ML093370215

R. E. Ginna Nuclear Power Plant - License Amendment Request: Proposed Changes to the Emergency Plan

ML093370215
Person / Time
Site:	Ginna
Issue date:	11/30/2009
From:	John Carlin Constellation Energy Nuclear Group
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML093370215 (100)

Text

John Carlin Site Vice President R.E. Ginna Nuclear Power Plant, LLC 1503 Lake Road Ontario, New York 14519-9364 585.771.5200

,a joint venture of 585.771.3943 Fax O Const.llation

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iohn.carlina-cenqllc.com EneiWg D

November 30, 2009 U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:

Document Control Desk

SUBJECT:

R.E. Ginna Nuclear Power Plant Docket No. 5 0-244 License Amendment Request: Proposed Changes to the Emergency Plan In accordance with the provision of 10 CFR 50.90, R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC) is submitting a license amendment request to change the R.E. Ginna Nuclear Power Plant (Ginna) Emergency Plan.

The enclosed proposed changes involve upgrading selected Ginna Emergency Action Levels (EALs) based on NEI 99-01, Revision 5, "Methodology for Development of Emergency Action Levels," using the guidance of NRC Regulatory Issue Summary 2003-18, Supplement 2, "Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels." The current EAL scheme in use at Ginna is based on NUMARC/NESP-007, "Methodology for development of Emergency Action Levels." The plan, as changed, would continue to meet the standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR 50. Pursuant to 10 CFR 50.54(q), Ginna LLC requests NRC approval of this proposed change to the Ginna Emergency Plan prior to implementation.

In accordance with 10 CFR 50.91(a)(1), Ginna LLC has performed a No Significant Hazards Consideration analysis. Ginna LLC has concluded that the changes proposed by this license amendment request present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

The enclosure to this letter provides descriptions and assessments of the proposed changes. An attachment to the enclosure provides the existing Emergency Plan pages marked up to show the proposed changes. There are no additional commitments associated with this amendment request.

Av' 4 John Carlin Site Vice President a jOint venture of-~----,

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U. S. Nuclear Regulatory Commission Washington, DC 20555 R.E. Ginna Nuclear Power Plant, LLC 1503 Lake Road Ontario, New York 14519-9364 585.771.5200 585.771.3943 Fax john.carlin@cengllc.com November 30, 2009 ATTENTION:

Document Control Desk

SUBJECT:

R.E. Ginna Nuclear Power Plant Docket No. 50-244 License Amendment Request: Proposed Changes to the Emergency Plan In accordance with the provision of 10 CFR 50.90, R.E. Ginna Nuclear Power Plant, LLC (Ginna

. LLC) is sUbmitting a license amendment request to change the R.E. Ginna Nuclear Power Plant (Ginna) Emergency Plan.

The enclosed proposed changes involve upgrading selected Ginna Emergency Action Levels (EALs) based on NEI 99-01, Revision 5, "Methodology for Development of Emergency Action Levels," using the guidance of NRC Regulatory Issue Summary 2003-18, Supplement 2, "Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels." The current EAL scheme in use at Ginna is based on NUMARCINESP-007, "Methodology for development of Emergency Action Levels." The plan, as changed, would continue to meet the standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR 50. Pursuant to 10 CFR 50.54(q), Ginna LLC requests NRC approval of this proposed change to the Ginna Emergency Plan prior to implementation.

In accordance with 10 CFR 50.91(a)(1), Ginna LLC has performed a No Significant Hazards Consideration analysis. Ginna LLC has concluded that the changes proposed by this license amendment request present no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

The enclosure to this letter provides descriptions and assessments of the proposed changes. An attachment to the enclosure provides the existing Emergency Plan pages marked up to show the proposed changes. There are no additional commitments associated with this amendment request.

tAJ P LAJiLL-/ oo~~a 9

Document Control Desk November 30,2009 Page 2 These proposed changes to the Ginna Emergency Plan and our determination of no significant hazards have been reviewed by our Plant Operations Review Committee (PORC).

In accordance with 10 CFR 50.91(b)(1), a copy of this amendment application is being provided to the designated New York State official. The changes have also been discussed with the Monroe County and Wayne County Emergency Management personnel.

Ginna LLC requests approval of these proposed changes by May 29, 2010. In addition, Ginna LLC requests an implementation period of 60 days.

Should you have questions regarding this matter, please contact Mr. Thomas Harding at (585) 771-5219.

STATE OF NEW YORK

TO WIT:

COUNTY OF WAYNE I, John Carlin, being duly sworn, state that I am Vice President, R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC), and that I am duly authorized to execute and file this request on behalf of Ginna LLC. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Ginna LLC employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.

\\0 Subscribed and sworn before me, a Notary Public in and f he State of New York and County of fa(aeoi 2)i

, this 30 day of

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j(2009.

WITNESS my Hand and Notarial Seal:

Nota-ry"t Piblic SHARON L. MILLER Notary PublicState of New York RegistrationNo.

1IMI6017755 Comm'ss n E

, MonroeCounty 2 0

Commnission Expi'res:Oecernber 21, 20/_.0 Document Control Desk November 30, 2009 Page 2 These proposed changes to the Ginna Emergency Plan and our determination of no significant hazards have been reviewed by our Plant Operations Review Committee (PORC).

In accordance with 10 CFR 50.91(b)(1), a copy of this amendment application is being provided to the designated New York State official. The changes have also been discussed with the Monroe County and Wayne County Emergency Management personnel.

Ginna LLC requests approval of these proposed changes by May 29,2010. In addition, Ginna LLC requests an implementation period of 60 days.

Should you have questions regarding this matter, please contact Mr. Thomas Harding at (585) 771-5219.

STATE OF NEW YORK TO WIT:

COUNTY OF WAYNE I; John Carlin, being duly sworn, state that I am Vice President, R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC), and that I am duly authorized to execute and file this request on behalf of Ginna LLC. To the best of my knowledge and belief, the statements contained in this document are true and correct. To the extent that these statements are not based on my personal knowledge, they are based upon information provided by other Ginna LLC employees and/or consultants. Such information has been reviewed in accordance with company practice and I believe it to be reliable.

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Subscribed and sworn before ~e, a Notary publ~n and fiJ!~eI.State of New York and County of nOon.e o~

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WITNESS my Hand and Notarial Seal:

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. SHARON L MILLER Notary PUblidtaie of New York RegistralionNo.01MI6017755

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Document Control Desk November 30,2009 Page 3

Enclosure:

Evaluation of Proposed Changes cc:

D.V. Pickett, NRC S.J. Collins, NRC Resident Inspector, NRC P.D. Eddy, NYSDPS A.L. Peterson, NYSERDA G. Bastido, Wayne County Emergency Management M. Meisenzahl, Monroe County Office of Emergency Management Document Control Desk November 30,2009 Page 3

Enclosure:

Evaluation of Proposed Changes cc:

D.V. Pickett, NRC S.l Collins, NRC Resident Inspector, NRC P.D. Eddy, NYSDPS A.L. Peterson, NYSERDA G. Bastido, Wayne County Emergency Management M. Meisenzahl, Monroe County Office of Emergency Management

ENCLOSURE EVALUATION OF PROPOSED CHANGES R.E. Ginna Nuclear Power Plant, LLC November 30, 2009 ENCLOSURE EVALUATION OF PROPOSED CHANGES R.E. Ginna Nuclear Power Plant, LLC November 30,2009

ENCLOSURE EVALUATION OF PROPOSED CHANGES TABLE OF CONTENTS 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Significant Hazards Consideration 4.3 Conclusions

6.0 REFERENCES

ATTACHMENTS

1.

Red-line of the Current Ginna EAL Technical Basis Document

2.

Clean Copy of the Proposed Ginna EAL Technical Basis Document

3.

Red-line of NEI 99-01 Revision 5

4.

Clean Copy of Proposed Ginna EALs

5.

Plant-Specific EAL Guideline Cross Reference

6.

EAL Differences and Deviations I

ENCLOSURE EVALUATION OF PROPOSED CHANGES TABLE OF CONTENTS 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Significant Hazards Consideration 4.3 Conclusions

6.0 REFERENCES

ATTACHMENTS

1.

Red-line of the Current Ginna EAL Technical Basis Document

2.

Clean Copy of the Proposed Ginna EAL Technical Basis Document

3.

Red-line ofNE! 99-01 Revision 5

4.

Clean Copy of Proposed Ginna EALs

5.

Plant-Specific EAL Guideline Cross Reference

6.

EAL Differences and Deviations I

ENCLOSURE EVALUATION OF PROPOSED CHANGES 1.0

SUMMARY

DESCRIPTION In accordance with the provision of 10 CFR 50.90, R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC) is submitting a license amendment request to change the R.E. Ginna Nuclear Power Plant (Ginna) Emergency Plan.

The proposed changes involve upgrading selected Ginna Emergency Action Levels (EALs) based on NEI 99-01, Revision 5, "Methodology for Development of Emergency Action Levels,"

using the guidance of NRC Regulatory Issue Summary 2003-18, Supplement 2, "Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels."

The current EAL scheme in use at Ginna is based on NUMARC/NESP-007, "Methodology for development of Emergency Action Levels." The plan, as changed, would continue to meet the standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR 50. Ginna LLC has reviewed the proposed changes in accordance with 10 CFR 50.54(q), and has determined these changes are considered a decrease in effectiveness of the approved emergency plan.

2.0 DETAILED DESCRIPTION The Ginna Emergency Plan currently uses the NUMARC/NESP-007 EAL scheme. Ginna LLC is proposing to change the existing scheme for Ginna for the following selected hazard - based EALs to that described in NEI 99-01, Revision 5, "Methodology for Development of Emergency Action Levels," January 2003, as endorsed by the Nuclear Regulatory Commission (NRC) in Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors,"

Revision 4, July 2003:

EAL Number Classification Level Summary Description 7.3.1 Unusual Event Loss of Annunciators 7.3.3 Alert Loss of Annunciators 7.3.4 Site Area Emergency Loss of Annunciators 8.2.1 Unusual Event Fire 8.2.2 Alert Fire or Explosion 8.3.1 Unusual Event Vehicle Crash 8.3.2 Unusual Event Explosion 8.3.3 Unusual Event Toxic Gas 8.3.4 Alert Vehicle Crash 8.3.5 Alert Toxic Gas NEI 99-01 revision 5 represents an improvement in hazard based EALs versus those based on the NUMARC document. Revising the hazard-based EALs allows Ginna to take advantage of improved EAL wording and basis.

The current Ginna NUMARC/NESP-007 based EALs were developed in 1994. At that time, it was decided that the loss of any one safety system annunciator panel, versus the "approximately 75%" recommended by the NUMARC document, was an accurate description of the conditions 2

ENCLOSURE EVALUATION OF PROPOSED CHANGES 1.0

SUMMARY

DESCRIPTION In accordance with the provision of 10 CFR 50.90, R.E. Ginna Nuclear Power Plant, LLC (Ginna LLC) is submitting a license amendment request to change the R.E. Ginna Nuclear Power Plant (Ginna) Emergency Plan.

The proposed changes involve upgrading selected Ginna Emergency Action Levels (EALs) based on NEI 99-01, Revision 5, "Methodology for Development of Emergency Action Levels,"

using the guidance of NRC Regulatory Issue Summary 2003-18, Supplement 2, "Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels."

The current EAL scheme in use at Ginna is based on NUMARCINESP-007, "Methodology for development of Emergency Action Levels." The plan, as changed, would continue to meet the standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR 50. Ginna LLC has reviewed the proposed changes in accordance with 10 CFR 50.54(q), and has determined these changes are considered a decrease in effectiveness of the approved emergency plan.

2.0 DETAILED DESCRIPTION The Ginna Emergency Plan currently uses the NUMARCINESP-007 EAL scheme. Ginna LLC is proposing to change the existing scheme for Ginna for the following selected hazard - based EALs to that described in NEI 99-01, Revision 5, "Methodology for Development of Emergency Action Levels," January 2003, as endorsed by the Nuclear Regulatory Commission (NRC) in Regulatory Guide 1.101, " Emergency Planning and Preparedness for Nuclear Power Reactors,"

Revision 4, July 2003:

EAL Number Classification Level Summary Description 7.3.1 Unusual Event Loss of Annunciators 7.3.3 Alert Loss of Annunciators 7.3.4 Site Area Emergency Loss of Annunciators 8.2.1 Unusual Event Fire 8.2.2 Alert Fire or Explosion 8.3.1 Unusual Event Vehicle Crash 8.3.2 Unusual Event Explosion 8.3.3 Unusual Event Toxic Gas 8.3.4 Alert Vehicle Crash 8.3.5 Alert Toxic Gas NEI 99-01 revision 5 represents an improvement in hazard based EALs versus those based on the NUMARC document. Revising the hazard-based EALs allows Ginna to take advantage of improved EAL wording and basis.

The current Ginna NUMARCINESP-007 based EALs were developed in 1994. At that time, it was decided that the loss of anyone safety system annunciator panel, versus the "approximately 75%" recommended by the NUMARC document, was an accurate description of the conditions 2

ENCLOSURE EVALUATION OF PROPOSED CHANGES that met the Initiating Condition as detailed in NUMARC/NESP-007. Ginna has eight safety system annunciator panels in the Main Control Room. 75% of those would equal six panels.

The NUMARC document states "This EAL recognizes the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment." During EAL development, it was concluded that the indications available in the Main Control Room at that time were such that the loss of any one of the safety system annunciator panels created sufficient challenges to the operating crews to result in a potential decrease in the level of safety of the plant. Hence, the EAL developers considered the loss of one safety system annunciator panel to meet the definition of a Notification of Unusual Event.

That concept was carried to the related emergency classifications at the Alert and Site Area Emergency levels. The loss of annunciator emergency action levels were endorsed by the NRC in a Safety Evaluation Report dated 2/15/1995 as part of the overall approval of the new EAL scheme for Ginna.

Subsequent to the approval of the NUMARC-based EALs for Ginna, improvements in Main Control Room indications took place. The EAL bases were not revisited after completion of the upgrades. Once the Main Control Room upgrades were complete, the conservatism of the annunciator loss EAL's had increased, given the additional indications that were now available to monitor plant conditions without the use of annunciators. At this point, loss of a single safety system annunciator panel no longer constituted a potential decrease in the level of safety of the plant. However, this was not recognized as an opportunity to improve the EALs.

Ginna LLC has experienced two loss of annunciator events, each of which resulted in the declaration of a Notification of Unusual Event. The 7/4/2007 event resulted in a loss of all annunciators in the Main Control Room. The event on 2/5/2009 involved the loss of three safety system annunciator panels. During the later event, the experience of the operating crews caused them to question the validity of the basis that the loss of a single safety system annunciator panel constituted a Notification of Unusual Event. Investigation into the 2009 event revealed the conservatism in the current EALs and caused Ginna LLC to investigate the re-alignment of the EALs with NRC-endorsed guidance.

In addition to the Annunciator EALs, the current wording and basis of other hazard-based Ginna EALs contains certain ambiguities that make emergency classification more difficult. The proposed revision brings industry operating experience to the EALs from NEI 99-01 revision 5.

NRC Regulatory Issue Summary (RIS) 2005-02, Clarifying the Process for Making Emergency Plan Changes defines a decrease in effectiveness as a change in an emergency preparedness (EP) requirement that results in the degradation or loss of the capability to perform a function or perform a function in a timely manner, as contained in the emergency plan. RIS 2005-02 clarifies a change in an EP requirement based on capability, means the emergency plan as changed, would result in the loss or degradation of the capability to meet the regulatory requirements of an emergency plan. Consequently, the capability to perform a function(s) as previously stated in the emergency plan no longer exists or is degraded. RIS 2005-02 defines an EP requirement, in part, as a statement made in the emergency plan which addresses how a 3

ENCLOSURE EVALUATION OF PROPOSED CHANGES that met the Initiating Condition as detailed in NUMARCINESP-007. Ginna has eight safety system annunciator panels in the Main Control Room. 75% of those would equal six panels.

The NUMARC document states "This EAL recognizes the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment." During EAL development, it was concluded that the indications available in the Main Control Room at that time were such that the loss of anyone of the safety system annunciator panels created sufficient challenges to the operating crews to result in a potential decrease in the level of safety of the plant. Hence, the EAL developers considered the loss of one safety system annunciator panel to meet the definition of a Notification of Unusual Event.

That concept was carried to the related emergency classifications at the Alert and Site Area Emergency levels. The loss of annunciator emergency action levels were endorsed by the NRC in a Safety Evaluation Report dated 2/15/1995 as part of the overall approval ofthe new EAL scheme for Ginna.

Subsequent to the approval ofthe NUMARC-based EALs for Ginna, improvements in Main Control Room indications took place. The EAL bases wer~ not revisited after completion of the upgrades. Once the Main Control Room upgrades were complete, the conservatism of the annunciator loss EAL's had increased, given the additional indications that were now available to monitor plant conditions without the use of annunciators. At this point, loss of a single safety system annunciator panel no longer constituted a potentia! decrease in the level of safety of the plant. However, this was not recognized as an opportunity to improve the EALs.

Ginna LLC has experienced two loss of annunciator events, each of which resulted in the declaration of a Notification of Unusual Event. The 7/412007 event resulted in a loss of all annunciators in the Main Control Room. The event on 215/2009 involved the loss of three safety system annunciator panels. During the later event, the experience of the operating crews caused them to question the validity of the basis that the loss of a single safety system annunciator panel constituted a Notification of Unusual Event. Investigation into the 2009 event revealed the conservatism in the current EALs and caused Ginna LLC to investigate the re-alignment of the EALs with NRC-endorsed guidance.

In addition to the Annunciator EALs, the current wording and basis of other hazard-based Ginna EALs contains certain ainbiguities that make emergency classification more difficult. The proposed revision brings industry operating experience to the EALs from NEI 99-01 revision 5.

NRC Regulatory Issue Summary (RIS) 2005-02, Clarifying the Process for Making Emergency Plan Changes defines a decrease in effectiveness as a change in an emergency preparedness (EP) requirement that results in the degradation or loss of the capability to perform a function or perform a function in a timely manner, as contained in the emergency plan. RIS 2005-02 clarifies a change in an EP requirement based on capability, means the emergency plan as changed, would result in the loss or degradation of the capability to meet the regulatory requirements of an emergency plan. Consequently, the capability toperform a function(s) as previously stated in the emergency plan no longer exists or is degraded. RIS 2005-02 defines an EP requirement, in part, as a statement made in the emergency plan which addresses how a 3

ENCLOSURE EVALUATION OF PROPOSED CHANGES particular regulatory requirement will be met and emphasizes all EP requirements are subject to the 10 CFR 50.54(q) change process.

Ginna LLC has reviewed these changes in accordance with 10 CFR 50.54(q), and has determined that the proposed changes are considered a decrease in effectiveness of the approved emergency plan and require prior approval before implementation. The proposed changes would result in a minor degradation of the function as defined in the current Ginna LLC emergency plan, but still meet NUMARC/NESP-007 requirements. This degradation does not result in a degrading of the level of public safety.

3.0 TECHNICAL EVALUATION

These changes affect the Ginna Emergency Plan and do not alter requirements of the Operating License or the Technical Specifications. These changes do not alter any of the assumptions used in the safety analyses, nor do they cause any safety system parameters to exceed their acceptance limit. Therefore, the proposed changes have no adverse effect on plant safety. Additionally, these changes can be made without adverse impact to plant operations or to the health and safety of the public.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.47(b)(4) states "A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures."

10 CFR 50 Appendix E, section IV. Content of Emergency Plans, item B. Organization states "The means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of local and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring. These initial emergency action levels shall be discussed and agreed on by the applicant or licensee and state and local governmental authorities, and approved by the NRC.

Thereafter, emergency action levels shall be reviewed with the State and local governmental authorities on an annual basis. A revision to an emergency action level must be approved by the NRC before implementation if:

4 ENCLOSURE EVALUATION OF PROPOSED CHANGES particular regulatory requirement will be met and emphasizes all EP requirements are subject to the 10 CFR SO.S4(q) change process.

Ginna LLC has reviewed these changes in accordance with 10 CFR SO.S4(q), and has determined that the proposed changes are considered a decrease in effectiveness of the approved emergency plan and require prior approval before implementation. The proposed changes would result in a minor degradation of the function as defined in the current Ginila LLC emergency plan, but still meet NUMARCINESP-007 requirements. This degradation does not result in a degrading of the level of public safety.

3.0 TECHNICAL EVALUATION

These changes affect the Ginna Emergency Plan and do not alter requirements of the Operating License or the Technical Specifications. These changes do not alter any of the assumptions used in the safety analyses, nor do they cause any safety system parameters to exceed their acceptance limit. Therefore, the proposed changes have no adverse effect on plant safety. Additionally, these changes can be made without adverse impact to plant operations or to the health and safety of the public.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR S0.47(b)(4) states "A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures."

10 CFR SO Appendix E, section IV. Content of Emergency Plans, item B. Organization states "The means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of local and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring. These initial emergency action levels shall be discussed and agreed on by the applicant or licensee and state and local governmental authorities, and approved by the NRC.

Thereafter, emergency action levels shall be reviewed with the State and local governmental authorities on an annual basis. A revision to an emergency action level must be approved by the NRC before implementation if:

4

ENCLOSURE EVALUATION OF PROPOSED CHANGES (1)

The licensee is changing from one emergency action level scheme to another emergency action level scheme (e.g., a change from an emergency action level scheme based on NUREG-0654 to a scheme based upon NUMARC/NESP-007 or NEI-99-01);

(2)

The licensee is proposing an alternate method for complying with the regulations; or (3)

The emergency action level revision decreases the effectiveness of the emergency plan.

A licensee shall submit each request for NRC approval of the proposed emergency action level change as specified in § 50.4. If a licensee makes a change to an EAL that does not require NRC approval, the licensee shall submit, as specified in § 50.4, a report of each change made within 30 days after the change is made."

Regulatory Guide 1.101 Revision 4, Section C. Regulatory Position states "The guidance in NUMARC/NESP-007 (Revision 2, January 1992), "Methodology for Development of Emergency Action Levels," is acceptable to the NRC staff as an alternative method to that described in Appendix 1 to NUREG-0654/FEMA-REP-1 for developing EALs required in Section IV.B of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4). In addition, the guidance contained in NEI 99-01 (Revision 4, January 2003), "Methodology for Development of Emergency Action Levels," is acceptable to the NRC staff as an alternative method to that described in Appendix 1 to NUREG-0654/FEMA-REP-1 and NUMARC/NESP-007 for developing EALs required in Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4)."

10 CFR 50.54(q) requires, "Proposed changes that decrease the effectiveness of the approved emergency plans may not be implemented without application to and approval by the Commission. The licensee shall submit, as specified in 10 CFR 50.4, a report of each proposed change for approval."

4.2 Significant Hazards Consideration Ginna LLC has evaluated whether or not a significant hazards consideration (SHC) is warranted with the proposed changes by addressing the three criterion set forth in 10 CFR 50.92(c) as discussed below.

Criterion 1:

Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

These changes affect the R.E. Ginna Nuclear Power Plant Emergency Plan and do not alter any of the requirements of the Operating License or the Technical Specifications. The proposed changes do not modify any plant equipment and do not impact any failure modes that could lead to an accident. Additionally, the proposed changes have no effect on the consequence of any analyzed accident since the changes do not affect any equipment related 5

ENCLOSURE EVALUATION OF PROPOSED CHANGES (1)

The licensee is changing from one emergency action level scheme to another emergency action level scheme (e.g., a change from an emergency action level scheme based on NUREG-0654 to a scheme based upon NUMARCINESP-007 or NEI-99-01);

(2)

The licensee is proposing an alternate method for complying with the regulations; or (3)

The emergency action level revision decreases the effectiveness of the emergency plan.

A licensee shall submit each request for NRC approval of the proposed emergency action level change as specified in § 50.4. If a licensee makes a change to an EAL that does not require NRC approval, the licensee shall submit, as specified in § 50.4, a report of each change made within 30 days after the change is made."

Regulatory Guide 1.101 Revision 4, Section C. Regulatory Position states "The guidance in NUMARCINESP-007 (Revision 2, January 1992), "Methodology for Development of Emergency Action Levels," is acceptable to the NRC staff as an alternative method to that described in Appendix 1 to NUREG-0654IFEMA-REP-1 for developing EALs required in Section IV.B of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4). In addition, the guidance contained in NEI 99-01 (Revision 4, January 2003), "Methodology for Development of Emergency Action Levels," is acceptable to the NRC staff as an alternative method to that described in Appendix 1 to NUREG-0654IFEMA-REP-l and NUMARCINESP-007 for developing EALs required in Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4)."

10 CFR 50.54(q) requires, "Proposed changes that decrease the effectiveness of the approved emergency plans may not be implemented without application to and approval by the Commission. The licensee shall submit, as specified in 10 CFR 50.4, a report of each proposed change for approval."

4.2 Significant Hazards Consideration Ginna LLC has evaluated whether or not a significant hazards consideration (SHC) is warranted with the proposed changes by addressing the three criterion set forth in 10 CFR 50.92(c) as discussed below.

Criterion 1:

Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

These changes affect the R.E. Ginna Nuclear Power Plant Emergency Plan and do not alter any of the requirements of the Operating License or the Technical Specifications. The proposed changes do not modify any plant equipment and do not impact any failure modes that could lead to an accident. Additionally, the proposed changes have no effect on the consequence of any analyzed accident since the changes do not affect any equipment related 5

ENCLOSURE EVALUATION OF PROPOSED CHANGES to accident mitigation. Based on this discussion, the proposed amendment does not increase the probability or consequences of an accident previously evaluated.

Criterion 2:

Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

These changes affect the R.E. Ginna Nuclear Power Plant Emergency Plan and do not alter any of the requirements of the Operating License or the Technical Specifications. They do not modify any plant equipment and there is no impact on the capability of the existing equipment to perform their intended functions. No system setpoints are being modified and no changes are being made to the method in which plant operations are conducted. No new failure modes are introduced by the proposed changes. The proposed amendment does not introduce accident initiator or malfunctions that would cause a new or different kind of accident. Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Criterion 3:

Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

These changes affect the R.E. Ginna Nuclear Power Plant Emergency Plan and do not alter any of the requirements of the Operating License or the Technical Specifications. The proposed changes do not affect any of the assumptions used in the accident analysis, nor do they affect any operability requirements for equipment important to plant safety. Therefore, the proposed changes will not result in a significant reduction in the margin of safety as defined in the bases for technical specifications covered in this license amendment request.

In summary, Ginna LLC concludes that the proposed amendment does not represent a significant hazards consideration under the standards set forth in 10 CFR 50.92(c).

4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission' regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6 ENCLOSURE EVALUATION OF PROPOSED CHANGES to accident mitigation. Based on this discussion, the proposed amendment does not increase the probability or consequences of an accident previously evaluated.

Criterion 2:

Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

These changes affect the R.E. Ginna Nuclear Power Plant Emergency Plan and do not alter any of the requirements of the Operating License or the Technical Specifications. They do not modify any plant equipment and there is no impact on the capability of the existing equipment to perform their intended functions. No system setpoints are being modified and no changes are being made to the method in which plant operations are conducted. No new failure modes are introduced by the proposed changes. The proposed amendment does not introduce accident initiator or malfunctions that would cause a new or different kind of accident. Therefore, the proposed amendment does not create. the possibility of a new or different kind of accident from any accident previously evaluated.

Criterion 3:

Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

These changes affect the R.E. Ginna Nuclear Power Plant Emergency Plan and do not alter any ofthe requirements ofthe Operating License or the Technical Specifications. The proposed changes do not affect any of the assumptions used in the accident analysis, nor do they affect any operability requirements for equipment important to plant safety. Therefore, the proposed changes will not result in a significant reduction in the margin of safety as defined in the bases for technical specifications covered in this license amendment request.

In summary, Ginna LLC concludes that the proposed amendment does not represent a significant hazards consideration under the standards set forth in 10 CFR 50.92(c).

4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission' regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6

ENCLOSURE EVALUATION OF PROPOSED CHANGES

5.0 ENVIRONMENTAL CONSIDERATION

Ginna LLC has determined that the proposed amendment would not change requirements with respect to use of a facility component located within the restricted area, as defined by 10 CFR 20, nor would it change inspection or surveillance requirements. Ginna LLC has evaluated the proposed change and has determined that the change does not involve:

I.

A Significant Hazards Consideration II.

A significant change in the types or significant increase in the amounts of any effluent that may be released off site, or III.

A significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (1 0)(ii). Therefore, pursuant to 10 CFR 5.1.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

(1)

NUMARC/NESP-007, "Methodology for development of Emergency Action Levels" (2)

NEI 99-01, Revision 5, "Methodology for Development of Emergency Action Levels" (3)

NRC Regulatory Issue Summary 2003-18, Supplement 2, "Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels" (4)

NRC Regulatory Issue Summary 2005-02, Clarifying the Process for Making Emergency Plan Changes 7

ENCLOSURE EVALUATION OF PROPOSED CHANGES

5.0 ENVIRONMENTAL CONSIDERATION

Ginna LLC has determined that the proposed amendment would not change requirements with respect to use of a facility component located within the restricted area, as defined by 10 CFR 20, nor would it change inspection or surveillance requirements. Ginna LLC has evaluated the proposed change and has determined that the change does not involve:

I.

A Significant Hazards Consideration II.

A significant change in the types or significant increase in the amounts of any effluent that may be released off site, or III.

A significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (10)(ii). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

(1)

NUMARCINESP-007, "Methodology for development of Emergency Action Levels" (2)

NEI 99-01, Revision 5, "Methodology for Development of Emergency Action Levels" (3)

NRC Regulatory Issue Summary 2003-18, Supplement 2, "Use of Nuclear Energy*

Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels" (4)

NRC Regulatory Issue Summary 2005-02, Clarifying the Process for Making Emergency Plan Changes 7

ATTACHMENT (1)

Red-line of the Current Ginna EAL Technical Basis Document R.E. Ginna Nuclear Power Plant, LLC November 30, 2009 ATTACHMENT (1)

Red-line of the Current Ginna EAL Technical Basis Document R.E. Ginna Nuclear Power Plant, LLC November 30, 2009

ATTACHMENT (1)

Red-line of the Current Ginna Technical Basis Document Additions to the current document are highlighted text. Deletions to the current document are strikethrough text.

ATTACHMENT (1)

Page 1-1 ATTACHMENT (1)

Red-line of the Current Ginna Technical Basis Document Additions to the current document are highlighted text. Deletions to the current document are strikethrough text.

ATIACHMENT (1)

Page 1-1

7.0 Equipment Failures 7.3 Loss of Indications /Alarms /

Communication Capability 7.3.1 Unusual Event Unplanned less, of annunciators or indications on any Control Room Panols, Table 7.3 for >1 5 mmR.

Increased su...illanco i, requi*ed fr* safe plant opo.ation Tr'blr% 7.

Vital Con*trl Room Panels A

ZiAiA E-F-

G Unplanned. loss of the following for 15 minutes or lbngde Vor more Control Room Annunciators listed in Table 7.3 An aoro~ximate 75% reduction in Control Room safetVY sivstem indications Table 7,3 Control Room AnnunciatorPanels NUMARG4 Unplanned loss of most or all safety System annRunciation or indication in the'control roomn for greater than 15 minutes With reactor coolant temperature >20OF.

!NEI 99-01 Rev. 5 IC:.

Lnplanned loss of safety system annunciation orindication in the control room for 15 minutes oi fong er.!

FPB loss/potential loss:

N/A Mode Applicability:

1-Power operations, 2-startup, 3-hot shutdown, 4-hot standby Basis:

Npote:._ The Emergency Director should not wait until the applicable time has elapse.,t,'

Jhould likely declare the eventassoon asit,is determinedth th*6*c:ndition has'

• xceeded, or will likely exceed, the applicable time.

This EAL recognizes the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment. Recognition of the availability of computer based indication equipment is considered (PPCS and SAS).

"U-planned" loss of annunciators or indicators ekludes Enciudýs scheduled maintenance and testing activities.

ATTACHMENT (1)

Page 1-2 7.0 Equipment Failures 7.3

,Loss of Indications /Alarms /

Communication Capability 7.3.1 Unusual Event Unplanned loss of annunciators or indications on any Control Room Panels, Table 7.3 for >15 fffiA.:.

-AN[)

Increased surveillance is required for safe plant operation I

1a:le r AAVir C:AtNi Ro:m r e

~.QI:~lanned lossofthe,following for' 15 minutes or long:!ill

~ or more Control Room Annunciators listed in Table 7.3,

o~

G (A,n ap-Qroximate 75% reduCtion inCoritrol Room safeti s~stem: indications NUMARC IC:

Unplanned loss of most or all safety system annunciation or indication in the' control room for greater than 15 minutes with reactor coolant temperature >200F.

!NEI99-01 Rev.5IC:!

i!:J.QI:~lanned loss of safet~systerT1 annunciation or indication ir:l the cOntrol room for 15 minutes' on

!2Dg~

FPB loss/potential loss:

N/A Mode Applicability:

1-Power operations, 2-startup, 3-hot shutdown, 4-hot standby Basis:

Note:. The Emergenc~Director should not wait until the aQQlicable.time has elaQseCl,;but

~hould 'Iikel~ deClare the 'event as soon as" it,is determiriedJb~~;,tb~:cobditi()nd;aS

~xceeded, or will likely exceed, the aQl2licable time.!

This EAL recognizes the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment. Recognition oOhe availability of computer based indication equipment is considered (PPCS and SAS).

"-U-Rplanned" loss of annunciators or indicators m<Gludes lnclud~.§ scheduled maintenance and testing activities.

ATIACHMENT (1)

Page 1-2

Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety

• ystem annunciators or indications are lost, there is an increased risk that a degraded plant,

,ondition could go undetected.

It is not intended that plant personnel perform a detailed count of the instrumentation lost but the use of judgment by the Shift Manager as the threshold for determining the severity of the plant conditions. This ju.dgment i6 u.pported by the specific opinion of the Shift Manager that additional operating personnel will b8 requ1ired to provide inrG.eased moenitoring of systemA operation to safely operate the plant-.

175% of lost annunciators is defined as loss of 6 of the 8 annunciator panels listed on Table 7.3.!

iLoss of 75% of Control Room safety indications is loss of 75% of the indicators on the center and left sections of the main control board indications.

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptable power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by their specific Technical Specification.

The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via IOCFR50.72. If the shutdown is not in compliance with the Technical Specification action, the Unusual Event is based on EAL 7.1.1, Inability to Reach Required Shutdown Within Technical Specification Limits.

Annunciators or indicators for this EAL must include those identified in the Abnormal Operating procedures, in the Emergency Operating Procedures, and in other EALs (e.g., area, process, and/or effluent rad monitors, etc.).

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

Due to the limited number of safety systems in operation in cold shutdown, refueling, and defueled modes, this EAL is not applicable during these modes of operation.

This Unusu-al1 Eve~nt will bo escalated to an Alert if a tranesient iinprogeress duorig the los6 of annunciationA or ind-icatioen.,

IThis Unusual Event will be escalated to an Alert based on a concurrent loss of compensatory indications or if a SIGNIFICANT TRANSIENT is in progress during the loss of annunciation o*

indication.]

PEG Reference NEI 99-01 Revision 5:] SU3.1 Basis Reference(s):

None ATTACHMENT (1)

Page 1-3

Quantification is arbitra[y', however, it is estimated that if aQl'~roximately' 75% of the safet~

~y.stem annunciators or indications are lost, there is an increased risk that a degraded J2lant

Condition could go undetected.!

It is not intended that plant personnel perform a detailed count of the instrumentation lost but the use of judgment by the Shift Manager as the threshold for determining the severity of the plant conditions. This judgment is supported by the spesifis opinion of the Shift Manager that additional operating personnel will be required to provide insreased monitoring of system operation to safely operate the plant.

175% of lost annunciators is defined as loss of 6 of the 8 annunciator J2anels listed on Table 7.3'!

[Loss of 75% of Control Room safety. indications is loss of 75% of the indicators on the centen

and left sections of the main control board indications.1 It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptable power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by their specific Technical Specification.

The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10CFR50.72. If the shutdown is not in compliance with the Technical Specification action, the Unusual Event is based on EAL 7.1.1, Inability to Reach Required Shutdown Within Technical Specification Limits.

Annunciators or indicators for this EAL must include those identified in the Abnormal Operating procedures, in the Emergency Operating Procedures, and in other EALs (e.g., area, process, and/or effluent rad monitors, etc.).

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

Due to the limited number of safety systems in operation in cold shutdown, refueling, and defueled modes, this EAL is not applicable during these modes of operation.

This Unusual Event will be essalated to an Alert if a transient is in progress during the loss of annunsiation or indisation.

jrhis Unusual Event will be escalated to an Alert based on a concurrent loss of coml2ensato~

indications or if a SIGNIFICANT TRANSIENT isin J2rogress during the loss of annunciation on

)ndication.1 PEG Reference (NEI 99-01 Revision 5:1 SU3.1 Basis Reference(s):

None ATIACHMENT (1)

Page 1-3

7.0 Equipment Failures 7.3 Loss of Indications /Alarms /

Communication Capability 7.3.3 Alert Unplanned loss of annunciators or ii n any Control Rom* Panels, Table 7.3 for > 15 Incr.eaesed 6urveillance iS required for safe plant operation ANDeithei=

A plant transient in; progress

-OR PPCS is unavailable Table *7 3 Vital ConrolI Room Panels A

PAA 1

kUnplanned loss of the following 'for, 15 minutes or longer.'

or more Control: RoomAnnunciators listed'in Table 7$

Wn approximate 75% reduction in Control Room safetysystem indications, IAND EITHEA A SIGNIFICANT TRANSIENT is in'progrs

ýfopensatory indications are unavailable ITable 7.3 Control Room Annunciator Panels I AA I

ý8.

I '.C,o 1 ",0, 1 'ý 1 F 1 G K 1A ARG 4tr Unplanned loss of moest or all safety system annunciation or inictin n otrol room With either (1) a significant transiont in progress, or (2) compensatory non alarming indicators are unavailable with reactor coolant >200 OF.

XNEl 99-01 -Rev., 5 IC:I Unpanned, loss of safety system ýannunciation or indication in the control room ~with ite (i)

S$IGNIFICANT TRANSIENT in progress, or () compestr inicators unaviae.

FPB loss/potential loss:

N/A Mode Applicability:

1 -Power operations, 2-startup, 3-hot shutdown, 4-hot standby Basis:

Note:, The EmergeýncyI Director should not wait uni h plica'ble time ha elase 7t

ýhul dclare the event as soon as it is determined that the ýcondition `hasexceddor

~w~lliel eceed, the pplicable time.

ATTACHMENT (1)

Page 1-4 7.0 Equipment Failures 7.3.3 Alert 7.3 Loss of Indications /Alarms /

Communication Capability Unplanned loss of annunciators or indications on any Control Room Panels, Table 7.6 for> 15 mffi,.

--ANG Increased surveillance is required for safe plant operation AND either:

A plant transient in progress

-GR PPCS is unavailable Table 7.3 Vital Control Room Panels

~~lai1ned loss of the following for* 1'5'minutes orlongiill e or more C,ontrol Room Annuhciators listed in Table 7:3,

'OR

~

~n aQr2roxiniate 75% reduction iil Control Ro'om'safet~,s~stemjndicationS.

~NDEITHER

~SIGNIFICANTTRANSIENT is in'grogress.

OR

ComQensato[yindicatioris areunavailable~

NlJMARC IC:

Unplanned loss of most or all safety system annunciation or indication in control room with either (1) a significant transient in progress, or (2) compensatory non alarming indicators are unavailable with reactor coolant> 200 OF.

INEI 99-01 *Rev. 5 le:j i!;mglanned, loss of safet~ s~stemannunciation or indication in the controrroom, with eitner Ina'

!SIGNIFICANT TRANSIENT in grogress, or(g)comQensatorY indicators unavailable.!

FPB loss/potential loss:

N/A Mode Applicability:

1-Power operations, 2-startup, 3-hot shutdown, 4-hot standby Basis:

[Note: The'Emergenc~Director should not wait until the aQQlicable'fime has ela~sed,but

~hould declare the event as soon as it is determined that the.cohditiol1:'has exceeded,.Q!j Wililikel~'exceed, the'agQlicablefimeJ ATIACHMENT (1)

Page 1-4

This EAL recognizes the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment during a traneient SGIUFICAT TT.

Recognition of the availability of computer based indication equipment is considered (PPCS, SAS, etc.).

"J,=planned" loss of annunciators or indicators does-et include' scheduled maintenance and testing activities.

It is; not intended that plant perso~nnl performA a detailed count of the finsruF*,m~enta;tion lost but the use of judgment by the Shift M.anager as the threshold for determining the.e.erity of the plant conditions. This judgment ir, supported by the specific opinion of the Shift Manager that additional operatfing personnel will be requirFed topovd iceased monitoring of syste-m operation to 6afely operate the plant.

Q i abi tiraryhLowever, iti st hatrif, p fox-mytely, 5 Ip_

s annuncitorso indiators" arelost, there is.ate** _*f*Sanc iincreased i e

e*.,

&yf th plant codtos It' is alsoa no inene thtteSitMn'rbak d

wihdak'

~Fn5 ofteidcaoso in -:not-inand left sectiopa ns ofthe §ain eoto badidct~~

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptable power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification.

The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 1 OCFR50.72. n

ý s

If t is n in

i. i Vnc i -wthi etT ii fid th~ii T~edhni ----- S-7iftiM Required AatiowQn 11'in iie.

Annunciators or indicators for this EAL iRG'udes jhopld imne'ýd those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e. g., area, process, and/or effluent rad monitors, etc.).

"Significant transien"P-t" includes response to automatic or manually initiated-func-tions-Guch as trips, FRubacks inVolVing greater than 25% thermal power change, ECCS injections, or therm~al power oscillations of, 10-%5 or greater-.

SI~NIFIANT TRASIENT:An, U.NP LNQED &ent,

~Iing n rm~o h olwn: ~

ATTACHMENT (1)

Page 1-5 This EAL recognizes the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment during a transient S11~l[fllil~fiiifiT~~:$;lll§mm. Recognition of the availability of computer based indication equipment is considered (PPCS, SAS, etc.).

"-lJ.Aplanned" loss of annunciators or indicators does not include~ scheduled maintenance and testing activities.

It is not intended that plant personnel perform a detailed count of the instrumentation lost but the use of judgment by the Shift Manager as the threshold for determining the severity of the plant conditions. This judgment is supported by the specific opinion of the Shift Manager that additional operating personnel 'IIill be required to provide increased monitoring of system operation to safely operate the plant.

Annunciators or indicators for this EAL includes ~tfIp'l!ii~~~~41i!im'ld!~~AtQ those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e. g., area, process, and/or effluent rad monitors, etc.).

~~t~ii1j:Gtigafimii!IID:~iiID§l:;te:§i_~)T§ftjiIDJ.{0,jf;~ll:CRils~m~ffifasJ~~~~~

i!r<!$.'I$]IltmID:m;rai~i&t{fID~ta:rilJiim~imi~mtmI~&.lt~tlllf(I~:t!fr!tifiiWilIDjfM\\l:iJiifrm9ta~

mmmi~~lmmlfWtl~

"Significant transient" includes response to automatic or manually initiated functions such as trips, run backs involving greater than 25% thermal power change, EGGS injections, or thermal power oscillations of 10% or greater.

~r~:~:flJjI~~itili@j)[$.;II~Jitmoo:wi~~:&~i~jey:elfiliriDWJiliR$lem_rrer&fltac.ill[wMgIX~1

~1t'iG~iltmi~illj[~@G~t11ftjlmjjl~~fZo~~il!i~t$M~(~mtAAt~iml&tajmjAAtiW ATIACHMENT (1)

Page 1-5

'greater than 25% full electrical load,_(3) Reactor Trip, (4)Safety Injection Activation,or (5n

ýhermal power oscillations Igreater than 10% of rated thermal power.

If both a major portion of the ann..unciation sy*tem and all computer monitorig are U.aVa.lablc to the extent that the additional operating personnel arc required to moneitor indications, the Aler 4 sFequGed-Due to the limited number of safety systems in operation during cold shutdown, refueling and defueled modes, no EAL is indicated during these modes of operation.

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

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

This Alert will be escalated to a Site Area Emergegncy if the opetrating crew cannot monit-o-rthe ransientinLprogress due to a concurrent loss of compensatory indications with a SIGNIFICANT TRANSIENT in Droaress durina the loss of annunciation or indicationi PEG

Reference:

NEI 99-01 Revision 5:1 SA4.1 Basis Reference(s):

None ATTACHMENT (1)

Page 1-6 greater than 25% full electrical load, (3) Reactor TriQ, (4) Safety. Injection Activation, 'Or (§i

~hermal Qower oscillations greater than 10% of rated thermal ~

If both a major portion of the annunGiation system and all Gomputer monitoring are unavailable to the e>ftent that the additional operating personnel are required to monitor indiGations, the Alert is required.

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

[Fifteen minutes was selected as a threshold to exclude transient or momentarY_Qower losses.!

This Alert will be eSGalated to a Site Area EmergenGY if the operating Grew Gannot monitor the transient in progress.

jThis Alert will be escalated to a Site Area Emergency' if the oQerating crew cannot monitor the,

~ransient in Qrogress due to a concurrent loss of comQensatory indications with a SIGNIFICANlj

,TRANSIENT in Qrogress during the loss of annunciation or indication.!

PEG

Reference:

NEI 99-01 Revision 5:! SA4.1 Basis Reference(s):

None ATIACHMENT (1)

Page 1-6

7.0 Equipment Failures 7.3 Loss of Indications /Alarms /

Communication Capability 7.3.4 Site Area Emergency Loss of annunciators o r ind-ic-ation meon any Control Room Panels, Table7.

-AND Complete less of ability to moneitor all critical safety function Status

-AND A plant transient in progress Table 7.3 Vital ConAtrol Room Pane's A

AA 8

G 9

G Loss&of the.followin gfor 1.5 minutes or longqr 6 or more Control Room Annunciator Panels.listed in Table 7.3

'An approximate 75% reduction jin Control Roomsafety indicationd

'A SIGNIFICANT TRANSIENT. isin iprogress._

WD:]

'Conicensatorv indicationis areunavailable.!

iTable 7.3 Control Room Annunciator Panels

'A' A

E Inability to mon*tor a ;ignifiGa*t t*rasient in progress with reactor coolant > 200 OF.

ýNEI 99-01 Rev. 51C, Inabty to.monitor a SIGNIFICANT TRANSIENT n progr FPB losslpotential loss:

N/A Mode Applicability:

1-Power operations, 2-startup, 3-hot shutdown, 4-hot standby Basis:

"Note: The Emergency Director should not wait until the applicable timehas e apsed7Au should declare the event as soon as it is determined that the conditiontihas exceededc or

.ikely exceed, the applicable time.

This EAL recognizes the inability of the Control Room staff to monitor the plant response to a tFansien,,SIGNIFICANT-TRANSIENTi.

ATTACHMENT (1)

Page 1-7 7.0 Equipment Failures 7.3.4 Site Area Emergency 7.3 Loss of Indications /Alarms /

Communication Capability Loss of annunciators or indications on any Control Room Panels, Table 7.3

--ANQ Complete loss of ability to monitor all critical safety function status

--ANQ A plant transient in progress Table 7.3 Vital Control Room Panels A

Loss6f the followingfort5miriutesor.lbngiij

6 Of more Control Room Annunciator Pal1els'Jisted in Table 7,.3. '

PR lA.nal2Qroximate 75% reductior:ijnControl Room safet~iridication~

lAND

~

lA. SIGNIFICANT TRANSIENT is in QrogressJ

~ND:

CorrlQensatorY indicatioris :aFe tmavailable.1 NUMARC IC:

Inability to monitor a significant transient in progress with reactor coolant> 200 of.

[NEI 99-01 Rev; 5'IC::

!Inabilityto:monitor a SIGNIFICANT TRANSIENT.in Qrog~

FPB loss/potential loss:

N/A Mode Applicability:

1-Power operations, 2-startup, 3-hot shutdown, 4-hot standby Basis:

[No'te:.The,Emergenc~Dire'CtoLshould hot wa it:i;,mti I th~ aQQlicabletime'has ela~sed; bu~

Should, deClarethef eyeritassoon as, it is,determinedthattheConclition.has exceeded;R!]

Wililikel~ exceed/the aQQlicable timeJ This EAL recognizes the inability of the Control Room staff to monitor the plant response to a transient :SIGNIFICANTTRANSIENlj.

ATIACHMENT (1)

Page 1-7

"'Planned" and "UNPLANNED" actions are not differentiated since the loss of instrumentation of mgnitude is of such significance during a transient that the cause of the loss is not an ameliorating factor.J

',Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety

• ystem annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity the plant conditions. It is also not intended that the Shift Manager.be tasked with makings judgment decision as to whether additional personnel are required to provide increased

'monitorin of system operation. 75% of lost annunciators is defined as loss of 6 of the e

'annunciator panels listed on Table 7.3. Loss of 75% of Control Room safety indications is loss

'of 75% of the indicators on the center and left sections of the main control board indications.

It is further recognized that most plant designs provide redundant safety system indication' powered from separate uninterruptible power supplies. While failure of a large portion of

'annunciators is more likely than a failure of a large portion of indications the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific,!

'or several, safety system indicators should remain a function of that specific system ojr bcomponent operability status. This will be addressed by the specific Technical Specification.

Frhe initiation of a Technical Specification imposed plant shutdown related to the instrument loss

,will be reported via 10 CFR 50.72. If the shutdown is not in compliance with the Technical

• pecification action, the UE is based on EAL 7.1.1 "Plant is not brought to required operating

'mode within Technical Specification LCO Required Action Completion Time.',

A Site Area Emergency is considered to exist if the Control Room staff cannot monitor safety functions needed for protection of the public.

Annunciators for this EAL should be limited to include those identified in the Abnormal Operating Procedures, in the CSFST's and Emergency Operating Procedures, and in other EALs (e. g., rad monitors, etc.).

"Significant tr-ansient" include6 response to automatic or Manually initiated functions 6uch as srGams, runbacks inVolvig greater than 252% thermnal poweFr change, ECCS injections, or thermal pawer eosillations of 1%

or greater*.

SIGNIFICANT TRANSIENT: An UNPLANNED event involving one or more of the following: (ly

'utomatic turbine runback greater than 25% thermal reactor power,_(2) electrical load rejeton

'greater than 25% full electrical load,_(3) ReactorTrip,_(4) Safety Injection Activation, or (5) thermal.power oscillations greater than 10% of rated thermal power.

Indications needed to monitor critical safety functions necessary for protection of the public must include Control Room indications, computer generated indications and dedicated annunciation capability. The specific indications should be those used to determine such functions as the ability to shut down the reactor, maintain the core cooled and in a coolable geometry, to remove heat from the core, to maintain the reactor coolant system intact, and to maintain containment intact.

ATTACHMENT (1)

Page 1-8

,'Planned" and "UNPLANNED" actions are not differentiated since the loss of instrumentationo~

~his magnitude is of such significance during a transient that the cause ofthe loss is not ad

~ameliorating factor.!

Ouantification is arbitrarY.., however,it is estimated that if a~~roximatel~ 75% of the safet~

~y.stem annunciators or indicators are lost, there is an increased. risk that a degraded ~Iant

Condition could go undetected. It is not intended that ~Iant ~ersonnel ~erform a detailed count o~

~he instrumentation lost but use the value as a judgment threshold for determining the severit~

Of the ~Iant conditions. It is also not intended that the Shift Manager.be tasked with making a judgment decision as to whether additional ~ersonnel are reQuired to~rovide increased

'monitoring of s~stemo~eration. 75% of lost annunciators is defined as loss of 6 of the 8,

!annunciator ~anels listed on Table 7.3. Loss of 75% of Control Room safet~ indications is los~

of 75% of the indicators on the center and left sections of the main control board indications.1

[It is furtherrecognized that most ~Iant designs ~rovide redundant safet~ s~stem indication'

'~oweredfrom se~arate uninterru~tible ~ower su~~lies. While failure of a large ~ortion o~

~annunciators is more likel~ than a failure of a large ~ortion of indications, the concern is included

'in this EAL due to difficult~ associated with assessment of ~Iant conditions. The loss of s~ecific,1 pr several, safet~ s~stem indicators should remain a function of that s~ecific s~stem on

~~onent o~erabilit~ status. This will be addressed by the s~ecific Technical S~ecification.!

jfhe initiation of a Technical S~ecification im~osed ~Iantshutdown related to the instrument los~

Will be re~orted via 10 CFR 50.72. If the shutdown is not in com~liance with the Technical

!§~ecification action,the UE is based on EAL 7.1.1 "Plant is not brought to reQuired o~erating

'mode within Technical S~ecification LCO ReQuired Action Com~letion Time.'i A Site Area Emergency is considered to exist if the Control Room staff cannot monitor safety functions needed for protection of the public.

Annunciators for this EAL should be limited to include those identified in the Abnormal Operating Procedures, in the CSFST's and Emergency Operating Procedures, and in other EALs (e. g., rad monitors, etc.).

"Significant transient" includes response to automatic or manually initiated functions such as scrams, runbacks involving greater than 25% thermal power change, EGGS injections, or thermal pO'Ner oscillations of 10% or greater.

!SIGNIFICANT TRANSIENT: An UNPLANNED event involving one or more of the following: (1~

~utomatic turbine runback greater than 25% thermal reactor ~ower, (2) electrical load rejection' breater than 25% fullelectricalload, (3) ReactorTri~, (4) Safet~ InjeCtion Activation, or (§~

~hermal ~ower oscillations greater than 10% of rated thermal ~

Indications needed to monitor critical safety functions necessary for protection of the public must include Control Room indications, computer generated indications and dedicated annunciation capability. The specific indications should be those used to determine such functions as the ability to shut down the reactor, maintain the core cooled and in a coolable geometry, to remove heat from the core, to maintain the reactor coolant system intact, and to maintain containment intact.

ATTACHMENT (1)

Page 1-8

"Pl-anne-d" actioes are excluded 4fro the EAL 6ince the 1966 9fi-rmotto f

thie, m~agnitude HS of sucwh Significance during a t~arancient that the cue of the Iness is. not anR amreliorating factor.

L'Corpensatory indications" in this context includes computer based information such as PPCS and SASJ.

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

'Due to the ýlimited number of safety systems in operation during.cold shutdown, refueling and

'defueled modes, no EAL is indicated durinq these modes of operation.1 PEG

Reference:

'NEI 99-01 Revision 5: SS6.1 Basis Reference(s):

None ATTACHMENT (1)

Page 1-9 "Planned" actions are excluded from the EAL since the loss of instrumentation of this magnitude is of such significance during a transient that the cause of the loss is not an ameliorating factor.

tQQrrlQensatory indications" in this context includes comQuter based information such as PPC8;

and 8A8.1

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

Oue to the limited number of safet~ s~stemsin oQeration during cold Shutdown', refueling and

~efueled modes, no EALis indicated during these modes of oQerati6n.1 PEG

Reference:

!NEI 99-01 Revision 5:! 886.1 Basis Reference(s):

None ATIACHMENT (1)

Page 1-9

8.0 Hazards 8.2.1 Unusual Event 8.2 Fire or Explosion fl 1

I "unrrMPa Pri in An'.. Wlint;;rA;I 4ip R~l P or R-A not oeaing-uisede in 4 -4 Min m

of Genrroi Rem-om.

"J IV.........

7 At at!A n:

oir R

P~l-nt 4rA Turbino Building T-SC Building Seri-e Building TOnt.minated Stoiage Building Table 8.3 Plant Vital Arcas S

ron#rol Building 0

ReactoFr "ontainment 1u1iiin EAuxiliar-y BuilDng Intermoediate Building E=meraencGV DPie-SlBildn S!anaE~y t'.uxiiiar; Pe-ooawaer mOUNiiag Scnreen House FIRE in ANY of the areas listed in Table 8.4, not extinguished within 15 minutes ofA.

'* Control Room notification'

,* Verification of a Control Room FIRE alarm

[Table 8.4 Plant Vital and Adjacent Areasl Intermediate Building TSC Building Service Building' Contaminated Storage Building' Control Building Containment Building Auxiliary Building Turbine Building Diesel Generator Building(s)

Standby Auxiliary Feedwater Building Screen House-ATTACHMENT (1)

Page 1-10 8.0 Hazards 8.2 Fire or Explosion 8.2.1 Unusual Event Confirmed fire in any plant area, Table 8.2 or B.3 not extinguished in < 15 min. of Control Room notifiGation:

Table 8.2 Plant AFeas Turbine Building TSC Building ServiGe Building Contaminated Storage Building Table 8.3 Plant Vital AFeas Control Building ReaGtor Containment Building Auxiliary Building Intermediate Building EmergenGY Diesel Building Standby Auxiliary Feedwater Building SGreen l=Iouse

FIRE in ANY of the areas listed in Table 8.4, not extinguished within 15 minute~ of:1

.. i Control Room notification' PR

~ *. Verification of a Control Room FIRE alarm' jTable 8.4 Plant Vital and Adjacent Areas:

Intermediate Building

~

TSC Building Service Building' Contaminated Storage Building' Control Building Containment Building AuxiliarY Building' Turbine Building Diesel Generator Building(s).

I.

Standby AuxiliarY Feedwater'-B-u-il-d-in-'g

~

Screen HOuse.'

ATIACHMENT (1)

Page 1-10

NUJMARG-C Fire within protected area boundary not extingui.hed. with., 1R minutes of detection.

'NEI 99-01 Rev. 5 IC:-

'FIRE within the PROTECTED AREA not extinguished within 15 minutes of detection o EXPLOSION within the PROTECTED AREA..

FPB loss/potential loss:

N/A Mode Applicability:

All Basis:

The purpose of this EAL is to address the magnitude and extent of fires that may be potentially significant precursors to damage to safety systems. it addresses the FIRE, and not the' egradation in performance of affected systems that may result. This exc'-ludes ch itms ars fires within admninistrati9n buildings, waste basket fires, and otheFr, small1 foresF of no safety eonsequence.

As used here, detection is visual observation and reportby plant personnel or sensor alarmR indication.1 The 15 minute time period begins with a credible notification that a FIRE is occurring., or indication of a fire detection system alarm/actuation. Verification of a fire detection system'

,larm/actuation includes actions that can be taken within the control room or other nearb site'

• pecific location to ensure that it is not spurious. An alarm is assumed to be an indication of a FIRE unless it is disproved within the 15 minute period by personnel dispatched to the scene. In'

'ther words, a personnel report from the scene may be used to disprove a sensor alarm if,

'received within 15 minutes of the alarm, but shall not be required to verify the alarm.

[he intent of this 15 minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket)/

ITable 8.4 contains VITAL AEAS and buildings and areas in actual contact with or immediatelm,

'adjacent to VITAL AREAS or other significant buildings or areas. The intent of this EAL is not to, include buildings_(iLe., warehouses) or areas that are not in actual contact with or immediately,

'djacent to VITAL AREAS. This excludes FIRES within administration buildings, waste-baske, FIRES, and other small FIRES of no safety consequence. Immediately adjacent implies that ths area immediately adjacent contains or may contain equipment or cabling that could impiact'

'quipment located in VITAL AREAS or the fire could damage equipment inside VITAL AREAS;

'or that precludes access to VITAL AREAS.

'Escalation of this emergency classification level, if appropriate, would be based on EAL 8.2.2.1 PEG

Reference:

NEI 99-01 Revision 5: HU2.1 Basis Reference(s):

1.

Site Plot Plan ATTACH M ENT (1)

Page 1-11 NUMARC IC:

Fire within protected area boundary not extinguished withrn 15 minutes of detection.

NEI 99-01 Rev. 5 Ie

!

(FIRE within the PROTECTED AREA not extinguished within 15 minutes of detection on (EXPLOSION within the PROTECTED AREA.. I FPB loss/potential loss:

N/A Mode Applicability:

All Basis:

The purpose of this EAL is to address the magnitude and extent of fires that may be potentially significant precursors to damage to safety systems. lit addresses the FIRE, and not the.

~gradation in p-erformance of affected systems that may result.! This excludes such items as fires within administration buildings, waste basket fires, and other small fires of no safety consequence.

(A.s used here, detection is visual observation and:rep-ort by_p-Iant p-ersonnel or sensor alarm'

)ndication.l jfhe 15 minute time p-eriod begins with a credible notification that a FIRE is occurring.. ~

'indication of a fire detection system alarm/actuation. Verification of a fire.detection sy~

alarm/actuation includes actions that can be taken within the control room or other nearby~

§p-ecific location to ensure that it is not sp-urious. An alarm is assumed to be an indication of a'

FIRE unless it is disp-roved within the 15 minute p-eriodby p-ersonnel disp-atched to the scene. In' pther words, a p-ersonnel rep-ort from the scene may be used to disp-rove a sensor alarm if)

'received within 15 minutes of the alarm, but shall not be reguired to verify the alarm.!

jfhe intent of this 15 minute duration is to size the FIRE and to discriminate against small FIRES;

~hat are readily extinguished (e.g., smoldering waste p-ap-er basket)j jfable 8.4 contains VITAL AEAS and buildings and areas in actual contact with or immediatel~

§,gjacent to VITAL AREAS or other significant buildings or areas. The intent of this EAL is not td, include buildings (Le., warehouses) or areas that are not in actual contact with or immediatel~

§,gjacent to VITAL AREAS. This excludes FIRES within administration buildings, waste-basket

FIRES, and other small FIRES of no safety conseguence. Immediately adjacent imp-lies that the.

area immediately adjacent contains or may contain eguip-ment or cabling that could imp-act

@,guip-ment located in VITAL AREAS or the fire could damage eguip-ment inside VITAL AREAS;

or that p-recludes access to VITAL AREAS.!

[Escalation of this emergency classification level, *if aQp-rop-riate, would be based on EAL 8.2.2.1 PEG

Reference:

iNEI 99-01 Revision 5:1 HU2.1 Basis Reference(s):

1.

Site Plot Plan ATIACHMENT (1)

Page 1-11

8.0 Hazards 8.2.2 Alert 8.2 Fire or Explosion M~r^

^r

^-

'flapin ffn

ýnn nIn

ýr^

1,,klp Q ')

^r T7,kl^ Q ')Ia 6

1 A

j 1 fLI*

l-EITHER4 Y 11 rnnnA14 A IFr f

shutdewn

--OR ann~

.,dar nrk,,a-tarrn~,aJk,,nrlaJefn

~~--------

i peeFfGmaR~e Opura y cla f-I two v y

w9rd v oyo Um Tabr,.

le 8. 2 I

Plant A rang Turbine Building T-SC Building SerVice Building Coentaminated Storage Buildinvg Tablae 83 Plant Vital Areas Intermnediate Building mFonrFgery Diesel u13iding Standby Awuiliay Feedwater Building Screen House FIRE or EXPLOSION resulting in VISIBLE DAMAGE to ANY of the following.structured

'containinq safety systems or components, listed in Table 8.3, OR control room indication of deqraded performance of those safety systems:i I--

Table 8.3 Plant Vital Areas*,

Intermediate Building Control Building Containment Building Auxiliary Building p

. Diesel Generator Buildings*

ATTACHMENT (1)

Page 1-12 8.0 Hazards 8.2 Fire or Explosion 8.2.2 Alert Fire or explosion in any plant area, Table 8.2 or Table 8.3 which EITHER results in visible damage to plant equipment or structures needed for safe shutdown

-GR affects safety system operability as indicated by degraded system performance Table B.2 Plant AFeas Turbine Building TSC Building Service Building Contaminated Storage Building Table B.3 Plant Vital AFeas Control Building Reactor Containment Building Auxiliary Building Intermediate Building Emergency Diesel Building Standby Auxiliary Feedwater Building Screen House

[FIRE or EXPLOSION resulting in VISIBLE DAMAGE to ANY of the following.structure~

containing safety~ystems or comQonents, listed in Table 8.3,

'OR

~

control room indication of degraded Qerformance of those safety~ystems:1 Table 8.3 Plant Vital Areas

~.

Intermediate Building

~.

Control Building

~.

Containment Building

~.

. AuxiliarY Building l

~.

. *... D'iesel Generator BUildingJ.§1 ATTACHMENT (1)

Page 1-12

Standby Auxiliary Feedwater.Building Screen House NEI 99-01 Rev. 5 IC:

Fire or explosion affecting the operability of plant safety systems required to establish or maintain safe shutdown.

FPB loss/potential loss:

N/A Mode Applicability:

All Basis:

The listed areas contain functions and systems required for the safe shutdown of the plant. The REGNPP safe shutdown analysis was consulted for equipment and plant areas required for the applicable mode.

With regard to o.p...iOns, only those explosions of sufficiaent force to damnage permanent structuro, or equIpmet rcquired for safe operation, or which result in degraded performance ot safoty systems within the identified plant a..a. 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 nearby structures and materials. No attempt is made in this EAL to assess the actual magnitude of the damage. The wording of this EAL does not imply that an assessment of safety system performance is intended to be performed, rather that as a result of the event, safety system parameter symptoms are degraded. The declaratiAn-no an A.let and the atiation of th, TS" Will pro.ide the Ermergency Coordintor -with the resources needed to peForm damage assessm.ents. The Emr-.gency Coordinator also needs to osie an" security aspects of the explosions A steam line break that damages permanent structures or equipment would be classified under this EAL. The method of damage is not as important as the degradation of plant structures or equipment.

1YISIBLE.DAMAGE (excluding cosmetic damage:to'structures facades or windows such a lnts scrapes; broken.windows-and tears in sheet metal facades@ is used to identify

,magnituded f the FIRE or EXPLOSION and to discriminate against minor FIRESý and rEXPLOSIONS.

IThe reference to structures containingsafety ystems or comporents is included to discrimihate, against FIRES or EXPLOSIONS in areas having a low probability ',of affecting safe operation.

Thesgnificance here is not that asafetysystemwasdegraded but the fact that the FIREr

'EXPLOSION was large enough to cause damage to thesesyms The useof VISIBLE DAMAGE (excluding cosmetic damage to structures, facades, or windows,

'uch as dents, scrap es, broken windows and tears in sheet metal facades) 3Shouldnotbel interpreted as mandatinq a lengthy damage assessment prior-to classification. The declarationR ATTACHMENT (1)

Page 1-13 Ie Standby' Auxiliary: Feedwater-Building'

!. ' ',' Screen Housd, NUMARC IC:

NEI 99-01 Rev. 5 Ie:

Fire or explosion affecting the operability of plant safety systems required to establish or maintain safe shutdown.

FPB loss/potential loss:

N/A Mode Applicability:

All Basis:

The listed areas contain functions and systems required for the safe shutdown of the plant. The REGNPP safe shutdown analysis was consulted for equipment and plant areas required for the applicable mode.

VVith regard to e*plosions, only those e*plosions of sufficient force to damage permanent structures or equipment required for safe operation, or which result in degraded performance of safety systems within the identified plant areas 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 nearby structures and materials. No attempt is made in this EAL to assess the actual magnitude of the damage. The wording of this EAL does not imply that an assessment of safety system performance is intended to be performed, rather that as a result of the event, safety system parameter symptoms are degraded. The declaration of an Alert and the activation of the TSC will provide the Emergency Coordinator with the resources needed to perform damage assessments. The Emergency Coordinator also needs to consider any security aspects of the e*plosions.

A steam line break that damages permanent structures or equipment would be classified under this EAL. The method of damage is not as important as the degradation of plant structures or equipment.

~ISIBLE,DAMAGE (excluding cosmetic damage to struCtureS,facades, 'or windows such* as,

~,'scra~esi brokem:window5'andtears in'sheetmetal'faCEid~s~ 'is asedto'identify"th~

~gnitude 6f the FIRE or EXPLOSION andtodiscriniinate againstminorFIRESand

[EXPLOSIONS.!

trhe reference to structUres containing safety. sy'stems or comQonents is include,d to discriminate,'

~gainst FIRES or EXPLOSIONSin,areas having a loW i:2robability"6faffecting safe oQerationJ

~gnificance here is not that a safety. sy.stentWasdegraded but theJa'Ct thattheFIRE,on

[EXPLOSION was'large enough to cause'damage tothesesy'stems'.l jFhe use of VISIBLE DAMAGE (excluding cosmetic damage to structures', facades; orwindoviis~

~uch asdents,scraQes, broken windows and tears in sheet metal facades f shduld: [lOt be, lhterQretedas mandatihg' a ler:tgthy' damage ass'essment Qr'ickto classific'ation.,:Th'e declaration' ATIACHMENT (1)

Page 1-13

bf an Alert and the activation. of the Technical Sup'port Center will provide the EYergenCy

'Director with the resources needed to perform detailed damage aSsessments.

iTheEmergency Director also needs to consider any security aspects of the EXPLOSION.!

ITable 8.3 specdfy site specific structures'or areas'that contain safety system; or component and

[functions required for safe shutdown Of the plant. Site specific Safe Shutdown Analysis should be consulted for equipment and plant areas required to establish or maintain.safe shutd*wn.!

rEscalation of this emergency classification level7< if appropriate,will be based on System' WMalfunctions, Fission Product Barrier Degradation 'or Abnormal Rad Levels/ Radi01ogipai Effluent EALs.

PEG

Reference:

,NEI199-01 Revision 5: HA2.1 Basis Reference(s):

1.

Site Plot Plan ATTACHMENT (1)

Page 1-14 pf an Alert and the activationofthe Technical SUQQort Center will Qro'vide the Erhergenc~

[Director with the resources needed to Qerform. detailed damage.assessments.l Irhe Emergency Director also needs to consider any' security as Qectsof the EXPLOSION.!

ITable 8.3 sQecify site sQecific structures or areas that contain safet~ system; or comQonemfand Wunctions reQuired for safe shutdown of the Qlant. Site sQecific Safe Shutdown Analysis should be consulted for eQuiQment and Qlant areas reQuired to establish.or maintain.. safe shutdown.!

!Escalationof this emergency classification level,:: if aQQroQriate,wili be based on Sy~

Malfunctions, Fission Product Barrier Degradation'i:>r Abnormal Rad Levels I Radiological

[Effluent EALs'!

PEG

Reference:

[NEI99-01 Revision 5:! HA2.1 Basis Reference(s):

1.

Site Plot Plan ATIACHMENT (1)

Page 1-14

8.0

,,aZads 8.3 Mian-Made Events RUM.

UnIusual Event Ve\\u;le I

i crash into Or Fpriecti;e Which lmpacts plant structures9 or ystens-withi i2roe~etea Okrpa beuRdaFy n

N4UMARG4C-Natural and destructive phonomena affocting the protoctod area.

FPB lsslVpot*ntiaI less:

Modo Applicabilityr The Protec~te~d.AroA_ boundar,' is within the securfity isolation zone and is defined in the site Thfis EAL addr-esses, cuch itmns-am, plane, helicopter, train, bargo, car or truck cr.ash, orimac of other projectiles that may potentially damiage plant structuresconainn funct4ions andC-sys~tems6 required foFr, cafe Ish-utdown01 of the plant. If tho cras~h is cofirmod to affect a plant Vital area, the event may be escalated to Ale~t.

PEG D^r R......n.!

Bakop Roeferoncc(e):;

i.

Site Plot Plan ATTACHM ENT (1)

Page 1-15 8.0 loIazards 8.3 MaR Made EveRts Y

sl::lal Elfent 8.3.1R" t m. ";I~iR Pretested Area

.. asts plant strl::lctl::lres or sys e b 'Into or projectile V.'RISR Imp VeRlsle srasH bOl::lndary NUMARC IC:.

Ra affecting tRe protested area.

Natl::lral and destrl::lctlve pRenome FPO less/peteRtial less:

NIA Mede AppliGability:

AU TRe Protested Area bOl::ln a 1

.es"rily plaR.

trusk sra.~ er impast

. barge Gar or as plane Relisopter, train" f nctions and

. d fer sa e s 1::1 systems reql::llre I ted to Alert.

area, tRe event may be essa a PEG RefereRGe:

HY1.4 Oasis RefereRGe(s):

1.

Site Plot Plan ATIACHMENT (1)

Page i-iS

8.0 Hazards 8.3 Man-Made Events 8.3.2 Unusual Event Report by plant porsonnel of an explosion within ProetecGted Area boundanh resulting in wissible damage to permanent structures or equipment EXPLOSION within the PROTECTED AREA.

NUMARC]G--

NatuFal and destructive phenrmena affecting the protocted area.

'NEI 99-01 Rev. 5 IC:I

,HU2 - FIRE within the PROTECTED AREA not extinguished within 15 minutes of detection or EXPLOSION within the PROTECTED AREA.

FPB loss/potential loss:

N/A Mode Applicability:

All Basis:

The Protected Area boundar,' is within the security isolation zone and is defined in the Site sersupty p-n.

ForF this E=AL, onlY those explosions o-f sufcetforce to damage perm~anent stuructues or equipment within the RrPrtected Area should be considered.

suwsedhere, anexplosion isa rapid, violent, unconfine~d combustion, or a catastrophic failure of pressurized equipment, that potentially imparts significant energy to near by structur~es and mnaterials. No attempt isMade i this EAL to ases the actual magnitude of the damage. The occurrence of the expoinwt repo~rts of evidenc~e of damage (e. q., deformation, scorching) is sufficient for declAaration, The Emnergency Coordinator also needs to con~sid-er any security aspects of the explosion;.

.A.

s.teamR line break that damages permnanent structures or equipment would be classified under this E-=AL'.

This does-not include the stearImp lie reak itself. The method of damage is not as impo"tant as the degradation of plant structures or equip me This EAL addresses the magnitude and extent of EXPLOSIONS that may be potentially

_jgnificant precursors of damage to safety systems. It addresses the EXPLOSION and not th*

,e gradation in performance of affected systems that may result.

ýAs used here, detection is visual observation and report by plant personnel or sensor alarmi indication.1

.This EAL addresses only those EXPLOSIONS of sufficient force to damage permanenf

,structures or equipment within the PROTECTED AREA.!

No attempt is made to assess the actual magnitude of the damage. The occurrence of the' EXPLOSION is sufficient for declaration.!

iThe Emergency, director also needs to consider any security aspects of the EXPLOSIONi

ýEscalation of this emerqency classification level, if appropriate, would be based on EAL8.2.2.!

ATTACHMENT (1)

Page 1-16 8.0 Hazards 8.3 Man-Made Events 8.3.2 Unusual Event Report by plant peFSonnel of an explosion within Protested Area bOl::lndal)' resl::llting in visible damage to permanent strl::lctl::lres or eql::lipment (EXPLOSION within the PROTECTED AREA!

NUMARC IC:

Natl::lral and destFl::lctive phenomena affecting the protected area.

iNEI 99-01 Rev. 5IC:!

HU2 - FIRE within the PROTECTED AREA not extinguished within 15 minutes of detection on

EXPLOSION within the PROTECTED AREAl FPB loss/potential loss:

N/A Mode Applicability:

All Basis:

The Protected Area bOl::lndary is Illithin the secl::lrity isolation zone and is defined in the site secl::lrity plan.

For this EAL, only those explosions of sl::lfficient force to damage permanent strl::lctl::lres or eql::lipment within the Protected Area shol::lld be considered. As I::Ised here, an explosion is a rapid, violent, I::Inconfined combl::lstion, or a catastrophic faill::lre of pressl::lrized eql::lipment, that potentially imparts significant energy to near by strl::lctl::lres and materials. No attempt is made in this EAL to assess the actl::lal magnitl::lde of the damage. The occl::lrrence of the explosion Illith reports of evidence of damage (e. g., deformation, scorching) is sl::lfficient for declaration. The Emergency Coordinator also needs to consider any secl::lrity aspects of the explosion.

A steam line break that damages permanent strl::lctl::lres or eql::lipment I.... ol::lld be classified I::Inder this EAL. This does not incll::lde the steam line break itself. The method of damage is not as important as the degradation of plant stFl::lotl::lres or eql::lipment.

jThis EAL addresses the magnitude and extent of EXPLOSIONS that may be p-otentiall~

~gnificant p-recursors of damage to safety systems. It addresses the EXPLOSION,and not the:

~gradationin p-erformance of affected systems that may res u 1t.1

\\A.s used here, detection is visual observation and rep-ort by_p-Iant p-ersonnel or sensor alarml

indication.1 jThis EAL addresses only those EXPLOSIONS of sufficient force to damag~p-ermanent

structures or eguip-ment within the PROTECTED AREAl

!No attemp-t is made to assess the actual magnitude of the damage. The occurrence of the, (EXPLOSION is sufficient for declaration.!

jThe Emergency director also needs to consider any security asp-ects of the EXPLOSION,~

gp-p-licable.l

[Escalation* of this emergency classification level, if ap-p-rop-riate, would be based on EAL 8.2.2.1 ATIACHMENT (1)

Page 1-16

PEG

Reference:

NEI 99-01 Revision 5:

U2 Basis Reference(s):

1.

Site Plot Plan ATTACHMENT (1)

Page 1-17 PEG

Reference:

!NEI 99-01 Revision 5:1 HU1.5 HU2.2 Basis Reference(s):

1.

Site Plot Plan ATTACHMENT (1)

Page 1-17

8.0 Hazards 8.3.3 Unusual Event 8.3 Man-Made Events

+/-L..~.

IJ

.1......

L

.L.......J.

LL~..... J.L...

R-poR or eTecTIonR OT tVxic or Tlnmmble q*e5 tnhat culd enteFr r n9FHave enteroe WIArnn tne PrFtected. A rpea bound-al,' in amounts that u,I-affec-t the health of plant peronnel or cafe plaRt Report by local, county Or state officials for potential eyacuation of site personnel based en effi;e-evPup Tojxi, corrosive, asphyxiant or flammable gases in amounts that have or could adversely affect

,NORMAL PLANT OPERATIONS

ObR,

,Report by local, county or state officials for evacuation or sheltering of site personnel based or an off-site event.

NUMARG4t~

Release of toxicr-or fl-ammable gases dee~med-detrim~ental to safe operation of the plat

'NEI 99-01 Rev. 5 IC" rHU3 - Release of toxic. corrosive. asDhvxiant, or flammable aases deemed detrimental td

'NORMAL PLANT OPERATIONS.!

FPB loss/potential loss:

N/A Mode Applicability:

All Basis:

This EA I

i based On releases in Gcocentration s1WI w ithi imn te sie budy that will affect 1

i J

Ie health of plant personn-1el r affec-ting the safe operation of the plant with the plant being within the evacuatfion. _area of an offsite event (i. e., tanke-r truck acc~ident releasing toxic g-ases, etc.) -

The evacuation area is as determnined_ fromn the DOT Eivacuation Tables for Selected Hazardouws Materials, in the DOT mFergency Response GuideforHazardous Materials.

if a spill/leak is-determined to be a "mnajor spill" by 11P ENV 3 criteria, classific~ation under this EAL would be aPepprprate.

Should an eXPloi8Gon occu'r within a specified plant area, an Alert would be declared based On EAL 8.v2.2.-

ll~

l*

i v

jThis EAL is based on the release of toxic, corrosive, asphyxiant or flammable gases of sufficient

• uantity to affect NORMAL PLANT OPERATIONS.!

IThe fact that SCBA may be worn does not eliminate the need to declare the event.!

This EAL is not intended to require significant assessment or quantification. It assumes an

,uncontrolled process that has the potential to affect plant operations. This would preclude small or incidental releases, or releases that do not impact structures needed for plant operation. This-.

ATTACHMENT (1)

Page 1-18 8.0 Hazards 8.3 Man-Made Events 8.3.3 Unusual Event Report or detection of toxio or flammable gases that Gould enter or have entered within the Proteoted Area boundary in amounts that Gould affeot the health of plant personnel or safe plant operation

-GR Report by looal, oounty or state offioials for potential evaouation of site personnel based on offsite e\\!ent

~,

corrosive, aSQhy'xiant or flammable gases in amounts that have or could adversely' affect iNORMALPLANT OPERATIONs'

'OR

~

~~YJ~.~.L county. or state officials for evacuation or sheltering of site QersonnelbasedOn

~an off-site event.i NUMARC IC:

Release of toxic or flammable gases deemed detrimental to safe operation of the plant.

iNEI 99-01 Rev. 5 IC~

HU3 - Release of toxic, corrosive, aSQhy'xiant, or flammable gases deemed detrimental td,

NORMAL PLANT OPERA TIONS.I FPB loss/potential loss

N/A Mode Applicability:

All Basis:

This EAL is based on releases in oonoentrations within the site boundary that will affect the health of plant personnel or affeoting the safe operation of the plant '.vith the plant being within the evaouation area of an offsite event (i. e., tanker truok aooident releasing toxic gases, eto.).

The evaouation area is as determined from the DOT Evaouation Tables for Selected Hazardous Materials, in the DOT Emergenoy Response Guide for Hazardous Materials.

If a spill/leak is determined to be a "major spill" by IP ENV d oriteria, olassifioation under this EAL would be appropriate.

Should an explosion ooour within a speoified plant area, an Alert.. '.. ould be deolared based on EAL 8.2.2.

IThis EAL is based on the release of toxic, corrosive, aSQhy'xiant or flammable gases of sufficient Quantity' to affect NORMAL PLANT OPERA TIONS.i jThe fact that SCBA may' be worn does not eliminate the need to declare the event.1 jThis EAL is not intended to reguire significant assessment or guantification. It assumes an

uncontrolled Qrocess that has the Qotential to affect Qlant oQerations. This would QreClude small br incidental releases,* or releases that do not imQact structures. needed for Ql'ant oQeration. This~

ATIACHMENT (1)

Page 1-18

,could bebased upon documented analysis, indication of personal ill effects from exposure_,

o

• perating experience with the hazards!

jAn asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels.

Most commony, a__sshyxiantswork by mere_ yssplacing air in. an enclosed environment. This

'reduces the concentration of oxygen below the normal level of aroundf19%; which can% lead to breathing difficulties, unconsciousnessor even'death.!

tEscalation of this emeraencv classification level" if appropriaite, would be based on EAL8:3.5.!

PEG

Reference:

[NEI 99-01 Revision 5:1 HU3.1 NEI 99-01 Revision 5: HU3.2 Basis Reference(s):

1. IP lNV 3, Re, ATTACHMENT (1) 6pense to a Spill of Hazardous Material or Waste Page 1-19

Could be 'based up-on documentedanaly-sis, indication of p-ersorial ill effects from exp-osure;...Q!]

Qp-erating exp-erience with the hazards.!

~i1 as~h~xiant is a gas cap-a ole of reducing the level ofox~genin the bodY-' to dangerous levels.!

Mostcomtn6nl~,* asp-h~xiar'itswork by-merely-.disp-Iacing air in an enClosed environment. ThiS,

'reduces the concentration ofoxy'gen'below the nornial level 6faround.,1.9%;,which cc:mleadtd, breathing difficulties, unconseiousnessor even death.!

[Escalation of this eniergenc~ classification.Ievel;'if,ap-p-roi2riate; would bebased6n\\EAl::8:3.5.!

PEG

Reference:

[NEI,99-01 Revision 5:1 HU3.1

!NEr 99.:01 Revision 5:1 HU3.2 Basis Reference(s):

1. IP EN" a, Response to a Spill of l=Iazardous Material or Waste INonE~

ATTACHMENT (1)

Page 1-19

8.0 Hazards 8.3 8.3.4 Alert Man-Made Events I *.r.rntn*

Fi plat *t-;;

imip= Inhhir R I

Table 8.3 Plant Vital Areas Control Building Reaete* Containment Building 0

Auxiliary Building Intermediate Building Emergency Diesel Building(s)

Standby Auxiliary Feedwater Building Screen House iVehicle crash resulting in VISIBLE DAMAGE to:j ANY of the structures containing safety systems or components, listed in Table 8.3

'ontrol room indication of deqraded performance of those safety systems' K"

URARG4C NatUiml amd dper, tir~dKe 1henomona affectORGI the plant vital area NEI 99-01 Rev. 5 IC:-

l

[Natural or destructive phenomena affecting VITAL AREAS.

FPB loss/potential loss:

N/A Mode Applicability:

All Basis:

i I*

I I I

I la I

my! hm~!r~ rr'~tiJItt~d in m nun? '~'itmI mini r~ino ~iThir~rtr~r1 to J..-..-.---...-I-.--

forces beyond design limits, and thus damage mnay be accumed to have occurred to plant roafety systemsr. The initial report should not be interpreted as mandating a lengthy damage assessmentpirt lsiiain No attempt is made in this, EAL to assess the actua mnitude of the dama ge.

T-hie EA*L addresses such items as plane, heOl;cptc-, tra-i, barge,,c-r o-r truc crah,- o impact Of nF-qjeti~es*;* tIeo

a÷,

t vital a;ea

,Ir-.'

ATTACHMENT (1)

Page 1-20 8.0 Hazards 8.3 Man-Made Events 8.3.4 Alert Vehicle crash or projectile impact '.vhich precludes personnel access to or damages equipment in plant vital areas, Table 8.a Table 8.3 Plant Vital Areas Control Building Reactor Containment Building Auxiliary Building Intermediate Building Emergency Diesel Building~

Standby Auxiliary Feedwater Building Screen House

~ehicle crash resulting in VISIBLE DAMAGE to:1

~NY of the structures containing safety~ystems or comQonents, listed in Table 8.3;

'OR

~

pontrol room indication of degraded Qerformance of those safety~ystem~

NUMARC IC:

Natural and destructive phenomena affecting the plant vital area.

NEI 99-01 Rev. 5 Ie::

Natural or destructive Qhenomena affecting VITAL AREAS.I FPB loss/potential loss:

N/A Mode Applicability:

All Basis:

This EAL addresses 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 prior to classification. ()Jo attempt is made in this EAL to assess the actual magnitude of the damage.

This EAL addresses such items as plane, helicopter, train, barge, car or truck crash, or impact of projectiles into a plant vital area.

ATIACHMENT (1)

Page 1-20

[This EAL addresses the occurrence of an event that has resulted in VISIBLE DAMAGE (excluding cosmetic damage to structures, facades, or windows such as dents, scrapes, broken

'Windows and tears in sheet metal facades) to plant structures or areas containing equipmenf necessary for a safe shutdown, or has caused damage to the safety systems in those structures evidenced by control room indications of degraded system response or performance. Thd

'occurrence of VISIBLE DAMAGE (excluding cosmetic damage to structures, facades, or

'windows such as dents, scrapes, broken windows and tears in sheet metal facades) and/oj ddegraded system response is intended to discriminate against lesser events. The initial repor' 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 significanc6 here is not that a particular system or structure was damaged, but rather, that the event was of

• ufficient magnitude to cause this deg.radation.

ITable 8.3 specifies the Ginna structures or areas that contain safety system, or component and

'unctions required for safe shutdown of the plant and are based on the Ginna Safe Shutdown'

'Analysis.I PEG

Reference:

,NEI 99-01 Revision 5: HA1.5 Basis Reference(s):

None ATTACHMENT (1)

Page 1-21

[his EAL addresses the occurrence of an event that has resulted in VISIBLE DAMAGB

~(excluding cosmeticdarnage to structures, facades, or windows such as dents, scrap-es, broken' windows and tears in sheet metal facades) to p-Iant structures or areas containing eguip-ment

'necessa!y for a safe shutdown, or has caused damage to the safety systems in those structure~

evidenced by control room indications of degraded system resp-onse or p-erformance. The,

occurrence of VISIBLE DAMAGE (excluding cosmetic damage to structures, facades,~

windows such as dents, scrap-es, broken windows and tears in sheet metal facades) and/orl

~graded system resp-onse is intended to discriminate against less,er events. The initial rep-ort

should not be interp-reted as mandating a lengthy damage assessment p-rior to classification. Nd,

~p-t is made in this EAL to assess the actual magnitude of the damage. The significance, here is not that a p-articular system or structure was damaged, but rather, that the event was o~

~ufficient magnitude to cause this degradation.!

jfable 8.3sp-ecifies the Ginna structures or areas that contain safety system, or comp-onent and

~unctions reguiredfor safe shutdown of the p-Iant and are based on the Ginna Safe Shutdown'

~naly:§liJ PEG

Reference:

[NEI 99-01 Revision 5:1 HA 1.5 Basis Reference(s):

None ATTACHMENT (1)

Page 1-21

8.0 Hazards 8.3.5 Alert 8.3 Man-Made Events t~~~~ooort

~

~

~

~

I:I or aefn:1oi o amoeac~winn~un iai

~ i~i i

I concentrationc that will be Upte threatening to plant pe69reonOl o precludie accece to equipment needed for safe plant operation Tr-ki- 0 '1 01-

'1.+-1 A-Control Building interm~ediato Building EmFergency Dicese Building A*

II A

'1" Standby Auxla; i-eeawVer ii ding S creen House Access to a VITAL AREA listed in Table 8.3 is prohibited due to toxic, corrosive, asphyxiant orm flammable qases which ieopardize operation of systems required to maintain safe operations or

'safely shutdown the reactor.!

Table 8.3 Plant Vital Areas, Control Building Containment Building' Auxiliary Building I*

Intermediate Building Diesel Generator Building.(s)1 Standby Auxiliary FeedwaterBuilding' Screen Houser ATTACHMENT (1)

Page 1-22 8.0 Hazards 8.3 Man-Made Events 8.3.5 Alert Report or detection of toxic or flammable gases '.vithin a plant vital area, Table 8.3, in concentrations that will be life threatening to plant personnel or preclude access to equipment needed for safe plant operation Table 8.3 Plant Vital Areas Control Building Reactor Containment Building Auxiliary Building Intermediate Building Emergency Diesel Building Standey Auxiliary f:eedwater Building Screen House

~ccess to a VITAL AREA listed in Table 8.3 is I2rohibited due to toxic, corrosive, aSl2h~xiant on

~Iammable gases which jeol2ardize ol2eration of s~stems reguired to maintain safe ol2erations on

~afel~ shutdown the reactor.!

l Table 8.3 Plant Vital Areas I.

- I I

Control Building I.,

Containment Building I.

I Auxiliary Building I.

I Intermediate Building I.

I

-Diesel-Generator Building-<~~

I.

I Standb~Auxiliary Feedwater BUilding I.

I Screen Housd ATIACHMENT (1)

Page 1-22

Release of toxi or flammablo gases within a facility ctructuro which jeopardizes operation of syste ms roquirod to maintain safe operations Or to establish or maintain cold shutdown

ýNEI 99-01 Rev. 5 IC:-

'Access to a VITAL AREA is prohibited due to release of toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of systems required to maintain safe operations or' a~fely shutdown the reactor.!

FPB loss/potential loss:

N/A Mode Applicability:

All Basis:

T-his RALIs based on gases, that have entered a plant Structure precluding access to equipment necessary for the safe operation of the plant. This EAL applies to buildings and aroas contiguous to plant vital areas or other significant buildings or areas. The ntn of this EAL is not to-i~ncludo buildings (i. e., warehouses) or other areac that are not contgWuou OrFmeitl ad~jacent to plant vital areas. it is appropriate that inrGeased mRonitoring be don~e to ascc~taqn whether consequential damage has occurred.

,Gases in a VITAL AREA can affect the ability to safely operate or safely shutdown thereco.

IThe fact that SCBA may be worn does not eliminate the need to declare the event.

Declaration should not be delayed for confirmation from atmospheric testing if the atmospherd 1poses an immediate threat to life and health or an immediate threat of severe exposure to bases. This could be based upon documented analysis, indication of personal ill effects from,

'eposure, or o peratin g experience with the hazards.

If the equipment in the stated area was already inoperable, or out of service, before the event'.

d, then this EAL should not be declared as it will have no adverse impact on the ability of sfhe pnt to safely operate or safely shutdown beyond that already allowed by Technical pecifications at the time of the event.!

neasphyaioant is a gas capable of reducin the level of oxygen in the body o dangerous level Most commonly,das phyxiants work by merely displacing air in an enclosed environment. Thio' reduces the concentration of oxygen below the normal level of around 19% which can lead t breathing, difficulties, unconsciousness or even death.

'An uncontrolled release of flammable gasses within a facilit structure has the potential to affeof

ý operation of the plant by imiting ither operator or eqip ment operations due b

tothe potential for ignition and resultinghequipment damage/personnel injury. Flammable gAsses, nasphyarogen and acetylene, are routinely used to maintain plant sstems (ydrogenro e

pMost/components (acetylene - used in welding). This EAL assumes concentrations oT

'flammable gasses which can ignite/suppor obsin Escaeltn of this emergency classification level if app op

riate, will be based on Sylte Malfunctions, Fission Product Barrier Degradation or Abnormal Rad Levels / Radioactiv Effluent EALs.

ATTACHMENT (1)

Page 1-23 NUMARC IC:

Release of toxic or flammable gases within a facility structure which jeopardizes operation of systems required to maintain safe operations or to establish or maintain cold shutdown.

lNEI 99-01 Rev. 5 Ie:!

It\\ccess to a VITAL AREA is ~rohibited due to release of toxic, corrosive, as~h~xiant on flammable gases which jeo~ardize o~eration of systems reguired to maintain safe o~erations on

safel~ shutdown the reactor'!

FPB loss/potential loss:

N/A Mode Applicability:

All Basis:

This EAL is based on gases that have entered a plant structure precluding access to equipment necessary for the safe operation of the plant. This EAL applies to buildings and areas contiguous to plant vital areas or other significant buildings or areas. The intent of this EAL is not to inch:::lde buildings (i. e., warehouses) or other areas that are not contiguous or immediately adjacent to plant vital areas. It is appropriate that increased monitoring be done to ascertain

'Nhether consequential damage has occurred.

Gases in a VITAL AREA can affect the abilit~ to safel~ o~erate or safel~ shutdown the reactor.!

jfhe fact that SCBA ma~ be worn does not eliminate the need to declare the event.!

Declaration should not be delayed for confirmation from atmospheric testing if the atmosphere'

'poses an immediate threat to life and health or an immediate threat of severe exposure td

~ases. This could be based upon documented analysis, indication of ~ersonal ill effects fr~

~~osure, or o~erating ex~erience with the hazards.1 Ilf the equipment in the stated area was already inoperable, or out of service, before the eventi

,occurred, then this EAL should not be declared as it will have no adverse impact on the ~y~

~he plant to safely operate or safely shutdown be~ond that alread~ allowed b~ Technical Specifications at the time of the event.

~Qhyxiant is a g~~able of reduL--c-:-i n-g--:7th-e--:l:-ev-e--:l-o-=f-o-x-~g-e-n--:-in-tC:-h-e-=-b-o-d:-~-:-t-o-d:-a-n-g-e-ro-u-s-=-Ie-v-e-=-Is-'.

Most commonly, as~h~xiants work b~ merel~ dis~lacing air in an enclosed environment. Thi~

'reduces the concentration of ox~gen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.!

~n uncontrolled release of flammable gasses within a facilit~ structure has the ~otential to affect

safe o~eration of the ~Iant b~ limiting either o~erator or egui~ment o~erations due to the.

. ~otential for ignition and resulting egui~ment damage/~ersonnel injury. Flammable gasses,~

~~drogen and acet~lene, are routinel~ used to maintain ~Iant s~stems (h~drogen) or to re~ai~

~ui~menUcom~onents (acetylene - used in welding). This EAL assumes concentrations o~

flammable gasses which can ignite/su~~ort combustion.!

iEscalation of this emergency classification level, if a~~ro~riate, will be based on S~stem' Malfunctions, Fission Product Barrier Degradation or Abnormal Rad Levels I Radioactive:

Effluent EALs.!

ATIACHMENT (1)

Page 1-23

PEG

Reference:

NEI 99-01 Revision 5:1 HA3.1 HA3.2 Basis Reference(s):

None ATTACHMENT (1)

Page 1-24 PEG

Reference:

NEI 99-01 Revision 5:1 HA3.1

~

Basis Reference(s):

None ATIACHMENT (1)

Page 1-24

ATTACHMENT (2)

Clean Copy of the Proposed Ginna EAL Technical Basis Document R.E. Ginna Nuclear Power Plant, LLC November 30, 2009 ATTACHMENT (2)

Clean Copy of the Proposed Ginna EAL Technical Basis Document R.E. Ginna Nuclear Power Plant, LLC November 30,2009

7.0 Equipment Failures 7.3 Loss of Indications /Alarms /

Communication Capability 7.3.1 Unusual Event Unplanned loss of the following for 15 minutes or longer:

6 or more Control Room Annunciators listed in Table 7.3 OR An approximate 75% reduction in Control Room safety system indications I Table 7.3 Control Room Annunciator Panels A

AA B

C D

E F

G NEI 99-01 Rev. 5 IC:

Unplanned loss of safety system annunciation or indication in the control room for 15 minutes or longer.

FPB loss/potential loss:

N/A Mode Applicability:

1-Power operations, 2-startup, 3-hot shutdown, 4-hot standby Basis:

Note: The Emergency Director should not wait until the applicable time has elapsed, but should likely declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.

This EAL recognizes the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment. Recognition of the availability of computer based indication equipment is considered (PPCS and SAS).

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

Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indications are lost, there is an increased risk that a degraded plant condition could go undetected.

It is not intended that plant personnel perform a detailed count of the instrumentation lost but the use of judgment by the Shift Manager as the threshold for determining the severity of the plant conditions.

75% of lost annunciators is defined as loss of 6 of the 8 annunciator panels listed on Table 7.3.

Loss of 75% of Control Room safety indications is loss of 75% of the indicators on the center and left sections of the main control board indications.

ATTACHMENT (2)

Page 2-1 7.0 Equipment Failures 7.3.1 Unusual Event 7.3 Loss of Indications /Alarms /

Communication Capability Unplanned loss of the following for 15 minutes or longer:

6 or more Control Room Annunciators listed in Table 7.3 OR An approximate 75% reduction in Control Room safety system indications NEI 99-01 Rev. 5 IC:

Unplanned loss of safety system annunciation or indication in the control room for 15 minutes or longer.

FPB loss/potential loss:

N/A Mode Applicability:

1-Power operations, 2-startup, 3-hot shutdown, 4-hot standby Basis:

Note: The Emergency Director should not wait until the applicable time has elapsed, but should likely declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.

This EAL recognizes the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment Recognition of the availability of computer based indication equipment is considered (PPCS and SAS).

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

Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indications are lost, there is an increased risk that a degraded plant condition could go undetected.

It is not intended that plant personnel perform a detailed count of the instrumentation lost but the use of judgment by the Shift Manager as the threshold for determining the severity of the plant conditions.

75% of lost annunciators is defined as loss of 6 of the 8 annunciator panels listed on Table 7.3.

Loss of 75% of Control Room safety indications is loss of 75% of the indicators on the center and left sections of the main control board indications.

ATIACHMENT (2)

Page 2-1

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptable power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by their specific Technical Specification.

The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10CFR50.72. If the shutdown is not in compliance with the Technical Specification action, the Unusual Event is based on EAL 7.1.1, Inability to Reach Required Shutdown Within Technical Specification Limits.

Annunciators or indicators for this EAL must include those identified in the Abnormal Operating procedures, in the Emergency Operating Procedures, and in other EALs (e.g., area, process, and/or effluent rad monitors, etc.).

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

Due to the limited number of safety systems in operation in cold shutdown, refueling, and defueled modes, this EAL is not applicable during these modes of operation.

This Unusual Event will be escalated to an Alert based on a concurrent loss of compensatory indications or if a SIGNIFICANT TRANSIENT is in progress during the loss of annunciation or indication.

PEG Reference NEI 99-01 Revision 5: SU3.1 Basis Reference(s):

None AT'ACHM ENT (2)

Page 2-2 It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptable power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment cif plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by their specific Technical Specification.

The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10CFR50.72. If the shutdown is not in compliance with the Technical Specification action, the Unusual Event is based on EAL 7.1.1, Inability to Reach Required Shutdown Within Technical Specification Limits.

Annunciators or indicators for this EAL must include those identified in the Abnormal Operating procedures, in the Emergency Operating Procedures, and in other EALs(e.g., area, process, and/or effluent rad monitors, etc.}.

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

Due to the limited number of safety systems in operation in cold shutdown, refueling, and defueled modes, this EAL is not applicable during these modes of operation.

This Unusual Event will be escalated to an Alert based on a concurrent loss of compensatory indications or if a SIGNIFICANT TRANSIENT is in progress during the loss of annunciation or indication.

PEG Reference NEI 99-01 Revision 5: SU3.1 Basis Reference(s):

None ATIACHMENT (2)

Page 2-2

7.0 Equipment Failures 7.3 Loss of Indications /Alarms I Communication Capability 7.3.3 Alert Unplanned loss of the following for 15 minutes or longer:

6 or more Control Room Annunciators listed in Table 7.3 OR An approximate 75% reduction in Control Room safety system indications AND EITHER A SIGNIFICANT TRANSIENT is in progress OR Compensatory indications are unavailable Table 7.3 Control Room Annunciator Panels A

AA B

C D

E F

G NEI 99-01 Rev. 5 IC:

Unplanned loss of safety system annunciation or indication in the control room with either (1) a SIGNIFICANT TRANSIENT in progress, or (2) compensatory indicators unavailable.

FPB loss/potential loss:

N/A Mode Applicability:

1-Power operations, 2-startup, 3-hot shutdown, 4-hot standby Basis:

Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.

This EAL recognizes the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment during a SIGNIFICANT TRANSIENT. Recognition of the availability of computer based indication equipment is considered (PPCS, SAS, etc.).

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

Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions. It is also not intended that the Shift Manager be tasked with making a judgment decision as to whether additional personnel are required to provide increased monitoring of system operation. 75% of lost annunciators is defined as loss of 6 of the 8 ATTACHMENT (2)

Page 2-3 7.0 Equipment Failures 7.3.3 Alert 7.3 Loss of Indications /Alarms /

Communication Capability Unplanned loss of the following for 15 minutes or longer:

6 or more Control Room Annunciators listed in Table 7.3 OR An approximate 75% reduction in Control Room safety system indications AND EITHER A SIGNIFICANT TRANSIENT is in progress OR Compensatory indications are unavailable NE199-01 Rev. 51C:

Unplanned loss of safety system annunciation or indication in the control room with either (1) a SIGNIFICANT TRANSIENT in progress, or (2) compensatory indicators unavailable.

FPB loss/potential loss:

N/A Mode Applicability:

1-Power operations, 2-startup, 3-hot shutdown, 4-hot standby Basis:

Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.

This EAL recognizes the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment during a SIGNIFICANT TRANSIENT. Recognition of the availability of computer based indication equipment is considered (PPCS, SAS, etc.).

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

Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions. It is also not intended that the Shift Manager be tasked with making a judgment decision as to whether additional personnel are required to provide increased monitoring of system operation. 75% of lost annunciators is defined as loss of 6 of the 8 ATTACHMENT (2)

Page 2-3

annunciator panels listed on Table 7.3. Loss of 75% of Control Room safety indications is loss of 75% of the indicators on the center and left sections of the main control board indications.

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptable power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification.

The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 1 OCFR50.72. If the shutdown is not in compliance with the Technical Specification action, the UE is based on EAL 7.1.1 "Plant is not brought to required operating mode within Technical Specification LCO Required Action Completion Time."

Annunciators or indicators for this EAL should be limited to those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e. g., area, process, and/or effluent rad monitors, etc.).

"Compensatory indications" in this context includes computer based information such as PPCS and SAS If both a major portion of the annunciation system and all computer monitoring are unavailable, the Alert is required.

SIGNIFICANT TRANSIENT: An UNPLANNED event involving one or more of the following: (1) automatic turbine runback greater than 25% thermal reactor power, (2) electrical load rejection greater than 25% full electrical load, (3) Reactor Trip, (4) Safety Injection Activation, or (5) thermal power oscillations greater than 10% of rated thermal power.

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

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

This Alert will be escalated to a Site Area Emergency if the operating crew cannot monitor the transient in progress due to a concurrent loss of compensatory indications with a SIGNIFICANT TRANSIENT in progress during the loss of annunciation or indication.

PEG

Reference:

NEI 99-01 Revision 5: SA4.1 Basis Reference(s):

None ATTACHMENT (2)

Page 2-4 annunciator panels listed on Table 7.3. Loss of 75% of Control Room safety indications is loss of 75% of the indicators on the center and left sections of the main control board indications.

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptable power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indica.tors should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification.

The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10CFR50.72.lfthe shutdown is not in compliance with the Technical Specification action, the UE is based on EAL 7.1.1 "Plant is not brought to required operating mode within Technical Specification LCO Required Action Completion Time."

Annunciators or indicators for this EAL should be limited to those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e. g., area, process, and/or effluent rad monitors, etc.).

"Compensatory indications" in this context includes computer based information such as PPCS and SAS If both a major portion of the annunciation system and all computer monitoring are unavailable, the Alert is required.

SIGNIFICANT TRANSIENT: An UNPLANNED event involving one or more of the following: (1) automatic turbine runback greater than 25% thermal reactor power, (2) electrical load rejection greater than 25% full electrical load, (3) Reactor Trip, (4) Safety Injection Activation, or (5) thermal power oscillations greater than 10% of rated thermal power.

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

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

This Alert will be escalated to a Site Area Emergency if the operating crew cannot monitor the transient in progress due to a concurrent loss of compensatory indications with a SIGNIFICANT TRANSIENT in progress during the loss of annunciation or indication.

PEG

Reference:

NEI 99-01 Revision 5: SA4.1 Basis Reference(s):

None ATIACHMENT (2)

Page 2-4

7.0 Equipment Failures 7.3 Loss of Indications /Alarms /

Communication Capability 7.3.4 Site Area Emergency Loss of the following for 15 minutes or longer:

6 or more Control Room Annunciator Panels listed in Table 7.3 OR An approximate 75% reduction in Control Room safety indications AND A SIGNIFICANT TRANSIENT is in progress.

AND Compensatory indications are unavailable.

Table 7.3 Control Room Annunciator Panels A

AA B

C D

E F

G NEI 99-01 Rev. 5 IC:

Inability to monitor a SIGNIFICANT TRANSIENT in progress.

FPB loss/potential loss:

N/A Mode Applicability:

1-Power operations, 2-startup, 3-hot shutdown, 4-hot standby Basis:

Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.

This EAL recognizes the inability of the Control Room staff to monitor the plant response to a SIGNIFICANT TRANSIENT.

"Planned" and "UNPLANNED" actions are not differentiated since the loss of instrumentation of this magnitude is of such significance during a transient that the cause of the loss is not an ameliorating factor.

Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions. It is also not intended that the Shift Manager be tasked with making a judgment decision as to whether additional personnel are required to provide increased monitoring of system operation. 75% of lost annunciators is defined as loss of 6 of the 8 annunciator panels listed on Table 7.3. Loss of 75% of Control Room safety indications is loss of 75% of the indicators on the center and left sections of the main control board indications.

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of ATTACHMENT (2)

Page 2-5 7.0 Equipment Failures 7.3 7.3.4 Site Area Emergency Loss of the following for 15 minutes or longer:

Loss of Indications /Alarms /

Communication Capability 6 or more Control Room Annunciator Panels listed in Table 7.3 OR An approximate 75% reduction in Control Room safety indications AND A SIGNIFICANT TRANSIENT is in progress.

AND Compensatory indications are unavailable.

NEI 99-01 Rev. 5 IC:

Inability to monitor a SIGNIFICANT TRANSIENT in progress.

FPB loss/potential loss:

N/A Mode Applicability:

1-Power operations, 2-startup, 3-hot shutdown, 4-hot standby Basis:

Note: The Emergency Director should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time.

This EAL recognizes the inability of the Control Room st~ff to monitor the plant response to a SIGNIFICANT TRANSIENT.

"Planned" and "UNPLANNED" actions are not differentiated since the loss of instrumentatiori of this magnitude is of such significance during a transient that the cause of the loss is not an ameliorating factor.

Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions. It is also not intended that the Shift Manager be tasked with making a judgment decision as to whether additional personnel are required to provide increased monitoring of system operation. 75% of lost annunciators is defined as loss of 6 of the 8 annunciator panels listed on Table 7.3. Loss of 75% of Control Room safety indications is loss of 75% of the indicators on the center and left sections of the main control board indications.

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of ATTACHMENT (2)

Page 2-5

annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification.

The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action, the UE is based on EAL 7.1.1 "Plant is not brought to required operating mode within Technical Specification LCO Required Action Completion Time."

A Site Area Emergency is considered to exist if the Control Room staff cannot monitor safety functions needed for protection of the public.

Annunciators for this EAL should be limited to include those identified in the Abnormal Operating Procedures, in the CSFST's and Emergency Operating Procedures, and in other EALs (e. g., rad monitors, etc.).

SIGNIFICANT TRANSIENT: An UNPLANNED event involving one or more of the following: (1) automatic turbine runback greater than 25% thermal reactor power, (2) electrical load rejection greater than 25% full electrical load, (3) Reactor Trip, (4) Safety Injection Activation, or (5) thermal power oscillations greater than 10% of rated thermal power.

Indications needed to monitor critical safety functions necessary for protection of the public must include Control Room indications, computer generated indications and dedicated annunciation capability. The specific indications should be those used to determine such functions as the ability to shut down the reactor, maintain the core cooled and in a coolable geometry, to remove heat from the core, to maintain the reactor coolant system intact, and to maintain containment intact.

"Compensatory indications" in this context includes computer based information such as PPCS and SAS.

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 EAL is indicated during these modes of operation.

PEG

Reference:

NEI 99-01 Revision 5: SS6.1 Basis Reference(s):

None ATTACHMENT (2)

Page 2-6 annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification.

The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action, the UE is based on EAL 7.1.1 "Plant is not brought to required operating mode within Technical Specification LCO Required Action Completion Time."

A Site Area Emergency is considered to exist if the Control Room staff cannot monitor safety functions needed for protection of the public.

Annunciators for this EAL should be limited to include those identified in the Abnormal Operating Procedures, in the CSFST's and Emergency Operating Procedures, and in other EALs (e. g., rad monitors, etc.).

SIGNIFICANT TRANSIENT: An UNPLANNED event involving one or more of the following: (1) automatic turbine runback greater than 25% thermal reactor power, (2) electrical load rejection greater than 25% full electrical load, (3) Reactor Trip, (4) Safety Injection Activation, or (5) thermal power oscillations greater than 10% of rated thermal power.

Indications needed to monitor critical safety functions necessary for protection of the public must include Control Room indications, computer generated indications and dedicated annunciation capability. The specific indications should be those used to determine such functions as the.

ability to shut down the reactor, maintain the core cooled and in a coolable geometry, to remove heat from the core, to maintain the reactor coolant system intact, and to maintain containment intact.

"Compensatory indications" in this context includes computer based information such as PPCS and SAS.

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 EAL is indicated during these modes of operation.

PEG

Reference:

NEI 99-01 Revision 5: SS6.1 Basis Reference(s):

None ATTACHMENT (2)

Page 2-6

8.0 Hazards 8.2 Fire or Explosion 8.2.1 Unusual Event FIRE in ANY of the areas listed in Table 8.4, not extinguished within 15 minutes of:

Control Room notification OR Verification of a Control Room FIRE alarm Table 8.4 Plant Vital and Adjacent Areas 0

Intermediate Building TSC Building 0

Service Building Contaminated Storage Building Control Building Containment Building Auxiliary Building Turbine Building Diesel Generator Building(s)

Standby Auxiliary Feedwater Building Screen House NEI 99-01 Rev. 5 IC:

FIRE within the PROTECTED AREA not extinguished within 15 minutes of detection or EXPLOSION within the PROTECTED AREA.

FPB loss/potential loss:

N/A Mode Applicability:

All Basis:

The purpose of this EAL is to address the magnitude and extent of fires that may be potentially significant precursors to damage to safety systems. It addresses the FIRE, and not the degradation in performance of affected systems that may result.

As used here, detection is visual observation and report by plant personnel or sensor alarm indication.

The 15 minute time period begins with a credible notification that a FIRE is occurring, or indication of a fire detection system alarm/actuation. Verification of a fire detection system alarm/actuation includes actions that can be taken within the control room or other nearby site specific location to ensure that it is not spurious. An alarm is assumed to be an indication of a FIRE unless it is disproved within the 15 minute period by personnel dispatched to the scene. In ATTACHMENT (2)

Page 2-7 8.0 Hazards 8.2 Fire or Explosion 8.2.1 Unusual Event FIRE in ANY of the areas listed in Table 8.4, not extinguished within 15 minutes of:

Control Room notification OR Verification of a Control Room FIRE alarm Table 8.4 Plant Vital and Adjacent Areas Intermediate Building TSC Building Service Building Contaminated Storage Building Control Building Containment Building Auxiliary Building Turbine Building Diesel Generator Building(s)

Standby Auxiliary Feedwater Building Screen House NEI 99*01 Rev. 5 Ie:

FIRE within the PROTECTED AREA not extinguished within 15 minutes of detection or EXPLOSION within the PROTECTED AREA.

FPB loss/potential loss:

N/A Mode Applicability:

All Basis:

The purpose of this EAL is to address the magnitude and extent of fires that may be potentially significant precursors to damage to safety systems. It addresses the FIRE, and not the degradation in performance of affected systems that may result.

As used here, detection is visual observation and report by plant personnel or sensor alarm indication.

The 15 minute time period begins with a credible notification that a FIRE is occurring, or indication of a fire detection system alarm/actuation. Verification of a fire detection system alarm/actuation includes actions that can be taken within the control room or other nearby site specific location to ensure that it is not spurious. An alarm is assumed to be an indication of a FIRE unless it is disproved within the 15 minute period by personnel dispatched to the scene. In ATIACHMENT (2)

Page 2-7

other words, a personnel report from the scene may be used to disprove a sensor alarm if received within 15 minutes of the alarm, but shall not be required to verify the alarm.

The intent of this 15 minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket).

Table 8.4 contains VITAL AEAS and buildings and areas in actual contact with or immediately adjacent to VITAL AREAS or other significant buildings or areas. The intent of this EAL is not to include buildings (i.e., warehouses) or areas that are not in actual contact with or immediately adjacent to VITAL AREAS. This excludes FIRES within administration buildings, waste-basket FIRES, and other small FIRES of no safety consequence. Immediately adjacent implies that the area immediately adjacent contains or may contain equipment or cabling that could impact equipment located in VITAL AREAS or the fire could damage equipment inside VITAL AREAS or that precludes access to VITAL AREAS.

Escalation of this emergency classification level, if appropriate, would be based on EAL 8.2.2.

PEG

Reference:

NEI 99-01 Revision 5: HU2.1 Basis Reference(s):

1.

Site Plot Plan ATTACHMENT (2)

Page 2-8 other words, a personnel report from the scene may be used to disprove a sensor alarm if received within 15 minutes of the alarm, but shall not be required to verify the alarm.

The intent of this 15 minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket).

Table 8.4 contains VITAL AEAS and buildings and areas in actual contact with or immediately adjacent to VITAL AREAS or other significant buildings or areas. The intent of this EAL is not to include buildings (i.e., warehouses) or areas that are not in actual contact with or immediately adjacent to VITAL AREAS. This excludes FIRES within administration buildings, waste-basket FIRES, and other small FIRES of no safety consequence. Immediately adjacent implies that the area immediately adjacent contains or may contain equipment or cabling that could impact equipment located in VITAL AREAS or the fire could damage equipment inside VITAL AREAS or that precludes access to VITAL AREAS.

Escalation of this emergency classification level, if appropriate, would be based on EAL 8.2.2.

PEG

Reference:

NEI 99-01 Revision 5: HU2.1 Basis Reference(s):

1.

Site Plot Plan ATIACHMENT (2)

Page 2-8

8.0 Hazards 8.2 Fire or Explosion 8.2.2 Alert FIRE or EXPLOSION resulting in VISIBLE DAMAGE to ANY of the following structures containing safety systems or components, listed in Table 8.3 OR control room indication of degraded performance of those safety systems:

Table 8.3 Plant Vital Areas e

Intermediate Building 0

Control Building Containment Building Auxiliary Building Diesel Generator Building(s)

Standby Auxiliary Feedwater Building Screen House NEI 99-01 Rev. 5 IC:

Fire or explosion affecting the operability of plant safety systems required to establish or maintain safe shutdown.

FPB loss/potential loss:

N/A Mode Applicability:

All Basis:

The listed areas contain functions and systems required for the safe shutdown of the plant. The REGNPP safe shutdown analysis was consulted for equipment and plant areas required for the applicable mode.

As used here, an explosion is a rapid, violent, unconfined combustion, or a catastrophic failure of pressurized equipment, that potentially imparts significant energy to nearby structures and materials. No attempt is made in this EAL to assess the actual magnitude of the damage. The wording of this EAL does not imply that an assessment of safety system performance is intended to be performed, rather that as a result of the event, safety system parameter symptoms are degraded.

A steam line break that damages permanent structures or equipment would be classified under this EAL. The method of damage is not as important as the degradation of plant structures or equipment.

ATTACHMENT (2)

Page 2-9 8.0 Hazards 8.2 Fire or Explosion 8.2.2 Alert FIRE or EXPLOSION resulting in VISIBLE DAMAGE to ANY of the following structures containing safety systems or components, listed in Table 8.3 OR control room indication of degraded performance of those safety systems:

Table 8.3 Plant Vital Areas Intermediate Building Control Building Containment Building Auxiliary Building

\\

Diesel Generator Building(s)

Standby Auxiliary Feedwater Building Screen House NEI 99-01 Rev. 5 Ie:

Fire or explosion affecting the operability of plant safety systems required to establish or maintain safe shutdown.

FPB loss/potential loss:

N/A Mode Applicability:

All Basis:

The listed areas contain functions and systems required,for the safe shutdown of the plant. The REGNPP safe shutdown analysis was consulted for equipment and plant areas required for the applicable mode.

As used here, an explosion is a rapid, violent, unconfined combustion, or a catastrophic failure of pressurized equipment, that potentially imparts significant energy to nearby structures and materials. No attempt is made in this EAL to assess the actual magnitude of the damage. The wording of this EAL does not imply that an assessment of safety system performance is intended to be performed, rather that as a result of the event, safety system parameter symptoms are degraded.

A steam line break that damages permanent structures or equipment would be classified under this EAL. The method of damage is not as important as the degradation of plant structures or equipment.

ATIACHMENT (2)

Page 2-9

VISIBLE DAMAGE is used to identify the magnitude of the FIRE or EXPLOSION and to discriminate against minor FIRES and EXPLOSIONS.

The reference to structures containing safety systems or components is included to discriminate against FIRES or EXPLOSIONS in areas having a low probability of affecting safe operation.

The significance here is not that a safety system was degraded but the fact that the FIRE or EXPLOSION was large enough to cause damage to these systems.

The use of VISIBLE DAMAGE should not be interpreted as mandating a lengthy damage assessment prior to classification. The declaration of an Alert and the activation of the Technical Support Center will provide the Emergency Director with the resources needed to perform detailed damage assessments.

The Emergency Director also needs to consider any security aspects of the EXPLOSION.

Table 8.3 specify site specific structures or areas that contain safety system, or component and functions required for safe shutdown of the plant. Site specific Safe Shutdown Analysis should be consulted for equipment and plant areas required to establish or maintain safe shutdown.

Escalation of this emergency classification level, if appropriate, will be based on System Malfunctions, Fission Product Barrier Degradation or Abnormal Rad Levels / Radiological Effluent EALs.

PEG

Reference:

NEI 99-01 Revision 5: HA2.1 Basis Reference(s):

1.

Site Plot Plan ATTACHMENT (2)

Page 2-10 VISIBLE DAMAGE is used to identify the magnitude of the FIRE or EXPLOSION and to discriminate against minor FIRES and EXPLOSIONS.

The reference to structures containing safety systems or components is included to discriminate against FIRES or EXPLOSIONS in areas having a low probability of affecting safe operation.

The significance here is not that a safety system was degraded but the fact that the FIRE or EXPLOSION was large enough to cause damage to these systems.

The use of VISIBLE DAMAGE should not be interpreted as mandating a lengthy damage assessment prior to classification. The declaration of an Alert and the activation of the Technical Support Center will provide the Emergency Director with the resources needed to perform detailed damage assessments.

The Emergency Director also needs to consider any security aspects of the EXPLOSION.

Table 8.3 specify site specific structures or areas that contain safety system, or component and functions required for safe shutdown of the plant. Site specific Safe Shutdown Analysis should be consulted for equipment and plant areas required to establish or maintain safe shutdown.

Escalation of this emergency classification level, if appropriate, will be based on System Malfunctions, Fission Product Barrier Degradation or Abnormal Rad Levels I Radiological Effluent EALs.

PEG

Reference:

NEI 99-01 Revision 5: HA2.1 Basis Reference(s):

1.

Site Plot Plan ATIACHMENT (2)

Page 2-10

8.0 Hazards 8.3 Man-Made Events 8.3.2 Unusual Event EXPLOSION within the PROTECTED AREA.

NEI 99-01 Rev. 5 IC:

HU2 - FIRE within the PROTECTED AREA not extinguished within 15 minutes of detection or EXPLOSION within the PROTECTED AREA.

FPB loss/potential loss:

N/A Mode Applicability:

All Basis:

This EAL addresses the magnitude and extent of EXPLOSIONS that may be potentially significant precursors of damage to safety systems. It addresses the EXPLOSION, and not the degradation in performance of affected systems that may result.

As used here, detection is visual observation and report by plant personnel or sensor alarm indication.

This EAL addresses only those EXPLOSIONS of sufficient force to damage permanent structures or equipment within the PROTECTED AREA.

No attempt is made to assess the actual magnitude of the damage. The occurrence of the EXPLOSION is sufficient for declaration.

The Emergency director also needs to consider any security aspects of the EXPLOSION, if applicable.

Escalation of this emergency classification level, if appropriate, would be based on EAL 8.2.2.

PEG

Reference:

NEI 99-01 Revision 5: HU2.2 Basis Reference(s):

1.

Site Plot Plan ATTACHMENT (2)

Page 2-11 8.0 Hazards 8.3 Man-Made Events 8.3.2 Unusual Event EXPLOSION within the PROTECTED AREA.

NEI 99-01 Rev. 5 Ie:

HU2 - FIRE within the PROTECTED AREA not extinguished within 15 minutes of detection or EXPLOSION within the PROTECTED AREA.

FPB loss/potential loss:

N/A Mode Applicability:

All Basis:

This EAL addresses the magnitude and extent of EXPLOSIONS that may be potentially significant precursors of damage to safety systems. It addresses the EXPLOSION, and not the degradation in performance of affected systems that may result.

As used here, detection is visual observation and report by plant personnel or sensor alarm indication.

This EAL addresses only those EXPLOSIONS of sufficient force to damage permanent structures or equipment within the PROTECTED AREA.

No attempt is made to assess the actual magnitude of the damage. The occurrence of the EXPLOSION is sufficient for declaration.

The Emergency director also needs to consider any security aspects of the EXPLOSION, if applicable.

Escalation of this emergency classification level, if appropriate, would be based on EAL 8.2.2.

PEG

Reference:

NEI 99-01 Revision 5: HU2.2 Basis Reference(s):

1.

Site Plot Plan ATIACHMENT (2)

Page 2-11

8.0 Hazards 8.3 Man-Made Events 8.3.3 Unusual Event Toxic, corrosive, asphyxiant or flammable gases in amounts that have or could adversely affect NORMAL PLANT OPERATIONS OR Report by local, county or state officials for evacuation or sheltering of site personnel based on an off-site event.

NEI 99-01 Rev. 5 IC:

Release of toxic, corrosive, asphyxiant, or flammable gases deemed detrimental to NORMAL PLANT OPERATIONS.

FPB loss/potential loss:

N/A Mode Applicability:

All Basis:

This EAL is based on the release of toxic, corrosive, asphyxiant or flammable gases of sufficient quantity to affect NORMAL PLANT OPERATIONS.

The fact that SCBA may be worn does not eliminate the need to declare the event.

This EAL is not intended to require significant assessment or quantification. It assumes an uncontrolled process that has the potential to affect plant operations. This would preclude small or incidental releases, or releases that do not impact structures needed for plant operation.

An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels.

Most commonly, asphyxiants work by merely displacing air in an enclosed environment. This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.

Escalation of this emergency classification level, if appropriate, would be based on EAL 8.3.5.

PEG

Reference:

NEI 99-01 Revision 5: HU3.1 NEI 99-01 Revision 5: HU3.2 Basis Reference(s):

None ATTACHMENT (2)

Page 2-12 8.0 Hazards 8.3 Man-Made Events 8.3.3 Unusual Event Toxic, corrosive, asphyxiant or flammable gases in amounts that have or could adversely affect NORMAL PLANT OPERATIONS OR Report by local, county or state officials for evacuation or sheltering of site personnel based on an off-site event.

NEI 99-01 Rev. 5 Ie:

Release of toxic, corrosive, asphyxiant, or flammable gases deemed detrimental to NORMAL PLANT OPERATIONS.

FPB loss/potential loss:

N/A Mode Applicability:

All Basis:

This EAL is based on the release of toxic, corrosive, asphyxiant or flammable gases of sufficient quantity to affect NORMAL PLANT OPERATIONS.

The fact that SCBA may be worn does not eliminate the need to declare the event.

This EAL is not intended to require significant assessment or quantification. It assumes an uncontrolled process that has the potential to affect plant operations. This would preclude small or incidental releases, or releases that do not impact structures needed for plant operation.

An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels.

Most commonly, asphyxiants work by merely displacing air in an enclosed environment. This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.

I' Escalation of this emergency classification level, if appropriate, would be based on EAL 8.3.5.

PEG

Reference:

NEI 99-01 Revision 5: HU3.1 NEI 99-01 Revision 5: HU3.2 Basis Reference(s):

None ATTACHMENT (2)

Page 2-12

8.0 Hazards 8.3 Man-Made Events 8.3.4 Alert Vehicle crash resulting in VISIBLE DAMAGE to:

ANY of the structures containing safety systems or components, listed in Table 8.3 OR Control Room indication of degraded performance of those safety systems Table 8.3 Plant Vital Areas Control Building Containment Building Auxiliary Building Intermediate Building Emergency Diesel Building(s)

Standby Auxiliary Feedwater Building Screen House NEI 99-01 Rev. 5 IC:

Natural or destructive phenomena affecting VITAL AREAS.

FPB losslpotential loss:

N/A Mode Applicability:

All Basis:

This EAL addresses the occurrence of an event that has resulted in VISIBLE DAMAGE to plant structures or areas containing equipment necessary for a safe shutdown, or has caused damage to the safety systems in those structures evidenced by control room indications of degraded system response or performance. The occurrence of VISIBLE DAMAGE and/or degraded system response is intended to discriminate against lesser events. The initial report 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 significance here is not that a particular system or structure was damaged, but rather, that the event was of sufficient magnitude to cause this degradation.

Table 8.3 specifies the Ginna structures or areas that contain safety system, or component and functions required for safe shutdown of the plant and are based on the Ginna Safe Shutdown Analysis.

ATTACHMENT (2)

Page 2-13 8.0 Hazards 8.3 Man-Made Events 8.3.4 Alert Vehicle crash resulting in VISIBLE DAMAGE to:

ANY of the structures containing safety systems or components, listed in Table 8.3 OR Control Room indication of degraded performance of those safety systems Table 8.3 Plant Vital Areas Control Building Containment Building Auxiliary Building Intermediate Building.

Emergency Diesel Building(s)

Standby Auxiliary Feedwater Building Screen House NEI 99-01 Rev. 5 Ie:

Natural or destructive phenomena affecting VITAL AREAS.

FPB loss/potential loss:

N/A Mode Applicability:

All Basis:

This EAL addresses the occurrence of an event that has resulted in VISIBLE DAMAGE to plant structures or areas containing equipment necessary for a safe shutdown, or has caused damage to the safety systems in those structures evidenced by control room indications of.

degraded system response or performance. The occurrence of VISIBLE DAMAGE and/or degraded system response is intended to discriminate against lesser events. The initial report 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 significance here is not that a particular system or structure was damaged, but rather, that the event was of sufficient magnitude to cause this degradation.

Table 8.3 specifies the Ginna structures or areas that contain safety system, or component and functions required for safe shutdown of the plant and are based on the Ginna Safe Shutdown Analysis.

ATIACHMENT (2)

Page 2-13

PEG

Reference:

NEI 99-01 Revision 5: HA1.5 Basis Reference(s):

None ATTACHMENT (2)

Page 2-14 PEG

Reference:

NEI 99-01 Revision 5: HA 1.5 Basis Reference{s):

None ATIACHMENT (2)

Page 2-14

8.0 Hazards 8.3 Man-Made Events 8.3.5 Alert Access to a VITAL AREA listed in Table 8.3 is prohibited due to toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of systems required to maintain safe operations or safely shutdown the reactor.

Table 8.3 Plant Vital Areas Control Building 0

Containment Building Auxiliary Building 9

Intermediate Building Diesel Generator Building(s)

Standby Auxiliary Feedwater Building Screen House NEI 99-01 Rev. 5 IC:

Access to a VITAL AREA is prohibited due to release of toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of systems required to maintain safe operations or safely shutdown the reactor.

FPB loss/potential loss:

N/A Mode Applicability:

All Basis:

Gases in a VITAL AREA can affect the ability to safely operate or safely shutdown the reactor.

The fact that SCBA may be worn does not eliminate the need to declare the event.

Declaration should not be delayed for confirmation from atmospheric testing if the atmosphere poses an immediate threat to life and health or an immediate threat of severe exposure to gases. This could be based upon documented analysis, indication of personal ill effects from exposure, or operating experience with the hazards.

ATTACHMENT (2)

Page 2-15 8.0 Hazards 8.3 Man-Made Events 8.3.5 Alert Access to a VITAL AREA listed in Table 8.3 is prohibited due to toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of systems required to maintain safe operations or safely shutdown the reactor.

Table 8.3 Plant Vital Areas Control Building Containment Building Auxiliary Building Intermediate Building Diesel Generator Building(s)

Standby Auxiliary Feedwater Building Screen House NEI 99-01 Rev. 5 Ie:

Access to a VITAL AREA is prohibited due to release of toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of systems required to maintain safe operations or safely shutdown the reactor.

FPB loss/potential loss:

N/A Mode Applicability:

All Basis:

Gases in a VITAL AREA can affect the ability to safely operate or safely shutdown the reactor.

The fact that SCBA may be worn does not eliminate the need to declare the event.

Declaration should not be delayed for confirmation from atmospheric testing if the atmosphere poses an immediate threat to life and health or an immediate threat of severe exposure to gases. This could be based upon documented analysis, indication of personal ill effects from exposure, or operating experience with the hazards.

ATIACHMENT (2)

Page 2-15

If the equipment in the stated area was already inoperable, or out of service, before the event occurred, then this EAL should not be declared as it will have no adverse impact on the ability of the plant to safely operate or safely shutdown beyond that already allowed by Technical Specifications at the time of the event.

An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels.

Most commonly, asphyxiants work by merely displacing air in an enclosed environment. This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.

An uncontrolled release of flammable gasses within a facility structure has the potential to affect safe operation of the plant by limiting either operator or equipment operations due to the potential for ignition and resulting equipment damage/personnel injury. Flammable gasses, such as hydrogen and acetylene, are routinely used to maintain plant systems (hydrogen) or to repair equipment/components (acetylene - used in welding). This EAL assumes concentrations of flammable gasses which can ignite/support combustion.

Escalation of this emergency classification level, if appropriate, will be based on System Malfunctions, Fission Product Barrier Degradation or Abnormal Rad Levels / Radioactive Effluent EALs.

PEG

Reference:

NEI 99-01 Revision 5: HA3.1 Basis Reference(s):

None ATTACHMENT (2)

Page 2-16 If the equipment in the stated area was already inoperable, or out of service, before the event occurred, then this EAt should not be declared as it will have no adverse impact on the ability of the plant to safely operate or safely shutdown beyond that already allowed by Technical Specifications at the time of the event.

An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels.

Most commonly, asphyxiants work by merely displacing air in an enclosed environment. This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.

An uncontrolled release of flammable gasses within a facility structure has the potential to affect safe operation of the plant by limiting either operator or equipment operations due to the potential for ignition and resulting equipment damage/personnel injury. Flammable gasses, such as hydrogen and acetylene, are routinely used to maintain plant systems (hydrogen) or to repair equipment/components (acetylene - used in welding). This EAL assumes concentrations of flammable gasses which can ignite/support combustion.

Escalation of this emergency classification level, if appropriate, will be based on System Malfunctions, Fission Product Barrier Degradation or Abnormal Rad Levels / Radioactive Effluent EALs.

PEG

Reference:

NEI 99-01 Revision 5: HA3.1 Basis Reference(s):

None ATTACHMENT (2)

Page 2-16

ATTACHMENT (3)

Red-line of NEI 99-01 Revision 5 R.E. Ginna Nuclear Power Plant, LLC November 30, 2009 ATTACHMENT. (3)

Red-line of NEI 99-01 Revision 5 R.E. Ginna Nuclear Power Plant, LLC November 30, 2009

Inititin. Condition N O01TIFICATION OF UNUSUAL EVJENT 17.0 Equipment Failures 1*7.3 Loss of Indications./ Alarms / Communications Capabnllit 17.3.1 UNUSUAL EVENl INE 99-01 Rev. 5 IC:I SUNPLANNED loss of safety system annunciation or indication in the control room for 15 minutes or longer.

Ope:ating Mode Applicability:

U-Power Operation, 7 Startup,,-.Hot Standby, 3Hot Shutdown

,FPB losslpotential loss:

Example Emergency Action Level:

Nota:*

The Em*erge lly Directo Shld-A-t dcclarc the cvcnt as soon as ti dctcr exeed, the asiglic-able time.

ait until the applicak

• mincd-that the coni le time has elapsed, but lhould dition has e)(eeeded, or Will likely 4-UNPLANNED Loss of g*rcater than apr--..imat.ly 75% of the following for 15 minutes or longer:

6(Site speCifie ontrol Room A nnunciaty Paneioten)b 6 or more Control Room Annunciator Panels listed in Table 7.3 OR (Sit apcic coto roome indications'nicaion

~n p~proximate 75% reduction in Control Room safety system indications iTable 7.3 Control Room Annunciator Panels' ATTACHMENT (3)

Page 3-1 SU3 Initiating Condition NOTIFICATION OF UNUSUAL &\\f&NT

~.,o Equipment Failures

~.3 Loss of Indications./ Alarms I Communicatiol1sf::apabilit~

~.3.1 UN~SUAL EVENTj

[NEt 99-01 Rev. 5 tC:~

~U3 i UNPLANNED loss of safety system annunciation or indication in the control room for 15 minutes or longer.

Operating Mode Applicability:

,FPB loss/~otential 1055:1 NIA'

~

&Jlample Emergency Action Level:

I!] Power Operation, ~

Startup, ~Hot Standby, ~Hot Shutdown Nate; rAe ElTlergeRcy Director SAOl:Jls Rot wait l:JRtii tAe af}f}lical:lle tilTle Aas elaf}ses, l:Il:Jt SAol:Jls seelare tAe eveRt as SOOR as it is seteFlTliReS tAat tAe cOReiitioR Aas e)(ceeses, or will likely e>Eeees, tAe af}f}lieal:lle tilTle.

+/-:

UNPLANNED Loss of greater tAaR af}f}ro)(ilTlately 713% of the following for 15 minutes or longer:

a..

(Site sf}eeifie cORtrol rOOITl safety systelTl aRRl:JRCiatioR) 6 or more Control Room Annunciator Panels listed in Table 7.3 OR (Site sf}eeific cORtrol roolTl safety systelTl iReiicatioR)

!An a~'proximate 75% reduction in Control Room safety system indication~

~able 7.3 Control Room Annunciator Panel~

ATTACHMENT (3)

Page 3-1

Basis:

'Note: The Emergency Director should not wait until the applicable time has elapsed, but should Feclare the event as soon as it is determined that the condition has exceeded, or will likelýy exceed, the applicable timeý This IC and its zaz.ocbtcd EAL a;r intendcd to recognizeg the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment.

Recognition of the availability of computer based indication equipment is considered [egP~kg; p EC',.G.uerp, etc-.4]P(PPCS and SAS).

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

Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions.

i75% of lost annunciators is defined as loss of 6 of the 8 annunciator panels listed on Table 7.3. Loss o~f i75% of Control Room safety indications is loss of 75% of the indicators on the center and left sections of the main control board indications)

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10CFR50.72. If the shutdown is not in compliance with the Technical Specification action, the NOUE is based on &Ua EAL 7.1.1 "Inability to Reach Required Shutdown Within Technical Specification Limits."

[Site see*4e a*r-nnunciators or indicators for this EAL must include those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e.g., area, process, and/or effluent rad monitors, etc.)4 Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

ATTACHMENT (3)

Page 3-2 Basis:

Note:* The Emergency Director should not wait until the a~plicable time has elapsed, but should:

~eclare the event as ~oon as it is determined that the condition has exceeded, or wililikel~

~exceed, the applicable time.!

This Ie aRa its associatea EAL are iRteRaea to recognize§ the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment.

Recognition of the availability of computer based indication equipment is considered (e.g., $PIJS, (3J9Rt 9R'1(3l:1ter, etE.]:(PPCS and SAS~.

"Planned" loss of annunciators or indicators includes scheduled maintenance ahd testing activities.

Quantification is arbitrary, however, it is estimated that if approximately 75% ofthe safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions.

~5% of lost annunciators is defined as loss of 6 of the 8 annunciator panels listed on Table 7.3. Loss o~

~5% of Control Room safety indications is loss of 75% of the indicators on the center and left sections o~

~he main control board indications.!

It is further recognized that most plant designs provide redun~ant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10CFRSO.72. If the shutdown is not in compliance with the Technical Specification action, the NOUE is based on ~

lEAL 7.1.~ "Inability to Reach Required Shutdown Within Technical Specification Limits."

($;te s(3ejfi 6~nnunciators or indicators for this EAL must include those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e.g., area, process, and/or effluent rad monitors, etc.H Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

ATTACHMENT (3)

Page 3-2

jDue to the limited number of safety systems in operation during cold shutdown, refueling, and defueled modes, no IC is indicated during these modes of operation.1 This NOWE -Unusual Event will be escalated to an Alert based on a concurrent loss of compensatory indications or if a SIGNIFICANT TRANSIENT is in progress during the loss of annunciation or indication.

'PEG

Reference:

NEI 99-01 Revision 5: SU3.11 Basis Reference(s).'

ATTACHMENT (3)

Page 3-3

{Due to the limited number of safety systems in operation during cold shutdown, refueling, and defueled modes, no Ie is indicated during these modes of operation.}

This NGYf-iUnusual Even~ will be escalated to an Alert based on a concurrent loss of compensatory indications or if a SIGNIFICANT TRANSIENT is in progress during the loss of annunciation or indication.

[PEG Reference~

[NEI 99-01 Revision 5: SU3.11

[Basis Reference(~)i None

~

ATIACHMENT (3)

Page 3-3

6A4 Initiating Condition -ALERT 17.0 Equipment Failures 17,3 Loss of Indications i Alarms / Communications Capability 7.3.3 ALER-1i INE 99-01 Rev. 5 IC:.

]UNPLANNED Loss of safety system annunciation or indication in the control room with EITHER (1) a SIGNIFICANT TRANSIENT in progress, or (2) compensatory indicators unavailable.

SMode Applicability:

• -Power Operation, F Startup 7 Hot Standby, Hot Shutdown FPB loss/potential loss:]

Exam pie-Emergency Action Level:

Notc:

The Emcrgcncy Director zhould nt; wzit un.Atil the applecable time has elapsed, but rhou'ld decbr~e the cvent as soon as it is dctcFRmincd thait the condition has cxcceded, or Will likely excccd, the zappliczable timc.

1.

a.

UNPLANNED loss Of grczacr tFh tepproximztely:

75% of the following for 15 minutes or longer:

(Site speeifie controll room safety system annuncizftion)

" (Site specific control room safety sysztem idc~in l

6 or more Control Room Annunciator Panels listed in Table 7.31 p

An approximate 75% reduction in Control Room safety system indications b,

FA ' EITHER ef the fellewi+g:

A SIGNIFICANT TRANSIENT is in progress.

Compensatory indications are unavailable.

ATTACHMENT (3)

Page 3-4 SA4 Initiating Condition ALERT i7.0 Equipment Failure~

~.3 Loss of Indications j Alarms I Communications Capabilit~

~.3.3 ALERli

[NEI 99-01 Rev. SIC;

~A4 ~ UNPLANNED Loss of safety system annunciation or indication in the control room with EITHER (1) a SIGNIFICANT TRANSIENT in progress, or (2) compensatory indicators unavailable.

Operating Mode Applicability:

I!J Power Operation, §] Startup, ~

Hot Standby,

!I] Hot Shutdown lFPB loss/Qotential 1055:1 iNiAl EJlample Emergency Action Level:

Nate; Tl:le EA'lergency Director sl:lol::llel not wait I::Intil tl:le al3l3lical3le tiA'le I:las elal3seel, I3l::1t sl:lol::llel eleciaFe tl:le event as soon as it is eleterA'lineei tl:lat tl:le conelition I:las e*ceeeleel, or will likely e*ceeel, tl:le al3l3lical3le tiA'le.

1.

a.

UNPLANNED loss of greater tl:lan al3l3rQ)(iA'lately 75% of the following for 15 minutes or longer:

(Site sl3ecific contFOI FOOA'l safety systeA'l annl::lnciation)

(Site sl3ecific control rooA'l safety systeA'l inelication) 6 or more Control Room Annunciator Panels listed in Table 7.3,

~

An approximate 75% reduction in Control Room safety system indication~

~ND, EITHER of tl:le following:

A SIGNIFICANT TRANSIENT is in progress.

Compensatory indications are unavailable.

ATTACHMENT (3)

Page 3-4

Basis:

Note:

The Emergency Director~should not wait untilthe applicable time has elapsed, but should, Ieclare the event as soon as it is determined that the condition has exceeded, or will likely, exceed, the applicable time!

This IC Li intcndcd to EA recognizeg the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment during a SIGNIFICANT TRANSIENT.

lRecognition of the availability of computer based indication equipment is considered (-

o c-nptre

.',(P PCS, SAS),

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

Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions. It is also not intended that the Shift.

.,4peF

[Mannagelij be tasked with making a judgment decision as to whether additional personnel are required to provide increased monitoring of system operation.

175% of lost annunciators is defined as loss of 6 of the 8 annunciator panels listed on Table 7.3. Loss ofj

ý75% of Control Room safety indications is loss of 75% of the indicators on the center and left sections o'f

,he main control board indicationsJ It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action, the

_UE is based on SU2 "Inability to RcachFALl V... "Plant is not brought to Required S...dew Operating Mode Within Technical Specification 4Mfits tOGIRequired Action Completion Time."

ATTACH MENT (3)

Page 3-5

~able 7.3 Control Room Annunciator Panel~

I I

I I

I Basis:

Note:

The Emergency Director should not wait until, the a~plicable time has elapsed, but should:

~eclare the event as soo'n as it is determined that the condition has~xceeded,or wililikel~

~xceed, the a~plicable time.!

This Ie is iAteAaea to IEA4 recognize§ the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment during a SIGNIFICANT TRANSIENT.

{Recognition of the availability of computer based indication equipment is considered (e. g., $P{)$, fJleRt C9R'1fJl:lter, etc.}.} :(PPCS, SAS):

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

Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions. It is also not intended that the Shift Sl:Iflervisor ~g~

be tasked with making a judgment decision as to whether additional personnel are required to provide increased monitoring of system operation.

\\75% of lost annunciators is defined as loss of 6 of the 8 annunciator panels listed on Table, 7.3. Loss 0"

\\75% of Control Room safety indications is loss of 75% of the indicators on the center and left sections 0"

~he main control board indications{

It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action, the l&9UE is based on SU2 "IAaeility to Read'! :EA4 i7.1.~ "Plant is not brought to Required St:tl:ltaowA :Operating Mode: Within Technical Specification!:+ffiit5 WG!Required Action Completion Tim~."

ATTACHMENT (3)

Page 3-5

r;.&t -speife qr-*ennunciators or indicators for this EAL should be limited those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e.g., area, process, and/or effluent rad monitors, etc.).]

"Compensatory indications" in this context includes computer based information such as -gS FPPDCS and K.

[This should include all computer systems available for this use depending on specific plant design and subsequent retrofits.] If both a major portion of the annunciation system and all computer monitoring are unavailable, the Alert is required.

{SIGNIFICANT TRANSIENT: An UNPLANNED event involving one or more of the following- (1) automaticd

,turbine runback greater than 25% thermal reactor power, (2) electrical load rejection greater than 25Y

,full electrical load, (3) Reactor Trip, (4) Safety Injection Activation, or (5) thermal power oscillations

'greater than 10% of rated thermal powerJ fDue to the limited number of safety systems in operation during cold shutdown, refueling and defueled modes, no IC is indicated during these modes of operation.4 Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.

This Alert will be escalated to a Site Area Emergency if the operating crew cannot monitor the transient in progress due to a concurrent loss of compensatory indications with a SIGNIFICANT TRANSIENT is in progress during the loss of annunciation or indication.

PEG

Reference:

i

,NEI 99-01 Revision 5: SA4.11

,Basis' Reference(s):

ATTACHMENT (3)

Page 3-6

[Site 5f)eiji 9~nnunciatars or indicators for this EAL should be limited those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (e.g., area, process, and/or effluent rad monitors, etc.).}

"Compensatory indications" in this context includes computer based information such as £P.QS [pPCS and:

~A~. [This should include all computer systems available for this use depending on specific plant design and subsequent retrofits.] If both a major portion of the annunciation system and all computer monitoring are unavailable, the Alert is required.

{SIGNIFICANT TRANSIENT: An UNPLANNED event involving one or more of the following: (1) automatic;

~urbine runback greater than 25% thermal reactor power, (2) electrical load rejection greater than25o/c1

~ull electrical load, (3) Reactor Trip, (4) Safety Injection Activation, or (5) thermal power oscillation~

'greater than 10% of rated thermal power.!

{Due to the limited number of safety systems in operation during cold shutdown, refueling and defueled modes, no Ie is indicated during these modes of operation.}

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

This Alert will be escalated to a Site Area Emergency if the operating crew cannot monitor the transient in progress due to a concurrent loss of compensatory indications with a SIGNIFICANT TRANSIENT is in progress during the loss of annunciation or indication.

[PEG

Reference:

[NEI 99-01 Revision 5: SA4.1i

[Basis' Reference{~)i

Non~

ATTACHMENT (3)

Page 3-6

ca6 Ilnitiatinlg Condition SI-T1"1"E AREA EMERGENCY i7.0 Equipment Failure, j7.3 Loss of Indications / Alarms / Communication Capability 17.3.4 SITE AREA EMERGENCY INEI 99-01 Rev. 5 IC;ý S

Inability to monitor a SIGNIFICANT TRANSIENT in progress.

Opetatilm3-Mode Applicability:

U-Power Operation, 7 Startup, Hot Standby, Hot Shutdown FPB losslpotential loss:;

Eample Emergency Action Level:

Note.

Th E mcrgency ircctor-shou,,d not t.

~it until the app~iwable time has elaipsed, butshe-i'd 0

ucuiarc the c':cnt as~ seen asz it is-ctcermincu thatJ the eeR~i iuon has cxcccuae~, or WINi kIelhy emeed, tnh oiicejln time-.

Loss of frfetcr thzn apprfximately 75% of the following for 15 minutes or longer:

0 (Site* peeifiee-ntro. l rooem f.ty system znnuncbtien)

OR 0

(Site speci-fic control room lsafety systemidcaon 6 or more Control Room Annunciator Panels listed in Table 7.3 OR An approximate 75% reduction in Control Room safety indications AND 43-A SIGNIFICANT TRANSIENT is in progress.

AND ATTACHMENT (3)

Page 3-7 S56 Initiating Condition SITE AREA EMERGENCY

~.o Equipment Failure~

~.3 Loss of Indications I Alarms I Communication Capabilit~

~.3.4 SITE AREA EMERGENC~

I I

NEI 99-01 Rev. 5 IC:;

~S6 i Inability to monitor a SIGNIFICANT TRANSIENT in progress.

OpeFating Mode Applicability:

~

Power Operation, ~

Startup, ~

Hot Standby,

[j Hot Shutdown iFPB 10ss/Rotentiai 1055:1

'N/ftJ Example Emergency Action Level:

Nate; Tl=te ER'lergeAcy Director sl:lol:llEl AOt "'Iait I:IAtil tl:le a~~licaBle tiR'le I:las ela~seEl, Bl:lt sl:lol:llEl Eleclare tl:le e'/eAt as SOOA as it is EleterR'liAeEl tl:lat tl:le cOAElitioA I:las e)(ceeEleEl, or will liI~ely mEceeEl, tl:le a~~licaBle tiR'le.

1.

a.

Loss of greater tl:laA a~~re)(iR'lately 75% of the following for 15 minutes or longer:

(Site s~ecific cOAtrel reoR'l safety systeR'l aAAI:IAeiatioA)

(Site s~eeific cOAtrol reoR'l safety systeR'l iAElieatioA) 6 or more Control Room Annunciator Panels listed in Table 7.3 OR An approximate 75% reduction in Control Room safety indications AND A SIGNIFICANT TRANSIENT is in progress.

AND ATTACHMENT (3)

Page 3-7

Compensatory indications are unavailable.

Basis:

'Note: The Emergency Director should not wait until the applicable time has elapsed, but should

,eclare the event as soon as it is determined that the condition has exceeded, or~will likely; exceed, the applicable time)

This IC is intcndcd to

.EA recognizeý the threat to plant safety associated with the complete loss of capability of the control room staff to monitor plant response to a SIGNIFICANT TRANSIENT.

"Planned" and "UNPLANNED" actions are not differentiated since the loss of instrumentation of this magnitude is of such significance during a transient that the cause of the loss is not an ameliorating factor.

Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions. It is also not intended that the Shift S--e'.*se:

[Manage_ be tasked with making a judgment decision as to whether additional personnel are required to provide increased monitoring of system operation.

L75% of lost annunciators is defined as loss of 6 of the 8 annunciator panels listed~on Table7.3. Loss of 75% of Control Room safety indications is loss of 75% of the indicators on the center and left sectionsf

,the main control board indicationsi It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action, the NQUE is based on SU2 "Inability to RcechEAL 17.1.1 "Plant is not brought to' Required Shutdown Within Technical Specification IARs LCO Required,

!ction Completion Tim*."

ATTACHMENT (3)

Page 3-8 e.,

Compensatory indications are unavailable.

~able 7.3 Control Room Annunciator Panel~

I ~ I I

I' o o

Basis:

I I

I IR'

~ I

Note:

The Emergency Director should not wait until the applicable time has elapsed, but shoul~

~eclare the event as soon as it is determined that the condition has exceeded, orwililikel~

~exceed, the al?plicable time.!

This Ie is iAteAEleEl to [EAW recognize§ the threat to plant safety associated with the complete loss of capability of the control room staff to monitor plant response to a SIGNIFICANT TRANSIENT.

"Planned" and "UNPLANNED" actions are not differentiated since the loss of instrumentation of this magnitude is of such significance during a transient that the cause ofthe loss is not an ameliorating factor.

Quantification is arbitrary, however, it is estimated that if approximately 75% of the safety system annunciators or indicators are lost, there is an increased risk that a degraded plant condition could go undetected. It is not intended that plant personnel perform a detailed count of the instrumentation lost but use the value as a judgment threshold for determining the severity of the plant conditions. It is also not intended that the Shift Sl:Il3ervisor ~g~

be tasked with making a judgment decision as to whether additional personnel are required to provide increased monitoring of system operation.

175% of lost annunciators is defined as loss of 6 of the 8 annunciator panels listed.on Table7.3.Loss o~

i75%ofControl Room safety indications is loss of 75% of the indicators on the center arid left. se<;.tiqns o~

~he main control board indicationsl It is further recognized that most plant designs provide redundant safety system indication powered from separate uninterruptible power supplies. While failure of a large portion of annunciators is more likely than a failure of a large portion of indications, the concern is included in this EAL due to difficulty associated with assessment of plant conditions. The loss of specific, or several, safety system indicators should remain a function of that specific system or component operability status. This will be addressed by the specific Technical Specification. The initiation of a Technical Specification imposed plant shutdown related to the instrument loss will be reported via 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action, the NGUE is based on SU2 "IAaeility to Read'! m 17.1.1 "Plant is not brought to: Required Shutdown Within Technical Specification -I::iffi+ts [LCO Required:

~ction Completion Tim~."

ATIACHMENT (3)

Page 3-8

A Site Area Emergency is considered to exist if the control room staff cannot monitor safety functions needed for protection of the public while a significant transient is in progress.

[Site speeýfife, nnunciatorsfor this EAL should be limited to include those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (.g., area, process, and/or effluent rad monitors, etc.)4 SIGNIFICANT TRANSIENT: An UNPLANNED event involving one or more of the following: (1) automatic!

frurbine runback greater than 25% thermal reactor power, (2) electrical load rejection greater than 259/81 full electrical load, (3) Reactor Trip, (4) Safety Injection Activation, or (5) thermal power oscillations' kreater than 10% of rated thermal poweri Sit.

.;peefl*4.ndications needed to monitor safety functions necessary for protection of the public must include control room indications, computer generated indications and dedicated annunciation capability.

fThe specific indications should be those used to determine such functions as the ability to shut down the reactor, maintain the core cooled, to maintain the reactor coolant system intact, maintain the spent fuel cooled, and to maintain containment intact.4 "Compensatory indications" in this context includes computer based information such as SPDS. This should include all computer systems available for this use depending on specific plant design and subsequent retrofits.

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 4G f ALI is indicated during these modes of operation.4

!PEG

Reference:

'NEI 99-01 Revision 5: SS6.1

,Basis Reference(s)!

ATTACHMENT (3)

Page 3-9 A Site Area Emergency is considered to exist if the control room staff cannot monitor safety functions needed for protection of the public while a significant transient is in progress.

(Site sfJeeijie ~nnunciators for this EAL should be limited to include those identified in the Abnormal Operating Procedures, in the Emergency Operating Procedures, and in other EALs (.g., area, process, and/or effluent rad monitors, etc.)}

~IGNIFICANT TRANSIENT: An UNPLANNED event involving one or more of the following: (1) automatiq

~urbine runback greater than 25% thermal reactor power, (2) electrical load rejection greater than 25'X1

~ull electrical load, (3) Reactor Trip, (4) Safety~jection Activation; or (5) thermal power oscillation~

greater than 10% of rated thermal powed Site 513ecific i~ndications needed to monitor safety functions necessary for protection of the public must include control room indications, computer generated indications and dedicated annunciation capability.

{The specific indications should be those used to determine such functions as the ability to shut down the reactor, maintain the core cooled, to maintain the reactor coolant system intact, maintain the spent fuel cooled, and to maintain containment intact.}

"Compensatory indications" in this context includes computer based information such as SPDS. This should include all computer systems available for this use depending on specific plant design and subsequent retrofits.

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 lf~A~ is indicated during these modes of operation.}

NEI 99-01 Revision 5: SS6.11

[Basis Reference(~)i None'

~

ATTACHMENT (3)

Page 3-9

NUZ Initiating Condition -,NOTIRI*ATION OAF UN* UUJillAl FVENlT

8.0 Hazards 8.2 Fire or ExplosionI 8.2.1 UNUSUAL EVENT INEI 99-01 Rev. 5 IC-FIRE within the PROTECTED AREA not extinguished within 15 minutes of detection or EXPLOSION within the PROTECTED AREA.

Operating Mode Applicability: All

,FPB losslpotential loss:

Example Emergency Action Level:

(1 or 2)

FIRE in ANY!&f the areas listed in Table 8.4) not extinguished within 15 minutes of, control room notification or verification of a control room FIRE alarm in ANY* of thc followin.Og a:c:

(site specifi arca lest)

EXPLOSION within the PROTECTED AREA.

ATTACHMENT (3)

Page 3-10 MU2 Initiating Condition NOTIFICATION OF UNUSUAL E¥ENT

8.0 Hazard~

~.2 Fire or Explosio~

I

,8.2.1 UNUSUAL EVENlj INEI 99-01 Rev. 5 Ie::

FIRE within the PROTECTED AREA not extinguished within 15 minutes of detection or EXPLOSION within the PROTECTED AREA.

Operating Mode Applicability: All

[FPB loss/Qotential loss:]

N/pJ Example Emergency Action Level:

(1 or 2)

-+/--:

FIRE in ANY ~of the areas listed in Table 8.4) not extinguished within 15 minutes of8 control room notification or verification of a control room FIRE alarm iA ANV af tl:le fella..... iAg areas:

(site sl3eeifie area list)

~

EXPLOSION within the PROTECTED AREA.

ATIACHMENT (3)

Page 3-10

fTable 8.4 Plant Vital and Adjacent Areas!

Intermediate Buildin' I, TSC Buildin*

Service Building Contaminated Storage Building Control Buildin.

Containment Buildinc Auxiliary Building Turbine Buildingc Diesel Generator Building(s)

Standby Auxiliary Feedwater Building Screen Ho'u-s Basis:

This EAL addresses the magnitude and extent of FIRES or EXPLOSIONS that may be potentially significant precursors of damage to safety systems. It addresses the FIRE / EXPLOSION, and not the degradation in performance of affected systems that may result.

As used here, detection is visual observation and report by plant personnel or sensor alarm indication.

EAL #1 The 15 minute time period begins with a credible notification that a FIRE is occurring, or indication of a fire detection system alarm/actuation. Verification of a fire detection system alarm/actuation includes actions that can be taken within the control room or other nearby site specific location to ensure that it is not spurious. An alarm is assumed to be an indication of a FIRE unless it is disproved within the 15 minute period by personnel dispatched to the scene. In other words, a personnel report from the scene may be used to disprove a sensor alarm if received within 15 minutes of the alarm, but shall not be required to verify the alarm.

The intent of this 15 minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket).

[The site spc-fi. &. t T*head bl"* rnited and Gppiies t. Table 8.4 contains VITAL AREAS an buildings and areas in actual contact with or immediately adjacent to VITAL AREAS or other significant buildings or areas. The intent of this IC is not to include buildings (i.e., warehouses) or areas that are not in actual contact with or immediately adjacent to VITAL AREAS. This excludes FIRES within administration ATTACHMENT (3)

Page 3-11 jrable 8.4 Plant Vital and Adjacent Areas!

Intermediate Building TSC Building Service Building t

Contaminated Storage Building Control Building

~.

Containment Building AuxiliarY Building Turbine Building I.

Diesel Generator Building(sY, I.

Standby AuxiliarY Feedwater'-B--u-il-d-in-'g Screen House,'

Basis:

This EAL addresses the magnitude and extent of FIRES or EXPLOSIONS that may be potentially significant precursors of damage to safety systems. It addresses the FIRE / EXPLOSION, and not the degradation in performance of affected systems that may result.

As used here, detection is visual observation and report by plant personnel or sensor alarm indication.

The 15 minute time period begins with a credible notification that a FIRE is occurring, or indication of a fire detection system alarm/actuation. Verification of a fire detection system alarm/actuation includes actions that can be taken within the control room or other nearby site specific location to ensure that it is not spurious. An alarm is assumed to be an indication of a FIRE unless it is disproved within the 15 minute period by personnel dispatched to the scene. In other words, a personnel report from the scene may be used to disprove a sensor alarm if received within 15 minutes of the alarm, but shall not be required to verify the alarm.

The intent of this 15 minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket).

[TRe site s{!JeGiiiG list SRfJl:lt9 Be tiR'liteg EJR9 EJ{!J{!Jlies tfJ ITable 8.4 contains VITAL AREAS and, buildings and areas in actual contact with or immediately adjacent to VITAL AREAS or other significant buildings or areas. The intent o/this Ie is not to include buildings (i.e., warehouses) or areas that are not in actual contact with or immediately adjacent to VITAL AREAS. This excludes FIRES within administration ATIACHMENT (3)

Page 3-11

buildings, waste-basket FIRES, and other small FIRES of no safety consequence. Immediately adjacent implies that the area immediately adjacent contains or may contain equipment or cabling that could impact equipment located in VITAL AREAS or the fire could damage equipment inside VITAL AREAS or that precludes access to VITAL AREAS.1 EAL #2 This EAL addresses only those EXPLOSIONS of sufficient force to damage permanent structures or equipment within the PROTECTED AREA.

No attempt is made to assess the actual magnitude of the damage. The occurrence of the EXPLOSION is sufficient for declaration.

The Emergency director also needs to consider any security aspects of the EXPLOSION, if applicable.

Escalation of this emergency classification level, if appropriate, would be based on IA21rEAL 78.2.2.

PEG

Reference:

NEI 99-01 Revision 5: HU2.11 iBasis Reference(s)_

11. Site Plot Plan ATTACHMENT (3)

Page 3-12 buildings, waste-basket FIRES, and other small FIRES of no safety consequence. Immediately adjacent implies that the area immediately adjacent contains or may contain equipment or cabling that could impact equipment located in VITAL AREAS or the fire could damage equipment inside VITAL AREAS or that precludes access to VITAL AREAS.}

This EAL addresses only those EXPLOSIONS of sufficient force to damage permanent structures or equipment within the PROTECTED AREA.

No attempt is made to assess the actual magnitude of the damage. The occurrence of the EXPLOSION is sufficient for declaration.

The Emergency director also needs to consider any security aspects ofthe EXPLOSION, if applicable.

Escalation of this emergency classification level, if appropriate, would be based on ~EAL 8.2.2!.

,PEG

Reference:

[NEI 99-01 Revision 5: HU2.11

[Basis Reference(s)i

11.

Site Plot Plan ATTACHMENT (3)

Page 3-12

HU3 Initiating Condition iNO/TIFI"CATINON*N O llF UNUSUAL EVENT.

.O Hazards

!8.3 - Man-Made Events

,4.3.3 UNUSUAL EVENTn INl 99-0i Rev:.5 IC:

Release of toxic, corrosive, asphyxiant, or flammable gases deemed detrimental to NORMAL PLANT OPERATIONS.

a Mode Applicability: All

'FPB loss/potentialr IOss:,

Example Emergency Action Levels: (1 or 2),

Toxic, corrosive, asphyxiant or flammable gases in amounts that have or could adversely affect NORMAL PLANT OPERATIONS.

2 Report by local, county or state officials for evacuation or sheltering of site personnel based on an off-site event.

Basis:

This EAL is based on the release of toxic, corrosive, asphyxiant or flammable gases of sufficient quantity to affect NORMAL PLANT OPERATIONS.

The fact that SCBA may be worn does not eliminate the need to declare the event.

IThis XGEAL, is not intended to require significant assessment or quantification. It assumes an uncontrolled process that has the potential to affect plant operations. This would preclude small or incidental releases, or releases that do not impact structures needed for plant operation.4 An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment. This reduces the ATTACHMENT (3)

Page 3-13 Initiating Condition NOTIFICATION OF UNUSUAL &'.!&NT i

' 'I

8.0

',Hazard~

i' "I

,.3, ','Man-Made, Event~

I."

. I

a,,3~3 UNUSUAL EVENlj INEI99-OfRev. 5Ic:~

MU3 Release of toxic, corrosive, asphyxiant, or flammable gases deemed detrimental to NORMAL PLANT OPERATIONS.

Operating Mode Applicability: All

!FPB IO$s/potentiaHoss:l iiWA1 IN/~

&Kample Emergency Action Levels: (lor 2)

Toxic, corrosive, asphyxiant or flammable gases in amounts that have or could adversely affect NORMAL PLANT OPERATIONS.

~

Report by local, county or state officials for evacuation or sheltering of site personnel based on an off-site event.

Basis:

This EAL is based on the release of toxic, corrosive, asphyxiant or flammable gases of sufficient quantity to affect NORMAL PLANT OPERATIONS.

The fact that SCBA may be worn does not eliminate the need to declare the event.

{This ~!EA~ is not intended to require significant assessment or quantification. It assumes an uncontrolled process that has the potential to affect plant operations. This would preclude small or incidental releases, or releases that do not impact structures needed for plant operation.}

An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment. This reduces the ATTACHMENT (3)

Page 3-13

concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.

Escalation of this emergency classification level, if appropriate, would be based on 4A EAL 8.3.5.

,PEG

Reference:

1 NEl 99-01 Revision 5: HU3.1

-NEI 99-01 Revision 5: HU3.2,

'Basis Reference(s)_

ATTACH MENT (3)

Page 3-14 concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.

Escalation of this emergency classification level, if appropriate, would be based on -I=4A3-iEAL 8.3.5;.

[PEG

Reference:

[NEI 99-01 Revision 5: HU3.1i

[NEI 99-01 Revision 5: HU3.2

!Sasis Reference(~.l~

None

~

ATIACHMENT (3)

Page 3-14

NA2 Initiating Condition -ALE--R-T.

'8.2 Fire orEplosior*

,8.2.2 ALEReI INEI 99-01 Rev. 5 IC:I FIRE or EXPLOSION affecting the operability of plant safety systems required to establish or maintain safe shutdown.

Operat14g Mode Applicability: All jFPB loss/potential loss:

Example Emergency Action Level:

FIRE or EXPLOSION resulting in VISIBLE DAMAGE to ANY of the following structures containing safety systems or components, listed in Table 8.

OR control room indication of degraded performance of those safety systems:

(site speaifile PltaUtV Iriet)

Fr rIable 8.3 Plant Vital Areas I

Intermediate Building' Control Building' Containment Building Auxiliary Building' Diesel Generator Building.(Ls ATTACHMENT (3)

Page 3-15 Initiating Condition ALERT

8.2 Fire orEplosio~

8.2.2 ALERli

[NEI 99-01 Rev. 5 IC::

MA2 FIRE or EXPLOSION affecting the operability of plant safety systems required to establish or maintain safe shutdown.

Operating Mode Applicability: All

[FPB loss/~otential 1055:1 iN/A!

Example Emergency Action Level:

1.

FIRE or EXPLOSION resulting in VISIBLE DAMAGE to ANY of the following structures containing safety systems or components, [listed in Table 8.3:

OR control room indication of degraded performance of those safety systems:

(site s!3ccific StFl:lctl:lFC list)

~able 8.3 Plant Vital Area~

Intermediate Buildind Control Buildind Containment Building' AuxiliarY. Buildind Diesel Generator Building(~1.

ATIACHMENT (3)

Page 3-15

Standby Auxlhiary Feedwater Building 0

Screen House Basis:

iThe listed areas contain functions and systems required for the safe shutdown of the plant, The REGNPP safe shutdown analysis wasconsulted for equipment and plant areas required for the applicable modeJ iAsused here, an explosion is a rapid, violent, unconfined combustion, or a catastrophic failure of]

pressurized equiprment, that potentially imparts significant energy to nearby structures and materials.!

No attemptis made in this EAL to assess the actual magnitude of the damage. The wording of this EALI loes not imply that an assessment of safety system performance is intended to be performed, rather

,that as a result of the event, safety system parameter symptoms are degraded A steam line break that damages permanent structures or equipment would be classified under this EALJ iThe method of damage is not as important as the degradation of plant structures or equipmentJ VISIBLE DAMAGE is used to identify the magnitude of the FIRE or EXPLOSION and to discriminate against minor FIRES and EXPLOSIONS.

The reference to structures containing safety systems or components is included to discriminate against FIRES or EXPLOSIONS in areas having a low probability of affecting safe operation. The significance here is not that a safety system was degraded but the fact that the FIRE or EXPLOSION was large enough to cause damage to these systems.

The use of VISIBLE DAMAGE should not be interpreted as mandating a lengthy damage assessment prior to classification. The declaration of an Alert and the activation of the Technical Support Center will provide the Emergency Director with the resources needed to perform detailed damage assessments.

The Emergency Director also needs to consider any security aspects of the EXPLOSION.

jr-h.s.A. he'd ITable 8.3 specify site specific structures or areas that contain safety system, or component and functions required for safe shutdown of the plant. Site specific Safe Shutdown Analysis should be consulted for equipment and plant areas required to establish or maintain safe shutdown.4 Escalation of this emergency classification level, if appropriate, will be based on System Malfunctions, Fission Product Barrier Degradation or Abnormal Rad Levels / Radiological Effluent ICs.

PEG

Reference:

,NEI 99-01 Revision 5: HA2.1

,Basis Reference(s):,

ATTACHMENT (3)

Page 3-16

~

Standby' Auxiliary. Feedwater Building' Screen Housd Basis:

~he listed areas contain functions and systems required for the safe shutdown of the plant The REGNP~

~afeshutdownanalysis was consulted foreguipment and plant areas required for the ae.plicable mode~

~sused here,an explosion isa rapid, violent, unconfined. combustion, or a catastrophic failureo~

presstirizedequipnient, that potentially imparts significant energy to nearby structures and materials.!

iNo attempt is made in this EAL to assess the actual magnitude ofthe damage.The wording of this EA~

~oes not irnply thatan.assessment of safety system performance is intended to be performed, rathe~

I

~hat asa result ofthe event, safetY2ystem parameter symptoms are degraded,

!A steam line break that damages permanent structures or equipment would be classified under this EAL~

~he method of damage is not as imj:lortant as the degradation of plant structures or equipment1 VISIBLE DAMAGE is used to identify the magnitude of the FIRE or EXPLOSION and to discriminate against minor FIRES and EXPLOSIONS.

The reference to structures containing safety systems or components is included to discriminate against FIRES or EXPLOSIONS in areas having a low probability of affecting safe operation. The significance here is not that a safety system was degraded but the fact that the FIRE or EXPLOSION was large enough to cause damage to these systems.

The use of VISIBLE DAMAGE should not be interpreted as mandating a lengthy damage assessment prior to classification. The declaration of an Alert and the activation of the Technical Support Center will provide the Emergency Director with the resources needed to perform detailed damage assessments.

The Emergency Director also needs to consider any security aspects of the EXPLOSION.

[TJ:lis EAL SR91:1!i ITable 8.3, specify site specific structures or areas that contain safety system, or component and functions required for safe shutdown of the plant. Site specific Safe Shutdown Analysis should be consulted for equipment and plant areas required to establish or maintain safe shutdown.}

Escalation of this emergency classification level, if appropriate, will be based on System Malfunctions, Fission Product Barrier Degradation or Abnormal Rad Levels / Radiological Effluent ICs.

PEG*

Reference:

[NEI 99-01* Revision 5: HA2.11

[Basis Reference(~)i ATTACHMENT (3)

Page 3-16

11. Site Plot Plan ATTACHMENT (3)

Page 3-17 I

Site Plot Plan

1.

ATTACHMENT (3)

Page 3-17

1&-1-2 T

ý

ý

ý

ý9ý--,2

~ES~U S~S 3 ULIE *~E ELI

~

mniii:uuni LONUIKIGEl FILl I ir IL.-. I iijre ijr UJFIUJ~U.-.L ~~IU I 0.3 Man-Made, Events 8.2.1 UNUSUAL EVEN1T JNEI 99-01 Rev; 5 IC:.

FIRE within the PROTECTED AREA not extinguished within 15 minutes of detection or EXPLOSION within the PROTECTED AREA.

Operating Mode Applicability: All

',FPB-losslpotentiall loss.1 Example Emergency Action Level:

(1 or 2) 4 FIRE not extinguished within 15 minutes of control room notification or verification of a control room FIRE alarm in ANY of the following areas (sitesp e;cific; a*rc I*it) able8.4 Plant Vital and Adjacent Areas

'Intermediate Building 0"

.TSC Building SerVi;e Building

,Contaminated 'Storage Building S

'Cont*rol Building' Containment Building

.Auxiliary Building' Turbine Building_

Diesel Generator Buiilding(s),'

StandbyAuxiliary Feedwator Building-ScreenLHHouse7

1.

EXPLOSIGN' WAtWA the PROTECTED AREA.

Basis:

ATTACHMENT (3)

Page 3-18 Initiating Condition NOTIFICATION OF UNUSUAL EVENT

8.3,"; Man-ivlade.Event~

8.~'.1 'UNUSUAL EVENl]

INEI99-01Rev. 5 Ie::

MU2 FIRE within the PROTECTED AREA not extinguished within 15 minutes of detection or EXPLOSION within the PROTECTED AREA.

Operating Mode Applicability: All

[FPB'loss/~otentialloss:1 fN/,AJ

~

EJlample Emergency Action Level: (lor 2)

-h FIRE not extinguished within 15 minutes of control room notification or verification of a control room FIRE alarm in ANY of the following areas pn Table8..$,:

(site sl3ecific area list) jTable8~4PlantVital and'Adjacent' Area~

'Intermediate Building

~... ::rsc Building I".,

I.,,

~

I',.

I,.

I..

Se'r"IIice Building'

]

.,. Contaminated Storage Building,

'Control Building'

,Contairln1enfSuilding AUxilia!y'.Building' I.,;..... ' Turbine Building Di~seI'C3Em~r~to-r-B"""ui~ld~in;-,

g-(s"'C'lj,--=-~-:-'"""1 Stal1dby Auxili~ry Fee'dwat'erBuilding'

!.", ScreenHous~

2.

eXPLOSION withiA the PROTeCTeD AReA.

Basis:

ATTACHMENT (3)

Page 3-18

This EAL addresses the magnitude and extent of FIRES or EXPLOSIONS that may be potentially significant precursors of damage to safety systems. It addresses the FIRE / EvXPLOSI.ON, and not the degradation in performance of affected systems that may result.

As used here, detection is visual observation and report by plant personnel or sensor alarm indication.

EA#44 The 15 minute time period begins with a credible notification that a FIRE is occurring, or indication of a fire detection system alarm/actuation. Verification of a fire detection system alarm/actuation includes actions that can be taken within the control room or other nearby site specific location to ensure that it is not spurious. An alarm is assumed to be an indication of a FIRE unless it is disproved within the 15 minute period by personnel dispatched to the scene. In other words, a personnel report from the scene may be used to disprove a sensor alarm if received within 15 minutes of the alarm, but shall not be required to verify the alarm.

The intent of this 15 minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket).

[The spite

÷

.vts',uA bc !!irnitcd bnd Table 8. applies to buildings and areas in actual contact with or immediately adjacent to VITAL AREAS or other significant buildings or areas. The intent of this IG FE7AL is not to include buildings (i.e., warehouses) or areas that are not in actual contact with or immediately adjacent to VITAL AREAS. This excludes FIRES within administration buildings, waste-basket FIRES, and other small FIRES of no safety consequence. Immediately adjacent implies that the area immediately adjacent contains or may contain equipment or cabling that could impact equipment located in VITAL AREAS or the fire could damage equipment inside VITAL AREAS or that precludes access to VITAL AREAS.4 ThiS EAL @

dd.. ss.s only theoS

EXPLOIO, NS of 1c, ffiCict fer* e to d...ge per

,a nent St..*ru..

S o r cquipmcnt within the PROTECTED ARPEA-.

No attempt OS m-ade to assess the actual magnitude of the damage. The occ-eurrence-e of the EXPLOGSION i The Eme*r*g*

y dircctr 9.al nccds to c9nsider any sccurity aspTcts of the EXPLOSION, if appliceable.

Escalation of this.m..g.n.y classification level, I

app.op.iat., would be basc.d on HA2.

PEG

Reference:

,NEI 99-01 Revision 5:HU2.1

'Basis Reference(s)l

1. Site Plot Plan' ATTACHMENT (3)

Page 3-19 This EAL addresses the magnitude and extent of FIRES or eXPLOSIONS that may be potentially significant precursors of damage to safety systems. It addresses the FIRE / eXPLOSION, and not the degradation in performance of affected systems that may result.

As used here, detection is visual observation and report by plant personnel or sensor alarm indication.

The 15 minute time period begins with a credible notification that a FIRE is occurring, or indication of a fire detection system alarm/actuation. Verification of a fire detection system alarm/actuation includes actions that can be taken within the control room or other nearby site specific location to ensure that it is not spurious. An alarm is assumed to be an indication of a FIRE unless it is disproved within the 15 minute period by personnel dispatched to the scene. In other words, a personnel report from the scene may be used to disprove a sensor alarm if received within 15 minutes of the alarm, but shall not be required to verify the alarm.

The intent ofthis 15 minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket).

[TRe site sped/if list s"'e~/Ei Be !i~iteEi aREi ITable 8.4. applies to buildings and areas in actual contact with or immediately adjacent to VITAL AREAS or other significant buildings or areas. The intent of this I{; !EA~

is not to include buildings (i.e., warehouses) or areas that are not in actual contact with or immediately adjacent to VITAL AREAS. This excludes FIRES within administration buildings, waste-basket FIRES, and other small FIRES of no safety consequence. Immediately adjacent implies that the area immediately adjacent contains or may contain equipment or cabling that could impact equipment located in VITAL AREAS or the fire could damage equipment inside VITAL AREAS or that precludes access to VITAL AREAS.}

This eAL aelelresses oRly those eXPLOSIONS of sl:lfficieRt force to elamage l'lermaReRt strl:lctl:lres or eEll:lil'lmeRt withiR the PROTECTED AReA.

No atteml'lt is maele to assess the actl:lal magRitl:lele of the elamage. The OCCl:lrreRCe of the eXPLOSION is sl:lfficieRt for eleciaratioR.

The emergeRCY elirector also Reeels to cORsieler aRY secl:Irity aSl'lects of the eXPLOSION, if al'll'llicaBle.

escalatieR of this emergeRCY classificatioR le'/el, if al'll'lrel'lriate, 'Nol:llel Be Baseel OR I=IA2.

PEG

Reference:

[NEI 99-01 Revision 5: HU2.11

~Basis Reference(s)i

1. !Site Plot Plan' ATIACHMENT (3)

Page 3-19

NU111 Initwating Condition -NOTIFICATION OF UNUSUAL EVENT

'8.3 Man-Made Events

,8.3.2 UNUSUAL EVENT INEI 99-01 Rev. 5 ICi FIRE within the PROTECTED AREA not extinguished within 15 minutes of detection or EXPLOSION within the PROTECTED AREA.

Operat-ing Mode Applicability: All IFPB loss/potential loss:

Example Emergency Action Level:

(1 or 2)

1.

FIRE not cxtwnguizhcd withmn is Fmiutcz of control roomA notifiation or Yeritieat eR et a control room FIRE AlarM in ANY of the following arcas:

(sIte szp f;ifi area Ist),

EXPLOSION within the PROTECTED AREA.

Basis:

This EAL addresses the magnitude and extent ofFI 9 EXPLOSIONS that may be potentially significant precursors of damage to safety systems. It addresses the R4R EXPLOSION, and not the degradation in performance of affected systems that may result.

As used here, detection is visual observation and report by plant personnel or sensor alarm indication.

The 15 mninutc time pcried begins with a crcdible notification that a FIRE 6iz( ocurig or idication of a fire dctcctAion system alarm/acatujation. VerificationR of a fie dctection system alarm/actainicu actionz that cAn hp ta4ken w.ithin thc otro room9 o9FAr othcr nea;rby site spccific loar-tion to enPRA-~

that i S~ not SGHrious. An alarmA i*aSm to be an indication of A FIRE - nlczJ it k dizrnrA;;d within thc 15_r

.. intc pcF.id by pcr..nn.l dispat.hed. to. the qzc........ In ether 4009FGs, a pcrzonnc rcport from the scene o-f the -alarmI, but Shall no-t be requiFed to er;ify the alarm.

1;;A,', a Arm*;; ;;

r-

, ;Vp AM A';.;;

PA

." p ;.

ATTACHMENT (3)

Page 3-20 Initiating Cenditien NOTIFICATION OF UNUSUAL E\\,ENT

8.3 Man-Made Event~

8.3.2 UNUSUAL EVENT!

INEI 99-01 Rev. SIC; MU2 FIRE within the PROTECTED AREA not extinguished within 15 minutes of detection or EXPLOSION within the PROTECTED AREA.

Operating Mode Applicability: All iFPB loss/~otentialloss:1

!N/~

~

Example Emergency Action Level: (lor 2)

1.

I=IR~ RSt e)(tiRgl:lisReei witRiR 15 R'liRl:Ites sf eSRtrsl resR'l RstifieatisR sr verifieatisR sf a eSRtrel rssR'l I=IR~ alarR'l iR ANY sftRe fsllswiRg areas:

(site sfleeifie area list)

~

EXPLOSION within the PROTECTED AREA.

Basis:

This EAL addresses the magnitude and extent of I=IR~S sr EXPLOSIONS that may be potentially significant precursors of damage to safety systems. It addresses the -Fm-f EXPLOSION, and not the degradation in performance of affected systems that may result.

As used here, detection is visual observation and report by plant personnel or sensor alarm indication.

TRe 15 R'liRl:Ite tiR'le fle!risell;)egiRs "vitR a ereelil;)le RstifieatisR tRat a I=IR~ is seel:lrriRg, sr iRelieatisR sf a fire eleteetisR s."steR'l alarR'l/aetl:latisR. VerifieatisR sf a fire eleteetisR s."steR'l alarR'l/aetl:latisR iRell:Ieles aetisRs tRat eaR I;)e takeR witRiR tRe eSRtrsl resR'l sr stRer Rearl;)." site sfleeifie IseatisR ts eRSl:lre tRat it is RSt Sfll:lrisl:lS. AR alarR'l is assl:lR'leei ts I;)e aR iRelieatisR sf a I=IR~ l:IRless it is elisflreveel witRiR tRe 15 R'liRl:Ite flerisell;)." flerssRRel elisflateReei ts tRe seeRe. IR stRer wsrels, a flerssRRel reflsrt freR'l tRe seeRe R'la." I;)e l:Iseei ts elisflrsve a seRssr alarR'l if reeeiveel witRiR 15 R'liRl:Ites sf tRe alarR'l, I;)l:It sRall RSt I;)e reEfl:lireei ts ';erify tRe alarR'l.

ATIACHMENT (3)

Page 3-20

Thc inteRt of this 15s

,inut duratio*ni to Size the FIRE and to di*crm;*inat aga;inst small FIRES that arc readily extinguis*zd (e.g., Sz...dcaRig waste papcr baskct).

[ThM sitespa cAList sheould bt e EiPitOd and applics to buidings and amaes in entual sntruct With oA

mNo diattemY sadacant to VTA e

ARES or ethear significnt buildings Ter orras. Me intcent of this IW is net t inclUde bUildingS (iýc., WarchouSes) or: arcs that arcP n1t Wn act4Ual contact# With or immcfldiately adlacent to V41TAL 4REAS. This excludas, F-IRES9 within agdmginistation buildings, waste basket FIRES, and ether small FIRES ofe neogncty ctonsausnees.

immnsdiately adjacunt implies that the arEX imOdiatOy apdjacane Ecntains or may eertaen cuipmsnt rcation, that co tould iepa equipment located in VIT4A AREAS or thefir-e could damage eguipment inside VITAL AREAS or-that prrclwdes rcca6ss to 111TAL AREAS-.]I This EAL addresses only those EXPLOSIONS of sufficient force to damage permanent structures or equipment within the PROTECTED AREA.

No attempt is made to assess the actual magnitude of the damage. The occurrence of the EXPLOSION is sufficient for declaration.

The Emergency director also needs to consider any security aspects of the EXPLOSION, if applicable.

Escalation of this emergency classification level, if appropriate, would be based on =A-Z FEAL 8.-2.21.

PPEG

Reference:

NEI 99-01 Revision 5: HU2.2 Basis Referencels)j

11. Site Plot Plani ATTACHMENT (3)

Page 3-21 Tl'le iRteRt oftl'lis 15 R"IiRloIte elloIratioR is to size tl'le I=IRE aRel to eliscriR"liRate agaiRst sR"lalll=lRES tl'lat are reaelily e)(tiRglolisl'leel (e.g., sR"loleleriRg 'uaste l3al3er l3asket).

[TRe site s~eEijiE list SRal:l/EiBe IiR'liteEi BREi B~~!ies ta Bl:liJEiiRgS BREi BFeas iR BGtI:lB! EaRtBEt witf:! ar iR'lR'leEiiBte/y BfijBEeRt ta It/TAL AREAS ar atf:!er SigRijiEBRt Bl:liJEiiRgS ar BreBS. The iRteRt at tRis !e is Rat ta iRdl:lEie Bl:li!EiiRgs (-i.e., IIIBFeRal:lSes) ar B.,,BS tf:!Bt B,':e Rat iR BEtI:lB/ EaRtBGt lIIitf:! ar iR'lR'leEiiBtety BEJjBEeRt ta VlTAL AREAS. This ~fJI:lEies RRfS lIIitRiR BEiR'liRistrBtiaR Bl:litEiiRgS, WBSte BBsket RRfS, BREi atRer SR'lBJI RRES 9/ Ra s9/ety EaRseEil:leREe. IR'lR'leEiiBtel;, BEJjBEeRt iR'l~!ies tRBt tf:!e BreB iR'lR'leEiiBtel;, BEJjBEeRt 9RtBiRS ar R'lBy EaRtBiR eEil:li~R'leRt ar EBB/iRg tRBt Eal:l!Ei iR'l~BEt eEil:li~R'leRt !aEBteEi iR VITAL AREAS ar tRejire Eal:l!Ei EiBR'lBge eEil:li~R'leRt iRsiEie VITAL AREAS ar tf:!Bt ~reE!I:IEies BEEess ta VITAL AREAS.]

This EAL addresses only those EXPLOSIONS of sufficient force to damage permanent structures or equipment within the PROTECTED AREA.

No attempt is made to assess the actual magnitude of the damage. The occurrence of the EXPLOSION is sufficient for declaration.

The Emergency director also needs to consider any security aspects of the EXPLOSION, if applicable.

Escalation of this emergency classification level, if appropriate, would be based on ~

lEAL 8.2.2!.

PEG

Reference:

NEI 99-01 Revision 5: HU2.2

Sasis Reference(s).;]

11.. Site Plot Plan:

ATIACHMENT (3)

Page 3-21

HAI Initiating Condition - ALERT

'8.0 Hazards 8.3 Man-Made Events 8.3.4 ALER'i NEI 99-01 Rev. 5 IC:

Natural or destructive phenomena affecting VITAL AREAS.

Oper-ati.g-Mode Applicability: All FPB loss/potential Ioss:I Example Emergency Action Levels: (I or 2 or 3 or, or 5 or 6)

1.

a.

Scismic event g..atcr than Op..ating Ba"sis Earthquake (,- E) a indicacd-rby (site specii ei~

intrMcntation) rcading (sitcspec-ific OBE limt)

AN19

b. Earthquake confirmced by EITHER of the followng "Earthquake felt in plant-SNational Earqhuak1 Ge*ter 2I.

Tornado Striking or high winds greatcr than (site speeifie Mph) rczulting in VISIBLE DAMAGE to

.ANY11 of the folloWing Structurcz__1 containing safety systems or compencnts OR control roomR iniatio of dcgradcd pcrfiformancc of these safety systcmzi:

(site specific 5tFWctWrc list)

3.

Intcrnal flooding n AN.Y of the fellew.ng areaS resulting in an -lectrical shock hazard that prccludcz aeeess to opcratc orf monito._er safety equip~mcnt OR conAtrolI room ndcto of dcgradcd perfor-Mancc of these safety systems; (site specific area lost)

ATTACHMENT (3)

Page 3-22 Initiating Condition ALERT

8.0 Hazard~

I I

~.3 Man-Made Event~

,I

,8.3.4 ALERTj

!NEI 99-01 Rev. 51C; Natural or destructive phenomena affecting VITAL AREAS.

Operating Mode Applicability: All lFPB loss/~otential 1055:1

N/.AJ Example Emergency Action Levels: (lor 2 or 3 or 4 or S or 6)

HAi

1.

a.

Seismic elJeRt greater tl=laR Ol3eratiRg 8asis eartl=lElbiake (08e) as iRElicateEi B'( (site sl3eci~ic seismic iRstrblmeRtatioR) reaEiiRg (site sl3eci~ic 08e limit).

B.

eartl=lElbiake cOR~irmeEi By IiITIolIiR o~ tl=le ffiliowiRg:

eartl=lElblal<e ~elt iR I3laRt NatioRal eartl=lElblal<e CeRter

2.

TomaEio stril<iRg or I=ligl=l WiREiS greater tl=laR (site sl3eci~ic ml3l=l) resbiltiRg iR VISI8Le DAMAGe to ANY o~ tl=le ~ollowiRg strblctblres cORtaiRiRg sa~ety s.,'stems or Com130ReRts OR cORtrol room iREiicatioR o~ EiegraEieEil3erffirmaRce o~ tl=lose sa~ety systems:

(site sl3eci~ic strblctblre list)

3.

IRterRal ~looEiiRg iR ANY oftl=le ~ollowiRg areas resbiltiRg iR aR electrical sl=locl< l=lazarEi tl=lat I3reclblEies access to ol3erate or mORitor sa~et'( eElblil3meRt OR cORtrol room iREiicatioR o~

EiegraEieEil3e~OrmaRce o~ tl=lose sa~ety systems:

(site sl3eci~ic area list)

ATIACHMENT (3)

Page 3-22

4.

Tur'binc bilUrc generated PROJ ECTILES FesultmnR in VISIBLE DAMAGE9 to or penetratweRn At A13Y 4 the folloWing Structurcz containing safety systems or components OR control roo-m. *nRction-.-wA. o-f L

pcgrfacad pcF;9FRrorm~ncc these safecty system s--

(site spccifir: StwrAUctu list)

Vehicle crash resulting in VISIBLE DAMAGE to ANY of the following structures containing safety systems or components OR control room indication of degraded performance of those safety systems:

(site spccific ztFWctWre lost)

Frable 8.3 Plant Vital Areas Control Building' Containment Building Auxiliary Building Intermediate Building Diesel Generator Building.(s, Standby Auxiliary Feedwater Building Screen House f. I

,(Site

• zp*,ie oeeuens,

,,ultig in VISI*LE DAAGE: Wo.. NY oftfl following Str*Uct, v

w eentaffining safecty sys~tems or compennts ORl control room snolcztion o;Eef dgadcd~ pertrmzmnc of these saifety systems (sktc speeifie StFUcturc Ifist)

Basis:

-hee r EALs a

f-th ddresset the occurrence of the event has resulted in VISIBLE DAMAGE to plant structures or areas containing equipment necessary for a safe shutdown, or has caused damage to the safety systems in those structures evidenced by control room indications of ATTACHMENT (3)

Page 3-23

4.

T\\,;Irl:liAe fail\\,;lre geAerateei PROJ~CTIL~S res\\,;lltiAg iA VISIBL~ DI\\MI\\G~ to or l3eAetratioA of.o.NY of tAe foliowiAg str\\,;lct\\,;lres cOAtaiAiAg safety systems or com130AeAts OR cOAtrel reom iAelicatioA of elegraeleell3erformaAce of tAose safety systems:

(site sl3ecific str\\,;lct\\,;lre list)

Vehicle crash resulting in VISIBLE DAMAGE to ANY of the following structures containing safety systems or components OR control room indication of degraded performance of those safety systems:

(site sl3ecific str\\,;lct\\,;lre list).

~able 8.3 Plant Vital Area~

Control Building

~.

Containment Building AuxiliarY Building l

~.

Intermediate Building

~.

Diesel Generator Building.(~i Standby' AuxiliarY Feedwater Building l

~.

Screen Housd,

6.

(Site sl3ecific oCC\\,;lrreAces) res\\,;lltiAg iA VISIBL~ DI\\MI\\G~ to ANY oftAe follo'.... iAg str\\,;lct\\,;lres cOAtaiAiAg safety s',stems or COm130AeAts OR cOAtrol reom iAelicatioA of elegraeleell3erformaAce of tRose safety systems:

(site sl3ecific str\\,;lct\\,;lre list)

Basis:

TRese ~hi~ EAL5 escalates from ~Ul iA tAat ~addresse~ the occurrence of the event has resulted in VISIBLE DAMAGE to plant structures or areas containing equipment necessary for a safe shutdown, or has caused damage to the safety systems in those structures evidenced by control room indications of ATIACHMENT (3)

Page 3-23

degraded system response or performance. The occurrence of VISIBLE DAMAGE and/or degraded system response is intended to discriminate against lesser events. The initial report 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 significance here is not that a particular system or structure was damaged, but rather, that the event was of sufficient magnitude to cause this degradation.

Escalation of this emergency classification level, if appropriate, would be based on System Malfunction 4C6 FEALs.

I T-hes 94LS sheold siaet4 site soeccitfr-sth '-tu~~

r-'oarcas that coentain 6cap ty syctrnq, or-corengpnent and J

tunctNens r-equrcd tar cata hutdewn at the plent. 9i pci ac5~donAay~codb eensuiked ar-equ~pncent and pient ar-eoc r-equmrd to esteb!61? or-rnaentae sG0 shutdew,,,.4 EAtI#4 SeiszmiceP-cnt-os sf *-hi 0-;magnitude can Fesult in a VITAL AREA being swbjcctcd to ferccs bcyond design limits, and thus damage may be assumed-to-have occurroed to plant safety syste.

[This ~

~

~

~

~~

thahl h~db ac nstccific-FS6AR design basis. See EPRI sponser-ed "Guideiincc fo; Afdurlefa Weant Response to en E-a.thqGakc ' dated Oc-teber 1989, fer-informatiN eniri vent

-eteger~es~d T-he 'a tion-al Earthguakc CcntcPr c-an con~fir-m if ancthguakc has ccu-r-rcd inthe area of thc plant.

This E.AL1 is based on a tornado9 Strfiking (touching downq) or high W.inds that have eaused VISIBLE DAMAGE t SctRietre containing fi"inc"tion-" or stffi" ruir'ed for safe h-uWtdO. of the plant.

[TMe high wind vaiue sheuld be bosed en site spcfic FSAR dervign basis &s leng as it is within the raenge-of tha instr-umc-ntGAtion avaiblab foer wind speed.!

ThizELO dre t-hc effect of internal flooding eaused by events such as compencnt failures, equipment misalignment, or outage activity mishap. It *-, based on the degadcd pe,*, Fanc of syste ms, or has created indUctrial safety hazardS (e.g., electrical shock) that preclude neeezzary aceezste eperate oFAr monto zf-;FS4-ty equipment. The inability to accaze, operate or monitor*9 safety equipment.

I represents an actual 9r Subztantial potential degrad-at*ion ot the level ot satety ot the plant.

I ATTACHMENT (3)

Page 3-24 degraded system response or performance. The occurrence of VISIBLE DAMAGE and/or degraded system response is intended to discriminate against lesser events. The initial report 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 significance here is not that a particular system or structure was damaged, but rather, that the event was of sufficient magnitude to cause this degradation.

Escalation of this emergency classification level, if appropriate, would be based on System Malfunction

~IEAL~.

~ALs #2 #§

[TRese flUs SRal:lte s{3eei{y site s{3eei{ie stFl:letl:lfS ar areas tRat eaRtaiR safety systeR'l, ar eaR'l{3aReRt aRe ffJRetiaRs re6fl:li."e jar S9fe SRl:lteawR af tRe {3.'aRt. Site s{3eei{ie Safe SRl:lteaViR ARatysis SRal:lteBe eaRSI:IJtee fer e6fl:li{3R'1eRt aRe {3taRt areas re6fl:liree ta estaB.'isR ar R'laiRtaiR sflje SRl:lteaVlR.]

Seismic eveRts of this magRitl:lae caR resl:llt iR a VITAL AR~A BeiRg sl:lBjectea to forces BeyoRa aesigR limits, aRa thl:ls aamage may Be assl:lmea to hal.. e occl:lrrea to I'IlaRt safety systems.

[TRis tRresRa"e sRal:lleBe Basee aR site s{3eei{ie FSAR fiesigR Basis. See fPR! S{3aRSaree "Gl:lifie!iRe5 far Nl:lelear PJaRt ReS{3aRSe ta aR fartR6fl:lake", eatee OeteBer 1989, fer iRjfsfR'latiaR aR seisR'lie e'JeRt eategaries. ]

The NatioRal ~arthEll:lalEe CeRter caR cORfirm if aR earthEll:lalEe has occl:lrrea iR the area of the I'IlaRt.

This ~AL is Basea OR a tOFRaao strilEiRg (tOl:lchiRg aOI.... R) or high wiRas that have cal:lsea VISI8L~ DAM/'.G~

to strl:lctl:lres cORtaiRiRg fl:lRctioRs or systems reEll:lirea for safe shl:ltaowR of the I'IlaRt.

[TRe RigR wiRe 'r'a"l:Ie sRal:lleBe Basee aR site s{3eei{ie FSAR eesigR Basis as "aRg as it is VlitRiR tRe FBRge ef tRe iRstrl:lR'leRtatiaR a'JailaBJe far wiRe s{3eee.]

This ~AL aaaresses the effect of iRterRal flooaiRg cal:lsea BY eveRts sl:lch as COml'lOReRt faill:lres, eEll:lil'lmeRt misaligRmeRt, or ol:ltage activity mishal'ls. It is Basea OR the aegraaea I'IerformaRce of systems, or has createa iRal:lstrial safety hazaras (e.g., electrical shock) that I'Irecll:lae Recessary access to ol'lerate or mORitor safety eEll:lil'lmeRt. The iRaBility to access, ol'lerate or mORitor safety eEll:lil'lmeRt rel'lreseRts aR actl:lal or sl:lBstaRtial I'IoteRtial aegraaatioR of the level of safety of the I'IlaRt.

ATIACHMENT (3)

Page 3-24

Flooding as 'use-d in t-his' E.AL deascribes a condition w..here w0.aterf is enterinig the roomR faster t-han ntle equipmcnt is capable Of removYal, resulting in a rise of water level w~ithin the room. Classification of this EAL s.hould no be delayed while corrective actions are being taken toisolae the wate

[The site spntr~c arnear 'r'udc those a~rcasm t haGt conetain systenms r-cguircd for safe shutdown of the plant-,

whiich arc not designed to he par-tially or-fully suobmor-gd. The plnt's IPE-EF ma~y provido insight into afroas-1 to9 bo conidro whn dovoloping this EAL.]

This EIALaddr*esses the thre.at^ toA, isafety related equipment imposed by PROJECTILEs generated by main turbine Irotating component failures. T-herefore, this EAL is cnsistent with the definitio of an ALRT in that the potential exists for actual or substantfial potenitial degradation of the levoel.of safiety of the plant&

Note that-this EAL would not noFrmally be applicable in cold shutdown, refueling, or dofuelod modcs s~ince-steam is not nor-mally available to rotate the m~ain turbine in these plant coend-itions. If semfro alte.rate SOurFees is being used to rotate the main turbineforttesting, then this L wo u.d be applic.able

[The site spoc-fic-list of aroas45 shoulbd incrluwdo all agroas coentaining safety strubc-turo-, systom,; or corngponent-,

their controls, and their-powor. supplios.]

This EAL addresses vehicle crashes within the PROTECTED AREA that results in VISIBLE DAMAGE to VITAL AREAS or indication of damage to safety structures, systems, or components containing functions and systems required for safe shutdown of the plant.

E-AL--"

This E.AL adrese ther site specific phenomena that-re-sult inVISIBLE DIAMA.AGE to VIT.A.L AR1E.AS or results in i nd-ication oef damage to safety structures, systems, or components containing functions, and systemAs required for safe sh-utdoAwnA o-f the plant (such as hurricane, flood, or sciche) that canalob precursors of mo-re serfious events.

[Sites subject to severe weather-as dofinod in tho NUMARC-station blac-rkout itaiosshoubld inc-ludeoan E-At based-on acrtivation o!f,esýereettha&.nitigaiton precoduros (o.g., procaoutionary,shutdowvns, diesel tosting, staff call outs, otcj].

IPEG

Reference:

NEI 99-01 Revision 5: HA1.5,

,Basis Reference(s):

ATTACHMENT (3)

Page 3-25 I=looeliRg as l:Jseel iR tl:lis EAL elescril3es a cORelitioR wl:lere ",.'ater is eRteriRg tl:le roOFA faster tl:laR iRstalleel eEll:Jij3FAeRt is caj3al3le of reFAoval, resl:JltiRg iR a rise of water level '.vitl:liR tl:le roOFA. ClassificatioR of tl:lis EAL sl:lOl:Jlel Rot l3e elelayeel '.vl:lile correcti'/e actioRs are l3eiRg takeR to isolate tl:le '.vater SOl:Jrce.

[The site sfJeeijie flFefJS iRdl:JEie #lase flr:flS tRflt eaRtfliR systeR'ls reEfI:Ji.'=efi Jar S9jfe sRl:JtfiawR 9f tRe fJtflRt, VlRieR flre Rat fiesigRefi ta Be fJflrtiflt/;' af JfJ:JU'I' sl:JBR'lergefi. TRe fJJflRt'S IPEEE R'lfly fJrBlt'ifie iRSigRt iRta flFeflS ta Be eaRsifier:fi wReR Eie~'eJBfJiRg #lis ElK]

Tl:lis EAL aelelresses tl:le tl:lreat to safety relateel eEll:Jij3FAeRt iFAj3oseell3y PROJECTILEs geRerateell3y FAaiR tl:Jrl3iRe rotatiRg COFAj30ReRt faill:Jres. Tl:lerefore, tl:lis EAL is cORsisteRt witl:l tl:le elefiRitioR of aR ALERT iR tl:lat tl:le j30teRtial e)(ists for actl:Jal or sl:Jl3staRtialj3oteRtial elegraelatioR of tl:le le'/elof safety of tl:le j3laRt.

Note tl:lat tl:lis EAL WOl:Jlel Rot RorFAally l3e aj3j3lical3le iR colel sl:ll:Jtelo"'IA, refl:JeliRg, or elefl:Jeleel FAoeles siRce steaFA is Rot RorFAally availal3le to rotate tl:le FAaiR tl:Jrl3iRe iR tl:lese j3laRt cORelitioRS. If steaFA froFA alteFAate SOl:Jrces is l3eiRg l:Jseel to rotate tl:le FAaiR tl:Jrl3iRe for testiRg, tl:leR tl:lis EAL '.vol:Jlell3e aj3j3lical3le iR tl:lese sl:ll:JtelOWR FAoeles.

[The site sfJeeijie list 9f fl,"'eflS sRal:JJfi iRetl:JEie flU flr:flS eaRtfliRiRg safety strl:Jetl:JFe, systeR'l, aF eaR'lfJaReRt, tRefF eaRtraJs, flRfi tReir fJawer Sl:JfJfJNes.]

This EAL addresses vehicle crashes within the PROTECTED AREA that results in VISIBLE DAMAGE to VITAL AREAS or indication of damage to safety structures, systems, or components containing functions and systems required for safe shutdown of the plant.

Tl:lis EAL aelelresses otl:ler site sj3ecific j3l:leROFAeRa tl:lat resl:Jlt iR VISI8LE DAMAGE to VITAL AREAS or resl:Jlts iR iRelicatioR of elaFAage to safety strl:Jctl:Jres, systeFAs, or COFAj30ReRts cORtaiRiRg fl:JRctioRs aRel systeFAs reEll:Jireel for safe sl:ll:JtelOWR of tl:le j3laRt (sl:Jcl:l as l:ll:JrriCaRe, flooel, or seicl:le) tl:lat caR also l3e j3reCl:JrSors of FAore seriol:Js eveRts.

[Sites sl:Jl3jeet ta selt'e,.:e wefltRer flS fiejiRefi iR tRe PJW.4ARC stfltiaR BJflekal:Jt iRitifltilt'es sRal:Jtfi iReJl:Jfie flR EAL Bflsefi aR fletir,cfltiaR af tRe se~'eFe VlefltReF R'litigfltiaR fJraeefil:Jr:s (e.g., fJr:efll:JtiaRfl!}' sRl:JtfiawRS, fiieset testiRg, stfJjf eflU al:Jts, ete.}.]

(PEG

Reference:

(NEI 99-01 Revision 5: HA 1.5.

iBasis Reference(~)i (None, ATTACHMENT (3)

Page 3-25

HIA3 EI I3~l

-n -i O--

n n- -r -i n-n AL E 1-in 1 8.0 Hazards 8.3

Man-Made Events 8.3.5 AALERTI

[NEI 99-01 Rev. 5 IC:1 Access to a VITAL AREA is prohibited due to release of toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of systems required to maintain safe operations or safely shutdown the reactor.

Operatii*g Mode Applicability: All PFPB loss/potential loss:]

Example Emergency Action Levels:

4.----

Access to a VITAL AREA. listed in Table 8.3' is prohibited due to toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of systems required to maintain safe operations or safely shutdown the reactor)

I Table 8.3 Plant Vital AreasI Control Building' Containment Building Auxiliary Building Intermediate BUilding Diesel Generator Buildin_(s)

Standby Auxiliary Feedwater Building' ATTACHMENT (3)

Page 3-26 Initiating Condition ALERT

~.o Hazard~

~.3

• Man.;Made Event~

I

, j

8.3~5ALER1j I

)

NEI 99-01 Rev. SIC:;

MA3 Access to a VITAL AREA is prohibited due to release of toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of systems required to maintain safe operations or safely shutdown the reactor.

Operating Mode Applicability: All

!FPB loss/~otential 1055:1 NI.A!

Example Emergency Action Levels:

1.

Access to a VITAL AREA~ listed in Table 8.3; is prohibited due to toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of systems required to maintain safe operations or

safel'y'shutdown the reactod I~I ----------T-a-b-le-8-.3---P-la-n-t-V-ita-I-A-r-ea~~

.Control Buildfng Containment Building

~..

AuxiliarY Buildind

~.

Intermediate Building Diesel Generator* Building.<§i

~.

Standby' AuxiliarY Feedwater Building ATIACHMENT (3)

Page 3-26

Screen House Basis:

Gases in a VITAL AREA can affect the ability to safely operate or safely shutdown the reactor.

The fact that SCBA may be worn does not eliminate the need to declare the event.

Declaration should not be delayed for confirmation from atmospheric testing if the atmosphere poses an immediate threat to life and health or an immediate threat of severe exposure to gases. This lcould be based upon documented analysis, indication of personal ill effects from exposure, or operating

'experience with.the hazards.-

If the equipment in the stated area was already inoperable, or out of service, before the event occurredI then this EAL should not be declared as it will have no adverse impact on the ability of the plant to safel operate or safely shutdown beyond that already allowed by Technical Specifications at the time of the An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment. This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.

An uncontrolled release of flammable gasses within a facility structure has the potential to affect safe operation of the plant by limiting either operator or equipment operations due to the potential for ignition and resulting equipment damage/personnel injury. Flammable gasses, such as hydrogen and acetylene, are routinely used to maintain plant systems (hydrogen) or to repair equipment/components (acetylene - used in welding). This EAL assumes concentrations of flammable gasses which can ignite/support combustion.

Escalation of this emergency classification level, if appropriate, will be based on System Malfunctions, Fission Product Barrier Degradation or Abnormal Rad Levels/ Radioactive Effluent 4c- [Ns.

PEG

Reference:

NEI 99-01 Revision 5:HA3.1

[Basis Reference(s)l' FN-oneI ATTACHMENT (3)

Page 3-27

• Screen Housd Basis:

Gases in a VITAL AREA can affect the ability to safely operate or safely shutdown the reactor.

The fact that SCBA may be worn does not eliminate the need to declare the event.

Declaration should not be delayed for confirmation from atmospheric testing if the atmosphere poses an immediate threat to life and health or an immediate threat of ~evere exposure. to gases. ThisCOlJ!d ~

ibased. upon d~cumented analysis, indiC()tion of personal ill effects from exposure, or operati~d

~penence with the hazardsr If the equipment in the stated area was already inoperable, or out of service, before the event occurred, fhen this EAL should not be declared as it will have no adverse impact on the ability of the plant to saf~

operate or safely shutdown beyond that already allowed by Technical Specifications at the time of the.

!eventj An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment. This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.

An uncontrolled release of flammable gasses within a facility structure has the potential to affect safe operation of the plant by limiting either operator or equipment operations due to the potential for ignition and resulting equipment damage/personnel injury. Flammable gasses, such as hydrogen and acetylene, are routinely used to maintain plant systems (hydrogen) or to repair equipment/components (acetylene - used in welding). This EAL assumes concentrations of flammable gasses which can ignite/support combustion.

Escalation of this emergency classification level, if appropriate, will be based on System Malfunctions, Fission Product Barrier Degradation or Abnormal Rad Levels / Radioactive Effluent -It !EAWs.

PEG

Reference:

!NEI 99-01 Revision 5: HA3.11

[Basis Reference(~)i

[None:

ATIACHMENT (3)

Page 3-27

ATTACHMENT (4)

Clean Copy of Proposed Ginna EALs R.E. Ginna Nuclear Power Plant, LLC November 30, 2009 ATTACHMENT (4)

Clean Copy of Proposed Ginna EALs R.E. Ginna Nuclear Power Plant, LLC November 30,2009

7.3 Loss of IndicationslAlarm/Communication Capability GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT PROCEED TO EPIP 1-4 1

PROCEED TO EPIP 1-3 PROCEED TO EPIP 1-2 PROCEED TO EPIP 1-1 7.3.4 Loss of the following for 15 minutes or longer:

6 or more of the following Control Room Annunciator panels

-A

-AA

-B

-C

-D

-E

-F

-G OR An approximate 75% reduction in Control Room safety system indications AND

- A significant transient in progress AND

- Compensatory indications are unavailable Mode Applicability:

- (1) Power Operations

- (2) Startup

- (3) Hot Shutdown

- (4) Hot Standby 7.3.3 Unplanned loss of the following for 15 minutes or longer:

6 or more of the following Control Room Annunciator panels

-A

-AA

-B

-C

-D

-E

-F

-G OR An approximate 75% reduction in Control Room safety system indications AND EITHER

- A significant transient in progress OR

- Compensatory indications are unavailable Mode Applicability:

- (1) Power Operations

- (2) Startup

- (3) Hot Shutdown

- (4) Hot Standby 7.3.1 Unplanned loss of the following for 15 minutes or longer:

6 or more of the following Control Room Annunciator panels

-A

-AA

-B

-C

-D

-E

-F

-G OR An approximate 75% reduction in Control Room safety system indications Mode Applicability:

- (1) Power Operations

- (2) Startup

- (3) Hot Shutdown

- (4) Hot Standby Page 25 of 30 ATTACHMENT (4)

Page-4-1 7.3 Loss of Indications/Alarm/Communication Capability GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT PROCEED TO EPIP 1-4 PROCEED TO EPIP 1-3 PROCEED TO EPIP 1-2 PROCEED TO EPIP 1-1 7.3.4 7.3.3 7.3.1 Loss of the following for Unplanned loss of the following Unplanned loss of the following 15 minutes or longer:

for 15 minutes or longer:

for 15 minutes or longer:

6 or more of the following 6 or more of the following 6 or more of the following Control Room Annunciator Control Room Annunciator Control Room Annunciator panels panels panels

-A

-A

-A

-AA

-AA

-AA

-8

-8

-8

-C

-C

-C

-D

-D

-D

-E

-E

-E

-F

-F

-F

-G

-G

-G OR OR OR An approximate 75% reduction An approximate 75% reduction An approximate 75% reduction in Control Room safety system in Control Room safety system in Control Room safety system indications indications indications AND AND EITHER Mode Applicability:

- A significant transient in

- A significant transient in

- (1) Power Operations progress progress

- (2) Startup AND OR

- (3) Hot Shutdown

- Compensatory indications are

- Compensatory indications are

- (4) Hot Standby unavailable unavailable Mode Applicability:

Mode Applicability:

- (1) Power Operations

- (1) Power Operations

- (2) Startup

- (2) Startup

- (3) Hot Shutdown

- (3) Hot Shutdown

- (4) Hot Standby

- (4) Hot Standby Page 25 of 30 ATIACHMENT (4)

Page 4-1

8.2 Fire or Explosion GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT PROCEED TO EPIP 1-4 PROCEED TO EPIP 1-3 PROCEED TO EPIP 1-2 PROCEED TO EPIP 1-1 8.2.2 8.2.1 Fire or explosion resulting in Fire in any of the following visible damage to:

areas not extinguished within Any of the following 15 minutes of:

structures containing safety Control Room notification systems or components OR OR

- Verification of a Control

- Control Room indication of Room fire alarm degraded performance of those safety systems

- Intermediate Building

- TSC Building

- Intermediate Building

- Service Building

- Control Building

- Contaminated Storage

- Containment Building Building

- Auxiliary Building

- Control Building

- Diesel Generator Building(s)

- Containment Building

- Standby Auxiliary

- Auxiliary Building Feedwater Building

- Turbine Building

- Screen House

- Diesel Generator Building(s)

Mode Applicability:

- Standby Auxiliary

-All Feedwater Building

- Screen House Mode Applicability:

-All ATTACHMENT (4)

Page 4-2 8.2 Fire or Explosion GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT PROCEED TO EPIP 1-4 PROCEED TO EPIP 1-3 PROCEED TO EPIP 1-2 PROCEED TO EPIP 1-1 8.2.2 8.2.1 Fire or explosion resulting in Fire in any of the following visible damage to:

areas not extinguished within Any of the following 15 minutes of:

structures containing safety Control Room notification systems or components OR OR

- Verification of a Control Control Room indication of Room fire alarm degraded performance of those safety systems

- Intermediate Building

- Intermediate Building

- TSC Building

- Service Building

- Control Building

- Contaminated Storage

- Containment Building Building

- Auxiliary Building

- Control Building

- Diesel Generator Building(s)

- Containment Building

- Standby Auxiliary

- Auxiliary Building Feedwater Building

- Turbine Building

- Screen House

- Diesel Generator Building(s)

Mode Applicability:

- Standby Auxiliary

-All Feedwater Building

- Screen House Mode Applicability:

-All ATTACHMENT (4)

Page 4-2

Page 27 of 30 8.3 Man-Made Events GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT PROCEED TO EPIP 1-4 PROCEED TO EPIP 1-3 PROCEED TO EPIP 1-2 PROCEED TO EPIP 1-1 8.3.4 8.3.1 Vehicle crash resulting in DELETED visible damage to:

8.3.2

- Any of the following Explosion within the protected structures containing safety area.

systems or components Mode Applicability:

OR

-All

- Control Room indication of 8.3.3 degraded performance of Toxic, corrosive, axphyxiant or those safety systems flammable gasses in amounts

- Intermediate Building that have or could

- Control Building adversely affect normal plant

- Containment Building.

operations

- Auxiliary Building OR

- Diesel Generator Building(s)

Report by local, county or

- Standby Auxiliary state officials for evacuation or Feedwater Building sheltering of site personnel Mode Applicability:

based on an off-site event

-All Mode Applicability:

-All ATTACHMENT (4)

Page 4-3 Page 27 of 30 8.3 Man-Made Events GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT PROCEED TO EPIP 1-4 PROCEED TO EPIP 1-3 PROCEED TO EPIP 1-2 PROCEED TO EPIP 1-1 8.3.4 8.3.1 Vehicle crash resulting in DELETED visible damage to:

8.3.2 Any of the following Explosion within the protected structures containing safety area.

systems or components Mode Applicability:

OR

-All Control Room indication of 8.3.3 degraded performance of Toxic, corrosive, axphyxiant or those safety systems flammable gasses in amounts

- Intermediate Building that have or could

- Control Building adversely affect normal plant

- Containment BUilding.

operations

- Auxiliary Building OR

- Diesel GeneratorBuilding(s)

Report by local, county or

- Standby Auxiliary state officials for evacuation or FeedwaterBuilding sheltering of site personnel Mode Applicability:

based on an off-site event

-All Mode Applicability:

-All ATTACHMENT (4)

Page 4-3

8.3 Man-Made Events GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT PROCEED TO EPIP 1-4 PROCEED TO EPIP 1-3 PROCEED TO EPIP 1-2 PROCEED TO EPIP 1-1 8.3.5 Access to a vital area listed below is prohibited due to toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of systems required to maintain safe operations or safely shutdown the reactor

- Control Building

- Containment Building

- Auxiliary Building

- Intermediate Building

- Diesel Generator Building(s)

- Standby Auxiliary Feedwater Building

- Screen House Mode Applicability:.

-All ATTACHMENT (4)

Page 4-4 8.3 Man-Made Events GENERAL EMERGENCY SITE AREA EMERGENCY ALERT UNUSUAL EVENT PROCEED TO EPIP 1-4 PROCEED TO EPIP 1-3 PROCEED TO EPIP 1-2 PROCEED TO EPIP 1-1 8.3.5 Access to a vital area listed below is prohibited due to toxic, corrosive, asphyxiant or flammable gases which jeopardize operation of systems required to maintain safe operations or safely shutdown the reactor

- Control Building

- Containment Building

- Auxiliary Building

- Intermediate Building

- Diesel Generator Building{s)

- Standby Auxiliary Feedwater Building

- Screen House Mode Applicability:...

-All ATIACHMENT (4)

Page 4-4

ATTACHMENT (5)

Plant-Specific EAL Guideline Cross Reference R.E. Ginna Nuclear Power Plant, LLC November 30, 2009 ATTACHMENT (5)

Plant-Specific EAL Guideline Cross Reference R.E. Ginna Nuclear Power Plant, LLC November 30, 2009

ATTACHMENT (5)

Plant-Specific EAL Guideline Cross Reference This Attachment compares the Plant-Specific EAL Guideline (PEG) references between NUMARC/NESP-007 and NEI 99-01 Revision 5 Ginna EAL NUMARC/NESP-007 PEG NEI 99-01 Revision 5 PEG 7.3.1 SU3.1 SU3.1 7.3.3 SA4.1 SA4.1 7.3.4 SS6.1 SS6.1 8.2.1 HU2.1 HU2.1 8.2.2 HA2.1 HA2.1 8.3.1 HU1.4 None 8.3.2 HU1.5 HU2.2 8.3.3 HU3.1, HU3.2 HU3.1, HU3.2 8.3.4 HA1.5 HA1.5 8.3.5 HA3.1, HA3.2 HA3.1 ATTACHMENT (5)

Page 5-1 ATTACHMENT (5)

Plant-Specific EAL Guideline Cross Reference This Attachment compares the Plant-Specific EAL Guideline (PEG) references between NUMARC/NESP-007 and NEI 99-01 Revision 5 Ginna EAL NUMARC/NESP-007 PEG NEI 99-01 Revision 5 PEG 7.3.1 SU3.1 SU3.1 7.3.3 SA4.1 SA4.1 7.3.4 SS6.1 SS6.1 8.2.1 HU2.1 HU2.1 8.2.2 HA2.1 HA2.1 8.3.1 HU1.4 None 8.3.2 HU1.5 HU2.2 8.3.3 HU3.1, HU3.2 HU3.1, HU3.2 8.3.4 HA1.5 HA1.5 8.3.5 HA3.1, HA3.2 HA3.1 ATIACHMENT (5)

Page 5-1

ATTACHMENT (6)

EAL Differences and Deviations R.E. Ginna Nuclear Power Plant, LLC November 30, 2009 ATTACHMENT (6)

EAL Differences and Deviations R.E. Ginna Nuclear Power Plant, LLC November 30, 2009

ATTACHMENT (6)

EAL Differences and Deviations This Attachment lists the differences and deviations for each EAL. NRC Regulatory Issue Summary (RIS) 2003-18 Supplement 2 defines Difference and Deviation for EAL changes.

Difference and Deviation A difference is an EAL change where the basis scheme guidance differs in wording but agrees in meaning and intent, such that classification of an event would be the same, whether using the basis scheme guidance or the site-specific proposed EAL.

Examples of differences include the use of site-specific terminology or administrative reformatting of site-specific EALs.

A deviation is an EAL change where the basis scheme guidance differs in wording and is altered in meaning or intent, such that classification of the event could be different between the basis scheme guidance and the site-specific proposed EAL. Examples of deviations include the use of altered mode applicability, altering key words or time limits, or changing words of physical reference (protected area, safety-related equipment, etc.).

ATTACHMENT (6)

Page 6-1 ATTACHMENT (6)

EAL Differences and Deviations This Attachment lists the differences and deviations for each EAL. NRC Regulatory Issue Summary (RIS) 2003-18 Supplement 2 defines Difference and Deviation for EAL changes.

Difference and Deviation A difference is an EAL change where the basis scheme guidance differs in wording but agrees in meaning and intent, such that classification of an event would be the same, whether using the basis scheme guidance or the site-specific proposed EAl.

Examples of differences include the use of site-specific terminology or administrative reformatting of site-specific EALs.

A deviation is an EAL change where the basis scheme guidance differs in wording and is altered in meaning or intent, such that classification of the event could be different between the basis scheme guidance and the site-specific proposed EAl. Examples of deviations include the use of altered mode applicability, altering key words or time limits, or changing words of physical reference (protected area, safety-related equipment, etc.).

ATTACHMENT (6)

Page 6-1

Current Ginna EAL NEI EAL Revised Ginna EAL 7.3.1 SU3.1 7.3.1 Unplanned loss of annunciators UNPLANNED Loss of greater than Unplanned loss of the following or indications on any of the approximately 75% of the for 15 minutes or longer:

following Control Room Panels following for 15 minutes or 6 or more of the following for greater than 15 minutes longer:

Control Room Annunciator A,AA,B,C,D,E,,G (Site specific control room safety panels A,AA,B,C,D,E,F,G AND system annunciation)

OR increased surveillance is OR An approximate 75% reduction required for safe plant operation (Site specific control room in Control Room safety system safety system indication) indications Site Specific 0

Added site specific annunciators that have safety system annunciation.

Defined safety system indications as the center and middle sections of the main control board.

Difference None Deviation None ATTACHMENT (6)

Page 6-2 Current Ginna EAL NEIEAL Revised Ginna EAL 7.3.1 SU3.1 7.3.1 Unplanned loss of annunciators UNPLANNED Loss of greater than Unplanned loss of the following or indications on any of the approximately 75% of the for 15 minutes or longer:

following Control Room Panels following for 15 minutes or 6 or more of the following for greater than 15 minutes longer:

Control Room Annunciator A,AA,B,C,D,E"G (Site specific control room safety panels A,AA,B,C,D,E,F,G AND system annunciation)

OR increased surveillance is OR An approximate 75% reduction required for safe plant operation (Site specific control room in Control Room safety system safety system indication) indications Site Specific Added site specific annunciators that have safety system annunciation.

Defined safety system indications as the center and middle sections of the main control board.

Difference None Deviation None ATTACHMENT (6)

Page 6-2

Current Ginna EAL NEI EAL Revised Ginna EAL 7.3.3 SA4.1 7.3.3 Unplanned loss of annunciators UNPLANNED loss of greater than Unplanned loss of the following or indications on any of the approximately 75% of the for 15 minutes or longer:

following Control Room Panels following for 15 minutes or 6 or more of the following for greater than 15 minutes longer:

Control Room Annunciator A,AA,B,C,D,E,F,G (Site specific control room safety panels A,AA,B,C,D,E,F,G AND system annunciation)

OR increased surveillance is (Site specific control room safety An approximate 75% reduction required for safe plant operation system indication) in Control Room safety system AND EITHER EITHER of the following:

indications A plant transient in progress A SIGNIFICANT TRANSIENT is AND EITHER OR in progress.

A significant transient in PPCS is unavailable e

Compensatory indications progress are unavailable.

OR Compensatory indications are unavailable Site Specific 0

Added site specific annunciators that have safety system annunciation.

0 Defined safety system indications as the center and middle sections of the main control board.

Difference None Deviation None ATTACHMENT (6)

Page 6-3 Current Ginna EAL NEI EAL Revised Ginna EAL 7.3.3 SA4.1 7.3.3 Unplanned loss of annunciators UNPLANNED loss of greater than Unplanned loss of the following or indications on any of the approximately 75% of the:

for 15 minutes or longer:

following Control Room Panels following for 15 minutes or 6 or more of the following for greater than 15 minutes longer:

Control Room Annunciator A,AA,B,C,D,E,F,G (Site specific control room safety panels A,AA,B,C,D,E,F,G AND system annunciation)

OR increased surveillance is (Site specific control room safety An approximate 75% reduction required for safe plant operation system indication) in Control Room safety system AND EITHER EITHER of the following:

indications A plant transient in progress

• A SIGNIFICANT TRANSIENT is AND EITHER OR in progress.

A significant transient in PPCS is unavailable

• Compensatory indications progress are unavailable.

OR Compensatory indications are unavailable Site Specific Added site specific annunciators that have safety system annunciation.

Defined safety system indications as the center and middle sections of the main control board.

Difference None Deviation None ATIACHMENT (6)

Page 6-3

Current Ginna EAL NEI EAL Revised Ginna EAL 7.3.4 SS6.1 7.3.4 Loss of annunciators or Loss of greater than Loss of the following for 15 indications on any of the approximately 75% of the minutes or longer:

following Control Room Panels following for 15 minutes or 6 or more of the following A,AA, B,C,D,E,F,G longer:

Control Room Annunciator AND (Site specific control room safety panels A,AA,B,C,D,E,F,G Complete loss of ability to system annunciation)

OR monitor any critical safety OR An approximate 75% reduction function status (Site specific control room safety in Control Room safety system AND system indication) indications A plant transient in progress AND AND A SIGNIFICANT TRANSIENT is in A significant transient in progress.

progress AND AND Compensatory indications are Compensatory indications are unavailable.

unav'ailable Site Specific 0

Added site specific annunciators that have safety system annunciation.

Defined safety system indications as the center and middle sections of the main control board.

Difference None Deviation None ATTACHMENT (6)

Page 6-4 Current Ginna EAL NEIEAL Revised Ginna EAL 7.3.4 SS6.1 7.3.4 Loss of annunciators or Loss of greater than Loss of the following for 15 indications on any of the approximately 75% of the minutes or longer:

following Control Room Panels following for 15 minutes or 6 or more of the following A,AA,B,C,D,E,F,G longer:

Control Room Annunciator AND (Site specific control room safety panels A,AA,B,C,D,E,F,G Complete loss of ability to system annunciation)

OR monitor any critical safety OR An approximate 75% reduction function status (Site specific control room safety in Control Room safety system AND system indication) indications A plant transient in progress AND AND A SIGNIFICANT TRANSIENT is in A significant transient in progress.

progress AND AND Compensatory indications are Compensatory indications are unavailable.

unaVailable Site Specific Added site specific annunciators that have safety system annunciation.

Defined safety system indications as the center and middle sections of the main control board.

Difference None Deviation None ATTACHMENT (6)

Page 6-4

Current Ginna EAL NEI EAL Revised Ginna EAL 8.2.1 HU2.1 8.2.1 Confirmed fire in any of the FIRE not extinguished within 15 Fire in any of the following areas following plant areas not minutes of control room not extinguished within 15 extinguished within 15 minutes notification or verification of a minutes of:

of control room notification control room FIRE alarm in ANY Control Room notification

- Intermediate Building of the following areas:

OR

- TSC Building Verification of a Control Room

- Service Building (site specific area list) fire alarm

- Contaminated Storage 0

Intermediate Building Building 9

TSC Building

- Control Building 0

Service Building

- Containment Building 0 Contaminated Storage

- Auxiliary Building Building

- Turbine Building

- Emergency Diesel R

Control Building Building B

Reactor Containment

- Standby Auxiliary Building Feedwater Building 0

Auxiliary Building

- Screen House a

Turbine Building 0

Diesel Generator Building(s) a Standby Auxiliary Feedwater Building Screen House Site Specific Listed Buildings that contain vital areas or in actual contact with vital areas.

Difference Moved "Control Room notification" and "Verification of Control Room fire alarm" into the EOP format for ease of use.

Deviation None ATTACHMENT (6)

Page 6-5 Current Ginna EAL NEI EAL Revised Ginna EAL 8.2.1 HU2.1 8.2.1 Confirmed fire in any of the FIRE not extinguished within 15 Fire in any of the following areas following plant areas not minutes of control room not extinguished within 15 extinguished within 15 minutes notification or verification of a minutes of:

of control room notification control room FIRE alarm in ANY Control Room notification

- Intermediate Building of the following areas:

OR

- TSC Building Verification of a Control Room

- Service Building (site specific area list) fire alarm

- Contaminated Storage Intermediate Building Building TSC Building

- Control Building

\\

• Service Building

- Containment Building

• Contaminated Storage

- Auxiliary Building Building

- Turbine Building

- Emergency Diesel

• Control Building Building

• Reactor Containment

- Standby Auxiliary Building Feedwater Building

• AuxiliarY Building

- Screen House

• Turbine Building Diesel Generator Building(s)

• Standby Auxiliary Feedwater Building

• Screen House Site Specific Listed Buildings that contain vital areas or in actual contact with vital areas.

Difference Moved "Control Room notification" and "Verification of Control Room fire alarm" into the EOP format for ease of use.

Deviation None ATIACHMENT (6)

Page 6-5

Current Ginna EAL NEI EAL Revised Ginna EAL 8.2.2 HA2.1 8.2.2 Fire or explosion in any of the FIRE or EXPLOSION resulting in Fire or explosion resulting in following plant areas which VISIBLE DAMAGE to ANY of the visible damage to:

EITHER following structures containing Any of the following results in visible damage to plant safety systems or components structures containing safety equipment or structures needed OR control room indication of systems or components for safe shutdown degraded performance of those OR OR safety systems:

- Control Room indication of affects safety system operability degraded performance of as indicated by degraded system (site specific structure list) those safety systems performance

- Intermediate Building

- Intermediate Building

- TSC Building

- Control Building

- Service Building

- Containment Building

- Contaminated Storage

- Auxiliary Building Building

- Diesel Generator Building(s)

- Control Building

- Standby Auxiliary

- Containment Building Feedwater Building

- Auxiliary Building

- Screen House

-Turbine Building

- Emergency Diesel Building

- Standby Auxiliary Feedwater Building

- Screen House Site Specific Listed Buildings that contain vital areas or in actual contact with vital areas.

Difference Inserted list of buildings into the middle of the EAL for ease of use.

Deviation ATTACHMENT (6)

Page 6-6 Current Ginna EAL 8.2.2 Fire or explosion in any of the following plant areas which EITHER results in visible damage to plant equipment or structures needed for safe shutdown OR affects safety system operability NEI EAL HA2.1 FIRE or EXPLOSION resulting in VISIBLE DAMAGE to ANY ofthe following structures containing safety systems or components OR control room indication of degraded performance of those safety systems:

as indicated by degraded system (site specific structure list) performance

- Intermediate Building

- TSC Building

- Service Building

- Contaminated Storage Building

- Control Building

- Containment Building

- Auxiliary Building

- Turbine Building

- Emergency Diesel Building

- Standby Auxiliary Feedwater Building

- Screen House Revised Ginna EAL 8.2.2 Fire or explosion resulting in visible damage to:

Any of the following structures containing safety systems or components OR

- Control Room indication of degraded performance of those safety systems

- Intermediate Building

- Control Building

- Containment Building

- Auxiliary Building

- Diesel Generator Building(s)

- Standby Auxiliary Feedwater Building

- Screen House Site Specific Listed Buildings that contain vital areas or in actual contact with vital areas.

Difference Inserted list of buildings into the middle of the EAL for ease of use.

Deviation ATIACHMENT (6)

Page 6-6

Current Ginna EAL NEI EAL Revised Ginna EAL 8.3.1 None DELETED Vehicle crash into or projectile which impacts plant structures or systems within Protected Area Boundary Site Specific Difference Deviation ATTACHMENT (6)

Page 6-7 Current Ginna EAL NEI EAL Revised Ginna EAL 8.3.1 None DELETED Vehicle crash into or projectile which impacts plant structures or systems within Protected Area Boundary Site Specific Difference Deviation ATTACHMENT (6)

Page 6-7

Current Ginna EAL NEI EAL Revised Ginna EAL 8.3.2 HU2.2 8.3.2 Report by plant personnel of an EXPLOSION within the Explosion within the protected explosion within Protected Area PROTECTED AREA.

area.

Boundary resulting in visible damage to permanent structures or equipment Site Specific None Difference None Deviation None ATTACHMENT (6)

Page 6-8 Current Ginna EAL NEI EAL Revised Ginna EAL 8.3.2 HU2.2 8.3.2 Report by plant personnel of an EXPLOSION within the Explosion within the protected explosion within Protected Area PROTECTED AREA.

area.

Boundary resulting in visible damage to permanent structures or equipment Site Specific None Difference None Deviation None ATTACHMENT (6)

Page 6-8

Current Ginna EAL NEI EAL Revised Ginna EAL 8.3.3 HU3.1 8.3.3 Report or detection of toxic or Toxic, corrosive, asphyxiarnt or Toxic, corrosive, axphyxiant or flammable gases that could flammable gases in amounts that flammable gasses in amounts enter or have entered within the have or could adversely affect that have or could have Protected Area Boundary in NORMAL PLANT OPERATIONS.

adversely affect normal plant amounts that could affect the HU3.2 operations health of plant personnel or safe Report by local, county or state OR plant operation officials for evacuation or Report by local, county or state OR sheltering of site personnel officials for evacuation or Report by local, county or state based on an off-site event, sheltering of site personnel officials for potential evacuation based on an off-site event.

of site personnel based on offsite event Site Specific None Difference None Deviation None ATTACHMENT (6)

Page 6-9 Current Ginna EAL NEI EAL Revised Ginna EAL 8.3.3 HU3.1 8.3.3 Report or detection of toxic or Toxic, corrosive, asphyxiant or Toxic, corrosive, axphyxiant or flammable gases that could flammable gases in amounts that flammable gasses in amounts enter or have entered within the have or could adversely affect that have or could have Protected Area Boundary in NORMAL PLANT OPERATIONS.

adversely affect normal plant amounts that could affect the HU3.2 operations health of plant personnel or safe Report by local, county or state OR plant operation*

officials for evacuation or Report by local, county or state OR sheltering of site personnel officials for evacuation or Report by local, county or state based on an off-site event.

sheltering of site personnel officials for potential evacuation based on an off-site event.

of site personnel based on offsite event Site Specific None Difference None Deviation None ATIACHMENT (6)

Page 6-9

Current Ginna EAL NEI EAL Revised Ginna EAL 8.3.4 HA1.5 8.3.4 Vehicle crash or projectile Vehicle crash resulting in VISIBLE Vehicle crash resulting in visible impact which precludes DAMAGE to ANY of the following damage to:

personnel access to or damages structures containing safety Any of the following structures equipment in the following plant systems or components OR containing safety systems or vital areas control room indication of components

- Control Building degraded performance of those OR

- Containment Building safety systems:

Control Room indication of

- Auxiliary Building degraded performance of those

- Intermediate Building (site specific structure list) safety systems

- Emergency Diesel Building e

Control Building

- Standby Auxiliary 0

Containment Building Feedwater Building Auxiliary Building

- Screen House 0AxlayBidn S

Diesel Generator Building(s)

Standby Auxiliary Feedwater Building Screen House Site Specific Listed buildings that contain safety systems or components Difference Added colon to format EAL into the EOP format for ease of use.

Deviation None ATTACHMENT (6)

Page 6-10 Current Ginna EAL NEI EAL Revised Ginna EAL 8.3.4 HA1.S 8.3.4 Vehicle crash or projectile Vehicle crash resulting in VISIBLE Vehicle crash resulting in visible impact which precludes DAMAGE to ANY of the following damage to:

personnel access to or damages structures containing safety Any of the following structures equipment in the following plant systems or components OR containing safety systems or vital areas control room indication of components

- Control Building degraded performance of those OR

- Containment Building safety systems:

Control Room indication of

- Auxiliary Building degraded performance of those

- Intermediate Building (site specific structure list) safety systems

- Emergency Diesel Building

• Control Building

- Standby Auxiliary Containment Building Feedwater Building

• Auxiliary Building

- Screen House Diesel Generator Building(s)

• Standby Auxiliary Feedwater Building

• Screen House Site Specific Listed buildings that contain safety systems or components Difference Added colon to format EAL into the EOP format for ease of use.

Deviation None ATTACHMENT (6)

Page 6-10

Current Ginna EAL NEI EAL Revised Ginna EAL 8.3.5 HA3.1 8.3.5 Report or detection of toxic or Access to a VITAL AREA is Access to a vital area listed flammable gases within the prohibited due to toxic, below is prohibited due to toxic, following plant vital areas, in corrosive, asphyxiant or corrosive, asphyxiant or concentrations that will be life flammable gases which flammable gases which threatening to plant personnel jeopardize operation of systems jeopardize operation of systems or precludes access to required to maintain safe required to maintain safe equipment needed for safe plant operations or safely shutdown operations or safely shutdown operations the reactor.

the reactor

- Control Building 0

Control Building

- Containment Building Containment Building

- Auxiliary Building e

Auxiliary Building

- Intermediate Building intermediate Building

- Emergency Diesel Building

- Standby Auxiliary Diesel Generator Building(s)

Feedwater Building 0

Standby Auxiliary Feedwater

- Screen House Building 0

Screen House Site Specific Listed vital plant areas Difference Listed vital plant areas to define the areas Deviation None ATTACHMENT (6)

Page 6-11 Current Ginna EAL NEI EAL Revised Ginna EAL 8.3.5 HA3.1 8.3.5 Report or detection of toxic or Access to a VITAL AREA is Access to a vital area listed flammable gases within the prohibited due to toxic, below is prohibited due to toxic, following plant vital areas, in corrosive, asphyxiant or corrosive, asphyxiant or concentrations that will be life flammable gases which flammable gases which threatening to plant personnel jeopardize operation of systems jeopardize operation of systems or precludes access to required to maintain safe required to maintain safe equipment needed for safe plant operations or safely shutdown operations or safely shutdown operations the reactor.

the reactor

- Control Building

• Control Building

- Containment Building

• Containment Building

- Auxiliary Building

• . Auxiliary Building

- Intermediate Building

• intermediate Building

- Emergency Diesel Building

- Standby Auxiliary

• Diesel Generator Building(s)

Feedwater Building Standby Auxiliary Feedwater

- Screen House Building Screen House Site Specific Listed vital plant areas Difference Listed vital plant areas to define the areas Deviation None ATTACHMENT (6)

Page 6-11