ML033160039

Transmittal of Revisions to Emergency Plan Implementing Procedures for Callaway Plant

ML033160039
Person / Time
Site:	Callaway
Issue date:	11/03/2003
From:	AmerenUE
To:	Document Control Desk, Office of Nuclear Reactor Regulation
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Download: ML033160039 (111)

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DATE: 11/03/03 AMEREN/UE PAGE: 60 TIME: 09:04:17 DOCUMENT CONTROL SYSTEM ARDC8801 DOCUMENT TRANSMITTAL TRANSMITTAL NUMBER: 517498 RETURN ACKNOWLEDGED TRANSMITTAL AND TO CONTROL NUMBER: 338U SUPERSEDED DOCUMENTS (IF APPLICABLE) TO:

TITLE: OTHER ADMINISTRATION RECORDS DEPT: NUCLEAR REGULATORY COMM. AMEREN/UE LOCATION: USNRC - WASH DC CALLAWAY PLANT TRANSMITTAL DATE: 20031103 P.O. BOX 620 FULTON, MO 65251 TRAN DOC RET ALT ALT CODE TYPE DOCUMENT NUMBER REV REV MED COPY MED COPY AFFECTED DOCUMENT R PROC EIP-ZZ-A---1 007 006 C 1 R PROC EIP-ZZ-00101 031 030 C 1 R PROC EIP-ZZ-00102 031 030 C 1 R PROC EIP-ZZ-00200 011 010 C 1 ACKNOWLEDGED BY: DATE:

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EIP-ZZ-A0001 Revision 007 October 15, 2003 CALLAWAY PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURE EIP-ZZ-A0001 EMERGENCY RESPONSE ORGANIZATION RESPONSIBLE DEPARTMENT Emerieencv Preparedness PROCEDURE OWNER D.R. Lewis WRITTEN BY D. R. Lewis PREPARED BY S. J. Crawford APPROVED BY I&aA@Jv S DATE ISSUED Ii 36b ACCOUNTABLE This procedure contains the following: win Pages 1 through 8 Attachments 1 through 1 Tables through Figures through Appendices 1 through 1 Checkoff Lists through This procedure has checkoff list(s) maintained in the mainframe computer.

Conversion of commitments to TRS reference/hidden text completed by Revision Number:

Non-T/S Commitments 003

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EIP-ZZ-A0001 Rev. 007 TABLE OF CONTENTS Section Page Number 1 PURPOSE AND SCOPE' 1 2 DEFINITIONS 1 3 RESPONSIBILITIES 2 4 PROCEDURE 6 5 REFERENCES 8 II 6 RECORDS 8 Emergency Response Organization Maintenance Form, 1 Page CA-#2448 Appendix 1 Departmental/ERO Position Ownership Listing 2 Pages EIP-ZZ-AO001 Rev. 007 EMERGENCY RESPONSE ORGANIZATION 1 PURPOSE AND SCOPE 1.1 This procedure defines the activities necessary to maintain the Emergency Response Organization (ERO). Additionally it identifies the expectations of Callaway Plant personnel to support the adequate staffing of the ERO.

2 DEFINITIONS 2.1 Emergency Response Organization (ERO) Position Owner -

Department Head or individual selected by the Dept Head to be responsible for identifying individuals to be trained, qualified and staff the (ERO) positions for which the department is responsible.

2.2 Emergency Response Personnel - Personnel designated, trained, qualified, and assigned to fill specific Emergency Response Organization (ERO) positions. They staff the Emergency Response Facilities to make them capable of fulfilling all intended emergency functions. Emergency Response Personnel may be duty responders, non-duty responders or as needed responders.

2.3 "As Needed" Personnel - Some Emergency Response Personnel are identified as "as needed" on Table 5 of the Radiological Emergency Response Plan (RERP). "As Needed" responders are notified to respond by manual callout as requested by their respective coordinator or supervisor.

2.4 Duty Responders - Emergency Response Personnel are assigned for rotating on-call coverage. They are scheduled for duty around the clock to ensure adequate response during off normal working hours. When on duty, they remain fit for duty, maintain their pager within hearing distance, and remain within the identified response time goal from their Emergency Response Facility.

In the event of an actual emergency, Duty Responders that are not on duty, but fit for duty and able to respond are also required to respond as Non Duty Responders.

2.5 Non-Duty Responders - Emergency Response Personnel that are not on a duty schedule but are expected to respond at all times to emergency or drill pages, if fit-for-duty, and within the response goal times. These are also referred to "pool" positions.

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EIP-ZZ-AOOO1 Rev. 007 2.6 Rapid Responders - Pre-designated Duty Responders assigned to positions to relieve the On-shift personnel of emergency functions not directly related to operation of the Plant.

2.7 Emergency Response Organization - An organization that has been established to provide managerial, technical and logistical support in the event of a radiological emergency declaration at the Callaway Plant. This organization is structured to provide control and coordination of on-site response, coordination of off-site response and dissemination of information to the public.

2.8 Emergency Response Organization Staffing Levels - The desired or optimum staffing level for the Emergency Response Organization is to maintain six (6) individuals qualified in each emergency response position identified in the RERP, chapter 5.

The minimum acceptable staffing level is three (3) qualified individuals per position.

2.9 Mobilization - The process of staffing the Emergency Response Facilities with the Emergency Response Organization. This process is initiated by announcements over Plant Gai-tronics System and activation of the Cellular Paging System.

3 RESPONSIBILITIES 3.1 Emersencv Preparedness (EP) Dent. - Emergency Preparedness is responsible for:

3.1.1 Assisting the Department Heads or ERO Position Owners in maintaining the optimum staffing level of the ERO. This will include as a minimum, a periodic review in the last quarter of each year.

3.1.2 Coordinating with Operations, Training, and the Training Simulator Group at the end of each calendar year, to develop the drill schedule for the upcoming year and publish it. (Some drills are required to be unannounced.)

3.1.3 Developing, controlling and evaluating drills for the ERO. Other ERO members may assist in this function as requested by EP.

3.2 ERO Position Owner - This responsibility may be maintained by the Department Head of the department that "owns" the ERO position or may be delegated to a designee. The responsibility of ERO position owner is as follows:

EIP-ZZ-AOOOI Rev. 007 3.2.1 Designate individuals to fill the respective ERO position(s) identified in Appendix 1. Staffing levels for the ERO positions are included in section 2.8 of this procedure. This includes filling any position vacancies due to transfers, rotations, retirements, or terminations.

3.2.2 Ensure personnel in the respective ERO positions are aware of their ERO position designation and that they maintain their ERO qualifications.

3.2.3 Coordinate with Emergency Preparedness and identify who will be participating in drills and Exercises as participants and as controllers.

3.2.4 Inform Emergency Preparedness clerk when personnel have been designated to the ERO position and when personnel will be removed from the ERO position.

3.3 ERO Team Owners - These are the Emergency Coordinators (ECs) for the TSC responders or Recovery Managers (RMs) for the EOF and JPIC responders. They have responsibility for:

• The performance of their team.

• Coordination with the ERO Position Owner to review any changes to responders assigned to their team.

3.4 Superintendent Protective Services - The Superintendent of Protective Services or his designee has the responsibility to:

• monitor the ERO staffing levels periodically,

• have specific ERO codes assigned to the selected responders;

• verify the training requirements identified in EIP-ZZ-AO066, RERP Training Program, have been completed prior to assigning the individual to an active responder position in the ERO,

• approve revisions to Appendix 1.

NOTE: Complete qualification requirements for individuals being assigned to the ERO, will be verified prior to assignment to an ERO position and assigning an ERO code.

3.5 Emergency Preparedness Clerk - When directed, the EP Clerk or designee will assign the appropriate ERO code in the ERO and Personnel databases. The clerk or designee will also arrange for the assignment of an ERO pager for the new responder.

EIP-ZZ-A0001 Rev. 007 3.6 Emergencv Response Organization (ERO) Members -

Members have the following specific responsibilities:

3.6.1 Maintaining qualifications and requalifications as per EIP-ZZ-A0066.

3.6.2 Being aware, that if declared pregnant, they should not respond to any declared emergency and that their ERO code will be inactivated. (CARS 200000370) 3.6.3 Being aware that if their TLD is taken due to medical procedures, they should not respond to any On-site Emergency Response Facility, including the EOF, until their TLD is returned.

JPIC ERO members, except for the Technical Representatives in the EOF, should still respond even if their TLD has been taken.

(CARS 200105018) 3.6.4 Participating in required tests, drills, and exercises.

NOTE: When notified by the Plant for an Emergency, instructions are given. Any Group Pages that do not display Emergency Response Organization instructions should be disregarded.

(CARS 199802824) 3.6.4.1 The minimum response for a TEST is a phone call to the emergency Audix.

3.6.4.2 A DRILL requires that ERO personnel follow the instructions on the ERO pager. These may include augmentation call-out drills which may require a call to the emergency Audix or may require response to the Emergency Response Facility for team drills and expanded Rapid Responder drills.

3.6.4.3 An EMERGENCY requires the same response as a DRILL.

NOTE: If an ACTUAL Plant Emergency message is received, all ERO members that are fit for duty should respond.

3.6.5 Apply an ERO sticker to driver license and get a new sticker if license is renewed.

3.6.6 Duty Responders (when on duty):

EIP-ZZ-A0001 Rev. 007 3.6.6.1 Wear or maintain assigned pager within bearing range at all times..

3.6.6.2 Maintain the duty cellular phone (if assigned) available for use at all times.

3.6.6.3 Remain "fit for duty" as specified in Callaway Plant Policies and Procedures.

3.6.6.4 Maintain ability to respond to their respective Emergency Response Facility within their response time goal, as specified in the RERP.

3.6.6.5 Respond to paging instructions safely and immediately.

3.6.6.6 Ensure duty exchange and turnover is verbal.

3.6.6.7 Notify Emergency Preparedness of previously arranged trades involving one day or greater so the duty schedule can be updated.

3.6.6.8 Rapid Responders responding to the EOF should be in possession of a key to the EOF to allow quick access.

3.6.6.9 Recovery Managers/Company Spokespersons, Technical Assessment Coordinators, Off-site Liaison Coordinators/EOF Communicators, and Dose Assessment Coordinators have Rapid Responder duty responsibilities as well as other Emergency Response Organization positions, and should respond to all emergency pages if fit for duty, even if not on duty.

3.6.6.9.1 All Spokespersons that are not Recovery Managers report to the JPIC. All other Recovery Managers report to the EOF. The JPIC has a 2-hour activation commitment; this would allow time for a Recovery Manager to report to the JPIC from the EOF in the event a Spokesperson had not reported for duty.

3.6.7 Responsibilities of Non-Duty Responders:

NOTE: Non-Duty Section Responders are considered emergency responders at all times. Exceptions are when the responder is not fit for duty, sick, on vacation, or out of the response area.

3.6.7.1 Non-Duty Section Responder (all Pool Positions) are expected to maintain assigned pager within hearing range at all times.

3.6.7.2 Follow the instruction displayed on the pager in an immediate and safe manner.

EIP-ZZ-A0001 Rev. 007 4 PROCEDURE 4.1 Emerigency Response Organization (ERO)

Mobilized at the ALERT or higher emergency classification or when deemed necessary by the Shift Supervisor. The ERO augments the on-shift emergency organization and consists of the Rapid Responders and Designated Emergency Response Personnel.

4.1.1 Normal Hours. Typically during normal working hours, Monday through Friday except for holidays, assigned members of the ERO are expected to man their respective facilities within a goal of 15 minutes from the time of declaration and be ready to assume peripheral duties from the Control Room within 30 minutes.

4.1.2 Off-Normal Hours. Assigned members of the ERO are expected to respond to the appropriate Emergency Response Facility within a goal of 75 minutes or less of the ALERT Emergency Declaration or decision to callout the ERO. The goal is to relieve the Control Room of the peripheral duties within 90 minutes or less of the declaration during off-normal hours.

4.2 Maintaining the Emergencv Response Organization 4.2.1 Adding ERO Designations and Deleting ERO Designations 4.2.1.1 To add a person to the ERO or to remove a person from the ERO, the ERO Position Owner MUST use Form CA-#2448, Attachment 1.

4.2.2 ERO Staffing and Scheduling 4.2.2.1 Appendix 1 lists the ERO positions and the associated departments responsible for designating the personnel for the various positions.

4.2.2.2 The ERO Position Owners should be aware of the training qualification dates for the designated ERO personnel, the schedule of RERP training and retraining. The drill schedule is available on the EP Web Page.

4.2.2.3 RERP Retraining is scheduled annually and the ERO Position Owner should coordinate the needed ERO retraining and the training schedule to maintain the desired staffing levels for the position.

EIP-ZZ-A0001 Rev. 007 4.2.2.4 ERO Positions filled by Duty Responders will be assigned to a team by the ERO Position Owner and coordinated with the team leader.

4.2.2.5 ERO Positions filled by non-Duty Response personnel (Pool Positions) will be required to attend the annual retraining as scheduled and participate in drills as identified by the ERO Position Owner.

4.2.2.6 If an assigned ERO member is promoted, transfers between departments, or rotates to a position that does not fill an ERO position, the assigned ERO member is expected to maintain qualifications for the position until a replacement is designated and the ERO Position Owner and Team Leader agree to release the departing member and have the ERO code inactivated..

It is recommended that ERO Position Owners have an additional person or two designated for the Emergency Response Positions for which their departments are responsible. These designated personnel should be trained and prepared to be assigned to an ERO position with minimal or no preparation in the event of transfer, promotion, or departure of assigned ERO Personnel.

4.2.3 ERO Drill Participation 4.2.3.1 EP will publish the schedule of drills shortly after the start of each year.

4.2.3.2 The ERO Position Owner must ensure that the team members (Duty Responders) are scheduled for the team drills. The non-Duty Responders (Pool Positions) MUST be scheduled to provide adequate support for the ERO and the drill schedule.

Individual changes to the scheduled drill participation will be coordinated through the ERO Position Owner and Emergency Preparedness (EP).

4.2.4 Qualification Tracking 4.2.4.1 EP publishes and distributes the Emergency Telephone Directory per the Surveillance program. This is a listing of all qualified personnel assigned to specific ERO Positions at the time of the printing.

4.2.4.2 Training and EP can provide additional reports showing designated personnel and the status of their qualifications.

EIP-ZZ-A0001 Rev. 007 4.2.4.3 EP will review the staffing levels and contact the respective Department Heads or their designee if the number of qualified responders assigned to the specific ERO positions is below the optimum staffing level. This will ensure that Department Heads and ERO Position Owners are aware of position staffing levels.

5 REFERENCES 5.1 10CFR26, Fitness for Duty 5.2 10CFR50.47, Emergency Plans 5.3 10CFR50 Appendix E, Emergency Planning and Preparedness for Production and Utilization 5.4 Callaway Plant Radiological Emergency Response Plan (RERP) 5.5 NRC Reg Guide 1.101, Emergency Planning and Preparedness for Nuclear Power Reactors 5.6 NUREG 0654/FEMA-REP-01, Revision 1, November 1980 5.7 APA-ZZ-00902, Employee Personnel Changes, Termination, and/or Access Withdrawal 5.8 EIP-ZZ-A0066, RERP Training Program 6 RECORDS 6.1 0. A. Records None 6.2 Commercial Records 6.2.1 Emergency Response Organization Maintenance Form, CA-#2448 (File Number K250.0010)

EIP-ZZ-A0001 Rev. 007 EMERGENCY RESPONSE ORGANIZATION ERO POSITION MAINTENANCE FORM Name of person to be added/removed from ERO PIN Number ERO Position a When ERO ADDITION Complete - To be completed by the ERO Position Owner

1. Does the individual have color vision impairment? Yes No NOTE: If color vision impairment is identified by the individual, Fitness for DutyNurses will evaluate to determine if the impairment would prevent the individual from performing Emergency Response Organization duties. (CARS 199700904)

2. ERO Responsibilities (Section 3.6) have been discussed with the new ERO member.

3. Initial Training/Retraining has been scheduled for the new ERO member and the new ERO member is aware of the scheduled training.

4. Drill observation or Facility Walk-Through scheduled with a qualified individual (Qualified ERO member, Training Department, or Emergency Preparedness). (CARS 199803843) (May be N/A if experience warrants).

5. Team Leader accepts this person to fill the ERO position. (Emergency Coordinator for TSC positions and Recovery Manager for EOF positions.) Discussed with EC or RM.

on Name Date

6. ERO member qualified for the position in accordance with EIP-ZZ-A0066.

- To be completed by the person in the new ERO Position

1. Obtain and Apply responder sticker from EP clerk and apply to driver license. Provide form to EP Clerk.

- To be completed by the Emergency PreparednessClerk

1. Pager Assigned. Number

2. ERO Listing updated on the EP Intranet Page and Personnel Database. (ERO code is "Active Status")

V When ERO DELETION Complete - To be completed by the ERO Position Owner

1. Arrangements have been made to ensure duty section is staffed until a permanent replacement has been identified, trained, and qualified.

2. Replacement ERO member has been identified and a CA # 2448 has been initiated for replacement.

3. ERO member advised not to respond as an ERO member, unless reinstated.

- To be completed by the Emergency PreparednessClerk

1. ERO Code removed from Personnel Database and ERO member name updated on the EP Web Site

2. Pager and/or cellular telephone returned to EP Clerk.

Page I of I Attachment 1 CA-#2448

EIP-ZZ-00101 Revision 031 October 15, 2003 CALLAWAY PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURE EIP-ZZ-00101 CLASSIFICATION OF EMERGENCIES RESPONSIBLE DEPARTMENT EMERGENCY PREPAREDNESS PROCEDURE OWNER W. R. Bevard WRITTEN BY W. R. Bevard PREPARED BY S. J. Crawford APPROVED BY a i -

NO V 0 300 DATE ISSUED CCOUNTABLE This procedure contains the following:

Pages 1 through 8 Attachments 1 through 3 Tables through Figures through Appendices through Checkoff Lists through __

This procedure has checkoff list(s) maintained in the mainframe computer.

Conversion of commitments to TRS reference/hidden text completed by Revision Number:

Non-T/S Commitments 024

EIP-ZZ-00101 Rev. 031 TABLE OF CONTENTS Section Page Number 1 PURPOSE AND SCOPE 1 2 DEFINITIONS 1 3 RESPONSIBILITIES 3 4 INITIATING CONDITIONS 3 5 PROCEDURE (COMN 3384) 4 6 FINAL CONDITIONS . 7 7 REFERENCES 7 8 RECORDS 8 Emergency Action Levels 10 Pages Emergency Action Levels Indicators Bases 50 Pages ARM Dose Rates 4 Pages

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EIP-ZZ-0 01-EIP-ZZ-00101 Rev. 031 CLASSIFICATION OF EMERGENCIES I PURPOSE AND SCOPE 1.1 PURPOSE This procedure provides guidelines for classification of emergencies.

1.2 SCOPE Establishes indications for determining conditions at which specific emergency classifications are to be declared.

2 DEFINITIONS 2.1 Emergency Classifications -

• Unusual Event - This classification is characterized by events in progress or which have occurred indicating a potential degradation of the level of safety of the Plant.. No releases of radioactive material requiring off-site response or monitoring are expected unless further degradation of safety systems occurs.

• Alert - This classification is characterized by events in progress or that have occurred which involve an actual or potential substantial degradation of the level of safety of the Plant. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.

• Site Emergency - The SITE EMERGENCY class includes accidents in which major failures of Plant functions needed for*

protection of the public have occurred or are likely to occur.

Any releases are not expected to exceed EPA Protective Action Guideline exposure levels except near the site boundary.

EIP-ZZ-00101 Rev. 031

• General Emergency - The GENERAL EMERGENCY class includes accidents which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity, and other accidents that have large radioactive release potential. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels off-site for more than the immediate site area.

2.2 Safe Shutdown Area - Section 5.4A.2 of the FSAR lists the systems required to achieve and maintain a safe shutdown. The following areas contain these required systems:

• Area 5

• Containment

• Aux Feed Pump Rooms

• Aux Building

• Diesel Generator Building

• UHS Cooling Tower

• ESW Pumphouse

• Control Building

• RWST

• Fuel Building 2.3 Transient - A transient is defined as a reactor power change of

+ 10% or safety injection initiated.

2.4 Invalid - Invalid alarms and readings may be the result of electronic noise, radio frequency interference, electromagnetic frequency interference, or spurious spikes of unknown nature. A buildup of radioactivity within the monitor or an increase in the ambient background for the monitor would also cause invalid alarms and readings.

EIP-ZZ-00101 Rev. 031 2.5 Valid - Valid alarms and readings are those verified by the operators to be the results of actual events or, in the case of effluent alarms and readings, verified to be the results of effluent concentrations.

3 RESPONSIBILITIES 3.1 SHIFT SUPERVISOR 3.1.1 Upon classification of an emergency, the Shift Supervisor assumes the position of Emergency Coordinator and initiates emergency actions including making Protective Action Recommendations to authorities responsible for implementing off-site emergency measures. The Shift Supervisor assigns on-shift personnel to emergency duties as deemed necessary, and notifies the EDO of the A emergency. The Shift Supervisor continues as acting Emergency Coordinator until relieved by the EDO. When relieved, the Shift Supervisor will resume normal duties in directing Plant Operations activities from the Control room. (COMN 3314) 3.2 EMERGENCY COORDINATOR 3.2.1 The Emergency Coordinator is responsible for directing overall emergency response on-site. Initially, the Shift Supervisor assumes the responsibilities of Emergency Coordinator. At the ALERT (or higher) emergency classification levels, the EDO will relieve the Shift Supervisor and assume the Emergency Coordinator duties.

The Emergency Coordinator directs the Emergency Response Organization from the TSC after relieving the Shift Supervisor.

(COMN 3327) 3.3 PLANT PERSONNEL 3.3.1 Responsible for immediately reporting any abnormal condition or event to the Shift Supervisor.

4 INITIATING CONDITIONS This procedure is initiated when:

4.1 Alarms, abnormal instrument readings, or reports of conditions that indicate an emergency situation (either real or potential) have occurred.

EIP-ZZ-00101 Rev. 031 4.2 A subsequent action step in a plant operating off-normal, or Emergency Procedure which refers to this procedure for classification of the indicated plant conditions.

5 PROCEDURE When abnormal or emergency conditions (real or potential) occur, the Shift Supervisor SHALL: (COMN 3384)

NOTE: Initial classification should take place as soon as possible but not > 15 minutes after recognition of initiating conditions.

5.1 Ensure that immediate actions (e.g., use of Emergency Procedures, dispatch the Fire Brigade, personnel, etc.) are taken for the safe and proper operation of the plant.

5.2 Using the indications available (alarms, readings, reports, etc.) and Attachment 1, Emergency Action Levels, determine the appropriate emergency classification as follows: (COMN 42546)

NOTE: Instrumentation listed in Attachment 1 is the primary means of determining conditions; if these are inoperative, others may be substituted.

5.2.1 Refer to the "Group" (in Attachment 1) that relates to the indications being received. The groups are:

Group One - Abnormal Radiation Events Group Two - Fission Product Barriers (COMN 41525)

Group Three - Hazards Affecting Plant Safety Group Four - System Malfunctions 5.2.2 Find the corresponding indication(s) and condition(s) appropriate to the actual indication(s).

5.2.2.1 Emergency Classification can also be based upon projected conditions/indications to ensure adequate measures are taken to mitigate any consequences of the emergency. (COMN 20606)

EIP-ZZ-00101 Rev. 031 5.2.2.2 If extra personnel are desired when no conditions exist that in his opinion warrant an emergency declaration, he may have the SAS operator activate the Emergency Callout System per KOA-ZZ-00200, Activation of the Callaway Plant Emergency Callout System, for duty rapid responders using MESSAGE #2 or for all available rapid responders, ERO Coordinators, and engineers using MESSAGE #10.

5.2.2.3 The Emergency Coordinator has the option to declare an UNUSUAL EVENT, ALERT, SITE EMERGENCY or GENERAL EMERGENCY when conditions exist that in his opinion warrant the declaration. This can be independent of any specific EAL.

5.2.2.4 Specific examples of other conditions which in the judgment of the Emergency Coordinator warrant declaration of an event:

(COMN 43073) a) Each Group 2 barrier could be considered for other factors that could determine whether a barrier is Potentially Lost or Lost. In addition, the inability to monitor the barrier could be a factor in considering the barrier Potentially Lost or Lost.

b) Specific examples of events that may require Emergency Coordinator judgment for the Unusual Event:

1) Aircraft crash on-site.

2) Near site explosion which may adversely affect normal site activities.

3) Near site release of toxic or flammable gas which may adversely affect normal site activities.

4) Uncontrolled RCS cool down due to Secondary Depressurization.

5) Unplanned loss of > 75% of plant annunciators due to event(s) not covered elsewhere.

6) Safeguards security events not covered elsewhere.

EIP-ZZ-0Ol 01 Rev. 031 c) Specific examples of events that may require Emergency Coordinator judgment for the Alert:

1) Conditions exist that indicate that plant systems may be degraded, and that increased monitoring of plant functions is warranted.

2) Safeguards security events not covered elsewhere.

d) Specific examples of events that may require Emergency Coordinator judgment for the Site Emergency:

1) Conditions exist that indicate actual or likely major failures of plant functions needed for protection of the public.

e) Specific examples of events that may require Emergency Coordinator judgment for the General Emergency:

1) Conditions exist that indicate actual or imminent substantial core degradation with potential for loss of containment.

2) Conditions exist that indicate potential for uncontrolled radionuclide releases expected to exceed EPA PAG plume exposure levels outside the EAB.

3) Safeguards security events not covered elsewhere.

5.2.2.5 The possibility exists that situations may have characteristics in two or more classes. In such an event, the emergency SHALL be categorized in the more severe class to ensure a conservative approach is taken. (COMN 3383) 5.2.3 Declare the emergency classification that is listed corresponding to the condition derived from Step 5.2.2 to facility personnel.

NOTE: Initial notifications to State and Local Agencies shall be initiated within 15 minutes after declaration of the emergency classification.

EIP-ZZ-00101 Rev. 031 5.3 Perform the necessary emergency implementing actions as outlined in EIP-ZZ-00102, Emergency Implementing Actions, to ensure the proper response is taken to implement the Callaway Plant Radiological Emergency Response Plan.

NOTE: If necessary, the EDO should be contacted to discuss emergency actions.

5.4 Reclassify the emergency as conditions dictate in accordance with this procedure.

6 FINAL CONDITIONS 6.1 Event Closeout or Plant Recovery has been declared per EIP-ZZ-00260, Event Closeout/Plant Recovery.

7 REFERENCES 7.1 Callaway Plant Radiological Emergency Response Plan 7.2 NUREG-0818, Emergency Action Levels for Light Water Reactors 7.3 EIP-ZZ-00102, Emergency Implementing Actions 7.4 EIP-ZZ-00260, Event Closeout/Plant Recovery 7.5 Callaway Plant Final Safety Analysis Report 7.6 Callaway Plant Technical Specifications 7.7 APA-ZZ-00703, Fire Protection Operability Criteria and Surveillance Requirements 7.8 APA-ZZ-01003, Off-Site Dose Calculation Manual 7.9 NESP-0007, Methodology for Development of Emergency Action Levels 7.10 Reg. Guide 1.101, Emergency Planning and Preparedness for Nuclear Power Reactors 7.11 OTO-SG-00001, Seismic Event 7.12 OTO-ZZ-00001, Control Room Inaccessibility EIP-ZZ-00101 Rev. 031 7.13 CTP-ZZ-01300, Atmospheric Hazard Control 7.14 OTO-RK-00001, Loss of Control Room Alarms 7.15 EIP-ZZ-01211, Management Action Guides For Nuclear Emergencies (MAGNEM) 7.16 KOA-ZZ-00200, Activation of the Callaway Plant Emergency Callout System 7.17 Emergency Action Level (EAL) Descriptions 7.18 EPCI-98-01, EAL Bases Calculation 7.19 FSAR CN 00-065, GTRE59/60 Alert and High Alarm Computer Setpoints 7.20 CTP-ZZ-08100, Post Accident Sampling Guidelines 8 RECORDS None C

C EIP-ZZ-00101 EMERGENCY ACTION LEVELS Rev. 031 Group 1 ABNORMAL RADIATION EVENTS Offslte Events UNUSUAL EVENT ALERT SITF EMEFRGENCY GENERAL EMERGENCY A. B. C. D.

Any Unplanned Release of Radioactivity Any Unplanned Release of Radioactivity EAB Dose Resulting From an Actual or EAB Dose Resulting From an Actual or to the Environment That Exceeds 2 Times to the Environment That Exceeds 200 Imminent Release of Gaseous Radioactivity Imminent Release of Gaseous Radioactivity the Radiological Effluent Control Limits in Times the Radiological Effluent Control Exceeds 100 nirem TEDE or 500 nwrem CDE Exceeds 1000 mrem TEDE or 5000 mrem the ODCM, (APA-ZZ-0 1003) for 260 Limits in the ODCM, (APA-ZZ-01003) for Thyroid for the Actual or Projected Duration of CDE Thyroid for the Actual or Projected minutes. ~15 minutes. the Release. Duration of the Release.

MODES: At All Times MODES: At All Times MODES: At All Times MODES: At All Times Indicators Indicators Indicators Indicators

1. Al of the following: 1. Ad of the following: ANY of the following: Ay of the following:

a. A vaid alarm and reading on anv of a. A vald alarm and reading on inv of the following effluent monitors: the following effluent monitors: '1. A valid reading on the Unit Vent monitor, GT- '1. A valid reading on the Unit Vent monitor, GT-HB-RE-18 HB-RE-18 RE-21B, > 2.42E+8 pCi/sec for 15 minutes or RE-21D. > 2.42 E+9 pCi/sec for 15 minutes or -

GT-RE-21 B GT-RE-21B longer. longer.

GH-RE-IOB GH-RE.IOB '@2. BtlhLof the following: '@2. Both of the following:

a. A Valid reading on any of the following a. A Valid reading on any of the following

b. The valid reading is 2 times the Hi Hi b. The valid reading is 200 times the Hi monitors: monitors:

alarm setpoint value. Hi alarm setpoint value. AB-RE-01 II >146 mrem/hr AB-RE-01 11 >1460 mrem/hr

c. The release cannot be terminated c. The release cannot be terminated AB-RE-0112>146 mremthr AB-RE-01 12 >1460 mremthr within 60 minutes of the alarm within 15 minutes of the alarm AB-RE-01 13 >146 mrem/hr AB-RE-01 13 >1460 mrem/hr actuation. actuation. AB-RE-01 14 >146 mremihr AB-RE-O 14 >1460 mrem/hr of the following: of the2 FC-RE-0385 >850 mnremlhr FC-RE-0385 >8500 mrem/hr

2. IIh of the following: @2. D2th of the following b. The reading has been, or is expected to be, b. The reading has been, or is expected to be,

a. Confirmed sample analysis indicates a. A Valid reading on Myof the exceeded for 15 minutes or longer. exceeded for 15 minutes or longer.

that a release exceeding 2 times the following monitors:

applicable values of the ODCM AB-RE-01 12>27 mrem/hr 3. A valid dose projection indicates >100 mrem 3. A valid dose projection indicates >1000 nurem (APA-sZ c1003)thas occurred. AB-RE-0112 >27 nrem/hr TEDE or >500 mrem CDE thyroid dose at, or TEDE or >5000 mirem CDE thyroid dose at, or

b. The release cannot be terminatedAB-RE-0113 >27 nuremrllr beyond, the EXCLUSION AREA beyond, the EXCLUSION AREA within 60 minutes. ABC-RE-03851 >150 nirnvh BOUNDARY using in plant rad data or field BOUNDARY using in plant rad data or field

b. Th -REl0eas >cno mrermnat monitoring team survey results. monitoring team survey results.

b. The release cannot be terninated within 15 minutes. 4. Field survey results at, or beyond, the EAB 4. Field survey results at, or beyond, the EAD corresponding to >100 nrixem/hr TEDE for I corresponding to >1,000 mirem/hr TEDE for I

3. fJLQhof the following: hour (or expected to continue for I hour) or hour (or expected to continue for I hour) or

a. Confirmed sample analysis indicates >500 mrnemhr CDE thyroid for I hour of >5,000 mrem/hr CDE thyroid for I hour of that a release exceeding 200 times the inhalation. inhalation.

applicable values of the ODCM (APA-ZZ-01003), has occurred. 'Declare the event using this indicator nl if actual 'Declare the event using this indicator onl if actual

b. The release camnot be terminated dose projections per Indicator 3 cannot be performed dose projections per Indicator 3 cannot be performed within 15 minutes. within 15 minutes of the monitors exceeding the within 15 minutes of the monitors exceeding the reading. reading.

@Release values based on average @ Release values based on average @ Release values based on average meteorological data and a I hour release meteorological data and a I hour release meteorological data and a I hour release duration. duration. duration.

Page I of 10 ATTACHMENT 1

C. C C.

EIP-ZZ-00101 EMERGENCY ACTION LEVELS Rev. 031 Group 1 ABNORMAL RADIATION EVENTS Onsite Events UNUSUAL EVENT ALERT J ALERT ]

E.* F.* G.*

An Unexpected Increase in Plant Radiation. Major Damage to Irradiated Fuel or Loss of Water Level Release of Rad Material, or an Increase in Rad Level that That Has or Will Result in the Uncovering of Irradiated Either Impedes Safe Operations or the Ability to Fuel Outside the Reactor Vessel. Establish or Maintain Cold Shutdown.

MODES: At All Times MODES: At All Times Unless Noted MODES: At All Times Indicators Indicators Indicators Any of the following: Any of the following: Any of the following:

1. Spent Fuel Pool level is decreasing on EC-LI-0039A 1. A VALID Hi-Hi Alarm on Fuel Building exhaust 1. Valid (confirmed by HP) reading on SD-33 (Control with Normal makeup being added, and all irradiated monitors GG-RE-27 _ 28 (Channel 273 or 283). Room) >15 mR/hr.

fuel assemblies remain covered.

2. Containment refueling bridge area radiation monitor 2. Valid (confirmed by HP) reading on the following

2. Refueling Pool level is decreasing on BB-LI-0053A (SD-4 1)> 100 mR/hr. (Mode 6 only.) Safe Shutdown ARMs:

or B with Normal makeup being added, and all SDRE-26 AB 2026 RHR Hx Area Wall irradiated fuel assemblies remain covered. 3. Fuel building area radiation monitor (SD-37 _ 38) SDRE-23 AB 2000 RHR Hx Area Corridor

> 30 mR/hr. SDRE-15 AB 1974 West Corridor-Central

3. Any valid (Confirmed by HP survey) ARM (other SDRE-16 AB 1974 West Corridor-South than a Group 1,G. Safe Shutdown ARM) >1000 4. Report of visual observation of loss of water level > 1000 times normal (normal levels can be times normal. (Normal levels can be considered as resulting in irradiated fuel being uncovered. considered as the monitor reading prior to the the monitor reading prior to the noticed increase.) noticed increase).

• This Initiating Condition is not meant to apply to

• This Initiating Condition is not meant to apply to

• This Initiating Condition is not meant to apply to anticipated temporary increases due to planned anticipated temporary increases due to planned anticipated temporary increases due to planned events (e.g., incore detector movement, radwaste events (e.g., incore detector movement, radwaste events (e.g., incore detector movement, radwaste container movement, depleted resin transfers, upper container movement, depleted resin transfers, upper container movement, depleted resin transfers, upper internal movements, etc.) internal movements, etc.) internal movements, etc.)

Page 2 of 10 ATTACHMENT 1

(7 C C-EIP-ZZ-00101 EMERGENCY ACTION LEVELS Rev. 031 Group 2 FISSION PRODUCT BARRIERS A. UNUSUAL EVENT B. ALERT C. SITE EMERGENCY D. STTE EMERGENCY E. GENERAL EMERGENCY Any CONTAINMENT Any RCS BARRIER Indicator AM RCS BARRIER Indicator A CTMT BARRIER Loss Indicator A Loss Indicator from any two barriers BARRIER Indicator or and and and Any FrUEL CLAD BARRIER Ainy FUEL CLAD BARRIER Any RCS Er FUEL CLAD BARRTER Any Indicator from the third Indicator Indicator Indicator CONTAINMENT BARRIER RCS BARRIER FUEL CLAD BARRIER MODES: 1.4 MODES: 1-4 MODES: 1-4 LIos Indicators: oss indicators: Loss indicators:

1. Containment Pressure 1. RCS Leak Rate 1. Critical Safety Function Status a) A rapid unexplained loss of CTMT pressure following an initial Safety Injection initiated with a loss of subcooling (less than Meet the entry requirements for increase in pressure. instrument error) using Attachment 2 or 3 of Emerg. Procedure FRC. I, Red Path for Core cooling.

oT E-0. *2. Primary Coolant Activity Level b) CTMT pressure a sump level not increasing with a LOCA. 2. SG Tube Rupture RCS coolant activity >300piCi/cc

2. Containment Isolation Valve Status a) Any of the following: dose equivalent 1-131.

Incomplete CTMT isolation allowing a release to the environment, I) GE-RE-92 (Channel 925) >2.0E-5 pCi/cc 3. Containment Radiation Monitoring following a valid CTMT isolation signal (CISA, CISB, CPIS). 2) BM-RE-25 (Channel 256) >1.OE-4 iCi/cc GT-RE-59 or 60 (Channels 591 21

3. SO Release with Primary-Secondary Leakage 3) SJ-RE-02 (Channel 026) >1.0E-4 pCi/cc 601) reading >2.8E+3 R/hr.

a) Pri-to-sec leakage verified greater than 150 gpd per SG, or 600 gpd 4) Level in any SG continues to increase in an total through all SGs. T. S. 3.4.13 uncontrolled manner Potential Loqsindicator:

and Any of the following-and 4. Critical Safety Function Status b) Any of the following: b __Anyofhe_______i Meet the entry requirements for

1) The leaking SG pressure is decreasing in an uncontrolled manner b) Any of the followinG pry requinraemn t forC or completely depressurized. ) The ruptured S pressure is decreasing in an FRC.2, Orange Path for Core

2) Use of the ruptured SG PORV for cool down or temperature uncontrolled manner or completely depressurized. Cooling or FRH.I, Red Path for control. 2) Use of the ruptured SG PORV for cool down or Heat Sink.

3) The leaking SO is supplying the TDAFW turbine. temperature control.

Potential Loss indicators: 3) The leaking SG is supplying the TDAFW turbine. 5. Core Exit Thermocourles

4. Critical Safety Function Status 3. Containment Radiation Monitorin' Core exit TCs >700 0F.

Meet the entry requirements for FRZ.A, Red Path Summary for CTMT. GT-RE-59 2o60 (Channels 591 or 601) reading > 6.4 E+0 R/hr.

5. Containment Pressure 6. Reactor Vessel Water Level a) H2 concentration incontainment >4%. Potential Loss indicators: a) RVLIS (Pumps Off) less than Pr . 4. Critical Safety Function Status 40%

b) Less than I full train of Ctmt spray and Ctmt cooling fans, with Ctmt Meet the entry requirement for FRH.I, Red Path Heat Sink or or pressure greater than 27 psig. FRP.l, Red Path for Integrity. b) RVLIS (Pumps On) less than

6. Sienificant Radioactive Inventory in Ctmt 5. RCS Leak Rate minimum GT-RE-59 or60 (Channels 591 or 601) reading >1.5 E+4 R/hr RCS leakage >50 gpm. RCP's on Minimum

7. Core Exit Thermocouples 6. SG Tube Rupture 4 44 a) Core exit TCs >1200OF and restoration procedures not effective in 15 a) Any of the following: 3 30 minutes. 1) GE-RE-92 (Channel 925) >2.0 E-5 llCilcc 2 20 or- 2) BM-RE-25 (Channel 256)'>1.0 E-4 pCi/cc 1 13 b) Core exit TCs >700'F and RVLIS (pumps off) <40% and restoration 3) SJ-RE-02 (Channel 026) >1.0 E-4 pCi/cc procedures not effective in 15 minutes. 4) Level in any SG continues to increase in an

8. Radiation Increase Outside Containment uncontrolled manner.

Unexplained increase in radiation levels in areai adjacent to the and containment. b) the primary-to-secondary leak rate exceeds 50 gpm.

• Refer to CTP-ZZ-08100.

Page 3 of 10 AT7ACHMENT 1

( C EIP-ZZ-00101 EMERGENCY ACTION LEVELS Rev. 031 A. B. C. D.

Confirmed Security Event Which Security Event in the Plant Protected Security Event in a Safe Shutdown Area. Security Event Resulting in a Loss of the Indicates a Potential Degradation in the Area. Ability to Reach and Maintain Cold Level of Safety of the Plant. Shutdown.

MODES: At All Times MODES: At All Times MODES: At All Times MODES: At All Times Indicators Indicators Indicators Indicators Any of the following: Confirmed report of an intrusion by a Any of the following Any of the following:

hostile force into the plant Protected 1. Bomb device discovered within any

1. Bomb device discovered within the Area. of the following areas: 1. Occupation of the Control Room by a plant Protected Area and outside the

• Area 5 hostile force.

following Safe Shutdown Areas:

• Containment Aux Feed Pump Rooms 2. Occupation of the Aux Shutdown

• Area 5 Aux Building Panel by a hostile force.

• Containment

• Diesel Generator Building

• Aux Feed Pump Rooms

• UHS Cooling Tower

• Aux Building

• ESW Pumphouse

• Diesel Generator Building

• Control Building

• UHS Cooling Tower

• RWST

• ESW Pumphouse

• Fuel Building

• Control Building

• RWST 2. Confirmed report of an intrusion by a

• Fuel Building hostile force into any of the following areas:

2. Confirmed report of an attempted

• Area 5 entry or sabotage.

• Containment

• Aux Feed Pump Rooms

3. A site specific credible security

• Aux Building threat.

• Diesel Generator Building

• UHS Cooling Tower

• ESW Pumphouse

• Control Building

• RWST

• Fuel Building Page 4 of 10 ATTACHMENT 1

( C-EIP-ZZ-00101 EMERGENCY ACTION LEVELS Rev. 031 Group 3 HAZARDS AFFECTING PLANT SAFETY Fires Natural and Destructive Events UNUSUAL EVENT ALERT UNUSUAL EVENT ALERT E. F. G. H.

Fire Within Protected Area Boundary Fire Affecting the Operability of Plant Natural and Destructive Phenomena Natural and Destructive Phenomena Not Extinguished Within 15 Minutes Safety Systems Required to Establish Affecting the Protected Area. Affecting a Safe Shutdown Area.

of Verification. or Maintain Safe Shutdown.

MODES: At All Times MODES: At All Times MODES: At All Times MODES: At All Times Indicators Indicators Indicators Indicators

1. Fire in or adiacent to any of the 1. Fire in any of the following areas: Any of the following: Any of the following:

following:

• Area 5 1. a. Response spectrum recorder 1. a. Operating basis earthquake

• Area 5

• Containment operating annunciator 98E annunciator 98D alarms in the

• Containment

• Aux Feed Pump Rooms alarms in the Control Room Control Room

• Aux Feed Pump Rooms

• Aux Building and and

• Aux Building

• Diesel Generator Building b. Verified to be a real event per b. Earthquake greater than OBE

• Diesel Generator Building

• UHS Cooling Tower OTO-SG-00001. levels (0.12g) in the horizontal and

• UHS Cooling Tower

• ESW Pumphouse 2. Report of a main turbine rotating vertical directions as indicated by

• ESW Pumphouse

• Control Building component failure resulting in LIGHT "OSG-AE-1J" or LIGHT

• Control Building

• RWST casing penetration or major damage "OSG-AE-2"

• RWST

• Fuel Building to seals causing a rapid loss of 2. a. Report of a tornado, high wind,

• Fuel Building and lubricating oil or hydrogen. vehicle crash, explosion, or other and 2. There is visible damage to 3. Explosion, vehicle crash or tornado natural or destructive phenomena

2. Not extinguished within 15 permanent structures or in or adjacent to any of the to any of the following Safe minutes of control room equipment, affecting the following: Shutdown areas:

verification of a fire. operability of safety related

• Area 5

• Area 5 equipment.

• Containment

• Containment

• Aux Feed Pump Rooms

• Aux Feed Pump Rooms

• Aux Building

• Aux Building

• Diesel Generator Building

• Diesel Generator Building

• UHS Cooling Tower

• UHS Cooling Tower

• ESW Pumphouse

• ESW Pumphouse

• Control Building

• Control Building

• RWST

• RWST

• Fuel Building

• Fuel Building and

b. There is visible damage to permanent structures or equipment, affecting plant operations.

Page 5 of 10 ATTACHMENT 1

. I . ... . . - .. . - ... ". H . - W..

C C-EIP-ZZ-00101 EMERGENCY ACTION LEVELS Rev. 031 Group 3 HAZARDS AFFECTING PLANT SAFETY Toxic Gas Control Room Evacuation Events UNUSUAL EVENT ALERT ALERT SITE EMERGENCY J. K. L.

Release of Toxic or Flammable Gases Release of Toxic or Flammable Gases Control Room Evacuation Has Been Control Room Evacuation Has Been Deemed Detrimental to Safe Operation Within a Facility Structure Which Initiated. Initiated and Plant Control Cannot Be of the Plant. Jeopardizes Operation of Systems Established.

Required to Establish or Maintain Cold Shutdown.

MODES: At All Times MODES: At All Times MODES: At All Times MODES: At All Times Indicators Indicators Indicators Indicators Any of the following: Anx of the following: Entry into OTO-ZZ-00001, Control 1. Entry into OTO-ZZ-00001,

1. Report or detection of toxic or 1. Report or detection of toxic or Room Inaccessibility, is required. Control Room Inaccessibility, is flammable gases that enter within flammable gases, not properly required.

the Exclusion Area Boundary, that contained, within or adiacent to any have created a HAZARDOUS of the following Safe Shutdown and ATMOSPHERE per Areas, that have created a CTP-ZZ-01300, deemed HAZARDOUS ATMOSPHERE 2. Control of the Aux Feed System detrimental to safe operation. per CTP-ZZ-01300jeopardizing and a SG PORV for cooldown

2. Confirmed report by local, County operation of systems required to cannot be established within 15 or State Officials of potential establish or maintain Cold minutes.

evacuation of site personnel as Shutdown determined from the DOT evacuation tables for selected

• Area 5 hazardous materials in the DOT

• Containment Emergency Response Guide for

• Aux Feed Pump Rooms Hazardous Materials.

• Aux Building

• Diesel Generator Building

• UHS Cooling Tower

• ESW Pumphouse

• Control Building

• RWST

• Fuel Building Page 6 of 10 PATTACHMENT 1

C C C EIP-ZZ-00101 EMERGENCY ACTION LEVELS Rev. 031 Group 4 SYSTEM MALFUNCTIONS 1

Annunciator Events UNUSUAL EVFNT ALERT SITE EMERGENCY A. B. C.

Unplanned Loss of Most or All Alarms (Annunciators) for Unplanned Loss of Most or All Annunciators With Either a Inability to Monitor a Significant Transient in Progress.

Greater Than 15 Minutes. Transient In Progress, or the Plant Computer is Unavailable.

MODES: 1-4 MODES: 1-4 MODES: 1-4 Indicators Indicators Indicators

-. AnM of the following: 1. My of the following: 1. AnM of the following:

a. 3 of 4 field power supplies indicate < 105 volts for a. 3 of 4 field power supplies indicate < 105 volts for a. 3 of 4 field power supplies indicate < 105 volts greater than 15 minutes (loss of all annunciators) greater than 15 minutes (loss of all annunciators) (loss of all annunciators).

and not a result of planned action. and not a result of planned action. b. Field Power Supply Bus voltage is less than 105

b. Field Power Supply Bus voltage is less thah 105 b. Field Power Supply Bus voltage is less than 105 volts (loss of all annunciators).

volts for greater than 15 minutes (loss of all volts for greater than 15 minutes (loss of all c. Ten or more logic power supplies have failed (loss annunciators) and not a result of planned action. annunciators) and not a result of planned action. of all annunciators).

c. Ten or more logic power supplies have failed for c. Ten or more logic power supplies have failed for d. Five or more Multiplexer Adapter Rack Fuses have greater than 15 minutes (loss of all annunciators) greater than 15 minutes (loss of all annunciators) failed (loss of all annunciators).

and not a result of planned action. and not a result of planned action. or

d. Five or more Multiplexer Adapter Rack Fuses have d. Five or more Multiplexer Adapter Rack Fuses have 2. ,1. of the following:

failed for greater than 15 minutes and not a result failed for greater than 15 minutes and not a result a. Any combination of power supplies (including of planned action. of planned action. Optical Isolators) or Multiplexer Adapter Rack or or Fuses have failed.

2. All of the following: 2. All of the following: b. Any minimum comoensatorv actions, per

a. Any combination of power supplies (including a. Any combination of power supplies (including OTO-RK-00001. cannot be maintained.

Optical Isolators) or Multiplexer Adapter Rack Optical Isolators) or Multiplexer Adapter Rack and Fuses have failed for greater than 15 minutes. Fuses have failed for greater than 15 minutes. 3. An_ of the following:

b. Any minimum compensatorv actions, per b. Any minimum comnensatory actions, per a. A change in reactor power greater than +10%.

OTO-RK-00001, cannot be maintained. OTO-RK-00001, cannot be maintained. b. Safety injection initiation.

c. The loss does not result from planned action. c. The loss does not result from planned action.

and 4. Compensatory plant parameters monitored via the plant

3. Any of the following: computer, per OTO-RK-00001, are not valid or cannot

a. A change in reactor power greater than *10%. be obtained.

b. Safety injection initiation.

c. Compensatory plant parameters monitored via the plant computer, per OTO-RK-00001, are not valid or cannot be obtained.

Page 7 of 10 ATTACHMENT 1

(7 EMERGENCY ACTION LEVELS EIP-ZZ-00101 Rev. 031 Group 4 SYSTEM MALFUNCTIONS Electrical Events (Shutdown)

I. V D. E. F. G. H.

I UNUSUAL EVENT J.3.

UNUSUAL EVFNT K.

ALERT Loss of All Offsite Only One AC Source Loss of All Offsite Loss of All Vital Prolonged Loss of All Loss of Required DC Loss of All Loss of All Offsite Power to Essential to Essential Busses for Power and Loss of All DC Power Offsite Power and Prolonged Power During Cold Offsite Power to Power and Loss of All Busses for Greater >15 Minutes Such That Onsite AC Power to Loss of All Onsite AC Shutdown or Refueling Essential Busses Onsite AC Power to Than 15 Minutes. Any Additional Single Essential Busses. Power. Mode for Greater Than for Greater Than Essential Busses During Failure Would Result 15 Minutes. 15 Minutes. Cold Shutdown or in Station Blackout. Refueling.

MODES: 1-4 MODES: 1-4 MODES: 1-4 MODES: 1-4 MODES: 1-4 MODES: 5; 6 MODES: 5.6 MODES: 5. 6. Defueled t I. t Indicators Indicators TIndicators Indicators Indicators Indicators Indicators Indicators All of the 1. Loss of anv 3 of 1. Loss of gll 4 of the 1. Loss (Bus AUl of the following: 1. Loss of Division I 1. Loss of 1. Loss of all 4 of the following: the following following power Voltage 1. Loss of offsite power to Vital DC power as offsite power following power

1. Loss of power sources: sources: < 106.9 VDC) NBOI and NBO2.

• indicated by to NBOI and sources:

offsite power a. Offsite power a. Offsite power of all 4 of the 2. Loss of both Emergency <106.9 VDC on NBO2.

• a. Offsite power to NBOI and to NB01

• to NBOL

• following Diesel Generators NE01 NKO or NK03. to NBOl

• NBO2.

• b. Offsite power b. Offsite power busses: and NE02. and and b. Offsite power to NBO2

• to NB02

• a. NK01 3. a. Restoration of at Loss of Division 2 2. The loss of to NBO2 *

2. The loss of c. Emergency c. Emergency b. NK02 least one Vital DC power as offsite power c Emergency offsite power Diesel NEOI Diesel NE01 c. NK03 emergency bus indicated by has occurred Diesel NE01 has occurred d. Emergency d. Emergency d. NK04 within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is <106.9 VDC for>15 d. Emergency for >15 Diesel NE02 Diesel NE02 not likely. NK02 or NK04. minutes. Diesel NE02 minutes. and br and and and 2. Failure to b. Meet the entry and 2. The loss of all 4

2. The loss of all 3 2. The loss of all 4 restore power requirements for 2. The loss of both has occurred for has occurred for has occurred for to at least one FRC. I, Red Path Divisions has >15 minutes.

>15 minutes. >15 minutes. DC bus for Core Cooling. occurred for >15 within 15 minutes.

minutes.

• Note: Supply Breakers opening due to degraded switchyard voltage is considered a Loss of Offsite Power.

Page 8 of 10 ATTACHMENT 1

( C EIP-ZZ-00101 EMERGENCY ACTION LEVELS Rev. 031 Group 4 SYSTEM MALFUNCTIONS Shutdown Capability UNUSUAL EVENT ALERT SITE EMERGENCY SITE EMERGENCY L.* M. N. O.

Inability to Perform a Required Shutdown Inability to Maintain Plant in Cold Shutdown. Loss of Water Level That Has or Will Complete Loss of Function Needed to Within Technical Specification Limits. Uncover Fuel in the Reactor Vessel. Achieve or Maintain Hot Shutdown.

MODES: 1-4 MODES: 5,6 MODES: 5,6 MODES: 1-4 Indicators Indicators Indicators Indicators

1. The plant is not brought to a required 1. A-ny of the following: 1. Any of the following: I AUl of the following:

operating mode within a Technical a. Complete loss of both trains of a. Complete loss of both trains of a. Failure to bring the reactor Specification LCO action completion RHR. RHR. subcritical with the control rods time. b. Complete loss of both trains of b. Complete loss of both trains of fully inserted.

CCW. CCW. b. Complete loss of all Boron Injection

c. Complete loss of both trains of c. Complete loss of both trains of Flowpaths.

ESW. ESW.

and and 2. All of the following:

2. Either of the following: 2. Either of the following: a. All steam generator levels <10%

a. Greater than 2001F on any valid a. Greater than 2001F on any valid wide range.

incore thermocouple.* incore thermocouple.* b. All steam dump valves to condenser b: Uncontrolled temperature rise, with b. Uncontrolled temperature rise, with (AB UV-34, 35 and 36) are NOT no actions available that will likely no actions available that will likely responding to steam header pressure prevent approaching 200'F on any prevent approaching 200'F on mny controller (AB PK-507 or valid incore thermocouple.* valid incore thermocouple.* AB UK-33).

and c. All steam generator steam dump

3. a. Water level in the reactor vessel is valves to atmosphere are NOT less than 2.0 inches on operating properly (AB-PIC-IA, BB-LI-0053A or B. 2A, 3A and 4A).

or d. Complete loss of both RHR trains.

b. RVLIS (pumps off) <55% (A complete loss of ESW or CCW constitutes a complete loss of RHR.)

3. All of the following:

a. The Ultimate Heat Sink (UHS) is

• If a thermocouple is not available, use Wide

• If a thermocouple is not available, use Wide inoperable as a result of level or

• It is not intended to declare an Unusual Range Hot Leg temperature indications: Range Hot Leg temperature indications: temperature.

Event due to an unknown condition or

• BBT1413A - Loop I

• BBT1413A - Loop I b. Complete loss of both UHS Cooling failure resulting in exceeding the

• BBT1423A - Loop 2

• BBT1423A - Loop 2 Tower trains.

allowable action statement time. The

• RECORDERS

• RECORDERS allowable action statement time is always BBTR413 - Loop I BBTR413 - Loop I available from the time of the discovery. BBTR423 - Loop 2 BBTR423 - Loop 2 BBTR433 - Loop 3 BBTR433 - Loop 3 BBTR443 - Loop 4 BBTR443 - Loop 4 Page 9 of 10 ATTACHMENT 1

C C-EIP-ZZ-00101 EMERGENCY ACTION LEVELS Rev. 031 Group 4 SYSTEM MALFUNCTION! S Communication Events RCS/Fuel Events Reactor Protection System UNUSUAL EVENT UNUSUAL EVFNT f UNUSUAL EVENT _____I SrTF, EMERGENCY GENERAL EMERGENCY P. Q. R. S. T. U.

Unplanned Loss of All Onsite or Offsite Fuel Clad Degradation RCS Leakage Failure of Reactor Protection Failure of Reactor Protection Failure of the Reactor Communication Capabilities System Instrumentation to System Instrumentation to Protection System to Complete or Initiate an Complete or Initiate an Complete an Automatic Trip Automatic Reactor Trip Automatic Reactor Trip Once and Manual Trip Was NOT Once a Reactor Protection a Reactor Protection System Successful and There Is System Setpoint Has Been Setpoint Has Been Exceeded Indication of an Extreme Exceeded and Manual Trip and Manual Trip Was NOT Challenge to the Ability to Was Successful. Successful. Cool the Core.

MODES: 1-6 MODES: 1.6 MODES: 1-4 MODES: 1, 2 MODES: 1.2 MODES: 1. 2 Indicators Indicators Indicators Indicators Indicators Indicators

1. AU of the following on-site 1. An of the 1. Any of the 1. All of the following: 1. All of the following: 1. All of the following:

systems: following: following: a. An automatic (not a. An automatic (not a. An automatic (not

a. Complete failure of Plant a. >1.0 pCi/gram a. Unidentified manual) reactor trip manual) reactor trip manual) reactor trip telephone systems Dose leakage greater setpoint has been setpoint has been setpoint has been*

b. Complete failure of Gai- Equivalent than 10 gpm. exceeded as listed in exceeded as listed in exceeded as listed in tronics systems 1-131 for b. Pressure Attachment I of Attachment I of E-0. Attachment 1 of E-0.

c. Complete failure of Plant greater than a boundary E-0. b. An automatic reactor b. An automatic reactor radios 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> leakage greater b. An automatic trip is NOT trip is NOT

d. Complete failure of Plant continuous than 10 gpm. reactor trip is NOT successful. successful.

Emergency Dedicated Phones. period. c. Identified successful. c. A manual reactor c. A manual reactor or b. Dose leakage greater c. A manual reactor trip is NQO trip is NOT

2. All of the following offsite systems: Equivalent than 25 gpm. trip IS successful' successful using successful using

a. Complete failure of ENS (Red 1.131 activity using manual trip manual trip switches manual trip switches Phone) line. exceeding the switches SB-HS-I SB-HS-1 on RL003 SB-HS-1 on RL003

b. Complete failure of Back Up limits of Tech on RL003 QBR AND SB-HS-42 on AND SB-HS-42 on Radio System (BURS). Spec Fig. SB-HS-42 on RLOO6. RLOO6.

c. Complete failure of Plant 3.4-1. (ITS RLOO6. d. Meet the entry telephone system. Fig. 3.4.16-1) requirements for

d. Complete failure of the c. >100/Ebarg FRC.I OR FRH.I1, Sheriffs radio system. Ci/gram of red path summaries

e. Complete failure of the gross for core cooling and SENTRY notification system. radioactivity. heat sink.

Page 10 of 10 ATTACHMENT 1

EIP-ZZ-O0101 Rev. 031 I

I i

II i

4

. I I

EMERGENCY ACTION LEVELS I

i I

i INDI CATORS BASES i I

Page I of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 1 Abnormal Radiation 'Events Initiating Condition Emergency Classification A. Any Unplanned Release of Unusual Event Radioactivity to the Environment That Exceeds 2 Times the Radiological Effluent Control Limits in the ODCM (APA-ZZ-01003) for 260 minutes.

MODES: At All Times Indicators

1. All of the following:

a. A valid alarm and reading on any effluent monitor:

HB-RE-18 (Channel 186)

GT-RE-21B (Channel 213)

GT-RE-1OB (Channel 103)

b. The valid reading is 2 times the Hi Hi alarm setpoint (trip setpoint) value.

c. The release cannot be terminated within 60 minutes of the alarm actuation.

OR

2. Both of the following:

a. Confirmed sample analysis indicates that a release exceeding 2 times the applicable values of the ODCM (APA-ZZ-01003), has occurred.

b. The release cannot be terminated within 60 minutes.

Bases The Radiological Effluent Control Limits (REC's) used are in the FSAR Chapter 16.

Any Unplanned Release would be any inadvertent or accidental release of radioactive material.

An Unplanned Release is also a release via normal pathways without a release permit or proper authorization, or without proper sampling and analysis, or resulting in significant deviation from the requirements of the release permit.

Valid alarms and readings are those verified by the operators to be the results of effluent concentrations. Invalid alarms and readings may be the result of electronic noise, radio frequency interference, electromagnetic frequency interference, or spurious spikes of unknown nature. A buildup of radioactivity within the monitor or an increase in the ambient background for the monitor would also cause an invalid alarm.

The time frame of 60 minutes is used to indicate a definite loss of control. This is also the time used in IOCFR50.72 for a continuing release that would require notification. This loss of control for 260 minutes is of more significance than the level of release in this EAL.

Page 2 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group I Abnormal Radiation Events Initiating Condition Emergency Classification B. Any Unplanned Release of Alert Radioactivity to the Environment That Exceeds -

200 Times the Radiological Effluent Control Limits in the ODCM (APA-ZZ-01003) for 215 minutes.

MODES: At All Times Indicators

1. All of the following:

a. A valid alarm and reading on any effluent monitor:

HB-RE-18 GT-RE-21B GT-RE-1OB

b. The valid reading is 200 times the Hi Hi alarm setpoint (trip setpoint) value.

c. The release cannot be terminated within 15 minutes of the alarm actuation.

OR

2. Both of the following:

a. A Valid reading on any of the following monitors:

AB-RE-0111 >27 mrem/hr AB-RE-0112 >27 mrem/hr AB-RE-0113 >27 mrem/hr AB-RE-0114 >27 mrem/hr FC-RE-0385 >150 mrem/hr

b. The release cannot be terminated within 15 minutes.

OR

3. Both of the following:

a. Confirmed sample analysis indicates that a release exceeding 200 times the applicable values of the ODCM (APA-ZZ-01003), has occurred.

b. The release cannot be terminated within 15 minutes.

Bases The Radiological Effluent Control Limits (REC's) used are in the FSAR Chapter 16. The release values for 2.a. are based on average meteorological data and a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> release duration.

This event escalates from the Unusual Event by escalating the magnitude of the release by a factor of 100. The increased level of release is the significant factor in this EAL. The duration is reduced to 15 minutes in recognition of the increased level.

PAge 3 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group . Abnormal Radiation Events Initiating Condition Emergency Classification C. EAB Dose Resulting Site Emergency From an Actual or Imminent Release of Gaseous Radioactivity Exceeds 100 mrem TEDE or 500 mrem CDE Thyroid for the Actual or Projected Duration of the Release.

MODES: At All Times Indicators Any of the following:

• 1. A valid reading on the Unit Vent monitor GT-RE-21B indicates

>2.42E+8 pCi/sec for 15 minutes or longer.

• @2. Both of the following:

a. A Valid reading on any of the following monitors:

AB-RE-0111 >146 mrem/hr AB-RE-0112 >146 mrem/hr AB-RE-0113 >146 mrem/hr AB-RE-0114 >146 mrem/hr FC-RE-0385 >850 mrem/hr

b. The reading has been, or is expected to be, exceeded for 15 minutes or longer.

3. A valid dose projection indicates >100 mrem TEDE or >500 mrem CDE thyroid dose at, or beyond, the EXCLUSION AREA BOUNDARY using in plant rad data or field monitoring team survey results.

4. Field survey results at, or beyond, the EAB corresponding to

>100 mrem/hr TEDE for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (or expected to continue for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />) or

>500 mrem/hr CDE thyroid for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of inhalation.

• Declare the event using this indicator only if an actual dose projections, per Indicator 3 cannot be performed within 15 minutes of the monitors exceeding the reading.

QRelease values based on average meteorological data and a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> release duration.

Bases Valid alarms and readings are those verified by the operators to be the results of effluent concentrations. Invalid alarms and readings may be the result of electronic noise, radio frequency interference, electromagnetic frequency interference, or spurious spikes of unknown nature. A buildup of radioactivity within the monitor or an increase in the ambient background for the monitor would also cause an invalid alarm.

The 100 mrem integrated dose in this initiating condition provides a desirable gradient (one order of magnitude) between the Alert, Site Emergency, and General Emergency classes. It is deemed that exposures less than this limit are not consistent with the Site Emergency class description. The 500 mrem integrated thyroid dose was established in consideration of the 1:5 ratio of the EPA Protective Action Guidelines for whole body and thyroid.

The release value for item 1 above, rad monitor GT-RE-21B, is based on average meteorological data and a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> release duration. Actual meteorology should be used whenever possible since it gives the most accurate dose assessment. (CARS 200104820)

The release values for 2.a. are based on average meteorological data and a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> release duration. Actual Meteorology should be used whenever possible since it gives the most accurate dose assessment.

Thyroid doses are based upon EPA 400, manual of protective action guides and protective actions for nuclear incidents.

Page 4 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 1 Abnormal Radiation Events Initiating Condition Emergencv Classification D. EAB Dose Resulting General Emergency From an Actual or Imminent Release of Gaseous Radioactivity Exceeds 1000 mrem TEDE or 5000 mrem CDE Thyroid for the Actual or Projected Duration of the Release.

MODES: At All Times Indicators Mny of the following:

• 1. A valid reading on the Unit Vent monitor GT-RE-21B indicates >2.42E+9 pCi/sec for 15 minutes or longer.

• 02. Both of the following:

a. A Valid reading on any of the following monitors:

AB-RE-0111 >1460 mrem/hr AB-RE-0112 >1460 mrem/hr AB-RE-0113 >1460 mrem/hr AB-RE-0114 >1460 mrem/hr FC-RE-0385 >8500 mrem/hr

b. The reading has been, or is expected to be, exceeded for 15 minutes or longer.

3. A valid dose projection indicates >1000 mrem TEDE or >5000 mrem CDE thyroid dose at, or beyond, the EXCLUSION AREA BOUNDARY using inplant rad data or field monitoring team survey results.

4. Field survey results at, or beyond, the EAB corresponding to >1000 mrem/hr TEDE for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (or expected to continue for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />) or >5000 mrem/hr CDE thyroid for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of inhalation.

• Declare the event using this indicator only if an actual dose projections per Indicator 3 cannot be performed within 15 minutes of the monitors exceeding the reading.

ORelease values based on average meteorological data and a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> release duration.

Bases Valid alarms and readings are those verified by the operators to be the results of effluent concentrations. Invalid alarms and readings may be the result of electronic noise, radio frequency interference, electromagnetic frequency interference, or spurious spikes of unknown nature. A buildup of radioactivity within the monitor or an increase in the ambient background for the monitor would also cause an invalid alarm.

The setpoints in Indicator 1., are 10 times the values calculated for EAL IC. The 1000 mrem whole body and the 5000 mrem thyroid integrated dose are based on the EPA protective action guidance which indicates that public protective actions are indicated if the dose exceeds 1 rem whole body or 5 rem thyroid. This is consistent with the emergency class description for a General Emergency. This level constitutes the upper level of the desirable gradient for the Site Emergency.

The release value for item 1 above, rad monitor GT-RE-21B, is based on average meteorological data and a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> release duration. Actual meteorology should be used whenever possible since it gives the most accurate dose assessment.

The release values for 2.a. are based on average meteorological data and a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> release duration. Actual Meteorology should be used whenever possible since it gives the most accurate dose assessment.

Thyroid doses are based upon EPA 400, manual of protective action guides and protective actions for nuclear incidents.

Page 5 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 1 Abnormal Radiation Events Initiating Condition Emergency Classification E.* An Unexpected Increase in Unusual Event Plant Radiation.

MODES: At All Times Indicators Any of the following:

1. Spent Fuel Pool level is decreasing on EC-LI-0039A with Normal makeup being added, and all irradiated fuel assemblies remain covered.

2. Refueling Pool level is decreasing on BB-LI-0053A or B with Normal makeup being added, and all irradiated fuel assemblies remain covered.

3. Any valid (Confirmed by HP survey) ARM (other than a Group 1,G. Safe Shutdown ARM) >1000 times normal. (Normal levels can be considered as the monitor reading prior to the noticed increase.)

• This Initiating Condition is not meant to apply to anticipated temporary increases due to planned events (e.g., incore detector movement, radwaste container movement, depleted resin transfers, upper internal movements, etc.)

Bases Valid alarms and readings are those verified by the operators to be the results of effluent concentrations. Invalid alarms and readings may be the result of electronic noise, radio frequency interference, electromagnetic frequency interference, or spurious spikes of unknown nature. A buildup of radioactivity within the monitor or an increase in the ambient background for the monitor would also cause an invalid alarm.

All of the above events tend to have long lead times relative to potential for radiological release outside the site boundary, thus impact to public health and safety is very low.

Indicator 3 addresses unplanned increases in in-plant radiation levels that represent a degradation in the control of radioactive material, and represent a potential degradation in the level of safety of the plant.

Page 6 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 1 Abnormal Radiation Zvents Initiating Condition Emercencv Classification F.* Major Damage to Irradiated Alert Fuel or Loss of Water Level That Has or Will Result in the Uncovering of Irradiated Fuel Outside the Reactor Vessel.

MODES: At All Times Indicators Anv of the following:

1. A VALID Hi-Hi Alarm on Fuel Building exhaust monitors GG-RE-27 or 28

.2. Containment refueling bridge area radiation monitor (SD-41) >100 mR/hr.

3. Fuel building area radiation monitor (SD-37 or 38) >30 mR/hr.

4. Report of visual observation of loss of water level resulting in irradiated fuel being uncovered.

• This Initiating Condition is not meant to apply to anticipated temporary increases due to planned events (e.g., incore detector movement, radwaste container movement, depleted resin transfers, upper internal movements.

Bases This Initiating Condition applies to spent fuel requiring water coverage.

NUREG-0818, 'Emergency Action Levels for Light Water Reactors,' forms the basis for these EALs.

For indicator 1, the Hi-Hi alarm setpoint is the Tech. Spec. 3.3.8-3 required trip setpoint value. This setpoint is established such that the actual submersion dose rate would not exceed 4 mR/hr in the fuel building. This would be representative of the conditions required for this EAL.

Page 7 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 1 Abnormal Radiation Events For Indicator 2:

Containment Dose Rate The Dose Rate Conversion Factor for this calculation is an EPA 400 based conversion factor.

The source term originates from Calc ZZ-341, Rev. 1. See Attachment 3, Page 1 of 4. The Tech Spec (FSAR 16.11.2.4.1.B) concentration of 5 E-3 pCi/cc will result in a dose rate of 100 mR/Hr to personnel inside containment.

D/R = (CONC) (DRCF)

This corresponds well to the Tech Spec (FSAR 16.11.2.4.2) basis statement that the equivalent dose rate is 'approximately 150 mR/Hr." Therefore, a dose rate on SD-41 of >100 mR/Hr would be an indication for declaration of an Alert (currently set to Alarm at 100 mR/Hr to indicate a High Radiation Area).

D/R > 100 mR/Hr (ARM SD-41)

For Indicator 3:

Fuel Building Dose Rates The Dose Rate Conversion Factor for this calculation is an EPA 400 based conversion factor.

The source term originates from Calc ZZ-341, Rev. 1. See Attachment 3, Page 2 of 4. A concentration of 1.46 E-3, the Hi-Hi alarm setpoint on GT-RE-27/28 will result in a dose rate of 30 mR/Hr to personnel inside the Fuel Building.

Therefore, a dose rate of >30 mR/Hr on SD-37 or -38 would be.an indication for declaration of an Alert (Alarm setpoint is 15 mR/Hr per Tech Spec Table 3.3-6 (FSAR 16.3.3.6) based on criticality monitoring).

D/R > 30 mR/Hr (ARM SD-37 or 38) l Indicator 4, eliminates the need for Spent Fuel Pool & Refueling Pool level indication, as at Callaway indication is not capable of displaying level as low as the top of a fuel assembly.

Page 8 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 1 Abnormal Radiation Events Initiating Condition Emergencv Classification G.* Release of Rad Material, Alert or an Increase in Rad Level that Either Impedes Safe Operations or the Ability to Establish or Maintain Cold Shutdown.

MODES: At All Times Indicators Any of the following:

1. Valid (confirmed by HP) reading on SD-33 (Control Room) >15 mR/hr.

2. Valid (confirmed by HP) reading on the following Safe Shutdown Area ARMs:

SDRE-26 AB 2026 RHR Hx Area Wall SDRE-23 AB 2000 RHR Hx Area Corridor SDRE-15 AB 1974 West Corridor-Central SDRE-16 AB 1974 West Corridor-South

>1000 times normal (normal levels can be considered as the monitor.

reading prior to the noticed increase).

• This Initiating Condition is not meant to apply to anticipated temporary increases due to planned events (e.g., incore detector movement, radwaste container movement, depleted resin transfers, upper internal movements, etc.)

Bases Valid means that a radiation monitor reading has been confirmed by the operators to be correct.

This Initiating Condition addresses increased radiation levels that impede necessary access to operating stations, or other areas containing equipment that must be operated manually, in order to maintain safe operation or perform a safe shutdown. It is this impaired ability to operate the plant that results in the actual or potential substantial degradation of the level of safety of the plant. The cause and/or magnitude of the increase in radiation levels are not a concern of this Initiating Condition. The Emergency Coordinator must consider the source or cause of the increased radiation levels and determine if any other Initiating Condition may be involved. For example, a dose rate of 15 mR/hr in the control room may be a problem in itself. However, the increase may also be indicative of high dose rates in the containment due to a LOCA. In this latter case, a Site Emergency or General Emergency may be indicated by the fission product barrier matrix ICs.

Areas requiring continuous occupancy include the control room. The value of 15 mR/hr is derived from the GDC 19 value of 5 rem in 30 days with-adjustment for expected occupancy times. Although Section III.D.3 of NUREG-0737, 'Clarification of TMI Action Plan Requirements', provides that the 15 mR/hr value can be averaged over the 30 days, the value is used here without averaging, as a 30 day duration implies an event potentially more significant than an Alert.

For Indicator 2, 1000 times normal represents the factor used in the Unusual Event, however these particular monitors are located in areas of required infrequent access to maintain plant safety functions.

This Initiating Condition is not intended to apply to anticipated temporary increases due to planned events (e.g., incore detector movement, radwaste container movement, depleted resin transfers, etc.)

Page 9 of'50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 2 Fission Product Barriers CONTAINesMT BARRIER EALs:

The Containment Barrier includes the containment building, its connections up to and including the outermost containment isolation valves. This barrier also includes the main steam, feedwater, and blowdown line extensions outside the containment building up to and including the outermost secondary side isolation valve.

Loss Indicators

1. Containment Pressure Rapid unexplained loss of pressure (i.e., not attributable to containment spray or condensation effects) following an initial pressure increase indicates a loss of containment integrity. Containment pressure and sump levels should increase as a result of the mass and energy release into containment from a LOCA. Thus, sump level or pressure not increasing indicates containment bypass and a loss of containment integrity.

2. Containment Isolation Valve Status This EAL is intended to address incomplete containment isolation that allows a breach of the containment barrier as described above. It represents a loss of the containment barrier. It is not intended to address failures during testing. The existence of an in-line charcoal filter does not stop a release path since the filter is not effective at removing fission noble gases.

3. SG Release With Primary To Secondary Leakage This EAL addresses SG tube ruptures with secondary side releases to atmosphere including those from the atmospheric steam dump valves (manual or automatic), main steam safety valves and steam supplied to the TDAFW Turbine unless successfully isolated via appropriate isolation valves. For larger breaks RCS BARRIER SG Tube Rupture "Loss' or "Potential Loss' EALs would result in an Alert. For SG tube ruptures which may involve multiple steam generators or unisolable secondary line breaks, this EAL would exist in conjunction with RCS BARRIER 'Loss" EAL 2 and would result in a Site Emergency. Escalation to General Emergency would be based on the addition of a 'Loss' or 'Potential Loss' of the FUEL CLAD BARRIER.

Page 10 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 2 Fission Product Barriers CONTA1NMUNT BARRIER EAL9 (cont):

Potential Loss Indicators

4. Critical Safety Function Status RED path indicates an extreme challenge to the safety function derived from appropriate instrument readings and/or sampling results, and thus represents a potential loss of containment. Conditions leading to a containment RED path result from RCS barrier and/or Fuel Clad Barrier Loss. Thus, this EAL is primarily a discriminator between Site Emergency and General Emergency representing a potential loss of the third barrier.

5. Containment Pressure The second potential loss EAL represents a potential loss of containment in that the containment heat removal/depressurization system (e.g., containment sprays, but not including containment venting strategies) are either lost or performing in a degraded manner, as indicated by containment pressure greater than the setpoint at which the equipment was suppose to have actuated.

6. Significant Radioactive Inventory in Ctmt If GT-RE-59 and GT-RE-60 are not available, refer to HTP-ZZ-07010, Alternate Method to Obtain CHARMS Reading.

The (>15,000 R/hr) reading is a value, which indicates significant fuel damage well in excess of the EALs associated with both loss of Fuel Clad and loss of RCS Barriers. A major release of radioactivity requiring offsite protective actions from core damage is not possible unless a major failure of fuel cladding allows radioactive material to be released from the core into the reactor coolant. Regardless of whether containment is challenged, this amount of activity in containment, if released, could have such severe consequences that it is prudent to treat this as a potential loss of containment, such that a General Emergency declaration is warranted. NUREG-1228, Source Estimations During Incident Response to Severe Nuclear Power Plant Accidents,'

indicates that such conditions do not exist when the amount of clad damage is less than 20%. The radiation monitor reading corresponding to 20% fuel clad damage was calculated using the Westinghouse Owners Group (WOG) 'Post Accident Core Damage Assessment Methodology (CDAM) dated November 1984. This document was approved by the NRC for core damage assessment. Based upon a Containment high Range Area Radiation Monitor (CHARM) reading, a percent clad damage (equivalent to percent noble gas release) can be estimated. Westinghouse makes the assumption that any percent noble gas release requires an equal percent clad damage. Conversely, a Radiation Monitor reading can be produced given the percent clad damage.

7. Core Exit Thermocouples The condition in this EAL potential loss represents imminent melt sequence which, if not corrected, could lead to vessel failure and an increased potential for containment failure.

8. Radiation Increase Outside Containment This potential loss indicator represents a loss of the containment barrier by increased radiation levels in areas adjacent to the containment which cannot be explained from leaks outside of the containment barrier.

Page 11 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 2 Fission Product Barriers CONTAINMENT BARRIER EAL9 (cont):

Radiation Monitor Reading (R/hr) x CTMT Volume (ft3)

R/hr - MWt =

Plant Power (MWt) x 2x10b(fti) where:

R/hr - MWt = 5.5 for a 20% noble gas release.equivalent to 20% clad failure.

CTMT Volume = 2.5x106 ft3 Plant Power = 3565 MWt Solving for Radiation Monitor Reading:

5.5(3565 MWt)(2x106 ft3 )

CHARM Reading = 3 2.5xlOsfti

= 15686 R/hr

7. Core Exit Thermocouples In this EAL, the function restoration procedures are those emergency operating procedures that address the recovery of the core cooling critical safety functions.

The procedure is considered effective if the temperature is decreasing or if the vessel water level is increasing.

The conditions in this potential loss EAL represent imminent melt sequence, which, if not corrected, could lead to vessel failure and an increased potential for containment failure. In conjunction with the core exit thermocouple EALs, RCS BARRIER indicator

1. and FUEL CLAD BARRIER indicator 1., this EAL would result in the declaration of a General Emergency -- loss of two barriers and the potential loss of a third. If the function restoration procedures are ineffective, there is no 'success' path.

Several accident analyses (e.g., NUREG--1150) have concluded that function restoration procedures can arrest core degradation within the reactor vessel in a significant fraction of the core damage scenarios, and that the likelihood of containment failure is very small in these events. Given this, it is appropriate to provide a reasonable period to allow function restoration procedures to arrest the core melt sequence.

Whether or not the procedures will be effective should be apparent within 15 minutes.

The Emergency Coordinator should make the declaration as soon as it is determined that the procedures have been, or will be ineffective.

RCS BARRIER EALs:

The RCS Barrier includes the RCS primary side and its connections up to and including the pressurizer safety and relief valves, and other connections up to and including the primary isolation valves.

Page 12 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 2 Fission Product Barriers Loss Indicators

1. RCS Leak Rate The 'Loss" EAL addresses conditions where leakage from the RCS is greater than available inventory control capacity such that a loss of subcooling has occurred. The loss of subcooling is the fundamental indication that the inventory control systems are inadequate in maintaining RCS pressure and inventory against the mass loss through the leak. Safety injection initiated indicates all available inventory control capacity is in service.

2. SG Tube Rupture This EAL is intended to address the full spectrum of Steam Generator (SG) tube rupture events in conjunction with Containment Barrier 'Loss' EAL 3 and Fuel Clad Barrier EALs. The 'Loss' EAL addresses ruptured SG(s) with an unisolable Secondary Line Break corresponding to the loss of 2 of 3 fission product barriers (RCS Barrier and.

Containment Barrier, this EAL will always result in Containment Barrier "Loss' EAL 3).

This allows the direct release of radioactive fission and activation products to the environment. Resultant offsite dose rates are a function of many variables. Examples include: Coolant Activity, Actual Leak Rate, SG Carry Over, Iodine Partitioning, and Meteorology. Therefore, dose assessment in accordance with EAL ID., *Site Boundary Dose Resulting from an Actual or Imminent Release of Gaseous Radioactivity that Exceeds 1000 mR Whole Body or 5000 mR Thyroid for the Actual or Projected Duration of the Release Using Actual Meteorology', is required when there is indication that the fuel matrix/clad is potentially lost.

Indications are consistent with the diagnostic activities of the Emergency Operating Procedures (EOPs). This includes indication of S/G level increasing uncontrollably, increased secondary radiation levels, and an uncontrolled or complete depressurization of the ruptured SG. Secondary radiation increases are observed via radiation monitoring of Condenser Air Ejector Discharge, SG Blowdown, and SG Sampling System.

Determination of the 'uncontrolled, depressurization of the ruptured SG should be based on indication that the pressure decrease in the ruptured steam generator is not a function of operator action. This should prevent declaration based on a depressurization that results from an EOP induced cooldown of the RCS that does not involve the prolonged release of contaminated secondary coolant from the affected SG to the environment. This EAL includes unisolable steam breaks, feed breaks, and stuck open safety or relief valves. The manual use of a ruptured SG PORV for cooldown and steam supplied to the TDAFW Turbine also meets this Initiating Condition.

Page 13 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 2 Fission Product Barriers RCS BARRIER EALs (cont):

3. Containment Radiation Monitoringr If GT-RE-59 and GT-RE-60 are not available, refer to HTP-ZZ-07010, Alternate Method to Obtain CHARMS Reading.

The (6.4 R/hr) reading is a value, which indicates the release of reactor coolant to the containment. The reading was calculated assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with normal operating concentrations (i.e., within T/S) into the containment atmosphere.

Table 6 of ANSI/ANS-18.l-1984 was used to determine the RCS source term for nominal concentrations of noble gas and iodine radionuclides. A containment radiation level of greater than 6.4 R/Hr on GT-RE-59/60 is used to indicate a loss of RCS barrier fission product barrier. See Attachment 3, Page 3 of 4.

Potential Loss Indicators

4. Critical Safety Function Status RED path indicates an extreme challenge to the safety function derived from appropriate instrument readings, and these CSFs indicate a potential loss of RCS barrier.

5. RCS Leak Rate The 'Potential Loss' EAL is based on the inability to maintain normal liquid inventory within the Reactor Coolant System (RCS) by normal operation of the Chemical and Volume Control System which is considered as any one of three centrifugal charging pumps discharging to the charging header. In conjunction with the SG Tube Rupture

'Potential Loss' EAL this assures that any event that results in significant RCS inventory shrinkage or loss (e.g., events leading to reactor trip and ECCS actuation) will result in no lower than an 'Alert" emergency classification. The 50 gpm indicator is based on 1 CCP in service with a 75 gpm letdown orifice in service.

6. SG Tube Rupture The 'Potential Loss" indications are consistent with the diagnostic activities of the Emergency Operating Procedures with indications based on the inability to maintain normal liquid inventory within the Reactor Coolant System (RCS) by normal operation of the Chemical and Volume Control System. This is considered as any one of three centrifugal charging pumps discharging to the charging header. In conjunction with the RCS Leak Rate 'Potential Loss" EAL this assures that any event that results in significant RCS inventory shrinkage or loss (e.g., events leading to reactor trip and ECCS actuation) will result in no lower than an 'Alert" emergency classification.

Page 14 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 2 Fission Product Barriers FUEL CLAD BARRIER EALs:

The Fuel Clad Barrier is the zircalloy tubes that contains the fuel pellets.

Loss Indicators

1. Critical Safety Function Status RED path indicates an extreme challenge to the safety function. ORANGE path indicates a severe challenge to the safety function.

Core Cooling - RED indicates significant superheating and core uncovery and is considered to indicate loss of the Fuel Clad Barrier.

A separate core exit TC value is not used as a loss indicator, as a 12000 TC value is a red path for core cooling and would be a redundant indication.

2. Primary Coolant Activity Level Assessment by the NUMARC EAL Task Force indicates that this amount of coolant activity is well above that expected for iodine spikes and corresponds to about 2% to 5% fuel clad damage. This amount of clad damage indicates significant clad heating and thus the Fuel Clad Barrier is considered lost.

DEI is determined by Chemistry procedure CTP-ZZ-08100, Post Accident Sampling Guidelines.

3. Containment Radiation Monitoring If GT-RE-59 and GT-RE-60 are not available, refer to HTP-ZZ-07010, Alternate Method to Obtain CHARMS Reading.

The >2800 R/hr reading is a value which indicates the release of reactor coolant, with elevated activity indicative of fuel damage, into the containment. The reading was calculated assuming the instantaneous release and dispersal of the reactor coolant noble gas and iodine inventory associated with a concentration of 300 pCi/gm dose equivalent 1-131 into the containment atmosphere. Reactor coolant concentrations of this magnitude are several times larger than the maximum concentrations (including iodine spiking) allowed within technical specifications and are therefore indicative of fuel damage (approximately 2 - 5% clad failure depending on core inventory and RCS volume). See Attachment 3, Page 4 of 4.

Page 15 of 50 ATTACHMENT 2

EIP-ZZ-001 01 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 2 Fission Product Barriers FUEL CLAD BARRIER EALs (cont):

Potential Loss Indicators RED path indicates an extreme challenge to the safety function. ORANGE path indicates a severe challenge to the safety function.

4. Critical Safety Function Status Core Cooling - ORANGE indicates subcooling has been lost and that some clad damage may occur. Heat Sink - RED indicates the ultimate heat sink function is under extreme challenge and thus these two items indicate potential loss of the Fuel Clad Barrier.

A separate core exit TC value is not used as a potential loss indicator, as a 700° TC value is an orange path for core cooling and would be a redundant indication.

5. Core Exit Thermocouples The 700° corresponds to a loss of subcooling that will require at least a Core Cooling

'ORANGE path'.

6. Reactor Vessel Water Level This level is approximately at the top of the active fuel and corresponds to the Core Cooling ORANGE path' values.

Page 16 of 50 ATIACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACMION LEVEL INDICATORS BASES Group 3 Hazards Affecting Plant Safety Initiating Condition Emergency Classification A. Confirmed Security Event Unusual Event Which Indicates a Potential Degradation in the Level of Safety of the Plant.

MODES: At All Times Indicators Any of the following:

1. Bomb device discovered within the plant Protected Area and outside the following Safe Shutdown Areas:

• Area 5

• Containment

• Aux Feed Pump Rooms

• Aux Building

• Diesel Generator Building

• UHS Cooling Tower

• ESW Pumphouse

• Control Building

• RWST

• Fuel Building

2. Confirmed report of an attempted entry or sabotage.

3. A site specific credible security threat.

Bases:

A Security Threat is any event in which there is a reason to believe that a person or persons has threatened to commit or cause, or attempted to commit or cause any of the following.

1. A theft or unlawful diversion of nuclear fuel or spent nuclear fuel from the plant site.

2. Significant physical damage to the plant, its equipment, nuclear fuel, spent nuclear fuel or carrier equipment transporting nuclear fuel or spent nuclear fuel.

3. Interruption of the plant's normal operations through the unauthorized use of, or tampering with, the plant's equipment, machinery, components, controls or security system.

4. Any armed attack of the plant's Protected area.

5. Credible bomb or extortion threat.

6. Confirmed hostage or duress situation at the Callaway Plant.

A confirmed threat is considered credible if notification of the threat has come from the NRC, FBI, or Local Law Enforcement and they consider the threat to be credible or if the threat is deemed credible by the SS/EDO, and the threat is specifically directed at the Callaway Plant.

Page 17 of 50 ATrACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 3 Hazards Affecting Plant Safety Initiating Condition Emergency Classification B. Security Event in the Alert Plant Protected Area.

MODES: At All Times Indicators Confirmed report of an intrusion by a hostile force into the plant Protected Area.

Bases:

This class of security events represents an escalated threat to plant safety above that contained in the Unusual Event.

Page 18 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 3 Hazards Affecting Plant Safety Initiating Condition Emergencv Classification C. Security Event in a Site Emergency Safe Shutdown Area.

MODES: At All Times Indicator Anv of the following

1. Bomb device discovered within any of the following areas:

• Area 5

• Containment

• Aux Feed Pump Rooms

• Aux Building

• Diesel Generator Building

• UHS Cooling Tower

• ESW Pumphouse

• Control Building

• RWST

• Fuel Building

2. Confirmed report of an intrusion by a hostile force into any of the following areas:

• Area 5

• Containment

• Aux Feed Pump Rooms

• Aux Building

• Diesel Generator Building

• UHS Cooling Tower

• ESW Pumphouse

• Control Building

• RWST

• Fuel Building Bases:

This class of security events represents an escalated threat to plant safety above that contained in the Alert Initiating Condition in that a hostile force has progressed from the Protected Area to a Safe Shutdown Area. These areas contain Safe Shutdown Systems as defined per the FSAR Appendix 5.4(A).

Page 19 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 3 Hazards Affecting Plant Safety Initiating Condition Emergencv Classification D. Security Event Resulting General Emergency in a Loss of the Ability to Reach and Maintain Cold Shutdown.

MODES: At All Times Indicator Anv of the following:

1. Occupation of the Control Room by a hostile force.

2. Occupation of the Aux Shutdown Panel by a hostile force.

Bases:

This Initiating Condition encompasses conditions under which a hostile force has taken physical control of Safe Shutdown areas required to reach and maintain safe shutdown.

Page 20 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 3 Hazards Affecting Plant Safety Initiating Condition Emergency Classification E. Fire Within Protected Unusual Event Area Boundary Not Extinguished Within 15 Minutes of Verification MODES: At All Times Indicator

1. Fire in or adjacent to any of the following:

• Area 5

• Containment

• Aux Feed Pump Rooms

• Aux Building

• Diesel Generator Building

• UHS Cooling Tower

• ESW Pumphouse

• Control Building

• RWST

• Fuel Building and

2. Not extinguished within 15 minutes of control room verification of a fire.

Bases:

The purpose of this Initiating Condition is to address the magnitude and extent of fires that may be potentially significant precursors to damage to safety systems. This excludes such times as fires within administration buildings, waste-baskets fires, and other small fires of no safety consequence. This Initiating Condition applies to buildings and areas adjacent to Safe Shutdown areas or other significant buildings or areas. The intent of this Initiating Condition is not to include buildings (i.e., warehouses) or areas that are not immediately adjacent to Safe Shutdown areas. These areas contain Safe Shutdown Systems as defined per the FSAR Appendix 5.4(A). Verification of the alarm in this context means those actions taken in the control room to determine that the control room alarm is not spurious.

Page 21 of 50 ATTACHMENT 2

EIP-ZZ-001 01 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 3 Hazards Affecting Plant Safety Initiating Condition Emergency Classification F. Fire Affecting the Alert Operability of Plant Safety Systems Required to Establish or Maintain Safe Shutdown.

MODES: At All Times Indicators

1. Fire in any of the following areas:

• Area 5

• Containment

• Aux Feed Pump Rooms

• Aux Building

• Diesel Generator Building

• UHS Cooling Tower

• ESW Pumphouse

• Control Building

• RWST

• Fuel Building and

2. There is visible damage to permanent structures or equipment, affecting the operability of safety related equipment.

Bases:

Areas containing functions and systems required for the safe shutdown of the plant are specified per FSAR Appendix 5.4(A).

The inclusion of a 'report of visible damage should not be interpreted as mandating a lengthy damage assessment prior to classification. No attempt is made in this EAL to assess the actual magnitude of the damage. The declaration of an Alert and the activation of the TSC will provide the Emergency Coordinator with the resources needed to perform these damage assessments.

Page 22 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 3 Hazards Affecting Plant Safety Initiating Condition Emergency Classification G. Natural and Destructive Unusual Event Phenomena Affecting the Protected Area.

MODES: At All Times Indicators Any of the following:

1. a. Response spectrum recorder operating annunciator 98E alarms in the Control Room and

b. Verified to be a real event per OTO-SG-00001.

2. Report of a turbine rotating component failure resulting in casing penetration or major damage to seals causing a rapid loss of lubricating oil or hydrogen.

3. Explosion, vehicle crash or tornado in or adjacent to any of the following:

• Area 5

• Containment

• Aux Feed Pump Rooms

• Aux Building

• Diesel Generator Building

• UHS Cooling Tower

• ESW Pumphouse

• Control Building

• RWST

• Fuel Building Bases:

The Protected Area Boundary is defined in the site security plan.

Indicator 1 was developed on a site-specific basis. Damage may be caused to some portions of the site, but should not affect ability of safety functions to operate. Method of detection is response validated per OTO-SG-00001. As defined in the EPRI-sponsored 'Guidelines for Nuclear Plant Response to an Earthquake', dated October 1989, a 'felt earthquake is:

An earthquake of sufficient intensity such that: (a) the vibratory ground motion is felt at the nuclear plant site and recognized as an earthquake based on a consensus of control room operators on duty at the time, and (b) for plants with operable seismic instrumentation, the seismic switches of the plant are activated. For most plants with seismic instrumentation, the seismic switches are set at an acceleration of about 0.01g.

Page 23 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 3 Hazards Affecting Plant Safety Indicator 2 is intended to address main turbine rotating component failures of significant magnitude to cause observable damage to the turbine casing or to the seals of the turbine generator. Of major concern is the potential for rapid loss of combustible fluids (lubricating oils) and gases (hydrogen cooling) to the plant environs. This EAL is consistent with the definition of an Unusual Event while maintaining the anticipatory nature desired and recognizing the risk to non-safety related equipment.

In indicator 3 only those events in or adjacent to any area containing Safe Shutdown Systems, should be considered. As used here, an explosion is a rapid, violent, unconfined combustion, or a catastrophic failure of pressurized equipment, that potentially imparts significant energy to near-by structures and materials. No attempt is made in this EAL to assess the actual magnitude of the damage. The occurrence of the explosion with reports of evidence of damage (e.g., deformation, scorching) is sufficient for declaration.

Page 24 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 3 Hazards Affecting Plant Safety Initiatina Condition Emergency Classification H. Natural and Destructive Alert Phenomena Affecting a Safe Shutdown Area.

MODES: At All Times Indicators Any of the following:

1. a. Operating basis earthquake annunciator 98D alarms in the Control Room and

b. Earthquake greater than OBE levels (0.12g)in the horizontal and vertical directions as indicated by LIGHT 'OSG-AE-lor LIGHT

• OSG-AE-21

2. a. Report of a tornado, high wind, vehicle crash, explosion, or other natural or destructive phenomena to any of the following Safe Shutdown areas:

• Area 5

• Containment

• Aux Feed Pump Rooms

• Aux Building

• Diesel Generator Building

• UHS Cooling Tower

• ESW Pumphouse

• Control Building

• RWST

• Fuel Building and

b. There is visible damage to permanent structures or equipment, affecting plant operations.

Bases:

Indicator 1 is based on FSAR design basis. Seismic events of this magnitude can cause damage to safety functions.

Indicator 2 specifies areas containing systems and functions required for safe shutdown of the plant per FSAR Appendix 5.4(A). This indicator is intended to address such items as plane or helicopter crash into a plant vital area.

Each-of these EALs is intended to address events that may have resulted in a plant vital area being subjected to forces beyond design limits, and thus damage may be assumed to have occurred to plant safety systems. The initial report' should not be interpreted as mandating a lengthy damage assessment magnitude of the damage. The declaration of an Alert and the activation of the TSC will provide the Emergency Coordinator with the resources needed to perform these damage assessments.

Page 25 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 3 Hazards Affecting Plant Safety Initiating Condition Emergencv Classification I. Release of Toxic or Unusual Event Flammable Gases Deemed Detrimental to Safe Operation of the Plant.

MODES: At All Times Indicators Apy of the following:

1. Report or detection of toxic or flammable gases that enter within the Exclusion Area Boundary, that have created a HAZARDOUS ATMOSPHERE per CTP-ZZ-01300, deemed detrimental to safe operation.

2. Confirmed report by local, County or State Officials of potential evacuation of site personnel as determined from the DOT evacuation tables for selected hazardous materials in the DOT Emergency Response Guide for Hazardous Materials.

Bases:

This Initiating Condition is based on releases in concentrations within the site boundary that will affect the health of plant personnel or affecting the safe operation of the plant with the plant being within the evacuation area of an offsite event (i.e., tanker truck accident releasing toxic gases, etc.) The evacuation area is as determined from the DOT Evacuation Tables for Selected Hazardous Materials, in the DOT Emergency Response Guide for Hazardous Materials.

This EAL does not apply to routine or planned activities such as painting, use of cleaners/solvents, etc., that do not affect safe operation of the Plant.

Page 26 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 3 Hazards Affecting Plant Safety Initiating Condition Emergency Classification J. Release of Toxic or Alert Flammable Gases Within a Facility Structure Which Jeopardizes Operation of Systems Required to Establish or Maintain Cold Shutdown.

MODES: At All Times Indicators Any of the following:

1. Report or detection of a toxic or flammable gases, not properly contained, within or adjacent to any of the following Safe Shutdown Areas, that have created a HAZARDOUS ATMOSPHERE per CTP-ZZ-01300, jeopardizing operation of systems required to establish or maintain Cold Shutdown.

• Area 5

• Containment

• Aux Feed Pump Rooms

• Aux Building

• Diesel Generator Building

• UHS Cooling Tower

• ESW Pumphouse

• Control Building

• RWST

• Fuel Building Bases:

This Initiating Condition is based on gases that have entered a plant structure affecting the safe operation of the plant. This Initiating Condition applies to Safe Shutdown Areas. The intent of this Initiating Condition is not to include buildings (i.e., warehouses) or other areas that are not immediately adjacent to Safe Shutdown Areas. It is appropriate that increased monitoring be done to ascertain whether consequential damage has occurred.

Page 27 of 50 ATrACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 3 Hazards Affecting Plant Safety Initiating Condition Emergency Classification K. Control Room Evacuation Alert Has Been Initiated.

MODES: At All Times Indicators Entry into OTO-ZZ-00001, Control Room Inaccessibility, is required.

Bases:

With the control room evacuated, additional support, monitoring and direction through the Technical Support Center and/or other Emergency Operations Center is necessary.

Page 28 of 50 AWTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 3 Hazards Affecting Plant Safety InitiatinQ Condition Emergency Classification L. Control Room Evacuation Site Emergency Has Been Initiated and Plant Control Cannot Be Established.

MODES: At All Times Indicators iI

1. Entry into OTO-ZZ-00001, Control Room Inaccessibility is required.

and

2. Control of the Aux Feed System and a SG PORV for cooldown cannot be established within 15 minutes.

Bases:

Expeditious transfer of safety systems has not occurred but fission product barrier damage may not yet be indicated. The time for transfer is based on how quickly control must be reestablished without core uncovering and/or core damage. In cold shutdown and refueling modes, operator concern is directed toward maintaining core cooling such as is discussed in Generic Letter 88-17, 'Loss of Decay Heat Removal.' In power operation, hot standby, and hot shutdown modes, operator concern is primarily directed toward maintaining critical safety functions and thereby assuring fission product barrier integrity.

The 15 minutes is consistent with Westinghouse Response Plan for Immediate Evacuation of the Control Room Time Study. Plant cooldown established per OTO-ZZ-00001 would require Aux feed to be initiated and control of SG Power Operated Relief valves and the Aux feed pumps to be established from the Aux shutdown panel.

4 Page 29 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 4 System Malfunctions Initiating Condition Emergency Classification A. Unplanned Loss of Most Unusual Event or All Alarms (Annunciators) for Greater Than 15 Minutes.

MODES: 1-4 Indicators

1. Any of the following:

a. 3 of 4 field power supplies have failed for greater than 15 minutes (loss of all annunciators) and not a result of planned action.

b. Field Power Supply voltage is less than 105 volts for greater than 15 minutes (loss of all annunciators) and not a result of planned action.

c. Ten or more logic power supplies have failed for greater than 15 minutes (loss of all annunciators) and not a result of planned action.

d. Five or more Multiplexer Adapter Rack Fuses have failed for greater than 15 minutes and not a result of planned action.

or

2. All of the following:

a. Any combination of power supplies (including Optical Isolators) or Multiplexer Adapter Rack Fuses have failed for greater, than 15 minutes.

b. Any minimum compensatory actions, per OTO-RK-00001, cannot be maintained.

c. The loss does not result from planned action.

Bases:

This Initiating Condition and its associated EAL are intended to recognize the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment.

Since the system is operating at just over 3 amps, and each power supply is rated for a maximum 3 amps, soon after losing the third power supply the fourth will fail due to overcurrent. Output voltage of the Field Power Supply less than 105 volts indicates that a degraded voltage situation exists. Under this condition, all Field Power Supplies are considered inoperable.

Losing 10 of the 14 logic power supplies is considered losing 'Most' annunciators.

Losing 5 of the 8 annunciator racks is considered losing 'Most' of the annunciators.

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

Due to the limited number of safety systems in operation during cold shutdown, refueling, and defueled modes; no Initiating Condition is indicated during these modes of operation.

This Unusual Event will be escalated to an Alert if a transient is in progress during the loss of annunciation or indication.

i Page 30 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 4 System Malfunctions Initiating Condition Emergencv Classification B. Unplanned Loss of Most or All Alert Annunciators With Either a Transient In Progress, or the Plant Computer is Unavailable.

MODES: 1-4 Indicators

1. Any of the following:

a. 3 of 4 field power supplies have failed for greater than 15 minutes (loss of all annunciators) and not a result of planned action.

b. Field Power Supply voltage is less than 105 volts for greater than 15 minutes (loss of all annunciators) and not a result of planned action.

c. Ten or more logic power supplies have failed for greater than 15 minutes (loss of all annunciators) and not a result of planned action.

d. Five or more Multiplexer Adapter Rack Fuses have failed for greater than 15 minutes and not a result of planned action.

or

2. All of the following:

a. Any combination of power supplies (including Optical Isolators).or Multiplexer Adapter Rack Fuses have failed for greater than 15 minutes.

b. Any minimum compensatory actions, per OTO-RK-00001, cannot be maintained.

c. The loss does not result from planned action.

and

3. Any of the following:

a. A change in reactor power greater than + 10%.

b. Safety injection initiation.

c. Compensatory plant parameters monitored via the plant computer, per OTO-RK-00001, are not valid or cannot be obtained.

Bases:

This Initiating Condition and its associated EAL are intended to recognize the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment during a transient. Recognition of the availability of computer based indication equipment is considered SPDS, plant computer, etc.)

Since the system is operating at just over 3 amps, and each power supply is rated for a maximum 3 amps, soon after losing the third power supply the fourth will fail due to overcurrent. Output voltage of the Field Power Supply less than 105 volts indicates that a degraded voltage situation exists. Under this condition, all Field Power Supplies are considered inoperable.

Losing 10 of the 14 logic power supplies is considered losing 'Most annunciators.

Losing 5 of the 8 annunciator racks is considered losing 'Most" of the annunciators.

'Planned, loss of annunciators or indicators includes scheduled maintenance and testing activities.

If both a major portion of the annunciation system and all computer monitoring are unavailable to the extent that additional operating personnel are required to monitor I indications, the Alert is required.

Due to the limited number of safety systems in operation during cold shutdown, refueling and defueled modes. No Initiating Condition is indicated during these modes of operation.

This Alert will be escalated to a Site Emergency if the operating Crew cannot monitor the transient in progress.

Page 31 of 50 ATT7ACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 4 System Malfunctions Initiating Condition Emergency Classification C. Inability to Monitor a Site Emergency Significant Transient in Progress.

MODES: 1-4 Indicators

1. Any of the following:

a. 3 of 4 field power supplies indicate < 105 volts (loss of all annunciators).

b. Field Power Supply voltage is less than 105 volts (loss of all annunciators).

c. Ten or more logic power supplies have failed (loss of all annunciators).

d. Five or more Multiplexer Adapter Rack Fuses have failed (loss of all annunciators).

or

2. All of the following:

a. Any combination of power supplies (including Optical Isolators) or Multiplexer Adapter Rack Fuses have failed.

b. Any minimum compensators actions, per OTO-RK-00001, cannot be maintained.

and

3. Any of the following:

a. A change in reactor power greater than +10 %.

b. Safety injection initiation.

and

4. Compensatory plant parameters monitored via the plant computer, per OTO-RX-00001, are not valid or cannot be obtained.

Bases:

This Initiating Condition and its associated EAL are intended to recognize the inability of the control room staff to monitor the plant response to a transient. A Site Emergency is considered to exist if the control room staff cannot monitor safety functions needed for protection of the public.

Since the system is operating at just over 3 amps, and each power supply is rated for a maximum 3 amps, soon after losing the third power supply the fourth will fail due to overcurrent. Output voltage of the Field Power Supply less than 105 volts indicates that a degraded voltage situation exists. Under this condition, all Field Power Supplies are considered inoperable.

Losing 10 of the 14 logic power supplies is considered losing Mosts annunciators.

Losing 5 of the 8 annunciator racks is considered losing 'Most, of the annunciators.

'Planned' actions are included in this EAL since the loss of instrumentation of this magnitude is of such significance during a transient that the cause of the loss is not important.

Page 32 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 4 System Malfunctions Initiating Condition Emergencv Classification D. Loss of All Offsite Power Unusual Event to Essential Busses for Greater Than 15 Minutes.

MODES: 1-6 Indicators All of the following:

1. Loss of offsite power to NB01 and NBO2.

2. The loss of offsite power has occurred for >15 minutes.

Bases:

Prolonged loss of AC power reduces required redundancy and potentially degrades the level of safety of the plant by rendering the plant more vulnerable to a complete Loss .of AC Power (Station Blackout). Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Page 33 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 4 System Malfunctions Initiating Conditions Emergency Classification E. Only One AC Source to Alert Essential Busses for

>15 Minutes Such That Any Additional Single Failure Would Result In Station Blackout.

MODES: 1-4 Indicators

1. Loss of any 3 of the following power sources:

a. Offsite power to NB01

b. Offsite power to NBO2

c. Emergency Diesel NE01

d. Emergency Diesel NE02 and

2. The Loss of all 3 has occurred for >15 minutes.

Bases:

The condition indicated by this Initiating Condition is the degradation of the off-site and on-site power systems such that any additional single failure would result in a station blackout.

The subsequent loss of this single power source would escalate the event to a Site Emergency after an additional 15 minutes.

Page 34 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 4 System Malfunctions Initiating Condition EmerQency Classification F. Loss of All Offsite Site Emergency Power and Loss of All Onsite AC Power to Essential Busses.

MODES: 1-4 Indicators

1. Loss of all 4 of the following power sources:

a. Offsite power to NB01

b. Offsite power to NBO2

c. Emergency Diesel NE01

d. Emergency Diesel NE02 and

2. The Loss of all 4 has occurred for >15 minutes.

Bases:

Loss of all AC power compromises all plant safety systems requiring electric power including RHR, ECCS, Containment Heat Removal and the Ultimate. Heat Sink. Prolonged loss of all AC power will cause core uncovering and loss of containment integrity, thus this event can escalate to a General Emergency.

The 15 minutes ensures the loss is other than a transient or momentary power loss.

I Page 35 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 4 System Malfunctions Initiating Condition Emergencv Classification G. Loss of All Vital DC Site Emergency Power MODES: 1-4 Indicators

1. Loss (Bus Voltage < 106.9 VDC) of all 4 of the following busses:

I

a. NK01

b. NK02

c. NK03

d. NK04 and

2. Failure to restore power to at least one DC bus within 15 minutes.

Bases:

Loss of all DC power compromises ability to monitor and control plant safety functions.

Prolonged loss of all DC power will cause core uncovering and loss of containment integrity when there is significant decay heat and sensible heat in the reactor system. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

f I

Page 36 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACIMON LEVEL INDICATORS BASES Group 4 System Malfunctions Initiating Condition Emergencv Classification H. Prolonged Loss of All General Emergency Offsite Power and Prolonged Loss of All Onsite AC Power.

MODES: 1-4 Indicators All of the following:

1. Loss of offsite power to NB01 and NBO2.

2. Loss of both Emergency Diesel Generators NE01 and NE02.

3. a. Restoration of at least one emergency bus within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is not likely.

or

b. Meet the entry requirements for FRC.1, Red Path for Core Cooling.

Bases:

Loss of all AC power compromises all plant safety systems requiring electric power including RHR, ECCs, Containment Heat Removal and the Ultimate Heat Sink. Prolonged loss of all AC power will lead to loss of fuel clad, RCS, and containment. The 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> to restore AC power is based on a site blackout coping analysis FSAR Appendix 8.3A 'Station Blackout', performed in conformance with 10 CFR 50.63 and Regulatory Guide 1.155, 'Station-Blackout".

This Initiating Condition is specified to assure that in the unlikely event of a prolonged station blackout, timely recognition of the seriousness of the event occurs and that declaration of a General Emergency occurs as early as is appropriate, based on a reasonable assessment of the event trajectory.

The likelihood of restoring at least one emergency bus should be based on a realistic appraisal of the situation since a delay in an upgrade decision based on only a chance of mitigating the event could result in a loss of valuable time in preparing and implementing public protective actions. In addition, under these conditions, fission product barrier monitoring capability may be degraded. Although it may be difficult to predict when power can be restored, it is necessary to give the Emergency Coordinator a reasonable idea of how quickly (s)he may need to declare a General Emergency based on two major considerations:

1. Are there any present indications that core cooling is already degraded to the point that Loss or Potential Loss of Fission Product Barriers is IMMINENT?

2. If there are no present indications of such core cooling degradation, how likely is it that power can be restored in time to assure that a loss of two barriers with a potential loss of the third barrier can be prevented?

Page 37 of 50 oATACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 4 System Malfunctions Initiating Condition Emergency Classification I. Loss of Required DC Power Unusual Event During Cold Shutdown or Refueling Mode for Greater Than 15 Minutes.

MODES: 5,6 Indicators

1. Loss of Division 1 Vital DC power as indicated by <106.9 VDC on:

NKO1 or NK03 and Loss of Division 2 Vital DC power as indicated by <106.9 VDC on:

NK02 or NK04.

and

2. Failure to restore power to at least one operable Division of Vital DC power within 15 minutes.

Bases:

The purpose of this Initiating Condition and its associated EALs is to recognize a loss of DC power compromising the ability to monitor and control the removal of decay heat during Cold Shutdown or Refueling operations. This EAL is intended to be anticipatory in as much as the operating crew may not have necessary indication and control of equipment needed to respond to the loss.

Unplanned was not used in this Initiating Condition and EAL, because as written one Division of Vital DC power can be inoperable for planned maintenance activities. The loss of the remaining operable train would require an Unusual Event. In no instance would maintenance be planned on both divisions.

The 106.9 VDC bus voltage in Indicator 1, is based on the minimum bus voltage necessary for the operation of safety related equipment.

Page 38 of 50 ATIACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 4 System Malfunctions InitiatinQ Condition Emergency Classification J. Loss of All Offsite Power Unusual Event to Essential Busses for Greater Than 15 Minutes.

MODES: 5-6 Indicators All of the following: I

1. Loss of offsite power to NB01 and NBO2.

2. The loss of offsite power has occurred for >15 minutes.

Bases:

Prolonged loss of AC power reduces required redundancy and potentially degrades the level of safety of the plant by rendering the plant more vulnerable to a complete Loss of AC Power (Station Blackout). Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Page 39 of 50 AT7ACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 4 System Malfunctions Initiating Condition Emergency Classification K. Loss of All Offsite Alert Power and Loss of All Onsite AC Power to Essential Busses During Cold Shutdown or Refueling.

MODES: 5,6, and Defueled Indicators

1. Loss of all 4 of the following power sources:

a. Offsite power to NBOl

b. Offsite power to NBO2

c. Emergency Diesel NE01

d. Emergency Diesel NE02 and

2. The loss of all 4 has occurred for >15 minutes.

Bases:

Loss of all AC power compromises all plant safety systems requiring electric power including RHR, ECCS, Containment Heat Removal, Spent Fuel Heat Removal and the Ultimate Heat Sink.

When in cold shutdown, refueling, or defueled mode the event can be classified as an Alert, because of the significantly reduced decay heat, lower temperature and pressure, increasing the time to restore one of the emergency busses, relative to that specified for the Site Emergency EAL. Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

Page 40 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 4 System Malfunctions InitiatinQ Condition Emergency Classification L.* Inability to Perform a Unusual Event Required Shutdown Within Technical Specification Limits.

MODES: 1-4 Indicators

1. The plant is not brought to a required operating mode within a Technical Specification LCO action completion time.

• It is not intended to declare an Unusual Event due to an unknown condition or failure resulting in exceeding the allowable action statement time. The allowable action completion time is always available from the time of discovery.

Bases:

Limiting Conditions of Operation (LCOs) require the plant to be brought to a required shutdown mode when the Technical Specification required configuration cannot be restored.

Depending on the circumstances, this may or may not be an emergency or precursor to a more severe condition. In any case, the initiation of plant shutdown required by the site Technical Specifications requires a one hour report fewer than 10 CFR 50.72 (b) Non-emergency events. The plant is within its safety envelope when being shut down within the allowable action completion time in the Technical Specifications. An immediate Notification of an Unusual Event is required when the plant is not brought to the required operating mode within the allowable action completion time in the Technical Specifications.

Page 41 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 4 System Malfunctions Initiating Condition Emergency Classification M. Inability to Maintain Alert Plant in Cold Shutdown MODES: 5,6 Indicators

1. Any of the following:

a. Complete loss of both trains of RHR.

b. Complete loss of both trains of CCW.

c. Complete loss of both trains of ESW.

and

2. Either of the following:

a. Greater than 200'F on any valid incore thermocouple.*

b. Uncontrolled temperature rise, with no actions available that will likely prevent approaching 200VF on any valid incore thermocouple.*

• If a thermocouple is not available, use Wide Range Hot Leg temperature indications:

• BBTI413A - Loop 1

• BBTI423A - Loop 2

• RECORDERS BBTR413 - Loop 1 BBTR423 - Loop 2 BBTR433 - Loop 3 BBTR443 - Loop 4 Bases:

Indicators 1 and 2 indicate a complete loss of Technical Specification required functions to maintain Cold Shutdown.

For PWRs, this Initiating Condition and its associated EAL are based on concerns raised by Generic Letter 88-17, 'Loss of Decay Heat Removal." A number of phenomena such as pressurization, vortexing, steam generator U-tube draining, RCS level differences when operating at a mid-loop condition, decay heat removal system design, and level instrumentation problems can lead to conditions where decay heat removal is lost and core uncovery can occur. NRC analyses show that sequences that can cause core uncovery in 15 to 20 minutes and severe core damage within an hour after decay heat removal is lost. Under these conditions, RCS integrity is lost and fuel clad integrity is lost or potentially lost, which is consistent with a Site Emergency.

'Uncontrolled' means that system temperature increase is not the result of planned actions by the plant staff. The intent is to declare the ALERT when less than 2000 F, only when temperature is increasing and it is known that there is not time to take action to stop the temp from exceeding 200'F.

Page 42 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 4 System Malfunctions Initiating Condition Emergencv Classification N. Loss of Water Level That Site Emergency Has or Will Uncover Fuel in the Reactor Vessel.

MODES: 5, 6 Indicators

1. Any of the following:

a. Complete loss of both trains of RHR.

b. Complete loss of both trains of CCW.

c. Complete loss of both trains of ESW.

and

2. Either of the following:

a. Greater than 200'F on any valid incore thermocouple.*

b. Uncontrolled temperature rise, with no actions available that will likely prevent approaching 2000 F on any valid incore thermocouple.*

and

3. a. Water level in the reactor vessel is less than 2.0 inches on BB-LI-0053A or B.

or

b. RVLIS (pumps off) <55%.

• If a thermocouple is not available, use Wide Range Hot Leg temperature indications:

• BBTI413A - Loop 1

• BBTI423A - Loop 2

• RECORDERS BBTR413 - Loop 1 BBTR423 - Loop 2 BBTR433 - Loop 3 BBTR443 - Loop 4 Bases:

Under the conditions specified by this Initiating Condition, severe core damage can occur and reactor coolant system pressure boundary integrity may not be assured.

For indicator 3.a. 2.0 inches is used as the lowest readable level on the instruments within their accuracy. For indicator 3.b. RVLIS (pumps off) is used. If a Reactor Coolant pump is running, void fraction rather than core water level would have to be considered.

This Initiating Condition covers sequences such as prolonged boiling following lQss of decay heat removal. Thus, declaration of a Site Emergency is warranted under the conditions specified by the Initiating Condition. Escalation to a general emergency is via radiological effluence.

.Page 43 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 4 System Malfunctions Initiating Condition Emergencv Classification

0. Complete Loss of Function Site Emergency Needed to Achieve or Maintain Hot Shutdown.

MODES: 1-4 Indicators

1. All of the following:

a. Failure to bring the reactor subcritical with the control rods fully inserted.

b. Complete loss of all Boron Injection Flowpaths.

or

2. All of the following:

a. All steam generator levels <10% wide range.

b. All steam dump valves to condenser (ABUV34, 35, and 36) are NOT responding to steam header pressure controller (AB PK507 or AB UK-33).

c. All steam generator steam dump valves to atmosphere are NOT operating properly (AB-PIC-lA, 2A, 3A, and 4A).

d. Complete loss of both RHR trains. (A complete loss of ESW or CCW constitutes a complete loss of RHR.)

or

3. All of the following:

a. The Ultimate Heat Sink (UHS) is inoperable as a result of level or temperature.

b. Complete loss of both UHS Cooling Tower trains.

Bases:

This EAL addresses complete loss of functions, including ultimate heat sink and reactivity control, required for hot shutdown with the reactor at pressure and temperature. Under these conditions, there is an actual major failure of a system intended for protection of the public. Thus, declaration of a Site Emergency is warranted.

Indicator 1. a., control rods, defines the inability to shutdown the reactor normally.

Indicator l.b., defines the inability to add boric acid to the RCS. A complete loss of Boron Injection is defined as a loss of the required FSAR 16.1.2.2 Boron Injection flowpath(s).

Indicator 2 indicates a complete loss of Heat Sink.

Indicator 3 indicates a complete loss of the Ultimate Heat Sink.

Page 44 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 4 System Malfunctions Initiating Condition Emeraencv Classification P. Unplanned Loss of All Unusual Event Onsite or Offsite Communication Capabilities MODES: 1-6 Indicators

1. All of the following on-site systems:

a. Complete failure of Plant telephone systems.

b. Complete failure of Gai-tronics systems.

c. Complete failure of Plant radios.

d. Complete failure of Plant Emergency Dedicated Phones.

or

2. All of the following offsite systems:

a. Complete failure of ENS (Red Phone) line.

b. Complete failure of Back Up Radio System (BURS).

c. Complete failure of Plant telephone system.

d. Complete failure of the Sheriff's radio system.

e. Complete failure of the Sentry notification system.

Bases:

The purpose of this Initiating Condition and its associated EALs is to recognize a loss of communications capability that either defeats the plant operations staff ability to perform routine tasks necessary for plant operations or the ability to communicate problems with offsite authorities. The loss of offsite communications ability is expected to be significantly more comprehensive than the condition addressed by 10 CFR 50.72.

Indicator 1, encompasses the total loss of all means of routine communications.

Indicator 2, encompasses the loss of all means of communications with offsite authorities.

This EAL is intended to be used only when extraordinary means are being utilized to make communications possible (relaying of information from radio transmissions, individuals being sent to offsite locations, etc.)

Page 45 of 50 ATrACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 4 System Malfunctions Initiating Condition Emergency Classification Q. Fuel Clad Degradation Unusual Event MODES: 1-6 Indicators

1. Anv of the following:

a. >1.0 pCi/gram Dose Equivalent 1-131 for greater than a 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> continuous period.

b. Dose Equivalent 1-131 activity exceeding the limits of Tech Spec Fig.

Fig. 3.4.16-1.

c. >100/E bar pCi/gram of gross radioactivity.

Bases:

This Initiating Condition is included as an Unusual Event because it is considered to be a potential degradation in the level of safety of the plant and a potential precursor of more serious problems.

Indicators 1, 2 and 3 are Technical Specification 3.4.16 limits.

The Alert alarm for the Chemical and Volume Control System Letdown Monitor (Failed Fuel Monitor) SJ-RE-01 was not used as an indicator for high coolant activity. If the monitor alarms, our procedures require sampling to confirm hi activity. Listing it as an indicator duplicates the other indicators.

Page 46 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 4 System Malfunctions Initiating Condition Emergencv Classification R. RCS Leakage Unusual Event MODES: 1-4 Indicators

1. Any of the following:

a. Unidentified leakage greater than 10 gpm.

b. Pressure boundary leakage greater than 10 gpm.

c. Identified leakage greater than 25 gpm.

Bases:

This Initiating Condition is included as an Unusual Event because it may be a precursor of more serious conditions and, as result, is considered to be a potential degradation of the level of safety of the plant. The 10 gpm value for the unidentified and pressure boundary leakage was selected as it is observable with normal control room indications. Lesser values must generally be determined through time-consuming surveillance tests (e.g., mass balances). The EAL for identified leakage is set at a higher value due to the lesser significance of identified leakage in comparison to unidentified or pressure boundary leakage.

Page 47 of 50 ATTACHMENT 2

EIP-ZZ-001 01 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 4 System Malfunctions Initiating Condition Emercencv Classification S. Failure of Reactor Alert Protection System Instrumentation to Complete or Initiate an Automatic Reactor Trip Once a Reactor Protection System Setpoint Has Been Exceeded AND Manual Trip Was Successful.

MODES: 1,2 Indicators

1. All of the following:

a. An automatic (not manual) reactor trip setpoint has been exceeded as listed in Attachment 1 of E-0.

b. An automatic reactor trip is NOT successful.

C. A manual reactor trip IS successful using manual trip switches SB-HS-1 on RL003 OR SB-HS-42 on RLOO6.

Bases:

This condition indicates failure of the automatic protection system to trip the reactor..

This condition is more than a potential degradation of a safety system in that a front line automatic protection system did not function in response to a plant transient and thus the plant safety has been compromised, and design limits of the fuel may have been exceeded. An Alert is indicated because conditions exist that lead to potential loss of fuel clad or.RCS.

A reactor protection system setpoint being exceeded (rather than limiting safety system setpoint being exceeded) is specified here because failure of the automatic protection system is the issue.

t Page 48 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. Q31 EMERGENCY ACTION LEVEL INDICATORS BASES Group 4 System Malfunctions Initiating Condition Emergency Classification T. Failure of Reactor Site Emergency Protection System Instrumentation to Complete or Initiate an Automatic Reactor Trip Once a Reactor Protection System Setpoint Has Been Exceeded AND Manual Trip Was NOT Successful.

MODES: 1, 2 Indicators

1. All of the following:

a. An automatic (not manual) reactor trip setpoint has been exceeded as listed in Attachment 1 of E-0.

b. An automatic reactor trip is NOT successful.

c. A manual reactor trip is NOT successful using manual trip switches SB-HS-1 on RL003 AND SB-HS-42 on RLOO6.

Bases:

Automatic and manual trip are not considered successful if action away from the reactor control console was required to trip the reactor.

Under these conditions, the reactor may produce more heat than the maximum decay heat load for which the safety systems are designed.

A Site Emergency is indicated because conditions exist that may lead to imminent loss or potential loss of both fuel clad and RCS. Although this Initiating Condition may be viewed as redundant to the Fission Product Barrier Degradation Initiating Condition, its inclusion is necessary to better assure timely recognition and emergency response.

Page 49 of 50 ATTACHMENT 2

EIP-ZZ-00101 Rev. 031 EMERGENCY ACTION LEVEL INDICATORS BASES Group 4 System Malfunctions Initiating Condition Emercencv Classification U. Failure of the Reactor General Emergency Protection System to Complete an Automatic Trip AND Manual Trip Was NOT Successful AND There is Indication of an Extreme Challenge to the Ability to Cool the Core.

MODES: 1, 2 Indicators

1. All of the following:

a. An automatic (not manual) reactor trip setpoint has been exceeded as listed in Attachment 1 of E-0.

b. An automatic reactor trip is NOT successful.

c. A manual reactor trip is NOT successful using manual trip switches SB-HS-1 on RL003 AND SB-HS-42 on RLOO6.

d. Meet the entry requirements for FRC.1 OR FRH.1, red path summaries for core cooling or heat sink.

Bases:

Automatic and manual trip are not considered successful if action away from the reactor control console is required to scram the reactor.

Under the conditions of this Initiating Condition and its associated EALs, efforts to bring the reactor subcritical have been unsuccessful and, as a result, the reactor is producing more heat than the maximum decay heat load for which the safety systems were designed.

Although there are capabilities away from the reactor control console, such as emergency boration, the continuing temperature rise indicates that these capabilities are not effective. This situation could be a precursor for a core melt sequence.

The entry requirements for FRC.1 indicate an extreme challenge to the ability to cool the core. The entry requirements for FRH.1 indicate a extreme challenge to the ability to initially remove heat during the early stages of this sequence.

In the event either of these challenges exist at a time that the reactor has not been brought below the power associated with the safety system design (typically 3 to 5% power) a core melt sequence exists. In this situation, core degradation can occur rapidly. For this reason, the General Emergency declaration is intended to be anticipatory of the fission product barrier matrix declaration to permit maximum off-site intervention time.

Page 50 of 50 ATI'ACHMENT 2

C (CEIP-ZZ-00101

(

Rev. 031 Containment ARM Dose Rate for Abnormal Radiation Events FHA-RB Iodine EPA-400 EDE Dose Rate Saurce Term Rlter Corrected PERCENT Table 5-3 Weighted Unit Weighted Tech pec equivalent to from calc Correction for OFTOTAL Dose Conversion Dose Conversion correction Dose Conversion value for Tech Spec value Z-341 rev1 Factor* pre-filtration in Cont. FACMR FACIOR factor FAC1OR Cont. Conc of 5.0E-3 uCVcc ISOM PE (CO (unitless) (CO Dec. equiv (rem-cm3luCl-Hr) (rem-cm3/uCi-Hr) (mr/rem) (mr-cm3/uCl-Hr) (uCVcc) (mF'hr)"

Kr-83m O.OOE+00 1 0.00+00 0.000 O.OOE+OO 0.00+00 1.00+03 O.OOE+00 5.00E-03 O.0OE+00 Kr-85 2.46E+02 1 2.46E+02 0.019 1.30E3+00 2.422-02 1.00+03 2.42E+01 5.00E-03 1.21 E-01 Kr-85m O.OOE+00 1 O.OOE+00 0.000 9.30E+01 O.OOE+00 1.00E+03 O.OOE00 5.00E-03 O.OOE+00 Kr-87 O.OOE+00 1 O.OOE+00 0.000 5.10E+02 0.00+00 1.OOE+03 0.00+00 5.00E-03 0.00+00 Kr-88 O.OOE+00 1 0.00+00 0.000 1.30E+03 0.00+00 1.00E+03 O.OOE+00 5.00E-03 0.00+00 Kr-89 O.OOE+00 1 O.OOE+00 0.000 1.20E+03 O.OOE+00 1.00E+03 O.OOE+00 5.00E-03 O.OOE+00 1-131 1.29E-01 100 1.29E+01 0.001 2.20E+02 2.15E-01 1.00E+03 2.15E+02 5.00E-03 1.07E+00 Xe-131m 9.75E+01 1 9.75E+01 0.007 4.90E+00 3.61 E-02 1.00+03 3.61 E+01 5.00E-03 1.81 E-01 1-132 1.09E-01 100 1.09E+01 0.001 1.402+03 1.152+00 1.00E+03 1.15E+03 5.00E-03 5.77E+00 1-133 1.36E-02 100 1.36E+00 0.000 3.50E+02 3.60E-02 1.00E+03 3.60E+01 5.002-03 1.80E-01 Xe-133 1.26E+04 1 1.26E+04 0.952 2.00E+01 1.90E+01 1.OOE+03 1.90E+04 5.00E-03 9.52E+01 Xe-133m 2.38E+02 1 2.38E+02 0.018 1.702+01 3.06E-01 1.002+03 3.06E+02 5.002-03 1.532+00 1-134 O.OOE+00 100 O.OOE+00 0.000 1.60E+03 0.002+00 1.00E+03 O.OOE+00 5.002-03 O.OOE+00 1-135 9.71 E-06 100 9.71 E-04 0.000 9.50E+02 6.972-05 1.00E+03 6.97E-02 5.00E-03 3.49E-04 Xe-135 2.31 E+01 1 2.31 E+01 0.002 1.40E+02 2.44E-01 1.002+03 2.44E+02 5.00E-03 1.222+00 Xe-135m 7.79E-02 1 7.79E-02 0.000 2.50E+02 1.472-03 1.002+03 1.47E+00 5.002-03 7.36E-03 Xe-138 O.OOE+00 1 O.OOE+00 0.000 7.10E+02 O.OOE+00 1.002+03 O.OOE+00 5.002-03 0.00+00 MTALS 1.32E+04 1.000 2.11E+04 1.05E+02

• lhe source term In cac zz-341, rev1 isa post filtersource term based on a 99%lodine removal efficiency. Snce the EALdose rate Isforthe atmosphere within containment (upstream of the filter), the removed portionsof the lodineshad to be refactored back Into the equation.

" Assumes1mr/hr=1mR'hr Page 1 of 4 ATTACHMENT 3

( C EIP-ZZ-00101 (

Rev. 031 Fuel Bldz ARM Dose Rate for Abnormal Radiation Events FHA-FB.

Iodine EPA-400 EDE Dose Rate Source Term ilter Corrected PERCENT Table 5-3 Weighted Unit Weighted Hi-Hi equivalent to from calc Correction for OFMOTAL Dose Converson Dose Conversion correction Dose Conversion alarm setpoint Hi-Hi alarm on ZZ-341 rev1 Factor* pre-filtration in R3 FACTOR FACTOR factor FACTOR on GT-RE-27/28 GT-FE-27/28 I19OPE (Ci) (unitless) (Ci) Dec. equiv (rem-cm3/uCi-Hr) (rem-cm3/uCi-Hr) (mr/rem) (mr-cm3/uCi-Hr) (uCVcc) (mFRhr)

Kr-83m O.OOE+00 1 O.OOE+00 0.000 O.OOE+00 0.002+00 1.00E+03 O.OOE+00 1.46E-03 O.OOE+00 Kr-85 5.89E+02 1 5.89E+02 0.019 1.30E+00 2.41 E-02 1.002+03 2.41 E+01 1.46E-03 3.53E-02 Kr-85m O.OOE+00 1 O.OOE+00 0.000 9.302+01 0.00+00 1.00E+03 O.OOE+00 1.46E-03 O.OOE+00 Kr-87 0.00+00 1 O.OOE+00 0.000 5.1 OE+02 0.00+00 1.002+03 O.OOE+00 1.46E-03 0.00+00 Kr-88 O.OOE+00 1 0.00+00 0.000 1.30E+03 O.OOE+00 1.OOE+03 O.OOE+00 1.462-03 O.OOE+00 Kr-89 0.OOE+00 1 O.OOE+00 0.000 1.20E+03 0.002+00 1.00E+03 O.OOE+00 1.462-03 0.002+00 1-131 3.33E-01 100 3.332E+01 0.001 2.20E+02 2.31 E-01 1.00E+03 2.31 E+02 1.462-03 3.372-01 Xe-131m 2.34E+02 1 2.34E+02 0.007 4.90E+00 3.622-02 1.OOE+03 3.62E+01 1.46E-03 5.28E-02 1t132 2.82E-01 100 2.82E+01 0.001 1.40E+03 1.24E+00 1.OOE+03 1.24E+03 1.462-03 1.82E+O00 1-133 3.52E-02 100 3.52E+00 0.000 3.50E+02 3.88E-02 1.00E+03 3.88E+01 1.46E-03 5.672-02 Xe-133 3.02E+04 1 3.02E+04 0.952 2.00E+01 1.90E+01 1.00E+03 1.90E+04 1.46E-03 2.78E+01 Xe-133m 5.70E+02 1 5.70E+02 0.018 1.70E+01 3.062-01 1.00+03 3.06E+02 1.46E-03 4.46E-01 1-134 O.OOE+00 100 0.00+00 0.000 1.60E+03 O.OOE+00 1.00E+03 O.OOE+00 1.46E-03 O.OOE+00 1-135 2.51 E-05 100 2.51 E-03 0.000 9.50E+02 7.52E-05 1.00+03 7.52E-02 1.46E-03 1.101-04 Xe-135 5.55E+01 1 5.55E+01 0.002 1.40E+02 2.45E-01 1.00E+03 2.45E+02 1.46E-03 3.58E-01 Xe-135m 1.872-01 1 1.87E-01 0.000 2.50E+02 1.47E-03 1.00E+03 1.47E+00 1.46E-03 2.15E-03 Xe-138 O.OOE+00 1 O.OOE+00 0.000 7.1 OE+02 O.OOE+00 1.00E+03 O.OOE+OO 1.46E-03 0.00+00 lOTALS 3.17E+04 1.000 2.12E+04 3.092+01

'The source term in calc zz-341, revi isa pos filter source term based on a 99%lodlne removal efficlency. Snce the EALdose rate Isforthe atmos'phere within the fuel building (upstream of the filter), the removed portlonsof the lodineshad to be refactored back into the equation.

'*Assunmes1mR=1mr Page 2 of 4 ATTACHMENT 3

( C EIP-ZZ-00101

(

Rev. 031 Containment ARM Dose Rate for RCS Barrier EAL RCSSource Source Term Total activity Concentration EPA-400 EDE Term Normal Unit ANS18.1, 1984 RCS Dispersed Containment of activity Table 5-3 concentration Conversion corrected Volume within the Volume dispersed into Dose Conversion ANS1 8.1, 1984 Factor for units PCS Containment FACTOR Dose Rate ISOTOPE (uCVgm) (gm/cc)* (uCVcc) (cc) (uCi) (cc) (uCVcc) (rem-cm3/uCl-Hr) (RFhr)**

Kr-85 4.30E-01 6.92E-01 2.98E-01 3.46E+08 1.03E+08 7.08E+10 1.45E-03 1.30E+00 1.89E-03 Kr-85m 1.60E-01 6.92E-01 1.11 E-01 3.46E+08 3.83E+07 7.08E+10 5.41 E-04 9.30E+01 5.03E-02 Kr-87 1.50E-01 6.92E-01 1.04E-01 3.46E+08 3.59E+07 7.08E+10 5.07E-04 5.1 0E+02 2.59E-01 Kr-88 2.80E-01 6.92E-01 1.94E-01 3.46E+08 6.70E+07 7.08E+10 9.47E-04 1.30E+03 1.23E+0o 1-131 4.50E-02 6.92E-01 3.11 E-02 3.46E+08 1.08E+07 7.08E+10 1.52E-04 2.20E+02 3.35E-02 Xe-131m 7.30E-01 6.92E-01 *5.05E-01 3.46E+08 1.75E+08 7.08E+10 2.47E-03 4.90E+00 1.21 E-02 1-132 2.1 OE-01 6.92E-01 1.45E-01 3.46E+08 5.03E+07 7.08E+10 7.1 OE-04 1.40E+03 9.94E-01 1-133 1.40E-01 6.92E-01 9.69E-02 3.46E+08 3.35E+07 7.08E+10 4.73E-04 3.50E+02 1.66E-01 Xe-133 2.60E+00 6.92E-01 1.80E+00 3.46E+08 6.23E+08 7.08E+10 8.79E-03 2.00E+01 1.76E-01 Xe-133m 7.00E-02 6.92E-01 4.84E-02 3.46E+08 1.68E+07 7.08E+10 2.37E-04 1.70E+01 4.02E-03 1-134 3.40E-01 6.92E-01 2.35E-01 3.46E+08 8.14E1+07 7.08E+10 1.15E-03 1.60E+03 1.84E+0O 1-135 2.60E-01 6.92E-01 1.80E-01 3.46E+08 6.23E+07 7.08E+10 8.79E-04 9.50E+02 8.35E-01 Xe-135 8.50E-01 6.92E-01 5.88E-01 3.46E+08 2.04E+08 7.08E+10 2.87E-03 1.40E+02 4.02E-01 Xe-135m 1.30E-01 6.92E-01 9.OOE-02 3.46E+08 3.11 E+07 7.08E1+10 4.40E-04 2.50E+02 1.1OE-01 Xe-137 3.40E-02 6.92E-01 2.35E-02 3.46E+08 8.14E+06 7.08E+10 1.15E-04 1.1OE+02 1.26E-02 Xe-138 1.20E-01 6.92E-01 8.30E-02 3.46E+08 2.87E+07 7.08E+10 4.06E-04 7.1OE+02 2.885E-01 6.42Ei-00

• ANS18.1 unitsare in uCVgm. Assuming an average temperature of 600 degreesFand 2250 psi, luCVgm= 0.692 uCVcc.

Keenan & Keys Seam Tables'1970

• • Assumes 1 R= 1 Rem.

Page 3 of 4 P oATITACHMENT 3

C C EIP-ZZ-00101 Rev. 031 Containment ARM Dose Rate for Fuel Clad Barrier EAL Source Term Source Term Massof Total activity Concentration EPA-400 EDE 1%failed fuel DE-131 Converted equivalent RCS Dispersed Containment of activity Table 5-3 from FSAR Factor to DE-131 to 300 uCVgm FSARtable within the Volume dispersed into Dose Converson Table 11.1-5 TD-14844 lodInesonly DE1131* 11.1A-1 RCS Containment FAC1OR Dose Rate ISIOPE (uCVgm) (unitless) (uClgm) (uCVgm) (gim) (uCI) (cc) (uCVcc) (rem-cm3/uCi-Hr) (F/hr)*

Kr-83m 1.82E-01 0 0.00+00 1.67E+01 2.402E+08 4.OOE+09 7.082E+10 5.65E-02 O.OOE+00 O.OOE+00 Kr-85 6.702-02 0 O.OOE+00 6.14E5+00 2.40E+08 1.472E+09 7.0824+10 2.08E-02 1.302+00 2.70E-02 Kr-85m 9.00E-01 0 O.OOE+00 8.24E+01 2.40E+08 1.9824+10 7.08E+10 2.79E-01 9.30E+01 2.60E+01 Kr-87 5.27E-01 0 O.OOE+00 4.83E+01 2.40E+08 1.16E+10 7.08E+10 1.64E-01 5.10E+02 8.35E+01 Kr-88 1.69E+00 0 0.00+00 1.55E+02 2.40E+08 3.72E+10 7.08E+10 5.25E-01 1.30E+03 6.82E+02 Kr-89 4.53E-02 0 0.00+00 4.15E+00 2.40E+08 9.96E+08 7.08E+10 1.41 E-02 1.20E+03 1.69E+01 1-131 2.25E+00 1.000 2.25E+00 2.06E+02 2.40E+08 4.95E+10 7.08E+10 6.99E-01 2.20E+02 1.54E+02 Xe-131m 1.592-01 0 O.OOE+00 1.46E+01 2.40E+08 3.502+09 7.08E+10 4.94E-02 4.90E+00 2.42E-01 1-132 8.33E-01 0.036 3.00E-02 7.63E+01 2.40E+08 1.83E+10 7.08E+10 2.59E-01 1.40E+03 3.62E+02 1-133 3.17E+00 0.270 8.56E-01 2.90E+02 2.402+08 6.97E+10 7.08E+10 9.84E-01 3.50E+02 3.44E+02 Xe-133 4.33E+01 0 0.00+00 3.97E+03 2.40E+08 9.52E+11 7.082+10 1.34E+01 2.00E+01 2.69E+02 Xe-133m 8.67E-01 0 0.00+00 7.94E+01 2.402+08 1.912E+10 7.08E+10 2.69E-01 1.70E+01 4.58E+00 1-134 3.92E-01 0.017 6.66E-03 3.59E+01 2.40E+08 8.622+09 7.08E+10 1.22E-01 1.60E+03 1.95E+02 1-135 1.58E+00 0.084 1.33E-01 1.45E+02 2.402+08 3.47E+10 7.08E+10 4.91 E-01 9.50E+02 4.66E+02 Xe-135 2.58E+00 0 O.OOE+00 2.36E+02 2.40E+08 5.67E+10 7.082+10 8.01 E-01 1.40E+02 1.12E+02 Xe-135m 1.182-01 0 O.OOE+00 1.08E+01 2.402+08 2.59E+09 7.08E+10 3.66E-02 2.502+02 9.16E+00 Xe-137 8.15E-02 0 0.00+00 7.47E+00 2.40E+08 1.79E+09 7.08E+10 2.53E-02 1.10+02 2.78E+00 Xe-138 3.96E-01 0 O.OOE+00 3.63E+01 2.40E+08 8.71 2+09 7.08E+10 1.23E-01 7.10E+02 8.732+01 Total DE-131 3.28E+00 2.81 +03

• Multiply the Scurce term In column 2 by 300/3.28 total for 1-131 DE.

• • Assumes1 R= 1 Rem.

Page 4 of 4 P ATIACHMENT 3

T EIP-ZZ-00102 Revision 031 October 15, 2003 CALLAWAY PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURE EIP-ZZ-00102 EMERGENCY IMPLEMENTING ACTIONS RESPONSIBLE DEPARTMENT EMERGENCY PREPAREDNESS PROCEDURE OWNER WV. R. Bevard WRITTEN BY W. R. Bevard PREPARED BY S. J. Crawford APPROVED BY NOV 0 2003 DATE ISSUED I\- ACCOUNTABIJLE This procedure contains the following:

Pages 1 through 6 Attachments 1 through 5 Tables through Figures through Appendices through Checkoff Lists through This procedure has checkoff list(s) maintained in the mainframe computer.

Conversion of commitments to TRS reference/hidden text completed by Revision Number:

Non-T/S Commitments 019 14

t EIP-ZZ-00102 Rev. 031 TABLE OF CONTENTS Section Page Number 1 PURPOSE AND SCOPE 1 2 DEFINITIONS 1 3 RESPONSIBILITIES 1 4 PROCEDURE 2 5 REFERENCES 6 5.10 KOA-ZZ-1212A, Rapid Plume Assessment Tech 6 6 RECORDS 6 Attachment 1 - Emergency Announcement 1 Page Attachment 2- Operations Personnel Emergency Actions 1 Page Attachment 3- Set-Up and Operation of the Model 177 Ratemeter 1 Page Attachment 4- Off Site Notification Form I Page Attachment 5- Procedure Flow Chart 2 Pages ji EIP-ZZ-001 02 Rev. 031 EMERGENCY IMPLEMENTING ACTIONS 1 PURPOSE AND SCOPE 1.1 This procedure provides guidance to the Emergency Coordinator for implementing emergency actions when an emergency has been classified or reclassified per EIP-ZZ-00101, Classification of Emergencies. (COMN 3312) 2 DEFINITIONS 2.1 RELEASE ABOVE NORMAL OPERATING LIMITS - A discharge of radioactive effluent that results in a reading of 0.1 mrem/hr or greater at the Exclusion Area Boundary (EAB).

3 RESPONSIBILITIES 3.1 EMERGENCY COORDINATOR 3.1.1 Responsible for implementing this procedure and directing emergency response as follows: (COMN 42570)

NOTE: The responsibilities that the Emergency Coordinator may delegate are indicated with an asterisk (*).

3.1.1.1 Classifying and declaring emergencies.

3.1.1.2 Authorizing personnel exposure in excess of 10CFR20 limits.

3.1.1.3 Assumes decision-making responsibilities for implementing strategies identified in the Severe Accident Management Guidelines.

3.1.1.4 *Directing operations of emergency response organizations.

3.1.1.5 *Requesting the formation of emergency teams.

3.1.1.6 *Initiating the implementation of on-site protective actions.

3.1.1.7 *Ensuring that on-site and off-site emergency response organizations are kept up to date on emergency conditions.

EIP-ZZ-00102 Rev. 031 3.1.1.8 *Ensuring that site-wide announcements are made on the plant Public Address (PA) system.

3.2 SHIFT SUPERVISOR 3.2.1 Until relieved, the Shift Supervisor acts as the Emergency Coordinator. (COMN 3314) 4 PROCEDURE NOTE: Monitor Emergency Action Levels (EALs) throughout this procedure.

NOTE: The flowchart Attachment 5 may be use to assist in the performance of this procedure.

4.1 Notify Facility Personnel:

4.1.1 Announce the Emergency Classification and the time of declaration.

4.1.2 Announce the Cause.

4.2 Manually Initiate ERFIS from Main Control Board and Do Not "Reset" until instructed by Tech Assessment Staff.

4.3 Notify On-Site Personnel:

CA UTION: If CODE RED or CODE BLACK is in progress, on-site emergency announcements should be held to a minimum and prohibit movement of personnel until CODE condition is secured.

4.3.1 Prepare Attachment 1. If an Alert or higher is being declared, the Emergency Response Organization SHALL be activated. (COMN 42535) (COMN 3391)

NOTE: The Emergency Response Organization may be activated prior to an ALERT as necessary to provide additional support.

4.3.2 Sound the Plant Emergency Alarm from the Control Room.

4.3.3 Perform Attachment 1, making the emergency announcement applicable to the Emergency Classification. Include if there is a localized emergency (e.g., fire, flood), announcing the type and location, and instruct personnel to stand clear of the affected area.

EIP-ZZ-00102 Rev. 031 NOTE: Emergency Callout System activation does not need to be done if activated already at a lower classification level.

4.4 At an ALERT or higher classification call out the emergency organization by I having the SAS operator activate the Emergency Callout System per KOA-ZZ-00200 for rapid responders using MESSAGE #1. i II NOTE: The Shift Supervisor has a Satellite Cellular Phone to be used as a last resort backup to the telephone and radio systems. If installed systems and backups fail the Satellite Cellular Phone may be used for offsite communications.

4.5 Notify Off-Site Agencies:

4.5.1 Shift Supervisor complete or direct completion of the SENTRY screen or complete Attachment 4 and give it to the Communicator.

NOTE: If the condition or cause of the classification has already been corrected the form should be completed as prescribed for the emergency. A statement should then made in the Notes section, lower right hand side, "The condition that caused the (emergency classification) has been corrected and Event closeout has been declared. Also ensure NRC operations is notified within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. CARS 199700852 NOTE: After the initial reporting, if the NRC Operations Center is activated, the NRC will request additional information. The personnel communicating with NRC should be knowledgeable with the facility's operation and with the event to provide and update information about the evolving incident. The level of communication will depend on the development and the significance of the event.

EIP-ZZ-00102 Rev. 031 CA UTION: As a minimum, the immediate protective action recommendation for a GENERAL EMERGENCY, is evacuation within a 2 mile radius and 5 miles downwind of the plant in affected sectors.

(COMN 3954) 4.5.2 Incorporate protective action recommendations in accordance with EIP-ZZ-00212, Protective Action Recommendations.

4.5.3 Implement EIP-ZZ-00201, Notifications. Initial notifications to State and Local Authorities SHALL be initiated within 15 minutes after declaration of an emergency. (COMN 3946)

NOTE: Notifications should be initiated within 15 minutes if conditions change and approximately every 30 minutes if conditions are stable. When at an Unusual Event and conditions are stable the notification frequency may be extended with the concurrence of SEMA and the EPZ Counties.

4.6 Ensure Attachment 2, Operations Personnel Emergency Actions, is taken to the Field Office for use by the Field Supervisor or first available individual. Extra Operations personnel report to the Field Office at the first Emergency Announcement.

4.7 Notify the Emergency Duty Officer and discuss the following: (COMN 3946) 4.7.1 Emergency Classification.

4.7.2 Plant status and actions taken.

4.7.3 Callout of response organizations.

4.7.4 Notification of off-site agencies.

4.8 Notify the Recovery Manager of an Unusual Event. (COMN 3946)

NOTE.- Notification of the Recov&ry Manager is not required at an Alert or higher as this is accomplished using EIP-ZZ-00200 and KOA-ZZ-00200.

4.9 If a Release above normal operating limits is in progress or projected ensure dose assessment and EIP-ZZ-00212 is initiated.

i i

EIP-ZZ-00102 Rev. 031 4.9.1 DISCUSS the need to dispatch the Rapid Plume Assessment Tech (RPAT) with the On Shift Dose Assessment Tech. ref (KOA-ZZ-1212A).

4.9.2 If Abnormal In-plant radiological conditions exist, set up a ratemeter at the door of the Control Room per Attachment 3.

4.10 Implement EIP-ZZ-00217, Emergency Response Data System Activation (ERDS) as soon as possible but in all cases within one-hour of an ALERT or higher classification. The Shift Supervisor may delegate this to Tech Assessment in the TSC.

4.11 Evaluate Assembly/Evacuation per EIP-ZZ-00230, Accountability.

(COMN 3983). (COMN 3986)

NOTE: Accountability SHALL occur within 30 minutes of an Assembly/Evacuation announcement. (COMN 42531) 4.12 Form and/or Dispatch Emergency Teams as necessary using EIP-ZZ-00220, Emergency Team Formation.

4.13 Contact Chemistry and initiate Post-Accident Sampling as required.

4.14 Implement the Severe Accident Management Guidelines as required.

4.14.1 The control room should implement SACRG-1, Severe Accident Control Room Guideline Initial Response.

4.14.2 The control room should implement SACRG-2, Severe Accident Control Room Guideline for Transients after the TSC is Functional.

4.15 If non-Ameren support is needed, direct the Admin Coordinator to implement the Additional Assistance section of their checklist.

4.16 Event Reclassification/Plant Recovery/Event Closeout 4.16.1 If emergency has been reclassified return to Step 3.1 and perform the applicable steps.

4.16.2 Evaluate EIP-ZZ-00260, Event Closeout/Plant Recovery, to determine if plant recovery or closeout conditions have been met.

lNOTE: The NRC should be notified of the intent to declare recovery.

4.17 Return to Step 3.11 and continue assessment if emergency has not been reclassified or event closeout/plant recovery has not been declared.

EIP-ZZ-00102 Rev. 031 5 REFERENCES 5.1 Callaway Plant Radiological Emergency Response Plan (RERP) 5.2 APA-ZZ-00743, Fire Team Organization and Duties 5.3 EIP-ZZ-00200, Augmentation of the Emergency Organization 5.4 EIP-ZZ-00201, Notifications 5.5 EIP-ZZ-00211, Field Monitoring 5.6 EIP-ZZ-00212, Protective Action Recommendations 5.7 EIP-ZZ-00217, Emergency Response Data System Activation 5.8 EIP-ZZ-00230, Accountability 5.9 EIP-ZZ-00260, Event Closeout/Plant Recovery 5.10 KOA-ZZ-1212A, Rapid Plume Assessment Tech 5.11 KOA-ZZ-00200, Activation of the Callaway Plant Emergency Callout System

.5.12 NRC Correspondence 11/27/2000, Recording Emergency Notification System Telephone Conversations 6 RECORDS 6.1 All facility logs, SENTRY or MAGNEM screen prints, office memos, notes, etc.,

should be attached to the Coordinator checklist and turned in to the Admin Coordinator and/or Emergency Preparedness (EP)

NOTE: Recordings of Emergency Notification System (ENS) and Health Physics Network (HPN) lines are available from the NRC recording system following the termination of an emergency event.

6.2 QA Records 6.2.1 Attachment 1, Emergency Announcement (File K171.0010)

EIP-ZZ-00102 Rev. 031 Emergency Announcement NOTE: If CODE RED or CODE BLACK is in progress, on-site emergency announcements should be held to a minimum and prohibit movement of personnel until CODE condition is secured.

SOUND THE PLANT EMERGENCY ALARM ATTENTION ALL PERSONNEL! ATTENTION ALL PERSONNEL!

UNUSUAL EVENT A(N) ALERT HAS BEEN DECLARED AT__ i i

SITE EMERGENCY (time)

GENERAL EMERGENCY THE CAUSE OF THE EMERGENCY IS Emergency Organization Activation o Unusual Event ALL MEMBERS OF THE ON-SHIFT EMERGENCY ORGANIZATION REPORT TO YOUR STATIONS.

O Alert or Higher ALL MEMBERS OF THE EMERGENCY RESPONSE ORGANIZATION REPORT TO YOUR STATIONS.

Actions For Non-Essential Personnel o Unusual Event ALL NON-ESSENTIAL PERSONNEL CONTINUE WITH YOUR NORMAL DUTIES UNLESS FURTHER INSTRUCTIONS ARE GIVEN.

O Alert ALL NON-ESSENTIAL PERSONNEL CONTINUE WITH YOUR NORMAL DUTIES UNLESS FURTHER INSTRUCTIONS ARE GIVEN. IF YOU ARE NOT BADGED FOR PROTECTED AREA ACCESS, YOU MUST EVACUATE THE PLANT SITE.

L Site/General 0l Normal hours ALL NON-ESSENTIAL PERSONNEL REPORT TO YOUR PRE-DESIGNATED ASSEMBLY AREAS IN THE CMB (Consider weather and AND TRAINING CENTER. TAKE ALL PERSONAL radiological conditions BELONGINGS SUCH AS COATS, CAR KEYS AND PRIOR to making PURSES. FOLLOW THE INSTRUCTIONS OF YOUR announcement.) SUPERVISOR AND SECURITY OFFICERS.

ACCOUNTABILITY WILL BE PERFORMED.

0 Off-normal ALL NON-ESSENTIAL PERSONNEL PROCEED TO THE hours TSC AND AWAIT FURTHER INSTRUCTIONS.

ACCOUNTABILITY WILL BE PERFORMED.

Special instructions, (i.e. special routes during releases. seek cover during storms)

EC/RM APPROVAL Page I of I ATTACHMENT I

EIP-ZZ-00102 Rev. 031 OPERATIONS PERSONNEL EMERGENCY ACTIONS NOTE: Pre-designated Personnel inside the Protected Area report to the Control Room/Field Office upon a Reactor Trip or at the first Emergency Announcement. All are Essential Personnel unless specifically released by the Shift Supervisor. Once released they do not report to the Field Office if accountability is declared, they respond as all other Non-Essential Personnel.

THE FIELD SUPERVISOR. OR DESIGNEE. PERFORMS THE FOLLOWING:

1.1 Prepare a list of personnel reporting to the Field Office along with their badge numbers.

(Note: A Security officer is generally assigned to pick up a copy of the list for accountability). Include on-watch Equipment Operators, (EO's). Have all personnel card into the Field Office Conference Room card reader (The card reader is used for accountability only).

1.1.1 The Polisher and Primary EO's should report to the Control Room to provide assistance.

They should return to the Field Office when relieved by I&C Technicians.

1.1.2 The formation and dispatch of Emergency Teams should use EIP-ZZ-00220 as a guide.

1.1.3 Rad Chem Technician(s) report to the Control Room/Field Office to assist in personnel monitoring, team briefing and rapid dose assessment. Emergency Team Briefing Form in EIP-ZZ-00220 may be used as a guide.

NOTE: When personnel leave the Field Office on assignment they should sign out, card out and be tracked to maintain accountability.

1.2 Designate the Fire Brigade members using personnel not on watch if available. Refer to APA-ZZ-00743, Fire Team Organization and Duties.

1.3 All Field Office personnel should go to HP Access, obtain an Electronic Dosimeter (ED) and sign in on RWP 911. If released as Non-Essential Personnel, individuals should sign off of RWP 911 and return their ED prior to leaving the site. This is to ensure all personnel dispatched from the Control Room or Field Office have their dose tracked.

CAU77ON: Remain aware of plant radiological conditions and do not dispatch operators into areas where conditions may be changing without Health Physics support and briefings.

1.4 If radiological conditions are a potential hazard, set up a ratemeter at the door and allow entrance only through that door. Refer to Attachment 3.

1.5 If the Field Office is required to be evacuated, all personnel then report to the Control Room or TSC as needed.

1.6 Assign Operators to the TSC for emergency team support as required and available.

Page I of I ATTACHMENT 2

EIP-ZZ-00102 Rev. 031 11I11 _1141911W

1. Remove Model 177 ratemeter, frisker probe, detector cable, power cord, and check source from the E-Kit cabinet located behind the control boards. There are two instruments, one for the door to the field office, one for the door to the Control Room.

2. Connect detector and power cords, if not already connected, to the Model 177 ratemeter and verify the following switch settings:

Front Panel: EJ On/Off switch in "ON" position.

E] Volume adjusted to hear audible counts.

L] Response switch in "slow" position.

Rear Panel: L Subtract switch in "Off' position (if meter has Subtract Switch.)

3. Prior to the first use of the day, perform response check as follows:

LI Ensure instrument has a current calibration sticker.

El Set the range switch to the appropriate position and place the detector on the check source bracket.

E] Verify the response is within the acceptable range as specified on the response value determination form/sticker for that check source.

[I Check the instrument alarm by adjusting the ALARM SET switch so that it is slightly less than the count rate of the source.

LI Remove the source from the detector.

LI Depress the RESET button. The alarm condition should clear.

L] If the pre-operational checks are satisfactory, complete the attached pre-operational check sticker. (If either the alarm or the response check failed, notify the Health Physics Coordinator and obtain an operational ratemeter.)

LI Return the check source to the E-Kit cabinet.

4. Set up one ratemeter at the door to the Field Office and one rate meter at the door to the Control Room for use. For each:

LI Connect detector and power cords, if not already connected, to the Model 177 ratemeter and verify the following switch settings:

Front Panel: LI On/Off switch in "ON" position.

LI Volume adjusted to hear audible counts.

[1Response switch in "slow" position.

• I Range switch to the value necessary to maintain "on scale" display. Normally, this should be the "XI" scale.

Rear Panel: LI Alarm set at "5".

C] Subtract switch in "Off" position if meter has Subtract Switch.

LI Ensure the probe sets "face up" when not being used. (This allows the next user to frisk prior to handling the detector, and allows the detector to monitor area and airborne radiation levels.)

5. If the ratemeter background reading exceeds the "Xl" scale (500 CPM) during use, notify the Health Physics Coordinator.

Page I of I ATTACHMENT 3

C -.1.

OFF SITE NO( ZATION FORM (FAX Copy to TSC-68604 & EOF-64900)

EIP-ZZ-001O02(

Rev. 031 A

GENERAL INFORMATION: PROTECTIVE ACTIONS:

1)DRILL MESSAGE: I (Yes/No) 19) PROTECTIVE ACTIONS RECOMMENDED: E (Yes/No)

2) EMERGENCY CLASSIFICATION: l ;7: 20) PROTECTIVE ACTION BASIS:: F -

3) DATE/TIME DECLARED: /I I TYPE LOCATION SECTORS

21) 22) 23)

4) EMERGENCY ACTION LEVEL: I  : iv7,XI I . . LL.:r.I 24) 25) 26)

27) 28) 29)

30) Additional Protective Actions:

6) REACTOR STATUS: I ~-n'1 I RELEASE STATUS:

8) RELEASE INFORMATION:

I I

9).

10) RELEASE START TIME: PROJECTED DOSES:

11) RELEASE DURATION: 1 ~~~~~~Hrs. 31) PROJECTED DOSE BASIS:  ! v-Distance TEDE (Rem) Thyroid (Rem)

12) WIND DIRECTION: From to 13) [= Deg 14) SECTORS: l EAB 32) 36)

15) WIND SPEED: 2 miles 33) 37)

PLUME ARRIVAL TIME: 5 miles 34) 38)

16) 2 Miles 17) 5 Miles 10 miles 35) 39)

18) 10 Miles i

I ADDITIONAL NOTES:

40)

EC/RM APPROVAL:_ COMMUNICATOR.

Distribution:Recovery Manager Page 1 of 1 ATTACHMENT 4 Communicator CA-#023 1 State ofMissouri File #KI 71.0010

I EIP-ZZ-00102 Rev. 031 START NOTIFY FACILITY PERSONNEL ANNOUNCE THE EMERGENCY CLASSIFICATION, THE DECLARATION TIME, and THE CAUSE.

MANUALLY INITIATE ERFISl NOTIFY ON-SITE PERSONNEL COMPLETE ATTACHMENT I SOUND THE EMERGENCY ALARM ICONTACTl EDO ConsIder havingHAE S SAS ACTIVATE CALLOUT ACTIVATE CALLOUT per KOA-ZZ-00200 per KOA-ZZ-00200 Message #2 or #1O if lMessage #1 for extra help If not already activated for_______

ext.

_ _ _help at a lower classification EIP-ZZ-0021 2 PROTECTIVE ACTION RECOMMENDATION EVACUATION 2 MILES AROUND 5 MILES DOWN WIND MINIMUM GE{NERAL Yes MERGENC

'I No0 EIP-ZZ-00212 EVALUATE PLANT CONDITIONS TO DETERMINE IF ADDITIONAL NOTIFY OFF-SITE AGENCIES PAR REQUIRED Complete SENTRY or Complete Attachment 4, Give to Communicators to Implement EIP-ZZ-00201 NOTE: The Shift Supervisor has a Satellite Cellular Phone to be used as a last resort No ALERT or er backup to the telephone and radio systems. If installed systems and backups fail the Yes Satellite Cellular Phone may ASSIGN ATTACHMENT 2 be used for offsite rO THE FIELD SUPERVISOR OR OTHER AVAILABLE communications.

PERSONNEL REPORTING TO THE FIELD OFFICE NOTIFY EDO The EDO should call In when paged

--- T WITHIN 1 HOUR INITIATE ERDS PER EIP.ZZ-00217 MAY BE DELEGATED TO TECH ASSESSMENT

( PAGE 2 ) Page1 of2 A1TACH MENT 5~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Pagel of2 ATTACHMENT 5

EIP-ZZ-00102 Rev. 031 DOSE ASSESSMENT I:

NON Yes AMEREN- UE SUPPORT NEEDED Page 2 of 2 ATTACHMENT 5

EIP-ZZ-00200 Revision 01 1 October 15, 2003 CALLAWAY PLANT EMERGENCY PLAN IMPLEMENTING PROCEDURE EIP-ZZ-00200 AUGMENTATION OF THE EMERGENCY ORGANIZATION RESPONSIBLE DEPARTMENT Emertencv Preparedness PROCEDURE OWNER S. J. Crawford WRITTEN BY D. E. Trokev PREPARED BY S. J. Crawford APPROVED BY 'A /9 6" NOV032003 DATE ISSUED 1 -5(3 ACCoUNTABLE This procedure contains the following:

Pages 1 through 4 Attachments 1 through 4 Tables through Figures through Appendices through Checkoff Lists through This procedure has 0 checkoff list(s) maintained in the mainframe computer.

Conversion of commitments to TRS reference/hidden text completed by Revision Number:

Non-T/S Commitments 007 l

EIP-ZZ-00200 Rev. 011 TABLE OF CONTENTS Section Page Number 1 PURPOSE AND SCOPE 1 iI 2 DEFINITIONS I 3 RESPONSIBILITIES 2 4 INITIATING CONDITIONS 2 5 PROCEDURE 2 5.1 CALLAWAY PLANT EMERGENCY PAGING SYSTEM ACTIVATION .2 5.2 EMERGENCY RESPONSE FACILITIES (ERFS) 3 5.3 FAILURE OF THE PAGING SYSTEM 4 6 REFERENCES 4 7 RECORDS 4 Attachment I Pager Response - Rapid Responder Emergency Response 1 Page Organization Pager Response - TSC Emergency Response Organization 1 Page Pager Response - EOF/JPIC Emergency Response Organization 1 Page Manual Callout List 2 Pages EIP-ZZ-00200 EIP-ZZ-00200 Rev. 011 AUGMENTATION OF THE EMERGENCY ORGANIZATION 1 PURPOSEAND SCOPE 1.1 PURPOSE This procedure provides guidance for the augmentation of the Callaway Plant Emergency Response Organization (ERO).

1.2 SCOPE 1.2.1 This procedure outlines the proper use of the Callaway Plant's Emergency Paging System.

2 DEFINITIONS 2.1 Callaway Plant Emergency Callout System - An alpha/numeric paging system and Community Alert Network (CAN), used to notify the Emergency Response Organization of needed response.

2.2 Emergency Response Facility (ERF) - A collective name for specifically designated locations which are equipped to facilitate the control and coordination of emergency activities and assessment.

2.3 Emergency Response Personnel - AmerenUE and/or contract personnel trained to fill emergency response positions within the Emergency Response Organization.

l 2.4 System Activation - Initiating the Emergency Callout System for an event, such as an Emergency, Drill, or Test.

2.4.1 Emergency Message - An actual event, thus giving the message to the responders that an emergency has been declared, this is not a drill, and response to their Emergency Response Facility is necessary.

2.4.2 Drill Message - A planned mock event, thus giving the message to the responders that this is a drill, but response to their Emergency Response Facility is still necessary.

EIP-ZZ-00200 Rev. 011 2.4.3 Test Message - A planned event, where the message to the responders is that a test is being conducted, only a test, and response to their Emergency Response Facility is not required.

3 RESPONSIBILITIES 3.1 The Shift Supervisor (SS)/Emergency Coordinator (EC) is responsible for providing the Secondary Alarm Station (SAS)

Operator with proper information to initiate the Callaway Plant Paging System.

3.2 The SAS Operator is responsible for activating the Callaway Plant Emergency Callout System as per KOA-ZZ-00200, Activation of the Callaway Plant Emergency Callout System.

4 INITIATING CONDITIONS 4.1 Implement this procedure upon any of the following conditions:

• Declaration of an Alert.

• Declaration of a Site Emergency.

• Declaration of a General Emergency.

• At the discretion of the Shift Supervisor/Emergency Coordinator.

5 PROCEDURE l 5.1 CALLAWAY PLANT EMERGENCY CALLOUT SYSTEM ACTIVATION 5.1.1 The SS/EC notifies the Secondary Alarm Station (SAS) Operator to activate the Callaway Plant Emergency Callout System using KOA-ZZ-00200, Activation of the Callaway Plant Emergency l . Callout System.

EIP-ZZ-00200 Rev. 011 5.1.2 The SAS Operator records responses to the augmentation for Rapid Responders on Attachment 1 by retrieving Audix messages per KOA-ZZ-00200.

5.1.3 The SAS operator should initiate a third page if an incomplete response is attained from Responders on Attachment I within the first 15 minutes prior to delivery of Attachment 1 to the SS/EC.

5.1.4 The SAS Operator forwards Attachment 1 to the SS/EC when complete or in approximately fifteen (15) minutes.

5.1.5 If positions on Attachment 1 remain unfilled the SS/EC should initiate a manual callout per section 5.3.

5.1.6 When Attachment 1 is complete, FAX it to the TSC (68604) and EOF (64900).

5.2 EMERGENCY RESPONSE FACILITIES (ERFS) 5.2.1 Each Emergency Response Facility is responsible for their respective mailbox. The activity of verifying ERO Staffing for each facility should be assigned to the Logistics Support Group in the EOF, or the Admin Coordinator in the TSC.

5.2.2 To access the Audix mailbox, dial 64777 and enter the proper extension listed below, followed by the (#) key. Press the (#) key again for the password.

• TSC Emergency Response Organization - 68400

• EOF/JPIC Emergency Response Organization - 68202 5.2.3 Follow the Audix directions to get messages.

5.2.4 Do NOT delete messages. Press the (#) key to skip messages without deleting. Emergency Preparedness WILL delete the messages after the event.

5.2.5 Fill out Attachment 2 for the TSC and Attachment 3 for the EOF/JPIC.

EIP-ZZ-00200 Rev. 011 5.3 FAILURE OF THE CALLOUT SYSTEM 5.3.1 If the callout system should fail or if some of the positions fail to respond, the SS/EC will identify available personnel to perform a manual callout.

5.3.2 Using the Emergency Telephone Directory, Attachment 1, and Attachment 4, locate the page that contains the list of personnel qualified for the position desired and call each until positions are filled with the appropriate number of responders.

NOTE: The Responders MUST be asked if they are fit for duty and given any additional information stipulated by the SS/EC.

6 REFERENCES 6.1 KOA-ZZ-00200, Activation of the Callaway Plant Emergency Callout System.

7 RECORDS 7.1 After the event, send Attachments 1, 2, 3, and 4 to Emergency Preparedness for proper dissemination to QA Record File K171.0010.

EJP-ZZ-00200 Rev. 011 I CALLOUT RESPONSE (Audix 64600)

RAPID RESPONDERS EMERGENCY RESPONSE ORGANIZATION DATE TIME OF DECLARATION ESTIMATED TIME OF NAME POSITION ARRIVAL EDO/EMERGENCY COORDINATOR (EDO/BC)

K) TECHNICAL ASSESSMENT COORDINATOR (TAC)

TSC COMMUNICATOR (ENS)

RECOVERY MANAGER (RM)

OFF-SITE LIAISON'COORDINATOR (OSL)

DOSE ASSESSMENT COORDINATOR (DAC)

HEALTH PHYSICS COORDINATOR (HPC)

I NOTE: For Rapid Responder positions not filled, the SS/EC should initiate a manual callout per EIP-ZZ-00200 section 5.3.

Page I of I ATTACHMENT 1

EIP-ZZ-00200 Rev. 011 I CALLOUT RESPONSE (Audix 68400)

TSC EMERGENCY RESPONSE ORGANIZATION DATE TIME OF DECLARATION ESTIMATED NUMBER TIME OF NAME POSITION REQUIRED ARRIVAL ADMINISTRATIVE COORDINATOR 1 CHEMISTRY COORDINATOR (CC) 1 CONTROL ROOM/TSC LIAISON (CT) 1 ELECTRICAL ENGINEER 1 ELECTRICIANS 2 EMERGENCY TEAM COORDINATOR - Electrical 1 EMERGENCY TEAM COORDINATOR - Mechanical 1 ENGINEERING STATUS BOARD/LOGKEEPERS 3 I&C ENGINEER 1 MECHANICAL ENGINEER 1 MECHANICS 2 OPERATIONS SUPPORT COORDINATOR (OSC) I RAD CHEM SUPPORT 14 I&C TECHNICIAN REACTOR/NUCLEAR ENGINEER I SECURITY COORDINATOR 1 STORES PERSONNEL I _

TSC LEAD ENGINEER I Page I of I ATTACHMENT 2

EIP-ZZ-00200 Rev. 011 I CALLOUT RESPONSE (Audix 68202)

EOF/JPIC EMERGENCY RESPONSE ORGANIZATION DATE TIME OF DECLARATION ESTIMATED NUMBER TINME OF NAME POSITION REQUIRED ARRIVAL COMPANY SPOKESPERSON 1 DOSE ASSESSMENT COORDINATOR (DAC) 1 .

EOF COMMUNICATOR 1 JPIC ADMINISTRATOR 1 JPIC COORDINATOR 1 JPIC EDITOR 1 WIC MEDIA HOST 1 PIC TECHNICAL REPRESENTATIVE 2 LOGISTICAL SUPPORT COORDINATOR (LSC) 1 LOGISTICAL SUPPORT STAFF 2 PLANT ASSESSMENT COORDINATOR (PAC)I PLANT ASSESSMENT STAFF 2 PROTECTIVE MEASURES COORDINATOR (PMC) 1 Page I of I ATTACHMENT 3

EIP-ZZ-00200 Rev. 011 MANUAL CALLOUT LIST POSITION Number ACCEPTING INDIVIDUAL Required (name) 1 Rad Chem Support 14 2 Electicians 2 3 Protective Measures Coordinator (PMC) 1 4 Chemistry Coordinator 1 5 Operations Support Coordinator (OSC) 6 Emerg. Team Coordinator Electrical 1 7 Emerg. Team Coordinator Mechanical I 8 Control Room (CR)/ITSC Liaison 1 i 9 TSC Lead Engineer 1 10 Dose Assessment Coordinator 1 11 EOF Communicator I Pagel of2 ATTACHMENT 4

EIP-ZZ-00200 Rev. 011 MANUAL CALLOUT LIST POSITION Number ACCEPTING INDIVIDUAL Required (name)

Mechanics R

+ 4 13 I&C Engineer 1 14 Reactor/Nuclear Engineer 15 Mechanical Engineer 16 Electrical Engineer 17 Plant Assessment Coordinator (PAC) 18 Engineering Status Board/Logkeepers 3 19 Plant Assessment Staff 1 20 Stores Personnel I 21 Security Coordinator 1 22 Administrative Coordinator I 23 Logistical Support Coordinator I 24 Logistical Support Staff 2 25 Company Spokesperson 1 26 JPIC Technical Representative 2 27 JPIC Coordinator 1 28 JPIC Administrator 1 29 JPIC Editor 1 30 JPIC Media Host 1 31 I&C Technician 1 Page 2 of 2 ATTACHMENT 4