ML14164A071
Text
ATTACHMENT 8 DISCUSSION OF REVISION TO THE RADIOLOGICAL EMERGENCY PLAN ANNEX FOR OYSTER CREEK NUCLEAR GENERATING STATION EP-AA-1 010 Enclosures
- A - EAL Comparison Matrix Document
- B - EAL Red-Line Basis Document
- C - EAL Basis Document
NEI 99-01 REVISION 6 DEVELOPMENT OF EMERGENCY ACTION LEVELS FOR NON-PASSIVE REACTORS ATTACHMENT 8 DISCUSSION OF REVISION TO THE RADIOLOGICAL EMERGENCY PLAN ANNEX FOR OYSTER CREEK NUCLEAR GENERATING STATION I
mr ExetonGenerationo
NEI 99-01 Rev 6 Proposed EAL Justification AG1 Initiating Condition - GENERAL EMERGENCY Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE.
Operating Mode Applicability: All Example Emergency Action Levels: (1 or 2 or 3)
Notes:
The Emergency Director should declare the General Emergency promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.
If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.
The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
- 1. Reading on any of the following radiation monitors greater than the reading shown for 15 minutes or longer:
(site specific monitor list and threshold values)
- 2.
Dose assessment actual meteorology indicates doses greater than 1000 mrem TEDE or 5000 mrem thyroid CDE at or beyond (site specific dose receptor point)
- 3.
Field survey results indicate EITHER of the following at or beyond (site specific dose receptor point):
Closed window dose rates greater than 1000 mR/hr expected to continue for 60 minutes or longer.
Analysis of field survey samples indicate thyroid CDE greater than 5000 mrem for one hour of inhalation.
RG1 Initiating Condition:
Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mRem TEDE or 5,000 mRem thyroid CDE.
Operating Mode Applicability:
1.2,3,4,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. Readings on ANY Table R1 Effluent Monitor > Table R1 value for
> 15 minutes.
- 2.
Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER:
- a.
- b.
- 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.
- b. Analyses of field survey samples indicate > 5000 mRem CDE Thyroid for 60 minutes of inhalation.
Table RI Effluent Monitor Thresholds Effluent Monitor General Emergency Main Stack RAGEMS 8.69 E+01 uCi/cc HRM OR 3.53 E-08 amps HRM Turbine Building RAGEMS 7.17 E-01 uCi/cc HRM HRM = High Range Monitor E
No Change F
Difference FIDeviation Listed site-specific monitors and Threshold values to ensure timely classification.
- 1) Added the following to bullet #3" Classification based on effluent monitor readings assumes that a release path to the environment is established." In order to delete the following from the basis "Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 11x17 procedure matrix used by the SM.
Page 1 of166
[
Justification AS1 Initiating Condition - SITE AREA EMERGENCY Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE.
Operating Mode Applicability: All Example Emergency Action Levels: (1 or 2 or 3)
Notes:
The Emergency Director should declare the Site Area Emergency promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.
If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.
The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
- 1.
Reading on any of the following radiation monitors greater than the reading shown for 15 minutes or longer:
(site specific monitor list and threshold values)
- 2.
Dose assessment actual meteorology indicates doses greater than 1000 mrem TEDE or 5000 mrem thyroid CDE at or beyond (site specific dose receptor point)
- 3.
Field survey results indicate EITHER of the following at or beyond (site specific dose receptor point):
Closed window dose rates greater than 100 mR/hr expected to continue for 60 minutes or longer.
Analysis of field survey samples indicate thyroid CDE greater than 500 mrem for one hour of inhalation.
RS1 Initiating Condition:
Release of gaseous radioactivity resulting in offsite dose greater than 100 mRem TEDE or 500 mRem thyroid CDE.
Operating Mode Applicability:
1,2,3,4,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.
Readings on ANY Table R1 Effluent Monitor > Table Ri value for
> 15 minutes.
- 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER:
- a.
- b.
- 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.
- b.
Analyses of field survey samples indicate > 500 mRem CDE Thyroid for 60 minutes of inhalation.
Table R1 Effluent Monitor Thresholds Effluent Monitor Site Area Emergency Main Stack RAGEMS 8.69 E+00 uCi/cc HRM OR 3.53 E-09 amps HRM Turbine Building RAGEMS 3.65 E+05 cpm LRM HRM = High Range Monitor LRM = Low Range Monitor
[:
No Change 1--1 Difference F1 Deviation Listed site-specific monitors and Threshold values to ensure timely classification.
- 1) Added the following to bullet #3" Classification based on effluent monitor readings assumes that a release path to the environment is established." In order to delete the following from the basis "Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 1 1x17 procedure matrix used by the SM.
Page 2 of66
NEI 99-01 Rev 6 Proposed EAL Justification AAI Initiating Condition - ALERT Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE.
Operating Mode Applicability:
All Example Emergency Action Levels:
(1 or 2 or 3)
Note:
The Emergency Director should declare the Alert promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.
If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.
The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
- 1. Reading on any of the following radiation monitors greater than the reading shown for 15 minutes or longer:
(site-specific monitor list and threshold values)
- 2.
Dose assessment actual meteorology indicates doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond (site specific dose receptor point)
- 3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond (site-specific dose receptor point) for one hour of exposure.
- 4.
Field survey results indicate EITHER of the following at or beyond (site specific dose receptor point):
Closed window dose rates greater than 10 mR/hr expected to continue for 60 minutes or longer.
Analysis of field survey samples indicate thyroid CDE greater than 50 mrem for one hour of inhalation.
RAI Initiating Condition:
Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE.
Operating Mode Applicability:
1,2,3,4, 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. Readings on ANY Table R1 Effluent Monitor > Table RI value for
> 15 minutes.
- 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER:
- a.
- b.
- 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 > 60 minutes.
- b.
Analyses of field survey samples indicate > 50 mRem CDE Thyroid for 60 minutes of inhalation.
Table RI Effluent Monitor Thresholds Effluent Monitor Alert Main Stack RAGEMS 8.69 E-01 uCi/cc HRM OR 3.53 E-10 amps HRM Turbine Building RAGEMS 3.65 E+04 cpm LRM HRM = High Range Monitor LRM = Low Range Monitor 1
No Change ri Difference FIDeviation Listed site-specific monitors and Threshold values to ensure timely classification.
- 1) Added the following to bullet #3" Classification based on effluent monitor readings assumes that a release path to the environment is established." In order to delete the following from the basis "Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 1 1x17 procedure matrix used by the SM.
- 2) Calculation was performed to determine the radiation monitor response for a radioactive liquid release with an activity equivalent to provide lOmrem TEDE or 50mrem thyroid CDE at the site boundary via the normal site release pathway. The calculation determined the liquid radwaste system was no longer used and was cut and capped oiff. As such the liquid radwaste effluent monitor was not included in this EAL Page 3 of66
0 NEI 99-01 Rev 6 1
Proposed EAL Justification AU1 Initiating Condition - UNUSUAL EVENT Release of gaseous or liquid radioactivity greater than 2 times the (site-specific effluent release controlling document) limits for 60 minutes or longer Operating Mode Applicability:
All Example Emergency Action Levels:
(1 or 2 or 3)
Note:
The Emergency Director should declare the Unusual Event promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded.
If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes.
If the effluent flow past an effluent monitor is known to have stopped, indicating that the release path is isolated, the effluent monitor reading is no longer valid for classification purposes.
- 1.
Reading on ANY effluent radiation monitor greater than 2 times the (site-specific effluent release controlling document) limits for 60 minutes or longer:
(site-specific monitor list and threshold values corresponding to 2 times the controlling document limits)
- 2.
Reading on ANY effluent radiation monitor greater than 2 times the alarm setpoint established by a current radioactivity discharge permit for 60 minutes or longer.
- 3.
Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times (site-specific effluent release controlling document limits) for 60 minutes or longer.
RU1 Initiating Condition:
Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer.
Operating Mode Applicability:
1,2,3,4, 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. Readings on ANY Table R1 Effluent Monitor > Table RI value for
>60 minutes:
Table R1 Effluent Monitor Thresholds Effluent Monitor Unusual Event Main Stack RAGEMS 4.07 E+03 cps LRM Turbine Building RAGEMS 4.16 E+02 cpm LRM LRM = Low Range Monitor OR
- 2.
Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 2 times ODCM Limit with a release duration of> 60 minutes.
ii No Change M
Difference
[I Deviation Listed site-specific monitors and Threshold values to ensure timely classification.
- 1) Added the following to bullet #3" Classification based on effluent monitor readings assumes that a release path to the environment is established." In order to delete the following from the basis "Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the 11x17 procedure matrix used by the SM.
- 2) Calculation was performed to determine the radiation monitor response for a radioactive liquid release with an activity equivalent to provide 2 times the ODCM.
The calculation determined the liquid radwaste system was no longer used and was cut and capped oiff. As such the liquid radwaste effluent monitor was not included in this EAL Page 4 of 66
NEI 99-01 Rev 6 Proposed EAL Justification AG2 RG2 Initiating Condition -- GENERAL EMERGENCY LN Change J Difference Deviation Spent fuel pool level cannot be restored to at least (site-specific Level 3 description) for 60 minutes or longer.
- 1)
EAL not used in accordance with the discussion in Section 1.4, NRC Order Operating Mode Applicability:
All EA-1 2-051, it is recommended that this EAL be implemented when the enhanced spent fuel pool level instrumentation is available for use. The completion of the Example Emergency Action Levels:
enhanced SFP level indicators and need for the inclusion of this EAL is being tracked in accordance with Exelon Generation Company, LLC's Initial Status NOTES:
The Emergency Director should declare the General Emergency Report to March 12, 2012 Commission Order Modifying Licenses with Regard for promptly upon determining that 60 minutes has been exceeded, Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) dated or will likely be exceeded October 25,2012.
- 1.
Spent fuel pool level cannot be restored to at least (site-specific Level 3 description) for 60 minutes or longer.
Page 5 of 66
NEI 99-01 Rev 6 Proposed EAL Justification AS2 RS2 Initiating Condition - SITE AREA EMERGENCY D No Change 13] Difference K] Deviation Spent fuel pool level cannot be restored to at least (site-specific Level 3 description)
- 1)
EAL not used in accordance with the discussion in Section 1.4. NRC Order EA-12-051, it is recommended that this EAL be implemented when the enhanced Operating Mode Applicability:
All spent fuel pool level instrumentation is available for use. The completion of the enhanced SFP level indicators and need for the inclusion of this EAL is being Example Emergency Action Levels:
tracked in accordance with Exelon Generation Company, LLC's Initial Status Report to March 12, 2012 Commission Order Modifying Licenses with Regard for
- 1.
Spent fuel pool level cannot be restored to at least (site-specific Level 3 Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) dated description)
October 25,2012.
Page 6 of 66
NEI 99-01 Rev 6 Proposed EAL Justification AA2RA Initiating Condition - ALERT IRA2I No Change Difference Deviation Initiating Condition:
L Significant lowerng of water level above, or damage to, irradiated fuel.
Significant lowering of water level above, or damage to, irradiated fuel.
- 1) Listed site-specific monitors and Threshold values to ensure timely Operating Mode Applicability:
All Operating Mode Applicability:
classification.
1,2,3.4, D Example Emergency Action Levels:
(1 or 2 or 3)
Emergency Action Level (EAL):
- 2) EAL #3 not used in accordance with the discussion in Section 1.4, NRC Order EA-1 2-051. it is recommended that this EAL be implemented when the enhanced
- 1. Uncovery of irradiated fuel in the REFUELING PATHWAY.
- 1.
Uncovery of irradiated fuel in the REFUELING PATHWAY.
spent fuel pool level instrumentation is available for use. The completion of the OR enhanced SFP level indicators and need for the inclusion of this EAL is being
- 2.
Damage to irradiated fuel resulting in a release of radioactivity from the tracked in accordance with Exelon Generation Company, LLC's Initial Status fuel as indicated by ANY of the following radiation monitors:
- 2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel Report to March 12, 2012 Commission Order Modifying Licenses with Regard for as indicated by ANY Table R2 Radiation Monitor reading a1000 mRemlhr.
Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) dated (site-specific listing of radiation monitors, and the associated readings, October 25,2012.
setpoints and/or alarms)
Table R2 Refuel Floor ARM's
- 3. Lowering of spent fuel pool level to (site-specific Level 2 value).
C-5. Crit Mon C-10, North Wall C-9, North Wall B-9, Open Floor Page 7 of 66
NEI 99-01 Rev 6 1
Proposed EAL I
Justification AU2 Initiating Condition: UNUSUAL EVENT UNPLANNED loss of water level above irradiated fuel Operating Mode Applicability:
All Example Emergency Action Levels:
- 1.
- a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated by ANY of the following:
(site-specific level indications).
AND
- b. UNPLANNED rise in area radiation levels as indicated by ANY of the following radiation monitors.
(site-specific list of area radiation monitors)
RU2 Initiating Condition:
UNPLANNED loss of water level above irradiated fuel Operating Mode Applicability:
1,2, 3,4, 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 < 583 inches (GEMAC Wide Range, floodup calibration).
OR Indication or report of a drop in water level in the REFUELING PATHWAY.
AND
- b. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors in Table R2.
F-*
No Change 1
Difference 1
Deviation Listed site specific level indication and monitors to ensure timely classification.
Table R2 Refuel Floor ARM's C-5, Crit Mon C-10, NorthWall C-9, North Wall B-9, Open Floor Page 8 of 66
NEI 99-01 Rev 6 Proposed EAL Justification AA3 Initiating Condition - ALERT Radiation levels that impede access to equipment necessary for normal plant operations, cooldown or shutdown.
Operating Mode Applicability:
All Example Emergency Action Levels:
(1 or 2)
Note:
If the equipment in the listed room or area was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted
- 1. Dose rate greater than 15 mR/hr in ANY of the following areas:
- Control Room
- Central Alarm Station
- (other site-specific areas/rooms)
- 2.
An UNPLANNED event results in radiation levels that prevent or significantly impede access to any of the following plant rooms or areas:
(site-specific list of plant rooms or areas with entry-related mode applicability identified)
RA3 Initiating Condition:
Radiation levels that impede access to equipment necessary for normal plant operations, cooldown or shutdown.
Operating Mode Applicability:
- 1, 2, 3, 4,D Emergency Action Level (EAL):
No Change 1:
Difference 1
1 Deviation Listed site specific plant rooms and areas with identified mode applicability to ensure timely classification.
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 R3 areas:
Table R3 Areas Requiring Continuous Occupancy C
Main Control Room M
Central Alarm Station- (by survey)
- 2.
UNPLANNED event results in radiation levels that prohibit or significantly impede access to ANY of the following Table R4 plant rooms or areas:
Table R4 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Reactor Building*
Modes 3 and 4 Areas required to establish shutdown cooling Page 9 of 66
NEI 99-01 Rev 6 Proposed EAL Justification NEI 99-01 Rev 6 Proposed EAL Justification
+
4 SU3 Initiating Condition: UNUSUAL EVENT Reactor coolant activity greater than Technical Specification allowable limits.
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels:
- 1.
(Site-specific radiation monitor) reading greater than (site-specific value).
- 2.
Sample analysis indicates that a reactor coolant activity value is greater than an allowable limit specified in Technical Specifications.
RU3 Initiating Condition:
Reactor coolant activity greater than Technical Specification allowable limits.
Operating Mode Applicability:
1,2 Emergency Action Level (EAL):
- 1.
Offgas system radiation monitor Hi-Hi alarm.
- 2.
Specific coolant activity > 4.0 uCl/gm Dose equivalent 1-131.
D No Change I
Difference 1
Deviation
- 1) Listed site-specific monitor and Threshold value to ensure timely classification.
- 2) Listed this system category EAL in the radiological category EAL section to maintain consistency with current and previous revisions of Exelon EALs. This will ensure a timely classification since the threshold values are more aligned with the radiological category vice system category.
Page 10 of 66
NEt 99-01 Rev 6 Fission Product Barrier Matrix FGI Loss of any two barriers AND Loss or Potential Loss of third barrier.
1,2 FSI Loss or Potential Loss of ANY two barriers.
1.2 FAl ANY Loss or ANY Potential Loss of either Fuel Clad or RCS 1,2 FC - Fuel Clad RC - Reactor Coolant System CT - Containment Sub-C;ategory Loss Potential Loss Loss Potential Loss Loss Potential Loss
- 1. RCS Activity I A.
UNPLANNED rapid drop in primary A. Primary containment pressure greater containment pressure following than (site-specific value)
Pnmary A. (Site specific indications that Containment A. Primarycontainment pressure primary containment pressure rise OR Pressure reator coolant activity is greater None greater than (site-specific value)
None OR B. (site-specific explosive mixture) exists Primary than 300 uCilgm dose equivalent due to RCS leakage.
inside primary containment Continment 1-131)
B. Primary containment pressure Containment response not consistent with LOCA OR Conditions conditions.
C. HCTL exceeded.
A. RPV water level cannot be restored A.
RPV water level cannot be A. Primary containment flooding and maintained above (site-specific restored and maintained above
- 2. RPV Water required.
RPV water level corresponding to (site-specific RPV level None None A. Primary containment flooding required.
Level top of active fuel) or cannot be corresponding to the top of active determined, fuel) or cannot be determined.
A. UNISOLABLE direct downstream pathway to the environment exists after primary containment isolation signal OR A. UNISOLABLE primary system leakage A. UNISOLABLE break in any of the that results in exceeding EITHER of B. Intentional primary containment 3.RCS Leak Rate/
following:the following:
venting per EOPs Primary None None potential for high-energy line breas)
- 1. ax Normal Operating None Containment OR Temperature C. UNISOLABLE primary system Isolation Failure B. Emergency RPV Depressurization OR leakage that results in exceeding
- 2. Max Normal Operating Area EITHER of the following:
Radiation Level.
- 1. Max Safe Operating Temperature.
- 2. Max Safe Operating Area Radiation Level.
4.Primary A. Primary Containment Radiation A. Primary Containment Radiation A. Primary Containment Radiation Monitor Containment Monitor reading greater than None Monitor reading greater than (site-None None reading greater than (site-specific Radiation (site-specific value),
specific value).
value).
A. Any Condition in the opinion of A. Any Condition in the opinion of the A. ANY Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the
- 5. Emergency the Emergency Director that Emergency Director that indicates Emergency Director that indicates Loss Emergency Director that indicates Emergency Director that indicates Loss Emergency Director that indicates Potential Director Judgment indicates Loss of the Fuel Clad Potential Loss of the Fuel Clad Barrier.
of the RCS Barrier.
Potential Loss of the RCS Barrier.
of the Containment Barrier.
Loss of the Containment Barrier.
Barrier.
Page 11 of 66
0 Proposed Fission Product Barrier Matrix issio Pro__
__alxH FGI Loss of any two barriers AND Loss or Potential Loss of third barrier.
I FS1 Loss or Potential Loss of ANY two barriers.
1]rI FAI ANY Loss or ANY Potential Loss of either Fuel Clad or RCS FC - Fuel Clad RC - Reactor Coolant System CT - Containment SUb-Category Loss Potential Loss Loss Potential Loss Loss Potential Loss
- 2. RPV water level cannot be restored and
- 1. RPV water level cannot be restored and
- 2. RPV Water o
Plant conditions indicate primary maintained o 0 inches TAF maintained > 0 Inches TAF Plant conditions indicate primary containment Level ontainmentOR OR None None flooding is required.
- 3. RPV water level cannot be determined.
- 2. RPV water level cannot be determined.
- 3. Drywell pressure s 44 pslg and rising.
- 1. Drywall pressure N
3.0 Delg.
- 1. UNPLANNED rapid drop in Drywell pressure 4-
- a. Drywell or torus hydrogen concentration
- 3. Primary AND following Drywell pressure dse.
> 6%.
- 2. Drywelt pressure response tot consistent
> 5%.
- 5. Heat Capacity Temperature Limit (EMG-3200.02 Fig. Ft exceeded,
- 3. UNISOLABLE primary system leakage that
- 1. UNISOLABLE Main Steam Line (MSL).
results in EITHER of the following:
Isolation Condenser, Feedwater. or a Secondary Containment area RVVCU line break.
temperature > EMG-3200.111 Max 4.RCS Leak Rate None None OR Normal (Table 11) operating level.
- 2. Emergency RPV Depressurization is
- b. Secondary Containment area radiation
- required, level t EMG-3200.11 Max Normal (Table 12) operating level.
5.Primary Containment Hi Range Radiation Containment Hi Range Radiation Monitoring None Containment Monitoring System (CHRRMS) reading None System (CHRRMS) reading > I00R/hr.
None Containment Hi Range Radiation Monitoring Radiation
> 630 R/hr.
System (CHRRMS) readings 1210 R/hr.
- 1. UNISOLABLE direct downstream pathway to the environment exists after primary containment isolation signal.
- 2. Intentional Primary Containment ventinglpurging per EOPs or SAMGs due to accident conditions.
6.Primary OR Containment None None None None
- 3. UNISOLABLE primary system leakage that None Isolation failure results in EITHER of the following:
- a. Secondary Containment area temperature > EMG-3200.11 Max Safe (Table 11) operating level.
- b. Secondary Containment area radiation level s EMG-3200.11 Max Safe (Table 12) operating level.
- 7. Emergency A. Any Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the A. Any Condition in the opinion of the tEmergency Director that indicates Loss Emergency Director that indicates Potential Emergency Director that indicates Loss of Emergency Director that indicates Potential Emergency Director that indicates Loss of the Emergency Director that indicates Potential Loss Director Judgment of the Fuel Clad Banter.
Loss of the Fuel Clad Barrer.
the RCS Barrier.
Loss of the RCS Barrier.
Containment Barrier, of the Containment Barrier.
Page 12 of 66
NEI 99-01 Rev 6 Proposed EAL Justification Category: Fuel Clad Barrier FC1 Category: Fuel Clad Barrier FC1 M
No Change Differenc Deviation RCS Activity RCS Activity
- 1) Listed site-specific threshold value to ensure timely classification.
Operating Mode Applicability:
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 Fission Product Barrier Threshold:
Fission Product Barrier (FPB) Threshold:
Loss Loss A. (Site specific indications that reactor coolant activity is greater than 300 uCi/gm Coolant activity > 300 uCilgm Dose Equivalent 1-131.
dose equivalent 1-131)
Page 13 of 66
NEI 99-01 Rev 6 Proposed EAL Justification Category: Fuel Clad Barrier FC2 Category: Fuel Clad Barrier FC2 E
No Change Diffrce Deviation RPV Water Level RCS Activity
- 1) Listed site-specific threshold value to ensure timely classification.
Operating Mode Applicability:
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 Fission Product Barrier Threshold:
Fission Product Barrier (FPB) Threshold:
Loss Loss A. Primary containment flooding required.
- 1. Plant conditions indicate primary containment flooding is required.
Potential Loss
- 2. RPV water level cannot be restored and maintained > 0 inches TAF A. RPV water level cannot be restored and maintained above (site-specific RPV OR water level corresponding to top of active fuel) or cannot be determined.
- 3. RPV water level cannot be determined.
Page 14 of 66
NEI 99-01 Rev 6 Proposed EAL Justification Category: Fuel Clad Barrier FC4 Category: Fuel Clad BarrierFC No Change Diffene F
Deviation Primary Containment Radiation Primary Containment Radiation
- 1) Listed site-specific monitor and threshold value to ensure timely classification.
Operating Mode Applicability:
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3 Fission Product Barrier Threshold:
Fission Product Barrier (FPB) Threshold:
Loss Loss A. Primary Containment Radiation Monitor reading greater than (site-specific Containment Hi Range Radiation Monitoring System (CHRRMS) reading value).
> 530 R/hr.
Page 15 of 66
NEI 99-01 Rev 6 Proposed EAL Justification Category: Fuel Clad Barrier FC6 Category: Fuel Clad BarrierFC7 No Chag Diffrce Deviation Emergency Director Judgment Emergency Director Judgment Operating Mode Applicability:
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 Fission Product Barrier Threshold:
Fission Product Barrier (FPB) Threshold:
Loss Loss A. Any Condition in the opinion of the Emergency Director that indicates Loss of
- 1. Any Condition in the opinion of the Emergency Director that indicates Loss of the Fuel Clad Barrier.
the Fuel Clad Barrier.
Potential Loss Potential Loss A. Any Condition in the opinion of the Emergency Director that indicates Potential
- 2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.
Loss of the Fuel Clad Barrier.
Page 16 of 66
NEI 99-01 Rev 6 Proposed EAL Justification Category: Reactor Coolant System Barrier RCI Category: Reactor Coolant System BarrierC No Change Differece Deviation Primary Containment Pressure Primary Containment Pressure/Conditions
- 1) Listed site-specific threshold value to ensure timely classification.
Operating Mode Applicability:
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3 Fission Product Barrier Threshold:
Fission Product Barrier (FPB) Threshold:
Loss Loss A. Primary containment pressure greater than (site-specific value) due to RCS
- 1. Drywell pressure > 3.0 peig.
leakage.
AND
- 2. Drywell pressure rise is due to RCS leakage Page 17 of 66
NEI 99-01 Rev 6 Proposed EAL Justification Category: Reactor Coolant System Barrier RC2 Category: Reactor Coolant System Barrier RC2 E
No Change Diffrence Deviation RPV Water Level RPV Water Level
- 1) Listed site-specific threshold value to ensure timely classification.
Operating Mode Applicability:
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3 Fission Product Barrier Threshold:
Fission Product Barrier (FPB) Threshold:
Loss Loss A. RPV water level cannot be restored and maintained above (site-specific RPV
- 1. RPV water level cannot be restored and maintained > 0 inches TAF level corresponding to the top of active fuel) or cannot be determined.
- 2. RPV water level cannot be determined.
Page 18 of 66
0 NEI 99-01 Rev 6 Proposed EAL Justification Category: Reactor Coolant System Barrier RC3 Category: Reactor Coolant System BarrierC No Change
[]
Diffeence Deviation RCS Leak Rate RCS Leak Rate
- 1) Listed site-specific systems and threshold values to ensure timely classification.
Operating Mode Applicability:
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3 Fission Product Barrier Threshold:
Fission Product Barrier (FPB) Threshold:
Loss Loss A. UNISOLABLE break in any of the following: ( site-specific systems with potential
- 1. UNISOLABLE Main Steam Line (MSL), Isolation Condenser, Feedwater, or for high-energy line breas)
RWCU line break.
OR OR B. Emergency RPV Depressurization
- 2. Emergency RPV Depressurization is required.
Potential Loss A. UNISOLABLE primary system leakage that results in exceeding EITHER of the Potential Loss following:
- 3. UNISOLABLE primary system leakage that results in EITHER of the following:
- 1. Max Normal Operating Temperature
- a. Secondary Containment area temperature > EMG-3200.11 Max Normal OR (Table 11) operating level.
- 2. Max Normal Operating Area Radiation Level.
- b. Secondary Containment area radiation level > EMG-3200.11 Max Normal (Table 12) operating level.
Page 19 of 66
NEI 99-01 Rev 6 Proposed EAL Justification Category: Reactor Coolant System Barrier RC4 Category: Reactor Coolant System Barrier 5
No Change El] Difference 11 Deviation Primary Containment Radiation Primary Containment Radiation
- 1) Listed site-specific monitor and threshold value to ensure timely classification.
Operating Mode Applicability:
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Fission Product Barrier Threshold:
Fission Product Barrier (FPB) Threshold:
Loss Loss A. Primary Containment Radiation Monitor reading greater than (site-specific Containment Hi Range Radiation Monitoring System (CHRRMS) reading value).
> 1000 RWhr.
Page 20 of 66
NEI 99-01 Rev 6 Proposed EAL Justification Category: Reactor Coolant System Barrier RC6 Category: Reactor Coolant System Barrier RC W No Change Difference Deviation Emergency Director Judgment Emergency director Judgment Operating Mode Applicability:
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 Fission Product Barrier Threshold:
Fission Product Barrier (FPB) Threshold:
Loss Loss A. Any Condition in the opinion of the Emergency Director that indicates Loss of
- 1. ANY Condition in the opinion of the Emergency Director that indicates Loss of the RCS Barrier.
the RCS Barrier.
Potential Loss Potential Loss A. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.
- 2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.
Page 21 of 66
NEI 99-01 Rev 6 Proposed EAL Justification Category: Containment Barrier CTI Category: Containment Barrier No Change Difrenc Deviation Primary Containment Conditions Primary Containment Pressure/Conditions
- 1) Listed site-specific threshold values to ensure timely classification.
Operating Mode Applicability:
Operating Mode Applicability:
- 2) The words "and rising" were added to account for the momentary spike in Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3 pressure where pressure is now lowering, the risk of a potential loss of Fission Product Barrier Threshold:
Fission Product Barrier (FPB) Threshold:
containment is no longer present, this wording is also consistent with present EAL wording.
Loss Loss C.
UNPLANNED rapid drop in primary containment pressure following primary
- 1. UNPLANNED rapid drop in Drywell pressure following Drywell pressure rise.
containment pressure rise OR OR
- 2. Drywell pressure response not consistent with LOCA conditions.
B.
Primary containment pressure response not consistent with LOCA conditions.
Potential Loss Potential Loss D.
Primary containment pressure greater than (site-specific value)
- 3. Drywell pressure > 44 psig and rising.
OR OR E.
(site-specific explosive mixture) exists inside primary containment
- 4.
>6%.
AND
- 3.
HCTL exceeded.
- b. Drywell or torus oxygen concentration
> 5%.
- 5. Heat Capacity Temperature Limit (EMG-3200.02 Fig. F) exceeded.
Page 22 of 66
NEI 99-01 Rev 6 Proposed EAL Justification NEI 99-01 Rev 6 Proposed EAL Justification CT2 CT2 No Change D
Difference 1
Deviation Category: Containment Barrier RPV Water Level Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:
Potential Loss A. Primary containment flooding required.
Category: Containment Barrier RPV Water Level Operating Mode Applicability:
1,2,3 Fission Product Barrier (FPB) Threshold:
Potential Loss Plant conditions indicate primary containment flooding is required.
Page 23 of 66
NEI 99-01 Rev 6 Proposed EAL Justification Category: Containment Barder Category: Containment BarrierT No Change
[]
Differenc E
Deviation Primary Containment Isolation Failure Primary Containment Isolation Failure
- 1) Listed site-specific threshold values to ensure timely classification.
Operating Mode Applicability:
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown 1,2, 3 Fission Product Barrier Threshold:
Fission Product Barrier (FPB) Threshold:
Loss Loss A. UNISOLABLE direct downstream pathway to the environment exists after
- 1. UNISOLABLE direct downstream pathway to the environment exists after primary containment isolation signal primary containment isolation signal.
OR OR
- 2. Intentional Primary Containment venting/purging per EOPs or SAMGs due to B. Intentional primary containment venting per EOPs accident conditions.
OR OR C. UNISOLABLE primary system leakage that results in exceeding EITHER of the
- 3. UNISOLABLE primary system leakage that results in EITHER of the following:
following:
- a. Secondary Containment area temperature > EMG-3200.11 Max Safe (Table 11 ) operating level.
- 1. Max Safe Operating Temperature.
OR OR
- b. Secondary Containment area radiation level > EMG-3200.11I Max Safe
- 2. Max Safe Operating Area Radiation Level.
(Table 12) operating level.
Page 24 of 66
NEI 99-01 Rev 6 Proposed EAL Justification Category: Containment Barrier CT4 Category: Containment Barrier CT5 E
No Change Differnc Deviation Primary Containment Radiation Primary Containment Radiation
- 1) Listed site-specific monitor and threshold value to ensure timely classification.
Operating Mode Applicability:
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown 1,2,3 Fission Product Barrier Threshold:
Fission Product Barrier (FPB) Threshold:
Potential Loss Potential Loss A. Primary Containment Radiation Monitor reading greater than (site-specific Containment Hi Range Radiation Monitoring System (CHRRMS) reading value).
> 1210 R/hr.
Page 25 of 66
NEI 99-01 Rev 6 Proposed EAL Justification Category: Containment Barrier CTS Category: Containment Barrier No Change Diffre Deviation Emergency director Judgment Emergency Director Judgment Operating Mode Applicability:
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Fission Product Barrier Threshold:
Fission Product Barrier (FPB) Threshold:
Loss Loss A. Any Condition in the opinion of the Emergency Director that indicates Loss of
- 1. Any Condition in the opinion of the Emergency Director that indicates Loss of the Containment Barrier.
the Containment Barrier.
Potential Loss Potential Loss A. Any Condition in the opinion of the Emergency Director that indicates Potential
- 2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.
Loss of the Containment Barrier.
Page 26 of 66
NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition: GENERAL EMERGENCY SGI Initiating Condition:
MG No Change Difference Deviation Prolonged loss of all offsite and all onsite AC power to emergency buses.
Prolonged loss of all offsite and all onsite AC power to emergency buses.
Listed site specific equipment, site specific time based on station blackout coping Operating Mode Applicability:
Operating Mode Applicability:
analysis, and site specific indication to ensure timely classification.
Power Operation, Startup, Hot Standby, Hot Shutdown 1, 2, 3 Example Emergency Action Levels:
Emergency Action Level (EAL):
Note: The Emergency Director should declare the General Emergency promptly upon determining that (site-specific hours) has been exceeded, or will Note:
likely be exceeded.
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 ALL offsite and ALL onsite AC power to (site-specific emergency buses).
1 Loss of ALL offsite AC power to 4160V Buses IC and 1D.
AND AND
- 2. Failure of EDG-1 and EDG-2 Emergency Diesel Generators to supply power to
- b.
EITHER of the following:
4160V Buses IC and 1D.
AND Restoration of at least one emergency bus in less than (site-specific hours) is not likely.
- 3.
EITHER of the following:
- a. Restoration of at least one 4160V Bus (1C or 1D) in < 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is not (Site-specific indication of an inability to adequately likely.
remove heat from the core)
Page 27 of 66
NEI 99-01 Rev 6 1
Proposed EAL Justification SS1 Initiating Condition: SITE AREA EMERGENCY Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or longer.
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels:
Note:
The Emergency Director should declare the Site Area Emergency promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.
Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses) for 15 minutes or longer.
MS1 Initiating Condition:
Loss of all offsite and onsite AC power to emergency 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. Loss of ALL offsite AC Power to 4160V Buses 1C and 1D.
AND
- 2. Failure of EDG-1 and EDG-2 Emergency Diesel Generators to supply power to 4160V Buses 1C and 1D.
AND
- 3. Failure to restore power to at least one 4160V Bus (1C or 1D) in < 15 minutes from the time of loss of both offsite and onsite AC power.
No Change I Difference I
Deviation
- 1) Listed site specific equipment to ensure timely classification.
Page 28 of 66
NEI 99-01 Rev 6 1
Proposed EAL Justification SA1 Initiating Condition: ALERT Loss of all but one AC power source to emergency buses for 15 minutes or longer.
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels:
Note: The Emergency Director should declare the Alert promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.
- 1.
- a.
AC power capability to (site-specific emergency buses) is reduced to a single power source for 15 minutes or longer.
AND
- b.
Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS.
MAI 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 4160V Buses 1C and 1D reduced to only one of the following power sources for > I5 minutes.
Startup Transformer SA Startup Transformer SB EDG-1 Emergency Diesel Generator EDG-2 Emergency Diesel Generator AND
- 2. ANY additional single power source failure will result in a loss of all AC power to SAFETY SYSTEMS.
No Change FIDifference 1
Deviation
- 1) Listed site specific equipment to ensure timely classification.
Page 29 of 66
NEI 99-01 Rev 6 Proposed EAL I
Justification Sul Initiating Condition: UNUSUAL EVENT Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels:
Note:
The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.
Loss of ALL offsite AC power capability to (site-specific emergency buses) for 15 minutes or longer 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 4160V Buses IC and 1D for
>15 minutes.
No Change
[*
Difference I
Deviation
- 1) Listed site specific equipment to ensure timely classification.
Page 30 of 66
NEt 99-01 Rev 6 Proposed EAL Justification SGS Initiating Condition: GENERAL EMERGENCY Loss of all AC and Vital DC power sources for 15 minutes or longer.
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels:
Note:
The Emergency Director should declare the General Emergency promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.
- 1.
Loss of ALL offsite and ALL onsite AC power to (site-specific emergency buses) for 15 minutes or longer.
AND Indicated voltage is less than (site-specific bus voltage value) on ALL (site-specific vital DC buses) for 15 minutes or longer.
MG2 Initiating Condition:
Loss of all AC and Vital DC power sources for 15 minutes or longer.
Operating Mode Applicability:
1,2,3 Emergency Action Level (EAL):
Note:
The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1.
Loss of ALL offsite AC power to 4160V Busesl C and 1 D.
AND
- 2.
Failure of EDG-1 and EDG-2 Emergency Diesel Generators to supply power to 4160V Buses 1C and 1D..
AND
- 3.
Voltage is < 115 VDC on 125 VDC battery busses B and C.
AND
- 4.
ALL AC and Vital DC power sources have been lost for> 15 minutes.
[H No Change Difference 1-Deviation
- 1) Listed site specific equipment to ensure timely classification.
- 2) Removed the word "indicated" this will allow for an indication problem to not cause confusion on the need to declare.
Page 31 of 66
NEI 99-01 Rev 6 Proposed EAL Justification SS8 Initiating Condition: SITE AREA EMERGENCY Loss of all Vital DC power for 15 minutes or longer.
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels:
Note:
The Emergency Director should declare the Site Area Emergency promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.
Indicated voltage is less than (site-specific bus voltage value) on ALL Vital DC buses for 15 minutes or longer.
MS2 Initiating Condition:
Loss of all Vital DC power for 15 minutes or longer.
Operating Mode Applicability:
1.2,3 Emergency Action Level (EAL):
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 < 115 VDC on 125 VDC battery busses B and C for
> 15 minutes.
D No Change
-IDifference FIDeviation
- 1) Listed site specific equipment and site specific value to ensure timely classification.
- 2) Removed the word "indicated" this will allow for an indication problem to not cause confusion on the need to declare.
Page 32 of 66
NEI 99-01 Rev 6 Proposed EAL Justification SS5 Initiating Condition: SITE AREA EMERGENCY Inability to shutdown the reactor causing a challenge to (core cooling [PWR] / RPV water level [BWRI) or RCS heat removal.
Operating Mode Applicability:
Power Operation Example Emergency Action Levels:
1.
a.
An automatic (trip [PWR] / scram [BVVR]) did not shutdown the reactor.
AND
- b.
All manual actions to shutdown the reactor have been unsuccessful.
AND
- c.
EITHER of the following conditions exist:
- 1.
(Site-specific indication of an inability to adequately remove heat from the core)
- 2.
(Site-specific indication of an inability to adequately remove heat from the RCS)
MS3 Initiating Condition:
Inability to shutdown the reactor causing a challenge to RPV water level or RCS heat removal.
Operating Mode Applicability:
1,2 Emergency Action Level (EAL):
- 1. Automatic scram did not shutdown the reactor as indicated by Reactor Power
> 2%.
AND
- 2. ALL manual / ARI actions to shutdown the reactor have been unsuccessful as indicated by Reactor Power > 2%.
AND
- 3. EITHER of the following conditions exist:
RPV water level cannot be restored and maintained > -20 inches TAF.
" Heat Capacity Temperature Limit (EMG-3200.02 Fig. F) exceeded.
D No Change M
Difference 7
Deviation
- 1) Listed site specific indications to ensure timely classification.
- 2) Mode 2 included in operating mode applicability as per developer notes.
NEI 99-01 Rev 6
[
Proposed EAL Justification SA5 MA3 Initiating Condition: ALERT Automatic or manual (trip [PVVR] / scram [BWR]) fails to shutdown the reactor, and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor.
Operating Mode Applicability:
Power Operation Example Emergency Action Levels:
Note:
A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.
I.
- a.
An automatic (trip [PWR] / scram [SWR]) did not shutdown the reactor.
AND
- b.
Manual action taken at the reactor control consoles are not successful in shutting down the reactor.
Initiating Condition:
Automatic or manual scram fails to shutdown the reactor, and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor.
Operating Mode Applicability:
1,2 Emergency Action Level (EAL):
Note:
A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.
- 1. Automatic or manual scram did not shutdown the reactor as indicated by Reactor Power > 2%.
AND
- 2. Manual / ARI actions taken at the Reactor Console are not successful in shutting down the reactor as indicated by Reactor Power > 2%.
Dý No Change M
Difference F
Deviation
- 1) Listed site specific indications to ensure timely classification.
- 2) Mode 2 included in operating mode applicability as per developer notes.
NEI 99-01 Rev 6 Proposed EAL Justification SU5 Initiating Condition: UNUSUAL EVENT Automatic or manual (trip [PWR] / scram [BWR]) fails to shutdown the reactor.
Operating Mode Applicability:
Power Operation Example Emergency Action Levels:
(1 or 2)
Note:
A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.
- 1.
- a.
An automatic (trip [PWRJ / scram [BWR]) did not shutdown the reactor.
AND
- b.
A subsequent manual action taken at the reactor control consoles is successful in shutting down the reactor.
- 2.
- a.
A manual scram ([PWR] I scram [BWRJ) did not shutdown the reactor.
AND
- b.
EITHER of the following:
- 1.
A subsequent manual action taken at the reactor control consoles is successful in shutting down the reactor.
- 2.
A subsequent automatic (trip [PWRJ / scram [BWR]) is successful in shutting down the reactor.
MU3 Initiating Condition:
Automatic or manual scram fails to shutdown the reactor.
Operating Mode Applicability:
H No Change Fq Difference
[
Deviation
- 1) Listed site specific indications to ensure timely classification.
- 2) Mode 2 included in operating mode applicability as per developer notes.
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 rmds or implementation of boron injection strategies.
- a. Automatic scram did not shutdown the reactor as indicated by Reactor Power > 2%.
AND
- b. Subsequent manual I ARI action taken at the Reactor Console is successful in shutting down the reactor.
- 2.
- a. Manual scram did not shutdown the reactor as indicated by Reactor Power > 2%.
AND
- b. EITHER of the following:
- 1. Subsequent manual / ARI action taken at the Reactor Console is successful in shutting down the reactor.
- 2. Subsequent automatic scram / ARI is successful in shutting down the reactor.
Page 35 of 66
NEt 99-01 Rev 6 Proposed EAL Justification SA2 Initiating Condition: ALERT UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress.
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels:
Note:
The Emergency Director should declare the Alert promptly upon determining that 15 minutes has been exceeded, or will likely be
- exceeded,
- 1. a. An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the Control Room for 15 minutes or longer.
[see table below]
[ BWR parameter list]
[PWR parameter list]
Reactor Power Reactor Power RPV Level RCS Level RPV Pressure RCS Pressure Primary Containment Pressure In Core/Core Exit Temperature Levels in at least (site specific Suppression Pool Level number) steam generators nPool Temperature Steam Generator Auxiliary or Suppression PEmergency Feed Water Flow AND
- b. Any of the following transient events in progress.
Automatic or Manual runback greater than 25% thermal reactor power Electrical load rejection greater than 25% full electrical load Reactor Scram [BWR] / trip [PWR]
ECCS (SI) actuation Thermal power oscillations greater than 10% [BWR]
MA4 Initiating Condition:
UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress.
Operating Mode Applicability:
1.2,3 Emergency Action Level (EAL):
Note:
The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1.
UNPLANNED event results in the inability to monitor ANY Table M1 parameters from within the Control Room for > 15 minutes.
M No Change I
Difference FIDeviation Table M1 Control Room Parameters Reactor Power RPV Water Level RPV Pressure Drywell Pressure Torws Water Level Torus Water Temperature AND
- 2.
ANY Table M2 transient in progress.
Table M2 Significant Transients Turbine Trip Reactor Scram ECCS Actuation Thermal power change > 25%
Thermal Power oscillations > 10%
Page 36 of 66
NEI 99-01 Rev 6 Proposed EAL Justification SU2 Initiating Condition: UNUSUAL EVENT UNPLANNED loss of Control Room indications for 15 minutes or longer.
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels:
Note:
The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.
An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the Control Room for 15 minutes or longer.
[see table below]
[ SWR parameter list]
[PWR parameter list]
Reactor Power Reactor Power RPV Level RCS Level RPV Pressure RCS Pressure Primary Containment Pressure In Core/Core Exit Temperature Levels in at least (site specific Suppression Pool Level number) steam generators Steam Generator Auxiliary or Suppression Pool Temperature Emergency Feed Water Flow 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 MI Control Room Parameters Reactor Power RPV Water Level RPV Pressure Drywell Pressure Torus Water Level Torus Water Temperature W
No Change FIDifference FIDeviation Page 37 of 66
NEI 99-01 Rev 6 Proposed EAL Justification SA9 MA5 Initiating Condition: ALERT Initiating Condition: ALERT Hazardous event affecting a SAFETY SYSTEM needed for the current operating mode.
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels:
- 1.
- a.
The occurrence of ANY of the following hazardous events:
Seismic event (earthquake)
Internal or external flooding event High winds or tornado strike FIRE EXPLOSION (site-specific hazards)
Other events with similar hazard characteristics as determined by the Shift Manager AND b
EITHER of the following:
- 1.
Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM needed for the current operating mode.
- 2.
The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure needed for the current operating mode.
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.
- b.
The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure required by Technical Specifications for the current operating mode.
- c.
A seismic event required a manual reactor scram per ABN-38, Station Seismic Event.
H--
No Change W
Difference FIDeviation 1 ) No additional site specific hazards noted
- 2) Changed the word "needed" to "required" in the IC and "required by Technical Specification" in the EAL to be consistent with terminology used by operators and minimize confusion.
Page 38 of 66
0 NEI 99-01 Rev 6 Proposed EAL Justification SU4 Initiating Condition: UNUSUAL EVENT RCS leakage for 15 minutes or longer.
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels:
(1 or 2 or 3)
Note:
The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.
- 1.
RCS unidentified or pressure boundary leakage greater than (site-specific value) for 15 minutes or longer.
- 2.
RCS identified leakage greater than (site-specific value) for 15 minutes or longer
- 3.
Leakage from the RCS to a location outside containment greater than 25 gpm for 15 minutes or longer MUB 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.
- 2. RCS identified leakage in the Drywell >25 gpm for-> 15 minutes.
- 3. Leakage from the RCS to a location outside the Drywell >25 gpm for
> 15 minutes.
F-1 No Change Difference Deviation 1
) Listed site specific values to ensure timely classification.
- 2) in EAL #3 Changed wording from containment to Drywell for clarity to better define the primary containment structure.
- 3. Without this wording would have been in EAL #1 or #2 concurrent with #3. With the added wording each EAL can be called separately.
Page 39 of 66
NEI 99-01 Rev 6 Initiating Condition: UNUSUAL EVENT Loss of all onsite or offsite communications capabilities Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels:
(1 or 2 or 3)
- 1. Loss of ALL of the following onsite communication methods:
(site-specific list of communications methods)
- 2.
Loss of ALL of the following ORO communication methods:
(site-specific list of communications methods)
- 3.
Loss of ALL of the following NRC communication methods:
(site-specific list of communications methods)
Proposed EAL Justification SU6 Initiating Condition:
MU7 W
No Change F IDifference FIDeviation
- 1) Listed site specific communication methods to ensure timely classification.
Loss of all onsite or offsite communication capabilities.
Operating Mode Applicability:
1,2,3 Emergency Action Level (EAL):
- 1. Loss of all Table M3 Oneite communications capability affecting the ability to perform routine operations.
- 2.
Loss of all Table M3 Offsite communication capability affecting the ability to perform offsite notifications.
- 3.
Loss of all Table M3 NRC communication capability affecting the ability to perform NRC notifications.
Table M3 Communications Capabili ty System Onslte Offsite NRC Plant Paging System X
Station Radio X
Conventional Telephone lines X
X X
Satellite Phone system X
X X
NARS X
HPN X
X ENS X
X Page 40 of 66
NEI 99-01 Rev 6 Proposed EAL I
Justification CA2 Initiating Condition: ALERT Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or longer.
Operating Mode Applicability:
Cold Shutdown, Refueling, Defueled Example Emergency Action Levels:
Note:
The Emergency Director should declare the Alert promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.
Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses) for 15 minutes or longer.
CAI Initiating Condition:
Loss of all offsite and onsite AC power to emergency buses for 15 minutes or longer.
Operating Mode Applicability:
3,4, 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. Loss of all offsite AC power to 4160V Buses 1C and 1D.
AND
- 2.
Failure of EDG-1 and EDG-2 Emergency Diesel Generators to supply power to 4160V Buses 1C and 1D..
AND
- 3.
Failure to restore power to at least one 4160V bus (1C or 1D) in < 15 minutes from the time of loss of both offsite and onsite AC power.
E No Change 1-1 Difference 1--
Deviation
- 1) Listed site specific equipment to ensure timely classification.
Page 41 of66
NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition: UNUSUAL EVENT Initiating Condition:
No Change Difference Deviation Loss of all but one AC power source to emergency buses for 15 minutes or longer.
Loss of all but one AC power source to emergency buses for 15 minutes or
- 1) Listed site specific equipment to ensure timely classification.
Operating Mode Applicability:
longer.
Cold Shutdown, Refueling, Defueled Operating Mode Applicability:
Example Emergency Action Levels:
3,4, D Note: The Emergency Director should declare the Unusual Event promptly upon Emergency Action Level (EAL):
determining that 15 minutes time has been exceeded, or will likely be exceeded.
Note:
- 1.
- a.
AC power capability to (site-specific emergency buses) is reduced to a The Emergency Director should declare the event promptly upon determining single power source for 15 minutes or longer, that the applicable time has been exceeded, or will likely be exceeded.
AND
- 1.
AC power capability to 4160V Buses 1C and 1D reduced to only one of
- b.
Any additional single power source failure will result in loss of all AC the following power sources for > 15 minutes.
power to SAFETY SYSTEMS.
Startup Transformer SA Startup Transformer SB EDG-1 Emergency Diesel Generator EDG-2 Emergency Diesel Generator AND
- 2.
ANY additional single power source failure will result in a loss of all AC power to SAFETY SYSTEMS.
Page 42 of 66
NEI 99-01 Rev 6 Proposed EAL Justification CA6 Initiating Condition - ALERT Hazardous event affecting SAFETY SYSTEM needed for the current operating mode.
Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels:
- 1. a.
The occurrence of ANY of the following hazardous events:
Seismic event (earthquake)
Internal or external flooding event High winds or tornado strike FIRE EXPLOSION (site-specific hazards)
Other events with similar hazard characteristics as determined by the Shift Manager AND
- b.
EITHER of the following:
- 1.
Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM needed for the current operating mode.
- 2.
The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure needed for the current operating mode.
CA2 Initiating Condition:
Hazardous event affecting SAFETY SYSTEM required for the current operating mode.
Operating Mode Applicability:
3,4 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.
- b.
The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure required by Technical Specifications for the current operating mode.
- c.
A seismic event required a manual reactor scram per ABN-38, Station Seismic Event.
H No Change
-X-Difference Deviation
- 1) No additional site specific hazards noted
- 2) Changed the word "needed" to "required" in the IC and "required by Technical Specification" in the EAL to be consistent with terminology used by operators and minimize confusion.
Page 43 of 66
NEI 99-01 Rev 6 Proposed EAL Justification CU4 Initiating Condition: UNUSUAL EVENT Loss of Vital DC power for 15 minutes or longer.
Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels:
Note:
The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.
Indicated voltage is less than (site-specific bus voltage value) on required Vital DC buses for 15 minutes or longer.
CU3 Initiating Condition:
Loss of Vital DC power for 15 minutes or longer.
Operating Mode Applicability:
3,4 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 < 115 VDC on required 125 VDC battery busses B and C for > 15 minutes.
E-No Change E
Difference 1
Deviation
- 1) Listed site specific voltage and equipment to ensure timely classification.
- 2) Removed the word "indicated" this will allow for an indication problem to not cause confusion on the need to declare.
Page 44 of 66
NEI 99-01 Rev 6 1
Proposed EAL Justification CUS Initiating Condition: UNUSUAL EVENT Loss of all onsite or offsite communications capabilities Operating Mode Applicability:
Cold Shutdown, Refueling, Defuled Example Emergency Action Levels:
(1 or 2 or 3)
- 1. Loss of ALL of the following onsite communication methods:
(site-specific list of communications method
- 2.
Loss of ALL of the following ORO communications s) methods:
(site-specific list of communications methods)
- 3.
Loss of ALL of the following NRC communications methods:
(site-specific list of communications methods)
CU4 Initiating Condition:
Loss of all onsite or offsite communication capabilities.
Operating Mode Applicability:
3,4, D Emergency Action Level (EAL):
- 1. Loss of all Table C1 Onsite communications capability affecting the ability to perform routine operations.
- 2.
Loss of all Table C1 Offsite communication capability affecting the ability to perform offsite notifications.
- 3. Loss of all Table C1 NRC communication capability affecting the ability to perform NRC notifications.
No Change D:1 Difference 1:
Deviation
- 1) Listed site specific communications methods to ensure timely classification Table C1 Communications Capabi ity System Onsite Offsits NRC Plant Paging System X
Station Radio X
Conventional Telephone lines X
X X
Satellite Phone system X
X X
NARS X
HPNX X
ENS 2X,
ýX Page 45 of 66
NEI 99-01 Rev 6 Proposed EAL Justification CA3 CA5 NOCag Difrne Deato Initiating Condition: ALERT Initiating Condition:
C No Change Difference Deviation Inability to maintain the plant in cold shutdown.
Inability to maintain plant in cold shutdown.
- 1) Listed site specific Technical Specification cold shutdown temperature limit and Operating Mode Applicability:
Operating Mode Applicability:
site-specific pressure reading to ensure timely classification.
Cold Shutdown, Refueling 3, 4 Example Emergency Action Levels:
(1 or 2)
Emergency Action Level (EAL):
Note:
The Emergency Director should declare the Alert promptly upon Note:
determining that the applicable has been exceeded, or will likely be The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1.
UNPLANNED increase in RCS temperature to greater than (site-specific Technical Specification cold shutdown temperature limit) for greater than the duration specified in the following table.
- 1. UNPLANNED rise in RCS temperature > 212*F due to loss of decay
- 2.
UNPLANNED RCS pressure increase greater than (site-specific pressure heat removal for > Table C2 duration.
reading). (This EAL does not apply during water-solid plant conditions.
[PWR])
Table C2 RCS Heat-up Duration Thresholds Table: RCS Heat-up Duration Thresholds RCS Status Containment Closure Heat-up Duration RCS Status Containment Closure Heat-up Duration Status Status Intact Not Applicable 60 minutes*
Intact (but not Established 20 minutes*
RCS Reduced Not Applicable 60 minutes*
Not Intact Inventory [PWR])
Not Intact (or at Established 20 minutes*
Not Established 0 minutes reduced inventory
[PWR])
Not Established 0 minutes
- If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, then EAL #1 is not If an RCS heat removal system is in operation within this time frame and applicable.
RCS temperature is being reduced, the EAL is not applicable.
- 2. UNPLANNED RPV pressure rise> 10 psig as a result of temperature rise due to loss of decay heat removal.
Page 46 of 66
[
Justification CU3 Initiating Condition: UNUSUAL EVENT UNPLANNED increase in RCS temperature.
Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels:
(1 or 2)
Note:
The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.
- 1.
UNPLANNED increase in RCS temperature to greater than (site-specific Technical Specification cold shutdown temperature limit).
[SWR]) level indication for 15 minutes or longer.
CUs Initiating Condition:
UNPLANNED rise in RCS temperature.
Operating Mode Applicability:
3,4 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> 212*F due to loss of decay heat removal.
- 2.
Loss of the following for >15 minutes.
ALL RCS temperature indications AND ALLRPV level indications H-1 No Change E
Difference FIDeviation
- 1) Listed site specific Technical Specification cold shutdown temperature limit to ensure timely classification.
- 2) Changed the word increase to rise in the initiating condition to be consistent with operations language and training.
Page 47 of 66
NEI 99-01 Rev 6 Proposed EAL Justification CG1 CG6 Initiating Condition: GENERAL EMERGENCY Loss of (reactor vessel/RCS (PWRI or RPV [BWR]) inventory affecting fuel clad integrity with containment challenged.
Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels:
(1 or 2)
Note:
The Emergency Director should declare the General Emergency promptly upon determining that 30 minutes time has been exceeded, or will likely be exceeded.
- 1. a. (Reactor vessel/RCS [PWRj or RPV [BWR]) vessel level less than (site-specific level) for 30 minutes or longer.
AND
- b. ANY indication from the Containment Challenge Table
- 2.
a.. (Reactor vessel/RCS [PWR] or RPV [BWRI) vessel level cannot be monitored for 30 minutes or longer.
AND
- b. Core uncovery is indicated by ANY of the following:
(Site-specific radiation monitor) reading greater than (site-specific value)
Erratic source range monitor indication [PWR]
UNPLANNED increase in (site-specific sump and/or tank levels) of sufficient magnitude to indicate core uncovery (Other site-specific indications)
AND
- c. ANY indication from the Containment Challenge Table).
Initiating Condition:
Loss of reactor vessel / RCS inventory affecting fuel clad integrity with containment challenged.
Operating Mode Applicability:
3,4 Emergency Action Level (EAL):
Note:
F No Change W
Difference FIDeviation
- 1) Listed site specific levels, radiation monitors, and sumps and tanks to ensure timely classification.
- 2) Listed Explosive mixture in the Containment Challenge Table to ensure timely classification.
- 3) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keeping with current EAL wording.
The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
AND
- b. Any Containment Challenge Indication (Table C4)
- 2.
- a. RPV water level unknown for > 30 minutes.
AND
- b. Core uncovery is indicated by ANY of the following:
- 1.
Table C3 indications of a sufficient magnitude to indicate core uncovery.
- 2.
Refuel Floor Area Radiation Monitor C-1 0, North Wall, reading
>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 Torus level rise*
UNPLANNED vessel make up rate rise*
Observation of leakage or inventory loss
- Rise in level is attributed to a loss of RPV inventory.
Table: Containment Challenge Table CONTAINMENT CLOSURE not established*
(Explosive mixture) exists inside containment UNPLANNED increase in containment pressure Secondary containment radiation monitor reading above (site-specific value) [BWR]
- if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency is nnt ronl,rorl not re uired I
Table C4 Containment Challenge Indications Primary Containment Hydrogen Concentration > 6% and Oxygen Concentration > 6%
UNPLANNED rise in containment pressure CONTAINMENT CLOSURE not established*
ANY Secondary Containment radiation monitor > EMG-3200.11 Maximum Safe (Table 12).
- 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.
Ji.
LI _____________________________________________________________________________
Page 48 of 66
NEI 99-01 Rev 6 Proposed EAL Justification CS1 Initiating Condition: SITE AREA EMERGENCY Loss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory affecting core decay heat removal capability.
Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels:
(1 or 2 or 3)
Note:
The Emergency Director should declare the Site Area Emergency promptly upon determining that 30 minutes time has been exceeded, or will likely be exceeded.
- 1. a. CONTAINMENT CLOSURE not established.
AND
- b. (Reactor vessel/RCS [PWR] or RPV [BWR]) level less than (site-specific level).
- 2.
- a. CONTAINMENT CLOSURE established.
AND
- b. (Reactor vessel/RCS [PWR] or RPV [BWR]) level less than (site-specific level).
- 3.
- a. (Reactor vessel/RCS [PVVR] or RPV [BWMR) level cannot be monitored for 30 minutes or longer.
AND
- b. Core uncovery is indicated by ANY of the following:
(Site-specific radiation monitor) reading greater than (site-specific value)
Erratic source range monitor indication [PWR]
UNPLANNED increase in (site-specific sump and/or tank levels) of sufficient magnitude to indicate core uncovery (Other site-specific indications)
CS6 Initiating Condition:
Loss of reactor vessel I RCS inventory affecting core decay heat removal capabilities.
Operating Mode Applicability:
3,4 Emergency Action Level (EAL):
Note:
D No Change E
Difference 1
Deviation
- 1) Listed site specific values for level, radiation monitors, and sumps and tanks to ensure timely classification.
- 2) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keeping with current EAL wording.
The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. With CONTAINMENT CLOSURE not established, RPV water level
< 56 inches TAF.
- 2.
With CONTAINMENT CLOSURE established, RPV water level
< 0 inches TAF.
- 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 Refuel Floor Area Radiation Monitor C-10. North Wall, reading
>3 R/hr.
Table C3 Indications of RCS Leakage UNPLANNED floor or equipment sump level rise*
UNPLANNED Torus level rise*
UNPLANNED vessel make up rate rise*
Observation of leakage or inventory loss
- Rise in level is attributed to a loss of RPV inventory.
Page 49 of 66
0 NEI 99-01 Rev 6 1
Proposed EAL Justification CA1 Initiating Condition: ALERT Loss of (reactor vessel/RCS [PWR] or RPV [BNR]) inventory Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)
Note:
The Emergency Director should declare the Alert promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.
- 1.
Loss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory as indicated by level less than (site-specific level).
- 2.
- a. (Reactor vessel/RCS [PWR] or RPV [BWR]) level cannot be monitored for 15 minutes or longer AND
- b. UNPLANNED increase in (site-specific sump and/or tank) levels due to a loss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory.
CA6 Initiating Condition:
Loss of reactor vessel / RCS 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.
Loss of RPV inventory as indicated by level < 86 inches TAF.
- 2.
- a. RPV 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 Torus level rise*
UNPLANNED vessel make up rate rise*
Observation of leakage or inventory loss
- Rise in level is attributed to a loss of RPV inventory.
D ]
No Change FW Difference 1:
Deviation
- 1) Listed site specific levels, and sumps and tanks to ensure timely classification.
- 2) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keeping with current EAL wording.
Page 50 of 66
NEI 99-01 Rev 6 Proposed EAL Justification NEI199-01 Rev 6 Proposed EAL Justification
-f 4
Cul Initiating Condition: UNUSUAL EVENT UNPLANNED loss of (reactor vessel/RCS [PWRj or RPV [BWR]) inventory for 15 minutes or longer.
Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels:
(1 or 2)
Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.
- 1. UNPLANNED loss of reactor coolant results in (reactor vessel/RCS
[PWR] or RPV [BWR]) level less than a required lower limit for 15 minutes or longer.
- 2. a. (Reactor vessel/RCS [P,1R] or RPV [BWRI) level cannot be monitored.
AND
- b. UNPLANNED increase in (site-specific sump and/or tank) levels.
CU6 Initiating Condition:
UNPLANNED loss of reactor vessel / RCS 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 RPV level above the procedurally established lower limit for
> 15 minutes.
- 2. a. RPV 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 Torus level rise*
UNPLANNED vessel make up rate rise*
Observation of leakage or inventory loss
- Rise in level is attributed to a loss of RPV inventory.
D -] No Change E
Difference D: Deviation
- 1) Described "a required lower limit" as a procedurally established lower limit, and listed site specific sumps and tanks to ensure timely classification.
- 2) Worded "cannot be monitored" as unknown to ensure clarity for instances when the indicator is working but is over/under ranged. This is also in keeping with current EAL wording.
Page 51 of 66
NEI 99-01 Rev 6 Proposed EAL Justification HGI HGI m
m-Initiating Condition: GENERAL EMERGENCY Initiating Condition:
Li No Change
[jj Difference Deviation HOSTILE ACTION resulting in loss of physical control of the facility.
HOSTILE ACTION resulting in loss of physical control of the facility.
- 1) List site security shift supervision as Security Force.
- 2) Added descriptors to better explain each safety function and allow for a timely Operating Mode Applicability:
Operating Mode Applicability:
classification.
All 1,2,3,4, D Example Emergency Action Levels:
Emergency Action Level (EAL):
- 1.
- a. A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the (site-specific security shift supervision).
- 1.
A notification from the Security Force that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA.
AND AND
- 2.
- a.
ANY Table Hi safety function cannot be controlled or maintained.
- b. EITHER of the following:
- 1. ANY of the following safety functions cannot be controlled or
- b.
Damage to spent fuel has occurred or is IMMINENT maintained.
Reactivity control Table H1 Safety Functions Core cooling [PVvR] / RPV water level [BWR]
Reactivity Control RCS heat removal (ability to shutdown the reactor and keep it shutdown)
- RPV Water Level (ability to cool the core)
- 2. Damage to spent fuel has occurred or is IMMINENT
- RCS Heat Removal (ability to maintain a heat sink)
Page 52 of 66
NEI 99-01 Rev 6 1
Proposed EAL Justification HSI Initiating Condition: SITE AREA EMERGENCY HOSTILE ACTION within the Protected Area.
Operating Mode Applicability:
All Example Emergency Action Levels:
A HOSITLE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the (site-security shift supervision).
HSI Initiating Condition:
HOSTILE ACTION within the Protected Area.
F No Change
-IDifference FIDeviation
- 1) List site security shift supervision as Security Force.
Operating Mode Applicability:
1,2,3,4, D Emergency Action Level (EAL):
A notification from the Security Force that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA.
Page 53 of 66
NEI 99-01 Rev 6 HA1 Initiating Condition: ALERT HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.
Operating Mode Applicability:
All Example Emergency Action Levels:
(t or 2)
- 1.
A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the (site-specific security shift supervision).
- 2.
A validated notification from NRC of an aircraft attack threat within 30 minutes of the site.
Proposed EAL Justification
-+
HA1 Initiating Condition:
HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.
Operating Mode Applicability:
1,2, 3,4, D Emergency Action Level (EAL):
- 1.
A validated notification from NRC of an aircraft attack threat < 30 minutes from the site.
- 2.
Notification by the Security Force that a HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLED AREA.
M No Change FIDifference FIDeviation
- 1) List site security shift supervision as Security Force.
Page 54 of 66
NEI 99-01 Rev 6 Proposed EAL Justification HUt HlUl 1F1 Initiating Condition: UNUSUAL EVENT Initiating Condition:
LiJ No Change M* Difference FIDeviation Confirmed SECURITY CONDITION or threat.
Confirmed SECURITY CONDITION or threat.
1 ) List site security shift supervision as Security Force.
Operating Mode Applicability:
M2)
Further described credible security threat through listing a site specific Operating Mode Applicability:
procedure.
All 1,2,3,4, D Example Emergency Action Levels:
(1 or 2 or 3)
Emergency Action Level (EAL):
- 1.
A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the (site-specific security shift supervision).
- 1.
Notification of a credible security threat directed at the site as determined per SY-AA-101-132, Security Assessment and Response to Unusual Activities.
- 2.
Notification of a credible security threat directed at the site.
- 3.
A validated notification from the NRC providing information of an aircraft
- 2.
A validated notification from the NRC providing information of an aircraft
- threat, threat.
- 3.
Notification by the Security Force of a SECURITY CONDITION that does not involve a HOSTILE ACTION.
Page 55 of 66
NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition: SITE AREA EMERGENCY Initiating Condition:
Li No Change F] Difference LJDeviation Inability to control a key safety function from outside the Control Room.
Inability to control a key safety function from outside the Control Room.
- 1) EAL uses the site specific Control Room evacuation procedures to effectively list all of the alternate locations, panels, and stations requested by the developer notes. This would be the procedures the Control Room would Operating Mode Applicability:
Operating Mode Applicability:
enter should such an event occur, this allows for greater clarity as to when this EAL would apply than if each panel and station used in alternate shutdown All 1, 2, 3, 4, D were to be listed,
- 2) Added descriptors to better explain each safety function and allow for a Example Emergency Action Levels:
(1 and 2)
Emergency Action Level (EAL):
timely classification.
Note: The Emergency Director should declare the Site Area Emergency Note:
promptly upon determining that (site-specific number of minutes) has been
- 3) Changed "An event" to" A Control Room evacuation" to remove confusion if exceeded, or will likely be exceeded.
The Emergency Director should declare the event promptly upon determining that partial plant control was transferred to outside the control room with the control the applicable time has been exceeded, or will likely be exceeded.
room still manned, due to testing or equipment failure.
- 1.
An event has resulted in plant control being transferred from the Control Room to (site-specific remote shutdown panels and local control stations).
I A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per ABN-30 Control Room Evacuation.
- 2.
Control of ANY of the following key safety functions is not reestablished AND within (site-specific number of minutes).
- 2. Control of ANY Table H1 key safety function is not reestablished in < 15 minutes.
Reactivity control Table HI Safety Functions Core cooling [PWR] / RPV water level [BW4R RCS heat removal Reactivity Control (ability to shutdown the reactor and keep it shutdown)
- RPV Water Level (ability to cool the core)
- RCS Heat Removal (ability to maintain a heat sink)
Page 56 of 66
NEI 99-01 Rev 6 Proposed EAL Justification HA6 HA2 Initiating Condition: ALERT Initiating Condition:
[j No Change I--
Difference
[
Deviation Control Room evacuation resulting in transfer of plant control to alternate locations.
Control Room evacuation resulting in transfer of plant control to alternate locations.
- 1) EAL uses the site specific Control Room evacuation procedures to effectively list all of the alternate locations, panels, and stations requested by the developer notes. This would be the procedures the Control Room would enter should such an Operating Mode Applicability:
Operating Mode Applicability:
event occur, this allows for greater clarity as to when this EAL would apply than if each panel and station used in alternate shutdown were to be listed, All 1,2, 3, 4, D
- 2) Changed "An event" to" A Control Room evacuation" to remove confusion if partial plant control was transferred to outside the control room with the control Example Emergency Action Levels:
Emergency Action Level (EAL):
room still manned, due to testing or equipment failure.
An event has resulted in plant control being transferred from the Control Room to A Control Room evacuation has resulted in plant control being transferred from (site-specific remote shutdown panels and local control stations).
the Control Room to alternate locations per ABN-30 Control Room Evacuation.
Page 57 of 66
NEI 99-01 Rev 6 Proposed EAL Justification HU4 HU3 Initiating Condition: UNUSUAL EVENT FIRE potentially degrading the level of safety of the plant.
Operating Mode Applicability:
Initiating Condition:
FIRE potentially degrading the level of safety of the plant.
Operating Mode Applicability:
1,2, 3,4, D M No Change FIDifference FIDeviation
- 1) Listed site specific list of plant rooms or areas that contain SAFETY SYSTEM equipment to ensure timely classification.
All Example Emergency Action Levels:
(1 or 2 or 3 or 4)
Note:
The Emergency Director should declare the Unusual Event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
1
- a.
A FIRE is NOT extinguished within 15-minutes of ANY of the following FIRE detection indications:
Report from the field (i.e., visual observation)
Receipt of multiple (more than 1) fire alarms or indications Field verification of a single fire alarm AND
- b.
The FIRE is located within ANY of the following plant rooms or areas:
(site-specific list of plant rooms or areas)
- 2.
- a.
Receipt of a single fire alarm (i.e., no other indications of a FIRE).
AND
- b.
The FIRE is located within ANY of the following plant rooms or areas:
(site-specific list of plant rooms or areas)
AND
- c. The existence of a FIRE is not verified within 30-minutes of alarm receipt.
- 3.
A FIRE within the plant or ISFS1 [for plants with an ISFSI outside the plant Protected Area] PROTECTED AREA not extinguished within 60-minutes of the initial report, alarm or indication.
- 4.
A FIRE within the plant or ISFSI [for plants with an ISFSI outside the plant Protected Area] PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.
Emergency Action Level (EAL):
Note:
The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1.
A FIRE in ANY Table H2 area is not extinguished in < 15-minutes of ANY of the following FIRE detection indications:
Report from the field (i.e., visual observation)
Receipt of multiple (more than 1) fire alarms or indications Field verification of a single fire alarm Table H2 Vital Areas Reactor Building (when inerted the Drywell is exempt) 4160V Switchgear Rooms (1C and 1D)
Control Room Complex (MOB, Upper and Lower Cable Spreading Rooms)
Main Transformer/Condensate Transfer Pad Intake Structure
- 1 EDG Vault
- 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.
- 3.
A FIRE within the plant or ISFSI PROTECTED AREA not extinguished in
< 60 minutes of the initial report, alarm or indication.
- 4.
A FIRE within the plant or ISFSI PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.
Page 58 of 66
NEI 99-01 Rev 6 Proposed EAL Justification HU2 HU4 Initiating Condition: UNUSUAL EVENT Initiating Condition:
D No Change M
Difference ij]
Deviation Seismic event greater than OBE levels.
Seismic event greater than OBE levels.
- 1) Used Alternate developer notes allowed wording since specific Control Room indication of a seismic event > OBE is not available.
Operating Mode Applicability:
Operating Mode Applicability:
All 1,2,3,4, D Example Emergency Action Levels:
Emergency Action Level (EAL):
Seismic event greater than Operating Basis Earthquake (OBE) as indicated by:
- a.
(site-specific indication that a seismic event met or exceeded ORE limits)
Seismic event > Operating Basis Earthquake (OBE) as indicated by:
- 1. Control Room personnel feel an actual or potential seismic event.
AND
- 2. The occurrence of a seismic event has resulted in a spurious Reactor Scram or required a Plant shutdown in accordance with ABN-38, Station Seismic Event.
Page 59 of 66
NEI 99-01 Rev 6
[
Proposed EAL I
Justification HA5 Initiating Condition: ALERT Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.
Operating Mode Applicability:
All Example Emergency Action Levels:
Note: If the equipment in the listed room or area was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted.
1.
- a.
Release of a toxic, corrosive, asphyxiant or flammable gas into any of the following plant rooms or areas:
(site-specific list of plant rooms or areas with entry-related mode applicability identified)
AND
- b.
Entry into the room or area is prohibited or impeded.
HA5 Initiating Condition:
Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.
Operating Mode Applicability:
1,2,3,4, D Emergency Action Level JEAL):
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 Applicability Area Entry Related Mode Applicability Reactor Building*
Modes 3 and 4
.Areas required to establish shutdown cooling AND
- 2.
Entry into the room or area is prohibited or impeded E
No Change FIDifference I
Deviation
- 1) Listed plant specific rooms and areas with entry related mode applicability to ensure timely classification.
Page 60 of 66
S NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition: UNUSUAL EVENT Hazardous Event Operating Mode Applicability:
All Example Emergency Action Levels:
(1 or 2 or 3 or 4)
Note:
EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.
I.
A tornado strike within the PROTECTED AREA.
- 2. Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component needed for the current operating mode.
- 3. Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).
- 4.
A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles,
- 5. (Site-specific list of natural or technological hazard events)
HU6 Initiating Condition:
Hazardous Event Operating Mode Applicability:
1,2,3,4, 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.
- 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.
- 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).
- 4. A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.
- 5. Abnormal Intake Structure level, as indicated by EITHER:
> 4.5 ft. MSL (> 4.25 psig on PI-533-1172 and PI-533-1173 or > 4.5 ft MSL on CR-423-11 pt 24 and pt 23).
- b. < -3.0 ft. MSL L 0.95 psig on PI-533-1172 and PI-533-1173 or <
-3.0 ft MSL on CR-423-11 pt 24 and pt 23).
MSL = Mean Sea Level F ] No Change FIDifference FIDeviation
- 1) Included River water level as part of the site specific list of natural or technological hazard events. The EAL values selected are the current Approved UE EAL values.
- 2) Changed the word "needed" to "required by Technical Specifications" in the EAL to be consistent with terminology used by operators and minimize confusion.
Page 61 of 66
NEI 99-01 Rev 6 Proposed EAL Justification HG8 HG7 mF Initiating Condition: GENERAL EMERGENCY Initiating Condition:
[-'
No Change F
Difference L
Deviation Other conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrant declaration of a General Emergency.
declaration of a General Emergency.
Operating Mode Applicability:
Operating Mode Applicability:
Aul 1,2,3,4, D Example Emergency Action Levels:
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 Other conditions exist which in the judgment of the Emergency Director indicate substantial core degradation or melting with potential for loss of containment that events are in progress or have occurred which involve actual or IMMINENT integrity or HOSTILE ACTION that results in an actual loss of physical control of substantial core degradation or melting with potential for loss of containment the facility. Releases can be reasonably expected to exceed EPA Protective Action integrity or HOSTILE ACTION that results in an actual loss of physical control of Guideline exposure levels off-site for more than the immediate site area.
the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels off-site for more than the immediate site area..
Page 62 of 66
NEI 99-01 Rev 6 Proposed EAL Justification HS8 HS7mm Initiating Condition: SITE AREA EMERGENCY Initiating Condition:
L-'
No Change LJ Difference F
Deviation Other conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrant declaration of a Site Area Emergency.
declaration of a Site Area Emergency.
Operating Mode Applicability:
Operating Mode Applicability:
All 1,2,3,4, D Example Emergency Action Levels:
Emergency Action Level (EAL):
Other conditions exist which in the judgment of the Emergency Director indicate Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major thaents e
in the jud which Emerge a ctor indicate failures of plant functions needed for protection of the public or HOSTILE ACTION at events are in progress or have occurred which involve actual or likely major that results in intentional damage or malicious acts; (1) toward site personnel or tures of plant functions needed for protection of the public or HOSTILE ACTION equipment that could lead to the likely failure of or; (2) that prevent effective that coult ln to the licius aftsr (2) that peneltor access to equipment needed for the protection of the public. Any releases are not equipment that could lead to the likely failure of or; (2) that prevent effective expected to result in exposure levels which exceed EPA Protective Action access to equipment needed for the protection of the public. Any releases are not Guideline exposure levels beyond the site boundaryd expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.
Page 63 of 66
NEI 99-01 Rev 6 Proposed EAL Justification HA6 HA7 mmm Initiating Condition: ALERT Initiating Condition:
[-j No Change LJ Difference
[
Deviation Other conditions exist which in the judgment of the Emergency Director warrant Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert.
declaration of an Alert.
Operating Mode Applicability:
Operating Mode Applicability:
All 1,2, 3,4, D Example Emergency Action Levels:
Emergency Action Level (EAL):
Other conditions exist which in the judgment of the Emergency Director indicate Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve an actual or potential that evnts e
in phe cudred wh e
an actor pntial substantial degradation of the level of safety of the plant or a security event that that events are in progress or have occurred which involve an actual or potential involves probable life threatening risk to site personnel or damage to site substantial degradation of the level of safety of the plant or a security event that
~involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be involves probable life threatening risk to site personnel or damage to site limited to small fractions of the EPA Protective Action Guideline exposure levels, equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.
Page 64 of 66
NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition: UNUSUAL EVENT Initiating Condition:
L7i No Change LJ Difference Deviation Other conditions existing which in the judgment of the Emergency director warrant declaration of an UNUSUAL EVENT.
Other conditions existing which in the judgment of the Emergency director warrant declaration of an UNUSUAL EVENT.
Operating Mode Applicability:
Operating Mode Applicability:
All 1,2,3,4, D Example Emergency Action Levels:
Other conditions exist which in the judgment of the Emergency Director indicate Emergency Action Level (EAL):
that events are in progress or have occurred which indicate a potential Other conditions exist which in the judgment of the Emergency Director indicate degradation of the level of safety of the plant or indicate a security threat to facility that events are in progress or have occurred which indicate a potential protection has been initiated. No releases of radioactive material requiring offsite degradation of the level of safety of the plant or indicate a security threat to facility response or monitoring are expected unless further degradation of safety systems protection has been initiated. No releases of radioactive material requiring offsite occurs.
response or monitoring are expected unless further degradation of safety systems occurs.
Page 65 of 66
NEI 99-01 Rev 6 Proposed EAL Justification Initiating Condition: UNUSUAL EVENT E-HUI Initiating Condition:
E-HU D No Change Difference Deviation Damage to a loaded cask CONFINEMENT BOUNDARY.
Damage to a loaded cask CONFINEMENT BOUNDARY.
- 1) Listed 2x the site specific cask specific allowable radiation level as per Oyster Creek Generating Station ISFSI 10CFR72.212 Evaluation Rev. 5 Operating Mode Applicability:
Operating Mode Applicability:
- 2) Not all technical specification radiation readings were on contact, one is a All radiation reading at 3ft required by technical specification. Modified the EAL by 1,A23, 4, D removing the "on the surface" requirement, and required "a radiation reading" allowing for the technical specification 3ft reading to be added to the EAL.
Example Emergency Action Levels:
Emergency Action Level (EAL):
Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than (2 times the site-specific cask specific technical specification allowable radiation level) on the surface of the spent fuel Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by a cask.
radiation reading:
> 800mrlhr (gamma + neutron) 3 feet from the HSM surface OR
> 200mrlhr (gamma + neutron) outside the HSM door on centerline of DSC OR
> 4Omrlhr (gamma + neutron) end of shield wall exterior Page 66 of 66
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Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARGI Initiating Condition:
Release of gaseous radioactivity resulting in offsite dose greater than 1000 mRrem TEDE or 5000 mRrem thyroid CDE.
Operating Mode Applicability:
1,2,3,4, D Emergency Acton Level (EAL):
Notes:
- The Emergency Director should declare the GenReal Emergcc;y cvent 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 the applicable time4
.mnutes.
" Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.
" The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
(1)
Reading onj A NY Of the folloWing raidiationA monitorS greater-than the reading Shown for 15 minutes or longer:
(site specifici mnoniteR list and threshold values)
- 1. Readings on ANY Table RI Effluent Monitor > Table RI value for > 15 minutes:
Table R1 Effluent Monitor Thresholds Effluent Monitor General Emergency Main Stack RAGEMS 8.69 E+01 uCi/cc HRM OR 3.53 E-08 amps HRM Turbine Building RAGEMS 7.17 E-01 uCi/cc HRM HRM = High Range Monitor OR Month 20XX OCGS 3-1 EP-AA-1010 (Revision XX)
Ovster Creek Generatina Station Annex Exelon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS
- 2. Dose assessment using actual meteorology indicates doses at or beyond (site speGifie dose recePt9o poin)* the site boundary of EITHER:
II l i-lol eUrFVS reSUits !inaicato-A AT ;-9 I-t11 oryRG kmei roiwn to eoa(~OSpoe dese receptor p*oit):*.
Closed windAo doso rates greater than 1,000 mR'hr expeIted to continue for Anialyses-r of fiteld-Asur.ey samples indicate thyroid CDE greater than 5,000 mromA for one hou r of inh~alation.,
- 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.
- b. Analyses of field survey samples indicate > 5000 mRem CDE Thyroid for 60 minutes of inhalation.
Basis:
This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 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 mRrem while the 5000 mRfem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.
Month 20XX OCGS 3-2 EP-AA-1010 (Revision XX)
Oyster Creek Generating Station Annex Exelon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Classeific-ation based-on offluent monitor readings aassuswmes that a4 r1es path to the enyironwment-is-tetAb-ifished. If tho effluwent flow pact an offluon~t mon~itor is known to hav stopped duo to actions to olate the release path, then the efflu'ntmo nitreading is no longer valid for classificsation purposes.
Basis Reference(s):
- 1.
NEI 99-01 Rev 6, AG1
- 2.
EP-EAL-0610, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Oyster Creek Generating Station
- 3.
BNE Correspondence dated February 1, 2007
- 4.
CY-OC-170-301, Offsite Dose Calculation Manual for Oyster Creek
- 5.
EP-AA-1 10-200, Dose Assessment
- 6.
EP-AA-1 10-201, On Shift Dose Assessment Month 20XX OCGS 3-3 EP-AA-1010 (Revision XX)
f) ator rook rZonarnfin Atntinn Annoy Pyalnn "rla2r A~I@*~ar (~rn~k (~cn~rntinn ~t~*inn Anniiv Fv~Inn Nh uv~Ig~h2r Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARS1 Initiating Condition:
Release of gaseous radioactivity resulting in offsite dose greater than 100 mRfem TEDE or 500 mRrem thyroid CDE.
Operating Mode Applicability:
1,2, 3,4, D Emergency Acton Level (EAL):
Notes:
" The Emergency Director should declare the Site Area
,,,,orgency 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 the applicable time15-inudes.
" Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.
" The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
(1)
Reading on 'ANY nof t-he following rad-itioAn mon~itOre greater-than the reading shown fr15-FAno or longer:If (site 6pecific monitor liret and therechold ':aluec)
(2)
Doco asesseeot ucing actual meteorology indicatec desoc greater than 100 mnrem TEDE)F OF 500 AMrer thyroid ODE= at or beyond (site specific doe recepto peGt)
(3)
Field curvey results indic-ate EITHER Of the follov.'ing at Or beyond (cite epecific doco receptor point):
- Closed Aindow dose rates greater-than! 100 mR'hrw expected to continue for 60 minut~es or-lngen
- Analyses of field suvy samples indicAte thyroid CDE greater-than 500 mfem for-one hour of inhal-Ation.
Month 20XX OCGS 3-4 EP-AA-1010 (Revision XX)
(')v-QfPr rook r2anargating Aftfinn Annaw Fvalnn Nije-lanr Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS
- 1. Readings on ANY Table R1 Effluent Monitor > Table R1 value for> 15 minutes:
Table R1 Effluent Monitor Thresholds Effluent Monitor Site Area Emergency Main Stack RAGEMS 8.69 E+00 uCi/cc HRM OR 3.53 E-09 amps HRM Turbine Building RAGEMS 3.65 E+05 cpm LRM HRM = High Range Monitor LRM = Low Range Monitor OR
- 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER:
- 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.
- b. Analyses of field survey samples indicate > 500 mRem CDE Thyroid for 60 minutes of inhalation.
Basis:
This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs).
It includes both monitored and un-monitored releases. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public.
Month 20XX OCGS 3-5 EP-AA-1010 (Revision XX)
Oug-ta~r C~rook Ma~nersmting Station Annex Exelon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS 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 mR-em while the 500 mRfem I thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.
Clccfiatonbased onA efflueAnt moanitor roa;dings assumes; that ;a reloarce path to th en.ironment ;i% otblihed.*
If the,fn flo. pa. t n effluent monitor ic known to have setpped due to-actione-to isolato the-reec h, thenj the efflunt monitor PRedn ir, no longer valid forF classificatin pu 67ec Escalation of the emergency classification level would be via IC RAG 1.
Basis Reference~s):
1.
NEI 99-01 Rev 6, AS1
- 2.
EP-EAL-0610, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Oyster Creek Generating Station
- 3.
BNE Correspondence dated February 1, 2007
- 4.
CY-OC-170-301, Offsite Dose Calculation Manual for Oyster Creek
- 5.
EP-AA-1 10-200, Dose Assessment
- 6.
EP-AA-1 10-201, On Shift Dose Assessment Month 20XX OCGS 3-6 EP-AA-1010 (Revision XX)
flunfor Creek riantarating Afnfinn Anne-ky Fl(Alnn N.ele_:ar flv~cw Cn~k ~An~ntin
~$ainn nnExFvAon Nulatk2r Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS Initiating Condition:
ARA1I Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mRfem TEDE or 50 mRfem thyroid CDE.
Operating Mode Applicability:
1,2, 3,4, D Emergency Acton Level (EAL):
Notes:
" The Emergency Director should declare the Alert-vent 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 the applicable time!5 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.
k i)
M.aU!Ag OR:*
atA-U -A +-.eFeitil~ 6 OW for 15 Minlutes Or lon;ger:
(site specic l.monitor list aRd thirlelld values)
(2)
Drose asoee...ment ueing actual m"eteorology ind.+ate. do.e.* greater than 10 mrom T1flF at so IMrM thurnki CDC: 'nt ar haucand (Imta smariafin dnaa ranenntnr nnon4_
yv.1-
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r.,v,,,.i.
(3)
Analysis of a liquid ffluent a*m.ple indicates, a *oncntr*t*in or release rate that w:ould result in doses grea~ter thRan 0me EEo 0me hri D
to beyond (Site specific dose receptor point) for one hour-I Of eXpG6UF9-.
(4)
Field survey results indicate EITHER of the f-.oll~.ing at Or beyond (Site specific doee reG8epto pit*)i:
Closed1 Aindow d~ose rates efeater-than 11) mR'hr exp~ected to continue ter (30 mtiutes or-
!eagen p.,n..,r,~c,
,~vr.a.m n....tp~,
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.nn.nnrpw.nrp.p n..nnra..r.a.,
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- *AA~flJ J~J
~JC *1A Jt41 V 'J
~
t
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hour of inh:Al-atin.
Month 20XX OCGS 3-7 EP-AA-1010 (Revision XX)
Qyntar rook Ganerating Station Annoy Evi:Ynn Ni~t-lon*r f
- lv u
t wvvw Crllnl (lWn rntlni tn in llllVA Fwivi w Niv IHVI Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS
- 1. Readings on ANY Table R1 Effluent Monitor > Table RI value for > 15 minutes.
Table R1 Effluent Monitor Thresholds Effluent Monitor Alert Main Stack RAGEMS 8.69 E-01 uCi/cc HRM OR 3.53 E-10 amps HRM Turbine Building RAGEMS 3.65 E+04 cpm LRM HRM = High Range Monitor LRM = Low Range Monitor OR
- 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER:
- a.
- b.
- 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:
Month 20XX OCGS 3-8 EP-AA-1010 (Revision XX)
Ovater Crook Generatina St2tion Annex Exelon NUC102r Oyster..
.Creek..
Gene
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Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS
- a.
Gamma (closed window) dose rates > 10 mR/hr are expected to continue for a 60 minutes.
- 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 mRerem while the 50 mRfem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.
The radwaste liquid discharge system is currently closed off with a plant modification installed blank flange. To perform a discharge would require a plant modification to remove the flange. Since the liquid radwaste system is not operable, no EAL threshold has been developed for this release point.
lassificattion basod on effluent monitor readini s assumes that a release oath to tho eWviFiment oir, establoshed. if the effluent flow patn ef t mon9 fitor is known to have stopped due to actions to isolate th *rele..ah, then the effluenAt. m.ni.to reading is no longer valid for ciassificaton purp6e7 Escalation of the emergency classification level would be via IC RAS1.
Basis Reference(s):
1.
NEI 99-01 Rev 6, AAI Month 20XX OCGS 3-9 EP-AA-1010 (Revision XX)
Oyster Creek Generating Station Annex Exelon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS
- 2.
EP-EAL-0610, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Oyster Creek Generating Station
- 3.
BNE Correspondence dated February 1, 2007
- 4.
CY-OC-170-301, Offsite Dose Calculation Manual for Oyster Creek
- 5.
ABN-27, Inadvertent Overboard Radioactive Release or Cross Contamination
- 6.
EP-EAL-0617, Oyster Creek Criteria for Choosing Liquid Effluent EAL Threshold Values Month 20XX OCGS 3-10 EP-AA-1010 (Revision XX)
I=xAIon N.nlAar Ovs~ter Creek GBneratinn Station Annex Exelon Nhclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS Initiating Condition:
ARU I Release of gaseous or liquid radioactivity greater than 2 times the ODCM (site-speGifi.f effluent reloase controlling document) limits for 60 minutes or longer.
Operating Mode Applicability:
1,2, 3,4, D Emergency Acton Level (EAL):
Notes:
" The Emergency Director should declare the Un'usual Event event promptly upon determining that 60-0miinutesthe 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 the applicable time6Q.-minute.
" Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.
(1)
Reading en ANY effluent. radiation monitor greater than 2 times the (ite specific effluen~t WRelae
.ontrllin documnent) limits for 60 minuteS Or longer:
(Site Specific-monitor list and threshold Yalues corresponding to 2 timne6 the controlling document limits (2)
Reading on ANY effluent radiation moniRtor greater than 2 times the alarmA 6otpit erstablished by a current radioactivity discharge eeRmit forF 60- mlinutes Or loGer.
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document) limits for 60 min, d'o
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- lliW*l IL I WI*W*
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- 1. Readings on ANY Table R1 Effluent Monitor > Table RI value for > 60 minutes:
Table R1 Effluent Monitor Thresholds Effluent Monitor Unusual Event Main Stack RAGEMS 4.07 E+03 cps LRM Turbine Building RAGEMS 4.16 E+02 cpm LRM LRM = Low Range Monitor Month 20XX OCGS 3-11 EP-AA-1010 (Revision XX)
Ovster Creek Generatina Station Annex Exelon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS OR
- 2. 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.
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.
C-lass-ificwation bhased-on effluent monmitor read-ings assumes that. a release patht the enviFronmet is established. if the effluent flow past an effluent moniWt ors knownt have stopped due to acations to isol~ate the relearse path, then; th9e effluent mlenit-c-r re~ading is no longer valid for cl6iiaio7upss Releases should not be prorated or averaged. For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.
The radwaste liquid discharge system is currently closed off with a plant modification installed blank flange. To perform a discharge would require a plant modification to remove the flange. Since the liquid radwaste system is not operable, no EAL threshold has been developed for this release point.
FEAL A-2 T-his _AL_ -addresses radioactivity releases that cause effluent radiation monto readings to exceed 2 times the limit established by a radioactivity discharge permit. Thi EAL will typic all" be associated with planned batch releases from non continuous rceaso patwy egFdwaste, astega)
EAL #1 Basis:
F=Ai-#-l-This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous e -liquid-effluent pathways.
Month 20XX OCGS 3-12 EP-AA-1010 (Revision XX)
lvt.AInn NcIAsar nvatarr-rank rjanarnfinn Rfatinn Annax Exellon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS EAL #2 Basis:
&AL-1 --
- 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 RAAI.
Basis Reference(s):
- 1.
NEI 99-01 Rev 6, AU1
- 2.
EP-EAL-0610, Criteria for Choosing Radiological Gaseous Effluent EAL Threshold Oyster Creek Generating Station
- 3.
BNE Correspondence dated February 1, 2007
- 4.
CY-OC-170-301, Offsite Dose Calculation Manual for Oyster Creek
- 5.
ABN-27, Inadvertent Overboard Radioactive Release or Cross Contamination Month 20XX OCGS 3-13 EP-AA-1010 (Revision XX)
nunter Creek Generating Station Annay FYAInn N.P.In* r Ov~tr Cmk (~n~rtinn~tntnn An~vExelnn N~uclear Tnhlia AC(N Z2..2 OCGS EAL Technical Basis I HWiW VVWV W
b RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS Initiating Condition:
Significant lowering of water level above, or damage to, irradiated fuel.
Operating Mode Applicability:
1,2,3,4, D Emergency Acton Level (EAL):
(1)
UncoVeFy Of i-rradiatod fuel in the REFUELING PATH'AIAY.
ARA2 (2)
Damage to irradiated fuel Fresulting in a release of radioactivity from the fuel ars indicated by ANY of the folloWing radiation meniters:
(Site spocific listing of radiation mo-nitors, and the associ-kated readings, setpeints and/or alarms)
(3)
Lowcring of spent fuel pool level to (site specific Level 2 value). [See Dovelp2
- 1. Uncovery of irradiated fuel in the REFUELING PATHWAY.
- 2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by ANY Table R2 Radiation Monitor reading >1000 mRemlhr Table R2 Refuel Floor ARM's
" C-5, Crit Mon C-10, North Wall
" C-9, North Wall B-9, Open Floor Month 20XX OCGS 3-14 EP-AA-1010 (Revision XX)
Ovater Creek Generatina Station Annex Exelon Nuclear Oyter...C...ek G
......tina Station..Annex..E.....n.Nucle.r Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS 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.
CONFINEMENT BOUNDARY: The irradiated fuel dry storage cask barrier(s) between areas containing radioactive substances and the environment.
This IC addresses events that have caused IMMINENT or actual damage to an irradiated fuel assembly.,
WQ,,Qant lw_,÷ er.ng of watr lov.,l
,.,ithiR Mth Spent fu., p9ol *See Deveoper*
Ntes).
These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment. As such, they represent an actual or potential substantial degradation of the level of safety of the plant.
This IC applies to irradiated fuel that is licensed for dry storage up to the point that the loaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss of the CONFINEMENT BOUNDARY is classified in accordance with IC E-HUI.
EAL #1 Basis:
F=AL--#-
This EAL escalates from RAU2 in that the loss of level, in the affected portion of the REFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery of irradiated fuel. Indications of irradiated fuel uncovery may include direct or indirect visual observation (e.g., reports from personnel or camera images), as well as significant changes in water and radiation levels, or other plant parameters. Computational aids may also be used (e.g., a boil-off curve). Classification of an event using this EAL should be based on the totality of available indications, reports and observations.
While an area radiation monitor could detect aA inr.easerise 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.
Month 20XX OCGS 3-15 EP-AA-1010 (Revision XX)
Oyster Creek Generating Station Annex Exelon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS 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 RA-or C ICs.
Spent fuel peel water, lveiV at this-value is 'within t he lo*wel eand, of the level range necerssar,' to preyent Significant do65e consequencesfro~m. direct gamma radiation1 to per-sonnel per~forming operations in the_ Vicinit,' Of the epent fuel pool.
This coendito reflects a significant loss of spent fuel pool wxater inetr'and ths it isasoapecuror to-a loss of the ability to adequately cool the iraitdfuel assebles, Stored in the pol Eiscalation cf the emnergency cAss4159ifiroat-69n level would be via Ir-s ASO Or A82 (see AS-2 DoVlOGpor Note-S).
Basis Reference(s):
1.
NEI 99-01lRev 6, AA2
- 2.
RAP G-7-a, SKM SRG TNK LVL LO-LO
- 3.
RAP-i OF-I-in, Crit Mon C5 Hi
- 4.
RAP-I OF-3-m, North Wall C9 Hi Vent Trip
- 5.
RAP-I OF-2-m, North Wall C10 Hi
- 6.
RAP-i OF-4-m, North Wall B39 Hi Vent Trip Month 20XX OCGS 3-16 EP-AA-1010 (Revision XX)
Ovster Crook Generatina Station Annex mm*w*vi i i I*VBVll Exelon Nuclear OytrCee eeain ttonAnxEAmnNdn Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARU2 Initiating Condition:
UNPLANNED loss of water level above irradiated fuel.
Operating Mode Applicability:
1, 2, 3,4, D Emergency Acton Level (EAL):
(1)
- a.
UNPLANNED wateIr level drop in the REFUELING1 PATHWAY as indicated by ANY of the following:
(site specificg leve indications).
- 19.
U N P'ANNED1 ri in r
re radiation leve'ls ass indic-ated byANY of the following radiation monitors.
(site specific list of are-a raddiation mon9itors) 1.
- a.
UNPLANNED water level drop in the REFUELING PATHWAY as indicated by ANY of the following:
" Refueling Cavity water level < 583 inches (GEMAC Wide Range, floodup calibration).
OR Indication or report of a drop in water level in the REFUELING PATHWAY.
AND
- b.
UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors in Table R2.
Table R2 Refuel Floor ARM's C-5, Crit Mon
" C-10, North Wall
" C-9, North Wall
- B-9, Open Floor Month 20XX OCGS 3-17 EP-AA-1010 (Revision XX)
Oyster Creek Generating Station Annex I:::alnn Nhir-lnar Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS Basis:
UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.
REFUELING PATHWAY: all the cavities, tubes, canals and pools through which irradiated fuel may be moved or stored, but not including the reactor vessel below the flange.
This IC addresses a deGrease-loss in water level above irradiated fuel sufficient to cause elevated radiation levels. This condition could be a precursor to a more serious event and is also indicative of a minor loss in the ability to control radiation levels within the plant. It is therefore a potential degradation in the level of safety of the plant.
A water level dereaseeloss 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 a4 *AGoeaserise 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 inRGeaserise due to planned evolutions such as lifting of the reactor vessel head or movement of a fuel assembly. Note that this EAL is applicable only in cases where the elevated reading is due to an UNPLANNED loss of water level.
A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.
Escalation of the emergency classification level would be via IC RAA2.
Basis Reference(s):
- 1.
NEI 99-01 Rev 6, AU2
- 2.
RP-AA-203 Exposure Control and Authorization
- 3.
RAP-G-7-a, SKM SRG TNK LVL LO-LO
- 4.
205.94.0 RPV Floodup Using Core Spray
- 5.
205.95.0 Reactor Flood-up / Drain-down
- 6.
FSAR Figure 7.6-3 Month 20XX OCGS 3-18 EP-AA-1010 (Revision XX)
Ovster Creek Generatina Station Annex Exelon Nuclear OytrCee eeainaSainlnelxlo ula Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS ARA3 Initiating Condition:
Radiation levels that impede access to equipment necessary for normal plant operations, cooldown or shutdown.
Operatiling Mode Applicability:
1,2, 3,4, D Emergency Acton Level (EAL):
Note:
If the equipment in the listed-room or area listed in Table R4 was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted (1)
Dose rate greater than 15 mnR/hr in ANY of the following areas:
a CMant rRoomfRo
" Central Alarm Station-
" (other site Speei& areaS480MS)
(2)
An U-NP-ASNNED ev.ent results in radiation levels that prohibit or impede access to any of the following plant rooms Or areas:
(site specific list of plant rooms or ar~easb with entry related mode appliability,
- 1. Dose rate g~eateF-thani> 15 mRlhr in ANY of the following Table R3 areas:
Table R3 Areas Requiring Continuous Occupancy
" Main Control Room
" Central Alarm Station - (by survey)
OR Month 20XX OCGS 3-19 EP-AA-1010 (Revision XX)
t') afar rook rtanarnfinn Afnfinn Annoy I=xAInn N.cl*ar flu~~r (r~~ (~o~r~inn t2*nn AnnvExelon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS I RADIOLOGICAL EFFLUENTS
- 2. UNPLANNED event results in radiation levels that prohibit or significantly impede access to any of the following Table R4 plant rooms or areas:
Table R4 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability Reactor Building*
Modes 3 and 4
- Areas required to establish shutdown cooling Basis:
UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.
This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or impede personnel from performing actions necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal plant proceduresmaintain normnal plant operation, or to porfoFrm a normnal plant cooldown n sh'-tdew;:,-.
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 R4 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 serviceat the time of the
'le:ated radiation lev'els. The emergency classification is not contingent upon whether entry is actually necessary at the time of the increased radiation levels. Access should be Month 20XX OCGS 3-20 EP-AA-1010 (Revision XX)
I=*Alnn N.P.la*r flv-mm~r C~rook (GAnersatinn Station Annax Fwalnn N~ijelonzr Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., installing temporary shielding, 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 4erise occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.
" The increased radiation levels are a result of a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., radiography, spent filter or resin transfer, etc.).
" The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).
" The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.
Escalation of the emergency classification level would be via Recognition Category RA, C or F ICs.
Basis Reference(s):
- 1.
NEI 99-01 Rev 6, AA3
- 2.
ABN-29, Plant Fires
- 3.
EMG-3200.1 1, Secondary Containment Control Safe Shutdown Area Month 20XX OCGS 3-21 EP-AA-1010 (Revision XX)
Ovater Creek Generatina Station Annex Exelon Nuclear Oyster...Cr.ek G.n....tina Station.Annex.E.e..n.Nu.le.
Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY ABNORMAL RAD LEVELS / RADIOLOGICAL EFFLUENTS SRU3 Initiating Condition:
Reactor coolant activity greater than Technical Specification allowable limits.
Operating Mode Applicability:
1,2 Emergency Acton Level (EAL):
(1)
(Site specific radiation mon~itor) reading greater than (site SPecific value)-.
(2)
Sample analysis indicates that a reactor coolant activit*' value is greate. than n allo.able limit specified in Te*hnical Speifi;-ati;ns.
- 1.
Offgas system radiation monitor Hi-Hi alarm.
- 2.
Specific coolant activity > 4.0 uCligm 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 RA lCs.
Basis Reference(s):
- 1.
NEI 99-01 Rev 6, SU3
- 2.
Technical Specifications 3.6.A
- 3.
ABN-26, High Main Steam Line or Off Gas Activity
- 4.
RAP10F-1-c, Offgas HI-HI Month 20XX OCGS 3-22 EP-AA-1010 (Revision XX)
Oyster Creek Generating Station Annex Exelon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis 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 Emergency Acton 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 OCGS 3-23 EP-AA-1010 (Revision XX)
Oyster Creek Generating Station Annex Exelon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FS1 Initiating Condition:
Loss or Potential Loss of ANY two barriers.
Operating Mode Applicability:
1,2 Emergency Acton 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 OCGS 3-24 EP-AA-1010 (Revision XX)
Ovater Creek Generatina Station Annex Exelon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis 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 Emergency Acton 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 FS1.
Basis Reference(s):
- 1.
NEI 99-01 Rev 6, Table 9-F-2 Month 20XX OCGS 3-25 EP-AA-1010 (Revision XX)
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snwUU Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC1 Initiating Condition:
RCS Activity Operating Mode Applicability:
1,2 Fission Product Barrier (FPB) Threshold:
LOSS A. (Site Sp9cific indications that reactor coo-lant acotiVity is greater than 300_uGW9gm dos equ.ivalent I 1)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 Month 20XX OCGS 3-26 EP-AA-1010 (Revision XX)
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Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC2 Initiating Condition:
RPV Water Level Operating Mode Applicability:
1,2 Fission Product Barrier (FPB),Threshold:
LOSS A-.1. Plant conditions indicate PrimaPy-primary containment flooding is required.
POTENTIAL LOSS A;--2. RPV water level cannot be restored and maintained above (site s.epific RPV Wat. r *po.. *c.....pndi. g to tho top of
..tI'" fuol)> 0 inches TAF.
of-OR
- 3. RPV water level cannot be determined.
Basis:
Loss 2-AThreshold #1 Basis The Loss threshold represents the EOP requirement for primary containment flooding.
This is identified in the BWROG EPGs/SAGs when the phrase, "Primary Containment Flooding Is Required," appears. Since a site-specific RPV water level is not specified here, the Loss threshold phrase, "Primary containment flooding required," also accommodates the EOP need to flood the primary containment when RPV water level cannot be determined and core damage due to inadequate core cooling is believed to be occurring.
Potential Loss 2-AThreshold #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 baFieF Barder RC2 Loss threshold 2-.
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 RPV water level control with low-pressure injection sources. In some events, elevated Month 20XX OCGS 3-27 EP-AA-1010 (Revision XX)
Oyster Creek Generating Station Annex IFvalnn Minlnrlr Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION 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.
In high-power ATWS/failure to scram events, EOPs may direct the operator to deliberately lower RPV water level to the top of active fuel in order to reduce reactor power. RPV water level i. then controlled between the top of act,, ive fuel,,
I -and the hMinimu..m. Ste am,,
Cooling RPV Water Level (MSCR*W^.
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 SA5-MA3 or SS&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.
EMG-3200.01A, RPV Control - No ATWS
- 3.
EMG-3200.01 B, RPV Control - With ATWS
- 4.
EMG-3200.08A, RPV Flooding - No ATWS
- 5.
EMG-3200.08B, RPV Flooding - With ATWS
- 6.
EMG-3200.02, Primary Containment Control Month 20XX OCGS 3-28 EP-AA-1010 (Revision XX)
(I afar ('-raak (Zanarnfin Atntinn Annay i*y*lnn N.*lAar flu~~r (rn~ A~nr~*nn Lt~ainn nnvExelnn NucleI~ar Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC5 Initiating Condition:
Primary Containment Radiation Operating Mode Applicability:
1,2 Fission Product Barrier (FPB) Threshold:
LOSS A. Prim"*A;
,ontainMo,,t radiation mon4.itor roading gre-ato,4r t.han (Site pecific value)
Containment Hi Range Radiation Monitoring System (CHRRMS) reading > 530 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 Tthreshold-4.A-since it indicates a loss of both the Fuel Clad Barrier and the RCS Barrier. Note that a combination of the two monitor readings appropriately escalates the emergency classification level to a Site Area Emergency.
There is no Fuel Clad Barrier Potential Loss threshold associated with Primary Containment Radiation.
Basis Reference(s):
- 1.
NEI 99-01 Rev 6, Table 9-F-2
- 2.
Core Damage Assessment Methodology Month 20XX OCGS 3-29 EP-AA-1010 (Revision XX)
t-luafor rrank rjanarnfinn Afnfinn Annoy EXI:*nn Nne-logir flu~frar (~m~k (~nt~ratinn ~tMinn Anng&v FvAInn Nmut~Ia~2r Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION FC7 Initiating Condition:
Emergency Director Judgment.
Operating Mode Applicability:
1,2 Fission Product Barier (FPB) Threshold:
LOSS 1A.
Any condition in the opinion of the Emergency Director that indicates Loss of the Fuel Clad Barrier.
POTENTIAL LOSS 2A.
Any condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.
Basis:
Loss Threshold #1 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 #2 Basis Potontial Lnoe A A This threshold addresses any other factors that may be used by the Emergency Director in determining whether the Fuel Clad Barrier is potentially lost. The Emergency Director should also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.
Basis Reference(s):
- 1.
NEI 99-01 Rev 6, Table 9-F-2 Month 20XX OCGS 3-30 EP-AA-1010 (Revision XX)
Ovater Crook Generatina Station Annex Exelon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC2 Initiating Condition:
RPV Water Level Operating Mode Applicability:
1,2 Fission Product Barrier (FPB) Threshold:
LOSS
- 1. RPV water level cannot be restored and maintained above (sate sp.ific. R*,V wate.
,e
- cOrn, to the top o,
,cti"o fuol> 0 inches TAF ei-OR
- 2. RPV water level cannot be determined.
Basis:
LeS&4A.
This water level corresponds to the tep-Top of aGtive-Active fuel-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 baFF*8-Barrier FC2 Potential Loss threshold-2.A. Thus, this threshold indicates a Loss of the RCS barrier and Potential Loss of the Fuel Clad barrier and that appropriately escalates the emergency classification level to a Site Area Emergency.
This threshold is considered to be exceeded when, as specified in the site-specific EOPs, RPV 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 OCGS 3-31 EP-AA-1010 (Revision XX)
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Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION 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.
In high-power ATWS/failure to scram events, EOPs may direct the operator to deliberately lower RPV water level to the top of ativ-fuel-in order to reduce reactor power. RP'... te lev, i.. thon control*ed between the top of,cti,,
fuel and the Minimum, Steam Cooling RPV WA-ater L..e.e (MSROA4A* 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 SA5-MA3 or SS5-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.
2000-GLN-3200.01, Plant Specific Technical Guideline
- 3.
2000-BAS-3200.02, EOP Users Guide I
Month 20XX OCGS 3-32 EP-AA-1010 (Revision XX)
Oyster Creek Generating Station Annex F=*rlnn N~nlanr Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC3 Initiating Condition:
Primary Containment Pressure Operating Mode Applicability:
1,2 Fission Product Barier (FPB) Threshold:
LOSS A. Pri-.m.a' Ontainment presur g*reater than (Site
'epoifi value) due to R IS leakag
- 1. Drywell pressure > 3.0 psig.
AND
- 2. Drywell pressure rise is due to RCS leakage Basis:
The (site.eific '... alue)> 3.0 psig primary containment pressure is the d yweltDrywell high pressure setpoint which indicates a LOCA by automatically initiating the-ECCS-ef equiyalent makeup system.
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 primary containment pressure. Pressures of this magnitude can be caused by non-LOCA events such as a loss of Drywell cooling or inability to control primary containment 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 Electromatic Relief Valve (EMRV) or EMRV leakage is not considered either identified or unidentified leakage by Technical Specifications and, therefore, is not applicable to this EAL.
There is no Potential Loss threshold associated with Primary Containment Pressure.
Basis Reference(s):
- 1.
NEI 99-01 Rev 6, Table 9-F-2
- 2.
EMG-3200.01A, RPV Control - No ATWS
- 3.
EMG-3200.02, Primary Containment Control
- 4.
2000-BAS-3200.02, EOP User's Guide Month 20XX OCGS 3-33 EP-AA-1010 (Revision XX)
Ovater Crook Generatina Station Annex Exelon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC4 Initiating Condition:
RCS Leak Rate Operating Mode Applicability:
1,2 Fission Product Barrier (FPB) Threshold:
LOSS Al. UNISOLABLE Main Steam Line (MSL), Isolation Condenser, Feedwater, or RWCU line break. in ANY of t*he folo;-ing: (site..
ep.c.ySt.e.
With potential for high energy OR
- 82. Emergency RPV Depressurization is required.
POTENTIAL LOSS 3A. UNISOLABLE primary system leakage that results in EITHER of the following:
- a. Secondary Containment area temperature > EMG-3200.11 Max Normal (Table 11) operating level.
- b. Secondary Containment area radiation level > EMG-3200.11 Max Normal (Table 12) operating level.
- 1. Max Normal Operating TemperatuFe OR
- 2. Max Normal Operating Area Radiation L
.c.
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.
Month 20XX OCGS 3-34 EP-AA-1010 (Revision XX)
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Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Loss Threshold #1 Basis-3.
Large high-energy lines that rupture outside primary containment can discharge significant amounts of inventory and jeopardize the pressure-retaining capability of the RCS until they are isolated. If it is determined that the ruptured line cannot be promptly isolated from the Control Room, the RCS barrier Loss threshold is met.
Loss Threshold #2 Basis-3.B 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-Electromatic relief valves (SRVsEMRVs) and keep them open. Even though the RCS is being vented into the
.pro inpotorus, 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- #3 Basis &A Potential loss of RCS based on primary system leakage outside the primary containment is determined from EOP temperature or radiation Max Normal Operating values in areas such as main steam line tunnelTrunnion room, Isolation Condenser, RWCU RGIG, HP-G-,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 Tthreshold
- 13A (after a containment isolation) and a General Emergency when the Fuel Clad Barrier criteria is also exceeded.
Month 20XX OCGS 3-35 EP-AA-1010 (Revision XX)
Oyster Creek Generating Station Annex Exelon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Basis Reference(s):
- 1.
NEI 99-01 Rev 6, Table 9-F-2
- 2.
EMG-3200.1 1, Secondary Containment Control
- 3.
2000-GLN-3200.01, Plant Specific Technical Guideline Month 20XX OCGS 3-36 EP-AA-1010 (Revision XX)
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Primary Containment radiation Operating Mode Applicability:
1,2 Fission Product Barrier (FPB) Threshold:
LOSS Containment Hi Range Radiation Monitoring System (CHRRMS) reading > 100R/hr.
A. Prima' containment radiaition reading greater than (site specifi value).
Basis:
The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that reactor coolant activity equals Technical Specification allowable limits. This value is lower than that specified for Fuel Clad Barrier FC5 Loss Tthreshold 44A-since it indicates a loss of the RCS Barrier only.
There is no Reactor Coolant System Potential Loss threshold associated with Primary Containment Radiation.
Basis Reference(s):
- 1.
NEI 99-01 Rev 6, Table 9-F-2
- 2.
EP-EAL-061 1, Criteria for Choosing Containment Radiation Monitor Reading Indicative of Loss of RCS Barrier Month 20XX OCGS 3-37 EP-AA-1010 (Revision XX)
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Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION RC7 Initiating Condition:
Emergency Director Judgment.
Operating Mode Applicability:
1,2 Fission Product Barrier (FPB) Threshold:
LOSS Al.
Any condition in the opinion of the Emergency Director that indicates Loss of the RCS Barrier.
POTENTIAL LOSS A2.
Any condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.
Basis:
Loss 6-AThreshold #1 Basis:
This threshold addresses any other factors that are to be used by the Emergency Director in determining whether the RCS Barrier is lost.
Potential Loss 6&AThreshold #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 OCGS 3-38 EP-AA-1010 (Revision XX)
Oyster Creek Generating Station Annex Exelon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT2 Initiating Condition:
RPV Water Level Operating Mode Applicability:
1,2 Fission Product Barrier (FPB) Threshold:
POTENTIAL LOSS A.-Plant conditions indicate P-imary-primary containment flooding is required.
Basis:
Potential Loes 2. A The Potential Loss threshold is identical to the Fuel Clad Barrier FC2 Loss threshold RPV Water Level 2.:A. The Potential Loss requirement for Primary Containment Flooding indicates adequate core cooling cannot be restored and maintained and that core damage is possible. BWR EPGsEOPs/SAMGs specify the conditions that require primary containment flooding. When primary containment flooding is required, the E-PGs EOPs are exited and SAMGs are entered. Entry into SAMGs 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.
EMG-3200.01 B, RPV Control - With ATWS
- 3.
EMG-3200.08A, RPV Flooding - No ATWS
- 4.
EMG-3200.08B, RPV Flooding - With ATWS
- 5.
EMG-3200.02, Primary Containment Control6. EMG-3200.01A, RPV Control -
No ATWS Month 20XX OCGS 3-39 EP-AA-1010 (Revision XX)
Ovater Crook Generatina Station Annex Exelon Nuclear Oyster Creek Generatina Station Annex Exelon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT3 Initiating Condition:
Primary Containment Conditions Operating Mode Applicability:
1,2 Fission Product Barrier (FPB) Threshold:
LOSS Al. UNPLANNED rapid drop in prmar; containment Drywell pressure following p~#maiy containment presureDrywell rise.
OR B2. PF;,,ay conditions.
GRa e..me.tDrywell pressure response not consistent with LOCA I POTENTIAL LOSS A3. PF*Mary-eDrywellentainmen pressure and rising.
OR greater than (site spe' ;ifi.value)>
44 psig
- 84. (sito sepoific explosive mixtdure)
Torus Hydrogen concentration > 6%.
AND exiete ineido primary GGtameflt a. Drywell or
- b. Drywell or Torus Oxygen concentration > 5%.
OR G5. H-T-LG-Heat Capacity Temperature Limit (EMG-3200.02 Fig. F) 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 4.A*-and-1BThreshold #1 and #2 Basis Rapid UNPLANNED loss of p im I tainmentDrywell pressure (i.e., not attributable to dryweliDrywell spray or condensation effects) following an initial pressure inGeaserise indicates a loss of pinmar'y cntainmtDrywell integrity. P...
.aFy G9Atawlme*tDrywell pressure should erise as a result of mass and energy release into the primary containment from a LOCA. Thus, primarm;..........
Drywell pressure not increasing under these conditions indicates a loss of PuimaF y
GentainmentDrywell 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 Month 20XX OCGS 3-40 EP-AA-1010 (Revision XX)
I:yAInn N.*IA*r flimtpr Crook r na~rating Stt2ion Annex Ex.eInn Nsiucler Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION bypass condition. A pressure suppression bypass path would not be an indication of a containment breach.
Potential Loss 4-lAThreshold #3 Basis The threshold pressure is the prm; tainmentDrywell internal design pressure.
Structural acceptance testing demonstrates the capability of the p-imay G~taw~me*Drywell to resist pressures greater than the internal design pressure. A pressure of this magnitude is greater than those expected to result from any design basis accident and, thus, represent a Potential Loss of the Containment barrier.
Potential Loss 4-BThreshold #4 Basis If hydrogen concentration reaches or exceeds the lower flammability limit, as defined in plant EOPs, in an oxygen rich environment, a potentially explosive mixture exists. If the combustible mixture ignites inside the primary containment, loss of the Containment barrier could occur.
Potential Loss 41-GThreshold #5 Basis The Heat Capacity Temperature Limit (HCTL) is the highest
.uppres....
polI temperaturee froM Which Em:Fergency RP2V DepresSUrization will not raise:
8 uppression chamber temperaturo above the maximum temRperature cap-ability of the suppression-chambher and equipment within the uprsIo chamber: which may be required to operate whenteR' ispresuized, QR
- Suppression;A-cshamber pressure above Primnary Containment Pressure Limit A, while the Fate of energy transfer fromn the RPV to-the coentainment is greater tha the capacity Of the cont-ainmen-t. Vent.
The HCTL is a function of RPV pressure, suprsio potorus temperature and SUPP~ssie torus 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 99-0 1 Rev 6, Table 9-17-2
- 2.
FSAR Update 6.2.1.1.3
- 3.
Technical Specifications 5.2 Basis
- 4.
EMG-3200.02 Primary Containment Control Month 20XX OCGS 3-41 EP-AA-1010 (Revision XX)
I=x*lon Nuclear Ovster Creek Generatina Stration Annex Exelon Nucla~r Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT5 Initiating Condition:
Primary Containment Radiation Operating Mode Applicability:
1,2 Fission Product Barrier (FPB) Threshold:
POTENTIAL LOSS A.
i.May Contain;ment radiation Fnitor reading gre-ater than (Site 6pecific Value)
Containment Hi Range Radiation Monitoring System (CHRRMS) reading > 1210 RFhr.
Basis:
There is no Loss threshold associated with Primary Containment Radiation.
PotntiaL',
I r.A The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the primary containment, assuming that 20% of the fuel cladding has failed. This level of fuel clad failure is well above that used to determine the analogous Fuel Clad Barrier Loss and RCS Barrier Loss thresholds.
NUREG-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 exist7 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 OCGS 3-42 EP-AA-1010 (Revision XX)
I=ymlnn Nu*lmar Ov--mfr Creek (GAneratina Stsation Annex Exelnn Nuclanr Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT6 Initiating Condition:
Primary Containment Isolation Failure Operating Mode Applicability:
1,2 Fission Product Barrier (FPB) Threshold:
LOSS Al. UNISOLABLE direct downstream pathway to the environment exists after primary I containment isolation signal.
OR B2. Intentional Pprimary CGontainment venting/purging per EOP-s or SAGs due to accident conditions.
OR G3. UNISOLABLE primary system leakage that results in EITHER of the following:
-l-a. Secondary Containment area temperature > EMG-3200.11 Max Safe (Table
- 11) operating level. Maw., 2-safo, Op..ating Temperature OR 2b. Secondary Containment area radiation level > EMG-3200.11 Max Safe (Table
- 12) operating level. Wax Safe, OperatinR Radiation 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 3AThreshold #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, Isolation Condenser line 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 OCGS 3-43 EP-AA-1010 (Revision XX)
Ovater Crook Generatina Station Annex Exelon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Following the leakage of RCS mass into primary containment and a rise in primary containment pressure, there may be minor radiological releases associated with allowable primary containment leakage through various penetrations or system components. Minor releases may also occur if a primary containment isolation valve(s) fails to close but the primary containment atmosphere escapes to an enclosed system.
These releases do not constitute a loss or potential loss of primary containment but should be evaluated using the Recognition Category A-R ICs.
Loss 34BThreshold #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 dPywelDrywell high pressure scram setpoint) does not meet the threshold condition.
Loss 3=,Threshold #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.
In combination with RCS Barrier RC4 pPotential ILoss Threshold #33-A this threshold would result in a Site Area Emergency.
There is no Potential Loss threshold associated with Primary Containment Isolation Failure.
Month 20XX OCGS 3-44 EP-AA-1010 (Revision XX)
Oyster Creek Generating Station Annex Exelon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Basis Reference(s):
- 1.
NEI 99-01 Rev 6, Table 9-F-2
- 2.
2000-GLN-3200.01, Plant Specific Technical Guideline
- 3.
EMG-3200.02, Primary Containment Control
- 4.
Support Procedures -32, -34, -41, -44
- 5.
2000-GLN-3200.03, OCNGS Plant Specific Technical Guidelines for Severe Accident Guidelines
- 6.
EMG-3200.1 1, Secondary Containment Control Month 20XX OCGS 3-45 EP-AA-1010 (Revision XX)
Exalon Nuclaar Ouster Creek Generatina Station Annex Eeo ula Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION CT7 Initiating Condition:
Emergency Director Judgment.
Operating Mode Applicability:
1,2 Fission Product Barrier (FPB) Threshold:
LOSS Al.
Any condition in the opinion of the Emergency Director that indicates Loss of the Containment Barrier.
POTENTIAL LOSS A2.
Any condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.
Basis:
Loss 6-,AThreshold #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 6AThreshold #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 OCGS 3-46 EP-AA-1010 (Revision XX)
Oyster Creek Generating Station Annex Fyelnn N.*l*r Exelon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY FISSION PRODUCT BARRIER DEGRADATION Month 20XX OCGS 3-47 EP-AA-1010 (Revision XX)
Ovster Creek Generatina Station Annex Exelon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSGl Initiating Condition:
Prolonged loss of all Off-site and all On-Site AC power to emergency busses.
Operating Mode Applicability:
1,2 Emergency Action Level (EAL):
Note:
The Emergency Director should declare the General E-negency. vent promptly upon determining that (site.pecif-c hours) the applicable time has been exceeded, or will likely be exceeded.
1-a-Loss of ALL offsite and ALL,nste AC power to 4160V Buses lC and 1D.-(site Gpecific emnergenc; bJuses).
AND
- 2.
Failure of EDG-1 and EDG-2 Emergency Diesel Generators to supply power to 4160V Buses 1C and 1D.
AND 3b. EITHER of the following:
- a. Restoration of at least one 4160V -emeFgeny- *au-Bus (IC or 1D) -in < I hours is notlss than (site.pecific.
hours) is n likely.
(Site specificidcaino an inability to adequately remove heat fro~m the core)
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 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 mereany fission product Month 20XX OCGS 3-48 EP-AA-1010 (Revision XX)
Ovster Creek Gener2tina St2tion Annex Exellon NUCle2r Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS barriers.
In addition, fission product barrier monitoring capabilities may be degraded under these conditions.
The EAL should require declaration of a General Emergency prior to meeting the thresholds for IC FGI.
This will allow additional time for implementation of offsite protective actions.
Escalation of the emergency classification from Site Area Emergency will occur if it is projected that power cannot be restored to at least one AC emergency bus by the end of the analyzed station blackout coping period. Beyond this time, plant responses and event trajectory are subject to greater uncertainty, and there is an increased likelihood of challenges to multiple fission product barriers.
The estimate for restoring at least one emergency bus should be based on a realistic appraisal of the situation. Mitigation actions with a low probability of success should not be used as a basis for delaying a classification upgrade. The goal is to maximize the time available to prepare for, and implement, protective actions for the public.
The EAL will also require a General Emergency declaration if the loss of AC power results in parameters that indicate an inability to adequately remove decay heat from the core.
Basis Reference(s):
- 1.
NEI 99-01 Rev 6, SG1
- 2.
UFSAR Section 8.2, Offsite Power System
- 3.
ABN-37, Station Blackout
- 4.
ABN-60, Grid Emergency
- 5.
Regulatory Guide 1.155, Station Blackout
- 6.
TDR-1099, "Station Blackout Evaluation Report"
- 7.
2000-BAS-3200.02, EOP User's Guide
- 8.
2000-GLN-3200.01, Plant Specific Technical Guideline
- 9.
OCNGS Drawing BR 3000
- 10.
ABN-36, Loss of Off-Site Power Month 20XX OCGS 3-49 EP-AA-1010 (Revision XX)
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Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS M$SS I Initiating Condition:
Loss of all offsite and all onsite AC power to emergency busses for 15 minutes or longer.
Operating Mode Applicability:
1,2 Emergency Action Level (EAL):
Note: The Emergency Director should declare the Site Area Em.rgen-yevent promptly upon determining that the applicable time 45-riiiutes-has been exceeded, or will likely be exceeded.
- 1. Loss of ALL offsite and All ns;ito AC Power to (site.p..ific em.ergency buses)4160V Buses lC and 1D f*o 15 minuts Or longer,.
AND
- 2. Failure of EDG-1 and EDG-2 Emergency Diesel Generators to supply power to 4160V Buses lC and 1D.
AND
- 3. Failure to restore power to at least one 4160V Bus (1C or 1D) 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 RAG1, FG1, -e-f MSG1, or MG2.
Month 20XX OCGS 3-50 EP-AA-1010 (Revision XX)
Oyster Creek Generating Station Annex Exelon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Basis Reference(s):
- 1.
NEI 99-01 Rev 6, SS1
- 2.
UFSAR Section 8.2, Offsite Power System
- 3.
OCNGS Drawing BR 3000
- 4.
ABN-36, Loss of Off-Site Power
- 5.
ABN-37, Station Blackout
- 6.
ABN-60, Grid Emergency Month 20XX OCGS 3-51 EP-AA-1010 (Revision XX)
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~JV~a I 'I lw 1W 11 iildiD~~.IIJ~I~i, Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSAI Initiating Condition:
Loss of all but one AC power source to emergency buses for 15 minutes or longer.
Operating Mode Applicability:
1,2 Emergency Action Level (EAL):
Note: The Emergency Director should declare the eventAlet promptly upon determining that the applicable time 415-inu*tes-has been exceeded, or will likely be exceeded.
- 1. AC power capability to 4160V Buses 1C and 1D reduced to only one of the following power sources for > 15 minutes.
- Startup Transformer SA
- Startup Transformer SB
- a. AGpor c-.apability to (sit*
- pecific emergency buses) ;) raedued to a single poWer Sourco for 15 minu-tes or Iongcr.
AND 2b. Any additional single power source failure will result in a loss of all AC power to 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. This IC provides an escalation path from IC MSU1.
An "AC power source" is a source recognized in AQP--ABNs and EOPs, and capable of supplying required power to an emergency bus. Some examples of this condition are presented below.
Month 20XX OCGS 3-52 EP-AA-1010 (Revision XX)
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WEWE Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS
" A loss of all offsite power with a concurrent failure of all but one emergency power source (e.g., an onsite diesel generator).
" A loss of all offsite power and loss of all emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from the unit main generator.
" A loss of emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being back-fed from an offsite power source.
Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.
Escalation of the emergency classification level would be via IC MSS1.
I I
Basis Reference(s):
- 1.
NEI 99-01 Rev 6, SA1
- 2.
UFSAR Section 8.2, Offsite Power System
- 2.
OCNGS Drawing BR 3000
- 3.
ABN-36, Loss of Off-Site Power
- 4.
ABN-37, Station Blackout
- 5.
ABN-60, Grid Emergency Month 20XX OCGS 3-53 EP-AA-1010 (Revision XX)
Ovster Creek Generatina Station Annex Exelon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSUI Initiating Condition:
Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.
Operating Mode Applicability:
1,2 Emergency Action Level (EAL):
Note: The Emergency Director should declare the Unusual Ee-ntevent promptly upon determining that the applicable time 41-minutes-has been exceeded, or will likely be exceeded.
1-.Loss of ALL offsite AC power capability to 4160V Buses 1C and 1D (site-spc..ific em*ergency buse.) for > 15 minutes-e-IeF4GP.
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, 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 MSA1.
Basis Reference(s):
- 1.
NEI 99-01 Rev 6, SU
- 2.
UFSAR Section 8.2, Offsite Power System
- 3.
OCNGS Drawing BR 3000
- 4.
ABN-36, Loss of Off-Site Power
- 5.
ABN-60, Grid Emergency Month 20XX OCGS 3-54 EP-AA-1010 (Revision XX)
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-4.2y RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Initiating Condition:
Loss of all AC and Vital DC power sources for 15 minutes or longer.
Operating Mode Applicability:
1,2 Emergency Action Level (EAL):
MSG21 I Note: The Emergency Director should declare the General E,,g.=.n.
.y vent promptly upon determining that the applicable time 15nmintes-has been exceeded, or will likely be exceeded.
- 1.
Loss of ALL offsite AC power to 4160V Buses 1 C and 1 D.
AND
- 2.
Failure of EDG-1 and EDG-2 Emergency Diesel Generators to supply power to 4160V Buses 1C and 1D.
AND
- 3.
Voltage is < 115 VDC on 125 VDC battery busses B and C.
AND
- 4.
ALL AC and Vital DC power sources have been lost for >15 minutes.
buses) f.r 15 m.inutes Or lo*g*r.
AND hb. Ind-icated v:oltage is loss than (site Specific bus voltage v:alue) on L
(site specific.,ital DC busses,) for 15 minutes Or longr.
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.
Month 20XX OCGS 3-55 EP-AA-1010 (Revision XX)
flv-qpr Creek CGAneratinn Station Annex Exelon Nuc~lear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS This IC addresses a concurrent and prolonged loss of both AC and Vital DC power. A loss of all AC power compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink. A loss of Vital DC power compromises the ability to monitor and control SAFETY SYSTEMS. A sustained loss of both AC and DC power will lead to multiple challenges to fission product barriers.
Fifteen minutes was selected as a threshold to exclude transient or momentary power losses. The 15-minute emergency declaration clock begins at the point when all EAL conditions are met.
Basis Reference(s):
- 1.
NEI 99-01 Rev 6, SG8
- 2.
UFSAR Section 8.3.2, DC Power Systems
- 3.
UFSAR Section 8.2, Offsite Power System
- 4.
OCNGS Drawing BR 3000
- 5.
ABN-36, Loss of Off-Site Power
- 6.
ABN-37, Station Blackout
- 7.
ABN-60, Grid Emergency
- 8.
ABN-54, Loss of DC Distribution Center B
- 9.
ABN-55, Loss of DC Distribution Center C Month 20XX OCGS 3-56 EP-AA-1010 (Revision XX)
Ex*lon NuP-I*ar lvster Creek Gener~atinn Station Annex Exelnn Niuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSS28 Initiating Condition:
Loss of all vital DC power for 15 minutes or longer.
Operating Mode Applicability:
1,2 Emergency Action Level (EAL):
Note: The Emergency Director should declare the S.ite Ar-e,_ E-
-,gencyevent promptly upon determining that the applicable time 45-minues -has been exceeded, or will likely be exceeded.
Inddir, ated-vVoltage is < 115 VDC less than (site specific bus voltage value) on 125 VDC battery busses B and C ALL (site specific Vital DG busses) for >15 minutes-GF lengjeF.
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 RAG1, FG1 or MSG28.
Basis Reference(s):
- 1.
NEI 99-01 Rev 6, SS8
- 2.
OCNGS Drawing BR 3000
- 3.
ABN-54, Loss of DC Distribution Center B
- 4.
ABN-55, Loss of DC Distribution Center C Month 20XX OCGS 3-57 EP-AA-1010 (Revision XX)
I=xAInn Nu*IAar Owflufr Cree~k Ganer~atinn Stsation Annex Exelnn Nucleazr Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSS361 Initiating Condition:
Inability to shutdown the reactor causing a challenge to RPV water level or RCS heat removal.
Operating Mode Applicability:
1 Emergency Action Level (EAL):
- 1. Automatic scram did not shutdown the reactor as indicated by Reactor Power > 2%.
AND
- 2. ALL manual / ARI actions to shutdown the reactor have been unsuccessful as indicated by Reactor Power > 2%.
AND
- 3. EITHER of the following conditions exist:
" RPV water level cannot be restored and maintained > -20 inches TAF.
OR Heat Capacity Temperature Limit (EMG-3200.02 Fig. F) exceeded.
(Site specifi indication of an to adequately remove heat from the core)
(Site specific indication of an i tto adequately move heat from the ROS)
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 injectionall subsequent operator ac.tion.s to manually shutdown the reactor 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.
Month 20XX OCGS 3-58 EP-AA-1010 (Revision XX)
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EAL #3 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.
RPV values are actual levels, not indicated levels. Therefore, they may need level compensation depending on conditions.
Escalation of the emergency classification level would be via IC RAG1 or FG1.
Basis Reference(s):
- 1.
NEI 99-01 Rev 6, SS5
- 2.
EMG-3200.01 B, RPV Control - with ATWS
- 3.
EMG-3200.02, Primary Containment Control
- 4.
2000-BAS-3200.02, EOP User's Guide
- 5.
2000-GLN-3200.01, Plant Specific Technical Guideline
- 6.
EMG-3200.01A, RPV Control - no ATWS Month 20XX OCGS 3-59 EP-AA-1010 (Revision XX)
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,f 1U*U Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSA35 Initiating Condition:
Automatic or manual scram fails to shutdown the reactor, and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor.
Operating Mode Applicability:
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. ApaAutomatic or manual scram did not shutdown the reactor as indicated by Reactor Power > 2%.
AND
- 2. Manual / ARI actions taken at the reactor control consoelReactor Console are not successful in shutting down the reactor as indicated by Reactor Power > 2%.
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 G9,tr*9-consoles to shutdown the reactor are also unsuccessful. This condition represents an actual or potential substantial degradation of the level of safety of the plant. An emergency declaration is required even if the reactor is subsequently shutdown by an action taken away from the reactor GGI*GI consoles since this event entails a significant failure of the RPS.
A manual action at the reactor Gentr-el onsoles 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 GGtrc-consoles (e.g., locally opening breakers). Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be "at the reactor G9I*tr consoles".
Taking the Reactor Mode Switch to SHUTDOWN Shutdown is considered to be a manual scram action.
The plant response to the failure of an automatic or manual reactor scram will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other Month 20XX OCGS 3-60 EP-AA-1010 (Revision XX)
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Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS 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 MSS35. Depending upon plant responses and symptoms, escalation is also possible via IC FSI. Absent the plant conditions needed to meet either IC MSS35 or FS1, an Alert declaration is appropriate for this event.
It is recognized that plant responses or symptoms may also require an Alert declaration in accordance with the Recognition Category F ICs; however, this IC and EAL are included to ensure a timely emergency declaration.
A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.
Basis Reference(s):
- 1.
NEI 99-01 Rev 6, SA5
- 2.
EMG-3200.01A, RPV Control - no ATWS
- 3.
EMG-3200.01 B, RPV Control - with ATWS
- 4.
2000-BAS-3200.02, EOP User's Guide
- 5.
2000-GLN-3200.01, Plant Specific Technical Guideline Month 20XX OCGS 3-61 EP-AA-1010 (Revision XX)
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~~tin Ana~vExelln Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSU35I Initiating Condition:
Automatic or manual scram fails to shutdown the reactor.
Operating Mode Applicability:
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. An-aAutomatic scram -did not shutdown the reactor as indicated by Reactor Power > 2%.
.AND
- b. A--sSubsequent manual / ARI action taken at the reactOr cwntrol raenelesReactor Console is successful in shutting down the reactor.
- 2.
- a. A-mManual scram -did not shutdown the reactor as indicated by Reactor Power > 2%.
AND
- b. EITHER of the following:
- 1.
A--sSubsequent manual / ARI action taken at the rcactor Gcntrol GoselesReactor Console is successful in shutting down the reactor.
- 2. A-sSubsequent automatic scram / ARI is successful in shutting down the reactor.
Basis:
This IC addresses a failure of the RPS to initiate or complete an automatic or manual reactor scram that results in a reactor shutdown, and either a subsequent operator manual action taken at the reactor GentreI consoles or an automatic scram is successful in shutting down the reactor. This event is a precursor to a more significant condition and thus represents a potential degradation of the level of safety of the plant.
EAL #1 Basis Following the failure on an automatic reactor scram, operators will promptly initiate manual actions at the reactor Gentrfe consoles 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.
Month 20XX OCGS 3-62 EP-AA-1010 (Revision XX)
t-1 afar C-rook (' Pnarnfinn Atntinn Annoy Fvalnn NMItt-lor fLu*r(rk nm tin ttinAnvF ln IrIr Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS EAL #2 Basis If an initial manual reactor trip is unsuccessful, operators will promptly take manual action at another location(s) on the reactor Gei#rI consoles to shutdown the reactor (e.g., initiate a manual reactor scram / ARI using a different switch). Depending upon several factors, the initial or subsequent effort to manually scram the reactor, or a concurrent plant condition, may lead to the generation of an automatic reactor scram signal. If a subsequent manual or automatic scram / ARI is successful in shutting down the reactor, core heat generation will quickly fall to a level within the capabilities of the plant's decay heat removal systems.
A manual action at the reactor Gente! consoles is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core (e.g., initiating a manual reactor scram). This action does not include manually driving in control rods or implementation of boron injection strategies.
Actions taken at back-panels or other locations within the Control Room, or any location outside the Control Room, are not considered to be "at the reactor Getro Iconsoles".
Taking the Reactor Mode Switch to Shutdown is considered to be a manual scram action.
The plant response to the failure of an automatic or manual reactor tscram will vary based upon several factors including the reactor power level prior to the event, availability of the condenser, performance of mitigation equipment and actions, other concurrent plant conditions, etc. If subsequent operator manual actions taken at the reactor Gertre! consoles are also unsuccessful in shutting down the reactor, then the emergency classification level will escalate to an Alert via IC MgA35. Depending upon the plant response, escalation is also possible via IC FA1. Absent the plant conditions needed to meet either IC MSA35 or FA1, an Unusual Event declaration is appropriate for this event.
A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria.
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.
Month 20XX OCGS 3-63 EP-AA-1010 (Revision XX)
I=x*lon Nuclear Ovstvr Cra~k Gancaratinn Station Annex Exnlvn N.uclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Basis Reference(s):
- 1.
NEI 99-01 Rev 6, SU5
- 2.
EMG-3200.01A, RPV Control - no ATWS
- 3.
EMG-3200.01 B, RPV Control - with ATVVS
- 4.
2000-BAS-3200.02, EOP User's Guide
- 5.
2000-GLN-3200.01, Plant Specific Technical Guideline Month 20XX OCGS 3-64 EP-AA-1010 (Revision XX)
(I ator
('_ragak rZonaratin Afafinn Annov Pyninn kl"Aa2r Au@t~r (~rnak flanaratinn ~*2tinn Ann~v Fvalnn MImuIa2r Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSA421 Initiating Condition:
UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress.
Operating Mode Applicability:
1,2 Emergency Action Level (EAL):
Note: The Emergency Director should declare the eventAled promptly upon determining that the applicable time 1-6-minutes-has been exceeded, or will likely be exceeded.
- 1.
- a. AR,-UNPLANNED event results in the inability to monitor ANYeneo r moeA Table Mlef,the*followin parameters from within the Control Room for > 15 minutes O-FIGR§Gf.
Table M1 Control Room Parameters
.B.WA Prameter UM...
Reactor Power Reactfo Power RPV Water Level RPV Pressure Drywell Pressure RPV Wat.r Level,
Torus Water Level
- Torus Water Temperature RPV7 Pressure Primir~y Containment Suppr-ession Pool Lel Supprc*s*ion Pool Temperature Month 20XX OCGS 3-65 EP-AA-1010 (Revision XX)
Ovater Creek Generatina Station Annax Exelon Nuclear
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Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS AND
- b. Any Table M24 the.,el*e...i. g transient events in progress.
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Table M2 Significant Transients
" Reactor Scram
- ECCS Actuation
- Thermal power change >25%
" Thermal Power oscillations > 10%
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 eoRe OrFmeeany 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.
Month 20XX OCGS 3-66 EP-AA-1010 (Revision XX)
Ovater Creek Gener2tina Station Annex Exelon NUCIe2r Oy te Cre Gen...
Stat....n.A..nex.E......n.Nu..le.r Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS 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-IOeveRPV water level and RCS heat removal.
The loss of the ability to determine oRo or-moreany 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 OrFmoroeany 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 RAS1.
Basis Reference(s):
- 1.
NEI 99-01 Rev 6, SA2 Month 20XX OCGS 3-67 EP-AA-1010 (Revision XX)
Fx*lon N.d*ar flvster Creek (Anersatina Staution Annex Exelnn Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Initiating Condition:
UNPLANNED loss of Control Room indications for 15 minutes or longer.
Operating Mode Applicability:
1,2 Emergency Action Level (EAL):
MSU42 Note: The Emergency Director should declare the Unusual E'-ent vent promptly upon determining that the applicable time 1-5-minutes-has been exceeded, or will likely be exceeded.
a-AR-UNPLANNED event results in the inability to monitor ono* eo FerANY Table M1 parameters from within the Control Room for > 15 minutes.
Table M1 Control Room Parameters
" Reactor Power
" RPV Water Level
- RPV Pressure
- Drywell Pressure
" Torus Water Level
" Torus Water Temperature I. no t-he following p Moth f
it.hin thAe Cogntr olI ROo mR fo r 15 m-inuLtes
- 2. [RWR par~mytc
- 3. [PW-Rparmctfe
- 4. Reactor Power
- 6. React..
Pewer 51-z S8.
7P ae ec
-. ~bie
- 10. "N' Pressu
- 11. RCS Pr-essure 42].
1?
- 13.1n Cfre/Cer-e C*ntainment Er.t Temperaturc Pressure
- 14. Suppression Pl
- 15. Levels in at least Leve (site speeifi number)sem
- 16. Suppression Poo
- 17. Steam Generator-Teinpe~nu-Av~ilayff
___WaterFlw Month 20XX OCGS 3-68 EP-AA-1010 (Revision XX)
Oyster Creek Generating Station Annex Exelon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Month 20XX OCGS 3-69 EP-AA-1010 (Revision XX)
I=x*lon NuclAar flvster Creek Generzatinn Station Annex Exellon Nucla~r Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS Basis:
UNPLANNED: A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.
SAFETY SYSTEM: A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the ECCS.
These are typically systems classified as safety-related.
This IC addresses the difficulty associated with monitoring normal plant conditions without the ability to obtain SAFETY SYSTEM parameters from within the Control Room.
This condition is a precursor to a more significant event and represents a potential degradation in the level of safety of the plant.
As used in this EAL, an "inability to monitor" means that values for one oFrFmreany of the listed parameters cannot be determined from within the Control Room.
This situation would require a loss of all of the Control Room sources for the given parameter(s). For example, the reactor power level cannot be determined from any analog, digital and recorder source within the Control Room.
An event involving a loss of plant indications, annunciators and/or display systems is evaluated in accordance with 10 CFR 50.72 (and associated guidance in NUREG-1022) to determine if an NRC event report is required.
The event would be reported if it significantly impaired the capability to perform emergency assessments. In particular, emergency assessments necessary to implement abnormal operating procedures, emergency operating procedures, and emergency plan implementing procedures addressing emergency classification, accident assessment, or protective action decision-making.
This EAL is focused on a selected subset of plant parameters associated with the key safety functions of reactivity control, core cooling and RCS heat removal. The loss of the ability to determine ono or moroany 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 moeany of the listed parameters are lost, then the ability to determine the values of other SAFETY SYSTEM parameters may be impacted as well.
For example, if the value for reactor vessel level cannot be determined from the indications and recorders on a main control board, the SPDS or the plant computer, the availability of other parameter values may be compromised as well.
Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication.
Escalation of the emergency classification level would be via IC MSA42.
Basis Reference(s):
Month 20XX OCGS 3-70 EP-AA-1010 (Revision XX)
Oyster Creek Generating Station Annex Exelon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS
- 1.
NEI 99-01 Rev 6, SU2 Month 20XX OCGS 3-71 EP-AA-1010 (Revision XX)
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Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSA58 Initiating Condition:
Hazardous event affecting a SAFETY SYSTEM needed-required for the current operating mode.
Operating Mode Applicability:
1,2 Emergency Action Level (EAL):
(-14
- 1. a The occurrence of ANY of the following hazardous events:
" Seismic event (earthquake)
- Internal or external flooding event
" High winds or tornado strike
" FIRE
- EXPLOSION
" (site Specific hazards)
" Other events with similar hazard characteristics as determined by the Shift Manager AND 2.b-.
EITHER of the following:
a.4-1 Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM needed-required by Technical Specifications for the current operating mode.
- b. 2.
The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure needed-required by Technical Specifications for the current operating mode.
- c.
A seismic event required a manual reactor scram per ABN-38, Station Seismic Event.
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 Month 20XX OCGS 3-72 EP-AA-1010 (Revision XX)
Ovster Creek Generatina Station Annex Exelon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS 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.
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, nieeded-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-1.b.4EAL #2.a addresses damage to a SAFETY SYSTEM train that is required to be operable by Technical Specifications for the current operating mode, and is in sewiee/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 -44EAL #2.b 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 seevieeoperation or readily apparent through indications alone, or--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 OCGS 3-73 EP-AA-1010 (Revision XX)
I=xAInn N.*l*ar Ovster Creek (Anersatinn Stsation Annex Exelnn Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS MSU64 Initiating Condition:
RCS leakage for 15 minutes or longer.
Operating Mode Applicability:
1,2 Emergency Action Level (EAL):
Note: The Emergency Director should declare the Unusual E'ventevent promptly upon determining that the applicable time 1-5-minutes-has been exceeded, or will likely be exceeded.
- 1. RCS unidentified or pressure boundary leakage in the Drywell g-eateF-thaR
> 10 gpm for > 15 minutes. (site Specific value) for 15 minutes Or longer.
- 2. RCS identified leakage in the Drywell gFeate&-thaFi->25 gpm for > 15 minutes.(site-specific value) fo 15 minutes Or longer.
- 3. Leakage from the RCS to a location outside eRtaninmet-the Drywell >25 gpm for >
15 minutes ge. ater than 25 gpm for 15 minutes, Or l.ngr.
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 steam ge.neraaton. r 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 Month 20XX OCGS 3-74 EP-AA-1010 (Revision XX)
fllafar (rnni, (flangrafinn A*tinn AnnoyFAn tdzr-eu*W
.3
- s.
C.
~
I=Yelnn N.rlAar Exelon Nuclear Table OCGS 3-2 OCGS EAL Technical Basis RECOGNITION CATEGORY SYSTEM MALFUNCTIONS 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.
The release of mass from the RCS due to the as-designed/expected operation of any relief valve does not warrant an emergency classification.
F:WRI,!sAa stuck-open Safety-Electromatic Relief Valve (6R-VEMRV) or SRV-EMRV 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.
Technical Specifications 3.3.D, Reactor Coolant System Leakage Month 20XX OCGS 3-75 EP-AA-1010 (Revision XX)