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

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

ML14164A063
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: ML14164A063 (189)

Text

Clinton Annex Clinton Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSA59 Initiating Condition:

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

1,2,3 Emergency Action Level (EAL): (4-4 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 e (sitoe-pocifi hazards)" Other events with similar hazard characteristics as determined by the Shift Manager ANDEITHER of the following:

a.4-. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM reguiredieeded by Technical Specifications for the current operating mode.OR b. 2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure requiredeeded by Technical Specifications for the current operating mode.Basis: FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.EXPLOSION:

A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization.

A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion.

Such events may require a post-event inspection to determine if the attributes of an explosion are present.Month 20XX CL 3-74 EP-AA-1003 (Revision XX)

Clinton Annex Exellon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS SAFETY SYSTEM: A system reguired for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the EGOS. These are typically systems classified as safety-related.

VISIBLE DAMAGE: Damage to a component or structure that is readily observable without measurements, testing, or analysis.

The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected component or structure.

This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or a structure containing SAFETY SYSTEM components, requiredfieeded for the current operating mode, " required ", i.e. required to be operable by Technical Specifications for the current operating mode. This condition significantly reduces the margin to a loss or potential loss of a fission product barrier, and therefore represents an actual or potential substantial degradation of the level of safety of the plant. Manual or automatic electrical isolation of safety eguipment due to flooding, in and of itself, does not constitute degraded performance and is classified under HU6.EAL 4-. 4.a Basis This EAL addresses damage to a SAFETY SYSTEM train that is- required to be operable by Technical Specifications for the current operating mode, and is in se~iGeloperation since indications for it will be readily available.

The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.EAL 41-bM.b Basis-This EAL addresses damage to a SAFETY SYSTEM component that is reguired to be operable by Technical Specifications for the current operating mode, and is not in se.....e/operation or readily apparent through indications alone, of-as well as damage to a structure containing SAFETY SYSTEM components.

Operators will make this determination based on the totality of available event and damage report information.

This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level would be via IC FS1 or RAS1.If the EAL conditions of MA5 are not met then assess the event via HU3, HU4 or HU6.Basis Reference(s):

1. NEI 99-01, Rev 6 SA9 Month 20XX CL 3-75 EP-AA-1003 (Revision XX)

Exalon Nuclear Clinton Annex Eeo ula RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSU64 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 Unusual Event vent promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.1. RCS unidentified or pressure boundary leakage in the Drywell g-eateF-than

> 10 gpm for > 15 minutes. ite pcfic. v.alue). for 15 minutes Or longer-.OR 2. RCS identified leakage in the DrDwellg.eate..

ha-fre spocific value) for 15 mninutes Or longer.OR 3. Leakage from the RCS to a location outside Gontaiiment-the Dwwell >25 lppm for >15 minutes. greater than 25 gp, fr 15 6 mnutes or longe.Basis: UNISOLABLE:

An open or breached system line that cannot be isolated, remotely or locally.This IC addresses RCS leakage which may be a precursor to a more significant event.In this case, RCS leakage has been detected and operators, following applicable procedures, have been unable to promptly isolate the leak. This condition is considered to be a potential degradation of the level of safety of the plant.EAL #1 and EAL_#2 Basis These EALs are focused on a loss of mass from the RCS due to "unidentified leakage","pressure boundary leakage" or "identified leakage" (as these leakage types are defined in the plant Technical Specifications).

EAL #3 Basis This EAL addresses a RCS mass loss caused by an UNISOLABLE leak through an interfacing system.These EALs thus apply to leakage into the containment, a secondary-side system (e~g.steam generator tube leakage in a PWR) or a location outside of containment.

The leak rate values for each EAL were selected because they are usually observable with normal Control Room indications.

Lesser values typically require time-consuming calculations to determine (e.g., a mass balance calculation).

EAL #1 uses a lower value that reflects the greater significance of unidentified or pressure boundary leakage.Month 20XX CL 3-76 EP-AA-1003 (Revision XX)

Exelon Nuclear Clinton Annex ..... ..N.c. .a.RECOGNITION CATEGORY SYSTEM MALFUNCTIONS The release of mass from the RCS due to the as-designed/expected operation of any relief valve does not warrant an emergency classification.

FGWR!eTAa stuck-open Safety Relief Valve (SRV) or SRV leakage is not considered either identified or unidentified leakage by Technical Specifications and, therefore, is not applicable to this EAL.The 15-minute threshold duration allows sufficient time for prompt operator actions to isolate the leakage, if possible.Escalation of the emergency classification level would be via ICs of Recognition Category RA or F.Basis Reference(s):

1. NEI 99-01 Rev 6, SU4 2. USAR 5.2.5.1 3. CPS 9043.06, Drywell Floor Drain Sump Flow Test 00PS404 4. CPS 9443.01, Drywell Equipment Drain Sump Flow E31-N578 Channel Cal 01 PS274 5. CPS 4401.01, EOP-1 RPV Control 6. CPS 4001.01, Reactor Coolant Leakage 7. Clinton Power Station Emergency Operating Procedures Technical Bases, Section 12 8. ITS 3.4.5 Month 20XX CL 3-77 EP-AA-1003 (Revision XX)

('-lintnn Annoy IFvplnn Niidlpar RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSU76 Initiating Condition:

Loss of all On-site or Off-site communications 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.

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 microwave)

X X X ENS X X HPN X X Satellite Phones X X 1. Las o-af ALL Qf t-he folloi~ng onsito comnmunication mnethods:;(cite csecific list Of communicationS method-') I~ , A! 1 j-f +k frdju~rr 11 ~ f n ~ r m.~,',ire ,n ~k~~, woo %7 XY V w %7vr 8 t- 1U 11W Idt bW ...... _1 11- 1_f Month 20XX CL 3-78 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear Clinton Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS

3. Loss of ALL of the follo-wing NRC co-mmunications mnethods (site-sepoific list Of communications mcethods)Basis: This IC addresses a significant loss of on-site._.-e--offsite, or NRC communications capabilities.

While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to Offsite Response Organizations (OROs. and the NRC.This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).EAL #1 Basis aAddresses a total loss of the communications methods used in support of routine plant operations.

EAL #2 Basis aAddresses a total loss of the communications methods used to notify all OROs of an emergency declaration.

The OROs referred to here are listed in procedure EP-MW-114-100-F-01, Nuclear Accident Reporting System (NARS) Form._(see .Deelpe.Netes).EAL #3 Basis aAddresses a total loss of the communications methods used to notify the NRC of an emergency declaration.

Basis Reference(s):

1. NEI 99-01 Rev 6, SU6 2. EP-MW-1 24-1001, Facilities Inventories and Equipment Tests 3. UFSAR Section 9.5.2 Month 20XX CL 3-79 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear Clinton Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA12 Initiating Condition:

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

4,5, D Emergency Action Level (EAL): Note: The Emergency Director should declare the Alel--event promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.1. Loss of ALL offsite AC power to vital busses 1Al and 1 B1.AND 2. Failure of DG 1 A and DG 1 B emergency diesel generators to supply power to vital busses 1Al and 1B1.AND 3. Failure to restore power to at least one vital bus (excluding Division III) in < 15 minutes from the time of loss of both offsite and onsite AC power.Les of ALL o- ff,,itw,-and ALL AC P,,r 4. to bUSc,) foFr 15 minutoc or longor.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 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.When in the cold shutdown, refueling,-

r-defuele mode, this condition is not classified as a Site Area Emergency because of the increased time available to restore an emergency bus to service. Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition represents an actual or potential substantial degradation of the level of safety of the plant.Month 20XX CL 3-80 EP-AA-1003 (Revision XX)

Exelon Nuclear Clinton Annex........N.

.l.a.RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.Escalation of the emergency classification level would be via IC CS6 or RAS1.Basis Reference(s):

1. NEI 99-01 Rev 6, CA2 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, Unit1 Docket No. 50-461 Month 20XX CL 3-81 EP-AA-1003 (Revision XX)

Milntnn Anngav P~vdmlonn k::lm-Imir t~I 1 ntr~n An n~v FvmIe~n hi. .w~Ia~ar RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CI Initiating Condition:

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

4,5, D Emergency Action Level (EAL): Note: The Emergency Director should declare the Unusual Eventcvent promptly J12 upon determining that 15 minutes has been exceeded, or will likely be exceeded.1. AC power capability to vital busses (1Al, 11B1) reduced to only one of the followinq power sources for > 15 minutes.* Emergency Reserve Auxiliary Transformer (ERAT)* Reserve Auxiliarv Transformer B (RAT B)* Emergency Diesel Generator DG 1 A* 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.powor 6ource for 15 mninutoc Or longer.AND b. Any additional Singlo powewr failrFe will result in loss of all AC to SAFETY SYSTEMS.Basis: SAFETY SYSTEM: A system reauired for safe plant operation.

coolina down the plant and/or llacina it in the cold shutdown condition includina the ECCS.These are tvDicallv 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 SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment.

When in the cold shutdown, refueling, or defueled refueling mode, this condition is not classified as an Alert because of the increased time available to restore another power source to Month 20XX CL 3-82 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS service. Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition is considered to be a potential degradation of the level of safety of the plant.An "AC power source" is a source recognized in A Off Normal Procedures and EOPs, and capable of supplying required power to an emergency bus (excluding Division III). 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 lIaR onsite diesel generator).

1.A I--e of all e p less of al: ,rI ,n p.-,r onc:to diosel genorator) with a singlo train of omorgoncy busos being back fed from th Unit main gneratr-.* A loss of emergency power sources (e.g., onsite diesel generators) with a single train of Division I and II emergency buses being baGk-fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.The subsequent loss of the remaining single power source would escalate the event to an Alert in accordance with IC CA12.Basis Reference(s):

1. NEI 99-01 Rev 6 CU2 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 3-83 EP-AA-1003 (Revision XX)

Annoy IFvalnn N,,arlr RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CA26 Initiating Condition:

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

4,5 Emergency Action Level (EAL): 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" ( .ito.spocific hazards)" Other events with similar hazard characteristics as determined by the Shift Manager AND 2.b. EITHER of the following:

a.4-7 Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM required.eeded by Technical Specifications for the current operating mode.OR b. 2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure requiredneeded by Technical Specifications for the current operating mode.Basis: FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.EXPLOSION:

A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization.

A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, aroundina, arcina, etc.) should not automatically be considered an explosion.

Such Month 20XX CL 3-84 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS events may require a post-event inspection to determine if the attributes of an explosion are present.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

VISIBLE DAMAGE: Damage to a component or structure that is readily observable without measurements, testing, or analysis.

The visual impact of the damage is sufficient to cause concem regarding the operability or reliability of the affected component or structure.

This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or a structure containing SAFETY SYSTEM components, required.eeded for the current operating mode, " required ", i.e. required to be operable by Technical Specifications for the current operating mode. This condition significantly reduces the margin to a loss or potential loss of a fission product barrier, and therefore represents an actual or potential substantial degradation of the level of safety of the plant. Manual or automatic electrical isolation of safety equipment due to flooding, in and of itself, does not constitute degraded performance and is classified under HU6.EAL 4-b4#2.a Basis-aAddresses damage to a SAFETY SYSTEM train that is required to be operable by Technical Specifications for the current operating mode, and is in seeviGeeoperation since indications for it will be readily available.

The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.EAL 14.2#.b Basis-aAddresses damage to a SAFETY SYSTEM component that is- required to be operable by Technical Specifications for the current operating mode, and is not in seeViGe/operation or readily apparent through indications alone, or to a structure containing SAFETY SYSTEM components.

Operators will make this determination based on the totality of available event and damage report information.

This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level would be via IC CS6 or RASI.If the EAL conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.Basis Reference(s):

1. NEI 99-01 Rev 6, CA6 Month 20XX CL 3-85 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear Clinton Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU34 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 Unusual Evontevent promptly upon determining that 15 minutes-time has been exceeded, or will likely be exceeded.Voltage is < 108 VDC on required 125 VDC battery busses 1A and 1B for > 15 minutes.Ind-incato-d voltago i Is les than (cite-_pegif;i bus voltage value) on required Vital DG busce for 15 minutes Or 'ongor.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 addresses a loss of Vital DC power which compromises the ability to monitor and control operable SAFETY SYSTEMS when the plant is in the cold shutdown or refueling mode. In these modes, the core decay heat load has been significantly reduced, and coolant system temperatures and pressures are lower; these conditions IP r-easerise the time available to restore a vital DC bus to service. Thus, this condition is considered to be a potential degradation of the level of safety of the plant.As used in this EAL, "required" means the Vital DC buses necessary to support operation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment.

For example, if Train A is out-of-service (inoperable) for scheduled outage maintenance work and Train B is in-service (operable), then a loss of Vital DC power affecting Train B would require the declaration of an Unusual Event. A loss of Vital DC power to Train A would not warrant an emergency classification.

I Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.Depending upon the event, escalation of the emergency classification level would be via IC CA6 or CA53, or an IC in Recognition Category BA.Month 20XX CL 3-86 EP-AA-1 003 (Revision XX) lintrnn Annv I:=valtn K,,r-liar RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS Basis Reference(s):

1. NEI 99-01 Rev 6, CU4 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 3-87 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CU4" Initiating Condition:

Loss of all onsite or offsite communications 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 Cl Offsite communication capability affectina the ability to perform offsite notifications.

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

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 microwave)

X X X ENS X X HPN X X Satellite Phones X X! A -- L- -1 fItQAn nanifir n ;A f nmmmi inctnpnmthadsz

ý*2 1 es of ALL nf tha fnh1n(Awinq C)P 0 mmiiniratienn mnethedsn (sit I wecific IiSt Of communIRications mothods)i* lf Month 20XX CL 3-88 EP-AA-1003 (Revision XX)

Exelon Nuclear Clinton Annex Eeo ula RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS

3. Loss of ALL of the olwn NRC cormmunic-ations mothods (site spocific list Of communications methods)Basis: This IC addresses a significant loss of on-site._-e-offsite, or NRC communications capabilities.

While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to Offsite Response Organizations (OROsI and the NRC.This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).EAL #1 Basis aAddresses a total loss of the communications methods used in support of routine plant operations.

EAL #2 Basis aAddresses a total loss of the communications methods used to notify all OROs of an emergency declaration.

The OROs referred to here are listed in procedure EP-MW-114-100-F-01, Nuclear Accident Reporting System (NARS) Form',,.-.,".,,.

Notes,).EAL #3 Basis aAddresses a total loss of the communications methods used to notify the NRC of an emergency declaration.

Basis Reference(s):

1. NEI 99-01 Rev 6, CU5 2. EP-MW-1 24-1001, Facilities Inventories and Equipment Tests 3. UFSAR Section 9.5.2 Month 20XX CL 3-89 EP-AA-1003 (Revision XX)

Anngmv Fvalnn N"MorAr (~Iint~~n Annmv Fwe~Inn N.ir~I~ar RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CA53 Initiating Condition:

Inability to maintain the plant in cold shutdown.Operating Mode Applicability:

4,5 Emergency Action Level (EAL): Note: The Emergency Director should declare the AleI-event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.1. UNPLANNED rise in RCS temDerature

> 200°F due to loss of decay heat removal for > Table C2 duration.Table C2 RCS Heat-up Duration Thresholds RCS Containment Closure Heat-up Status Status Duration Intact Not Applicable 60 minutes*Not Intact Established 20 minutes*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 applicable.

OR 2. UNPLANNED RPV pressure rise > 10 psig as a result of temperature rise due to loss of decav heat removal.J I li A i IL L ....-- -L I- -/!0 .-.1 _*[_I.Al 11116111 -_- Mt~L. la -1rd~~ ,n -' %A -d ann n.t In *1 fln e5fr. n ow cnp yn UJAL At* S.w. IS r_1S 1; ... i ., l A .... I .a.----------

I ~'fflh1IfiI 11(JrIII(::JIItJrI tZt)iiJ t:i iiiiiitJ~.~[i IUIIIUL1ZIIUILI

~EI I III I ~11~ UILzIL..I durtio cocificd in thc fA1lo G table.Month 20XX CL 3-90 EP-AA-1003 (Revision XX)

Clinton Annex Exellon Nuclear Clinton Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS Table: RCS Heat -up Duration Throohold RGS Status S ,,ta, ,,v .HovoUe 14at-Up Duration I4~tae~b.Status mred-uceAd i'ot Net-applicabl 60 imiteel Not intact (Or at rcducod Estabisehed 20 iniues inventeF~y-PWRI)

Not Established 0F~ue* if an RCS heat romova! system is in oporation within this time framo and RCS temperature is being roeduced, the SAL is not applicable.

2. UNP-A.NNIED RCS preecuro increa greater than (cite specific prossure reading). (This EAL does not apply during wator solid plant conditions.

fPWRI)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 Rarameter change or event may be known or unknown.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment (primary or secondary) and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

RCS is intact when the RCS pressure boundary is in its normal condition for the Cold Shutdown mode of operation (e.g. no freeze seals, or steam line nozzle plugs. etc.).This IC addresses conditions involving a loss of decay heat removal capability or an addition of heat to the RCS in excess of that which can currently be removed. Either condition represents an actual or potential substantial degradation of the level of safety of the plant.A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.

The RC S Heat-up Duration Thresholds table addresses an iRa oneaierise in RSC temperature when CONTAINMENT CLOSURE is established but the RCS is not intact, or RCS inoentoey is reduced (e.g., midiloop operation in Pcu Rs). The 20-minute criterion was included to allow time for operator action to address the temperature ofteaperise.

The RCS Heat-up Duration Thresholds table also addresses af inereaserise in RCS temperature with the RCS intact. The status of CONTAINMENT CLOSURE is not Month 20XX CL 3-91 EP-AA-1003 (Revision XX)

Clinton Annex Exallon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS crucial in this condition since the intact RCS is providing a high pressure barrier to a fission product release. The 60-minute time frame should allow sufficient time to address the temperature i*AGeaserise without a substantial degradation in plant safety.Finally, in the case where there is an ier-easerse in RCS temperature, the RCS is not intact Or is at roducod i.... nte, [P.., , and CONTAINMENT CLOSURE is not established, no heat-up duration is allowed (i.e., 0 minutes).

This is because 1) the evaporated reactor coolant may be released directly into the Containment atmosphere and subsequently to the environment, and 2) there is reduced reactor coolant inventory above the top of irradiated fuel.EAL #2 Basis pProvides a pressure-based indication of RCS heat-up.Escalation of the emergency classification level would be via IC CS64- or RAS1.Basis Reference(s):

1. NEI 99-01 Rev 6, CA3 2. Technical Specifications 3.6.1.1 3. Technical Specifications 3.6.4.1 4. OU-AA-1 03, Shutdown Safety Management Program 5. CPS 3002.01, Heatup and Pressurization

6. CPS 3002.01 C003, MODE 3 Checklist 7. CPS 4006.01, Loss of Shutdown Cooling 8. CPS 9000.06, Reactor Coolant and Vessel Metal/Pressure/Temperature Limit Logs 9. CPS 9433.13, ECCS Reactor Steam Dome Pressure B21-N097A(B)

Channel 6 Calibration Month 20XX CL 3-92 EP-AA-1 003 (Revision XX)

Clinton Annex Exelon Nuclear Clinton Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CU53 Initiating Condition:

UNPLANNED i;Greaserise in RCS temperature Operating Mode Applicability:

4,5 Emergency Action Level (EAL): I Note: The Emergency Director should declare the Unucual Eventevent promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.1. UNPLANNED rise in RCS temperature

> 200OF due to loss of decay heat removal.OR 2. Loss of the following for > 15 minutes.* ALL RCS temperature indications AND* ALL RPV water level indications

1. UNPLA\NNED inropecs in RCS tompcraturo to greater than (sito Spocific Tochnical Specification cold nhutdowAn tomperatu ro limit).2. Loss of.ALL-1 RCS. temporture and roactor '.occoLRCS lovol indication for 15 mninutes Or longer.Basis: UNPLANNED:

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

The cause of the parameter change or event may be known or unknown.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment (primary or secondary) and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

This IC addresses an UNPLANNED inreaserise in RCS temperature above the Technical Specification cold shutdown temperature limit, or the inability to determine RCS temperature and level, represents a potential degradation of the level of safety of the plant. If the RCS is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency Director should also refer to IC CA53.Month 20XX CL 3-93 EP-AA-1003 (Revision XX)

Anng-.f IPvlenn N, ma~r r~I;r~tr~n Anna,, FvaIr~n NI. .~Ia~r RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS RCS is intact when the RCS pressure boundary is in its normal condition for the Cold Shutdown mode of operation (e.g. no freeze seals, or steam line nozzle Plugs, etc.).A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.

EAL #1 involves a loss of decay heat removal capability, or an addition of heat to the RCS in excess of that which can currently be removed, such that reactor coolant temperature cannot be maintained below the cold shutdown temperature limit specified in Technical Specifications.

During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.

During an outage, the level in the reactor vessel will normally be maintained above the reactor vessel flange. Refueling evolutions that lower water level below the reactor vessel flange are carefully planned and controlled.

A loss of forced decay heat removal at reduced inventory may result in a rapid i, reaserise in reactor coolant temperature depending on the time after shutdown.EAL #2 reflects a condition where there has been a significant loss of instrumentation capability necessary to monitor RCS conditions and operators would be unable to monitor key parameters necessary to assure core decay heat removal. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.

I Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.

Escalation to Alert would be via IC CA6 based on an inventory loss or IC CA53 based on exceeding plant configuration-specific time criteria.Basis Reference(s):

Month 20XX CL 3-94 EP-AA-1003 (Revision XX) nten AnnovY F=valnn N"Aarhr (~Iintr~n Ann~v Fv~Inn M.irI~~r RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS

1. NEI 99-01 Rev 6, CU3 2. Technical Specifications Table 1.1-1 3. CPS 4401.01, EOP-1 RPV Control 4. Clinton Power Station Emergency Operating Procedures Technical Bases, Section 12 5. CPS 4411.07, RPV Level Instrumentation

6. MA-CL-716-102, Reactor Disassembly

7. CPS 3002.01, Heatup and Pressurization

8. CPS 9000.06, Reactor Coolant and Vessel Metal/Pressure/Temperature Limit Logs Month 20XX CL 3-95 EP-AA-1003 (Revision XX)

Exelan Nuclear Clinton Annex Eeo ula RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CG64-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 Eme.g.ny-" vent promptly upon determining that 30 minutes has been exceeded, or will likely be exceeded.1. a. RPV water level < -162 inches(rAF) 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 indications OR" Containment High Range Monitors 1 RIX-CM061 or 1 RIX-CM062

>3 R/hr.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 in RPV inventory.

Month 20XX CL 3-96 EP-AA-1003 (Revision XX)

Exelon Nuclear Clinton Annex......n.Nu..

e..RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS AND c. Any Containment Challenge Indication (Table 04)Table C4 Containment Challenae 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* 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.1 .a. (Reactolr ess than (cite-pepoifi level) for 30 minuteG Or AND b. ANY indication fro~m the Containment Challenge Table (see below)-.;. A. m-ea c-%; ar v Rs- aV m GS e v eI anno:; t n u*cR m. n i ;_ered- iur aw rii~iUte6 OF~ ignur.AIND b. Cre uncoaver..

is indicated by ANY. oft the fellowin p ~tz 'nccinc raciianon monirori reaaini~ greater man isire ~neciiic YLUUeJ c' c~------------------------

...r-C, ý-I'mau,c soiircep r-ange monitOr findiation 0 0 , 4 e UNPLANNEDL increase in (site speeifle sumnp anwer tank) levels 31 sumtlcent ffutfniff"e to inluieute ufffe titun~Ver.umner site suecinc mn~iicarion~, AND G. AN ind-ication from the Containment Challenge Table (see below)-.Containment Challenge Table Month 20XX CL 3-97 EP-AA-1 003 (Revision XX)

Vlintnn Anngbv I::alnn N~rilpar RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CLOSTE net ihed, (Explesive mixture) exists inside containment.

UNPLANNED increase in containmaent pressure* if CONTIAINAMENT CLOSURE i re -establi;hed prior to ,xceeding the 30.min, te time limit, then declaration of a General Emergency

i. no required.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.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.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment (primary or secondary) and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

This IC addresses the inability to restore and maintain reactor vessel level above the top of active fuel with containment challenged.

This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity.

Releases can be reasonably expected to exceed EPA Protective Action Guidelines (PAG) exposure levels offsite for more than the immediate site area.Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.With CONTAINMENT CLOSURE not established, there is a high potential for a direct and unmonitored release of radioactivity to the environment.

If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen bum will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity.

It therefore represents a challenge to Containment integrity.

In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a core uncovery could result in an explosive gas mixture in containment.

If all installed hydrogen gas monitors are out-of-service during an event leading to fuel cladding damage, it may not be possible to obtain a containment hydrogen gas concentration reading as ambient conditions within the containment will preclude personnel access.Month 20XX CL 3-98 EP-AA-1003 (Revision XX)

Clinton Annex Exellon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS During periods when installed containment hydrogen gas monitors are out-of-service, operators may use the other listed indications to assess whether or not containment is challenged.

In EAL-2.bEAL

1. 2, the 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties).

It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.

The inability to monitor RPV -eyeIRPV water level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation.

If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RPV.These EALs address concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Basis Reference(s):

1. NEI 99-01 Rev 6, CG1 2. CPS 4401.01, EOP-1 RPV Control 3. CPS 4402.01, EOP-6 Primary Containment Control 4. Clinton Power Station Emergency Operating Procedures Technical Bases, Sections 9, 10 and 12 5. CPS 4406.01, EOP-8 Secondary Containment Control 6. USAR Figure 6.2-132 7. USAR Table 1.3-4 8. Technical Specifications 3.6.1.1 9. Technical Specifications 3.6.4.1 10. OU-AA-1 03, Shutdown Safety Management Program 11. Clinton Power Station Emergency Operating Procedures Technical Bases 12. CPS 4411.07, RPV Level Instrumentation

13. CPS 3306.01, Source/Intermediate Range Monitors (SRM/IRM)Month 20XX CL 3-99 EP-AA-1003 (Revision XX) f'.lintnn Annav FvI~vnn Mitrlmar rIintr~n Annoy FvoIrin Mm a,.imor RECOGNITION CATEGORY*COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS C6 Initiating Condition:

Loss of RPV inventory affecting core decay heat removal capability.

Operating Mode Applicability:

4,5 Emergency Action Level (EAL): Note: The Emergency Director should declare the Sito Aroa Emor..gncyveynt promptly upon determining that 30 minutes 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 indications OR" Containment High Range Monitors 1 RIX-CM061 or 1 RIX-CM062

>3 R/hr.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 in RPV inventory.

S 1.a.

CLOSURE not established.

Month 20XX CL 3-100 EP-AA-1 003 (Revision XX)

M.1;nf[nn Annav Fwainn Nnnr-liaar RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS ANDl llPmb i 1. t -iactr~ voccoi: GS II-ev~~'-f or R-HV FYWv-MI level less than (CitO CPOCaiTIC h d df 2. a. CONTAINMIVENT CLOSURE I ANDlR. (Ke2CTrA0FCyesseVF.

iGAWVi-ti OF H-wv IWAi- level less thanf tsite b d b spe~ii e~eQ-ve;6. a. (tipactor vessev G8 .2" eF~'tr or F-w :ni level Gannot DeRRO monnorca 6o U Minutc Or longor. -i df AND t1 .na Ran A ; ;.,Ia.. A k.. A LIV Sd *k 6 ia11 .n Mv U.. I. "a tptt y '..V t t7 to. Vl.*~i WV "q=Io .* t,.J f u 0 i'bite ffctc aiaion moitOri maoinP' greater- than (si1te specme vaiue)-r.. .j~~~~~0..... /* I-i-rtme snir-ee rann1e meniter- ki-3lwcntion FQIDW T TXT1DT A XTXTr77-%

: r...... I A / 11 1 1 V Ir-r. ; +W J "v =r n ¶t*1 TV *fl ~ r vO~ -V~arnp cm"' LIAW vJalfrfl 7 V t7 ntr rNt*A Uri mnagnitude to indieate cor-e uncovery*(Other site specific indications)

Basis: CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment (primary or secondary) and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

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 add.,roe-e a -ignifiant and prOlonRgd less of RPV inventoy control and , p Gy ,.ea...i.g to I...,;".MMINENT-f',ue., dmg, The lost inventory may be due to a RCS component failure, a loss of configuration control or prolonged boiling of reactor coolant. These conditions entail major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.

I Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If Month 20XX CL 3-101 EP-AA-1003 (Revision XX)

Clinton Annex Exellon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS RCS/reactor vessel level cannot be restored, fuel damage is probable.Outage/shutdown contingency plans typically provide for re-establishing or verifying CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory control functions.

The difference in the specified RCS/reactor vessel levels of EALs #1.-b and#2-.b reflect the fact that with CONTAINMENT CLOSURE established, there is a lower probability of a fission product release to the environment.

In EAL #3-,a the 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties).

It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.

The inability to monitor RPV-leyelRPV water level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation.

If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RPV.These EALs address concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Escalation of the emergency classification level would be via IC CG--6 or ARG1.Basis Reference(s):

1. NEI 99-01 Rev 6, CS1 2. Technical Specifications Table 3.3.5.1-1 3. ORM Attachment 2-7, Table 5 4. CPS 4401.01, EOP-1 RPV Control 5. Clinton Power Station Emergency Operating Procedures Technical Bases, Section 12 6. CPS 4411.07, RPV Level Instrumentation

7. USAR 5.2.5.1 8. CPS 9043.06, Drywell Floor Drain Sump Flow Test 00PS404 9. CPS 9443.01, Drywell Equipment Drain Sump Flow E31 -N578 Channel Cal 01 PS274 10. CPS 3306.01, Source/Intermediate Range Monitors (SRM/IRM)Month 20XX CL 3-102 EP-AA-1003 (Revision XX)

Clinton Annex Exellon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS

11. Technical Specifications 3.6.1.1 12. Technical Specifications 3.6.4.1 13. OU-AA-103, Shutdown Safety Management Program 14. CPS 3002.01, Heatup and Pressurization

15. CPS 5062.01, ALARM PANEL 5062 ANNUNCIATORS

-ROW 1 Month 20XX CL 3-103 EP-AA-1003 (Revision XX) iPlintnn AaagsY i:vglelnn Ki iial-mor 1mml ILl ntr l lllA nnvFAVIrV N. *IVl4a1I RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA6I-Initiating Condition:

Loss of RPV inventory.

Operating Mode Applicability:

4,5 Emergency Action Level (EAL): Note: The Emergency Director should declare the event Aled -promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.1. a. Loss of RPV inventorv as indicated bv 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 Leakaqe" 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 in RPV inventory.

.1 I ...J ...-- -i. -1= ' t r-'rr t cv Q8 Inv nn t -ry a- induG rao lay lrevl iess than kskIT po_ Tm'I 2. a. Rn actOr level cannoVt be mnlitrcd for 15 I Iiutcc Or lonaor AND I/

• I \ I/AIqA AI IBR 9ARIil IAtlAIA AI IA 9A 0I. ur4r ;.imLi II;GkuaLL iiR lt.Iu. eITI SUiiu anuiiii. Kuuu levels di~ue t less of roactr voeceVlR vS invnt.,rv.

I B Month 20XX CL 3-104 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING 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.-.This IC addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier).This condition represents a potential substantial reduction in the level of plant safety.Fer-EAL #11, Basis-aA lowering of water level below -45.5 inches (site .6,eific le'.,l) indicates that operator actions have not been successful in restoring and maintaining RPV water level. The heat-up rate of the coolant will erise as the available water inventory is reduced.A continuing de9,easeloss in water level will lead to core uncovery.Although related, EAL #1 is concerned with the loss of RCS inventory and not the potential concurrent effects on systems needed for decay heat removal (e.g., loss of a Residual Heat Removal suction point). An iP;,reaserise in RCS temperature caused by a loss of decay heat removal capability is evaluated under IC CA53.Fer-EAL #2 Basis ,-the inability to monitor RPV-IeveIRPV water level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation.

If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RPV.The 15-minute duration for the loss of level indication was chosen because it is half of the EAL duration specified in IC CS64-If the RPV invewte~y-water level continues to lower, then escalation to Site Area Emergency would be via IC CS64-.Month 20XX CL 3-105 EP-AA-1003 (Revision XX)

Exalon Nuclear Clinton Annex Eeo ula RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS Basis Reference(s):

1. NEI 99-01 Rev 6, CA1 2. Technical Specifications Table 3.3.5.1-1 3. ORM Attachment 2-7, Table 5 4. CPS 4401.01, EOP-1 RPV Control 5. CPS Emergency Operating Procedures Technical Bases, Section 12 6. CPS 4411.07, RPV Level Instrumentation

7. USAR 5.2.5.1 8. CPS 9043.06, Drywell Floor Drain Sump Flow Test 00PS404 9. CPS 9443.01, Drywell Equipment Drain Sump Flow E31-N578 Channel Cal 10. CPS 5065.06, ALARM PANEL 5065 ANNUNCIATORS

-ROW 6 Month 20XX CL 3-106 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS Initiating Condition:

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

4,5 Emergency Action Level (EAL): CU6I-I Note: The Emergency Director should declare the Unusual E'-ntcvent promptly upon determining that 15 minutes 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 03 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 in RPV inventorv.

1.

lo6 i Of reactor coolant &resUltS in osc'VRS levol loss, than A rouired lower limit fFor 15 minutes OFr i". a. macGCo VCeSC",',-Z

.... ca nno. DO mon",rep-.

AND 9. UI'L:'.riPJIM

!nRGoase in ske-s D0CITI sumn anoR19/-FtaK IleVoic. -'-------

-Basis: "" * \ ..... I-- ...........

iv 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.Month 20XX CL 3-107 EP-AA-1003 (Revision XX)

Clinton Annex Clinton Annex Exellan Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS This IC addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor RPV IeveIRPV water level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant.The procedurally established lower limit is not an operational band established above the procedural limit to allow for operator action prior to exceeding the procedural limit, but it is the procedurally established lower limit.Refueling evolutions that decrease RCS water inventory are carefully planned and controlled.

An UNPLANNED event that results in water level decreasing below a procedurally required limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered.EAL #1 recognizes that the minimum required RPV-IevelRPV water level can change several times during the course of a refueling outage as different plant configurations and system lineups are implemented.

This EAL is met if the minimum level, specified for the current plant conditions, cannot be maintained for 15 minutes or longer. The minimum level is typically specified in the applicable operating procedure but may be specified in another controlling document.The 15-minute threshold duration allows sufficient time for prompt operator actions to restore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level.EAL #2 addresses a condition where all means to determine RPV-levelRPV water level have been lost. In this condition, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RPV.Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA6-- or CA53.Month 20XX CL 3-108 EP-AA-1003 (Revision XX)

Exalon Nuclear Clinton Annex Eeo ula RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS Basis Reference(s):

1. NEI 99-01, Rev. 6 CU1 2. Technical Specifications Table 3.3.5.1-1 3. ORM Attachment 2-7, Table 5 4. CPS 4100.01, Reactor SCRAM.4. CPS 4401.01, EOP-1 RPV Control 5. CPS Emergency Operating Procedures Technical Bases, Section 12 6. CPS 4411.07, RPV Level Instrumentation

7. USAR 5.2.5.1 8. CPS 9043.06, Drywell Floor Drain Sump Flow Test 00PS404 9. CPS 9443.01, Drywell Equipment Drain Sump Flow E31 -N578 Channel Cal 10. MA-CL-716-102, Reactor Disassembly

11. USAR Figure 3.8-31 12. USAR Table 7.1-13 Month 20XX CL 3-109 EP-AA-1003 (Revision XX)

AnneY I=yplnn r~lintnn Annex Fvaeinn Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG1 Initiating Condition:

HOSTILE ACTION resulting in loss of physical control of the facility.Operating Mode Applicability:

1,2,3,4,5, D Emergency Action Level (EAL): 1. A notification from the Security Force that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA.AND 2. a. ANY Table H1 safety function cannot be controlled or maintained.

OR b. Damaae to sDent fuel has occurred or is IMMINENT Table H1 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)A l p

• l *1. a. Ax I-IuI II 'w I Iur, 16 occu--lrring or Pas o roa wit-in the FriO-"l i " A DC A -%e-- rmr%^rfn,4 kw fkm it, irifti gnkiff--j 1rnI 5 t ~**

• S- --L AOL-" e5 .5* ld I ANM I- IT 1r a-- -,C L-..J.~1 Lo. ag i fl1 -I viv j, b~l ..t.;uwt v" .A lklff I AL- x " ., -I -A. .X. .--A..* & L- -1 i.~ ~~~~~~~~~~~~~~

R. im oiwriuN c' uimoi ~rimu uiw~uv mnaintained-."Reactivity eontroel"-Coe* eeeli~g" RCS heat rwemval OR 2.Damaee to seent fuel has occurred Or is IMMINENT.Month 20XX CL 3-110 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Basis: HOSTILE ACTION: An act toward a NPP or its Personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.PROJECTILE:

An obiect directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.IMMINENT:

The traiectory 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.HOSTILE FORCE: One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, eguipped with suitable weapons capable of killing, maiming, or causing destruction.

This IC addresses an event in which a HOSTILE FORCE has taken physical control of the facility to the extent that the plant staff can no longer operate equipment necessary to maintain key safety functions.

It also addresses a HOSTILE ACTION leading to a loss of physical control that results in actual or IMMINENT damage to spent fuel due to 1) damage to a spent fuel pool cooling system (e.g., pumps, heat exchangers, controls, etc.) or, 2) loss of spent fuel pool integrity such that sufficient water level cannot be maintained.

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].Emorgency plans and implementing procedures aro public documonets; theroforo, EALe should not inclrporato SocurityI lenitiye information.

This inIudoc information that ma' be advantageous to a potential adversary, such as the paiticUars spqecific threat Or throat location.

Securit',,'sensfitie infenrmatien should be Month 20XX CL 3-111 EP-AA-1003 (Revision XX)

('lintnn AnnoyN.nlAar Veiltvnuu nnlvn vinlln NIuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY coentaminod in non-public documentc cuch as the SocUrity Plan.Basis Reference(s):

1. NEI 99-01, Rev. 6 HG1 2. Station Security Plan -Appendix C Month 20XX CL 3-112 EP-AA-1003 (Revision XX)

Mlintr~n Annav PIrvlnn hlrMl.,Ir RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS1 Initiating Condition:

HOSTILE ACTION within the PROTECTED AREA.Operating Mode Applicability:

1,2,3,4,5, D Emergency Action Level (EAL): A notification from the Security Force that a HOSTILE ACTION is occurrinq or has occurred within the PROTECTED AREA.1. A HOSTILE ACTION ic occurring or has occurrod within the PROTECTED AREA as, ropo-d by the (citocpe,, s.,,., shift .uporwici,,).

Basis: HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.PROJECTILE:

An obiect directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.HOSTILE FORCE: One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTED AREA. This event will require rapid response and assistance due to the possibility for damage to plant equipment.

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.Month 20XX CL 3-113 EP-AA-1003 (Revision XX)

Pllfra'n Ann-,w FvYgalnn Nii~l-ar t~i ~ A nn~w Fvalrhn MuaiIm~r RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering).

The Site Area Emergency declaration will mobilize ORO resources and have them available to develop and implement public protective actions in the unlikely event that the attack is successful in impairing multiple safety functions.

This IC does not apply to a HOSTILE ACTION directed at an ISFSI PROTECTED AREA located outside the plant PROTECTED AREA; such an attack should be assessed using IC HA1. It also does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR§ 50.72.Emorgency plans and implementing prOcodurec arc public documentrs; therefore, EAI~s should noticroaeScrt senrsitive information.

T-his includes information that specific throat or throant loca--tioan.

SocUrity Sensitive information should be containod in non-public docume~nts such as the Security Plan.Escalation of the emergency classification level would be via IC HG1.Basis Reference(s):

1. NEI 99-01 Rev 6, HS1 2. Station Security Plan -Appendix C Month 20XX CL 3-114 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA1 Initiating Condition:

HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.Operating Mode Applicability:

1,2,3,4,5, D Emergency Action Level (EAL): 1. A validated notification from NRC of an aircraft attack threat < 30 minutes from the site.1.A H4OSTILE ACTION is eccurring or has occurred within the OWNE CONTROLLED AREA as repcrted by the (site specific seeur~ity shift super.'isioni).

OR 2. Notification by the Security Force that a HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLED AREA.A validated notification from, NR, of an aircraft attack threat within 30 minutos of the ste Basis: HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.PROJECTILE:

An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.OWNER CONTROLLED AREA (OCA): The property associated with the station and owned by the company. Access is normally limited to persons enterinng for official business.Month 20XX CL 3-115 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.HOSTILE FORCE: One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the plant and staff for a potential aircraft impact.Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering).

The Alert declaration will also heighten the awareness of Offsite Response Organizations, allowing them to be better prepared should it be necessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE.Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.EAL #1 Basis Addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in a heightened state of readiness.

This EAL is met when the threat-related information has been validated in accordance with CPS 4305.01, Security Threat Intrusion.

EAL #2 Basis-1-i&-aApplicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action directed against an ISFSI that is located outside the plant PROTECTED AREA.Month 20XX CL 3-116 EP-AA-1003 (Revision XX)I AnnAY FYplnn RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY anticipAted arriVal time is Within 30 minutes. The intent of this SAL is to ensure that threat related not~ifiations aro made in a tamely mnanner so that plant personnel and OROs are in a heightened stae f rea:d-iness;L.

This EAL is mnet When the throat related infor~m.atfion has boon v-alid-ated-in -accorQd-ance With (sitcsecii proedure).

The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft.

The status and size of the plane may be provided by NORAD through the NRC.In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.Emorgccy plans and i procedures are pu iblic documents; therefore, EAIls should net incorporate Sccurity sensitive information.

This inldsifrainthat may be advantageous to a potential advcrsaiy, such as the particulars coneiga specific threat Or threat location.

Security-sensitive infenrmatien should be cnandi non Dublic documents such as the SeuiyPlan.

Escalation of the emergency classification level would be via IC HS1.Basis Reference(s):

1. NEI 99-01 Rev 6, HA1 2. Station Security Plan -Appendix C 3. CPS 4305.01, Security Threat Intrusion Month 20XX CL 3-117 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU1 Initiating Condition:

Confirmed SECURITY CONDITION or threat.Operating Mode Applicability:

1,2,3,4,5, D Emergency Action Level (EAL): 1. Notification of a credible security threat directed at the site as determined Der SY-AA-1 01-132, Security Assessment and Response to Unusual Activities.

1 .A SECURITY CONDITION that does not involve a HO0ST-ILE ACTION as rpepored by the (site specific secur-ity shift supervision).

OR 2. A validated notification from the NRC providing information of an aircraft threat.2. Notification of a er-edible secur-ity threat dir-ected at the site.OR 3. Notification by the Security Force of a SECURITY CONDITION that does not involve a HOSTILE ACTION.3. A validated noettifcaitiso"n tho NRC providing information of an aircraft threat.Basis: SECURITY CONDITION:

Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safely of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION 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.

HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.Month 20XX CL 3-118 EP-AA-1003 (Revision XX)

Ann--v Fiavlnn Nid-loar RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY PROJECTILE:

An obiect directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, and thus represent a potential degradation in the level of plant safety.Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs HA1, HS1 and HG1.Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.Classification of these events will initiate appropriate threat-related notifications to plant personnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].EAL #1 Basis Addresses the receipt of a credible security threat. The credibility of the threat is~Q~A~QAd in ~rr~ord~nr~A with ~Y-AA-1O1-1f~'

rnfnrnnonr (run conwnmun"m~

cupo~icin) b-onauc thocoar^ tho jn~u rainodj to aonfirm thati a coourit a ot anntrallod duo to tho noturo of SafoouardcA andl 10 CFR- 0 Q.0 ifrain EAL #2 Basis aAddresses the threat from the impact of an aircraft on the Dlant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft.

The status and size of the plane may also be provided by NORAD through the NRC. Validation of the threat is performed in accordance with CPS 4305.01, Security Threat Intrusion

°6..ite-.

6e.efi .DF e ..addrcce....

the reocipt of a e .edible t t..,r h, eat.-. The of the thr.eat ;i-with (site spocific procodur)EAL #3 Basis fReferences Security Force(..t.

c),ccfic .c.urot': h ....r- ..o. -because these are the individuals trained to confirm that a security event is occurring or has occurred.Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR § 2.39 information.addrccec tho tho from ho ..ofr--. .. .an irrarft on tho plant. Th- UPC Hoadquart-ra Op-ort~onc Officor HOO) ~.il qonmmuniaoto to tho liconcop ^ tho throat in':oijo a^ n aioraft. Tho -tot..^CI and ^ ci o tho p1ano9 ma,' Olen h- hr'.'io b'; NO.Ar) Jhrougch tho NRC. 110'aldtionn of tho thr-oat I I !ll I !t __1 ..... \porroroa in oooranoo w:n lenocpoo:iC rcgr)I I Month 20XX CL 3-119 EP-AA-1 003 (Revision XX)]

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Em~ergoncy plane and implementing proceduros are pubicMD dOeumcnts; therfefoe, EAI~s Shoul-d- not incomor~ate Security-sensitive infosmation.

This includes info~mation that may be advantageous to a potenti-al adversaa~, SUch as tho pa~tiGUlaFS concering -a specfctrato het oain Socurity-rsensitive ninforma2tionn should becontained in non public documon9tsA suc9h as the Security Plan.Escalation of the emergency classification level would be via IC HA1.Basis Reference(s):

1. NEI 99-01 Rev 6, HU1 2. SY-AA-101-132, Security Assessment and Response to Unusual Activities

3. Station Security Plan -Appendix C 4. NRC Safeguards Advisory 10/6/01 5. Letter from Mr. B. A. Boger (NRC) to Ms. Lynette Hendricks (NEI) dated 2/4/02 6. CPS 4305.01, Security Threat Intrusion Month 20XX CL 3-120 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS26 Initiating Condition:

Inability to control a key safety function from outside the Control Room.Operating Mode Applicability:

1,2,3, 4,5, D Emergency Action Level (EAL): Note: The Emergency Director should declare the Site A.oa ..egon.y.vent promptly upon determining that (site -speific numb.. f f15 minutes) has been exceeded, or will likely be exceeded.1. A Control Room evacuation has resulted in plant control being transferred from the Control Room to altemate locations per CPS 4003.01, Remote Shutdown.-;

AND 2. Control of ANY Table H1 key safety function is not reestablished in < 15 minutes.Table H1 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)1. a. An event has resulted in plant corol being transferd panels and control StatiGns).

from the Control RoOM to (cite spec~ific_

remoete shutdown AM~b. Conltrol of ANY. of the foellowing key safety functions is notI reieustablished wAithin (site specific number of mninutes).

9 ReactiVity control tv iM I IVV~ r3v l-4 iv I IE A_11R66 heat removal Month 20XX CL 3-121 EP-AA-1003 (Revision XX) 1'lintnn AnnoiY I5=vm~ln N, iil-haar (~Iintr~n Ann0v F v.I,~n Nm.w~Ia~r RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Basis: The time period to establish control of the plant starts when either: a. Control of the plant is no lonqer maintained in the Main Control Room OR b. The last Operator has left the Main Control Room.This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations, and the control of a key safety function cannot be reestablished in a timely manner. The failure to gain control of a key safety function following a transfer of plan control to alternate locations is a precursor to a challenge to one or more fission product barriers within a relatively short period of time.The determination of whether or not "control" is established at the remote safe shutdown location(s) is based on Emergency Director judgment.

The Emergency Director is expected to make a reasonable, informed judgment within (the ,im.e 15 minutes whether or not the operating staff has control of key safety functions from the remote safe shutdown location(s).

Escalation of the emergency classification level would be via IC FGI or CG6I-.Basis Reference(s):

1. NEI 99-01, Rev 6 HS6 2. CPS 4003.01, Remote Shutdown Month 20XX CL 3-122 EP-AA-1003 (Revision XX)

Annga-P:vdmlrn M"Admrl~t~I I uitrui A nn~w ... .t~u a a-.. S. .~n ~ S S RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA26 Initiating Condition:

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

Operating Mode Applicability:

1, 2, 3, 4, 5, D Emergency Action Level (EAL): A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per CPS 4003.01, Remote Shutdown.

An-event remote shutdown panols and local1 coenitroml stations).

Basis: This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations outside the Control Room. The loss of the ability to control the plant from the Control Room is considered to be a potential substantial degradation in the level of plant safety.Following a Control Room evacuation, control of the plant will be transferred to alternate shutdown locations.

The necessity to control a plant shutdown from outside the Control Room, in addition to responding to the event that required the evacuation of the Control Room, will present challenges to plant operators and other on-shift personnel.

Activation of the ERO and emergency response facilities will assist in responding to these challenges.

Escalation of the emergency classification level would be via IC HS26.Basis Reference(s):

1. NEI 99-01, Rev 6 HA6 2. CPS 4003.01, Remote Shutdown Month 20XX CL 3-123 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3~Initiating Condition:

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

1,2,3,4,5, D Emergency Action Level (EAL): Note: The Emergency Director should declare the Unusual Eventevent 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 extinauished in < 15-minutes of ANY of the t 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 sinale 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 Month 20XX CL 3-124 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY 3 A FIRE within the plant 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.

(1) a. A FIRE is NOT extinguished within 1 _,minutes of ANY of the following FIRE detecti, n " Report from the field (i.c., visual obsew.atien)" Receipt Of mnultiple (more than 1) fire alarmc OrFniain" Field Verification.

of a single fire alarm AND b. The FIRE is. locnated within ANY of the following plant rooms Or arcas:;(sftc specific list of plant rooms OF areas)(2) a. Receipt of a single fir alaFrm (i.e., no other indications of a FIRE).;AND b. The FIRE is locatedwmit~hin ANY nof t~he following plant rooms Or areas: (site-specific list of plant roomAs Or areas)AND G. The existence of a FIRE is not verified within 30 minutes of alarm receipt;(3) A FI1RE within the plant or- ISF-SI (for- plants with an ISE-SI euttide the ph-nt P-roteeted Area I PROTECTED AREA not e~dinguishod-within 6-0 minutes, ofth inRitial report, alarm Or indication.

(4) A F! RE within the plant or- ISFSI [for- plants with a;n ISESIQ oultside the plant Pro9toctod A rea) PROTECGTED AREA that requi~res firofighting Suppoed by an eftsite fire response agencY to extgnguirh Month 2QXX CL 3-125 EP-AA-1 003 (Revision XX)

Exelan Nuclear Clinton Annex .x..... Nu.. ea.RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Basis: FIRE: Combustion characterized by heat and liqht. Sources of smoke such as slippinq drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.EAL #1 Basis The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE could be a drop in fire main pressure, automatic activation of a suppression system, etc.Upon receipt, operators will take prompt actions to confirm the validity of an initial fire alarm, indication, or report. For EAL assessment purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and not the time that a subsequent verification action was performed.

Similarly, the fire duration clock also starts at the time of receipt of the initial alarms, indication or report.EAL #2 Basis This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will take prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed.

A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional time is allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress.If an actual FIRE is verified by a report from the field, then EAL #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted.

Month 20XX CL 3-126 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY EAL #3 Basis In addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety. Thin ,basis e,,nds to FIRE .ccur.ing within th'PRO C TED A of an IFig 1 oc Jtdl outside the plant PROTECTED AREA;.[Senten.e for- plants with an kiWS outside the plant Proeteted Area]EAL #4 Basis If a FIRE within the plant or- 4399 [for- plants with an ISFS outside the plant Protected AFeal-PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded.

The dispatch of an offsite firefighting agency to the site requires an emergency declaration only if it is needed to actively support firefighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish.

Declaration is not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.Basis-Related Requirements from Appendix R Appendix R to 10 CFR 50, states in part: Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions." When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.

In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify a single alarm is well within this worst-case 1-hour time period.Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA26 or MA5SAg.Month 20XX CL 3-127 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Basis Reference(s):

1. NEI 99-01, Rev 6 HU4 2. USAR Appendix F 3. USAR Figure 1.2-3, Principal Station structure Month 20XX CL 3-128 EP-AA-1003 (Revision XX)

ExAIon Clinton Annex ExeIon Nuclasr RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU42 Initiating Condition:

Seismic event greater than OBE levels.Operating Mode Applicability:

1,2,3,4,5, D Emergency Action Level (EAL): 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 q)* 5009-2A (Acceleration Exceeded at Seismic Switch Operating Basis Earthquake at 0.11 a Horz / 0.11 g Vert on seismic switch 1VS-EM-014)

• 5009-1 A (Acceleration Exceeded Safe Shutdown Earthquake (SSE) at 0.25 g)Seismic eveont groator than Operating Basis Earthquake (01BE) as indicated bya.a. (citc cpecific indication that a ceicrnic event mnet Or oxceodod 013E limits)Basis: This IC addresses a seismic event that results in accelerations at the plant site greater than those specified for an Operating Basis Earthquake (OBE)'. An earthquake greater than an OBE but less than a Safe Shutdown Earthquake (SSE)2 should have no significant impact on safety-related systems, structures and components; however, some time may be required for the plant staff to ascertain the actual post-event condition of the plant (e.g., performs walk-downs and post-event inspections).

Given the time necessary to perform walk-downs and inspections, and fully understand any impacts, this event represents a potential degradation of the level of safety of the plant.Event verification with external sources should not be necessary during or following an OBE. Earthquakes of this magnitude should be readily felt by on-site personnel and recognized as a seismic event (e.g., typical lateral accelerations are in excess of 0.08g).The Shift Manager or Emergency Director may seek external verification if deemed appropriate (e.g., a call to the USGS, check intemet news sources, etc.); however, the verification action must not preclude a timely emergency declaration.

1 An OBE is vibratory ground motion for which those features of a nuclear power plant necessary for continued operation without undue risk to the health and safety of the public will remain functional.

An SSE is vibratory ground motion for which certain (generally, safety-related) structures, systems, and components must be designed to remain functional.

Month 20XX CL 3-129 EP-AA-1 003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA26 or MA5SA9.Basis Reference(s):

1. NEI 99-01, Rev 6 HU2 2. CPS 4301.01, Earthquake Month 20XX CL 3-130 EP-AA-1003 (Revision XX)0 Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA5 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: 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 ADplicability Area Entry Related Mode Applicability Auxiliary Buildinq*

Modes 3, 4, and 5 Auxiliary Building Modes 4 and 5 Steam Tunnel* I*Areas required to establish shutdown cooling AND 2. Entry into the room or area is prohibited or impeded Note: if the equipment in the li-ted- room oFr area, Wa,, already inoperable OFr out of 6er~ico bMor the ovent occurred, then no em~ergencY claGcification ic Wa~a~te4d-(1) a. e of a texi,, cr Or flammable gas inte any of the followngpan rom or ar47:* "! ,,re i,,

• r II *istelto eIR lpo ist 9; plani roome Or arkeass with enIr: rciaioa mode applicability identified)

I b. Entr; into the roomn Or area us prohibited or impeded.Basis: Month 20XX CL 3-131 EP-AA-1 003 (Revision XX)

('lintnn Annoy I=yAInn Nuclear (mIin tv Anngmy E~vxlnn Nulewar RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY This IC addresses an event involving a release of a hazardous gas that precludes or impedes access to equipment necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal plant proceduresmawtain no..al plant oporati.n, Or r.qui;rd for a normal plant coo"down and .. h.. ddoee'w.wn.

This condition represents an actual or potential substantial degradation of the level of safety of the plant.Table H3 is a list of plant rooms or areas with entry-related mode applicability that contain equipment which require 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).

This Table does not include the Control Room since adequate enqineered safety/design features are in place to preclude a Control Room evacuation due to the release of a hazardous gas.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 gaseous release preclude the ability to place shutdown cooling in serviceat the timo of the gasoouc release. The emergency classification is not contingent upon whether entry is actually necessary at the time of the release.Evaluation of the IC and EAL do not require atmospheric sampling; it only requires the Emergency Director's judgment that the gas concentration in the affected room/area is sufficient to preclude or significantly impede procedurally required access. This judgment may be based on a variety of factors including an existing job hazard analysis, report of ill effects on personnel, advice from a subject matter expert or operating experience with the same or similar hazards. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

An emergency declaration is not warranted if any of the following conditions apply." The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the gaseous release).

For example, the plant is in Mode 1 when the gaseous release occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4." The gas release is a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., fire suppression system testing)." The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

Month 20XX CL 3-132 EP-AA-1003 (Revision XX)

M.intnn Annioy Fwailnn N"Alpar (91 ntr~n Ann~v Fv.Inn N.u~IAsur RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY* The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment.

This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.This EAL does not apply to firefighting activities that generate smoke, that automatically or manually activate a fire suppression system in an area, or to intentional inerting of containment.

I Escalation of the emergency classification level would be via Recognition Category RA, C or F ICs.Basis Reference(s):

1. NEI 99-01, Rev 6 HA5 2. USAR Appendix F 3. ACIT 660892-14, Station Halon Discharge IDLH Evaluation Month 20XX CL 3-133 EP-AA-1003 (Revision XX)

M.intnn AnnovY l:YaInn N"nAlmar RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU63 Initiating Condition:

Hazardous Event Operating Mode Applicability:

1,2,3,4,5, D Emergency Action Level (EAL): Note: EAL #4 does not agglv 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 SDecifications for the current operatina mode.OR 3. Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite 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 > 696ft.Note: SAL #3 does not apply to routinc traffi impediments such as fog, snwico wchic-lo b-reakdowjnsA~n or aGcidents-.

(1) A tornad stFrike within the PROTECTED AREA.(2) Intemal rovom O area flooding of a magnitude SUfficient to require manual or automatic tnf aR S.AFETY SYSTEM component needed for the current operating sodo-.IBm n\-I W4 "M n nf Wohi th P*15V...rf*

C Ir AU Pr A r' ,A,, A offstw eye zwdous matenals te.g., an eftsiteGHeFRIGal SAIN OF TOXIGG gas elease)-.v I Month 20XX CL 3-134 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY (4) A hazardous eve'nt that rosults in on-site conditions sufficient to prohibit the plant.Staff from accessing the site via personal vchiclec.(5) (Site sp8cific list of niatural Or technoloGgical hazard events)Basis: PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.EAL #1 Basis aAddresses a tornado striking (touching down) within the Protected Area.EAL #2 Basis aAddresses flooding of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns.Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode.EAL #3 Basis aAddresses a hazardous materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel within the PROTECTED AREA.EAL #4 Basis aAddresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles.

Examples of such an event include site flooding caused by a hurricane, heavy rains, up-river water releases, dam failure, etc., or an on-site train derailment blocking the access road.This EAL is not intended tooapply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the flooding around the Cooper Station during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in 2011.Month 20XX CL 3-135 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY rEAL #4 add-rocc, (sitoe pGifi, dor,-pti;,..-

EAL #5 Basis: A lake level of 696 ft el. is one foot below the 100-year flood elevation and represents a decision point: based on rate of lake level rise, and expected level crest, to shutdown the plant in order to assure safe plant shutdown (MODE 3) prior to lake level reachinq 697 ft.Escalation of the emergency classification level would be based on ICs in Recognition Categories RA, F, MS, H or C.Basis Reference(s):

1. NEI 99-01, Rev 6 HU3 2. CPS 4304.01, Flooding 3. Sargent & Lundy Report SL-4576 "Internal Flooding -Safe Shutdown Analysis and INPO SOER No. 85-5 Comparison Evaluation Report," Clinton Power Station, January 31, 1990 4. CPS 4303.02, Abnormal Lake Level Month 20XX CL 3-136 EP-AA-1003 (Revision XX)

Exelon Nuclear Clinton Annex Eeo ula RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG7 Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of a GENERAL EMERGENCY.

Operating Mode Applicability:

1,2,3,4,5, D Emergency Action Level (EAL): (-14) Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility.Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.Basis: IMMINENT:

The traiectory 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.HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE:

An obiect directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a General Emergency.

Basis Reference(s):

1. NEI 99-01, Rev 6 HG7 Month 20XX CL 3-137 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS7 Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of a SITE AREA EMERGENCY.

Operating Mode Applicability:

1,2,3, 4,5, D Emergency Action Level (EAL): (414 Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts, (1) toward site personnel or equipment that could lead to the likely failure of or, (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.Basis: HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy eguipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE:

An obiect directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a Site Area Emergency.

Basis Reference(s):

1. NEI 99-01, Rev 6 HS7 Month 20XX CL 3-138 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA7 Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of an ALERT Operating Mode Applicability:

1,2,3, 4,5, D Emergency Action Level (EAL): M( Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.Basis: HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy eguipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE:

An obiect directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an Alert.Basis Reference(s):

1. NEI 99-01, Rev 6 HA7 Month 20XX CL 3-139 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU7 Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of an (NQ) UNUSUAL EVENT.Operating Mode Applicability:

1,2,3,4,5, D Emergency Action Level (EAL): (44 Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated.

No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.Basis: This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an NOUEUNUSUAL EVENT.Basis Reference(s):

1. NEI 99-01, Rev 6 HU7 Month 20XX CL 3-140 EP-AA-1 003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY E-HUI Initiating Condition Damacie to a loaded cask CONFINEMENT BOUNDARY.Operating Mode Applicability:

Emergency Action Level (EAL): (1) Daage to a loaded caSk FINEMENT BOUNDARY as indicatod by an on-contact radiation roading greate than (2 timnes the cite-specific cask specific technical specification allowable radiation level) on the surface of the spent fuel Gask.Basis: This 1C addresses an event that results in damage to the CONFINEMENT BOUNDARY of -a Storage cask -ontaining spent fuel. ,a tIo ir adiated fuel that is ;icen-ed for dry storage beginning at the point that the loanded- storage cas'k is s~ealed. The issues o conGern are the creation of a potential Or actual release path to the enVironment-, degradation of one or more fuel assemblies duo to envirnmental factors, a configration changes Which could cause challenge ig the cask or fuel from The existenc-e of "damage" is determined by radiological sur.'ey. The technica specification multiple of "2 times", which is also used in Recogniti GCategory A IC AU!, is used here to distinguish between no-en emegency and emergencY conditions.

The emphasis fo-r. thisclssfiato is the degradation in the level of saeyo 9h spent fuel ca-;sk- and not the magnitude of the associated dose Or doseP r-ate4. it is ecognized that in the case of extremne damage to a loaded cask, the fact that the "on contact" dose rate limit is exceeded may be determnined based on measurement of a dose rate at somne distance fromr t~he ca:sk.-Secrit reateuevnts for ISESIs a;re covered u-nder Ir-A HWl a1nd HAl.Basis Reference(s):

I I 00A1 D,, I r'ial I10 Month 20XX Appendix 2-1 EP-AA-1003 (Revision XX) f'lin*#n Annimy=:::v- I %'rn M, irl"-"nr r'I;m~*,~n A nn~v ~v~Ii9Ii kin ~ ~uII IIAI** ~*** ~ EJ~~I.JI I I~IA~I~~I RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RG1 Initiating Condition:

Release of gaseous radioactivity resulting in offsite dose greater than 1000 mRem TEDE or 5000 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+1 0 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 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.

Month 20XX CL 3-31 EP-AA-1003 (Revision XX)

Mlinfnn Annoy IPY,-,In kiii -lnnr RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RG1 (cont)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 mRem while the 5000 mRem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.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 3-32 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RS1 Initiating Condition:

Release of gaseous radioactivity resulting in offsite 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 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+09 uCi/sec (> 1.03 E+3 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. > 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 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.

Month 20XX CL 3-33 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RS1 (cont)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 mRem while the 500 mRem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.Escalation of the emergency classification level would be via IC RG1.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 3-34 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA1 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 uCi/sec (> 1.03 E+2 uCi/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 Month 20XX CL 3-35 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RAI (cont)Emergency Action Level (EAL) (cont): 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 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 a 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 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 mRem while the 50 mRem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.Escalation of the emergency classification level would be via IC Month 20XX CL 3-36 EP-AA-1003 (Revision XX) r~li nfnn Annay I:=valrn Niiirl--nr

(~Iintnn Ann~v Fv~Ir~n M..r~Ia~r RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA1 (cont)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 3-37 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RUI 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 ORIX-PRO40 OR" Discharge Permit specified monitor OR 2. The sum of readings on the HVAC and SGTS Radiation Monitors> 1.17 E+06 uCi/sec (> 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.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.Month 20XX CL 3-38 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RUI (cont)Basis (cont): 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.

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 This EAL addresses radioactivity releases that cause effluent radiation monitor readings to exceed 2 times the limit established by a radioactivity discharge permit. This EAL will typically be associated with planned batch releases from non-continuous release pathways (e.g., radwaste, waste gas).EAL #2 Basis This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous effluent pathways.EAL #3 Basis This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).Escalation of the emergency classification level would be via IC RA1.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 3-39 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA2 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): 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 (1PRO06A-D)

• CCP Exhaust (1PR042A-D)

• Containment Exhaust (1PR001A-D)

• Containment Fuel xfer Plenum (1 PRO08A-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.IMMINENT:

The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly.

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.Month 20XX CL 3-40 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA2 (cont)Basis (cont): EAL #1 Basis This EAL escalates from RU2 in that the loss of level, in the affected portion of the REFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery of irradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visual observation (e.g., reports from personnel or camera images), as well as significant changes in water and radiation levels, or other plant parameters.

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

While an area radiation monitor could detect an rise 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 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 Category R or C ICs.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 CIL 3-41 EP-AA-1003 (Revision XX)

Clintnn Annov I=v-,Inn K, it-Iaor Clintnn Ann~v Fvcinn Miu~Ia~ar RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU2 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 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 R1.Table RI Fuel Handling Incident Radiation Monitors 0 Fuel Building Exhaust (1PRO06A-D) 0 CCP Exhaust (1 PR042A-D)* Containment Exhaust (1PRO01A-D)

• Containment Fuel xfer Plenum (1 PRO08A-D)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.Month 20XX CL 3-42 EP-AA-1003 (Revision XX) rlintnn Annoy Ivalntn Kh ,#-Idr Clintnn Ann~v Fv~Ir~n NI. ~RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU2 (cont)Basis (cont): This IC addresses a 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.A water level 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 rise 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 rise due to planned evolutions such as lifting of the reactor vessel head or movement of a fuel assembly.

Note that this EAL is applicable only in cases where the elevated reading is due to an UNPLANNED loss of water level.A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.Escalation of the emergency classification level would be via IC RA2.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 CIL 3-43 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS 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: Table R2 Areas Requiring Continuous Occupancy" Main Control Room (1RIX-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 Modes 4 and 5 Steam Tunnel**Areas required to establish shutdown cooling Month 20XX CL 3-44 EP-AA-1003 (Revision XX)

('1_infnn Annoy IPvalnn Kn~r-l,-r C~Iin*v~n Ann~v FvaIr~n M.mr~I~i~r RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA3 (cont)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.

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 equipment which require 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 service. 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 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 rise 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.Month 20XX CL 3-45 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RA3 (cont)Basis (cont): Escalation of the emergency classification level would be via Recognition Category R, 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 3-46 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS RU3 Initiating Condition:

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

1,2,3 Emergency Action Level (EAL): 1. Offgas post-treatment radiation monitor 1RIX-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 R ICs.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 -1RIX-PR035

6. CPS 5140.47, AR/PR Annunciator

-Off Gas Post-Treat PRM #2 -1 RIX-PR041 7. CPS 4004.02, Loss of Vacuum Month 20XX CL 3-47 EP-AA-1003 (Revision XX)

Clinton Annex Exallon 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 3-48 EP-AA-1003 (Revision XX)

Annoy khi -lanr CIin*nn Annav Fv~Ir~n Mm mr~Ii~ar 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 3-49 EP-AA-1003 (Revision XX) rlinftrn Annv=,vdmlrn Khir-Ignmr 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 3-50 EP-AA-1 003 (Revision XX)

('linfrnn Ann,-v I::v,-Inn Kiinil--or RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC1 Initiating Condition:

RCS Activity Operating Mode Applicability:

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

LOSS Coolant activity > 300 uCilgm Dose Equivalent 1-131.Basis: This threshold indicates that RCS radioactivity concentration is greater than 300 PCi/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 3-51 EP-AA-1003 (Revision XX)

Clinton Annex Exellon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC2 Initiating Condition:

RPV water level Operating Mode Applicability:

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

LOSS 1. Plant Conditions indicate Primary Containment flooding is required.POTENTIAL LOSS 2. RPV water level cannot be restored and maintained

> -162 inches (TAF)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 Threshold

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) EOP's/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 thought to be occurring.

Potential Loss Threshold

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 Barrier RC2 Loss threshold.

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

This threshold is considered to be exceeded when, as specified in the site-specific EOPs, RPV water 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 Month 20XX CL 3-52 EP-AA-1003 (Revision XX)

('linfrn I::,a', I n Nim-ld-ar C~Iin*,~n Ann0w ~v~Ir~n Mi iI~~r RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC2 (cont)Basis (cont): 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 in order to reduce reactor power. 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 MA3 or 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/1005.09M002

7. Clinton Power Station Emergency Operating Procedures Technical Bases 8. 4000.01, Abnormal RPV water level Month 20XX CL 3-53 EP-AA-1003 (Revision XX)

Clintnn Annex Fyialnn Ni-linar Clinton Annex EAwn.JtIAwr RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC5 Initiating Condition:

Primary Containment Radiation Operating Mode Applicability:

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

LOSS 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: 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 pCi/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 Thresholds 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 3-54 EP-AA-1 003 (Revision XX)

Clintnn Annpx Clinton Annex Pyninn N,,uIanr RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC7 Initiating Condition:

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.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 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 3-55 EP-AA-1003 (Revision XX)

.linfen Annay I=vgmltn hhtllrl~r (~Untnn Ann~v Fvalnn Muu~-Ic~r 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

> -162 inches (TAF)OR 2. 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.This water level corresponds to the Top of Active Fuel (TAF) and is used in the EOPs to indicate challenge to core cooling.The RPV water level threshold is the same as Fuel Clad Barrier FC2 Potential Loss threshold.

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

This threshold is considered to be exceeded when, as specified in the site-specific EOPs, RPV water 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.

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 Month 20XX CL 3-56 EP-AA-1 003 (Revision XX) rlintnn Annoy IPvalnn

(~Iintnn Ann~v Fv~Inn MIIrI~2r RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC2 (cont)Basis (cont): 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 in order to reduce reactor power. 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 MA3 or 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 CIL 3-57 EP-AA-1003 (Revision XX)

Clinton Annex Exallon Nuclaar RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC3 Initiating Condition:

Primary Containment Conditions Operating Mode Applicability:

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

LOSS 1. Drywell pressure >1.68 psig.AND 2. Drywell pressure rise is due to RCS leakage Basis: The > 1.68 psig pressure is the Drywell high pressure setpoint which indicates a LOCA by automatically initiating ECCS.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 7. 4001.01, Reactor Coolant Leakage Month 20XX CIL 3-58 EP-AA-1003 (Revision XX)

I:xelnn Clinton Annex FwieInn Nucler~I RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC4 Initiating Condition:

RCS Leak Rate Operating Mode Applicability:

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

LOSS 1. UNISOLABLE Main Steam Line (MSL), Feedwater, RWCU, or RCIC line break.OR 2. Emergency RPV Depressurization is required.POTENTIAL LOSS 3. UNISOLABLE primary system leakage that results in EITHER of the following:

a. Secondary Containment area temperature

> EOP-8 Maximum Normal operating levels.OR b. Secondary Containment area radiation level > EOP-8 Maximum Normal operating 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 describing magnitude of steam or water release.* Use of system high 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 significant than the indications that would be expected from system leakage and therefore should be considered a system break.Loss Threshold

1. 1 Basis 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, the RCS barrier Loss threshold is met.Month 20XX CL 3-59 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC4 (cont)Basis (cont): Loss Threshold

1. 2 Basis 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 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, 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 conjunction 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 CT6 Loss Threshold#1 (after a containment isolation) and a General Emergency when the Fuel Clad Barrier criteria is also exceeded.Month 20XX CL 3-60 EP-AA-1003 (Revision XX)

Mlinftnn Annoy IPYalrmn Niii-Ihaar

(~Iintr~n Ann~v Fv~Inn Mi ir~Ia~r RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC4 (cont)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 01PS274 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 CIL 3-61 EP-AA-1003 (Revision XX)

Annoy I~volrnn NMelarlr ('Iin4r~n Ann~v Fvalnn Mu .rI~2r RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC5 Initiating Condition:

Primary Containment radiation Operating Mode Applicability:

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

LOSS 1. Drywell radiation monitor reading > 10OR/hr (>1.00 E+02 R/hr).OR 2. Containment radiation monitor reading > 33 R/hr (>3.3 E+01 R/hr).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 Thresholds since it indicates a loss of the RCS Barrier only.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 3-62 EP-AA-1003 (Revision XX)

I'.lintnn Annoy P:Y,l,n1n MR id-hIar rImntr~n Ann~v ~v~Ij~n Mi .r~Ia~r RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC7 Initiating Condition:

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 RCS Barrier.POTENTIAL LOSS 2. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS 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 RCS Barrier is lost.Potential Loss Threshold

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 3-63 EP-AA-1003 (Revision XX) rlintnn Annoy I=Yalnn N,,Al2r Clintnn Ann~v Fv~Inn M..e-Ia~ar 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 Plant conditions indicate Primary Containment flooding is required.Basis: The Potential Loss threshold is identical to the Fuel Clad Barrier FC2 Loss threshold RPV water level. 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 3-64 EP-AA-1003 (Revision XX)

Clinton Annex Explan Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT3 Initiating Condition:

Primary Containment Conditions Operating Mode Applicability:

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

LOSS 1. UNPLANNED rapid drop in primary containment pressure following primary containment pressure rise.OR 2. Primary containment pressure response not consistent with LOCA conditions.

POTENTIAL LOSS 3. Primary Containment pressure > 15 psig and rising.OR 4. a. Drywell hydrogen concentration

> 9%.OR b. Containment Hydrogen concentration

> SAG-2, Deflagration Limit.OR 5. Heat Capacity Temperature Limit (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 Threshold

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

Primary containment pressure should rise 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 3-65 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT3 (cont)Basis (cont): Potential Loss Threshold

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 Threshold

1. 4 Basis If hydrogen concentration reaches or exceeds the 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 Threshold

1. 5 Basis 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 3-66 EP-AA-1003 (Revision XX) rlinfnn Annoy I=vglrn kl"i-ldnnr RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT5 Initiating Condition:

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)Basis: There is no Loss threshold associated with Primary Containment Radiation.

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

NUREG-1228, Source Estimations During Incident Response to Severe Nuclear Power Plant Accidents, indicates the fuel clad failure must be greater than approximately 20%in order for there to be a major release of radioactivity requiring offsite protective actions. For this condition to exist there must already have been a loss of the RCS Barrier and the Fuel Clad Barrier. It is therefore prudent to treat this condition as a potential loss of containment which would then escalate the emergency classification level to a General Emergency.

Basis Reference(s):

1. NEI 99-01 Rev 6, Table 9-F-2 2. Core Damage Assessment Methodology Month 20XX CIL 3-67 EP-AA-1 003 (Revision XX)

Exelan Nuclear Clinton Annex Eeo ula RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT6 Initiating Condition:

Primary Containment Isolation Failure Operating Mode Applicability:

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

LOSS 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.

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

a. Secondary Containment area temperature

> EOP-8, Maximum Safe operating levels.OR b. Secondary Containment area radiation level > EOP-8, Maximum Safe operating 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 Threshold

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 pathway to the environment" could be through the Turbine/Condenser, or direct release to the Turbine or Reactor Building.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.Month 20XX CL 3-68 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT6 (cont)Basis (cont): Following the leakage of RCS mass into primary containment and a rise in primary containment pressure, there may be minor radiological releases associated with allowable primary containment leakage through various penetrations or system components.

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

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 Drywell high pressure scram setpoint) does not meet the threshold condition.

Loss Threshold

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 conjunction 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.Month 20XX CL 3-69 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear Clinton Annex Exelon Nuclear RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT6 (cont)Basis (cont): In combination with RCS Barrier RC4 Potential Loss Threshold

1. 3 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 3-70 EP-AA-1003 (Revision XX) rlintnn Annoy IFwalnn kle-lanr C~Iintnn Ann0w Fv~Inn NiirIa~r RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT7 Initiating Condition:

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 Containment Barrier.POTENTIAL LOSS 2. Any condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment 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 Containment Barrier is lost.Potential Loss Threshold

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 3-71 EP-AA-1003 (Revision XX)

ClIinton Annex ExaInn Nucler~I RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG1 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 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 1 B1.AND 2. Failure of DG 1A and DG 1B emergency diesel generators to supply power to vital busses WA1 and 1B1.AND 3. EITHER of the following:

a. Restoration of at least one vital bus (excluding Division Ill) in < 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is not likely.OR b. RPV water level cannot be restored and maintained

> -187 inches.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.

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 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 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 FG1. This will allow additional time for implementation of offsite protective actions.Month 20XX CL 3-72 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG1 (cont)Basis (cont): 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 3-73 EP-AA-1 003 (Revision XX) rlinfnn Pvainn Niielanr RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS1 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 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 1 Al and 11B1.AND 2. Failure of DG 1A and DG 1B emergency diesel generators to supply power to vital busses 1A1 and 1B1.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 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 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 RG1, FG1, MG1, or MG2.Month 20XX CL 3-74 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear Clint.n.Anne..Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS1 (cont)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 3-75 EP-AA-1003 (Revision XX) rlintnn Annov F:vY--Inn K'Irle-Igr RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA1 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 (1Al, 1 B1) 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.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 SYSTEMS. In 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 MUI.An "AC power source" is a source recognized in Off Normal Procedures and EOPs, and capable of supplying required power to an emergency bus (excluding Division Ill).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 II onsite diesel generator).

Month 20XX CL 3-76 EP-AA-1 003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MAI (cont)Basis (cont):* A loss of emergency power sources (e.g., onsite diesel generators) with a single Division I and II train of emergency buses being 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 MS1.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 3-77 EP-AA-1003 (Revision XX)

Clinton Annexr Clinton Annex FvAInn Nnnioni~r RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU1 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 1 Al and 11B1 for > 15 minutes.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 Ill), 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 MA1.Basis Reference(s):

1. NEI 99-01 Rev 6, SU1 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 3-78 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS 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 11B1.AND 2. Failure of DG 1A and DG 1B emergency diesel generators to supply power to vital busses WA1 and 1B1.AND 3. Voltage is < 108 VDC on unit 125 VDC battery busses 1A and lB.AND 4. ALL AC and Vital DC power sources have been lost for > 15 minutes.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 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 EAL conditions are met.Month 20XX CL 3-79 EP-AA-1 003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MG2 (cont)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 3-80 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS2 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 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.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 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 RG1, FG1 or MG2.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 3-81 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS 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.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 injection are unsuccessful, and continued power generation is challenging the capability to adequately remove heat from the core and/or the RCS. This condition will lead to fuel damage if additional mitigation actions are unsuccessful and thus warrants the declaration of a Site Area Emergency.

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

This is appropriate in that the Recognition Category F ICs/EALs do not address the additional threat posed by a failure to shutdown the reactor. The inclusion of this IC and EAL ensures the timely declaration of a Site Area Emergency in response to prolonged failure to shutdown the reactor.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 RG1 or FG1.Month 20XX CIL 3-82 EP-AA-1003 (Revision XX)

Clintnn Clinton Annex FvAvnn Nu.clearv RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MS3 (cont)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 3-83 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA3 Initiating Condition:

Automatic or manual scram fails to shutdown the reactor, and subsequent manual actions taken at the reactor control console 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 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 console 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 console since this event entails a significant failure of the RPS.A manual action at the reactor control console 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 console (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 console".Taking the Reactor Mode Switch to Shutdown is considered to be a manual scram action.Month 20XX CL 3-84 EP-AA-1003 (Revision XX)

Clinton Annex I=xelon Nuclear Clinon AnexExelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA3 Basis (cont): The plant response to the failure of an automatic or manual reactor scram will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If the failure to shutdown the reactor is prolonged enough to cause a challenge to the RPV water level or RCS heat removal safety functions, the emergency classification level will escalate to a Site Area Emergency via IC MS3. Depending upon plant responses and symptoms, escalation is also possible via IC FS1. Absent the plant conditions needed to meet either IC MS3 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 1Cs; however, this IC and EAL are included to ensure a timely emergency declaration.

A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.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 3-85 EP-AA-1003 (Revision XX)

Clintnn Annex I::xelnn Clinton Annex ExeIon NuclerIsr RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU3 Initiating Condition:

Automatic or manual scram fails to shutdown 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. a. Automatic scram did not shutdown the reactor as indicated by Reactor Power > 5%.AND b. Subsequent manual / ARI action taken at the Reactor Control 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 Control Console is successful in shutting down the reactor.OR 2. Subsequent 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 console 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.Month 20XX CL 3-86 EP-AA-1 003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU3 (cont)Basis (cont): EAL #1 Basis Following the failure on an automatic reactor scram, operators will promptly initiate manual actions at the reactor control console to shutdown the reactor (e.g., initiate a manual reactor scram). If these manual actions are 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.EAL

1. 2 Basis If an initial manual reactor trip is unsuccessful, operators will promptly take manual action at another location(s) on the reactor control console 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 I 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 console 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 console".Taking the Reactor Mode Switch to Shutdown is considered to be a manual scram action.The plant response to the failure of an automatic or manual reactor scram will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If subsequent operator manual actions taken at the reactor control console are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC MA3. Depending upon the plant response, escalation is also possible via IC FAI. Absent the plant conditions needed to meet either IC MA3 or FA1, an Unusual Event declaration is appropriate for this event.A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.Month 20XX CL 3-87 EP-AA-1003 (Revision XX) t'linfenn Annmv=~vglr~n ilr CIin*r~n A nn~v ~vnir~n Mm mr~I~~r RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU3 (cont)Basis (cont): 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 signal 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.

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 3-88 EP-AA-1003 (Revision XX)

Clinton Annex Fwalan Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS 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.Table M1 Control Room Parameters 0 Reactor Power 0 RPV water level 0 RPV Pressure 0 Primary Containment Pressure 0 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 Month 20XX CL 3-89 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA4 (cont)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 water level and RCS heat removal. The loss of the ability to determine one or more of these parameters from within the Control Room is considered to be more significant than simply a reportable condition.

In addition, if all indication sources for one or more of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well. For example, if the value for RPV water level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well.Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.

Escalation of the emergency classification level would be via ICs FS1 or IC RSI.Basis Reference(s):

1. NEI 99-01 Rev 6, SA2 Month 20XX CL 3-90 EP-AA-1 003 (Revision XX)

IFvlnn MhirlI~nr Clinton Annex I=Yalnn Nia-lonr RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU4 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 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.Month 20XX CL 3-91 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU4 (cont)Basis (cont): 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, 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 MA4.Basis Reference(s):

1. NEI 99-01 Rev 6, SU2 Month 20XX CL 3-92 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA5 Initiating Condition:

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.Basis: FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.EXPLOSION:

A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization.

A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion.

Such events may require a post-event inspection to determine if the attributes of an explosion are present.Month 20XX CL 3-93 EP-AA-1 003 (Revision XX)

ClIinton Annex Fvalnn Miirlan~r RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MA5 (cont)Basis (cont): SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

VISIBLE DAMAGE: Damage to a component or structure that is readily observable without measurements, testing, or analysis.

The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected component or structure.

This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or a structure containing SAFETY SYSTEM components, required for the current operating mode, "required", i.e. required to be operable by Technical Specifications for the current operating mode. This condition significantly reduces the margin to a loss or potential loss of a fission product barrier, and therefore represents an actual or potential substantial degradation of the level of safety of the plant. Manual or automatic electrical isolation of safety equipment due to flooding, in and of itself, does not constitute degraded performance and is classified under HU6.EAL #2.a Basis This EAL addresses damage to a SAFETY SYSTEM train that is required to be operable by Technical Specifications for the current operating mode, and is in operation since indications for it will be readily available.

The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.E#2.b Basis This EAL addresses damage to a SAFETY SYSTEM component that is required to be operable by Technical Specifications for the current operating mode, and is not in operation or readily apparent through indications alone, as well as damage to a structure containing SAFETY SYSTEM components.

Operators will make this determination based on the totality of available event and damage report information.

This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level would be via IC FS1 or RS1.If the EAL conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.Basis Reference(s):

1. NEI 99-01, Rev 6 SA9 Month 20XX CL 3-94 EP-AA-1003 (Revision XX)

Clintnn ClIinton Annex Fvnlnn Nucler~I.RECOGNITION CATEGORY SYSTEM MALFUNCTIONS 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 >25 gpm for > 15 minutes.Basis: UNISOLABLE:

An open or breached system line that cannot be isolated, remotely or locally.This IC addresses RCS leakage which may be a precursor to a more significant event.In this case, RCS leakage has been detected and operators, following applicable procedures, have been unable to promptly isolate the leak. This condition is considered to be a potential degradation of the level of safety of the plant.EAL #1 and EAL #2 Basis These EALs are focused on a loss of mass from the RCS due to "unidentified leakage","pressure boundary leakage" or "identified leakage" (as these leakage types are defined in the plant Technical Specifications).

EAL #3 Basis This EAL addresses a RCS mass loss caused by an UNISOLABLE leak through an interfacing system.These EALs thus apply to leakage into the containment, a secondary-side system or a location outside of containment.

The leak rate values for each EAL were selected because they are usually observable with normal Control Room indications.

Lesser values typically require time-consuming calculations to determine (e.g., a mass balance calculation).

EAL #1 uses a lower value that reflects the greater significance of unidentified or pressure boundary leakage.Month 20XX CL 3-95 EP-AA-1003 (Revision XX)

IFvalnn N, rlintnn Annex RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU6 (cont)Basis (cont): 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.The 15-minute threshold duration allows sufficient time for prompt operator actions to isolate the leakage, if possible.Escalation of the emergency classification level would be via ICs of Recognition Category R or F.Basis Reference(s):

1. NEI 99-01 Rev 6, SU4 2. USAR 5.2.5.1 3. CPS 9043.06, Drywell Floor Drain Sump Flow Test 00PS404 4. CPS 9443.01, Drywell Equipment Drain Sump Flow E31-N578 Channel Cal 01 PS274 5. CPS 4401.01, EOP-1 RPV Control 6. CPS 4001.01, Reactor Coolant Leakage 7. Clinton Power Station Emergency Operating Procedures Technical Bases, Section 12 8. ITS 3.4.5 Month 20XX CL 3-96 EP-AA-1003 (Revision XX)

('-Inft~n A nnav I=Y-rlnn, nM-Id-,gr RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU7 Initiating Condition:

Loss of all On-site or Off-site communications 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.

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 microwave)

X X X ENS X X HPN X X Satellite Phones X X Basis: This IC addresses a significant loss of on-site, offsite, or NRC communications capabilities.

While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).Month 20XX CL 3-97 EP-AA-1003 (Revision XX)

Clinton Annex Clinto AnnexExelon Nuc~lear RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MU7 (cont)Basis (cont): EAL #1 Basis Addresses a total loss of the communications methods used in support of routine plant operations.

EAL #2 Basis Addresses a total loss of the communications methods used to notify all OROs of an emergency declaration.

The OROs referred to here are listed in procedure EP-MW-114-100-F-01, Nuclear Accident Reporting System (NARS) Form.EAL #3 Basis Addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.

Basis Reference(s):

1. NEI 99-01 Rev 6, SU6 2. EP-MW-1 24-1001, Facilities Inventories and Equipment Tests 3. UFSAR Section 9.5.2 Month 20XX CL 3-98 EP-AA-1003 (Revision XX)

I:xelon Clinton Annex .xel.n Nucr.lear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CAI Initiating Condition:

Loss of all offsite and all 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 1Al and 1B1.AND 2. Failure of DG 1A and DG 1B emergency diesel generators to supply power to vital busses 1A1 and 1B1.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.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 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.When in the cold shutdown or refueling or mode, this condition is not classified as a Site Area Emergency because of the increased time available to restore an emergency bus to service. Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition represents an actual or potential substantial degradation of the level of safety of the plant.Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.Escalation of the emergency classification level would be via IC CS6 or RS1.Month 20XX CL 3-99 EP-AA-1 003 (Revision XX)

Clinton Annex Exelon Nuclear Clinon AnexExelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA1 (cont)Basis Reference(s):

1. NEI 99-01 Rev 6, CA2 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, Unit1 Docket No. 50-461 Month 20XX CL 3-100 EP-AA-1003 (Revision XX)

Clinton AnnaX FwaYinn NMidlpl r RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS cul Initiating Condition:

Loss of all but one AC power source to emergency buses 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. AC power capability to vital busses (1Al, 11B1) 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.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 SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment.

When in the cold shutdown or refueling mode, this condition is not classified as an Alert because of the increased time available to restore another power source to service.Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition is considered to be a potential degradation of the level of safety of the plant.An "AC power source" is a source recognized in Off Normal Procedures and EOPs, and capable of supplying required power to an emergency bus (excluding Division Ill).Some examples of this condition are presented below.Month 20XX CL 3-101 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear Clinon AnexExelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CUI (cont)Initiating Condition:

• A loss of all offsite power with a concurrent failure of all but one emergency power source (e.g., Division I and II onsite diesel generator)." A loss of emergency power sources (e.g., onsite diesel generators) with a single train of Division I and II emergency buses being fed from an offsite power source.Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.The subsequent loss of the remaining single power source would escalate the event to an Alert in accordance with IC CA1.Basis Reference(s):

1. NEI 99-01 Rev 6 CU2 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 3-102 EP-AA-1003 (Revision XX) infrnn Annmv Ir--Ir~n K, ,o-I--mr r~Iintr~n Annn~i, ~.u. .t~r* n... .~n ~ ~~** ..-~RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS 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.Basis: FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.EXPLOSION:

A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization.

A release of steam (from high energy lines or components) or an electrical component failure (caused by short circuits, grounding, arcing, etc.) should not automatically be considered an explosion.

Such events may require a post-event inspection to determine if the attributes of an explosion are present.Month 20XX CIL 3-103 EP-AA-1003 (Revision XX)

Clinton Annex Exelnn N....clear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA2 (cont)Basis (cont): SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

VISIBLE DAMAGE: Damage to a component or structure that is readily observable without measurements, testing, or analysis.

The visual impact of the damage is sufficient to cause concern regarding the operability or reliability of the affected component or structure.

This IC addresses a hazardous event that causes damage to a SAFETY SYSTEM, or a structure containing SAFETY SYSTEM components, required for the current operating mode, "required", i.e. required to be operable by Technical Specifications for the current operating mode. This condition significantly reduces the margin to a loss or potential loss of a fission product barrier, and therefore represents an actual or potential substantial degradation of the level of safety of the plant. Manual or automatic electrical isolation of safety equipment due to flooding, in and of itself, does not constitute degraded performance and is classified under HU6.EAL #2.a Basis Addresses damage to a SAFETY SYSTEM train that is required to be operable by Technical Specifications for the current operating mode, and is in operation since indications for it will be readily available.

The indications of degraded performance should be significant enough to cause concern regarding the operability or reliability of the SAFETY SYSTEM train.EAL #2.b Basis Addresses damage to a SAFETY SYSTEM component that is required to be operable by Technical Specifications for the current operating mode, and is not in operation or readily apparent through indications alone, or to a structure containing SAFETY SYSTEM components.

Operators will make this determination based on the totality of available event and damage report information.

This is intended to be a brief assessment not requiring lengthy analysis or quantification of the damage.Escalation of the emergency classification level would be via IC CS6 or RS1.If the EAL conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.Basis Reference(s):

1. NEI 99-01 Rev 6, CA6 Month 20XX CL 3-104 EP-AA-1003 (Revision XX)

Clinton Annex Exalan Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS 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 IA and 1B for> 15 minutes.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 addresses a loss of Vital DC power which compromises the ability to monitor and control operable SAFETY SYSTEMS when the plant is in the cold shutdown or refueling mode. In these modes, the core decay heat load has been significantly reduced, and coolant system temperatures and pressures are lower; these conditions rise the time available to restore a vital DC bus to service. Thus, this condition is considered to be a potential degradation of the level of safety of the plant.As used in this EAL, "required" means the Vital DC buses necessary to support operation of the in-service, or operable, train or trains of SAFETY SYSTEM equipment.

For example, if Train A is out-of-service (inoperable) for scheduled outage maintenance work and Train B is in-service (operable), then a loss of Vital DC power affecting Train B would require the declaration of an Unusual Event. A loss of Vital DC power to Train A would not warrant an emergency classification.

Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.Depending upon the event, escalation of the emergency classification level would be via IC CA6 or CA5, or an IC in Recognition Category R.Month 20XX CL 3-105 EP-AA-1003 (Revision XX)

Clinton Annexr Clinton Annex .x.l..n Nucleair RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU3 (cont)Basis Reference(s):

1. NEI 99-01 Rev 6, CU4 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 3-106 EP-AA-1003 (Revision XX)

I'_linfenn Annmv IPy--Inn NM ,hlnr (lintrhn A nnav ~v~Ir~n NI u RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU4 Initiating Condition:

Loss of all onsite or offsite communications 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 Cl NRC communication capability affecting the ability to perform NRC notifications.

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 microwave)

X X X ENS X X HPN X X Satellite Phones X X Basis: This IC addresses a significant loss of on-site, offsite, or NRC communications capabilities.

While not a direct challenge to plant or personnel safety, this event warrants prompt notifications to Offsite Response Organizations (OROs) and the NRC.This IC should be assessed only when extraordinary means are being utilized to make communications possible (e.g., use of non-plant, privately owned equipment, relaying of on-site information via individuals or multiple radio transmission points, individuals being sent to offsite locations, etc.).EAL #1 Basis Addresses a total loss of the communications methods used in support of routine plant operations.

Month 20XX CL 3-107 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CU4 (cont)Basis (cont): EAL #2 Basis Addresses a total loss of the communications methods used to notify all OROs of an emergency declaration.

The OROs referred to here are listed in procedure EP-MW-114-100-F-01, Nuclear Accident Reporting System (NARS) Form.EAL #3 Basis Addresses a total loss of the communications methods used to notify the NRC of an emergency declaration.

Basis Reference(s):

1. NEI 99-01 Rev 6, CU5 2. EP-MW-1 24-1001, Facilities Inventories and Equipment Tests 3. UFSAR Section 9.5.2 Month 20XX CL 3-108 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA5 Initiating Condition:

Inability to maintain the plant in cold shutdown.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. UNPLANNED rise in RCS temperature

> 200OF due to loss of decay heat removal for > Table C2 duration.Table C2 RCS Heat-up Duration Thresholds RCS Containment Closure Heat-up Status Status Duration Intact Not Applicable 60 minutes*Not Intact Established 20 minutes*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 applicable.

OR 2. UNPLANNED RPV pressure rise > 10 psig as a result of temperature rise due to loss of decay heat removal.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.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment (primary or secondary) and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

RCS is intact when the RCS pressure boundary is in its normal condition for the Cold Shutdown mode of operation (e.g. no freeze seals, or steam line nozzle plugs, etc.).Month 20XX CL 3-109 EP-AA-1 003 (Revision XX)

Annex Nllrlenr rlintnn Annex FvAllnn Nuclea~r RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA5 (cont)Basis (cont): This IC addresses conditions involving a loss of decay heat removal capability or an addition of heat to the RCS in excess of that which can currently be removed. Either condition represents an actual or potential substantial degradation of the level of safety of the plant.A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.

The RCS Heat-up Duration Thresholds table addresses a rise in RCS temperature when CONTAINMENT CLOSURE is established but the RCS is not intact. The 20-minute criterion was included to allow time for operator action to address the temperature rise.The RCS Heat-up Duration Thresholds table also addresses a rise in RCS temperature with the RCS intact. The status of CONTAINMENT CLOSURE is not crucial in this condition since the intact RCS is providing a high pressure barrier to a fission product release. The 60-minute time frame should allow sufficient time to address the temperature rise without a substantial degradation in plant safety.Finally, in the case where there is a rise in RCS temperature, the RCS is not intact, and CONTAINMENT CLOSURE is not established, no heat-up duration is allowed (i.e., 0 minutes).

This is because 1) the evaporated reactor coolant may be released directly into the Containment atmosphere and subsequently to the environment, and 2) there is reduced reactor coolant inventory above the top of irradiated fuel.EAL #2 Basis Provides a pressure-based indication of RCS heat-up.Escalation of the emergency classification level would be via IC CS6 or RS1.Month 20XX CL 3-110 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA5 (cont)Basis Reference(s):

1. NEI 99-01 Rev 6, CA3 2. Technical Specifications 3.6.1.1 3. Technical Specifications 3.6.4.1 4. OU-AA-103, Shutdown Safety Management Program 5. CPS 3002.01, Heatup and Pressurization

6. CPS 3002.01C003, MODE 3 Checklist 7. CPS 4006.01, Loss of Shutdown Cooling 8. CPS 9000.06, Reactor Coolant and Vessel Metal/Pressure/Temperature Limit Logs 9. CPS 9433.13, ECCS Reactor Steam Dome Pressure B21-N097A(B)

Channel 6 Calibration Month 20XX CL 3-111 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU5 Initiating Condition:

UNPLANNED rise in RCS temperature 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. UNPLANNED rise in RCS temperature

> 200OF due to loss of decay heat removal.OR 2. Loss of the following for >_15 minutes.* ALL RCS temperature indications AND* ALL RPV water level indications 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.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment (primary or secondary) and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

This IC addresses an UNPLANNED rise in RCS temperature above the Technical Specification cold shutdown temperature limit, or the inability to determine RCS temperature and level, represents a potential degradation of the level of safety of the plant. If the RCS is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency Director should also refer to IC CA5.RCS is intact when the RCS pressure boundary is in its normal condition for the Cold Shutdown mode of operation (e.g. no freeze seals, or steam line nozzle plugs, etc.).A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.

Month 20XX CL 3-112 EP-AA-1003 (Revision XX)

Clintnn Annex Fyplnn Clinton AnnexE~n NuI~RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU5 (cont)Basis (cont): EAL #1 involves a loss of decay heat removal capability, or an addition of heat to the RCS in excess of that which can currently be removed, such that reactor coolant temperature cannot be maintained below the cold shutdown temperature limit specified in Technical Specifications.

During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.

During an outage, the level in the reactor vessel will normally be maintained above the reactor vessel flange. Refueling evolutions that lower water level below the reactor vessel flange are carefully planned and controlled.

A loss of forced decay heat removal at reduced inventory may result in a rapid rise in reactor coolant temperature depending on the time after shutdown.EAL #2 reflects a condition where there has been a significant loss of instrumentation capability necessary to monitor RCS conditions and operators would be unable to monitor key parameters necessary to assure core decay heat removal. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation.

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

Escalation to Alert would be via IC CA6 based on an inventory loss or IC CA5 based on exceeding plant configuration-specific time criteria.Basis Reference(s):

1. NEI 99-01 Rev 6, CU3 2. Technical Specifications Table 1.1-1 3. CPS 4401.01, EOP-1 RPV Control 4. Clinton Power Station Emergency Operating Procedures Technical Bases, Section 12 5. CPS 4411.07, RPV Level Instrumentation

6. MA-CL-716-102, Reactor Disassembly

7. CPS 3002.01, Heatup and Pressurization

8. CPS 9000.06, Reactor Coolant and Vessel Metal/Pressure/Temperature Limit Logs Month 20XX CL 3-113 EP-AA-1003 (Revision XX)

Clinton AnnexNinP.Ipnr Clinton Annex FvAlnn N"1irI.qr RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS 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 (TAF) 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 indications OR" Containment High Range Monitors 1RIX-CM061 or 1RIX-CM062

>3 R/hr.AND c. ANY Containment Challenge Indication (Table C4)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.

Month 20XX CL 3-114 EP-AA-1 003 (Revision XX)

Clinton Annex

• Clinton Annex Expinn Nucler I-RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CG6 (cont)Emergency Action Level (EAL) (cont): 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* 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.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.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.CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment (primary or secondary) and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

This IC addresses the inability to restore and maintain reactor vessel level above the top of active fuel with containment challenged.

This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity.

Releases can be reasonably expected to exceed EPA Protective Action Guidelines (PAG) exposure levels offsite for more than the immediate site area.Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.With CONTAINMENT CLOSURE not established, there is a high potential for a direct and unmonitored release of radioactivity to the environment.

If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.Month 20XX CIL 3-115 EP-AA-1003 (Revision XX)

Clintnn Clinton Annex Fxellnn NuclerI~m RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CG6 (cont)Basis (cont): The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity.

It therefore represents a challenge to Containment integrity.

In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a core uncovery could result in an explosive gas mixture in containment.

If all installed hydrogen gas monitors are out-of-service during an event leading to fuel cladding damage, it may not be possible to obtain a containment hydrogen gas concentration reading as ambient conditions within the containment will preclude personnel access.During periods when installed containment hydrogen gas monitors are out-of-service, operators may use the other listed indications to assess whether or not containment is challenged.

In EAL #2 the 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties).

It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.

The inability to monitor RPV water level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation.

If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RPV.These EALs address concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Month 20XX CL 3-116 EP-AA-1003 (Revision XX)

AnneY ClIinton Annexw Fvpnn Naucla?-qr RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CG6 (cont)Basis Reference(s):

1. NEI 99-01 Rev 6, CG1 2. CPS 4401.01, EOP-1 RPV Control 3. CPS 4402.01, EOP-6 Primary Containment Control 4. Clinton Power Station Emergency Operating Procedures Technical Bases, Sections 9, 10 and 12 5. CPS 4406.01, EOP-8 Secondary Containment Control 6. USAR Figure 6.2-132 7. USAR Table 1.3-4 8. Technical Specifications 3.6.1.1 9. Technical Specifications 3.6.4.1 10. OU-AA-103, Shutdown Safety Management Program 11. Clinton Power Station Emergency Operating Procedures Technical Bases 12. CPS 4411.07, RPV Level Instrumentation

13. CPS 3306.01, Source/Intermediate Range Monitors (SRM/IRM)Month 20XX CL 3-117 EP-AA-1003 (Revision XX)

Nuclear Clinton Annex EVelon Nuc lea.r RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CS6 Initiating Condition:

Loss of RPV inventory affecting core decay heat removal capability.

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 leve I< -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 indications OR" Containment High Range Monitors 1RIX-CM061 or 1RIX-CM062

>3 R/hr.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.

Month 20XX CL 3-118 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear Clinon AnexExelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CS6 (cont)Basis: CONTAINMENT CLOSURE: The procedurally defined conditions or actions taken to secure containment (primary or secondary) and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

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.The lost inventory may be due to a RCS component failure, a loss of configuration control or prolonged boiling of reactor coolant. These conditions entail major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration.

Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If RCS/reactor vessel level cannot be restored, fuel damage is probable.Outage/shutdown contingency plans typically provide for re-establishing or verifying CONTAINMENT CLOSURE following a loss of heat removal or RCS inventory control functions.

The difference in the specified RCS/reactor vessel levels of EALs #1 and #2 reflect the fact that with CONTAINMENT CLOSURE established, there is a lower probability of a fission product release to the environment.

In EAL #3 the 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties).

It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring.

The inability to monitor RPV water level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation.

If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RPV.These EALs address concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal; SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management.

Escalation of the emergency classification level would be via IC CG6 or RGI.Month 20XX CL 3-119 EP-AA-1003 (Revision XX)

Clinton Annex IFvplnn Nnnilpar Clinton Annex F..lon wIrwIAl RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CS6 (cont)Basis Reference(s):

1. NEI 99-01 Rev 6, CS1 2. Technical Specifications Table 3.3.5.1-1 3. ORM Attachment 2-7, Table 5 4. CPS 4401.01, EOP-1 RPV Control 5. Clinton Power Station Emergency Operating Procedures Technical Bases, Section 12 6. CPS 4411.07, RPV Level Instrumentation

7. USAR 5.2.5.1 8. CPS 9043.06, Drywell Floor Drain Sump Flow Test 00PS404 9. CPS 9443.01, Drywell Equipment Drain Sump Flow E31-N578 Channel Cal 01PS274 10. CPS 3306.01, Source/Intermediate Range Monitors (SRM/IRM)11. Technical Specifications 3.6.1.1 12. Technical Specifications 3.6.4.1 13. OU-AA-103, Shutdown Safety Management Program 14. CPS 3002.01, Heatup and Pressurization

15. CPS 5062.01, ALARM PANEL 5062 ANNUNCIATORS

-ROW 1 Month 20XX CL 3-120 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS 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.

Basis: UNPLANNED:

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

The cause of the parameter change or event may be known or unknown.This IC addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier).

This condition represents a potential substantial reduction in the level of plant safety.EAL #1 Basis A lowering of water level below -45.5 inches indicates that operator actions have not been successful in restoring and maintaining RPV water level. The heat-up rate of the coolant will rise as the available water inventory is reduced. A continuing loss in water level will lead to core uncovery.Month 20XX CL 3-121 EP-AA-1003 (Revision XX)

Clintnn Annex l:xeInn Clinton Annex Exelon Numr~clar RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CA6 (cont)Basis (cont): Although related, EAL #1 is concerned with the loss of RCS inventory and not the potential concurrent effects on systems needed for decay heat removal (e.g., loss of a Residual Heat Removal suction point). An rise in RCS temperature caused by a loss of decay heat removal capability is evaluated under IC CA5.EAL #2 Basis The inability to monitor RPV water level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation.

If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RPV.The 15-minute duration for the loss of level indication was chosen because it is half of the EAL duration specified in IC CS6 If the RPV water level continues to lower, then escalation to Site Area Emergency would be via IC CS6.Basis Reference(s):

1. NEI 99-01 Rev 6, CA1 2. Technical Specifications Table 3.3.5.1-1 3. ORM Attachment 2-7, Table 5 4. CPS 4401.01, EOP-1 RPV Control 5. CPS Emergency Operating Procedures Technical Bases, Section 12 6. CPS 4411.07, RPV Level Instrumentation

7. USAR 5.2.5.1 8. CPS 9043.06, Drywell Floor Drain Sump Flow Test 00PS404 9. CPS 9443.01, Drywell Equipment Drain Sump Flow E31-N578 Channel Cal 10. CPS 5065.06, ALARM PANEL 5065 ANNUNCIATORS

-ROW 6 Month 20XX CL 3-122 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU6 Initiating Condition:

UNPLANNED loss of RPV inventory 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. UNPLANNED loss of reactor coolant results in the inability to restore and maintain 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.

Month 20XX CL 3-123 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY COLD SHUTDOWN I REFUELING SYSTEM MALFUNCTIONS CU6 (cont)Basis: UNPLANNED:

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

The cause of the parameter change or event may be known or unknown.This IC addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor RPV water level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant.The procedurally established lower limit is not an operational band established above the procedural limit to allow for operator action prior to exceeding the procedural limit, but it is the procedurally established lower limit.Refueling evolutions that decrease RCS water inventory are carefully planned and controlled.

An UNPLANNED event that results in water level decreasing below a procedurally required limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered.EAL #1 recognizes that the minimum required RPV water level can change several times during the course of a refueling outage as different plant configurations and system lineups are implemented.

This EAL is met if the minimum level, specified for the current plant conditions, cannot be maintained for 15 minutes or longer. The minimum level is typically specified in the applicable operating procedure but may be specified in another controlling document.The 15-minute threshold duration allows sufficient time for prompt operator actions to restore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level.EAL #2 addresses a condition where all means to determine RPV water level have been lost. In this condition, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the RPV.Continued loss of RCS inventory may result in escalation to the Alert emergency classification level via either IC CA6 or CA5.Month 20XX CL 3-124 EP-AA-1003 (Revision XX)

I=vdmlrn Khu-1gnr Minton Annax RECOGNITION CATEGORY COLD SHUTDOWN / REFUELING SYSTEM MALFUNCTIONS CU6 (cont)Basis Reference(s):

1. NEI 99-01, Rev. 6 CU1 2. Technical Specifications Table 3.3.5.1-1 3. ORM Attachment 2-7, Table 5 4. CPS 4100.01, Reactor SCRAM.4. CPS 4401.01, EOP-1 RPV Control 5. CPS Emergency Operating Procedures Technical Bases, Section 12 6. CPS 4411.07, RPV Level Instrumentation

7. USAR 5.2.5.1 8. CPS 9043.06, Drywell Floor Drain Sump Flow Test 00PS404 9. CPS 9443.01, Drywell Equipment Drain Sump Flow E31-N578 Channel Cal 10. MA-CL-716-102, Reactor Disassembly

11. USAR Figure 3.8-31 12. USAR Table 7.1-13 Month 20XX CL 3-125 EP-AA-1 003 (Revision XX)

Clinton Annex Exelon Nuclear Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG1 Initiating Condition:

HOSTILE ACTION resulting in loss of physical control of the facility.Operating Mode Applicability:

1, 2,3,4,5, D Emergency Action Level (EAL): 1. A notification from the Security Force that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA.AND 2. a. ANY Table H1 safety function cannot be controlled or maintained.

OR b. Damage to spent fuel has occurred or is IMMINENT Table H1 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)Basis: HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.PROJECTILE:

An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.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.Month 20XX CL 3-126 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG1 (cont)Basis (cont): HOSTILE FORCE: One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

This IC addresses an event in which a HOSTILE FORCE has taken physical control of the facility to the extent that the plant staff can no longer operate equipment necessary to maintain key safety functions.

It also addresses a HOSTILE ACTION leading to a loss of physical control that results in actual or IMMINENT damage to spent fuel due to 1) damage to a spent fuel pool cooling system (e.g., pumps, heat exchangers, controls, etc.) or, 2) loss of spent fuel pool integrity such that sufficient water level cannot be maintained.

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].Basis Reference(s):

1. NEI 99-01, Rev. 6 HG1 2. Station Security Plan -Appendix C Month 20XX CL 3-127 EP-AA-1003 (Revision XX)

Clintnn N, r Clinton Annex FvYplnn mmrelanr RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HSI Initiating Condition:

HOSTILE ACTION within the PROTECTED AREA.Operating Mode Applicability:

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.Basis: HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.PROJECTILE:

An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.HOSTILE FORCE: One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI): A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTED AREA. This event will require rapid response and assistance due to the possibility for damage to plant equipment.

Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].Month 20XX CL 3-128 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS1 (cont)Basis (cont): As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering).

The Site Area Emergency declaration will mobilize ORO resources and have them available to develop and implement public protective actions in the unlikely event that the attack is successful in impairing multiple safety functions.

This IC does not apply to a HOSTILE ACTION directed at an ISFSI PROTECTED AREA located outside the plant PROTECTED AREA; such an attack should be assessed using IC HAl. It also does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR§ 50.72.Escalation of the emergency classification level would be via IC HG1.Basis Reference(s):

1. NEI 99-01 Rev 6, HS1 2. Station Security Plan -Appendix C Month 20XX CL 3-129 EP-AA-1003 (Revision XX)

Clinton Annex I= h'm ClIinton Anne~x F-zeinn N~-ln RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA1 Initiating Condition:

HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.Operating Mode Applicability:

1,2,3,4,5, D Emergency Action Level (EAL): 1. A validated notification from NRC of an aircraft attack threat < 30 minutes from the site.OR 2. Notification by the Security Force that a HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLED AREA.Basis: HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.PROJECTILE:

An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.OWNER CONTROLLED AREA (OCA): The property associated with the station and owned by the company. Access is normally limited to persons entering for official business.PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.HOSTILE FORCE: One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

This IC addresses the occurrence of a HOSTILE ACTION within the OWNER CONTROLLED AREA or notification of an aircraft attack threat. This event will require rapid response and assistance due to the possibility of the attack progressing to the PROTECTED AREA, or the need to prepare the plant and staff for a potential aircraft impact.Month 20XX CL 3-130 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HAI (cont)Basis (cont): Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal or sheltering).

The Alert declaration will also heighten the awareness of Offsite Response Organizations, allowing them to be better prepared should it be necessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE.Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc. Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.EAL #1 Basis Addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in a heightened state of readiness.

This EAL is met when the threat-related information has been validated in accordance with CPS 4305.01, Security Threat Intrusion.

EAL #2 Basis Applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA. This includes any action directed against an ISFSI that is located outside the plant PROTECTED AREA.The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft.

The status and size of the plane may be provided by NORAD through the NRC.In some cases, it may not be readily apparent if an aircraft impact within the OWNER CONTROLLED AREA was intentional (i.e., a HOSTILE ACTION). It is expected, although not certain, that notification by an appropriate Federal agency to the site would clarify this point. In this case, the appropriate federal agency is intended to be NORAD, FBI, FAA or NRC. The emergency declaration, including one based on other ICs/EALs, should not be unduly delayed while awaiting notification by a Federal agency.Month 20XX CL 3-131 EP-AA-1003 (Revision XX)

AnnoY I::vimlrnn N, *-I--nr t~Iintnn Ann~v ~v~Irhn Muui-I~~r RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HAI (cont)Basis (cont): Escalation of the emergency classification level would be via IC HS1.Basis Reference(s):

1. NEI 99-01 Rev 6, HA1 2. Station Security Plan -Appendix C 3. CPS 4305.01, Security Threat Intrusion Month 20XX CL 3-132 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HUI Initiating Condition:

Confirmed SECURITY CONDITION or threat.Operating Mode Applicability:

1, 2,3,4,5, D Emergency Action Level (EAL): 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.

OR 2. A validated notification from the NRC providing information of an aircraft threat.OR 3. Notification by the Security Force of a SECURITY CONDITION that does not involve a HOSTILE ACTION.Basis: SECURITY CONDITION:

Any Security Event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A SECURITY CONDITION does not involve a HOSTILE ACTION 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.

HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station.PROJECTILE:

An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, and thus represent a potential degradation in the level of plant safety.Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs HA1, HS1 and HG1.Month 20XX CL 3-133 EP-AA-1003 (Revision XX)

Clinton Annex FxeInn Clinton Annex Exelon NuclerIAm RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HUI (cont)Basis (cont): Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event.Classification of these events will initiate appropriate threat-related notifications to plant personnel and OROs.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].EAL #1 Basis Addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with SY-AA-101-132.

EAL #2 Basis Addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft.

The status and size of the plane may also be provided by NORAD through the NRC. Validation of the threat is performed in accordance with CPS 4305.01, Security Threat Intrusion.

EAL #3 Basis References Security Force because these are the individuals trained to confirm that a security event is occurring or has occurred.

Training on security event confirmation and classification is controlled due to the nature of Safeguards and 10 CFR § 2.39 information.

Escalation of the emergency classification level would be via IC HA1.Basis Reference(s):

1. NEI 99-01 Rev 6, HU1 2. SY-AA-101-132, Security Assessment and Response to Unusual Activities

3. Station Security Plan -Appendix C 4. NRC Safeguards Advisory 10/6/01 5. Letter from Mr. B. A. Boger (NRC) to Ms. Lynette Hendricks (NEI) dated 2/4/02 6. CPS 4305.01, Security Threat Intrusion Month 20XX CL 3-134 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS2 Initiating Condition:

Inability to control a key safety function from outside the Control Room.Operating Mode Applicability:

1, 2, 3, 4, 5, D 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 Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per CPS 4003.01, Remote Shutdown.AND 2. Control of ANY Table H1 key safety function is not reestablished in < 15 minutes.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)Basis: The time period to establish control of the plant starts when either: a. Control of the plant is no longer maintained in the Main Control Room OR b. The last Operator has left the Main Control Room.This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations, and the control of a key safety function cannot be reestablished in a timely manner. The failure to gain control of a key safety function following a transfer of plan control to alternate locations is a precursor to a challenge to one or more fission product barriers within a relatively short period of time.The determination of whether or not "control" is established at the remote safe shutdown location(s) is based on Emergency Director judgment.

The Emergency Director is expected to make a reasonable, informed judgment within 15 minutes whether or not the operating staff has control of key safety functions from the remote safe shutdown location(s).

Escalation of the emergency classification level would be via IC FG1 or CG6.Month 20XX CL 3-135 EP-AA-1003 (Revision XX)

I-lintn~n Ann-av C%-gmlrn Kl"o-lgsýr CIin4nn A nnav I ~ Mm. a~ ~ r RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS2 (cont)Basis Reference(s):

1. NEI 99-01, Rev 6 HS6 2. CPS 4003.01, Remote Shutdown Month 20XX CL 3-136 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA2 Initiating Condition:

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

Operating Mode Applicability:

1,2,3,4,5, D Emergency Action Level (EAL): A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per CPS 4003.01, Remote Shutdown.Basis: This IC addresses an evacuation of the Control Room that results in transfer of plant control to alternate locations outside the Control Room. The loss of the ability to control the plant from the Control Room is considered to be a potential substantial degradation in the level of plant safety.Following a Control Room evacuation, control of the plant will be transferred to alternate shutdown locations.

The necessity to control a plant shutdown from outside the Control Room, in addition to responding to the event that required the evacuation of the Control Room, will present challenges to plant operators and other on-shift personnel.

Activation of the ERO and emergency response facilities will assist in responding to these challenges.

Escalation of the emergency classification level would be via IC HS2.Basis Reference(s):

1. NEI 99-01, Rev 6 HA6 2. CPS 4003.01, Remote Shutdown Month 20XX CL 3-137 EP-AA-1003 (Revision XX)

Clinton Annex N Clinton Annex ExeInn Nucler~I RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 Initiating Condition:

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

1, 2, 3, 4, 5, D 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:

OR 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 Table H2 Vital Areas" Containment" Auxiliary Building" Fuel Building" Control Building* Diesel Generator

& HVAC Building* Screenhouse

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 plant 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.

Month 20XX CL 3-138 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 (cont)Basis: FIRE: Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute FIRES. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of safety of the plant.EAL #1 Basis The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE could be a drop in fire main pressure, automatic activation of a suppression system, etc.Upon receipt, operators will take prompt actions to confirm the validity of an initial fire alarm, indication, or report. For EAL assessment purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and not the time that a subsequent verification action was performed.

Similarly, the fire duration clock also starts at the time of receipt of the initial alarms, indication or report.EAL #2 Basis This EAL addresses receipt of a single fire alarm, and the existence of a FIRE is not verified (i.e., proved or disproved) within 30-minutes of the alarm. Upon receipt, operators will take prompt actions to confirm the validity of a single fire alarm. For EAL assessment purposes, the 30-minute clock starts at the time that the initial alarm was received, and not the time that a subsequent verification action was performed.

A single fire alarm, absent other indication(s) of a FIRE, may be indicative of equipment failure or a spurious activation, and not an actual FIRE. For this reason, additional time is allowed to verify the validity of the alarm. The 30-minute period is a reasonable amount of time to determine if an actual FIRE exists; however, after that time, and absent information to the contrary, it is assumed that an actual FIRE is in progress.Month 20XX CL 3-139 EP-AA-1 003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 (cont)Basis (cont): If an actual FIRE is verified by a report from the field, then EAL #1 is immediately applicable, and the emergency must be declared if the FIRE is not extinguished within 15-minutes of the report. If the alarm is verified to be due to an equipment failure or a spurious activation, and this verification occurs within 30-minutes of the receipt of the alarm, then this EAL is not applicable and no emergency declaration is warranted.

EAL #3 Basis In addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plant PROTECTED AREA not extinguished within 60-minutes may also potentially degrade the level of plant safety.EAL #4 Basis If a FIRE within the plant PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded.

The dispatch of an offsite firefighting agency to the site requires an emergency declaration only if it is needed to actively support firefighting efforts because the fire is beyond the capability of the Fire Brigade to extinguish.

Declaration is not necessary if the agency resources are placed on stand-by, or supporting post-extinguishment recovery or investigation actions.Basis-Related Requirements from Appendix R Appendix R to 10 CFR 50, states in part: Criterion 3 of Appendix A to this part specifies that "Structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions." When considering the effects of fire, those systems associated with achieving and maintaining safe shutdown conditions assume major importance to safety because damage to them can lead to core damage resulting from loss of coolant through boil-off.Because fire may affect safe shutdown systems and because the loss of function of systems used to mitigate the consequences of design basis accidents under post-fire conditions does not per se impact public safety, the need to limit fire damage to systems required to achieve and maintain safe shutdown conditions is greater than the need to limit fire damage to those systems required to mitigate the consequences of design basis accidents.

Month 20XX CL 3-140 EP-AA-1003 (Revision XX)

Annnx ClIinton Annex Exeinn NMman~~r RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU3 (cont)Basis (cont): In addition, Appendix R to 10 CFR 50, requires, among other considerations, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify a single alarm is well within this worst-case 1-hour time period.Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA2 or MA5.Basis Reference(s):

1. NEI 99-01, Rev 6 HU4 2. USAR Appendix F 3. USAR Figure 1.2-3, Principal Station structure Month 20XX CL 3-141 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU4 Initiating Condition:

Seismic event greater than OBE levels.Operating Mode Applicability:

1, 2, 3,4, 5, D Emergency Action Level (EAL): 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)

• 5009-1A (Acceleration Exceeded Safe Shutdown Earthquake (SSE) at 0.25 g)Basis: This IC addresses a seismic event that results in accelerations at the plant site greater than those specified for an Operating Basis Earthquake (OBE)1.An earthquake greater than an OBE but less than a Safe Shutdown Earthquake (SSE)2 should have no significant impact on safety-related systems, structures and components; however, some time may be required for the plant staff to ascertain the actual post-event condition of the plant (e.g., performs walk-downs and post-event inspections).

Given the time necessary to perform walk-downs and inspections, and fully understand any impacts, this event represents a potential degradation of the level of safety of the plant.Event verification with external sources should not be necessary during or following an OBE. Earthquakes of this magnitude should be readily felt by on-site personnel and recognized as a seismic event (e.g., typical lateral accelerations are in excess of 0.08g).The Shift Manager or Emergency Director may seek external verification if deemed appropriate (e.g., a call to the USGS, check internet news sources, etc.); however, the verification action must not preclude a timely emergency declaration.

Depending upon the plant mode at the time of the event, escalation of the emergency classification level would be via IC CA2 or MA5.Basis Reference(s):

1. NEI 99-01, Rev 6 HU2 2. CPS 4301.01, Earthquake 1 An OBE is vibratory ground motion for which those features of a nuclear power plant necessary for continued operation without undue risk to the health and safety of the public will remain functional.

An SSE is vibratory ground motion for which certain (generally, safety-related) structures, systems, and components must be designed to remain functional.

Month 20XX CL 3-142 EP-AA-1003 (Revision XX)

Annov IPvalnn khinr-lar RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA5 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: 9 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 Modes 4 and 5 Steam Tunnel**Areas required to establish shutdown cooling AND 2. Entry into the room or area is prohibited or impeded Basis: This IC addresses an event involving a release of a hazardous gas that precludes or impedes access to equipment necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal plant procedures.

This condition represents an actual or potential substantial degradation of the level of safety of the plant.Table H3 is a list of plant rooms or areas with entry-related mode applicability that contain equipment which require 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).

Month 20XX CL 3-143 EP-AA-1003 (Revision XX)

Clinton Annexr Clinton Annex FvelInn Nucler~I RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA5 (cont)Basis (cont): This Table does not include the Control Room since adequate engineered safety/design features are in place to preclude a Control Room evacuation due to the release of a hazardous gas.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 gaseous release preclude the ability to place shutdown cooling in service. The emergency classification is not contingent upon whether entry is actually necessary at the time of the release.Evaluation of the IC and EAL do not require atmospheric sampling; it only requires the Emergency Director's judgment that the gas concentration in the affected room/area is sufficient to preclude or significantly impede procedurally required access. This judgment may be based on a variety of factors including an existing job hazard analysis, report of ill effects on personnel, advice from a subject matter expert or operating experience with the same or similar hazards. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

An emergency declaration is not warranted if any of the following conditions apply." The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the gaseous release).

For example, the plant is in Mode 1 when the gaseous release occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4." The gas release is a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., fire suppression system testing)." The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections)." The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels. Most commonly, asphyxiants work by merely displacing air in an enclosed environment.

This reduces the concentration of oxygen below the normal level of around 19%, which can lead to breathing difficulties, unconsciousness or even death.This EAL does not apply to firefighting activities that generate smoke, that automatically or manually activate a fire suppression system in an area, or to intentional inerting of containment.

Escalation of the emergency classification level would be via Recognition Category R, C or F ICs.Month 20XX CL 3-144 EP-AA-1003 (Revision XX)

Clinton Annex Clinton Annex ExeInn Niuclemar RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA5 (cont)Basis Reference(s):

1. NEI 99-01, Rev 6 HA5 2. USAR Appendix F 3. ACIT 660892-14, Station Halon Discharge IDLH Evaluation Month 20XX CL 3-145 EP-AA-1 003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 Initiating Condition:

Hazardous Event Operating Mode Applicability:

1, 2,3,4,5, D Emergency Action Level (EAL): Note:* 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 offsite 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 > 696ft.Basis: PROTECTED AREA: An area that normally encompasses all controlled areas within the security protected area fence.SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS. These are typically systems classified as safety-related.

This IC addresses hazardous events that are considered to represent a potential degradation of the level of safety of the plant.EAL #1 Basis Addresses a tornado striking (touching down) within the Protected Area.Month 20XX CL 3-146 EP-AA-1003 (Revision XX)

Clintnn Annoy I:=Yalnn RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU6 (cont)Basis (con't);: EAL #2 Basis Addresses flooding of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns.Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode. Manual isolation of power to a SAFETY SYSTEM component as a result of leakage is an event of lesser impact and would be expected to cause small and localized damage. The consequence of this type of event is adequately assessed and addressed in accordance with Technical Specifications.

EAL #3 Basis Addresses a hazardous materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel within the PROTECTED AREA.EAL #4 Basis Addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles.

Examples of such an event include site flooding caused by a hurricane, heavy rains, up-river water releases, dam failure, etc., or an on-site train derailment blocking the access road.This EAL is not intended to apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the flooding around the Cooper Station during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in 2011.EAL #5 Basis: A lake level of 696 ft el. is one foot below the 100-year flood elevation and represents a decision point; based on rate of lake level rise, and expected level crest, to shutdown the plant in order to assure safe plant shutdown (MODE 3) prior to lake level reaching 697 ft.Escalation of the emergency classification level would be based on ICs in Recognition Categories R, F, M, H or C.Basis.Reference(s):

1. NEI 99-01, Rev 6 HU3 2. CPS 4304.01, Flooding 3. Sargent & Lundy Report SL-4576 "Internal Flooding -Safe Shutdown Analysis and INPO SOER No. 85-5 Comparison Evaluation Report," Clinton Power Station, January 31, 1990 4. CPS 4303.02, Abnormal Lake Level Month 20XX CL 3-147 EP-AA-1 003 (Revision XX)

Clinton Annex Exelon Nuclear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HG7 Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of a GENERAL EMERGENCY.

Operating Mode Applicability:

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

Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.Basis: 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.HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE:

An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a General Emergency.

Basis Reference(s):

1. NEI 99-01, Rev 6 HG7 Month 20XX CL 3-148 EP-AA-1003 (Revision XX)

('Hlnfr~n A nn,'.v I=v,-%1rn Kiirl-har f~Iin4rhn Ann~v ~v~Ii~n kin ~RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HS7 Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of a SITE AREA EMERGENCY.

Operating Mode Applicability:

1,2, 3, 4, 5, D Emergency Action Level (EAL): Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts, (1) toward site personnel or equipment that could lead to the likely failure of or, (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.Basis: HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE:

An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for a Site Area Emergency.

Basis Reference(s):

1. NEI 99-01, Rev 6 HS7 Month 20XX CL 3-149 EP-AA-1003 (Revision XX)

Clinton Annex Exelon Nuclear Clinto AnnexExelon NuclIear RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HA7 Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of an ALERT.Operating Mode Applicability:

1, 2,3,4,5, D Emergency Action Level (EAL): Other conditions exist which, in the judgment of the Emergency Director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.Basis: HOSTILE ACTION: An act toward a NPP or its personnel that includes the use of violent force to destroy equipment, take HOSTAGES, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, PROJECTILEs, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

HOSTILE ACTION should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on the NPP. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).HOSTAGE: A person(s) held as leverage against the station to ensure that demands will be met by the station PROJECTILE:

An object directed toward a NPP that could cause concern for its continued operability, reliability, or personnel safety.This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an Alert.Basis Reference(s):

1. NEI 99-01, Rev 6 HA7 Month 20XX CL 3-150 EP-AA-1003 (Revision XX)

Annex CrIintnn Annex FvaInn Nw-lor~I RECOGNITION CATEGORY HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY HU7 Initiating Condition:

Other conditions exist which in the judgment of the Emergency Director warrant declaration of an UNUSUAL EVENT.Operating Mode Applicability:

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

No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.Basis: This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist which are believed by the Emergency Director to fall under the emergency classification level description for an UNUSUAL EVENT.Basis Reference(s):

1. NEI 99-01, Rev 6 HU7 Month 20XX CL 3-151 EP-AA-1003 (Revision XX)