SBK-L-12062, License Amendment Request 12-01 Proposed Changes to Emergency Action Levels Regarding Safety System Indications

License Amendment Request 12-01 Proposed Changes to Emergency Action Levels Regarding Safety System Indications

ML12124A341
Person / Time
Site:	Seabrook
Issue date:	04/30/2012
From:	Freeman P NextEra Energy Seabrook
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
SBK-L-12062
Download: ML12124A341 (61)

Text

NExTeram ENERGY SEABROOK April 30, 2012 10 CFR 50.90 SBK-L-12062 Docket No. 50-443 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Seabrook Station License Amendment Request 12-01 Proposed Changes to Seabrook Station Emergency Action Levels Regarding Safety System Indications In accordance with the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), NextEra Energy Seabrook, LLC (NextEra) is submitting License Amendment Request (LAR) 12-01 to revise the Seabrook Station Emergency Plan. The proposed changes are associated with the initiating conditions involving a loss of safety system annunciation or indication in the control room. The current classification scheme includes emergency action levels (EAL) that could place the plant in an emergency classification based solely on a loss of radiation monitoring indications. However, a loss of radiation monitoring indications by itself does not represent degradation in the level of plant safety. Therefore, the proposed changes revise the EALs to include radiation monitoring indications within the aggregate of safety system indications that are considered when evaluating a loss of safety system indications rather than separate EALs. The changes are consistent with NEI 99-01, "Methodology for Development of Emergency Actions Levels," revision 5.

As discussed in the evaluation, the proposed change does not involve a significant hazards consideration pursuant to 10 CFR 50.92, and there are no significant environmental impacts associated with the change.

The Station Operation Review Committee has reviewed this LAR. NextEra has determined that with the proposed changes, the emergency plan will continue to meet the requirements in 10 CFR 50, Appendix E, and the planning standards of § 50.47(b). A copy of this LAR has been forwarded to the New Hampshire State Liaison Officer pursuant to 10 CFR 50.91 (b).

NextEra Energy Seabrook, LLC, P.O. Box 300, Lafayette Road, Seabrook, NH 03874

United States Nuclear Regulatory Commission SBK-L-12062 / Page 2 No new commitments are made as a result of this change.

NextEra requests NRC review and approval of LAR 12-01 with issuance of a license amendment by April 15, 2013 and implementation of the amendment within 90 days.

Should you have any questions regarding this letter, please contact Mr. Michael O'Keefe, Licensing Manager, at (603) 773-7745.

Sincerely, NextEra Energy Seabrook, LLC Paul Freeman Site Vice President Enclosure cc: NRC Region I Administrator J. G. Lamb, NRC Project Manager W. J. Raymond, NRC Senior Resident Inspector Mr. Christopher M. Pope, Director Homeland Security and Emergency Management New Hampshire Department of Safety Division of Homeland Security and Emergency Management Bureau of Emergency Management 33 Hazen Drive Concord, NH 03305 Mr. John Giarrusso, Jr., Nuclear Preparedness Manager The Commonwealth of Massachusetts Emergency Management Agency 400 Worcester Road Framingham, MA 01702-5399

NEXTVra ENER OYOK SEABROOK AFFIDAVIT The following information is enclosed in support of this License Amendment Request:

• NextEra Energy Seabrook's Evaluation of the Proposed Change I, Paul Freeman, Site Vice President of NextEra Energy Seabrook, LLC hereby affirm that the information and statements contained within this license amendment request are based on facts and circumstances which are true and accurate to the best of my knowledge and belief.

Sworn and Subscribed before me this 3D day of AVO* 2012 Paul Freeman Notary Pub# . Site Vice President

Enclosure NextEra Energy Seabrook's Evaluation of the Proposed Change

Subject:

Proposed Changes to Seabrook Station Emergency Action Levels Regarding Safety System Indications 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 Conclusion

6.0 REFERENCES

Attachments:

1. Comparison of the EALs in NEI 99-01, the current Seabrook EALs, and the proposed EALs.

2. Differences and deviations between the proposed EALs and NEI 99-01.

3. Marked up copy of EALs

4. Clean copy of EALs

5. Marked up copy of EAL technical basis

6. Clean copy of EAL technical basis I

1.0

SUMMARY

DESCRIPTION NextEra Energy Seabrook, LLC (NextEra) is proposing changes to the emergency action levels (EAL) associated with the initiating conditions involving a loss of safety system annunciation or indication in the control room. The current classification scheme includes EALs that could place the plant in an emergency action level based solely on a loss of radiation monitoring indications. These EALs are unnecessarily limiting and inconsistent with the intent of NEI 99-0 1, Methodology for Development of Emergency Action Levels, because the current scheme could result in an event declaration for a loss of radiation monitors, a condition that does not indicate a reduction in the level of safety of the plant. Therefore, the proposed changes revise the EALs to include radiation monitoring indications within the aggregate of safety system indications rather than separate EALs.

The proposed changes revise the EALs for the initiating conditions below:

Initiating Condition Classification Level EAL summary Description SU3 Unusual Event Loss of safety system indication SA4 Alert Loss of safety system indication SS6 Site Area Emergency Loss of safety system indication or annunciation The Attachments to this Enclosure include:

1. Comparison of the EALs in NEI 99-01, revision 5; the current Seabrook EALs, and the proposed EALs.

2. Differences and deviations between the proposed EALs and NEI 99-01.

3. Marked up copy of EALs

4. Clean copy of EALs

5. Marked up copy of EAL technical basis

6. Clean copy of EAL technical basis 2

2.0 DETAILED DESCRIPTION Below are the proposed changes to the EALS associated with initiating conditions SU3, SA4, and.SS6, which involve a.loss of safety system annunciation or indication in the control room. Changes from the current EALs are shown in bold italictype.

Initiating Condition SU3 Current EAL Proposed EAL Initiating Condition SU3 InitiatingCondition SU3 UNPLANNED loss of most or all safety UNPLANNED loss of most or all safety system annunciation or indication in the system annunciation or indication in the Control Room for > 15 minutes Control Room for > 15 minutes Op. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4 Emergency Action Level(s) Emergency Action Level(s)

Note: The Emergency Directorshould not wait until 15 minutes has elapsed,but should declare the event as soon as it is determinedthat the condition has exceeded, or will likely exceed 15 minutes.

1. UNPLANNED loss of approximately 75% 1. UNPLANNED loss of approximately 75%

or more of UA annunciators for > 15 or more of UA annunciators for > 15 minutes. minutes.

OR OR

2. UNPLANNED loss of approximately 75% 2. UNPLANNED loss of approximately 75%

or more of Main Control Board indications or more of the following safety-related for> 15 minutes. indications for> 15 minutes:

a. Safety-related indicationson the Main ControlBoards (MCBs)

AND

b. Radiation monitor indicationson CP-180 A andB.

OR

3. UNPLANNED loss of approximately 75%

or more of radiation monitor indications for> 15 minutes.

3

Initiating Condition SA4 Current EAL Proposed EAL Initiating Condition SA4 : - "" .... ', ' InitiatingCondition SA4 "'..........

UNPLANNED loss of most or all safety UNPLANNED loss of most or all safety system annunciation or indication in Control system annunciation or indication in Control Room with either (1) a SIGNIFICANT Room with either (1) a SIGNIFICANT TRANSIENT in progress, or (2) TRANSIENT in progress, or (2) compensatory indicators are unavailable compensatory indicators are unavailable Op. Modes: 1, 2, 3, 4 Op. Modes. 1, 2, 3, 4 Emergency Action Level(s) Emergency Action Level(s)

Note: The Emergency Directorshould not wait until 15 minutes has elapsed, but should declare the event as soon as it is determinedthat the condition has exceeded, or will likely exceed 15 minutes.

1. EITHER of thefollowing: (a or b)

1. a. UNPLANNED loss of approximately a. UNPLANNED loss of approximately 75% or more of UA annunciators for > 75% or more of UA annunciators for >

15 minutes. 15 minutes.

OR OR

b. UNPLANNED loss of approximately b. UNPLANNED loss of approximately 75% or more of Main Control Board 75% or more of the following safety-indications for> 15 minutes. relatedindications for> 15 minutes:

OR 1. Safety-related indicationson the Main ControlBoards (MCBs)

c. UNPLANNED loss of approximately AND 75% or more of radiation monitor 2. Radiationmonitor indicationson indications for> 15 minutes. CP-180A andB.

AND AND

2. Either of the following: (a or b) 2. EITHER of the following: (a or b)

a. A SIGNIFICANT TRANSIENT is in a. A SIGNIFICANT TRANSIENT is in progress. progress.

OR OR

b. Compensatory indications are b. Compensatory indications are unavailable. unavailable.

4

Initiating Condition SS6 Current EAL Proposed EAL InitiatingCondition SS6 InitiatingConditionSS6:..

Inability to monitor a SIGNIFICANT Inability to monitor a SIGNIFICANT TRANSIENT in progress TRANSIENT in progress Op. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4 Emergency Action Level(s) Emergency Action Level(s)

Note: The Emergency Directorshould not wait until 15 minutes has elapsed, but should declare the event as soon as it is determinedthat the condition has exceeded, or will likely exceed 15 minutes.

1. SIGNIFICANT TRANSIENT in 1. SIGNIFICANT TRANSIENT in progress. progress.

AND AND

2. EITHER of the following: (a or b)

2. a. Loss of approximately 75% or more a. Loss of approximately 75% or more of UA annunciators. of UA annunciatorsfor > 15 minutes.

OR OR

b. Loss of approximately 75% or more b. Loss of approximately 75% or more of Main Control Board indications, of the following safety-related OR indicationsfor > 15 minutes:

c. Loss of approximately 75% or more 1. Safety-related indicationson the of radiation monitor indications. Main ControlBoards (MCBs)

AND

2. Radiationmonitor indications on CP-180 A and B.

AND AND

3. Compensatory indications are 3. Compensatory indications are unavailable, unavailable.

AND AND

4. Complete loss of the ability to monitor all 4. Complete loss of the ability to monitor all Critical Safety Functions. Critical Safety Functions.

5

3.0 TECHNICAL EVALUATION

The Seabrook Station emergency classification scheme is based on NEI 99-01, Methodology for Development of Emergency Action Levels, revision4 [Reference 1],

which the NRC endorsed for use as guidance in developing or changing a standard emergency classification and action level scheme in Regulatory Issue Summary 2003-18

[Reference 2].

On February 22, 2008, the NRC accepted NEI 99-01, revision 5, as providing an acceptable basis for making EAL changes [Reference 3]. Therefore, the changes proposed in this request have been evaluated using the latest approved guidance in NEI 99-0 1, revision 5, which did not make significant changes to the EALs affected by the proposed changes.

This proposed change revises the EALs associated with initiating conditions SU3, SA4, and SS6. Initiating conditions SU3 and SA4 address an unplanned loss of safety system annunciation or indication in the control room, and SS6 involves the inability to monitor a significant event in progress. Attachment 1 provides a table that displays the EALs in NEI 99-01, revision 5, for these conditions; the current Seabrook Station EALs, and the proposed EALs.

Proposedchange to include radiationmonitors in aggregateof safety system indicators Initiating conditions SU3, SA4, and SS6 in NEI 99-01 are concerned with a loss of the ability to monitor changing plant conditions. Each of these initiating conditions contains an EAL that addresses a loss of greater than approximately 75% of the site specific control room safety system indication for 15 minutes or longer. Seabrook's implementation of this generic EAL established two separate EALs with an "or" logic, one for a loss of main control board indications and another for loss of radiation monitor indications. As a consequence, when evaluating SU3, the loss of greater than 75% of the radiation monitor indications in the control room would place the plant in an unusual event. Similarly, a loss of greater than 75% of the radiation monitor indications in the control room would meet the threshold for satisfying one attribute in the EAL logic for placing the plant in an emergency classification under initiating conditions SA4 and SS6.

The declaration of an emergency based only on a loss of radiation monitor indications is overly restrictive and inconsistent with the guidance in NEI 99-01. A loss of radiation monitor indications by itself does not meet the threshold for placing the plant in an emergency classification level. This condition does not indicate potential degradation in plant safety that presents a threat to public health and safety or to plant workers. NEI 99-01 does not provide a separate EAL for loss of radiation monitor indications; rather, the EAL specifies a loss of control room safety system indications. Radiation monitors are only one type of indicator included in the aggregate of control room safety system 6

indications. Therefore, the proposed change revises the EAL so that the control room safety indications include the combination of main control board indicators and radiation monitors.

The revised EALs provide more accurate and appropriate criteria for evaluating plant conditions for degradation in the level of safety. As a result,.the determination of.

protective measures that would be considered within and outside the site boundary to protect health and safety will more accurately reflect the threat posed by the plant conditions. The revised EALs will continue to protect the health and safety of the public and plant personnel by initiating an emergency response commensurate with the extent of degradation of plant safety.

Proposedchange to identify radiationmonitors that function as safety system indications The intent of initiating conditions SU3, SA4, and SS6 and their associated EALs is to recognize the difficulty associated with monitoring plant conditions following a loss of a major portion of safety system indications. The EALs are concerned with safety system indications; therefore, the radiation monitor indications involved with this EAL are the safety-related monitors. The safety-related radiation monitors are displayed in the Seabrook control room on panels CP-180A and CP-180B. Accordingly, the proposed change revises the EAL to specify that the radiation monitors of concern in this EAL are the safety-related radiation monitors on CP-1 80A and CP-1 80B.

A developer note in the generic basis for the affected initiating conditions discusses that the site specific control room safety system indications must include those identified in the abnormal operating procedures, emergency operating procedures, and in other EALs (e.g., area, process, and/or effluent radiation monitors, etc.). The initiating conditions, however, are concerned with "Safety System" indication. Safety-related systems are those required to function to achieve the system responses assumed in the plant safety evaluations and those needed to shut down the plant safely. Therefore, limiting the radiation monitoring instrumentation involved in these EALs to the safety related indications in the control room is consistent with the intent of the initiating condition, which is to address a loss of safety system indications Proposedchange to SS6 to add 15-minute durationfor loss of indication The proposed change to the EAL for SS6 adds a 15-minute duration for a loss of safety system annunciation or safety system indication. The current EAL does not specify a duration for the loss of indication, so the EAL is met immediately upon a loss of annunciation or indication. Adding the 15-minute criterion provides a threshold to exclude a loss of annunciation or indication that is the result of a transient or momentary power loss. This change is consistent with NEI 99-01, revision 5, which added the 15-minute criterion that was not included in revision 4.

7

Provosedchanve to add note to EALs The proposed change includes adding a note to the EALs for initiating conditions SU3, SA4, and SS6. The note states "The Emergency Director should not wait until 15 minutes has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed 15 minutes.'" The addition of this note is consistent with the intent of NEI 99-01.

Differences and Deviations Attachment 2 identifies differences and deviations between the proposed changes to the Seabrook EALs and the EALs in NEI 99-01. Regulatory Issue Summary (RIS) 2003-18, Supplement 2, "Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels," [Reference 4] defines differences and deviations.

A difference is an EAL change where the basis scheme guidance differs in wording but agrees in meaning and intent, such that classificationof an event would be the same, whether using the basis scheme guidance or the site-specific proposedEAL. Examples of differences include the use of site-specific terminology or administrativere-formatting 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 classificationof the event could be different between the basis scheme guidance and the site-specificproposedEAL.

Examples of deviations include the use of altered mode applicability,alteringkey words or time limits, or changing words ofphysical reference (protectedarea, safety-relatedequipment, etc.).

Attachments 3 and 4 provide markups and clean copies of the EALs, respectively, showing the proposed changes. Markups and clean copies of the revised EAL technical basis are provide in Attachments 5 and 6, respectively.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.47 establishes the standards for offsite emergency response plans for nuclear power reactors. 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 8

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. 1, Assessment Actions, states "The means to be used for determining the magnitude 1of, 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."

10 CFR 50.54, Conditions of licenses, paragraph (q)(4) states "The changes to a licensee's emergency plan that reduce the effectiveness of the plan as defined in paragraph (q)(1)(iv) of this section may not be implemented without prior approval by the NRC. A licensee desiring to make such a change after February 21, 2012 shall submit an application for an amendment to its license. In addition to the filing requirements of §§ 50.90 and 50.91, the request must include all emergency plan pages affected by that change and must be accompanied by a forwarding letter identifying the change, the reason for the change, and the basis for concluding that the licensee's emergency plan, as revised, will continue to meet the requirements in appendix E to this part and, for nuclear power reactor licensees, the planning standards of § 50.47(b)."

Conclusion Regulatory Guide 1.219, Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors [Reference 5], discusses that NRC approval could be required for a change to the logic of an EAL that would result in a particular event not being declared when the declaration would have occurred before the change.

The proposed changes will result in an event not being declared when the declaration would have occurred before the change. Therefore, the proposed changes reduce the effectiveness of the emergency plan and require NRC approval prior to implementation.

NextEra has determined that with the proposed changes, the emergency plan will continue to meet the requirements in 10 CFR 50, Appendix E, and the planning standards of § 50.47(b). The proposed changes are consistent with NEI 99-01.

The changecontains one variation from the developer note in the generic basis regarding the scope of radiation monitors that provide safety system indication.

However, the scope of radiation monitors proposed for consideration in the EALs includes the safety related radiation monitor indications in the control room, 9

which addresses a loss of safety system indications consistent with the intent of the generic EALs.

'4.2 Significant Hazards Consideration No Significant Hazards Consideration In accordance with 10 CFR 50.92, NextEra Energy Seabrook has concluded that the proposed change does not involve a significant hazards consideration (SHC).

The basis for the conclusion that the proposed change does not involve a SHC is as follows:

1. The proposed change does not involve a significant increase in the probability or consequences of an accidentpreviously evaluated The proposed changes to the Seabrook Station emergency plan do not impact the physical function of plant structures, systems, or components (SSCs) or the manner in which SSCs perform their design function. The proposed changes neither adversely affect accident initiators or precursors, nor alter design assumptions. The proposed changes do not alter or prevent the ability of operable SSCs to perform their intended function to mitigate the consequences of an initiating event within assumed acceptance limits. No operating procedures or administrative controls that function to prevent or mitigate accidents are affected by the proposed changes.

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

2. The proposed change does not create the possibility of a new or different kind of accidentfrom any previously evaluated The proposed changes will not impact the accident analysis. The changes do not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed), a change in the method of plant operation, or new operator actions. The proposed changes will not introduce failure modes that could result in a new accident, and the change does not alter assumptions made in the safety analysis. The proposed changes revise emergency action levels (EAL), which establish the thresholds for placing the plant in an emergency classification. EALs are not initiators of any accidents.

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

10

3. The proposed change does not involve a significantreduction in the margin of safety.

Margin of safety is associated with confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant system pressure boundary, and containment structure) to. limit the level of radiation dose to.the public.

The proposed changes are associated with the EALs and do not impact operation of the plant or its response to transients or accidents. The changes do not affect the Technical Specifications or the operating license. The proposed changes do not involve a change in the method of plant operation, and no accident analyses will be affected by the proposed changes.

Additionally, the proposed changes will not relax any criteria used to establish safety limits and will not relax any safety system settings. The safety analysis acceptance criteria are not affected by these changes. The proposed changes will not result in plant operation in a configuration outside the design basis.

The proposed changes do not adversely affect systems that respond to safely shutdown the plant and to maintain the plant in a safe shutdown condition.

The revised EALs provide more appropriate and accurate criteria for determining protective measures that should be considered within and outside the site boundary to protect health and safety. The emergency plan will continue to activate an emergency response commensurate with the extent of degradation of plant safety.

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

Based on the above, NextEra concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(b), and, accordingly, a finding of "no significant hazards consideration" is justified.

4.3 Conclusions 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's 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.

11

5.0 ENVIRONMENTAL CONSIDERATION

NextEra has evaluated the proposed amendment for environmental considerations. The review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirements.

However, the proposed amendment 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 offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendments meet the eligibility criterion for categorical exclusion set for 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 needs to be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. NEI-99-01, Methodology for Development of Emergency Action Levels, revision 4, January 2003

2. Regulatory Issue Summary 2003-18, "Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels," Revision 4, Dated January 2003; October 8, 2003

3. NRC letter "U.S. Nuclear Regulatory Commission Review and Endorsement of NEI 99-01, Revision 5, dated February 2008," February 22, 2008 (ADAMS accession No.

ML080430535)

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

5. Regulatory Guide 1.219, "Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors," November 2011 12

Attachment 1 Comparison of the EALs in NEI 99-01, revision 5; the current Seabrook EALs, And the proposed EALs

Attachment 1 Comparison of the EALs in NEI 99-01, the current Seabrook EALs, and the proposed EALs (Proposed changes to the Seabrook EAL are shown in bold italic type.)

Initiating Condition SU3 NEI 99-01, Rev. 5 Seabrook Procedure ER 1.1 - Current Seabrook Procedure ER 1.1 - Proposed Initiating Condition SU3 Initiating ConditionSU3 Initiating Condition SU3 UNPLANNED loss of safety system annunciation UNPLANNED loss of most or all safety system UNPLANNED loss of most or all safety system or indication in the control room for 15 minutes or annunciation or indication in the Control Room for annunciation or indication in the Control Room for longer. > 15 minutes > 15 minutes Op. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4 Emergency Action Level(s) Emergency Action Level(s) Emergency Action Level(s)

Note: The Emergency Director should not wait Note: The Emergency Directorshould not wait until the applicable time has elapsed, but until 15 minutes has elapsed,but should should declare the event as soon as it is declare the event as soon as it is determined that the condition has exceeded, determinedthat the condition has or will likely exceed, the applicable time. exceeded, or will likely exceed 15 minutes.

1. UNPLANNED loss of greater than 1. UNPLANNED loss of approximately 75% or 1. UNPLANNED loss of approximately 75% or approximately 75% of the following for 15 more of UA annunciators for > 15 minutes. more of UA annunciators for > 15 minutes.

minutes or longer:

a. (Site specific control room safety system annunciation)

OR OR OR

b. (Site specific control room safety system 2. UNPLANNED loss of approximately 75% or 2. UNPLANNED loss of approximately 75% or indication) more of Main Control Board indications for > more of the following safety-related 15 minutes. indications for > 15 minutes:

c. Safety-relatedindications on the Main Control Boards (MCBs)

AND

d. Radiation monitor indicationson CP-180 A and B.

OR

3. UNPLANNED loss of approximately 75% or more of radiation monitor indications for > 15 minutes.

I

Attachment 1 Comparison of the EALs in NEI 99-01, the current Seabrook EALs, and the proposed EALs (Proposed changes to the Seabrook EAL are shown in bold italic type.)

Initiatinq Condition SA4 NEI 99-01, Rev. 5 Seabrook Procedure ER 1.1 - Current Seabrook Procedure ER 1.1 - Proposed Initiating Condition SA4 InitiatingCondition SA4 InitiatingCondition SA4 UNPLANNED Loss of safety system annunciation UNPLANNED loss of most or all safety system UNPLANNED loss of most or all safety system or indication in the control room with EITHER (1) a annunciation or indication in Control Room with annunciation or indication in Control Room with SIGNIFICANT TRANSIENT in progress, or (2) either (1) a SIGNIFICANT TRANSIENT in either (1) a SIGNIFICANT TRANSIENT in compensatory indicators unavailable, progress, or (2) compensatory indicators are progress, or (2) compensatory indicators are Op. Modes: 1, 2, 3, 4 unavailable unavailable Op. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4 Emergency Action Level(s) Emergency Action Level(s) Emergency Action Level(s)

Note: The Emergency Director should not wait Note: The Emergency Directorshould not wait until the applicable time has elapsed, but until 15 minutes has elapsed,but should declare the event as soon as it is should declare the event as soon as it determined that the condition has is determined that the condition has exceeded, or will likely exceed, the exceeded, or will likely exceed 15 applicable time. minutes.

1. a. UNPLANNED loss of greater than 1. EITHER of the following: (a orb) approximately 75% of the following for 15 minutes or longer:

• (Site specific control room safety 1. a. UNPLANNED loss of approximately 75% a. UNPLANNED loss of approximately 75%

system annunciation) or more of UA annunciators for > 15 or more of UA annunciators for > 15 minutes. minutes.

OR OR OR

• (Site specific control room safety b. UNPLANNED loss of approximately 75% b. UNPLANNED loss of approximately 75%

system indication or more of Main Control Board indications or more of the following safety-related for > 15 minutes. indications for > 15 minutes:

OR 1. Safety-related indicationson the Main Control Boards (MCBs)

c. UNPLANNED loss of approximately 75% AND or more of radiation monitor indications for 2. Radiationmonitor indications on

> 15 minutes. CP-180 A and B.

AND AND

b. EITHER of the following: 2. Either of the following: (a or b) 2. EITHER of the following: (a or b) 2

Attachment 1 Comparison of the EALs in NEI 99-01, the current Seabrook EALs, and the proposed EALs (Proposed changes to the Seabrook EAL are shown in bold italic type.)

" A SIGNIFICANT TRANSIENT is in a. A SIGNIFICANT TRANSIENT is in a. A SIGNIFICANT TRANSIENT is in progress. progress. progress.

" Compensatory indications are OR OR unavailable

b. Compensatory indications are b. Compensatory indications are unavailable, unavailable.

Initiating Condition SS6 NEI 99-01, Rev. 5 Seabrook Procedure ER 1.1 - Current Seabrook Procedure ER 1.1 - Proposed Initiating Condition SS6 Initiating Condition SS6 Initiating Condition SS6 Inability to Monitor a SIGNIFICANT TRANSIENT Inability to monitor a SIGNIFICANT TRANSIENT Inability to monitor a SIGNIFICANT TRANSIENT in Progress. in progress in progress Op. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4 Emergency Action Level(s) Emergency Action Level(s) Emergency Action Level(s)

Note: The Emergency Director should not wait Note: The Emergency Directorshould not wait until the applicable time has elapsed, but until 15 minutes has elapsed, but should declare the event as soon as it is should declare the event as soon as it determined that the condition has is determined that the condition has exceeded, or will likely exceed, the exceeded, or will likely exceed 15 applicable time. minutes.

1. a. Loss of greater than approximately 75% of 1. SIGNIFICANT TRANSIENT in progress. 1. SIGNIFICANT TRANSIENT in progress.

the following for 15 minutes or longer: AND AND

2. EITHER of the following: (a or b)

• (Site specific control room safety 2. a. Loss of approximately 75% or more of a. Loss of approximately 75% or more of system annunciation) UA annunciators. UA annunciators for> 15 minutes.

OR OR OR

b. Loss of approximately 75% or more of b. Loss of approximately 75% or more of

" (Site specific safety system Main Control Board indications, the following safety-related indications indication) OR for > 15 minutes:

c. Loss of approximately 75% or more of 1. Safety-related indicationson the radiation monitor indications. Main Control Boards (MCBs)

AND 3

Attachment 1 Comparison of the EALs in NEI 99-01, the current Seabrook EALs, and the proposed EALs (Proposed changes to the Seabrook EAL are shown in bold italic type.)

2. Radiation monitor indications on CP-180 A and B.

AND AND AND

b. A SIGNIFICANT TRANSIENT is in 3. Compensatory indications are unavailable. 3. Compensatory indications are unavailable.

progress.

AND AND AND c Compensatory indications are unavailable. 4. Complete loss of the ability to monitor all 4. Complete loss of the ability to monitor all Critical Safety Functions. Critical Safety Functions.

4

Attachment 2 Differences and Deviations I

Attachment 2 Differences and Deviations Initiatinq Condition SU3 NEI 99-01, Rev. 5 Seabrook Procedure ER 1.1 - Proposed Differences and Deviations changes are shown in bold italic type Initiating Condition SU3 InitiatingCondition SU3 UNPLANNED loss of safety system UNPLANNED loss of most or all safety Note: Differences and deviations between NEI 99-01 and the annunciation or indication in the control system annunciation or indication in the Seabrook proposed changes are discussed below. Proposed room for 15 minutes or longer. Control Room for > 15 minutes changes to the Seabrook EALs are shown in bold italic type.

Op. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4 Emergency Action Level(s) Emergency Action Level(s)

Note: The Emergency Director should Note: The Emergency Directorshould not Difference not wait until the applicable time has wait until 15 minutes has elapsed, elapsed, but should declare the but should declare the event as The Seabrook-specific EAL replaces "the applicable time" used in event as soon as it is determined soon as it is determined that the NEI 99-01 with "15 minutes." This difference only adds specificity that the condition has exceeded, or condition has exceeded, or will to the note and is consistent with the intent of the generic EAL.

will likely exceed, the applicable likely exceed 15 minutes.

time. Deviation None

1. UNPLANNED loss of greater than 1. UNPLANNED loss of approximately 75%

approximately 75% of the following or more of UA annunciators for > 15 for 15 minutes or longer: minutes.

a. (Site specific control room safety (No change to current EAL) system annunciation)

OR OR

b. (Site specific control room safety 2. UNPLANNED loss of approximately Difference system indication) 75% or more of the following safety-related indications for > 15 minutes: The Seabrook-specific EAL identifies the site specific control

e. Safety-related indicationson the room safety indications for the generic EAL in NEI 99-01. Safety Main ControlBoards (MCBs) system indication includes the safety-related indications on the AND main control board and the safety-related radiation monitor f Radiationmonitor indications on indications in the control room, which are located on control CP-180 A and B. panels CP-180A and CP-180B. This difference from the generic EAL adds site-specific instrumentation to the EAL and is consistent with the intent of NEI 99-01.

I

Attachment 2 Differences and Deviations Although not part of the basis, the generic basis for this initiating condition includes a developer note, which discusses that the site specific indicators for this EAL must include those identified in the abnormal operating procedures, emergency operating procedures, and in other EALs (e.g., area, process, and/or effluent radiation monitors, etc.). The initiating condition, however, is concerned with "Safety System" indication. Safety-related systems are those required to function to achieve the system responses assumed in the plant safety evaluations and those needed to shutdown the plant safely. Therefore, limiting the instrumentation involved in this EAL to the safety related indications in the control room is consistent with the intent of the initiating condition, which is to address a loss of safety system indications. This variation from the developer note does not alter the intent of the EAL.

Deviation None 2

Attachment 2 Differences and Deviations Initiating Condition SA4 NEI 99-01, Rev. 5 Seabrook Procedure ER 1.1 - Proposed Differences and Deviations changes are shown in bold italic type InitiatingCondition SA4 InitiatingCondition SA4 Note: Differences and deviations between NEI 99-01 and the UNPLANNED Loss of Safety System UNPLANNED loss of most or all safety Seabrook proposed changes are discussed below. Proposed Annunciation or Indication in the Control system annunciation or indication in Control changeskoptheosebrooknEAs are showned bold ictpe.

Room With Either (1) a SIGNIFICANT Room with either (1) a SIGNIFICANT changes to the Seabrook EALs are shown in bold italic type.

TRANSIENT in Progress, or (2) TRANSIENT in progress, or (2)

Compensatory Indicators Unavailable. compensatory indicators are unavailable Op. Modes: 1, 2, 3, 4 Op. Modes: 1, 2, 3, 4 Emergency Action Level(s) Emergency Action Level(s)

Note: The Emergency Director should Note: The Emergency Directorshould not Difference not wait until the applicable time has wait until 15 minutes has elapsed, elapsed, but should declare the but should declare the event as The Seabrook-specific EAL replaces "the applicable time" used in event as soon as it is determined soon as it is determined that the NEI 99-01 with "15 minutes." This difference only adds specificity that the condition has exceeded, or condition has exceeded, or will to the note and is consistent with the intent of the generic EAL.

will likely exceed, the applicable likely exceed 15 minutes.

time. Deviation None

1. a. UNPLANNED loss of greater than 1. EITHER of the following: (a orb) Difference approximately 75% of the following for 15 minutes or longer: The Seabrook-specific EAL uses a format different from that in NEI 99-01. This administrative re-formatting is a difference from the generic EAL that does not alter the initiating condition, EAL, or logic scheme.

• (Site specific control room a. UNPLANNED loss of approximately safety system annunciation) 75% or more of UA annunciators for (No 'change to current EAL)

> 15 minutes.

OR OR 3

Attachment 2 Differences and Deviations (Site specific control room b. UNPLANNED loss of approximately Difference safety system indication 75% or more of the following safety-related indications for> 15 The Seabrook-specific EAL identifies the site specific control minutes: room safety indications for the generic EAL in NEI 99-01. Safety

1. Safety-related indications on system indication includes the safety-related indications on the the Main Control Boards main control board and the safety-related radiation monitor (MCBs) indications in the control room, which are located on control AND panels CP-180A and CP-180B. This difference from the generic

2. Radiation monitor indications EAL adds site-specific instrumentation to the EAL and is on CP-180 A and B consistent with the intent of NEI 99-01.

Although not part of the basis, the generic basis for this initiating condition includes a developer note, which discusses that the site specific indicators for this EAL must include those identified in the abnormal operating procedures, emergency operating procedures, and in other EALs (e.g., area, process, and/or effluent radiation monitors, etc.). The initiating condition, however, is concerned with "Safety System" indication. Safety-related systems are those required to function to achieve the system responses assumed in the plant safety evaluations and those needed to shutdown the plant safely. Therefore, limiting the instrumentation involved in this EAL to the safety related indications in the control room is consistent with the intent of the initiating condition, which is to address a loss of safety system indications. This variation from the developer note does not alter the intent of the EAL.

Deviation None AND

b. EITHER of the following: 2. EITHER of the following: (a or b)

" a. A SIGNIFICANT TRANSIENT is in (No change to current EAL)

A SIGNIFICANT TRANSIENT is in progress. progress.

" Compensatory indications OR are unavailable.

b. Compensatory indications are unavailable.

4

Attachment 2 Differences and Deviations Initiating Condition SS6 NEI 99-01, Rev. 5 Seabrook Procedure ER 1.1 - Proposed Differences and Deviations changes are shown in bold italic type Initiating Condition SS6 Initiating Condition SS6 Inability to Monitor a SIGNIFICANT Inability to monitor a SIGNIFICANT Note: Differences and deviations between NEI 99-01 and the TRANSIENT in Progress. TRANSIENT in progress Seabrook proposed changes are discussed below. Proposed Op. ModesN 1, Z 3, 4 Op. Modes: 1, Z 3, 4 changes to the Seabrook EALs are shown in bold italic type.

Emergency Action Level(s) Emergency Action Level(s)

Note: The Emergency Director should Note: The Emergency Directorshould not Difference not wait until the applicable time has wait until 15 minutes has elapsed, elapsed, but should declare the but should declare the event as The Seabrook-specific EAL replaces "the applicable time" used in event as soon as it is determined soon as it is determined that the NEI 99-01 with "15 minutes." This difference only adds specificity that the condition has exceeded, or condition has exceeded, or will to the note and is consistent with the intent of the generic EAL.

will likely exceed, the applicable likely exceed 15 minutes.

time. Deviation None

1. a. Loss of greater than 1. SIGNIFICANT TRANSIENT in approximately 75% of the progress. (No change to current EAL) following for 15 minutes or AND longer: 2. EITHER of the following: (a or b) Difference (Site specific control room a. Loss of approximately 75% or more of UA annunciators for > The Seabrook-specific EAL uses a format different from that in 15minutes. NEI 99-01. This administrative re-formatting is a difference from the generic EAL that does not alter the initiating condition, EAL, or logic scheme.

OR OR 5

Attachment 2 Differences and Deviations

b. Loss of approximately 75% or Difference

• (Site specific safety system more of the following safety-indication) related indications for> 15 The Seabrook-specific EAL identifies the site specific control minutes: room safety indications for the generic EAL in NEI 99-01. Safety

1. Safety-related indications system indication includes the safety-related indications on the on the Main Control Boards main control board and the safety-related radiation monitor (MCBs) indications in the E0fitrol room, which are located on control AND panels CP-180A and CP-180B. This difference from the generic

2. Radiationmonitor EAL adds site-specific instrumentation to the EAL and is indicationson CP-180 A and consistent with the intent of NEI 99-01.

B.

Although not part of the basis, the generic basis for this initiating condition includes a developer note, which discusses that the site specific indicators for this EAL must include those identified in the abnormal operating procedures, emergency operating procedures, and in other EALs (e.g., area, process, and/or effluent radiation monitors, etc.). The initiating condition, however, is concerned with "Safety System" indication. Safety-related systems are those required to function to achieve the system responses assumed in the plant safety evaluations and those needed to shutdown the plant safely. Therefore, limiting the instrumentation involved in this EAL to the safety related indications in the control room is consistent with the intent of the initiating condition, which is to address a loss of safety system indications. This variation from the developer note does not alter the intent of the EAL.

Deviation None AND AND

b. A SIGNIFICANT TRANSIENT is 3. Compensatory indications are in progress. unavailable.

AND AND (NO change to current EAL) c Compensatory indications are 4. Complete loss of the ability to monitor unavailable, all Critical Safety Functions.

6

Attachment 3 Marked up Copy of EALs

ER 1.1 Page43 Rev. 50 Figure 1 Initiating Conditions and Emergency Action Levels SYSTEM MALFUNCTION Initiating Condition -- UNUSUAL EVENT UNPLANNED loss of most or all safety system annunciation or indication in the Control Room for > 15 minutes Operating Mode Applicability: 1, 2, 3 and 4 Emergency Action Levels:

Note: The Emergency Director should not wait until 15 minutes has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed 15 minutes.

1. UNPLANNED loss of approximately 75% or more of UA annunciators for > 15 minutes.

• • OR **

2. UNPLANNED loss of approximately 75% or more of Main Control Bard thefollowing safety-related indications for > 15 minutes.

a. Safety-related indicationson the Main ControlBoards (MCBs)

AND

b. Radiation monitor indicationson CP-180 A and B.

3. UNPLANNED les of approximately 750% or more of radiaton monitor- indieations for > 15

ER 1.1 Page 49 Rev. 50 Figure 1 Initiating Conditions and Emergency Action Levels SYSTEM MALFUNCTION Initiating Condition -- ALERT 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 indicators are unavailable Operating Mode Applicability: 1, 2, 3 and 4 Emergency Action Levels:

Note: The Emergency Director should not wait until 15 minutes has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed 15 minutes.

1. EITHER of thefollowing: (a or b)

a. UNPLANNED loss of approximately 75% or more of UA annunciators for > 15 minutes.

OR

b. UNPLANNED loss of approximately 75% or more of Main Control Board thefollowing safety-relatedindications for > 15 minutes:

1. Safety-related indicationson the Main ControlBoards (MCBs)

AND

2. Radiation monitor indicationson CP-180 A and B.

OR

-- T ThTTbT A xThTI*T'* ! ---- ~ '*7~*fl/

c. U1NrL2AIT-rJ1u" tos1o approximately -""~ or-mere et raitatatn momiter inuietattans iorf 2-AND

2. Either of the following: (a or b)

a. A SIGNIFICANT TRANSIENT is in progress.

OR

ER 1.1 Page 50 Rev. 50 Figure 1 Initiating Conditions and Emergency Action Levels

b. Compensatory indications are unavailable.

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

ER 1.1 Page 55 Rev. 50 Figure 1 Initiating Conditions and Emergency Action Levels SYSTEM MALFUNCTION Initiating Condition -- SITE AREA EMERGENCY Inability to monitor a SIGNIFICANT TRANSIENT in progress Operating Mode Applicability: 1, 2, 3 and 4 Emergency Action Levels:

Note: The Emergency Director should not wait until 15 minutes has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed 15 minutes.

1. SIGNIFICANT TRANSIENT in progress.

AND

2. Either of thefollowing: (a or b)

a. Loss of approximately 75% or more of UA annunciatorsfor > 15 minutes..

OR

b. Loss of approximately 75% or more of Main Control Board the following safety-related indicationsfor > 15 minutes:

1. Safety-relatedindications on the Main ControlBoards (MCBs)

AND

2. Radiation monitor indicationson CP-180A and B.

OR G. Less of approeximately 75,0% or-mor-e of radiation monitor indications.

AND

3. Compensatory indications are unavailable.

ER 1.1 Page 56 Rev. 50 Figure 1 Initiating Conditions and Emergency Action Levels AND

4. Complete loss of the ability to monitor all Critical Safety Functions.

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

Attachment 4 Clean Copy of EALs

ER 1.1 Page43 Rev. 50 Figure 1 Initiating Conditions and Emergency Action Levels SYSTEM MALFUNCTION Initiating Condition -- UNUSUAL EVENT UNPLANNED loss of most or all safety system annunciation or indication in the Control Room for > 15 minutes Operating Mode Applicability: 1, 2, 3 and 4 Emergency Action Levels:

Note: The Emergency Director should not wait until 15 minutes has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed 15 minutes.

1. UNPLANNED loss of approximately 75% or more of UA annunciators for > 15 minutes.

• • OR **

2. UNPLANNED loss of approximately 75% or more of the following safety-related indications for >

15 minutes.

a. Safety-related indications on the Main Control Boards (MCBs)

AND

b. Radiation monitor indications on CP-180 A and B.

ER 1.1 Page49 Rev. 50 Figure 1 Initiating Conditions and Emergency Action Levels SYSTEM MALFUNCTION Initiating Condition -- ALERT 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 indicators are unavailable Operating Mode Applicability: 1, 2, 3 and 4 Emergency Action Levels:

Note: The Emergency Director should not wait until 15 minutes has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed 15 minutes.

I1. EITHER of the following: (a or b)

a. UNPLANNED loss of approximately 75% or more of UA annunciators for > 15 minutes.

OR

b. UNPLANNED loss of approximately 75% or more of the following safety-related indications for > 15 minutes-

1. Safety-related indications on the Main Control Boards (MCBs)

AND

2. Radiation monitor indications on CP-180 A and B.

AND

2. Either of the following: (a or b)

a. A SIGNIFICANT TRANSIENT is in progress.

OR

b. Compensatory indications are unavailable.

ER 1.1 Page 50 Rev. 50 Figure 1 Initiating Conditions and Emergency Action Levels NOTE SIGNIFICANT TRANSIENT is an UNPLANNED event involving one or more of the following: (1) automatic turbine runback >25% thermal reactor power, (2)- electrical load rejection >25% full electrical load, (3) Reactor Trip, (4) Safety Injection Activation, or (5) thermal power oscillations >10%

ER 1.1 Page 55 Rev. 50 Figure 1 Initiating Conditions and Emergency Action Levels SYSTEM MALFUNCTION Initiating Condition-- SITE AREA EMERGENCY-Inability to monitor a SIGNIFICANT TRANSIENT in progress Operating Mode Applicability: 1, 2, 3 and 4 Emergency Action Levels:

Note: The Emergency Director should not wait until 15 minutes has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed 15 minutes.

1. SIGNIFICANT TRANSIENT in progress.

AND

2. Either of the following: (a or b)

a. Loss of approximately 75% or more of UA annunciators for > 15 minutes..

OR

b. Loss of approximately 75% or more of the following safety-related indications for > 15 minutes:

1. Safety-related indications on the Main Control Boards (MCBs)

AND

2. Radiation monitor indications on CP-180 A and B.

AND

3. Compensatory indications are unavailable.

AND

4. Complete loss of the ability to monitor all Critical Safety Functions.

ER 1.1 Page 56 Rev. 50 Figure 1 Initiating Conditions and Emergency Action Levels NOTE SIGNIFICANT TRANSIENT is an UNPLANNED event involving one or more of the following: (1) automatic turbine runback >25% thermal reactor power, (2) electrical load rejection >.25% full electrical load, (3) Reactor Trip, (4) Safety Injection Activation, or (5) thermal power oscillations >10%

Attachment 5 Marked up Copy of EAL Technical Basis 0

EALDBD Rev. 32 SYSTEM MALFUNCTION Initiating Condition -- UNUSUAL EVENT UNPLANNED loss of most or all safety system annunciation-or indication in the Control Room for > 15 minutes Operating Mode Applicability: 1, 2, 3 and 4 Emergency Action Levels:

Note: The Emergency Directorshould not wait until 15 minutes has elapsed,but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed 15 minutes.

1. UNPLANNED loss of approximately 75% or more of UA annunciators for > 15 minutes.

• • OR **

2. UNPLANNED loss of approximately 75% or more of Main Control Board the following safety-related indications for > 15 minutes.

a. Safety-relatedindicationson the Main Control Boards (MCBs)

AND

b. Radiation monitor indicationson CP-180 A and B.

• • OR **

TThTTbT A~.TNTr'Th ~ C .. . ...* **.- _ /. - . . . .

- -- . JO Jl *_*= -

UI4.LUWg.L ioi- 0: approima-telv 7;z!5ý or-more of-rudiation monitor- ineteatuons for 15 minutes.

Basis:

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

"Planned"loss of annunciatorsor indicatorsincludes scheduled maintenance and testing activities.

The UA annunciators assist the operator in determining the cause of a reactor trip or safety injection. A following set of essential parameters is also monitored.

" Reactor Trip Signals

" ESF Actuation Signals Page 109 04/09/12

EALDBD Rev. 32

" Certain Technical Specification Deviations

" Important Systems 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.

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 IC is indicated during these modes of operation.

It is 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 10 CFR50.72. If the shutdown is not in compliance with the Technical Specification action, the Unusual Event is based on SU2.

DiisGussmon on RDMS Indications and the "76%" limit This section documents the numerical basis for the following statement.

.- ,If both RDMVS (VA X) hot computers are simultaneously lo. t removing radiation monitor display availability to both CP295 and the Main Plant computer,AD

2. At least 19 radiation monitor channels in Attachment B to AOP OS1252.04 are available, THEN

3. The number of lost radiate*n monitoring indica*i*onis 7.5%, AND

4. An Unusual Event declaration is*ROt required.

See the basis for Initiating Condition SM;A. fo-r a discuss6ion Of compensator,' measures to taken inth.eet that lost indications meet orF excGeed 75%.

Assumptions and Limitations:

" The scope of this assessment includes radiation monitorF indications, available in tho Control Room, from detectors located within seismic Category Istructures and/or at mRonitored effluent points. Indications from radiation monitors inthe Administration Buildin wee eXcluded to be consistent with NEI 99 01 guidance (i.e., limit to in plant montor).In addition, Administration Building monitors are not relied upon to asses reactor operation or nuclear safety.

" The seetdmonitor indications must be tho-se that would be assessed during the performance of AOPs and EOPs, and emergency action levels.

" Radiation monitors that are not routinely available in Modes 1, 2, 3 and 4 (i.e., they arc brough in sR.'e during Modes 5 o-r 6) were not included in this aseset since this Initiating Condition is applicable in Modes 1 through 4 only

" Boeth RIDIVS (VAX) host comnputers fail at the same time; monto iniatosnC 295 Page 110 04/09/12

EALDBD Rev. 32 and the MPCS are simultaneously lost.

" The idicGatiens on the safety related Control Panels CP R8A and GP 180B r available.

" The RM 6550 indication On the Control Room stanchioG near OP-295 remains available.

" All RM 80s in the feld, aRnd the associated local readouts, remain available.

Firs~t, determine the total ml-numbr of radiation mnontoridcain using the above assumptionS and limitations.

SArea Radiation Monitor indications - 30

- Process Radiation Monitor indications - 20

" Airborne Radiation MonR11itor

• indications - 25 [Note that RM 6528 is countedI times since this point simply displays the coretlmid/hi indication from RM 6528 1, 2 and 3.]

The total number of idctos-30 + 20 + 25 5 Operations provided input that the following mnientor indications are not referenced in EOPS or A;Ps. EP verfi*ed that these monitors are not necessary for evaluation of EALs.

• RM 6568 1, Norm (ED "A

" RM 6566 1, E~mergency CEVA SRM6531 1, PB Gas Ajusting the total number fo1 these mnitors yields 75 3*I-7-2 e Iitiating Condition SUI, an emergency declaration ma be required flost RDA AS indications meet or eXceed approximately 75%. Therefore, the number of available and compensator' indications should be apprimtely 26% or more of the total indications.

The total l Of indications necessary is 72*0.26 18.72; round to 1n-9 indicaivtionRs needed.

The following 22 monitor indications lP f. 190A, GP 18 OB, and RM6550 On the stanchioq near GP 295 ma" be counted towards this requirement

• Area Radiation Monitor indications e RM 6576 A and RM 6576 B e RM RM 6-550Q

• AiborFne Radiation Monitor niain

" RK 6548 displays 1 channel RM 6548 A!

" RK 6506A displays 2 channels RM 6506 ,A! and A2 oRK 6507A displays 2 c-hannels RM 6507 Al and A2

" RK 6506B displays 2 channels RM-6506 B! an B2

" RK 6507B displays 2 channels RM 6507 B! and B2

" RK 6526 displays RM-6526 1 and 2

" RK 6527A displays 2 channels RM 6527 ,A! and A2

" RK 6527B displays 2 channels RM 6527 BI and B2

" RK 6528 displays 4 channels RM 6528 1, RM 6528 2, RM 6528 3, and RM 6528-4, If less thanp 19 of the 22 indications listed are operable, than an Unusual Evenmt dec-laration is requiwed.

Page 111 04/09/12

EALDBD Rev. 32 The following table can be used to tabulate the total number of available radiation monitor indications for any given failure or set of failures. AS noted above, the required total i 9 Page 112 04/09/12

EALDBD Rev. 32 Table of Radiation Monitors A bale # INSTRUMENT C-HANlI DESCRIPTION LOCATIDN 1 RKR6506 A 4- CR East Air Intake 1 RM GP 180-A 2 1-RK-6506-A 2 CR East Air Intake 1 RM GP 1 3 1*RK 657-A- 4 Re+tAr Int+ak-e -1 RM OP 180A 4 4-RK-6507- A 2 CR West Air Intake 1 RM OP 180-A 5 RM RK 65761- Cont Hi Range Rad 1-RM O-P 180 A 6 .1-RK 6527 A 4- Gent Bl!dg Purge Line 1 RM OP 180 -A.

7 RK 6527-A -2 Cent Bldg Purge Line 1 RM OP 180 A 8 _RK 6526 1 Cant Par-tiUiate 1 RM OP 180 A g

1 R- 6526 GCent Gas 1RMGP180A 4o 1 RK 6548 Cant Gas Back-up 1-RM OP 180.4A 44 1 RK 6528 ow

.Range Plant Vent WR Gas 1 RM GP1 A 421 RK 6528 22 Mid Range (Note!) Plant Vent WR Gas 1 RM GP 180A

!-RK 6528 3 High Range (Note!) Plant Vent WR Gas 1 RM OP 180A 4 !RK-6528-4 EffluentI-eave Plant Vent WVR Gas 1-RM OP 180 A

.1 -RK6506*4 1- CR East Air Intake 1-RM GP 180 B 6 1 RK 6506 2 OR East Air Intake 1_RM OP 180 B 4-7 1!RK 6507-R 4- CR West Air Intake 1-RM OP 180 B 1-RK 6507 B 2 CR West Air intake 1-RM CP 18B 49 1 RI "65776B 4 G1nt Hi Range Rad 1 RM OP 180 B 2o 4 RK 6527 B 4 Cant Bldg Purge Line 1 RM OP 180 B 24 1-RK 6527-B 2 Cant Bldg Purge Line 1 RM OP 180 B 22 RM RM-6550 GR-AFea Stanchian near

______PP225 T.Note 1:/f W ,,w ,aneg mo.it.r is op."Mrabe, 6526- 2 mid r; nge and gMi 6528 3 hig ran go is assumed to be operable so green (opeF) LED light i

_ not -app~akea.

...... ,L ---- JL='--* ..... ,L L--

An Unusuail *event can *be e.aated .e,* to an t viai Wvif ir orn pelnsatery auo* n cGainn Be takeR Within 15 minutes Of maniRtar lass 9F a transient sinpragress

• v during the lass af

+;  ; A; +; *n RHHYFIG cl "m Rr- ri 160 Ofi-.

Page 113 04/09/12

EALDBD Rev. 32

Reference:

Attachment B to OS1252.04, Fai!ure of RDMS Computer or Control Room Radiation Mon*"ito.r Display. UFSAR section 7.5, Safety-Related Display Instrumentation Page 114 04/09/12

EALDBD Rev. 32 SYSTEM MALFUNCTION Initiating Condition -- ALERT 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 indicators are unavailable Operating Mode Applicability: 1, 2, 3 and 4 Emergency Action Levels:

Note: The Emergency Directorshould not wait until 15 minutes has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed 15 minutes.

1. EITHER of the following: (a or b)

a. UNPLANNED loss of approximately 75% or more of UA annunciators for > 15 minutes.

OR

b. UNPLANNED loss of approximately 75% or more of Main Control Board the following safety-related indications for > 15 minutes-

1. Safety-related indicationson the Main Control Boards (MCBs)

AND

2. Radiationmonitor indicationson CP-180 A and B.

OR

e. LJ1sPLAN'NED lesoffappr-a*XEimately 750% or- more of r-adiation monitor- n 4iA-4 A".4 for-> 15 mninutes.

AND

2. Either of the following: (a or b)

a. A SIGNIFICANT TRANSIENT is in progress.

OR

b. Compensatory indications are unavailable.

Basis:

Page 120 04/09/12

EALDBD Rev. 32 This IC and its associated EAL are intended to recognize the difficulty associated with monitoring changing plant conditions without the use of a major portion of the annunciation or indication equipment during a transient. Recognition of the availability of computer based indication equipment is considered (e.g., SPDS, plant computer, etc.).

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

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.

The UA annunciators assist the operator in determining the cause of a reactor trip or safety injection. A following set of essential parameters is also monitored.

" Reactor Trip Signals

" ESF Actuation Signals

" Certain Technical Specification Deviations

" Important Systems It is 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 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action, the Unusual Event is based on SU2.

"Compensatory indications" in this context includes computer-based information such as the Video Alarm System (VAS), Safety Parameter Display System (SPDS), etc. If both a major portion of the annunciation system and all computer monitoring are unavailable, the Alert is required. it respect to radiati*on monito indications, compensatory SOUrces of data are other RDMS consoles located outside the Control Room. Use of these consoles as a comnpensatory measure may require assigning dedicated cOm*muc*ators to relay information to the Control Reemn.

Compensator; actions for a significant loss of radiation moniRtor indications are specified in Attachment C of Procedure OS1252.0h. Implementation of these c.Mpe.satey' ac*tinS within 15 minutes9 06 su1fficient may preclude an Alert declaration based On SA4.

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 IC is indicated during these modes of operation.

Dais*ussein on RDMS Cmnensator': Measures and the "75%" limit Page 121 04/09/12

EALDBD Rev. 32 Thai sIection documents the numerical basis foF the 'OMpeRsator. actioRn preseRte in Procedu--re 0S1 252.04, Fmailure of RDMS Computer or Control Room-F Radiation Moni~tor Display.

These actionRS may be implemented in response to the loss of a signifficant number of RDMS indications i"nRthe Control Room. More spe*ifi*ally, timely implementation of these actions will obviate the need fr a.n Aler declaration since the "approximately 75% o/r more." EAI criterion Page 122 04/09/12

EALDBD Rev. 32 AssumWtions and Limitations:

" The.cope of this assessment includes radiation monitor indiations, available On the Control Room, from dctectorFs located within seismic Categor,' I structur~es and/or at monitored effluent points. Indications. from radiation monitorFs in the Administration Building were excluided to be consistent with NEI 99 01 guidance (i.e., limit to in plant noniRrGs). In addition, Admnifstration Building monit*r ae not.Frelied upon to assess reactor operation Or nuclear safety.

" The selected mon)itorF indicatio)Sns mut be those that would be assessed dupring he pen rnmaRne of AOP a*nd EDPs, and ermergency aGt*on levels.

i RadiatonR monitors that are not rou1tinely available in Modes 1, 2, 3 andi (i.e., they are1 brought in serAce duFring Modes 5 or 6) were not included in this assessmnent sine thiS Initiating Gondliion is appliGable in Modes through iiv;I i oliyl E3GtH MLPa IIU HS UUfp~iiU1~

G fil at te sam trie; rAGITOriw IRGIuaIcGRw OR up 4o and the MPCS are simul1taneously lost-

• The ind-ica-;tionsm on the safety related Control Pane-ls C-Pl R-QA. and GP 1808 remnain avafiable

• The RM 6550 indication on the Control ROOM stanchion near GP 295 remafins available.

• All RM 80s in the field, and the assocGiated local readouts, remain available.

First, dete~rmine the total number of radiation monitor indicationsG using the above assumptions and limitations.

" Area Radiation MonitorF indications - 30

" Process Radiation Moni~tor indications 0

" Airborne Radiation Moni~tor indications - 25 [Note that RM 6528 is coun~ted 4 tim~es since this point simply displays the Gcorrect le/mid/hi indication fromF RM 6528 1, 2 and 3.].

The total numoer of InuicationS - Au +~zzW *s Z /:)

O~perations provided input that the fc G~l~ wingmontorindcatonsare not referenc ?d OnEQPs oF

0. vl=r- V cl Con r"Wri WrIco C11-0 ri" rir"ýýOocjt-r "-Apý I 1ý "" " N 0 RDA 6568 1, Normal CE.A

_ R 6566 1, E.mergency CEVA RM 6531 1, WPB Gas II J I I II *l Adj6,,,qtg the total num-mer mtor thlese mnonitors yieldis 75 7 Perz Ini~tiating Condition SM4, an emergency declaration mnay be requirFed if lost RDMS indications meet or exceed approximately 75%. Therefore, the number of available and comnpensator; indications should be aprxmtely 26% Or mor~e of the total indications.

The total num~ber of .inaiations I= I=

necessary is 72 * .26 - 18.72 F~ ound to 19 indIcGations, needed.

Page 123 04/09/12

EALDBD Rev. 32 The followinOg 22 monRitorinictin fromF GP 180A, GP 180B, and RM6550 On the stanchion near GP 295 mna" be counted towards this requiremnent:

. Area Radiat-in Moni÷tor indication,

" RM 6576 A and RM 6576 B

" RM RM 6550)

" Airborne Radiation Monitor indications_

E) RK 65418 displays 1 channel RM 65418 -A!

" RK 6506A displays 2 channels RM 6506 Al andA2

" RK 6507A displays 2 channels RM 6507 Al and A2

" RK 6506B displays 2 channels RM 6506 B! and B2 oRK 6507B3 displays 2 channels RM -6507-81 and EB2

" RK 6526 displays RM 6526 1 and-2

" RK 6527A displays 2 channels RM 6527 Al and A2

" RK 6527B displays 2 channelrs RM 6527 B1 and EB2

" RK 6528 displays 4 hnnl RNA 6528 1, RM-6528 2, RMA 6528 3, and R 581 Inother words, if 19 of 22 indications in the Control Room are available, no specific comipensator' measures eurd!rto preclude an Alert declaration.

If less than; 19 of the radiation monEitor indications listed are NOT inOPERATE STATUS, then Attachment G to G, 1252.04, Failurep of RDAS* 4S; Computer or Co.ntrol Room Radiation Monitor Dis~play identifies additional local idton s asneet ?opnsate for the loss of an"f radiation mo*nRito indications dropping the co.int below 19, On a one for one basis.

WIth respect to tiFmni for implementation Of coIpensator' measures, note that EAL 1.G states, "UNPLANNED loss of approximately 75% or more of radiation monitor indications for 15 miRutes." EAL 2.b states, "ComrpeRsatr,' iRdiGations are u navailable. " IRother words, ar Aler, is required if 15 Minutes elapses after an UNPLANNED loss of approximately 75% Or more of radiation mon..ito indications, and there a. e no compensator' indications available (sufficient to get below the 75% riterion). For this reasn, the compensator' measures presented 091252.04 should be implemented within 15 minutes of the loss of both RDMS host The follo)wing table can be used to tabulate the total number of available radiation monitor indications for any given failure or set of failuires. As noted above, the required total i 9 Page 124 04/09/12

EALDBD Rev. 32 Table of Radiation Mon tors Available # INSTRUMENT GHANNE-L- DESCRIPTION LOCATION 4- RK-6506-A 4- CR East Air Intake I RM GP 180 A 2 1 RK 6506 A 2 CR East Air Intake 1 RM CP 180A, 3 1 RK 67A 4 GR West Air ntake 1 RM--P8-A 4 1-RK-6507-A 2 CR West Air Intake 1 RMCP8O 5 RM RK 6576 A ,,ont Hi Rage Rad 1-RM GP 180 A 6 4 A 4- C ,6527 ,nt Purge Line Bldg 1-RM OP 180--

7 1 RK-6527-A 2 Cant Bl!dg Purge Line 1 RM OP 18A 1RK-6.5264 I Cent Pa~icuate 1 RM OP 18A 1-RK 6526 ! GRMP 8OA.

g 1 RK*6"548 Cent Gas Bakup

- 1-RK 654 LowRaRge Plant Vent W.R Gas 1 RM GP-180 A

- 1-RK-65282- Mod Range (Nate!) Plant Vent VVR Gas

_1Z RK 652.8 3 High Range (Nate!) Plant Vent WVR Gas I RM G. 180 44 4 RK-65ffueR Leve4 Plant Vent WR Gas 1 RM CP 180 A 1*-RK- 6506B 4- CR East Air Intake 1 RM GP 180 B 4-6 1 *K-*5 2 CR East Air Wntake 1 RM CP 180 B 4-7 I RK-6507 B 4 CR West Air intake 1 RM CP 80 B 4- 4-RK 6507-B 2 CR WestAir Intake I-RM OP 180 B 4- 1-RK 6576 B 4 Cant Hi RaRnge Rad 1 RM CP 180 B 2-1 RK 6527 B 4 Cant Bl*dg Purge Line 1 1RM GP 1 B 24 1 RK 65 2 Cant Bldg Purge Line 1 RM CP1 180 B 22 RM-RM 6550 GR-AFea Stanchian nea TtNote 1., if WRGM low ran go mn~itor-is operable, PM 6528 2 m~id rneadP 6528 3 high range is asisumed to be operable soq gr~een (oper) LED light is notappfiGable-7

Reference:

Attachmnent B to 051252.01, Failure of RDMS Camnputer or Cantral Reeam Radiatien Manitar Display UFSAR section 7.5, Safety-Related Display Instrumentation Page 125 04/09/12

EALDBD Rev. 32 SYSTEM MALFUNCTION Initiating Condition -- SITE AREA EMERGENCY Inability to monitor a SIGNIFICANT TRANSIENT in progress Operating Mode Applicability: 1, 2, 3 and 4 Emergency Action Levels:

Note: The Emergency Directorshould not wait until 15 minutes has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed 15 minutes.

1. SIGNIFICANT TRANSIENT in progress.

AND

2. Either of the following: (a or b)

a. Loss of approximately 75% or more of UA annunciators for > 15 minutes..

OR

b. Loss of approximately 75% or more of Main Control Board the following safety-relatedindicationsfor > 15 minutes:

1. Safety-relatedindications on the Main Control Boards (MCBs)

AND

2. Radiation monitor indications on CP-180 A and B.

OR

e. Less of approximately 759%, or-more ef r-adiation monitor- indications.

AND

3. Compensatory indications are unavailable.

AND

4. Complete loss of the ability to monitor all Critical Safety Functions.

Basis:

Page 132 04/09/12

EALDBD Rev. 32 This IC and its associated EAL are intended to recognize the inability of the control room staff to monitor the plant response to a transient. A Site Area Emergency is considered to exist if the control room staff cannot monitor the Critical Safety Functions during a transient.

The UA annunciators assist the operator in determining the cause of a reactor trip or safety injection. A following set of essential parameters is also monitored.

N Reactor Trip Signals M ESF Actuation Signals 0 Certain Technical Specification Deviations 0 Important Systems 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.

"Compensatory indications" include analog/digital readouts, and computer-based information such as.the Video Alarm System (VAS) or Safety Parameter Display System (SPDS).

SIGNIFICANT TRANSIENT: is an UNPLANNED event involving one or more of the following:

(1) automatic turbine runback >25% thermal reactor power, (2) electrical load rejection >25%

full electrical load, (3) Reactor Trip, (4) Safety Injection Activation, or (5) thermal power oscillations >10%

"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.

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 IC is indicatedduring these modes of operation.

Reference:

UFSAR Section 7.5, Safety-Related Display Instrumentation.

Page 133 04/09/12

Attachment 6 Clean Copy of EAL Technical Basis

EALDBD Rev. 32 SYSTEM MALFUNCTION Initiating Condition -- UNUSUAL EVENT UNPLANNED loss of most or all safety system annunciation orindication in theControl Room for > 15 minutes Operating Mode Applicability: 1, 2, 3 and 4 Emergency Action Levels:

Note: The Emergency Director should not wait until 15 minutes has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed 15 minutes.

1. UNPLANNED loss of approximately 75% or more of UA annunciators for > 15 minutes.

• • OR **

2. UNPLANNED loss of approximately 75% or more the following safety-related indications for > 15 minutes.

a. Safety-related indications on the Main Control Boards (MCBs)

AND

b. Radiation monitor indications on CP-180 A and B.

Basis:

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

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

The UA annunciators assist the operator in determining the cause of a reactor trip or safety injection. A following set of essential parameters is also monitored.

U Reactor Trip Signals U ESF Actuation Signals U Certain Technical Specification Deviations U Important Systems Page 109 04/09/12 1

EALDBD Rev. 32 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.

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 IC is indicated during these modes of operation.-.

It is 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 10CFR50.72. If the shutdown is not in compliance with the Technical Specification action, the Unusual Event is based on SU2.

Reference:

UFSAR section 7.5, Safety-Related Display Instrumentation Page 110 04/11/12

EALDBD Rev. 32 SYSTEM MALFUNCTION Initiating Condition -- ALERT 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 indicators are unavailable Operating Mode Applicability: 1, 2, 3 and 4 Emergency Action Levels:

Note: The Emergency Director should not wait until 15 minutes has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed 15 minutes.

1. EITHER of the following: (a or b)

a. UNPLANNED loss of approximately 75% or more of UA annunciators for > 15 minutes.

OR

b. UNPLANNED loss of approximately 75% or more of the following safety-related indications for > 15 minutes-

1. Safety-related indications on the Main Control Boards (MCBs)

AND

2. Radiation monitor indications on CP-180 A and B.

AND

2. Either of the following: (a or b)

a. A SIGNIFICANT TRANSIENT is in progress.

OR

b. Compensatory indications are unavailable.

Basis:

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

Page 116 04/09/12 1

EALDBD Rev. 32 "Planned" loss of annunciators or indicators includes scheduled maintenance and testing activities.

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....

The UA annunciators assist the operator in determining the cause of a reactor trip or safety injection. A following set of essential parameters is also monitored.

" Reactor Trip Signals

" ESF Actuation Signals

" Certain Technical Specification Deviations M Important Systems It is 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 10 CFR 50.72. If the shutdown is not in compliance with the Technical Specification action, the Unusual Event is based on SU2.

"Compensatory indications" in this context includes computer-based information such as the Video Alarm System (VAS), Safety Parameter Display System (SPDS), etc. If both a major portion of the annunciation system and all computer monitoring are unavailable, the Alert is required.

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 IC is indicated during these modes of operation.

Reference:

UFSAR section 7.5, Safety-Related Display Instrumentation Page 117 04/09/12 I

EALDBD Rev. 32 SYSTEM MALFUNCTION Initiating Condition -- SITE AREA EMERGENCY Inability to monitor a SIGNIFICANT TRANSIENT in progress Operating Mode Applicability: 1, 2, 3 and 4 Emergency Action Levels:

Note: The Emergency Director should not wait until 15 minutes has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed 15 minutes.

1. SIGNIFICANT TRANSIENT in progress.

AND

2. Either of the following: (a or b)

a. Loss of approximately 75% or more of UA annunciators for > 15 minutes..

OR

b. Loss of approximately 75% or more of the following safety-related indications for > 15 minutes:

1. Safety-related indications on the Main Control Boards (MCBs)

AND

2. Radiation monitor indications on CP-1 80 A and B.

AND

3. Compensatory indications are unavailable.

AND

4. Complete loss of the ability to monitor all Critical Safety Functions.

Basis:

This IC and its associated EAL are intended to recognize the inability of the control room staff to monitor the plant response to a transient. A Site Area Emergency is considered to exist if the control room staff cannot monitor the Critical Safety Functions during a transient.

Page 124 04/09/12 1

EALDBD Rev. 32 The UA annunciators assist the operator in determining the cause of a reactor trip or safety injection. A following set of essential parameters is also monitored.

" Reactor Trip Signals

" ESF Actuation Signals

" Certain Technical Specification Deviations

" Important Systems 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.

"Compensatory indications" include analog/digital readouts, and computer-based information such as the Video Alarm System (VAS) or Safety Parameter Display System (SPDS).

SIGNIFICANT TRANSIENT: is an UNPLANNED event involving one or more of the following:

(1) automatic turbine runback >25% thermal reactor power, (2) electrical load rejection >25%

full electrical load, (3) Reactor Trip, (4) Safety Injection Activation, or (5) thermal power oscillations >10%

"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.

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 IC is indicated during these modes of operation.

Reference:

UFSAR Section 7.5, Safety-Related Display Instrumentation.

Page 125 04/09/12 1