ML14164A069: 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 1: Line 1:
{{Adams
#REDIRECT [[RA-14-032, Attachment 7: Discussion of Revision to the Radiological Emergency Plan Annex for Limerick Generating Station. LGS 3-70 Page LGS 3-155]]
| number = ML14164A069
| issue date = 05/30/2014
| title = Attachment 7: Discussion of Revision to the Radiological Emergency Plan Annex for Limerick Generating Station. LGS 3-70 Page LGS 3-155
| author name =
| author affiliation = Exelon Generation Co, LLC
| addressee name =
| addressee affiliation = NRC/FSME, NRC/NMSS
| docket = 05000352, 05000353
| license number =
| contact person =
| case reference number = RA-14-032, RS-14-115, TMI-14-046
| document report number = EP-AA-1008
| package number = ML14164A053
| document type = Emergency Preparedness-Emergency Plan
| page count = 193
}}
 
=Text=
{{#Wiki_filter:I imprirnk (tanarnfinn Afiqfinn AnnoyI=yelnn rFyokinn N"t-loarRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSA59Initiating Condition:
Hazardous event affecting a SAFETY SYSTEM needed-required for the currentoperating mode.Operating Mode Applicability:
1,2,3Emergency Action Level (EAL):(4- 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 vpecific, hazard,)" Other events with similar hazard characteristics as determined by theShift ManagerAND2.1a, EITHER of the following:
a.4-. Event damage has caused indications of degraded performance inat least one train of a SAFETY SYSTEM needed-required byTechnical Specifications for the current operating mode.ORb.2-. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEMcomponent or structure needed-required by Technical Specifications for the current operating mode.Basis:FIRE: Combustion characterized by heat and light. Sources of smoke such as 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 20XXLGS 3-70EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExellon NuclearRECOGNITION 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 ECCS. 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, nae l-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.EA.14 EAL #2.a addresses damage to a SAFETY SYSTEM train that is required tobe operable by Technical Specifications for the current operating mode, and is inSeeiGeoperation 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. -OAL1-b-h.
EAL #2.b addresses damage to a SAFETY SYSTEM component that isrequired to be operable by Technical Specifications for the current operating mode, andis not in sewiGeloperation or readily apparent through indications alone, er-as well asdamage to a structure containing SAFETY SYSTEM components.
Operators will makethis determination based on the totality of available event and damage reportinformation.
This is intended to be a brief assessment not requiring lengthy analysis orquantification 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.Month 20XXLGS 3-71EP-AA-1008 (Revision XX)
I imarirk rZanarnfin
-Qfnfitn AnnavI::alnn I~dl,,rl~
RECOGNITION CATEGORYSYSTEM MALFUNCTIONS Basis Reference(s):
'1. NEI 99-01, Rev 6 SA92. UFSAR Section 2.5, Geology and Seimology
: 3. UFSAR Section 3.4.1, Flood Protection
: 4. UFSAR Section 6.2.1.1.1, Design Bases5. UFSAR Section 9.2.6.4.2, Spray Pond Water Requirements
: 6. DBD L-S-46, Meteorological and Seismic Monitoring Systems7. DBD L-T-17, Dynamic Qualification Program8. Specification NE-0294, "Fire Safe Shutdown Analysis Specification"
: 9. SE-5 Earthquake
: 10. SE-4 Flood11. SE-9, Preparation for Severe WeatherMonth 20XXLGS 3-72EP-AA-1008 (Revision XX)
F:Yalnn Nnne-llnr Simeric~k Ganaratinn Station Annex vInNuIi2RECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSU641Initiating Condition:
RCS leakage for 15 minutes or longer.Operating Mode Applicability:
1,2,3Emergency Action Level (EAL):Note: The Emergency Director should declare the Unusual Event vent promptly upondetermining that the applicable time 45 iniites-has been exceeded, or will likelybe exceeded.
: 1. RCS unidentified or pressure boundary leakage in the DrywellgFeater-than
> 10 gpm for > 15 minutes.
(site spec.ifc value) for, 15 minute, Or lon.ger.OR2. RCS identified leakage in the Drywell greater-than->25 gpm for > 15 minutes.(site-Specifc value) f, 15 minuter, r
OR3. Leakage from the RCS to a location outside the Drywellfntainme
>25 gpm for >15 minutes ge. ater than 25 gpm for 1 -5 Minutes Or long.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.These EALs thus apply to leakage into the containment, a secondary-side systemsteam gen.rator
÷,tube leakage iR a PIR) 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 Month 20XXLGS 3-73EP-AA-1008 (Revision XX)
I imarirnk rpncargting Atntion Annex~ Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS 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 a-anyrelief valve does not warrant an emergency classification.
FcrFBWR'.,Aa stuck-open Safety Relief Valve (SRV) or SRV leakage is not considered either identified or unidentified leakage by Technical Specifications and, therefore, is notapplicable to this EAL.The 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 RA or F.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SU42. Technical Specifications 3.4.3, Reactor Coolant System Leakage3. Technical Specifications 3.9.8, Water Level -Reactor Vessel4. DBD L-S-34, Radwaste System5. OT-101 High Pressure6. T-102 Primary Containment
: Control, Table DW/T-17. GP-6.1 U/1 (U/2) Shutdown Operations
-Refueling, Core Alteration and CoreOff-Loading
: 8. DBD L-S-16, Reactor Instrumentation System (RIS)9. ST-6-107-596-*
liywelwDrywell Floor Drain Sump/Equipment Drain TankSurveillance LogMonth 20XXLGS 3-74EP-AA-1008 (Revision XX)
ExAIon NuclearLimeric~k
£GAneratina Station Annex Exelon Nucla~rRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSU76Initiating Condition:
Loss of all On-site or Off-site communications capabilities.
Operating Mode Applicability:
1,2,3Emergency Action Level (EAL):1. Loss of ALL Table M3 Onsite communications capability affecting the ability toperform routine operations.
OR2. Loss of ALL Table M3 Offsite communication capability affecting the ability toperform offsite notifications.
OR3. Loss of ALL Table M3 NRC communication capability affecting the ability toperform NRC notifications.
Table M3 Communications Capability System Onsite Offsite NRCStation Radio XPlant Public Address (PA) XPrelude System X XStation Phones X X xSatellite Phones X X XNARS XHPN X XENS X X1. Loss of ALL of the following onsite communication mnethods:
(sito specific list of communications method2. Loss of ALL of the following OROQ communn'Aications
: 6) meAt~ho~ds6 (s0iteA e__9Acific liSt Of communications mnethods)
Month 20XXLGS 3-75EP-AA-1008 (Revision XX)
I=YAInn Sim.vrit.k vn.r..in A.t-tin Annv. Evxinn Nv. uclarRECOGNITION CATEGORYSYSTEM MALFUNCTIONS 23 I-oss oef ALLI of the NRC cmmunication methods:(site spocifict list- of comnctosmothods)
Basis:This IC addresses a significant loss of on-site,-O-
: offsite, or NRC communications capabilities.
While not a direct challenge to plant or personnel safety, this eventwarrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.This IC should be assessed only when extraordinary means are being utilized to makecommunications possible (e.g., use of non-plant, privately owned equipment, relaying ofon-site information via individuals or multiple radio transmission points, individuals beingsent to offsite locations, etc.).EAL #1 BasisaAddresses a total loss of the communications methods used in support of routine plantoperations.
EAL #2 BasisaAddresses a total loss of the communications methods used to notify all OROs of anemergency declaration.
The OROs referred to here are listed in procedure EP-MA-1 14-1 00-F-01, State / Local Event Notification Form. (soo Notes)-.EAL #3 BasisaAddresses a total loss of the communications methods used to notify the NRC of anemergency declaration.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, SU62. UFSAR Section 9.5.2, Communication Systems3. SE-12 Loss of Communications Month 20XXLGS 3-76EP-AA-1008 (Revision XX)
I imarink ranarnfinn Afnfinn AnnoyFvalnn N.nla~rI imaarir~k
(~ong~rn*inn
~t~atinn Ann~v Fvalnn hI..t~Iaar RECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CA121Initiating Condition:
Loss of all offsite and all onsite AC power to emergency busses for 15 minutes orlonger.Operating Mode Applicability:
4,5, DEmergency Action Level (EAL):Note: The Emergency Director should declare the AleFt-vent promptly upondetermining that the applicable time 15 minutes time has been exceeded, or willlikely be exceeded.
: 1. Loss of ALL offsite AC power to unit 4KV Safeguards Buses.AND2. Failure of Dl1(21),
D12(22),
D13(23),
and D14(24) Emergency DieselGenerators to supply power to unit 4KV Safeguards Buses.AND3. Failure to restore power to at least one unit 4KV Safeguards bus in < 15minutes from the time of loss of both offsite and onsite AC power.Loes of ALL offs*te ane ALL A,-'-nsite AC Power to (site specifc emergency buses) fo1 4-5min*utes Or longer.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related 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.When in the cold shutdown, refueling, or defueled mode, this condition is not classified as a Site Area Emergency because of the increased time available to restore anemergency bus to service.
Additional time is available due to the reduced core decayheat load, and the lower temperatures and pressures in various plant systems.
Thus,when in these modes, this condition represents an actual or potential substantial degradation of the level of safety of the plant.Month 20XXLGS 3-77EP-AA-1008 (Revision XX)
I imgwir-k f.anarnfin
-Q#nfinn AnngivI:=alnn kl"anrlrI m~rjI,(anr$in~~+rn n~vF~n uMI~RECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via IC CS64- or RAS1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, CA22. UFSAR Section 8.2, Offsite Power System3. E 10-20 Loss of Offsite Power4. DBD L-S-05, 4KV System5. DBD L-T-03, Electrical IssuesMonth 20XXLGS 3-78EP-AA-1008 (Revision XX)
Fyplnn Nimloa=rSimerick (GAneratinn Sta~tion AnnexFA~nNu~a RECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS Cu12iInitiating Condition:
Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:
4,5, DEmergency Action Level (EAL):Note: The Emergency Director should declare the Unusual Ev,-tevent promptly upondetermining that the applicable time 15-mwtes-has been exceeded, or will likelybe exceeded.
: 1. AC power capability to unit 4KV Safeguards Buses reduced to only one of thefollowing power sources for > 15 minutes.* 101 Safeguards Transformer
* 201 Safeguards Transformer SD1 1(21) Diesel Generator
* D12(22) Diesel Generator
* D13(23) Diesel Generator
* D14(24) Diesel Generator AND2. ANY additional single power source failure will result in a loss of ALL AC powerto SAFETY SYSTEMS.A LAI: !; ;.r-.. k- -AI .4. i.;.- .,.-.; .- --w ,,.,-*. .,.,4,,-,.., .....I-.t v FrwV. 31, ".'PCI ty t ,,,d .to ..t .a ,,, " ,, vor ,,vr
,v M........
t v t ,.-,,,"S apower source for 15 minutes, or longer.ANDb. Any additional single poWor source failure Will recult iR loss of all AG power toBasis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.
This IC describes a significant degradation of offsite and onsite AC power sources suchthat any additional single failure would result in a loss of all AC power to SAFETYMonth 20XXLGS 3-79EP-AA-1008 (Revision XX)
-7Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS SYSTEMS.
In this condition, the sole AC power source may be powering one, or morethan one, train of safety-related equipment.
When in the cold shutdown, refueling, or defueled mode, this condition is not classified as an Alert because of the increased time available to restore another power source toservice.
Additional time is available due to the reduced core decay heat load, and thelower temperatures and pressures in various plant systems.
Thus, when in thesemodes, this condition is considered to be a potential degradation of the level of safety ofthe plant.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.* A loss of all offsite power with a concurrent failure of all but one emergency powersource (e.g., an onsite diesel generator).
* A loss of all offsite power and loss of all emergency power sources (e.g., onsitediesel generators) with a single train of emergency buses being back-fed from theunit main generator.
* A loss of emergency power sources (e.g., onsite diesel generators) with a singletrain of emergency buses being back-fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof power.The subsequent loss of the remaining single power source would escalate the event toan Alert in accordance with IC CA12.Basis Reference(s):
: 1. NEI 99-01 Rev 6 CU22. UFSAR Section 8.2, Offsite Power System3. E 10-20 Loss of Offsite Power4. DBD L-S-05, 4KV System5. DBD L-T-03, Electrical IssuesMonth 20XXLGS 3-80EP-AA-1008 (Revision XX)I Limeric~k Generatinn Station Annex Exeoln Nucle~arRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CA26Initiating Condition:
Hazardous event affecting SAFETY SYSTEM nieeded-required for the current operating mode.Operating Mode Applicability:
4,5Emergency Action Level (EAL):1. a- The occurrence of ANY of the following hazardous events:" Seismic event (earthquake)
" Internal or external flooding event" High winds or tornado strike* FIRE" EXPLOSION
" (site specific hazards)" Other events with similar hazard characteristics as determined by theShift ManagerAND2.b. EITHER of the following:
a.. Event damage has caused indications of degraded performance inat least one train of a SAFETY SYSTEM needed-required byTechnical Specifications for the current operating mode.ORb. 2 The event has caused VISIBLE DAMAGE to a SAFETY SYSTEMcomponent or structure needed-required by Technical Specifications for the current operating mode.Basis:FIRE: Combustion characterized by heat and light. Sources of smoke such as 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 20XXLGS 3-81EP-AA-1008 (Revision XX)
Limerick Generating-Station AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS 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.
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.E.A b--EAL #2.a addresses damage to a SAFETY SYSTEM train that is required tobe operable by Technical Specifications for the current operating mode, and is inSeivioperation 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-I EAL #2.b addresses damage to a SAFETY SYSTEM component that isrequired to be operable by Technical Specifications for the current operating mode, andis not in eeVice peration or readily apparent through indications alone, or to a structure containing SAFETY SYSTEM components.
Operators will make this determination based on the totality of available event and damage report information.
This is intendedto be a brief assessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level would be via IC CS64- or RASI.If the EAL conditions of CA2 are not met then assess the event via HU3, HU4, or HU6.Basis Reference(s):
: 1. NEI 99-01 Rev 6, CA6Month 20XXLGS 3-82EP-AA-1008 (Revision XX)
NuclearLimeric~k Generatinn Station Annex Exelon NucleanrRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS CU34Initiating Condition:
Loss of Vital DC power for 15 minutes or longer.Operating Applicability:
4,5Emergency Action Level (EAL):Note: The Emergency Director should declare the Unusual Even-tvent promptly upondetermining that the applicable time 15 minutes time has been exceeded, or willlikely be exceeded.
Voltage is < 108 VDC on required 125 VDC battery busses 1(2)FA, FB, FC, FD for > 15minutes.Ind-iated g lss than (site Specii bu6 V9otage Value) On required Vital DGbesforF 15 minutes or logRer.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 operable SAFETY SYSTEMS when the plant is in the cold shutdown orrefueling mode. In these modes, the core decay heat load has been significantly
: reduced, and coolant system temperatures and pressures are lower; these conditions increase the time available to restore a vital DC bus to service.
Thus, this condition isconsidered to be a potential degradation of the level of safety of the plant.As used in this EAL, "required" means the Vital DC buses necessary to supportoperation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment.
For example, if Train A is out-of-service (inoperable) for scheduled outage maintenance work and Train B is in-service (operable),
then a loss of Vital DC power affecting Train Bwould require the declaration of an Unusual Event. A loss of Vital DC power to Train Awould not warrant an emergency classification.
Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Depending upon the event, escalation of the emergency classification level would be viaIC CA64- or CA53, or an IC in Recognition Category RA.Basis Reference(s):
: 1. NEI 99-01 Rev 6, CU42. UFSAR Section 8.3.2, DC Power SystemsMonth 20XXLGS 3-83EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS
: 3. DBD P-L-01A, 125/250 VDC System4. E-1(2)FA Loss of Division I Safeguard 125/250V DC BUS 1FA5. E-1(2)FB Loss of Division II Safeguard 125/250V DC BUS 1FB6. E-1(2)FC Loss of Division III Safeguard 125/250V DC BUS 1FC7. E-1(2)FD Loss of Division IV Safeguard 125/250V DC BUS 1FDMonth 20XXLGS 3-84EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CU45 IInitiating Condition:
Loss of all onsite or offsite communications capabilities.
Operating Mode Applicability:
4,5, DEmergency Action Level (EAL):1. Loss of ALL Table C1 Onsite communications capability affecting the ability toperform routine operations.
OR2. Loss of ALL Table C1 Offsite communication capability affecting the ability toperform offsite notifications.
OR3. Loss of ALL Table C1 NRC communication capability affecting the ability toperform NRC notifications.
Table C1 Communications Capability System Onsite Offsite NRCStation Radio XPlant Public Address (PA) XPrelude System X XStation Phones X X XSatellite Phones X X XNARS XHPN X XENS X XJ I _ _ _ _ l I
* _ JP LI -- In _ !-- ----tL ....... ."-- --..... ll-- -- -I--to LOSS,;&#xfd;.
EOT MAL !La r-T ftne T~I OW% flO T. ur W.m1iato T-i ..FT 1 w dT..JI. L *XA 1 t ---. ...--- .tsite specdk list Of GOMMUnIcatiOnS..
metnoa)') Inr of Al I ~-I kAth faljnru~na R Q a~cirm nialm rnmu,+d.
-(cite 69ocific-lisit of co-emmunicationA moethoe&4 Month 20XXLGS 3-85EP-AA-1008 (Revision XX)
Simeric~k Gener~atinn Station Annexv Exelln Nucle~arRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS
: 2. Lss of ALL of the followiOng NRC OM comuications_
m~ethodsBasis:This IC addresses a significant loss of on-site,
-er-offsite, or NRC communications capabilities.
While not a direct challenge to plant or personnel safety, this eventwarrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.This IC should be assessed only when extraordinary means are being utilized to makecommunications possible (e.g., use of non-plant, privately owned equipment, relaying ofon-site information via individuals or multiple radio transmission points, individuals beingsent to offsite locations, etc.).EAL #1 BasisaAddresses a total loss of the communications methods used in support of routine plantoperations.
EAL #2 BasisaAddresses a total loss of the communications methods used to notify all OROs of anemergency declaration.
The OROs referred to here are listed in procedure EP-MA-1 14-1 00-F-01, State / Local Event Notification Form (see Developer Notes).EAL #3 BasisaAddresses a total loss of the communications methods used to notify the NRC of anemergency declaration.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, CU52. UFSAR Section 9.5.2, Communication Systems3. SE-12 Loss of Communications Month 20XXLGS 3-86EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CA53Initiating Condition:
Inability to maintain the plant in cold shutdown.
Operating Mode Applicability:
4,5Emergency Action Level (EAL):Note: The Emergency Director should declare the AleFtevent promptly upondetermining that the applicable time has been exceeded, or will likely beexceeded.
: 1. UNPLANNED rise in RCS temperature
> 200OF due to lossremoval for > Table C2 duration.
of decay heatTable C2 RCS Heat-up Duration Thresholds RCS Containment Closure Heat-upStatus Status DurationIntact Not Applicable 60 minutes*Not Intact Established 20 minutes*Not Established 0 minutes* If an RCS heat removal system is in operation withinthis time frame and RCS temperature is being reduced,then EAL #1 is not applicable.
OR2. UNPLANNED RPV pressure rise > 10 psig as a result of temperature rise due toloss of decay heat removal.1. UN PLA~NNED increasce in RCS temperature to greater than (site specificT~ankn na I Qnaneifnh2tin naldabutdaw
,r~~.n tarna rntu ,rn Nmet! famr a ranar than'. tha14 1. r. A ; 9&#xfd; 9-ii kitit-Clt 'dH tPpt:b 0 "t 0 vdw "q to mMonth 20XXLGS 3-87EP-AA-1008 (Revision XX)
I::xalon NudAarLimericvk Gnrartinv Station Annex Exelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS T-a-ble:
RDCS3 Hatup Du,-.ratian Thresholds Cona- nn Me n t C I --u-re ______RCSStau.Status Heat up Dur-ation reducod not liappliGa IN -tIA- A-Not intact (or at red ucod ~stabhlhs 20 monutes*mivelteFy-fPW4R])
Not Eistablished 9 inutes* If an RCS heat rcmeyal system is in opcration within this time frameand RCS temperatur~e is being reducod, the EAL is not applicable-.
.UNIPn ANINE RCS prssure inr.ease greatr mthan (site reading).
(This =AL= doer, not apply durinig water- so0lid plant conditions.
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.CONTAINMENT CLOSURE:
The procedurally defined conditions or actions taken tosecure containment (primary or secondary for BWR) and its associated structures,
: systems, and components as a functional barrier to fission product release undershutdown conditions.
RCS is intact when the RCS pressure boundary is in its normal condition for the ColdShutdown mode of operation (e.g. no freeze seals, or steam line nozzle plugs, etc.).This IC addresses conditions involving a loss of decay heat removal capability or anaddition of heat to the RCS in excess of that which can currently be removed.
Eithercondition represents an actual or potential substantial degradation of the level of safetyof the plant.A momentary UNPLANNED excursion above the Technical Specification cold shutdowntemperature limit when the heat removal function is available does not warrant aclassification.
The RCS Heat-up Duration Thresholds table addresses an 4iR-easerise in RCStemperature when CONTAINMENT CLOSURE is established but the RCS is not intact.7Or RCS is- reduced (e.g., mid loop operation in The 20-minute criterion was included to allow time for operator action to address the temperature The RCS Heat-up Duration Thresholds table also addresses ao iRGeaserise in RCStemperature with the RCS intact. The status of CONTAINMENT CLOSURE is notMonth 20XXLGS 3-88EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS crucial in this condition since the intact RCS is providing a high pressure barrier to afission product release.
The 60-minute time frame should allow sufficient time toaddress the temperature ieaserise without a substantial degradation in plant safety.Finally, in the case where there is aw i4reaserise in RCS temperature, the RCS is notintact Or is at redued in.ento.;
[P.., Rj, and CONTAINMENT CLOSURE is notestablished, no heat-up duration is allowed (i.e., 0 minutes).
This is because 1) theevaporated reactor coolant may be released directly into the Containment atmosphere and subsequently to the environment, and 2) there is reduced reactor coolant inventory above the top of irradiated fuel.EAL #2 provides a pressure-based indication of RCS heat-up.Escalation of the emergency classification level would be via IC CS64- or RASI.Basis Reference.():
: 1. NEI 99-01 Rev 6, CA32. Technical Specifications LCO 3.6.5.1, Reactor Enclosure Secondary Containment Integrity
: 3. Technical Specifications Table 1.2, Operational Conditions
: 4. DBD L-S-16, Reactor Instrumentation System (RIS)5. UFSAR Section 6.2, Containment Systems6. UFSAR Section 6.3, Emergency Core Cooling Systems7. Technical Specifications LCO 3.6.1.1, Primary Containment Integrity
: 8. ST-6-107-640
: 9. ST-6-107-641
: 10. GP-6.2, Shutdown Operations-Shutdown Conditions Tech Spec ActionsMonth 20XXLGS 3-89EP-AA-1008 (Revision XX)
I imariek (' Zonarnfinn Afnfinn AnnaXExAIon NuclearI im~ri~k (onanmtin
~~atin An~vExelnn Nuclea~rRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CU53Initiating Condition:
UNPLANNED ieaeerise in RCS temperature Operating Mode Applicability:
4,5Emergency Action Level (EAL):Note: The Emergency Director should declare the Unusual Eventevent promptly upondetermining that the applicable time 1-5-- iutee-has been exceeded, or will likelybe exceeded.
: 1. UNPLANNED rise in RCS temperature
> 200OF due to loss of decay heatremoval.OR2. Loss of the following for >15 minutes.ALL RCS temperature indications AND* ALLRPV water level indications
: 1. UNPLA.NNED incr~easr.e in RCS G temperature to greater than (site specificTechnic~al Specification cold shutdol.wnfl temperature limit).-2. Loss of ALL RCS temperature and reactor vesseVRCS; lev.el indication for 15minutes Or longer.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.CONTAINMENT CLOSURE:
The procedurally defined conditions or actions taken tosecure containment (primary or secondary for BWR) and its associated structures,
: systems, and components as a functional barrier to fission product release undershutdown conditions.
This IC addresses an UNPLANNED iRreaserise in RCS temperature above theTechnical Specification cold shutdown temperature limit, or the inability to determine RCS temperature and level, represents a potential degradation of the level of safety ofMonth 20XXLGS 3-90EP-AA-1008 (Revision XX)
I=xAInn Simeric~k CGAneratinn Station Anne~x Exelnn ucleanrRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS the plant. If the RCS is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency Director should also refer to IC CA53.RCS is intact when the RCS pressure boundary is in its normal condition for theCold Shutdown mode of operation (e.g. no freeze seals, or steam line nozzle plugs,etc.).A momentary UNPLANNED excursion above the Technical Specification cold shutdowntemperature limit when the heat removal function is available does not warrant aclassification.
EAL #1 involves a loss of decay heat removal capability, or an addition of heat to theRCS in excess of that which can currently be removed, such that reactor coolanttemperature cannot be maintained below the cold shutdown temperature limit specified in Technical Specifications.
During this condition, there is no immediate threat of fueldamage because the core decay heat load has been reduced since the cessation ofpower operation.
During an outage, the level in the reactor vessel will normally be maintained above thereactor vessel flange. Refueling evolutions that lower water level below the reactorvessel flange are carefully planned and controlled.
A loss of forced decay heat removalat reduced inventory may result in a rapid inGreaserise in reactor coolant temperature depending on the time after shutdown.
EAL #2 reflects a condition where there has been a significant loss of instrumentation capability necessary to monitor RCS conditions and operators would be unable tomonitor key parameters necessary to assure core decay heat removal.
During thiscondition, there is no immediate threat of fuel damage because the core decay heatload has been reduced since the cessation of power operation.
Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.
Escalation to Alert would be via IC CA64- based on an inventory loss or IC CA53 basedon exceeding plant configuration-specific time criteria.
Month 20XXLGS 3-91EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS Basis Reference(s):
: 1. NEI 99-01 Rev 6, CU32. T-102, Primary Containment Control -Bases3. DBD L-S-16, Reactor Instrumentation System (RIS)4. ST-6-107-640-*
RX Vessel Temperature and Pressure Monitoring
: 5. GP-6.1 U/1(U/2)
Shutdown Operations
-Refueling, Core Alteration and CoreOff-Loading
: 6. ST-6-107-641-*
RX Vessel Temperature and Pressure Monitoring with no RHRShutdown Cooling Loops in Operation
: 7. GP-6.2, Shutdown Operations-Shutdown Conditions Tech Spec ActionsMonth 20XXLGS 3-92EP-AA-1008 (Revision XX) l=xAInn N.nlAarLimeric~k (GAnerztinn Staition Annex Exelnn NuclezarRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CG64-Initiating 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 Gen-ral -- --ergecye vent promptlyupon determining that the applicable time 3Q-miites-has been exceeded, or willlikely be exceeded.
: 1. a. RPV water level < -161 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 core uncovery.
OR" ANY Table C5 Refuel Floor Area Radiation Monitor >3 R/hr.ANDc. ANY Containment Challenge Indication (Table C4)IMonth 20XXLGS 3-93EP-AA-1008 (Revision XX)
Limeric~k Generatina Station Annex Exeonn NuclearRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS Table C3 Indications of RCS Leakage" UNPLANNED floor or equipment sump level rise** UNPLANNED Suppression Pool level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.
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 > T-103 / SAMP Max SafeOp Value (MSO).* if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency is not required.
Table C5Refuel Floor ARM's" RIS29-M1-1(2)K600, Drywell Head Laydown" RIS30-M1-1(2)K600, Dryer / Separator Area" RIS31-M1-1(2)K600, Spent Fuel Pool* RIS32-Ml-1(2)K600, New Fuel storage Vault* RIS33-M1-1(2)K600, Pool Plug Laydowni. a. (Reactor v:occolRCS level less than (site sepoific leveol) for 30 mninutec orFAND19. ANY andicatien from the Cotanen hallenge Table (see below).2. .Racator veccoU1CSZ level cnnont be4 monitored for 30 min-toc or longer.Month 20XXLGS 3-94EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONSb. Cor ucoinve ry is indicated by ANY of the fowl.ng:e (Site specific radiation moenitor-)
reading greater-thant (site speeific value)* Eratic source range moenitor-indicationt UUNPLANNED inAcrease in (qite s i ump and/ot r tank) levels of suffiente magnitde to indicate ore unover]nI (Other site speeifin indications)
ANDG. ANY ondicatien roem the Containment challenge Table (see belw).CoGntainment Challengo TableCONTAINMENT CLOSURE not establishedl (Explosive mixture) eKists inside contiffnment-UNPLANNED inemase in containmentupressrfe TI IC ONTAINdrENT CLOSURE a ii e established prino to rXccoding the 30 minute timelimit, then declaration of a Genecral Eim gen .t required.
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.IMMINENT:
The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.CONTAINMENT CLOSURE:
The procedurally defined conditions or actions taken tosecure containment (primary or secondary for BWR) and its associated structures,
: systems, and components as a functional barrier to fission product release undershutdown conditions.
This IC addresses the inability to restore and maintain reactor vessel level above thetop of active fuel with containment challenged.
This condition represents actual orIMMINENT substantial core degradation or melting with potential for loss of containment integrity.
Releases can be reasonably expected to exceed EPA Protective ActionGuidelines (PAG) exposure levels offsite for more than the immediate site area.Following an extended loss of core decay heat removal and inventory makeup, decayheat will cause reactor coolant boiling and a further reduction in reactor vessel level. IfRCS/reactor vessel level cannot be restored, fuel damage is probable.
Month 20XXLGS 3-95EP-AA-1008 (Revision XX)
Limerick Generi inn Station Annex Exelnn Nucler~IRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS With CONTAINMENT CLOSURE not established, there is a high potential for a directand unmonitored release of radioactivity to the environment.
If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.
The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at thelower deflagration limit). A hydrogen burn will raise containment pressure and couldresult in collateral equipment damage leading to a loss of containment integrity.
Ittherefore represents a challenge to Containment integrity.
In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to acore uncovery could result in an explosive gas mixture in containment.
If all installed hydrogen gas monitors are out-of-service during an event leading to fuel claddingdamage, it may not be possible to obtain a containment hydrogen gas concentration reading as ambient conditions within the containment will preclude personnel access.During periods when installed containment hydrogen gas monitors are out-of-service, operators may use the other listed indications to assess whether or not containment ischallenged.
EAL 2.a the 30-minute criterion is tied to a readily recognizable eventstart time (i.e., the total loss of ability to monitor level), and allows sufficient time tomonitor, assess and correlate reactor and plant conditions to determine if core uncoveryhas actually occurred (i.e., to account for various accident progression andinstrumentation uncertainties).
It also allows sufficient time for performance of actionsto terminate
: leakage, recover inventory control/makeup equipment and/or restore levelmonitoring.
The inability to monitor RP-V-IleyeIRPV water level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation.
If water level cannot be monitored, operators may determine that aninventory loss is occurring by observing changes in sump and/or tank levels. Sumpand/or tank level changes must be evaluated against other potential sources of waterflow to ensure they are indicative of leakage from the RPV.These EALs address concerns raised by Generic Letter 88-17, Loss of Decay HeatRemoval; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in theUnited States; and NUMARC 91-06, Guidelines for Industry Actions to AssessShutdown Management.
Month 20XXLGS 3-96EP-AA-1008 (Revision XX)
I imarirk I'Ziangarnfin
_Qfnfinn AnnovPginY~rn
, nr~lanrRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS Basis Reference(s):
: 1. NEI 99-01 Rev 6, CG12. T-102 Primary Containment Control -Bases3. T-103 Secondary Containment Control -Bases4. DBD P-S-20, Neutron Monitoring System5. DBD L-T-02, Containment, Section 3.2.146. Technical Specifications 3.6.1.1, Primary Containment Integrity
: 7. Technical Specifications 3.6.5.1, Reactor Enclosure Secondary Containment Integrity
: 8. UFSAR section 6.2.1.1.3.1, Summary Evaluation
: 9. EP-AEL-0501, Estimation of Radiation Monitor Readings Indicating CoreUncovery During Refuel10. T-101 RPV Control -Bases11. SAMP-2, Containment and Radioactivity Release ControlMonth 20XXLGS 3-97EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CS641Initiating Condition:
Loss of RPV inventory affecting core decay heat removal capability.
Operating Mode Applicability:
4,5Emergency Action Level (EAL):Note: The Emergency Director should declare the Sit.eArea F.-=r-.e..,yevent promptlyupon determining that the applicable time 320minutes-has been exceeded, or willlikely be exceeded.
: 1. With CONTAINMENT CLOSURE not established, RPV water level < -129inchesOR2. With CONTAINMENT CLOSURE established, RPV water level < -161 inches(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 core uncovery.
OR" ANY Table C5 Refuel Floor Area radiation Monitor >3 R/hr.Table C3 Indications of RCS Leakage" UNPLANNED floor or equipment sump level rise** UNPLANNED Suppression Pool level rise*" UNPLANNED vessel make up rate rise" Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.
Month 20XXLGS 3-98EP-AA-1008 (Revision XX)
I imprink ranamfinn Atnfinn AnnoyFvalnn N~i-lonrIll Im ik I I bn VII n I III A nbvFvln .iVhUuRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS Table C5Refuel Floor ARM's" RIS29-M1-1(2)K600, Drywell Head Laydown* RIS30-M 1-1 (2)K600, Dryer / Separator Area" RIS31-M1-1(2)K600, Spent Fuel Pool* RIS32-M1-1(2)K600, New Fuel storage Vault" RIS33-M1-1(2)K600, Pool Plug LaydownI I" I I:4. .-G 0N-44.....N 1-08~~r L4 RLUnot esi O btp IGI clp.-AMlevel)-1 :2 ,-R CONTlAINMlNlT C S1 I ,tlhoI-ANDHo 0 m 0XI 0 1 11 4.1&#xfd;k efl -V60 Gmto-VN1 0APve.+00-CH f tr&#xfd;IA&#xfd; ---% I r-1 A &#xfd;&#xfd;l .I-(I'&#xb6;eac~or ansei~r-a~
I-'V'I-I r t-&#xfd;i--'..
tT'.'m ao.o Cflfl0 mi moitrnoTo
.iumAnuto oFr longor.--------------
0- -- ---.. .AMDk ('r% .rn.,n nn&#xb6;GaII A 1.IV ^f *ka11* *** j l*-------------------
CW I UILV I '..... -ro 1;4fatic seurce range monitor ma1ication
-, b'- '' ~9 pr~~~A tiinueffa tn tsite ,peecii SUfM3 aflWEr- funilH feVefi, 0.-u ,IlCIIte!- -- .-- -Ifma~niiucio w inui~uie v~re uncuven,'* 1= *" \.uiner ~ne succino inaicanonsi Month 20XXLGS 3-99EP-AA-1008 (Revision XX)
I::yAInn N.nlAarLimerick (GAnerstinn Station Annex Exelnn NuclesarRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS 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.CONTAINMENT CLOSURE:
The procedurally defined conditions or actions taken tosecure containment (primary or secondary for BWR) and its associated structures,
: systems, and components as a functional barrier to fission product release undershutdown conditions.
This IC a 6;4-9Rgant and prolonged I,. of R\ ;R " inntorcontrol
,a'nd ,makeup apability lading to IMMINENT fuel damag. The lost inventory may be due toa RCS component
: failure, a loss of configuration control or prolonged boiling of reactorcoolant.
These conditions entail major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.
Following an extended loss of core decay heat removal and inventory makeup, decayheat will cause reactor coolant boiling and a further reduction in reactor vessel level. IfRCS/reactor vessel level cannot be restored, fuel damage is probable.
Outage/shutdown contingency plans typically provide for re-establishing or verifying CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory controlfunctions.
The difference in the specified RCS/reactor vessel levels of EALs #1-b and#2- reflect the fact that with CONTAINMENT CLOSURE established, there is a lowerprobability of a fission product release to the environment.
In EAL #3.a, the 30-minute criterion is tied to a readily recognizable event start time(i.e., the total loss of ability to monitor level), and allows sufficient time to monitor,assess and correlate reactor and plant conditions to determine if core uncovery hasactually occurred (i.e., to account for various accident progression and instrumentation uncertainties).
It also allows sufficient time for performance of actions to terminate
: leakage, recover inventory control/makeup equipment and/or restore level monitoring.
The inability to monitor RPV-levyeRPV water level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation.
If water level cannot be monitored, operators may determine that aninventory loss is occurring by observing changes in sump and/or tank levels. Sumpand/or tank level changes must be evaluated against other potential sources of waterflow to ensure they are indicative of leakage from the RPV.These EALs address concerns raised by Generic Letter 88-17, Loss of Decay HeatRemoval; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in theUnited States; and NUMARC 91-06, Guidelines for Industry Actions to AssessShutdown Management.
Escalation of the emergency classification level would be via IC CG4-6 or ARGI.Month 20XXLGS 3-100EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS Basis Reference(s):
: 1. NEI 99-01 Rev 6, CS12. Technical Specification Table 3.3.2-23. T-101 RPV Control -Bases4. T-102 Primary Containment Control -Bases5. T-103 Secondary Containment Control -Bases6. DBD P-S-20, Neutron Monitoring System7. DBD L-T-02, Containment, Section 3.2.148. Technical Specifications 3.6.1.1, Primary Containment Integrity
: 9. Technical Specifications 3.6.5.1, Reactor Enclosure Secondary Containment Integrity
: 10. DBD L-S-34, Radwaste SystemMonth 20XXLGS 3-101EP-AA-1008 (Revision XX)
NuclaarLimeric.k Station Annex Exmvon RECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS CA641Initiating Condition:
Loss of RPV inventory.
Operating Mode Applicability:
4,5Emergency Action Level (EAL):Note: The Emergency Director should declare the event AleFt-promptly upondetermining that the applicable time 46r-miuttes-has been exceeded, or will likelybe exceeded.
: 1. a. Loss of RPV inventory as indicated by level < -38 inches.OR2. a. RPV water level unknown for > 15 minutes.ANDb. Loss of RPV inventory per Table C3 indications.
Table C3 Indications of RCS Leakage" UNPLANNED floor or equipment sump level rise** UNPLANNED Suppression Pool level rise*" UNPLANNED vessel make up rate rise" Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.
.Losof reacotor esoRCinntr'ass ind-ic-ated by level loss than (Site specsific Ieive+)2. a. Reactor veSselIROS level cannot be monitored for 15 mninutes Or longerANDb. UNPLvANNED in.cease in (site specific sump and/or tank) levels due tloss of reactor vossel/RCS inventor;-.
Month 20XXLGS 3-102EP-AA-1008 (Revision XX)
I imariek rtanarnfinn Afnfinn AnnoyF:yalnn Nnnr~la=r I imorirgvw (vnwvzutiww vt~winn Animw FvInvw N w RECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS 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.This IC addresses conditions that are precursors to a loss of the ability toadequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier).
This condition represents a potential substantial reduction in the level of plant safety.F-er-EAL
#1T Basis-aA lowering of water level below -38 inches (site level) indicates that operatoractions have not been successful in restoring and maintaining RPV water level. Theheat-up rate of the coolant will if, feaserise as the available water inventory is reduced.A continuing deGrease-drop in water level will lead to core uncovery.
Although
: related, EAL #1 is concerned with the loss of RCS inventory and not thepotential concurrent effects on systems needed for decay heat removal (e.g., loss of aResidual Heat Removal suction point). Ae i rise in RCS temperature caused bya loss of decay heat removal capability is evaluated under IC CA53.Fef-EAL #2 Basis,4The inability to monitor RP-V-LeveIRPV water level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation.
If water level cannot be monitored, operators may determine that aninventory loss is occurring by observing changes in sump and/or tank levels. Sumpand/or tank level changes must be evaluated against other potential sources of waterflow to ensure they are indicative of leakage from the RPV.The 15-minute duration for the loss of level indication was chosen because it is half ofthe EAL duration specified in IC CS64-If the RPV iwent.e--water level continues to lower, then escalation to Site AreaEmergency would be via IC CS64.Basis Reference(s):
: 1. NEI 99-01 Rev 6, CA12. Technical Specification Table 3.3.2-23. Technical Specification 3.4.3, Reactor Coolant System Leakage4. ARC-MCR-213-E3 Div 1 Reactor Lo-Lo-Lo Level5. DBD L-S-16, Reactor Instrumentation System (RIS)6. DBD L-S-34, Radwaste System7. T-102 Primary Containment ControlMonth 20XXLGS 3-103EP-AA-1008 (Revision XX)
I:l(Alnn N.nlAArLimericvk vwvneaw-tinn Station Annex Exvavwn NuclearRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CU6- IInitiating 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 Unusual E.ventevent promptly upondetermining that the applicable time 15-*nutes--has been exceeded, or will likelybe exceeded.
: 1. UNPLANNED loss of reactor coolant results in the inability to restore andmaintain RPV water level to above the procedurally established lower limit for> 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 Suppression Pool level rise*" UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.
: 1. UNPLAlNNED 1loS Of reactor coolant reSultS in reactor vessel!ROS level less than ar ed Wer limit for 15 mnuteqs; r longer.i&#xfd;. a. KeaGTor vessovn-z.i level cannot DO monnoreG.-
ANDla UNI-'LA1414M~
inGrease in 6118 WeDCITI SUmo anwor ialK~ levels.113a. 8is:-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.Month 20XXLGS 3-104EP-AA-1008 (Revision XX)
ExAIon NuclearLimeric~k Generatinn Station Annex Exellon Nuclea~rRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS This IC addresses the inability to restore and maintain water level to a requiredminimum level (or the lower limit of a level band), or a loss of the ability to monitor RPVIevIRPV water level concurrent with indications of coolant leakage.
Either of theseconditions is considered to be a potential degradation of the level of safety of the plant.The procedurally established lower limit is not an operational band established abovethe procedural limit to allow for operator action prior to exceeding the procedural limit,but it is the procedurally established lower limit.Refueling evolutions that decrease RCS water inventory are carefully planned andcontrolled.
An UNPLANNED event that results in water level decreasing below aprocedurally required limit warrants the declaration of an Unusual Event due to thereduced water inventory that is available to keep the core covered.EAL #1 BasisfRecognizes that the minimum required RPV-leveIRPV water level can change severaltimes during the course of a refueling outage as different plant configurations andsystem lineups are implemented.
This EAL is met if the minimum level, specified for thecurrent plant conditions, cannot be maintained for 15 minutes or longer. The minimumlevel is typically specified in the applicable operating procedure but may be specified inanother controlling document.
The 15-minute threshold duration allows sufficient time for prompt operator actions torestore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level.EAL #2 BasisaAddresses a condition where all means to determine RI2-Veve!RPV water level havebeen lost. In this condition, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changesmust be evaluated against other potential sources of water flow to ensure they areindicative of leakage from the RPV.Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA6-4 or CA53.Basis Reference(s):
: 1. NEI 99-01, Rev. 6 CU12. Technical Specification Table 3.3.2-23. ST-6-107-596-1 DiywellDrywell Floor Drain Sump/Equipment Drain TankSurveillance
: 4. Technical Specification 3.4.3, Reactor Coolant Leakage5. Technical Specifications 3.9.8, Water Level -Reactor Vessel6. DBD L-S-34, Radwaste System7. OT-101 High gFyweliDrywell Pressure8. T-102 Primary Containment
: Control, Table DW/T-19. GP-6.1 U/1(2) Shutdown Operations
-Refuel Core Alterations
& Core Off-loading Month 20XXLGS 3-105EP-AA-1008 (Revision XX)
NuclearLimeric.
k G. neratinn Stantion *Exmn Nii..Inler RECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS
: 10. DBD L-S-16, Reactor Instrumentation System (RIS)Month 20XXLGS 3-106EP-AA-1008 (Revision XX)
I imarink (.anarnfinn Afnfinn AnnoyFvnlnn NimP.Ionr I imiwir~k
(~nr2tinn
~t~tinn Anng~v Fv~Inn NiIr~In2r RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHG1Initiating 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 orhas 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)I1 .a. A. HU V LL N :+K A" N 16 occurrina or nAM occurrea WRnIn Mne PdW I t6 I LA D1A rc rv,mA~r k.~ +k~ t +t if, I.tu t k ftrl nriullilUlWlrt
*..- I w3pT c c bpwk ki owba %-- -bt b rdV 5/f.ANDb. EITHER of the follow.n.
ha, ocured:.I1. A.NY o-nf t-h e follo(wing sgafety functionrb c-annot be8 conrolldo
" Reactivity control" Coe e~alfing" RCS heat remoeval0442. Damage to SpenRt fuel has occurred or is IMMINENT.
Month 20XXLGS 3-107EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs,
: vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included.
HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE:
A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE:
An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.IMMINENT:
The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.HOSTILE FORCE: Any individuals who are engaged in a determined
: assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.
This IC addresses an event in which a HOSTILE FORCE has taken physical control ofthe facility to the extent that the plant staff can no longer operate equipment necessary to maintain key safety functions.
It also addresses a HOSTILE ACTION leading to aloss of physical control that results in actual or IMMINENT damage to spent fuel due to1) damage to a spent fuel pool cooling system (e.g., pumps, heat exchangers,
: controls, etc.) or, 2) loss of spent fuel pool integrity such that sufficient water level cannot bemaintained.
Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].
Emergenc~y plans and implementing procedures are public documents; thorefore, E=ALesshould not inorporI9Ate S-ecurity soesitive ifraonThic nlue informat4ion thatmay be adI'_ta :ious t a potenti
.uch as the partic.-uar.
tcifll__in throat Or threat Icatien.
Security censitivo infermation should beMonth 20XXLGS 3-108EP-AA-1008 (Revision XX)
I imarirnk rwangarnainn Atatinn AnnoyExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYcontained in non public documents such a466 the Security Plan.Basis Reference(s):
: 1. NEI 99-01, Rev. 6 HGI5. Station Security Plan -Appendix CMonth 20XXLGS 3-109EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS1Initiating Condition:
HOSTILE ACTION within the PROTECTED AREA.Operating Mode Applicability:
1, 2,3, 4, 5, DEmergency Action Level (EAL):A notification from the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the PROTECTED AREA.1. A HOSTILE ACTION is -c-urring Or has ocurr-ed within thc PROTECTED-AREA. as reported by the (site specific.
secr.ity shift supervision).
'Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs,
: vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included.
HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE:
A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE:
An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.HOSTILE FORCE: Any individuals who are engaged in a determined
: assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.
INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI):
A complex that isdesigned and constructed for the interim storage of spent nuclear fuel and otherradioactive materials associated with spent fuel storage.This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTED AREA. This event will require rapid response and assistance due to the possibility fordamage to plant equipment.
Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Month 20XXLGS 3-110EP-AA-1008 (Revision XX) l:xAlon N.clAarLimeric~k Genergating Stsation Annex Exelnon NucleIAar RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYSecurity plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].
As time and conditions allow, these events require a heightened state of readiness bythe plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering).
The Site Area Emergency declaration will mobilize OROresources and have them available to develop and implement public protective actionsin the unlikely event that the attack is successful in impairing multiple safety functions.
This IC does not apply to a HOSTILE ACTION directed at an ISFSI PROTECTED AREA located outside the plant PROTECTED AREA; such an attack should beassessed using IC HA1. It also does not apply to incidents that are accidental events,acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by aHOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters,physical disputes between employees, etc. Reporting of these types of events isadequately addressed by other EALs, or the requirements of 10 CFR &sect; 73.71 or 10 CFR&sect; 50.72.cAEmorgncy plans and implementing procedures are public docauments; therefore, EAI~sshouldd not incorpor~ateA S-ecrmity 6eonsitiye information.
This inclu-des inform=at-ion thatmnay be advantageous to a potetial aadhg.'esary, SUch as the particulars concerning aspecific threat Or threat location.
Security sensitiv:e infor~mation should be-cnandi non public documnents suc-h as the SecUrity Plan.Escalation of the emergency classification level would be via IC HGI.Basis Reference(s):
1I. NEI 99-01 Rev 6, HSi3. Station Security Plan -Appendix CMonth 20XXLGS 3-111EP-AA-1008 (Revision XX)
Limerick Generating Station AnnayNiilaln=r LimArir~k
(~AnArsatinn
~tntinn Anni~w Fv~Inn N.ar~I~~ar RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA1Initiating Condition:
HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threatwithin 30 minutes.Operating Mode Applicability:
1,2,3,4,5, DEmergency Action Level (EAL):1. A validated notification from NRC of an aircraft attack threat < 30 minutes fromthe site.1. A HOST4LE ACTION4 is eouring or- has occurred within the OWNERCONTRLLEDAREAas reported by the (site specific security shift super-vision).
OR2. Notification by the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the OWNER CONTROLED AREA.A v.alidated notificationl from NRC of an aircraft attack threat within 30 minutes etthe steBasis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs,
: vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included.
HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE:
A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE:
An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.OWNER CONTROLLED AREA (OCA): The property associated with the station andowned by the company.
Access is normally limited to persons entering for officialbusiness.
Month 20XXLGS 3-112EP-AA-1008 (Revision XX)
I imprink rvanarnfinn Stntinn AnnoyI=yAInn I imrir~ (~n~r~tnn
~atin Annv Falnn WiIt-lcgr RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYPROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.HOSTILE FORCE: Any individuals who are engaged in a determined
: assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.
This IC addresses the occurrence of a HOSTILE ACTION within the OWNERCONTROLLED AREA or notification of an aircraft attack threat. This event will requirerapid response and assistance due to the possibility of the attack progressing to thePROTECTED AREA, or the need to prepare the plant and staff for a potential aircraftimpact.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].
As time and conditions allow, these events require a heightened state of readiness bythe plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering).
The Alert declaration will also heighten the awareness ofOffsite Response Organizations, allowing them to be better prepared should it benecessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE.Examples include the crash of a small aircraft, shots from hunters, physical disputesbetween employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR &sect; 73.71 or 10 CFR &sect; 50.72.EAL #1 BasisAddresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes.
The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in aheightened state of readiness.
This EAL is met when the threat-related information hasbeen validated in accordance with SE-23, Security Threat.EAL #2 Basis--is-aApplicable for any HOSTILE ACTION occurring, or that has occurred, in theOWNER CONTROLLED AREA. This includes any action directed against an ISFSI thatis located outside the plant PROTECTED AREA.Month 20XXLGS 3-113EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYEA.L #2 add_..s....
tho the imp.ct of an ai-rcaft on the plant, and theanticipated arri'..a!
time is within -30_ minutes.
The intent of this EA'_ is to enSUre thatthreant reaed noific-ationAs
-are ma-d-e i~n -a timely manner son that plant personnel andOROL; arc in a heightened state oif readiness.
T~his EA Is met when the threat reatedinformation ha been valid-ated in accordance with (site specific procedure).
The NRC Headquarters Operations Officer (HOO) will communicate to the licensee ifthe threat involves an aircraft.
The status and size of the plane may be provided byNORAD through the NRC.In some cases, it may not be readily apparent if an aircraft impact within the OWNERCONTROLLED AREA was intentional (i.e., a HOSTILE ACTION).
It is expected, although not certain, that notification by an appropriate Federal agency to the site wouldclarify this point. In this case, the appropriate federal agency is intended to be NORAD,FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.I_ I! _ J ....... *-- *LZ- --- fiA I -hmnrnnn~'!
nrnnn inn imninmenrino nrocnaure~
are nunuc nocumnnrn:
inereroro.
tJ~Lc ............................
~--should I Security senitie IThis il in othatm:aV be wdatgos to a Detential advcesar:.
such aS the Darticulars conernn a--vfha ok~'~ r thrpmt Inntn Rianud, ,Rjh, ti inf,~rvvatfo em ik' he rnentainM n* 5L U*5b SdS5--------
-----9-Escalation of the emergency classification level would be via IC HS1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, HA12. Station Security Plan -Appendix C3. SE-23 Security ThreatMonth 20XXLGS 3-114EP-AA-1008 (Revision XX)
LimArit~k fl~nari~tinn
~tsatinn AnnaxLimerick Generatinn Station Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU1Initiating Condition:
Confirmed SECURITY CONDITION or threat.Operating Mode Applicability:
1, 2,3,4,5, DEmergency Action Level (EAL):1. Notification of a credible security threat directed at the site as determined perSY-AA-1 01-132, Security Assessment and Response to Unusual Activities.
: 1. A SECURITY CONDITION that does not inolve a HO1STILE ACTION&#xfd;T as r.eported bythe (site specific security shift supe...ision).
OR2. A validated notification from the NRC providing information of an aircraft threat.2. Notification of a cr-edible security threat dir-eeted at the site.OR3. Notification by the Security Force of a SECURITY CONDITION that does notinvolve a HOSTILE ACTION.3 A notification from the NRIC inform;ation of an a-r..aft threat.-.
Basis:SECURITY CONDITION:
Any Security Event as listed in the approved securitycontingency plan that constitutes a threat/compromise to site security, threat/risk to sitepersonnel, or a potential degradation to the level of safety of the plant. A SECURITYCONDITION does not involve a HOSTILE ACTIONSAFETY 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.
HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs,
: vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included.
HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE:
A person(s) held as leverage against the station to ensure that demandswill be met by the station.Month 20XXLGS 3-115EP-AA-1008 (Revision XX)
Simeric~k Generatinn Station Annex Exelon NuclIearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYPROJECTILE:
An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEMequipment, and thus represent a potential degradation in the level of plant safety.Security events which do not meet one of these EALs are adequately addressed by therequirements of 10 CFR &sect; 73.71 or 10 CFR &sect; 50.72. Security events assessed asHOSTILE ACTIONS are classifiable under ICs HA1, HS1 and HG1.Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Classification of these events will initiate appropriate threat-related notifications to plantpersonnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].
EAL #1 BasisAddresses the receipt of a credible security threat. The credibility of the threat isassessed in accordance with SY-AA-101-132.
roforoncos .pecific socu.ity shiftOR) bocauso these are the individuals trainedto c fhat a securiy eventioccuFrring or has ...urrod. oecuity event confirmation and c.ntroilled-due to the nat-ure Of nd 10 FR &sect; 2.39 "nfmatien.
EAL #2 BasisaAddresses the threat from the impact of an aircraft on the plant. The NRCHeadquarters Operations Officer (HOO) will communicate to the licensee if the threatinvolves an aircraft.
The status and size of the plane may also be provided by NORADthrough the NRC. Validation of the threat is performed in accordance with SE-23,Security Threat (site specifc p.O.edure).
add .esses the .e..,pt of a credible securitythreat. The credibility of the threat is assessed in accordance with (site specificpr49reduwe)-
EAL #3 BasisfReferences Security Force(site specific security shift .upeision)
-because these arethe individuals trained to confirm that a security event is occurring or has occurred.
Training on security event confirmation and classification is controlled due to the natureof Safeguards and 10 CFR &sect; 2.39 information.addresses the threat from the impact ofan aircraft on the plant. The NRC Headquarters Operations Officer (HOO) willcommunicate to the licensee if the threat involves an aircraft.
The status and size of theplane may also be provided by NORAD through the NRC. Validation of the threat isperformed in accordance with (site-specific procedure).
Month 20XXLGS 3-116EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYEm~ergency P18Ac and implementing procodure aro public dOcum~ents; thoreforo, EJ\Lch nt Securlity Ion iti'.Ie information.
Thi, iIcludic i nhis rm ion thitm-ay be advantageous to a pe ntial+adea+,',
uh as the paticular6' concerig.
,epeci thea or.throat location.
Security cencritiov informnation-
-hould be cOntai f ha rtrna ;ned innon public, dUcmentl 1Uch a. the 8GuriF-.,
Plan.Escalation of the emergency classification level would be via IC HA1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, HU12. Station Security Plan -Appendix C3. SY-AA-1 01-132, Security Assessment and Response to Unusual Activities Month 20XXLGS 3-117EP-AA-1008 (Revision XX)
Fvtalnn Nau-InarLimerick GAn.r.tinn St1ation Annex ..alnn 111.11RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS26Initiating Condition:
Inability to control a key safety function from outside the Control Room.Operating Mode Applicability:
1, 2, 3, 4, 5, DEmergency Action Level (EAL):Note: The Emergency Director should declare the Site Arpa Eme..e.G--yvent promptlyupon determining that (site spoGific number of the applicable time Mifutes)
-hasbeen exceeded, or will likely be exceeded.
: 1. A Control Room evacuation has resulted in plant control being transferred from theControl Room to alternate locations per:" SE-1, Remote ShutdownOR" SE-6, Alternate Remote ShutdownAND2. Control of ANY Table H1 key safety function is not reestablished in < 15 minutes.Table HI Safety Functions
* Reactivity Control (ability to shut down the reactor and keep it shutdown)
* RPV Water Level (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)I. a. An ovent has roculted in plant conrol1 being tranefeFred panels, and locna!contro stations).
from the Control Room to (site epecific remote shutdowANDb. Control oif ANY of tho following key safet functiens is not reectablished within (cite re~oific number of minutes).-
9 ReactiVity control* ..^&^.
r&#xa3;)lAIl::)l I heat I8 IV JI Vww l i v "JMonth 20XXLGS 3-118EP-AA-1008 (Revision XX)
I=xAIon Limeric~k Generatinn Sta~tion Annex Exeoln Nuclekiar RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYBasis:The time period to establish control of the plant starts when either:a. Control of the plant is no longer maintained in the Main Control RoomORb. The last Operator has left the Main Control Room.This IC addresses an evacuation of the Control Room that results in transfer of plantcontrol to alternate locations, and the control of a key safety function cannot bereestablished in a timely manner. The failure to gain control of a key safety functionfollowing a transfer of plan control to alternate locations is a precursor to a challenge toone or moroany-fission product barriers within a relatively short period of time.The determination of whether or not "control" is established at the remote safeshutdown location(s) is based on Emergency Director judgment.
The Emergency Director is expected to make a reasonable, informed judgment within (the site-. .pe..ftimefGF ef) 15 minutes whether or not the operating staff has control of key safetyfunctions from the remote safe shutdown location(s).
Escalation of the emergency classification level would be via IC FG1 or CG6--.Basis Reference(s):
: 1. NEI 99-01, Rev 6 HS62. SE-1, Remote Shutdown3. SE-6, Alternate Remote ShutdownMonth 20XXLGS 3-119EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA26Initiating Condition:
Control Room evacuation resulting in transfer of plant control to alternate locations.
Operating Mode Applicability:
1, 2, 3,4,5, DEmergency Action Level (EAL):A Control room evacuation has resulted in plant control being transferred from theControl Room to alternate locations per:" SE-1, Remote ShutdownOR" SE-6, Alternate Remote ShutdownAn event has roculted in plant cOntro beinig traneferrod fromA the Conrol1 Room to (SiteremOteA ohtW, pane'ls and lecal control Basis:This IC addresses an evacuation of the Control Room that results in transfer of plantcontrol to alternate locations outside the Control Room. The loss of the ability to controlthe plant from the Control Room is considered to be a potential substantial degradation in the level of plant safety.Following a Control Room evacuation, control of the plant will be transferred to alternate shutdown locations.
The necessity to control a plant shutdown from outside the ControlRoom, in addition to responding to the event that required the evacuation of the ControlRoom, will present challenges to plant operators and other on-shift personnel.
Activation of the ERO and emergency response facilities will assist in responding tothese challenges.
Escalation of the emergency classification level would be via IC HS26.Basis Reference(s):
: 1. NEI 99-01, Rev 6 HA62. SE-1, Remote Shutdown3. SE-6, Alternate Remote ShutdownMonth 20XXLGS 3-120EP-AA-1008 (Revision XX)
I imariek rtanarnfinn Afnfinn AnnoyFvalnn NiemlanrI img~rir~k
(~n~r~a*inn
~t2tinn Annoy Fwalnn .ir~Io~rRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU34Initiating Condition:
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 Unusual Eenttvent promptlyupon determining that the applicable time has been exceeded, or will likelybe exceeded.
: 1. A FIRE in ANY Table H2 area is not extinguished in < 15-minutes of ANY of thefollowing FIRE detection indications:
S00Report from the field (i.e., visual observation)
Receipt of multiple (more than 1) fire alarms or indications Field verification of a single fire alarmTable H2 Vital Areas" Reactor Enclosure (when inerted the Drywell is exempt)" Control Enclosure
" Diesel Generator Enclosure
" Spray Pond Pump House / Spray NetworkORa. Receipt of a single fire alarm in ANY Table H2 area (i.e., no other indications of a FIRE).ANDb. The existence of a FIRE is not verified in < 30 minutes of alarm receipt.OR2.3 A FIRE within the plant PROTECTED AREA not extinguished in < 60-minutes ofthe initial report, alarm or indication.
Month 20XXLGS 3-121EP-AA-1008 (Revision XX)
I imprirk rj&nPrafingqfskfinnAnnPX Fvplnn Nw-Ia~rI,,,,v,,v.k
( ..v, .=.=-il .v,=in --RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYOR4 A FIRE within the plant PROTECTED AREA that requires firefighting support byan offsite fire response agency to extinguish.
(4\ -- A i~rll"Jlr"
: kl/rV"lr
--,,,I.:--
-,,: J , L,:.. 4 C .. _ --4 .A I.I 4L I ,-IIHI J a. A~ r-Im is 1401 extneuised T nl MU~AL n.LIII IUr QIIIUU ANY etJ th UI IIU:ui1R~i FIRE detection idctos0 0 %r+,ss f-.rv. tha f.iald (o ~ae .-otua nintnvP, ..1Z&#xfd;W lafnwT&#xfd;Jwa W&#xfd; ax&#xfd; a-!jwA* ~~.IJL
* It I~uUt5~.~*
~I 5 .. -LI SLAIN 5/ .5. SL.I I SII IV0 riiiu YeFIRIIUUiU[1 of a sina.jle TIL; UIUI iANDLo. -tH 1=1 ft'. ;L. Iu0..tuu~t W~.;H;;I fl-f; t~ t; tL110WH.
V**~ CttFDPIPO
~S(site specific liSt Of plant rooms or areas)--Z -- &#xfd;z a ReCOmyT ef a sinaio rire aiarmT ii.e.. SO efnRe indicatiw%
of a Fu-1i ---- -- --- --AIND-1W Vig I f I IJ gIcsite soeGII:H list OT roo mOr aleas4A kll'll.AND-c. The existene- of a FIRE is not within 30 meinutes of alalrm receipt.(3) A FIRE within the plant or ISE=Si [for- Plants with aon IfWSI o-utside the plnDr,-'jpp4=a 1212C)= .. PikprI oiAhiv Arl mnt itp QfthinWfiial renort alarmA Or inldigatiOn I-., -9IAN A W~itflifl e niant or IN-I-N! =Fn WaRn?5 mlm Anf !IIk-NI PFl!T~tpyd me flwflfl\'/5P...te.tedAr.ea.
PR O TED AR.EA that requires fir.fi.htinaMCI r"suoort by an___ --L." .... :__ Lon-Uita Trem Fesoons aaoncGV r exunaIRR
---------
,-Basis:FIRE: Combustion characterized by heat and light. Sources of smoke such as slippingdrive belts or overheated electrical equipment do not constitute FIRES. Observation ofMonth 20XXLGS 3-122EP-AA-1008 (Revision XX)
Limeric~k Genersatinn Station Annex Exelon N~uelanrRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYflame is preferred but is NOT required if large quantities of smoke and heat areobserved.
PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.This IC addresses the magnitude and extent of FIRES that may be indicative of apotential degradation of the level of safety of the plant.EAL #1 BasisThe intent of the 15-minute duration is to size the FIRE and to discriminate againstsmall FIRES that are readily extinguished (e.g., smoldering waste paper basket).
Inaddition to alarms, other indications of a FIRE could be a drop in fire main pressure, automatic activation of a suppression system, etc.Upon receipt, operators will take prompt actions to confirm the validity of an initial firealarm, indication, or report. For EAL assessment
: purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and notthe time that a subsequent verification action was performed.
Similarly, the fire durationclock also starts at the time of receipt of the initial alarms, indication or report.EAL #2 BasisThis EAL addresses receipt of a single fire alarm, and the existence of a FIRE is notverified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt,operators will take prompt actions to confirm the validity of a single fire alarm. For EALassessment
: purposes, the 30-minute clock starts at the time that the initial alarm wasreceived, and not the time that a subsequent verification action was performed.
A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional timeis allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, andabsent information to the contrary, it is assumed that an actual FIRE is in progress.
If an actual FIRE is verified by a report from the field, then EAL #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within15-minutes of the report. If the alarm is verified to be due to an equipment failure or aspurious activation, and this verification occurs within 30-minutes of the receipt of thealarm, then this EAL is not applicable and no emergency declaration is warranted.
EAL #3 BasisIn addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plantPROTECTED AREA not extinguished within 60-minutes may also potentially degradethe level of plant safety. This extonds to a FIRE= ..cur. g ihin theMonth 20XXLGS 3-123EP-AA-1008 (Revision XX) l::yAInn Limeric~k flenerainn Stsation Annex Ex.eInn NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYPRTEC TED A RE A of arn IS I,-loated
-outsd -ahMe plant PROTE/"CTED A REA4.[Sentence for plants with an ISFS-RI ounsid-a the plant Pm0tectdAmea]
EAL #4 BasisIf a FIRE within the plant or iSFSI [fo 1plant6 with an ISESI oL'.s.de the plant&#xf7;P..ec.e Areal-PROTECTED AREA is of sufficient size to require a response by an offsitefirefighting agency (e.g., a local town Fire Department),
then the level of plant safety ispotentially degraded.
The dispatch of an offsite firefighting agency to the site requiresan emergency declaration only if it is needed to actively support firefighting effortsbecause the fire is beyond the capability of the Fire Brigade to extinguish.
Declaration is not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.Basis-Related Requirements from Appendix RAppendix R to 10 CFR 50, states in part:Criterion 3 of Appendix A to this part specifies that "Structures,
: systems, andcomponents important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires andexplosions."
When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safetybecause damage to them can lead to core damage resulting from loss of coolantthrough boil-off.
Because fire may affect safe shutdown systems and because the loss of functionof systems used to mitigate the consequences of design basis accidents underpost-fire conditions does not per se impact public safety, the need to limit firedamage to systems required to achieve and maintain safe shutdown conditions isgreater than the need to limit fire damage to those systems required to mitigatethe consequences of design basis accidents.
In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train (G.2.c).
As used in EAL #2, the 30-minutes to verify asingle alarm is well within this worst-case 1-hour time period.Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA26 or MSA50.Basis Reference(s):
: 1. NEI 99-01, Rev 6 HU42. Specification NE-0294, "Fire Safe Shutdown Analysis Specification" Month 20XXLISS 3-124EP-AA-1008 (Revision XX)
I imarie-k rZonaratin Afnfinn AnnowFxAlnn I imkriie (~n~rninn
*~tin An~v xelon Nucler~iRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU42Initiating Condition:
Seismic event greater than OBE levels.Operating Mode Applicability:
1, 2,3,4, 5, DEmergency Action Level (EAL):Seismic event > Operating Basis Earthquake (OBE) as indicated by:" ARC-MCR-00C693, WINDOW B1, OBE EXCEEDED alarmedOR* OBE red light is lit at panel 00C693SemicFi event greater than Operating Basis Earthquakc (0BE) as indicatedby
: a. (site specific indication that a eei vent met or eXceeded OBEF limits)Basis:This IC addresses a seismic event that results in accelerations at the plant site greaterthan those specified for an Operating Basis Earthquake (OBE)'. An earthquake greaterthan an OBE but less than a Safe Shutdown Earthquake (SSE)2 should have nosignificant impact on safety-related
: systems, structures and components; however,some time may be required for the plant staff to ascertain the actual post-event condition of the plant (e.g., performs walk-downs and post-event inspections).
Giventhe time necessary to perform walk-downs and inspections, and fully understand anyimpacts, this event represents a potential degradation of the level of safety of the plant.Event verification with external sources should not be necessary during or following anOBE. Earthquakes of this magnitude should be readily felt by on-site personnel andrecognized as a seismic event (e.g., typical lateral accelerations are in excess of 0.08g).The Shift Manager or Emergency Director may seek external verification if deemedappropriate (e.g., a call to the USGS, check internet news sources, etc.); however, theverification action must not preclude a timely emergency declaration.
Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA26 or MA5.An OBE is vibratory ground motion for which those features of a nuclear power plantnecessary for continued operation without undue risk to the health and safety of the?ublic will remain functional.
An SSE is vibratory ground motion for which certain (generally, safety-related) structures,
: systems, and components must be designed to remain functional.
MoSEi irtoygon ointhforXLG 3h125 cran(eerally, 008et (revisineX)
Month 20XXLGS 3-125EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYS"g.Basis Reference(s):
: 1. NEI 99-01, Rev 6 HU22. SE-5, Earthquake
: 3. ARC-MCR-00C693 B1, OBE ExceededMonth 20XXLGS 3-126EP-AA-1008 (Revision XX)
I imarink (tanarnfinn Afnfinn AnnoyI:=Yalnn Ni~rlan=r RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA5Initiating Condition:
Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.
Operating Mode Applicability:
1, 2, 3,4,5, DEmergency Action Level (EAL):Note: If the equipment in the listed room or area was already inoperable, or out ofservice, before the event occurred, then no emergency classification iswarranted.
: 1. Release of a toxic, corrosive, asphyxiant or flammable gas in a Table H3 area.Table H3Areas with Entry Related Mode Applicability Area Entry Related ModeApplicability Reactor Enclosure Modes 3, 4, and 5AND2. Entry into the room or area is prohibited or impededNo-te: If the equipment in the li-teAd-room Or area wars already inoperable or outof veer-ie before the eent occurred, then no emnergency classification iswa~ante4d-(1) a. Release of a toxiccroie asphyxiant Or flammable gas into any of thefollowing plant roome or areae:&#xfd;~.!LL. ~J.... -IA.J ~...J.~F'~'iT ~1'T"'iI'f-
" I~W 'I~f FW'~' FV-~1 ~ W, -~ffI11appliailt ietiid--ANQh. Entry into the room or area is. Drahibitod or imoodoBasis:This IC addresses an event involving a release of a hazardous gas that precludes orimpedes access to equipment necessary to transition the plant from normal plantoperation to cooldown and shutdown as specified in normal plant procedures.
Maintainnormal plant operation, Or ..quir. d for a norm.al plant coodown and shutdown.
ThisMonth 20XXLGS 3-127EP-AA- 1008 (Revision XX)
Limarick r-anarating Agginn AnnoyFvalnn NnMar~l:I imnrir~k
(~An~rsatinn
~t~tinn Ann~v Fwailnn Miur~h'~zar RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYcondition represents an actual or potential substantial degradation of the level of safetyof the plant.Table H3 is a list of plant rooms or areas with entry-related mode applicability thatcontain equipment which require a manual/local action necessary to transition the plantfrom normal 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 or record keeping nature (e.g., normal rounds or routine inspections).
This Table does not include the Control Room since adequate engineered safety/design features are in place to preclude a Control Room evacuation due to the release of ahazardous gas.An Alert declaration is warranted if entry into the affected room/area is, or may be,procedurally required during the plant operating mode in effect and the gaseous releasepreclude the ability to place shutdown cooling in serviceat the time of the gaseousrelease.
The emergency classification is not contingent upon whether entry is actuallynecessary at the time of the release.Evaluation of the IC and EAL do not require atmospheric sampling; it only requires theEmergency Director's judgment that the gas concentration in the affected room/area issufficient to preclude or significantly impede procedurally required access. Thisjudgment may be based on a variety of factors including an existing job hazard analysis, report of ill effects on personnel, advice from a subject matter expert or operating experience with the same or similar hazards.
Access should be considered as impededif extraordinary measures are necessary to facilitate entry of personnel into the affectedroom/area (e.g., requiring use of protective equipment, such as SCBAs, that is notroutinely employed).
An emergency declaration is not warranted if any of the following conditions apply." The plant is in an operating mode different than the mode specified for the affectedroom/area (i.e., entry is not required during the operating mode in effect at the timeof the gaseous release).
For example, the plant is in Mode 1 when the gaseousrelease occurs, and the procedures used for normal operation, cooldown andshutdown do not require entry into the affected room until Mode 4." The gas release is a planned activity that includes compensatory measures whichaddress the temporary inaccessibility of a room or area (e.g., fire suppression system testing).
" The action for which room/area entry is required is of an administrative or 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.Month 20XXLGS 3-128EP-AA-1008 (Revision XX)
I imarid-k ranarafinn Atnfinn AnnoyNuclearI imrii~ (~n~r2inn t~tnn An~vExelnn Nuclea~rRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYAn asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosedenvironment.
This reduces the concentration of oxygen below the normal level ofaround 19%, which can lead to breathing difficulties, unconsciousness or even death.This EAL does not apply to firefighting activities that generate smoke, that automatically or manually activate a fire suppression system in an area, or to intentional inerting ofcontainment.
Escalation of the emergency classification level would be via Recognition Category RA,C or F ICs.Basis Reference(s):
: 1. NEI 99-01, Rev 6HA5Month 20XXLGS 3-129EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU63Initiating 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 an offsiteevent involving hazardous materials (e.g., an offsite chemical spill or toxic gasrelease).
OR4. A hazardous event that results in on-site conditions sufficient to prohibit the plantstaff from accessing the site via personal vehicles.
ORNot&: EAI 93 does no9t apply to- roautinge traffic impediments Asuc-h as fog, snow, ice, orvehicle beakdW OF... or aidentG-.
(1) A tornado WI;thin t he PROTECTED AREA.(2) Internal room or aarea flooeding of a magnitude suffic-ient to reqir manal orautomatic ectIca irsolation of a SAFETY&#xfd; SYSTE:M copoen needed for the,current operafing m vde.(3) Movement of personnel wvithin the PROTIEC-TED AREA. isipdddue to anv ffsite evenIt involving hazardous m Vaterial (o.g., an oflite chemlical Spoil Or toxicla Fellease*7V Month 20XXLGS 3-130EP-AA-1008 (Revision XX)
I imprink rtanpmfinn Afnfinn AnnoyIFvalnn MN~arlrI imarir~k
(~c&n~r~a*inn
~t~atinn Ann~v Fv~Inn N.it~Ig~ar RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY(4) A hazardou, evont that results in on site conditions 6uf49cion to prohibit the plant.staff from. _accessing tho site v.ia personal41 yehocles(5) (Site specific list o-f naturaal Or tecGhnological hazard events)Basis:PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.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 hazardous events that are considered to represent a potential degradation of the level of safety of the plant.EAL #1 BasisaAddresses a tornado striking (touching down) within the Protected Area.EAL #2 BasisaAddresses flooding of a building room or area that results in operators isolating powerto a SAFETY SYSTEM component due to water level or other wetting concerns.
Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker orrelay trip). To warrant classification, operability of the affected component must berequired by Technical Specifications for the current operating mode. Manual isolation ofpower to a SAFETY SYSTEM component as a result of leakage is an event of lesserimpact and would be expected to cause small and localized damage. The consequence of this type of event is adequately assessed and addressed in accordance withTechnical Specifications.
EAL #3 BasisaAddresses a hazardous materials event originating at an offsite location and ofsufficient magnitude to impede the movement of personnel within the PROTECTED AREA.EAL #4 BasisaAddresses a hazardous event that causes an on-site impediment to vehicle movementand significant enough to prohibit the plant staff from accessing the site using personalvehicles.
Examples of such an event include site flooding caused by a hurricane, heavyrains, up-river water releases, dam failure, etc., or an on-site train derailment blockingthe access road.This EAL is not intended to apply to routine impediments such as fog, snow, ice, orvehicle breakdowns or accidents, but rather to more significant conditions such as theMonth 20XXLGS 3-131EP-AA-1008 (Revision XX)
I imri- 9' Znarnfinn
-Q*ninn AnnoyI::Yalnn URECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHurricane Andrew strike on Turkey Point in 1992, the flooding around the CooperStation during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in2011.'Al 95 addressoe (sito Escalation of the emergency classification level would be based on ICs in Recognition Categories RA, F, M9, H or C.Basis Reference~s):
: 1. NEI 99-01, Rev 6 HU32. UFSAR Section 3.4.1, Flood Protection
: 3. UFSAR Section 6.2.1.1.1, Design Bases4. SE-5 Earthquake 5 SE-4 Flood6. SE-9 Preparation for Severe WeatherMonth 20XXLGS 3-132EP-AA-1008 (Revision XX)
Exelon NuclearLimerick floneratinn Station Annex Exelnn NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHG7Initiating Condition:
Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a GENERAL EMERGENCY.
Operating Mode Applicability:
1, 2, 3, 4, 5, DEmergency Action Level (EAL):(41) Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which involve actual or IMMINENTsubstantial core degradation or melting with potential for loss of containment integrity orHOSTILE ACTION that results in an actual loss of physical control of the facility.
Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.Basis:IMMINENT:
The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs,
: vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included.
HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE:
A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE:
An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for aGeneral Emergency.
Basis Reference(s):
: 1. NEI 99-01, Rev 6 HG7Month 20XXLGS 3-133EP-AA-1008 (Revision XX)
I imprink rpnprntinn Afatinn AnnoyIFyalnn NMin-Ionr RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS7Initiating Condition:
Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a SITE AREA EMERGENCY.
Operating Mode Applicability:
1, 2, 3, 4, 5, DEmergency Action Level (EAL):(-14 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 failuresof plant functions needed for protection of the public or HOSTILE ACTION that results inintentional damage or malicious acts, (1) toward site personnel or equipment that couldlead to the likely failure of or, (2) that prevent effective access to equipment needed forthe protection of the public. Any releases are not expected to result in exposure levelswhich exceed EPA Protective Action Guideline exposure levels beyond the siteboundary.
Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs,
: vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included.
HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE:
A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE:
An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for a SiteArea Emergency.
Basis Reference(s):
: 1. NEI 99-01, Rev 6 HS7Month 20XXLGS 3-134EP-AA-1008 (Revision XX)
I imariek rZonarnfin Atatinn AnnovFyalnn Niiela2rI im~riuk (~n~r~*inn
~*~*inn Annoy Fvolnn MEII,102r RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA7Initiating Condition:
Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an ALERT Operating Mode Applicability:
1, 2,3,4,5, DEmergency Action Level (EAL):(-1-) 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 substantial degradation of the level of safety of the plant or a security event thatinvolves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to smallfractions of the EPA Protective Action Guideline exposure levels.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs,
: vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included.
HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE:
A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE:
An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for anAlert.Basis Reference(s):
: 1. NEI 99-01, Rev 6 HA7Month 20XXLGS 3-135EP-AA-1008 (Revision XX)
I=xAInn Limenrick tGAnerztinn Station Annex Exelnn Nucler~IRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU7Initiating Condition:
Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an (NOU-UNUSUAL EVENT.Operating Mode Applicability:
1, 2, 3, 4, 5, DEmergency Action Level (EAL):(1-) Other conditions exist which in the judgment of the Emergency Director indicatethat events are in progress or have occurred which indicate a potential degradation ofthe level of safety of the plant or indicate a security threat to facility protection has beeninitiated.
No releases of radioactive material requiring offsite response or monitoring areexpected unless further degradation of safety systems occurs.Basis:This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for anNQUE-UNUSUAL EVENT.Basis Reference(s):
: 1. NEI 99-01, Rev 6 HU7Month 20XXLGS 3-136EP-AA-1008 (Revision XX)
I im~rit* (~An~ratinn
~t*tinn AnnAYI::Yalnn Nind-la==r Limerick Goneratinn Station AnnexRECOGNITION CATEGORYISFSI MALFUNCTIONS E-HU1Initiating Condition Damage to a loaded cask CONFINEMENT BOUNDARY.
Operating Mode Applicability:
1, 2,3,4,5, DEmergency Action Level (EAL):Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by a radiation reading:* > 1400 mremlhr on the HSM or HSM-H front surface (applicable to type 161BTH DSC only)OR* > 800 mremlhr at 3 ft from the HSM surface (applicable to 61BT DSC only)OR* > 200 mremlhr on the HSM or HSM-H door centerline OR* > 40 mrem/hr on the end shield wall exterior(1-.
to a loaded ca.k CONFINEMENT BOUNDARY a6 indicated by an oncontact radiation reading greater than (2 times the site specific.
cask epecific technical Basis:CONFINEMENT BOUNDARY:
The irradiated fuel dry storage cask barrier(s) betweenareas containing radioactive substances and the environment.
INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) : A complex that isdesigned and constructed for the interim storage of spent nuclear fuel and otherradioactive materials associated with spent fuel storage.This IC addresses an event that results in damage to the CONFINEMENT BOUNDARYof a storage cask containing spent fuel. It applies to irradiated fuel that is licensed fordry storage beginning at the point that the loaded storage cask is sealed. The wordcask, as used in this EAL, refers to the storage container in use at the site for drystorage of irradiated fuel. The issues of concern are the creation of a potential or actualrelease path to the environment, degradation of one Or moreany fuel assemblies due toenvironmental
: factors, and configuration changes which could cause challenges inremoving the cask or fuel from storage.Month 20XXLGS 3-134EP-AA-1008 (Revision XX)
I imariwi-(' Znarnfinn
_Qffirn AnnavIPvalnn khu-lanrRECOGNITION CATEGORYISFSI MALFUNCTIONS The existence of "damage" is determined by radiological survey. The technical specification multiple of "2 times", which is also used in Recognition Category RA ICRAU, is used here to distinguish between non-emergency and emergency conditions.
The emphasis for this classification is the degradation in the level of safety of the spentfuel cask and not the magnitude of the associated dose or dose rate. It is recognized that in the case of extreme damage to a loaded cask, the fact that the "on-contact" doserate limit is exceeded may be determined based on measurement of a dose rate atsome distance from the cask.Security-related events for ISFSIs are covered under ICs HU1 and HA1.Basis Reference(s):
: 1. NEI 99-01, Rev 6 E-HU12. Limerick Generating Station ISFSI 1OCFR72.212 Evaluation Rev 6 Attachment  
: 13. OU-LG-643, Transport of Loaded Transfer Cask and 61 BT dry shielded Canisterto Transfer
: Trailer, to ISFSI, and Alignment/Insertion into Horizontal Storage Module"Month 20XXLGS 3-135EP-AA-1008 (Revision XX)
I imckrie-k rZangarnfin 4Z*n*ien AnnoyI:=Y--Inn khtt-lanr I imcrie4 (~ancr~*inn
~*~tie~n Ann~v Fv~iInn Muui-Io~r Table LGS 3-2: LGS EAL Technical Basis Action Level Technical Basis Page IndexGeneral Site Area Alert Unusual EventEAL Pg. EAL Pg. EAL Pg. EAL Pg.RG1 3-33 RS1 3-35 RA1 3-37 RU1 3-40_ RA2 3-43 RU2 3-45_ _RA3 3-47 RU3 3-50FG1 3-51 FS1 3-52 FA1 3-53 1 1Fuel Clad RCS Containment FC1 3-54FC2 3-55 RC2 3-59 CT2 3-66RC3 3-61 CT3 3-67RC4 3-62FC5 3-57 RC5 3-64 CT5 3-69CT6 3-70FC7 3-58 RC7 3-65 CT7 3-73MG1 3-74 MS1 3-76 MA1 3-78 MUW 3-80MG2 3-81 MS2 3-83MS3 3-84 MA3 3-86 MU3 3-88MA4 3-91 MU4 3-94MA5 3-96MU6 3-99MU7 3-101CA1 3-103 CU1 3-105CA2 3-107CU3 3-109CU4 3-111CA5 3-113 CU5 3-115CG6 3-117 CS6 3-121 CA6 3-124 CU6 3-126HG1 3-129 HS1 3-131 HA1 3-133 HU1 3-136HS2 3-138 HA2 3-140HU3 3-141HU4 3-145HA5 3-146HU6 3-148HG7 3-150 HS7 3-151 HA7 3-152 HU7 3-153I I I E-HU1 3-154Month 20XXLGS 3-32EP-AA-1008 (Revision XX)
Limerick Generatincl Station AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RG1Initiating Condition:
Release of gaseous radioactivity resulting in offsite dose greater than 1000 mRem TEDEor 5000 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 theapplicable time has been exceeded, or will likely be exceeded.
" If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to theenvironment is established.
If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes.
" The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment usingactual meteorology are available.
: 1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15 minutes.OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 1000 mRem TEDEORb. > 5000 mRem CDE ThyroidOR3. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates >1000 mR/hr are expected to continuefor > 60 minutes.ORb. Analyses of field survey samples indicate
> 5000 mRem CDE Thyroid for60 minutes of inhalation.
Month 20XXLGS 3-33EP-AA-1008 (Revision XX)
 
rLimeric~k (GAneratinn Station Annex FwaeInn NuleIzarRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RG1 (cont)Emergency Action Level (EAL) (cont):Table R1 Effluent Monitor Thresholds Release Path General Emergency North Stack (WR Monitor:
RIX-26-076-4) 1.92 E+08 uCi/secSouth Stack (Unit 1: RY26-185A-3
/ 2.71 E-01 uCi/secRY26-185-B-3 or Unit 2: RY26-285A-3
/RY26-285-B-3)
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 mRem while the 5000 mRem thyroid CDEwas established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroidCDE.Basis Reference(s):
: 1. NEI 99-01 Rev 6, AGI2. LGS ODCM3. EP-EAL-0608 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Limerick Generating Station4. DBD L-S-43, Radiation Monitoring SystemMonth 20XXLGS 3-34EP-AA-1008 (Revision XX)
 
Simeric~k Gecnea~rtincn Station Annex~ ExvInn NucleI~ar RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RS1Initiating Condition:
Release of gaseous radioactivity resulting in offsite dose greater than 100 mRem TEDEor 500 mRem thyroid CDE.Operating Mode Applicability:
1, 2,3,4,5, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the event promptly upon determining that theapplicable time has been exceeded, or will likely be exceeded.
" If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release path to theenvironment is established.
If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes.
" The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment usingactual meteorology are available.
: 1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for > 15 minutes.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 for60 minutes of inhalation.
Month 20XXLGS 3-35EP-AA-1008 (Revision XX)
Limerick Generatinq Station AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RS1 (cont)Emergency Action Level (EAL) (cont):Table R1 Effluent Monitor Thresholds Release Path Site Area Emergency North Stack (WR Monitor:
RIX-26-076-4) 1.92 E+07 uCi/secSouth Stack (Unit 1: RY26-185A-3
/ 2.71 E-02 uCi/secRY26-185-B-3 or Unit 2: RY26-285A-3
/RY26-285-B-3)
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 mRem while the 500 mRemthyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDEand thyroid CDE.Escalation of the emergency classification level would be via IC RG1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, AS12. LGS ODCM3. EP-EAL-0608 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Limerick Generating Station4. DBD L-S-43, Radiation Monitoring SystemMonth 20XXLGS 3-36EP-AA-1008 (Revision XX)
Limerick Generatinci Station AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS RA1Initiating Condition:
Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mRemTEDE 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 theapplicable time has been exceeded, or will likely be exceeded.
* If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 15 minutes.* Classification based on effluent monitor readings assumes that a release path to theenvironment is established.
If the effluent flow past an effluent monitor is known tohave stopped due to actions to isolate the release path, then the effluent monitorreading is no longer valid for classification purposes.
" The pre-calculated effluent monitor values presented in EAL #1 should be used foremergency classification assessments until the results from a dose assessment usingactual meteorology are available.
: 1. Readings on ANY Table R1 Effluent Monitor > Table RI value for > 15 minutes.OR2. Dose assessment using actual meteorology indicates doses at or beyond the siteboundary of EITHER:a. > 10 mRem TEDEORb. > 50 mRem CDE ThyroidOR3. Analysis of a liquid effluent sample indicates a concentration or release rate thatwould result in doses greater than EITHER of the following at or beyond the siteboundarya. 10 mRem TEDE for 60 minutes of exposureORb. 50 mRem CDE Thyroid for 60 minutes of exposureORMonth 20XXLGS 3-37EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExellon NuclearLimric.G...a.n Stat..on.Anne.........Nuclea.
RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA1 (cont)Emergency Action Level (EAL) (cont):4. Field survey results at or beyond the site boundary indicate EITHER:a. Gamma (closed window) dose rates > 10 mR/hr are expected tocontinue for > 60 minutes.ORb. Analyses of field survey samples indicate
> 50 mRem CDEThyroid for 60 minutes of inhalation.
Table R1 Effluent Monitor Thresholds Release Path AlertNorth Stack (WR Monitor:
RIX-26-076-4) 1.92 E+06 uCi/secSouth Stack (Unit 1: RY26-185A-3
/ 2.71 E-03 uCi/secRY26-185-B-3 or Unit 2: RY26-285A-3
/RY26-285-B-3)
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 mRem while the 50 mRem thyroidCDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE andthyroid CDE.Escalation of the emergency classification level would be via IC RS1.Month 20XXLGS 3-38EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA1 (cont)Basis Reference(s):
: 1. NEI 99-01 Rev 6, AA12. LGS ODCM3. EP-EAL-0608 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Limerick Generating Station4. L-S-43 Radiation Monitoring System5. ARC-BOP-0AC304 C1 Liquid Radwaste Discharge Rad Monitor Hi Hi6. ARC-MCR-003 El North Stack Hi-Hi Radiation
: 7. ARC-MCR-003 F1 Units 1&2 South Stack Hi-Hi Radiation
: 8. EP-EAL-0615 Revision 0, Limerick Criteria for Choosing Radiological LiquidEffluent EAL Threshold ValuesMonth 20XXLGS 3-39EP-AA-1008 (Revision XX)
I imerink r--pprpting
-qfzitinn,&nnPy IFYalnn MitnllnrRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU1Initiating Condition:
Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60minutes or longer.Operating Mode Applicability:
1,2,3,4,5, DEmergency Action Level (EAL):Notes:" The Emergency Director should declare the event promptly upon determining that theapplicable time has been exceeded, or will likely be exceeded.
* If an ongoing release is detected and the release start time is unknown, assume thatthe release duration has exceeded 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 of the following effluent monitors
> 2 times alarm setpointestablished by a current radioactive release discharge permit for 60 minutes.9 Radwaste Discharge Effluent Monitor (RR63-OR001)
ORe Discharge Permit specified monitorOR2. Readings on ANY Table R1 Effluent Monitor > Table RI value for > 60 minutes:Table R1 Effluent Monitor Thresholds Release Path Unusual EventNorth Stack (WR Monitor:
RIX-26-076-4) 2.20 E+04 uCi/secSouth Stack (Unit 1: RY26-185A-3
/ 3.09 E-05 uCilsecRY26-185-B-3 or Unit 2: RY26-285A-3
/RY26-285-B-3)
OR3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations orrelease rates > 2 times ODCM Limit with a release duration of > 60 minutes.Month 20XXLGS 3-40EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RUI (cont)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.
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 BasisThis EAL addresses radioactivity releases that cause effluent radiation monitor readingsto exceed 2 times the limit established by a radioactivity discharge permit. This EAL willtypically be associated with planned batch releases from non-continuous releasepathways (e.g., radwaste, waste gas).The effluent monitors listed are those normally used for planned discharges.
If adischarge is performed using a different flowpath or effluent monitor other than thoselisted (e.g., a portable or temporary effluent monitor),
then the declaration criteria will bebased on the monitor specified in the Discharge Permit.EAL #2 BasisThis EAL addresses normally occurring continuous radioactivity releases from monitored gaseous effluent pathways.
EAL #3 BasisThis EAL addresses uncontrolled gaseous or liquid releases that are detected by sampleanalyses or environmental
: surveys, particularly on unmonitored pathways (e.g., spills ofradioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).Escalation of the emergency classification level would be via IC RA1.Month 20XXLGS 3-41EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RUI (cont)Basis Reference(s):
: 1. NEI 99-01 Rev 6, AU12. LGS ODCM3. EP-EAL-0608 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EALThreshold Values Limerick Generating Station4. L-S-43 Radiation Monitoring System5. ARC-BOP-0AC304 C1 Liquid Radwaste Discharge Rad Monitor Hi Hi6. ARC-MCR-1 09 A2 1 Service Water Rad Monitor Hi-Hi7. ARC-MCR-01 1 C-4 RHRSW Rad Monitor Hi-Hi8. ARC-MCR-003 El North Stack Hi-Hi Radiation
: 9. ARC-MCR-003 F1 Units 1&2 South Stack HI-Hi Radiation Month 20XXLGS 3-42EP-AA-1008 (Revision XX) l=xelnn N rLimerick Generatina Sta~tion Annex FvAlnn Nucler~IRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA2Initiating 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. Uncovery of irradiated fuel in the REFUELING PATHWAY.OR2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel asindicated by ANY Table R2 Radiation Monitor reading >1000 mRem/hr.Table R2Refuel Floor ARM's* RIS29-M1-1(2)K600, Drywell Head Laydown* RIS30-M1-1(2)K600, Dryer / Separator Area* RIS31-M1-1(2)K600, Spent Fuel Pool" RIS32-M1-1(2)K600, New Fuel storage Vault" RIS33-M1-1(2)K600, Pool Plug LaydownBasis:REFUELING PATHWAY:
all the cavities, tubes, canals and pools through whichirradiated fuel may be moved or stored, but not including the reactor vessel below theflange.IMMINENT:
The trajectory of events or conditions is such that an EAL will be met within arelatively short period of time regardless of mitigation or corrective actions.CONFINEMENT BOUNDARY:
The irradiated fuel dry storage cask barrier(s) betweenareas containing radioactive substances and the environment.
This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly.
These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment.
As such, theyrepresent an actual or potential substantial degradation of the level of safety of the plant.This IC applies to irradiated fuel that is licensed for dry storage up to the point that theloaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss ofthe CONFINEMENT BOUNDARY is classified in accordance with IC E-HUI.Month 20XXLGS 3-43EP-AA-1008 (Revision XX)
I iminritkrI, V'anrtafinn Qftx*iIn AnncavPvg%1^n Kl"A-Igs&#xfd;r 23RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA2 (cont)Basis (cont):EAL #1 BasisThis EAL escalates from RU2 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 a rise in a dose rate due to a lowering ofwater level in some portion of the REFUELING
: PATHWAY, the reading may not be areliable 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 BasisThis EAL addresses a release of radioactive material caused by mechanical damage toirradiated fuel. Damaging events may include the dropping, bumping or binding of anassembly, or dropping a heavy load onto an assembly.
A rise in readings on radiation monitors should be considered in conjunction with in-plant reports or observations of apotential fuel damaging event (e.g., a fuel handling accident).
Escalation of the emergency would be based on either Recognition Category R or C ICs.Basis Reference(s):
: 1. NEI 99-01 Rev 6, AA22. ON-120 Fuel Handling Problems3. DBD L-S-43, Radiation Monitoring System4. ARC MCR 112-15 Fuel Pool Storage Hi/Lo Level5. DBD L-S-16, Reactor Instrumentation System (RIS)6. DBD L-S-52, Fuel Pool Cooling and Cleanup SystemMonth 20XXLGS 3-44EP-AA-1008 (Revision XX)
 
L ime~rick Ge~nerating Staition Annex Fyelnn Nmmr-loar RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU2Initiating Condition:
UNPLANNED loss of water level above irradiated fuel.Operating Mode Applicability:
1, 2, 3, 4, 5, DEmergency Action Level (EAL):1. UNPLANNED water level drop in the REFUELING PATHWAY as indicated by ANYof the following:
* Refueling Cavity water level < 484 inches.OR" Spent Fuel Pool level < 22 feet above seated irradiated fuel.OR* Indication or report of a drop in water level in the REFUELING PATHWAY.AND2. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors inTable R2.Table R2Refuel Floor ARM's" RIS29-M1-1(2)K600, Drywell Head Laydown" RIS30-M1
-1 (2)K600, Dryer / Separator Area" RIS31-M1-1(2)K600, Spent Fuel Pool* RIS32-M1-1(2)K600, New Fuel storage Vault" RIS33-M1-1(2)K600, Pool Plug LaydownMonth 20XXLGS 3-45EP-AA-1008 (Revision XX)
Limerick Generating Station Annexl=xelon NuclearExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU2 (cont)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 through whichirradiated fuel may be moved or stored, but not including the reactor vessel below theflange.This IC addresses a loss in water level above irradiated fuel sufficient to cause elevatedradiation levels. This condition could be a precursor to a more serious event and is alsoindicative of a minor loss in the ability to control radiation levels within the plant. It istherefore a potential degradation in the level of safety of the plant.A water level loss will be primarily determined by indications from available levelinstrumentation.
Other sources of level indications may include reports from plantpersonnel (e.g., from a refueling crew) or video camera observations (if available) or fromany other temporarily installed monitoring instrumentation.
A significant drop in the waterlevel may also cause a rise in the radiation levels of adjacent areas that can be detectedby monitors in those locations.
The effects of planned evolutions should be considered.
For example, a refueling bridgearea radiation monitor reading may rise due to planned evolutions such as lifting of thereactor vessel head or movement of a fuel assembly.
Note that this EAL is applicable only in cases where the elevated reading is due to an UNPLANNED loss of water level.A drop in water level above irradiated fuel within the reactor vessel may be classified inaccordance Recognition Category C during the Cold Shutdown and Refueling modes.Escalation of the emergency classification level would be via IC RA2.Basis Reference(s):
: 1. NEI 99-01 Rev 6, AU22. Technical Specifications 3.9.83. ON-120 Fuel Handling Problems4. DBD L-S-16, Reactor Instrumentation System (RIS)5. DBD L-S-52, Fuel Pool Cooling and Cleanup System6. ARC MCR 112-15 Fuel Pool Storage Hi/Lo Level7. GP-6.1 U/1(2) Shutdown Operations
-Refuel Core Alterations
& Core Off-loading Month 20XXLGS 3-46EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA3Initiating Condition:
Radiation levels that impede access to equipment necessary for normal plant operations, cooldown or shutdown.
Operating Mode Applicability:
1,2, 3, 4, 5, DEmergency Action Level (EAL):Note:* If the equipment in the room or area listed in Table R4 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 areas contained in Table R3:Table R3Areas Requiring Continuous Occupancy
* Main Control Room" Central Alarm Station -(by survey)OR2. UNPLANNED event results in radiation levels that prohibit or significantly impedeaccess to ANY of the areas contained in Table R4:Table R4Areas with Entry Related Mode Applicability Area Entry Related ModeApplicability Reactor Enclosure*
Modes 3, 4, and 5* Areas required to establish shutdown coolingMonth 20XXLGS 3-47EP-AA-1008 (Revision XX)
NuP.lenrSimeric~k Generating Station Annex Exelnn Nui~clear RECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA3 (cont)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.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 plantprocedures.
As such, it represents an actual or potential substantial degradation of thelevel of safety of the plant. The Emergency Director should consider the cause of theincreased radiation levels and determine if another IC may be applicable.
Table R4 is a list of plant rooms or areas with entry-related mode applicability that containequipment which require a manual/local action necessary to transition the plant fromnormal plant operation to cooldown and shutdown as specified in normal 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 at the time andthe elevated radiation levels preclude the ability to place shutdown cooling in service.The emergency classification is not contingent upon whether entry is actually necessary at the time of the increased radiation levels. Access should be considered as impeded ifextraordinary measures are necessary to facilitate entry of personnel into the affectedroom/area (e.g., installing temporary shielding beyond that required by procedures, requiring use of non-routine protective equipment, requesting an extension in dose limitsbeyond normal administrative limits).An emergency declaration is not warranted if any of the following conditions apply." The plant is in an operating mode different than the mode specified for the affectedroom/area (i.e., entry is not required during the operating mode in effect at the time ofthe elevated radiation levels).
For example, the plant is in Mode 1 when the radiation rise occurs, and the procedures used for normal operation, cooldown and shutdowndo 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.).Month 20XXLGS 3-48EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Fxelnn Nucler~IRECOGNITION CATEGORYABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA3 (cont)Basis (cont):" 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 R, Cor F ICs.Basis Reference(s):
: 1. NEI 99-01 Rev 6, AA32. UFSAR Table 7.7-2, Locations for Area Radiation Monitor Sensors3. SE-1 Remote Shutdown4. SE-6 Alternate Remote Shutdown5. SE-8 Fire6. DBD L-S-43, Radiation Monitoring SystemMonth 20XXLGS 3-49EP-AA-1 008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS RU3Initiating Condition:
Reactor coolant activity greater than Technical Specification allowable limits.Operating Mode Applicability:
1,2,3.Emergency Action Level (EAL):1. Air Ejector discharge radiation monitor (RISH 26 1(2)K601 A, B) Hi-Hi alarm.OR2. Specific coolant activity
> 4.0 uCIIgm 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 R ICs.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SU32. Technical Specifications 3.4.5, Specific Activity3. Technical Specifications 3.4.5, Basis4. UFSAR Table 11.5-1, Process and Effluent Radiation Monitoring Systems5. DBD L-S-43, Radiation Monitoring System6. ARC MCR 109-G1, Air Ejector Offgas Discharge HI-HI Radiation Month 20XXLGS 3-50EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon 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 20XXLGS 3-51EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon 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 20XXLGS 3-52EP-AA-1008 (Revision XX)
 
rSimeric~k (GAneratinn Station Annex FwAlnn Nuclea&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 20XXLGS 3-53EP-AA-1 008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC1Initiating Condition:
RCS ActivityOperating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
LOSSCoolant activity
> 300 uCi/gm Dose Equivalent 1-131.Basis:This threshold indicates that RCS radioactivity concentration is greater than 300 [iCi/gmdose equivalent 1-131. Reactor coolant activity above this level is greater than thatexpected for iodine spikes and corresponds to an approximate range of 2% to 5% fuelclad damage. Since this condition indicates that a significant amount of fuel claddamage has occurred, it represents a loss of the Fuel Clad Barrier.It is recognized that sample collection and analysis of reactor coolant with highlyelevated activity levels could require several hours to complete.
Nonetheless, asample-related threshold is included as a backup to other indications.
There is no Potential Loss threshold associated with RCS Activity.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXLGS 3-54EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexExelon NuclearExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC2Initiating Condition:
RPV Water LevelOperating 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
> -161 inches (TAF).OR3. RPV water level cannot be determined.
Basis:Loss Threshold
#1 BasisThe Loss threshold represents the EOP requirement for primary containment flooding.
This is identified in the BWROG EPGs/SAGs when the phrase, "Primary Containment Flooding Is Required,"
appears.
Since a site-specific RPV water level is not specified here, the Loss threshold phrase, "Primary containment flooding required,"
alsoaccommodates the EOP need to flood the primary containment when RPV water levelcannot be determined and core damage due to inadequate core cooling is believed tobe occurring.
Potential Loss Threshold
#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 Barrier RC2 Loss threshold.
Thus,this threshold indicates a Potential Loss of the Fuel Clad barrier and a Loss of the RCSbarrier that appropriately escalates the emergency classification level to a Site AreaEmergency.
This threshold is considered to be exceeded when, as specified in the site-specific EOPs, RPV water level cannot be restored and maintained above the specified levelfollowing depressurization of the RPV (either manually, automatically or by failure of theRCS barrier) or when procedural guidance or a lack of low pressure RPV injection sources preclude Emergency RPV depressurization.
EOPs allow the operator a widechoice of RPV injection sources to consider when restoring RPV water level to withinprescribed limits. EOPs also specify depressurization of the RPV in order to facilitate Month 20XXLGS 3-55EP-AA-1008 (Revision XX)
Simerick Generatinn Sta~tion Annex Fxellnn Nucler~IRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC2 (cont)Basis (cont):RPV water level control with low-pressure injection sources.
In some events, elevatedRPV pressure may prevent restoration of RPV water level until pressure drops belowthe 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 in order to reduce reactor power. Although suchaction is a challenge to core cooling and the Fuel Clad barrier, the immediate need toreduce reactor power is the higher priority.
For such events, ICs MA3 or MS3 will dictatethe need for emergency classification.
Since the loss of ability to determine if adequate core cooling is being provided presentsa significant challenge to the fuel clad barrier, a potential loss of the fuel clad barrier isspecified.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-22. T-1 11 Level Restoration
/ Steam Cooling-BASES3. T-1 17 Level/Power Control -BASESMonth 20XXLGS 3-56EP-AA-1008 (Revision XX)
 
No Limeric~k Generating Staition Annex Fvainn him-lanrRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC5Initiating Condition:
Primary Containment Radiation Operating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
LOSSDrywell radiation monitor reading > 1.90 E+02 R/hr.Basis:The radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the primary containment, assuming that reactor coolant activityequals 300 pCi/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 Threshold since it indicates a loss of both the Fuel Clad Barrier andthe RCS Barrier.
Note that a combination of the two monitor readings appropriately escalates the emergency classification level to a Site Area Emergency.
There is no Fuel Clad Barrier Potential Loss threshold associated with PrimaryContainment Radiation.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-22. Core Damage Assessment Methodology
: 3. Technical Specifications Table 3.3.7.5-1, Accident Monitoring Instrumentation
: 4. DBD L-S-43, Radiation Monitoring System5. ST-2-026-418-1 Accident Monitoring
-Primary Containment Post -LOCARadiation Division IIl Calibration (RE-26-191A)
: 6. ST-0-026-640-*
Alternate Monitoring for Inop Post-LOCA Radiation MonitorsMonth 20XXLGS 3-57EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION FC7.Initiating Condition:
Emergency Director Judgment.
Operating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
LOSS1. Any condition in the opinion of the Emergency Director that indicates Loss of the FuelClad Barrier.POTENTIAL LOSS2. Any condition in the opinion of the Emergency Director that indicates Potential Lossof 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 BasisThis threshold addresses any other factors that may be used by the Emergency Directorin determining whether the Fuel Clad Barrier is potentially lost. The Emergency Directorshould also consider whether or not to declare the barrier potentially lost in the eventthat barrier status cannot be monitored.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-2Month 20XXLGS 3-58EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION 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
> -161 inches (TAF).OR2. RPV water level cannot be determined.
Basis:This water level corresponds to the Top of Active Fuel (TAF) and is used in the EOPs toindicate challenge to core cooling.The RPV water level threshold is the same as Fuel Clad Barrier FC2 Potential Lossthreshold.
Thus, this threshold indicates a Loss of the RCS barrier and Potential Loss ofthe Fuel Clad barrier and that appropriately escalates the emergency classification levelto a Site Area Emergency.
This threshold is considered to be exceeded when, as specified in the site-specific EOPs, RPV water level cannot be restored and maintained above the specified levelfollowing depressurization of the RPV (either manually, automatically or by failure of theRCS barrier) or when procedural guidance or a lack of low pressure RPV injection sources preclude Emergency RPV depressurization EOPs allow the operator a widechoice of RPV injection sources to consider when restoring RPV water level to withinprescribed limits. EOPs also specify depressurization of the RPV in order to facilitate RPV water level control with low-pressure injection sources.
In some events, elevatedRPV pressure may prevent restoration of RPV water level until pressure drops belowthe shutoff heads of available injection sources.
Therefore, this RCS barrier Loss is metonly after either: 1) the RPV has been depressurized, or required emergency RPVdepressurization has been attempted, giving the operator an opportunity to assess thecapability of low-pressure injection sources to restore RPV water level or 2) no lowpressure RPV injection systems are available, precluding RPV depressurization in anattempt to minimize loss of RPV inventory.
The term, "cannot be restored and maintained above," means the value of RPV waterlevel is not able to be brought above the specified limit (top of active fuel). Thedetermination requires an evaluation of system performance and availability in relationto the RPV water level value and trend. A threshold prescribing declaration when 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.
Month 20XXLGS 3-59EP-AA-1008 (Revision XX)
N Limeric~k Generatinn Station Annex Exelnn NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC2 (cont)Basis (cont):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 in order to reduce reactor power. Although suchaction is a challenge to core cooling and the Fuel Clad barrier, the immediate need toreduce reactor power is the higher priority.
For such events, ICs MA3 or MS3 will dictatethe need for emergency classification.
There is no RCS Potential Loss threshold associated with RPV Water Level.Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-22. T-BAS, TRIPS / SAMPS -Bases3. T 101, RPV Control4. T-1 11, Level Restoration
/ Steam CoolingMonth 20XXLGS 3-60EP-AA-1008 (Revision XX)
Limerick Generatinq Station AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC3Initiating Condition:
Primary Containment PressureOperating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
LOSS1. Drywell pressure
> 1.68 psig.AND2. Drywell pressure rise is due to RCS leakageBasis:The > 1.68 psig primary containment pressure is the Drywell high pressure setpointwhich indicates a LOCA by automatically initiating ECCS.The second threshold condition focuses the fission product barrier loss threshold on afailure of the RCS instead of the non-LOCA malfunctions that may adversely affectprimary containment pressure.
Pressures of this magnitude can be caused by non-LOCA events such as a loss of Drywell cooling or inability to control primarycontainment vent/purge.
The release of mass from the RCS due to the as-designed/expected operation of anyrelief valve does not warrant an emergency classification.
A stuck-open Safety Relief Valve (SRV) or SRV leakage is not considered eitheridentified or unidentified leakage by Technical Specification and, therefore, is notapplicable to this EAL.There is no Potential Loss threshold associated with Primary Containment Pressure.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-22. T-101 RPV Control3. T-102 Primary Containment Control -BasesMonth 20XXLGS 3-61EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexN Exelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC4Initiating Condition:
RCS Leak RateOperating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
LOSS1. UNISOLABLE Main Steam Line (MSL), HPCI, Feedwater, RWCU, or RCIC linebreak.OR2. Emergency RPV Depressurization is required.
POTENTIAL LOSS3. UNISOLABLE primary system leakage that results in EITHER of the following:
: a. Secondary Containment area temperature
> T-103 / SAMP, Max Norm Op Value(MNO).ORb. Secondary Containment area radiation level > T-103 / SAMP, Max Norm OpValue (MNO).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.Loss Threshold
#1 BasisLarge 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, the RCS barrier Loss threshold is met.Month 20XXLGS 3-62EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC4 (cont)Basis (cont):Loss Threshold
#2 BasisEmergency 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 suppression pool, a Loss of the RCS barrier exists due tothe diminished effectiveness of the RCS to retain fission products within its boundary.
Potential Loss Threshold
#3 BasisPotential 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, RCIC, HPCI, etc., which indicate adirect path from the RCS to areas outside primary containment.
A Max Normal Operating value is the highest value of the identified parameter expectedto occur during normal plant operating conditions with all directly associated supportand control systems functioning properly.
The indicators reaching the threshold barriers and confirmed to be caused by RCSleakage from a primary system warrant an Alert classification.
A primary system isdefined to be the pipes, valves, and other equipment which connect directly to the RPVsuch that a reduction in RPV pressure will effect a decrease in the steam or water beingdischarged through an unisolated break in the system.In general, multiple indications should be used to determine if a primary system isdischarging outside Primary Containment.
For example, a high area radiation 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 Threshold
#1 (after a containment isolation) and a General Emergency when the Fuel Clad Barriercriteria is also exceeded.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-22. SAMP-2, Containment and Radioactivity Release Control3. T-103, Secondary Containment ControlMonth 20XXLGS 3-63EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC5Initiating Condition:
Primary Containment radiation Operating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
LOSSDrywell radiation monitor reading > 10OR/hr.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 Threshold since it indicates a loss of the RCS Barrieronly.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 RCS BarrierMonth 20XXLGS 3-64EP-AA-1008 (Revision XX)
 
Limeric.
k Ge.n. ratinn Stvatin Annex Fv.inn Nucle!w marRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION RC7Initiating Condition:
Emergency Director Judgment.
Operating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
LOSS1. Any condition in the opinion of the Emergency Director thatBarrier.POTENTIAL LOSS2. Any condition in the opinion of the Emergency Director thatof the RCS Barrier.indicates Loss of the RCSindicates Potential LossBasis:Loss Threshold
#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 Threshold
#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 20XXLGS 3-65EP-AA-1008 (Revision XX)
 
rLimeric~k Generatinn Station Annex FvA-Inn NuclerIzi RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT2Initiating Condition:
RPV Water LevelOperating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
POTENTIAL LOSSPlant conditions indicate Primary Containment flooding is required.
Basis:The Potential Loss threshold is identical to the Fuel Clad Barrier FC2 Loss threshold RPV Water Level. The Potential Loss requirement for Primary Containment Floodingindicates adequate core cooling cannot be restored and maintained and that coredamage is possible.
BWR EPGs/SAGs specify the conditions that require primarycontainment flooding.
When primary containment flooding is required, the EPGs areexited and SAGs are entered.
Entry into SAGs is a logical escalation in response to theinability to restore and maintain adequate core cooling.PRA studies indicate that the condition of this Potential Loss threshold could be a coremelt sequence which, if not corrected, could lead to RPV failure and increased 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. T-BAS (INTRO) Introduction To Trips And Samps -Bases3. T-1 11, Level Restoration
/ Steam Cooling -Bases4. T-116, RPV Flooding
-Bases5. T-1 17, Level/Power Control -BasesMonth 20XXLGS 3-66EP-AA-1008 (Revision XX)
I imarie-Ir I'Zinnarnfin
_Qtntiewn AnnovI:::alenn M, ,rlrI r I,(~~ran
~~i~n A nv vI~nhmmrI~
~... -~- **~ *4t* .- ~t~***t*~%
.2..RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT3Initiating Condition:
Primary Containment Conditions Operating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
LOSS1. UNPLANNED rapid drop in primary containment pressure following primarycontainment pressure rise.OR2. Primary containment pressure response not consistent with LOCA conditions.
POTENTIAL LOSS3. Drywell pressure
> 55 psig and rising.OR4. a. Drywell or Suppression Pool Hydrogen concentration
> 6%.ANDb. Drywell or Suppression Pool Oxygen concentration
> 5%.OR5. Heat Capacity Limit (T-102 Curve SP/T-1) exceeded.
Basis:UNPLANNED:
A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.Loss Threshold
#1 and #2 BasisRapid UNPLANNED loss of primary containment pressure (i.e., not attributable toDrywell spray or condensation effects) following an initial pressure rise indicates a lossof primary containment integrity.
Primary containment pressure should rise as a result ofmass and energy release into the primary containment from a LOCA. Thus, primarycontainment pressure not increasing under these conditions indicates a loss of primarycontainment 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 bypass condition.
A pressure suppression bypass path would not be an indication of acontainment breach.Month 20XXLGS 3-67EP-AA-1008 (Revision XX)
Limerick Generatinq Station AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT3 (cont)Basis (cont):Potential Loss Threshold
#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 Threshold
#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 Threshold
#5 BasisThe HCTL is a function of RPV pressure, suppression pool temperature andsuppression pool water level. It is utilized to preclude failure of the containment andequipment in the containment necessary for the safe shutdown of the plant andtherefore, the inability to maintain plant parameters below the limit constitutes apotential loss of containment.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-22. UFSAR Section 6.2.13. DBD L-T-12, Design Basis Accidents, Transients and Events4. DBD L-S-25A, Primary Containment Pressure Suppression System5. DBD L-T-02, Containment, Section 3.2.146. T-102 Primary Containment Control -BasesMonth 20XXLGS 3-68EP-AA-1008 (Revision XX)
PIni~nn N~i-lonrSimeric~k (GAneratinn Station Annex vIn ~mrI2RECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT5Initiating Condition:
Primary Containment Radiation Operating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
POTENTIAL LOSSDrywell radiation monitor reading > 4.35 E+02 R/hr.Basis:There is no Loss threshold associated with Primary Containment Radiation.
The radiation monitor reading corresponds to an instantaneous release of all reactorcoolant mass into the primary containment, assuming that 20% of the fuel cladding hasfailed. This level of fuel clad failure is well above that used to determine the 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
: 3. Technical Specifications Table 3.3.7.5-1
: 4. DBD L-S-43, Radiation Monitoring System5. ST-2-026-418-1 Accident Monitoring
-Primary Containment Post -LOCARadiation Division III Calibration (RE-26-191A)
: 6. ST-0-026-640-*
Alternate Monitoring for Inop Post-LOCA Radiation MonitorsMonth 20XXLGS 3-69EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexNuclearExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT6Initiating Condition:
Primary Containment Isolation FailureOperating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
LOSS1. UNISOLABLE direct downstream pathway to the environment exists after primarycontainment isolation signal.OR2. Intentional Primary Containment venting/purging per EOPs or SAGs due to accidentconditions.
OR3. UNISOLABLE primary system leakage that results in EITHER of the following:
: a. Secondary Containment area temperature
> T-103 / SAMP Max Safe OpValue (MSO).ORb. Secondary Containment area radiation level > T-103 / SAMP Max Safe OpValue (MSO).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 Threshold
#1 BasisThe use of the modifier "direct" in defining the release path discriminates againstrelease paths through interfacing liquid systems or minor release pathways, such asinstrument lines, not protected by the Primary Containment Isolation System (PCIS).Leakage into a closed system is to be considered only if the closed system is breachedand thereby creates a significant pathway to the environment.
Examples includeunisolable Main Steamline, HPCI or RCIC steamline breaks, unisolable RWCU systembreaks, and unisolable containment atmosphere vent paths.Examples of "downstream pathway to the environment" could be through theTurbine/Condenser, or direct release to the Turbine or Reactor Building.
The existence of a filter is not considered in the threshold assessment.
Filters do notremove fission product noble gases. In addition, a filter could become ineffective due toiodine and/or particulate loading beyond design limits (i.e., retention ability has beenexceeded) or water saturation from steam/high humidity in the release stream.Month 20XXLGS 3-70EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT6 (cont)Basis (cont):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 R ICs.Loss Threshold
#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 Drywell high pressure scramsetpoint) does not meet the threshold condition.
Loss Threshold
#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 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.
In combination with RCS Barrier RC4 Potential Loss Threshold
#3 this threshold wouldresult in a Site Area Emergency.
Month 20XXLGS 3-71EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT6 (cont)Basis (cont):There is no Potential Loss threshold associated with Primary Containment Isolation Failure.Basis Reference(s):
: 1. NEI 99-01 Rev 6, Table 9-F-22. T-103, Secondary Containment Control3. T-102, Primary Containment Control4. T-200, Primary Containment Emergency Vent Procedure
: 5. T-228, Inerting
/ Purging Primary Containment Month 20XXLGS 3-72EP-AA-1008 (Revision XX)
Limerick Generatinq Station AnnexExelon NuclearRECOGNITION CATEGORYFISSION PRODUCT BARRIER DEGRADATION CT7Initiating Condition:
Emergency Director Judgment.
Operating Mode Applicability:
1,2,3Fission Product Barrier (FPB) Threshold:
LOSS1. Any condition in the opinion of the Emergency Director that indicates Loss of theContainment Barrier.POTENTIAL LOSS2. Any condition in the opinion of the Emergency Director that indicates Potential Lossof the Containment Barrier.Basis:Loss Threshold
#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 Threshold
#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 20XXLGS 3-73EP-AA-1008 (Revision XX)
Simeric~k Generatinn Station Annex FvApinn Nula~r~IRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MG1Initiating Condition:
Prolonged loss of all Off-site and all On-Site AC power to emergency busses.Operating Mode Applicability:
1,2,3Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.
1 Loss of ALL offsite AC power to unit 4 KV Safeguards Buses.AND2. Failure of D11(21) and D12(22),
D13(23),
and D14(24) Emergency DieselGenerators to supply power to unit 4KV Safeguards Buses.AND3. EITHER of the following:
: a. Restoration of at least one unit 4KV safeguards Bus in < 2 hours is not likely.ORb. RPV water level cannot be restored and maintained
> -186 inches.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.
This IC addresses a prolonged loss of all power sources to AC emergency buses. Aloss of all AC power compromises the performance of all SAFETY SYSTEMS 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 ANY fission product barriers.
Inaddition, fission product barrier monitoring capabilities may be degraded under theseconditions.
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 andMonth 20XXLGS 3-74EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MG1 (cont)Basis (cont):event trajectory are subject to greater uncertainty, and there is an increased likelihood of challenges to multiple fission product barriers.
The estimate for restoring at least one emergency bus should be based on a realistic appraisal of the situation.
Mitigation actions with a low probability of success should notbe used as a basis for delaying a classification upgrade.
The goal is to maximize thetime available to prepare for, and implement, protective actions for the public.The EAL will also require a General Emergency declaration if the loss of AC powerresults in parameters that indicate an inability to adequately remove decay heat fromthe core.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SG12. UFSAR Section 8.2, Offsite Power System3. E 10/20 Loss of Offsite Power4. DBD L-S-05, 4KV System5. DBD L-T-03, Electrical Issues6. T-101 RPV ControlMonth 20XXLGS 3-75EP-AA-1008 (Revision XX)
 
Limeric~k Generatinn Station Annex FvYplnn N.Jionchr RECOGNITION CATEGORYSYSTEM MALFUNCTIONS MS1Initiating Condition:
Loss of all offsite and all onsite AC power to emergency busses for 15 minutes orlonger.Operating Mode Applicability:
1,2,3Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining that theapplicable time has been exceeded, or will likely be exceeded.
: 1. Loss of ALL offsite AC Power to unit 4KV Safeguards Buses.AND2. Failure of D11(21),
D12(22),
D13(23),
and D14(24) Emergency Diesel Generators tosupply power to unit 4KV Safeguards Buses.AND3. Failure to restore power to at least one unit 4KV Safeguards bus in < 15 minutesfrom the time of loss of both offsite and onsite AC power.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 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.Escalation of the emergency classification level would be via ICs RG1, FG1, MG1, orMG2.Month 20XXLGS 3-76EP-AA-1008 (Revision XX)
 
Simeric~k (GAnea~tinn Stamtion Annex Fyolem N~ialr&ipr RECOGNITION CATEGORYSYSTEM MALFUNCTIONS MS1 (cont)Basis Reference(s):
: 1. NEI 99-01 Rev 6, SS12. UFSAR Section 8.2, Offsite Power System3. E 10/20 Loss of Offsite Power4. DBD L-S-05, 4KV System5. DBD L-T-03, Electrical Issues6. T-101 RPV ControlMonth 20XXLGS 3-77EP-AA-1 008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MA1Initiating Condition:
Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:
1,2,3Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.
: 1. AC power capability to unit 4KV Safeguards Buses reduced to only one of thefollowing power sources for > 15 minutes.* 101 Safeguards Transformer
* 201 Safeguards Transformer
* Dl1(21) Diesel Generator
* D12(22) Diesel Generator SD13(23)
Diesel Generator
* D14(24) Diesel Generator AND2. ANY additional single power source failure will result in a loss of ALL 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 aretypically systems classified as safety-related.
This IC describes a significant degradation of offsite and onsite AC power sources suchthat any additional single failure would result in a loss of all AC power to SAFETYSYSTEMS.
In this condition, the sole AC power source may be powering one, or morethan one, train of safety-related equipment.
This IC provides an escalation path from ICMUl.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.o A loss of all offsite power with a concurrent failure of all but one emergency powersource (e.g., an onsite diesel generator).
Month 20XXLGS 3-78EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MA1 (cont)Basis (cont):" A loss of all offsite power and loss of all emergency power sources (e.g., onsitediesel generators) with a single train of emergency buses being back-fed from theunit main generator.
" A loss of emergency power sources (e.g., onsite diesel generators) with a singletrain of emergency buses being back-fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof power.Escalation of the emergency classification level would be via IC MS1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SAl2. UFSAR Section 8.2, Offsite Power System3. E 10/20 Loss of Offsite Power4. DBD L-S-05, 4KV System5. DBD L-T-03, Electrical IssuesMonth 20XXLGS 3-79EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MU1Initiating Condition:
Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.Operating Mode Applicability:
1,2,3Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.
Loss of ALL offsite AC power capability to unit 4KV Safeguards Buses for >15 minutes.Basis:This IC addresses a prolonged loss of offsite power. The loss of offsite power sourcesrenders the plant more vulnerable to a complete loss of power to AC emergency buses.This condition represents a potential reduction in the level of safety of the plant.For emergency classification
: purposes, "capability" means that an offsite AC powersource(s) is available to the emergency buses, whether or not the buses are poweredfrom it.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof offsite power.Escalation of the emergency classification level would be via IC MA1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SU12. UFSAR Section 8.2, Offsite Power System3. E 10/20 Loss of Offsite Power4. DBD L-S-05, 4KV System5. DBD L-T-03, Electrical IssuesMonth 20XXLGS 3-80EP-AA-1008 (Revision XX)
Simeric~k Generatinn Station Annex Fyi-Inn NuI~clarRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MG2Initiating Condition:
Loss of all AC and Vital DC power sources for 15 minutes or longer.Operating Mode Applicability:
1,2,3Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.
: 1. Loss of ALL offsite AC power to unit 4KV safeguards Buses.AND2. Failure of D11(21),
D12(22),
D13(23),
and D14(24) Emergency Diesel Generators to supply power to unit 4KV Safeguards Buses.AND3. Voltage is < 105 VDC on unit 125 VDC battery busses 1(2)FA, FB, FC, and FD.AND4. ALL AC and Vital DC power sources have been lost for > 15 minutes.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 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 EALconditions are met.Month 20XXLGS 3-81EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MG2 (cont)Basis Reference(s):
: 1. NEI 99-01 Rev 6, SG82. UFSAR Section 8.3.2, DC Power Systems3. DBD P-L-01A, 125/250 VDC System4. E-1(2)FA Loss of Division I Safeguard 125/250V DC BUS 1FA5. E-1(2)FB Loss of Division II Safeguard 125/250V DC BUS 1FB6. E-1(2)FC Loss of Division III Safeguard 125/250V DC BUS 1FC7. E-1(2)FD Loss of Division IV Safeguard 125/250V DC BUS 1FD8. UFSAR Section 8.2, Offsite Power System9. E 10/20 Loss of Offsite Power10. DBD L-S-05, 4KV System11. DBD L-T-03, Electrical IssuesMonth 20XXLGS 3-82EP-AA-1 008 (Revision XX)
Limerick Generating Station Annex Exelon Nucle;RECOGNITION CATEGORYSYSTEM MALFUNCTIONS MSInitiating Condition:
Loss of all vital DC power for 15 minutes or longer..Operating Mode Applicability:
1,2,3Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.
ar2Voltage is < 105 VDC on 125 VDC battery busses 1(2)FA, FB, FC, and FD for> 15 minutes.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.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via ICs RG1, FG1 or MG2.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SS82. UFSAR Section 8.3.2, DC Power Systems3. DBD P-L-01A, 125/250 VDC System4. E-1(2)FA Loss of Division I Safeguard 125/250V DC BUS 1FA5. E-1(2)FB Loss of Division II Safeguard 125/250V DC BUS 1FB6. E-1(2)FC Loss of Division III Safeguard 125/250V DC BUS 1FC7. E-1(2)FD Loss of Division IV Safeguard 125/250V DC BUS 1FDMonth 20XXLGS 3-83EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MS3Initiating Condition:
Inability to shutdown the reactor causing a challenge to RPV water level or RCS heatremoval.Operating Mode Applicability:
1,2Emergency Action Level (EAL):1. Automatic scram did not shutdown the reactor as indicated by Reactor Power > 4%.AND2. ALL manual / ARI actions to shutdown the reactor have been unsuccessful asindicated by Reactor Power > 4%.AND3. EITHER of the following conditions exist:" RPV water level cannot be restored and maintained
> -186 inches.OR" Heat Capacity Limit (T-102 Curve SP/T-1) exceeded.
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, are unsuccessful, and continued power generation is challenging thecapability to adequately remove heat from the core and/or the RCS. This condition willlead to fuel damage if additional mitigation actions are unsuccessful and thus warrantsthe declaration 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 thereactor.A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.
Escalation of the emergency classification level would be via IC RG1 or FG1.Month 20XXLGS 3-84EP-AA-1 008 (Revision XX)
Limerick Generating Station AnnexRECOGNITION CATEGORYSYSTEM MALFUNCTIONS Basis Reference(s):
: 1. NEI 99-01 Rev 6, SS52. T-101 RPV Control -Bases3. T-1 17 Level/Power Control -Bases4. T-1 02 Primary Containment Control -BasesExelon NuclearMS3 (cont)Month 20XXLGS 3-85EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexExelon NuclearExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS 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 down thereactor.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 by ReactorPower > 4%.AND2. Manual / ARI actions taken at the Reactor Console are not successful in shuttingdown the reactor as indicated by Reactor Power > 4%.Basis:This IC addresses a failure of the RPS to initiate or complete an automatic or manualreactor scram that results in a reactor shutdown, and subsequent operator manualactions taken at the reactor consoles to shutdown the reactor are also unsuccessful.
This condition represents an actual or potential substantial degradation of the level ofsafety of the plant. An emergency declaration is required even if the reactor issubsequently shutdown by an action taken away from the reactor consoles since thisevent entails a significant failure of the RPS.A manual action at the reactor consoles is any operator action, or set of actions, whichcauses the control rods to be rapidly inserted into the core (e.g., initiating a manualreactor 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 reactorconsoles (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 consoles".
Taking the Reactor Mode Switch to Shutdown is considered to be a manual scramaction.Month 20XXLGS 3-86EP-AA-1008 (Revision XX)
Limeric~k GeAnerating Station An nex Fv0Ilnn NM1ionI~r RECOGNITION CATEGORYSYSTEM MALFUNCTIONS MA3Basis (cont):The plant response to the failure of an automatic or manual reactor scram will varybased upon several factors including the reactor power level prior to the event,availability of the condenser, performance of mitigation equipment and actions, otherconcurrent plant conditions, etc. If the failure to shutdown the reactor is 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 MS3. Depending upon plant responses and symptoms, escalation is also possiblevia IC FSI. Absent the plant conditions needed to meet either IC MS3 or FS1, an Alertdeclaration is appropriate for this event.It is recognized that plant responses or symptoms may also require an Alert declaration in accordance with the Recognition Category F ICs; however, this IC and EAL areincluded to ensure a timely emergency declaration.
A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, SA52. T-101 RPV Control -Bases3. T-1 17 Level/Power Control -BasesMonth 20XXLGS 3-87EP-AA-1008 (Revision XX)
Simeric~k Generatinn Station Annex ExaInn NucleIarRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MU3Initiating Condition:
Automatic or manual scram fails to shutdown the reactor.Operating Mode Applicability:
1,2Emergency Action Level (EAL):Note:* A manual action is any operator action, or set of actions, which causes the controlrods to be rapidly inserted into the core, and does not include manually driving incontrol rods or implementation of boron injection strategies.
: 1. a. Automatic scram did not shutdown the reactor as indicated by ReactorPower > 4%.ANDb. Subsequent manual / ARI action taken at the Reactor Console is successful in shutting down the reactor.OR2. a. Manual scram did not shutdown the reactor as indicated by Reactor Power> 4%.ANDb. EITHER of the following:
: 1. Subsequent manual / ARI action taken at the Reactor Console issuccessful in shutting down the reactor.OR2. Subsequent automatic scram / ARI is successful in shutting 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 consoles or an automatic scram is successful inshutting down the reactor.
This event is a precursor to a more significant condition andthus represents a potential degradation of the level of safety of the plant.Month 20XXLGS 3-88EP-AA-1008 (Revision XX)
Limerick Generatinq Station AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MU3 (cont)Basis (cont):EAL #1 BasisFollowing the failure on an automatic reactor scram, operators will promptly initiatemanual actions at the reactor consoles to shutdown the reactor (e.g., initiate a manualreactor scram). If these manual actions are successful in shutting down the reactor,core heat generation will quickly fall to a level within the capabilities of the plant's decayheat removal systems.EAL #2 BasisIf an initial manual reactor trip is unsuccessful, operators will promptly take manualaction at another location(s) on the reactor consoles to shutdown the reactor (e.g.,initiate a manual reactor scram/ARI using a different switch).
Depending upon severalfactors, the initial or subsequent effort to manually scram the reactor, or a concurrent plant condition, may lead to the generation of an automatic reactor scram signal. If asubsequent manual or automatic scram/ARI is successful in shutting down the reactor,core heat generation will quickly fall to a level within the capabilities of the plant's decayheat removal systems.A manual action at the reactor consoles is any operator action, or set of actions, whichcauses the control rods to be rapidly inserted into the core (e.g., initiating a manualreactor 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 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 consoles are also unsuccessful in shutting down the reactor, then theemergency classification level will escalate to an Alert via IC MA3. Depending upon theplant response, escalation is also possible via IC FA1. Absent the plant conditions needed to meet either IC MA3 or FA1, an Unusual Event declaration is appropriate forthis event.A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.
Month 20XXLGS 3-89EP-AA-1008 (Revision XX)
I:yelnn N Limerick Generatinn Station Annex Exelnn NucleIarRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MU3 (cont)Basis (cont):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 createda 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 EALsare not applicable and no classification is warranted.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, SU52. T-101 RPV Control3. Technical Specifications Table 3.3.1.1-1 Month 20XXLGS 3-90EP-AA-1008 (Revision XX)
I imario-k (Zanarnfin Atntinn AnnoyI::valnn kl~dlrlrI imaria-Ie
(~~n~rzitinn
~t2tinn Ann~v Fv~Inn NI. mrI~~rRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MA4Initiating Condition:
UNPLANNED loss of Control Room indications for 15 minutes or longer with asignificant transient in progress.
Operating Mode Applicability:
1,2,3Emergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.
: 1. UNPLANNED event results in the inability to monitor ANY Table M1 parameter from within the Control Room for > 15 minutes.Table M1 Control Room Parameters
" Reactor Power" RPV Water Level* RPV Pressure" Drywell Pressure* Suppression Pool Level* Suppression Pool Temperature AND2. ANY Table M2 transient in progress.
Table M2 Significant Transients
* Automatic or Manual Runback > 25% thermal reactor power" Electrical Load Rejection
> 25% full electrical load* Reactor Scram* ECCS Actuation
" Thermal Power oscillations
> 10%Month 20XXLGS 3-91EP-AA-1008 (Revision XX)
LimArir~k
~~AnAr~ltinn
~t~tinn Annn'~Limerick Generatinn Station Annex Fvalnn N"d-lanrRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MA4 (cont)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 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 any of the listedparameters cannot be determined from within the Control Room. This situation wouldrequire a loss of all of the Control Room sources for the given parameter(s).
Forexample, the reactor power level cannot be determined from any analog, computerpoint, 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, RPV water level and RCS heat removal.
The lossof the ability to determine any of these parameters from within the Control Room isconsidered to be more significant than simply a reportable condition.
In addition, if allindication sources for any of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. Forexample, if the value for RPV water level cannot be determined from the indications andrecorders on a main control board, the SPDS or the plant computer, the availability ofother parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.
Escalation of the emergency classification level would be via ICs FS1 or IC RS1.Month 20XXLGS 3-92EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExellon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MA4 (cont)Basis Reference(s):
: 1. NEI 99-01 Rev 6, SA22. DBD L-T-06, Human Factors, Section 6.1.13. T-101 RPV Control4. T-102 Primary Containment Control5. ON-122, Loss of Main Control Room Annunciators
-BasesMonth 20XXLGS 3-93EP-AA-1 008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearLimerik.Ge.ratln Staio.AnexEx
.o.NuceaRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MU4Initiating 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 parameters fromwithin the Control Room for > 15 minutes.Table M1 Control Room Parameters
" Reactor Power" RPV Water Level* RPV Pressure* Drywell Pressure* Suppression Pool Level* Suppression Pool Temperature 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 any of the listedparameters cannot be determined from within the Control Room. This situation wouldrequire a loss of all of the Control Room sources for the given parameter(s).
Forexample, the reactor power level cannot be determined from any analog, digital andrecorder source within the Control Room.Month 20XXLGS 3-94EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MU4 (cont)Basis (cont):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 any of these parameters from within the Control Room isconsidered to be more significant than simply a reportable condition.
In addition, if allindication sources for any of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. Forexample, if the value for reactor vessel level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.
Escalation of the emergency classification level would be via IC MA4.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SU22. DBD L-T-06, Human Factors, Section 6.1.13. T-101 RPV Control4. T-102 Primary Containment Control5. ON-122, Loss of Main Control Room Annunciators
-BasesMonth 20XXLGS 3-95EP-AA-1008 (Revision XX)
 
I imerirnk r~ener~atinn St~ation Annex Fvalnn Niiltpa~r RECOGNITION CATEGORYSYSTEM MALFUNCTIONS MA5Initiating Condition:
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 theShift ManagerAND2. EITHER of the following:
: a. Event damage has caused indications of degraded performance inat least one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.ORb. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEMcomponent or structure required by Technical Specifications for thecurrent 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 20XXLGS 3-96EP-AA-1008 (Revision XX)
I::Y#_lnn N
rI imprirck (Generatinn Rtation Annex FYAlnn NmurlI2rRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MA5 (cont)Basis (cont):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.
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, required for the current operating mode, "required",
i.e. required to be operable by Technical Specifications for the currentoperating mode. This condition significantly reduces the margin to a loss or potential loss of a fission product barrier, and therefore represents an actual or potential substantial degradation of the level of safety of the plant. Manual or automatic electrical isolation of safety equipment due to flooding, in and of itself, does not constitute degraded performance and is classified under HU6.EAL #2.a addresses damage to a SAFETY SYSTEM train that is required to beoperable by Technical Specifications for the current operating mode, and is in operation since indications for it will be readily available.
The indications of degradedperformance should be significant enough to cause concern regarding the operability orreliability of the SAFETY SYSTEM train.EAL #2.b addresses damage to a SAFETY SYSTEM component that is required to beoperable by Technical Specifications for the current operating mode, and is not inoperation or readily apparent through indications alone, as well as damage to astructure 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 RS1.If the EAL conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.Month 20XXLGS 3-97EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MA5 (cont)Basis Reference(s):
: 1. NEI 99-01, Rev 6 SA92. UFSAR Section 2.5, Geology and Seimology
: 3. UFSAR Section 3.4.1, Flood Protection
: 4. UFSAR Section 6.2.1.1.1, Design Bases5. UFSAR Section 9.2.6.4.2, Spray Pond Water Requirements
: 6. DBD L-S-46, Meteorological and Seismic Monitoring Systems7. DBD L-T-17, Dynamic Qualification Program8. Specification NE-0294, "Fire Safe Shutdown Analysis Specification"
: 9. SE-5 Earthquake
: 10. SE-4 Flood11. SE-9, Preparation for Severe WeatherMonth 20XXLGS 3-98EP-AA-1008 (Revision XX)
L imeric~k Generatina Station Annex FvAlnn Nucler~IRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MU6Initiating 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 that theapplicable 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.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.These EALs thus apply to leakage into the containment, a secondary-side system or alocation 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.Month 20XXLGS 3-99EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MU6 (cont)Basis (cont):The release of mass from the RCS due to the as-designed/expected operation of anyrelief valve does not warrant an emergency classification.
A stuck-open Safety Relief Valve (SRV) or SRV leakage is not considered eitheridentified or unidentified leakage by Technical Specification and, therefore, is notapplicable to this EAL.The 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 R or F.Basis Reference(s):
: 1. NEI 99-01 Rev 6, SU42. Technical Specifications 3.4.3, Reactor Coolant System Leakage3. Technical Specifications 3.9.8, Water Level -Reactor Vessel4. DBD L-S-34, Radwaste System5. OT-101 High Drywell Pressure6. T-102 Primary Containment
: Control, Table DW/T-17. GP-6.1 U/I (U/2) Shutdown Operations
-Refueling, Core Alteration and CoreOff-Loading
: 8. DBD L-S-16, Reactor Instrumentation System (RIS)9. ST-6-107-596-*
Drywell Floor Drain Sump/Equipment Drain Tank Surveillance LogMonth 20XXLGS 3-100EP-AA-1008 (Revision XX)
FxAInn rLimeric=k ==-ting Station Annex Fxvwwn NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MU7Initiating Condition:
Loss of all On-site or Off-site communications capabilities.
Operating Mode Applicability:
1,2,3Emergency Action Level (EAL):1. Loss of ALL Table M3 Onsite communications capability affecting the ability toperform routine operations.
OR2. Loss of ALL Table M3 Offsite communication capability affecting the ability toperform offsite notifications.
OR3. Loss of ALL Table M3 NRC communication capability affecting the ability toperform NRC notifications.
Table M3 Communications Capability System Onsite Offsite NRCStation Radio XPlant Public Address (PA) XPrelude System X XStation Phones X X XSatellite Phones X X XNARS XHPN X XENS X XBasis:This IC addresses a significant loss of on-site,
: offsite, or NRC communications capabilities.
While not a direct challenge to plant or personnel safety, this eventwarrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.This IC should be assessed only when extraordinary means are being utilized to makecommunications possible (e.g., use of non-plant, privately owned equipment, relaying ofon-site information via individuals or multiple radio transmission points, individuals beingsent to offsite locations, etc.).Month 20XXLGS 3-101EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYSYSTEM MALFUNCTIONS MU7 (cont)Basis (cont):EAL #1 BasisAddresses a total loss of the communications methods used in support of routine plantoperations.
EAL #2 BasisAddresses a total loss of the communications methods used to notify all OROs of anemergency declaration.
The OROs referred to here are listed in procedure EP-MA-1 14-100-F-01, State / Local Event Notification Form.EAL #3 BasisAddresses a total loss of the communications methods used to notify the NRC of anemergency declaration.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, SU62. UFSAR Section 9.5.2, Communication Systems3. SE-12 Loss of Communications Month 20XXLGS 3-102EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS CA1Initiating Condition:
Loss of all offsite and all onsite AC power to emergency busses for 15 minutes orlonger.Operating Mode Applicability:
4,5, DEmergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.
: 1. Loss of ALL offsite AC power to unit 4KV Safeguards Buses.AND2. Failure of D11(21),
D12(22),
D13(23),
and D14(24) Emergency DieselGenerators to supply power to unit 4KV Safeguards Buses.AND3. Failure to restore power to at least one unit 4KV Safeguards bus in< 15 minutes from the time of loss of both offsite and onsite AC power.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 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.When in the cold shutdown, refueling, or defueled mode, this condition is not classified as a Site Area Emergency because of the increased time available to restore anemergency bus to service.
Additional time is available due to the reduced core decayheat load, and the lower temperatures and pressures in various plant systems.
Thus,when in these modes, this condition represents an actual or potential substantial degradation of the level of safety of the plant.Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Escalation of the emergency classification level would be via IC CS6 or RS1.Month 20XXLGS 3-103EP-AA-1008 (Revision XX)
 
Limerick Generating Station Annex .xe..n RECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS CAI (cont)Basis Reference(s):
: 1. NEI 99-01 Rev 6, CA22. UFSAR Section 8.2, Offsite Power System3. E 10-20 Loss of Offsite Power4. DBD L-S-05, 4KV System5. DBD L-T-03, Electrical IssuesMonth 20XXLGS 3-104EP-AA-1 008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS culInitiating Condition:
Loss of all but one AC power source 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 thatthe applicable time has been exceeded, or will likely be exceeded.
: 1. AC power capability to unit 4KV Safeguards Buses reduced to only one of thefollowing power sources for > 15 minutes.* 101 Safeguards Transformer
* 201 Safeguards Transformer
* D1l1(21)
Diesel Generator
* D12(22) Diesel Generator
* D13(23) Diesel Generator
* D14(24) Diesel Generator AND2. ANY additional single power source failure will result in a loss of ALL AC powerto SAFETY SYSTEMS.Basis:SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.
This IC describes a significant degradation of offsite and onsite AC power sources suchthat any additional single failure would result in a loss of all AC power to SAFETYSYSTEMS.
In this condition, the sole AC power source may be powering one, or morethan one, train of safety-related equipment.
When in the cold shutdown, refueling, or defueled mode, this condition is not classified as an Alert because of the increased time available to restore another power source toservice.
Additional time is available due to the reduced core decay heat load, and thelower temperatures and pressures in various plant systems.
Thus, when in thesemodes, this condition is considered to be a potential degradation of the level of safety ofthe plant.Month 20XXLGS 3-105EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS CUI (cont)Initiating Condition:
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." A loss of all offsite power with a concurrent failure of all but one emergency powersource (e.g., an onsite diesel generator).
* A loss of all offsite power and loss of all emergency power sources (e.g., onsitediesel generators) with a single train of emergency buses being back-fed from theunit main generator.
* A loss of emergency power sources (e.g., onsite diesel generators) with a singletrain of emergency buses being back-fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof power.The subsequent loss of the remaining single power source would escalate the event toan Alert in accordance with IC CAl.Basis Reference(s):
: 1. NEI 99-01 Rev 6 CU22. UFSAR Section 8.2, Offsite Power System3. E 10-20 Loss of Offsite Power4. DBD L-S-05, 4KV System5. DBD L-T-03, Electrical IssuesMonth 20XXLGS 3-106EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexI=xnlon Exelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS 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 as determined by theShift ManagerAND2. EITHER of the following:
: a. Event damage has caused indications of degraded performance inat least one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.ORb. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEMcomponent or structure required by Technical Specifications for thecurrent 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.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plantand/or placing it in the cold shutdown condition, including the ECCS. These aretypically systems classified as safety-related.
Month 20XXLGS 3-107EP-AA-1008 (Revision XX)
I impri(ck (GAneratinn Stamtion Annex Fvainn INmI-io2r RECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS CA2 (cont)Basis (cont):VISIBLE DAMAGE: Damage to a component or structure that is readily observable without measurements,
: testing, or analysis.
The visual impact of the damage 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, required for the current operating mode, "required",
i.e. required to be operable by Technical Specifications for the currentoperating mode. This condition significantly reduces the margin to a loss or potential loss of a fission product barrier, and therefore represents an actual or potential substantial degradation of the level of safety of the plant. Manual or automatic electrical isolation of safety equipment due to flooding, in and of itself, does not constitute degraded performance and is classified under HU6.EAL #2.a addresses damage to a SAFETY SYSTEM train that is required to beoperable by Technical Specifications for the current operating mode, and is in operation since indications for it will be readily available.
The indications of degradedperformance should be significant enough to cause concern regarding the operability orreliability of the SAFETY SYSTEM train.EAL #2.b addresses damage to a SAFETY SYSTEM component that is required to beoperable by Technical Specifications for the current operating mode, and is not inoperation or readily apparent through indications alone, or to a structure containing SAFETY SYSTEM components.
Operators will make this determination based on thetotality of available event and damage report information.
This is intended to be a briefassessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level would be via IC CS6 or RSI.If the EAL conditions of CA2 are not met then assess the event via HU3, HU4, or HU6.Basis Reference(s):
: 1. NEI 99-01 Rev 6, CA6Month 20XXLGS 3-108EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS CU3Initiating Condition:
Loss of Vital DC power for 15 minutes or longer.Operating Mode Applicability:
4,5Emergency 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 required 125 VDC battery busses 1(2)FA, FB, FC, and FD for> 15 minutes.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 operable SAFETY SYSTEMS when the plant is in the cold shutdown orrefueling mode. In these modes, the core decay heat load has been significantly
: reduced, and coolant system temperatures and pressures are lower; these conditions increase the time available to restore a vital DC bus to service.
Thus, this condition isconsidered to be a potential degradation of the level of safety of the plant.As used in this EAL, "required" means the Vital DC buses necessary to supportoperation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment.
For example, if Train A is out-of-service (inoperable) for scheduled outage maintenance work and Train B is in-service (operable),
then a loss of Vital DC power affecting Train Bwould require the declaration of an Unusual Event. A loss of Vital DC power to Train Awould not warrant an emergency classification.
Fifteen minutes was selected as a threshold to exclude transient or momentary powerlosses.Depending upon the event, escalation of the emergency classification level would be viaIC CA6 or CA5, or an IC in Recognition Category R.Month 20XXLGS 3-109EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS CU3 (cont)Basis Reference(s):
: 1. NEI 99-01 Rev 6, CU42. UFSAR Section 8.3.2, DC Power Systems3. DBD P-L-01A, 125/250 VDC System4. E-1(2)FA Loss of Division I Safeguard 125/250V DC BUS 1FA5. E-1(2)FB Loss of Division II Safeguard 125/250V DC BUS 1FB6. E-1(2)FC Loss of Division III Safeguard 125/250V DC BUS 1FC7. E-1(2)FD Loss of Division IV Safeguard 125/250V DC BUS 1FDMonth 20XXLGS 3-110EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS CU4Initiating Condition:
Loss of all onsite or offsite communications capabilities.
Operating Mode Applicability:
4,5, DEmergency Action Level (EAL):1. Loss of ALL Table C1 Onsite communications capability affecting the ability toperform routine operations.
OR2. Loss of ALL Table Cl Offsite communication capability affecting the ability toperform offsite notifications.
OR3. Loss of ALL Table C1 NRC communication capability affecting the ability toperform NRC notifications.
Table C1 Communications Capability System Onsite Offsite NRCStation Radio XPlant Public Address (PA) XPrelude System X XStation Phones X X XSatellite Phones X X XNARS XHPN X XENS X XBasis:This IC addresses a significant loss of on-site,
: offsite, or NRC communications capabilities.
While not a direct challenge to plant or personnel safety, this eventwarrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.This IC should be assessed only when extraordinary means are being utilized to makecommunications possible (e.g., use of non-plant, privately owned equipment, relaying ofon-site information via individuals or multiple radio transmission points, individuals beingsent to offsite locations, etc.).EAL #1 BasisAddresses a total loss of the communications methods used in support of routine plantoperations.
Month 20XXLGS 3-111EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS CU4 (cont)Basis (cont):EAL #2 BasisAddresses a total loss of the communications methods used to notify all OROs of anemergency declaration.
The OROs referred to here are listed in procedure EP-MA-1 14-100-F-01, State / Local Event Notification Form.EAL #3 BasisAddresses a total loss of the communications methods used to notify the NRC of anemergency declaration.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, CU52. UFSAR Section 9.5.2, Communication Systems3. SE-12 Loss of Communications Month 20XXLGS 3-112EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS CA5Initiating Condition:
Inability to maintain the plant in cold shutdown.
Operating Mode Applicability:
4,5Emergency 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 rise in RCS temperature
> 200OF due to loss of decay heatremoval for > Table C2 duration.
Table C2 RCS Heat-up Duration Thresholds RCS Containment Closure Heat-upStatus Status DurationIntact Not Applicable 60 minutes*Not Intact Established 20 minutes*Not Established 0 minutes* If an RCS heat removal system is in operation withinthis time frame and RCS temperature is being reduced,then EAL #1 is not applicable.
OR2. UNPLANNED RPV pressure rise > 10 psig as a result of temperature rise due toloss of decay heat removal.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.CONTAINMENT CLOSURE:
The procedurally defined conditions or actions taken tosecure containment (primary or secondary) and its associated structures,
: systems, andcomponents as a functional barrier to fission product release under shutdownconditions.
RCS is intact when the RCS pressure boundary is in its normal condition for the ColdShutdown mode of operation (e.g. no freeze seals, or steam line nozzle plugs, etc.).Month 20XXLGS 3-113EP-AA-1008 (Revision XX)
I imariek rZgznarntin Atntinn AnnoyI=valrn Mm-latarI im~riri,
(~n~r2tinn
~t2tinn Ann~v FvMnn NmmuIc~rRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS CA5 (cont)Basis (cont):This IC addresses conditions involving a loss of decay heat removal capability or anaddition of heat to the RCS in excess of that which can currently be removed.
Eithercondition represents an actual or potential substantial degradation of the level of safetyof the plant.A momentary UNPLANNED excursion above the Technical Specification cold shutdowntemperature limit when the heat removal function is available does not warrant aclassification.
The RCS Heat-up Duration Thresholds table addresses a rise in RCS temperature when CONTAINMENT CLOSURE is established but the RCS is not intact. The 20-minute criterion was included to allow time for operator action to address thetemperature rise.The RCS Heat-up Duration Thresholds table also addresses a rise in RCS temperature with the RCS intact. The status of CONTAINMENT CLOSURE is not crucial in thiscondition since the intact RCS is providing a high pressure barrier to a fission productrelease.
The 60-minute time frame should allow sufficient time to address thetemperature rise without a substantial degradation in plant safety.Finally, in the case where there is a rise in RCS temperature, the RCS is not intact , andCONTAINMENT CLOSURE is not established, no heat-up duration is allowed (i.e., 0minutes).
This is because 1) the evaporated reactor coolant may be released directlyinto the Containment atmosphere and subsequently to the environment, and 2) there isreduced reactor coolant inventory above the top of irradiated fuel.EAL #2 provides a pressure-based indication of RCS heat-up.Escalation of the emergency classification level would be via IC CS6 or RS1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, CA32. Technical Specifications LCO 3.6.5.1, Reactor Enclosure Secondary Containment Integrity
: 3. Technical Specifications Table 1.2, Operational Conditions
: 4. DBD L-S-16, Reactor Instrumentation System (RIS)5. UFSAR Section 6.2, Containment Systems6. UFSAR Section 6.3, Emergency Core Cooling Systems7. Technical Specifications LCO 3.6.1.1, Primary Containment Integrity
: 8. ST-6-107-640
: 9. ST-6-107-641
: 10. GP-6.2, Shutdown Operations-Shutdown Conditions Tech Spec ActionsMonth 20XXLGS 3-114EP-AA-1008 (Revision XX)
Limerick Generating Station Annexl=xelon NuclearExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS CU5Initiating Condition:
UNPLANNED rise in RCS temperature Operating Mode Applicability:
4,5Emergency 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 rise in RCS temperature
> 200OF due to loss of decay heatremoval.OR2. Loss of the following for >15 minutes." ALL RCS temperature indications AND* ALL RPV water level indications 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.CONTAINMENT CLOSURE:
The procedurally defined conditions or actions taken tosecure containment (primary or secondary) and its associated structures,
: systems, andcomponents as a functional barrier to fission product release under shutdownconditions.
This IC addresses an UNPLANNED rise in RCS temperature above the Technical Specification cold shutdown temperature limit, or the inability to determine RCStemperature and level, represents a potential degradation of the level of safety of theplant. If the RCS is not intact and CONTAINMENT CLOSURE is not established duringthis event, the Emergency Director should also refer to IC CA5.RCS is intact when the RCS pressure boundary is in its normal condition for the ColdShutdown mode of operation (e.g. no freeze seals, or steam line nozzle plugs, etc.).A momentary UNPLANNED excursion above the Technical Specification cold shutdowntemperature limit when the heat removal function is available does not warrant aclassification.
Month 20XXLGS 3-115EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexI:xelon NuclearExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS CU5 (cont)Basis (cont):EAL #1 involves a loss of decay heat removal capability, or an addition of heat to theRCS in excess of that which can currently be removed, such that reactor coolanttemperature cannot be maintained below the cold shutdown temperature limit specified in Technical Specifications.
During this condition, there is no immediate threat of fueldamage because the core decay heat load has been reduced since the cessation ofpower operation.
During an outage, the level in the reactor vessel will normally be maintained above thereactor vessel flange. Refueling evolutions that lower water level below the reactorvessel flange are carefully planned and controlled.
A loss of forced decay heat removalat reduced inventory may result in a rapid rise in reactor coolant temperature depending on the time after shutdown.
EAL #2 reflects a condition where there has been a significant loss of instrumentation capability necessary to monitor RCS conditions and operators would be unable tomonitor key parameters necessary to assure core decay heat removal.
During thiscondition, there is no immediate threat of fuel damage because the core decay heatload has been reduced since the cessation of power operation.
Fifteen minutes was selected as a threshold to exclude transient or momentary lossesof indication.
Escalation to Alert would be via IC CA6 based on an inventory loss or IC CA5 based onexceeding plant configuration-specific time criteria.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, CU32. T-102, Primary Containment Control -Bases3. DBD L-S-16, Reactor Instrumentation System (RIS)4. ST-6-107-640-*
RX Vessel Temperature and Pressure Monitoring
: 5. GP-6.1 U/1(U/2)
Shutdown Operations
-Refueling, Core Alteration and CoreOff-Loading
: 6. ST-6-107-641-*
RX Vessel Temperature and Pressure Monitoring with no RHRShutdown Cooling Loops in Operation
: 7. GP-6.2, Shutdown Operations-Shutdown Conditions Tech Spec ActionsMonth 20XXLGS 3-116EP-AA-1008 (Revision XX)
F=Yplnn Limeric~k Generatinn Station AnnexFxnnNiIAm RECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS 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 thatthe applicable time has been exceeded, or will likely be exceeded.
: 1. a. RPV water level < -161 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* ANY Table C5 Refuel Floor Area Radiation Monitor >3 R/hr.ANDc. ANY Containment Challenge Indication (Table C4)Table C3 Indications of RCS Leakage" UNPLANNED floor or equipment sump level rise** UNPLANNED Suppression Pool level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.
Month 20XXLGS 3-117EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS CG6 (cont)Emergency Action Level (EAL) (cont):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 > T-103 / SAMP Max SafeOp Value (MSO).* if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency is not required.
Table C5Refuel Floor ARM's" RIS29-M1-1(2)K600, Drywell Head Laydown" RIS30-Ml
-1 (2)K600, Dryer / Separator Area* RIS31-Mi-1(2)K600, Spent Fuel Pool* RIS32-M1-1(2)K600, New Fuel storage Vault* RIS33-M1-1(2)K600, Pool Plug LaydownBasis:UNPLANNED:
A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.IMMINENT:
The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.CONTAINMENT CLOSURE:
The procedurally defined conditions or actions taken tosecure containment (primary or secondary for BWR) and its associated structures,
: systems, and components as a functional barrier to fission product release undershutdown conditions.
Month 20XXLGS 3-118EP-AA-1008 (Revision XX)
Limerick Generatinq Station AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS CG6 (cont)Basis (cont):This IC addresses the inability to restore and maintain reactor vessel level above thetop of active fuel with containment challenged.
This condition represents actual orIMMINENT substantial core degradation or melting with potential for loss of containment integrity.
Releases can be reasonably expected to exceed EPA Protective ActionGuidelines (PAG) exposure levels offsite for more than the immediate site area.Following an extended loss of core decay heat removal and inventory makeup, decayheat will cause reactor coolant boiling and a further reduction in reactor vessel level. IfRCS/reactor vessel level cannot be restored, fuel damage is probable.
With CONTAINMENT CLOSURE not established, there is a high potential for a directand unmonitored release of radioactivity to the environment.
If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.
The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at thelower deflagration limit). A hydrogen burn will raise containment pressure and couldresult in collateral equipment damage leading to a loss of containment integrity.
Ittherefore represents a challenge to Containment integrity.
In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to acore uncovery could result in an explosive gas mixture in containment.
If all installed hydrogen gas monitors are out-of-service during an event leading to fuel claddingdamage, it may not be possible to obtain a containment hydrogen gas concentration reading as ambient conditions within the containment will preclude personnel access.During periods when installed containment hydrogen gas monitors are out-of-service, operators may use the other listed indications to assess whether or not containment ischallenged.
In EAL 2.a the 30-minute criterion is tied to a readily recognizable event start time (i.e.,the total loss of ability to monitor level), and allows sufficient time to monitor, assess andcorrelate reactor and plant conditions to determine if core uncovery has actuallyoccurred (i.e., to account for various accident progression and instrumentation uncertainties).
It also allows sufficient time for performance of actions to terminate
: leakage, recover inventory control/makeup equipment and/or restore level monitoring.
The inability to monitor RPV water level may be caused by instrumentation and/orpower failures, or water level dropping below the range of available instrumentation.
Ifwater level cannot be monitored, operators may determine that an inventory loss isoccurring by observing changes in sump and/or tank levels. Sump and/or tank levelchanges must be evaluated against other potential sources of water flow to ensure theyare indicative of leakage from the RPV.Month 20XXLGS 3-119EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CG6 (cont)Basis (cont):These EALs address concerns raised by Generic Letter 88-17, Loss of Decay HeatRemoval; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in theUnited States; and NUMARC 91-06, Guidelines for Industry Actions to AssessShutdown Management.
Basis Reference(s):
: 1. NEI 99-01 Rev 6, CG12. T-102 Primary Containment Control -Bases3. T-103 Secondary Containment Control -Bases4. DBD P-S-20, Neutron Monitoring System5. DBD L-T-02, Containment, Section 3.2.146. Technical Specifications 3.6.1.1, Primary Containment Integrity
: 7. Technical Specifications 3.6.5.1, Reactor Enclosure Secondary Containment Integrity
: 8. UFSAR section 6.2.1.1.3.1, Summary Evaluation
: 9. EP-AEL-0501, Estimation of Radiation Monitor Readings Indicating CoreUncovery During Refuel10. T-101 RPV Control -Bases11. SAMP-2, Containment and Radioactivity Release ControlMonth 20XXLGS 3-120EP-AA-1008 (Revision XX)
 
I imerie-k (GAnerntinn Station Annex FvaInn NuclekarRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS CS6Initiating Condition:
Loss of RPV inventory affecting core decay heat removal capability.
Operating Mode Applicability:
4,5Emergency Action Level (EAL):Note:e The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.
: 1. With CONTAINMENT CLOSURE not established, RPV water level < -129inchesOR2. With CONTAINMENT CLOSURE established, RPV water level < -161 inches(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 core uncovery.
OR* ANY Table C5 Refuel Floor Area Radiation Monitor >3 R/hr.Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Suppression Pool level rise** UNPLANNED vessel make up rate rise" Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.
Month 20XXLGS 3-121EP-AA-1008 (Revision XX)
Limeric~k Gener~atina Station Annex Fxelnn Nucler~IRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS CS6 (cont)Emergency Action Level (EAL) (cont):Table C5Refuel Floor ARM's* RIS29-M1-1(2)K600, Drywell Head Laydown* RIS30-M1-1(2)K600, Dryer / Separator Area" RIS31-M1-1(2)K600, Spent Fuel Pool* RIS32-M1-1(2)K600, New Fuel storage Vault* RIS33-M1-1(2)K600, Pool Plug LaydownBasis:UNPLANNED:
A parameter change or an event that is not 1) the result of an intendedevolution or 2) an expected plant response to a transient.
The cause of the parameter change or event may be known or unknown.CONTAINMENT CLOSURE:
The procedurally defined conditions or actions taken tosecure containment (primary or secondary for BWR) and its associated structures,
: systems, and components as a functional barrier to fission product release undershutdown conditions.
The lost inventory may be due to a RCS component
: failure, a loss of configuration control or prolonged boiling of reactor coolant.
These conditions entail major failures ofplant functions needed for protection of the public and thus warrant a Site AreaEmergency declaration.
Following an extended loss of core decay heat removal and inventory makeup, decayheat will cause reactor coolant boiling and a further reduction in reactor vessel level. IfRCS/reactor vessel level cannot be restored, fuel damage is probable.
Outage/shutdown contingency plans typically provide for re-establishing or verifying CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory controlfunctions.
The difference in the specified RCS/reactor vessel levels of EALs #1 and #2reflect the fact that with CONTAINMENT CLOSURE established, there is a lowerprobability of a fission product release to the environment.
Month 20XXLGS 3-122EP-AA-1008 (Revision XX) ime~rick (Generatinn Station Annex Fyalon N,~rIippr RECOGNITION CATEGORYCOLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CS6 (cont)Basis (cont):In EAL #3.a, the 30-minute criterion is tied to a readily recognizable event start time(i.e., the total loss of ability to monitor level), and allows sufficient time to monitor,assess and correlate reactor and plant conditions to determine if core uncovery hasactually occurred (i.e., to account for various accident progression and instrumentation uncertainties).
It also allows sufficient time for performance of actions to terminate
: leakage, recover inventory control/makeup equipment and/or restore level monitoring.
The inability to monitor RPV water level may be caused by instrumentation and/orpower failures, or water level dropping below the range of available instrumentation.
Ifwater level cannot be monitored, operators may determine that an inventory loss isoccurring by observing changes in sump and/or tank levels. Sump and/or tank levelchanges must be evaluated against other potential sources of water flow to ensure theyare indicative of leakage from the RPV.These EALs address concerns raised by Generic Letter 88-17, Loss of Decay HeatRemoval; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in theUnited States; and NUMARC 91-06, Guidelines for Industry Actions to AssessShutdown Management.
Escalation of the emergency classification level would be via IC CG6 or RG1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, CS12. Technical Specification Table 3.3.2-23. T-101 RPV Control -Bases4. T-102 Primary Containment Control -Bases5. T-103 Secondary Containment Control -Bases6. DBD P-S-20, Neutron Monitoring System7. DBD L-T-02, Containment, Section 3.2.148. Technical Specifications 3.6.1.1, Primary Containment Integrity
: 9. Technical Specifications 3.6.5.1, Reactor Enclosure Secondary Containment Integrity
: 10. DBD L-S-34, Radwaste SystemMonth 20XXLGS 3-123EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS 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 thatthe applicable time has been exceeded, or will likely be exceeded.
: 1. Loss of RPV inventory as indicated by level < -38 inches.OR2. a. RPV water level unknown for > 15 minutes.ANDb. Loss of RPV inventory per Table C3 indications.
Table C3 Indications of RCS Leakage" UNPLANNED floor or equipment sump level rise*" UNPLANNED Suppression Pool level rise*" UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.
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.This IC addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier).
Thiscondition represents a potential substantial reduction in the level of plant safety.EAL #1 BasisA lowering of water level below -38 inches indicates that operator actions have not beensuccessful in restoring and maintaining RPV water level. The heat-up rate of thecoolant will rise as the available water inventory is reduced.
A continuing decrease inwater level will lead to core uncovery.
Month 20XXLGS 3-124EP-AA-1008 (Revision XX)
 
rLimeric~k Generatinn Station Annex FxeInn NuclerIAm RECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS CA6 (cont)Basis (cont):Although
: related, EAL #1 is concerned with the loss of RCS inventory and not thepotential concurrent effects on systems needed for decay heat removal (e.g., loss of aResidual Heat Removal suction point). A rise in RCS temperature caused by a loss ofdecay heat removal capability is evaluated under IC CA5.EAL #2 BasisThe inability to monitor RPV water level may be caused by instrumentation and/orpower failures, or water level dropping below the range of available instrumentation.
Ifwater level cannot be monitored, operators may determine that an inventory loss isoccurring by observing changes in sump and/or tank levels. Sump and/or tank levelchanges must be evaluated against other potential sources of water flow to ensure theyare indicative of leakage from the RPV.The 15-minute duration for the loss of level indication was chosen because it is half ofthe EAL duration specified in IC CS6If the RPV water level continues to lower, then escalation to Site Area Emergency wouldbe via IC CS6.Basis Reference(s):
: 1. NEI 99-01 Rev 6, CA12. Technical Specification Table 3.3.2-23. Technical Specification 3.4.3, Reactor Coolant System Leakage4. ARC-MCR-213-E3 Div 1 Reactor Lo-Lo-Lo Level5. DBD L-S-16, Reactor Instrumentation System (RIS)6. DBD L-S-34, Radwaste System7. T-102 Primary Containment ControlMonth 20XXLGS 3-125EP-AA-1008 (Revision XX) mvimmriemk vnermtinn Stamtion Annex Fva.nn MllutlorRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS 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 thatthe applicable time has been exceeded, or will likely be exceeded.
: 1. UNPLANNED loss of reactor coolant results in the inability to restore and maintainRPV water level to above the procedurally established lower limit for > 15minutes.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 Suppression Pool level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.
Month 20XXLGS 3-126EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexExelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS CU6 (cont)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.This IC addresses the inability to restore and maintain water level to a requiredminimum level (or the lower limit of a level band), or a loss of the ability to monitor RPVwater level concurrent with indications of coolant leakage.
Either of these conditions isconsidered to be a potential degradation of the level of safety of the plant.The procedurally established lower limit is not an operational band established abovethe procedural limit to allow for operator action prior to exceeding the procedural limit,but it is the procedurally established lower limit.Refueling evolutions that decrease RCS water inventory are carefully planned andcontrolled.
An UNPLANNED event that results in water level decreasing below aprocedurally required limit warrants the declaration of an Unusual Event due to thereduced water inventory that is available to keep the core covered.EAL #1 BasisRecognizes that the minimum required RPV water level can change several timesduring the course of a refueling outage as different plant configurations and systemlineups are implemented.
This EAL is met if the minimum level, specified for the currentplant conditions, cannot be maintained for 15 minutes or longer. The minimum level istypically specified in the applicable operating procedure but may be specified in anothercontrolling document.
The 15-minute threshold duration allows sufficient time for prompt operator actions torestore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level.EAL #2 BasisAddresses a condition where all means to determine RPV water level have been lost.In this condition, operators may determine that an inventory loss is occurring byobserving changes in sump and/or tank levels. Sump and/or tank level changes mustbe evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RPV.Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA6 or CA5.Month 20XXLGS 3-127EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYCOLD SHUTDOWN
/ REFUELING SYSTEM MALFUNCTIONS CU6 (cont)Basis Reference(s):
: 1. NEI 99-01, Rev. 6 CU12. Technical Specification Table 3.3.2-23. ST-6-107-596-1 Drywell Floor Drain Sump/Equipment Drain Tank Surveillance
: 4. Technical Specification 3.4.3, Reactor Coolant Leakage5. Technical Specifications 3.9.8, Water Level -Reactor Vessel6. DBD L-S-34, Radwaste System7. OT-101 High Drywell Pressure8. T-102 Primary Containment
: Control, Table DW/T-19. GP-6.1 U/1(2) Shutdown Operations
-Refuel Core Alterations
& Core Off-loading
: 10. DBD L-S-16, Reactor Instrumentation System (RIS)Month 20XXLGS 3-128EP-AA-1008 (Revision XX)
Limeric~k (Generatinn Stamtion Annex FvAImnn N~tlorIAi RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHG1Initiating 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 HOSITLE ACTION is occurring orhas 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 H1 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)Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs,
: vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included.
HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE:
A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE:
An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.IMMINENT:
The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.Month 20XXLGS 3-129EP-AA-1008 (Revision XX)
I irnarink rZpnprnfin Rfnfinn Annoymlr n khr-lmorI I rir~Ic (~na~r2tinn
~t2tinn Ann~v ~v~Iv~n M.ur~In~r RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHG1 (cont)Basis (cont):HOSTILE FORCE: Any individuals who are engaged in a determined
: assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.
This IC addresses an event in which a HOSTILE FORCE has taken physical control ofthe facility to the extent that the plant staff can no longer operate equipment necessary to maintain key safety functions.
It also addresses a HOSTILE ACTION leading to aloss of physical control that results in actual or IMMINENT damage to spent fuel due to1) damage to a spent fuel pool cooling system (e.g., pumps, heat exchangers,
: controls, etc.) or, 2) loss of spent fuel pool integrity such that sufficient water level cannot bemaintained.
Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].
Basis Reference(s):
: 1. NEI 99-01, Rev. 6 HG15. Station Security Plan -Appendix CMonth 20XXLGS 3-130EP-AA-1008 (Revision XX)
N rLimeric~k (GAneratinn Station Annex Fwainn Nw-lorIAa RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS1Initiating Condition:
HOSTILE ACTION within the PROTECTED AREA.Operating Mode Applicability:
1,2,3,4,5, DEmergency Action Level (EAL):A notification from the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the PROTECTED AREA.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs,
: vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included.
HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE:
A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE:
An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.HOSTILE FORCE: Any individuals who are engaged in a determined
: assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.
INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI):
A complex that isdesigned and constructed for the interim storage of spent nuclear fuel and otherradioactive materials associated with spent fuel storage.This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTED AREA. This event will require rapid response and assistance due to the possibility fordamage to plant equipment.
Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].
Month 20XXLGS 3-131EP-AA-1 008 (Revision XX)
I imerick Ganiarnfin Afnfinn AnnnyFyc~lnn Nid-lonrI in'IArir~k
(~n~r~tinn
~*~tinn Ann~v Fw~Inn Nmma~I~2r RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS1 (cont)Basis (cont):As time and conditions allow, these events require a heightened state of readiness bythe plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering).
The Site Area Emergency declaration will mobilize OROresources and have them available to develop and implement public protective actionsin the unlikely event that the attack is successful in impairing multiple safety functions.
This IC does not apply to a HOSTILE ACTION directed at an ISFSI PROTECTED AREA located outside the plant PROTECTED AREA; such an attack should beassessed using IC HAl. It also does not apply to incidents that are accidental events,acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by aHOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters,physical disputes between employees, etc. Reporting of these types of events isadequately addressed by other EALs, or the requirements of 10 CFR &sect; 73.71 or 10 CFR&sect; 50.72.Escalation of the emergency classification level would be via IC HG1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, HS13. Station Security Plan -Appendix CMonth 20XXLGS 3-132EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexI=xelon Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA1Initiating Condition:
HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threatwithin 30 minutes.Operating Mode Applicability:
1, 2,3,4,5, DEmergency Action Level (EAL):1. A validated notification from NRC of an aircraft attack threat < 30 minutes fromthe site.OR2. Notification by the Security Force that a HOSTILE ACTION is occurring or hasoccurred within the OWNER CONTROLED AREA.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs,
: vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included.
HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE:
A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE:
An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.OWNER CONTROLLED AREA (OCA): The property associated with the station andowned by the company.
Access is normally limited to persons entering for officialbusiness.
PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.HOSTILE FORCE: Any individuals who are engaged in a determined
: assault, overtly orby stealth and deception, equipped with suitable weapons capable of killing, maiming,or causing destruction.
This IC addresses the occurrence of a HOSTILE ACTION within the OWNERCONTROLLED AREA or notification of an aircraft attack threat. This event will requirerapid response and assistance due to the possibility of the attack progressing to thePROTECTED AREA, or the need to prepare the plant and staff for a potential aircraftimpact.Month 20XXLGS 3-133EP-AA-1008 (Revision XX)
Limerick Generatinci Station AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA1 (cont)Basis (cont):Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].
As time and conditions allow, these events require a heightened state of readiness bythe plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering).
The Alert declaration will also heighten the awareness ofOffsite Response Organizations, allowing them to be better prepared should it benecessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE.Examples include the crash of a small aircraft, shots from hunters, physical disputesbetween employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR &sect; 73.71 or 10 CFR &sect; 50.72.EAL #1 BasisAddresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes.
The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in aheightened state of readiness.
This EAL is met when the threat-related information hasbeen validated in accordance with SE-23, Security Threat.EAL #2 BasisApplicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNERCONTROLLED AREA. This includes any action directed against an ISFSI that islocated outside the plant PROTECTED AREA.The NRC Headquarters Operations Officer (HOO) will communicate to the licensee ifthe threat involves an aircraft.
The status and size of the plane may be provided byNORAD through the NRC.In some cases, it may not be readily apparent if an aircraft impact within the OWNERCONTROLLED AREA was intentional (i.e., a HOSTILE ACTION).
It is expected, although not certain, that notification by an appropriate Federal agency to the site wouldclarify this point. In this case, the appropriate federal agency is intended to be NORAD,FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.Escalation of the emergency classification level would be via IC HSI.Month 20XXLGS 3-134EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA1 (cont)Basis Reference(s):
: 1. NEI 99-01 Rev 6, HA12. Station Security Plan -Appendix C3. SE-23 Security ThreatMonth 20XXLGS 3-135EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU1Initiating Condition:
Confirmed SECURITY CONDITION or threat.Operating Mode Applicability:
1,2,3,4,5, DEmergency Action Level (EAL):1. Notification of a credible security threat directed at the site as determined perSY-AA-101-132, Security Assessment and Response to Unusual Activities.
OR2. A validated notification from the NRC providing information of an aircraft threat.OR3. Notification by the Security Force of a SECURITY CONDITION that does notinvolve a HOSTILE ACTION.Basis:SECURITY CONDITION:
Any Security Event as listed in the approved securitycontingency plan that constitutes a threat/compromise to site security, threat/risk to sitepersonnel, or a potential degradation to the level of safety of the plant. A SECURITYCONDITION does not involve a HOSTILE ACTIONSAFETY 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.
HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs,
: vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included.
HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE:
A person(s) held as leverage against the station to ensure that demandswill be met by the station.PROJECTILE:
An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEMequipment, and thus represent a potential degradation in the level of plant safety.Security events which do not meet one of these EALs are adequately addressed by therequirements of 10 CFR &sect; 73.71 or 10 CFR &sect; 50.72. Security events assessed asHOSTILE ACTIONS are classifiable under ICs HA1, HS1 and HG1.Month 20XXLGS 3-136EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexI=xelon NuclearExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHUl (cont)Basis (cont):Timely and accurate communications between Security Shift Supervision and theControl Room is essential for proper classification of a security-related event.Classification of these events will initiate appropriate threat-related notifications to plantpersonnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12,Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].
EAL #1 BasisAddresses the receipt of a credible security threat. The credibility of the threat isassessed in accordance with SY-AA-101-132, Security Assessment and Response toUnusual Activities.
EAL #2 BasisAddresses the threat from the impact of an aircraft on the plant. The NRCHeadquarters Operations Officer (HOO) will communicate to the licensee if the threatinvolves an aircraft.
The status and size of the plane may also be provided by NORADthrough the NRC. Validation of the threat is performed in accordance with SE-23,Security Threat.EAL #3 BasisReferences Security Force because these are the individuals trained to confirm that asecurity event is occurring or has occurred.
Training on security event confirmation andclassification is controlled due to the nature of Safeguards and 10 CFR &sect; 2.39information.
Escalation of the emergency classification level would be via IC HA1.Basis Reference(s):
: 1. NEI 99-01 Rev 6, HU12. Station Security Plan -Appendix C3. SY-AA-1 01-132, Security Assessment and Response to Unusual Activities Month 20XXLGS 3-137EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS2Initiating Condition:
Inability to control a key safety function from outside the Control Room.Operating Mode Applicability:
1,2,3,4,5, DEmergency Action Level (EAL):Note:The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.
: 1. A Control Room evacuation has resulted in plant control being transferred from theControl Room to alternate locations per:" SE-1, Remote ShutdownOR* SE-6, Alternate Remote ShutdownAND2. Control of ANY Table H1 key safety function is not reestablished in < 15 minutes.Table H1 Safety Functions
* Reactivity Control (ability to shut down the reactor and keep it shutdown)
* RPV Water Level (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)Basis:The time period to establish control of the plant starts when either:a. Control of the plant is no longer maintained in the Main Control RoomORb. The last Operator has left the Main Control Room.This IC addresses an evacuation of the Control Room that results in transfer of plantcontrol to alternate locations, and the control of a key safety function cannot bereestablished in a timely manner. The failure to gain control of a key safety functionfollowing a transfer of plan control to alternate locations is a precursor to a challenge toany fission product barriers within a relatively short period of time.Month 20XXLGS 3-138EP-AA-1008 (Revision XX)
I imaria-Ie r~onarntinn
-qttinn AnnovFvalem N"nlanra -RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS2 (cont)Basis (cont):The determination of whether or not "control" is established at the remote safeshutdown location(s) is based on Emergency Director judgment.
The Emergency Director is expected to make a reasonable, informed judgment within 15 minuteswhether or not the operating staff has control of key safety functions from the remotesafe shutdown location(s).
Escalation of the emergency classification level would be via IC FG1 or CG6.Basis Reference(s):
: 1. NEI 99-01, Rev 6 HS62. SE-1, Remote Shutdown3. SE-6, Alternate Remote ShutdownMonth 20XXLGS 3-139EP-AA-1 008 (Revision XX)
Limerick Generating Station AnnexNuclearExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA2Initiating Condition:
Control Room evacuation resulting in transfer of plant control to alternate locations.
Operating Mode Applicability:
1,2,3, 4,5, DEmergency Action Level (EAL):A Control Room evacuation has resulted in plant control being transferred from theControl Room to alternate locations per:" SE-1, Remote ShutdownOR" SE-6, Alternate Remote ShutdownBasis:This IC addresses an evacuation of the Control Room that results in transfer of plantcontrol to alternate locations outside the Control Room. The loss of the ability to controlthe plant from the Control Room is considered to be a potential substantial degradation in the level of plant safety.Following a Control Room evacuation, control of the plant will be transferred to alternate shutdown locations.
The necessity to control a plant shutdown from outside the ControlRoom, in addition to responding to the event that required the evacuation of the ControlRoom, will present challenges to plant operators and other on-shift personnel.
Activation of the ERO and emergency response facilities will assist in responding tothese challenges.
Escalation of the emergency classification level would be via IC HS2.Basis Reference(s):
: 1. NEI 99-01, Rev 6 HA62. SE-1, Remote Shutdown3. SE-6, Alternate Remote ShutdownMonth 20XXLGS 3-140EP-AA-1008 (Revision XX)
 
Simeric~k Generatinn Stt~ion Annex ExueInn Nucler~IRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU3Initiating Condition:
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 thatthe applicable time has been exceeded, or will likely be exceeded.
: 1. A FIRE in ANY Table H2 area is not extinguished in < 15-minutes of ANY of thefollowing FIRE detection indications:
S0Report from the field (i.e., visual observation)
Receipt of multiple (more than 1) fire alarms or indications Field verification of a single fire alarmTable H2 Vital Areas* Reactor Enclosure (when inerted the Drywell is exempt)" Control Enclosure
* Diesel Generator Enclosure
* Spray Pond Pump House / Spray NetworkOR2. a. Receipt of a single fire alarm in ANY Table H2 area (i.e., no other indications of a FIRE).ANDb. The existence of a FIRE is not verified in < 30 minutes of alarm receipt.OR3 A FIRE within the plant PROTECTED AREA not extinguished in < 60-minutes ofthe initial report, alarm or indication.
OR4 A FIRE within the plant PROTECTED AREA that requires firefighting support byan offsite fire response agency to extinguish.
Month 20XXLGS 3-141EP-AA-1008 (Revision XX)
I imnrir~k
(~AnArMinn
~t~tinn AnnAYN Limerick Generatinn Station Annex Exi-Inn NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU3 (cont)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.
PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.This IC addresses the magnitude and extent of FIRES that may be indicative of apotential degradation of the level of safety of the plant.EAL #1 BasisThe intent of the 15-minute duration is to size the FIRE and to discriminate againstsmall FIRES that are readily extinguished (e.g., smoldering waste paper basket).
Inaddition to alarms, other indications of a FIRE could be a drop in fire main pressure, automatic activation of a suppression system, etc.Upon receipt, operators will take prompt actions to confirm the validity of an initial firealarm, indication, or report. For EAL assessment
: purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and notthe time that a subsequent verification action was performed.
Similarly, the fire durationclock also starts at the time of receipt of the initial alarms, indication or report.EAL #2 BasisThis EAL addresses receipt of a single fire alarm, and the existence of a FIRE is notverified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt,operators will take prompt actions to confirm the validity of a single fire alarm. For EALassessment
: purposes, the 30-minute clock starts at the time that the initial alarm wasreceived, and not the time that a subsequent verification action was performed.
A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional timeis allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, andabsent information to the contrary, it is assumed that an actual FIRE is in progress.
Month 20XXLGS 3-142EP-AA-1008 (Revision XX)
I imarir-k rganarntin At2tinn AnnoyI=voln~n I mrii (nrtin~tain n~v~a~n*aIa RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU3 (cont)Basis (cont):If an actual FIRE is verified by a report from the field, then EAL #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within15-minutes of the report. If the alarm is verified to be due to an equipment failure or aspurious activation, and this verification occurs within 30-minutes of the receipt of thealarm, then this EAL is not applicable and no emergency declaration is warranted.
EAL #3 BasisIn addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plantPROTECTED AREA not extinguished within 60-minutes may also potentially degradethe level of plant safety.EAL #4 BasisIf a FIRE within the plant PROTECTED AREA is of sufficient size to require a responseby an offsite firefighting agency (e.g., a local town Fire Department),
then the level ofplant safety is potentially degraded.
The dispatch of an offsite firefighting agency to thesite requires an emergency declaration only if it is needed to actively support firefighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish.
Declaration is not necessary if the agency resources are placed on stand-by, orsupporting post-extinguishment recovery or investigation actions.Basis-Related Requirements from Appendix RAppendix R to 10 CFR 50, states in part:Criterion 3 of Appendix A to this part specifies that "Structures,
: systems, andcomponents important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires andexplosions."
When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safetybecause damage to them can lead to core damage resulting from loss of coolantthrough boil-off.
Because fire may affect safe shutdown systems and because the loss of functionof systems used to mitigate the consequences of design basis accidents underpost-fire conditions does not per se impact public safety, the need to limit firedamage to systems required to achieve and maintain safe shutdown conditions isgreater than the need to limit fire damage to those systems required to mitigatethe consequences of design basis accidents.
Month 20XXLGS 3-143EP-AA-1008 (Revision XX)
 
rI imerirk r~enprgntinn Atption Annax Expinn NuirclnrRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU3 (cont)Basis (cont):In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train (G.2.c).
As used in EAL #2, the 30-minutes to verify asingle alarm is well within this worst-case 1-hour time period.Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA2 or MA5.Basis Reference(s):
: 1. NEI 99-01, Rev 6 HU42. Specification NE-0294, "Fire Safe Shutdown Analysis Specification" Month 20XXLGS 3-144EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU4Initiating Condition:
Seismic event greater than OBE levels.Operating Mode Applicability:
1, 2,3,4,5, DEmergency Action Level (EAL):Seismic event > Operating Basis Earthquake (OBE) as indicated by:* ARC-MCR-00C693, WINDOW B1, OBE EXCEEDED alarmedOR* OBE red light is lit at panel 00C693Basis:This IC addresses a seismic event that results in accelerations at the plant site greaterthan those specified for an Operating Basis Earthquake (OBE)1.An earthquake greaterthan an OBE but less than a Safe Shutdown Earthquake (SSE)2 should have nosignificant impact on safety-related
: systems, structures and components; however,some time may be required for the plant staff to ascertain the actual post-event condition of the plant (e.g., performs walk-downs and post-event inspections).
Giventhe time necessary to perform walk-downs and inspections, and fully understand anyimpacts, this event represents a potential degradation of the level of safety of the plant.Event verification with external sources should not be necessary during or following anOBE. Earthquakes of this magnitude should be readily felt by on-site personnel andrecognized as a seismic event (e.g., typical lateral accelerations are in excess of 0.08g).The Shift Manager or Emergency Director may seek external verification if deemedappropriate (e.g., a call to the USGS, check internet news sources, etc.); however, theverification action must not preclude a timely emergency declaration.
Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA2 or MA5.Basis Reference(s):
: 1. NEI 99-01, Rev 6 HU22. SE-5, Earthquake
: 3. ARC-MCR-00C693 B1, OBE Exceeded1 An OBE is vibratory ground motion for which those features of a nuclear power plantnecessary for continued operation without undue risk to the health and safety of thepublic will remain functional.
An SSE is vibratory ground motion for which certain (generally, safety-related) structures,
: systems, and components must be designed to remain functional.
Month 20XXLGS 3-145EP-AA-1008 (Revision XX)
 
Simeric~k Gener~atinn Stamtion Annex Fxeinn Nuclea~rRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA5Initiating Condition:
Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.
Operating Mode Applicability:
1,2, 3, 4, 5, DEmergency Action Level (EAL):Note:* The Emergency Director should declare the event promptly upon determining thatthe applicable time has been exceeded, or will likely be exceeded.
: 1. Release of a toxic, corrosive, asphyxiant or flammable gas in a Table H3 area.Table H3Areas with Entry Related Mode Applicability Area Entry Related ModeApplicability Reactor Enclosure*
Modes 3, 4, and 5*Areas required to establish shutdown coolingAND2. Entry into the room or area is prohibited or impededBasis:This IC addresses an event involving a release of a hazardous gas that precludes orimpedes access to equipment necessary to transition the plant from normal plantoperation to cooldown and shutdown as specified in normal plant procedures.
Thiscondition represents an actual or potential substantial degradation of the level of safetyof the plant.Table H3 is a list of plant rooms or areas with entry-related mode applicability thatcontain equipment which require a manual/local action necessary to transition the plantfrom normal 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 or record keeping nature (e.g., normal rounds or routine inspections).
This Table does not include the Control Room since adequate engineered safety/design features are in place to preclude a Control Room evacuation due to the release of ahazardous gas.Month 20XXLGS 3-146EP-AA-1008 (Revision XX)
I imariek (Zanarnfin
-Qfn#itn AnngvF:,vAmlnn i,,e-lInmr I mri~ (nr~mn $4~h Anv vI~iMi,-I~
** ** *
* t* t* *r. **f l.RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA5 (cont)Basis (cont):An Alert declaration is warranted if entry into the affected room/area is, or may be,procedurally required during the plant operating mode in effect and the gaseous releasepreclude the ability to place shutdown cooling in service.
The emergency classification is not contingent upon whether entry is actually necessary at the time of the release.Evaluation of the IC and EAL do not require atmospheric sampling; it only requires theEmergency Director's judgment that the gas concentration in the affected room/area issufficient to preclude or significantly impede procedurally required access. Thisjudgment may be based on a variety of factors including an existing job hazard analysis, report of ill effects on personnel, advice from a subject matter expert or operating experience with the same or similar hazards.
Access should be considered as impededif extraordinary measures are necessary to facilitate entry of personnel into the affectedroom/area (e.g., requiring use of protective equipment, such as SCBAs, that is notroutinely employed).
An emergency declaration is not warranted if any of the following conditions apply.* The plant is in an operating mode different than the mode specified for the affectedroom/area (i.e., entry is not required during the operating mode in effect at the timeof the gaseous release).
For example, the plant is in Mode 1 when the gaseousrelease occurs, and the procedures used for normal operation, cooldown andshutdown do not require entry into the affected room until Mode 4." The gas release is a planned activity that includes compensatory measures whichaddress the temporary inaccessibility of a room or area (e.g., fire suppression system testing).
* The action for which room/area entry is required is of an administrative or 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.An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosedenvironment.
This reduces the concentration of oxygen below the normal level ofaround 19%, which can lead to breathing difficulties, unconsciousness or even death.This EAL does not apply to firefighting activities that generate smoke, that automatically or manually activate a fire suppression system in an area, or to intentional inerting ofcontainment.
Escalation of the emergency classification level would be via Recognition Category R, Cor F ICs.Basis Reference(s):
: 1. NE 99-01, Rev 6 HA5Month 20XXLGS 3-147EP-AA-1008 (Revision XX)
I imariek rpnprntinn Afiqfinn AnnoyF::valrn Nllr~la=r I im~rii-k
(~~n~r~atinn
~t~$inn Ann0w Fvg~Inn M..r~I0~r RECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU6Initiating 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 an offsiteevent involving hazardous materials (e.g., an offsite chemical spill or toxic gasrelease).
OR4. A hazardous event that results in on-site conditions sufficient to prohibit the plantstaff from accessing the site via personal vehicles.
Basis:PROTECTED AREA: An area that normally encompasses all controlled areas within thesecurity protected area fence.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 hazardous events that are considered to represent a potential degradation of the level of safety of the plant.Month 20XXLGS 3-148EP-AA-1008 (Revision XX)
Limeric~k (GAneratinn St~ation Annex FvAInn N"H~IanrRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU6 (cont)Basis (cont):EAL #1 BasisAddresses a tornado striking (touching down) within the Protected Area.EAL #2 BasisAddresses flooding of a building room or area that results in operators isolating power toa SAFETY SYSTEM component due to water level or other wetting concerns.
Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker orrelay trip). To warrant classification, operability of the affected component must berequired by Technical Specifications for the current operating mode. Manual isolation ofpower to a SAFETY SYSTEM component as a result of leakage is an event of lesserimpact and would be expected to cause small and localized damage. The consequence of this type of event is adequately assessed and addressed in accordance withTechnical Specifications.
EAL #3 BasisAddresses a hazardous materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel within the PROTECTED AREA.EAL #4 BasisAddresses a hazardous event that causes an on-site impediment to vehicle movementand significant enough to prohibit the plant staff from accessing the site using personalvehicles.
Examples of such an event include site flooding caused by a hurricane, heavyrains, up-river water releases, dam failure, etc., or an on-site train derailment blockingthe access road.This EAL is not intended to apply to routine impediments such as fog, snow, ice, orvehicle breakdowns or accidents, but rather to more significant conditions such as theHurricane Andrew strike on Turkey Point in 1992, the flooding around the CooperStation during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in2011.Escalation of the emergency classification level would be based on ICs in Recognition Categories R, F, M, H or C.Basis Reference(s):
: 1. NEI 99-01, Rev 6 HU32. UFSAR Section 3.4.1, Flood Protection
: 3. UFSAR Section 6.2.1.1.1, Design Bases4. SE-5 Earthquake 5 SE-4 Flood6. SE-9 Preparation for Severe WeatherMonth 20XXLGS 3-149EP-AA-1008 (Revision XX)
Limerick Generatina Station AnnexExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHG7Initiating Condition:
Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a GENERAL EMERGENCY.
Operating Mode Applicability:
1, 2, 3, 4, 5, DEmergency Action Level (EAL):Other conditions exist which in the judgment of the Emergency Director indicate thatevents are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILEACTION that results in an actual loss of physical control of the facility.
Releases can bereasonably expected to exceed EPA Protective Action Guideline exposure levels offsitefor more than the immediate site area.Basis:IMMINENT:
The trajectory of events or conditions is such that an EAL will be met withina relatively short period of time regardless of mitigation or corrective actions.HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs,
: vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included.
HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE:
A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE:
An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for aGeneral Emergency.
Basis Reference(s):
: 1. NEI 99-01, Rev 6 HG7Month 20XXLGS 3-150EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexExAIon Exelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHS7Initiating Condition:
Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of a SITE AREA EMERGENCY.
Operating Mode Applicability:
1, 2, 3, 4, 5, DEmergency Action Level (EAL):Other conditions exist which in the judgment of the Emergency Director indicate thatevents are in progress or have occurred which involve actual or likely major failures ofplant functions needed for protection of the public or HOSTILE ACTION that results inintentional damage or malicious acts, (1) toward site personnel or equipment that couldlead to the likely failure of or, (2) that prevent effective access to equipment needed forthe protection of the public. Any releases are not expected to result in exposure levelswhich exceed EPA Protective Action Guideline exposure levels beyond the siteboundary.
Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs,
: vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included.
HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE:
A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE:
An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for a SiteArea Emergency.
Basis Reference(s):
: 1. NEI 99-01, Rev 6 HS7Month 20XXLGS 3-151EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexNuclearExelon NuclearRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHA7Initiating Condition:
Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an ALERT.Operating Mode Applicability:
1, 2, 3, 4, 5, DEmergency Action Level (EAL):Other conditions exist which, in the judgment of the Emergency
: Director, indicate thatevents are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probablelife threatening risk to site personnel or damage to site equipment because of HOSTILEACTION. Any releases are expected to be limited to small fractions of the EPAProtective Action Guideline exposure levels.Basis:HOSTILE ACTION: An act toward a NPP or its personnel that includes the use ofviolent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee toachieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs,
: vehicles, or other devices used to deliver destructive force. Other actsthat satisfy the overall intent may be included.
HOSTILE ACTION should not beconstrued to include acts of civil disobedience or felonious acts that are not part of aconcerted attack on the NPP. Non-terrorism-based EALs should be used to addresssuch activities (i.e., this may include violent acts between individuals in the ownercontrolled area).HOSTAGE:
A person(s) held as leverage against the station to ensure that demandswill be met by the stationPROJECTILE:
An object directed toward a NPP that could cause concern for itscontinued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for anAlert.Basis Reference(s):
: 1. NEI 99-01, Rev 6 HA7Month 20XXLGS 3-152EP-AA-1008 (Revision XX)
I irnnrig-k
(' Zanarnfin
-Q+o+ien Annav=,vglrn k1mir-Igitar lI .ml~ Iri.pk ItB l114111t~n r ~ jir ~44rn A nv****S ** b**i LtPl b***l I U!nllt^l..A lt ll
* 11*
* l* l --* lRECOGNITION CATEGORYHAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETYHU7Initiating Condition:
Other conditions exist which in the judgment of the Emergency Director warrantdeclaration of an UNUSUAL EVENT.Operating Mode Applicability:
1, 2, 3, 4, 5, DEmergency Action Level (EAL):Other conditions exist which in the judgment of the Emergency Director indicate thatevents are in progress or have occurred which indicate a potential degradation of thelevel of safety of the plant or indicate a security threat to facility protection has beeninitiated.
No releases of radioactive material requiring offsite response or monitoring areexpected unless further degradation of safety systems occurs.Basis:This IC addresses unanticipated conditions not addressed explicitly elsewhere but thatwarrant declaration of an emergency because conditions exist which are believed by theEmergency Director to fall under the emergency classification level description for anUNUSUAL EVENT.Basis Reference(s):
: 1. NEI 99-01, Rev 6 HU7Month 20XXLGS 3-153EP-AA-1008 (Revision XX)
Limerick Generating Station AnnexExelon NuclearRECOGNITION CATEGORYISFSI MALFUNCTIONS E-HU1Initiating Condition Damage to a loaded cask CONFINEMENT BOUNDARY.
Operating Mode Applicability:
1, 2,3,4,5, DEmergency Action Level (EAL):Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by a radiation reading:* > 1400 mrem/hr on the HSM or HSM-H front surface (applicable to type 161BTH DSC only)OR* > 800 mrem/hr at 3 ft from the HSM surface (applicable to 61 BT DSC only)OR0 > 200 mrem/hr on the HSM or HSM-H door centerline OR* > 40 mremlhr on the end shield wall exterior.Basis:CONFINEMENT BOUNDARY:
The irradiated fuel dry storage cask barrier(s) betweenareas containing radioactive substances and the environment.
INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) : A complex that isdesigned and constructed for the interim storage of spent nuclear fuel and otherradioactive materials associated with spent fuel storage.This IC addresses an event that results in damage to the CONFINEMENT BOUNDARYof a storage cask containing spent fuel. It applies to irradiated fuel that is licensed fordry storage beginning at the point that the loaded storage cask is sealed. The wordcask, as used in this EAL, refers to the storage container in use at the site for drystorage of irradiated fuel. The issues of concern are the creation of a potential or actualrelease path to the environment, degradation of any fuel assemblies due toenvironmental
: factors, and configuration changes which could cause challenges inremoving the cask or fuel from storage.The existence of "damage" is determined by radiological survey. The technical specification multiple of "2 times", which is also used in Recognition Category R IC RU1,is used here to distinguish between non-emergency and emergency conditions.
Theemphasis for this classification is the degradation in the level of safety of the spent fuelcask and not the magnitude of the associated dose or dose rate. It is recognized that inthe case of extreme damage to a loaded cask, the fact that the "on-contact" dose ratelimit is exceeded may be determined based on measurement of a dose rate at somedistance from the cask.Month 20XXLGS 3-154EP-AA-1008 (Revision XX)
Limerick Generating Station Annex Exelon NuclearRECOGNITION CATEGORYISFSI MALFUNCTIONS E-HU1 (cont)Basis (cont):Security-related events for ISFSIs are covered under ICs HU1 and HA1.Basis Reference(s):
: 1. NEI 99-01, Rev 6 E-HU12. Limerick Generating Station ISFSI 1OCFR72.212 Evaluation Rev 6 Attachment
: 13. OU-LG-643, Transport of Loaded Transfer Cask and 61 BT Dry Shielded Canisterto Transfer
: Trailer, to ISFSI, and Alignment/Insertion into Horizontal StorageModule"Month 20XXLGS 3-155EP-AA-1008 (Revision XX)}}

Revision as of 14:43, 9 July 2018

Redirect to:

Retrieved from "https://kanterella.com/w/index.php?title=ML14164A069&oldid=872816"