RA-14-032, Clinton, Unit 1, Attachment 4, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1003, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 4A and 4B, Cover - Cl 3-73

Clinton, Unit 1, Attachment 4, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1003, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 4A and 4B, Cover - Cl 3-73

ML14164A062
Person / Time
Site:	Clinton
Issue date:	05/30/2014
From:	Exelon Generation Co
To:	NRC/FSME, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML14164A053	List: ML14164A054 ML14164A055 ML14164A056 ML14164A058 ML14164A060 ML14164A061 ML14164A062 ML14164A063 ML14164A064 ML14164A065 ML14164A066 ML14164A067 ML14164A068 ML14164A069 ML14164A071 ML14164A073 ML14164A076 ML14164A079 NEI 99-01, Braidwood, Units 1 and 2, Attachment 2, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1001, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 2A, and 2B, Cover Through Pa NEI 99-01, Byron, Units 1 and 2, Attachment 3, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1002, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosures 3A, 3B, Cover - by 3-74 NEI 99-01, Byron, Units 1 and 2, Attachment 3, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1002, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosures 3B, 3C, by 3-75 - by 3-157 NEI 99-01, Clinton, Unit 1, Attachment 4, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1003, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 4A and 4B, Cover - Cl 3-73 NEI 99-01, Clinton, Unit 1, Attachment 4, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1003, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 4B and 4C, Cl 3-74 - Cl 3-151 NEI 99-01, Dresden, Units 2 & 3, Attachment 5, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1004, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 5A and 5B, Cover - Dr 3-76 NEI 99-01, Dresden, Units 2 & 3, Attachment 5, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1004, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 5B and 5C, Dr 3-77 - Dr 3-160 NEI 99-01, LaSalle, Units 1 & 3, Attachment 6, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1005, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 6A and 6B, Cover - LS 3-74 NEI 99-01, License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors. RA-14-032, Attachment 10: Discussion of Revision to the Radiological Emergency Plan Annex for Quad Cities Nuclear Power Station, Page QC 3-69 Through End RA-14-032, Attachment 11: Discussion of Revision to the Radiological Emergency Plan Annex for Three Mile Island Nuclear Station, Page TMI 3-80 Through End RA-14-032, Attachment 7: Discussion of Revision to the Radiological Emergency Plan Annex for Limerick Generating Station. Cover Through Page LGS 3-69 RA-14-032, Attachment 7: Discussion of Revision to the Radiological Emergency Plan Annex for Limerick Generating Station. LGS 3-70 Page LGS 3-155 RA-14-032, Attachment 8: Discussion of Revision to the Radiological Emergency Plan Annex for Oyster Creek Nuclear Generating Station, Page Ocgs 3-76 Through End RA-14-032, Attachment 8: Discussion of Revision to the Radiological Emergency Plan Annex for Oyster Creek Nuclear Generating Station. Cover Through Page Ocgs 3-75 RA-14-032, Attachment 9: Discussion of Revision to the Radiological Emergency Plan Annex for Peach Bottom Atomic Power Station, Cover Through Page PBAPS 3-76 RA-14-032, Attachment 9: Discussion of Revision to the Radiological Emergency Plan Annex for Peach Bottom Atomic Power Station, Page PBAPS 3-77 Through End RA-14-032, Braidwood, Units 1 and 2, Attachment 2, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1001, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 2A, and 2B, Cover Through Pa RA-14-032, Byron, Units 1 and 2, Attachment 3, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1002, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosures 3A, 3B, Cover - by 3-74 RA-14-032, Byron, Units 1 and 2, Attachment 3, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1002, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosures 3B, 3C, by 3-75 - by 3-157 RA-14-032, Clinton, Unit 1, Attachment 4, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1003, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 4A and 4B, Cover - Cl 3-73 RA-14-032, Clinton, Unit 1, Attachment 4, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1003, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 4B and 4C, Cl 3-74 - Cl 3-151 RA-14-032, Dresden, Units 2 & 3, Attachment 5, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1004, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 5A and 5B, Cover - Dr 3-76 RA-14-032, Dresden, Units 2 & 3, Attachment 5, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1004, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 5B and 5C, Dr 3-77 - Dr 3-160 RA-14-032, LaSalle, Units 1 & 3, Attachment 6, Discussion of Revision to the Radiological Emergency Plan Annex, EP-AA-1005, NEI 99-01, Rev. 6, Development of Emergency Action Levels for Non-Passive Reactors, Enclosure 6A and 6B, Cover - LS 3-74 RA-14-032, License Amendment Request to Adopt Emergency Action Level Schemes Pursuant to NEI 99-01, Revision 6, Development of Emergency Action Levels for Non-Passive Reactors. RS-14-115, Attachment 9: Discussion of Revision to the Radiological Emergency Plan Annex for Peach Bottom Atomic Power Station, Page PBAPS 3-77 Through End TMI-14-046, Attachment 8: Discussion of Revision to the Radiological Emergency Plan Annex for Oyster Creek Nuclear Generating Station, Page Ocgs 3-76 Through End
References
NEI 99-01, Rev 6, RA-14-032, RS-14-115, TMI-14-046 EP-AA-1003
Download: ML14164A062 (141)

Text

ATTACHMENT 4 DISCUSSION OF REVISION TO THE RADIOLOGICAL EMERGENCY PLAN ANNEX FOR CLINTON POWER STATION EP-AA-1003 Enclosures

• Enclosure 4A -EAL Comparison Matrix Document* Enclosure 4B -EAL Red-Line Basis Document* Enclosure 4C -EAL Basis Document NEI 99-01 REVISION 6 DEVELOPMENT OF EMERGENCY ACTION LEVELS FOR NON-PASSIVE REACTORS ATTACHMENT 4 DISCUSSION OF REVISION TO THE RADIOLOGICAL EMERGENCY PLAN ANNEX FOR CLINTON POWER STATION SExeLonGeneration, Hu611 NEH 99-01 Rev 6 Proposed EAL Justification AGI Initiating Condition

-GENERAL EMERGENCY Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5.000 mrem thyroid CDE.Operating Mode Applicability:

All Example Emergency Action Levels: (1 or 2 or 3)Notes:* The Emergency Director should declare the General Emergency promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

1. Reading on any of the following radiation monitors greater than the reading shown for 15 minutes or longer: (site specific monitor list and threshold values)2. Dose assessment actual meteorology indicates doses greater than 1000 mren TEDE or 5000 mrem thyroid CDE at or beyond (site specific dose receptor point)3. Field survey results indicate EITHER of the following at or beyond (site specific dose receptor point): " Closed window dose rates greater than 1000 mR/hr expected to continue for 60 minutes or longer." Analysis of field survey samples indicate thyroid CDE greater than 5000 mrem for one hour of inhalation.

RG1 Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mRem TEDE or 5,000 mRem thyroid CDE.Operating Mode Applicability:

1,2,3.4,5, D Emergency Action Level (EAL): Notes: " The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.* The pre-calculaled effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

1. The sum of readings on the HVAC and SGTS Radiation Monitors> 1.03 E+10 uCtisec (> 1.03 E+4 Cijsec) for>_ 15 minutes (as found on Control room Panels or PPDS -Total Noble Gas Release Rate).OR 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER: a. > 1000 mRem TEDE OR b. > 5000 mRem CDE Thyroid OR 3. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates >1000 mR/hr are expected to continue for > 60 minutes.OR b. Analyses of field survey samples indicate > 5000 mRem CDE Thyroid for 60 minutes of inhalation.

D No Change 1fj Difference 1: Deviation 1) Listed site-specific monitors and Threshold values to ensure timely classification.

2) Added the following to bullet #3" Classification based on effluent monitor readings assumes thaI a release path to the environment is established." In order to delete the following from the basis "Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 1 1x17 procedure matrix used by the SM.Page I of 66 0 NEI 99-01 Rev 6 Proposed EAL I Justification ASI Initiating Condition

-SITE AREA EMERGENCY Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE.Operating Mode Applicability:

All Example Emergency Action Levels: (1 or 2 or 3)Notes: The Emergency Director should declare the Site Area Emergency promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.9 The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

1. Reading on any of the following radiation monitors greater than the reading shown for 15 minutes or longer: (site specific monitor list and threshold values)2. Dose assessment actual meteorology indicates doses greater than 1000 mrem TEDE or 5000 mrem thyroid CDE at or beyond (site specific dose receptor point)3. Field survey results indicate EITHER of the following at or beyond (site specific dose receptor point): " Closed window dose rates greater than 100 mR/hr expected to continue for 60 minutes or longer." Analysis of field survey samples indicate thyroid CDE greater than 500 mrem for one hour of inhalation.

RS1 Initiating Condition:

Release of gaseous radioactivity resulting in oltsite dose greater than 100 mRem TEDE or 500 mRem thyroid CDE.Operating Mode Applicability:

1.2.3.4.5.

D Emergency Action Level (EAL): Notes: " The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or wifl likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

1. The sum of readings on the HVAC and SGTS Radiation Monitors > 1.03 E+09 uCilsec (I 1.03 E+3 Cilsec) for > 15 minutes (as found on Control room Panels or PPDS -Total Noble Gas Release Rate).OR 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER: a. > 100 mRem TEDE OR b. > 500 mRem CDE Thyroid OR 3. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates >100 mRlhr are expected to continue for > 60 minutes.OR b. Analyses of field survey samples indicate > 500 mRem CDE Thyroid for 60 minutes of inhalation.

D-- No Change E Difference

-] Deviation 1) Listed site-specific monitors and Threshold values to ensure timely classification.

2) Added the following to bullet 3" Classification based on effluent monitor readings assumes that a release path to the environment is established." In order to delete the following from the basis "Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and thereior readily available on the 11x17 procedure matrix used by the SM.Page 2 oli66 NEI 99-01 Rev 6 [ Proposed EAL I Justification AA1 Initiating Condition

-ALERT Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE.Operating Mode Applicability:

All Example Emergency Action Levels: (1 or2 or 3)Note: " The Emergency Director should declare the Alert promptly upon determining that the applicable time has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes." If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.* The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

1. Reading on any of the following radiation monitors greater than the reading shown for 15 minutes or longer (site-specific monitor tist and threshold values)2. Dose assessment actual meteorology indicates doses greater than 10 mrem TEDE or 50 mrern thyroid CDE at or beyond (site specific dose receptor point)3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond (site-specific dose receptor point) for one hour of exposure.4. Field survey results indicate EITHER of the following at or beyond (site specific dose receptor point): " Closed window dose rates greater than 10 mR/hr expected to continue for 60 minutes or longer." Analysis of field survey samples indicate thyroid CDE greater than 50 mrern for one hour of inhalation.

RAI Initiating Condition:

Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE.Operating Mode Applicability:

1,2, 3, 4, 5, D Emergency Action Level (EAL): Notes: " The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes." Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

1. The sum of readings on the HVAC and SGTS Radiation Monitors > 1.03 E+08 uCilsec (> 1.03 E+2 Ci/sec) for > 15 minutes (as found on Control room Panels or PPDS -Total Noble Gas Release Rate).OR 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER: a. > 10 mRem TEDE OR b. > 50 mRem CDE Thyroid OR 3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than EITHER of the following at or beyond the site boundary a. 10 mRem TEDE for 60 minutes of exposure OR b. 50 mRem CDE Thyroid for 60 minutes of exposure 11] No Change [ Difference F Deviation 1) Listed site-specific monitors and Threshold values to ensure timely classification.

2) Added the following to bullet #3 "Classification based on effluent monitor readings assumes that a release path to the environment is established." In order to delete the following from the basis "Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 1 1x17 procedure matrix used by the SM.3) Calculation was performed to determine the radiation monitor response for a radioactive liquid release with an activity equivalent to provide t0mrem TEDE or 50mrem thyroid CDE at the site boundary via the normal site release pathway. The calculation determined the radwaste liquid discharge system is not being maintained.

The effluent radiation monitor is not calibrated, as such if a release did occur through the system it would not display an accurate reading for the release.Since the liquid radwaste system is not operable.

no EAL Alert threshold will be developed for this point.4.OR Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates > 10 mRlhr are expected to continue for a 60 minutes.OR b. Analyses of field survey samples indicate >50 mRem CDE Thyroid for 60 minutes of inhalation.

Page 3 of 66 NEI 99-01 Rev 6 Proposed EAL Justification AU1 Initiating Condition

-UNUSUAL EVENT Release of gaseous or liquid radioactivity greater than 2 times the (site-specific effluent release controlling document) limits for 60 minutes or longer Operating Mode Applicability:

All Example Emergency Action Levels: (1 or 2 or 3)Note: " The Emergency Director should declare the Unusual Event promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded." If an ongoing release is detected and the release start time is unknown.assume that the release duration has exceeded 60 minutes." If the effluent flow past an effluent monitor is known to have stopped, indicating that the release path is isolated.

the effluent monitor reading is no longer valid for classification purposes.1. Reading on ANY effluent radiation monitor greater than 2 times the (site-specific effluent release controlling document) limits for 60 minutes or longer.(site-specific monitor list and threshold values corresponding to 2 times the controlling document limits)2. Reading on ANY effluent radiation monitor greater than 2 times the alarm selpoint established by a current radioactivity discharge permit for 60 minutes or longer.3. Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times (site-specific effluent release controlling document limits) for 60 minutes or longer.RU1 Initiating Condition:

Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer.Operating Mode Applicability:

1. 2, 3,4.5, D Emergency Action Level (EAL): Notes: " The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes." Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.1. VALID reading on any of the following effluent monitors > 2 times alarm setpoint established by a current radioactivity discharge permit for> 60 minutes." Radwaste Effluent Monitor 0RIX-PRO40 OR" Discharge Permit specified monitor OR 2. The sum of readings on the HVAC and SGTS Radiation Monitors> 1.17 E+06 uCilsec (> 1.17 Ci/sec) for > 60 minutes (as found on Control room Panels or PPDS -Total Noble Gas Release Rate).OR 3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 2 times ODCM Limit with a release duration of > 60 minutes.D-- No Change E- Difference

[:] Deviation 1) Listed site-specific monitors and Threshold values to ensure timely classification.

2) Added the following to bullet #3" Classification based on effluent monitor readings assumes that a release path to the environment is established." In order to delete the following from the basis "Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 1 Wl7 procedure matrix used by the SM.Page 4 of66 0 NEI 99-01 Rev 6 Proposed EAL Justification AG2 RG2 Initiating Condition

-GENERAL EMERGENCY A'--- No Change jj] Difference Deviation Spent fuel pool level cannot be restored to at least (site-specific Level 3 description) for 60 minutes or longer.1) EAL not used in accordance with the discussion in Section 1.4. NRC Order Operating Mode Applicability:

All EA-12-051.

it is recommended that this EAL be implemented when the enhanced spent fuel pool level instrumentation is available for use. The completon of the Example Emergency Action Levels: enhanced SFP level indicators and need for the inclusion of this EAL is being tracked in accordance with Exelon Generation Company. LLC's Initial Status NOTES: The Emergency Director should declare the General Emergency Reporn to March 12, 2012 Commission Order Modifying Licenses with Regard for promptly upon determining that 60 minutes has been exceeded.

Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) dated or will likely be exceeded October 25,2012.1. Spent fuel pool level cannot be restored to at least (site-specific Level 3 description) for 60 minutes or longer.Page 5 of 66 0 NEI 99-01 Rev 6 Proposed EAL Justification AS2 RS2 Initiating Condition

-SITE AREA EMERGENCY No Change Difference Deviation Spent fuel pool level cannot be restored to at least (site-specific Level 3 description)

1) EAL not used in accordance with the discussion in Section 1.4. NRC Order EA-1 2-051, it is recommended that this EAL be implemented when the enhanced Operating Mode Applicability:

All spent fuel pool level instrumentation is available for use. The completion of the enhanced SFP level indicators and need for the indusion of this EAL is being Example Emergency Action Levels: tracked in accordance with Exelon Generation Company. LLC's Initial Status Report to March 12. 2012 Commission Order Modifying Licenses with Regard for 1. Spent fuel pool level cannot be restored to at least (site-specific Level 3 Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) dated description)

October 25,2012.Page 6 of 66 0 0 NEI 99-01 Rev 6 Proposed EAL Justification AA2 Initiating Condition

-ALERT CRA2 F No Change Difference Deviation Significant lowering of water level above, or damage to, irradiated fuel. Significant lowering of water level above, or damage to. irradiated fuel. 1) Listed site-specific monitors and Threshold values to ensure timely classification.

Operating Mode Applicability:

All Operating Mode Applicability:

1. 2.3, 4.5, D 2) EAL #3 not used in accordance with the discussion in Section 1.4. NRC Oroer EA-12-051, it is recommended that this EAL be implemented when te enhanced Example Emergency Action Levels: (1 or 2 or 3) Emergency Action Level (EAL): spent fuel pool level instrumentation is available for use. The completion of the enhanced SFP level indicators and need for the inclusion of this EAL is being 1. Uncovery of irradiated fuel in the REFUELING PATHWAY. 1. Uncovery of irradiated fuel in the REFUELING PATHWAY. tracked in accordance with Exelon Generation Company, LLC's Initial Status OR Report to March 12, 2012 Commission Order Modifying Licenses with Regard for 2. Damage to irradiated fuel resulting in a release of radioactivity from the Reliable Spent Fuel Pool Instrumentafion (Order Number EA-12-051) dated fuel as indicated by ANY of the following radiation monitors:

2. Damage to irradialed fuel resulting in a release of radioactivily from the fuel October 25,2012.as indicated by ANY Table R1 Radiation Monitor reading >1000 mRemihr.(site-specific listing of radiation monitors, and the associated readings, setpoints and/or alarms) Table RI Fuel Handling Incident Radiation Monitors 3. Lowering of spent fuel pool level to (site-specific Level 2 value)." Fuel Building Exhaust (1 PRO06A-D)* CCP Exhaust (1PRO42A-D)" Containment Exhaust (IPR001A-D)" Containment Fuel xfer Plenum (1PR008A-D)

Page 7 o0166 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:

UNUSUAL EVENT AU2 Initiating Condition:

RU2 E No Change Differnce Deviation UNPLANNED loss of water level above irradiated fuel UNPLANNED loss of water level above irradiated fuel 1) Listed site specific level indication and monitors to ensure timely Operating Mode Applicability:

All Operating Mode Applicability:

classification.

1,2, 3,4, 5, D Example Emergency Action Levels: Emergency Action Level (EAL): 1. a. UNPLANNED water level drop in the REFUELING PATHWAY as 1. a.UNPLANNED water level drop in the REFUELING PATHWAY as indicated by indicated by ANY of the following:

ANY of the following: " Refueling Cavity water level < 22 ft. 8 in. above the Reactor (site-specific level indications).

Vessel Flange OR AND , Spent Fuel Pool or Upper Containment Fuel Storage Pool water level< 23 ft.b. UNPLANNED rise in area radiation levels as indicated by ANY of the OR following radiation monitors.

• Indication or report of a drop in water level in the REFUELING PATHWAY.(site-specific list of area radiation monitors)

AND b.UNPLANNED Area Radiation Monitor reading rise on one or more radiation monitors in Table RI.Table R1 Fuel Handling Incident Radiation Monitors* Fuel Building Exhaust (1PRO06A-D)

• CCP Exhaust (IPRO42A-D)

• Containment Exhaust (1 PR001A-D)* Containment Fuel xfer Plenum (1 PRO08A-D)Page 8 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification AA3 Initiating Condition

-ALERT Radiation levels that impede access to equipment necessary for normal plant operations, cooldown or shutdown.Operating Mode Applicability:

All Example Emergency Action Levels: (1 or 2)Note: If the equipment in the listed room or area was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted* Dose rate greater than 15 mR/hr in ANY of the following areas:* Control Room* Central Alarm Station ( )other site-specific areas/rooms)

• An UNPLANNED event results in radiation levels that prevent or significantly impede access to any of the following plant rooms or areas: (site-specific list of plant rooms or areas with entry-related mode applicability identified)

RA3 Initiating Condition:

Radiation levels that impede access to equipment necessary for normal plant operations, cooldown or shutdown.Operating Mode Applicability:

1,2, 3,4,5, D Emergency Action Level (EAL): Note:* If the equipment in the room or area listed in Table R3 was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted.

1. Dose rate> 15 mR/hr in ANY of the following Table R2 areas: No Change 1 Difference

[: Deviation 1) Listed site specific plant rooms and areas with identified mode applicability to ensure timely classification.

Table R2 Areas Requiring Continuous Occupancy" Main Control Room (1 RIX-AR035)" Central Alarm Station -(by survey)OR 2. UNPLANNED event results in radiation levels that prohibit or significantly impede access to ANY of the following Table R3 plant rooms or areas: Table R3 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Auxiliary Building*

Modes 3, 4, and 5 Auxiliary Building Steam Modes 4 and 5 Tunnel**Areas required to establish shutdown cooling Page 9 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:

UNUSUAL EVENT SU3 Initiating Condition:

RU3 E No Change Differnc H Deviation Reactor coolant activity greater than Technical Specification allowable limits. Reactor coolant activity greater than Technical Specification allowable limits. 1) Listed site-specific monitor and Threshold value to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

2) Listed this system category EAL in the radiological category EAL section to Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 maintain consistency with current and previous revisions of Exelon EALs. This wilt Example Emergency Action Levels: Emergency Action Level (EAL): ensure a timely classification since the threshold values are more aligned with the radiological category vice system category.1. (Site-specific radiation monitor) reading greater than (site-specific value). 1. Offgas post-treatment radiation monitor 1 RIX-PR035/41 channel 7 HI alarm.OR OR 2. Sample analysis indicates that a reactor coolant activity value is greater than 2. Specific coolant activity > 4.0 uClIgm Dose equivalent 1-131.an allowable limit specified in Technical Specifications.

Page 10 of 66 NEI 99-01 rev 6 Fission Product Barrier Matrix Fission_____________

Id Ir MtiGNRLMREYSTAAEEECHtix__l__" FGI Loss of any two barriers AND Loss or Potential Loss of third barrier. 1,2,3 FSI Loss or Potential Loss of ANY two barriers.

1,2,3 FAI ANY Loss or ANY Potential Loss of either Fuel Clad or RCS 1,2,3 FC -Fuel Clad RC -Reactor Coolant System CT -Containment Sub-Category Loss Potential Loss Loss Potential Loss Loss Potential Loss 1 RCS Activity / A. UNPLANNED rapid drop in primary A. Primary containment pressure greater Primary containment pressure following than (site-specific value)Piay A. (Site specific indications that piaycnanetpesr ieO Containment A. Primary containment pressure primary containment pressure rise OR Pressure reator coolant activity is greater None greater than (site-specific value) None OR B. (site-specific explosive mixture) exists Primary than 300 uCi/gm dose equivalent due to RCS leakage. inside primary containment Continment 1-131) B. Primary containment pressure Conitainnt response not consistent with LOCA OR Conditions conditions.

C. HCTL exceeded.A. RPV water level cannot be A. RPV water level cannot be A. Primary containment flooding restored and maintained above restored and maintained above 2. RPV water level required. (site-specific RPV water level (site-specific RPV water level Ne N A Primary containment flooding corresponding to top of active corresponding to the top of required.fuel) or cannot be determinedg active fuel) or cannot be determined.

A. UNISOLABLE direct downstream pathway to the environment exists after primary containment isolation signal OR A. UNISOLABLE primary system leakage A. tUNISOLABLE break in sy of the that results in exceeding EITHER of Intentional primary containment A. NIOLALEbrak n ny f he the followiing:

venting per EOPs 3.RCS Leak Rate/ following: ( site-specific systems with oMxowing venting pR Primary None None potential for highenergy line bras) 1. Max Normal Operating OR None Containment OR Temperature C. UNISOLABLE primary system Isolation Failure B OR leakage that results in exceeding B. Emergency RPV Depressurization

2. Max Normal Operating Area EITHER of the following:

Radiation Level. 1. Max Safe Operating Temperature.

OR 2. Max Safe Operating Area Radiation Level.4.Primary A. Primary Containment Radiation A. Primary Containment Radiation A. Primary Containment Radiation Monitor Containment Monitor reading greater than None Monitor reading greater than (site- None None reading greater than (site-specific Radiation (site-specific value), specific value). value).A. Any Condition in the opinion of the A. Any Conditon in the opinion of the A. ANY Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the Emergency 5. Emergency Emergency Director that indicates Loss Emergency Director that indicates Potential Emergency Director that indicates Loss of Emergency Director that indicates Potential Emergency Director that indicates Loss of the Director that indicates Potential Loss of the Director Judgment of the Fuel Clad Barrier. Loss of the Fuel Clad Barrier. the RCS Baraer. Low of the RCS Barrier. Containment Barrier. Containment Barrier.Page 11 of 66 Proposed Fission Product Barrier Matrix FisionProuctBarierMatix________RGNC I SITEAREAEMERGENCY I ALERT__Hot__Matrix I Ff31 Loss of any two barriers AND Loss or Potential Loss of third barrier. TEDn FSI Loss or Potential Loss of ANY two barriers.

Egj FAII ANY Loss or ANY Potential Loss of either Fuel Clad or RCS rni -FC -Fuel Clad RC -Reactor Coolant System CT -Containment Sub-Category Loss Potential Lose Loss Potential Loss Loss Potential Loss Coolant activity > 300 uClIgm Dose None None 1. RCS Activity Equivalent 1-131. None None None 2. RPV water level cannot be restored and 1. RPV water level cannot be restored and 2. RPV water level 1. Plant conditions indicate Primary maintained

' -162 Inches (TAF) maintained>

-162 Inches (TAF) Plant conditions indicate Primary Containment Containment flooding is required.

OR OR None None flooding is required.3. RPV water level cannot be determined.

2. RPV water level cannot be determined.

3. Primary Containment pressure > 15 psig and rising.1. UNPLANNED rapid drop in pnmary OR 1. Drywell pressure >1.68 psig. containment pressure following primary 4. a. Drywel[ hydrogen concentration

> 9%.3. Primary AND containment pressure rise. OR Containment None None 2. Drywell pressure rise is due to RCS None OR b. Containment Hydrogen concentration

_Pressure/Conditions leakage 2. Primary containment pressure response not SAG-2, Deflagration Limit.consistent with LOCA conditions.

OR 5. Heat Capacity Temperature Limit (EOP-6.Fig.P) exceeded.3. UNISOLABLE primary system leakage that results in EITHER of the following:

1. UNISOLABLE Main Steam Line (MSL), a. Secondary Containment area Feedwater, RWCU, or RCIC line break. temperature

> EOP-8 Maximum 4RCS Leak Rate None None OR Normal operating levels. None None 2. Emergency RPV Depressurization is OR required.

b. Secondary Containment radiation level> EOP-8 Maximum Normal operating level.1. Drywell radiation monitor reading > 260 1 Drywell radiation monitor reading > 1. Drywell radiation monitor reading > 590R/hr I>5Primary R/hr I> 2.60 E+02 R/hr). 100R/hr (>1.00 E+02 R/hr). 5.90 E+02 R/hr)Containment OR None OR None None OR Radiation

2. Containment radiation monitor reading 2 Containment radiation monitor reading > 2. Containment radiation monitor reading > 97> 41.3 RWhr (4.13 E+01 R/hr). 33 R/hr (>3.3 E+01 R/hr). Rihr (>9.70 E+01 R/hr)1. UNISOLABLE direct downstream pathway to the environment exists after primary containment isolation signal.OR 2. Intentional Primary Containment venting/purging per EOPs or SAGs due to accident conditions.

6.Primary OR Containment None NONE None None 3. UNISOLABLE primary system leakage that None Isolaietion Failure results in EITHER of the following:

a. Secondary Containment area temperature

> EOP-8, Maximum Safe operating levels.OR b. Secondary Containment radiation level > EOP-8, Maximum Safe operating levels.7 Emergency A. Any Condition in the opinion of the A. Any Condition in the opinion of the A. ANY Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the Emergency Emergency Director that indicates Loss Emergency Director that indicates Potential Emergency Director that indicates Loss of Emergency Director that indicates Potential Emergency Director that indicates Loss of the Director that indicates Potential Loss of the Director Judgment of the Fuel Clad Barrier. Loss of the Fuel Clad Barrier, the RCS Barrier. Loss of the RCS Barrier. Containment Barrier. Containment Barrier.Page 12 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Fuel Clad Barrier FC1 Category:

Fuel Clad Barrier FCI M No Change Diffrence Deviation RCS Activity RCS Activity 1) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss Loss A. (Site specific indications that reactor coolant activity is greater than 300 uCi/gm Coolant activity > 300 uCilgm Dose Equivalent 1-131.dose equivalent 1-131)Page 13 of 66 S NEI 99-01 Rev 6 Proposed EAL Justification Category:

Fuel Clad Barrier FC2 Category:

Fuel Clad Barrier FC2 M No Change Difference Deviation RPV Water Level RCS Activity 1) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby. Hot Shutdown 1.2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss Loss A. Primary containment flooding required.

1. Plant conditions indicate Primary Containment flooding is required.Potential Loss Potential Loss A. RPV water level cannot be restored and maintained above (site-specific RPV 2. RPV water level cannot be restored and maintained

> -162 inches (TAF)water level corresponding to top of active fuel) or cannot be determined.

OR 3. RPV water level cannot be determined.

Page 14 of 66 NEI 99-01 Rev 6 Proposed EAL Justification FC4 FC5 ff NOCag Dferne { eito Category:

Fuel Clad Barrier Category:

Fuel Clad Barrier ['E No Change E] Difference Deviation Primary Containment Radiation Primary Containment Radiation

1) Listed site-specific monitor and threshold value to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss Loss A. Primary Containment Radiation Monitor reading greater than (site-specific

1. Drywell radiation monitor reading > 260 R/hr (> 2.60 E+02 R/hr).value). OR 2. Containment radiation monitor reading > 41.3 R/hr (4.13 E+01 R/hr).Page 15 of 66 0 NEI 99-01 Rev 6 Proposed EAL Justification FC6 Category:

Fuel Clad Barrier Emergency Director Judgment Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:

Loss A. Any Condition in the opinion of the Emergency Director that indicates Loss of the Fuel Clad Barrier.Potential Loss A. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.FC7 Category:

Fuel Clad Barrier Emergency Director Judgment Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

Loss 1. Any Condition in the opinion of the Emergency Director that indicates Loss of the Fuel Clad Barrier.Potential Loss 2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.E No Change 1-1 Difference 1 Deviation Page 16 of66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Reactor Coolant System Barrier Rd Category:

Reactor Coolant System Barrier RC3 W No Change Difference Deviation Primary Containment Pressure Primary Containment Pressure/Conditions

1) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss Loss A. Primary containment pressure greater than (site-specific value) due to RCS 1. Drywell pressure >1.68 psig.leakage. AND 2. Drywell pressure rise is due to RCS leakage.Page 17 of 66 NEI 99-01 Rev 6 Proposed EAL Justification RC2 RC2 D N~ag ~ feec eito Category:

Reactor Coolant System Barrier Category:

Reactor Coolant System Barrier RC l No Change Difference Deviation RPV Water Level RPV Water Level 1 ) Listed site-specific threshold value to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss Loss A. RPV water level cannot be restored and maintained above (site-specific RPV 1. RPV water level cannot be restored and maintained

> -162 inches (TAF).level corresponding to the top of active fuel) or cannot be determined.

OR 2. RPV water level cannot be determined.

Page 18 of66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Reactor Coolant System Barrier RC3 Category:

Reactor Coolant System BarrierC No Change Dieene Deviation RCS Leak Rate RCS Leak Rate 1) Listed site-specific systems and threshold values to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss Loss A. UNISOLABLE break in any of the following: ( site-specific systems with potential

1. UNISOLABLE Main Steam Line (MSL), Feedwater,, RWCU or RCIC line for high-energy line breas) break.OR OR B. Emergency RPV Depressurization

2. Emergency RPV Depressurization is required.Potential Loss A. UNISOLABLE primary system leakage that results in exceeding EITHER of the Potential Loss following:

1. Max Normal Operating Temperature.

3. UNISOLABLE primary system leakage that results in EITHER of the following:

OR a. Secondary Containment area temperature

> EOP-8 Maximum Normal 2. Max Normal Operating Area Radiation Level. operating levels.OR b. Secondary Containment area radiation level > EOP-8 Maximum Normal operating levels.Page 19 of 66 0 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Reactor Coolant System Barrier RC4 Category:

Reactor Coolant System Barrier RC5 [ No Change Difference Deviation Primary Containment Radiation Primary Containment Radiation

1) Listed site-specific monitor and threshold value to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss Loss A. Primary Containment Radiation Monitor reading greater than (site-specific

1. Drywell radiation monitor reading > I 00R/hr (>1.00 E+02 R/hr).value). OR 2. Containment radiation monitor reading > 33 R/hr (>3.3 E+01 R/hr).Page 20 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Reactor Coolant System Barrier RC6 Category:

Reactor Coolant System Barrier RC' No Change Difference Deviation Emergency Director Judgment Emergency director Judgment Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss Loss A. Any Condition in the opinion of the Emergency Director that indicates Loss of 1. ANY Condition in the opinion of the Emergency Director that indicates Loss of the RCS Barrier. the RCS Barrier.Potential Loss Potential Loss A. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier. 2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.Page 21 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CTI Category:

Containment Barrier CT3 D No Change Diffrence Deviation Primary Containment Conditions Primary Containment Pressure/Conditions

1) Listed site-specific threshold values to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

2) The words 'and rising" were added to account for the momentary spike in Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3 pressure where pressure is now lowering, the risk of a potential loss of Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

containment is no longer present, this wording is also consistent with present EAL wording.Loss Loss C. UNPLANNED rapid drop in primary containment pressure following primary 1. UNPLANNED rapid drop in Drywell pressure following Drywell pressure rise.containment pressure rise OR OR 2. Drywell pressure response not consistent with LOCA conditions.

B. Primary containment pressure response not consistent with LOCA conditions.

Potential Loss Potential Loss D. Primary containment pressure greater than (site-specific value)OR 3. Primary Containment pressure>t5 psig and rising.E. (site-specific explosive mixture) exists inside primary containment OR OR 4. a. Drywell hydrogen concentration

> 9%.3. HCTL exceeded.

OR b. Containment Hydrogen concentration

> SAG-2, Deflagration Limit.OR 5. Heat Capacity Temperature Limit (EOP-6, Fig.P) exceeded.Page 22 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CT2 Category:

Containment BarrierCT2 No Change Differn Deviation RPV Water Level RPV Water Level Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3 Fission Product Barrier Threshold:

Fission Product Baffler (FPB) Threshold:

Potential Loss Potential Loss A. Primary containment flooding required.

Plant conditions indicate Primary Containment flooding is required.Page 23 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CT3 Category:

Containment Barrier No Change Differ Deviation Primary Containment Isolation Failure Primary Containment Isolation Failure 1) Listed site-specific threshold values to ensure timely classification.

Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss Loss A. UNISOLABLE direct downstream pathway to the environment exists after 1. UNISOLABLE direct downstream pathway to the environment exists after primary containment isolation signal primary containment isolation signal.OR OR B. Intentional primary containment venting per EOPs 2. Intentional Primary Containment venting/purging per EOPs or SAMGs due to OR accident conditions.

C. UNISOLABLE primary system leakage that results in exceeding EITHER of the OR following:

3. UNISOLABLE primary system leakage that results in EITHER of the following:

1. Max Safe Operating Temperature.

a. Secondary Containment area temperature

> EOP-8 Maximum Safe OR operating levels.2. Max Safe Operating Area Radiation Level. OR b. Secondary Containment area radiation level > EOP-8 Maximum Safe operating levels.Page 24 of 66 NEI 99-01 RevS Proposed EAL Justification NEI 99-01 Rev 6 Proposed EAL Justification-I i-CT4 Category:

Containment Barrier Primary Containment Radiation Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:

Potential Loss A. Primary Containment Radiation Monitor reading greater than (site-specific value).CT5 Category:

Containment Barrier Primary Containment Radiation Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

Potential Loss 1. Drywell radiation monitor reading > 590R/hr (> 5.90 E+02 R/hr)OR 2. Containment radiation monitor reading > 97 R/hr (>9.70 E+01 R/hr)E No Change 1 Difference 1 Deviation 1) Listed site-specific monitor and threshold value to ensure timely classification.

Page 25 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Category:

Containment Barrier CT6 Category:

Containment BarrierT No Change Difference Deviation Emergency director Judgment Emergency Director Judgment Operating Mode Applicability:

Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 Fission Product Barrier Threshold:

Fission Product Barrier (FPB) Threshold:

Loss Loss A. Any Condition in the opinion of the Emergency Director that indicates Loss of 1. Any Condition in the opinion of the Emergency Director that indicates Loss of the Containment Barrier. the Containment Barrier.Potential Loss Potential Loss A. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier. 2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.Page 26 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SGl MG1I-- m Difrne m eito Initiating Condition:

GENERAL EMERGENCY Initiating Condition:

[jI No Change Fj Difference

[j Deviation Prolonged loss of all offsite and all onsite AC power to emergency buses. Prolonged loss of all offsite and all onsite AC power to emergency buses.1) Listed site specific equipment, site specific time based on station blackout Operating Mode Applicability:

Operating Mode Applicability:

coping analysis, and site specific indication to ensure timely classification.

Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 Example Emergency Action Levels: Emergency Action Level (EAL): Note: The Emergency Director should declare the General Emergency promptly Note: upon determining that (site-specific hours) has been exceeded, or will 0 The Emergency Director should declare the event promptly upon determining likely be exceeded, that the applicable time has been exceeded, or will likely be exceeded.1. a. Loss of ALL offsite and ALL onsite AC power to (site-specific emergency buses). 1 Loss of ALL offsite AC power to vital busses lAl and 1B1.AND AND 2. Failure of DG 1A and DG 1 B emergency diesel generators to supply power to b. EITHER of the following:

vital busses 1A1 and 1131.AND" Restoration of at least one emergency bus in less than 3. EITHER of the following: (site-specific hours) is not likely, a. Restoration of at least one vital bus (excluding Division 1II) in < 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is not likely." (Site-specific indication of an inability to adequately OR remove heat from the core)b. RPV water level cannot be restored and maintained

> -187 inches.Page 27 of 66 NEI 99-01 Rev 6 ] Proposed EAL Justification SS1 Initiating Condition:

SITE AREA EMERGENCY Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or longer.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the Site Area Emergency promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses)for 15 minutes or longer.MS1 Initiating Condition:

Loss of all offsite and onsite AC power to emergency busses for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC Power to vital busses WA1 and 161.AND 2. Failure of DG 1A and DG 1B emergency diesel generators to supply power to vital busses WAl and 161.AND 3. Failure to restore power to at least one vital bus (excluding Division Ill) in< 16 minutes from the time of loss of both offsite and onsite AC power H--x-I No Change 1- Difference FIDeviation

1) Listed site specific equipment to ensure timely classification.

Page 28 of 66 NEI 99-01 Rev 6] Proposed EAL Justification SA1 Initiating Condition:

ALERT Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the Alert promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.1. a. AC power capability to (site-specific emergency buses) is reduced to a single power source for 15 minutes or longer.AND b. Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS.I MA1I Initiating Condition:

Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. AC power capability to vital busses (1A1, 1813) reduced to only one of the following power sources for > 15 minutes.* Emergency Reserve Auxiliary Transformer (ERAT)* Reserve Auxiliary Transformer B (RAT B)* Emergency Diesel Generator DG 1A* Emergency Diesel Generator DG 1 B AND 2. ANY additional single power source failure will result in a loss of ALL AC power to Division I and II SAFETY SYSTEMS.No Change F ]Difference F Deviation 1) Listed site specific equipment to ensure timely classification.

Page 29 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification Sul Initiating Condition:

UNUSUAL EVENT Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.Loss of ALL offsite AC power capability to (site-specific emergency buses) for 15 minutes or longer MUl Initiating Condition:

Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.Loss of ALL offsite AC power capability to vital busses 1WA and 1 B1 for > 15 minutes.No Change 1 Difference FIDeviation

1) Listed site specific equipment to ensure timely classification.

Page 30 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification

-SG8 Initiating Condition:

GENERAL EMERGENCY Loss of all AC and Vital DC power sources for 15 minutes or longer.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the General Emergency promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.1. Loss of ALL offsite and ALL onsite AC power to (site-specific emergency buses) for 15 minutes or longer.AND Indicated voltage is less than (site-specific bus voltage value) on ALL (site-specific vital DC busses) for 15 minutes or longer.MG2 Initiating Condition:

Loss of all AC and Vital DC power sources for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to vital busses 1Al and 1B1.AND 2. Failure of DG 1A and DG 1B emergency diesel generators to supply power to vital busses WAl and 1B1.AND 3. Voltage is ' 108 VDC on unit 125 VDC battery busses 1A and 1B.AND 4. ALL AC and Vital DC power sources have been lost for >15 minutes.-' No Change M Difference

[-- Deviation 1) Listed site specific voltage and equipment to ensure timely classification.

2) Removed the word "indicated" this will allow for an indication problem to not cause confusion on the need to declare.Page 31 of 66 0 NEI 99-01 Rev 6 Proposed EAL Justification SS8 Initiating Condition:

SITE AREA EMERGENCY Loss of all Vital DC power for 15 minutes or longer.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the Site Area Emergency promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.Indicated voltage is less than (site-specific bus voltage value) on ALL Vital DC buses for 15 minutes or longer.MS2 Initiating Condition:

Loss of all Vital DC power for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): D No Change 7- Difference FIDeviation

1) Listed site specific voltage and equipment to ensure timely classification.

2) Removed the word "indicated" this will allow for an indication problem to not cause confusion on the need to declare.Note: a The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.Voltage is <108 VDC on 125 VDC battery busses 1A and 1 B for >15 minutes.Page 32 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification SS5 Initiating Condition:

SITE AREA EMERGENCY Inability to shutdown the reactor causing a challenge to (core cooling [PWR] / RPV water level [BWR]) or RCS heat removal.Operating Mode Applicability:

Power Operation Example Emergency Action Levels: 1. a. An automatic (trip [PVVR] / scram [BWR]) did not shutdown the reactor.AND b. All manual actions to shutdown the reactor have been unsuccessful.

AND c. EITHER of the following conditions exist: 1. (Site-specific indication of an inability to adequately remove heat from the core)OR 2. (Site-specific indication of an inability to adequately remove heat from the RCS)MS3 Initiating Condition:

Inability to shutdown the reactor causing a challenge to RPV water level or RCS heat removal.Operating Mode Applicability:

1,2 Emergency Action Level (EAL): 1. Automatic scram did not shutdown the reactor as indicated by Reactor Power> 5%.AND 2. ALL manual / ARI actions to shutdown the reactor have been unsuccessful as indicated by Reactor Power > 5%.AND 3. EITHER of the following conditions exist: " RPV water level cannot be restored and maintained

> -187 inches OR" Heat Capacity Temperature Limit (EOP-6, Fig. P) exceeded.D No Change F Difference FI- Deviation 1) Listed site specific indications to ensure timely classification.

2) Mode 2 included in operating mode applicability as per developer notes.3) Added ARI as an equivalent scram Page 33 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:

ALERT Automatic or manual (trip [PWR] / scram [BWR]) fails to shutdown the reactor, and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor.Operating Mode Applicability:

Power Operation Example Emergency Action Levels: Note: A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

1. a. An automatic (trip [PWR] / scram [BWR]) did not shutdown the reactor.AND b. Manual action taken at the reactor control consoles are not successful in shutting down the reactor.MA3 Initiating Condition:

Automatic or manual scram fails to shutdown the reactor, and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor.Operating Mode Applicability:

1,2 Emergency Action Level (EAL): Note:* A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

1. Automatic or manual scram did not shutdown the reactor as indicated by Reactor Power > 5%.AND 2. Manual / ARI actions taken at the Reactor Console are not successful in shutting down the reactor as indicated by Reactor Power > 5%.[H No Change Fq Difference FIDeviation

1) Listed site specific indications to ensure timely classification.

2) Mode 2 included in operating mode applicability as per developer notes.3) Added ARI as an equivalent scram Page 34 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:

UNUSUAL EVENT Automatic or manual (trip [PWR] / scram [BWR]) fails to shutdown the reactor.Operating Mode Applicability:

Power Operation Example Emergency Action Levels: (1 or 2)Note: A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

1. a. An automatic (trip [PWR] / scram [BWR]) did not shutdown the reactor.AND b. A subsequent manual action taken at the reactor control consoles is successful in shutting down the reactor.2. a. A manual scram ([PWRJ / scram [BWR]) did not shutdown the reactor.AND b. EITHER of the following:

1. A subsequent manual action taken at the reactor control consoles is successful in shutting down the reactor.OR 2. A subsequent automatic (trip [PWR] / scram [BWR]) is successful in shutting down the reactor.MU3 Initiating Condition:

Automatic or manual scram fails to shutdown the reactor.Operating Mode Applicability:

F No Change M Difference FIDeviation

1) Listed site specific indications to ensure timely classification.

2) Mode 2 included in operating mode applicability as per developer notes.3) Added ARI as an equivalent scram 1,2 Emergency Action Level (EAL): Note:* A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

a. Automatic scram did not shutdown the reactor as indicated by Reactor Power > 5%.AND b. Subsequent manual / ARI action taken at the Reactor Console is successful in shutting down the reactor.OR 2. a. Manual scram did not shutdown the reactor as indicated by Reactor Power > 5%.AND b. EITHER of the following:

1. Subsequent manual / ARI action taken at the Reactor Console is successful in shutting down the reactor.OR 2. Subsequent automatic scram / ARI is successful in shutting down the reactor.Page 35 of 66 NE199-01 Rev 6 [ Proposed EAL Justification SA2 Initiating Condition:

ALERT UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the Alert promptly upon determining that 15 minutes has been exceeded.

or will likely be exceeded.1. a. An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the Control Room for 15 minutes or longer.[see table below][ BWR parameter list] [PWR parameter list]Reactor Power Reactor Power RPV water level RCS Level RPV Pressure RCS Pressure Primary Containment Pressure In Core/Core Exit Temperature Suppression Pool Level Levels in at least (site specific number)steam generators Suppression Pool Temperature Steam Generator Auxiliary or Emergency Feed Water Flow AND b. Any of the following transient events in progress.* Automatic or Manual runback greater than 25% thermal reactor power* Electrical load rejection greater than 25% full electrical load* Reactor Scram [BWR] / trip [PWR]* ECCS (SI) actuation* Thermal power oscillations greater than 10% [BWR]MA4 Initiating Condition:

UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED event results in the inability to monitor ANY Table M1 parameters from within the Control Room for >15 minutes.MI No Change FIDifference FIDeviation Table M1 Control Room Parameters

• Reactor Power* RPV water level* RPV Pressure* Primary Containment Pressure* Suppression Pool Level* Suppression Pool Temperature AND 2. ANY Table M2 transient in progress.Table M2 Significant Transients

• Recirc Runback >25% Reactor Power* Reactor Scram* ECCS Actuation* Thermal Power oscillations

> 10% Reactor Power change Page 36 of 66 NEI 99-01 Rev 6 [ Proposed EAL I Justification SU2 Initiating Condition:

UNUSUAL EVENT UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the Control Room for 15 minutes or longer.[see table below][ BWR parameter list] [PWR parameter list]Reactor Power Reactor Power RPV water level RCS Level RPV Pressure RCS Pressure Primary Containment Pressure In Core/Core Exit Temperature Levels in at least (site specific Suppression Pool Level number) steam generators Suppression Pool Temperature Steam Generator Auxiliary or Emergency Feed Water Flow MU4 No Change FIDifference FIDeviation Initiating Condition:

UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.UNPLANNED event results in the inability to monitor ANY Table M1 parameters from within the Control Room for > 15 minutes.Table Ml Control Room Parameters

• Reactor Power* RPV water level* RPV Pressure* Primary Containment Pressure* Suppression Pool Level* Suppression Pool Temperature Page 37 of 66 NEI 99-01 Rev 6 SA9 Initiating Condition:

ALERT Hazardous event affecting a SAFETY SYSTEM needed for the current operating mode.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: 1. a. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)

• Internal or external flooding event* High winds or tornado strike* FIRE* EXPLOSION* (site-specific hazards)* Other events with similar hazard characteristics as determined by the Shift Manager AND b. EITHER of the following:

1. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM needed for the current operating mode.OR 2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure needed for the current operating mode.Proposed EAL [ Justification MAS Initiating Condition:

ALERT Hazardous event affecting a SAFETY SYSTEM required for the current operating mode.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): 1. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)

• Internal or external flooding event* High winds or tornado strike* FIRE* EXPLOSION* Other events with similar hazard characteristics as determined by the Shift Manager AND 2. EITHER of the following:

a. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.OR b. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure required by Technical Specifications for the current operating mode.H NO Change Difference

-Deviation 1) No additional site specific hazard noted 2) Changed the word "needed" to "required by technical Specifications to be consistent with terminology used by operators and minimize confusion.

Page 38 of 66 NEI 99-01 Rev 6 Proposed EAL Justification SU4 Initiating Condition:

UNUSUAL EVENT RCS leakage for 15 minutes or longer.Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: (1 or 2 or 3)Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.1. RCS unidentified or pressure boundary leakage greater than (site-specific value) for 15 minutes or longer.2. RCS identified leakage greater than (site-specific value) for 15 minutes or longer 3. Leakage from the RCS to a location outside containment greater than 25 gprn for 15 minutes or longer MU6 Initiating Condition:

RCS leakage for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. RCS unidentified or pressure boundary leakage in the Drywell > 10 gpm for> 15 minutes.OR 2. RCS identified leakage in the Drywell >25 gpm for > 15 minutes.OR 3. Leakage from the RCS to a location outside the Drywell t >25 gpm for> 15 minutes.F No Change M Difference D Deviation 1) Listed site specific values to ensure timely classification.

2) Changed wording from containment to Drywell for clarity to better define the primary containment structure.

3) In EAL #1 and 2 added "into the Drywell" to differentiate between EAL #1/2 and#3. Without this wording would have been in EAL #1 or #2 concurrent with #3. With the added wording each EAL can be called separately.

Page 39 of 66 NEI 99-01 Rev 6 Proposed EAL [ Justification Initiating Condition:

UNUSUAL EVENT Loss of all onsite or offsite communications capabilities Operating Mode Applicability:

Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: (1 or 2 or 3)1. Loss of ALL of the following onsite communication methods: (site-specific list of communications method 2. Loss of ALL of the following ORO communications s) methods: (site-specific list of communications methods)3. Loss of ALL of the following NRC communications methods: (site-specific list of communications methods)bU5 MU7 Initiating Condition:

Loss of all onsite or offsite communication capabilities.

Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): 1. Loss of ALL Table M3 Onsite communications capability affecting the ability to perform routine operations.

OR 2. Loss of ALL Table M3 Offsite communication capability affecting the ability to perform offsite notifications.

OR 3. Loss of ALL Table M3 NRC communication capability affecting the ability to perform NRC notifications.

M No Change FIDifference I Deviation 1) Listed site specific communication methods to ensure timely classification.

Table M3 Communications Capability System Onsite Offsite NRC Plant Radio X Plant Page X Sound Powered Phones X PCS Phones X X X All telephone Lines (Commercial and X X X microwave)

ENS X X HPN X X Satellite Phones X X Page 40 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification CA2 Initiating Condition:

ALERT Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or longer.Operating Mode Applicability:

Cold Shutdown, Refueling, Defueled Example Emergency Action Levels: Note: The Emergency Director should declare the Alert promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses)for 15 minutes or longer.CAI Initiating Condition:

Loss of all offsite and onsite AC power to emergency busses for 15 minutes or longer.Operating Mode Applicability:

4,5 Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to vital busses WA1 and 181.AND 2. Failure of DG 1A and DG 1 B emergency diesel generators to supply power to vital busses WA1 and 181.AND 3. Failure to restore power to at least one vital bus (excluding Division Ill) in< 15 minutes from the time of loss of both offsite and onsite AC power.El No Change E -1 Difference 1 Deviation 1) Listed site specific equipment to ensure timely classification.

Page 41 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:

UNUSUAL EVENT Initiating Condition:

No Change Difference Deviation Loss of all but one AC power source to emergency buses for 15 minutes or longer. Loss of all but one AC power source to emergency buses for 15 minutes or 1) Listed site specific equipment to ensure timely classification.

Operating Mode Applicability:

longer.Cold Shutdown, Refueling, Defueted Operating Mode Applicability:

Example Emergency Action Levels: 4, 5, D Note: The Emergency Director should declare the Unusual Event promptly upon Emergency Action Level (EAL): determining that 15 minutes time has been exceeded, or will likely be exceeded.

Note: 1. a. AC power capability to (site-specific emergency buses) is reduced to a e The Emergency Director should declare the event promptly upon determining single power source for 15 minutes or longer, that the applicable time has been exceeded, or will likely be exceeded.AND 1. AC power capability to vital busses (1A1, 11B1) reduced to only one of b. Any additional single power source failure will result in loss of all AC the following power sources for > 15 minutes.power to SAFETY SYSTEMS.

• Emergency Reserve Auxiliary Transformer (ERAT)* Reserve Auxiliary Transformer B (RAT B)* Emergency Diesel Generator DG 1A* Emergency Diesel Generator DG 1 B AND 2. ANY additional single power source failure will result in a loss of ALL AC power to SAFETY SYSTEMS (excluding Division Ill).Page 42 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification CA6 Initiating Condition

-ALERT Hazardous event affecting SAFETY SYSTEM needed for the current operating mode.Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: 1. a. The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)

• Internal or external flooding event* High winds or tornado strike* FIRE* EXPLOSION* (site-specific hazards)* Other events with similar hazard characteristics as determined by the Shift Manager AND b. EITHER of the following:

1. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM needed for the current operating mode.OR 2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure needed for the current operating mode.CA2 Initiating Condition:

Hazardous event affecting SAFETY SYSTEM required for the current operating mode.Operating Mode Applicability:

4,5 Emergency Action Level (EAL): 1 .The occurrence of ANY of the following hazardous events:* Seismic event (earthquake)

• Internal or external flooding event* High winds or tornado strike" FIRE" EXPLOSION" Other events with similar hazard characteristics as determined by the Shift Manager AND 2. EITHER of the following:

a. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.OR b. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure required by Technical Specifications for the current operating mode.H No Change M Difference El Deviation 1) No additional site specific hazard noted 2) Changed the word "needed" to "required by technical Specifications to be consistent with terminology used by operators and minimize confusion.

Page 43 of 66 0 NEI 99-01 Rev 6 Proposed EAL Justification CU4 Initiating Condition:

UNUSUAL EVENT Loss of Vital DC power for 15 minutes or longer.Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.Indicated voltage is less than (site-specific bus voltage value) on required Vital DC buses for 15 minutes or longer.CU3 Initiating Condition:

Loss of Vital DC power for 15 minutes or longer.Operating Mode Applicability:

4,5 Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.Voltage is < 108 VDC on required 125 VDC battery busses 1A and IB for> 15 minutes.D No Change E Difference 1 Deviation 1) Listed site specific voltage and equipment to ensure timely classification.

2) Removed the word "indicated" this will allow for an indication problem to not cause confusion on the need to declare.Page 44 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification CU5 Initiating Condition:

UNUSUAL EVENT Loss of all onsite or offsite communications capabilities Operating Mode Applicability:

Cold Shutdown, Refueling, Defuled Example Emergency Action Levels: (1 or 2 or 3)1. Loss of ALL of the following onsite communication methods: (site-specific list of communications method 2. Loss of ALL of the following ORO communications s) methods: (site-specific list of communications methods)3. Loss of ALL of the following NRC communications methods: (site-specific list of communications methods)CU4 Initiating Condition:

Loss of all onsite or offsite communication capabilities.

Operating Mode Applicability:

4.5, D Emergency Action Level (EAL): 1. Loss of ALL Table C1 Onsite communications capability affecting the ability to perform routine operations.

OR 2. Loss of ALL Table C1 Offsite communication capability affecting the ability to perform offsite notifications.

OR 3. Loss of ALL Table C1 NRC communication capability affecting the ability to perform NRC notifications.

E No Change D-- Difference 1 Deviation 1) Listed site specific communications methods to ensure timely classification Table C1 Communications Capability System Onsite Offsite NRC Plant Radio X Plant Page X Sound Powered Phones X PCS Phones X X X All telephone Lines (Commercial and X X X microwave)

ENS X X HPN X X Satellite Phones X X Page 45 of 66 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:

ALERT Initiating Condition:

A No Change Difference Deviation Inability to maintain the plant in cold shutdown.

Inability to maintain plant in cold shutdown.

1) Listed site specific Technical Specification cold shutdown temperature limit and Operating Mode Applicability:

Operating Mode Applicability:

site-specific pressure reading to ensure timely classification.

Cold Shutdown, Refueling 4, 5 Example Emergency Action Levels: (1 or 2) Emergency Action Level (EAL): Note: The Emergency Director should declare the Alert promptly upon Note: determining that the applicable has been exceeded, or will likely be The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED increase in RCS temperature to greater than (site-specific Technical Specification cold shutdown temperature limit) for greater than the duration specified in the following table. 1. UNPLANNED rise in RCS temperature>

200*F due to loss of decay 2. UNPLANNED RCS pressure increase greater than (site-specific pressure heat removal for > Table C2 duration.reading). (This EAL does not apply during water-solid plant conditions.

[PWR]) Table C2 RCS Heat-up Duration Thresholds Table: RCS Heat-up Duration Thresholds RCS Status Containment Closure Heat-up Duration RCS Status Containment Closure Heat-up Duration Status Status Intact Not Applicable 60 minutes*Intact (but not Established 20 minutes*RCS Reduced Not Applicable 60 minutes* Not Intact Inventory

[PVVR])Not Intact (or at Established 20 minutes* Not Established 0 minutes reduced inventory[PWR]) Not Established 0 minutes

• If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, then EAL #1 is not If an RCS heat removal system is in operation within this time frame and applicable.

RCS temperature is being reduced, the EAL is not applicable.

OR 2. UNPLANNED RPV pressure rise> 10 psig as a result of temperature rise due to loss of decay heat removal.Page 46 of 66 NEI 99-01 Rev 6 Proposed EAL Justification CU3 CU5 f ] Nf Initiating Condition:

UNUSUAL EVENT Initiating Condition:

[j No Change Difference Deviation UNPLANNED increase in RCS temperature.

UNPLANNED rise in RCS temperature.

1) Listed site specific Technical Specification cold shutdown temperature limit Operating Mode Applicability:

Operating Mode Applicability:

to ensure timely classification.

Cold Shutdown, Refueling 4, 5 2) Changed the word increase to rise in the initiating condition to be consistent Example Emergency Action Levels: (1 or 2) Emergency Action Level (EAL): with operations language and training.Note: The Emergency Director should declare the Unusual Event promptly Note: upon determining that 15 minutes time has been exceeded, or will likely 0 The Emergency Director should declare the event promptly upon be exceeded.

determining that the applicable time has been exceeded, or will likely be 1. UNPLANNED increase in RCS temperature to greater than (site-specific exceeded.Technical Specification cold shutdown temperature limit).2. Loss of ALL RCS temperature and (reactor vessel/RCS

[PWR] or RPV 1. UNPLANNED rise in RCS temperature>

2001F due to loss of decay[BWR]) level indication for 15 minutes or longer, heat removal.OR 2. Loss of the following for >_15 minutes." ALLRCS temperature indications AND" ALL RPV water level indications Page 47 of 66 0 NEI 99-01 Rev 6 ] Proposed EAL Justification CG1 Initiating Condition:

GENERAL EMERGENCY Loss of (reactor vessel/RCS

[PWR] or RPV [BWRJ) inventory affecting fuel clad integrity with containment challenged.

Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the General Emergency promptly upon determining that 30 minutes time has been exceeded, or will likely be exceeded.1. a. (Reactor vessel/RCS

[PKWR or RPV [BW(R]) vessel level less than (site-specific level) for 30 minutes or longer.AND b. ANY indication from the Containment Challenge Table 2. a.. (Reactor vessel/RCS

[PWR] or RPV [BlAR]) vessel level cannot be monitored for 30 minutes or longer.AND b. Core uncovery is indicated by ANY of the following:

• (Site-specific radiation monitor) reading greater than (site-specific value)* Erratic source range monitor indication

[PWR]* UNPLANNED increase in (site-specific sump and/or tank levels) of sufficient magnitude to indicate core uncovery* (Other site-specific indications)

AND c. ANY indication from the Containment Challenge Table).CG6 Initiating Condition:

Loss of RPV inventory affecting fuel clad integrity with containment challenged.

Operating Mode Applicability:

4,5 Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. a. RPV water level < -162 inches for > 30 minutes.AND b. Any Containment Challenge Indication (Table C4)OR 2. a. RPV water level unknown for > 30 minutes.AND b. Core uncovery is indicated by ANY of the following:

• Table C3 indications.of a sufficient magnitude to indicate core uncovery.OR* Erratic Source Range Neutron Monitor indication.

OR* Containment High Range Monitors 1RIX-CM061 or 1 RIX-CM062

>3 R/hr.AND c. ANY Containment Challenge Indication (Table C4)H-1 No Change E Difference 1 Deviation 1) Listed site specific levels, radiation monitors, and sumps and tanks to ensure timely classification.

2) Listed Explosive mixture in the Containment Challenge Table to ensure timely classification.

3) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keeping with current EAL wording.Table C3 Indications of RCS Leakage Table: Containment Challenge Table* CONTAINMENT CLOSURE not established-

• (Explosive mixture) exists inside containment

• UNPLANNED increase in containment pressure* Secondary containment radiation monitor reading above (site-specific value) [BWR]if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency is not required.* UNPLANNED floor or equipment sump level rise** UNPLANNED Suppression Pool level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory Table C4 Containment Challenge Indications

• Drywell Hydrogen Concentration

> 9%* Containment hydrogen concentration

> SAG-2 Fig. R, Deflagration Limit* UNPLANNED rise in containment pressure* CONTAINMENT CLOSURE not established

• ANY Secondary Containment radiation monitor > EOP 8 Table U Maximum Safe operating level I1 '.UIN I/JlrtNIVIrN I -.-LOUr-C is prior Lo exc-eeding LIle Jlu-minute core uncovery time limit, then escalation to a General Emergency is not reouired.Page 48 of 66 NEI 99-01 Rev 6 1 Proposed EAL Justification CSt Initiating Condition:

SITE AREA EMERGENCY Loss of (reactor vessel/RCS

[PWRI or RPV [BWR]) inventory affecting core decay heat removal capability.

Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2 or 3)Note: The Emergency Director should declare the Site Area Emergency promptly upon determining that 30 minutes time has been exceeded, or will likely be exceeded.1. a. CONTAINMENT CLOSURE not established.

AND b. (Reactor vessel/RCS

[PWR] or RPV [BlR]) level less than (site-specific level).2. a. CONTAINMENT CLOSURE established.

AND b. (Reactor vessel/RCS

[PWR] or RPV [BWR]) level less than (site-specific level).3. a. (Reactor vessel/RCS

[PWVRJ or RPV [BWR]) level cannot be monitored for 30 minutes or longer.AND b. Core uncovery is indicated by ANY of the following: " (Site-specific radiation monitor) reading greater than (site-specific value)" Erratic source range monitor indication

[PVIVR]" UNPLANNED increase in (site-specific sump and/or tank levels) of sufficient magnitude to indicate core uncovery" (Other site-specific indications)

CS6 Initiating Condition:

Loss of RPV inventory affecting core decay heat removal capabilities.

Operating Mode Applicability:

4,5 Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. With CONTAINMENT CLOSURE not established, RPV water level < -145.5 inches OR 2. With CONTAINMENT CLOSURE established, RPV water level < -162 inches (TAF)OR 3. a. RPV water level unknown for > 30 minutes AND b. Core uncovery is indicated by ANY of the following: " Table C3 indications of a sufficient magnitude to indicate core uncovery OR" Erratic Source Range Neutron Monitor indication.

OR" Containment High Range Monitors 1RIX-CM061 or 1RIX-CM062 >3 R/hr.D No Change E Difference 1 Deviation 1) Listed site specific values for level, radiation monitors, and sumps and tanks to ensure timely classification.

2) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keeping with current EAL wording.Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Suppression Pool level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.

Page 49 of 66 NEI 99-01 Rev 6 Proposed EAL I Justification CA1 Initiating Condition:

ALERT Loss of (reactor vessel/RCS

[P4R] or RPV [BWR]) inventory Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Alert promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.1. Loss of (reactor vessel/RCS

[PWR] or RPV [BWR]) inventory as indicated by level less than (site-specific level).2. a. (Reactor vessel/RCS

[PWRJ or RPV [BWR]) level cannot be monitored for 15 minutes or longer AND b. UNPLANNED increase in (site-specific sump and/or tank) levels due to a loss of (reactor vessel/RCS

[PWR] or RPV [BWR]) inventory.

CA6 Initiating Condition:

Loss of RPV inventory Operating Mode Applicability:

4,5 Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. a. Loss of RPV inventory as indicated by level < -45.5 inches.OR 2. a. RPV water level unknown for > 15 minutes.AND b. Loss of RPV inventory per Table C3 indications.

Table C3 Indications of RCS Leakage* UNPLANNED floor or equipment sump level rise** UNPLANNED Suppression Pool level rise** UNPLANNED vessel make up rate rise* Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.

H No Change Difference Deviation 1) Listed site specific levels, and sumps and tanks to ensure timely classification.

2) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keeping with current EAL wording.Page 50 of 66 NEI 99-01 Rev 6 1 Proposed EAL I Justification Cul Initiating Condition:

UNUSUAL EVENT UNPLANNED loss of (reactor vessel/RCS

[PWR] or RPV [BWRI) inventory for 15 minuteS or longer.Operating Mode Applicability:

Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.1. UNPLANNED loss of reactor coolant results in (reactor vessel/RCS

[PWR] or RPV [BWR]) level less than a required lower limit for 15 minutes or longer.2. a. (Reactor vessel/RCS

[PWR] or RPV [BWRI) level cannot be monitored.

AND b. UNPLANNED increase in (site-specific sump and/or tank) levels.CU6 Initiating Condition:

UNPLANNED loss of RPV inventory for 15 minutes or longer.Operating Mode Applicability:

4,5 Emergency Action Level (EAL): Note: 9 The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED loss of reactor coolant results in the inability to restore and maintain RPV water level above the procedurally established lower limit for > 15 minutes.OR 2. a. RPV water level unknown AND b. Loss of RPV inventory per Table C3 indications.

Table C3 Indications of RCS Leakage" UNPLANNED floor or equipment sump level rise*" UNPLANNED Suppression Pool level rise*" UNPLANNED vessel make up rate rise" Observation of leakage or inventory loss*Rise in level is attributed to a loss of RPV inventory.

D No Change E Difference 1 Deviation 1) Described "a required lower limit" as a procedurally established lower limit, and listed site specific sumps and tanks to ensure timely classification.

2) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keeping with current EAL wording.Page 51 of 66 0 NEI 99-01 Rev 6 Proposed EAL Justification HG1 HGI mm Initiating Condition:

GENERAL EMERGENCY Initiating Condition:

LF No Change [-j Difference

[j Deviation HOSTILE ACTION resulting in loss of physical control of the facility.

HOSTILE ACTION resulting in loss of physical control of the facility.

1) List site security shift supervision as Security Force.2) Added descriptors to better explain each safety function and allow for a timely Operating Mode Applicability:

Operating Mode Applicability:

classification.

All 1, 2, 3,4, 5, D Example Emergency Action Levels: Emergency Action Level (EAL): 1. a. A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the (site-specific security shift supervision).

1. A notification from the Security Force that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA.AND AND 2. a. ANY Table H1 safety function cannot be controlled or maintained.

b. EITHER of the following:

OR 1. ANY of the following safety functions cannot be controlled or b. Damage to spent fuel has occurred or is IMMINENT maintained.

• Reactivity control Table H1 Safety Functions*Core cooling [PWR)J / RPV water level [HWR]C RCS heat removal / Reactivity Control (ability to shut down the reactor and keep it shutdown)* RPV water level (ability to cool the core)OR

• RCS Heat Removal (ability to maintain heat sink)2. Damage to spent fuel has occurred or is IMMINENT Page 52 of 66 0 NEI 99-01 Rev 6 1 Proposed EAL Justification HSI HSI Initiating Condition:

SITE AREA EMERGENCY HOSTILE ACTION within the Protected Area.Operating Mode Applicability:

Initiating Condition:

HOSTILE ACTION within the Protected Area.Operating Mode Applicability:

F -No Change F Difference 1 Deviation 1) List site security shift supervision as Security Force.All Example Emergency Action Levels: A HOSITLE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the (site-security shift supervision).

1,2.3, 4, 5, D Emergency Action Level (EAL): A notification from the Security Force that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA.Page 53 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HA1 HAl1 Initiating Condition:

ALERT Initiating Condition:

Ll I No Change j Difference F Deviation HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack 1) List site security shift supervision as Security Force.threat within 30 minutes. threat within 30 minutes.Operating Mode Applicability:

Operating Mode Applicability:

All 1,2, 3, 4, 5, D Example Emergency Action Levels: (1 or 2) Emergency Action Level (EAL): 1. A HOSTILE ACTION is occurring or has occurred within the OWNER I. A validated notification from NRC of an aircraft attack threat < 30 minutes CONTROLLED AREA as reported by the (site-specific security shift from the site.supervision).

2. A validated notification from NRC of an aircraft attack threat within 30 OR minutes of the site.2. Notification by the Security Force that a HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLED AREA.Page 54 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HU1 HUI F-f m-- Difrec -Dvito Initiating Condition:

UNUSUAL EVENT Initiating Condition:

LU No Change [V] Difference Deviation Confirmed SECURITY CONDITION or threat.Confirmed SECURITY CONDITION or threat. 1) List site security shift supervision as Security Force.Operating Mode Applicability:

2) Further described credible security threat through listing a site specific Operating Mode Applicability:

procedure.

All 1,2, 3,4,5, D Example Emergency Action Levels: (1 or 2 or 3)Emergency Action Level (EAL): 1. A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the (site-specific security shift supervision).

1. Notification of a credible security threat directed at the site as determined per SY-AA-101-132, Security Assessment and Response to Unusual Activities.

2. Notification of a credible security threat directed at the site. OR 2. A validated notification from the NRC providing information of an aircraft 3. A validated notification from the NRC providing information of an aircraft threat.threat.OR 3. Notification by the Security Force of a SECURITY CONDITION that does not involve a HOSTILE ACTION.Page 55 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HSB H52 mm Initiating Condition:

SITE AREA EMERGENCY Initiating Condition:

LJ No Change j Difference 1J Deviation Inability to control a key safety function from outside the Control Room. Inability to control a key safety function from outside the Control Room. 1) EAL uses the site specific Control Room evacuation procedures to effectively list all of the alternate locations, panels, and stations requested by the developer notes. This would be the procedures the Control Room would enter should such an Operating Mode Applicability:

Operating Mode Applicability:

event occur, this allows for greater clarity as to when this EAL would apply than if each panel and station used in alternate shutdown were to be listed, All 1, 2, 3,4, 5, D 2) Added descriptors to better explain each safety function and allow for a timely classification.

Example Emergency Action Levels: (1 and 2) Emergency Action Level (EAL): Note: The Emergency Director should declare the Site Area Emergency promptly Note: 3) Changed "An event" to" A Control Room evacuation" to remove confusion if upon determining that (site-specific number of minutes) has been partial plant control was transferred to outside the control room with the control exceeded, or will likely be exceeded.

a The Emergency Director should declare the event promptly upon determining room still manned, due to testing or equipment failure.that the applicable time has been exceeded, or will likely be exceeded.1. An event has resulted in plant control being transferred from the Control Room to (site-specific remote shutdown panels and local control stations).

1. A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per CPS 4003.01, Remote 2. Control of ANY of the following key safety functions is not reestablished Shutdown.within (site-specific number of minutes).

AND* Reactivity control 2. Control of ANY Table H1 key safety function is not reestablished in < 15 minutes.* Core cooling [P1'R] / RPV water level [BWR]* RCS heat removal Table HI Safety Functions* Reactivity Control (ability to shut down the reactor and keep it shutdown)* RPV water level (ability to cool the core)* RCS Heat Removal (ability to maintain heat sink)Page 56 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HA6 HA2 Initiating Condition:

ALERT Initiating Condition:

H No Change rq Difference FIDeviation Control Room evacuation resulting in transfer of plant control to alternate locations.

Control Room evacuation resulting in transfer of plant control to alternate locations.

1) EAL uses the site specific Control Room evacuation procedures to effectively list all of the alternate locations, panels, and stations requested by the developer notes. This would be the procedures the Control Room would enter should such an Operating Mode Applicability:

Operating Mode Applicability:

event occur, this allows for greater clarity as to when this EAL would apply than if each panel and station used in alternate shutdown were to be listed, All 1, 2, 3, 4, 5, D 2) Changed "An event" to" A Control Room evacuation" to remove confusion if partial plant control was transferred to outside the control room with the control Example Emergency Action Levels: Emergency Action Level (EAL): room still manned, due to testing or equipment failure.An event has resulted in plant control being transferred from the Control Room to A Control Room evacuation has resulted in plant control being transferred from (site-specific remote shutdown panels and local control stations), the Control Room to alternate locations per CPS 4003.01, Remote Shutdown..

Page 57 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HU4 HU3 Initiating Condition:

UNUSUAL EVENT FIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:

Initiating Condition:

FIRE potentially degrading the level of safety of the plant.Operating Mode Applicability:

1, 2, 3,4, 5, D M No Change FIDifference FIDeviation

1) Listed site specific list of plant rooms or areas that contain SAFETY SYSTEM equipment to ensure timely classification.

All Example Emergency Action Levels: (1 or 2 or 3 or 4)Note: The Emergency Director should declare the Unusual Event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. a. A FIRE is NOT extinguished within 15-minutes of ANY of the following FIRE detection indications:

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

• Receipt of multiple (more than 1) fire alarms or indications

• Field verification of a single fire alarm AND b. The FIRE is located within ANY of the following plant rooms or areas: (site-specific list of plant rooms or areas)2. a. Receipt of a single fire alarm (i.e., no other indications of a FIRE).AND b. The FIRE is located within ANY of the following plant rooms or areas: (site-specific list of plant rooms or areas)AND c. The existence of a FIRE is not verified within 30-minutes of alarm receipt.3. A FIRE within the plant or ISFSI [for plants with an ISFSI outside the plant Protected Area] PROTECTED AREA not extinguished within 60-minutes of the initial report, alarm or indication.

4. A FIRE within the plant or ISFSI (for plants with an ISFSI outside the plant Protected Area] PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.

Emergency Action Level (EAL): Note:* The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. A FIRE in ANY Table H2 area is not extinguished in < 15-minutes of ANY of the following FIRE detection indications:

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

• Receipt of multiple (more than 1) fire alarms or indications

• Field verification of a sinole fire alarm Table H2 Vital Areas* Containment

• Auxiliary Building* Fuel Building* Control Building* Diesel Generator

& HVAC Building* Screenhouse OR 2. a. Receipt of a single fire alarm in ANY Table H2 area (i.e., no other indications of a FIRE).AND b. The existence of a FIRE is not verified in < 30 minutes of alarm receipt.OR 3. A FIRE within the PROTECTED AREA not extinguished in < 60-minutes of the initial report, alarm or indication.

OR 4. A FIRE within the plant PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.

Page 58 of 66 NEI 99-0 Initiating Condition:

UNUSUAL EVENT Seismic event greater than OBE levels.Operating Mode Applicability:

1 Rev 6 Proposed EAL Justification

-.- -- + -l HUz HU4 Initiating Condition:

Seismic event greater than OBE levels.Operating Mode Applicability:

1,2, 3, 4,5, D Emergency Action Level (EAL):No Change -- Difference FIDeviation

1) Listed site specific measure of determining OBE limits have been exceeded to ensure timely classification.

All Example Emergency Action Levels: Seismic event greater than Operating Basis Earthquake (OBE) as indicated by: a. (site-specific indication that a seismic event met or exceeded OBE limits)Seismic event > Operating Basis Earthquake (OBE) as indicated by one or more of the following annunciators:

• 5009-2B (Acceleration Exceeded Operating Basis Earthquake (OBE) at 0.10 g)* 5009-2A (Acceleration Exceeded at Seismic Switch Operating Basis Earthquake at 0.11 g Horz / 0.11 g Vert on seismic switch 1VS-EM-014)

• 5009-IA (Acceleration Exceeded Safe Shutdown Earthquake (SSE) at 0.25 g)Page 59 of 66 NE199-01 Rev 6 Proposed EAL Justification HAS Initiating Condition:

ALERT Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.Operating Mode Applicability:

All Example Emergency Action Levels: Note: If the equipment in the listed room or area was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted.

1 .a. Release of a toxic, corrosive, asphyxiant or flammable gas into any of the following plant rooms or areas: (site-specific list of plant rooms or areas with entry-related mode applicability identified)

AND b. Entry into the room or area is prohibited or impeded.HAS Initiating Condition:

Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.Operating Mode Applicability:

1,2, 3,4, 5, D Emergency Action Level (EAL): Note: 0 If the equipment in the listed room or area was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted.

1. Release of a toxic, corrosive, asphyxiant or flammable gas in a Table H3 area.Table H3 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Auxiliary Building*

Modes 3.4, and 5 Auxiliary Building Steam Modes 4 and 5 Tunnel**Areas required to establish shutdown cooling AND 2. Entry into the room or area is prohibited or impeded F No Change FIDifference FIDeviation

1) Listed plant specific rooms and areas with entry related mode applicability to ensure timely classification.

Page 60 of 66 0 NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition:

UNUSUAL EVENT Hazardous Event Operating Mode Applicability:

HU3 HU6 All Example Emergency Action Levels: (1 or 2 or 3 or 4)Note: EAL #3 does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.

t A tornado strike within the PROTECTED AREA.2. Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component needed for the current operating mode.3. Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsile chemical spill or toxic gas release).4. A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.5. (Site-specific list of natural or technological hazard events)Initiating Condition:

Hazardous Event Operating Mode Applicability:

1,2. 3,4, 5, D Emergency Action Level (EAL): Note:[j] No Change [31 Difference Li Deviation 1) Adoed Abnormal Lake level as a natural or technological hazard events. The EAL value selected is the current approved UE EAL value.2) Changed the word "needed" to "required by Technical Specifications' in the EAL to be consistent with terminology used by operators and minimize confusion.

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

1. Tornado strike within the PROTECTED AREA OR 2. Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component required by Technical Specifications for the current operating mode.OR 3. Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an ofisite chemical spill or toxic gas release).OR 4. A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.OR 5. Abnormal lake level, as indicated by High lake level > 696ff.Page 61 of 66 S NEI 99-01 Rev 6 Proposed EAL Justification HG7 HG7- Dfeec Deito Initiating Condition:

GENERAL EMERGENCY Initiating Condition:

Gl7 No Change j Difference L Deviation Other conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrant declaration of a General Emergency.

declaration of a General Emergency.

Operating Mode Applicability:

Operating Mode Applicability:

All 1, 2, 3, 4, 5, D Example Emergency Action Levels Emergency Action Level (EAL): Other conditions exist which in the judgment of the Emergency Director indicate Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or IMMINENT that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility.

Releases can be reasonably expected to exceed EPA Protective Action the facility.

Releases can be reasonably expected to exceed EPA Protective theGfcidlity.

Rex lesels off-ste fomreasonably excth tohexediEPAte Ptecte A Action Guideline exposure levels off-site for more than the immediate site area..Guideline exposure levels off-site for more than the immediate site area.Page 62 of 66 0 NE199-01 Rev 6 Proposed EAL Justification HS7 HS7 m m D Initiating Condition:

SITE AREA EMERGENCY Initiating Condition: No Change L]Difference L] Deviation Other conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrant declaration of a Site Area Emergency.

declaration of a Site Area Emergency.

Operating Mode Applicability:

Operating Mode Applicability:

All 1, 2, 3,4, 5, D Example Emergency Action Levels: Emergency Action Level (EAL): Other conditions exist which in the judgment of the Emergency Director indicate Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major thents e in phe oud which invole a ctor ikeycajo failures of plant functions needed for protection of the public or HOSTILE ACTION that events are in progress or have occurred which involve actual or likely major that results in intentional damage or malicious acts; (1) toward site personnel or failures of plant functions needed for protection of the public or HOSTILE ACTION equipment that could lead to the likely failure of or; (2) that prevent effective that results in intentional damage or malicious acts; (1) toward site personnel or access to equipment needed for the protection of the public. Any releases are not equipment that could lead to the likely failure of or; (2) that prevent effective expected to result in exposure levels which exceed EPA Protective Action access to equipment needed for the protection of the public. Any releases are not Gudexp netedtoresutin exposure levels beexpected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.

Guideline exposure levels beyond the site boundary.Page 63 of 66 NEI 99-01 Rev 6 Proposed EAL Justification.HA7 HA7 mm Initiating Condition:

ALERT Initiating Condition:

E No Change [j Difference F Deviation Other conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert. declaration of an Alert.Operating Mode Applicability:

Operating Mode Applicability:

All 1, 2, 3, 4, 5, D Example Emergency Action Levels: Emergency Action Level (EAL): Other conditions exist which in the judgment of the Emergency Director indicate Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve an actual or potential tha substantial degradation of the level of safety of the plant or a security event that that events are in progress or have occurred which involve an actual or potential involves probable life threatening risk to site personnel or damage to site substantial degradation of the level of safety of the plant or a security event that equipment because of HOSTILE ACTION. Any releases are expected to be involves probable life threatening risk to site personnel or damage to site limited to small fractions of the EPA Protective Action Guideline exposure levels, equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.Page 64 of 66 NEI 99-01 Rev 6 Proposed EAL Justification HU7 HU7 mm -Initiating Condition:

UNUSUAL EVENT Initiating Condition:

[-- jj No Change [ Difference I Deviation Other conditions existing which in the judgment of the Emergency director warrant declaration of an UNUSUAL EVENT. Other conditions existing which in the judgment of the Emergency director warrant declaration of an UNUSUAL EVENT.Operating Mode Applicability:

Operating Mode Applicability:

All 1, 2, 3, 4, 5. D Example Emergency Action Levels: Other conditions exist which in the judgment of the Emergency Director indicate Emergency Action Level (EAL): that events are in progress or have occurred which indicate a potential Other conditions exist which in the judgment of the Emergency Director indicate degradation of the level of safety of the plant or indicate a security threat to facility that events are in progress or have occurred which indicate a potential protection has been initiated.

No releases of radioactive material requiring offsite degradation of the level of safety of the plant or indicate a security threat to facility response or monitoring are expected unless further degradation of safety systems protection has been initiated.

No releases of radioactive material requiring offsite occurs. response or monitoring are expected unless further degradation of safety systems occurs.Page 65 of 66 NEI 99-01 Rev 6 Proposed EAL Justification E-HU1 Initiating Condition:

UNUSUAL EVENT Damage to a loaded cask CONFINEMENT BOUNDARY.Operating Mode Applicability:

H1 No Change WIDifference 1 Deviation Clinton Station does not have an ISFSI, All Example Emergency Action Levels: Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than (2 times the site-specific cask specific technical specification allowable radiation level) on the surface of the spent fuel cask.Page 66 of 66 Clinton AnnAx Clinton Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARG1 Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 1000 mRfem TEDE or 5000 mRirem thyroid CDE.Operating Mode Applicability:

1,2, 3, 4,5, D Emergency Action Level (EAL): Notes: 9 The Emergency Director should declare the Gencral Emergency event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.o Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.9 The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

(1) Reading on ANY of the following radiation monRitors groatr than the voading shown for 15 minutes or longer (s~ite-spec~ific moneitor list and therseehod values.)1. The sum of readings on the HVAC and SGTS Radiation Monitors > 1.03 E+110 uCi/sec (..1.03 E+4 Ci/sec) for > 15 minutes (as found on Control room Panels or PPDS -Total Noble Gas Release Rate).OR 2. Dose assessment using actual meteorology indicates doses at or beyond (sote-sppeeifig dose ......oint the site boundary of EITHER: a. > 1000 mRem TEDE OR b. > 5000 mRem CDE Thyroid OR Month 20XX CL 3-1 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS F s ..V.. EITHER o the f kr m..naa. t O ..Fg beyon.d (s fIenl AqeIV %., I peIV i l glpi .nypgl*V Vl el IVI lV llI AflA iD/k l oiOPO~fnll4

• Vn k o,.n*.r VIIIV Geewindow dose m tev IQreateF thankv .l 0 in~h ixe~e to A-aVVVn-p iii -m 60 minues -,!P.P Il for one hou-r Of inhalation.

3. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates >1000 mRlhr are expected to continue for > 60 minutes.OR b. Analyses of field survey samples indicate > 5000 mnRemn CDE Thyroid for 60 minutes of inhalation.

Basis: This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases.

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

The TEDE dose is set at the EPA PAG of 1000 mRfem while the 5000 mRfem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.ffm I el m a ml las-i6tlcaVtln hasea on etmluent monitOrr r-aaings assumes na;t a rolase patn to tnc enirnmnt is, estabihd if the effluent flow past an effluent monGitor is known to hav stopped due- to- actions to isolate the release path, then the effluent moni~tor reading i-s no longer valid for classification purposes., I Month 20XX CL 3-2 EP-AA-1 003 (Revision XX)

Exalon Nuclear Clinton Annex Eeo ula RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Basis Reference(s):

1. NEI 99-01 Rev 6, AG1 2. EP-AA-1 12-500, Emergency Environmental Monitoring

3. ODCM Section 6.3.1, Gaseous Effluents and Total Dose 4. CPS 3315.03, Radiation Monitoring (AR/PR)5. CPS 4979.01, Abnormal Release of Airborne Radioactivity

6. EP-EAL-0603 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Clinton Station Month 20XX CL 3-3 EP-AA-1 003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Month 20XX CL 3-4 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Month 20XX CL 3-5 EP-AA-1 003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARS1 Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 100 mR_3em TEDE or 500 mRFem thyroid CDE.Operating Mode Applicability:

1,2,3,4,5, D Emergency Action Level (EAL): Notes: e The Emergency Director should declare the Sito Area Emergency event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.e Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.* The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

(1) Reading on ANY of the following Fadiation monitore greater than the reading shown for 15 Finutec or lon ger (cte-We~eifiG mRonitor lir.t and throchold valuec)(2) Doeo assessment using actual mneteGorlogy indicatec dosec greater than 100G mr~em TEDE Or 500 mrom~ thyroid CDE at or beyond (c'ite-sepoific doe recepto (3) Field survey rocult indicate EITHER of the following at or beyond (cite-epecific_

deco receptor point): " Closed window dose fates greater than 100 mRP4f exipected to continue for- 60 fpnutes" Analyses of field sur.'ey samples indieate thyroid GDE gr-eater than 500 rnfem for- one hour of inhalation.

1. The sum of readings on the HVAC and SGTS Radiation Monitors_>

1.03 E+09 uCi/sec C_1.03 E+3 Ci/sec) for > 15 minutes (as found on Control room Panels or PPDS -Total Noble Gas Release Rate).OR Month 20XX CL 3-6 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS 2. Dose assessment usina actual meteoroloav indicates doses at or bevond the site boundary of EITHER: a. > 100 mRem TEDE OR b. > 500 mRem CDE Thyroid OR 3. Field survey results at or beyond the site boundarv indicate EITHER: a. Gamma (closed window) dose rates >100 mR/hr are expected to continue for > 60 minutes.OR b. Analyses of field survey samples indicate > 500 mRem CDE Thyroid for 60 minutes of inhalation.

Basis: This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs).It includes both monitored and un-monitored releases.

Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public.Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 10% of the EPA PAG of 1000 mRfem while the 500 mRfem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.Classification basod on offluent.

moneitor readings assumos that a reloase path to the irs established.

If tho effluont flow part an effluent monitor is known to H*V t*tPd.-1 t1H tt tf1H t f"M H8Flae M ,tW h flet O19 edn I iS no- lonwo vand for clAasslmrcation Durposce.I I Escalation of the emergency classification level would be via IC RAG1.Month 20XX CL 3-7 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Basis Reference(s):

1. NEI 99-01 Rev 6, AS1 2. EP-AA-1 12-500, Emergency Environmental Monitoring

3. ODCM Section 6.3.1, Gaseous Effluents 4. CPS 3315.03, Radiation Monitoring (AR/PR)5. CPS 4979.01, Abnormal Release of Airborne Radioactivity

6. EP-EAL-0603 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Clinton Station Month 20XX CL 3-8 EP-AA-1 003 (Revision XX)

Annov I::ylnn Ki"Mlar (~I ntr~n An nv Fvn inn Mm iIn~r RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARA1 Initiating Condition:

Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mR-em TEDE or 50 mRfem thyroid CDE.Operating Mode Applicability:

1, 2, 3, 4,5, D Emergency Action Level (EAL): Notes:* The Emergency Director should declare the Alei-event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.* If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.I e Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.e The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

1-4\

--- A KAV -& L_-&-I-.:

--:- : :-.- ---&- l -- L -.---: --..kl ) Reading Ui;u on e. iuiiuowiiy CIaUItLIVII MeiUtILUm gFeatF thani the Feaing~ shown1 (Site Specific monitor list and threshold v.alucs)TFRDR or !FO wmrnm thurnid CDPF 5t nr hra"nncl (nztaift'prt-afit cdnio ranantnr nnintlIr_jr ... -%-I .-......-,.v, ..... I" (3) Analy.s-,, of a liquid off luent sample indicate, a concentration lease rate that woeuld result in doses grcater than 10 mnrem TEDE Or 50 mremF thyroid CDE ato beyond (site-specific dose receptor point) for one hour of exposure-.

(4) Field sur':cy results indicate EITHER of the following at Or beyond (site-specificv dose r9GeptFr point).e Closed window dose rates than 10 'nm!r-. expe-ted to for- 60 ,,intes er leagen I-A ýýa ~naivses 01 iieiu survey sainDles inuicate HP.TOiU ~ ~rea~er man ou mrem ior one hourf of inihalatieon.

X Month 20XX CL 3-9 EP-AA-1 003 (Revision XX) f.linfo~n Anndav IPvialrnn NRirlhaar V~i nvi ll rid IIIFk qvIn M 1151Vl551 RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS 1. The sum of readings on the HVAC and SGTS Radiation Monitors > 1.03 E+08 uCi/sec (> 1.03 E+2 Ci/sec) for > 15 minutes (as found on Control room Panels or PPDS -Total Noble Gas Release Rate).OR 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER: a. > 10 mRem TEDE OR b. > 50 mRem CDE Thyroid OR 3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses areater than EITHER of the following at or beyond the site boundary: a. 10 mRem TEDE for 60 minutes of exposure OR b. 50 mRem CDE Thvroid for 60 minutes of exposure OR 4. Field survey results at or beyond the site boundary indicate EITHER: a. Gamma (closed window) dose rates > 10 mR/hr are expected to continue for > 60 minutes.OR b. Analyses of field survey samples indicate > 50 mRem CDE Thyroid for 60 minutes of inhalation.

Basis: This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases.

Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of Month 20XX CL 3-10 EP-AA-1003 (Revision XX)

(.lintnn Annoy I:yalnn Nia-loar (~I intnn A nn~v Fv.Inn IJuar~I.~r RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1000 mR-em while the 50 mR-em thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.C-lassidroficatin based on effluent moenitor roadings assumes that a rcloaso path to the onvironmont is established.

if the offluent flow pata ffluont moenitor is known to have stopped duo to actions to slt tho rocspt, then the effluent moenitor Feading is no longer valid for classificatio pupSes Escalation of the emergency classification level would be via IC RASI.Basis Reference(s):

1. NEI 99-01 Rev 6, AA1 2. ODCM Section 6.3.1, Gaseous Effluents 3. ODCM Section 6.3.2, Liquid Effluents 4. CPS 3315.03, Radiation Monitoring (AR/PR)5. CPS 4979.01, Abnormal Release of Airborne Radioactivity

6. CPS 4979.05, Abnormal Release of Radioactive Liquids 7. USAR Section 11.5.2.2.6, Liquid Radwaste Discharge Radiation Monitor 8. USAR Figure 2.1-7, CPS Restricted Area 9. EP-EAL-0603 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Clinton Station 10. EP-EAL-0621, Clinton Criteria for Choosing Radiological Liquid Effluent EAL Threshold Values Month 20XX CL 3-11 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARUM Initiating Condition:

Release of gaseous or liquid radioactivity greater than 2 times the ODCM .(ste-speGift A -fAlnt rloas;o contr olling document) limits for 60 minutes or longer.Operating Mode Applicability:

1, 2,3, 4,5, D Emergency Action Level (EAL): Notes: e The Emergency Director should declare the Un.usual E'-nt cvent promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded.e If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes.e Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.(1) Reading on ANY effluent radiation moenitor greater than -2 time-s the (site SPecifi effluent release controlling document) limits for 690 minutes or lo90F nger: (site-specific monitor list and threshold values corresponding to 2 timcs the controlling document limits)(2) Reading on ANY effluent radiation moniito greater thar 2 times the alarm setpoint established by a current radioactivity discharge permit for 60 minutes or lengcr.(3) Sample analysis for a gaseous or liquid release indicates a concentration oe roloaso rate greater than 2 times the (site-specific effluent release controlling document) limiotsA fo-r 60e minut~es Or longer.1. VALID reading on any of the following effluent monitors > 2 times alarm setpoint established by a current radioactivity discharge permit for > 60 minutes.* Radwaste Effluent Monitor ORIX-PRO40 OR* Discharge Permit specified monitor OR 2. The sum of readings on the HVAC and SGTS Radiation Monitors> 1.17 E+06 uCVsec (> 1.17 Cisec) for > 60 minutes (as found on Control room Panels or PPDS -Total Noble Gas Release Rate).OR Month 20XX CL 3-12 EP-AA-1003 (Revision XX) f.lintnn Anni-zv IPvAImln N"Aml-ar (~I mntr~n A ~v~Ir~ii Mm .,.I~ar RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS 3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 2 times ODCM Limit with a release duration of > 60 minutes.1. H14VA and SGTS8 Radiation 1.1706 (1.17 )WfOUnr on Control room DPanls or Basis: This IC addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release).

It includes any gaseous or liquid radiological release, monitored or un-monitored, including those for which a radioactivity discharge permit is normally prepared.Nuclear power plants incorporate design features intended to control the release of radioactive effluents to the environment.

Further, there are administrative controls established to prevent unintentional releases, and to control and monitor intentional releases.

The occurrence of an extended, uncontrolled radioactive release to the environment is indicative of degradation in these features and/or controls.Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

Glassification based on effluent monitor readings assumes that a rolcase patht the ,o.irOment ie established.

if the effluent flo, past an effluent mro'nit is knon to have stopped duo to actions to isolate the release path, then the effluent monitor r-eading is no longer valid for classification puF6rpose.

Releases should not be prorated or averaged.

For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.EAL #1 Basis: EA--#2-- This EAL addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This EAL will typically be associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste aas.EAL #2 Basis: EAL--#-I-This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous,,F liqid effluent pathways.Month 20XX CL 3-13 EP-AA-1003 (Revision XX)

M.intrnn Annoy I=:alrnn N,,ilaar (~Iintnn Ann.v Fv.Inn Mm .iIm~ar RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS EAL #3 Basis: SAL-#3 --This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).Escalation of the emergency classification level would be via IC RAA1.Basis Reference(s):

1. NEI 99-01 Rev 6, AU1 2. ODCM Section 6.3.1, Gaseous Effluents 3. ODCM Section 6.3.2, Liquid Effluents 4. CPS 3315.03, Radiation Monitoring (AR/PR)5. CPS 4979.01, Abnormal Release of Airborne Radioactivity

6. CPS 4979.05, Abnormal Release of Radioactive Liquids 7. USAR Section 11.5.2.2.6, Liquid Radwaste Discharge Radiation Monitor 8. EP-EAL-0603 Revision 1, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Values Clinton Station Month 20XX CL 3-14 EP-AA-1003 (Revision XX)

Explon Nuclear Clinton Annex Eeo ula RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARA2 Initiating Condition:

Significant lowering of water level above, or damage to, irradiated fuel.Operating Mode Applicability:

1,2,3,4,5, D Emergency Action Level (EAL): 14\ I I r , rM , f,,e1 ir; +k^ Dr-= IMlIk1*-%

DAT-LflAIAV

\'~1 I (2) Damago to irradiated fuol roculting in a roloaso of rad-ioactivity from tho fuel as indicatod by ANY of the following Fadiation mone~torc: (cite-specific listing of radiation monnitor-s, and the associatod readings, cotpointS n~d/o0r- al-armS)(3) LoWering of spont fuel pool level to (site specific Lovel 2 value). [See DoVW/QpeF 1. Uncovery of irradiated fuel in the REFUELING PATHWAY.OR 2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by ANY Table R1 Radiation Monitor reading >1000 mRem/hr Table R1 Fuel Handling Incident Radiation Monitors" Fuel Building Exhaust (1 PR006A-D)" CCP Exhaust (1 PR042A-D)" Containment Exhaust (1 PRO01 A-D)* Containment Fuel xfer Plenum (1 PR008A-D)Basis: REFUELING PATHWAY: all the cavities, tubes, canals and Pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange.Month 2QXX CL 3-15 EP-AA-1 003 (Revision XX) rlinton Anngv=~vmlnn hisiAgl-ar RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS IMMINENT:

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

The irradiated fuel dry storage cask barrier(s) between areas containing radioactive substances and the environment.

This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly., or a significant low..ing of water- +o-, l K tin the .p.nt fuel pool seo.Developr " ' -,. These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment.

As such, they represent an actual or potential substantial degradation of the level of safety of the plant.This IC applies to irradiated fuel that is licensed for dry storage up to the point that the loaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss of the CONFINEMENT BOUNDARY is classified in accordance with IC E-HU1.of tho omorgqopn.

Woud on oh ognition antoo..' A or C 1_. .EAL #1 Basis: EAL #4 This EAL escalates from RAU2 in that the loss of level, in the affected portion of the REFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery of irradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visual observation (e.g., reports from personnel or camera images), as well as significant changes in water and radiation levels, or other plant parameters.

Computational aids may also be used (e.g., a boil-off curve). Classification of an event using this EAL should be based on the totality of available indications, reports and observations.

While an area radiation monitor could detect an arise in a dose rate due to a lowering of water level in some portion of the REFUELING PATHWAY, the reading may not be a reliable indication of whether or not the fuel is actually uncovered.

To the degree possible, readings should be considered in combination with other available indications of inventory loss.A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.EAL #2 Basis: EAL-#2 Month 20XX CL 3-16 EP-AA-1003 (Revision XX)

(.Ii ntrfn Annoav Fvdalnn Rhmm-loar RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS This EAL addresses a release of radioactive material caused by mechanical damage to irradiated fuel. Damaging events may include the dropping, bumping or binding of an assembly, or dropping a heavy load onto an assembly.

A rise in readings on radiation monitors should be considered in conjunction with in-plant reports or observations of a potential fuel damaging event (e.g., a fuel handling accident).

Escalation of the emergency would be based on either Recognition Cateqory RA-or C l~s.Spont fuel pooavl w-ater level at this value is within the lowevwr endu ofl the level necossar,'

to prevent significant dose consequence6 fromn direct gamma radiation to nmnne piqnfe~minfl lane ationrsh in the1 yani *ni. of. thespent Ufuer~l nee!* Thu GendIn.VVl I to a less of the ability to adequately cool the +mad.at. fuel amrs;srmbes stored in the pool.EGcalation of the emergency Glassification level would be via v6 AS! or AS2.(see A*Develoer Aktes).Basis Reference(s):

1. NEI 99-01 Rev 6, AA2 2. USAR 1.2.2.4.11.3

3. Technical Specifications 3.7.7 4. CPS 4011.02, Spent Fuel Pool Abnormal Water Level Drop 5. MA-CL-716-102, Reactor Disassembly Month 20XX CL 3-17 EP-AA-1003 (Revision XX)

Exalon Nuclear Clinton Annex Eeo ula RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARU2 Initiating Condition:

UNPLANNED loss of water level above irradiated fuel.Operating Mode Applicability:

1,2,3,4,5, D Emergency Action Level (EAL): (1) a. UNPLANNED wator level drop in the REFUELING PATHWAY as by ANY of the following: (site specific level indications)-.

AND b. UNPLANNED rise in area radiation levels as indicated by ANY of the following Iadiation monitors.(site-speciffic list of arean rad-iation moenitors)

1. a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated by ANY of the following: " Refueling Cavity water level < 22 ft. 8 in. above the Reactor Vessel Flange OR" Spent Fuel Pool or Upper Containment Fuel Storage Pool water level< 23 ft.OR" Indication or report of a drop in water level in the REFUELING PATHWAY.AND b. UNPLANNED Area Radiation Monitor reading rise on one or more radiation monitors in Table RI.Table R1 Fuel Handlina Incident Radiation Monitors" Fuel Building Exhaust (1 PRO06A-D)" CCP Exhaust (1 PR042A-D)* Containment Exhaust (1 PRO01 A-D)" Containment Fuel xfer Plenum (1 PRO08A-D)Month 20XX CL 3-18 EP-AA-1003 (Revision XX)

Plinftnn Anngoy I:valnn N"lrAgmr 1~Iintr~n Ann~v Fv.inn Mi irI~ar RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Basis: UNPLANNED:

A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.

The cause of the parameter change or event may be known or unknown.REFUELING PATHWAY: all the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange.This IC addresses a deGrease loss in water level above irradiated fuel sufficient to cause elevated radiation levels. This condition could be a precursor to a more serious event and is also indicative of a minor loss in the ability to control radiation levels within the plant. It is therefore a potential degradation in the level of safety of the plant.I A water level derease-loss will be primarily determined by indications from available level instrumentation.

Other sources of level indications may include reports from plant personnel (e.g., from a refueling crew) or video camera observations (if available) or from any other temporarily installed monitoring instrumentation.

A significant drop in the water level may also cause an iGFeaserise in the radiation levels of adjacent areas that can be detected by monitors in those locations.

The effects of planned evolutions should be considered.

For example, a refueling bridge area radiation monitor reading may iiieeaserise due to planned evolutions such as lifting of the reactor vessel head or movement of a fuel assembly.

Note that this EAL is applicable only in cases where the elevated reading is due to an UNPLANNED loss of water level.A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.Escalation of the emergency classification level would be via IC RAA2.Basis Reference(s):

1. NEI 99-01 Rev 6, AU2 2. RP-AA-203, Exposure Control and Authorization

3. Technical Specifications 3.7.7 4. CPS 4011.02, Spent Fuel Pool Abnormal Water Level Drop 5. USAR Figure 3.8-31 6. USAR Table 7.1-13 7. USAR 9.1.4.2.10

8. MA-CL-716-102, Reactor Disassembly Month 20XX CL 3-19 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear Clinton Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS ARA3 Initiating Condition:

Radiation levels that impede access to equipment necessary for normal plant operations, cooldown or shutdown.Operating Mode Applicability:

1,2,3, 4,5, D Emergency Action Level (EAL): I Note: If the equipment in the listed-room or area listed in Table R3 was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted (1) Dose rate gFrater than 15 mR/hr in ANY of the following areas: e CCntrol RoomIA 5* Central Alarm Station S(other- site speeific areaskeems)

(2) An UNPLANNhED event rocults in radiation levels that pro-hibit.

or impede accoec to an" of the following plant FoomseFo aroasc: (cite-sepoific list of plant rooems Or aroac with entrY related Mode applicability

1. Dose rate eirate~-thai>

15 mR/hr in ANY of the following Table R2 areas: Table R2 Areas Requiring Continuous Occupancy 0 Main Control Room (1 RIX-AR035)

• Central Alarm Station -(by survey)OR Month 20XX CL 3-20 EP-AA-1 003 (Revision XX)

NuelAar Clinton Annex Exelon Nuclanr RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS 2. UNPLANNED event results in radiation levels that prohibit or significantly impede access to any of the following Table R3 plant rooms or areas: Table R3 Areas with Entrv Related Mode ADDlicabilitv Area Entry Related Mode Apjplicability Auxiliary Building*

Modes 3, 4, and 5 Auxiliary Building Modes 4 and 5 Steam Tunnel**Areas required to establish shutdown cooling Basis: UNPLANNED:

A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.

The cause of the parameter change or event may be known or unknown.This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or impede personnel from performing actions necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal plant procedures-maintain ormal plant operation, Or to perform a normaI plant -oldo1wn and shu-td-own.

As such, it represents an actual or potential substantial degradation of the level of safety of the plant. The Emergency Director should consider the cause of the increased radiation levels and determine if another IC may be applicable.

Table R3 is a list of plant rooms or areas with entry-related mode applicability that contain eguipment which reguire a manual/local action necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal operating procedures (establish shutdown cooling), where if this action is not completed the plant would not be able to attain and maintain cold shutdown.

This Table does not include rooms or areas for which entry is required solely to perform actions of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

Rooms and areas listed in EAL #1 do not need to be included in EAL #2, including the Control Room.For EAL #2, an Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect and the elevated radiation levels preclude the ability to place shutdown cooling in serviccat the time of tho elceatod radtiatfin lovols. The emergency classification is not contingent upon whether entry is actually necessary at the time of the increased radiation levels. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., installing temporary shielding beyond that Month 20XX CL 3-21 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS required by procedures, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits).An emergency declaration is not warranted if any of the following conditions apply." The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the elevated radiation levels). For example, the plant is in Mode 1 when the radiation i, G-ea erise occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.* The increased radiation levels are a result of a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., radiography, spent filter or resin transfer, etc.)." The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections)." The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.Escalation of the emergency classification level would be via Recognition Category BA, C or F ICs.Basis Reference(s):

1. NEI 99-01 Rev 6, AA3 2. USAR Table 12.3-2 3. USAR Appendix F, Fire Protection Safe Shutdown Analysis Month 20XX CL 3-22 EP-AA-1 003 (Revision XX)

I'.lintnn AnnovY I:=alnn N"Aarlr E~Iintrrn A nnv Fvalnn mu1.nr RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS SRU3 Initiating Condition:

Reactor coolant activity greater than Technical Specification allowable limits.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): (1) (Site rpecific radiation monitor) reading greater than (;ito-speGif Yalu,,.(2) Samplo analysis thata reactor colant actiVity'value is greater than an allowable limit sepoified in T-echnicaI SpecificationSS.

1. Offgas post-treatment radiation monitor 1 RIX-PR035/41 channel 7 HI alarm.OR 2. Specific coolant activity > 4.0 uCI/gm Dose equivalent 1-131.Basis: This IC addresses a reactor coolant activity value that exceeds an allowable limit specified in Technical Specifications.

This condition is a precursor to a more significant event and represents a potential degradation of the level of safety of the plant.Conditions that cause the specified monitor to alarm that are not related to fuel clad degradation should not result in the declaration of an Unusual Event.This EAL addresses site-specific radiation monitor readings that provide indication of a degradation of fuel clad integrity.

An Unusual Event is only warranted when actual fuel clad damage is the cause of the elevated coolant sample activity (as determined by laboratory confirmation).

Fuel clad damage should be assumed to be the cause of elevated Reactor Coolant activity unless another cause is known.Escalation of the emergency classification level would be via ICs FA1 or the Recognition Category BA ICs.Month 20XX CL 3-23 EP-AA-1003 (Revision XX)

Exellon Nuclear Clinton Annex Eeo ula RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Basis Reference(s):

1. NEI 99-01 Rev 6, SU3 2. Technical Specifications 3.4.8 3. USAR 3.7.5 4. CPS 3215.01, Off-Gas (OG)5. CPS 5140.46, AR/PR Annunciator

-Off Gas Post-Treat PRM #1 -1 RIX-PR035 6. CPS 5140.47, AR/PR Annunciator

-Off Gas Post-Treat PRM #2 -1 RIX-PRO41 7. CPS 4004.02, Loss of Vacuum Month 20XX CIL 3-24 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FG1 Initiating Condition:

Loss of ANY Two Barriers AND Loss or Potential Loss of the third barrier.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.Basis: Fuel Cladding, RCS and Containment comprise the fission product barriers.At the General Emergency classification level each barrier is weighted equally.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 Month 20XX CL 3-25 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FS1 Initiating Condition:

Loss or Potential Loss of ANY two barriers.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.Basis: Fuel Cladding, RCS and Containment comprise the fission product barriers.At the Site Area Emergency classification level, each barrier is weighted equally.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 Month 20XX CL 3-26 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FA1 Initiating Condition:

ANY Loss or ANY Potential Loss of either Fuel Clad or RCS.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Refer to Fission Product Barrier Loss and Potential Loss threshold values to determine barrier status.Basis: Fuel Cladding, RCS and Containment comprise the fission product barriers.At the Alert classification level, Fuel Cladding and RCS barriers are weighted more heavily than the Containment barrier. Unlike the Containment barrier, loss or potential loss of either the Fuel Cladding or RCS barrier may result in the relocation of radioactive materials or degradation of core cooling capability.

Note that the loss or potential loss of Containment barrier in combination with loss or potential loss of either Fuel Cladding or RCS barrier results in declaration of a Site Area Emergency under EAL FSI.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 Month 20XX CL 3-27 EP-AA-1 003 (Revision XX)

Exelon Nuclear Clinton Annex Eeo ula RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC1 Initiating Condition:

RCS Activity Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

LOSS A. (Sito Specific indications that rcactor coolant actiVity is groater than 300uGi/gm dos Coolant activity > 300 uCi/lrm Dose Equivalent 1-131.Basis: This threshold indicates that RCS radioactivity concentration is greater than 300 p.Ci/gm dose equivalent 1-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.It is recognized that sample collection and analysis of reactor coolant with highly elevated activity levels could require several hours to complete.

Nonetheless, a sample-related threshold is included as a backup to other indications.

There is no Potential Loss threshold associated with RCS Activity.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. CPS 4010.01, Reactor Coolant High Activity Month 20XX CL 3-28 EP-AA-1 003 (Revision XX)

(N.intnn Annoyv IFvalnn Nn,-loar (~Iintnn Ann~v Fv~Inn f~iuuri.~r RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC2 Initiating Condition:

RPV Water Level Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

LOSS A.-1. Plant conditions indicate Primary CGontainment flooding is required.POTENTIAL LOSS A-.2. RPV water level cannot be restored and maintained above (site RPV Water lovel corr..ponding to thv top o^f act'+'" fu"l)> -162 inches (TAF)Gr-OR 3. RPV water level cannot be determined.

Basis: RPV values are actual levels, not indicated levels. Therefore, they may need level compensation depending on conditions.

Compensated values may be used in accordance with the SAMG program.Loss 2-.AThreshold

1. 1 Basis The Loss threshold represents the EOP requirement for primary containment flooding.This is identified in the Boiling Water Reactor Owners Group (BWROG.EPGsEOPs/SAGs when the phrase, "Primary Containment Flooding Is Required," appears. Since a site-specific RPV water level is not specified here, the Loss threshold phrase, "Primary containment flooding required," also accommodates the EOP need to flood the primary containment when RPV water level cannot be determined and core damage due to inadequate core cooling is believed to be occurring.

Potential Loss 2AThreshold

1. 2 and #3 Basis: This water level corresponds to the top of the active fuel and is used in the EOPs to indicate a challenge to core cooling.The RPV water level threshold is the same as RCS Bbarrier RC2 Loss threshold.-2-.X Thus, this threshold indicates a Potential Loss of the Fuel Clad barrier and a Loss of the RCS barrier that appropriately escalates the emergency classification level to a Site Area Emergency.

This threshold is considered to be exceeded when, as specified in the site-specific EOPs, RPV-watei'RPV water level cannot be restored and maintained above the specified level following depressurization of the RPV (either manually, automatically or by failure of the RCS barrier) or when procedural guidance or a lack of low pressure Month 20XX CL 3-29 EP-AA-1 003 (Revision XX)

Anngay I=Yalnn Nin-loar f~I intr~n A nn~v Fv.inn Ni,~Iaizar RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RPV injection sources preclude Emergency RPV depressurization.

EOPs allow the operator a wide choice of RPV injection sources to consider when restoring RPV water level to within prescribed limits. EOPs also specify depressurization of the RPV in order to facilitate RPV water level control with low-pressure injection sources. In some events, elevated RPV pressure may prevent restoration of RPV water level until pressure drops below the shutoff heads of available injection sources. Therefore, this Fuel Clad barrier Potential Loss is met only after either: 1) the RPV has been depressurized, or required emergency RPV depressurization has been attempted, giving the operator an opportunity to assess the capability of low-pressure injection sources to restore RPV water level or 2) no low pressure RPV injection systems are available, precluding RPV depressurization in an attempt to minimize loss of RPV inventory.

The term "cannot be restored and maintained above" means the value of RPV water level is not able to be brought above the specified limit (top of active fuel). The determination requires an evaluation of system performance and availability in relation to the RPV water level value and trend. A threshold prescribing declaration when a threshold value cannot be restored and maintained above a specified limit does not require immediate action simply because the current value is below the top of active fuel, but does not permit extended operation below the limit; the threshold must be considered reached as soon as it is apparent that the top of active fuel cannot be attained.Entry into the "Steam Cooling" leg of the EOP's would be an example of an inability to"restore and maintain" level above TAF resulting in this threshold being met.In high-power ATWS/failure to scram events, EOPs may direct the operator to deliberately lower RPV water level to the top of active fuel in order to reduce reactor power. RPV water level is then controlled between the top of active fuel and the Minimum Steam Cooling RPV Water Level (GRW-'NL^.

Although such action is a challenge to core cooling and the Fuel Clad barrier, the immediate need to reduce reactor power is the higher priority.

For such events, ICs SA&-MA3 or SS5-MS3 will dictate the need for emergency classification.

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

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. 4401.01, EOP-1 RPV Control 3. 4404.01, EOP-1 ATWS RPV Control 4. 4403.01, EOP-2 RPV Flooding 5. Clinton Power Station Severe Accident Guidelines Technical Bases 6. STA/IA Guide/1 005.09M002

7. Clinton Power Station Emergency Operating Procedures Technical Bases Month 20XX CL 3-30 EP-AA-1003 (Revision XX)i Clinton Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION

8. 4000.01, Abnormal RPV Water Level Month 20XX CL 3-31 EP-AA-1003 (Revision XX) 9'11intnn Ann-v Fvalnn K,,-lma~r RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC54 Initiating Condition:

Primary Containment Radiation Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

LOSS A. Primary containm.ent.

radiation mGoito9r eading greater than , value)1. Drywell radiation monitor reading > 260 R/hr (> 2.60 E+02 R/hr).OR 2. Containment radiation monitor reading > 41.3 R/hr (4.13 E+01 R/hr).Basis: Less 4.The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that reactor coolant activity equals 300 gCi/gm dose equivalent 1-131. Reactor coolant activity above this level is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. Since this condition indicates that a significant amount of fuel clad damage has occurred, it represents a loss of the Fuel Clad Barrier.The radiation monitor reading in this threshold is higher than that specified for RCS Barrier RC5 Loss Tthresholds 4-A-since it indicates a loss of both the Fuel Clad Barrier and the RCS Barrier. Note that a combination of the two monitor readings appropriately escalates the emergency classification level to a Site Area Emergency.

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

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. Core Damage Assessment Methodology Month 20XX CL 3-32 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear Clinton Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC76 Initiating Condition:

Emergency Director Judgment.Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

LOSS 1A. Any condition in the opinion of the Emergency Director that indicates Loss of the Fuel Clad Barrier.POTENTIAL LOSS 2A. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.Basis: Loss Threshold

1. 1 Basis This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the Fuel Clad Barrier is lost.Potential Loss Threshold

1. 2 Basis Potential Loss 6.A This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Fuel Clad Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 Month 20XX CL 3-33 EP-AA-1003 (Revision XX)

Clinton Annex Exallon Nuclear Clinton Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC2 Initiating Condition:

RPV Water Level Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

LOSS 1. RPV water level cannot be restored and maintained above (sit -specific RPV wato,....'oI .or..onin

,,.,to the top of fu!> -162 inches (TAF)or-OR 2. RPV water level cannot be determined.

Basis: LesG-2-.RPV values are actual levels, not indicated levels. Therefore, they may need level compensation depending on conditions.

Compensated values may be used in accordance with the SAMG program.This water level corresponds to the Ttop of Aactive Ffuel (TAF) and is used in the EOPs to indicate challenge to core cooling.The RPV water level threshold is the same as Fuel Clad Bbarrier FC2 Potential Loss threshold-2-A.

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

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

Month 20XX CIL 3-34 EP-AA-1003 (Revision XX)

Clinton Annex Exellon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION The term, "cannot be restored and maintained above," means the value of RPV water level is not able to be brought above the specified limit (top of active fuel). The determination requires an evaluation of system performance and availability in relation to the RPV water level value and trend. A threshold prescribing declaration when a threshold value cannot be restored and maintained above a specified limit does not require immediate action simply because the current value is below the top of active fuel, but does not permit extended operation beyond the limit; the threshold must be considered reached as soon as it is apparent that the top of active fuel cannot be attained.Entry into the "Steam Cooling" leg of the EOP's would be an example of an inability to"restore and maintain" level above TAF resulting in this threshold being met.In high-power ATWS/failure to scram events, EOPs may direct the operator to deliberately lower RPV water level to the top of active fuel in order to reduce reactor power. RPV Wat.. level is then controlled between the top of active fuel and the inimu,.m Steam Cooling RPV W^.;ate. r L.evol (MSC^,RWL).

Although such action is a challenge to core cooling and the Fuel Clad barrier, the immediate need to reduce reactor power is the higher priority.

For such events, ICs SAS-MA3 or SS-MS3 will dictate the need for emergency classification.

There is no RCS Potential Loss threshold associated with RPV Water Level.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. 4401.01, EOP-1 RPV Control 3. Clinton Power Station Emergency Operating Procedures Technical Bases, Section 4. 4001.01, Reactor Coolant Leakage Month 20XX CL 3-35 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear Clinton Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC3I-Initiating Condition:

I Primary Containment P-r-eumfeConditions Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

LOSS A. Piirimary containmrent preSSUre greater than (site spccific valuc) due to RCS leakage-.1. Drvwell pressure >1.68 psig.AND 2. Drywell pressure rise is due to RCS leakage Basis: L-ess--1-A The (site- specific.

V.al.ue),->

1.68 psig prim"ar; contaf.inment.

pressure is the diywe Drywell high pressure setpoint which indicates a LOCA by automatically initiating the-ECCS-oi The second threshold condition focuses the fission product barrier loss threshold on a failure of the RCS instead of the non-LOCA malfunctions that may adversely affect Drywell pressure.

Pressures of this magnitude can be caused by non-LOCA events such as a loss of Drywell cooling or inability to control Drywell vent/purge.

The release of mass from the RCS due to the as-designed/expected operation of any relief valve does not warrant an emergency classification.

A stuck-open Safety Relief Valve (SRV) or SRV leakage is not considered either identified or unidentified leakage by Technical Specification and, therefore, is not applicable to this EAL.There is no RCS Potential Loss threshold associated with Primary Containment Pressure.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. 4401.01, EOP-1 RPV Control 3. 4402.01, EOP-6 Primary Containment Control 4. Clinton Power Station EOP Technical Bases 5. Technical Specifications Table 3.3.1.1-1 6. Technical Specifications Table 3.3.5.1-1 Month 20XX CL 3-36 EP-AA-1003 (Revision XX)

.lintenn Annoy Fyalnn N"rlanr RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION

7. 4001.01, Reactor Coolant Leakage Month 20XX CL 3-37 EP-AA-1 003 (Revision XX)

Annghv I::Yalnn Nlirlhuar E~I I ntr~n A nn~v Fv~Inn hI..rIo~mr RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC43 Initiating Condition:

RCS Leak Rate Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

LOSS Al. UNISOLABLE Main Steam Line (MSL), Feedwater, RWCU, or RCIC line break._-i.ANTY of the foallowing: (sitoe-pcific syste ms with potontial for high energy pbrke OR B2. Emergency RPV Depressurization is required.POTENTIAL LOSS 3A. UNISOLABLE primary system leakage that results in EITHER of the following:

a4-. Secondary Containment area temperature

> EOP-8 MaximumMax Normal 6operating T-empeatuFelevels.

OR b2. Secondary Containment area radiation level > EOP-8 Maximum Max-Normal boperating Area Radiation "Level.Basis: UNISOLABLE:

An open or breached system line that cannot be isolated, remotely or locally.Classification of a system break over system leakage is based on information available to the Control Room from the event. Indications that should be considered are: " Reports describinq magnitude of steam or water release." Use of system hiqh flow alarms / indications, if available," Significant changes in makeup requirements," Abnormal reactor water level changes in response to the event.The use of the above indications provides the Control Room the bases to determine that the on going event is more siqnificant than the indications that would be expected from system leakage and therefore should be considered a system break.Month 20XX CL 3-38 EP-AA-1003 (Revision XX)

Mlintr, n A nngbv I:v-alon M, ,tl-ar 1~ I. m~tr~n An nay FvaIr~n Mi .r~Ia~r RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Loss Threshold

1. 1 Basis-&A Large high-energy lines that rupture outside primary containment can discharge significant amounts of inventory and jeopardize the pressure-retaining capability of the RCS until they are isolated.

If it is determined that the ruptured line cannot be promptly isolated from' tkhe rol o-om, the RCS barrier Loss threshold is met.Loss Threshold

1. 2 Basis-3.13 Emergency RPV Depressurization in accordance with the EOPs is indicative of a loss of the RCS barrier. If Emergency RPV Depressurization is performed, the plant operators are directed to open safety relief valves (SRVs) and keep them open. Even though the RCS is being vented into the suppression pool, a Loss of the RCS barrier exists due to the diminished effectiveness of the RCS to retain fission products within its boundary.Potential Loss Threshold-

1. 3 Basis &A Potential loss of RCS based on primary system leakage outside the primary containment is determined from EOP temperature or radiation Max Normal Operating values in areas such as main steam line tunnel, RCIC, HPGI, etc., which indicate a direct path from the RCS to areas outside primary containment.

A Max Normal Operating value is the highest value of the identified parameter expected to occur during normal plant operating conditions with all directly associated support and control systems functioning properly.The indicators reaching the threshold barriers and confirmed to be caused by RCS leakage from a primary system warrant an Alert classification.

A primary system is defined to be the pipes, valves, and other equipment which connect directly to the RPV such that a reduction in RPV pressure will effect a decrease in the steam or water being discharged through an unisolated break in the system.In general, multiple indications should be used to determine if a primary system is discharging outside Primary Containment.

For example, a high area radiation condition does not necessarily indicate that a primary system is discharging into the Reactor Building since this may be caused by radiation shine from nearby steam lines or the movement of radioactive materials.

Conversely, a high area radiation condition in coniunction with other indications (e.g. room flooding, high area temperatures, reports of steam in the Reactor Building, an unexpected rise in Feedwater flowrate, or unexpected Main Turbine Control Valve closure) may indicate that a primary system is discharging into the Reactor Building.An UNISOLABLE leak which is indicated by Max Normal Operating values escalates to a Site Area Emergency when combined with Containment Barrier CT6Loss threshold#13-A (after a containment isolation) and a General Emergency when the Fuel Clad Barrier criteria is also exceeded.Month 20XX CL 3-39 EP-AA-1003 (Revision XX)

(.lintnn Annov IFYalnn N, ,rlaar RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. M05-1002, Main steam 3. USAR 5.2.5 4. USAR Tables 5.2-9a and 5.2-9b 5. 9043.06, Drywell Floor Drain Sump Flow Test 00PS404 6. 9443.01, Drywell Equipment Drain Sump Flow E31 -N578 Channel Cal 01 PS274 7. 4406.01, EOP-8 Secondary Containment Control 8. Clinton Power Station Emergency Operating Procedures Technical Bases, Section 10 9. USAR Figure 6.2-132 Month 20XX CL 3-40 EP-AA-1003 (Revision XX)

Clinton Annex.Exelon Nuclear Clinton Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC54 Initiating Condition:

Primary Containment radiation Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

LOSS 1. DrQwell radiation monitor reading > 100R/hr (>1.00 E+02 R/hr).OR 2. Containment radiation monitor reading > 33 R/hr (>3.3 E+01 RPhr).A. Prim-Ar' containment radiation roading greater than (sitoespocific value).Basis: The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that reactor coolant activity equals Technical Specification allowable limits. This value is lower than that specified for Fuel Clad Barrier FC5 Loss Tthresholds 4-A-since it indicates a loss of the RCS Barrier only.I There is no RCS Potential Loss threshold associated with Primary Containment Radiation.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. Calc. EP-EAL-0611 Month 20XX CL 3-41 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC76 Initiating Condition:

Emergency Director Judgment.Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

LOSS Al. Any condition in the opinion of the Emergency Director that indicates Loss of the RCS Barrier.POTENTIAL LOSS A2. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.Basis: Loss &6AThreshold

1. 1 Basis: This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the RCS Barrier is lost.Potential Loss 6&AThreshold

1. 2 Basis: This threshold addresses any other factors that may be used by the Emergency Director in determining whether the RCS Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 Month 20XX CL 3-42 EP-AA-1 003 (Revision XX)

Exalon Nuclear Clinton Annex Eeo ula RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT2 Initiating Condition:

RPV Water Level Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

POTENTIAL LOSS A-. Plant conditions indicate Primary GCQontainment flooding is required.Basis: Potential Ls, .2-.A The Potential Loss threshold is identical to the Fuel Clad Barrier FC2 Loss threshold RPV Water Level 2-.A. The Potential Loss requirement for Primary Containment Flooding indicates adequate core cooling cannot be restored and maintained and that core damage is possible.

BWR EOPs/SAGs specify the conditions that require primary containment flooding.

When primary containment flooding is required, the EOPs are exited and SAGs are entered. Entry into SAGs is a logical escalation in response to the inability to restore and maintain adequate core cooling.PRA studies indicate that the condition of this Potential Loss threshold could be a core melt sequence which, if not corrected, could lead to RPV failure and increased potential for primary containment failure. In conjunction with the RPV water level Loss thresholds in the Fuel Clad and RCS barrier columns, this threshold results in the declaration of a General Emergency.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. Clinton Power Station Severe Accident Guidelines Technical Bases 3. STA/IA Guide/1005.09M002 Month 20XX CL 3-43 EP-AA-1003 (Revision XX)

Exelon Nuclear Clinton Annex .......Nu.. e..RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT3U-Initiating Condition:

Primary Containment Conditions Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

LOSS I Al. UNPLANNED rapid drop in primary containment pressure following primary containment pressure rise.OR 132. Primary containment pressure response not consistent with LOCA conditions.

POTENTIAL LOSS A3. Primary containment pressure greater than (site specific value)> 15 DsiQ and rising.OR 84. (site specific explosive mi.ture) voxits inside prim.ary c ;ntain.cnt

a. Drywell hydrogen concentration

> 9%.OR b. Containment Hydrogen concentration

> SAG-2. Deflagration Limit.OR G5. HT-LG-Heat Capacity TemperatureLimit (EOP-6, Fig.P) exceeded.Basis: UNPLANNED:

A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.

The cause of the parameter change or event may be known or unknown.Loss and--4BThreshold

1. 1 and #2 Basis Rapid UNPLANNED loss of primary containment pressure (i.e., not attributable to dfpyel--containment spray or condensation effects) following an initial pressure iiaeaserise indicates a loss of primary containment integrity.

Primary containment pressure should iPe-eaeerise as a result of mass and energy release into the primary containment from a LOCA. Thus, primary containment pressure not increasing under these conditions indicates a loss of primary containment integrity.

These thresholds rely on operator recognition of an unexpected response for the condition and therefore a specific value is not assigned.

The unexpected (UNPLANNED) response is important because it is the indicator for a containment bypass condition.

A pressure suppression bypass path would not be an indication of a containment breach.Month 20XX CL 3-44 EP-AA-1 003 (Revision XX)

(Ninfnn Anncov F~valnn N,,Alar t~Iintnn Ann~v Fv.Inn Mi .r~I~ar RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Potential Loss .AThreshold

1. 3 Basis The threshold pressure is the primary containment internal design pressure.

Structural acceptance testing demonstrates the capability of the primary containment to resist pressures greater than the internal design pressure.

A pressure of this magnitude is greater than those expected to result from any design basis accident and, thus, represent a Potential Loss of the Containment barrier.Potential Loss 4-lBThreshold

1. 4 Basis If hydrogen concentration reaches or exceeds the ,owo. flammability limit, as defined in plant EOPs, in an oxygen rich environment, a potentially explosive mixture exists. If the combustible mixture ignites inside the primary containment, loss of the Containment barrier could occur.Potential Loss 4-.CThreshold

1. 5 Basis The Heat Capacity Temperature Limit (H.TL) is the highest suppreson pool temperature from~ which EmergencGy RPV Dcprcssurization will not raise:.Suppresion c-hamber temperature above the maximum tompcrature capability of ma e required to operate when the RPY ispeured OR*Spposn chamber pressure above Primnary Containment Pressure Limit-Al whil~e the r-atte of energy tr-ansAfer fromr the RPV toe the connt~ainment.

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

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. USAR 6.2.1.1.3 3. USAR Table 1.3-4 4. CPS 4402.01, EOP-6 Primary Containment Control 5. SAG2 6. Clinton Power Station Emergency Operating Procedures Technical Bases, Sections 9 and 12 Month 20XX CL 3-45 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT54 Initiating Condition:

Primary Containment Radiation Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

POTENTIAL LOSS A. Primnar' containment radiation monitor roading greater than (cite-sepoific value)1. Drywell radiation monitor reading > 59OR/hr (> 5.90 E+02 R/hr)OR 2. Containment radiation monitor reading > 97 R/hr (>9.70 E+01 R/hr)Basis: There is no Loss threshold associated with Primary Containment Radiation.

Potential Loes 4..A The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that 20% of the fuel cladding has failed. This level of fuel clad failure is well above that used to determine the analogous Fuel Clad Barrier Loss and RCS Barrier Loss thresholds.

NUREG-1 228, Source Estimations During Incident Response to Severe Nuclear Power Plant Accidents, indicates the fuel clad failure must be greater than approximately 20%in order for there to be a major release of radioactivity requiring offsite protective actions. For this condition to exist? there must already have been a loss of the RCS Barrier and the Fuel Clad Barrier. It is therefore prudent to treat this condition as a potential loss of containment which would then escalate the emergency classification level to a General Emergency.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. Core Damage Assessment Methodology Month 20XX CIL 3-46 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear Clinton Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT63 Initiating Condition:

Primary Containment Isolation Failure Operating Mode Applicability:

1,2,3 Fission Product Barrier (FPB) Threshold:

LOSS Al. UNISOLABLE direct downstream pathway to the environment exists after primary containment isolation signal.OR B2. Intentional Pprimary geontainment venting/Puring per EOP's or SAGs due to accident conditions.

OR G3. UNISOLABLE primary system leakage that results in EITHER of the following:

4-a. Secondary Containment area temperature

> EOP-8, MaximumMax Safe Ooperating T-empeFakwelevels.

OR 2b. Secondary Containment area radiation level > EOP-8, MaximumMax Safe 0operating Radiation levels.Basis: UNISOLABLE:

An open or breached system line that cannot be isolated, remotely or locally.These thresholds address incomplete containment isolation that allows an UNISOLABLE direct release to the environment.

Loss 3&AThreshold

1. 1 Basis The use of the modifier "direct" in defining the release path discriminates against release paths through interfacing liquid systems or minor release pathways, such as instrument lines, not protected by the Primary Containment Isolation System (PCIS).Leakage into a closed system is to be considered only if the closed system is breached and thereby creates a significant pathway to the environment.

Examples include unisolable Main Steamline, RCIC steamline breaks, unisolable RWCU system breaks, and unisolable containment atmosphere vent paths.Examples of "downstream Dathwav to the environment" could be throuah the Turbine/Condenser, or direct release to the Turbine or Reactor Building.Month 20XX CL 3-47 EP-AA-1003 (Revision XX)

Exalon Nuclear Clinton Annex Eeo ula RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION The existence of a filter is not considered in the threshold assessment.

Filters do not remove fission product noble gases. In addition, a filter could become ineffective due to iodine and/or particulate loading beyond design limits (i.e., retention ability has been exceeded) or water saturation from steam/high humidity in the release stream.Following the leakage of RCS mass into primary containment and a rise in primary containment pressure, there may be minor radiological releases associated with allowable primary containment leakage through various penetrations or system components.

Minor releases may also occur if a primary containment isolation valve(s)fails to close but the primary containment atmosphere escapes to an enclosed system.These releases do not constitute a loss or potential loss of primary containment but should be evaluated using the Recognition Category A--RICs.Loss 3,BThreshold

1. 2 Basis EOPs may direct primary containment isolation valve logic(s) to be intentionally bypassed, even if offsite radioactivity release rate limits will be exceeded.

Under these conditions with a valid primary containment isolation signal, the containment should also be considered lost if primary containment venting is actually performed.

Intentional venting of primary containment for primary containment pressure or combustible gas control to the secondary containment and/or the environment is a Loss of the Containment.

Venting for primary containment pressure control when not in an accident situation (e.g., to control pressure below the dyweIDrywell high pressure scram setpoint) does not meet the threshold condition.

Loss 3-GThreshold

1. 3 Basis The Max Safe Operating Temperature and the Max Safe Operating Radiation Level are each the highest value of these parameters at which neither: (1) equipment necessary for the safe shutdown of the plant will fail, nor (2) personnel access necessary for the safe shutdown of the plant will be precluded.

EOPs utilize these temperatures and radiation levels to establish conditions under which RPV depressurization is required.The temperatures and radiation levels should be confirmed to be caused by RCS leakage from a primary system. A primary system is defined to be the pipes, valves, and other equipment which connect directly to the RPV such that a reduction in RPV pressure will effect a decrease in the steam or water being discharged through an unisolated break in the system.In general, multiple indications should be used to determine if a primary system is discharging outside Primary Containment.

For example, a high area radiation condition does not necessarily indicate that a primary system is discharging into the Reactor Building since this may be caused by radiation shine from nearby steam lines or the movement of radioactive materials.

Conversely, a high area radiation condition in coniunction with other indications (e.g. room flooding, high area temperatures, reports of steam in the Reactor Building, an unexpected rise in Feedwater flowrate, or unexpected Main Turbine Control Valve closure) may indicate that a primary system is discharging into the Reactor Buildina.Month 20XX CL 3-48 EP-AA-1003 (Revision XX)

Ann--v 9vI::lnn N,,rlhur RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION In combination with RCS Barrier RC4 Ppotential Lloss Threshold

1. 3 &A this threshold would result in a Site Area Emergency.

There is no Potential Loss threshold associated with Primary Containment Isolation Failure.Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. CPS 4402.01, EOP-6 Primary Containment Control 3. SAG-2 4. Clinton Power Station Emergency Operating Procedures Technical Bases, Sections 8 and 9 5. 4406.01, EOP-8 Secondary Containment Control 6. Clinton Power Station Emergency Operating Procedures Technical Bases, Section 10 7. USAR Figure 6.2-132 Month 20XX CL 3-49 EP-AA-1 003 (Revision XX)

Annoy FYAInn M~inton Annax Extainn Nucler~I RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT76 Initiating Condition:

Emergency Director Judgment.Operating Mode Applicability:

1,2,3 EAL Threshold Values: LOSS Aj. Any condition in the opinion of the Emergency Director that indicates Loss of the Containment Barrier.POTENTIAL LOSS A2. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.Basis: Loss 6AThreshold

1. 1 Basis: This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the Containment Barrier is lost.Potential Loss fAThreshold

1. 2 Basis: This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Containment Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 Month 20XX CL 3-50 EP-AA-1003 (Revision XX) 9'-lintnn Annav F:valnn N"Aarlr (~Iintnn Ann~v FvoIrn N. irIn~ar RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSG1 Initiating Condition:

Prolonged loss of all Off-site and all On-Site AC power to emergency busses.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Note: The Emergency Director should declare the General Em.,gen-ye.ent promptly upon determining that (site specific h'u's)"hours has been exceeded, or will likely be exceeded.1--a-a. Loss of ALL offsite and, ALL Gst--';* AC power to (s"* ...... fiG ..........

buses)vital busses 1Al and 1B1.AND 2. Failure of DG 1A and DG 1B emeraencv diesel aenerators to SUDDIV Dower to vital busses WA1 and 1B1.AND 3b. EITHER of the following:

a. Restoration of at least one emerg9eny-vital bus (excluding Division Ill) in <_4 hours is notles than (site specific hours) Is not likely.OR b. RPV water level cannot be restored and maintained

> -187 inches.(Site seecifi. indication of an inabilitV to adequatelY remove heat from the core)* lBasis: SAFETY SYSTEM: A system reauired for safe plant operation, coolincl down the plant and/or placing it in the cold shutdown condition, including the EGGS. These are typically systems classified as safety-related.

RPV values are actual levels, not indicated levels. Therefore, they may need level compensation depending on conditions.

Compensated values may be used in accordance with the SAMG Droaram.This IC addresses a prolonged loss of all power sources to AC emergency buses. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat Month 20XX CL 3-51 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS removal/pressure control, spent fuel heat removal and the ultimate heat sink. A prolonged loss of these buses will lead to a loss of one or more fission product barriers.In addition, fission product barrier monitoring capabilities may be degraded under these conditions.

The EAL should require declaration of a General Emergency prior to meeting the thresholds for IC FGI. This will allow additional time for implementation of offsite protective actions.Escalation of the emergency classification from Site Area Emergency will occur if it is projected that power cannot be restored to at least one AC emergency bus by the end of the analyzed station blackout coping period. Beyond this time, plant responses and event trajectory are subject to greater uncertainty, and there is an increased likelihood of challenges to multiple fission product barriers.The estimate for restoring at least one emergency bus should be based on a realistic appraisal of the situation.

Mitigation actions with a low probability of success should not be used as a basis for delaying a classification upgrade. The goal is to maximize the time available to prepare for, and implement, protective actions for the public.The EAL will also require a General Emergency declaration if the loss of AC power results in parameters that indicate an inability to adequately remove decay heat from the core.Basis Reference(s):

1. NEI 99-01 Rev 6, SG1 2. USAR 8.3.1 3. USAR Section 8.1.5 4. USAR Section 8.3.1 5. CPS 4200.01, Loss of AC 6. Safety Evaluation By The Office Of Nuclear Reactor Regulation Related To Station Blackout, 10 CFR 50.63 Illinois Power Company, et al Clinton Power Station, Unit 1 Docket No. 50-461 7. CPS 4401.01, EOP-1 RPV Control Month 20XX CL 3-52 EP-AA-1003 (Revision XX)

Annaav IFv-lnn NIir-loi, RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSS1 Initiating Condition:

Loss of all offsite and all onsite AC power to emergency busses for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Note: The Emergency Director should declare the Sivte Ara Eme.geA-Gy,-vent promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.1. Loss of ALL offsite and AlL Init- AC Power to .eific emergency busses 1A1 and 1 B1 fo-4r 15 minut Or niger.L ..... \- -!A-- I 9W-9u- VITaI AND 2. Failure of DG 1 A and DG 1 B emeraencv diesel aenerators to SUDDIV Dower to vital busses 1Al and 1B1.AND 3. Failure to restore Dower to at least one vital bus (excludina Division II1) in < 15 minutes from the time of loss of both offsite and onsite AC Dower Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or olacina it in the cold shutdown condition.

includina the ECCS.These are typically systems classified as safety-related.

This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. In addition, fission product barrier monitoring capabilities may be degraded under these conditions.

This IC represents a condition that involves actual or likely major failures of plant functions needed for the protection of the public.Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.Escalation of the emergency classification level would be via ICs RAG1, FG1l_-eiG MSG 1, or MG2.Month 20XX CL 3-53 EP-AA-1003 (Revision XX)

(lintnn Annoy I=yalnn Ki"aarl~RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Basis Reference(s):

1. NEI 99-01 Rev 6, SS1 2. USAR Figure 8.3-1 3. USAR Section 8.1.5 4. USAR Section 8.3.1 5. CPS 4200.01, Loss of AC 6. Safety Evaluation By The Office Of Nuclear Reactor Regulation Related To Station Blackout, 10 CFR 50.63 Illinois Power Company, et al Clinton Power Station, Unit 1 Docket No. 50-461 Month 20XX CL 3-54 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSA1 Initiating Condition:

I Loss of all but one AC power source to emergency buses for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Note: The Emergency Director should declare the eventA~r promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.1. AC power capability to vital busses (1 Al. 11B1) reduced to only one of the following power sources for > 15 minutes." Emergency Reserve Auxiliary Transformer (ERAT)" Reserve Auxiliary Transformer B (RAT B)* Emeraency Diesel Generator DG 1 A* Emergency Diesel Generator DG 1 B a. AG powor capability to (cito spocific cmorgency busos) ir- roduced to a single poweF seoume for 15 minutes or longcr.AND 2b. Any-ANY additional single power source failure will result in a loss of all-ALL AC power to Division I and II SAFETY SYSTEMS-.Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to Division I and II SAFETY this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment.

This IC provides an escalation path from IC MSU1.An "AC power source" is a source recognized in AOPs-Off Normal Procedures and EOPs, and capable of supplying required power to an emergency bus (excluding Division II1). Some examples of this condition are presented below.* A loss of all offsite power with a concurrent failure of all but one emergency power source (e.g., Division I and llaf4 onsite diesel generator)-

Month 20XX CL 3-55 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS a A Iocc of all ,ff;ito and less of all morgnc, pcr p ou-,r, e (e.g., onsit;diesel goneratorc) with a single train of emor~goncY busces boing back-fed frM tho unit mai gncator-." A loss of emergency power sources (e.g., onsite diesel generators) with a single train of Division I and II emergency buses being baek-fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.Escalation of the emergency classification level would be via IC MSS1.Basis Reference(s):

1. NEI 99-01 Rev 6, SA1 2. USAR Figure 8.3-1 3. USAR Section 8.1.5 4. USAR Section 8.3.1 5. CPS 4200.01, Loss of AC 6. Safety Evaluation By The Office Of Nuclear Reactor Regulation Related To Station Blackout, 10 CFR 50.63 Illinois Power Company, et al Clinton Power Station, Unit 1 Docket No. 50-461 Month 20XX CL 3-56 EP-AA-1003 (Revision XX)

M.infenn AnnovY NiMmarlr (~I i ntr~n An nmv ~v~Lnn NI. uir.Lm~r RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Initiating Condition:

Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Note: The Emergency Director should declare the Unu-ual Evontcvent promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.1-. Loss of ALL offsite AC power capability to vital busses 1A1 and 1B1 (site-eGpcific buos). for > 15 minutes-er-OIge

.Basis: This IC addresses a prolonged loss of offsite power. The loss of offsite power sources renders the plant more vulnerable to a complete loss of power to AC emergency buses.This condition represents a potential reduction in the level of safety of the plant.For emergency classification purposes, "capability" means that an offsite AC power source(s) is available to the emergency buses (excluding Division 11), whether or not the buses are powered from it.Fifteen minutes was selected as a threshold to exclude transient or momentary losses of offsite power.Escalation of the emergency classification level would be via IC MSAI.Basis Reference(s):

1. NEI 99-01 Rev 6, SUW 2. USAR Figure 8.3-1 3. USAR Section 8.1.5 4. USAR Section 8.3.1 5. CPS 4200.01, Loss of AC Month 20XX CL 3-57 EP-AA-1003 (Revision XX)

M~infnn Annghv I::alnn N, 1-loar (91 ntr~n An nay Fv.inn Mm .,laar RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSG28 Initiating Condition:

Loss of all AC and Vital DC power sources for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Note: The Emergency Director should declare the Gonoral Emorgencycvent promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to vital busses 1 Al and 11B1.AND 2. Failure of DG 1A and DG 1 B emergency diesel generators to supply power to vital busses 1A1 and 1B1.AND 3. Voltaae is < 108 VDC on unit 125 VDC battery busses 1A and 1B.AND 4. ALL AC and Vital DC Dower sources have been lost for > 15 minutes.1. a. Les no- A- I efti;te an AL I ns;÷e At pwe ,buasoe) foFr 5 minutes o; r longr.AND b. lndicated veltage is than (site-Specific bus voltage value) on ALL (site- spcific Vital DCG buesses) for 156 minutes, or longo.Basis: SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or Dlacin it in the cold shutdown condition, includin.

the ECCS.These are typically systems classified as safety-related.

Month 20XX CL 3-58 EP-AA-1003 (Revision XX)

Clinton Annex I=xelon Nuclezr l~inton Annex Exellon Nucla~r RECOGNITION CATEGORY SYSTEM MALFUNCTIONS This IC addresses a concurrent and prolonged loss of both AC and Vital DC power. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. A loss of Vital DC power compromises the ability to monitor and control SAFETY SYSTEMS. A sustained loss of both AC and DC power will lead to multiple challenges to fission product barriers.Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. The 15-minute emergency declaration clock begins at the point when all EALs conditions are met.Basis Reference(s):

1. NEI 99-01 Rev 6, SG8 2. USAR 8.3.2 3. USAR Figure 8.3-7 4. USAR Table 8.3-5 5. USAR 8.3.2.1.1 6. CPS 4201.01, Loss of DC Power 7. Technical Specifications B3.8.4 8. USAR Figure 8.3-1 9. USAR Section 8.1.5 10. USAR Section 8.3.1 11. CPS 4200.01, Loss of AC 12. Safety Evaluation By The Office Of Nuclear Reactor Regulation Related To Station Blackout, 10 CFR 50.63 Illinois Power Company, et al Clinton Power Station, Unit 1 Docket No. 50-461 Month 20XX CL 3-59 EP-AA-1003 (Revision XX)

Clinton Annex Exellon Nuclear Clinton Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSS28 Initiating Condition:

Loss of all vital DC power for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Note: The Emergency Director should declare the Site Aroa promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.lRdiGated-vVoltage is < 108 VDCloss than (cite , pecific bus v...oltage v..alue) on 125 VDC battery busses 1 A and 1 BALL (site sp.ecific V..ital DG busses) for _>15 minutes-oFler-e-

.Basis: SAFETY SYSTEM: A system reguired for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses a loss of Vital DC power which compromises the ability to monitor and control SAFETY SYSTEMS. In modes above Cold Shutdown, this condition involves a major failure of plant functions needed for the protection of the public.Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.Escalation of the emergency classification level would be via ICs RAG1, FG1 or MSG28.Basis Reference(s):

1. NEI 99-01 Rev 6, SS8 2. USAR 8.3.2 3. USAR Figure 8.3-7 4. USAR Table 8.3-5 5. USAR 8.3.2.1.1 6. CPS 4201.01, Loss of DC Power 7. Technical Specifications B3.8.4 Month 20XX CL 3-60 EP-AA-1003 (Revision XX)

Clinton AnnexNnnclAar Clinton Annex Exelon Nucleasr RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSS36 Initiating Condition:

Inability to shutdown the reactor causing a challenge to RPV water level or RCS heat removal.Operating Mode Applicability:

1,2 Emergency Action Level (EAL): 1. Automatic scram did not shutdown the reactor as indicated by Reactor Power > 5%.AND 2. All-ALL manual / ARI actions to shutdown the reactor have been unsuccessful as indicated by Reactor Power > 5%.AND 3. EITHER of the following conditions exist:* RPV water level cannot be restored and maintained

> -187 inches OR" Heat Capacity Temperature Limit (EOP-6, Fig. P) exceeded.(Sito spoc-ific.

ind-ic-ation of an inability to adcquately romovo heat from the core)(Sito s~pecific indication of an inabil ity to adequately Femovc heat from the RCS)Basis: This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor scram that results in a reactor shutdown, all subsequent operator manual actions, both inside and outside the Control Room including driving in control rods and boron iniection all subsequent operator actionS to manually shutdown the reaGto- are unsuccessful, and continued power generation is challenging the capability to adequately remove heat from the core and/or the RCS. This condition will lead to fuel damage if additional mitigation actions are unsuccessful and thus warrants the declaration of a Site Area Emergency.

In some instances, the emergency classification resulting from this IC/EAL may be higher than that resulting from an assessment of the plant responses and symptoms against the Recognition Category F ICs/EALs.

This is appropriate in that the Recognition Category F ICs/EALs do not address the additional threat posed by a failure to shutdown the reactor. The inclusion of this IC and EAL ensures the timely declaration of a Site Area Emergency in response to prolonged failure to shutdown the I reactor.Month 20XX CL 3-61 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS RPV values are actual levels, not indicated levels. Therefore, they may need level compensation depending on conditions.

A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.Escalation of the emergency classification level would be via IC RAG1 or FGI.Basis Reference(s):

1. NEI 99-01 Rev 6, SS5 2. CPS 4100.01, Reactor scram 3. CPS 4401.01, EOP-1 RPV Control 4. CPS 4404.01, EOP-1A ATWS RPV Control 5. CPS 3304.02, Rod Control and Information System (RC&IS)6. CPS 4402.01, EOP-6 Primary Containment Control 7. Clinton Power Station Emergency Operating Procedures Technical Bases, Sections 4, 5, 8 and 12 Month 20XX CL 3-62 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSA36 Initiating Condition:

Automatic or manual scram fails to shutdown the reactor, and subsequent manual I actions taken at the reactor control consoles are not successful in shutting down the reactor.Operating Mode Applicability:

1,2 Emergency Action Level (EAL): I Note: A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

1. An,-aAutomatic or manual scram did not shutdown the reactor as indicated by Reactor Power > 5%.AND 2. Manual / ARI actions taken at the reactor cOntro! concolocReactor Control Console are not successful in shutting down the reactor as indicated by Reactor Power > 5%.Basis: This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor scram that results in a reactor shutdown, and subsequent operator manual actions taken at the reactor control consoles to shutdown the reactor are also unsuccessful.

This condition represents an actual or potential substantial degradation of the level of safety of the plant. An emergency declaration is required even if the reactor is subsequently shutdown by an action taken away from the reactor control consoles since this event entails a significant failure of the RPS.A manual action at the reactor control consoles is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor scram). This action does not include manually driving in control rods or implementation of boron injection strategies.

If this action(s) is unsuccessful, operators would immediately pursue additional manual actions at locations away from the reactor control consoles (e.g., locally opening breakers).

Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be "at the reactor control consoles".

Taking the Reactor Mode Switch to SHUTDOWN-Shutdown is considered to be a manual scram action.The plant response to the failure of an automatic or manual reactor scram will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If the failure to shutdown the reactor is prolonged Month 20XX CL 3-63 EP-AA-1003 (Revision XX)

Clinton ClIinton Annex Exelonf Nucle~ar RECOGNITION CATEGORY SYSTEM MALFUNCTIONS enough to cause a challenge to the RPV water level or RCS heat removal safety functions, the emergency classification level will escalate to a Site Area Emergency via IC MSS3. Depending upon plant responses and symptoms, escalation is also possible via IC FS1. Absent the plant conditions needed to meet either IC MSS36 or FS1, an Alert declaration is appropriate for this event.It is recognized that plant responses or symptoms may also require an Alert declaration in accordance with the Recognition Category F ICs; however, this IC and EAL are included to ensure a timely emergency declaration.

I A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.Basis Reference(s):

1. NEI 99-01 Rev 6, SA5 2. CPS 4100.01, Reactor scram 3. CPS 4401.01, EOP-1 RPV Control 4. CPS 4404.01, EOP-1A ATWS RPV Control 5. CPS 3304.02, Rod Control and Information System (RC&IS)6. CPS 4402.01, EOP-6 Primary Containment Control 7. Clinton Power Station Emergency Operating Procedures Technical Bases, Sections 4, 5, 8 and 12 Month 20XX CL 3-64 EP-AA-1003 (Revision XX)

Exalon Nuclear Clinton Annex E.........

le. .RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSU36 Initiating Condition:

Automatic or manual scram fails to shutdown the reactor.Operating Mode Applicability:

1,2 Emergency Action Level (EAL): I Note: A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.

1. a. A _-aAutomatic scram-did not shutdown the reactor as indicated by Reactor Power > 5%..AND b. A-sSubsequent manual / ARI action taken at the roactOr control Gen, selesReactor Control Console is successful in shutting down the reactor.OR 2. a. A-mManual scram--did not shutdown the reactor as indicated by Reactor Power > 5%.AND b. EITHER of the following:

1. A--sSubsequent manual / ARI action taken at the rcFactO cGOtrol GenselesReactor Control Console is successful in shutting down the reactor.OR 2. A-sSubsequent automatic scram / ARI -is successful in shutting down the reactor.Basis: This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor scram that results in a reactor shutdown, and either a subsequent operator manual action taken at the reactor control consoles or an automatic scram is successful in shutting down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.EAL #1 Basis Following the failure on an automatic reactor scram, operators will promptly initiate manual actions at the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor scram). If these manual actions are successful in shutting down the Month 20XX CL 3-65 EP-AA-1 003 (Revision XX)

Clinton Annex Exelon Nuclear Clinton Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS reactor, core heat generation will quickly fall to a level within the capabilities of the plant's decay heat removal systems.EAL #2 Basis If an initial manual reactor trip is unsuccessful, operators will promptly take manual action at another location(s) on the reactor control consoles to shutdown the reactor (e.g., initiate a manual reactor scram / ARI using a different switch). Depending upon several factors, the initial or subsequent effort to manually scram the reactor, or a concurrent plant condition, may lead to the generation of an automatic reactor scram signal. If a subsequent manual or automatic scram / ARI is successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plant's decay heat removal systems.A manual action at the reactor control consoles is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor scram). This action does not include manually driving in control rods or implementation of boron injection strategies.

Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be "at the reactor control consoles".

Taking the Reactor Mode Switch to Shutdown is considered to be a manual scram action.The plant response to the failure of an automatic or manual reactor tscram will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If subsequent operator manual actions taken at the reactor control consoles are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC MSA36. Depending upon the plant response, escalation is also possible via IC FAl. Absent the plant conditions needed to meet either IC MSA36 or FA1, an Unusual Event declaration is appropriate for this event.A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.I Should a reactor scram signal be generated as a result of plant work (e.g., RPS setpoint testing), the following classification guidance should be applied." If the signal generated as a result of plant work causes a plant transient that creates a real condition that should have included an automatic reactor scram and the RPS fails to automatically shutdown the reactor, then this IC and the EALs are applicable, and should be evaluated." If the signal generated as a result of plant work does not cause a plant transient but should have generated an RPS scram siqnal and the scram failure is determined through other means (e.g., assessment of test results), then this IC and the EALs are not applicable and no classification is warranted.

Month 20XX CL 3-66 EP-AA-1003 (Revision XX)

Exelon Nuclear Clinton Annex Exelon Nuclea~r RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Basis Reference(s):

1. NEI 99-01 Rev 6, SU5 2. Technical Specifications Table 3.3.1.1-1 3. CPS 4100.01, Reactor scram 4. CPS 4401.01, EOP-1 RPV Control 5. CPS 4404.01, EOP-1A ATWS RPV Control 6. CPS 3304.02, Rod Control and Information System (RC&IS)Month 20XX CL 3-67 EP-AA-1 003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSA42 Initiating Condition:

UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Note: The Emergency Director should declare the eventAle4 promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.1. a. AR-UNPLANNED event results in the inability to monitor one or moreANY Table Mlef the fellewiiig parameters from within the Control Room for >15 minutes

[see tlable Reactor Powcr___________________

Table M1 Control Room Parameters PAW W-atc. Level

• Reactor Power , RPV Water Level R* RPV Pressure* Primary Containment Pressure A...- Containmen.

t

• Suppression Pool Level SSuppression Pool Temperature AND b. Any Table M2ef the-f.llo...

transient events in progress." Automatic Or Manual runback greater than 25% thermnal reactor power" ElectriGal load rejectuio greater than 2I% full olutrical loead r" " E GS (811 actuation Month 20XX CL 3-68 EP-AA-1 003 (Revision XX)

Clinton Annex Exelon Nuclear Clinton Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Table M2 Significant Transients" Recirc Runback >25% Reactor Power" Reactor Scram* ECCS Actuation" Thermal Power oscillations>

10% Reactor Power change Basis: UNPLANNED:

A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.

The cause of the parameter change or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses the difficulty associated with monitoring rapidly changing plant conditions during a transient without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. During this condition, the margin to a potential fission product barrier challenge is reduced. It thus represents a potential substantial degradation in the level of safety of the plant.As used in this EAL, an "inability to monitor' means that values for one or more of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s).

For example, the reactor power level cannot be determined from any analog, computer point, digital and recorder source within the Control Room.An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1 022)to determine if an NRC event report is required.

The event would be reported if it significantly impaired the capability to perform emergency assessments.

In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making.

This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, RPV- evelRPV water level and RCS heat removal.The loss of the ability to determine one or more of these parameters from within the Month 20XX CL 3-69 EP-AA-1003 (Revision XX)

AnnAy ClIinton Annex Exelnn Nucler~I RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Control Room is considered to be more significant than simply a reportable condition.

In addition, if all indication sources for one or more of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for RPV water level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.

Escalation of the emergency classification level would be via ICs FS1 or IC RASI.Basis Reference(s):

1. NEI 99-01 Rev 6, SA2 Month 20XX CL 3-70 EP-AA-1003 (Revision XX) r-lintrn AnnsX i=yAIon (~Iintnn nnAY FvAon NucleIar RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSU42 Initiating Condition:

UNPLANNED loss of Control Room indications for 15 minutes or longer.Operating Mode Applicability:

1,2,3 Emergency Action Level (EAL): Note: The Emergency Director should declare the Unusual Evntcvent promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.a- AR-UNPLANNED event results in the inability to monitor one orFmoroANY Table M1 parameters from within the Control Room for > 15 minutes.Table M1 Control Room Parameters

• Reactor Power" RPV Water Level* RPV Pressure" Primary Containment Pressure" Suppression Pool Level" Suppression Pool Temperature If ý_ itL. _ 11- .... !*-.-It- --- !.t-!- I- rN -a r% X -A ý -!--I. 01 inc icuowino oaramciorc irom wnnin mo Loniroi rioum jor ip miriuic~OF gf-.2. [B WR p~zamctm 3. [PW-Rparameter

4. Reaetor- Power 6. ReactOr Power-8.RVWater-Level 9. RCS-bevde 110. RPV Pressure 11. RCS Prcssure-2.P-Pi~mar-y

13. in Corc.'Corc

14. Suppression Pco 16. Levels in at leas Level (site speeie number) steamf 16. Suppression Poo 17. Steam Cenerator Tempe~tu-Awufiar-___gne Feed Month 20XX CL 3-71 EP-AA-1003 (Revision XX)

Annex Exelon Nuclear r-linton Annex Exellon Nuclea~r RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Basis: UNPLANNED:

A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.

The cause of the parameter change or event may be known or unknown.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses the difficulty associated with monitoring normal plant conditions without the ability to obtain SAFETY SYSTEM parameters from within the Control Room. This condition is a precursor to a more significant event and represents a potential degradation in the level of safety of the plant.As used in this EAL, an "inability to monitor" means that values for one or more of the listed parameters cannot be determined from within the Control Room. This situation would require a loss of all of the Control Room sources for the given parameter(s).

For example, the reactor power level cannot be determined from any analog, digital and recorder source within the Control Room.An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required.

The event would be reported if it significantly impaired the capability to perform emergency assessments.

In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making.

This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling and RCS heat removal. The loss of the ability to determine one or more of these parameters from within the Control Room is considered to be more significant than simply a reportable condition.

In addition, if all indication sources for one or more of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well.For example, if the value for reactor vessel level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.

Escalation of the emergency classification level would be via IC MSA42.Month 20XX CL 3-72 EP-AA-1003 (Revision XX)

AnneY l~intnn Anntax Exelnn Nuclea~r RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Basis Reference(s):

1. NEI 99-01 Rev 6, SU2 Month 20XX CL 3-73 EP-AA-1003 (Revision XX)