L-MT-25-031, Site Specific Emergency Action Level Technical Basis Documents Change

Site Specific Emergency Action Level Technical Basis Documents Change

ML25268A012
Person / Time
Site:	Monticello
Issue date:	09/24/2025
From:	Neal M Northern States Power Company, Minnesota, Xcel Energy
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
L-MT-25-031
Download: ML25268A012 (1)

Text

(}, Xcel Energy*

September 24, 2025 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Monticello Nuclear Generating Plant Docket No. 50-263 2807 West County Road 75 Monticello, MN 55362 L-MT-25-031 1 0CFR50.54( q) 10 CFR 72.44(f)

Subsequent Renewed Facility Operating License No. DPR-22 Monticello Nuclear Generating Plant site specific Emergency Action Level Technical Basis Documents change In accordance with 10 CFR 50.54(q)(5) and 10 CFR 72.44(f), Northern States Power Company, a Minnesota corporation (NSPM), doing business as Xcel Energy, hereby submits descriptions of changes to the Standard Emergency Plan (SEP) Site-Specific Emergency Action Level (EAL) Technical Basis Documents for the Monticello Nuclear Generating Plant along with a summary of the analysis demonstrating that the changes do not reduce the effectiveness of the SEP. The SEP continues to meet the requirements in 10 CFR 50 Appendix E and the planning standards of 10 CFR 50.47(b).

Summary of Commitments This letter makes no new commitments and no revisions to existing commitments.

Michelle M. Neal Plant Manager, Monticello Nuclear Generating Plant Northern States Power Company - Minnesota Enclosure cc:

Administrator, Region Ill, USNRC Project Manager, Monticello, USNRC Resident Inspector, Monticello, USNRC Connected

• Committed

• Trustworthy

• Safe EPLAN Change Summary 4 pages follow

SUMMARY

OF CHANGES Page 1 of 4 Change (#) 1 (EPLAN Monticello EAL - Technical Basis Document)

==

Description:==

This change to EPLAN-04 updates the naming of the Reactor Building Vent (RBV) gaseous effluent monitor point that is used in assessing EALs RU1.1 and RA1.1 to align with the new naming of it per ECR 601000004461 (Wide Range Gas Monitor Replacement (Reactor Building Vent). The change also includes clarifications within the technical basis sections that resulted from plant operating experience and training feedback that target improved consistency and repeatability for Emergency Directors (EDs) and operating crews in making emergency declarations. Following is synopsis of the changes:

1.a - Update the EALs RU1.1 and RA1.1 to include the name of the new RBV WRGM monitor point/parameter used to assess emergency classifications per EALs RU1.1 and RA1.1 in support of the Monticello Nuclear Generating Plant (MNGP) WRGM replacement project ECR 601000004461 (Wide Range Gas Monitor Replacement (Reactor Building Vent)).

1.b - Add the clarification guidance of EP-FAQ-2018-04 to the Basis sections of Initiating Conditions (ICs) CA6 and SA9.

1.c - Add the following NOTE to the start of the Basis section of IC HU4 "ND-95209 provides a pictorial of site structures on Table H2."

1.d - Added the following text to the Basis sections of ICs SG1, SS1, SA1, and SU1.

"If a transformer is declared unavailable consider the transformer(s) not capable of supplying busses 15 and/or 16."

Doc ID or (Procedure Number) / Revision Number:

EPLAN-04 (Monticello - MNGP)

Document

Title:

E-Plan revisions to EPLAN-04 (Monticello)

PCR Number: 602000036689 - MNGP Editorial Basis (applies to E-Plan changes only)

See Evaluation Determination for a discussion of the editorial type changes.

SUMMARY

OF CHANGES Page 2 of 4 Licensing/Basis Affected From EPLAN-01, Standard Emergency Plan:

1.2 BACKGROUND

The Xcel Energy licensing basis for meeting the requirements of 10 CFR 50.47(b) and Appendix E include the following documents:

Site-Specific Emergency Action level (EAL) Technical Basis Document (EPLAN-04, EPLAN-

05) - Establishes the EAL scheme used by the sites to declare emergencies. The Technical Basis document references inputs to determine values or events that would result in event classification.

Evaluation Determination:

Regulatory Compliance Basis 1.a. The Reactor Building Vent (RBV) Wide Range Gas Radiation Monitors (WRGMs),

including their main control room indication/control panels, and interface to the plant computer in RTIME is being replaced under ECR 601000004461. The replacement is categorized as a design equivalent change to replace the General Atomics RM-80 WRGMs which are aging and showing signs of failure with Mirion Technologies WRGM monitors.

Replacement of the RBV WRGM equipment was evaluated separately under 50.54(q) MT-2023-781. That review concluded the new Mirion Technologies WRGM equipment aligns with the Emergency Plan and does not result in change to the Emergency Plan. The related change being made to this revision of EPLAN-04 is limited to updating the affected EALs RU1.1 and RA1.1 to include identification of the point/parameter used for assessing those emergency classifications as indicated on the new RBV WRGM monitor readouts that corresponds to same point/parameter used for assessing those EALs using the existing equipment that is being replaced. There is no change to the affected EAL thresholds. This is considered an editorial change (difference from approved EALs) to align the affected EALs with the name of the point/parameter on the new Mirion Technologies RBV WRGM display units that provides the same indication for assessing the affected EALs as the existing General Atomics RM-80 WRGMs. This change does not result in altering the meaning or threshold value being measured.

Justification: Editorial revision to align the EALs with the new WRGM equipment display readout labeling. This revision does not affect the EAL threshold and is consistent with the format of previous labels. The EAL will continue to classify at the correct classification level.

1.b - EPFAQ Number: 2018-04 (Hazardous Events Effects On Safety Systems Clarification), (ADAMS Accession No. ML18340A051) addressed an industry concern of how to classify events per ICs CA6 and SA9, for events leading to indications of degraded performance and/or VISIBLE DAMAGE when:

- The event affects equipment common to two or more safety systems or safety system trains.

SUMMARY

OF CHANGES Page 3 of 4

- The event affects a safety system that has only one train.

- The event affects two trains of a safety system having more than two trains.

The NRC Response to the FAQ was that EPFAQ 2018-04 is limited to providing clarification for certain conditions and does not propose alteration of previous guidance. As such, licensees who use EPFAQ 2018-04 to provide clarification to EAL schemes that were developed consistent with EPFAQ 2016-02 could consider the change to the EAL scheme to be a difference as provided by RIS 2003-18, Supplement 2.

Review of MNGP letter to the NRC, L-MT-17-065 (License Amendment Request to Revise the Emergency Action Level Scheme - Supplement and Response to Requests for Additional Information (CAC No. MF9560)) and MNGP's approved EALs and classification scheme via License Amendment No. 197 and evaluated by the NRC in a Safety Evaluation Report (SER) dated March 6, 2018, verified that MNGP's EAL Scheme was developed consistent with EPFAQ 2016-02. Given the above, MNGP is adopting the answers to the questions posed in EPFAQ 2018-04 verbatim into the EAL basis for ICs CA6 and SA9 as a difference.

Justification: Implements EPFAQ 2018-04 guidance. Implementation of this guidance has been determined to be an acceptable difference by the NRC (ML18340A051). Use of the basis information in assessing the applicability of the affected EALs will continue to classify the events at the correct classification level.

1.c - The added note is duplication of information already contained in the Reference section of the Basis. It does not change or alter the areas to which the EAL is applicable to and does not change the intent. This does not result in a change to the Emergency Plan. It is an editorial reformatting and duplication of information already in the document.

Justification: Editorial revision for clarity. This revision does not affect the EAL threshold and is consistent with information contained in the Basis References section of the EAL.

1.d - The added text is intended to provide clarity to the user regarding the availability of transformers taken out of service per procedure due to degraded performance or other adverse conditions (versus a failed condition). The addition of the text to the basis section is an editorial clarification intended to support the user in rapid application of a plant equipment condition to the EAL and minimize a performance challenge that could occur if recognition of meeting an IC or EAL is based solely on the memory of a licensed operator or an Emergency Director, especially during periods of high stress.

Justification: This has been determined to be a difference. The added text does not change or alter the conditions to which the EAL is applicable to and does not change the intent. It is an editorial clarification added to the basis to support timely assessment of the applicability of a plant equipment condition to the EAL. Use of the basis information in assessing the applicability of the affected EALs will continue to classify the events at the correct classification level.

Emergency Plan Effectiveness Basis The changes are limited to being editorial in nature and/or providing clarifications for applicability of certain plant conditions to the affected ICs and EALs. They do not alter the intent of the affected ICs and EALs and continue to:

• Classify at the correct classification level.

SUMMARY

OF CHANGES Page 4 of 4

• Logically integrate with other EALs in the EAL scheme.

• Ensure that the resulting EAL scheme is complete (i.e., classifies all potential emergency conditions).

The changes are considered "differences" from MNGP's SER approved EALs and classifications scheme as defined by RIS 2003-18, Supplement 2 that do not result in a "Reduction in Effectiveness" of the Emergency Plan.

Monticello Emergency Action Level (EAL) Technical Basis Document (EPLAN-04) 172 pages follow

Nuclear Licensing Document EPLAN-04 Revision: 3 Page 1 of 172

Title:

Monticello Emergency Action Level (EAL) Technical Basis Document Approval:

602000034970 fl Xcel Energy*

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 2 of 172 Table of Contents Page REGULATORY BACKGROUND......................................................................... 5 1.1 OPERATING REACTORS........................................................................... 5 1.2 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI).......... 5 1.3 NRC ORDER EA-12-051............................................................................. 6 MNGP KEY TERMINOLOGY............................................................................... 8 2.1 EMERGENCY CLASSIFICATION LEVEL (ECL)........................................ 9 2.2 INITIATING CONDITION (IC).................................................................... 10 2.3 EMERGENCY ACTION LEVEL (EAL)...................................................... 11 2.4 FISSION PRODUCT BARRIER THRESHOLD......................................... 11 DESIGN OF THE NEI 99-01 EMERGENCY CLASSIFICATION SCHEME ADOPTED BY MNGP........................................................................ 12 3.1 ASSIGNMENT OF EMERGENCY CLASSIFICATION LEVELS (ECLS)....................................................................................................... 12 3.2 TYPES OF INITIATING CONDITIONS AND EMERGENCY ACTION LEVELS...................................................................................... 16 3.3 MNGP SPECIFIC DESIGN CONSIDERATIONS....................................... 17 3.4 ORGANIZATION AND PRESENTATION OF GENERIC INFORMATION.......................................................................................... 17 3.5 IC AND EAL MODE APPLICABILITY....................................................... 18 MNGP SCHEME DEVELOPMENT GUIDANCE................................................ 20 4.1 GENERAL IMPLEMENTATION GUIDANCE............................................ 20 4.2 CRITICAL CHARACTERISTICS............................................................... 20 4.3 INSTRUMENTATION USED FOR EALS.................................................. 21 4.4 PRESENTATION OF SCHEME INFORMATION TO USERS................... 21 1.0 2.0 3.0 4.0

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 3 of 172 Table of Contents (Cont'd)

Page 4.5 INTEGRATION OF ICS/EALS WITH PLANT PROCEDURES.................. 22 4.6 BASIS DOCUMENT.................................................................................. 23 4.7 EAL/THRESHOLD REFERENCES TO MNGP AOP AND EOP SETPOINTS/CRITERIA............................................................................. 24 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS......................... 24 5.1 GENERAL CONSIDERATIONS................................................................ 24 5.2 CLASSIFICATION METHODOLOGY....................................................... 26 5.3 CLASSIFICATION OF MULTIPLE EVENTS AND CONDITIONS............. 26 5.4 CONSIDERATION OF MODE CHANGES DURING CLASSIFICATION..................................................................................... 26 5.5 CLASSIFICATION OF IMMINENT CONDITIONS..................................... 27 5.6 EMERGENCY CLASSIFICATION LEVEL UPGRADING AND DOWNGRADING....................................................................................... 27 5.7 CLASSIFICATION OF SHORT-LIVED EVENTS...................................... 27 5.8 CLASSIFICATION OF TRANSIENT CONDITIONS.................................. 28 5.9 AFTER-THE-FACT DISCOVERY OF AN EMERGENCY EVENT OR CONDITION........................................................................................ 29 5.10 RETRACTION OF AN EMERGENCY DECLARATION............................ 29 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT ICS/EALS........... 30 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION ICS/EALS........................................................................................................... 53 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

ICS/EALS........................................................................................................... 82 FISSION PRODUCT BARRIER ICS/EALS........................................................ 85 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS......................................................................................................... 100 5.0 6.0 7.0 8.0 9.0 10.0

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 4 of 172 Table of Contents (Cont'd)

Page SYSTEM MALFUNCTION ICS/EALS.............................................................. 131 APPENDIX A ACRONYMS AND ABBREVIATIONS................................................. 166 APPENDIX B DEFINITIONS....................................................................................... 169 11.0

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 5 of 172 REGULATORY BACKGROUND 1.1 OPERATING REACTORS Title 10, Code of Federal Regulations (CFR), Energy, contains the U.S.

Nuclear Regulatory Commission (NRC) regulations that apply to nuclear power facilities. Several of these regulations govern various aspects of an emergency classification scheme. A review of the relevant sections listed below will aid the reader in understanding the key terminology provided in Section 3.0 of this document.

10 CFR § 50.47(a)(1)(i) 10 CFR § 50.47(b)(4) 10 CFR § 50.54(q) 10 CFR § 50.72(a) 10 CFR § 50, Appendix E, IV.B, Assessment Actions 10 CFR § 50, Appendix E, IV.C, Activation of Emergency Organization The above regulations are supplemented by various regulatory guidance documents. Three documents of particular relevance to NEI 99-01 are:

NUREG-0654/FEMA-REP-1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants, October 1980. [Refer to Appendix 1, Emergency Action Level Guidelines for Nuclear Power Plants]

NUREG-1022, Event Reporting Guidelines 10 CFR § 50.72 and § 50.73 Regulatory Guide 1.101, Emergency Response Planning and Preparedness for Nuclear Power Reactors 1.2 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

Selected guidance in NEI 99-01 is applicable to the Monticello Nuclear Generating Plant (MNGP) emergency plan to fulfill the requirements of 10 CFR 72.32 for a stand-alone ISFSI. The emergency classification levels applicable to an ISFSI are consistent with the requirements of 10 CFR § 50 and the guidance in NUREG 0654/FEMA-REP-1. The initiating conditions germane to a 10 CFR § 72.32 emergency plan (as described in NUREG-1567) are subsumed within the classification scheme for a 10 CFR § 50.47 emergency plan.

1.0

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 6 of 172 The MNGP IC and EAL for an ISFSI are presented in Section 8.0, ISFSI ICs/EALs. IC EU1 covers the spectrum of credible natural and man-made events included within the scope of the ISFSI design. In addition, appropriate aspects of IC HU1 and IC HA1 address a HOSTILE ACTION directed against the ISFSI.

The analysis of potential onsite and offsite consequences of accidental releases associated with the operation of an ISFSI is contained in NUREG-1140, A Regulatory Analysis on Emergency Preparedness for Fuel Cycle and Other Radioactive Material Licensees. NUREG-1140 concluded that the postulated worst-case accident involving an ISFSI has insignificant consequences to public health and safety. This evaluation shows that the maximum offsite dose to a member of the public due to an accidental release of radioactive materials would not exceed 1 rem Effective Dose Equivalent.

Regarding the above information, the expectations for an offsite response to an Alert classified under a 10 CFR § 72.32 emergency plan are generally consistent with those for a Notification of Unusual Event in a 10 CFR § 50.47 emergency plan (e.g., to provide assistance if requested). Also, the MNGP Emergency Response Organization (ERO) required for a 10 CFR § 72.32 emergency plan is different than that prescribed for a 10 CFR § 50.47 emergency plan (e.g., no emergency technical support function).

1.3 NRC ORDER EA-12-051 The Fukushima Daiichi accident of March 11, 2011, was the result of a tsunami that exceeded the plants design basis and flooded the sites emergency electrical power supplies and distribution systems. This caused an extended loss of power that severely compromised the key safety functions of core cooling and containment integrity, and ultimately led to core damage in three reactors. While the loss of power also impaired the spent fuel pool cooling function, sufficient water inventory was maintained in the pools to preclude fuel damage from the loss of cooling.

Following a review of the Fukushima Daiichi accident, the NRC concluded that several measures were necessary to ensure adequate protection of public health and safety under the provisions of the backfit rule, 10 CFR 50.109(a)(4)(ii). Among them was to provide each spent fuel pool with reliable level instrumentation to significantly enhance the ability of key decision-makers to allocate resources effectively following a beyond design basis event. To this end, the NRC issued Order EA-12-051, Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, on March 12, 2012, to all US nuclear plants with an operating license, construction permit, or combined construction and operating license.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 7 of 172 NRC Order EA-12-051 states, in part, All licensees shall have a reliable indication of the water level in associated spent fuel storage pools capable of supporting identification of the following pool water level conditions by trained personnel: (1) level that is adequate to support operation of the normal fuel pool cooling system, (2) level that is adequate to provide substantial radiation shielding for a person standing on the spent fuel pool operating deck, and (3) level where fuel remains covered and actions to implement make-up water addition should no longer be deferred. To this end, all licensees must provide:

A primary and back-up level instrument that will monitor water level from the normal level to the top of the used fuel rack in the pool; A display in an area accessible following a severe event; and Independent electrical power to each instrument channel and provide an alternate remote power connection capability.

NEI 12-02, Industry Guidance for Compliance with NRC Order EA-12-051, To Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation, provides guidance for complying with NRC Order EA-12-051.

This document includes three EALs that reflect the availability of the enhanced spent fuel pool level instrumentation associated with NRC Order EA-12-051. These EALs are included within existing IC RA2, and new ICs RS2 and RG2.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 8 of 172 MNGP KEY TERMINOLOGY There are several key terms that appear throughout the emergency classification methodology for MNGP. These terms are introduced in this section to support understanding of subsequent material. As an aid to the reader, the following table is provided as an overview to illustrate the relationship of the terms to each other.

Emergency Classification Level GE SAE Alert Unusual Event Initiating Condition Initiating Condition Initiating Condition Initiating Condition Emergency Action Level (1)

• Operating Mode Applicability

• Notes

• Basis Emergency Action Level (1)

• Operating Mode Applicability

• Notes

• Basis Emergency Action Level (1)

• Operating Mode Applicability

• Notes

• Basis Emergency Action Level (1)

• Operating Mode Applicability

• Notes

• Basis (1) - When making an emergency classification, the Emergency Director must consider all information having a bearing on the proper assessment of an Initiating Condition. This includes the Emergency Action Level (EAL) plus the associated Operating Mode Applicability, Notes and the informing Basis information. In the Recognition Category F matrices, EALs are referred to as Fission Product Barrier Thresholds; the thresholds serve the same function as an EAL.

2.0 I

I I

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 9 of 172 2.1 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 (NUE)

Alert Site Area Emergency (SAE)

General Emergency (GE)

NOTIFICATION OF UNUSUAL EVENT (NUE)

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.

Purpose:

The purpose of this classification is to assure that the first step in future response has been carried out, to bring the operations staff to a state of readiness, and to provide systematic handling of unusual event information and decision-making.

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 PAG exposure levels.

Purpose:

The purpose of this classification is to assure that emergency personnel are readily available to respond if the situation becomes more serious or to perform confirmatory radiation monitoring if required, and provide offsite authorities current information on plant status and parameters.

2.1.1 2.1.2

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 10 of 172 SITE AREA EMERGENCY (SAE)

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.

Purpose:

The purpose of the Site Area Emergency declaration is to assure that emergency response centers are staffed, to assure that monitoring teams are dispatched, to assure that personnel required for evacuation of near-site areas are at duty stations if the situation becomes more serious, to provide consultation with offsite authorities, and to provide updates to the public through government authorities.

GENERAL EMERGENCY (GE)

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

Purpose:

The purpose of the General Emergency declaration is to initiate predetermined protective actions for the public, to provide continuous assessment of information from the licensee and offsite organizational measurements, to initiate additional measures as indicated by actual or potential releases, to provide consultation with offsite authorities, and to provide updates for the public through government authorities.

2.2 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.

Discussion: An IC describes an event or condition, the severity or consequences of which meets the definition of an emergency classification level. An IC can be expressed as a continuous, measurable parameter (e.g.,

RCS leakage), an event (e.g., an earthquake) or the status of one or more fission product barriers (e.g., loss of the RCS barrier).

2.1.3 2.1.4

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 11 of 172 Appendix 1 of NUREG-0654 does not contain example Emergency Action Levels (EALs) for each ECL, but rather Initiating Conditions (i.e., plant conditions that indicate that a radiological emergency, or events that could lead to a radiological emergency, has occurred). NUREG-0654 states that the Initiating Conditions form the basis for establishment by a licensee of the specific plant instrumentation readings (as applicable) which, if exceeded, would initiate the emergency classification. Thus, it is the specific instrument readings that would be the EALs.

Considerations for the assignment of a particular Initiating Condition to an emergency classification level are discussed in Section 3.0.

2.3 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.

Discussion: EAL statements may utilize a variety of criteria including instrument readings and status indications; observable events; results of calculations and analyses; entry into particular procedures; and the occurrence of natural phenomena.

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

Discussion: 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. The primary fission product barriers are:

Fuel Clad Reactor Coolant System (RCS)

Containment Upon determination that one or more fission product barrier thresholds have been exceeded, the combination of barrier loss and/or potential loss thresholds is compared to the fission product barrier IC/EAL criteria to determine the appropriate ECL.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 12 of 172 In some accident sequences, the ICs and EALs presented in the Abnormal Radiation Levels/ Radiological Effluent (R) Recognition Category will be exceeded at the same time, or shortly after, the loss of one or more fission product barriers. This redundancy is intentional as the former ICs address radioactivity releases that result in certain offsite doses from whatever cause, including events that might not be fully encompassed by fission product barriers (e.g., spent fuel pool accidents, design containment leakage following a LOCA, etc.).

DESIGN OF THE NEI 99-01 EMERGENCY CLASSIFICATION SCHEME ADOPTED BY MNGP 3.1 ASSIGNMENT OF EMERGENCY CLASSIFICATION LEVELS (ECLS)

An effective emergency classification scheme must incorporate a realistic and accurate assessment of risk, both to plant workers and the public. There are obvious health and safety risks in underestimating the potential or actual threat from an event or condition; however, there are also risks in overestimating the threat as well (e.g., harm that may occur during an evacuation). The NEI 99-01emergency classification scheme attempts to strike an appropriate balance between reasonably anticipated event or condition consequences, potential accident trajectories, and risk avoidance or minimization. NSPM has adopted the NEI 99-01 scheme, adding site-specific information as appropriate. This section discusses the background for development of the NEI 99-01 scheme and adds MNGP specific details where appropriate.

There are a range of non-emergency events reported to the US Nuclear Regulatory Commission (NRC) staff in accordance with the requirements of 10 CFR § 50.72. Guidance concerning these reporting requirements, and example events, are provided in NUREG-1022. Certain events reportable under the provisions of 10 CFR § 50.72 may also require the declaration of an emergency.

In order to align each Initiating Conditions (IC) with the appropriate ECL, it was necessary to determine the attributes of each ECL. The goal of this process is to answer the question, What events or conditions should be placed under each ECL? The following sources provided information and context for the development of ECL attributes.

Assessments of the effects and consequences of different types of events and conditions Typical abnormal and emergency operating procedure setpoints and transition criteria 3.0

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 13 of 172 Typical Technical Specification limits and controls Radiological Effluent Technical Specifications (RETS)/Offsite Dose Calculation Manual (ODCM) radiological release limits Review of selected Updated Final Safety Analysis Report (UFSAR) accident analyses Environmental Protection Agency (EPA) Protective Action Guidelines (PAGs)

NUREG 0654, Appendix 1, Emergency Action Level Guidelines for Nuclear Power Plants Industry Operating Experience Input from industry subject matter experts and MNGP staff The following ECL attributes were created to aid in the development of ICs and Emergency Action Levels (EALs). These attributes may be useful in briefing and training settings (e.g., helping an Emergency Director understand why a particular condition is classified as an Alert).

The attributes of each ECL are presented below.

NOTIFICATION OF UNUSUAL EVENT (NUE)

A Notification of Unusual Event, as defined in Section 2.1.1, includes but is not limited to an event or condition that involves:

A precursor to a more significant event or condition.

A minor loss of control of radioactive materials or the ability to control radiation levels within the plant.

A consequence otherwise significant enough to warrant notification to local, State and Federal authorities.

3.1.1

1.

2.

3.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 14 of 172 ALERT An Alert, as defined in Section 2.1.2, includes but is not limited to an event or condition that involves:

A loss or potential loss of either the fuel clad or Reactor Coolant System (RCS) fission product barrier.

An event or condition that significantly reduces the margin to a loss or potential loss of the fuel clad or RCS fission product barrier.

A significant loss of control of radioactive materials resulting in an inability to control radiation levels within the plant, or a release of radioactive materials to the environment that could result in doses greater than 1% of an EPA PAG at or beyond the site boundary.

A HOSTILE ACTION occurring within the OWNER CONTROLLED AREA, including those directed at an Independent Spent Fuel Storage Installation (ISFSI).

SITE AREA EMERGENCY (SAE)

A Site Area Emergency, as defined in Section 2.1.3, includes but is not limited to an event or condition that involves:

A loss or potential loss of any two fission product barriers - fuel clad, RCS and/or containment.

A precursor event or condition that may lead to the loss or potential loss of multiple fission product barriers within a relatively short period of time. Precursor events and conditions of this type include those that challenge the monitoring and/or control of multiple safety systems.

A release of radioactive materials to the environment that could result in doses greater than 10% of an EPA PAG at or beyond the site boundary.

A HOSTILE ACTION occurring within the plant PROTECTED AREA.

3.1.2

1.

2.

3.

4.

3.1.3

1.

2.

3.

4.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 15 of 172 GENERAL EMERGENCY (GE)

A General Emergency, as defined in Section 2.1.4, includes but is not limited to an event or condition that involves:

Loss of any two fission product barriers AND loss or potential loss of the third barrier - fuel clad, RCS and/or containment.

A precursor event or condition that, unmitigated, may lead to a loss of all three fission product barriers. Precursor events and conditions of this type include those that lead directly to core damage and loss of containment integrity.

A release of radioactive materials to the environment that could result in doses greater than an EPA PAG at or beyond the site boundary.

A HOSTILE ACTION resulting in the loss of key safety functions (reactivity control, core cooling/RPV water level or RCS heat removal) or damage to spent fuel.

RISK-INFORMED INSIGHTS Emergency preparedness is a defense-in-depth measure that is independent of the assessed risk from any particular accident sequence; however, the development of an effective emergency classification scheme can benefit from a review of risk-based assessment results. To that end, the development and assignment of certain ICs and EALs also considered insights from several site-specific probabilistic safety assessments (PSA -

also known as probabilistic risk assessment, PRA). Some generic insights from this review included:

Accident sequences involving a prolonged loss of all AC power are significant contributors to core damage frequency. For this reason, a loss of all AC power for greater than 15 minutes, with the plant at or above Hot Shutdown, was assigned an ECL of Site Area Emergency.

Precursor events to a loss of all AC power were also included as an Unusual Event and an Alert.

A station blackout coping analyses performed in response to 10 CFR § 50.63 and Regulatory Guide 1.155, Station Blackout, was used to determine a time-based criterion to demarcate between a Site Area Emergency and a General Emergency. The time dimension is critical to a properly anticipatory emergency declaration since the goal is to maximize the time available for State and local officials to develop and implement offsite protective actions. For MNGP, the coping 3.1.4 3.1.5

1.

2.

3.

4.

1.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 16 of 172 analysis determined that MNGP is a four (4) hour coping plant. This provides the basis for the time-based demarcation criterion between a Site Area Emergency and a General Emergency for MNGP For severe core damage events, uncertainties exist in phenomena important to accident progressions leading to containment failure.

Because of these uncertainties, predicting the status of containment integrity may be difficult under severe accident conditions. This is why maintaining containment integrity alone following sequences leading to severe core damage is an insufficient basis for not escalating to a General Emergency.

PSAs indicated that leading contributors to latent fatalities were sequences involving a containment bypass, a large Loss of Coolant Accident (LOCA) with early containment failure, a Station Blackout lasting longer than the site-specific coping period, and a reactor coolant pump seal failure. The generic EAL methodology needs to be sufficiently rigorous to address these sequences in a timely fashion.

3.2 TYPES OF INITIATING CONDITIONS AND EMERGENCY ACTION LEVELS The NEI 99-01 methodology adopted by MNGP makes use of symptom-based, barrier-based and event-based ICs and EALs. Each type is discussed below.

Symptom-based ICs and EALs are parameters or conditions that are measurable over some range using plant instrumentation (e.g., core temperature, reactor coolant level, radiological effluent, etc.). When one or more of these parameters or conditions are off-normal, reactor operators will implement procedures to identify the probable cause(s) and take corrective action.

Fission product barrier-based ICs and EALs are the subset of symptom-based EALs that refer specifically to the level of challenge to the principal barriers against the release of radioactive material from the reactor core to the environment. These barriers are the fuel cladding, the reactor coolant system pressure boundary, and the containment. The barrier-based ICs and EALs consider the level of challenge to each individual barrier - potentially lost and lost - and the total number of barriers under challenge.

Event-based ICs and EALs define a variety of specific occurrences that have potential or actual safety significance. These include the failure of an automatic reactor scram/trip to shut down the reactor, natural phenomena (e.g., an earthquake), or man-made hazards such as a toxic gas release.

2.

3.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 17 of 172 3.3 MNGP SPECIFIC DESIGN CONSIDERATIONS MNGP uses a single cycle, forced circulation, low power density boiling water reactor (BWR). General Electric Company designed the plant and supplied the nuclear steam supply system (NSSS), the initial reactor fuel, and turbine-generator unit and its related systems. This design is identified as BWR-3 by General Electric. ICs and EAL thresholds for a BWR NSSS have been appropriately incorporated into the MNGP emergency classification scheme.

The reactor coolant system (also called the reactor primary system) includes the reactor vessel; the 2-loop reactor coolant recirculation system with its pumps, pipes and valves; the main steam piping up to the main steam isolation valves; safety/relief valves; and the reactor auxiliary systems piping.

The reactor vessel contains the reactor core and supporting structure, steam separator and dryer assemblies, jet pumps, control rod guide tubes, and the Reactor Feedwater, Emergency Core Cooling System (ECCS), and Standby Liquid Control System spargers.

The Primary Containment System, consisting of a steel light-bulb-shaped drywell, a steel doughnut-shaped pressure suppression chamber, and interconnecting vent pipes, provides the first containment barrier surrounding the reactor vessel and reactor primary system. The primary containment system is designed to accommodate the pressures, temperatures, and hydrodynamic loads which would result from, or occur subsequent to a postulated loss-of-coolant accident (LOCA) within the primary containment and safety relief valve operations. Any leakage from the Primary Containment System is to the Secondary Containment System, consisting of the reactor building, the plant Standby Gas Treatment System, and the plant main stack. The primary safeguards functions of the secondary containment are to minimize ground level release of airborne radioactive materials, and to provide for controlled, filtered, elevated release of secondary containment atmosphere under postulated design basis accident conditions.

3.4 ORGANIZATION AND PRESENTATION OF GENERIC INFORMATION The schemes generic information is organized by Recognition Category in the following order.

R - Abnormal Radiation Levels / Radiological Effluent - Section 6.0 C - Cold Shutdown / Refueling System Malfunction - Section 7.0 E - Independent Spent Fuel Storage Installation (ISFSI) - Section 8.0 F - Fission Product Barrier - Section 9.0

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 18 of 172 H - Hazards and Other Conditions Affecting Plant Safety - Section 10.0 S - System Malfunction - Section 11.0 Each Recognition Category section contains a matrix showing the ICs and their associated emergency classification levels.

The following information and guidance is provided for each IC:

ECL - the assigned emergency classification level for the IC.

Initiating Condition - provides a summary description of the emergency event or condition.

Operating Mode Applicability - Lists the modes during which the IC and associated EAL(s) are applicable (i.e., are to be used to classify events or conditions).

Emergency Action Level(s) - Provides reports and indications that are considered to meet the intent of the IC.

For Recognition Category F, the fission product barrier thresholds are presented in a table applicable to MNGP, and arranged by fission product barrier and the degree of barrier challenge (i.e., potential loss or loss). This presentation method shows the synergism among the thresholds, and supports accurate assessments.

Basis - Provides background information that explains the intent and application of the IC and EALs. In some cases, the basis also includes relevant source information and references.

3.5 IC AND EAL MODE APPLICABILITY The NEI 99-01 emergency classification scheme adopted by MNGP was developed recognizing that the applicability of ICs and EALs will vary with plant mode. For example, some symptom-based ICs and EALs can be assessed only during the power operations, startup, or hot shutdown modes of operation when all fission product barriers are in place, and plant instrumentation and safety systems are fully operational. In the cold shutdown and refueling modes, different symptom-based ICs and EALs will come into play to reflect the opening of systems for routine maintenance, the unavailability of some safety system components and the use of alternate instrumentation.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 19 of 172 The following table shows which Recognition Categories are applicable in each plant mode. The ICs and EALs for a given Recognition Category are applicable in the indicated modes.

MODE APPLICABILITY MATRIX FOR MNGP Category Mode R

C E

F H

S Power Operations X

X X

X X

Startup X

X X

X X

Hot Shutdown X

X X

X X

Cold Shutdown X

X X

X Refueling X

X X

X Defueled X

X X

X MNGP Operating Modes Mode Title Reactor Mode Switch Position Average Reactor Coolant Temperature (F) 1 Power Operation Run NA 2

Startup Refuel1 or Startup/Hot Standby NA 3

Hot Shutdown1 Shutdown

> 212 4

Cold Shutdown1 Shutdown 212 5

Refueling2 Shutdown or Refuel NA Defueled (None): All fuel removed from the reactor vessel (i.e., full core offload during refueling or extended outage).

1.

All reactor vessel head closure bolts fully tensioned.

2.

One or more reactor vessel head closure bolts less than fully tensioned.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 20 of 172 MNGP SCHEME DEVELOPMENT GUIDANCE 4.1 GENERAL IMPLEMENTATION GUIDANCE MNGP ICs and EALs were developed to be unambiguous and readily assessable.

The IC is the fundamental event or condition requiring a declaration. The EAL(s) is the pre-determined threshold that defines when the IC is met. To this end, the MNGP ICs and EALs were developed with input from key stakeholders such as Operations, Training, Radiation Protection, Chemistry, and Engineering. MNGP specific indications, parameters, and values are consistent with licensing basis documents, plant procedures, training, calculations, and drawings.

Useful acronyms and abbreviations associated with the MNGP emergency classification scheme are presented in Appendix A, Acronyms and Abbreviations. Those specific to MNGP were included to be consistent with site terminology, site procedures, and training.

Many words or terms used in the MNGP emergency classification scheme have scheme-specific definitions. These words and terms are identified by being set in all capital letters (i.e., ALL CAPS). The definitions are presented in Appendix B, Definitions.

4.2 CRITICAL CHARACTERISTICS When crafting the scheme, MNGP ensured that certain critical characteristics were met. These critical characteristics are listed below.

The ICs, EALs, Operating Mode Applicability criteria, Notes and Basis information are consistent with industry guidance; while the actual wording may be different from NEI 99-01 Revision 6, the classification intent is maintained. With respect to Recognition Category F, the MNGP scheme includes a user-aid to facilitate timely and accurate classification of fission product barrier losses and/or potential losses.

The user-aid logic is consistent with the classification logic presented in Section 9.0.

The ICs, EALs, Operating Mode Applicability criteria, Notes and Basis information are technically complete and accurate (i.e., they contain the information necessary to make a correct classification).

EAL statements use objective criteria and observable values.

4.0

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 21 of 172 ICs, EALs, Operating Mode Applicability and Note statements and formatting consider human factors and are user-friendly.

The scheme facilitates upgrading of the emergency classification where necessary.

The scheme facilitates classification of multiple concurrent events or conditions.

4.3 INSTRUMENTATION USED FOR EALS MNGP EAL thresholds utilize instrumentation that is reliable and routinely maintained in accordance with site programs and procedures. Alarms referenced in EAL statements are those that are the most operationally significant for the described event or condition.

MNGP personnel have ensured that specified values used as EAL setpoints are within the calibrated range of the referenced instrumentation, and consider any automatic instrumentation functions that may impact accurate EAL assessment. In addition, EAL setpoint values do not use terms such as off-scale low or off-scale high since that type of reading may not be readily differentiated from an instrument failure. If instrumentation failures occur that have EALs associated with them (e.g., process radiation monitors) compensatory means of implementation may be used as described in plant procedures.

4.4 PRESENTATION OF SCHEME INFORMATION TO USERS The US Nuclear Regulatory Commission (NRC) expects licensees to establish and maintain the capability to assess, classify and declare an emergency condition promptly within 15 minutes after the availability of indications to plant operators that an emergency action level has been, or may be, exceeded. The MNGP emergency classification procedure and user aid (EAL Matrix) have been developed to facilitate accurate and timely classification. To this end, the following points have been considered.

The first users of an emergency classification procedure are the operators in the Control Room. During the allowable classification time period, they may have responsibility to perform other critical tasks, and will likely have minimal assistance in making a classification assessment.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 22 of 172 As an emergency situation evolves, members of the Control Room staff are likely to be the first personnel to notice a change in plant conditions.

They can assess the changed conditions and, when warranted, recommend a different emergency classification level to the Technical Support Center (TSC) and/or Emergency Operations Facility (EOF).

Emergency Directors in the TSC and/or EOF will have more opportunity to focus on making an emergency classification, and will probably have advisors from Operations available to help them.

The MNGP emergency classification scheme information for end users is presented in a manner with which licensed operators are most comfortable.

Input from the Operations and Operations Training Departments has been used to assist in the development of readily usable and easily understood classification tools (e.g., a procedure and EAL Matrix).

The MNGP EAL Matrix contains all the information necessary to make a correct emergency classification. MNGP EAL Matrix information includes the ICs, Operating Mode Applicability criteria, EALs and Notes. Notes are adequately captured on the EAL Matrix and pointed to by each applicable EAL. Basis information is not included on the MNGP EAL Matrix but it is readily available to emergency classification decision-makers.

MNGP has developed two matrices - one for use during power operations, startup and hot conditions, and another for cold shutdown and refueling conditions.

4.5 INTEGRATION OF ICS/EALS WITH PLANT PROCEDURES A rigorous integration of IC and EAL references into plant operating procedures is not recommended. This approach would greatly increase the administrative controls and workload for maintaining procedures. On the other hand, performance challenges may occur if recognition of meeting an IC or EAL is based solely on the memory of a licensed operator or an Emergency Director, especially during periods of high stress.

Visual cues (e.g., a step, note, caution, etc.) are included in plant procedures (including emergency operating procedures, abnormal operating procedures, alarm response procedures, and normal operating procedures), as appropriate, alerting the reader/user to consult the site emergency classification procedure.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 23 of 172 4.6 BASIS DOCUMENT A basis document is an integral part of an emergency classification scheme.

The material in this document supports proper emergency classification decision-making by providing informing background and development information in a readily accessible format. It can be referred to in training situations and when making an actual emergency classification, if necessary.

The document is also useful for establishing configuration management controls for EP-related equipment and explaining an emergency classification to offsite authorities. The content of the MNGP basis document includes, at a minimum, the following:

An MNGP Mode Applicability Matrix and description of operating modes (Section 3.5).

A discussion of the emergency classification and declaration process (Section 5.0).

Each Initiating Condition along with the associated EALs or fission product barrier thresholds, Operating Mode Applicability, Notes and Basis information.

A listing of acronyms and defined terms, similar to that presented in Appendices A and B, respectively. This material may be edited as needed to align with site-specific characteristics.

The MNGP Basis section does not contain information that could modify the meaning or intent of the associated IC or EAL. Information in the Basis is used only to clarify and inform decision-making for an emergency classification.

Basis information is readily available to be referenced, if necessary, by the Emergency Director. A copy of the MNGP basis document is maintained in the appropriate emergency response facilities.

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

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 24 of 172 4.7 EAL/THRESHOLD REFERENCES TO MNGP AOP AND EOP SETPOINTS/CRITERIA The criteria/values used in several EALs and fission product barrier thresholds were derived from MNGPs AOPs and EOPs. This approach is intended to maintain good alignment between operational diagnoses and emergency classification assessments. MNGP has verified that appropriate administrative controls are in place to ensure that a subsequent change to an AOP or EOP is screened to determine if an evaluation pursuant to 10 CFR 50.54(q) is required.

GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS 5.1 GENERAL CONSIDERATIONS When making an emergency classification, the Emergency Director 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 Operating Mode Applicability, Notes and the informing Basis information. In the Recognition Category F matrices, EALs are referred to as Fission Product Barrier Thresholds; the thresholds serve the same function as an EAL.

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.

All emergency classification assessments should 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, validation could be accomplished through an instrument channel check, response on related or redundant indicators, or direct observation by plant personnel. The validation of indications should be completed in a manner that supports timely emergency declaration.

For ICs and EALs that have a stipulated time duration (e.g., 15 minutes, 30 minutes, etc.), the Emergency Director 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 5.0

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 25 of 172 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.

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 10 § CFR 50.72.

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.); the EAL and/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).

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 MNGP scheme provides the Emergency Director 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 Emergency Director 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 into the Fission Product Barrier Tables; judgment may be used to determine the status of a fission product barrier.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 26 of 172 5.2 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(s) must be consistent with the related Operating Mode Applicability and Notes. If an EAL has been met or exceeded, then the IC is considered met and the associated ECL is declared in accordance with plant procedures.

When assessing an EAL that specifies a time duration for the off-normal 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.

5.3 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 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 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.

5.4 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.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 27 of 172 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.

5.5 CLASSIFICATION OF IMMINENT CONDITIONS Although EALs provide specific thresholds, the Emergency Director 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 Emergency Director, 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.

5.6 EMERGENCY CLASSIFICATION LEVEL UPGRADING AND DOWNGRADING Once a classification level is declared, no downgrade to a lower classification will be allowed. The MNGP Emergency Plan and classification EPIPs provide the applicable guidance for transition to Termination and/or Recovery.

Guidance concerning classification of rapidly escalating events or conditions is provided in RIS 2007-02.

5.7 CLASSIFICATION OF SHORT-LIVED EVENTS As discussed in Section 3.2, 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/trip the reactor followed by a successful manual scram/trip.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 28 of 172 5.8 CLASSIFICATION OF TRANSIENT CONDITIONS Many of the ICs and/or EALs contained in this document 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 where 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 RCIC fails to automatically start. RPV level rapidly decreases and the plant enters an inadequate RPV Water Level condition (a potential loss of the fuel clad barrier and a loss of the RCS barrier). If an operator manually starts RCIC in accordance with an EOP step and clears the inadequate RPV Water Level 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 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 where an operator is able to take a successful corrective action prior to the Emergency Director completing the review 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.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 29 of 172 5.9 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 is applicable. Specifically, the event should be reported to the NRC in accordance with 10 CFR § 50.72 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.

5.10 RETRACTION OF AN EMERGENCY DECLARATION Guidance on the retraction of an emergency declaration reported to the NRC is discussed in NUREG-1022.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 30 of 172 ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENT ICS/EALS GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT RG1 Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE.

Op. Modes: All RS1 Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE.

Op. Modes: All RA1 Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE.

Op. Modes: All RU1 Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer.

Op. Modes: All RG2 Spent fuel pool level cannot be restored to at least 15.25 for 60 minutes or longer.

Op. Modes: All RS2 Spent fuel pool level at 15.25.

Op. Modes: All RA2 Significant lowering of water level above, or damage to, irradiated fuel.

Op. Modes: All RU2 UNPLANNED loss of water level above irradiated fuel.

Op. Modes: All RA3 Radiation levels that impede access to equipment necessary for normal plant operations, cooldown or shutdown.

Op. Modes: All 6.0

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 31 of 172 RG1 ECL: General Emergency Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE.

Operating Mode Applicability: All Emergency Action Levels: (RG1.1 or RG1.2 or RG1.3)

NOTE:

The Emergency Director should declare the General Emergency promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

NOTE:

If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.

NOTE:

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:

The pre-calculated effluent monitor values presented in EAL RG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

RG1.1 Reading on the following radiation monitor greater than the reading shown for 15 minutes or longer:

Stack Effluent Monitor (Ch A or B) 8 E+07 µCi/sec RG1.2 Dose assessment using actual meteorology indicates doses greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE at or beyond the SITE BOUNDARY.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 32 of 172 RG1.3 Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:

Closed window dose rates greater than 1,000 mR/hr expected to continue for 60 minutes or longer.

Analyses of field survey samples indicate thyroid CDE greater than 5,000 mrem for one hour of inhalation.

Basis:

SITE BOUNDARY: For Dose Assessment and Protective Action Recommendation purposes the SITE BOUNDARY is the closest distance at which members of the public would be exposed to a radioactive release. The SITE BOUNDARY for liquid releases of radioactive material is defined in ODCM-02.01 (LIQUID EFFLUENTS).

The SITE BOUNDARY for gaseous releases of radioactive material is defined in ODCM-03.01 (GASEOUS EFFLUENTS).

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.

MNGP Basis Reference(s):

1.

Monticello Calculation CA 04-199, Methodology Used to Derive Radiation Monitor Readings for NEI 99-01 Rev 6

2.

ODCM-01.01 (OFF-SITE DOSE CALCULATION MANUAL (ODCM)

INTRODUCTION)

3.

ODCM-03.01 (GASEOUS EFFLUENTS), Section 2.7.1, Gaseous Effluents Bases

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 33 of 172

4.

ODCM-03.01 (GASEOUS EFFLUENTS), Figure 1, Monticello Nuclear Generating Plant Site Boundary for Gaseous Effluents

5.

A.2-807 (OFF-SITE DOSE ASSESSMENT AND PROTECTIVE ACTION RECOMMENDATIONS)

6.

Ops Man B.05.11-03 (PROCESS RADIATION MONITORING INSTRUMENTATION AND CONTROLS)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 34 of 172 RG2 ECL: General Emergency Initiating Condition: Spent fuel pool level cannot be restored to at least 15.25 for 60 minutes or longer.

Operating Mode Applicability: All Emergency Action Levels:

NOTE:

The Emergency Director should declare the General Emergency promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded.

RG2.1 Spent fuel pool level cannot be restored to at least 15.25 for 60 minutes or longer.

Basis:

This IC 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 would likely not be met until well after another General Emergency IC was met; however, it is included to provide classification diversity.

MNGP Basis Reference(s):

1.

Ops Man B.02.01-03 (FUEL POOL COOLING - INSTRUMENTATION AND CONTROLS)

2.

Ops Man B.02.01-05 (FUEL POOL COOLING SYSTEM OPERATION)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 35 of 172 RS1 ECL: Site Area Emergency Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE.

Operating Mode Applicability: All Emergency Action Levels: (RS1.1 or RS1.2 or RS1.3)

NOTE:

The Emergency Director should declare the Site Area Emergency promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

NOTE:

If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.

NOTE:

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:

The pre-calculated effluent monitor values presented in EAL RS1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

RS1.1 Reading on the following radiation monitor greater than the reading shown for 15 minutes or longer:

Stack Effluent Monitor (Ch A or B) 8 E+06 µCi/sec RS1.2 Dose assessment using actual meteorology indicates doses greater than 100 mrem TEDE or 500 mrem thyroid CDE at or beyond the SITE BOUNDARY.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 36 of 172 RS1.3 Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:

Closed window dose rates greater than 100 mR/hr expected to continue for 60 minutes or longer.

Analyses of field survey samples indicate thyroid CDE greater than 500 mrem for one hour of inhalation.

Basis:

SITE BOUNDARY: For Dose Assessment and Protective Action Recommendation purposes the SITE BOUNDARY is the closest distance at which members of the public would be exposed to a radioactive release. The SITE BOUNDARY for liquid releases of radioactive material is defined in ODCM-02.01 (LIQUID EFFLUENTS).

The SITE BOUNDARY for gaseous releases of radioactive material is defined in ODCM-03.01 (GASEOUS EFFLUENTS).

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 RG1.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 37 of 172 MNGP Basis Reference(s):

1.

Monticello Calculation CA 04-199, Methodology Used to Derive Radiation Monitor Readings for NEI 99-01 Rev 6

2.

ODCM-01.01 (OFF-SITE DOSE CALCULATION MANUAL (ODCM)

INTRODUCTION)

3.

ODCM-03.01 (GASEOUS EFFLUENTS), Section 2.7.1, Gaseous Effluents Bases

4.

ODCM-03.01 (GASEOUS EFFLUENTS), Figure 1, Monticello Nuclear Generating Plant Site Boundary for Gaseous Effluents

5.

A.2-807 (OFF-SITE DOSE ASSESSMENT AND PROTECTIVE ACTION RECOMMENDATIONS)

6.

Ops Man B.05.11-03 (PROCESS RADIATION MONITORING INSTRUMENTATION AND CONTROLS)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 38 of 172 RS2 ECL: Site Area Emergency Initiating Condition: Spent fuel pool level at 15.25.

Operating Mode Applicability: All Emergency Action Levels:

RS2.1 Lowering of spent fuel pool level to 15.25.

Basis:

This IC 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 RG1 or RG2.

MNGP Basis Reference(s):

1.

Ops Man B.02.01-03 (FUEL POOL COOLING - INSTRUMENTATION AND CONTROLS)

2.

Ops Man B.02.01-05 (FUEL POOL COOLING SYSTEM OPERATIONS)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 39 of 172 RA1 ECL: Alert Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE.

Operating Mode Applicability: All Emergency Action Levels: (RA1.1 or RA1.2 or RA1.3 or RA1.4)

NOTE:

The Emergency Director should declare the Alert promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

NOTE:

If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.

NOTE:

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:

The pre-calculated effluent monitor values presented in EAL RA1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

RA1.1 Reading on ANY of the following radiation monitors greater than the reading shown for 15 minutes or longer:

Gaseous Effluent Monitors Stack Effluent Monitor (Ch A or B) 8 E+05 µCi/sec A RBV Total Rel 6 E+05 µCi/sec B RBV EFF 6 E+05 µCi/sec Liquid Effluent Monitors Discharge Canal 2000 cps Service Water 700 cps TBNWS 9 E+04 cpm

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 40 of 172 RA1.2 Dose assessment using actual meteorology indicates doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the SITE BOUNDARY.

RA1.3 Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the SITE BOUNDARY for one hour of exposure.

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

Closed window dose rates greater than 10 mR/hr expected to continue for 60 minutes or longer.

Analyses of field survey samples indicate thyroid CDE greater than 50 mrem for one hour of inhalation.

Basis:

SITE BOUNDARY: For Dose Assessment and Protective Action Recommendation purposes the SITE BOUNDARY is the closest distance at which members of the public would be exposed to a radioactive release. The SITE BOUNDARY for liquid releases of radioactive material is defined in ODCM-02.01 (LIQUID EFFLUENTS).

The SITE BOUNDARY for gaseous releases of radioactive material is defined in ODCM-03.01 (GASEOUS EFFLUENTS).

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.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 41 of 172 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 RS1.

MNGP Basis Reference(s):

1.

Monticello Calculation CA 04-199, Methodology Used to Derive Radiation Monitor Readings for NEI 99-01 Rev 6

2.

ODCM-01.01 (OFF-SITE DOSE CALCULATION MANUAL (ODCM)

INTRODUCTION)

3.

ODCM-02.01 (LIQUID EFFLUENTS), Figure 1, Monticello Nuclear Generating Plant Site Boundary for Liquid Effluents

4.

ODCM-03.01 (GASEOUS EFFLUENTS), Section 2.7.1, Gaseous Effluents Bases

5.

ODCM-03.01 (GASEOUS EFFLUENTS), Figure 1, Monticello Nuclear Generating Plant Site Boundary for Gaseous Effluents

6.

A.2-807 (OFF-SITE DOSE ASSESSMENT AND PROTECTIVE ACTION RECOMMENDATIONS)

7.

Ops Man B.05.11-03 (PROCESS RADIATION MONITORING INSTRUMENTATION AND CONTROLS)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 42 of 172 RA2 ECL: Alert Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuel.

Operating Mode Applicability: All Emergency Action Levels: (RA2.1 or RA2.2 or RA2.3)

RA2.1 Uncovery of irradiated fuel in the REFUELING PATHWAY.

RA2.2 Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by ANY of the following radiation monitors:

Monitor Alarm/Trip A-1 1027 RB NE Low 20 mR/hr A-2 1027 RB N High 200 mR/hr A-3 1027 RB W Stairway 100 mR/hr RM-17-452A Reactor Building Ventilation Exhaust Plenum Monitor Ch A 26 mR/hr RM-17-452B Reactor Building Ventilation Exhaust Plenum Monitor Ch B 26 mR/hr RM-17-453A Fuel Pool Radiation Monitor Ch A 50 mR/hr RM-17-453B Fuel Pool Radiation Monitor Ch B 50 mR/hr RA2.3 Lowering of spent fuel pool level to 24.75.

Basis:

REFUELING PATHWAY: The reactor refueling cavity, spent fuel pool, or fuel transfer canal.

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 pool. 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.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 43 of 172 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 EU1.

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

EAL RA2.1 This EAL escalates from RU2 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.

EAL RA2.2 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 RA2.3 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 RS1 or RS2

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 44 of 172 MNGP Basis Reference(s):

1.

Ops Man B.05.12 (AREA RADIATION MONITORING SYSTEM)

2.

Ops Man B.05.11 (PROCESS RADIATION MONITORING SYSTEM)

3.

USAR Section 7.5.2, Plant Instrumentation and Control Systems - Process Radiation Monitoring System

4.

USAR Section 7.5.3, Plant Instrumentation and Control Systems - Area Radiation Monitoring System

5.

C.6-004-A-01 (REFUELING FLOOR AREA HI RADIATION)

6.

C.6-005-A-01 (REAC BLDG VENT & F P RAD CH A-HI/LO)

7.

C.6-005-A-02 (REAC BLDG VENT & F P RAD CH B-HI/LO)

8.

Ops Man B.02.01-03 (FUEL POOL COOLING - INSTRUMENTATION AND CONTROLS)

9.

Ops Man B.02.01-05 (FUEL POOL COOLING SYSTEM OPERATIONS)

10. 1024 (AREA RADIATION MONITOR CALIBRATION)

11. NX-9321-86, Spent Fuel Pool

12. CAP 1543790, No Technical Basis for Area Monitor Alarm Setpoints

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 45 of 172 RA3 ECL: Alert Initiating Condition: Radiation levels that impede access to equipment necessary for normal plant operations, cooldown or shutdown.

Operating Mode Applicability: All Emergency Action Levels: (RA3.1 or RA3.2)

NOTE:

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.

RA3.1 Dose rate greater than 15 mR/hr in ANY of the following areas:

Control Room (A-20 Control Room Low Range)

Central Alarm Station (by survey)

Secondary Alarm Station (by survey)

RA3.2 An UNPLANNED event results in radiation levels that prohibit or impede access to any of the Table H1 plant rooms or areas:

Table H1 Room Applicable Mode(s)

BOTH RHR Rooms (Reactor Building 896 SW and SE) 3 / 4 MCC-133 Room (Turbine Building 911 East)

MVP Room (Turbine Building 908 West) 2 / 3

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 46 of 172 Basis:

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.

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 should consider the cause of the increased radiation levels and determine if another IC may be applicable.

For EAL 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.

RA3.2 mode of applicability has been limited to the applicable modes identified in Table H1. If plant operating procedures or plant configuration changes result in changes to areas requiring access or modes at which access is required, a corresponding change to Table H1 areas will be required as originally evaluated under AR603000000450, MNGP Area Evaluation for use in EALs.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 47 of 172 Escalation of the emergency classification level would be via Recognition Category R, C or F ICs.

MNGP Basis Reference(s):

1.

GDC 19, Control Room

2.

NUREG-0737, Clarification of TMI Action Plan Requirements,Section III.D.3

3.

Ops Man B.05.12 (AREA RADIATION MONITORING SYSTEM)

4.

Ops Man C.1 (STARTUP PROCEDURE)

5.

Ops Man C.3 (SHUTDOWN PROCEDURE)

6.

C.5.1-1001 (EOP TECHNICAL BASES (MODES 1, 2, 3))

7.

C.5.1-1002 (EOP TECHNICAL BASES (MODE 4))

8.

C.5.1-1003 (EOP TECHNICAL BASES (MODE 5))

9.

USAR Section 10.3.1.5.1, Plant Auxiliary Systems - Safe Shutdown Analysis, General

10. USAR Section 12.2, Plant Structures and Shielding - Plant Principal Structures and Foundations

11. ND-95208, Monticello Property Map

12. ND-95209, Monticello Main Plant Structures

13. 4 AWI-08.04.01 (RADIATION PROTECTION PLAN)

14. A.2-401 (EMERGENCY EXPOSURE CONTROL)

15. AR60300000450, MNGP Area Evaluation use in EALs

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 48 of 172 RU1 ECL: Notification of Unusual Event Initiating Condition: Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer.

Operating Mode Applicability: All Emergency Action Levels: (RU1.1 or RU1.2 or RU1.3)

NOTE:

The Emergency Director should declare the Unusual Event promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded.

NOTE:

If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes.

NOTE:

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.

RU1.1 Reading on ANY of the following effluent radiation monitors greater than the listed values for 60 minutes or longer:

Gaseous Effluent Monitors Stack Effluent Monitor (Ch A or B) 4 E+05 µCi/sec A RBV Total Rel 3 E+04 µCi/sec B RBV EFF 3 E+04 µCi/sec Liquid Effluent Monitors Discharge Canal 900 cps Service Water 300 cps TBNWS 4 E+04 cpm RU1.2 Reading on ANY effluent radiation monitor greater than 2 times the alarm setpoint established by a current radioactivity discharge permit for 60 minutes or longer.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 49 of 172 RU1.3 Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times the ODCM limits for 60 minutes or longer.

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 RU1.1 - This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous or liquid effluent pathways.

EAL RU1.2 - 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 RU1.3 - 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 RA1.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 50 of 172 MNGP Basis Reference(s):

1.

Monticello Calculation 04-199, Methodology Used to Derive Radiation Monitor Readings for NEI 99-01 Rev 6

2.

ODCM-01.01 (OFF-SITE DOSE CALCULATION MANUAL (ODCM)

INTRODUCTION)

3.

ODCM-02.01 (LIQUID EFFLUENTS)

4.

ODCM-03.01 (GASEOUS EFFLUENTS)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 51 of 172 RU2 ECL: Notification of Unusual Event Initiating Condition: UNPLANNED loss of water level above irradiated fuel.

Operating Mode Applicability: All Emergency Action Levels:

RU2.1

a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated by ANY of the following:

Spent Fuel Pool low water level alarm Visual observation of an uncontrolled water level drop below a fuel pool skimmer surge tank inlet Observation of water leakage into the drywell or the reactor building from piping penetrations surrounding the drywell.

AND

b. UNPLANNED rise in area radiation levels as indicated by ANY of the following radiation monitors.

A-1 1027 RB NE Low A-2 1027 RB N High A-3 1027 RB W Stairway RM-17-453A or B Fuel Pool Monitoring System Basis:

REFUELING PATHWAY: The reactor refueling cavity, spent fuel pool, or fuel transfer canal.

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.

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

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 52 of 172 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.

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 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 RA2.

MNGP Basis Reference(s):

1.

Ops Man B.02.01-01 (FUEL POOL COOLING - FUNCTION & GENERAL DESCRIPTION OF SYSTEM)

2.

Ops Man B.05.12 (AREA RADIATION MONITORING SYSTEM)

3.

Procedure 0000-J, Operations Daily Log

4.

Ops Man C.6-004-B-33 (FUEL POOL COOLING SYSTEM TROUBLE)

5.

Ops Man C.6-065-A-06 (REFUELING HIGH LEAKAGE)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 53 of 172 COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTION ICS/EALS GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT CG1 Loss of RPV inventory affecting fuel clad integrity with containment challenged.

Op. Modes: Cold Shutdown, Refueling CS1 Loss of RPV inventory affecting core decay heat removal capability.

Op. Modes: Cold Shutdown, Refueling CA1 Loss of RPV inventory.

Op. Modes: Cold Shutdown, Refueling CU1 UNPLANNED loss of RPV inventory for 15 minutes or longer.

Op. Modes: Cold Shutdown, Refueling CA2 Loss of all offsite and all onsite AC power to essential buses for 15 minutes or longer.

Op. Modes: Cold Shutdown, Refueling, Defueled CU2 Loss of all but one AC power source to essential buses for 15 minutes or longer.

Op. Modes: Cold Shutdown, Refueling, Defueled CA3 Inability to maintain the plant in cold shutdown.

Op. Modes: Cold Shutdown, Refueling CU3 UNPLANNED rise in RCS temperature.

Op. Modes: Cold Shutdown, Refueling CU4 Loss of Vital DC power for 15 minutes or longer.

Op. Modes: Cold Shutdown, Refueling CU5 Loss of all onsite or offsite communications capabilities.

Op. Modes: Cold Shutdown, Refueling, Defueled CA6 Hazardous event affecting a SAFETY SYSTEM needed for the current operating mode.

Op. Modes: Cold Shutdown, Refueling 7.0

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 54 of 172 CG1 ECL: General Emergency Initiating Condition: Loss of RPV inventory affecting fuel clad integrity with containment challenged.

Operating Mode Applicability: Cold Shutdown, Refueling Emergency Action Levels: (CG1.1 or CG1.2)

NOTE:

The Emergency Director should declare the General Emergency promptly upon determining that 30 minutes has been exceeded, or will likely be exceeded.

CG1.1

a. RPV level less than -126 in. (TAF) for 30 minutes or longer.

AND

b. ANY indication from the Containment Challenge Table C1.

CG1.2

a. RPV level cannot be monitored for 30 minutes or longer.

AND

b. Core uncovery is indicated by EITHER of the following:

Refueling Floor radiation monitor reading greater than 3 R/hr UNPLANNED rise in drywell floor or equipment drain sump levels of sufficient magnitude to indicate core uncovery AND

c. ANY indication from the Containment Challenge Table C1 Containment Challenge Table C1 SECONDARY CONTAINMENT not established*

Greater than or equal to 6% hydrogen and greater than or equal to 5% oxygen in primary containment UNPLANNED rise in containment pressure resulting in Drywell pressure greater than 1.84 psig Two or more Reactor Building areas exceed Max Safe Radiation Levels (C.5-CSD-2 Table R (Mode 4) or C.5-RF Table R (Mode 5))

• If SECONDARY CONTAINMENT is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 55 of 172 Basis:

SECONDARY CONTAINMENT: SECONDARY CONTAINMENT includes the Reactor Building (including the HPCI Building), the Standby Gas Treatment System, the Offgas Dilution Fans, and connecting pipes and ducts. SECONDARY CONTAINMENT is isolated along with an automatic initiation of the Standby Gas Treatment System to minimize radiological releases to the environment.

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.

This IC addresses the inability to restore and maintain reactor vessel 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.

With SECONDARY CONTAINMENT not established, there is a high potential for a direct and unmonitored release of radioactivity to the environment. If SECONDARY CONTAINMENT is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.

The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at 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 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. 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.

In EAL CG1.2.b, 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

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 56 of 172 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 RPV 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 RPV.

These EALs address 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.

MNGP Basis Reference(s):

1.

Ops Man C.1 (STARTUP PROCEDURE)

2.

Ops Man C.4-B-04.01.F (LEAK INSIDE PRIMARY CONTAINMENT)

3.

Ops Man C.6-004-B-13 (DRYWELL EQUIP DRAIN LEAK RATE HI)

4.

Ops Man C.6-004-B-17 (DRYWELL FLOOR DRAIN SUMP HI)

5.

Ops Man C.6-004-B-18 (DRYWELL EQUIP DRAIN LEAK RATE CHANGE HI)

6.

Ops Man C.6-065-A-06 (REFUELING: HIGH LEAKAGE)

7.

C.5.1-1002 (EOP TECHNICAL BASES (MODE 4))

8.

C.5.1-1003 (EOP TECHNICAL BASES (MODE 5))

9.

USAR Section 5.2, Containment System - Primary Containment System

10. USAR Section 7.9-1, Plant Instrumentation and Control Systems - Accident Monitoring Instrumentation

11. MNGP Calculation CA-04-202, Dose Rates to CHRRM Detectors Due to Drop in RPV Water Level

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 57 of 172 CS1 ECL: Site Area Emergency Initiating Condition: Loss of RPV inventory affecting core decay heat removal capability.

Operating Mode Applicability: Cold Shutdown, Refueling Emergency Action Levels: (CS1.1 or CS1.2 or CS1.3)

NOTE:

The Emergency Director should declare the Site Area Emergency promptly upon determining that 30 minutes has been exceeded, or will likely be exceeded.

CS1.1

a. SECONDARY CONTAINMENT not established.

AND

b. RPV level less than -47 in.

CS1.2

a. SECONDARY CONTAINMENT established.

AND

b. RPV level less than -126 in. (TAF).

CS1.3

a. RPV level cannot be monitored for 30 minutes or longer.

AND

b. Core uncovery is indicated by EITHER of the following:

Refueling Floor radiation monitor reading greater than 3 R/hr UNPLANNED rise in drywell floor or equipment drain sump levels of sufficient magnitude to indicate core uncovery Basis:

SECONDARY CONTAINMENT: SECONDARY CONTAINMENT includes the Reactor Building (including the HPCI Building), the Standby Gas Treatment System, the Offgas Dilution Fans, and connecting pipes and ducts. SECONDARY CONTAINMENT is isolated along with an automatic initiation of the Standby Gas Treatment System to minimize radiological releases to the environment.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 58 of 172 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.

This IC addresses a significant and prolonged loss of RPV 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 SECONDARY CONTAINMENT following a loss of heat removal or RCS inventory control functions. The difference in the specified RCS/reactor vessel levels of EALs CS1.1.b and CS1.2.b reflect the fact that with SECONDARY CONTAINMENT established, there is a lower probability of a fission product release to the environment.

In EAL CS1.3.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 RPV 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 RPV.

These EALs address 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 IC CG1 or RG1.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 59 of 172 MNGP Basis Reference(s):

1.

Ops Man B.01.01-03 (REACTOR AND VESSEL ASSEMBLY)

2.

Ops Man B.05.06 (PLANT PROTECTION SYSTEM)

3.

Ops Man C.1 (STARTUP PROCEDURE)

4.

Ops Man C.4-B.04.01.F (LEAK INSIDE PRIMARY CONTAINMENT)

5.

Ops Man C.6-003-A-38 (REACTOR LOW LOW LEVEL)

6.

Ops Man C.6-004-B-13 (DRYWELL EQUIP DRAIN LEVEL RATE HI)

7.

Ops Man C.6-004-B-17 (DRYWELL FLOOR DRAIN SUMP HI LEVEL)

8.

Ops Man C.6-004-B-18 (DRYWELL EQUIP DRAIN LEAK RATE CHANGE HI)

9.

Tech Spec Table 3.3.5.1-1 (EMERGENCY CORE COOLING INSTRUMENTATION)

10. Tech Spec 3.4.4 (RCS OPERATIONAL LEAKAGE)

11. NX-7831-197-1, Reactor Vessel and Internals

12. MNGP Calculation CA-95-074, Low Low Reactor Water Level Group 1 and 3 Containment Isolation Setpoint Calculation

13. MNGP Calculation CA-04-202, Dose Rates to CHRRM Detectors Due to Drop in RPV Water Level

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 60 of 172 CA1 ECL: Alert Initiating Condition: Loss of RPV inventory.

Operating Mode Applicability: Cold Shutdown, Refueling Emergency Action Levels: (CA1.1 or CA1.2)

NOTE:

The Emergency Director should declare the Alert promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.

CA1.1 Loss of RPV inventory as indicated by level less than -47 in.

CA1.2

a. RPV level cannot be monitored for 15 minutes or longer AND

b. UNPLANNED rise in drywell floor or equipment drain sump levels due to a loss of RPV inventory.

Basis:

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.

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 CA1.1, a lowering of water level below -47 in. (Low-Low ECCS actuation setpoint) indicates that operator actions have not been successful in restoring and maintaining RPV 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 CA1.1 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.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 61 of 172 For EAL CA1.2, the inability to monitor RPV 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 RPV.

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 RPV inventory level continues to lower, then escalation to Site Area Emergency would be via IC CS1.

MNGP Basis Reference(s):

1.

Ops Man B.01.01-03 (REACTOR AND VESSEL ASSEMBLY -

INSTRUMENTATION AND CONTROLS)

2.

Ops Man B.05.06 (PLANT PROTECTION SYSTEM)

3.

Ops Man C.4-B.04.01.F (LEAK INSIDE PRIMARY CONTAINMENT)

4.

Ops Man C.6-003-A-38 (REACTOR LOW LOW LEVEL)

5.

Ops Man C.6-004-B-13 (DRYWELL EQUIP DRAIN LEAK RATE HI)

6.

Ops Man C.6-004-B-17 (DRYWELL FLOOR DRAIN SUMP HI)

7.

Ops Man C.6-004-B-18 (DRYWELL EQUIP DRAIN LEAK RATE CHANGE HI)

8.

9040 (TEMPORARY VESSEL LEVEL INSTRUMENTATION INSTALLATION AND RESTORATION)

9.

Tech Spec Table 3.3.5.1-1 (EMERGENCY CORE COOLING SYSTEM INSTRUMENTATION)

10. Ops Man C.6-065-A-06 (REFUELING HIGH LEAKAGE)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 62 of 172 CA2 ECL: Alert Initiating Condition: Loss of all offsite and all onsite AC power to essential buses for 15 minutes or longer.

Operating Mode Applicability: Cold Shutdown, Refueling, Defueled Emergency Action Levels:

NOTE:

The Emergency Director should declare the Alert promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.

CA2.1 Loss of ALL offsite and ALL onsite AC Power to essential buses 15 and 16 for 15 minutes or longer.

Basis:

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.

This EAL is indicated by the loss of all offsite and onsite AC power to the 4160V essential buses. Onsite sources include 11 and 12 Emergency Diesel Generators.

Offsite resources include 2R, 1R, and 1AR Transformers. If power is available from these sources, but is not supplied to the 4160V buses for whatever reason, the condition is still considered a loss of power.

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 essential 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.

Escalation of the emergency classification level would be via IC CS1 or RS1.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 63 of 172 MNGP Basis Reference(s):

1.

USAR Section 8.2, Plant Electrical Systems - Transmission System

2.

USAR Section 8.3, Plant Electrical Systems - Auxiliary Power System

3.

USAR Section 8.4, Plant Electrical Systems - Plant Standby Diesel Generator System

4.

USAR Figure 8.4-1, Diesel Generation System One Line Diagram

5.

NF-36175, Single Line Diagram - Station Connection

6.

Ops Man B.09.06-01 (4.16 KV STATION AUXILIARY - FUNCTION AND GENERAL DESCRIPTION OF SYSTEM)

7.

Ops Man C.4-B.09.02.A (STATION BLACKOUT)

8.

Ops Man C.4-B.09.02.B (LOSS OF NORMAL OFF-SITE POWER)

9.

Ops Man C.4-B.09.06.C (LOSS OF BUS 15 OR BUS 16)

10. Tech Spec 3.8.2 (AC SOURCES - SHUTDOWN)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 64 of 172 CA3 ECL: Alert Initiating Condition: Inability to maintain the plant in cold shutdown.

Operating Mode Applicability: Cold Shutdown, Refueling Emergency Action Levels: (CA3.1 or CA3.2)

NOTE:

The Emergency Director should declare the Alert promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

CA3.1 UNPLANNED rise in RCS temperature to greater than 212 °F for greater than the duration specified in Table C2.

Table C2: RCS Heat-up Duration Thresholds RCS SECONDARY CONTAINMENT Heat-up Duration Not intact Not Established 0 minutes Established 20 minutes*

Intact N/A 60 minutes*

• If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, the EAL is not applicable.

CA3.2 UNPLANNED RCS pressure rise greater than 10 psig.

Basis:

SECONDARY CONTAINMENT: SECONDARY CONTAINMENT includes the Reactor Building (including the HPCI Building), the Standby Gas Treatment System, the Offgas Dilution Fans, and connecting pipes and ducts. SECONDARY CONTAINMENT is isolated along with an automatic initiation of the Standby Gas Treatment System to minimize radiological releases to the environment.

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.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 65 of 172 This IC 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 SECONDARY CONTAINMENT is established but the RCS is not intact. 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 SECONDARY CONTAINMENT 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 and SECONDARY CONTAINMENT 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.

EAL CA3.2 provides a pressure-based indication of RCS heat-up.

Escalation of the emergency classification level would be via IC CS1 or RS1.

MNGP Basis Reference(s):

1.

Ops Man B.01.01-03 (REACTOR AND VESSEL ASSEMBLY -

INSTRUMENTATION AND CONTROLS)

2.

Ops Man C.3 (SHUTDOWN PROCEDURE)

3.

MNGP Emergency Plan Table 13, Instruments Available For Monitoring Major Systems

4.

USAR Section 7.4, Plant Instrumentation and Control Systems - Reactor Vessel Instrumentation

5.

Tech Spec Table 1.1-1 (MODES)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 66 of 172

6.

Tech Spec 3.6.4.1 (SECONDARY CONTAINMENT)

7.

Tech Spec 3.6.4.2 (SECONDARY CONTAINMENT ISOLATION VALVES (SCIVs))

8.

Tech Spec 3.6.4.3 (STANDBY GAS TREATMENT (SGT) SYSTEM)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 67 of 172 CA6 ECL: Alert Initiating Condition: Hazardous event affecting a SAFETY SYSTEM needed for the current operating mode.

Operating Mode Applicability: Cold Shutdown, Refueling NOTE:

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

NOTE:

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.

Emergency Action Levels:

CA6.1

a. The occurrence of ANY of the following hazardous events:

Seismic event (Earthquake)

Internal or external flooding event High winds or tornado strike FIRE EXPLOSION River level greater than 919 ft el.

River level less than 900.5 ft el.

Other events with similar hazard characteristics as determined by the Shift Manager AND

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 68 of 172

b. 1. Event damage has caused indications of degraded performance on one train of a SAFETY SYSTEM needed for the current operating mode.

AND

2. EITHER of the following:

Event damage has caused indications of degraded performance to a 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.

Basis:

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

Such events may require a post-event inspection to determine if the attributes of an explosion are present.

FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES.

Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.

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.

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.

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

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 69 of 172 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 for criteria CA6.1.b.1 of this EAL; 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.

Operators will make a determination of VISIBLE DAMAGE 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 SAFETY SYSTEMS or SAFETY SYSTEM trains (i.e., there are indications of degraded performance and/or VISIBLE DAMAGE affecting the common equipment) should be classified as an Alert under CA6 or SA9, as appropriate to the plant mode. By affecting the operability or reliability of multiple system trains, the loss of the common equipment effectively meets the two-train impact criteria that underlie the EALs and Basis.

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 CA6 or SA9 because the two-train impact criteria that underlie the EALs and Basis 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/Emergency Director 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 CA6 or SA9, as appropriate to the plant mode. This approach maintains consistency with the two-train impact criteria that underlie the EALs and Basis, and is warranted because the event was severe enough to affect the operability or reliability 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.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 70 of 172 Escalation of the emergency classification level would be via IC CS1 or RS1.

MNGP Basis Reference(s):

1.

Ops Man A.6 (ACTS OF NATURE)

2.

Ops Man B.05.14 (SEISMIC MONITORING SYSTEM)

3.

Ops Man B.05.16-01 (METEOROLOGICAL MONITORING - FUNCTION &

GENERAL DESCRIPTION OF SYSTEM)

4.

Ops Man B.06.04 (CIRCULATING WATER SYSTEM)

5.

C.4-B.05.14.A (EARTHQUAKE)

6.

C.6-006-C-08 (EARTHQUAKE)

7.

C.6-006-C-13 (OPERATIONAL BASIS EARTHQUAKE)

8.

USAR Section 10.3, Plant Auxiliary Systems - Plant Service Systems

9.

USAR Section 12.2, Plant Principal Structures and Foundations

10. USAR Appendix G, Chapter 3, Probable Maximum Flood Determination

11. USAR Table I.5-1, Location of High Energy Systems and Safe Shutdown Equipment by Volume

12. USAR Appendix J.4, Fire Protection Program - Safe Shutdown Analysis

13. ND-95208, Monticello Property Map

14. ND-95209, Monticello Main Plant Structures

15. 4 AWI-01.03.01 (QUALITY ASSURANCE PROGRAM BOUNDARY)

16. EC 25005, External Flooding Emergency Action Level Basis

17. NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 6 and EPFAQ 2018-004.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 71 of 172 CU1 ECL: Notification of Unusual Event Initiating Condition: UNPLANNED loss of RPV inventory for 15 minutes or longer.

Operating Mode Applicability: Cold Shutdown, Refueling Emergency Action Levels: (CU1.1 or CU1.2)

NOTE:

The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.

CU1.1 UNPLANNED loss of reactor coolant results in RPV level less than a procedurally required lower limit for 15 minutes or longer.

CU1.2

a. RPV level cannot be monitored.

AND

b. UNPLANNED rise in drywell floor or equipment drain sump levels.

Basis:

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.

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 RPV 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.

EAL CU1.1 recognizes that the minimum required RPV 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

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 72 of 172 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 CU1.2 addresses a condition where all means to determine RPV 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 RPV.

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

MNGP Basis Reference(s):

1.

Ops Man B.01.01-06 (REACTOR AND VESSEL ASSEMBLY - FIGURES)

2.

Ops Man C.3 (SHUTDOWN PROCEDURE)

3.

9001 (REACTOR WELL AND DRYER-SEPARATOR STORAGE POOL FILLING PROCEDURE)

4.

9006 (REACTOR WELL AND DRYER-SEPARATOR STORAGE POOL DRAINING PROCEDURE)

5.

9040 (TEMPORARY VESSEL LEVEL INSTRUMENTATION INSTALLATION AND RESTORATION)

6.

C.5.1-1002 (EOP TECHNICAL BASES (MODES 4))

7.

C.5.1-1003 (EOP TECHNICAL BASES (MODES 5))

8.

Ops Man C.4-B.04.01.F (LEAK INSIDE PRIMARY CONTAINMENT)

9.

Ops Man C.6-003-A-38 (REACTOR LOW LEVEL)

10. Ops Man C.6-004-B-13 (DRYWELL EQUIP DRAIN LEAK RATE HI)

11. Ops Man C.6-004-B-17 (DRYWELL FLOOR DRAIN SUMP HI LEVEL)

12. Ops Man C.6-004-B-18 (DRYWELL EQUIP DRAIN LEAK RATE CHANGE HI)

13. Ops Man C.6-065-A-06 (REFUELING HIGH LEAKAGE)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 73 of 172

14. Technical Specification 3.9 (REFUELING OPERATIONS)

15. MNGP Calculation CA-95-074, Low Low Reactor Water Level Group 1 and 3 Containment Isolation Setpoint Calculation

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 74 of 172 CU2 ECL: Notification of Unusual Event Initiating Condition: Loss of all but one AC power source to essential buses for 15 minutes or longer.

Operating Mode Applicability: Cold Shutdown, Refueling, Defueled Emergency Action Levels:

NOTE:

The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.

CU2.1

a. AC power capability to essential buses 15 and 16 is reduced to a single power source (Table S1) for 15 minutes or longer.

AND

b. Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS.

Table S1 1R Reserve Transformer 1AR Reserve Transformer 2R Auxiliary Transformer

1. 11 Emergency Diesel Generator

1. 12 Emergency Diesel Generator Basis:

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.

This IC describes a significant degradation of offsite and onsite AC power sources (Table S1) 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.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 75 of 172 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 essential 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 emergency power sources (e.g., onsite diesel generators) with a single train of essential buses being 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.

MNGP Basis Reference(s):

1.

USAR Section 8.2, Plant Electrical Systems - Transmission System

2.

USAR Section 8.3, Plant Electrical Systems - Auxiliary Power Systems

3.

USAR Section 8.4, Plant Electrical Systems - Plant Standby Diesel Generator System

4.

USAR Figure 8.4-1, Diesel Generation System One Line Diagram

5.

NF-36175, Single Line Diagram - Station Connection

6.

Ops Man B.09.06-01 (4.16 KV STATION AUXILIARY - FUNCTION AND GENERAL DESCRIPTION OF SYSTEM)

7.

Ops Man C.4-B.09.02.A (STATION BLACKOUT)

8.

Ops Man C.4-B.09.02.B (LOSS OF NORMAL OFF-SITE POWER)

9.

Ops Man C.4-B.09.06.C (LOSS OF BUS 15 OR BUS 16)

10. Tech Spec 3.8.2 (AC SOURCES - SHUTDOWN)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 76 of 172 CU3 ECL: Notification of Unusual Event Initiating Condition: UNPLANNED rise in RCS temperature.

Operating Mode Applicability: Cold Shutdown, Refueling Emergency Action Levels: (CU3.1 or CU3.2)

NOTE:

The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.

CU3.1 UNPLANNED rise in RCS temperature to greater than 212 °F.

CU3.2 Loss of ALL RCS temperature and RPV level indication for 15 minutes or longer.

Basis:

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.

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

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 CU3.1 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

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 77 of 172 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 CU3.2 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.

MNGP Basis Reference(s):

1.

C.5.1-1002 (EOP TECHNICAL BASES (MODES 4))

2.

C.5.1-1003 (EOP TECHNICAL BASES (MODES 5))

3.

Ops Man B.01.01-03 (REACTOR AND VESSEL ASSEMBLY -

INSTRUMENTATION AND CONTROLS)

4.

Ops Man C.3 (SHUTDOWN PROCEDURE)

5.

9040 (TEMPORARY VESSEL LEVEL INSTRUMENTATION INSTALLATION AND RESTORATION)

6.

Tech Spec Table 1.1-1 (MODES)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 78 of 172 CU4 ECL: Notification of Unusual Event Initiating Condition: Loss of Vital DC power for 15 minutes or longer.

Operating Mode Applicability: Cold Shutdown, Refueling Emergency Action Levels:

NOTE:

The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.

CU4.1 Indicated voltage is less than 110 VDC on required 125 VDC Vital DC buses for 15 minutes or longer.

Basis:

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.

The indicated voltage used in this threshold is based on battery sizing calculations.

The threshold is an average for both Division I and II batteries for battery voltages at 15 minutes prior to reaching the minimum required terminal voltage.

The Division I and II - 250 VDC battery systems need not be considered in this EAL because they supply power to large motor loads in the RCIC and HPCI systems and various non-critical loads. RCIC is an alternative source of make-up water for the reactor during normal plant shutdowns and transient events which lead to a loss of feedwater flow. HPCI is part of the Emergency Core Cooling System (ECCS) network. However, the Auto Depressurization System (ADS) is redundant in function to the HPCI system and does not require 250 VDC for operations. Therefore, these

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 79 of 172 systems need not be included in this EAL since loss of the 250 VDC battery systems would not cause core uncovering or loss of containment integrity.

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 R.

MNGP Basis Reference(s):

1.

USAR Section 8.5.1, Plant Electrical Systems - DC Power Supply Systems, Essential 250 Vdc System

2.

USAR Section 8.5.2, Plant Electrical Systems - DC Power Supply Systems, 125 Vdc System

3.

NE-36640-2, 125VDC Distribution Electrical Scheme

4.

MNGP Calculation CA-02-179, 125 Volt Div. I Calculation

5.

MNGP Calculation CA-02-192, 125 Volt Div. II Calculation

6.

Technical Specification 3.8.5 (DC SOURCES - SHUTDOWN)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 80 of 172 CU5 ECL: Notification of Unusual Event Initiating Condition: Loss of all onsite or offsite communications capabilities.

Operating Mode Applicability: Cold Shutdown, Refueling, Defueled Emergency Action Levels: (CU5.1 or CU5.2 or CU5.3)

CU5.1 Loss of ALL of the following onsite communication methods:

Commercial Telephones Plant Telephones Portable radios Plant PA System CU5.2 Loss of ALL of the following Offsite Response Organization (ORO) communications methods:

Commercial Telephones Direct Dedicated Telephones Radio/Receiver Transmitter CU5.3 Loss of ALL of the following NRC communications methods:

Federal Telecommunications System (FTS)

Commercial Telephones 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 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.).

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 81 of 172 EAL CU5.1 addresses a total loss of the communications methods used in support of routine plant operations.

EAL CU5.2 addresses a total loss of the communications methods used to notify all OROs of an emergency declaration. The OROs referred to here are the State of Minnesota, Wright County, and Sherburne County.

EAL CU5.3 addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.

MNGP Basis Reference(s):

1.

USAR Section 10.3.8, Plant Auxiliary Systems - Plant Service Systems, Plant Communications System

2.

MNGP Emergency Plan Section 7.2 - Communication Systems

3.

MNGP Emergency Plan Figure 13.7 - Direct Dedicated Telephones (Hot Lines)

4.

A.2-504 Emergency Communicator Duties in the TSC and OSC

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 82 of 172 INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

ICS/EALS UNUSUAL EVENT EU1 Damage to a loaded cask CONFINEMENT BOUNDARY.

Op. Modes: All 8.0

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 83 of 172 EU1 ECL: Notification of Unusual Event Initiating Condition: Damage to a loaded cask CONFINEMENT BOUNDARY.

Operating Mode Applicability: All Emergency Action Levels:

EU1.1 Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by a radiation reading greater than any of the values listed in Table E1, E2, or E3 as applicable to the HSM:

Table E1 (Applicable to HSMs 1A/B - 5A/B)

Location of Dose Rate Total Dose Rate (Neutron + Gamma mR/hr) 3 feet from the HSM Surface 800 On-Contact Outside HSM Door Centerline 200 On-Contact End shield wall exterior 40 Table E2 (Applicable to HSMs 6A/B - 10A/B)

Location of Dose Rate Total Dose Rate (Neutron + Gamma mR/hr)

On-Contact HSM or HSM-H Front Surface 1400 On-Contact HSM or HSM-H Door Centerline 200 On-Contact End shield wall exterior 40 Table E3 (Applicable to HSMs 11A/B - 15A/B)

Location of Dose Rate Total Dose Rate (Neutron + Gamma mR/hr)

On-Contact HSM-H Front Bird Screen 1300 On-Contact HSM-H Door Centerline 4

On-Contact End shield wall exterior 8

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 84 of 172 Basis:

CONFINEMENT BOUNDARY: The barrier(s) between areas containing spent fuel and the environment once the spent fuel is processed for dry storage.

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 technical specification multiple of 2 times, which is also used in Recognition Category R IC RU1, is used here to distinguish between non-emergency and emergency conditions.

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.

Security-related events for ISFSIs are covered under ICs HU1 and HA1.

MNGP Basis Reference(s):

1.

9508 (DSC TRANSFER FROM TRANSFER CASK TO HSM)

2.

ISFSI Tech Spec 1.2.7, HSM Dose Rates with a loaded Type 1 61BT DSC Only

- Amendment 9

3.

ISFSI Tech Spec 1.2.7f, HSM or HSM-H Dose Rates with a loaded Type 1 61BTH DSC Only - Amendment 10

4.

ISFSI Tech Spec 5.4.1 and 5.4.2, HSM-H Dose Rates with a loaded Type 1 61BTH DSC Only - Amendment 13

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 85 of 172 FISSION PRODUCT BARRIER ICS/EALS Recognition Category F Initiating Condition Matrix GENERAL EMERGENCY FG1 Loss of any two barriers and Loss or Potential Loss of the third barrier.

Op. Modes: Power Operation, Startup, Hot Shutdown SITE AREA EMERGENCY FS1 Loss or Potential Loss of any two barriers.

Op. Modes: Power Operation, Startup, Hot Shutdown ALERT FA1 Any Loss or any Potential Loss of either the Fuel Clad or RCS barrier.

Op. Modes: Power Operation, Startup, Hot Shutdown 3/3 2/3 1/2 Loss of at least 2 Barriers?

LOSS POTENTIAL LOSS FUEL CLAD LOSS POTENTIAL LOSS RCS LOSS POTENTIAL LOSS CONTAINMENT LOSS POTENTIAL LOSS FUEL CLAD LOSS POTENTIAL LOSS RCS LOSS POTENTIAL LOSS CONTAINMENT LOSS POTENTIAL LOSS FUEL CLAD LOSS POTENTIAL LOSS RCS FG1 - Loss of ANY Two Barriers AND Loss or Potential Loss of Third Barrier

-- YES --

FS1 - Loss or Potential Loss of ANY Two Barriers

-- NO --

FA1 - ANY Loss or ANY Potential Loss of EITHER Fuel Clad OR RCS 9.0 I

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 86 of 172 Fission Product Barrier Table Thresholds for LOSS or POTENTIAL LOSS of Barriers FG1 GENERAL EMERGENCY Loss of any two barriers and Loss or Potential Loss of the third barrier.

FS1 SITE AREA EMERGENCY Loss or Potential Loss of any two barriers.

FA1 ALERT Any Loss or any Potential Loss of either the Fuel Clad or RCS barrier.

Fuel Clad Barrier RCS Barrier Containment Barrier LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS

1. RCS Activity

1. Primary Containment Pressure

1. Primary Containment Conditions A. Coolant activity is greater than 300 µCi/gm dose equivalent I-131.

Not Applicable A. Primary containment pressure greater than 1.84 psig due to RCS leakage.

Not Applicable A. UNPLANNED rapid drop in primary containment pressure following primary containment pressure rise OR B. Primary containment pressure response not consistent with LOCA conditions.

A. Primary containment pressure greater than 56 psig OR B. Greater than or equal to 6%

hydrogen and greater than or equal to 5%

oxygen in Drywell or Torus OR C. Heat Capacity Limit (HCL) exceeded

2. RPV Water Level

2. RPV Water Level

2. RPV Water Level A. SAMG entry is required.

A. RPV water level cannot be restored and maintained above -126 in. or cannot be determined.

A. RPV water level cannot be restored and maintained above -126 in. or cannot be determined.

Not Applicable Not Applicable A. SAMG entry is required.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 87 of 172 Fuel Clad Barrier RCS Barrier Containment Barrier LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS

3. Not Applicable

3. RCS Leak Rate

3. Primary Containment Isolation Failure Not Applicable Not Applicable A. UNISOLABLE break in ANY of the following:

MSL; HPCI; RWCU; RCIC as indicated by high flow/temperature isolation setpoints OR B. Emergency RPV Depressurization.

A. UNISOLABLE primary system leakage that results in exceeding Control Room indication of EITHER of the following:

1. Max Normal Operating Temperature OR

2. Max Normal Operating Area Radiation Level.

A. UNISOLABLE direct downstream pathway to the environment exists after primary containment isolation signal OR B. Intentional primary containment venting per EOPs OR C. UNISOLABLE primary system leakage that results in exceeding Control Room indication of EITHER of the following:

1. Max Safe Operating Temperature.

OR

2. Max Safe Operating Area Radiation Level.

Not Applicable

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 88 of 172 Fuel Clad Barrier RCS Barrier Containment Barrier LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS LOSS POTENTIAL LOSS

4. Primary Containment Radiation

4. Primary Containment Radiation

4. Primary Containment Radiation A. Containment High Range Rad (Drywell Radiation) monitor reading greater than 1.5 E+03 R/hr Not Applicable A. Containment High Range Rad (Drywell Radiation) monitor reading greater than 6.2 E+01 R/hr Not Applicable Not Applicable A. Containment High Range Rad (Drywell Radiation) monitor reading greater than 3.3 E+04 R/hr

5. Emergency Director Judgment

5. Emergency Director Judgment

5. Emergency Director Judgment A. ANY condition in the opinion of the Emergency Director that indicates Loss of the Fuel Clad Barrier.

A. ANY condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.

A. ANY condition in the opinion of the Emergency Director that indicates Loss of the RCS Barrier.

A. ANY condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.

A. ANY condition in the opinion of the Emergency Director that indicates Loss of the Containment Barrier.

A. ANY condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 89 of 172 Basis Information For BWR EAL Fission Product Barrier Table FUEL CLAD BARRIER THRESHOLDS:

The Fuel Clad barrier consists of the zircalloy fuel bundle tubes that contain the fuel pellets.

1.

RCS Activity Loss 1.A This threshold indicates that RCS radioactivity concentration is greater than 300 Ci/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.

There is no Potential Loss threshold associated with RCS Activity.

2.

RPV Water Level Loss 2.A The Loss threshold represents any EOP requirement for entry into Severe Accident Management Guidelines. This is identified in the BWR EPGs/SAGs when adequate core cooling cannot be assured.

Potential Loss 2.A This water level corresponds to the top of the active fuel and is used in the EOPs to indicate a challenge to core cooling.

The RPV water level threshold is the same as RCS barrier Loss threshold 2.A.

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

This threshold is considered to be exceeded when, as specified in the site-specific EOPs, RPV water cannot be restored and maintained above the specified level following depressurization of the RPV (either manually, automatically or by failure of the RCS barrier) or when procedural guidance or a lack of low pressure RPV injection sources preclude Emergency RPV depressurization. EOPs allow the operator a wide choice of RPV injection sources to consider when restoring RPV water level to within prescribed limits. EOPs also specify depressurization of the

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 90 of 172 RPV in order to facilitate RPV water level control with low-pressure injection sources. In some events, elevated RPV pressure may prevent restoration of RPV water level until pressure drops below the shutoff heads of available injection sources. Therefore, this Fuel Clad barrier Potential Loss is met only after either: 1) the RPV has been depressurized, or required emergency RPV depressurization has been attempted, giving the operator an opportunity to assess the capability of low-pressure injection sources to restore RPV water level or 2) no low pressure RPV injection systems are available, precluding RPV depressurization in an attempt to minimize loss of RPV inventory.

The term cannot be restored and maintained above means the value of RPV water level is not able to be brought above the specified limit (top of active fuel).

The determination requires an evaluation of system performance and availability in relation to the RPV water level value and trend. A threshold prescribing declaration when a threshold value cannot be restored and maintained above a specified limit does not require immediate action simply because the current value is below the top of active fuel, but does not permit extended operation below the limit; the threshold must be considered reached as soon as it is apparent that the top of active fuel cannot be attained.

In high-power ATWS/failure to scram events, EOPs may direct the operator to deliberately lower RPV water level to the top of active fuel in order to reduce reactor power. RPV water level is then controlled between the top of active fuel and the Minimum Steam Cooling RPV Water Level (MSCRWL). Although such action is a challenge to core cooling and the Fuel Clad barrier, the immediate need to reduce reactor power is the higher priority. For such events, ICs SA5 or SS5 will dictate the need for emergency classification.

Since the loss of ability to determine if adequate core cooling is being provided presents a significant challenge to the fuel clad barrier, a potential loss of the fuel clad barrier is specified.

3.

Not Applicable (included for numbering consistency between barrier tables)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 91 of 172

4.

Primary Containment Radiation Loss 4.A The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that reactor coolant activity equals 300 Ci/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.

The radiation monitor reading in this threshold is higher than that specified for RCS Barrier Loss threshold 4.A 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 emergency classification level to a Site Area Emergency.

There is no Potential Loss threshold associated with Primary Containment Radiation.

5.

Emergency Director Judgment Loss 5.A This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the Fuel Clad Barrier is lost.

Potential Loss 5.A This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Fuel Clad Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 92 of 172 RCS BARRIER THRESHOLDS:

The RCS Barrier is the reactor coolant system pressure boundary and includes the RPV and all reactor coolant system piping up to and including the isolation valves.

1.

Primary Containment Pressure Loss 1.A The 1.84 psig primary containment pressure is the drywell high pressure setpoint which indicates a LOCA by automatically initiating the ECCS or equivalent makeup system.

There is no Potential Loss threshold associated with Primary Containment Pressure.

2.

RPV Water Level Loss 2.A This water level corresponds to the top of active fuel and is used in the EOPs to indicate challenge to core cooling.

The RPV water level threshold is the same as Fuel Clad barrier Potential Loss threshold 2.A. Thus, this threshold indicates a Loss of the RCS barrier and Potential Loss of the Fuel Clad barrier and that appropriately escalates the emergency classification level to a Site Area Emergency.

This threshold is considered to be exceeded when, as specified in the site-specific EOPs, RPV water cannot be restored and maintained above the specified level following depressurization of the RPV (either manually, automatically or by failure of the RCS barrier) or when procedural guidance or a lack of low pressure RPV injection sources preclude Emergency RPV depressurization EOPs allow the operator a wide choice of RPV injection sources to consider when restoring RPV water level to within prescribed limits. EOPs also specify depressurization of the RPV in order to facilitate RPV water level control with low-pressure injection sources. In some events, elevated RPV pressure may prevent restoration of RPV water level until pressure drops below the shutoff heads of available injection sources. Therefore, this RCS barrier Loss is met only after either: 1) the RPV has been depressurized, or required emergency RPV depressurization has been attempted, giving the operator an opportunity to assess the capability of low-pressure injection sources to restore RPV water level or 2) no low pressure RPV injection systems are available, precluding RPV depressurization in an attempt to minimize loss of RPV inventory.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 93 of 172 The term, cannot be restored and maintained above, means the value of RPV water level is not able to be brought above the specified limit (top of active fuel).

The determination requires an evaluation of system performance and availability in relation to the RPV water level value and trend. A threshold prescribing declaration when a threshold value cannot be restored and maintained above a specified limit does not require immediate action simply because the current value is below the top of active fuel, but does not permit extended operation beyond the limit; the threshold must be considered reached as soon as it is apparent that the top of active fuel cannot be attained.

In high-power ATWS/failure to scram events, EOPs may direct the operator to deliberately lower RPV water level to the top of active fuel in order to reduce reactor power. RPV water level is then controlled between the top of active fuel and the Minimum Steam Cooling RPV Water Level (MSCRWL). Although such action is a challenge to core cooling and the Fuel Clad barrier, the immediate need to reduce reactor power is the higher priority. For such events, ICs SA5 or SS5 will dictate the need for emergency classification.

There is no RCS Potential Loss threshold associated with RPV Water Level.

3.

RCS Leak Rate Loss Threshold 3.A Large high-energy lines that rupture outside primary containment can discharge significant amounts of inventory and jeopardize the pressure-retaining capability of the RCS until they are isolated. If it is determined that the ruptured line cannot be promptly isolated from the Control Room, the RCS barrier Loss threshold is met.

Loss Threshold 3.B Emergency RPV Depressurization in accordance with the EOPs is indicative of a loss of the RCS barrier. If Emergency RPV Depressurization is performed, the plant operators are directed to open safety relief valves (SRVs). Even though the RCS is being vented into the suppression pool, a Loss of the RCS barrier exists due to the diminished effectiveness of the RCS to retain fission products within its boundary.

Potential Loss Threshold 3.A Potential loss of RCS based on primary system leakage outside the primary containment is determined from EOP temperature or radiation Max Normal Operating values in areas such as main steam line tunnel, RCIC, HPCI, etc.,

which indicate a direct path from the RCS to areas outside primary containment.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 94 of 172 A Max Normal Operating value is the highest value of the identified parameter expected to occur during normal plant operating conditions with all directly associated support and control systems functioning properly.

The indicators reaching the threshold barriers and confirmed to be caused by RCS leakage from a primary system warrant an Alert classification. A primary system is defined to be the pipes, valves, and other equipment which connect directly to the RPV such that a reduction in RPV pressure will effect a decrease in the steam or water being discharged through an unisolated break in the system.

An UNISOLABLE leak which is indicated by Max Normal Operating values escalates to a Site Area Emergency when combined with Containment Barrier Loss threshold 3.A (after a containment isolation) and a General Emergency when the Fuel Clad Barrier criteria is also exceeded.

4.

Primary Containment Radiation Loss 4.A The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that reactor coolant activity equals Technical Specification allowable limits. This value is lower than that specified for Fuel Clad Barrier Loss threshold 4.A since it indicates a loss of the RCS Barrier only.

There is no Potential Loss threshold associated with Primary Containment Radiation.

5.

Emergency Director Judgment Loss 5.A This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the RCS barrier is lost.

Potential Loss 5.A This threshold addresses any other factors that may be used by the Emergency Director in determining whether the RCS Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 95 of 172 CONTAINMENT BARRIER THRESHOLDS:

The Primary Containment Barrier includes the drywell, the wetwell, their respective interconnecting paths, and other connections up to and including the outermost containment isolation valves. Containment Barrier thresholds are used as criteria for escalation of the ECL from Alert to a Site Area Emergency or a General Emergency.

1.

Primary Containment Conditions Loss 1.A and 1.B Rapid UNPLANNED loss of primary containment pressure (i.e., not attributable to drywell spray or condensation effects) following an initial pressure increase indicates a loss of primary containment integrity. Primary containment pressure should increase as a result of mass and energy release into the primary containment from a LOCA. Thus, primary containment pressure not increasing under these conditions indicates a loss of primary containment integrity.

These thresholds rely on operator recognition of an unexpected response for the condition and therefore a specific value is not assigned. The unexpected (UNPLANNED) response is important because it is the indicator for a containment bypass condition.

Potential Loss 1.A The threshold pressure is the primary containment internal design pressure.

Structural acceptance testing demonstrates the capability of the primary containment to resist pressures greater than the internal design pressure. A pressure of this magnitude is greater than those expected to result from any design basis accident and, thus, represent a Potential Loss of the Containment barrier.

Potential Loss 1.B If hydrogen concentration reaches or exceeds the lower flammability limit, as defined in plant EOPs, in an oxygen rich environment, a potentially explosive mixture exists. The existence of an explosive mixture ( 6% H2 and 5% O2) means, at a minimum, that the containment hydrogen concentration is sufficient to support a hydrogen burn. If the combustible mixture ignites inside the primary containment, loss of the Containment barrier could occur.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 96 of 172 Potential Loss 1.C The Heat Capacity Limit (HCL) is the highest suppression pool temperature from which Emergency RPV Depressurization will not raise:

Suppression chamber temperature above the maximum temperature capability of the suppression chamber and equipment within the suppression chamber which may be required to operate when the RPV is pressurized, OR Suppression chamber pressure above Primary Containment Pressure Limit A, while the rate of energy transfer from the RPV to the containment is greater than the capacity of the containment vent.

The HCL is a function of RPV pressure, suppression pool temperature and suppression pool water level. It is utilized to preclude failure of the containment and equipment in the containment necessary for the safe shutdown of the plant and therefore, the inability to maintain plant parameters below the limit constitutes a potential loss of containment.

2.

RPV Water Level There is no Loss threshold associated with RPV Water Level.

Potential Loss 2.A The Potential Loss threshold is identical to the Fuel Clad Loss RPV Water Level threshold 2.A. The Potential Loss requirement for entry into the Severe Accident Management Guidelines indicates adequate core cooling cannot be assured and that core damage is possible. BWR EPGs/SAGs specify the conditions when the EPGs are exited and SAMGs are entered. Entry into SAMGs is a logical escalation in response to the inability to assure adequate core cooling.

PRA studies indicate that the condition of this Potential Loss threshold could be a core melt sequence which, if not corrected, could lead to RPV failure and increased potential for primary containment failure. In conjunction with the RPV water level Loss thresholds in the Fuel Clad and RCS barrier columns, this threshold results in the declaration of a General Emergency.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 97 of 172

3.

Primary Containment Isolation Failure These thresholds address incomplete containment isolation that allows an UNISOLABLE direct release to the environment. A release path is direct if it allows for the migration of radioactive material from the containment to the environment in a generally uninterrupted manner (e.g., little or no holdup time);

therefore, within the context of a Containment Barrier Loss or Potential Loss threshold, a release path through the wetwell is a direct release path.

Loss 3.A The use of the modifier direct in defining the release path discriminates against release paths through interfacing liquid systems or minor release pathways, such as instrument lines, not protected by the Primary Containment Isolation System (PCIS).

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.

Following the leakage of RCS mass into primary containment and a rise in primary containment pressure, there may be minor radiological releases associated with allowable primary containment leakage through various penetrations or system components. Minor releases may also occur if a primary containment isolation valve(s) fails to close but the primary containment atmosphere escapes to an enclosed system. These releases do not constitute a loss or potential loss of primary containment but should be evaluated using the Recognition Category R ICs.

Loss 3.B EOPs may direct primary containment isolation valve logic(s) to be intentionally bypassed, even if offsite radioactivity release rate limits will be exceeded. Under these conditions with a valid primary containment isolation signal, the containment should also be considered lost if primary containment venting is actually performed.

Intentional venting of primary containment for primary containment pressure or combustible gas control to the secondary containment and/or the environment is a Loss of the Containment. In this situation conditions and trends are such that the Control Room staff has made a decision to perform an intentional controlled venting of the containment. This intentional venting action results in a bypass of the primary containment, whether it is anticipatory or otherwise. Venting for

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 98 of 172 primary containment pressure control when not in an accident situation (e.g., to control pressure below the drywell high pressure scram setpoint) does not meet the threshold condition.

Loss 3.C The Max Safe Operating Temperature and the Max Safe Operating Radiation Level are each the highest value of these parameters at which neither:

(1) equipment necessary for the safe shutdown of the plant will fail, nor (2) personnel access necessary for the safe shutdown of the plant will be precluded. EOPs utilize these temperatures and radiation levels to establish conditions under which RPV depressurization is required.

The temperatures and radiation levels should be confirmed to be caused by RCS leakage from a primary system. A primary system is defined to be the pipes, valves, and other equipment which connect directly to the RPV such that a reduction in RPV pressure will effect a decrease in the steam or water being discharged through an unisolated break in the system.

In combination with RCS potential loss 3.A this threshold would result in a Site Area Emergency.

There is no Potential Loss threshold associated with Primary Containment Isolation Failure.

4.

Primary Containment Radiation There is no Loss threshold associated with Primary Containment Radiation.

Potential Loss 4.A The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary 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.

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.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 99 of 172

5.

Emergency Director Judgment Loss 5.A This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the Containment barrier is lost.

Potential Loss 5.A This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Containment Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

MNGP Basis Reference(s):

1.

Ops Man B.02.04 (MAIN STEAM)

2.

Ops Man C.4-B.04.01.A (PRIMARY CONTAINMENT ISOLATION - GROUP 1)

3.

Ops Man C.6-005-A-25 (MAIN STEAM LINE HI FLOW CH A)

4.

Ops Man C.6-005-A-26 (MAIN STEAM LINE HI FLOW CH B)

5.

Ops Man C.6-003-B-56 (HIGH AREA TEMP STEAM LEAK)

6.

C.5.1-1001 (EOP TECHNICAL BASES (MODES 1, 2, 3))

7.

C.5-3505 (VENTING PRIMARY CONTAINMENT)

8.

MNGP Calculation CA-04-194, Containment High Range Radiation Monitor (CHRRM) Response to Drywell Activity

9.

USAR Section 5.2, Containment System - Primary Containment System

10. USAR Table Section 7.5, Plant Instrumentation and Control Systems - Plant Radiation Monitoring Systems

11. Tech Spec Table 3.3.3.1-1 (Post Accident Monitoring Instrumentation)

12. Tech Spec 3.6.1.1 (Primary Containment)

13. Tech Spec 3.6.4.1 (Secondary Containment)

14. NX-7831-197-1, Reactor Vessel & Internals

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 100 of 172 HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT HG1 HOSTILE ACTION resulting in loss of physical control of the facility.

Op. Modes: All HS1 HOSTILE ACTION within the Plant PROTECTED AREA.

Op. Modes: All HA1 HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.

Op. Modes: All HU1 Confirmed SECURITY CONDITION or threat.

Op. Modes: All HU2 Seismic event greater than OBE levels.

Op. Modes: All HU3 Hazardous event.

Op. Modes: All HU4 FIRE potentially degrading the level of safety of the plant.

Op. Modes: All HA5 Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.

Op. Modes: Startup, Hot Shutdown, Cold Shutdown HS6 Inability to control a key safety function from outside the Control Room.

Op. Modes: Power Operation, Startup, Hot Shutdown, Cold Shutdown, Refueling HA6 Control Room evacuation resulting in transfer of plant control to alternate locations.

Op. Modes: All HG7 Other conditions exist which in the judgment of the Emergency Director warrant declaration of a General Emergency.

Op. Modes: All HS7 Other conditions exist which in the judgment of the Emergency Director warrant declaration of a Site Area Emergency.

Op. Modes: All HA7 Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert.

Op. Modes: All HU7 Other conditions exist which in the judgment of the Emergency Director warrant declaration of a (NO)UE.

Op. Modes: All 10.0

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 101 of 172 HG1 ECL: General Emergency Initiating Condition: HOSTILE ACTION resulting in loss of physical control of the facility.

Operating Mode Applicability: All Emergency Action Levels:

HG1.1

a. A HOSTILE ACTION is occurring or has occurred within the Plant PROTECTED AREA as reported by the Security Shift Supervisor.

AND

b. EITHER of the following has occurred:

1. ANY of the following safety functions cannot be controlled or maintained.

Reactivity control RPV water level RCS heat removal OR

2. Damage to spent fuel has occurred or is IMMINENT.

Basis:

HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).

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.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 102 of 172 PROTECTED AREA: The area surrounding the plant encompassed by the chain link fence and certain structures as defined in the Security Plan; excludes the ISFSI Protected Area. In areas where two fences are present, the inner fence is designated as the Protected Area barrier.

This IC addresses an event in which a HOSTILE FORCE has taken physical control of the facility to the extent that the plant staff can no longer operate equipment necessary to maintain key safety functions. It also addresses a HOSTILE ACTION leading to a loss of physical control that results in actual or IMMINENT damage to spent fuel due to 1) damage to a spent fuel pool cooling system (e.g., pumps, heat exchangers, controls, etc.) or, 2) loss of spent fuel pool integrity such that sufficient water level cannot be maintained.

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].

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 Security Plan.

MNGP Basis Reference(s):

1.

MNGP Safeguards Contingency Plan

2.

C.4-L (RESPONSE TO SECURITY THREATS)

3.

NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan (and Independent Spent Fuel Storage Installation Security Program)

4.

ND-95209, Monticello Main Plant Structures

5.

QF1775 (DEFINITIONS)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 103 of 172 HG7 ECL: General Emergency Initiating Condition: Other conditions exist which in the judgment of the Emergency Director warrant declaration of a General Emergency.

Operating Mode Applicability: All Emergency Action Levels:

HG7.1 Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or 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.

Basis:

HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).

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.

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 Director to fall under the emergency classification level description for a General Emergency.

MNGP Basis Reference(s):

1.

QF1775 (DEFINITIONS)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 104 of 172 HS1 ECL: Site Area Emergency Initiating Condition: HOSTILE ACTION within the Plant PROTECTED AREA.

Operating Mode Applicability: All Emergency Action Levels:

HS1.1 A HOSTILE ACTION is occurring or has occurred within the Plant PROTECTED AREA as reported by the Security Shift Supervisor.

Basis:

HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).

PROTECTED AREA: The area surrounding the plant encompassed by the chain link fence and certain structures as defined in the Security Plan; excludes the ISFSI Protected Area. In areas where two fences are present, the inner fence is designated as the Protected Area barrier.

This IC addresses the occurrence of a HOSTILE ACTION within the Plant 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.

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 ORO

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 105 of 172 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 does not apply to a HOSTILE ACTION directed at an ISFSI PROTECTED AREA located outside the plant 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 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 Security Plan.

Escalation of the emergency classification level would be via IC HG1.

MNGP Basis Reference(s):

1.

MNGP Safeguards Contingency Plan

2.

C.4-L (RESPONSE TO SECURITY THREATS)

3.

NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan (and Independent Spent Fuel Storage Installation Security Program)

4.

ND-95209, Monticello Main Plant Structures

5.

QF1775 (DEFINITIONS)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 106 of 172 HS6 ECL: Site Area Emergency Initiating Condition: Inability to control a key safety function from outside the Control Room.

Operating Mode Applicability: Power Operation, Startup, Hot Shutdown, Cold Shutdown, Refueling Emergency Action Levels:

NOTE:

The Emergency Director should declare the Site Area Emergency promptly upon determining that 10 minutes has been exceeded, or will likely be exceeded.

HS6.1

a. An event has resulted in plant control being transferred from the Control Room to the alternate shutdown panel.

AND

b. Control of ANY of the following key safety functions is not reestablished within 10 minutes.

Reactivity control (Modes 1 and 2 only)

RPV water level RCS heat removal 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 alternate shutdown panel is based on Emergency Director judgment. The Emergency Director is expected to make a reasonable, informed judgment within 10 minutes whether or not the operating staff has control of key safety functions from the remote safe shutdown location(s). Ops Man C.4-C, Shutdown Outside the Control Room, provides specific instructions for evacuating the Control Room and establishing plant control at the

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 107 of 172 alternate shutdown panel. It should be noted here that analysis has shown that under worst case conditions (Assumed power level of 2004 MWt, Control Room fire coincident with loss of offsite power and reactor isolation and no available RPV injection) that indicated reactor level will decrease below the Top of Active Fuel (TAF) in approximately 11 minutes. Additionally, spurious operation of an SRV as a result of the fire event may lead to indicated reactor water level already being below TAF at the time of Operator arrival to the ASDS panel at the 10 minute mark. The EOPs would normally require depressurization before level reaches TAF however, thermal hydraulic analysis was performed and, given the above mentioned bounding scenarios, conservatively assumed reactor manual depressurization to occur at 17 minutes.

Escalation of the emergency classification level would be via IC FG1 or CG1.

MNGP Basis Reference(s):

1.

Ops Man C.4-C (SHUTDOWN OUTSIDE THE CONTROL ROOM)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 108 of 172 HS7 ECL: Site Area Emergency Initiating Condition: Other conditions exist which in the judgment of the Emergency Director warrant declaration of a Site Area Emergency.

Operating Mode Applicability: All Emergency Action Levels:

HS7.1 Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the 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.

Basis:

HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).

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 Director to fall under the emergency classification level description for a Site Area Emergency.

MNGP Basis Reference(s):

1.

QF1775 (DEFINITIONS)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 109 of 172 HA1 ECL: Alert Initiating Condition: HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.

Operating Mode Applicability: All Emergency Action Levels: (HA1.1 or HA1.2)

HA1.1 A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the Security Shift Supervisor.

HA1.2 A validated notification from NRC of an aircraft attack threat within 30 minutes of the site.

Basis:

HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).

OWNER CONTROLLED AREA: The OCA boundaries consist of the plant property enclosed by a three strand barbed wire fence and a posted boundary on the Wright County side of the river.

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 assistance due to the possibility of the attack progressing to the Plant 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

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 110 of 172 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, allowing them to be better prepared should it be necessary to consider further actions.

This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73 or 10 CFR § 50.72.

EAL HA1.1 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.

EAL HA1.2 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 site procedures.

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 Security Plan.

Escalation of the emergency classification level would be via IC HS1.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 111 of 172 MNGP Basis Reference(s):

1.

MNGP Safeguards Contingency Plan

2.

C.4-L (RESPONSE TO SECURITY THREATS)

3.

NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan (and Independent Spent Fuel Storage Installation Security Program)

4.

FP-S-FSIP-08 (CONTINGENCY PLAN IMPLEMENTING PROCEDURES)

5.

QF1775 (DEFINITIONS)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 112 of 172 HA5 ECL: Alert Initiating Condition: Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.

Operating Mode Applicability: Startup, Hot Shutdown, Cold Shutdown Emergency Action Levels:

NOTE:

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.

HA5.1

a. Release of a toxic, corrosive, asphyxiant or flammable gas into any of the Table H1 plant rooms or areas:

Table H1 Room Applicable Mode(s)

BOTH RHR Rooms (Reactor Building 896 SW and SE) 3 / 4 MCC-133 Room (Turbine Building 911 East)

MVP Room (Turbine Building 908 West) 2 / 3 AND

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

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.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 113 of 172 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 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 Directors 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.

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.

This EAL does not apply to firefighting activities that automatically or manually activate a fire suppression system in an area, or to intentional inerting of containment).

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 114 of 172 HA5.1 mode of applicability has been limited to the applicable modes identified in Table H1. If plant operating procedures or plant configuration changes result in changes to areas requiring access or modes at which access is required, a corresponding change to Table H1 areas will be required as originally evaluated under AR603000000450, MNGP Area Evaluation for use in EALs..

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

MNGP Basis Reference(s):

1.

Ops Man C.1 (STARTUP PROCEDURE)

2.

Ops Man C.3 (SHUTDOWN PROCEDURE)

3.

USAR Table I.5-1, Location of High Energy Systems and Safe Shutdown Equipment by Volume

4.

USAR Section 10.3, Plant Auxiliary Systems - Plant Service Systems

5.

USAR Section 12.2, Plant Structures and Shielding - Plant Principal Structures and Foundations

6.

ND-95209, Monticello Main Plant Structures

7.

AR603000000450, MNGP Area Evaluation for use in EALs.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 115 of 172 HA6 ECL: Alert Initiating Condition: Control Room evacuation resulting in transfer of plant control to alternate locations.

Operating Mode Applicability: All Emergency Action Levels:

HA6.1 An event has resulted in plant control being transferred from the Control Room to the alternate shutdown panel.

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.

Escalation of the emergency classification level would be via IC HS6.

MNGP Basis Reference(s):

1.

Ops Man C.4-C (SHUTDOWN OUTSIDE THE CONTROL ROOM)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 116 of 172 HA7 ECL: Alert Initiating Condition: Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert.

Operating Mode Applicability: All Emergency Action Levels:

HA7.1 Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to 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.

Basis:

HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).

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 Director to fall under the emergency classification level description for an Alert.

MNGP Basis Reference(s):

1.

QF1775 (DEFINITIONS)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 117 of 172 HU1 ECL: Notification of Unusual Event Initiating Condition: Confirmed SECURITY CONDITION or threat.

Operating Mode Applicability: All Emergency Action Levels: (HU1.1 or HU1.2 or HU1.3)

HU1.1 A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the Security Shift Supervisor.

HU1.2 Notification of a credible security threat directed at MNGP.

HU1.3 A validated notification from the NRC providing information of an aircraft threat.

Basis:

HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).

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.

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 or 10 CFR § 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs HA1, 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 OROs.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 118 of 172 Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].

EAL HU1.1 references Security Shift Supervisor because this is the individual 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.

EAL HU1.2 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with site procedures.

EAL HU1.3 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 site procedures.

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 Security Plan.

Escalation of the emergency classification level would be via IC HA1.

MNGP Basis Reference(s):

1.

MNGP Safeguards Contingency Plan

2.

C.4-L (RESPONSE TO SECURITY THREATS)

3.

NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan (and Independent Spent Fuel Storage Installation Security Program)

4.

FP-S-FSIP-08 (CONTINGENCY PLAN IMPLEMENTING PROCEDURES)

5.

QF1775 (DEFINITIONS)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 119 of 172 HU2 ECL: Notification of Unusual Event Initiating Condition: Seismic event greater than OBE levels.

Operating Mode Applicability: All Emergency Action Levels:

HU2.1 Seismic event greater than Operating Basis Earthquake (OBE) as indicated by Annunciator OPERATIONAL BASIS EARTHQUAKE (6-C-13) received.

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.

The Control Room annunciator EARTHQUAKE (6-C-08) alarms either by the seismic trigger of the Accelerograph Recording System or seismic switch of the Seismic Annunciator System. The annunciator OPERATIONAL BASIS EARTHQUAKE (6-C-13) alarms when its switch senses an acceleration 0.03g. The Accelerograph Recording System records accelerations in three directions, longitudinal, transversal and vertical.

This IC is based on the USAR operating basis earthquake (OBE) of 0.04g vertical or 0.06g horizontal. Classification for this IC is to occur upon receipt of annunciator 6-C-13 as it is immediately available to CR personnel and is readily assessed.

Seismic events of this magnitude (i.e., > OBE but DBE) have been analyzed and designed for at the MNGP. However, events of this magnitude can result in plant equipment being subjected to forces that require further engineering attention.

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., typical lateral accelerations are in excess of 0.08g). The Shift Manager or Emergency Director may seek external verification if deemed appropriate (e.g., a call to the USGS, check internet news sources, etc.);

however, the verification action must not preclude a timely emergency declaration.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 120 of 172 Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA6 or SA9.

MNGP Basis Reference(s):

1.

Ops Man A.6 (ACTS OF NATURE)

2.

Ops Man B.05.14-01 (SEISMIC MONITORING - SYSTEM OPERATION)

3.

C.4-B.05.14.A (EARTHQUAKE)

4.

C.6-006-C-08 (EARTHQUAKE)

5.

C.6-006-C-13 (OPERATIONAL BASIS EARTHQUAKE)

6.

USAR Section 2.6.5, Seismic Monitoring System

7.

USAR Section 12.2.1, Plant Principal Structures and Foundations, Design Basis

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 121 of 172 HU3 ECL: Notification of Unusual Event Initiating Condition: Hazardous event.

Operating Mode Applicability: All Emergency Action Levels: (HU3.1 or HU3.2 or HU3.3 or HU3.4 or HU3.5 or HU3.6)

NOTE:

EAL HU3.4 does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.

NOTE:

With EAL HU3.6 the Emergency Director should declare the Unusual Event promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded.

HU3.1 A tornado strike within the Plant PROTECTED AREA.

HU3.2 Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component needed for the current operating mode.

HU3.3 Movement of personnel within the Plant PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).

HU3.4 A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.

HU3.5 River level greater than 918 ft elevation.

HU3.6 River level less than 902.4 ft elevation for 60 minutes or longer.

Basis:

PROTECTED AREA: The area surrounding the plant encompassed by the chain link fence and certain structures as defined in the Security Plan; excludes the ISFSI Protected Area. In areas where two fences are present, the inner fence is designated as the Protected Area barrier.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 122 of 172 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.

This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.

EAL HU3.1 addresses a tornado striking (touching down) within the Protected Area.

EAL HU3.2 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 HU3.3 addresses a hazardous materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel within the Plant PROTECTED AREA.

EAL HU3.4 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 HU3.5 addresses a potential flood condition. The 918 ft elevation is selected for this EAL because it is the first elevation at which procedure actions are required to address flooding situations.

EAL HU3.6 addresses low river flow conditions. The low river water level threshold (902.4 ft elevation) corresponds to the low river flow threshold of 240 CFS. Low river level (i.e., flow) may be a precursor to loss of the ultimate heat sink and warrants further management attention.

Sixty minutes was selected as a threshold to exclude transient events affecting river level.

Escalation of the emergency classification level would be based on ICs in Recognition Categories A, F, S or C.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 123 of 172 MNGP Basis Reference(s):

1.

Ops Man A.6 (ACTS OF NATURE)

2.

USAR Section 10.3, Plant Auxiliary Systems - Plant Service Systems

3.

USAR Section 12.2, Plant Structures and Shielding - Plant Principal Structures and Foundations

4.

USAR Appendix G, Chapter 3, Probable Maximum Flood Determination

5.

ND-95208, Monticello Property Map

6.

ND-95209, Monticello Main Plant Structures

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 124 of 172 HU4 ECL: Notification of Unusual Event Initiating Condition: FIRE potentially degrading the level of safety of the plant.

Operating Mode Applicability: All Emergency Action Levels: (HU4.1 or HU4.2 or HU4.3 or HU4.4)

NOTE:

The Emergency Director should declare the Unusual Event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

HU4.1

a. A FIRE is NOT extinguished within 15-minutes of ANY of the following FIRE detection indications:

Report from the field (i.e., visual observation)

Receipt of multiple (more than 1) fire alarms or indications Field verification of a single fire alarm AND

b. The FIRE is located within ANY of the Table H2 plant rooms or areas.

HU4.2

a. Receipt of a single fire alarm (i.e., no other indications of a FIRE).

AND

b. The FIRE is located within ANY of the Table H2 plant rooms or areas.

AND

c. The existence of a FIRE is not verified within 30-minutes of alarm receipt.

HU4.3 A FIRE within the Plant PROTECTED AREA or ISFSI PROTECTED AREA not extinguished within 60-minutes of the initial report, alarm or indication.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 125 of 172 HU4.4 A FIRE within the Plant PROTECTED AREA or ISFSI PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.

Table H2 Building Name Room(s)/Area(s) with Safety Equipment Reactor Building All HPCI Building All Turbine Building All Control and Administration Building Control Room, Cable Spreading Room, and Battery Rooms Diesel Generator Building All Diesel Fuel Oil Transfer House All EFT Building All Intake Structure All Basis:

NOTE:

ND-95209 provides a pictorial of site structures on Table H2.

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.

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

ISFSI PROTECTED AREA: The area surrounding the Independent Spent Fuel Storage Installation encompassed by the double chain link fence surrounding the ISFSI as defined in the Security Plan; the ISFSI Protected Area is excluded from the Plant Protected Area.

PROTECTED AREA: The area surrounding the plant encompassed by the chain link fence and certain structures as defined in the Security Plan; excludes the ISFSI

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 126 of 172 Protected Area. In areas where two fences are present, the inner fence is designated as the Protected Area barrier.

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 HU4.1 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 HU4.2 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 HU4.1 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 HU4.3 In addition to a FIRE addressed by EAL HU4.1 or EAL HU4.2, a FIRE within the Plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 127 of 172 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.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 128 of 172 EAL HU4.4 If a FIRE within the Plant PROTECTED AREA or ISFSI 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 HU4.2, 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.

MNGP Basis Reference(s):

1.

USAR Section 10.3, Plant Auxiliary Systems - Plant Service Systems

2.

USAR Section 12.2, Plant Structures and Shielding - Plant Principal Structures and Foundations

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 129 of 172

3.

USAR Appendix I, Table I.5-1, Location of High Energy System and Safe Shutdown Equipment by Volume

4.

USAR Appendix J.4, Fire Protection Program - Safe Shutdown Analysis

5.

ND-95209, Monticello Main Plant Structures

6.

NF-36300-1-2, Block Wall Schedule Reactor Building

7.

NF-36300-1-3, Block Wall Schedule Turbine Building

8.

NF-3600-1-4, Block Wall Schedule Plant Admin Building and Offgas Stack

9.

4 AWI-01.03.01 (QUALITY ASSURANCE PROGRAM BOUNDARY)

10. Ops Man B.08.05-05 (FIRE PROTECTION SYSTEM OPERATION)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 130 of 172 HU7 ECL: Notification of Unusual Event Initiating Condition: Other conditions exist which in the judgment of the Emergency Director warrant declaration of a NUE.

Operating Mode Applicability: All Emergency Action Levels:

HU7.1 Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.

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 Director to fall under the emergency classification level description for a NUE.

MNGP Basis Reference(s):

1.

QF1775 (DEFINITIONS)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 131 of 172 SYSTEM MALFUNCTION ICS/EALS GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT SG1 Prolonged loss of all offsite and all onsite AC power to essential buses.

Op. Modes: Power Operation, Startup,, Hot Shutdown SS1 Loss of all offsite and all onsite AC power to essential buses for 15 minutes or longer.

Op. Modes: Power Operation, Startup,, Hot Shutdown SA1 Loss of all but one AC power source to essential buses for 15 minutes or longer.

Op. Modes: Power Operation, Startup,, Hot Shutdown SU1 Loss of all offsite AC power capability to essential buses for 15 minutes or longer.

Op. Modes: Power Operation, Startup,, Hot Shutdown SA2 UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress.

Op. Modes: Power Operation, Startup,, Hot Shutdown SU2 UNPLANNED loss of Control Room indications for 15 minutes or longer.

Op. Modes: Power Operation, Startup,, Hot Shutdown SU3 Reactor coolant activity greater than Technical Specification allowable limits.

Op. Modes: Power Operation, Startup,, Hot Shutdown SU4 RCS leakage for 15 minutes or longer.

Op. Modes: Power Operation, Startup,, Hot Shutdown SS5 Inability to shutdown the reactor causing a challenge to RPV water level or RCS heat removal.

Op. Modes: Power Operation SA5 Automatic or manual scram fails to shutdown the reactor, and subsequent manual actions taken at the main control boards are not successful in shutting down the reactor.

Op. Modes: Power Operation SU5 Automatic or manual scram fails to shutdown the reactor.

Op. Modes: Power Operation SU6 Loss of all onsite or offsite communications capabilities.

Op. Modes: Power Operation, Startup,, Hot Shutdown 11.0

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 132 of 172 GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT SG8 Loss of all AC and Vital DC power sources for 15 minutes or longer.

Op. Modes: Power Operation, Startup,, Hot Shutdown SS8 Loss of all Vital DC power for 15 minutes or longer.

Op. Modes: Power Operation, Startup,, Hot Shutdown SA9 Hazardous event affecting a SAFETY SYSTEM needed for the current operating mode.

Op. Modes: Power Operation, Startup,, Hot Shutdown

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 133 of 172 SG1 ECL: General Emergency Initiating Condition: Prolonged loss of all offsite and all onsite AC power to essential buses.

Operating Mode Applicability: Power Operation, Startup, Hot Shutdown Emergency Action Levels:

NOTE:

The Emergency Director should declare the General Emergency promptly upon determining that 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> has been exceeded, or will likely be exceeded.

SG1.1

a. Loss of ALL offsite and ALL onsite AC power to essential buses 15 and

16.

AND

b. EITHER of the following:

Restoration of at least one AC essential bus in less than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is not likely.

Reactor vessel water level cannot be restored and maintained above -150 (Minimum Steam Cooling RPV Water Level)

Basis:

This IC addresses a prolonged loss of all power sources to AC essential buses. 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 lead to a loss of one or more fission product barriers. In addition, fission product barrier monitoring capabilities may be degraded under these conditions.

If a transformer is declared unavailable consider the transformer(s) not capable of supplying busses 15 and/or 16.

The 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.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 134 of 172 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 essential 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 essential 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.

MNGP Basis Reference(s):

1.

Ops Man B.09.06-01 (4.16 KV STATION AUXILIARY - FUNCTION AND GENERAL DESCRIPTION OF SYSTEM)

2.

Ops Man C.4-B.09.02.A (STATION BLACKOUT)

3.

Ops Man C.4-B.09.02.B (LOSS OF NORMAL OFF-SITE POWER)

4.

Ops Man C.4-B.09.06.C (LOSS OF BUS 15 OR BUS 16)

5.

C.5.1-1001 (EOP TECHNICAL BASES (MODES 1, 2, 3))

6.

USAR Section 8.2.1, Plant Electrical Systems - Transmission System, Network Interconnections

7.

USAR Section 8.5.1.1, Plant Electrical Systems - DC Power Supply Systems, Essential 250 Vdc Systems, Design Basis

8.

USAR Section 8.12, Plant Electrical Systems - Station Blackout

9.

USAR Figure 8.4-1, Diesel Generation System One Line Diagram

10. NF-36175, Single Line Diagram - Station Connection

11. Tech Spec 3.8.1 (AC SOURCES - OPERATING)

12. Tech Spec 3.8.7 (DISTRIBUTION SYSTEMS - OPERATING)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 135 of 172 SG8 ECL: General Emergency Initiating Condition: Loss of all AC and Vital DC power sources for 15 minutes or longer.

Operating Mode Applicability: Power Operation, Startup, Hot Shutdown Emergency Action Levels:

NOTE:

The Emergency Director should declare the General Emergency promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.

SG8.1

a. Loss of ALL offsite and ALL onsite AC power to essential buses 15 and 16 for 15 minutes or longer.

AND

b. Indicated voltage is less than 110 VDC on ALL 125 VDC Vital DC buses for 15 minutes or longer.

Basis:

This IC addresses a concurrent and prolonged loss of both AC and Vital DC power. 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 loss of Vital DC power compromises the ability to monitor and control SAFETY SYSTEMS. A sustained loss of both AC and DC power will lead to multiple challenges to fission product barriers.

The indicated voltage used in this threshold is based on battery sizing calculations.

The threshold is an average for both Division I and II batteries for battery voltages at 15 minutes prior to reaching the minimum required terminal voltage.

The Division I and II - 250 VDC battery systems need not be considered in this EAL because they supply power to large motor loads in the RCIC and HPCI systems and various non-critical loads. RCIC is an alternative source of make-up water for the reactor during normal plant shutdowns and transient events which lead to a loss of feedwater flow. HPCI is part of the Emergency Core Cooling System (ECCS) network. However, the Auto Depressurization System (ADS) is redundant in function to the HPCI system and does not require 250 VDC for operations. Therefore, these

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 136 of 172 systems need not be included in this EAL since loss of the 250 VDC battery systems would not cause core uncovering or loss of containment integrity.

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.

MNGP Basis Reference(s):

1.

Ops Man B.09.06-01 (4.16 KV STATION AUXILIARY - FUNCTION AND GENERAL DESCRIPTION OF SYSTEM)

2.

Ops Man C.4-B.09.02.A (STATION BLACKOUT)

3.

Ops Man C.4-B.09.02.B (LOSS OF NORMAL OFF-SITE POWER)

4.

Ops Man C.4-B.09.06.C (LOSS OF BUS 15 OR BUS 16)

5.

USAR Section 8.2.1, Plant Electrical Systems - Transmission System, Network Interconnections

6.

USAR Section 8.5.1.1, Plant Electrical Systems - DC Power Supply Systems, Essential 250 Vdc System, Design Basis

7.

USAR Section 8.12, Plant Electrical Systems - Station Blackout

8.

USAR Figure 8.4-1, Diesel Generation System One Line Diagram

9.

NF-36175, Single Line Diagram - Station Connection

10. Tech Spec 3.8.1 (AC SOURCES - OPERATING)

11. Tech Spec 3.8.4 (DC SOURCES - OPERATING)

12. Tech Spec 3.8.7 (DISTRIBUTION SYSTEMS - OPERATING)

13. MNGP Calculation CA-02-179, 125 Volt Div. I Calculation

14. MNGP Calculation CA-02-192, 125 Volt Div. II Calculation

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 137 of 172 SS1 ECL: Site Area Emergency Initiating Condition: Loss of all offsite and all onsite AC power to essential buses for 15 minutes or longer.

Operating Mode Applicability: Power Operation, Startup, Hot Shutdown Emergency Action Levels:

NOTE:

The Emergency Director should declare the Site Area Emergency promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.

SS1.1 Loss of ALL offsite and ALL onsite AC power to essential buses 15 and 16 for 15 minutes or longer.

Basis:

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.

If a transformer is declared unavailable consider the transformer(s) not capable of supplying busses 15 and/or 16.

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

Escalation of the emergency classification level would be via ICs RG1, FG1 or SG1.

MNGP Basis Reference(s):

1.

Ops Man B.09.06-01 (4.16 KV STATION AUXILIARY - FUNCTION AND GENERAL DESCRIPTION OF SYSTEM)

2.

Ops Man C.4-B.09.02.A (STATION BLACKOUT)

3.

Ops Man C.4-B.09.02.B (LOSS OF NORMAL OFF-SITE POWER)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 138 of 172

4.

Ops Man C.4-B.09.06.C (LOSS OF BUS 15 OR BUS 16)

5.

USAR Section 8.2.1, Plant Electrical Systems - Transmission System, Network Interconnections

6.

USAR Figure 8.4-1, Diesel Generation System One Line Drawing

7.

NF-36175, Single Line Diagram - Station Connection

8.

Tech Spec 3.8.1 (AC SOURCES - OPERATING)

9.

Tech Spec 3.8.7 (DISTRIBUTION SYSTEMS - OPERATING)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 139 of 172 SS5 ECL: Site Area Emergency Initiating Condition: Inability to shutdown the reactor causing a challenge to RPV water level or RCS heat removal.

Operating Mode Applicability: Power Operation Emergency Action Levels:

SS5.1

a. An automatic or manual scram did not reduce reactor power to less than 4%.

AND

b. All manual actions to shutdown the reactor are not successful in reducing reactor power to less than 4%.

AND

c. EITHER of the following conditions exist:

Reactor vessel water level cannot be restored and maintained above -150 (Minimum Steam Cooling RPV Water Level)

Heat Capacity Limit (HCL) exceeded Basis:

This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor scram 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.

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 shutdown the reactor. The inclusion of this IC and EAL ensures the timely declaration of a Site Area Emergency in response to prolonged failure to shutdown the reactor.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 140 of 172 A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.

Escalation of the emergency classification level would be via IC RG1 or FG1.

MNGP Basis Reference(s):

1.

C.5.1-1001 (EOP TECHNICAL BASES (MODES 1, 2, 3))

2.

C.5-3101 (ALTERNATE ROD INSERTION)

3.

C.4-A (REACTOR SCRAM)

4.

USAR Table 7.6-1, Typical Reactor Protection System Scram Setpoints

5.

Tech Spec Table 3.3.1.1-1 (REACTOR PROTECTION SYSTEM INSTRUMENTATION)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 141 of 172 SS8 ECL: Site Area Emergency Initiating Condition: Loss of all Vital DC power for 15 minutes or longer.

Operating Mode Applicability: Power Operation, Startup, Hot Shutdown Emergency Action Levels:

NOTE:

The Emergency Director should declare the Site Area Emergency promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.

SS8.1 Indicated voltage is less than 110 VDC on ALL 125 VDC Vital DC buses for 15 minutes or longer.

Basis:

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.

The indicated voltage used in this threshold is based on battery sizing calculations.

The threshold is an average for both Division I and II batteries for battery voltages at 15 minutes prior to reaching the minimum required terminal voltage.

The Division I and II - 250 VDC battery systems need not be considered in this EAL because they supply power to large motor loads in the RCIC and HPCI systems and various non-critical loads. RCIC is an alternative source of make-up water for the reactor during normal plant shutdowns and transient events which lead to a loss of feedwater flow. HPCI is part of the Emergency Core Cooling System (ECCS) network. However, the Auto Depressurization System (ADS) is redundant in function to the HPCI system and does not require 250 VDC for operations. Therefore, these systems need not be included in this EAL since loss of the 250 VDC battery systems would not cause core uncovering or loss of containment integrity.

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

Escalation of the emergency classification level would be via ICs RG1, FG1 or SG8.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 142 of 172 MNGP Basis Reference(s):

1.

USAR Section 8.5.1, Plant Electrical Systems - DC Power Supply Systems, Essential 250 Vdc System

2.

USAR Section 8.5.2, Plant Electrical Systems - DC Power Supply Systems, 125 Vdc System

3.

NE-36640-2, 125VDC Distribution Electrical Scheme

4.

MNGP Calculation CA-02-179, 125 Volt Div. I Calculation

5.

MNGP Calculation CA-02-192, 125 Volt Div. II Calculation

6.

Tech Spec 3.8.4 (DC SOURCES - OPERATING)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 143 of 172 SA1 ECL: Alert Initiating Condition: Loss of all but one AC power source to essential buses for 15 minutes or longer.

Operating Mode Applicability: Power Operation, Startup, Hot Shutdown Emergency Action Levels:

NOTE:

The Emergency Director should declare the Alert promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.

SA1.1

a. AC power capability to essential buses 15 and 16 is reduced to a single power source (Table S1) for 15 minutes or longer.

AND

b. Any additional single power source failure will result in a loss of all AC power to SAFETY SYSTEMS.

Table S1 1R Reserve Transformer 1AR Reserve Transformer 2R Auxiliary Transformer

1. 11 Emergency Diesel Generator

1. 12 Emergency Diesel Generator Basis:

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.

This IC describes a significant degradation of offsite and onsite AC power sources (Table S1) 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

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 144 of 172 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 essential 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 emergency power sources (e.g., onsite diesel generators) with a single train of essential buses being back-fed from an offsite power source.

If a transformer is declared unavailable consider the transformer(s) not capable of supplying busses 15 and/or 16.

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.

MNGP Basis Reference(s):

1.

Ops Man B.09.06-01 (4.16 KV STATION AUXILIARY - FUNCTION AND GENERAL DESCRIPTION OF SYSTEM)

2.

Ops Man C.4-B.09.02.A (STATION BLACKOUT)

3.

Ops Man C.4-B.09.02.B (LOSS OF NORMAL OFF-SITE POWER)

4.

Ops Man C.4-B.09.06.C (LOSS OF BUS 15 OR BUS 16)

5.

USAR Section 8.2.1, Plant Electrical Systems - Transmission System, Network Interconnections

6.

USAR Figure 8.4-1, Diesel Generation System One Line Diagram

7.

NF-36175, Single Line Diagram - Station Connection

8.

Tech Spec 3.8.1 (AC SOURCES - OPERATING)

9.

Tech Spec 3.8.7 (DISTRIBUTION SYSTEMS - OPERATING)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 145 of 172 SA2 ECL: Alert Initiating Condition: UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress.

Operating Mode Applicability: Power Operation, Startup, Hot Shutdown Emergency Action Levels:

NOTE:

The Emergency Director should declare the Alert promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.

SA2.1

a. An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the Control Room for 15 minutes or longer.

Reactor Power RPV Water Level RPV Pressure Primary Containment Pressure Suppression Pool Level Suppression Pool Temperature AND

b. ANY of the following transient events in progress.

Automatic or manual runback greater than 25% thermal reactor power Electrical load rejection greater than 25% full electrical load Reactor scram ECCS actuation Thermal power oscillations greater than 10%

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 146 of 172 Basis:

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.

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, RPV level 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 RPV water level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well.

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

Escalation of the emergency classification level would be via ICs FS1 or IC RS1.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 147 of 172 MNGP Basis Reference(s):

1.

Ops Man C.4-B.05.13.A (LOSS OF ANNUNCIATOR)

2.

Ops Man B.05.10 (PROCESS COMPUTER)

3.

USAR Section 7.1, Plant Instrumentation and Control Systems - Summary Description

4.

USAR Section 7.13, Plant Instrumentation and Control Systems - Safety Parameter Display System

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 148 of 172 SA5 ECL: Alert Initiating Condition: Automatic or manual scram fails to shutdown the reactor, and subsequent manual actions taken at the main control boards are not successful in shutting down the reactor.

Operating Mode Applicability: Power Operation NOTE:

A manual 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.

Emergency Action Levels:

SA5.1

a. An automatic or manual scram did not reduce reactor power to less than 4%.

AND

b. Manual actions taken at the main control boards are not successful in reducing reactor power to less than 4%.

Basis:

This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor scram that results in a reactor shutdown, and subsequent operator manual actions taken at the main control boards (C-05) 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 main control boards since this event entails a significant failure of the RPS.

A manual action at the main control boards is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., see SU5).

This action does not include 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 main control boards (e.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 main control boards.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 149 of 172 Taking the Reactor Mode Switch to SHUTDOWN is considered to be a manual scram action.

The plant response to the failure of an automatic or manual reactor scram 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 shutdown the reactor is prolonged enough to cause a challenge to the RPV water level or RCS heat removal safety functions, the emergency classification level will escalate to a Site Area Emergency via IC SS5. Depending upon plant responses and symptoms, escalation is also possible via IC FS1. Absent the plant conditions needed to meet either IC SS5 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. The MNGP EOP entry condition for a failure to scram is defined to be a power above the APRM downscale setpoint (4%) following a reactor scram indicates that significant power is being generated. If a scram is successful, reactor power will be indicated to be less than 4%. Therefore, reducing power to LESS THAN 4% is used in SA5.1 as indication that a scram was successful.

MNGP Basis Reference(s):

1.

C.4-A (REACTOR SCRAM)

2.

C.5.1-1001 (EOP TECHNICAL BASES (MODES 1, 2, 3))

3.

C.5-3101 (ALTERNATE ROD INSERTION)

4.

USAR Table 7.6-1, Typical Reactor Protection System Scram Setpoints

5.

Tech Spec Table 3.3.1.1-1 (REACTOR PROTECTION SYSTEM INSTRUMENTATION)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 150 of 172 SA9 ECL: Alert Initiating Condition: Hazardous event affecting a SAFETY SYSTEM needed for the current operating mode.

Operating Mode Applicability: Power Operation, Startup, Hot Shutdown Emergency Action Levels:

NOTE:

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

NOTE:

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.

SA9.1

a. The occurrence of ANY of the following hazardous events:

Seismic event (Earthquake)

Internal or external flooding event High winds or tornado strike FIRE EXPLOSION River level greater than 919 ft el.

River level less than 900.5 ft el.

Other events with similar hazard characteristics as determined by the Shift Manager AND

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 151 of 172

b. 1. Event damage has caused indications of degraded performance on one train of a SAFETY SYSTEM needed for the current operating mode.

AND

2. EITHER of the following:

Event damage has caused indications of degraded performance to a 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.

Basis:

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

Such events may require a post-event inspection to determine if the attributes of an explosion are present.

FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES.

Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.

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.

VISIBLE DAMAGE: Damage to a SAFETY SYSTEM 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.

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

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 152 of 172 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 for criteria SA9.1.b.1 of this EAL; 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.

Operators will make a determination of VISIBLE DAMAGE 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 SAFETY SYSTEMS or SAFETY SYSTEM trains (i.e., there are indications of degraded performance and/or VISIBLE DAMAGE affecting the common equipment) should be classified as an Alert under CA6 or SA9, as appropriate to the plant mode. By affecting the operability or reliability of multiple system trains, the loss of the common equipment effectively meets the two-train impact criteria that underlie the EALs and Basis.

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 CA6 or SA9 because the two-train impact criteria that underlie the EALs and Basis 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/Emergency Director 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 CA6 or SA9, as appropriate to the plant mode. This approach maintains consistency with the two-train impact criteria that underlie the EALs and Basis, and is warranted because the event was severe enough to affect the operability or reliability 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.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 153 of 172 Escalation of the emergency classification level would be via IC FS1 or RS1.

MNGP Basis Reference(s):

1.

Ops Man A.6 (ACTS OF NATURE)

2.

Ops Man B.05.14 (SEISMIC MONITORING SYSTEM)

3.

Ops Man B.05.16-01 (METEOROLOGICAL MONITORING - FUNCTION &

GENERAL DESCRIPTION OF SYSTEM)

4.

Ops Man B.06.04 (CIRCULATING WATER SYSTEM)

5.

C.4-B.05.14.A (EARTHQUAKE)

6.

C.6-006-C-08 (EARTHQUAKE)

7.

C.6-006-C-13 (OPERATIONAL BASIS EARTHQUAKE)

8.

USAR Section 10.3, Plant Auxiliary Systems - Plant Service Systems

9.

USAR Section 12.2, Plant Structures and Shielding, Plant Principal Structures and Foundations

10. USAR Appendix G, Chapter 3, Probable Maximum Flood Determination

11. USAR Table I.5-1, Location of High Energy Systems and Safe Shutdown Equipment by Volume

12. USAR Appendix J.4, Fire Protection Program - Safe Shutdown Analysis

13. ND-95208, Monticello Property Map

14. ND-95209, Monticello Main Plant Structures

15. 4 AWI-01.03.01 (QUALITY ASSURANCE PROGRAM BOUNDARY)

16. EC 25005, External Flooding Emergency Action Level Basis

17. NEI 99-01, Development of Emergency Action Levels for Non-Passive Reactors, Revision 6 and EPFAQ 2018-004.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 154 of 172 SU1 ECL: Notification of Unusual Event Initiating Condition: Loss of all offsite AC power capability to essential buses for 15 minutes or longer.

Operating Mode Applicability: Power Operation, Startup, Hot Shutdown Emergency Action Levels:

NOTE:

The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.

SU1.1 Loss of ALL offsite AC power capability (Table S2) to essential buses 15 and 16 for 15 minutes or longer.

Table S2 1R Reserve Transformer 1AR Reserve Transformer 2R Auxiliary Transformer Basis:

This IC addresses a prolonged loss of offsite power (Table S2). The loss of offsite power sources renders the plant more vulnerable to a complete loss of power to AC essential 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 essential buses, whether or not the buses are powered from it.

If a transformer is declared unavailable consider the transformer(s) not capable of supplying busses 15 and/or 16.

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.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 155 of 172 MNGP Basis Reference(s):

1.

Ops Man B.09.06-01 (4.16 KV STATION AUXILIARY - FUNCTION AND GENERAL DESCRIPTION OF SYSTEM)

2.

Ops Man C.4-B.09.02.A (STATION BLACKOUT)

3.

Ops Man C.4-B.09.02.B (LOSS OF NORMAL OFF-SITE POWER)

4.

Ops Man C.4-B.09.06.C (LOSS OF BUS 15 OR BUS 16)

5.

USAR Section 8.2.1, Plant Electrical Systems - Transmission System, Network Interconnections

6.

USAR Figure 8.4-1, Diesel Generation System One Line Diagram

7.

NF-36175, Single Line Diagram - Station Connection

8.

Tech Spec 3.8.1 (AC SOURCES - OPERATING)

9.

Tech Spec 3.8.7 (DISTRIBUTION SYSTEMS - OPERATING)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 156 of 172 SU2 ECL: Notification of Unusual Event Initiating Condition: UNPLANNED loss of Control Room indications for 15 minutes or longer.

Operating Mode Applicability: Power Operation, Startup, Hot Shutdown Emergency Action Levels:

NOTE:

The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.

SU2.1 An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the Control Room for 15 minutes or longer.

Reactor Power RPV Water Level RPV Pressure Primary Containment Pressure Suppression Pool Level Suppression Pool Temperature Basis:

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.

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

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 157 of 172 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, RPV level 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 RPV water level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well.

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

Escalation of the emergency classification level would be via IC SA2.

MNGP Basis Reference(s):

1.

Ops Man C.4-B.05.13.A (LOSS OF ANNUNCIATOR)

2.

Ops Man B.05.10 (PROCESS COMPUTER)

3.

USAR Section 7.1, Plant Instrumentation and Control Systems - Summary Description

4.

USAR Section 7.13, Plant Instrumentation and Control Systems - Safety Parameter Display System

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 158 of 172 SU3 ECL: Notification of Unusual Event Initiating Condition: Reactor coolant activity greater than Technical Specification allowable limits.

Operating Mode Applicability: Power Operation, Startup, Hot Shutdown Emergency Action Levels: (SU3.1 or SU3.2)

SU3.1 Offgas Pretreatment Radiation Monitor (RM-17-150A or RM-17-150B) high radiation alarm (4-A-12) received.

SU3.2 Coolant sample activity greater than 0.2 µCi/gm dose equivalent I-131.

Basis:

This IC addresses a reactor coolant activity value that exceeds an allowable limit specified in Technical Specifications. This condition is a precursor to a more significant event and represents a potential degradation of the level of safety of the plant.

For EAL SU3.1 the Offgas high radiation alarm received from RM-17-150A or RM 150B is set to meet the Technical Specification allowable limit of less than or equal to 2.6E+5 µCi/sec after decay of 30 minutes.

EAL SU3.2 addresses reactor coolant samples exceeding coolant Technical Specifications.

Escalation of the emergency classification level would be via ICs FA1 or the Recognition Category R ICs.

MNGP Basis Reference(s):

1.

Ops Man B.07.02.02-01 (OFF-GAS HOLDUP SYSTEM - FUNCTION &

GENERAL DESCRIPTION OF SYSTEM)

2.

C.6-004-A-12 (OFF-GAS HI RADIATION)

3.

Tech Spec 3.4.6 (RCS SPECIFIC ACTIVITY)

4.

Tech Spec 3.7.6 (MAIN CONDENSER OFFGAS)

5.

Tech Spec 3.10.1 (INSERVICE LEAK AND HYDROSTATIC TESTING OPERATION)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 159 of 172 SU4 ECL: Notification of Unusual Event Initiating Condition: RCS leakage for 15 minutes or longer.

Operating Mode Applicability: Power Operation, Startup, Hot Shutdown Emergency Action Levels: (SU4.1 or SU4.2 or SU4.3)

NOTE:

The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.

SU4.1 RCS unidentified or pressure boundary leakage greater than 10 gpm for 15 minutes or longer.

SU4.2 RCS identified leakage greater than 25 gpm for 15 minutes or longer.

SU4.3 Leakage from the RCS to a location outside primary containment greater than 25 gpm for 15 minutes or longer.

Basis:

This IC addresses RCS leakage which may be a precursor to a more significant event.

In this case, RCS leakage has been detected and operators, following applicable procedures, have been unable to promptly isolate the leak. This condition is considered to be a potential degradation of the level of safety of the plant.

EAL SU4.1 and EAL SU4.2 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). EAL SU4.3 addresses a RCS mass loss caused by an UNISOLABLE leak through an interfacing system. These EALs thus apply to leakage into the containment or a location outside of containment.

The leak rate values for each EAL were selected because they are usually observable with normal Control Room indications. Lesser values typically require time-consuming calculations to determine (e.g., a mass balance calculation). EAL SU4.1 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. A stuck-open Safety Relief

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 160 of 172 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 R or F.

MNGP Basis Reference(s):

1.

Ops Man C.4-B.04.01.F (LEAK INSIDE PRIMARY CONTAINMENT)

2.

Ops Man C.6-004-B-03 (DRYWELL SUMP VALVES CLOSED)

3.

Ops Man C.6-004-B-17 (DRYWELL FLOOR DRAIN SUMP HI LEVEL)

4.

Ops Man C.6-004-B-18 (DRYWELL EQUIP DRAIN LEAK RATE CHANGE HI)

5.

Tech Spec 3.4.4 (RCS OPERATIONAL LEAKAGE)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 161 of 172 SU5 ECL: Notification of Unusual Event Initiating Condition: Automatic or manual scram fails to shutdown the reactor.

Operating Mode Applicability: Power Operation NOTE:

A manual 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.

Emergency Action Levels: (SU5.1)

SU5.1

a. An initial automatic or manual scram did not reduce reactor power to less than 4%.

AND

b. ANY of the following is successful in reducing reactor power to less than 4%:

Manual scram pushbuttons Mode switch to shutdown Alternate rod insertion (ARI)

Subsequent automatic scram Basis:

This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor scram that results in a reactor shutdown, and either a subsequent operator manual action taken at the main control boards (C-05) or an automatic scram is successful in shutting down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.

Following the failure on an automatic reactor scram, operators will promptly initiate manual actions at the main control boards to shutdown the reactor (e.g., initiate a manual reactor scram). If these manual actions are successful in shutting down the

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 162 of 172 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 scram is unsuccessful, operators will promptly take manual action at another location(s) on the main control boards to shutdown the reactor (e.g.,

manual scram pushbuttons, mode switch to Shutdown, Alternate Rod Insertion (ARI))

using a different switch). Depending upon several factors, the initial or subsequent effort to manually scram the reactor, or a concurrent plant condition, may lead to the generation of an automatic reactor scram signal. If a subsequent manual or automatic scram 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 main control boards 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 scram). This action does not include 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 main control boards.

Taking the Reactor Mode Switch to SHUTDOWN is considered to be a manual scram action.

The plant response to the failure of an automatic or manual reactor scram 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 main control boards 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.

Should a reactor scram 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 scram 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 scram 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.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 163 of 172 MNGP Basis Reference(s):

1.

C.4-A (REACTOR SCRAM)

2.

C.5.1-1001 (EOP TECHNICAL BASES (MODES 1, 2, 3))

3.

C.5-3101 (ALTERNATE ROD INSERTION)

4.

USAR Table 7.6-1, Typical Reactor Protection System Scram Setpoints

5.

Tech Spec Table 3.3.1.1-1 (REACTOR PROTECTION SYSTEM INSTRUMENTATION)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 164 of 172 SU6 ECL: Notification of Unusual Event Initiating Condition: Loss of all onsite or offsite communications capabilities.

Operating Mode Applicability: Power Operation, Startup, Hot Shutdown Emergency Action Levels: (SU6.1 or SU6.2 or SU6.3)

SU6.1 Loss of ALL of the following onsite communication methods:

Commercial Telephones Plant Telephones Portable radios Plant PA System SU6.2 Loss of ALL of the following Offsite Response Organization (ORO) communications methods:

Commercial Telephones Direct Dedicated Telephones Radio/Receiver Transmitter SU6.3 Loss of ALL of the following NRC communications methods:

Federal Telecommunications System (FTS)

Commercial Telephones 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 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.).

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 165 of 172 EAL SU6.1 addresses a total loss of the communications methods used in support of routine plant operations.

EAL SU6.2 addresses a total loss of the communications methods used to notify all OROs of an emergency declaration. The OROs referred to here are the State of Minnesota, Wright County, and Sherburne County.

EAL SU6.3 addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.

MNGP Basis Reference(s):

1.

USAR Section 10.3.8, Plant Auxiliary Systems - Plant Service Systems, Plant Communications System

2.

MNGP Emergency Plan Section 7.2 - Communication Systems

3.

MNGP Emergency Plan Figure 13.7 - Direct Dedicated Telephones (Hot Lines)

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 166 of 172 Appendix A ACRONYMS AND ABBREVIATIONS AC....................................................................................................... Alternating Current AOP.................................................................................. Abnormal Operating Procedure APRM.................................................................................. Average Power Range Meter ARI................................................................................................ Alternate Rod Insertion ATWS...................................................................... Anticipated Transient Without Scram BWR............................................................................................... Boiling Water Reactor CDE....................................................................................... Committed Dose Equivalent CFR...................................................................................... Code of Federal Regulations CTMT/CNMT................................................................................................. Containment DBA................................................................................................ Design Basis Accident DBE........................................................................................... Design Basis Earthquake DC............................................................................................................... Direct Current DSC...................................................................................................... Dry Shielded Cask EAL............................................................................................. Emergency Action Level ECCS........................................................................... Emergency Core Cooling System ECL.................................................................................. Emergency Classification Level EFT.............................................................................................. Exhaust Filtration Train EOF................................................................................... Emergency Operations Facility EOP............................................................................... Emergency Operating Procedure EPA.............................................................................. Environmental Protection Agency EPG................................................................................ Emergency Procedure Guideline EPIP................................................................ Emergency Plan Implementing Procedure EPRI.............................................................................. Electric Power Research Institute ERG............................................................................... Emergency Response Guideline FAA.................................................................................. Federal Aviation Administration FBI.................................................................................... Federal Bureau of Investigation FEMA.............................................................. Federal Emergency Management Agency FPB............................................................................................... Fission Product Barrier FSAR.................................................................................... Final Safety Analysis Report GE..................................................................................................... General Emergency HCL.................................................................................................... Heat Capacity Limit HOO................................................................................ Headquarters Operation Officer

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 167 of 172 Appendix A CONTD ACRONYMS AND ABBREVIATIONS HPCI................................................................................ High Pressure Coolant Injection HSM........................................................................................ Horizontal Storage Module IC.......................................................................................................... Initiating Condition ID.............................................................................................................. Inside Diameter IPEEE................. Individual Plant Examination of External Events (Generic Letter 88-20)

ISFSI............................................................Independent Spent Fuel Storage Installation Keff........................................................................ Effective Neutron Multiplication Factor LCO.................................................................................. Limiting Condition of Operation LOCA......................................................................................... Loss of Coolant Accident MCR................................................................................................... Main Control Room MSIV...................................................................................... Main Steam Isolation Valve MSL........................................................................................................ Main Steam Line mR, mRem, mrem, mREM............................................... milli-Roentgen Equivalent Man MW..................................................................................................................... Megawatt NEI.............................................................................................. Nuclear Energy Institute NPP................................................................................................... Nuclear Power Plant NRC............................................................................... Nuclear Regulatory Commission NSSS................................................................................ Nuclear Steam Supply System NORAD................................................... North American Aerospace Defense Command NSPM................................... Northern States Power Company, a Minnesota corporation

......................................................................................... doing business as Xcel Energy NUE..................................................................................... Notification Of Unusual Event OBE....................................................................................... Operating Basis Earthquake OCA.............................................................................................. Owner Controlled Area ODCM/ODAM......................................... Offsite Dose Calculation (Assessment) Manual ORO................................................................................ Off-site Response Organization PA............................................................................................................. Protected Area PAG........................................................................................ Protective Action Guideline PCIS..................................................................... Primary Containment Isolation System PRA/PSA...................... Probabilistic Risk Assessment / Probabilistic Safety Assessment PSIG................................................................................ Pounds per Square Inch Gauge

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 168 of 172 Appendix A CONTD ACRONYMS AND ABBREVIATIONS R......................................................................................................................... Roentgen RCC........................................................................................... Reactor Control Console RCIC................................................................................. Reactor Core Isolation Cooling RCS.............................................................................................Reactor Coolant System Rem, rem, REM...................................................................... Roentgen Equivalent Man RETS......................................................... Radiological Effluent Technical Specifications RHR............................................................................................. Residual Heat Removal RPS......................................................................................... Reactor Protection System RPV............................................................................................ Reactor Pressure Vessel RVLIS........................................................ Reactor Vessel Level Instrumentation System RWCU.......................................................................................... Reactor Water Cleanup SAE................................................................................................. Site Area Emergency SAMG...............................................................Severe Accident Management Guidelines SAR............................................................................................... Safety Analysis Report SBO......................................................................................................... Station Blackout SCBA...................................................................... Self-Contained Breathing Apparatus SPDS........................................................................... Safety Parameter Display System SRO........................................................................................... Senior Reactor Operator SRV..................................................................................................... Safety Relief Valve TAF...................................................................................................... Top of Active Fuel TBNWS................................................................. Turbine Building Normal Waste Sump TEDE................................................................................ Total Effective Dose Equivalent TSC........................................................................................... Technical Support Center USAR.............................................................................. Updated Safety Analysis Report

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 169 of 172 Appendix B DEFINITIONS The following definitions are taken from Title 10, Code of Federal Regulations, and related regulatory guidance documents.

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 PAG exposure levels.

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

Notification of Unusual Event (NUE): 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.

Site Area Emergency (SAE): 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.

The following are key terms necessary for overall understanding the NEI 99-01 emergency classification scheme.

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.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 170 of 172 Appendix B CONTD DEFINITIONS 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 (NUE)

Alert Site Area Emergency (SAE)

General Emergency (GE)

Fission Product Barrier Threshold: A pre-determined, site-specific, observable threshold indicating the loss or potential loss of a fission product barrier.

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.

Selected terms used in Initiating Condition and Emergency Action Level statements 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.

CONFINEMENT BOUNDARY: The barrier(s) between areas containing spent fuel and the environment once the spent fuel is processed for dry storage.

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

Such events may require a post-event inspection to determine if the attributes of an explosion are present.

FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES.

Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.

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

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 171 of 172 Appendix B CONTD DEFINITIONS HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included. HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).

HOSTILE FORCE: 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.

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.

ISFSI PROTECTED AREA: The area surrounding the Independent Spent Fuel Storage Installation encompassed by the double chain link fence surrounding the ISFSI as defined in the Security Plan; the ISFSI Protected Area is excluded from the Plant Protected Area.

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: The OCA boundaries consist of the plant property enclosed by a three strand barbed wire fence and a posted boundary on the Wright County side of the river.

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

PROTECTED AREA: The area surrounding the plant encompassed by the chain link fence and certain structures as defined in the Security Plan; excludes the ISFSI Protected Area. In areas where two fences are present, the inner fence is designated as the Protected Area barrier.

REFUELING PATHWAY: The reactor refueling cavity, spent fuel pool, or fuel transfer canal.

Monticello Emergency Action Level (EAL) Technical Basis Document Revision: 3 EPLAN-04 Page 172 of 172 Appendix B CONTD DEFINITIONS SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

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

SECONDARY CONTAINMENT: SECONDARY CONTAINMENT includes the Reactor Building (including the HPCI Building), the Standby Gas Treatment System, the Offgas Dilution Fans, and connecting pipes and ducts. SECONDARY CONTAINMENT is isolated along with an automatic initiation of the Standby Gas Treatment System to minimize radiological releases to the environment.

SITE BOUNDARY: For Dose Assessment and Protective Action Recommendation purposes the SITE BOUNDARY is the closest distance at which members of the public would be exposed to a radioactive release. The SITE BOUNDARY for liquid releases of radioactive material is defined in ODCM-02.01 (LIQUID EFFLUENTS).

The SITE BOUNDARY for gaseous releases of radioactive material is defined in ODCM-03.01 (GASEOUS EFFLUENTS).

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

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

VISIBLE DAMAGE: Damage to a SAFETY SYSTEM 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.