L-2019-203, License Amendment Request 264, Adopt Emergency Action Level (EAL) Scheme Described in NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors.

License Amendment Request 264, Adopt Emergency Action Level (EAL) Scheme Described in NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors.

ML19343A373
Person / Time
Site:	Turkey Point
Issue date:	12/06/2019
From:	Stamp B Florida Power & Light Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML19343A371	List: L-2019-203, License Amendment Request 264, Adopt Emergency Action Level (EAL) Scheme Described in NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors.
References
L-2019-203
Download: ML19343A373 (251)

Text

December 6, 2019 L-2019-203 10 CFR 50.90 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington D C 20555-0001 RE: Turkey Point Nuclear Plant, Unit 3 and 4 Docket Nos. 50-250 and 50-251 Renewed Facility Operating Licenses DPR-31 and DPR-41 License Amendment Request 264, Adopt Emergency Action Level (EAL) Scheme Described in NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors Pursuant to 10 CPR Part 50.90, Florida Power & Light Company (FPL) hereby requests amendments to Renewed Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Nuclear Plant Units 3 and 4 (Turkey Point), respectively. The proposed license amendments revise the Turkey Point Emergency Plan by adopting the methodology for developing an Emergency Action Level (EAL) scheme described in Nuclear Energy Institute (NEI) 99-01, Revision 6, Methodology for Development of Emergency Action Levels (ADAMS Accession No. ML110240324).

The enclosure to this letter provides FPLs evaluation of the proposed change. Attachment 1 to the enclosure provides a markup of Turkey Points Emergency Action Level Technical Bases Document reflecting the proposed change. Attachment 2 provides the re-typed version of the Emergency Acton Level Technical Bases Document. Attachment 3 provides a comparative matrix detailing the deviations and differences between the proposed change and NEI 99-01, Revision 6. Attachment 4 provides the calculations supporting the proposed change. Attachment 5 provides the EAL Scheme Wallcharts for the proposed change. The EAL Scheme Wallcharts are provided for information only and will be incorporated into the Turkey Point Emergency Plan upon implementation of the approved license amendments.

FPL has determined that the proposed change does not involve a significant hazards consideration pursuant to 10 CFR 50.92(c), and there are no significant environmental impacts associated with the proposed change. The Turkey Point Onsite Review Group has reviewed the proposed license amendments.

In accordance with 10 CFR 50.91(b)(1), a copy of the proposed license amendments is being forwarded to the State designee for the State of Florida.

FPL requests that the proposed change is processed as a normal license amendment request with approval within one year of submittal. Once approved, the amendments will be implemented within 184 days to allow consideration for outage schedules and required training cycles.

This letter contains no regulatory commitments.

Should you have any questions regarding this submission, please contact Mr. Robert Hess, Turkey Point Licensing Manager, at 305-246-4112.

Florida Power & Light Company 9760 SW 344th Street, Homestead, FL 33035

Turkey Point Nuclear Plant L-2019-203 Docket Nos. 50-250 and 50-251 Enclosure Page 1 of 7 EVALUATION OF THE PROPOSED CHANGES Turkey Point Nuclear Plant Unit 3 and Unit 4 License Amendment Request 264, Adopt Emergency Action Level (EAL) Scheme Described in NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors 1.0

SUMMARY

DESCRIPTION ............................................................................................................. 2 2.0 DETAILED DESCRIPTION ............................................................................................................. 2 2.1 System Design and Operation ............................................................................................ 2 2.2 Current Requirements / Description of the Proposed Change ........................................... 2 2.3 Reason for the Proposed Change ...................................................................................... 2

3.0 TECHNICAL EVALUATION

............................................................................................................ 3

4.0 REGULATORY EVALUATION

....................................................................................................... 3 4.1 Applicable Regulatory Requirements/Criteria ..................................................................... 3 4.2 Precedent ............................................................................................................................ 4 4.3 No Significant Hazards Consideration ................................................................................ 4 4.4 Conclusion .......................................................................................................................... 6

5.0 ENVIRONMENTAL CONSIDERATION

.......................................................................................... 6

6.0 REFERENCES

................................................................................................................................. 6

.. - Emergency Action Level Technical Bases Document (markup copy) - Emergency Action Level Technical Bases Document (clean copy) - Turkey Point NEI 99-01 Revision 6 EAL Comparison Matrix - EAL Scheme Supporting Calculations - EAL Scheme Wallcharts

Turkey Point Nuclear Plant L-2019-203 Docket Nos. 50-250 and 50-251 Enclosure Page 2 of 7 1.0

SUMMARY

DESCRIPTION Florida Power & Light Company (FPL) requests amendments to Renewed Facility Operating Licenses DPR-31 and DPR-41 for Turkey Point Nuclear Plant Units 3 and 4 (Turkey Point),

respectively. The proposed license amendments revise the Turkey Point Emergency Plan by adopting the methodology for developing an Emergency Action Level (EAL) scheme described in Nuclear Energy Institute (NEI) 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors ((Reference 6.1). In Reference 6.2, the NRC endorsed NEI 99-01, Revision 6, as acceptable for use by licensees seeking to upgrade the EALs in accordance with 10 CFR 50, Appendix E, Emergency Planning and Preparedness for Production and Utilization Facilities.

2.0 DETAILED DESCRIPTION 2.1 System Design and Operation The Turkey Point Emergency Plan describes FPLs plan for responding to emergencies at Turkey Point Units 3 and 4. The plan applies to plant emergencies having the potential to increase the risk of accidental radioactive material releases. The Emergency Plan defines emergency conditions and delineates the responsibilities and duties of the Emergency Response Organization (ERO) in order to protect the health and safety of the public and plant personnel. The plan was developed and is maintained in accordance with the applicable requirements of 10 CFR 50.47(b), 10 CFR 50.72 and 10 CFR50, Appendix E.

Associated with the Turkey Point Emergency Plan are implementing procedures which provide detailed information and data required by the ERO during a declared emergency.

The Turkey Point Emergency Plan utilizes EALs which establish site-specific criteria for emergency classification initiating conditions and which when met or exceeded, triggers a declaration of the corresponding emergency classification level. The EALs employ a variety of plant specific and external event criteria for the emergency classifications such as plant instrument readings and status indications, safety analysis and calculation results, entry into specified procedures, and observable events including the occurrence of natural phenomena. The EALs additionally direct plant personnel to implement pre-planned emergency response measures and facilitate timely decision making for executing precautionary and protective actions which protect the public health and safety.

2.2 Current Requirements / Description of the Proposed Change The current Turkey Point Emergency Plan EAL scheme is based on NEI 99-01, Revision 5 (Reference 6.3). In Reference 6.4, the NRC endorsed NEI 99-01, Revision 5, as an acceptable methodology for developing an EAL scheme. In Reference 6.5, the NRC authorized Turkey Points conversion to an EAL scheme based on NEI 99-01, Revision 5.

The proposed change revises the Turkey Point Emergency Plan by adopting the methodology for developing an EAL scheme described in NEI 99-01, Revision 6. In Reference 6.2, the NRC endorsed Revision 6 as acceptable for use by licensees seeking to upgrade the EAL scheme in accordance with 10 CFR 50, Appendix E.

2.3 Reason for the Proposed Change The proposed license amendments clarify the EAL requirements and incorporate NRC recommendations and industry lessons learned, thereby leading to more timely and accurate emergency classification declarations in response to radiological events.

Turkey Point Nuclear Plant L-2019-203 Docket Nos. 50-250 and 50-251 Enclosure Page 3 of 7

3.0 TECHNICAL EVALUATION

The proposed change revises the Turkey Point Emergency Plan by adopting the EAL scheme described in NEI 99-01, Revision 6. In Reference 6.6, the NRC provided a regulatory and technical analysis for NEI 99-01, Revision 6, which noted that licensees seeking to adopt NEI 99-01, Revision 6, must request a license amendment pursuant to 10 CFR 50.90. The staff further noted that close adherence to NEI 99-01, Revision 6, will enhance the staffs review by focusing on the deviations from NEI 99-01, Revision 6, based upon unique and site-specific reactor design considerations.

Consistent with Reference 6.6, Attachment 3 of this amendment request provides a matrix detailing the differences and deviations between the proposed EAL scheme and NEI 99-01, Revision 6. The matrix provides a line-by-line comparison of the Initiating Conditions (ICs), Mode Applicability and EALs in NEI 99-01 Rev. 6 versus the ICs, applicable Modes and EALs proposed for Turkey Point.

Attachment 4 provides site-specific calculations and related bases in support of the conclusions provided in Attachment 3. Hence, Attachments 3 and 4 comprise FPLs technical evaluation of the proposed EAL scheme. For use with Attachment 3, the source document references are provided in the Attachment 1 redline markup and the Attachment 2 clean copy of the proposed EAL Technical Bases Document. In evaluating the differences and deviations in Attachment 3, FPL employed the definition of differences and deviations provided in Regulatory Issues Summary (RIS) 2003-18, "Use of NEI 99-01, Methodology for Development of Emergency Action Levels (Reference 6.7),

as supplemented by RIS 2003-18, Supplement 1 and Supplement 2 (References 6.8 and 6.9).

FPL has evaluated the proposed EAL scheme in accordance with the requirements of 10 CFR 50.54(q) Conditions of Licenses, 10 CFR 50.47, "Emergency Plans," and 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities. FPL developed the proposed EAL scheme with consideration for consistency in terminology, use of objective criteria and observable values, human engineering and user friendliness, and logical progression for upgrading and downgrading events based on the potential risk to public health and safety. Consistent with the current EAL scheme, all setpoints and indications in the proposed EAL scheme are within the calibrated ranges of the specified instrumentation and the instrumentation resolution is appropriate for the specified setpoints and indications. FPL has additionally reviewed the proposed EAL scheme for consistency with the EAL Scheme Wallcharts (Attachment 3), an operator aid, to avoid ambiguous interpretations that could impact timely and accurate EAL assessments. Based on these efforts, FPL concludes that the proposed EAL scheme does not reduce the effectiveness of the Turkey Point Emergency Plan or the capability to meet the onsite and offsite emergency planning standards of 10 CFR 50.47(b) and the emergency planning and preparedness requirements of 10 CFR 50, Appendix E. Moreover, by adopting the EAL scheme of NEI 99-01, Revision 6, the Turkey Point Emergency Plan will continue to be conducted in a manner consistent with applicable regulations and industry lessons learned.

In accordance with Nuclear Fleet Administrative procedure EN-AA-203-1201, 10 CFR Applicability and 10 CFR 50.59 Screening Reviews, plant equipment and procedure changes are subject to screening for impact(s) to the Turkey Point licensing basis, including the Turkey Point Emergency Plan. During implementation of the proposed EAL scheme, plant changes having the potential to impact the Emergency Plan, including the EAL scheme and Technical Bases Document, will be evaluated to determine whether prior NRC approval is required pursuant to 10 CFR 50.54(q).

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50, Appendix E, Section IV.B, requires, in part, that emergency plans contain EALs for determining the need for notification and participation of various agencies and for determining when and what type of protective measures should

Turkey Point Nuclear Plant L-2019-203 Docket Nos. 50-250 and 50-251 Enclosure Page 4 of 7 be considered. Section IV.B further requires that the EALs are to be based on in-plant conditions and instrumentation, and onsite and offsite monitoring.

10 CFR 50, Appendix E, Section IV.B.2, states, in part, that licensees desiring to change its emergency action level scheme shall submit an application for an amendment to its license and receive NRC approval before implementation.

10 CFR 50.54(q) authorizes licensees to make changes to emergency plans without prior Commission approval provided the changes do not decrease the effectiveness of the plans and the plans continue to meet 10 CFR 50.47(b) standards and 10 CFR 50 Appendix E requirements.

10 CFR 50.47(b) specifies onsite and offsite emergency response plan standards that licensees must meet for an NRC determination of reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.

NUREG-0654/FEMA-REP-1, Appendix 1, provides offsite emergency response recommended actions for the emergency classification levels, specifies guidelines for developing EALs and provides examples of onsite and offsite activities initiated by or ongoing at each emergency classification level.

NSIR/DPR-ISG-01, Interim Staff Guidance for Emergency Planning for Nuclear Power Plants, specifies guidance for EAL identification and timely response to potentially classifiable conditions.

Regulatory Issue Summary (RIS) 2003-18, as supplemented by Supplements 1 and 2, specify guidelines for developing or changing an EAL scheme, including the evaluation of deviations and differences from standard EAL schemes.

The proposed license amendments comply with the requirements of 10 CFR 50, Appendix E, Section IV.B, 10 CFR 50.54(q) and 10 CFR 50.47(b), and do not alter the manner in which the Turkey Point Emergency Plan will be implemented consistent with applicable regulations and guidelines. Therefore, all regulatory requirements will continue to be satisfied as a result of the proposed change.

4.2 Precedent In Reference 6.10, Point Beach Nuclear Plant, Units 1 and 2 (Point Beach), was granted license amendments authorizing Point Beach to upgrade their EAL scheme to NEI 99-01, Revision 6. In Reference 6.11, Duane Arnold Energy Center received similar authorization.

The cited precedents are relevant to this amendment request because like the precedents, the proposed EAL scheme aligns closely in format and content with NEI 99-01, Revision 6, and the deviations and differences, as described in Attachment 2, do not decrease the effectiveness of the proposed EAL scheme when compared to NEI 99-01, Revision 6.

4.3 No Significant Hazards Consideration The proposed license amendments revise the Turkey Point Emergency Plan by adopting the EAL scheme described in NEI 99-01, Revision 6. As required by 10 CFR 50.91(a),

FPL has evaluated the proposed changes using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration.

An analysis of the issue of no significant hazards consideration is presented below:

Turkey Point Nuclear Plant L-2019-203 Docket Nos. 50-250 and 50-251 Enclosure Page 5 of 7 (1) Do the proposed amendments involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The EALs trigger the declaration of emergency classification levels in response to radiological events. The proposed change neither alters plant equipment nor the manner in which plant equipment is credited in accident analyses and thereby cannot increase the probability of an accident. The proposed change aligns with the latest EAL scheme endorsed by the NRC and as a result, cannot adversely affect the type or amount of effluent that may be released off-site or increase individual or cumulative occupational exposures resulting from any design basis accident, and thereby cannot increase the consequences of any accident.

Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

(2) Do the proposed amendments create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change neither installs new nor modifies existing plant equipment and thereby cannot introduce new equipment failure modes. The proposed change does not alter safety analysis inputs or assumptions, or create new accident initiators or precursors, and thereby cannot introduce a new or different type of accident. The proposed change aligns with the latest EAL scheme endorsed by the NRC and thereby cannot create unanalyzed radiological impacts.

Therefore, the proposed amendments do not create the possibility of a new or different kind of accident from any previously evaluated.

(3) Do the proposed amendments involve a significant reduction in a margin of safety?

Response: No The proposed change does not modify any safety limits, limiting safety system settings, or safety analysis assumptions or inputs, and thereby cannot affect plant operating margins. The proposed change does not modify equipment credited in safety analyses, and thereby cannot affect the integrity of any radiological barrier.

The proposed change aligns with the latest EAL scheme endorsed by the NRC and thereby cannot reduce the effectiveness of the Emergency Plan.

Therefore, the proposed amendments do not involve a significant reduction in a margin of safety.

Based upon the above analysis, FPL concludes that the proposed license amendment does not involve a significant hazards consideration, under the standards set forth in 10 CFR 50.92, Issuance of Amendment, and accordingly, a finding of no significant hazards consideration is justified.

Turkey Point Nuclear Plant L-2019-203 Docket Nos. 50-250 and 50-251 Enclosure Page 6 of 7 4.4 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed license amendments adopt the EAL scheme described in NRC endorsed NEI 99-06, Revision 6, for the Turkey Point Emergency Plan and do not reduce the capability to meet the emergency planning requirements of 10 CFR 50.47 and 10 CFR 50, Appendix E. The amendments change a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 because the amendments approve an acceptable EAL scheme required for operation of the facility. The proposed amendments do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendments meet the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendments.

6.0 REFERENCES

6.1 Nuclear Energy Institute 99-01, Revision 6, Methodology for Development of Emergency Action Levels, January 21, 2011 (ADAMS Accession No. ML110240324).

6.2 NRC Endorsement of NEI 99-01, Revision 6, U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 6, Dated November, 2012 (TAC NO. D92368),

March 28, 2013 (ADAMS Accession No. ML13091A209) 6.3 Nuclear Energy Institute, NEI 99-01, Revision 5, Methodology for Development of Emergency Action Levels, February 2008 (ADAMS Accession No. ML080450149) 6.4 NRC Letter to Nuclear Energy Institute, U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 5, Dated February 2008, February 22, 2008 (ADAMS Accession No. ML080430535) 6.5 NRC Letter to Florida Power & Light, Turkey Point, Units 3 and 4 - Evaluation of Proposed Emergency Action Level Revision (TAC NOS. MD9924 AND MD9925), December 14, 2009 (ADAMS Accession No. ML093360321) 6.6 NRC Endorsement of NEI 99-01, Revision 6, Package Content, Regulatory and Technical Analysis to Accept the Generic Guidance in NEI 99-01, Revision 6, as an Acceptable Methodology for the Development of an Emergency Action Level Scheme for Non-Passive Reactors, April 1, 2013 (Adams Accession No. ML13008A736) 6.7 Regulatory Issue Summary 2003-18, Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels, Revision 4, Dated January 2003", October 8, 2003 (Adams Accession No. ML032580518)

Turkey Point Nuclear Plant L-2019-203 Docket Nos. 50-250 and 50-251 Enclosure Page 7 of 7 6.8 Regulatory Issue Summary 2003-18, Supplement 1, Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels, Revision 4, Dated January 2003", July 13, 2004 (Adams Accession No. ML041550395) 6.9 Regulatory Issue Summary 2003-18, Supplement 2, Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels, Revision 4, Dated January 2003", December 12, 2005 (Adams Accession No. ML051450482) 6.10 NRC Letter to NextEra Energy Point Beach, LLC, Point Beach Nuclear Plant, Units 1 and 2 - Issuance of Amendments RE: Revision to the Point Beach Nuclear Plant Emergency Action Level Scheme (CAC NOS. MF9859 AND MF9860; EPID L-2017-LLA-0278), June 13, 2018 (ADAMS Accession No. ML18079A045) 6.11 NRC Letter to NextEra Energy Duane Arnold, LLC, Duane Arnold Energy Center - Issuance of Amendment No. 308 to Upgrade Emergency Action Level Scheme for Duane Arnold Energy Center (EPID L-2017-LLA-0420), November 30, 2018 (ADAMS Accession No. ML18292A566)

Turkey Point Nuclear Plant L-2019-203 Docket Nos. 50-250 and 50-251 Enclosure ATTACHMENT 1 TURKEY POINT UNITS 3 & 4 LICENSE AMENDMENT REQUEST 264 EMERGENCY ACTION LEVEL TECHNICAL BASES DOCUMENT (MARKUP)

(241 pages follow)

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Table of Contents

1.0 INTRODUCTION

....................................................................................................... 3 2.0 DISCUSSION ............................................................................................................ 3 2.1 Background ...................................................................................................... 3 2.2 Fission Product Barriers ................................................................................... 4 2.3 Fission Product Barrier Classification Criteria .................................................. 4 2.4 EAL Organization ............................................................................................. 4 2.5 Technical Bases Information ............................................................................ 7 2.6 Operational Mode Applicability ......................................................................... 8 3.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS .................................. 9 3.1 General Considerations .................................................................................... 9 3.2 Classification Methodology ............................................................................. 10

4.0 REFERENCES

........................................................................................................ 14 4.1 Developmental................................................................................................ 14 4.2 Implementing .................................................................................................. 14 5.0 DEFINITIONS, ACRONYMS & ABBREVIATIONS .................................................. 15 5.1 Definitions ....................................................................................................... 15 5.2 Abbreviations/Acronyms ................................................................................. 20 6.0 PTN-TO-NEI 99-01 Rev. 6 EAL CROSS-REFERENCE .......................................... 23 7.0 ATTACHMENTS ...................................................................................................... 27 7.1 Attachment 1, Emergency Action Level Technical Bases ............................... 27 7.2 Attachment 2, Safe Operation & Shutdown Areas Tables R-3 & H-2 Bases .. 27 Category R - Abnormal Rad Release / Rad Effluent .......................................................... 28 Category C - Cold Shutdown / Refueling System Malfunction ........................................... 67 Category E - Independent Spent Fuel Storage Installation (ISFSI).................................. 105 Category F - Fission Product Barrier Degradation ........................................................... 108 Category H - Hazards and Other Conditions Affecting Plant Safety ................................ 156 Category S - System Malfunction .................................................................................... 186 Page 2 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document

1.0 INTRODUCTION

This document provides an explanation and rationale for each Emergency Action Level (EAL) included in the NEI 99-1 Revision 6 EAL Upgrade Project for Turkey Point Nuclear Generating (PTN). It should be used to facilitate review of the PTN EALs and provide historical documentation for future reference. Decision-makers responsible for implementation of 0-EPIP-20101, Duties of Emergency Coordinator, may use this document as a technical reference in support of EAL interpretation. This information may assist the Emergency Coordinator (EC) in making classifications, particularly those involving judgment or multiple events. The basis information may also be useful in training and for explaining event classifications to off-site officials.

The expectation is that emergency classifications are to be made as soon as conditions are present and recognizable for the classification, but within 15 minutes or less in all cases of conditions present. Use of this document for assistance is not intended to delay the emergency classification.

Because the information in a basis document can affect emergency classification decision-making (e.g., the EC refers to it during an event), the NRC staff expects that changes to the basis document will be evaluated in accordance with the provisions of 10 CFR 50.54(q).

2.0 DISCUSSION 2.1 Background EALs are the plant-specific indications, conditions or instrument readings that are utilized to classify emergency conditions defined in the Turkey Point Nuclear Generating Emergency Plan.

In 1992, the NRC endorsed NUMARC/NESP-007 Methodology for Development of Emergency Action Levels as an alternative guidance to the original Standard Review Plan and NUREG-0654 EAL schemes.

NEI 99-01 (NUMARC/NESP-007) Revisions 4 and 5 were subsequently issued for industry implementation. Enhancements over earlier revisions included:

Consolidating the system malfunction initiating conditions and example emergency action levels which address conditions that may be postulated to occur during plant shutdown conditions.

Initiating conditions and example emergency action levels that fully address conditions that may be postulated to occur at permanently Defueled Stations and Independent Spent Fuel Storage Installations (ISFSIs).

Simplifying the fission product barrier EAL threshold for a Site Area Emergency.

Subsequently, Revision 6 of NEI 99-01 has been issued which incorporates resolutions to numerous implementation issues including the NRC EAL Frequently Asked Questions (FAQs).

Using NEI 99-01 Revision 6, "Methodology for the Development of Emergency Action Levels for Non-Passive Reactors, November 2012 (ref. 4.1.1), PTN conducted an EAL implementation upgrade project that produced the EALs discussed herein.

Page 3 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document 2.2 Fission Product Barriers Fission product barrier thresholds represent threats to the defense in depth design concept that precludes the release of radioactive fission products to the environment. This concept relies on multiple physical barriers, any one of which, if maintained intact, precludes the release of significant amounts of radioactive fission products to the environment.

Many of the EALs derived from the NEI methodology are fission product barrier threshold based. That is, the conditions that define the EALs are based upon thresholds that represent the loss or potential loss of one or more of the three fission product barriers. Loss and Potential Loss signify the relative damage and threat of damage to the barrier. A Loss threshold means the barrier no longer assures containment of radioactive materials. A Potential Loss threshold implies a greater probability of barrier loss and reduced certainty of maintaining the barrier.

The primary fission product barriers are:

A. Fuel Clad Barrier (FC): The Fuel Clad Barrier consists of the cladding material that contains the fuel pellets.

B. Reactor Coolant System Barrier (RCS): The RCS Barrier includes the RCS primary side and its connections up to and including the pressurizer safety and relief valves, and other connections up to and including the primary isolation valves.

C. Containment Barrier (CTMT): The Containment Barrier includes the containment building and connections up to and including the outermost containment isolation valves. This barrier also includes the main steam, feedwater, and blowdown line extensions outside the containment building up to and including the outermost secondary side isolation valve. Containment Barrier thresholds are used as criteria for escalation of the Emergency Classification Level (ECL) from an Alert to a Site Area Emergency or a General Emergency.

2.3 Fission Product Barrier Classification Criteria The following criteria are the bases for event classification related to fission product barrier loss or potential loss:

Alert:

Any loss or any potential loss of either Fuel Clad or RCS Barrier Site Area Emergency:

Loss or potential loss of any two barriers General Emergency:

Loss of any two barriers and loss or potential loss of the third barrier 2.4 EAL Organization The PTN EAL scheme includes the following features:

Division of the EAL set into three broad groups:

Page 4 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document o EALs applicable under any plant operational modes - This group would be reviewed by the EAL-user any time emergency classification is considered.

o EALs applicable only under hot operational modes - This group would only be reviewed by the EAL-user when the plant is in Hot Shutdown, Hot Standby, Startup, or Power Operation mode.

o EALs applicable only under cold operating modes - This group would only be reviewed by the EAL-user when the plant is in Cold Shutdown, Refueling or Defueled mode.

The purpose of the groups is to avoid review of hot condition EALs when the plant is in a cold condition and avoid review of cold condition EALs when the plant is in a hot condition. This approach significantly minimizes the total number of EALs that must be reviewed by the EAL-user for a given plant condition, reduces EAL-user reading burden and, thereby, speeds identification of the EAL that applies to the emergency.

Within each group, assignment of EALs to categories and subcategories:

Category and subcategory titles are selected to represent conditions that are operationally significant to the EAL-user. The PTN EAL categories are aligned to and represent the NEI 99-01 Recognition Categories. Subcategories are used in the PTN scheme as necessary to further divide the EALs of a category into logical sets of possible emergency classification thresholds. The PTN EAL categories and subcategories are listed below.

The primary tool for determining the emergency classification level is the EAL Classification Matrix. The user of the EAL Classification Matrix may (but is not required to) consult the EAL technical bases in order to obtain additional information concerning the EALs under classification consideration. The user should consult Section 3.0 and Attachment 1 of this document for such information.

Page 5 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document EAL Groups, Categories and Subcategories EAL Group/Category EAL Subcategory Any Operating Mode:

R - Abnormal Rad Levels / Rad Effluent 1 - Radiological Effluent 2 - Irradiated Fuel Event 3 - Area Radiation Levels H - Hazards and Other Conditions 1 - Security Affecting Plant Safety 2 - Seismic Event 3 - Natural or Technological Hazard 4 - Fire 5 - Hazardous Gas 6 - Control Room Evacuation 7 - EC Judgment E - Independent Spent Fuel Storage 1 - Confinement Boundary Installation (ISFSI)

Hot Conditions:

S - System Malfunction 1 - Loss of Emergency AC Power 2 - Loss of Vital DC Power 3 - Loss of Control Room Indications 4 - RCS Activity 5 - RCS Leakage 6 - RTS Failure 7 - Loss of Communications 8 - Containment Failure 9 - Hazardous Event Affecting Safety Systems F - Fission Product Barrier Degradation None Cold Conditions:

C - Cold Shutdown / Refueling System 1 - RCS Level Malfunction 2 - Loss of Emergency AC Power 3 - RCS Temperature 4 - Loss of Vital DC Power 5 - Loss of Communications 6 - Hazardous Event Affecting Safety Systems Page 6 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document 2.5 Technical Bases Information EAL technical bases are provided in Attachment 1 for each EAL according to EAL group (Any, Hot, Cold), EAL category (R, C, E, F, H and S) and EAL subcategory. A summary explanation of each category and subcategory is given at the beginning of the technical bases discussions of the EALs included in the category. For each EAL, the following information is provided:

Category Letter & Title Subcategory Number & Title Initiating Condition (IC)

Site-specific description of the generic IC given in NEI 99-01 Rev. 6.

EAL Identifier (enclosed in rectangle)

Each EAL is assigned a unique identifier to support accurate communication of the emergency classification to onsite and offsite personnel. Four characters define each EAL identifier:

1. First character (letter): Corresponds to the EAL category as described above (R, C, E, F, H or S)

2. Second character (letter): The emergency classification (G, S, A or U)

G = General Emergency S = Site Area Emergency A = Alert U = Unusual Event

3. Third character (number): Subcategory number within the given category.

Subcategories are sequentially numbered beginning with the number one (1). If a category does not have a subcategory, this character is assigned the number one (1).

4. Fourth character (number): The numerical sequence of the EAL within the EAL subcategory. If the subcategory has only one EAL, it is given the number one (1).

Classification (enclosed in rectangle):

General Emergency (G), Site Area Emergency (S), Alert (A) or Unusual Event (U).

EAL (enclosed in rectangle)

Exact wording of the EAL as it appears in the EAL Classification Matrix.

Page 7 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Mode Applicability One or more of the following plant operating conditions comprise the mode to which each EAL is applicable: 1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown, 5 -

Cold Shutdown, 6 - Refueling, DEF - Defueled, or All. (See Section 2.6 for operating mode definitions)

Definitions:

If the EAL wording contains a defined term, the definition of the term is included in this section. These definitions can also be found in Section 5.1.

Basis:

An EAL basis section that provides PTN-relevant information concerning the EAL as well as a description of the rationale for the EAL as provided in NEI 99-01 Rev. 6.

Reference(s):

Source documentation from which the EAL is derived 2.6 Operational Mode Applicability THERMAL MODE K eff POWER

• TAVG

1. Power Operation 0.99 > 5% 350°F

2. Startup 0.99 5% 350°F

3. Hot Standby < 0.99 0 350°F

4. Hot Shutdown < 0.99 0 > 200°F & < 350°F

5. Cold Shutdown < 0.99 0 200°F

6. Refueling ** 0.95 0 140°F Defueled NA NA NA - no fuel in reactor vessel

• Excluding Decay Heat

• • Fuel in the reactor vessel with the vessel head closure bolts less than fully tensioned or with the head removed The plant operating mode that exists at the time that the event occurs (prior to any protective system or operator action being initiated in response to the condition) should be compared to the mode applicability of the EALs. If a lower or higher plant operating mode is reached before the emergency classification is made, the declaration shall be based on the mode that existed at the time the event occurred.

Page 8 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document 3.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS 3.1 General Considerations When making an emergency classification, the EC must consider all information having a bearing on the proper assessment of an Initiating Condition (IC). This includes the Emergency Action Level (EAL) plus the associated Operational Mode Applicability, Notes, and the informing basis information. In the Recognition Category F matrices, EALs are based on loss or potential loss of Fission Product Barrier thresholds.

3.1.1 Classification Timeliness NRC regulations require the licensee to establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and to promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level. The NRC staff has provided guidance on implementing this requirement in NSIR/DPR-ISG-01, "Interim Staff Guidance, Emergency Planning for Nuclear Power Plants" (ref. 4.1.8).

3.1.2 Valid Indications All emergency classification assessments shall be based upon valid indications, reports or conditions. A valid indication, report, or condition, is one that has been verified through appropriate means such that there is no doubt regarding the indicators operability, the conditions existence, or the reports accuracy. For example, verification could be accomplished through an instrument channel check, response on related or redundant indicators, or direct observation by plant personnel.

An indication, report, or condition is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

3.1.3 Imminent Conditions For ICs and EALs that have a stipulated time duration (e.g., 15 minutes, 30 minutes, etc.), the EC should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time. If an ongoing radiological release is detected and the release start time is unknown, it should be assumed that the release duration specified in the IC/EAL has been exceeded, absent data to the contrary.

Page 9 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document 3.1.4 Planned vs. Unplanned Events A planned work activity that results in an expected event or condition which meets or exceeds an EAL does not warrant an emergency declaration provided that: 1) the activity proceeds as planned, and 2) the plant remains within the limits imposed by the operating license. Such activities include planned work to test, manipulate, repair, maintain or modify a system or component. In these cases, the controls associated with the planning, preparation and execution of the work will ensure that compliance is maintained with all aspects of the operating license provided that the activity proceeds and concludes as expected. Events or conditions of this type may be subject to the reporting requirements of 10CFR 50.72 (ref.

4.1.4).

3.1.5 Classification Based on Analysis The assessment of some EALs is based on the results of analyses that are necessary to ascertain whether a specific EAL threshold has been exceeded (e.g., dose assessments, chemistry sampling, RCS leak rate calculation, etc.). For these EALs, the EAL wording or the associated basis discussion will identify the necessary analysis. In these cases, the 15-minute declaration period starts with the availability of the analysis results that show the threshold to be exceeded (i.e., this is the time that the EAL information is first available). The NRC expects licensees to establish the capability to initiate and complete EAL-related analyses within a reasonable period of time (e.g., maintain the necessary expertise on-shift).

3.1.6 Emergency Coordinator (EC) Judgment While the EALs have been developed to address a full spectrum of possible events and conditions which may warrant emergency classification, a provision for classification based on operator/management experience and judgment is still necessary. The NEI 99-01 EAL scheme provides the EC with the ability to classify events and conditions based upon judgment using EALs that are consistent with the Emergency Classification Level (ECL) definitions (refer to Category H). The EC will need to determine if the effects or consequences of the event or condition reasonably meet or exceed a particular ECL definition. A similar provision is incorporated in the Fission Product Barrier Tables; judgment may be used to determine the status of a fission product barrier.

3.2 Classification Methodology To make an emergency classification, the user will compare an event or condition (i.e., the relevant plant indications and reports) to an EAL(s) and determine if the EAL has been met or exceeded. The evaluation of an EAL must be consistent with the related Operating Mode Applicability and Notes. If an EAL has been met or exceeded, the associated IC is likewise met, the emergency classification process clock starts, and the ECL must be declared in accordance with plant procedures no later than fifteen minutes after the process clock started.

When assessing an EAL that specifies a time duration for the potentially classifiable condition, the clock for the EAL time duration runs concurrently with the emergency classification process clock. For a full discussion of this timing requirement, refer to NSIR/DPR-ISG-01 (ref.

4.1.8).

Page 10 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document 3.2.1 Classification of Multiple Events and Conditions When multiple emergency events or conditions are present, the user will identify all met or exceeded EALs. The highest applicable ECL identified during this review is declared. For example:

If an Alert EAL and a Site Area Emergency EAL are met, whether at one unit or at two units, a Site Area Emergency should be declared.

There is no additive effect from multiple EALs meeting the same ECL. For example:

If two Alert EALs are met, whether at one unit or at two units, an Alert should be declared.

Related guidance concerning classification of rapidly escalating events or conditions is provided in Regulatory Issue Summary (RIS) 2007-02, Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events (ref. 4.1.2).

3.2.2 Consideration of Mode Changes During Classification The mode in effect at the time that an event or condition occurred, and prior to any plant or operator response, is the mode that determines whether or not an IC is applicable. If an event or condition occurs, and results in a mode change before the emergency is declared, the emergency classification level is still based on the mode that existed at the time that the event or condition was initiated (and not when it was declared). Once a different mode is reached, any new event or condition, not related to the original event or condition, requiring emergency classification should be evaluated against the ICs and EALs applicable to the operating mode at the time of the new event or condition.

For events that occur in Cold Shutdown or Refueling, escalation is via EALs that are applicable in the Cold Shutdown or Refueling modes, even if Hot Shutdown (or a higher mode) is entered during the subsequent plant response. In particular, the fission product barrier EALs are applicable only to events that initiate in the Hot Shutdown mode or higher.

3.2.3 Classification of Imminent Conditions Although EALs provide specific thresholds, the EC must remain alert to events or conditions that could lead to meeting or exceeding an EAL within a relatively short period of time (i.e., a change in the ECL is IMMINENT). If, in the judgment of the EC, meeting an EAL is IMMINENT, the emergency classification should be made as if the EAL has been met. While applicable to all emergency classification levels, this approach is particularly important at the higher emergency classification levels since it provides additional time for implementation of protective measures.

Page 11 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document 3.2.4 Emergency Classification Level Upgrading and Downgrading An ECL may be downgraded when the event or condition that meets the highest IC and EAL no longer exists, and other site-specific downgrading requirements are met. If downgrading the ECL is deemed appropriate, the new ECL would then be based on a lower applicable IC(s) and EAL(s). The ECL may also simply be terminated.

As noted above, guidance concerning classification of rapidly escalating events or conditions is provided in RIS 2007-02 (ref. 4.1.2).

3.2.5 Classification of Short-Lived Events Event-based ICs and EALs define a variety of specific occurrences that have potential or actual safety significance. By their nature, some of these events may be short-lived and, thus, over before the emergency classification assessment can be completed. If an event occurs that meets or exceeds an EAL, the associated ECL must be declared regardless of its continued presence at the time of declaration. Examples of such events include an earthquake or a failure of the reactor protection system to automatically scram the reactor followed by a successful manual scram.

3.2.6 Classification of Transient Conditions Many of the ICs and/or EALs employ time-based criteria. These criteria will require that the IC/EAL conditions be present for a defined period of time before an emergency declaration is warranted. In cases where no time-based criterion is specified, it is recognized that some transient conditions may cause an EAL to be met for a brief period of time (e.g., a few seconds to a few minutes). The following guidance should be applied to the classification of these conditions.

EAL momentarily met during expected plant response - In instances in which an EAL is briefly met during an expected (normal) plant response, an emergency declaration is not warranted provided that associated systems and components are operating as expected, and operator actions are performed in accordance with procedures.

EAL momentarily met but the condition is corrected prior to an emergency declaration - If an operator takes prompt manual action to address a condition, and the action is successful in correcting the condition prior to the emergency declaration, then the applicable EAL is not considered met and the associated emergency declaration is not required. For illustrative purposes, consider the following example:

An ATWS occurs and the high pressure ECCS systems fail to automatically start. The plant enters an inadequate core cooling condition (a potential loss of both the Fuel Clad and RCS Barriers). If an operator manually starts a high pressure ECCS system in accordance with an EOP step and clears the inadequate core cooling condition prior to an emergency declaration, then the classification should be based on the ATWS only.

It is important to stress that the 15-minute emergency classification assessment period (process clock) is not a grace period during which a classification may be delayed to allow the performance of a corrective action that would obviate the need to classify the event.

Emergency classification assessments must be deliberate and timely, with no undue delays.

The provision discussed above addresses only those rapidly evolving situations when an operator is able to take a successful corrective action prior to the EC completing the review Page 12 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document and steps necessary to make the emergency declaration. This provision is included to ensure that any public protective actions resulting from the emergency classification are truly warranted by the plant conditions.

3.2.7 After-the-Fact Discovery of an Emergency Event or Condition In some cases, an EAL may be met but the emergency classification was not made at the time of the event or condition. This situation can occur when personnel discover that an event or condition existed which met an EAL, but no emergency was declared, and the event or condition no longer exists at the time of discovery. This may be due to the event or condition not being recognized at the time or an error that was made in the emergency classification process.

In these cases, no emergency declaration is warranted; however, the guidance contained in NUREG-1022 (ref. 4.1.3) is applicable. Specifically, the event should be reported to the NRC in accordance with 10CFR 50.72 (ref. 4.1.4) within one hour of the discovery of the undeclared event or condition. The licensee should also notify appropriate State and local agencies in accordance with the agreed upon arrangements.

3.2.8 Retraction of an Emergency Declaration Guidance on the retraction of an emergency declaration reported to the NRC is discussed in NUREG-1022 (ref. 4.1.3).

Page 13 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document

4.0 REFERENCES

4.1 Developmental 4.1.1 NEI 99-01 Revision 6, Methodology for the Development of Emergency Action Levels for Non-Passive Reactors, ADAMS Accession Number ML12326A805 4.1.2 RIS 2007-02 Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events, February 2, 2007.

4.1.3 NUREG-1022 Event Reporting Guidelines: 10CFR50.72 and 50.73 4.1.4 10 CFR 50.72 Immediate Notification Requirements for Operating Nuclear Power Reactors 4.1.5 10 CFR 50.73 License Event Report System 4.1.6 Technical Specifications Table 1.2, Operational Modes 4.1.7 Turkey Point Unit 3 & 4 Offsite Dose Calculation Manual (ODCM) 4.1.8 NSIR/DPR-ISG-01 Interim Staff Guidance, Emergency Planning for Nuclear Power Plants 4.1.9 Turkey Point Plant Radiological Emergency Plan 4.1.10 Certificate of Compliance Appendix A NUHOMS HD System Generic Technical Specifications 4.1.11 UFSAR Chapter 9.5 Fuel Storage and Handling 4.1.12 0-ADM-051 Outage Risk Assessment and Control 4.2 Implementing 4.2.1 0-EPIP-20101, Duties of Emergency Coordinator 4.2.2 NEI 99-01 Rev. 6 to PTN EAL Comparison Matrix 4.2.3 PTN EAL Matrix Page 14 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document 5.0 DEFINITIONS, ACRONYMS & ABBREVIATIONS 5.1 Definitions (ref. 4.1.1 except as noted)

Selected terms used in Initiating Condition, Emergency Action Level statements and EAL bases are set in all capital letters (e.g., ALL CAPS). These words are defined terms that have specific meanings as used in this document. The definitions of these terms are provided below.

ALERT Events are in progress, or have occurred, which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION.

Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

CONFINEMENT BOUNDARY The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the PTN ISFSI, Confinement Boundary is defined as the NUHOMS Dry Shielding Canister (DSC) (ref. 4.1.10).

CONTAINMENT CLOSURE The procedurally defined conditions or actions taken to secure containment (Primary or Secondary)and associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

Containment Closure requirements are specified in 0-ADM-051 Outage Risk Assessment and Control (ref. 4.1.12).

EMERGENCY ACTION LEVEL (EAL)

A pre-determined, site-specific, observable threshold for an INITIATING CONDITION that, when met or exceeded, places the plant in a given emergency classification level.

EMERGENCY CLASSIFICATION LEVEL (ECL)

One of a set of names or titles established by the US Nuclear Regulatory Commission (NRC) for grouping off-normal events or conditions according to (1) potential or actual effects or consequences, and (2) resulting onsite and offsite response actions. The emergency classification levels, in ascending order of severity, are:

Notification of Unusual Event (NOUE)

Alert Site Area Emergency (SAE)

General Emergency (GE)

EXPLOSION A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not Page 15 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document automatically be considered an explosion. Such events require a post-event inspection to determine if the attributes of an explosion are present.

FAULTED The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

FIRE Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.

FISSION PRODUCT BARRIER THRESHOLD A pre-determined, site-specific, observable threshold indicating the loss or potential loss of a fission product barrier.

FLOODING A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.

GENERAL EMERGENCY Events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA PAG exposure levels offsite for more than the immediate site area.

HOSTAGE A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION An act toward a NPP PTN or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPPPTN. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

Page 16 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document HOSTILE FORCE One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

IMMINENT The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

IMPEDE(D)

Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.

INITIATING CONDITION (IC)

An event or condition that aligns with the definition of one of the four emergency classification levels by virtue of the potential or actual effects or consequences.

Normal Levels As applied to radiological IC/EALs, the highest reading in the past twenty-four hours excluding the current peak value.

OWNER CONTROLLED AREA (OCA)

That portion of FPL property surrounding and including the Turkey Point Plant which is subject to limited access and control as deemed appropriate by FPL (ref. 4.1.9).

PROJECTILE An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

PROTECTED AREA The area (within the OWNER CONTROLLED AREA) occupied by the nuclear units and associated equipment and facilities enclosed within the security perimeter fence. The area within which accountability of personnel is maintained in an emergency (ref. 4.1.9).

REFUELING PATHWAY Refueling cavity, fuel transfer canal, and spent fuel pit (SFP), but not including the reactor vessel, comprise the refueling pathway (ref. 4.1.11).

RUPTURED The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection.

Page 17 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document SAFETY SYSTEM A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10CFR50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

SECURITY CONDITION Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A Security Condition does not involve a HOSTILE ACTION.

SITE AREA EMERGENCY Events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA PAG exposure levels beyond the SITE BOUNDARY.

SITE BOUNDARY That line beyond which the land or property is not owned, leased or otherwise controlled by PTN (ref. 4.1.7).

UNISOLABLE An open or breached system line that cannot be isolated, remotely or locally.

UNPLANNED A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

UNUSUAL EVENT Events are in progress or have occurred which indicate a potential degradation in the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

VALID An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct Page 18 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

VISIBLE DAMAGE Damage to a SAFETY SYSTEM train that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected SAFETY SYSTEM train.

Damage to a component or structure that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected component or structure.

Page 19 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document 5.2 Abbreviations/Acronyms

°F ....................................................................................................... Degrees Fahrenheit

° ........................................................................................................................... Degrees AC ....................................................................................................... Alternating Current AFW....................................................................................................Auxiliary Feedwater AOP ................................................................................. Abnormal Operating Procedure ARM.............................................................................................. Area Radiation Monitor ATWS ...................................................................... Anticipated Transient Without Scram CDE .......................................................................................Committed Dose Equivalent CET ............................................................................................ Core Exit Thermocouple CFR ..................................................................................... Code of Federal Regulations CIAS .....................................................................Containment Isolation Actuation Signal CPM..................................................................................................... Counts Per Minute CSFST .................................................................. Critical Safety Function Status Checks CTMT............................................................................................................. Containment CVI ................................................................... Containment Ventilation Isolation System DEF .....................................................................................................................Defueled DBA ............................................................................................... Design Basis Accident DC ............................................................................................................... Direct Current DG .......................................................................................................... Diesel Generator EAL ............................................................................................. Emergency Action Level EC ............................................................................................... Emergency Coordinator ECCS............................................................................ Emergency Core Cooling System ECL ................................................................................. Emergency Classification Level EOF .................................................................................. Emergency Operations Facility EOP ............................................................................... Emergency Operating Procedure EPA .............................................................................. Environmental Protection Agency FAA ................................................................................. Federal Aviation Administration FBI ................................................................................... Federal Bureau of Investigation FC ........................................................................................................... Fuel Clad Barrier FEMA............................................................... Federal Emergency Management Agency FSAR .................................................................................... Final Safety Analysis Report GE ..................................................................................................... General Emergency GPM ....................................................................................................Gallons Per Minute HR .............................................................................................................. Heat Removal Hr. .............................................................................................................................. Hour HSM.........................................................................................Horizontal Storage Module IC ......................................................................................................... Initiating Condition Page 20 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document ICC ............................................................................................ Inadequate Core Cooling ISFSI............................................................ Independent Spent Fuel Storage Installation Keff ......................................................................... Effective Neutron Multiplication Factor LCO .................................................................................. Limiting Condition of Operation LER ............................................................................................... Licensee Event Report LOCA ......................................................................................... Loss of Coolant Accident LPSI .................................................................................... Low Pressure Safety Injection LRW........................................................................................................ Liquid Radwaste LWR................................................................................................... Light Water Reactor MCB.................................................................................................... Main Control Board MG ........................................................................................................... Motor Generator Min. ......................................................................................................................... Minute MPH........................................................................................................... Miles Per Hour mR, mRem, mrem, mREM .............................................. milli-Roentgen Equivalent Man MW .................................................................................................................... Megawatt NEI .............................................................................................. Nuclear Energy Institute NEIC ................................................................... National Earthquake Information Center NPP .................................................................................................. Nuclear Power Plant NRC ................................................................................ Nuclear Regulatory Commission NSSS ................................................................................ Nuclear Steam Supply System NORAD................................................... North American Aerospace Defense Command (NO)UE ................................................................................ Notification of Unusual Event OBE ...................................................................................... Operating Basis Earthquake OCA ...............................................................................................Owner Controlled Area ODCM............................................................................ Off-site Dose Calculation Manual ORO ................................................................................. Offsite Response Organization PA .............................................................................................................. Protected Area PAG ........................................................................................ Protective Action Guideline PORV .................................................................................. Power Operated Relief Valve PSIG ................................................................................ Pounds per Square Inch Gauge PTN ............................................................................... Turkey Point Nuclear Generating PTS ....................................................................................... Pressurized Thermal Shock R ........................................................................................................................ Roentgen RCS ............................................................................................ Reactor Coolant System Rem, rem, REM ....................................................................... Roentgen Equivalent Man RTS .................................................................................................. Reactor Trip System RVLMS ..............................................................Reactor Vessel Level Monitoring System SBO ......................................................................................................... Station Blackout Page 21 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document SCBA ....................................................................... Self-Contained Breathing Apparatus SFP ......................................................................................................... Spent Fuel Pool SG ......................................................................................................... Steam Generator SI .............................................................................................................. Safety Injection SIAS ............................................................................. Safety Injection Actuation System SM ............................................................................................................... Shift Manager SPDS ........................................................................... Safety Parameter Display System SRO ............................................................................................ Senior Reactor Operator SRV ..................................................................................................... Safety Relief Valve TC (T/C)...................................................................................................... Thermocouple TEDE ............................................................................... Total Effective Dose Equivalent TAF ....................................................................................................... Top of Active Fuel TS ................................................................................................Technical Specifications TSC .......................................................................................... Technical Support Center UFSAR ...................................................................Updated Final Safety Analysis Report USGS ............................................................................ United States Geological Survey Page 22 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document 6.0 PTN-TO-NEI 99-01 Rev. 6 EAL CROSS-REFERENCE This cross-reference is provided to facilitate association and location of a PTN EAL within the NEI 99-01 IC/EAL identification scheme. Further information regarding the development of the PTN EALs based on the NEI guidance can be found in the EAL Comparison Matrix.

PTN NEI 99-01 Rev. 6 Example EAL IC EAL RU1.1 AU1 1 RU1.2 AU1 2 RU1.3 AU1 3 RU2.1 AU2 1 RA1.1 AA1 1 RA1.2 AA1 2 RA1.3 AA1 3 RA1.4 AA1 4 RA2.1 AA2 1 RA2.2 AA2 2 RA2.3 AA2 3 RA3.1 AA3 1 RA3.2 AA3 2 RS1.1 AS1 1 RS1.2 AS1 2 RS1.3 AS1 3 RS2.1 AS2 1 RG1.1 AG1 1 RG1.2 AG1 2 RG1.3 AG1 3 RG2.1 AG2 1 Page 23 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document PTN NEI 99-01 Rev. 6 Example EAL IC EAL CU1.1 CU1 1 CU1.2 CU1 2 CU2.1 CU2 1 CU3.1 CU3 1 CU3.2 CU3 2 CU4.1 CU4 1 CU5.1 CU5 1, 2, 3 CA1.1 CA1 1 CA1.2 CA1 2 CA2.1 CA2 1 CA3.1 CA3 1, 2 CA6.1 CA6 1 CS1.1 CS1 1 CS1.2 CS1 2 CS1.3 CS1 3 CG1.1 CG1 1 CG1.2 CG1 2 EU1.1 EU1 1 FA1.1 FA1 1 FS1.1 FS1 1 FG1.1 FG1 1 HU1.1 HU1 1, 2, 3 HU2.1 HU2 1 HU3.1 HU3 1 Page 24 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document PTN NEI 99-01 Rev. 6 Example EAL IC EAL HU3.2 HU3 2 HU3.3 HU3 3 HU3.4 HU3 4 HU4.1 HU4 1 HU4.2 HU4 2 HU4.3 HU4 3 HU4.4 HU4 4 HU7.1 HU7 1 HA1.1 HA1 1, 2 HA5.1 HA5 1 HA6.1 HA6 1 HA7.1 HA7 1 HS1.1 HS1 1 HS6.1 HS6 1 HS7.1 HS7 1 HG7.1 HG7 1 SU1.1 SU1 1 SU3.1 SU2 1 SU4.1 SU3 1 SU5.1 SU4 1, 2, 3 SU6.1 SU5 1 SU6.2 SU5 2 SU7.1 SU6 1, 2, 3 SU8.1 SU7 1, 2 Page 25 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document PTN NEI 99-01 Rev. 6 Example EAL IC EAL SA1.1 SA1 1 SA3.1 SA2 1 SA6.1 SA5 1 SA9.1 SA9 1 SS1.1 SS1 1 SS2.1 SS8 1 SS6.1 SS5 1 SG1.1 SG1 1 SG2.1 SG8 1 Page 26 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document 7.0 ATTACHMENTS 7.1 Attachment 1, Emergency Action Level Technical Bases 7.2 Attachment 2, Safe Operation & Shutdown Areas Tables R-5 & H-2 Bases Page 27 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category R - Abnormal Rad Levels / Rad Effluent EAL Group: ANY (EALs in this category are applicable to any plant condition, hot or cold.)

Many EALs are based on actual or potential degradation of fission product barriers because of the elevated potential for offsite radioactivity release. Degradation of fission product barriers though is not always apparent via non-radiological symptoms. Therefore, direct indication of elevated radiological effluents or area radiation levels are appropriate symptoms for emergency classification.

At lower levels, abnormal radioactivity releases may be indicative of a failure of containment systems or precursors to more significant releases. At higher release rates, offsite radiological conditions may result which require offsite protective actions. Elevated area radiation levels in plant may also be indicative of the failure of containment systems or preclude access to plant vital equipment necessary to ensure plant safety.

Events of this category pertain to the following subcategories:

1. Radiological Effluent Direct indication of effluent radiation monitoring systems provides a rapid assessment mechanism to determine releases in excess of classifiable limits. Projected offsite doses, actual offsite field measurements or measured release rates via sampling indicate doses or dose rates above classifiable limits.

2. Irradiated Fuel Event Conditions indicative of a loss of adequate shielding or damage to irradiated fuel may preclude access to vital plant areas or result in radiological releases that warrant emergency classification.

3. Area Radiation Levels Sustained general area radiation levels which may preclude access to areas requiring continuous occupancy also warrant emergency classification.

Page 28 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer EAL:

RU1.1 Unusual Event Reading on any Table R-1 effluent radiation monitor > column "UE" for 60 min.

(Notes 1, 2, 3)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes.

Table R-1 Effluent Monitor Classification Thresholds Release Point Monitor GE SAE Alert UE Plant Vent RAD-6304 1.5E+01 µCi/cc 1.5E-00 µCi/cc 1.5E-01 µCi/cc 1.1E-02 µCi/cc Gaseous RAD-3-6418 1.6E+03 µCi/cc 1.6E+02 µCi/cc 1.6E+01 µCi/cc 6.3E-01 µCi/cc Spent Fuel Pool U4 via RAD-5.1E+02 µCi/cc 5.1E+01 µCi/cc 5.1E+00 µCi/cc 1.8E-01 µCi/cc 6304 Liquid Waste R-18 N/A N/A N/A 1.8E+04 cpm Discharge Liquid 3-R-19 N/A N/A N/A 1.8E+04 cpm S/G Blowdown 4-R-19 N/A N/A N/A 1.8E+04 cpm Mode Applicability:

All Definition(s):

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Page 29 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Basis:

This IC addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release). It includes any gaseous or liquid radiological 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 of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases. The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes.

Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.

EAL #1 - This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous or liquid effluent pathways (ref. 1, 2).

EAL #2 - This EAL addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This EAL will typically be associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas).

EAL #3 - This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).

Escalation of the emergency classification level would be via IC AA1RA1.

Reference(s):

1. Turkey Point Offsite Dose Calculation Manual (ODCM)

2. EP-CALC-PTN-1901 Radiological Effluent EAL Values

3. NEI 99-01 AU1 Page 30 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer EAL:

RU1.2 Unusual Event Reading on any effluent radiation monitors > 2 x the alarm setpoint established by a current radioactivity discharge permit for 60 min. (Notes 1, 2, 3)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes.

Mode Applicability:

All Definition(s):

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Basis:

This IC addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release). It includes any gaseous or liquid radiological 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 of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases. The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Page 31 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes.

Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.

EAL #1 - This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous or liquid effluent pathwaEAL #2 - This EAL addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This EAL will Such releases are typically be associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas) (ref. 1).

EAL #3 - This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).

Escalation of the emergency classification level would be via IC AA1RA1.

Reference(s):

1. Turkey Point Offsite Dose Calculation Manual (ODCM)

2. NEI 99-01 AU1 Page 32 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer.

EAL:

RU1.3 Unusual Event Sample analysis for a gaseous or liquid release indicates a concentration or release rate 2 x ODCM limits for 60 min. (Notes 1, 2)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

None Basis:

This IC addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release). It includes any gaseous or liquid radiological 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 of radioactive effluents to the environment. Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases. The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.

Page 33 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases EAL #1 - This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous or liquid effluent pathways.

EAL #2 - This EAL addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This EAL will typically be associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas).

EAL #3 - This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river ocean water systems, etc.).

Escalation of the emergency classification level would be via IC AA1RA1.

Reference(s):

1. Turkey Point Offsite Dose Calculation Manual (ODCM)

2. NEI 99-01 AU1 Page 34 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

RA1.1 Alert Reading on any Table R-1 effluent radiation monitor > column "ALERT" for 15 min.

(Notes 1, 2, 3, 4)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes.

Note 4 The pre-calculated effluent monitor values presented in EALs RA1.1, RS1.1 and RG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Table R-1 Effluent Monitor Classification Thresholds Release Point Monitor GE SAE Alert UE Plant Vent RAD-6304 1.5E+01 µCi/cc 1.5E-00 µCi/cc 1.5E-01 µCi/cc 1.1E-02 µCi/cc Gaseous RAD-3-6418 1.6E+03 µCi/cc 1.6E+02 µCi/cc 1.6E+01 µCi/cc 6.3E-01 µCi/cc Spent Fuel Pool U4 via RAD-5.1E+02 µCi/cc 5.1E+01 µCi/cc 5.1E+00 µCi/cc 1.8E-01 µCi/cc 6304 Liquid Waste R-18 N/A N/A N/A 1.8E+04 cpm Discharge Liquid 3-R-19 N/A N/A N/A 1.8E+04 cpm S/G Blowdown 4-R-19 N/A N/A N/A 1.8E+04 cpm Mode Applicability:

All Definition(s):

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the Page 35 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Basis:

This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual 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 this magnitude represent an actual or potential substantial degradation of the level of safety of the 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 and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes.

The values of the gaseous effluent thresholds in Table R-1 represents 10% of the SAE values calculated in EP-CALC-PTN-1901 Radiological Effluent EAL Values (ref. 1).

Escalation of the emergency classification level would be via IC AS1RS1.

Reference(s):

1. EP-CALC-PTN-1901 Radiological Effluent EAL Values

2. NEI 99-01 AA1 Page 36 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

RA1.2 Alert Dose assessment using actual meteorology indicates doses > 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the SITE BOUNDARY (Note 4)

Note 4: The pre-calculated effluent monitor values presented in EALs RA1.1, RS1.1 and RG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That line beyond which the land or property is not owned, leased or otherwise controlled by PTN.

Basis:

This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual 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 this magnitude represent an actual or potential substantial degradation of the level of safety of the 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 and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

Escalation of the emergency classification level would be via IC AS1RS1.

Reference(s):

1. 0-EPIP-20125 Off-site Dose Assessment Using the Unified RASCAL Interface (URI)

2. 0-EPIP-20126 Off-site Dose Calculations - Manual Method Page 37 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases

3. NEI 99-01 AA1 Page 38 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

RA1.3 Alert Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses > 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the SITE BOUNDARY for 60 min. of exposure (Notes 1, 2)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That line beyond which the land or property is not owned, leased or otherwise controlled by PTN.

Basis:

This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual 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 this magnitude represent an actual or potential substantial degradation of the level of safety of the 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 and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

This EAL is assessed per the ODCM (ref.1)

Escalation of the emergency classification level would be via IC AS1RS1.

Page 39 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Reference(s):

1. Turkey Point Offsite Dose Calculation Manual (ODCM)

2. NEI 99-01 AA1 Page 40 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL:

RA1.4 Alert Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:

Closed window dose rates > 10 mR/hr expected to continue for 60 min.

Analyses of field survey samples indicate thyroid CDE > 50 mrem for 60 min. of inhalation.

(Notes 1, 2)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That line beyond which the land or property is not owned, leased or otherwise controlled by PTN.

Basis:

This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual 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 this magnitude represent an actual or potential substantial degradation of the level of safety of the 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 and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have Page 41 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

Escalation of the emergency classification level would be via IC AS1RS1.

Reference(s):

1. 0-EPIP-20129 Emergency Response Team - Radiological Monitoring

2. NEI 99-01 AA1 Page 42 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL:

RS1.1 Site Area Emergency Reading on any Table R-1 effluent radiation monitor > column "SAE" for 15 min.

(Notes 1, 2, 3, 4)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes.

Note 4: The pre-calculated effluent monitor values presented in EALs RA1.1, RS1.1 and RG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Table R-1 Effluent Monitor Classification Thresholds Release Point Monitor GE SAE Alert UE Plant Vent RAD-6304 1.5E+01 µCi/cc 1.5E-00 µCi/cc 1.5E-01 µCi/cc 1.1E-02 µCi/cc Gaseous RAD-3-6418 1.6E+03 µCi/cc 1.6E+02 µCi/cc 1.6E+01 µCi/cc 6.3E-01 µCi/cc Spent Fuel Pool U4 via RAD-5.1E+02 µCi/cc 5.1E+01 µCi/cc 5.1E+00 µCi/cc 1.8E-01 µCi/cc 6304 Liquid Waste R-18 N/A N/A N/A 1.8E+04 cpm Discharge Liquid 3-R-19 N/A N/A N/A 1.8E+04 cpm S/G Blowdown 4-R-19 N/A N/A N/A 1.8E+04 cpm Mode Applicability:

All Definition(s):

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the Page 43 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite 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 are associated 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 and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 10% of the EPA PAG of 1,000 mrem while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes.

Escalation of the emergency classification level would be via IC AG1RG1.

Reference(s):

1. EP-CALC-PTN-1901 Radiological Effluent EAL Values

2. NEI 99-01 AS1 Page 44 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL:

RS1.2 Site Area Emergency Dose assessment using actual meteorology indicates doses > 100 mrem TEDE or 500 mrem thyroid CDE at or beyond the SITE BOUNDARY (Note 4)

Note 4: The pre-calculated effluent monitor values presented in EALs RA1.1, RS1.1 and RG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That line beyond which the land or property is not owned, leased or otherwise controlled by PTN.

Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite 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 are associated 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 and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 10% of the EPA PAG of 1,000 mrem while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

Escalation of the emergency classification level would be via IC AG1RG1.

Reference(s):

1. 0-EPIP-20125 Off-site Dose Assessment Using the Unified RASCAL Interface (URI)

2. 0-EPIP-20126 Off-site Dose Calculations - Manual Method

3. NEI 99-01 AS1 Page 45 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL:

RS1.3 Site Area Emergency Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:

Closed window dose rates > 100 mR/hr expected to continue for 60 min.

Analyses of field survey samples indicate thyroid CDE > 500 mrem for 60 min. of inhalation.

(Notes 1, 2)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That line beyond which the land or property is not owned, leased or otherwise controlled by PTN.

Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite 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 are associated 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 and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 10% of the EPA PAG of 1,000 mrem while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

Escalation of the emergency classification level would be via IC AG1RG1.

Page 46 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Reference(s):

1. 0-EPIP-20129 Emergency Response Team - Radiological Monitoring

2. NEI 99-01 AS1 Page 47 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL:

RG1.1 General Emergency Reading on any Table R-1 effluent radiation monitor > column "GE" for 15 min.

(Notes 1, 2, 3, 4)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Note 3: If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes.

Note 4: The pre-calculated effluent monitor values presented in EALs RA1.1, RS1.1 and RG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Table R-1 Effluent Monitor Classification Thresholds Release Point Monitor GE SAE Alert UE Plant Vent RAD-6304 1.5E+01 µCi/cc 1.5E-00 µCi/cc 1.5E-01 µCi/cc 1.1E-02 µCi/cc Gaseous RAD-3-6418 1.6E+03 µCi/cc 1.6E+02 µCi/cc 1.6E+01 µCi/cc 6.3E-01 µCi/cc Spent Fuel Pool U4 via RAD-5.1E+02 µCi/cc 5.1E+01 µCi/cc 5.1E+00 µCi/cc 1.8E-01 µCi/cc 6304 Liquid Waste R-18 N/A N/A N/A 1.8E+04 cpm Discharge Liquid 3-R-19 N/A N/A N/A 1.8E+04 cpm S/G Blowdown 4-R-19 N/A N/A N/A 1.8E+04 cpm Mode Applicability:

All Definition(s):

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the Page 48 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude will require implementation of protective actions for the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at the EPA PAG of 1,000 mrem while the 5,000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer VALID for classification purposes.

Reference(s):

1. EP-CALC-PTN-1901 Radiological Effluent EAL Values

2. NEI 99-01 AG1 Page 49 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL:

RG1.2 General Emergency Dose assessment using actual meteorology indicates doses > 1,000 mrem TEDE or 5,000 mrem thyroid CDE at or beyond the SITE BOUNDARY (Note 4)

Note 4: The pre-calculated effluent monitor values presented in EALs RA1.1, RS1.1 and RG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That line beyond which the land or property is not owned, leased or otherwise controlled by PTN.

Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude will require implementation of protective actions for the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at the EPA PAG of 1,000 mrem while the 5,000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

Reference(s):

1. 0-EPIP-20125 Off-site Dose Assessment Using the Unified RASCAL Interface (URI)

2. 0-EPIP-20126 Off-site Dose Calculations - Manual Method

3. NEI 99-01 AG1 Page 50 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 1 - Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL:

RG1.3 General Emergency Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:

Closed window dose rates > 1,000 mR/hr expected to continue for 60 min.

Analyses of field survey samples indicate thyroid CDE > 5,000 mrem for 60 min. of inhalation.

(Notes 1, 2)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Note 2: If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.

Mode Applicability:

All Definition(s):

SITE BOUNDARY - That line beyond which the land or property is not owned, leased or otherwise controlled by PTN.

Basis:

This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude will require implementation of protective actions for the public.

Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at the EPA PAG of 1,000 mrem while the 5,000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.

Page 51 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.

Reference(s):

1. 0-EPIP-20129 Emergency Response Team - Radiological Monitoring

2. NEI 99-01 AG1 Page 52 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: UNPLANNED loss of water level above irradiated fuel EAL:

RU2.1 Unusual Event UNPLANNED water level drop in the REFUELING PATHWAY as indicated by any of the following:

SFP or reactor cavity level instrument SFP or reactor cavity low level alarm Report of dropping level in SFP or reactor cavity AND UNPLANNED rise in corresponding area radiation levels as indicated by any Table R-2 radiation monitors Table R-2 Refueling Area Radiation Monitors ARM # Description R-2[5] Unit 3[4] Containment Operating Floor R-7[8] Unit 3[4] Spent Fuel Pit Canal Area R-21[22] Unit 3[4] Spent Fuel Pit North[South]

Mode Applicability:

All Definition(s):

UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

REFUELING PATHWAY- Refueling cavity, fuel transfer canal, and spent fuel pit (SFP), but not including the reactor vessel, comprise the refueling pathway.

Basis:

This IC addresses a decrease in water level above irradiated fuel sufficient to cause elevated radiation levels. This condition could be a precursor to a more serious event and is also indicative of a minor loss in the ability to control radiation levels within the plant. It is therefore a potential degradation in the level of safety of the plant.

Page 53 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases A water level decrease will be primarily determined by indications from available level instrumentation. Other sources of level indications may include reports from plant personnel (e.g., from a refueling crew) or video camera observations (if available). A significant drop in the water level may also cause an increase in the radiation levels of adjacent areas that can be detected by monitors in those locations.

The specified area radiation monitors are those expected to see increase area radiation levels as a result of a loss of REFUELING PATHWAY inventory (ref. 1, 2). Increasing radiation indications on these monitors in the absence of indications of decreasing REFUELING PATHWAY level are not classifiable under this EAL.

The effects of planned evolutions should be considered. For example, a refueling bridge area radiation monitor reading may increase due to planned evolutions such as lifting of the reactor 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 in accordance Recognition Category C during the Cold Shutdown and Refueling modes.

Escalation of the emergency classification level would be via IC AA2RA2.

Reference(s):

1. 3[4]-ONOP-033.1 Spent Fuel Pit (SFP) Cooling System Malfunction

2. 3[4]-ONOP-033.2 Refueling Cavity Seal Failure

3. NEI 99-01 AU2 Page 54 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuel EAL:

RA2.1 Alert IMMINENT uncovery of irradiated fuel in the REFUELING PATHWAY Mode Applicability:

All Definition(s):

CONFINEMENT BOUNDARY- The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the PTN ISFSI, Confinement Boundary is defined as the NUHOMS Dry Shielding Canister (DSC).

IMMINENT - The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

REFUELING PATHWAY- Refueling cavity, fuel transfer canal, and spent fuel pit (SFP), but not including the reactor vessel, comprise the refueling pathway.

Basis:

This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly, or a significant lowering of water level within the spent fuel poolREFUELING PATHWAY (see Developer Notes). These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment. As such, they represent an actual or potential substantial degradation of the level of safety of the plant.

This IC EAL applies to irradiated fuel that is licensed for dry storage up to the point that the loaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss of the CONFINEMENT BOUNDARY is classified in accordance with IC E-HU1.

Escalation of the emergency would be based on either Recognition Category A R or C ICsEALs.

EAL #1 This EAL escalates from AU2 RU2.1 in that the loss of level, in the affected portion of the REFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery of irradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visual observation (e.g., reports from personnel or camera images), as well as significant changes in water and radiation levels, or other plant parameters. Computational aids may also be used (e.g., a boil-off curve). Classification of an event using this EAL should be based on the totality of available indications, reports and observations.

While an area radiation monitor could detect an increase in a dose rate due to a lowering of water level in some portion of the REFUELING PATHWAY, the reading may not be a reliable Page 55 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases indication of whether or not the fuel is actually uncovered. To the degree possible, readings should be considered in combination with other available indications of inventory loss.

A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance with Recognition Category C during the Cold Shutdown and Refueling modes..EAL #2 This EAL addresses a release of radioactive material caused by mechanical damage to irradiated fuel. Damaging events may include the dropping, bumping or binding of an assembly, 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 a potential fuel damaging event (e.g., a fuel handling accident).

EAL #3 Spent fuel pool water level at this value is within the lower end of the level range necessary to prevent significant dose consequences from direct gamma radiation to personnel performing operations in the vicinity of the spent fuel pool. This condition reflects a significant loss of spent fuel pool water inventory and thus it is also a precursor to a loss of the ability to adequately cool the irradiated fuel assembles stored in the pool.

Escalation of the emergency classification level would be via ICs AS1 or AS2 (see AS2 Developer Notes).

Reference(s):

1. NEI 99-01 AA2 Page 56 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuel EAL:

RA2.2 Alert Damage to irradiated fuel resulting in a release of radioactivity AND VALID HIGH alarm on any of the following:

Any Table R-2 area radiation monitors R-3[4]-11 or R-3[4]-12 Containment Atmosphere Process Radiation Monitor R-14 Plant Vent Gas Monitor Table R-2 Refueling Area Radiation Monitors ARM # Description R-2[5] Unit 3[4] Containment Operating Floor R-7[8] Unit 3[4] Spent Fuel Pit Canal Area R-21[22] Unit 3[4] Spent Fuel Pit North[South]

Mode Applicability:

All Definition(s):

CONFINEMENT BOUNDARY- The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the PTN ISFSI, Confinement Boundary is defined as the NUHOMS Dry Shielding Canister (DSC).

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Basis:

The specified radiation monitors are those expected to see increased area radiation levels as a result of damage to irradiated fuel (ref. 1, 2, 3).

Page 57 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases This IC EAL addresses events that have caused imminent or actual damage to an irradiated fuel assembly, or a significant lowering of water level within the spent fuel pool (see Developer Notes). These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment. As such, they represent an actual or potential substantial degradation of the level of safety of the plant.

This IC EAL applies to irradiated fuel that is licensed for dry storage up to the point that the loaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss of the CONFINEMENT BOUNDARY is classified in accordance with IC E-HU1.

EAL #This EAL escalates from AU2 in that the loss of level, in the affected portion of the REFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery of irradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visual observation (e.g., reports from personnel or camera images), as well as significant changes in water and radiation levels, or other plant parameters. Computational aids may also be used (e.g., a boil-off curve). Classification of an event using this EAL should be based on the totality of available indications, reports and observations.

While an area radiation monitor could detect an increase in a dose rate due to a lowering of water level in some portion of the REFUELING PATHWAY, the reading may not be a reliable indication of whether or not the fuel is actually uncovered. To the degree possible, readings should be considered in combination with other available indications of inventory loss.

A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.

This EAL addresses a release of radioactive material caused by mechanical damage to irradiated fuel. Damaging events may include the dropping, bumping or binding of an assembly, 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 a potential fuel damaging event (e.g., a fuel handling accident). EAL #3Spent fuel pool water level at this value is within the lower end of the level range necessary to prevent significant dose consequences from direct gamma radiation to personnel performing operations in the vicinity of the spent fuel pool. This condition reflects a significant loss of spent fuel pool water inventory and thus it is also a precursor to a loss of the ability to adequately cool the irradiated fuel assembles stored in the pool.

Escalation of the emergency would be based on either Recognition Category A R or C ICs.

Escalation of the emergency classification level would be via ICs AS1or AS2 (see AS2 Developer Notes).

Reference(s):

1. 3[4]-ONOP-033.1 Spent Fuel Pit (SFP) Cooling System Malfunction

2. 3[4]-ONOP-033.2 Refueling Cavity Seal Failure

2. 3[4]-ONOP-033.3 Accidents Involving New or Spent Fuel

4. NEI 99-01 AA2 Page 58 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuel EAL:

RA2.3 Alert Lowering of spent fuel pool level to 43 ft. (Level 2) on LI-3[4]-651A or LI-3[4]-651B Mode Applicability:

All Definition(s):

None Basis:

This IC EAL addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly, or a significant lowering of water level within the spent fuel pool (see Developer Notes). These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment. As such, they represent an actual or potential substantial degradation of the level of safety of the plant.

This IC applies to irradiated fuel that is licensed for dry storage up to the point that the loaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss of the CONFINEMENT BOUNDARY is classified in accordance with IC E-HU1.

Escalation of the emergency would be based on either Recognition Category A or C ICs. EAL

1. This EAL escalates from AU2 in that the loss of level, in the affected portion of the REFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery of irradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visual observation (e.g., reports from personnel or camera images), as well as significant changes in water and radiation levels, or other plant parameters. Computational aids may also be used (e.g., a boil-off curve). Classification of an event using this EAL should be based on the totality of available indications, reports and observations.

While an area radiation monitor could detect an increase in a dose rate due to a lowering of water level in some portion of the REFUELING PATHWAY, the reading may not be a reliable indication of whether or not the fuel is actually uncovered. To the degree possible, readings should be considered in combination with other available indications of inventory loss.

A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.

This EAL addresses a release of radioactive material caused by mechanical damage to irradiated fuel. Damaging events may include the dropping, bumping or binding of an assembly, 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 a potential fuel damaging event (e.g., a fuel handling accident).

Page 59 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases EAL #3Spent fuel pool water level at this value is within the lower end of the level range necessary to prevent significant dose consequences from direct gamma radiation to personnel performing operations in the vicinity of the spent fuel pool. This condition reflects a significant loss of spent fuel pool water inventory and thus it is also a precursor to a loss of the ability to adequately cool the irradiated fuel assembles stored in the pool.

Escalation of the emergency classification level would be via ICs AS1 RS1 or ARS2 (see AS2 Developer Notes).

Post-Fukushima order EA-12-051 required the installation of reliable SFP level indication (LI-3[4]-651A and LI-3[4]-651B) capable of identifying normal level (Level 1), SFP level ~10 ft.

above the top of the fuel racks (Level 2 - 42 ft. 11 in.) and SFP level at the top of the fuel racks (Level 3 - 33 ft. 11 in.) (ref. 1, 2). Level 2 has been rounded to 43 ft.

Reference(s):

1. EC-280522 Design Change Package PTN-3 (PTN-4) Spent Fuel Pool Level Instrument Per NRC Order EA-12-051

2. 3[4]-PMI-033.03A Spent Fuel Pool Level Instrumentation LE/LIT-3[4]-651A System Calibration Verification and Maintenance

3. NEI 99-01 AA2 Page 60 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Spent fuel pool level at the top of the fuel racks EAL:

RS2.1 Site Area Emergency Lowering of spent fuel pool level to 34 ft. (Level 3) on LI-3[4]-651A or LI-3[4]-651B Mode Applicability:

All Definition(s):

IMMINENT - The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

Basis:

This IC EAL addresses a significant loss of spent fuel pool inventory control and makeup capability leading to IMMINENT fuel damage. This condition entails major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.

It is recognized that this IC would likely not be met until well after another Site Area Emergency IC was met; however, it is included to provide classification diversity.

Escalation of the emergency classification level would be via IC AG1 RG1 or AG2RG2.

Post-Fukushima order EA-12-051 required the installation of reliable SFP level indication (LI-3[4]-651A and LI-3[4]-651B) capable of identifying normal level (Level 1), SFP level ~10 ft.

above the top of the fuel racks (Level 2 - 42 ft. 11 in.) and SFP level at the top of the fuel racks (Level 3 - 33 ft. 11 in.) (ref. 1, 2). Level 3 has been rounded to 34 ft.

Reference(s):

1. EC-280522 Design Change Package PTN-3 (PTN-4) Spent Fuel Pool Level Instrument Per NRC Order EA-12-051

2. 3[4]-PMI-033.03A Spent Fuel Pool Level Instrumentation LE/LIT-3[4]-651A System Calibration Verification and Maintenance

3. NEI 99-01 AS2 Page 61 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 2 - Irradiated Fuel Event Initiating Condition: Spent fuel pool level cannot be restored to at least the top of the fuel racks for 60 minutes or longer EAL:

RG2.1 General Emergency Spent fuel pool level cannot be restored to at least 34 ft. (Level 3) on LI-3[4]-651A or LI-3[4]-651B for 60 min. (Note 1)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Mode Applicability:

All Definition(s):

None Basis:

This IC EAL addresses a significant loss of spent fuel pool inventory control and makeup capability leading to a prolonged uncovery of spent fuel. This condition will lead to fuel damage and a radiological release to the environment.

It is recognized that this IC EALwould likely not be met until well after another General Emergency IC EAL was met; however, it is included to provide classification diversity.

Post-Fukushima order EA-12-051 required the installation of reliable SFP level indication (LI-3[4]-651A and LI-3[4]-651B) capable of identifying normal level (Level 1), SFP level ~10 ft.

above the top of the fuel racks (Level 2 - 42 ft. 11 in.) and SFP level at the top of the fuel racks (Level 3 - 33 ft. 11 in.) (ref. 1, 2). Level 3 has been rounded to 34 ft.

Reference(s):

1. EC-280522 Design Change Package PTN-3 (PTN-4) Spent Fuel Pool Level Instrument Per NRC Order EA-12-051

2. 3[4]-PMI-033.03A Spent Fuel Pool Level Instrumentation LE/LIT-3[4]-651A System Calibration Verification and Maintenance

3. NEI 99-01 AG2 Page 62 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 3 - Area Radiation Levels Initiating Condition: Radiation levels that IMPEDE access to equipment necessary for normal plant operations, cooldown or shutdown EAL:

RA3.1 Alert Dose rate > 15 mR/hr in EITHER of the following areas:

Control Room Central Alarm Station Mode Applicability:

All Definition(s):

IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

Basis:

This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or impede personnel from performing actions necessary to maintain normal plant operation, or to perform a normal plant cooldown and shutdown. As such, it represents an actual or potential substantial degradation of the level of safety of the plant. The Emergency Director Coordinator should consider the cause of the increased radiation levels and determine if another IC may be applicable. For EAL #2, 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 at the time of the elevated radiation levels. 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 if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., installing temporary shielding, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits).

An emergency declaration is not warranted if any of the following conditions apply.

The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the elevated radiation levels). For example, the plant is in Mode 1 when the radiation increase occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.

Page 63 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases The increased radiation levels are a result of a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., radiography, spent filter or resin transfer, etc.).

The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.

Escalation of the emergency classification level would be via Recognition Category AR, C or F ICs.

Reference(s):

1. 0-ONOP-066 High Area Radiation Monitoring System Alarms

2. NEI 99-01 AA3 Page 64 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: R - Abnormal Rad Levels / Rad Effluent Subcategory: 3 - Area Radiation Levels Initiating Condition: Radiation levels that IMPEDE access to equipment necessary for normal plant operations, cooldown or shutdown EAL:

RA3.2 Alert An UNPLANNED event results in radiation levels that prohibit or IMPEDE access to any Table R-3 room or area (Note 5)

Note 5: If the equipment in the listed room or area was already inoperable or out-of-service before the event occurred, then no emergency classification is warranted.

Table R-3 Safe Operation & Shutdown Rooms/Areas Room/Area Mode(s)

Auxiliary Building 18' 1, 2, 3, 4, 5 Turbine Building (any level) 1, 2, 3, 4, 5 Containment 4, 5 HHSI Pump, CSP Rooms 3 RHR Pump & HX Rooms 4 Rad Waste Building 1, 2, 3, 4, 5 Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown, 5 - Cold Shutdown Definition(s):

IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

UNPLANNED-. A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

Basis:

This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or impede personnel from performing actions necessary to maintain normal plant operation, or to perform a normal plant cooldown and shutdown. As such, it represents an actual or potential substantial degradation of the level of safety of the plant. The Emergency Director Coordinator should consider the cause of the increased radiation levels and determine if another IC may be applicable.

Page 65 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases For EAL #2 RA3.2, 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 at the time of the elevated radiation levels. 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 if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., installing temporary shielding, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits).

An emergency declaration is not warranted if any of the following conditions apply:

The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the elevated radiation levels). For example, the plant is in Mode 1 when the radiation increase occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.

The increased radiation levels are a result of a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., radiography, spent filter or resin transfer, etc.).

The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.

Escalation of the emergency classification level would be via Recognition Category AR, C or F ICs.

If the equipment in the listed room or area was already inoperable, or out-of-service, before the event occurred, then no emergency should be declared since the event will have no adverse impact beyond that already allowed by Technical Specifications at the time of the event.

The list of plant rooms or areas with entry-related mode applicability identified specify those rooms or areas that contain equipment which require a manual/local action as specified in operating procedures used for normal plant operation, cooldown and shutdown. Rooms or areas in which actions of a contingent or emergency nature would be performed (e.g., an action to address an off-normal or emergency condition such as emergency repairs, corrective measures or emergency operations) are not included. In addition, the list specifies the plant mode(s) during which entry would be required for each room or area (ref. 1).

Reference(s):

1. Attachment 2 Safe Operation & Shutdown Areas Tables R-3 & H-2 Bases

2. NEI 99-01 AA3 Page 66 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category C - Cold Shutdown / Refueling System Malfunction EAL Group: Cold Conditions (RCS temperature 200ºF); EALs in this category are applicable only in one or more cold operating modes.

Category C EALs are directly associated with cold shutdown or refueling system safety functions. Given the variability of plant configurations (e.g., systems out-of-service for maintenance, containment open, reduced AC power redundancy, time since shutdown) during these periods, the consequences of any given initiating event can vary greatly. For example, a loss of decay heat removal capability that occurs at the end of an extended outage has less significance than a similar loss occurring during the first week after shutdown. Compounding these events is the likelihood that instrumentation necessary for assessment may also be inoperable. The cold shutdown and refueling system malfunction EALs are based on performance capability to the extent possible with consideration given to RCS integrity, CONTAINMENT CLOSURE, and fuel clad integrity for the applicable operating modes (5 -

Cold Shutdown, 6 - Refueling, DEF - Defueled).

The events of this category pertain to the following subcategories:

1. RCS Level RCS water level is directly related to the status of adequate core cooling and, therefore, fuel clad integrity.

2. Loss of Emergency AC Power Loss of vital plant electrical power can compromise plant safety system operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of onsite and offsite power sources for 4KV emergency buses.

3. RCS Temperature Uncontrolled or inadvertent temperature or pressure rises are indicative of a potential loss of safety functions.

4. Loss of Vital DC Power Loss of emergency plant electrical power can compromise plant safety system operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of power to or degraded voltage on the 125V DC vital buses.

5. Loss of Communications Certain events that degrade plant operator ability to effectively communicate with essential personnel within or external to the plant warrant emergency classification.

Page 67 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases

6. Hazardous Event Affecting Safety Systems Certain hazardous natural and technological events may result in VISIBLE DAMAGE to or degraded performance of multiple safety system trains warranting classification.

Page 68 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: UNPLANNED loss of RCS inventory EAL:

CU1.1 Unusual Event UNPLANNED loss of reactor coolant results in RCS water level less than a required lower limit for 15 min. (Note 1)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

UNPLANNED-. A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

Basis:

RCS water level less than a required lower limit is meant to be less than the lower end of the level control band being procedurally maintained for the current condition or evolution.

With the plant in Cold Shutdown, RCS water level is normally maintained within a pressurizer level control band (ref. 1). However, if RCS level is being controlled below the normal pressurizer level control band, or if level is being maintained in a designated band in the reactor vessel it is the inability to maintain level above the low end of the designated control band due to a loss of inventory resulting from a leak in the RCS that is the concern.

With the plant in Refueling mode, RCS water level is normally maintained at or above the reactor vessel flange (ref. 2).

This IC addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor (reactor vessel/RCS

[PWR] or RPV [BWR]) level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant.

Refueling evolutions that decrease RCS water inventory are carefully planned and controlled.

An UNPLANNED event that results in water level decreasing below a procedurally required limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered.

This EAL #1 recognizes that the minimum required (reactor vessel/RCS [PWR] or RPV

[BWR]) level can change several times during the course of a refueling outage as different plant configurations and system lineups are implemented. This EAL is met if the minimum level, specified for the current plant conditions, cannot be maintained for 15 minutes or longer.

Page 69 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases The minimum level is typically specified in the applicable operating procedure but may be specified in another controlling document.

The 15-minute threshold duration allows sufficient time for prompt operator actions to restore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level.

EAL #2 addresses a condition where all means to determine (reactor vessel/RCS [PWR] or RPV [BWR]) level have been 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 changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the (reactor vessel/RCS [PWR] or RPV [BWR]).

Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA1 or CA3.

Reference(s):

1. 3[4]-GOP-305 Hot Standby to Cold Shutdown

2. 3[4]-NOP-041.07 Draining the Reactor Coolant System

3. NEI 99-01 CU1 Page 70 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: UNPLANNED loss of RCS inventory EAL:

CU1.2 Unusual Event RCS water level cannot be monitored AND EITHER:

UNPLANNED increase in any Table C-1 sump or tank level due to a loss of RCS inventory Visual observation of UNISOLABLE RCS leakage Table C-1 Sumps/Tanks Containment Sump

1. 1 Waste Holdup Tank (DCS or Waste Boron Panel)

CVCS Holdup Tank (Waste Boron Panel)

RWST RHR Sumps Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.

UNPLANNED-. A parameter changes or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

Basis:

This IC addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor (reactor vessel/RCS [PWR]

or RPV [BWR]) level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant.

Refueling evolutions that decrease RCS water inventory are carefully planned and controlled.

An UNPLANNED event that results in water level decreasing below a procedurally required Page 71 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered.

EAL #1 recognizes that the minimum required (reactor vessel/RCS [PWR] or [BWR]) level can change several times during the course of a refueling outage as different plant configurations and system lineups are implemented. This EAL is met if the minimum level, specified for the current plant conditions, cannot be maintained for 15 minutes or longer. The minimum level is typically specified in the applicable operating procedure but may be specified in another controlling document.

The 15-minute threshold duration allows sufficient time for prompt operator actions to restore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level.

This EAL #2 addresses a condition where all means to determine (reactor vessel/RCS [PWR]

or [BWR]) level have been lost. In this condition, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels (Table C-1) (ref. 1, 2).

Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the (reactor vessel/RCS [PWR] or [BWR]).

Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA1 or CA3.

Reference(s):

1. 3[4]-ONOP-041.3 Excessive Reactor Coolant System Leakage

2. 3[4]-ONOP-041.8 Shutdown LOCA [Mode 5 OR 6]

3. NEI 99-01 CU1 Page 72 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Significant Loss of RCS inventory EAL:

CA1.1 Alert RCS water level < 23% on LIS-3[4]-6421 or LIS-3[4]-6423 Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

None Basis:

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). This condition represents a potential substantial reduction in the level of plant safety.

For this EAL #1, a lowering of RCS water level below the minimum required for continued SI pump operation (site-specific level) ft indicates that operator actions have not been successful in restoring and maintaining (reactor vessel/RCS [PWR] or RPV [BWR]) water level. The heat-up rate of the coolant will increase as the available water inventory is reduced. A continuing decrease in water level will lead to core uncovery.

The minimum RCS level for continued RHR pump operation is 23% on RCS Draindown Level Instrumentation (LIS-3[4]-6421 or LIS-3[4]-6423) (ref. 1).

Although related, this EAL is concerned with the loss of RCS inventory and not the potential concurrent effects on systems needed for decay heat removal (e.g., loss of a Residual Decay Heat Removal suction point). An increase in RCS temperature caused by a loss of decay heat removal capability is evaluated under IC CA3.

For EAL #2, the inability to monitor (reactor vessel/RCS [PWR] or RPV [BWR]) 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 an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the (reactor vessel/RCS [PWR] or RPV [BWR]).

The 15-minute duration for the loss of level indication was chosen because it is half of the EAL duration specified in IC CS1 If RCS the (reactor vessel/RCS [PWR] or RPV [BWR]) inventory water level continues to lower, then escalation to Site Area Emergency would be via IC CS1.

Reference(s):

Page 73 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases

1. 3[4]-ONOP-050 Loss of RHR

2. NEI 99-01 CA1 Page 74 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Significant Loss of RCS inventory EAL:

CA1.2 Alert RCS water level cannot be monitored for 15 min. (Note 1)

AND EITHER UNPLANNED increase in any Table C-1 sump or tank level due to a loss of RCS inventory Visual observation of UNISOLABLE RCS leakage Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Table C-1 Sumps/Tanks Containment Sump

1. 1 Waste Holdup Tank (DCS or Waste Boron Panel)

CVCS Holdup Tank (Waste Boron Panel)

RWST RHR Sumps Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.

UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

Page 75 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Basis:

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). This condition represents a potential substantial reduction in the level of plant safety.

For EAL #1, a lowering of water level below (site-specific level) indicates that operator actions have not been successful in restoring and maintaining (reactor vessel/RCS [PWR] or RPV

[BWR]) water level. The heat-up rate of the coolant will increase as the available water inventory is reduced. A continuing decrease in water level will lead to core uncovery.

Although related, EAL #1 is concerned with the loss of RCS inventory and not the potential concurrent effects on systems needed for decay heat removal (e.g., loss of a Residual Heat Removal suction point). An increase in RCS temperature caused by a loss of decay heat removal capability is evaluated under IC CA3.

For this EAL #2, the inability to monitor (reactor vessel/RCS [PWR] or RPV [BWR]) 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 an inventory loss is occurring by observing changes in sump and/or tank levels (Table C-1) (ref. 1, 2). Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the (reactor vessel/RCS [PWR] or RPV [BWR]) .

The 15-minute duration for the loss of level indication was chosen because it is half of the EAL duration specified in IC CS1.

If the (reactor vessel/RCS [PWR] or RPV [BWR]) inventory level continues to lower, then escalation to Site Area Emergency would be via IC CS1.

Reference(s):

1. 3[4]-ONOP-041.3 Excessive Reactor Coolant System Leakage

2. 3[4]-ONOP-041.8 Shutdown LOCA [Mode 5 OR 6]

3. NEI 99-01 CA1 Page 76 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory affecting core decay heat removal capability EAL:

CS1.1 Site Area Emergency RCS water level < 10% on LIS-3[4]-6421 or LIS-3[4]-6423 Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

IMMINENT - The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

Basis:

This IC addresses a significant and prolonged loss of (reactor vessel/RCS [PWR] or RCS

[BWR]) inventory control and makeup capability leading to IMMINENT fuel damage. 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 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, decay heat will cause reactor coolant boiling and a further reduction in RCS level. If RCS/reactor vesselRCS 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 control functions. The difference in the specified RCS/reactor vessel levels of EALs 1.b and 2.b reflect the fact that with CONTAINMENT CLOSURE established, there is a lower probability 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 has actually 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 (reactor vessel/RCS [PWR] or RCS [BWR]) 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 an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the (reactor vessel/RCS [PWR] or RCS [BWR]).

Page 77 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases 10% on RCS Draindown Level Instrumentation (LIS-3[4]-6421 or LIS-3[4]-6423) is the lowest RCS level that can be monitored in the cold condition and nominally corresponds to the bottom of the RCS hot leg (ref. 1).

Thisese EALs addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Escalation of the emergency classification level would be via ICs CG1 or AG1RG1.

Reference(s):

1. Drawing 5613-J-815/ Drawing 5614-J-815

2. Plant Curve Book PCB-3-S5F09/ PCB-4-S5F09

3. NEI 99-01 CS1 Page 78 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory affecting core decay heat removal capability EAL:

CS1.2 Site Area Emergency RCS level cannot be monitored for 30 min. (Note 1)

AND Core uncovery is indicated by any of the following:

UNPLANNED increase in any Table C-1 sump or tank level of sufficient magnitude to indicate core uncovery Visual observation of UNISOLABLE RCS leakage of sufficient magnitude to indicate core uncovery RAD-3[4]-6311B reading > 9.4E+04 R/hr (Refueling Mode)

Erratic source range monitor indications Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Table C-1 Sumps/Tanks Containment Sump

1. 1 Waste Holdup Tank (DCS or Waste Boron Panel)

CVCS Holdup Tank (Waste Boron Panel)

RWST RHR Sumps Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

IMMINENT - The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.

UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

Page 79 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Basis:

This IC addresses a significant and prolonged loss of (reactor vessel/RCS RCS [PWR] or RPV

[BWR]) inventory control and makeup capability leading to IMMINENT fuel damage. 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 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, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/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 control functions. The difference in the specified RCS/reactor vessel levels of EALs 1.b and 2.b reflect the fact that with CONTAINMENT CLOSURE established, there is a lower probability of a fission product release to the environment.

In this 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 has actually 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 (reactor vessel/RCS [PWR] or RPV [BWR]) 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 an inventory loss is occurring by observing changes in sump and/or tank levels (ref. 1, 2). Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the (reactor vessel/RCS [PWR] or RPV [BWR]) .

If the make-up rate to the RCS unexplainably rises above the pre-established rate, a loss of RCS inventory may be occurring even if the source of the leakage cannot be immediately identified. Visual observation of leakage from systems connected to the RCS that cannot be isolated could also be indicative of a loss of RCS inventory.

In the Refueling mode, as water level in the reactor vessel lowers, the dose rate above the core will rise. The dose rate due to this core shine should result in on-scale indications on area radiation monitors. A reading > 9.4E+04 R/hr on RAD-3[4]-6311B Containment High Range Radiation Monitor (CHRRM) is indicative of RCS water level at the top of active fuel while in the Refueling mode. Of the two CHRRM channels RAD-6311B has the most reliable response to the core shine due to its location on the 58 operating floor on both units (ref. 3).

Post-TMI accident studies indicated that the installed PWR nuclear instrumentation will operate erratically when the core is uncovered and that this should be used as a tool for making such determinations.

These This EALs addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United Page 80 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Escalation of the emergency classification level would be via IC CG1 or AG1RG1 Reference(s):

1. 3[4]-ONOP-041.3 Excessive Reactor Coolant System Leakage

2. 3[4]-ONOP-041.8 Shutdown LOCA [Mode 5 OR 6]

3. DBD PTN NEI-99-01 Radiation Monitor Values Used in Recognition Categories R, F and C

4. NEI 99-01 CS1 Page 81 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 1 - RCS Level Initiating Condition: Loss of RCS inventory affecting fuel clad integrity with containment challenged EAL:

CG1.1 General Emergency RCS level cannot be monitored for 30 min. (Note 1)

AND Core uncovery is indicated by any of the following:

UNPLANNED increase in any Table C-1 sump or tank level of sufficient magnitude to indicate core uncovery Visual observation of UNISOLABLE RCS leakage of sufficient magnitude to indicate core uncovery RAD-3[4]-6311B reading > 9.4E+04 R/hr (Refueling Mode)

Erratic source range monitor indications AND Any Containment Challenge indication, Table C-2 Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Note 6: If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, declaration of a General Emergency is not required.

Table C-1 Sumps/Tanks Containment Sump

1. 1 Waste Holdup Tank (DCS or Waste Boron Panel)

CVCS Holdup Tank (Waste Boron Panel)

RWST RHR Sumps Page 82 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Table C-2 Containment Challenge Indications CONTAINMENT CLOSURE not established (Note 6)

CTMT hydrogen concentration > 4%

UNPLANNED increase in CTMT pressure Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The procedurally defined conditions or actions taken to secure containment and associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

Containment Closure requirements are specified in 0-ADM-051 Outage Risk Assessment and Control.

IMMINENT - The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.

UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

Basis:

This IC addresses the inability to restore and maintain reactor vesselRCS level above the top of active fuel with containment challenged. This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity.

Releases can be reasonably expected to exceed EPA PAG exposure levels offsite for more than the immediate site area.

Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.

The inability to monitor (reactor vessel/RCS [PWR] or RCS [BWR]) 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 an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the (reactor vessel/RCS [PWR] or RPV [BWR]) (ref. 1, 3).

If the make-up rate to the RCS unexplainably rises above the pre-established rate, a loss of RCS inventory may be occurring even if the source of the leakage cannot be immediately Page 83 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases identified. Visual observation of leakage from systems connected to the RCS that cannot be isolated could also be indicative of a loss of RCS inventory.

In the Refueling mode, as water level in the reactor vessel lowers, the dose rate above the core will rise. The dose rate due to this core shine should result in on-scale indications on area radiation monitors. A reading > 9.4E+04 R/hr on RAD-3[4]-6311B Containment High Range Radiation Monitor (CHRRM) is indicative of RCS water level at the top of active fuel while in the Refueling mode. Of the two CHRRM channels RAD-6311B has the most reliable response to the core shine due to its location on the 58 operating floor on both units (ref. 3).

Post-TMI accident studies indicated that the installed PWR nuclear instrumentation will operate erratically when the core is uncovered and that this should be used as a tool for making such determinations.

In EAL 2.b, tThe 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 has actually 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.

Three conditions are associated with a challenge to containments capability to serve as an effective barrier to fission product release:

1. With CONTAINMENT CLOSURE not established, there is a high potential for a direct and 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.

2. 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 the lower deflagration limit of 4%). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a challenge to containment integrity.

In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a core uncovery could result in an explosive gas mixture in containment. However, containment monitoring and/or sampling should be performed to verify this assumption and a General Emergency declared if it is determined that hydrogen concentration has exceeded the minimum necessary to support a hydrogen burn (4%) (ref. 4). If all installed hydrogen gas monitors are out-of-service during an event leading to fuel cladding damage, 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 is challenged.

3. Any UNPLANNED rise in containment pressure in the Cold Shutdown or Refueling mode indicates a potential challenge of CONTAINMENT CLOSURE capability.

UNPLANNED containment pressure rise indicates CONTAINMENT CLOSURE cannot Page 84 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases be assured and the containment cannot be relied upon as a barrier to fission product release.

Thisese EALs addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Reference(s):

1. 3[4]-ONOP-041.3 Excessive Reactor Coolant System Leakage

2. 3[4]-ONOP-041.8 Shutdown LOCA [Mode 5 OR 6]

3. DBD PTN NEI-99-01 Radiation Monitor Values Used in Recognition Categories R, F and C

4. CA-3 Computational Aids Hydrogen Flammability in Containment

5. NEI 99-01 CG1 Page 85 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 2 - Loss of Emergency AC Power Initiating Condition: Loss of all but one AC power source to emergency buses for 15 minutes or longer EAL:

CU2.1 Unusual Event AC power capability, Table C-3, to 4KV emergency buses 3[4]A and 3[4]B reduced to a single power source for 15 min. (Note 1)

AND Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Table C-3 AC Power Sources Offsite Unit 3[4] Startup Transformer Unit 3[4] C Bus Transformer Unit 3[4] Opposite Unit Cross Tie Unit 3[4] Auxiliary Transformer back fed via Main Transformer (if already aligned)

Onsite 3A[4A] Emergency Diesel Generator 3B[4B] Emergency Diesel Generator 3[4] D Bus SBO Cross Tie Mode Applicability:

5 - Cold Shutdown, 6 - Refueling, DEF - Defueled Definition(s):

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10CFR50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; Page 86 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

Table C-3 provides a list of offsite and onsite AC electrical power sources credited for this EAL.

Offsite AC power sources annotated (if already aligned) require more than 15 minutes to establish and therefore are only credited if the source was already aligned at the time of AC power loss (ref. 1, 2, 3).

This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than 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 to service.

Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition is considered to be a potential degradation of the level of safety of the plant.

An AC power source is a source recognized in AOPs and EOPs, and capable of supplying required power to an emergency bus. Some examples of this condition are presented below.

A loss of all offsite power with a concurrent failure of all but one emergency power source (e.g., an onsite diesel generator).

A loss of all offsite power and loss of all emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from the unit main generator.

A loss of emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being fed or back-fed from an offsite power source.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.

The subsequent loss of the remaining single power source would escalate the event to an Alert in accordance with IC CA2.

This cold condition EAL is equivalent to the hot condition EAL SA1.1.

Reference(s):

1. Technical Specifications Section 3.8.1.2 A. C. Sources Shutdown

2. UFSAR section 8.2.2 Station Electrical System

3. 3[4]-NOP-092.01 Main/Auxiliary Transformer Backfeed

4. NEI 99-01 CU2 Page 87 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 2 - Loss of Emergency AC Power Initiating Condition: Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or longer EAL:

CA2.1 Alert Loss of all offsite and all onsite AC power to 4KV emergency buses 3[4]A and 3[4]B for 15 min. (Note 1)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling, DEF - Defueled Definition(s):

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10CFR50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

For this EAL credit can be taken for any AC power source that has sufficient capability to operate equipment necessary to maintain a safe shutdown condition, such as FLEX generators, provided it can be aligned within the 15 minute classification criteria.

This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the 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 an emergency bus to service. Additional time is available due to the reduced core decay heat 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 power losses.

Page 88 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Escalation of the emergency classification level would be via ICs CS1 or AS1RS1.

This cold condition EAL is equivalent to the hot condition EAL RS1.1.

Reference(s):

1. Technical Specifications Section 3.8.1.2 A. C. Sources Shutdown

2. UFSAR section 8.2.2 Station Electrical System

3. NEI 99-01 CU2 Page 89 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 3 - RCS Temperature Initiating Condition: UNPLANNED increase in RCS temperature EAL:

CU3.1 Unusual Event UNPLANNED increase in RCS temperature to > 200°F due to loss of decay heat removal capability (Note 14)

Note 14: In the absence of reliable RCS temperature indication caused by the loss of decay heat removal capability, classification should be based on time to 200°F assuming a 12°F per minute heat-up rate (4°F per minute if the refueling cavity is flooded) when in Mode 6 or the RCS is not intact in Mode 5. If the RCS is intact, classification should be based on the RCS pressure rise criteria of CA3.1.

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The procedurally defined conditions or actions taken to secure containment and associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

Containment Closure requirements are met when all of the following conditions exist:

The equipment hatch is closed with a minimum of four bolts.

All other penetrations are capable of being closed by a containment automatic isolation valve system or closed by manual valve or blind flanges.

UNPLANNED-. A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

Basis:

In the absence of reliable RCS temperature indication caused by the loss of decay heat removal capability, classification should be based on time to 200°F assuming a 12°F per minute heat-up rate (4°F per minute if the refueling cavity is flooded) when in Mode 6 or the RCS is not intact in Mode 5 (ref. 1). If the RCS is intact, classification should be based on the RCS pressure rise criteria of CA3.1. Assumed RCS heat-up rates are specified per 3[4]-

ONOP-050 Loss of RHR (ref. 2).

This IC EAL addresses an UNPLANNED increase in RCS temperature above the Technical Specification cold shutdown temperature limit or the inability to determine RCS temperature and level,and represents a potential degradation of the level of safety of the plant (ref. 1). If the RCS is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency DirectorEC should also refer to IC EAL CA3.1.

A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.

Page 90 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases EAL #1This EALThis EAL involves a loss of decay heat removal capability, or an addition of heat to the RCS in excess of that which can currently be removed, such that reactor coolant temperature cannot be maintained below the cold shutdown temperature limit specified in Technical Specifications. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.

During an outage, the level in the reactor vessel will normally be maintained at or above the reactor vessel flange. Refueling evolutions that lower water level below the reactor vessel flange are carefully planned and controlled. A loss of forced decay heat removal at reduced inventory may result in a rapid increase in reactor coolant temperature depending on the time after shutdown (ref. 3).

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 to monitor key parameters necessary to assure core decay heat removal. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.

Escalation to Alert would be via IC CA1 based on an inventory loss or IC CA3 based on exceeding plant configuration-specific time criteria.

Reference(s):

1. Technical Specifications Table 1.2, Operational Modes

2. 3[4]-ONOP-050 Loss of RHR

3. 0-ADM-051 Outage Risk Assessment and Control

4. NEI 99-01 CU3 Page 91 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 3 - RCS Temperature Initiating Condition: UNPLANNED rise in RCS temperature EAL:

CU3.2 Unusual Event Loss of all RCS temperature and RCS water level indication for 15 min. (Note 1)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Mode Applicability:

5 - Cold Shutdown, 6- Refueling Definition(s):

CONTAINMENT CLOSURE - The procedurally defined conditions or actions taken to secure containment and associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

Containment Closure requirements are specified in 0-ADM-051 Outage Risk Assessment and Control.

Basis:

This IC EALEAL addresses an UNPLANNED increase in RCS temperature above the Technical Specification cold shutdown temperature limit, or the inability to determine RCS temperature and level, andand represents a potential degradation of the level of safety of the plant. If the RCS is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency DirectorEC should also refer to IC EAL CA3.1.

A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.

EAL #1 involves a loss of decay heat removal capability, or an addition of heat to the RCS in excess of that which can currently be removed, such that reactor coolant temperature cannot be maintained below the cold shutdown temperature limit specified in Technical Specifications.

During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.

During an outage, the level in the reactor vessel will normally be maintained above the reactor vessel flange. Refueling evolutions that lower water level below the reactor vessel flange are carefully planned and controlled. A loss of forced decay heat removal at reduced inventory may result in a rapid increase in reactor coolant temperature depending on the time after shutdown.

EAL #2This EALThis EAL reflects a condition where there has been a significant loss of instrumentation capability necessary to monitor RCS conditions and operators would be unable to monitor key parameters necessary to assure core decay heat removal. During this Page 92 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.

Escalation to Alert would be via IC CA1 based on an inventory loss or IC CA3 based on exceeding plant configuration-specific time criteria.

Reference(s):

1. 0-ADM-051 Outage Risk Assessment and Control

2. NEI 99-01 CU3 Page 93 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 3 - RCS Temperature Initiating Condition: Inability to maintain plant in cold shutdown EAL:

CA3.1 Alert UNPLANNED rise in RCS temperature to > 200°F for > Table C-4 duration due to a loss of RCS cooling (Notes 1, 12)

OR UNPLANNED RCS pressure rise > 10 psig (does not apply to solid plant conditions)

Note 1: The EC should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

Note 12: If an RCS heat removal system is in operation within the applicable Table C-4 heat-up duration and RCS temperature is being reduced, the EAL is not applicable.

Note 14: In the absence of reliable RCS temperature indication caused by the loss of decay heat removal capability, classification should be based on time to 200°F assuming a 12°F per minute heat-up rate (4°F per minute if the refueling cavity is flooded) when in Mode 6 or the RCS is not intact in Mode 5. If the RCS is intact, classification should be based on the RCS pressure rise criteria of CA3.1.

Table C-4 RCS Heat-up Duration Thresholds CONTAINMENT RCS Status Heat-up Duration CLOSURE Status Intact AND not lowered N/A 60 min.

inventory Not intact OR Established 20 min.

lowered inventory Not established 0 min.

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

CONTAINMENT CLOSURE - The procedurally defined conditions or actions taken to secure containment and associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

Containment Closure requirements are specified in 0-ADM-051 Outage Risk Assessment and Control.

Page 94 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases UNPLANNED-. A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

Basis:

In the absence of reliable RCS temperature indication caused by the loss of decay heat removal capability, classification should be based on time to 200°F assuming a 12°F per minute heat-up rate (4°F per minute if the refueling cavity is flooded) when in Mode 6 or the RCS is not intact in Mode 5 (ref. 1). If the RCS is intact, classification should be based on the RCS pressure rise criteria of this EAL. Assumed RCS heat-up rates are specified per 3[4]-

ONOP-050 Loss of RHR (ref. 2).

The RCS is considered to be at lowered inventory when RCS level is less than or equal to 3 ft.

below the reactor vessel flange with fuel in the reactor vessel (ref. 3).

This IC EAL addresses conditions involving a loss of decay heat removal capability or an addition of heat to the RCS in excess of that which can currently be removed. Either condition represents an actual or potential substantial degradation of the level of safety of the plant.

A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.

The RCS Heat-up Duration Thresholds table addresses an increase in RCS temperature when CONTAINMENT CLOSURE is established but the RCS is not intact, or RCS inventory is reduced (e.g., mid-loop operation in PWRs). The 20-minute criterion was included to allow time for operator action to address the temperature increase.

The RCS Heat-up Duration Thresholds table also addresses an increase in RCS temperature with the RCS intact. The status of CONTAINMENT CLOSURE is not crucial in this condition since the intact RCS is providing a high pressure barrier to a fission product release. The 60-minute time frame should allow sufficient time to address the temperature increase without a substantial degradation in plant safety.

Finally, in the case where there is an increase in RCS temperature, the RCS is not intact or is at reduced inventory [PWR], and CONTAINMENT CLOSURE is not established, no heat-up duration is allowed (i.e., 0 minutes). This is because 1) the evaporated 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.

The RCS pressure rise threshold EAL #2 provides a pressure-based indication of RCS heat-up in the absence of RCS temperature monitoring capability.

Escalation of the emergency classification level would be via IC CS1 or AS1RS1.

Reference(s):

1. Technical Specifications Table 1.2, Operational Modes

2. 3[4]-ONOP-050 Loss of RHR

3. 0-ADM-051 Outage Risk Assessment and Control

4. NEI 99-01 CA3 Page 95 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Page 96 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 4 - Loss of Vital DC Power Initiating Condition: Loss of vital DC power for 15 minutes or longer EAL:

CU4.1 Unusual Event Indicated voltage < 105 VDC on any two vital 125 VDC buses (3D01, 4D01, 3D23, 4D23) for 15 min. (Note 1)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Definition(s):

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10CFR50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis The vital (Class 1E) 125 V DC power system consists of four physically and electrically separated buses - 3D01, 3D23, 4D01 and 4D23. Each bus has a 60 cell battery bank with an eight-hour rating, with a minimum operating voltage of 105 volts (ref. 1, 2, 3).

This IC addresses a loss of vital DC power which compromises the ability to monitor and control operable SAFETY SYSTEMS when the plant is in the cold shutdown or refueling 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 is considered 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 support operation 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 B would require the declaration of an Unusual Event. A loss of vital DC power to Train A would not warrant an emergency classification.

Page 97 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Depending upon the event, escalation of the emergency classification level would be via IC CA1 or CA3, or an IC in Recognition Category AR.

This cold condition EAL is equivalent to the hot condition EAL SS2.1.

Reference(s):

1. UFSAR Section 8.2.2.3 DC Power Systems

2. 5610-003-DB-002 Vital AC/DC Component Design Requirements

3. Technical Specifications Section 3.8.2.2 D.C. Sources Shutdown

4. NEI 99-01 CU4 Page 98 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 5 - Loss of Communications Initiating Condition: Loss of all onsite or offsite communications capabilities EAL:

CU5.1 Unusual Event Loss of all Table C-5 onsite communication methods OR Loss of all Table C-5 State and local agency communication methods OR Loss of all Table C-5 NRC communication methods Table C-5 Communication Methods State/

System Onsite NRC Local Plant Radio System X Commercial Telephone System X X X Plant Address (PA) System X Federal Telephone System (ENS) X EMnet X Hot Ring Down (HRD) Telephone System X Mode Applicability:

5 - Cold Shutdown, 6 - Refueling, DEF - Defueled Definition(s):

None Page 99 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Basis:

This IC addresses a significant loss of on-site or offsite communications capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to OROs State and local agencies and the NRC.

This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).

The first EAL condition EAL #1 addresses a total loss of the communications methods used in support of routine plant operations.

The second EAL condition EAL #2 addresses a total loss of the communications methods used to notify all OROs State and local agencies of an emergency declaration. The OROs State and local agencies referred to here are (see Developer Notes)the State of Florida and affected local communities.

The third EAL condition EAL #3 addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.

This cold condition EAL is equivalent to the hot condition EAL SU7.1.

Reference(s):

1. Turkey Point Plant Radiological Emergency Plan

2. NEI 99-01 CU5 Page 100 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: C - Cold Shutdown / Refueling System Malfunction Subcategory: 6 - Hazardous Event Affecting Safety Systems Initiating Condition: Hazardous event affecting SAFETY SYSTEMS needed for the current operating mode EAL:

CA6.1 Alert The occurrence of any Table C-6 hazardous event AND Event damage has caused indications of degraded performance on one train of a SAFETY SYSTEM needed for the current operating mode AND EITHER:

Event damage has caused indications of degraded performance to the second train of the SAFETY SYSTEM needed for the current operating mode Event damage has resulted in VISIBLE DAMAGE to the second train of the SAFETY SYSTEM needed for the current operating mode (Notes 9, 10)

Note 9: If the affected SAFETY SYSTEM train was already inoperable or out of service before the hazardous event occurred, then emergency classification is not warranted.

Note 10: If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.

Table C-6 Hazardous Events Seismic event (earthquake)

Internal or external FLOODING event High winds or tornado strike FIRE EXPLOSION Other events with similar hazard characteristics as determined by the Shift Manager Mode Applicability:

5 - Cold Shutdown, 6 - Refueling Page 101 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Definition(s):

EXPLOSION - A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization. A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion. Such events require a post-event inspection to determine if the attributes of an explosion are present.

FIRE - Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.

FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10CFR50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

VISIBLE DAMAGE - Damage to a SAFETY SYSTEM train that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected SAFETY SYSTEM train.

Basis:

This IC addresses a hazardous event that causes damage to SAFETY SYSTEMS needed for the current operating mode. In order to provide the appropriate context for consideration of an ALERT classification, the hazardous event must have caused indications of degraded SAFETY SYSTEM performance in one train, and there must be either indications of performance issues with the second SAFETY SYSTEM train or VISIBLE DAMAGE to the second train such that the potential exists for this second SAFETY SYSTEM train to have performance issues. In other words, in order for this EAL to be classified, the hazardous event must occur, at least one SAFETY SYSTEM train must have indications of degraded performance, and the second SAFETY SYSTEM train must have indications of degraded performance or VISIBLE DAMAGE such that the potential exists for performance issues. Note that this second SAFETY SYSTEM train is from the same SAFETY SYSTEM that has indications of degraded performance; commercial nuclear power plants are designed to be able to support single system issues without compromising public health and safety from radiological events.

Indications of degraded performance addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or Page 102 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases reliability of the SAFETY SYSTEM train.

VISIBLE DAMAGE addresses damage to a SAFETY SYSTEM train that is not in service/operation and that potentially could cause performance issues. Operators will make this determination 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. This VISIBLE DAMAGE should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

An event affecting equipment common to two or more trains of a safety system (i.e., there are indications of degraded performance and/or VISIBLE DAMAGE affecting the common equipment) should be classified as an Alert under this EAL, as appropriate to the plant mode.

By affecting the functionality of multiple trains of a safety system, the loss of the common equipment effectively meets the two-train impact criteria that underlie the EALs and bases.

An event affecting a single-train safety system (i.e., there are indications of degraded performance and/or VISIBLE DAMAGE affecting the one train) would not be classified under this EAL because the two-train impact criteria that underlie the EALs and bases would not be met. If an event affects a single-train safety system, then the emergency classification should be made based on plant parameters/symptoms meeting the EALs for another IC. Depending upon the circumstances, classification may also occur based on Shift Manager/EC judgement.

An event that affects two trains of a safety system (e.g., one train has indications of degraded performance and the other VISIBLE DAMAGE) that also has one or more additional trains should be classified as an Alert under this EAL, as appropriate to the plant mode. This approach maintains consistency with the two-train impact criteria that underlie the EALs and bases, and is warranted because the event was severe enough to affect the functionality of two trains of a safety system despite plant design criteria associated with system and system train separation and protection. Such an event may have caused other plant impacts that are not immediately apparent.

This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or a structure containing SAFETY SYSTEM components, needed for the current operating 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.

EAL 1.b.1 addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

EAL 1.b.2 addresses damage to a SAFETY SYSTEM component that is not in service/operation 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 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 CS1 or AS1RS1.

This cold condition EAL is equivalent to the hot condition EAL SA9.1.

Page 103 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Reference(s):

1. 0-EPIP-20106 Natural Emergencies

2. EP FAQ 2016-002

3. NEI 99-01 CA6 Page 104 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category E - Independent Spent Fuel Storage Installation (ISFSI)

EAL Group: ANY (EALs in this category are applicable to any plant condition, hot or cold.)

An independent spent fuel storage installation (ISFSI) is a complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage. A significant amount of the radioactive material contained within a canister must escape its packaging and enter the biosphere for there to be a significant environmental effect resulting from an accident involving the dry storage of spent nuclear fuel.

A Notification of Unusual Event is declared on the basis of the occurrence of an event of sufficient magnitude that a loaded cask CONFINEMENT BOUNDARY is damaged or violated.

The PTN ISFSI is located wholly outside the PTN plant PROTECTED AREA. Any security event related to the ISFSI is classified under either ICs HU1 or HA1 security event related EALs.

Page 105 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: E - ISFSI Subcategory: 1 - Confinement Boundary Initiating Condition: Damage to a loaded cask CONFINEMENT BOUNDARY EAL:

EU1.1 Unusual Event Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading on the surface of a loaded spent fuel cask (HSM) > any of the following:

1,600 mrem/hr on the HSM front bird screen 4 mrem/hr on the outside HSM door centerline 4 mrem/hr on the HSM end shield wall exterior Mode Applicability:

All Definition(s):

CONFINEMENT BOUNDARY- The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the PTN ISFSI, Confinement Boundary is defined as the NUHOMS Dry Shielding Canister (DSC).

INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.

Basis:

This IC addresses an event that results in damage to the CONFINEMENT BOUNDARY of a storage cask containing spent fuel. It applies to irradiated fuel that is licensed for dry storage beginning at the point that the loaded storage cask is sealed. The issues of concern are the creation of a potential or actual release path to the environment, degradation of one or more fuel assemblies due to environmental factors, and configuration changes which could cause challenges in removing the cask or fuel from storage.

The existence of damage is determined by radiological survey. The specified EAL threshold values correspond to 2 times the NUHOMS Horizontal Storage Module (HSM) technical specification external surface dose rate limits (ref. 1). The technical specification multiple of 2 times, which is also used in Recognition Category A R IC AU1RU1, 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 spent fuel 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 dose rate limit is exceeded may be determined based on measurement of a dose rate at some distance from the cask.

Page 106 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Security-related events for ISFSIs are covered under ICs HU1 and HA1.

Reference(s):

1. Certificate of Compliance Appendix A NUHOMS HD System Generic Technical Specifications Section 5.4 HSM-H Dose Rate Evaluation Program

2. NEI 99-01 E-HU1 Page 107 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category F - Fission Product Barrier Degradation EAL Group: Hot Conditions (RCS temperature > 200ºF); EALs in this category are applicable only in one or more hot operating modes.

EALs in this category represent threats to the defense in depth design concept that precludes the release of highly radioactive fission products to the environment. This concept relies on multiple physical barriers any one of which, if maintained intact, precludes the release of significant amounts of radioactive fission products to the environment. The primary fission product barriers are:

A. Fuel Clad Barrier (FC): The Fuel Clad Barrier consists of the cladding material that contains the fuel pellets.

B. Reactor Coolant System Barrier (RCS): The RCS Barrier includes the RCS primary side and its connections up to and including the pressurizer safety and relief valves, and other connections up to and including the primary isolation valves.

C. Containment Barrier (CTMT): The Containment Barrier includes the containment building and connections up to and including the outermost containment isolation valves. This barrier also includes the main steam, feedwater, and blowdown line extensions outside the containment building up to and including the outermost secondary side isolation valve. Containment Barrier thresholds are used as criteria for escalation of the Emergency Classification Level (ECL) from an Alert to a Site Area Emergency or a General Emergency.

The EALs in this category require evaluation of the loss and potential loss thresholds listed in the fission product barrier matrix of Table F-1. Loss and Potential Loss signify the relative damage and threat of damage to the barrier. Loss means the barrier no longer assures containment of radioactive materials. Potential Loss means integrity of the barrier is threatened and could be lost if conditions continue to degrade. The number of barriers that are lost or potentially lost and the following criteria determine the appropriate emergency classification level:

Alert:

Any loss or any potential loss of either Fuel Clad or RCS Barrier Site Area Emergency:

Loss or potential loss of any two barriers General Emergency:

Loss of any two barriers and loss or potential loss of third barrier The logic used for emergency classification based on fission product barrier monitoring should reflect the following considerations:

The Fuel Clad Barrier and the RCS Barrier are weighted more heavily than the Containment Barrier.

Page 108 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Unusual Event ICs associated with RCS and Fuel Clad Barriers are addressed under System Malfunction ICs.

For accident conditions involving a radiological release, evaluation of the fission product barrier thresholds will need to be performed in conjunction with dose assessments to ensure correct and timely escalation of the emergency classification. For example, an evaluation of the fission product barrier thresholds may result in a Site Area Emergency classification while a dose assessment may indicate that an EAL for General Emergency IC AG1 RG1 has been exceeded.

The fission product barrier thresholds specified within a scheme reflect plant-specific PTN design and operating characteristics.

As used in this category, the term RCS leakage encompasses not just those types defined in Technical Specifications but also includes the loss of RCS mass to any location- inside the containment, an interfacing system, or outside of the containment.

The release of liquid or steam mass from the RCS due to the as-designed/expected operation of a relief valve is not considered to be RCS leakage.

At the Site Area Emergency level, EAL users should maintain cognizance of how far present conditions are from meeting a threshold that would require a General Emergency declaration. For example, if the Fuel Clad and RCS fission product barriers were both lost, then there should be frequent assessments of containment radioactive inventory and integrity. Alternatively, if both the Fuel Clad and RCS fission product barriers were potentially lost, the Emergency DirectorEC would have more assurance that there was no immediate need to escalate to a General Emergency.

Page 109 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: Fission Product Barrier Degradation Subcategory: N/A Initiating Condition: Any loss or any potential loss of either Fuel Clad or RCS EAL:

FA1.1 Alert Any loss or any potential loss of EITHER Fuel Clad or RCS barrier (Table F-1)

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

None Basis:

Fuel Clad, RCS and Containment comprise the fission product barriers. Table F-1 lists the fission product barrier thresholds, bases and references.

At the Alert classification level, Fuel Clad and RCS barriers are weighted more heavily than the Containment barrier. Unlike the Containment barrier, loss or potential loss of either the Fuel Clad or RCS barrier may result in the relocation of radioactive materials or degradation of core cooling capability. Note that the loss or potential loss of Containment barrier in combination with loss or potential loss of either Fuel Clad or RCS barrier results in declaration of a Site Area Emergency under EAL FS1.1 Reference(s):

1. NEI 99-01 FA1 Page 110 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: Fission Product Barrier Degradation Subcategory: N/A Initiating Condition: Loss or potential loss of any two barriers EAL:

FS1.1 Site Area Emergency Loss or potential loss of any two barriers (Table F-1)

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

IMMINENT - The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

Basis:

Fuel Clad, RCS and Containment comprise the fission product barriers. Table F-1 lists the fission product barrier thresholds, bases and references.

At the Site Area Emergency classification level, each barrier is weighted equally. A Site Area Emergency is therefore appropriate for any combination of the following conditions:

One barrier loss and a second barrier loss (i.e., loss - loss)

One barrier loss and a second barrier potential loss (i.e., loss - potential loss)

One barrier potential loss and a second barrier potential loss (i.e., potential loss -

potential loss)

At the Site Area Emergency classification level, the ability to dynamically assess the proximity of present conditions with respect to the threshold for a General Emergency is important. For example, the existence of Fuel Clad and RCS Barrier loss thresholds in addition to offsite dose assessments would require continual assessments of radioactive inventory and Containment integrity in anticipation of reaching a General Emergency classification. Alternatively, if both Fuel Clad and RCS potential loss thresholds existed, the would have greater assurance that escalation to a General Emergency is less IMMINENT.

Reference(s):

1. NEI 99-01 FS1 Page 111 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: Fission Product Barrier Degradation Subcategory: N/A Initiating Condition: Loss of any two barriers and loss or potential loss of third barrier EAL:

FG1.1 General Emergency Loss of any two barriers AND Loss or potential loss of the third barrier (Table F-1)

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

None Basis:

Fuel Clad, RCS and Containment comprise the fission product barriers. Table F-1 lists the fission product barrier thresholds, bases and references.

At the General Emergency classification level each barrier is weighted equally. A General Emergency is therefore appropriate for any combination of the following conditions:

Loss of Fuel Clad, RCS and Containment Barriers Loss of Fuel Clad and RCS Barriers with potential loss of Containment Barrier Loss of RCS and Containment Barriers with potential loss of Fuel Clad Barrier Loss of Fuel Clad and Containment Barriers with potential loss of RCS Barrier Reference(s):

1. NEI 99-01 FG1 Page 112 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Table F-1 Fission Product Barrier Threshold Matrix & Bases Table F-1 lists the threshold conditions that define the Loss and Potential Loss of the three fission product barriers (Fuel Clad, Reactor Coolant System, and Containment). The table is structured so that each of the three barriers occupies adjacent columns. Each fission product barrier column is further divided into two columns; one for Loss thresholds and one for Potential Loss thresholds.

The first column of the table (to the left of the Fuel Clad Loss column) lists the categories (types) of fission product barrier thresholds. The fission product barrier categories are:

A. RCS or SG Tube Leakage B. Inadequate Heat removal C. CTMT Radiation / RCS Activity D. CTMT Integrity or Bypass E. EC Judgment Each category occupies a row in Table F-1 thus forming a matrix defined by the categories.

The intersection of each row with each Loss/Potential Loss column forms a cell in which one or more fission product barrier thresholds appear. If NEI 99-01 does not define a threshold for a barrier Loss/Potential Loss, the word None is entered in the cell.

Thresholds are assigned sequential numbers within each barrier column beginning with number one.

If a cell in Table F-1 contains more than one numbered threshold, each of the numbered thresholds, if exceeded, signifies a Loss or Potential Loss of the barrier. It is not necessary to exceed all of the thresholds in a category before declaring a barrier Loss/Potential Loss.

Subdivision of Table F-1 by category facilitates association of plant conditions to the applicable fission product barrier Loss and Potential Loss thresholds. This structure promotes a systematic approach to assessing the classification status of the fission product barriers.

When equipped with knowledge of plant conditions related to the fission product barriers, the EAL-user first scans down the category column of Table F-1, locates the likely category and then reads across the fission product barrier Loss and Potential Loss thresholds in that category to determine if a threshold has been exceeded. If a threshold has not been exceeded, the EAL-user proceeds to the next likely category and continues review of the thresholds in the new category If the EAL-user determines that any threshold has been exceeded, by definition, the barrier is lost or potentially lost - even if multiple thresholds in the same barrier column are exceeded, only that one barrier is lost or potentially lost. The EAL-user must examine each of the three fission product barriers to determine if other barrier thresholds in the category are lost or potentially lost. For example, if containment radiation is sufficiently high, a Loss of the Fuel Clad and RCS Barriers and a Potential Loss of the Containment Barrier can occur. Barrier Losses and Potential Losses are then applied to the algorithms given in EALs FG1.1, FS1.1, and FA1.1 to determine the appropriate emergency classification.

Page 113 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Table F-1 Fission Product Barrier Threshold Matrix Fuel Clad (FC) Barrier Reactor Coolant System (RC) Barrier Containment (CTMT) Barrier Category Loss Potential Loss Loss Potential Loss Loss Potential Loss

1. An automatic or manual ECCS A (SI) actuation required by EITHER:

1. UNISOLABLE RCS or SG tube leakage > 69 gpm

1. A leaking or RUPTURED SG is RCS or None None UNISOLABLE RCS FAULTED outside of CTMT None SG Tube leakage 2. Integrity-RED Path conditions Leakage SG tube RUPTURE met

1. Core Cooling-ORANGE Path conditions met B 3. Heat Sink-RED Path conditions met

1. Core Cooling-RED Path conditions met

1. Core Cooling-RED Path Inadequate conditions met

2. Heat Sink-RED Path conditions None AND None AND Heat met Heat sink is required Restoration procedures not Removal AND effective within 15 min. (Note 1)

Heat sink is required

2. Containment High Range C Radiation Monitor

2. Containment Mezzanine Radiation

2. Containment High Range Radiation Rad-3[4]-6311A/B reading Monitor Rad-3[4]-6311A/B reading CTMT > 5.4E+03 R/hr Monitor RI-3[4]-1404B reading > 2.2E+04 R/hr None > 10 mR/hr None None Radiation

/ RCS

3. Coolant activity > 300 Ci/gm Activity dose equivalent I-131

2. CTMT isolation is required 3. Containment-RED Path AND EITHER: conditions met CTMT integrity has been lost D based on EC judgment 4. CTMT hydrogen concentration UNISOLABLE pathway from > 4%

CTMT None None None None CTMT atmosphere to the Integrity environment exists or Bypass 5. CTMT pressure > 20 psig AND

< one full train of depressurization

3. Indications of RCS leakage equipment operating per design for outside of CTMT 15 min. (Notes 1, 11)

E 4. ANY condition in the opinion of 3. ANY condition in the opinion of 3. ANY condition in the opinion of 4. ANY condition in the opinion of the 4. ANY condition in the opinion of 6. ANY condition in the opinion of the the EC that indicates Loss of the the EC that indicates Potential the EC that indicates Loss of the EC that indicates Potential Loss of the EC that indicates Loss of the EC that indicates Potential Loss of EC Fuel Clad Barrier Loss of the Fuel Clad Barrier RCS Barrier the RCS Barrier CTMT Barrier the CTMT Barrier Judgment Page 114 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Fuel Clad Category: A. RCS or SG Tube Leakage Degradation Threat: Loss Threshold:

None Page 115 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Fuel Clad Category: A. RCS or SG Tube Leakage Degradation Threat: Potential Loss Threshold:

None Page 116 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Fuel Clad Category: B. Inadequate Heat Removal Degradation Threat: Loss Threshold:

1. Core Cooling-RED Path conditions met Definition(s):

None Basis:

This reading condition indicates temperatures within the core are sufficient to cause significant superheating of reactor coolant (ref. 1).

Reference(s):

1. 3[4]-EOP-F-0 Critical Safety Function Status Trees CSF F-0.2 Core Cooling

2. NEI 99-01 Inadequate Heat Removal Loss 2.A Page 117 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Fuel Clad Category: B. Inadequate Heat Removal Degradation Threat: Potential Loss Threshold:

1. Core Cooling-ORANGE Path conditions met Definition(s):

None Basis:

This reading condition indicates temperatures withthin the core sufficient to allow the onset of heat-induced cladding damage (ref. 1).

Reference(s):

1. 3[4]-EOP-F-0 Critical Safety Function Status Trees CSF F-0.2 Core Cooling

2. NEI 99-01 Inadequate Heat Removal Loss 2.A Page 118 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Fuel Clad Category: B. Inadequate Heat Removal Degradation Threat: Potential Loss Threshold:

2. Heat Sink-RED Path conditions met AND Heat sink is required Definition(s):

None Basis:

In combination with RCS Potential Loss B.3, meeting this threshold results in a Site Area Emergency.

This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the Fuel Clad Barrier. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators; during these conditions, classification using threshold is not warranted.

Meeting this threshold results in a Site Area Emergency because this threshold is identical to RCS Barrier Potential Loss threshold 2.AB.3; both will be met. This condition warrants a Site Area Emergency declaration because inadequate RCS heat removal may result in fuel heat-up sufficient to damage the cladding and increase RCS pressure to the point where mass will be lost from the system.

The phrase and heat sink required precludes the need for classification for conditions in which RCS pressure is less than SG pressure or Heat Sink-RED path entry was created through operator action directed by an EOP. For example, FR-H.1 is entered from CSFST Heat Sink-Red. Step 1 tells the operator to determine if heat sink is required by checking that RCS pressure is greater than any non-faulted SG pressure and RCS Thot is greater than 350ºF. If these conditions exist, Heat Sink is required. Otherwise, the operator is to either return to the procedure and step in effect or place RHR in service for heat removal. For large LOCA events inside the Containment, the SGs are moot because heat removal through the containment heat removal systems takes place. Therefore, Heat Sink Red should not be required and, should not be assessed for EAL classification because a LOCA event alone should not require higher than an Alert classification. (ref. 1, 2).

Page 119 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Reference(s):

1. 3[4]-EOP-F-0 Critical Safety Function Status Trees CSF F-0.3 Heat Sink

2. 3[4]-EOP-FR-H.1 Response to Loss of Secondary Heat Sink

3. NEI 99-01 Inadequate Heat Removal Fuel Clad Potential Loss 2.B Page 120 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Fuel Clad Category: C. CTMT Radiation / RCS Activity Degradation Threat: Loss Threshold:

2. Containment High Range Radiation Monitor Rad-3[4]-6311A/B reading > 5.4E+03 R/hr Definition(s):

None Basis:

Containment radiation monitor readings greater than the value shown indicates the release of reactor coolant, with elevated activity indicative of fuel damage, into the containment. The reading is derived assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with a concentration of ~5% clad failure into the containment atmosphere. Reactor coolant concentrations of this magnitude are several times larger than the maximum concentrations (including iodine spiking) allowed within Technical Specifications and are therefore indicative of fuel damage The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that reactor coolant activity equals 300 µCi/gm dose equivalent I-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier(ref. 1).

The radiation monitor reading in this threshold is higher than that specified for RCS Barrier Loss threshold C.1 2 since it indicates a loss of both the Fuel Clad barrier and the RCS barrier.

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

There is no Potential Loss threshold associated with RCS Activity / Containment Radiation.

Reference(s):

1. PTN NEI-99-01 Radiation Monitor EAL Value Determination

2. NEI 99-01 CTMT Radiation / RCS Activity FC Loss 3.A Page 121 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Fuel Clad Category: C. CTMT Radiation / RCS Activity Degradation Threat: Loss Threshold:

3. Coolant activity > 300 Ci/gm dose equivalent I-131 Definition(s):

None Basis:

This threshold indicates that RCS radioactivity concentration is greater than 300 µCi/gm dose equivalent I-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.

It is recognized that sample collection and analysis of reactor coolant with highly elevated activity levels could require several hours to complete. Nonetheless, a sample-related threshold is included as a backup to other indications.

There is no Potential Loss threshold associated with RCS Activity / Containment Radiation.

Reference(s):

1. NEI 99-01 CTMT Radiation / RCS Activity FC Loss 3.B Page 122 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Fuel Clad Category: C. CTMT Radiation / RCS Activity Degradation Threat: Potential Loss Threshold:

None Page 123 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Fuel Clad Category: D. CTMT Integrity or Bypass Degradation Threat: Loss Threshold:

None Page 124 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Fuel Clad Category: D. CTMT Integrity or Bypass Degradation Threat: Potential Loss Threshold:

None Page 125 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Fuel Clad Category: E. EC Judgment Degradation Threat: Loss Threshold:

4. Any condition in the opinion of the EC that indicates loss of the Fuel Clad barrier Definition(s):

None Basis:

This threshold addresses any other factors that are to be used by the Emergency DirectorEC in determining whether the Fuel Clad barrier is lost.

Reference(s):

1. NEI 99-01 Emergency Director Judgment Fuel Clad Loss 6.A Page 126 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Fuel Clad Category: E. EC Judgment Degradation Threat: Potential Loss Threshold:

3. Any condition in the opinion of the EC that indicates potential loss of the Fuel Clad barrier Definition(s):

None Basis:

This threshold addresses any other factors that are to be used by the Emergency DirectorEC in determining whether the Fuel Clad barrier is potentially lost. The Emergency DirectorEC should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

Reference(s):

1. NEI 99-01 Emergency Director Judgment Potential Fuel Clad Loss 6.A Page 127 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: A. RCS or S/G Tube Leakage Degradation Threat: Loss Threshold:

1. An automatic or manual SI actuation required by EITHER:

UNISOLABLE RCS leakage SG tube RUPTURE Definition(s):

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.

RUPTURE - The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection.

Basis:

This threshold is based on an UNISOLABLE RCS leak of sufficient size to require an automatic or manual actuation of the Emergency Core Cooling System (ECCS). This condition clearly represents a loss of the RCS Barrier.

This threshold is applicable to unidentified and pressure boundary leakage, as well as identified leakage. It is also applicable to UNISOLABLE RCS leakage through an interfacing system. The mass loss may be into any location - inside containment, to the secondary-side (i.e., steam generator tube leakage) or outside of containment.

A steam generator with primary-to-secondary leakage of sufficient magnitude to require a safety injection is considered to be RUPTURED. If a RUPTURED steam generator is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier Loss threshold 1.AA.1 will also be met.

Reference(s):

1. 3[4]-EOP-E-1 Loss of Reactor or Secondary Coolant

2. 3[4]-EOP-E-3 Steam Generator Tube Rupture

3. NEI 99-01 RCS or SG Tube Leakage Reactor Coolant System Loss 1.A Page 128 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: A. RCS or S/G Tube Leakage Degradation Threat: Potential Loss Threshold:

1. UNISOLABLE RCS or SG tube leakage > 69 gpm Definition(s):

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.

Basis:

This threshold is based on an UNISOLABLE RCS leak that results in the inability to maintain pressurizer level within specified limits by operation of a normally used charging (makeup) pump, but an ECCS (SI) actuation has not occurred. The threshold is met when RCS leakage is determined to exceed 69 gpm excluding normal reductions in RCS inventory such as letdown and RCP seal leakoffan operating procedure, or operating crew supervision, directs that a standby charging (makeup) pump be placed in service to restore and maintain pressurizer level (ref. 1, 2, 3).

This threshold is applicable to unidentified and pressure boundary leakage, as well as identified leakage. It is also applicable to UNISOLABLE RCS leakage through an interfacing system. The mass loss may be into any location - inside containment, to the secondary-side (i.e., steam generator tube leakage) or outside of containment.

If a the leaking steam generator (> 69 gpm) is also FAULTED outside of containment, the declaration escalates to a Site Area Emergency since the Containment Barrier Loss threshold 1.AA.1 will also be met.

Reference(s):

1. 3[4]-EOP-E-1 Loss of Reactor or Secondary Coolant

2. 3[4]-EOP-E-3 Steam Generator Tube Rupture

3. FSAR Table 9.2-2 Nominal Chemical and Volume Control System Performance

4. NEI 99-01 RCS or SG Tube Leakage Reactor Coolant System Potential Loss 1.A Page 129 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: A. RCS or S/G Tube Leakage Degradation Threat: Potential Loss Threshold:

2. Integrity-RED Path conditions met Definition(s):

None Basis:

The "Potential Loss" threshold is defined by the CSFST Integrity - RED path. CSFST Integrity -

Red Path plant conditions and associated PTS Limit A indicates an extreme challenge to the safety function when plant parameters are to the left of the limit curve following excessive RCS cooldown under pressure (ref. 1, 2).

This condition indicates an extreme challenge to the integrity of the RCS pressure boundary due to pressurized thermal shock - a transient that causes rapid RCS cooldown while the RCS is in Mode 3 or higher (i.e., hot and pressurized).

Reference(s):

1. 3[4]-EOP-F-0 Critical Safety Function Status Trees Enclosure 4 CSF F-0.4 Integrity

2. 3[4]-EOP-FR-P.1 Response to Imminent Pressurized Thermal Shock Condition

3. NEI 99-01 RCS or SG Tube Leakage Reactor Coolant System Potential Loss 1.B Page 130 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: B. Inadequate Heat Removal Degradation Threat: Loss Threshold:

None Page 131 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: B. Inadequate Heat Removal Degradation Threat: Potential Loss Threshold:

3. Heat Sink-RED Path conditions met AND Heat sink is required Definition(s):

None Basis:

In combination with Fuel Clad Potential Loss B.1, meeting this threshold results in a Site Area Emergency.

This condition indicates an extreme challenge to the ability to remove RCS heat using the steam generators (i.e., loss of an effective secondary-side heat sink). This condition represents a potential loss of the RCS Barrier. In accordance with EOPs, there may be unusual accident conditions during which operators intentionally reduce the heat removal capability of the steam generators; during these conditions, classification using threshold is not warranted.

Meeting this threshold results in a Site Area Emergency because this threshold is identical to Fuel Clad Barrier Potential Loss threshold 2.BB.2; both will be met. This condition warrants a Site Area Emergency declaration because inadequate RCS heat removal may result in fuel heat-up sufficient to damage the cladding and increase RCS pressure to the point where mass will be lost from the system.

The phrase and heat sink required precludes the need for classification for conditions in which RCS pressure is less than SG pressure or Heat Sink-RED path entry was created through operator action directed by an EOP. For example, FR-H.1 is entered from CSFST Heat Sink-Red. Step 1 tells the operator to determine if heat sink is required by checking that RCS pressure is greater than any non-faulted SG pressure and RCS Thot is greater than 350ºF. If these conditions exist, Heat Sink is required. Otherwise, the operator is to either return to the procedure and step in effect or place RHR in service for heat removal. For large LOCA events inside the Containment, the SGs are moot because heat removal through the containment heat removal systems takes place. Therefore, Heat Sink Red should not be required and, should not be assessed for EAL classification because a LOCA event alone should not require higher than an Alert classification. (ref. 1, 2).

Page 132 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Reference(s):

1. 3[4]-EOP-F-0 Critical Safety Function Status Trees CSF F-0.3 Heat Sink

2. 3[4]-EOP-FR-H.1 Response to Loss of Secondary Heat Sink

3. NEI 99-01 Inadequate Heat Removal RCS Potential Loss 2.B Page 133 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: C. CTMT Radiation/ RCS Activity Degradation Threat: Loss Threshold:

2. Containment Mezzanine Radiation Monitor RI-3[4]-1401B[1404B] reading > 10 mR/hr Definition(s):

None Basis:

A reading > the value shown is indicative of a breach in the RCS barrier (ref. 1).

The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that reactor coolant activity equals Technical Specification allowable limits. This value is lower than that specified for Fuel Clad barrier loss threshold 3.AC.2 since it indicates a loss of the RCS Barrier only.

There is no Potential Loss threshold associated with RCS Activity / Containment Radiation.

Reference(s):

1. PTN NEI-99-01 Radiation Monitor EAL Value Determination

2. NEI 99-01 CMT Radiation / RCS Activity RCS Loss 3.A Page 134 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: C. CTMT Radiation/ RCS Activity Degradation Threat: Potential Loss Threshold:

None Page 135 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: D. CTMT Integrity or Bypass Degradation Threat: Loss Threshold:

None Page 136 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: D. CTMT Integrity or Bypass Degradation Threat: Potential Loss Threshold:

None Page 137 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: E. EC Judgment Degradation Threat: Loss Threshold:

3. Any condition in the opinion of the EC that indicates loss of the RCS barrier Definition(s):

None Basis:

This threshold addresses any other factors that may be used by the Emergency DirectorEC in determining whether the RCS barrier is lost.

Reference(s):

1. NEI 99-01 Emergency Director Judgment RCS Loss 6.A Page 138 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Reactor Coolant System Category: E. EC Judgment Degradation Threat: Potential Loss Threshold:

4. Any condition in the opinion of the EC that indicates potential loss of the RCS barrier Definition(s):

None Basis:

This threshold addresses any other factors that may be used by the Emergency DirectorEC in determining whether the RCS barrier is potentially lost. The Emergency DirectorEC should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

Reference(s):

1. NEI 99-01 Emergency Director Judgment RCS Potential Loss 6.A Page 139 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Containment Category: A. RCS or SG Tube Leakage Degradation Threat: Loss Threshold:

1. A leaking or RUPTURED SG is FAULTED outside of CTMT Definition(s):

FAULTED - The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

RUPTURED - The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection.

Basis:

This threshold addresses a leaking or RUPTURED Steam Generator (SG) that is also FAULTED outside of containment. The condition of the SG, whether leaking or RUPTURED, is determined in accordance with the thresholds for RCS Barrier Potential Loss 1.A A.1and Loss 1.AA.1, respectively. This condition represents a bypass of the containment barrier.

FAULTED is a defined term within the NEI 99-01 methodology; this determination is not necessarily dependent upon entry into, or diagnostic steps within, an EOP. For example, if the pressure in a steam generator is decreasing uncontrollably ([part of the FAULTED definition)]

and the FAULTED steam generator isolation procedure is not entered because EOP user rules are dictating implementation of another procedure to address a higher priority condition, the steam generator is still considered FAULTED for emergency classification purposes.

The FAULTED criterion establishes an appropriate lower bound on the size of a steam release that may require an emergency classification. Steam releases of this size are readily observable with normal Control Room indications. The lower bound for this aspect of the containment barrier is analogous to the lower bound criteria specified in IC SU4 for the fuel clad barrier (i.e., RCS activity values) and IC SU5 for the RCS barrier (i.e., RCS leak rate values).

This threshold also applies to prolonged steam releases necessitated by operational considerations such as the forced steaming of a leaking or RUPTURED steam generator directly to atmosphere to cooldown the plant, or to drive an auxiliary (emergency) feed water pump. These types of conditions will result in a significant and sustained release of radioactive steam to the environment (and are thus similar to a FAULTED condition). The inability to isolate the steam flow without an adverse effect on plant cooldown meets the intent of a loss of containment.

Page 140 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Steam releases associated with the expected operation of a SG power operated relief valve or safety relief valve do not meet the intent of this threshold. Such releases may occur intermittently for a short period of time following a reactor trip as operators process through emergency operating procedures to bring the plant to a stable condition and prepare to initiate a plant cooldown. Steam releases associated with the unexpected operation of a valve (e.g., a stuck-open safety valve) do meet this threshold.

Following an SG tube leak or rupture, there may be minor radiological releases through a secondary-side system component (e.g., air ejectors, glad seal exhausters, valve packing, etc.). These types of releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category A R ICs.

The emergency classification levels resulting from primary-to-secondary leakage, with or without a steam release from the FAULTED SG, are summarized below.

Affected SG is FAULTED Outside of Containment?

P-to-S Leak Rate Yes No Less than or equal to 25 gpm No classification No classification Unusual Event per Unusual Event per Greater than 25 gpm SU4SU5.1 SU4SU5.1 Requires operation of a standby Site Area Emergency per charging (makeup) pump (RCS Alert per FA1.1 FS1.1 Barrier Potential Loss)

Requires an automatic or manual Site Area Emergency per ECCS (SIAS) actuation (RCS Alert per FA1.1 FS1.1 Barrier Loss)

There is no Potential Loss threshold associated with RCS or SG Tube Leakage.

Reference(s):

1. NEI 99-01 RCS or SG Tube Leakage Containment Loss 1.A Page 141 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Containment Category: A. RCS or SG Tube Leakage Degradation Threat: Potential Loss Threshold:

None Page 142 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Containment Category: B. Inadequate Heat Removal Degradation Threat: Loss None Page 143 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Containment Category: B. Inadequate Heat Removal Degradation Threat: Potential Loss Threshold:

1. Core Cooling-RED path conditions met AND Restoration procedures not effective within 15 min. (Note 1)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Definition(s):

IMMINENT: The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

Basis:

This condition represents an IMMINENT core melt sequence which, if not corrected, could lead to vessel failure and an increased potential for containment failure. For this condition to occur there must already have been a loss of the RCS Barrier and the Fuel Clad Barrier. If implementation of a procedure(s) to restore adequate core cooling is not effective (successful) within 15 minutes, it is assumed that the event trajectory will likely lead to core melting and a subsequent challenge of the Containment Barrier.

The restoration procedure is considered effective if core exit thermocouple readings are decreasing and/or if reactor vessel level is increasing. Whether or not the procedure(s) will be effective should be apparent within 15 minutes. The Emergency DirectorEC should escalate the emergency classification level to a General Emergency as soon as it is determined that the procedure(s) will not be effective.

Severe accident analyses (e.g., NUREG-1150) have concluded that function restoration procedures can arrest core degradation in a significant fraction of core damage scenarios, and that the likelihood of containment failure is very small in these events. Given this, it is appropriate to provide 15 minutes beyond the required entry point to determine if procedural actions can reverse the core melt sequence.

Reference(s):

1. 3[4]-EOP-F-0 Critical Safety Function Status Trees CSF F-0.2 Core Cooling

2. 3[4]-EOP-FR-C.1 Response to Inadequate Core Cooling

3. NEI 99-01 Inadequate Heat Removal Containment Potential Loss 2.A Page 144 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Containment Category: C. CTMT Radiation/RCS Activity Degradation Threat: Loss Threshold:

None Page 145 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Containment Category: C. CTMT Radiation/RCS Activity Degradation Threat: Potential Loss Threshold:

2. Containment High Range Radiation Monitor Rad-3[4]-6311A/B reading > 2.2E+04 R/hr Definition(s):

None Basis:

The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that 20% of the fuel cladding has failed. This level of fuel clad failure is well above that used to determine the analogous Fuel Clad Barrier Loss and RCS Barrier Loss thresholds (ref. 1).

NUREG-1228, Source Estimations During Incident Response to Severe Nuclear Power Plant 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 RCS barrier and the Fuel Clad barrier. It is therefore prudent to treat this condition as a potential loss of containment which would then escalate the emergency classification level to a General Emergency.

Reference(s):

1. PTN NEI-99-01 Radiation Monitor EAL Value Determination

3. NEI 99-01 CMT Radiation / RCS Activity Containment Potential Loss 3.A Page 146 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Containment Category: D. CTMT Integrity or Bypass Degradation Threat: Loss Threshold:

2. CTMT isolation (Phase A, B or CVI) is required AND EITHER:

CTMT integrity has been lost based on EC judgment UNISOLABLE pathway from CTMT atmosphere to the environment exists Definition(s):

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.

Basis:

The status of the containment barrier during an event involving steam generator tube leakage is assessed using Loss Threshold 1.AA.1.

These thresholds address a situation where containment isolation (Phase A, B or CVI) is required and one of two conditions exists as discussed below. Users are reminded that there may be accident and release conditions that simultaneously meet both bulleted thresholds 4.A.1 and 4.A.2. The threshold specifies (Phase A, B or CVI) as the site-specific isolation signals that initiate required containment isolations to preclude fission product release from the containment (ref. 1).

4.A.1First Threshold - Containment integrity has been lost, i.e., the actual containment atmospheric leak rate likely exceeds that associated with allowable leakage (or sometimes referred to as design leakage). Following the release of RCS mass into containment, containment pressure will fluctuate based on a variety of factors; a loss of containment integrity condition may (or may not) be accompanied by a noticeable drop in containment pressure.

Recognizing the inherent difficulties in determining a containment leak rate during accident conditions, it is expected that the Emergency DirectorEC will assess this threshold using judgment, and with due consideration given to current plant conditions, and available operational and radiological data (e.g., containment pressure, readings on radiation monitors outside containment, operating status of containment pressure control equipment, etc.).

Refer to the middle piping run of Figure 9-F-41. Two simplified examples are provided. One is leakage from a penetration and the other is leakage from an in-service system valve.

Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure.

Another example would be a loss or potential loss of the RCS barrier, and the simultaneous occurrence of two FAULTED locations on a steam generator where one fault is located inside containment (e.g., on a steam or feedwater line) and the other outside of containment. In this Page 147 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases case, the associated steam line provides a pathway for the containment atmosphere to escape to an area outside the containment.

Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable (design) containment leakage through various penetrations or system components. These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category A ICs.

4.A.2Second Threshold - Conditions are such that there is an UNISOLABLE pathway for the migration of radioactive material from the containment atmosphere to the environment. As used here, the term environment includes the atmosphere of a room or area, outside the containment, that may, in turn, communicate with the outside-the-plant atmosphere (e.g.,

through discharge of a ventilation system or atmospheric leakage). Depending upon a variety of factors, this condition may or may not be accompanied by a noticeable drop in containment pressure.

Refer to the top piping run of Figure 9-F-41. In this simplified example, the inboard and outboard isolation valves remained open after a containment isolation was required (i.e.,

containment isolation was not successful). There is now an UNISOLABLE pathway from the containment to the environment.

The existence of a filter is not considered in the threshold assessment. Filters do not remove fission product noble gases. In addition, a filter could become ineffective due to iodine and/or particulate loading beyond design limits (i.e., retention ability has been exceeded) or water saturation from steam/high humidity in the release stream.

Leakage between two interfacing liquid systems, by itself, does not meet this threshold.

Refer to the bottom piping run of Figure 9-F-41. In this simplified example, leakage in an RCP seal cooler is allowing radioactive material to enter the Auxiliary Building. The radioactivity would be detected by the Process Monitor. If there is no leakage from the closed water cooling system to the Auxiliary Building, then no threshold has been met. If the pump developed a leak that allowed steam/water to enter the Auxiliary Building, then the second threshold 4.B would be met. Depending upon radiation monitor locations and sensitivities, this leakage could be detected by any of the four monitors depicted in the figure and cause the first threshold 4.A.1 to be met as well.

Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable containment leakage through various penetrations or system components. Minor releases may also occur if a containment isolation valve(s) fails to close but the containment atmosphere escapes to an enclosed system. These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category A R ICs.

Reference(s):

1. UFSAR Section 6.6 Containment Isolation

2. NEI 99-01 CMT Integrity or Bypass Containment Loss 4.A Page 148 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Containment Category: D. CTMT Integrity or Bypass Degradation Threat: Loss Threshold:

3. Indications of RCS leakage outside of CTMT Definition(s):

None Basis:

To ensure proper escalation of the emergency classification, the RCS leakage outside of containment must be related to the mass loss that is causing the RCS Loss and/or Potential Loss threshold 1.AA.1 to be met.

The status of the containment barrier during an event involving steam generator tube leakage is assessed using Containment Loss Threshold A.1.

Containment sump, temperature, pressure and/or radiation levels will increase if reactor coolant mass is leaking into the containment. If these parameters have not increased, then the reactor coolant mass may be leaking outside of containment (i.e., a containment bypass sequence). Increases in sump, temperature, pressure, flow and/or radiation level readings outside of the containment may indicate that the RCS mass is being lost outside of containment.

Unexpected elevated readings and alarms on radiation monitors with detectors outside containment should be corroborated with other available indications to confirm that the source is a loss of RCS mass outside of containment. If the fuel clad barrier has not been lost, radiation monitor readings outside of containment may not increase significantly; however, other unexpected changes in sump levels, area temperatures or pressures, flow rates, etc.

should be sufficient to determine if RCS mass is being lost outside of the containment.

Refer to the middle piping run of Figure 9-F-41. In this simplified example, a leak has occurred at a reducer on a pipe carrying reactor coolant in the Auxiliary Building. Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure and cause containment loss threshold 4.A.1D.2 to be met as well.

Reference(s):

1. NEI 99-01 CMT Integrity or Bypass Containment Loss 4.B Page 149 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Figure 1: Containment Integrity or Bypass Examples 2nd Threshold-Airborne release from pathway Inside CTMT Effluent Auxiliary Building Monitor Vent Damper Filt Area Monitor Open valve Open valve Penetration Damper 1st Threshold-Airborne Airborne Monitor 2nd Threshold-RCS Open valve Open valve leakage 1st outside AB Interface leakage Threshold-Airborne release from Process penetration Monitor Closed Cooling Open valve Open valve Pump RCP Seal Cooling Page 150 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Containment Category: D. CTMT Integrity or Bypass Degradation Threat: Potential Loss Threshold:

3. Containment-RED Path conditions met Definition(s):

None Basis:

If containment pressure exceeds the design pressure of 55 psig (ref. 1, 2), there exists a potential to lose the containment barrier. To reach this level, there must be an inadequate core cooling condition for an extended period of time; therefore, the RCS and Fuel Clad barriers would already be lost. Thus, this threshold is a discriminator between a Site Area Emergency and General Emergency since there is now a potential to lose the third barrier.

Reference(s):

1. 3[4]-EOP-F-0 Critical Safety Function Status Trees CSF F-0.5 Containment

2. NEI 99-01 CMT Integrity or Bypass Containment Potential Loss 4.A Page 151 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Containment Category: D. CTMT Integrity or Bypass Degradation Threat: Potential Loss Threshold:

4. CTMT hydrogen concentration > 4%

Definition(s):

None Basis:

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 the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a potential loss of the containment barrier.

A containment hydrogen concentration of 4% conservatively represents the lowest threshold for flammability in the presence of oxygen (ref. 1).

Reference(s):

1. Computational Aids CA-3 Hydrogen Flammability In Containment

2. NEI 99-01 CMT Integrity or Bypass Containment Potential Loss 4.B Page 152 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Containment Category: D. CTMT Integrity or Bypass Degradation Threat: Potential Loss Threshold:

5. CTMT pressure > 20 psig with < one full train of CTMT heat removal systems operating per design for 15 min. (Notes 1, 11)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Note 11: One full train of CTMT heat removal systems consists of at least two Containment Coolers operating in conjunction with one Containment Spray Pump.

Definition(s):

None Basis:

This threshold describes a condition where containment pressure is greater than the setpoint at which containment energy (heat) removal systems are designed to automatically actuate, and less than one full train of equipment is capable of operating per design (ref. 1, 2). The 15-minute criterion is included to allow operators time to manually start equipment that may not have automatically started, if possible. This threshold represents a potential loss of containment in that containment heat removal/depressurization systems (e.g., containment sprays and Containment Coolers, ice condenser fans, etc., but not including containment venting strategies) are either lost or performing in a degraded manner.

One full train of CTMT heat removal systems consists of at least two Containment Coolers operating in conjunction with one Containment Spray Pump (ref. 1, 2).

Reference(s):

1. UFSAR Section 6.3 Emergency Containment Cooling

2. UFSAR Section 6.4 Containment Spray System

3. NEI 99-01 CMT Integrity or Bypass Containment Potential Loss 4.C Page 153 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Containment Category: E. EC Judgment Degradation Threat: Loss Threshold:

4. Any condition in the opinion of the EC that indicates loss of the CTMT barrier Definition(s):

None Basis:

This threshold addresses any other factors that may be used by the Emergency DirectorEC in determining whether the containment barrier is lost.

Reference(s):

1. NEI 99-01 Emergency Director Judgment Containment Loss 6.A Page 154 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Barrier: Containment Category: E. EC Judgment Degradation Threat: Potential Loss Threshold:

6. Any condition in the opinion of the EC that indicates potential loss of the CTMT barrier Definition(s):

None Basis:

This threshold addresses any other factors that may be used by the Emergency DirectorEC in determining whether the containment barrier is potentially lost. The Emergency DirectorEC should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

Reference(s):

1. NEI 99-01 Emergency Director Judgment Containment Potential Loss 6.A Page 155 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category H - Hazards and Other Conditions Affecting Plant Safety EAL Group: ANY (EALs in this category are applicable to any plant condition, hot or cold.)

Hazards are non-plant, system-related events that can directly or indirectly affect plant operation, reactor plant safety or personnel safety.

1. Security Unauthorized entry attempts into the PROTECTED AREA, bomb threats, sabotage attempts, and actual security compromises threatening loss of physical control of the plant.

2. Seismic Event Natural events such as earthquakes have potential to cause plant structure or equipment damage of sufficient magnitude to threaten personnel or plant safety.

3. Natural or Technological Hazard Other natural and non-naturally occurring events that can cause damage to plant facilities include tornados, FLOODING, hazardous material releases and events restricting site access warranting classification.

4. Fire FIRES can pose significant hazards to personnel and reactor safety. Appropriate for classification are FIRES within the plant PROTECTED AREA or which may affect operability of equipment needed for safe shutdown.

5. Hazardous Gas Toxic, corrosive, asphyxiant or flammable gas leaks can affect normal plant operations or preclude access to plant areas required to safely shutdown the plant.

6. Control Room Evacuation Events that are indicative of loss of Control Room habitability. If the Control Room must be evacuated, additional support for monitoring and controlling plant functions is necessary through the emergency response facilities.

7. EC Judgment The EALs defined in other categories specify the predetermined symptoms or events that are indicative of emergency or potential emergency conditions and thus warrant classification. While these EALs have been developed to address the full spectrum of possible emergency conditions which may warrant classification and subsequent implementation of the Emergency Plan, a provision for classification of emergencies based on operator/management experience and judgment is still necessary. The EALs of this category provide the EC the latitude to classify emergency conditions consistent with the established classification criteria based upon EC judgment.

Page 156 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: H - Hazards Subcategory: 1 - Security Initiating Condition: Confirmed SECURITY CONDITION or threat EAL:

HU1.1 Unusual Event A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by PTN Security Shift Supervision OR Notification of a credible security threat directed at the site OR A validated notification from the NRC providing information of an aircraft threat Mode Applicability:

All Definition(s):

HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION - An act toward PTN or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on PTN. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

OWNER CONTROLLED AREA (OCA) - That portion of FPL property surrounding and including the Turkey Point Plant which is subject to limited access and control as deemed appropriate by FPL.

PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

PROTECTED AREA - The area (within the OWNER CONTROLLED AREA) occupied by the nuclear units and associated equipment and facilities enclosed within the security perimeter fence. The area within which accountability of personnel is maintained in an emergency.

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10CFR50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

Page 157 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases (1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

SECURITY CONDITION - Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A security condition does not involve a HOSTILE ACTION.

SITE BOUNDARY - That line beyond which the land or property is not owned, leased or otherwise controlled by PTN.

Basis:

This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, 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 the requirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs HA1, and HS1 and HG1.

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to plant personnel and Offsite Response Organizations.

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].

The first threshold EAL #1 references the Security Shift Supervision (site-specific security shift supervision)because these are the 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 nature of Safeguards and 10 CFR § 2.39 information.

The second threshold EAL #2 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with SY-AA-102-1014 Threat Assessment and Reporting (site-specific procedure) (ref. 2).

The third threshold EAL #3 addresses the threat from the impact of an aircraft on the plant.

The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may also be provided by NORAD through the NRC. Validation of the threat is performed in accordance with SY-AA-102-1014 Threat Assessment and Reporting (ref.2)(site-specific procedure).

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the PTN Physical Security Plan (ref. 1).

Page 158 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Escalation of the emergency classification level would be via IC HA1.

Reference(s):

1. PTN Physical Security Plan

2. SY-AA-102-1014 Threat Assessment and Reporting

3. NEI 99-01 HU1 Page 159 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: H - Hazards Subcategory: 1 - Security Initiating Condition: HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes EAL:

HA1.1 Alert A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by PTN Security Shift Supervision OR A validated notification from NRC of an aircraft attack threat within 30 min. of the site Mode Applicability:

All Definition(s):

HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION - An act toward PTN or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on PTN. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

HOSTILE FORCE - One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

OWNER CONTROLLED AREA - That portion of FPL property surrounding and including the Turkey Point Plant which is subject to limited access and control as deemed appropriate by FPL.

PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

PROTECTED AREA - The area (within the OWNER CONTROLLED AREA) occupied by the nuclear units and associated equipment and facilities enclosed within the security perimeter fence. The area within which accountability of personnel is maintained in an emergency.

Basis:

This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and Page 160 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the plant and staff for a potential aircraft impact.

Timely and accurate communications between Security Shift Supervision and the Control 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 by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The Alert declaration will also heighten the awareness of Offsite Response Organizations (OROs), allowing them to be better prepared should it be necessary to consider further actions.

This IC EAL 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 disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.

The first threshold EAL #1 is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action directed against an ISFSI that is located outside the plant PROTECTED AREA.

The second threshold EAL #2 addresses 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 a heightened state of readiness. This EAL is met when the threat-related information has been validated in accordance with SY-AA-102-1014 Threat Assessment and Reporting (site-specific procedure)(ref. 2).

The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft. The status and size of the plane may be provided by NORAD through the NRC.

In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify 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.

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the PTN Physical Security Plan Security Plan for (ref. 1).

Escalation of the emergency classification level would be via IC HS1.

Page 161 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Reference(s):

1. PTN Physical Security Plan

2. SY-AA-102-1014 Threat Assessment and Reporting

3. NEI 99-01 HA1 Page 162 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: H - Hazards Subcategory: 1 - Security Initiating Condition: HOSTILE ACTION within the PROTECTED AREA EAL:

HS1.1 Site Area Emergency A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by PTN Security Shift Supervision Mode Applicability:

All Definition(s):

HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION - An act toward PTN or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on PTN. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

HOSTILE FORCE - One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

OWNER CONTROLLED AREA - That portion of FPL property surrounding and including the Turkey Point Plant which is subject to limited access and control as deemed appropriate by FPL.

PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

PROTECTED AREA - The area (within the OWNER CONTROLLED AREA) occupied by the nuclear units and associated equipment and facilities enclosed within the security perimeter fence. The area within which accountability of personnel is maintained in an emergency.

Basis:

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 for damage to plant equipment.

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event (ref. 1, 2).

Page 163 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases 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 by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering). The Site Area Emergency declaration will mobilize Offsite Response Organization (ORO) resources and have them available to develop and implement public protective actions in the unlikely event that the attack is successful in impairing multiple safety functions.

This IC EAL does not apply to a HOSTILE ACTION directed at an ISFSI Protected Area located outside the PROTECTED AREA; such an attack should be assessed 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 a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc.

Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate Security-sensitive information. This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location. Security-sensitive information should be contained in non-public documents such as the PTN Physical Security Plan Security Plan for (ref. 1).

Escalation of the emergency classification level would be via IC HG1.

Reference(s):

1. PTN Physical Security Plan

2. SY-AA-102-1014 Threat Assessment and Reporting

3. NEI 99-01 HS1 Page 164 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 2 - Seismic Event Initiating Condition: Seismic event greater than OBE levels EAL:

HU2.1 Unusual Event Control Room personnel feel an actual or potential seismic event AND The occurrence of a seismic event is confirmed in a manner deemed appropriate by the Shift Manager Mode Applicability:

All Definition(s):

None Basis:

This IC addresses a seismic event that results in accelerations at the plant site greater than those specified for an Operating Basis Earthquake (OBE). An earthquake greater than an OBE but less than a Safe Shutdown Earthquake (SSE) should have no significant 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). Given the time necessary to perform walk-downs and inspections, and fully understand any impacts, 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 an OBE.

Earthquakes of this magnitude should be readily felt by on-site personnel and recognized as a seismic event (e.g., lateral accelerations in excess of 0.08g05g). The Shift Manager or Emergency DirectorEC may seek external verification if deemed appropriate (e.g., a call to the U.S. Geological Survey (USGS), check internet news sources, etc.); however, the verification action must not preclude a timely emergency declaration.

For both Unit 3 and Unit 4, the OBE ground acceleration threshold is > 0.05g horizontal (ref.2).

The PTN Control Room does not have real time OBE exceedance alarms or indications.

Seismic instruments record ground accelerations but must be subsequently analyzed to determine OBE exceedance (ref. 1, 3). Therefore, classification of seismic events at PTN is based on a felt earthquake confirmed in a manner deemed appropriate by the Shift Manager.

The Shift Manager or Emergency Coordinator may seek external verification, such as the USGS, however the verification action must not preclude a timely emergency classification.

Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA6 or SA9.

Page 165 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Reference(s):

1. 0-EPIP-20106 Natural Emergencies

2. USFSAR Section 2.9.4.6 Earthquake Design Basis

3. USFSAR Section 5A-5.0 Seismic Instrumentation

4. NEI 99-01 HU2 Page 166 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 3 - Natural or Technological Hazard Initiating Condition: Hazardous event EAL:

HU3.1 Unusual Event A tornado strike within the PROTECTED AREA Mode Applicability:

All Definition(s):

PROTECTED AREA - The area (within the OWNER CONTROLLED AREA) occupied by the nuclear units and associated equipment and facilities enclosed within the security perimeter fence. The area within which accountability of personnel is maintained in an emergency.

Basis:

This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.

This EAL EAL #1 addresses a tornado striking (touching down) within the PROTECTED AREA.

EAL #2 addresses flooding of a building room or area that results in operators isolating power to 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 or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode.

EAL #3 addresses 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 addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles. Examples of such an event include site flooding caused by a hurricane, heavy rains, up-river water releases, dam failure, etc., or an on-site train derailment blocking the access road.

This EAL is not intended apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the flooding around the Cooper Station during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in 2011.

EAL #5 addresses (site-specific description).

Escalation of the emergency classification level would be based on ICs in Recognition Categories AR, F, S or C.

Page 167 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases If damage is confirmed visually or by other in-plant indications, the event may be escalated to an Alert under IC CA6 or SA9.

A tornado striking (touching down) within the PROTECTED AREA warrants declaration of an Unusual Event regardless of the measured wind speed at the meteorological tower. A tornado is defined as a violently rotating column of air in contact with the ground and extending from the base of a thunderstorm.

Reference(s):

1. 0-EPIP-20106 Natural Emergencies

2. NEI 99-01 HU3 Page 168 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 3 - Natural or Technological Hazard Initiating Condition: Hazardous event EAL:

HU3.2 Unusual Event Internal room or area FLOODING of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component required by Technical Specifications for the current operating mode Mode Applicability:

All Definition(s):

FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10CFR50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.

EAL #1 addresses a tornado striking (touching down) within the PROTECTED AREA.

This EAL addresses FLOODING of a building room or area that results in operators isolating power to 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 or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode (ref. 1, 2).

EAL #3 addresses 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 addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal Page 169 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases vehicles. Examples of such an event include site flooding caused by a hurricane, heavy rains, up-river water releases, dam failure, etc., or an on-site train derailment blocking the access road.

This EAL is not intended apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the flooding around the Cooper Station during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in 2011.

EAL #5 addresses (site-specific description).

Escalation of the emergency classification level would be based on ICs in Recognition Categories AR, F, S or C.

Refer to EAL CA6.1 or SA9.1 for internal flooding affecting more than one SAFETY SYSTEM train.

Reference(s):

1. UFSAR Section 5F.1 PTN Internal Flooding Protection

2. NEI 99-01 HU3 Page 170 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 3 - Natural or Technological Hazard Initiating Condition: Hazardous event EAL:

HU3.3 Unusual Event Movement of personnel within the PROTECTED AREA is IMPEDED due to an event external to the PROTECTED AREA involving hazardous materials (e.g., an offsite chemical spill or toxic gas release)

Mode Applicability:

All Definition(s):

IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

PROTECTED AREA - The area (within the OWNER CONTROLLED AREA) occupied by the nuclear units and associated equipment and facilities enclosed within the security perimeter fence. The area within which accountability of personnel is maintained in an emergency.

Basis:

This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.

This EAL EAL #1 addresses a tornado striking (touching down) within the PROTECTED AREA.

This EAL addresses flooding of a building room or area that results in operators isolating power to 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 or relay trip). To warrant classification, operabilit of the affected component must be required by Technical Specifications for the current operating mode.

EAL #3 This EAL addresses a hazardous materials event originating at an offsite location outside the PROTECTED AREA and of sufficient magnitude to IMPEDE the movement of personnel within the PROTECTED AREA.

EAL #4 addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles. Examples of such an event include site flooding caused by a hurricane, heavy rains, up-river water releases, dam failure, etc., or an on-site train derailment blocking the access road.

Page 171 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases This EAL is not intended apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the flooding around the Cooper Station during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in 2011.

EAL #5 addresses (site-specific description).

Escalation of the emergency classification level would be based on ICs in Recognition Categories AR, F, S M or C.

Reference(s):

1. NEI 99-01 HU3 Page 172 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 3 - Natural or Technological Hazard Initiating Condition: Hazardous event EAL:

HU3.4 Unusual Event A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles (Note 7)

Note 7: This EAL does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.

Mode Applicability:

All Definition(s):

FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.

Basis:

This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant. EAL #1 addresses a tornado striking (touching down) within the PROTECTED AREA.

This EAL addresses flooding of a building room or area that results in operators isolating power to 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 or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode.

EAL #3 addresses a hazardous materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel within the PROTECTED AREA.

This EAL EAL #4 addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles. Examples of such an event include site FLOODING caused by a hurricane, heavy rains, up-river water releases, dam failure, etc., or an on-site train derailment blocking the access road.

This EAL is not intended to apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the FLOODING around the Cooper Station during the Midwest floods of 1993, or the FLOODING around Ft. Calhoun Station in 2011.

EAL #5 addresses (site-specific description). Escalation of the emergency classification level would be based on ICs in Recognition Categories AR, F, S or C.

Page 173 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Reference(s):

1. NEI 99-01 HU3 Page 174 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 4 - Fire Initiating Condition: FIRE potentially degrading the level of safety of the plant EAL:

HU4.1 Unusual Event A FIRE is not extinguished within 15 min. of any of the following fire detection indications (Note 1):

Report from the field (i.e., visual observation)

Receipt of multiple (more than 1) fire alarms or indications Field verification of a single fire alarm AND The FIRE is located within any Table H-1 area Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Table H-1 PTN Fire Areas Containment Building Control Building Auxiliary Building Fuel Handling Building Turbine Building Emergency Diesel Generator Buildings Component Cooling Water (CCW) Area Intake Structure 4 KV Switchgear Rooms Main/Aux/Startup XFMRs Yard Areas:

o RWSTs o PWSTs o CSTs o Unit 3 DOST o Air Compressors o Bus C Mode Applicability:

All Definition(s):

Page 175 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases FIRE - Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Basis:

This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.

EAL #1 The 15 minute requirement begins with a credible notification that a FIRE is occurring, or receipt of multiple VALID fire detection system alarms or field validation of a single fire alarm.

The alarm is to be validated using available Control Room indications or alarms to prove that it is not spurious, or by reports from the field.

Table H-1 Fire Areas are those areas that contain equipment necessary for safe operation and shutdown of the plant (ref. 1, 2).

The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition 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 fire alarm, 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 not the time that a subsequent verification action was performed. Similarly, the fire duration clock also starts at the time of receipt of the initial alarm, indication or report. EAL #2 This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (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 EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, 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 time is 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, and absent 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 within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a spurious activation, and Page 176 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted.

EAL #3 In addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety. This basis extends to a FIRE occurring within the PROTECTED AREA of an ISFSI located outside the plant PROTECTED AREA. [Sentence for plants with an ISFSI outside the plant Protected Area]

EAL #4 If a FIRE within the plant or ISFSI [for plants with an ISFSI outside the plant Protected Area]

PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded. The dispatch of an offsite firefighting agency to the site 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, or supporting post-extinguishment recovery or investigation actions.

Basis-Related Requirements from Appendix R Appendix R to 10 CFR 50, states in part:

Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions."

When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.

Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.

In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of 1-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 a single 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 CA6 or SA9.

Reference(s):

Page 177 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases

1. UFSAR Section 5A-1.0 Design Bases of Structures, Systems and Equipment

2. 0-ONOP-016.20 Pre-Fire Plans

3. NEI 99-01 HU4 Page 178 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 4 - Fire Initiating Condition: FIRE potentially degrading the level of safety of the plant EAL:

HU4.2 Unusual Event Receipt of a single fire alarm (i.e., no other indications of a FIRE)

AND The fire alarm is indicating a FIRE within any Table H-1 area (excluding containment)

AND The existence of a FIRE is not verified within 30 min. of alarm receipt (Notes 1, 13)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Note 13: A containment fire alarm is considered VALID upon receipt of multiple zones (more than one) actuated on the fire alarm panel.

Table H-1 PTN Fire Areas Containment Building Control Building Auxiliary Building Fuel Handling Building Turbine Building Emergency Diesel Generator Buildings Component Cooling Water (CCW) Area Intake Structure 4 KV Switchgear Rooms Main/Aux/Startup XFMRs Yard Areas:

o RWSTs o PWSTs o CSTs o Unit 3 DOST o Air Compressors o Bus C Mode Applicability:

All Definition(s):

FIRE - Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.

Page 179 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Basis:

This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.

EAL #1 The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition 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 fire alarm, 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 not the time that a subsequent verification action was performed. Similarly, the fire duration clock also starts at the time of receipt of the initial alarm, indication or report.

EAL #2 The 30 minute requirement begins upon receipt of a single VALID fire detection system alarm (excluding containment). The alarm is to be validated using available Control Room indications or alarms to prove that it is not spurious, or by reports from the field. Actual field reports must be made within the 30 minute time limit or a classification must be made. If a fire is verified to be occurring by field report, classification shall be made based on EAL HU4.1, with the 15 minute requirement beginning with the verification of the fire by field report.

Table H-1 Fire Areas are those areas that contain equipment necessary for safe operation and shutdown of the plant (ref. 1, 2).

This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (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 EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed.

With regard to containment fire alarms, there is constant air movement in containment due to the operation of the containment ventilation system. The operating cooling units are drawing air to the units past the smoke detectors. It can be reasonably expected that a fire that burns for 15 minutes would produce sufficient products of combustion to cause fire detectors in multiple zones to alarm. Therefore a single containment fire alarm is not considered VALID.

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 time is allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to Page 180 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases determine if an actual FIRE exists; however, after that time, and absent 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 HU4.1 EAL #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted. EAL #3 In addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety. This basis extends to a FIRE occurring within the PROTECTED AREA of an ISFSI located outside the plant PROTECTED AREA. [Sentence for plants with an ISFSI outside the plant Protected Area]

EAL #4 Basis-Related Requirements from Appendix R: (It is recognized that PTN is a NFPA-805 Fire Program plant but the following Appendix R information supports the use of the 30 minute timing criteria based on a single fire alarm)

Appendix R to 10 CFR 50, states in part:

(Note; While PTN is an NFP-805 plant, the following excerpt from 10CFR 50 Appendix R provides the bases for the acceptability of the use of a 30-minute validation time for a single fire zone alarm.)

Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions."

When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.

Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.

In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of 1-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 HU4.2EAL #2, the 30-minutes to verify a single 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 CA6 or SA9.

Reference(s):

1. UFSAR Section 5A-1.0 Design Bases of Structures, Systems and Equipment

2. 0-ONOP-016.20 Pre-Fire Plans Page 181 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases

3. NEI 99-01 HU4 Page 182 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 4 - Fire Initiating Condition: FIRE potentially degrading the level of safety of the plant EAL:

HU4.3 Unusual Event A FIRE within the PROTECTED AREA not extinguished within 60 min. of the initial report, alarm or indication (Note 1)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Mode Applicability:

All Definition(s):

FIRE - Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.

PROTECTED AREA - The area (within the OWNER CONTROLLED AREA) occupied by the nuclear units and associated equipment and facilities enclosed within the security perimeter fence. The area within which accountability of personnel is maintained in an emergency.

Basis:

This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.

EAL #1 The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition 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 fire alarm, 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 not the time that a subsequent verification action was performed. Similarly, the fire duration clock also starts at the time of receipt of the initial alarm, indication or report.

EAL #2 This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (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 EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed.

Page 183 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases 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 time is 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, and absent 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 within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted.

EAL #3 In addition to a FIRE addressed by EAL HU4.1 #1 or HU4.2EAL #2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety.

This basis extends to a FIRE occurring within the PROTECTED AREA of an ISFSI located outside the plant PROTECTED AREA. [Sentence for plants with an ISFSI outside the plant Protected Area]EAL #4 If a FIRE within the plant or ISFSI [for plants with an ISFSI outside the plant Protected Area]

PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded. The dispatch of an offsite firefighting agency to the site 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, or supporting post-extinguishment recovery or investigation actions.

Basis-Related Requirements from Appendix R Appendix R to 10 CFR 50, states in part:

Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions."

When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.

Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.

In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one Page 184 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify a single 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 CA6 or SA9.

Reference(s):

1. NEI 99-01 HU4 Page 185 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 4 - Fire Initiating Condition: FIRE potentially degrading the level of safety of the plant EAL:

HU4.4 Unusual Event A FIRE within the PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish Mode Applicability:

All Definition(s):

FIRE - Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.

PROTECTED AREA - The area (within the OWNER CONTROLLED AREA) occupied by the nuclear units and associated equipment and facilities enclosed within the security perimeter fence. The area within which accountability of personnel is maintained in an emergency.

Basis:

This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.

EAL #1 The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition 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 fire alarm, 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 not the time that a subsequent verification action was performed. Similarly, the fire duration clock also starts at the time of receipt of the initial alarm, indication or report.

EAL #2 This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (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 EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, 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 time is allowed to Page 186 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases 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, and absent 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 within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted.

EAL #3 In addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety. This basis extends to a FIRE occurring within the PROTECTED AREA of an ISFSI located outside the plant PROTECTED AREA. [Sentence for plants with an ISFSI outside the plant Protected Area]

EAL #4 If a FIRE within the plant or ISFSI [for plants with an ISFSI outside the plant Protected Area]

PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded. The dispatch of an offsite firefighting agency to the site 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, or supporting post-extinguishment recovery or investigation actions.

The Shift Fire Brigade Advisor or Shift Fire Brigade Leader will assess whether the fire conditions warrant outside assistance (ref. 1).

Basis-Related Requirements from Appendix R Appendix R to 10 CFR 50, states in part:

Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions."

When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.

Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.

Page 187 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of 1-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 a single 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 CA6 or SA9.

Reference(s):

1. FP-AA-104-1003 Fire Response

2. NEI 99-01 HU4 Page 188 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 5 - Hazardous Gases Initiating Condition: Gaseous release IMPEDING access to equipment necessary for normal plant operations, cooldown or shutdown EAL:

HA5.1 Alert Release of a toxic, corrosive, asphyxiant or flammable gas into any Table H-2 room or area AND Entry into the room or area is prohibited or IMPEDED (Note 5)

Note 5: If the equipment in the listed room or area was already inoperable or out-of-service before the event occurred, then no emergency classification is warranted.

Table H-2 Safe Operation & Shutdown Rooms/Areas Room/Area Mode(s)

Auxiliary Building 18' 1, 2, 3, 4, 5 Turbine Building (any level) 1, 2, 3, 4, 5 Containment 4, 5 HHSI Pump, CSP Rooms 3 RHR Pump & HX Rooms 4 Rad Waste Building 1, 2, 3, 4, 5 Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown, 5 - Cold Shutdown Definition(s):

IMPEDE(D) - Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

Basis:

This IC addresses an event involving a release of a hazardous gas that precludes or IMPEDES access to equipment necessary to maintain normal plant operation, or required for a normal plant cooldown and shutdown. This condition represents an actual or potential substantial degradation of the level of safety of the plant.

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 at the time of the gaseous release. The Page 189 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases 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 the Emergency DirectorECs judgment that the gas concentration in the affected room/area is sufficient to preclude or significantly IMPEDE procedurally required access. This judgment 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 IMPEDED if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g.,

requiring use of protective equipment, such as SCBAs, that is not routinely 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 affected room/area (i.e., entry is not required during the operating mode in effect at the time of the gaseous release). For example, the plant is in Mode 1 when the gaseous release occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.

The gas release is a planned activity that includes compensatory measures which address 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 record keeping nature (e.g., normal rounds or routine inspections).

The access control measures are of a conservative or precautionary nature, and would not actually prevent or IMPEDE a required action.

If the equipment in the listed room or area was already inoperable, or out-of-service, before the event occurred, then no emergency should be declared since the event will have no adverse impact beyond that already allowed by Technical Specifications at the time of the event.

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 enclosed environment.

This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death. Steam can be an asphyxiant if present in sufficient concentration to reduce oxygen levels below normal.

This EAL does not apply to firefighting activities that generate smoke and that automatically or manually activate a fire suppression system in an area , or to intentional inerting of containment. (BWR only).

Escalation of the emergency classification level would be via Recognition Category AR, C or F ICs.

Reference(s):

1. Attachment 2 Safe Operation & Shutdown Areas Tables R-3 & H-2 Bases

2. NEI 99-01 HA5 Page 190 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 6 - Control Room Evacuation Initiating Condition: Control Room evacuation resulting in transfer of plant control to alternate locations EAL:

HA6.1 Alert An event has resulted in the Control Room being evacuated Mode Applicability:

All Definition(s):

None Basis:

This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations outside the Control Room. The loss of the ability to control the 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 Control Room, in addition to responding to the event that required the evacuation of the Control Room, will present challenges to plant operators and other on-shift personnel. Activation of the ERO and emergency response facilities will assist in responding to these challenges.

The Control Room is deemed to have been evacuated when the last licensed operator leaves the Control Room.

Escalation of the emergency classification level would be via IC HS6.

Reference(s):

1. 0-ONOP-105 Control Room Evacuation

2. NEI 99-01 HA6 Page 191 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 6 - Control Room Evacuation Initiating Condition: Inability to control a key safety function from outside the Control Room EAL:

HS6.1 Site Area Emergency An event has resulted in the Control Room being evacuated AND Control of any of the following key safety functions is not re-established within 15 min. of the last licensed operator leaving the Control Room (Note 1):

Reactivity (modes 1, 2 and 3 only)

Core cooling RCS heat removal Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown, 5 - Cold Shutdown, 6 - Refueling Definition(s):

None Basis:

This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations, and the control of a key safety function cannot be reestablished in a timely manner. The failure to gain control of a key safety function following a transfer of plant control to alternate locations is a precursor to a challenge to one or more fission product barriers within a relatively short period of time.

The determination of whether or not control is established at the remote safe shutdown location(s) is based on Emergency DirectorEC judgment. The Emergency DirectorEC is expected to make a reasonable, informed judgment within 15 (the site-specific time for transfer) minutes whether or not the operating staff has control of key safety functions from the remote safe shutdown location(s).

The Control Room is deemed to have been evacuated when the last licensed operator leaves the Control Room.

Establishment of the reactivity safety function is only applicable in Modes 1, 2 and 3. Sufficient shutdown margin has already been established once in modes 4, 5 and 6 (ref. 2).

Escalation of the emergency classification level would be via IC FG1 or CG1 Reference(s):

Page 192 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases

1. 0-ONOP-105 Control Room Evacuation

2. NRC EP FAQ 2015-014

3. NEI 99-01 HS6 Page 193 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 7 - EC Judgment Initiating Condition: Other conditions existing that in the judgment of the EC warrant declaration of a Unusual Event EAL:

HU7.1 Unusual Event Other conditions exist which, in the judgment of the EC, indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of SAFETY SYSTEMS occurs.

Mode Applicability:

All Definition(s):

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10CFR50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency DirectorEC to fall under the emergency classification level description for an Unusual EventNOUE.

Reference(s):

1. NEI 99-01 HU7 Page 194 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 7 - EC Judgment Initiating Condition: Other conditions exist that in the judgment of the EC warrant declaration of an Alert EAL:

HA7.1 Alert Other conditions exist which, in the judgment of the EC, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

Mode Applicability:

All Definition(s):

HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION - An act toward PTN or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on PTN. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

OWNER CONTROLLED AREA - That portion of FPL property surrounding and including the Turkey Point Plant which is subject to limited access and control as deemed appropriate by FPL.

PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

PROTECTED AREA - The area (within the OWNER CONTROLLED AREA) occupied by the nuclear units and associated equipment and facilities enclosed within the security perimeter fence. The area within which accountability of personnel is maintained in an emergency.

Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency DirectorEC to fall under the emergency classification level description for an Alert.

Page 195 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Reference(s):

1. NEI 99-01 HA7 Page 196 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 7 - EC Judgment Initiating Condition: Other conditions existing that in the judgment of the EC warrant declaration of a Site Area Emergency EAL:

HS7.1 Site Area Emergency Other conditions exist which, in the judgment of the EC, indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts, (1) toward site personnel or equipment that could lead to the likely failure of or, (2) that prevent effective access to equipment needed for the protection of the public.

Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the SITE BOUNDARY Mode Applicability:

All Definition(s):

HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.

HOSTILE ACTION - An act toward PTN or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on PTN. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

OWNER CONTROLLED AREA - That portion of FPL property surrounding and including the Turkey Point Plant which is subject to limited access and control as deemed appropriate by FPL.

PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

SITE BOUNDARY - That line beyond which the land or property is not owned, leased or otherwise controlled by PTN.

Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency DirectorEC to fall under the emergency classification level description for a SITE AREA EMERGENCY.

Page 197 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Reference(s):

1. NEI 99-01 HS7 Page 198 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: H - Hazards and Other Conditions Affecting Plant Safety Subcategory: 7 - EC Judgment Initiating Condition: Other conditions exist that in the judgment of the EC warrant declaration of a General Emergency EAL:

HG7.1 General Emergency Other conditions exist which, in the judgment of the EC, indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.

Mode Applicability:

All Definition(s):

HOSTAGE - A person(s) held as leverage against the station to ensure that demands will be met by the station.

IMMINENT - The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

HOSTILE ACTION - An act toward PTN or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILES, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on PTN. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the OWNER CONTROLLED AREA).

OWNER CONTROLLED AREA - That portion of FPL property surrounding and including the Turkey Point Plant which is subject to limited access and control as deemed appropriate by FPL.

PROJECTILE - An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.

PROTECTED AREA - The area (within the OWNER CONTROLLED AREA) occupied by the nuclear units and associated equipment and facilities enclosed within the security perimeter fence. The area within which accountability of personnel is maintained in an emergency.

Basis:

This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Page 199 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases DirectorEC to fall under the emergency classification level description for a GENERAL EMERGENCY.

Reference(s):

1. NEI 99-01 HG7 Page 200 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category S - System Malfunction EAL Group: Hot Conditions (RCS temperature > 200ºF); EALs in this category are applicable only in one or more hot operating modes.

Numerous system-related equipment failure events that warrant emergency classification have been identified in this category. They may pose actual or potential threats to plant safety.

The events of this category pertain to the following subcategories:

1. Loss of Emergency AC Power Loss of emergency plant electrical power can compromise plant safety system operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of onsite and offsite power sources for 4KV emergency buses.

2. Loss of Vital DC Power Loss of emergency plant electrical power can compromise plant safety system operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of power to or degraded voltage on the 125V DC vital buses.

3. Loss of Control Room Indications Certain events that degrade plant operator ability to effectively assess plant conditions within the plant warrant emergency classification. Losses of indicators are in this subcategory.

4. RCS Activity During normal operation, reactor coolant fission product activity is very low. Small concentrations of fission products in the coolant are primarily from the fission of tramp uranium in the fuel clad or minor perforations in the clad itself. Any significant rise from these base-line levels (~1% clad failures) is indicative of fuel failures and is covered under the Fission Product Barrier Degradation category. However, lesser amounts of clad damage may result in coolant activity exceeding Technical Specification limits. These fission products will be circulated with the reactor coolant and can be detected by coolant sampling.

5. RCS Leakage The reactor vessel provides a volume for the coolant that covers the reactor core. The reactor pressure vessel and associated pressure piping (reactor coolant system) together provide a barrier to limit the release of radioactive material should the reactor fuel clad integrity fail. Excessive RCS leakage greater than Technical Specification limits indicates potential pipe cracks that may propagate to an extent threatening fuel clad, RCS and containment integrity.

Page 201 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases

6. RTS Failure This subcategory includes events related to failure of the Reactor Trip System (RTS) to initiate and complete reactor trips. In the plant licensing basis, postulated failures of the RTS to complete a reactor trip comprise a specific set of analyzed events referred to as Anticipated Transient Without Scram (ATWS) events. For EAL classification, however, ATWS is intended to mean any scram failure event that does not achieve reactor shutdown. If RTS actuation fails to properly result in reactor shutdown, positive control of reactivity is at risk and could cause a threat to fuel clad, RCS and containment integrity.

7. Loss of Communications Certain events that degrade plant operator ability to effectively communicate with essential personnel within or external to the plant warrant emergency classification.

8. Containment Failure Failure of containment isolation capability (under conditions in which the containment is not currently challenged) warrants emergency classification. Failure of containment pressure control capability also warrants emergency classification.

9. Hazardous Event Affecting Safety Systems Various natural and technological events that result in degraded plant safety system train performance or significant VISIBLE DAMAGE warrant emergency classification under this subcategory.

Page 202 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 1 - Loss of Emergency AC Power Initiating Condition: Loss of all offsite AC power capability to emergency buses for 15 minutes or longer EAL:

SU1.1 Unusual Event Loss of all offsite AC power capability, Table S-1, to 4KV emergency buses 3[4]A and 3[4]B for 15 min. (Note 1)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Table S-1 AC Power Sources Offsite Unit 3[4] Startup Transformer Onsite 3A[4A] Emergency Diesel Generator 3B[4B] Emergency Diesel Generator Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

None Basis:

Table S-1 provides a list of offsite AC electrical power sources credited for this EAL (ref. 1, 2, 3).

This IC addresses a prolonged loss of offsite power. The loss of offsite power sources renders 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 power source(s) is available to the emergency buses, whether or not the buses are powered from it.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of offsite power.

Escalation of the emergency classification level would be via IC SA1.

Reference(s):

1. Technical Specifications Section 3.8.1 A. C. Sources Page 203 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases

2. UFSAR section 8.2.2 Station Electrical System

3. NEI 99-01 SU1 Page 204 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 1 - Loss of Emergency AC Power Initiating Condition: Loss of all but one AC power source to emergency buses for 15 minutes or longer EAL:

SA1.1 Alert AC power capability, Table S-1, to 4KV emergency buses 3[4]A and 3[4]B reduced to a single power source for 15 min. (Note 1)

AND Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Table S-1 AC Power Sources Offsite Unit 3[4] Startup Transformer Onsite 3A[4A] Emergency Diesel Generator 3B[4B] Emergency Diesel Generator Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10CFR50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

Table S-1 provides a list of offsite and onsite AC electrical power sources credited for this EAL.

(ref. 1, 2).

Page 205 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment. This IC provides an escalation path from IC SU1.

An AC power source is a source recognized in AOPs and EOPs, and capable of supplying required power to an emergency bus. Some examples of this condition are presented below.

A loss of all offsite power with a concurrent failure of all but one emergency power source (e.g., an onsite diesel generator).

A loss of all offsite power and loss of all emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fedcross tied to the other unit from the unit main generator.

A loss of emergency power sources (e.g., onsite diesel generators and unit cross ties) with a single train of emergency buses being back-fed from an offsite power source.

Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.

Escalation of the emergency classification level would be via IC SS1.

This hot condition EAL is equivalent to the cold condition EAL CU2.1.

Reference(s):

1. Technical Specifications Section 3.8.1 A. C. Sources

2. UFSAR section 8.2.2 Station Electrical System

3. NEI 99-01 SA1 Page 206 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 1 - Loss of Emergency AC Power Initiating Condition: Loss of all offsite power and all onsite AC power to emergency buses for 15 minutes or longer EAL:

SS1.1 Site Area Emergency Loss of all offsite and all onsite AC power to 4KV emergency buses 3[4]A and 3[4]B for 15 min. (Note 1)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10CFR50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

For this EAL credit can be taken for any AC power source that has sufficient capability to operate equipment necessary to maintain a safe shutdown condition, such as FLEX generators, provided it is already aligned or can be aligned within the 15 minute classification criteria (ref. 3).

This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink.

In addition, fission product barrier monitoring capabilities may be degraded under these conditions. This IC represents a condition that involves actual or likely major failures of plant functions needed for the protection of the public.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Escalation of the emergency classification level would be via ICs AG1RG1, FG1 or SG1.

This hot condition EAL is equivalent to the cold condition EAL CA2.1.

Page 207 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Reference(s):

1. Technical Specifications Section 3.8.1 A. C. Sources

2. UFSAR section 8.2.2 Station Electrical System

3. BD-EOP-ECA-0.0 Loss of All AC Power

4. NEI 99-01 SS1 Page 208 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: S -System Malfunction Subcategory: 1 - Loss of Vital AC Power Initiating Condition: Prolonged loss of all offsite and all onsite AC power to emergency buses EAL:

SG1.1 General Emergency Loss of all offsite and all onsite AC power to 4KV emergency buses 3[4]A and 3[4]B AND CETs > 1200ºF Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10CFR50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

For this EAL credit can be taken for any AC power source that has sufficient capability to operate equipment necessary to maintain a safe shutdown condition, such as FLEX generators (ref. 2, 3).

Core Damage Assessment uses a CET temperature of 750 °F - 1300 °F as the temperature indicative of a significantly damaged core (ref. 4). A temperature of 1200 °F has been selected consistent with the Critical Safety Function Status Tree (CSFST) Core Cooling Red Path threshold (ref. 5).

This IC addresses a prolonged loss of all power sources to AC emergency buses that results in degraded core cooling. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink.

A prolonged loss of these buses will eventually lead to a loss of one or more fission product barriers. In addition, fission product barrier monitoring capabilities may be degraded under these conditions.

Page 209 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases The For extended loss of emergency bus AC power events that do not result in a breach of the RCS barrier, this EAL should require declaration of a General Emergency prior to meeting the thresholds for IC FG1. This will allow additional time for implementation of offsite protective actions.

Escalation of the emergency classification from Site Area Emergency will occur if it is projected that power cannot be restored to at least one AC emergency bus by the end of the analyzed station blackout coping period. Beyond this time, plant responses and 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 not be used as a basis for delaying a classification upgrade. The goal is to maximize the time 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 power results in parameters that indicate an inability to adequately remove decay heat from the core.

Reference(s):

1. Technical Specifications Section 3.8.1 A. C. Sources

2. UFSAR section 8.2.2 Station Electrical System

3. BD-EOP-ECA-0.0 Loss of All AC Power

4. 0-EPIP-1302 Core Damage Assessment

5. 3[4]-EOP-F-0 Critical Safety Function Status Trees

6. NEI 99-01 SG1 Page 210 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 2 - Loss of Vital DC Power Initiating Condition: Loss of all vital DC power for 15 minutes or longer EAL:

SS2.1 Site Area Emergency Indicated voltage < 105 VDC on both vital 125 VDC buses 3D01[4D01] and 3D23[4D23]

for 15 min. (Note 1)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10CFR50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

The vital (Class 1E) 125 V DC power system consists of four physically and electrically separated buses - 3D01 and 3D23 (Unit 3) and 4D01 and 4D23 (Unit 4). Each bus has a 60 cell battery bank with an eight-hour rating, with a minimum operating voltage of 105 volts (ref.

1, 2, 3).

This IC addresses a loss of vital DC power which compromises the ability to monitor and 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 power losses.

Escalation of the emergency classification level would be via ICs AG1RG1, FG1 or SG8SG2.

This hot condition EAL equivalent of the cold condition EAL CU4.1.

Page 211 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Reference(s):

1. UFSAR Section 8.2.2.3 DC Power Systems

2. 5610-003-DB-002 Vital AC/DC Component Design Requirements

3. Technical Specifications Section 3.8.2. D.C. Sources

4. NEI 99-01 SS8 Page 212 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: S -System Malfunction Subcategory: 2 - Loss of Vital DC Power Initiating Condition: Loss of all emergency AC and vital DC power sources for 15 minutes or longer EAL:

SG2.1 General Emergency Loss of all offsite and all onsite AC power to 4KV emergency buses 3[4]A and 3[4]B 15 min. (Note 1)

AND Indicated voltage < 105 VDC on both vital 125 VDC buses 3D01[4D01] and 3D23[4D23]

for 15 min. (Note 1)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10CFR50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Basis:

This IC addresses a concurrent and prolonged loss of both emergency AC and vital DC power.

A loss of all emergency AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. A loss of vital DC power compromises the ability to monitor and control SAFETY SYSTEMS. A sustained loss of both emergency AC and vital DC power will lead to multiple challenges to fission product barriers.

For this EAL credit can be taken for any AC power source that has sufficient capability to operate equipment necessary to maintain a safe shutdown condition, such as FLEX generators (ref. 3).

Page 213 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases The vital (Class 1E) 125 V DC power system consists of four physically and electrically separated buses - 3D01 and 3D23 (Unit 3) and 4D01 and 4D23 (Unit 4). Each bus has a 60 cell battery bank with an eight-hour rating, with a minimum operating voltage of 105 volts (ref.

4, 5, 6).

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

The 15-minute emergency declaration clock begins at the point when both EAL thresholds are met.

Reference(s):

1. Technical Specifications Section 3.8.1 A. C. Sources

2. UFSAR section 8.2.2 Station Electrical System

3. BD-EOP-ECA-0.0 Loss of All AC Power

4. UFSAR Section 8.2.2.3 DC Power Systems

5. 5610-003-DB-002 Vital AC/DC Component Design Requirements

6. Technical Specifications Section 3.8.2. D.C. Sources

7. NEI 99-01 SG8 Page 214 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 3 - Loss of Control Room Indications Initiating Condition: UNPLANNED loss of Control Room indications for 15 minutes or longer EAL:

SU3.1 Unusual Event An UNPLANNED event results in the inability to monitor one or more Table S-2 parameters from within the Control Room for 15 min. (Note 1)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Table S-2 Safety System Parameters Reactor power RCS level RCS pressure CET temperature Level in at least one SG Auxiliary feedwater flow to at least one SG Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10CFR50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

Page 215 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Basis:

Applicable safety system parameters are listed in Table S-2.

The Safety Assessment System (SAS) and Emergency Response Data Acquisition and Display System (ERDADS) serve as redundant indicators which may be utilized as compensatory measures in lieu of the Control Room indicators associated with safety functions (ref. 1).

This IC addresses the difficulty associated with monitoring normal plant conditions without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. This condition is a precursor to a more significant event and represents a potential degradation in the level of safety of the plant.

As used in this EAL, an inability to monitor means that values for one or more of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s). For example, the reactor power level cannot be determined from any analog, digital and recorder source within the Control Room.

An event involving a loss of plant indications, annunciators and/or display systems is evaluated 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 it significantly 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 action decision-making.

This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling [PWR] / RPV level [BWR] and RCS heat removal.

The loss of the ability to determine one or more of these parameters from within the Control Room is considered to be more significant than simply a reportable condition. In addition, if all indication sources for one or more of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level [PWR] / RPVRCS water level [BWR] 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 losses of indication.

Escalation of the emergency classification level would be via IC SA2SA3.

Reference(s):

1. UFSAR Appendix 7A Distributed Control System/Safety Assessment System/Emergency Response Data Acquisition and Display System

2. NEI 99-01 SU2 Page 216 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 3 - Loss of Control Room Indications Initiating Condition: UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress EAL:

SA3.1 Alert An UNPLANNED event results in the inability to monitor one or more Table S-2 parameters from within the Control Room for 15 min. (Note 1)

AND Any significant transient is in progress, Table S-3 Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Table S-2 Safety System Parameters Reactor power RCS level RCS pressure CET temperature Level in at least one SG Auxiliary feedwater flow to at least one SG Table S-3 Significant Transients Automatic turbine runback > 25%

thermal reactor power Electrical load rejection > 25% full electrical load Reactor Trip SI actuation Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Page 217 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Definition(s):

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10CFR50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

UNPLANNED - A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.

Basis:

Applicable safety system parameters are listed in Table S-2.

Significant transients are listed in Table S-3.

The Safety Assessment System (SAS) and Emergency Response Data Acquisition and Display System (ERDADS) serve as redundant indicators which may be utilized as compensatory measures in lieu of the Control Room indicators associated with safety functions (ref. 1).

This IC addresses the difficulty associated with monitoring rapidly changing plant conditions during a transient without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. During this condition, the margin to a potential fission product barrier challenge is reduced. It thus represents a potential substantial degradation in the level of safety of the plant.

As used in this EAL, an inability to monitor means that values for one or more of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s). For example, the reactor power level cannot be determined from any analog, digital and recorder source within the Control Room.

An event involving a loss of plant indications, annunciators and/or display systems is evaluated 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 it significantly 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 action decision-making.

This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling [PWR] / RPV level [BWR] and RCS heat removal.

Page 218 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases The loss of the ability to determine one or more of these parameters from within the Control Room is considered to be more significant than simply a reportable condition. In addition, if all indication sources for one or more of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for reactor vessel level [PWR] / RPVRCS water level [BWR] 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 losses of indication.

Escalation of the emergency classification level would be via ICs FS1 or IC AS1RS1 Reference(s):

1. UFSAR Appendix 7A Distributed Control System/Safety Assessment System/Emergency Response Data Acquisition and Display System

2. NEI 99-01 SA2 Page 219 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 4 - RCS Activity Initiating Condition: Reactor coolant activity greater than Technical Specification allowable limits EAL:

SU4.1 Unusual Event Sample analysis indicates that a reactor coolant activity value is > any of the following allowable limits:

60 Ci/gm dose equivalent I-131 instantaneous 0.25 Ci/gm dose equivalent I-131 for > 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> 447.7 Ci/gm dose equivalent Xe-133 for > 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

None Basis:

This IC addresses a reactor coolant activity value that exceeds an allowable limit specified in Technical Specifications (ref. 1, 2). This condition is a precursor to a more significant event and represents a potential degradation of the level of safety of the plant.

Escalation of the emergency classification level would be via ICs FA1 or the Recognition Category A R ICs.

Reference(s):

1. Technical Specification 3.4.8 RCS Specific Activity

2. 3[4]-ONOP-041.4 Excessive RCS Activity

3. NEI 99-01 SU3 Page 220 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 5 - RCS Leakage Initiating Condition: RCS leakage for 15 minutes or longer EAL:

SU5.1 Unusual Event RCS unidentified or pressure boundary leakage > 10 gpm for 15 min.

OR RCS identified leakage > 25 gpm for 15 min.

OR Leakage from the RCS to a location outside containment > 25 gpm for 15 min.

(Note 1)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

UNISOLABLE - An open or breached system line that cannot be isolated, remotely or locally.

Basis:

Once the RCS leak rate has been quantified to be greater than the specified value, failure to isolate the leak within 15 minutes, or if known that the leak cannot be isolated within 15 minutes, from the time of leak rate quantification, requires immediate classification.

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.

The first and second EAL conditions EAL #1 and EAL #2 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 defined in the plant Technical Specifications). The third condition EAL

1. 3 addresses an RCS mass loss caused by an UNISOLABLE leak through an interfacing system. These conditions EALs thus apply to leakage into the containment, a secondary-side system (e.g., steam generator tube leakage in a PWR) or a location outside of containment.

The leak rate values for each condition 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). The first condition EAL #1 uses a lower value that 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 relief valve does not warrant an emergency classification. For PWRs, aAn emergency classification would Page 221 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases be required if a mass loss is caused by a relief valve that is not functioning as designed/expected (e.g., a relief valve sticks open and the line flow cannot be isolated). For BWRs, a stuck-open Safety Relief Valve (SRV) or SRV leakage is not considered either identified or unidentified leakage by Technical Specifications and, therefore, is not applicable to this EAL.

The 15-minute threshold duration allows sufficient time for prompt operator actions to isolate the leakage, if possible.

Escalation of the emergency classification level would be via ICs of Recognition Category A R or F.

Reference(s):

1. Technical Specification Section 1.0 Definitions

2. Technical Specification 3.4.6 RCS Leakage

3. 3[4]-ONOP-041.3 Excessive RCS Leakage

4. 3[4]-ONOP-071.2 Steam Generator Tube Leakage

5. NEI 99-01 SU4 Page 222 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 6 - RTS Failure Initiating Condition: Automatic or manual trip fails to shut down the reactor EAL:

SU6.1 Unusual Event An automatic trip did not shut down the reactor after any RPS setpoint is exceeded AND A subsequent automatic trip (RPS or AMSAC) or manual trip (reactor trip switches) is successful in shutting down the reactor as indicated by reactor power < 5% (Note 8)

Note 8: A manual trip action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

Mode Applicability:

1 - Power Operation Definition(s):

IMMINENT - The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.

Basis:

This IC EAL addresses a failure of the RPS to initiate or complete an automatic or manual reactor (trip [PWR] / scram [BWR])that results in a reactor shutdown, and either a subsequent operator manual action taken at the reactor control consolesin the control room (reactor trip switches) or an automatic (trip [PWR] / scram [BWR]) is successful in shutting down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.

Following the failure on an automatic reactor (trip[PWR] / scram [BWR]), operators will promptly initiate manual actions at the reactor control consoles to shutdown the reactor (e.g.,

initiate a manual reactor (trip[PWR] / scram [BWR]) using the reactor trip switches). 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 plants decay heat removal systems.

If an initial manual reactor (trip [PWR] / scram [BWR])is unsuccessful, operators will promptly take manual action at another location(s) on the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor (trip[PWR] / scram [BWR])) using a different switch).

Depending upon several factors, the initial or subsequent effort to manually (trip [PWR] / scram

[BWR]) the reactor, or a concurrent plant condition, may lead to the generation of an automatic reactor (trip [PWR] / scram [BWR]) signal. If a subsequent manual or automatic (trip [PWR] /

scram [BWR]) is successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plants decay heat removal systems.

Page 223 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases A manual action at the reactor control consolesin the control room is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor (trip using the reactor trip switches [PWR] / scram [BWR])). This action does not include opening MG set feeder breakers or opening the reactor trip feeder breakers locally, manually driving in control rods or implementation of boron injection strategies. Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be at the reactor control consoles.

Taking the Reactor Mode Switch to SHUTDOWN is considered to be a manual scram action.

[BWR]

The plant response to the failure of an automatic or manual reactor (trip[PWR] / scram [BWR])

will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If subsequent operator manual actions taken at the reactor control consoles are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC SA5. Depending upon the plant response, escalation is also possible via IC FA1. Absent the plant conditions needed to meet either IC SA5 or FA1, an Unusual Event declaration is appropriate for this event.

A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria (ref. 3, 4).

Should a reactor (trip [PWR] / scram [BWR])signal be generated as a result of plant work (e.g.,

RPS RTS setpoint testing), the following classification guidance should be applied.

If the signal causes a plant transient that should have included an automatic reactor (trip

[PWR] / scram [BWR])and the RPS fails to automatically shutdown the reactor, then this IC and the EALs are applicable, and should be evaluated.

If the signal does not cause a plant transient and the (trip [PWR] / scram [BWR])failure is determined through other means (e.g., assessment of test results), then this IC and the EALs are not applicable and no classification is warranted.

In the event that the operator identifies a reactor trip is IMMINENT and initiates a successful manual reactor trip before the automatic RPS trip setpoint is reached, no declaration is required. The successful manual trip of the reactor before it reaches its automatic trip setpoint or reactor trip signals caused by instrumentation channel failures do not lead to a potential fission product barrier loss. However, if subsequent manual reactor trip actions fail to shutdown the reactor, the event escalates to the Alert under EAL SA6.1.

Reference(s):

1. Technical Specification Table 1.2 Operational Modes

2. Technical Specification Table 3.3-1 Reactor Trip System Instrumentation

3. 3[4]-EOP-E-0 Reactor Trip or Safety Injection

4. 3[4]-EOP-FR-S.1 Response to Nuclear Power Generation/ATWS

5. NEI 99-01 SU5 Page 224 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 6 - RTS Failure Initiating Condition: Automatic or manual trip fails to shut down the reactor EAL:

SU6.2 Unusual Event A manual trip (reactor trip switches) did not shut down the reactor AND A subsequent automatic trip (RPS or AMSAC) or manual trip action taken at the reactor console (reactor trip switches) is successful in shutting down the reactor as indicated by reactor power < 5% (Note 8)

Note 8: A manual trip action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

Mode Applicability:

1 - Power Operation Definition(s):

None Basis:

This IC EAL addresses a failure of the RPS to initiate or complete an automatic ora manual reactor (trip [PWR] / scram [BWR]) that results in a reactor shutdown, and either a subsequent operator manual action taken at the reactor control consoles or an automatic (trip[PWR] /

scram [BWR]) is successful in shutting down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.

Following the failure on an automatic reactor (trip[PWR] / scram [BWR]), operators will promptly initiate manual actions at the reactor control consoles to shutdown the reactor (e.g.,

initiate a manual reactor (trip[PWR] / scram [BWR])). 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 plants decay heat removal systems.

If an initial manual reactor (trip[PWR] / scram [BWR]) is unsuccessful, operators will promptly take manual action at another location(s) on the reactor control consolesin the control room or at other locations outside of the control room to shutdown the reactor (e.g., initiate a manual reactor (trip[PWR] / scram [BWR])) using a different switchby opening MG set feeder breakers or opening the reactor trip feeder breakers locally) (ref. 3). However, those actions are not credited as a successful manual reactor trip for this EAL.

Depending upon several factors, the initial or subsequent effort to manually (trip [PWR] / scram

[BWR])the reactor, or a concurrent plant condition, may lead to the generation of an automatic reactor (trip [PWR] / scram [BWR])signal. If a subsequent manual or automatic (trip [PWR] /

Page 225 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases scram [BWR])is successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plants decay heat removal systems.

A manual action at the reactor control consolesin the control room is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor (trip using the reactor trip switches [PWR] / scram [BWR])). This action does not include opening MG set feeder breakers, opening the reactor trip feeder breakers locally, manually driving in control rods or implementation of boron injection strategies. Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be at the reactor control consoles.

Taking the Reactor Mode Switch to SHUTDOWN is considered to be a manual scram action.

[BWR]

The plant response to the failure of an automatic or manual reactor (trip [PWR] / scram [BWR])

will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If subsequent operator manual actions taken at the reactor control consoles are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC SA5. Depending upon the plant response, escalation is also possible via IC FA1. Absent the plant conditions needed to meet either IC SA5 or FA1, an Unusual Event declaration is appropriate for this event.

A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria (ref. 3, 4).

Should a reactor (trip [PWR] / scram [BWR]) signal be generated as a result of plant work (e.g., RPS setpoint testing), the following classification guidance should be applied.

If the signal causes a plant transient that should have included an automatic reactor (trip

[PWR] / scram [BWR]) and the RPS fails to automatically shutdown the reactor, then this IC and the EALs are applicable, and should be evaluated.

If the signal does not cause a plant transient and the (trip [PWR] / scram [BWR]) failure is determined through other means (e.g., assessment of test results), then this IC and the EALs are not applicable and no classification is warranted.

Reference(s):

1. Technical Specification Table 1.2 Operational Modes

2. Technical Specification Table 3.3-1 Reactor Trip System Instrumentation

3. 3[4]-EOP-E-0 Reactor Trip or Safety Injection

4. 3[4]-EOP-FR-S.1 Response to Nuclear Power Generation/ATWS

5. NEI 99-01 SU5 Page 226 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 2 - RTS Failure Initiating Condition: Automatic or manual trip fails to shut down the reactor and subsequent manual actions taken in the control room are not successful in shutting down the reactor EAL:

SA6.1 Alert An automatic or manual trip (reactor trip switches) did not shut down the reactor AND Subsequent automatic (RPS or AMSAC) or manual trip actions (reactor trip switches) are not successful in shutting down the reactor as indicated by reactor power 5% (Note 8)

Note 8: A manual trip action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

Mode Applicability:

1 - Power Operation Definition(s):

None Basis:

This IC EAL addresses a failure of the RPS to initiate or complete an automatic reactor trip or failure of a manual reactor (trip [PWR] / scram [BWR]) that results in a reactor shutdown, and subsequent operator manual actions taken at the reactor control consolesin the control room to shutdown the reactor are also unsuccessful. This condition represents an actual or potential substantial degradation of the level of safety of the plant. An emergency declaration is required even if the reactor is subsequently shutdown by an action taken away from the reactor control consoles since this event entails a significant failure of the RPS.

A manual action at the reactor control consolein the control room is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor (trip[PWR] / scram [BWR]) using the reactor trip switches). This action does not include opening MG set feeder breakers, opening the reactor trip feeder breakers locally, manually driving in control rods or implementation of boron injection strategies. If this action(s) is unsuccessful, operators would immediately pursue additional manual actions at locations away from the reactor control consolesoutside the control room (opening MG set feeder breakers, opening the reactor trip feeder breakers locallye.g., locally opening breakers).

Actions taken at back panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be at the reactor control consoles.

Taking the Reactor Mode Switch to SHUTDOWN is considered to be a manual scram action.

[BWR]

Page 227 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases The plant response to the failure of an automatic or manual reactor (trip [PWR] / scram [BWR])

will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If the failure to shut down the reactor is prolonged enough to cause a challenge to the core cooling [PWR] / RPV water level [BWR]or RCS heat removal safety functions, the emergency classification level will escalate to a Site Area Emergency via IC SS65. Depending upon plant responses and symptoms, escalation is also possible via IC FS1. Absent the plant conditions needed to meet either IC SS65 or FS1, an Alert declaration is appropriate for this event.

It is recognized that plant responses or symptoms may also require an Alert declaration in accordance with the Recognition Category F ICs; however, this IC and EAL are included to ensure a timely emergency declaration.

A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria (ref. 3, 4).

Reference(s):

1. Technical Specification Table 1.2 Operational Modes

2. Technical Specification Table 3.3-1 Reactor Trip System Instrumentation

3. 3[4]-EOP-E-0 Reactor Trip or Safety Injection

4. 3[4]-EOP-FR-S.1 Response to Nuclear Power Generation/ATWS

5. NEI 99-01 SA5 Page 228 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 2 - RTS Failure Initiating Condition: Inability to shut down the reactor causing a challenge to core cooling or RCS heat removal EAL:

SS6.1 Site Area Emergency An automatic or manual trip did not shut down the reactor AND All actions taken to shut down the reactor are not successful as indicated by reactor power 5%

AND EITHER:

CSFST Core Cooling-RED path conditions met CSFST Heat Sink-RED path conditions met Mode Applicability:

1 - Power Operation Definition(s):

None Basis:

This IC EAL addresses a failure of the RPS to initiate or complete an automatic reactor trip or failure of a manual reactor (trip [PWR] / scram [BWR]) that results in a reactor shutdown, all subsequent operator actions to manually shutdown the reactor are unsuccessful, and continued power generation is challenging the capability to adequately remove heat from the core and/or the RCS. This condition will lead to fuel damage if additional mitigation actions are unsuccessful and thus warrants the declaration of a Site Area Emergency.

Reactor shutdown achieved by use of other trip actions such as opening supply breakers, emergency boration, or manually driving control rods are also credited as a successful manual trip provided reactor power can be reduced to less than 5% before indications of an extreme challenge to either core cooling or heat removal exist.

In some instances, the emergency classification resulting from this IC/EAL may be higher than that resulting from an assessment of the plant responses and symptoms against the Recognition Category F ICs/EALs. This is appropriate in that the Recognition Category F ICs/EALs do not address the additional threat posed by a failure to shut down the reactor. The inclusion of this IC and EAL ensures the timely declaration of a Site Area Emergency in response to prolonged failure to shut down the reactor.

Page 229 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria (ref. 3, 4).

Indication that core cooling is extremely challenged is manifested by entry to Critical Safety Function Status Tree (CSFST) Core Cooling-RED path. Indication that heat removal is extremely challenged is manifested by entry to CSFST Heat Sink-RED path (ref. 5).

Escalation of the emergency classification level would be via IC AG1 RG1 or FG1.

Reference(s):

1. Technical Specification Table 1.2 Operational Modes

2. Technical Specification Table 3.3-1 Reactor Trip System Instrumentation

3. 3[4]-EOP-E-0 Reactor Trip or Safety Injection

4. 3[4]-EOP-FR-S.1 Response to Nuclear Power Generation/ATWS

5. 3[4]-EOP-F-0 Critical Safety Function Status Trees

6. NEI 99-01 SS5 Page 230 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 7 - Loss of Communications Initiating Condition: Loss of all onsite or offsite communications capabilities EAL:

SU7.1 Unusual Event Loss of all Table S-4 onsite communication methods OR Loss of all Table S-4 State and local agency communication methods OR Loss of all Table S-4 NRC communication methods Table S-4 Communication Methods State/

System Onsite NRC Local Plant Radio System X Commercial Telephone System X X X Plant Address (PA) System X Federal Telephone System (ENS) X EMnet X Hot Ring Down (HRD) Telephone System X Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

None Basis:

This IC addresses a significant loss of on-site or offsite communications capabilities. While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to OROs State and local agencies and the NRC.

This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-Page 231 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).

The first EAL condition EAL #1 addresses a total loss of the communications methods used in support of routine plant operations.

The second EAL condition EAL #2 addresses a total loss of the communications methods used to notify all OROs State and local agencies of an emergency declaration. The OROs State and local agencies referred to here are the State of Florida and local communities. (see Developer Notes)

The third EAL EAL #3 addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.

This hot condition EAL is equivalent to the cold condition EAL CU5.1.

Reference(s):

1. Turkey Point Plant Radiological Emergency Plan

2. NEI 99-01 SU6 Page 232 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 8 - Containment Failure Initiating Condition: Failure to isolate containment or loss of containment pressure control EAL:

SU8.1 Unusual Event Any penetration is not closed within 15 min. of a VALID CTMT isolation (Phase A, B or Containment Ventilation Isolation) actuation signal OR CTMT pressure > 20 psig with < one full train of CTMT heat removal systems operating per design for 15 min.

(Notes 1, 11)

Note 1: The EC should declare the event promptly upon determining that the time limit has been exceeded, or will likely be exceeded.

Note 11: One full train of CTMT heat removal systems consists of at least two Containment Coolers operating in conjunction with one Containment Spray Pump.

Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

VALID - An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicators operability, the conditions existence, or the reports accuracy is removed. Implicit in this definition is the need for timely assessment.

Basis:

This IC EAL addresses a failure of one or more containment penetrations to automatically isolate (close) when required by an actuation signal. It also addresses an event that results in high containment pressure with a concurrent failure of containment pressure control systems.

Absent challenges to another fission product barrier, either condition represents potential degradation of the level of safety of the plant.

For EAL #1the first condition, the containment isolation signal must be generated as the result on an off-normal/accident condition (e.g., a safety injection or high containment pressure); a failure resulting from testing or maintenance does not warrant classification. The determination of containment and penetration status - isolated or not isolated - should be made in accordance with the appropriate criteria contained in the plant AOPs and EOPs. The 15-minute criterion is included to allow operators time to manually isolate the required penetrations, if possible.

EAL #2The second condition addresses a condition where containment pressure is greater than the setpoint at which containment energy (heat) removal systems are designed to Page 233 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases automatically actuate, and less than one full train of equipment is capable of operating per design (ref. 1, 2).

One full train of CTMT heat removal systems consists of at least two Containment Coolers operating in conjunction with one Containment Spray Pump (ref. 1, 2).

The 15-minute criterion is included to allow operators time to manually start equipment that may not have automatically started, if possible. The inability to start the required equipment indicates that containment heat removal/depressurization systems (e.g., containment sprays or cooling fansice condenser fans) are either lost or performing in a degraded manner.

This event would escalate to a Site Area Emergency in accordance with IC FS1 if there were a concurrent loss or potential loss of either the Fuel Clad or RCS fission product barriers.

Reference(s):

1. UFSAR Section 6.3 Emergency Containment Cooling

2. UFSAR Section 6.4 Containment Spray System

3. NEI 99-01 SU7 Page 234 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases Category: S - System Malfunction Subcategory: 9 - Hazardous Event Affecting Safety Systems Initiating Condition: Hazardous event affecting SAFETY SYSTEMS needed for the current operating mode EAL:

SA9.1 Alert The occurrence of any Table S-5 hazardous event AND Event damage has caused indications of degraded performance on one train of a SAFETY SYSTEM needed for the current operating mode AND EITHER:

Event damage has caused indications of degraded performance to the second train of the SAFETY SYSTEM needed for the current operating mode Event damage has resulted in VISIBLE DAMAGE to the second train of the SAFETY SYSTEM needed for the current operating mode (Notes 9, 10)

Note 9: If the affected SAFETY SYSTEM train was already inoperable or out of service before the hazardous event occurred, then emergency classification is not warranted.

Note 10: If the hazardous event only resulted in VISIBLE DAMAGE, with no indications of degraded performance to at least one train of a SAFETY SYSTEM, then this emergency classification is not warranted.

Table S-5 Hazardous Events Seismic event (earthquake)

Internal or external FLOODING event High winds or tornado strike FIRE EXPLOSION Other events with similar hazard characteristics as determined by the Shift Manager Mode Applicability:

1 - Power Operation, 2 - Startup, 3 - Hot Standby, 4 - Hot Shutdown Definition(s):

EXPLOSION - A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization. A release of steam (from high energy Page 235 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion. Such events require a post-event inspection to determine if the attributes of an explosion are present.

FIRE - Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is not required if large quantities of smoke and heat are observed.

FLOODING - A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.

SAFETY SYSTEM - A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related (as defined in 10CFR50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure:

(1) The integrity of the reactor coolant pressure boundary; (2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

VISIBLE DAMAGE - Damage to a SAFETY SYSTEM train that is readily observable without measurements, testing, or analysis. The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected SAFETY SYSTEM train.

Basis:

This IC addresses a hazardous event that causes damage to SAFETY SYSTEMS needed for the current operating mode. In order to provide the appropriate context for consideration of an ALERT classification, the hazardous event must have caused indications of degraded SAFETY SYSTEM performance in one train, and there must be either indications of performance issues with the second SAFETY SYSTEM train or VISIBLE DAMAGE to the second train such that the potential exists for this second SAFETY SYSTEM train to have performance issues. In other words, in order for this EAL to be classified, the hazardous event must occur, at least one SAFETY SYSTEM train must have indications of degraded performance, and the second SAFETY SYSTEM train must have indications of degraded performance or VISIBLE DAMAGE such that the potential exists for performance issues. Note that this second SAFETY SYSTEM train is from the same SAFETY SYSTEM that has indications of degraded performance; commercial nuclear power plants are designed to be able to support single system issues without compromising public health and safety from radiological events.

Indications of degraded performance addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

VISIBLE DAMAGE addresses damage to a SAFETY SYSTEM train that is not in service/operation and that potentially could cause performance issues. Operators will make Page 236 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases this determination 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. This VISIBLE DAMAGE should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

An event affecting equipment common to two or more trains of a safety system (i.e., there are indications of degraded performance and/or VISIBLE DAMAGE affecting the common equipment) should be classified as an Alert under this EAL, as appropriate to the plant mode.

By affecting the functionality of multiple trains of a safety system, the loss of the common equipment effectively meets the two-train impact criteria that underlie the EALs and bases.

An event affecting a single-train safety system (i.e., there are indications of degraded performance and/or VISIBLE DAMAGE affecting the one train) would not be classified under this EAL because the two-train impact criteria that underlie the EALs and bases would not be met. If an event affects a single-train safety system, then the emergency classification should be made based on plant parameters/symptoms meeting the EALs for another IC. Depending upon the circumstances, classification may also occur based on Shift Manager/EC judgement.

An event that affects two trains of a safety system (e.g., one train has indications of degraded performance and the other VISIBLE DAMAGE) that also has one or more additional trains should be classified as an Alert under this EAL, as appropriate to the plant mode. This approach maintains consistency with the two-train impact criteria that underlie the EALs and bases, and is warranted because the event was severe enough to affect the functionality of two trains of a safety system despite plant design criteria associated with system and system train separation and protection. Such an event may have caused other plant impacts that are not immediately apparent.

This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or a structure containing SAFETY SYSTEM components, needed for the current operating 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.

EAL 1.b.1 addresses damage to a SAFETY SYSTEM train that is in service/operation since indications for it will be readily available. The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.

EAL 1.b.2 addresses damage to a SAFETY SYSTEM component that is not in service/operation 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 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 AS1RS1.

This hot condition EAL is equivalent of the cold condition EAL CA6.1.

Reference(s):

1. 0-EPIP-20106 Natural Emergencies Page 237 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 1 Emergency Action Level Technical Bases

2. EP FAQ 2016-002

3. NEI 99-01 SA9 Page 238 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 2 Safe Operation & Shutdown Rooms/Areas Tables R-3 & H-2 Bases

Background

NEI 99-01 Revision 6 ICs AA3 and HA5 prescribe declaration of an Alert based on impeded access to rooms or areas (due to either area radiation levels or hazardous gas concentrations) where equipment necessary for normal plant operations, cooldown or shutdown is located.

These areas are intended to be plant operating mode dependent. Specifically the Developers Notes for AA3 and HA5 states:

The site-specific list of plant rooms or areas with entry-related mode applicability identified should specify those rooms or areas that contain equipment which require a manual/local action as specified in operating procedures used for normal plant operation, cooldown and shutdown. Do not include rooms or areas in which actions of a contingent or emergency nature would be performed (e.g., an action to address an off-normal or emergency condition such as emergency repairs, corrective measures or emergency operations). In addition, the list should specify the plant mode(s) during which entry would be required for each room or area.

The list should not include rooms 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).

Further, as specified in IC HA5:

The list need not include the Control Room if adequate engineered safety/design features are in place to preclude a Control Room evacuation due to the release of a hazardous gas.

Such features may include, but are not limited to, capability to draw air from multiple air intakes at different and separate locations, inner and outer atmospheric boundaries, or the capability to acquire and maintain positive pressure within the Control Room envelope.

Page 239 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 2 Safe Operation & Shutdown Rooms/Areas Tables R-3 & H-2 Bases PTN Table R-3 and H-2 Bases A review of PTN general operating procedures identified the following mode dependent in-plant locations where procedurally defined actions are required for normal plant operation, shutdown, and cool-down:

MODE 1 (Power Operation)

Aux Building 18 Turbine Building (All levels)

Rad Waste Building MODE 2 (Startup)

Aux Building 18 Turbine Building (All levels)

Rad Waste Building MODE 3 (Hot Standby)

Aux Building 18 Turbine Building (All levels)

Vital SWGR, LC, MCC rooms (TB)

HHSI Pump, CSP rooms Rad Waste Building MODE 4 (Hot Shutdown)

Aux Building 18 Turbine Building (All levels)

Vital SWGR, LC, MCC rooms (TB)

Containment RHR Pump & Hx rooms Rad Waste Building Electrical Penetration rooms Mode 5 (Cold Shutdown)

Aux Building 18 Turbine Building (All levels)

Vital SWGR, LC, MCC rooms (TB)

Containment Rad Waste Building Electrical Penetration rooms Procedures Reviewed 3(4)-GOP-103 Power Operation to Hot Standby 3(4)-GOP-305 Hot Standby to Cold Shutdown 3(4)-GOP-100 Fast Load Reduction GOP-103, GOP-305, and GOP-100 have branching procedures to perform tasks to accomplish the steps in the General Procedure. These lower tier procedures are referenced in the General Procedures. All steps in the GPs were researched to provide input into these tables.

Page 240 of 241

Turkey Point Nuclear Generating Emergency Action Level Technical Bases Document Attachment 2 Safe Operation & Shutdown Rooms/Areas Tables R-3 & H-2 Bases Control Room ventilation systems have adequate engineered safety/design features in place to preclude a Control Room evacuation due to the external release of a hazardous gas (UFSAR Section 7.7 Operating Control Stations and Section 9.9 Control Building Ventilation System).

Therefore, the Control Room is not included in this assessment or in Table H-2. IC RA3 Example EAL #2 is adequately bounded by IC RA2 Example EAL #1. Therefore, the Control Room is not included in this assessment or in Table R-3.

Table R-3 & H-2 Results Table R-3 & H-2 Safe Operation & Shutdown Rooms/Areas Room/Area Mode(s)

Auxiliary Building 18' 1, 2, 3, 4, 5 Turbine Building (any level) 1, 2, 3, 4, 5 Containment 4, 5 HHSI Pump, CSP Rooms 3 RHR Pump & HX Rooms 4 Rad Waste Building 1, 2, 3, 4, 5 Page 241 of 241