses and symptoms, escalation is also possiblevia IC FSi. Absent the plant conditions needed to meet either IC MSS_3 or FS1, anAlert declaration is appropriate for this event.It is recognized that plant responses or symptoms may also require an Alert declaration in accordance with the Recognition Category F l1s; however, this IC and EAL areincluded to ensure a timely emergency declaration.

i A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.

Basis Reference(s):

1. NEI 99-01 Rev 6, SA52. DEOP 100 RPV Control3. DEOP 400-5 Failure to Scram4. DEOP 200-1 Primary Containment ControlMonth 20XXDR 3-63EP-AA-1004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSU36Initiating Condition:

Automatic or manual scram fails to shutdown the reactor.Operating Mode Applicability:

1,2Emergency Acton 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. Ap,-aAutomatic scram_-did not shutdown the reactor as indicated by ReactorPower > 6%..ANDb. A-sSubsequent manual / ARI action taken at the reactor control consoles issuccessful in shutting down the reactor.OR2. a. A-nManual scram-did not shutdown the reactor as indicated by ReactorPower > 6%.ANDb. EITHER of the following:
1. A-,Subsequent manual / ARI action taken at the reactor control consolesis 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 control consoles or an automatic scram is successful in shutting down the reactor.

This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.EAL #1 BasisFollowing the failure on an automatic reactor scram, operators will promptly initiatemanual actions at the reactor control consoles to shutdown the reactor (e.g., initiate amanual reactor scram). If these manual actions are successful in shutting down theMonth 20XXDR 3-64EP-AA-1004 (Revision XX)

AnnoyNuclearfr&AQdJn AnnAY Exellon NuclasrRECOGNITION CATEGORYSYSTEM MALFUNCTIONS

reactor, core heat generation will quickly fall to a level within the capabilities of theplant's decay heat removal systems.EAL #2 BasisIf an initial manual reactor trip is unsuccessful, operators will promptly take manualaction at another location(s) on the reactor control 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 control consoles is any operator action, or set of actions,which causes the control rods to be rapidly inserted into the core (e.g., initiating 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 control 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 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 subsequent operator manual actions taken at thereactor control consoles are also unsuccessful in shutting down the reactor, then theI emergency classification level will escalate to an Alert via IC MSA36. Depending uponthe plant response, escalation is also possible via IC FA1. Absent the plant conditions I needed to meet either IC MSA35 or FA1, an Unusual Event declaration is appropriate for this event.I A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.

I 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 determined through other means (e.g., assessment of test results),

then this IC and the EALsMonth 20XXDR 3-65EP-AA-1004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS are not applicable and no classification is warranted.

Basis Reference(s):

1. NEI 99-01 Rev 6, SU52. Technical Specifications Table 3.3.1.1-1
3. DEOP 100 RPV Control4. DEOP 400-5 Failure to ScramMonth 20XXDR 3-66EP-AA-1004 (Revision XX)

AnnAxNuelAarDresden Annex Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSA42Initiating Condition:

UNPLANNED loss of Control Room indications for 15 minutes or longer with asignificant transient in progress.

Operating Mode Applicability:

1,2,3Emergency Acton Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.

Tho E=m...goncy Diocto , should do.laro the Aler promptly upon determining that 15min*utes has boon exceoded, Or Will likely be exceeded-.

1. a.

event results in the inability to monitor oneo Or Table MWet th f",e,.-ewi parameters from within the Control Room for >15minutes Or--lene

.[B 14ZR pammDm, Ust]Reactor Po9wer___________________

Table MI Control Room Parameters RP, ..vel , Reactor Power* RPV Water LevelRtP

.RPV Pressure* Primary Containment PressurePria- .. .t.i-m. .* Torus Level....... e. Torus Temperature Suppression Pool LevelSuppression Pool Temperature ANDb. Any Table M2Wft the-

, transient events in progress.

" Automatic Or Manual Dunback gratcr than 26% the P-al reactor pRevwEloc~etrical load rejection greator than 25% full electrical loadMonth 2OXX DR 3-67 EP-AA-1004 (Revision XX)

AnnexNuelAarn1 VVweln Annex Exilin NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS ECCGS (SI) actuation Table M2 Significant Transients

" Turbine Trip" Reactor Scram* ECCS Activation

  • Recirc. Runback > 25% Reactor Power Change* Thermal Power oscillations

> 10% Reactor Power ChangeBasis: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 parameter change or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or olacin it in the cold shutdown condition.

includina 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 parameters from within the Control Room. During this condition, the margin to a potential fissionproduct barrier challenge is reduced.

It thus represents a potential substantial degradation in the level of safety of the plant.As used in this EAL, an "inability to monitor" means that values for one mereanv 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, 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 procedures Month 20XXDR 3-68EP-AA-1004 (Revision XX)

AnnoyN urJparflr.~e4.

Annv FvInn Nmir-Ipnr RECOGNITION CATEGORYSYSTEM MALFUNCTIONS addressing 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-IeveIRPV water level and RCS heat removal.The loss of the ability to determine one Or 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 or mroany 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 determined from 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.I 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 RASI.Basis Reference(s):

1. NEI 99-01 Rev 6, SA2Month 20XXDR 3-69EP-AA-1004 (Revision XX)

NuelAArVlmlden Anne E xeIon Nuc.IeVar RECOGNITION CATEGORYSYSTEM MALFUNCTIONS IMSU42Initiating Condition:

UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:

1,2,3Emergency Acton Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.J I 0 Iroll l lnoT. iTrýnrV=

uirnn.or1

ýVHF wr~noiiici anctar.0 i-Tflf E W Mictiai 1 &flf= nrrn 5 UnM.onW n crmf-%I g IV mlflant 1 R =inir.o hoo hann awaaandnd or wall likalu ha narnandnd a AR-UNPLANNED event results in the inability to monitor onoe Or mooANY Table M1parameter from within the Control Room for > 15 minutes.Table M1 Control Room Parameters

1. of the following paramctcrs from within the Control Room for 15 minutes2. [BWVR parmctc 3. [PWR Paramctcfr-
4. Reaetor Power 6. Reactor-Power-8.RVWater Lcvcl9 &RGS LeveI10. URPV1 Press,,c
11. RCS Pr-essure 1-2.Pr-muw
13. in Cor-e/Cor-e
14. Suppression Pol15. Levels in at leastLevel (site speeienumber) tam16. Supp sion Poo.17..Ste am lnrTempematur-e AuxilayeMonth 20XXDR 3-70EP-AA-1004 (Revision XX)

AnnAyNuelAarfrPAQd1n Annex Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS

2. [BWIR parawter-
3. WIW-Rparameter 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 parameter change 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 conditions without 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 nAe-O rmorFany 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-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 procedures addressing 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 one OrFmor-any of these parameters from within the ControlRoom is considered to be more significant than simply a reportable condition.

InI addition, if all indication sources for eeo r- merany 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.I Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.

I Escalation of the emergency classification level would be via IC MSA42.Month 20XXDR 3-71EP-AA-1004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS Basis Reference(s):

1. NEI 99-01 Rev 6, SU2Month 20XXDR 3-72EP-AA-1 004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSA59Initiating Condition:

Hazardous event affecting a SAFETY SYSTEM needd -reauired for the currentoperating mode.Operating Mode Applicability:

1,2,3Emergency Acton Level (EAL):(44 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 e (sito specific hazards)* Other events with similar hazard characteristics as determined by theShift ManagerAND2.b, EITHER of the following:Event damage has caused indications of degraded performance inat least one train of a SAFETY SYSTEM needed-required byTechnical Specification for the current operating mode.ORb._ 2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEMcomponent or structure needed-required by Technical Specification for the current operating mode.Basis:FIRE: Combustion characterized by heat and light. Sources of smoke such as slippingdrive belts or overheated electrical equipment do not constitute FIRES. Observation offlame is preferred but is NOT required if large quantities of smoke and heat areobserved.

EXPLOSION:

A rapid, violent and catastrophic failure of a piece of equipment due tocombustion, chemical reaction or overpressurization.

A release of steam (from highenergy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion.

Suchevents may require a post-event inspection to determine if the attributes of an explosion are present.Month 20XXDR 3-73EP-AA-1 004 (Revision XX) nroHarn AnnoyI=yalnn Nielalrn rncrI~n Ann~v Fv~Inn Nit urI~~rRECOGNITION CATEGORYSYSTEM MALFUNCTIONS SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the EGGS. These aretypically systems classified as safety-related.

VISIBLE DAMAGE: Damage to a component or structure that is readily observable without measurements,

testing, or analysis.

The visual impact of the damage issufficient to cause concern regarding the operability or reliability of the affectedcomponent or structure.

This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or astructure containing SAFETY SYSTEM components, needed-required for the currentoperating mode, "required",

i.e. required to be operable by Technical Specifications forthe current operating mode. This condition significantly reduces the margin to a loss orpotential loss of a fission product barrier, and therefore represents an actual or potential substantial degradation of the level of safety of the plant. Manual or automatic electrical isolation of safety equipment due to flooding, in and of itself, does not constitute degraded performance and is classified under HU6.EAL 41-b#.a Basis-This EAL addresses damage to a SAFETY SYSTEM train that is required to beoperable by Technical Specifications for the current operating mode, and is inseeAieoperation since indications for it will be readily available.

The indications ofdegraded performance should be significant enough to cause concern regarding theoperability or reliability of the SAFETY SYSTEM train.EAL 44.2.b BasisThis EAL -addresses damage to a SAFETY SYSTEM component that is- required to beoperable by Technical Specifications for the current operating mode, and is not insepeGvoperation or readily apparent through indications alone, er-as well as damage toa structure containing SAFETY SYSTEM components.

Operators will make thisdetermination based on the totality of available event and damage report information.

This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level would be via IC FS1 or RAS1.If the EAL conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.Basis Reference(s):

1. NEI 99-01, Rev 6 SA9Month 20XXDR 3-74EP-AA-1004 (Revision XX)

Dresden AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSU64Initiating Condition:

RCS leakage for 15 minutes or longer.Operating Mode Applicability:

1,2,3Emergency Acton Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.

The Emrgncy Diroct,-r shonulId4 the Unusual Event promptly upondtrig that 15 mninute has been eXceeded, Or Will likely be oxcevdod.

1. RCS unidentified or pressure boundary leakage in the Drywell ..eatef-"ha

> 10 apm for> 15 minutes ..(..t spcific value) for 15 m.inutes Or lon.ger..

OR2. RCS identified leakage in the Drvwell qreateF than-5amfo>1 iuts(ies*pecific value) for 15 mninutec or longer.OR3. Leakage from the RCS to a location outside Drvwell >25 gpm for >15 minutes .greater than 25 gpm. fo 16 minutes or longer.Basis:UNISOLABLE:

An open or breached system line that cannot be isolated, remotely orlocally.This IC addresses RCS leakage which may be a precursor to a more significant event.In this case, RCS leakage has been detected and operators, following applicable procedures, have been unable to promptly isolate the leak. This condition is considered to be a potential degradation of the level of safety of the plant.EAL #1 and EAL #2 BasisThese EALs are focused on a loss of mass from the RCS due to "unidentified leakage",

"pressure boundary leakage" or "identified leakage" (as these leakage types are definedin the plant Technical Specifications).

EAL #3 BasisThis EAL addresses a RCS mass loss caused by an UNISOLABLE leak through aninterfacing system.Month 20XXDR 3-75EP-AA-1004 (Revision XX)

AnnexI=xelon Nuclearfresden Annex Exelnn NucleanrRECOGNITION CATEGORYSYSTEM MALFUNCTIONS These EALs thus apply to leakage into the containment, a secondary-side system (e-g-.,steam gene.r.ato..

r tube,, leakage in a PWR) or a location outside of containment.

The leak rate values for each EAL were selected because they are usually observable with normal Control Room indications.

Lesser values typically require time-consuming calculations to determine (e.g., a mass balance calculation).

EAL #1 uses a lower valuethat reflects the greater significance of unidentified or pressure boundary leakage.The release of mass from the RCS due to the as-designed/expected operation of anyrelief valve does not warrant an emergency classification.

A stuck-onen Electromatic relief valve (ERV)/Taroet Rock SRV or ERV Target RockSRV leakage is not considered either identified or unidentified leakage by Technical Specifications and, therefore, is not applicable to this EAL.The rel.aso of mass from the RCS due to the as designed.expeted operation of..relief valve does not warrant an omorgoncy classification.

r-.. BWR's, aA stuck- penSafety Rolief Valve, (SRV) or, SR leakage is not conSidered

+ithe, identified OFunlonintifled leaage by I ifaiation and, tnlo4retro, is not applin lAio to tn"sThe 15-minute threshold duration allows sufficient time for prompt operator actions toisolate the leakage, if possible.

Escalation of the emergency classification level would be via ICs of Recognition Category BA or F.Basis Reference(s):

1. NEI 99-01 Rev 6, SU42. Technical Specification 3.4.4, RCS Operational Leakage3. UFSAR 5.2.5, Detection of Leakage through Reactor Coolant Pressure Boundary4. Technical Specifications 3.4.55. Unit 2(3) Appendix A Unit NSO Daily Surveillance Log6. DAN 902(3)-4 A-17 Equip Sump Lvl HI-HI7. DAN 902(3)-4 H-18 DQywaeDy~well Floor Drn Sump Lvl HI-HI8. DOA 0040-01 Slow Leak9. DOP 2000-24 DQywellDrywell Sump Operation
10. DGP 02-02 Reactor Vessel Slow FillMonth 20XXDR 3-76EP-AA-1004 (Revision XX)
Retrieved from "https://kanterella.com/w/index.php?title=ML14164A064&oldid=789907"