ML15141A048
| ML15141A048 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 05/07/2015 |
| From: | Capps S Duke Energy Carolinas |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML15141A047 | List: |
| References | |
| MNS-15-018 | |
| Download: ML15141A048 (127) | |
Text
Steven D. Capps DUKE Vice President EN Y
McGuire Nuclear Station Duke Energy MG01VP 112700 Hagers Ferry Road Huntersville, NC 28078 o: 980.875.4805 f: 980.875.4809 Steven.Capps@duke-energy.com 10 CFR 50.90 10 CFR 50 Appendix E May 07, 2015 MNS-1 5-018 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 Duke Energy Carolinas, LLC (Duke Energy)
McGuire Nuclear Station Units 1 and 2 Docket Nos. 50-369, 50-370 Renewed License Nos. NPF-9 and NPF-17
Subject:
License Amendment Request to Adopt Emergency Action Level Scheme Pursuant to NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors" dated November 2012 In accordance with the provisions of 10 CFR 50.90 and 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities,"Section IV.B, Duke Energy is submitting a request for an amendment to the Emergency Plan for McGuire Nuclear Station, Units 1 and 2 (MNS).
The proposed amendment involves upgrading selected MNS Emergency Action Levels (EALs) based on NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors," using the guidance of NRC Regulatory Issue Summary 2003-18, Supplement 2, "Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels." MNS currently uses an emergency classification scheme based on NUMARC/NESP-007 (Revision 2, January 1992), "Methodology for Development of Emergency Action Levels," (endorsed by the Nuclear Regulatory Commission in Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors," Revision 3, August 1992). The plan, as changed, would continue to meet the standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR 50. Pursuant to 10 CFR 50, Appendix E, Section IV.B, Duke Energy requests NRC approval of this proposed change to the MNS Emergency Plan prior to implementation.
United States Nuclear Regulatory Commission May 07, 2015 Page 2 The enclosures to this letter provide descriptions and assessments of the proposed changes.
The enclosures also provide the existing Emergency Plan pages marked up to show the proposed changes: - Evaluation of Proposed Change - MNS NEI 99-01, Revision 6 Emergency Action Level (EAL) Comparison Matrix - EAL Technical Bases Document (Clean Version) - EAL Technical Bases Document (Redline and Strikeout Version) - MNS Radiological Effluent EAL Values - MNS EAL Wallcharts Duke Energy requests approval of the proposed changes by April 30, 2016, with the amendment being implemented by the end of the third quarter 2016.
In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated North Carolina State Officials.
Duke Energy commits to review the new classification scheme with state and local emergency management officials following NRC approval and prior to implementation of the changes.
If there are any questions related to this submittal contact George Murphy at (980) 875-5715.
I declare under penalty of perjury that the foregoing is true and correct. Executed on May 07, 2015.
Steven D. Capps
Enclosures:
- Evaluation of Proposed Change - MNS NEI 99-01, Revision 6 Emergency Action Level (EAL) Comparison Matrix - EAL Technical Bases Document (Clean Version) - EAL Technical Bases Document (Redline and Strikeout Version) - MNS Radiological Effluent EAL Values - MNS EAL Wallcharts
United States Nuclear Regulatory Commission May 07, 2015 Page 3 xc:
V. M. McCree, Region II Administrator U.S. Nuclear Regulatory Commission Marquis One Tower 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, Georgia 30303-1257 G. E. Miller, Project Manager U.S. Nuclear Regulatory Commission 11555 Rockville Pike Mail Stop 8 G9A Rockville, MD 20852-2738 J. Zeiler NRC Senior Resident Inspector McGuire Nuclear Station W.L. Cox Ill, Section Chief North Carolina Department of Environment and Natural Resources Division of Environmental Health Radiation Protection Section 1645 Mail Service Center Raleigh. NC 27699-1645
ENCLOSURE I EVALUATION OF PROPOSED CHANGE
SUBJECT:
PROPOSED CHANGE TO MNS THE EMERGENCY PLAN 1.0
SUMMARY
DESCRIPTION 2.0 DETAILED DESCRIPTION
3.0 TECHNICAL EVALUATION
4.0 REGULATORY EVALUATION
4.1 APPUCABLE REGULATORY REQUIREMENTS/CRITERIA 4.2 NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION
4.3 CONCLUSION
S
5.0 ENVIRONMENTAL CONSIDERATION
6.0 REFERENCES
Page 2 of 8 1.0
SUMMARY
DESCRIPTION In accordance with the provisions of 10 CFR 50.90 and 10 CFR 50, Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities,"Section IV.B, Duke Energy is submitting a license amendment request to change the McGuire Nuclear Station (MNS) Emergency Plan.
The proposed changes involve upgrading selected MNS Emergency Action Levels (EALs) based on NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors," using the guidance of NRC Regulatory Issue Summary 2003-18, Supplement 2, "Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels." MNS currently uses an emergency classification scheme based on NUMARC/NESP-007 (Revision 2, January 1992), "Methodology for Development of Emergency Action Levels (endorsed by the Nuclear Regulatory Commission in Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors," Revision 3, August 1992 and approved for MNS in Reference 6). The plan, as changed, would continue to meet the standards in 10 CFR 50.47(b) and the requirements in Appendix E to 10 CFR 50.
2.0 DETAILED DESCRIPTION MNS currently uses an emergency classification scheme based on NUMARC/NESP-007 (Revision 2, January 1992), "Methodology for Development of Emergency Action Levels,"
(endorsed by the NRC in Regulatory Guide 1.101, "Emergency Planning and Preparedness for Nuclear Power Reactors," Revision 3, August 1992). Duke Energy requests approval to change the MNS scheme basis to that described in NEI 99-01, Revision 6.
3.0 TECHNICAL EVALUATION
The Initiating Conditions (ICs) and EALs that comprise the proposed scheme are presented in Enclosure 2. This matrix provides a cross-reference between each generic IC and EAL contained in NEI 99-01, Revision 6 and the proposed MNS-specific IC and EAL. Differences and Deviations are identified in accordance with the guidance discussed in RIS 2003-18 (and Supplements). The basis for each Difference is also included. There are no Deviations from NEI 99-01, Revision 6.
The matrix follows the presentation order of NEI 99-01, Revision 6, Abnormal Rad Levels/Radiological Effluent, Cold Shutdown/Refueling System Malfunction, Events Related to Independent Spent Fuel Storage Installation (ISFSI), Fission Product Barrier Degradation, Hazards and Other Conditions Affecting Plant Safety, and System Malfunction. The Defueled Station section is not used since MNS is an operating unit.
Page 3 of 8 Differences and Deviations As discussed in Regulatory Issue Summary (RIS) 2003-18, Supplement 2 dated December 12, 2005, differences and deviations are defined as follows:
" A difference is an EAL change where the basis scheme guidance differs in wording but agrees in meaning and intent, such that classification of an event would be the same, whether using the basis scheme guidance or the site-specific proposed EAL.
Examples of differences include the use of site-specific terminology or administrative re-formatting of site-specific EALs.
" A deviation is an EAL change where the basis scheme guidance differs in wording and is altered in meaning or intent, such that classification of the event could be different between the basis scheme guidance and the site-specific proposed EAL.
Examples of deviations include the use of altered mode applicability, altering key words or time limits, or changing words of physical reference (protected area, safety-related equipment, etc.). identifies each Difference between NEI 99-01 and the final products being evaluated in this LAR. These differences do not alter the meaning or intent of the ICs or EALs. There are no Deviations between NEI 99-01 and the final products being evaluated in this LAR.
Incorporation of Action Level Frequently Asked Questions (EALFAQs)
Where appropriate, information from Emergency Action Level Frequently Asked Questions (EALFAQs) has been incorporated into Enclosure 2 and Enclosure 3.
Related Documents includes the site-specific Technical Basis Document for each recognition category for the proposed scheme. A Redline and Strikeout version of the Technical Basis Document is provided as Enclosure 4. These documents include appropriate information from the basis information contained in NEI 99-01, Revision 6. Enclosure 5 contains the supporting calculation for MNS EAL Table R-1, "Effluent Monitor Classification Thresholds." contains the revised MNS EAL Wallcharts.
Page 4 of 8 Operational Modes and Applicability Mode applicability of the proposed ICs and EALs is consistent with the NEI 99-01, Revision 6 basis scheme. The Operating Modes for MNS, as defined in the Technical Specifications, are listed below.
REACTIVITY
% RATED Average Reactor Coolant MODE TITLE CONDITION THERMAL Temperature (OF)
(k.ff)
POWER 1
Power Operation
> 0.99
> 5 NA 2
Startup
> 0.99
< 5 NA 3
Hot Standby
< 0.99 NA
> 350 4
Hot Shutdown
< 0.99 NA 350 > Ta,0 > 200 5
Cold Shutdown
< 0.99 NA
< 200 6
Refueling NA NA NA In addition to these operating modes, NEI 99-01, Revision 6 defines the "Defueled" mode, as "All reactor fuel removed from Reactor Vessel (full core off load during refueling or extended outage)." MNS procedures recognize this condition as "No Mode".
State I Local Government Review of Proposed Changes Duke Energy interacts periodicaly with the North Carolina and local emergency management agencies. The State and local emergency management officials are advised of any EAL changes actually implemented. In the case of this EAL scheme revision, Duke Energy has committed to provide a review of the new classification scheme to State and local emergency management officials following NRC approval and prior to implementation.
Page 5 of 8 Implementation Description Duke Energy plans to implement the proposed emergency classification scheme in the third quarter of 20161. When implemented, the changes to the EALs presented in Enclosure 3 will become effective. The Emergency Action Level Technical Basis Documents (Enclosure 3) will be revised and maintained as a training and background reference resource. Any changes to the approved ICs and EALs will be made in accordance with 10 CFR 50.54(q).
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.47(b)(4) states, "A standard emergency classification and action level scheme, the bases of which include facility system and effluent parameters, is in use by the nuclear facility licensee, and State and local response plans call for reliance on information provided by facility licensees for determinations of minimum initial offsite response measures."
10 CFR 50 Appendix E, Section IV. Content of Emergency Plans, Item B, Assessment Actions states:
- 1. "The means to be used for determining the magnitude of, and for continually assessing the impact of, the release of radioactive materials shall be described, including emergency action levels that are to be used as criteria for determining the need for notification and participation of local and State agencies, the Commission, and other Federal agencies, and the emergency action levels that are to be used for determining when and what type of protective measures should be considered within and outside the site boundary to protect health and safety. The emergency action levels shall be based on in-plant conditions and instrumentation in addition to onsite and offsite monitoring. By June 20, 2012, for nuclear power reactor licensees, these action levels must include hostile action that may adversely affect the nuclear power plant. The initial emergency action levels shall be discussed and agreed on by the applicant or licensee and state and local governmental authorities, and approved by the NRC. Thereafter, emergency action levels shall be reviewed with the State and local governmental authorities on an annual basis."
- 2. "A licensee desiring to change its entire emergency action level scheme shall submit an application for an amendment to its license and receive NRC approval before implementing the change. Licensees shall follow the change process in 10 CFR 50.54(q) for all other emergency action level changes."
This plan is contingent on several factors including the anticipated time required for NRC review and approval and the MNS Unit 1 Refueling Outage to be conducted in Spring of 2016.
Page 6 of 8 Regulatory Guide 1.101, Emergency Planning and Preparedness for Nuclear Power Reactors, Revision 4, Section C. Regulatory Position states, "The guidance in NUMARC/NESP-007 (Revision 2, January 1992), "Methodology for Development of Emergency Action Levels," is acceptable to the NRC staff as an alternative method to that described in Appendix 1 to NUREG-0654/FEMA-REP-1 for developing EALs required in Section IV.B of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4). In addition, the guidance contained in NEI 99-01 (Revision 4, January 2003), "Methodology for Development of Emergency Action Levels," is acceptable to the NRC staff as an alternative method to that described in Appendix 1 to NUREG-0654/FEMA-REP-1 and NUMARCINESP-007 for developing EALs required in Section IV of Appendix E to 10 CFR Part 50 and 10 CFR 50.47(b)(4)."
This plan is contingent on several factors including the anticipated time required for NRC review and approval and the MNS Unit I Refueling Outage to be conducted in Spring of 2016.
4.2 Significant Hazards Consideration Duke Energy has evaluated whether or not a significant hazards consideration (SHC) is warranted with the proposed changes by addressing the three criterion set forth in 10 CFR 50.92(c) as discussed below.
Criterion 1:
Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
These changes affect the MNS Emergency Plan and do not alter any of the requirements of the Operating License or the Technical Specifications. The proposed changes do not modify any plant equipment and do not impact any failure modes that could lead to an accident. Additionally, the proposed changes do not impact the consequence of any analyzed accident since the changes do not affect any equipment related to accident mitigation. Based on this discussion, the proposed amendment does not increase the probability or consequences of an accident previously evaluated.
Criterion 2:
Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
These changes affect the MNS Emergency Plan and do not alter any of the requirements of the Operating License or the Technical Specifications. They do not modify any plant equipment and there is no impact on the capability of the existing equipment to perform its intended functions. No system setpoints are being modified, and no changes are being made to the method in which plant operations are conducted. No new failure modes are Page 7 of 8 introduced by the proposed changes. The proposed amendment does not introduce accident initiator or malfunctions that would cause a new or different kind of accident.
Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.
Criterion 3:
Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
These changes affect the MNS Emergency Plan and do not alter any of the requirements of the Operating License or the Technical Specifications. The proposed changes do not affect any of the assumptions used in the accident analysis, nor do they affect any operability requirements for equipment important to plant safety. Therefore, the proposed changes will not result in a significant reduction in the margin of safety as defined in the bases for technical specifications covered in this license amendment request.
4.3 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
5.0 ENVIRONMENTAL CONSIDERATION
Duke Energy has determined that the proposed amendment would not change requirements with respect to use of a facility component located within the restricted area, as defined by 10 CFR 20, nor would it change inspection or surveillance requirements. Duke Energy has evaluated the proposed change and has determined that the change does not involve:
I. A Significant Hazards Consideration, I1. A significant change in the types or significant increase in the amounts of any effluent that may be released off site, or I1l. A significant increase In individual or cumulative occupational radiation exposure.
Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9) and (10)(ii). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
Enclosure I Page 8 of 8
6.0 REFERENCES
- 1.
NUMARC/NESP-007, Revision 2, "Methodology for Development of Emergency Action Levels", dated January 1992 (ADAMS Accession No.ML041120174)
- 2.
NEI 99-01, Revision 6, "Development of Emergency Action Levels for Non-Passive Reactors", dated November 2012, (ADAMS Accession No. ML12326A805)
- 3.
NRC Regulatory Issue Summary 2003-18, Supplement 2, "Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels",
dated December 12, 2005 (ADAMS Accession No. ML051450482)
- 4.
Regulatory Guide 1.101, Revision 3, "Emergency Planning and Preparedness for Nuclear Power Reactors" dated August 1992 (ADAMS Accession No. ML003740302)
- 5.
Letter from Frank Rinaldi (USNRC) to H. B. Barron (Duke Energy) dated January 28, 1998, "Emergency Action Level Changes - McGuire Nuclear Station Units 1 and 2 (TAC Nos. M94491 and M94492)"
ENCLOSURE 2 MNS NEI 99-01, REVISION 6 EAL COMPARISON MATRIX
(,
DUKE ENERGY9 McGuire Nuclear Station NEI 99-01 Revision 6 EAL Comparison Matrix Revision 0 [5/6/15]
EAL Comparison Matrix MNS Table of Contents Section PaQe Introduction 1
Comparison Matrix Format 1
EAL Wording 1
EAL Emphasis Techniques 1
Global Differences 2
Differences and Deviations 3
Category A - Abnormal Rad Levels / Rad Effluents 12 Category C - Cold Shutdown / Refueling System Malfunction 29 Category D - Permanently Defueled Station Malfunction 50 Category E - Events Related to Independent Spent Fuel Storage Installations 52 Category F - Fission Product Barrier Degradation 54 Category H - Hazards and Other Conditions Affecting Plant Safety -------------------------------------------------------------------------------
67 Category S - System Malfunction 86 Table 1 - MNS EAL Categories/Subcategories 5
Table 2 - NEI / MNS EAL Identification Cross-Reference --------------------------------------------------------
6 Table 3 - Summary of Deviations 11 i ofi
EAL Comparison Matrix MINIS Introduction This document provides a line-by-line comparison of the Initiating Conditions (ICs), Mode Applicability and Emergency Action Levels (EALs) in NEI 99-01 Rev. 6 Final, Development of Emergency Action Levels for Non-Passive Reactors, ADAMS Accession Number ML12326A805, and the McGuire Nuclear Station (MNS) ICs, Mode Applicability and EALs. This document provides a means of assessing MNS differences and deviations from the NRC endorsed guidance given in NEI 99-01. Discussion of MNS EAL bases and lists of source document references are given in the EAL Technical Bases Document. It is, therefore, advisable to reference the EAL Technical Bases Document for background information while using this document.
MNS has taken no deviations from the generic guidance.
Comparison Matrix Format The ICs and EALs discussed in this document are grouped according to NEI 99-01 Recognition Categories. Within each Recognition Category, the ICs and EALs are listed in tabular format according to the order in which they are given in NEI 99-01. Generally, each row of the comparison matrix provides the following information:
NEI EAL/IC identifier NEI EAL/IC wording MNS EAL/IC identifier MNS EAL/IC wording Description of any differences or deviations EAL Wording In Section 4.1, NEI recommends the following: "The guidance in NEI 99-01 is not intended to be applied to plants "as-is"; however, developers should attempt to keep their site-specific schemes as close to the generic guidance as possible. The goal is to meet the intent of the generic Initiating Conditions (ICs) and Emergency Action Levels (EALs) within the context of site-specific characteristics - locale, plant design, operating features, terminology, etc.
Meeting this goal will result in a shorter and less cumbersome NRC review and approval process, closer alignment with the schemes of other nuclear power plant sites and better positioning to adopt future industry-wide scheme enhancements" EAL Emphasis Techniques Due to the width of the table columns and table formatting constraints in this document, line breaks and indentation may differ slightly from the appearance of comparable wording in the source documents. NEI 99-01 is the source document for the NEI EALs; the MNS EAL Technical Bases Document for the MNS EALs.
The print and paragraph formatting conventions summarized below guide presentation of the MNS EALs in accordance with the EAL writing criteria.
Space restrictions in the EAL table of this document sometimes override this criteria in cases when following the criteria would introduce undesirable complications in the EAL layout.
Upper case-bold print is used for the logic terms AND, OR and EITHER.
Bold font is used for certain logic terms, negative terms (not, cannot, etc.), any, all.
Upper case print is reserved for defined terms, acronyms, system abbreviations, logic terms (and, or, etc. when not used as a conjunction), annunciator window engravings.
Three or more items in a list are normally introduced with "Any of the following..." or "All of the following..." Items of the list begin with bullets when a priority or sequence is not inferred.
The use of AND/OR logic within the same EAL has been avoided when possible. When such logic cannot be avoided, indentation and separation of subordinate contingent phrases is employed.
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EAL Comparison Matrix MNS Global Differences The differences listed below generally apply throughout the set of EALs and are not repeated in the Justification sections of this document. The global differences do not decrease the effectiveness of the intent of NEI 99-01.
- 1. The NEI phrase "Notification of Unusual Event" has been changed to "Unusual Event" or abbreviated "UE" to reduce EAL-user reading burden.
- 2.
NEI 99-01 IC Example EALs are implemented in separate plant EALs to improve clarity and readability. For example, NEI lists all IC HU3 Example EALs under one IC. The corresponding MNS EALs appear as unique EALs (e.g., HU3.1 through HU3.4).
- 3.
Mode applicability identifiers (numbers/letter) modify the NEI 99-01 mode applicability names as follows: 1 - Power Operation, 2 -
Startup, 3 - Hot Standby, 4 - Hot Shutdown, 5 - Cold Shutdown, 6 -
Refueling, NM - No Mode. MNS defines NM the same as NEI 99-01defines Defueled as follows: "Reactor Vessel contains no irradiated fuel"
- 4.
NEI 99-01 uses the terms greater than, less than, greater than or equal to, etc. in the wording of some example EALs. For consistency and reduce EAL-user reading burden, MNS has adopted use of boolean symbols in place of the NEI 99-01 text modifiers within the EAL wording.
- 5.
"min." is the standard abbreviation for "minutes" and is used to reduce EAL user reading burden.
- 6. The term "Emergency Director" has been replaced by "Emergency Coordinator/EOF Director" consistent with site-specific nomenclature.
- 7. Wherever the generic bracketed PWR term "reactor vessel/RCS" is provided, MNS uses the term "NCS" as the site-specific nomenclature.
- 8.
IC/EAL identification:
NEI Recognition Category A "Abnormal Radiation Levels/
Radiological Effluents" has been changed to Category R "Abnormal Rad Levels / Rad Effluents." The designator "R" is more intuitively associated with radiation (rad) or radiological events. NEI IC designators beginning with "A" have likewise been changed to "R."
NEI 99-01 defines the thresholds requiring emergency classification (example EALs) and assigns them to ICs which, in turn, are grouped in "Recognition Categories." The MNS IC/EAL scheme includes the following features:
- a.
Division of the NEI EAL set into three groups:
o EALs applicable under all plant operating modes -
This group would be reviewed by the EAL-user any time emergency classification is considered.
o EALs applicable only under hot operating modes -
This group would only be reviewed by the EAL-user when the plant is in Hot Shutdown, Hot Standby, Startup or Power Operation mode.
o EALs applicable only under cold operating modes -
This group would only be reviewed by the EAL-user when the plant is in Cold Shutdown, Refueling or No Mode.
The purpose of the groups is to avoid review of hot condition EALs when the plant is in a cold condition and avoid review of cold condition EALs when the plant is in a hot condition. This approach significantly minimizes the total number of EALs that must be reviewed by the EAL-user for a given plant condition, reduces EAL-user reading burden and, thereby, speeds identification of the EAL that applies to the emergency.
- b.
Within each of the above three groups, assignment of EALs to categories/subcategories - Category and subcategory titles are selected to represent conditions that are operationally significant to the EAL-user.
Subcategories are used as necessary to further divide the EALs of a category into logical sets of possible emergency classification thresholds. The MNS EAL categories/subcategories and their relationship to NEI Recognition Categories are listed in Table 1.
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- c.
Unique identification of each EAL - Four characters comprise the EAL identifier as illustrated in Figure 1.
Figure 1 - EAL Identifier EAL Identifier XXX.X Category (R, H, E, S, F, C)-
j L
Sequential number within subcategoryfclassification Emergency classification (G, S, A, U)
Subcategory number (1 if no subcategory)
The first character is a letter associated with the category in which the EAL is located. The second character is a letter associated with the emergency classification level (G for General Emergency, S for Site Area Emergency, A for Alert, and U for Notification of Unusual Event). The third character is a number associated with one or more subcategories within a given category. Subcategories are sequentially numbered beginning with the number 1". If a category does not have a subcategory, this character is assigned the number '1 ". The fourth character is a number preceded by a period for each EAL within a subcategory. EALs are sequentially numbered within the emergency classification level of a subcategory beginning with the number "1".
The EAL identifier is designed to fulfill the following objectives:
o Uniqueness - The EAL identifier ensures that there can be no confusion over which EAL is driving the need for emergency classification.
o Speed in locating the EAL of concern - When the EALs are displayed in a matrix format, knowledge of the EAL identifier alone can lead the EAL-user to the location of the EAL within the classification matrix. The identifier conveys the category, subcategory and classification level. This assists ERO responders (who may not be in the same facility as the EC) to find the EAL of concern in a timely manner without the need for a word description of the classification threshold.
o Possible classification upgrade - The category/subcategory/identifier scheme helps the EAL-user find higher emergency classification EALs that may become active if plant conditions worsen.
Table 2 lists the MNS ICs and EALs that correspond to the NEI ICs/Example EALs when the above EAL/IC organization and identification scheme is implemented.
Differences and Deviations In accordance NRC Regulatory Issue Summary (RIS) 2003-18 "Use of Nuclear Energy Institute (NEI) 99-01, Methodology for Development of Emergency Action Levels" Supplements 1 and 2, a difference is an EAL change in which the basis scheme guidance differs in wording but agrees in meaning and intent, such that classification of an event would be the same, whether using the basis scheme guidance or the MNS EAL. A deviation is an EAL change in which the basis scheme guidance differs in wording and is altered in meaning or intent, such that classification of the event could be different between the basis scheme guidance and the MNS proposed EAL.
Administrative changes that do not actually change the textual content are neither differences nor deviations. Likewise, any format change that does not alter the wording of the IC or EAL is considered neither a difference nor a deviation.
The following are examples of differences:
Choosing the applicable EAL based upon plant type (i.e., BWR vs.
PWR).
Using a numbering scheme other than that provided in NEI 99-01 that does not change the intent of the overall scheme.
Where the NEI 99-01 guidance specifically provides an option to not include an EAL if equipment for the EAL does not exist at MNS (e.g.,
automatic real-time dose assessment capability).
Pulling information from the bases section up to the actual EAL that does not change the intent of the EAL.
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EAL Comparison Matrix MNS Choosing to state ALL Operating Modes are applicable instead of stating N/A, or listing each mode individually under the Abnormal Rad Level/Radiological Effluent and Hazard and Other Conditions Affecting Plant Safety sections.
Using synonymous wording (e.g., greater than or equal to vs. at or above, less than or equal vs. at or below, greater than or less than vs. above or below, etc.)
Adding MNS equipment/instrument identification and/or noun names to EALs.
Combining like ICs that are exactly the same but have different operating modes as long as the intent of each IC is maintained and the overall progression of the EAL scheme is not affected.
Any change to the IC and/or EAL, and/or basis wording, as stated in NEI 99-01, that does not alter the intent of the IC and/or EAL, i.e.,
the IC and/or EAL continues to:
o Classify at the correct classification level.
o Logically integrate with other EALs in the EAL scheme.
o Ensure that the resulting EAL scheme is complete (i.e.,
classifies all potential emergency conditions).
The following are examples of deviations:
Use of altered mode applicability.
Altering key words or time limits.
Changing words of physical reference (protected area, safety-related equipment, etc.).
Eliminating an IC. This includes the removal of an IC from the Fission Product Barrier Degradation category as this impacts the logic of Fission Product Barrier ICs.
C changing a Fission Product Barrier from a Loss to a Potential Loss or vice-versa.
Not using NEI 99-01 definitions as the intent is for all NEI 99-01 users to have a standard set of defined terms as defined in NEI 99-01.
Differences due to plant types are permissible (BWR or PWR).
Verbatim compliance to the wording in NEI 99-01 is not necessary as long as the intent of the defined word is maintained. Use of the wording provided in NEI 99-01 is encouraged since the intent is for all users to have a standard set of defined terms as defined in NEI 99-01.
Any change to the IC and/or EAL, and/or basis wording as stated in NEI 99-01 that does alter the intent of the IC and/or EAL, i.e., the IC and/or EAL:
o Does not classify at the classification level consistent with NEI 99-01.
o Is not logically integrated with other EALs in the EAL scheme.
o Results in an incomplete EAL scheme (i.e., does not classify all potential emergency conditions).
The "Difference Justification" columns in the remaining sections of this document identify each difference between the NEI 99-01 IC/EAL wording and the MNS IC/EAL wording. An explanation that justifies the reason for each difference is then provided. If the difference is determined to be a deviation, a statement is made to that affect and explanation is given that states why classification may be different from the NEI 99-01 IC/EAL and the reason for its acceptability. In all cases, however, the differences and deviations do not decrease the effectiveness of the intent of NEI 99-01. MNS has identified no deviations from the NEI 99-01 guidance as represented in Table 3.
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EAL Comparison Matrix MNS Table 1 - MNS EAL Categories/Subcategories MNS EALs NEI Category Subcategory Recognition Category Group: Any Operating Mode:
1 - Radiological Effluent Abnormal Rad Levels/Radiological Effluent R - Abnormal Rad Levels/Rad Effluent 2 - Irradiated Fuel Event ICs/EALs 3 - Area Radiation Levels H - Hazards and Other Conditions Affecting 1 - Security Hazards and Other Conditions Affecting Plant Safety 2 - Seismic Event Plant Safety ICs/EALs 3 - Natural or Technological Hazard 4 - Fire 5 - Hazardous Gas 6 - Control Room Evacuation 7 - Emergency Coordinator Judgment E -
ISFSI 1 - Confinement Boundary ISFSI ICs/EALs Group: Hot Conditions:
1 - Loss of Essential AC Power System Malfunction ICs/EALs 2 - Loss of Vital DC Power 3 - Loss of Control Room Indications 4 - NCS Activity S - System Malfunction 5 - NCS Leakage 6 - RPS Failure 7 - Loss of Communications 8 - Containment Failure 9 - Hazardous Event Affecting Safety Systems F - Fission Product Barrier None Fission Product Barrier ICs/EALs Group: Cold Conditions:
1 - NCS Level Cold Shutdown./ Refueling System 2 - Loss of Essential AC Power Malfunction ICs/EALs C - Cold Shutdown/Refueling System 3 - NCS Temperature Malfunction 4 - Loss of Vital DC Power 5 - Loss of Communications 6 - Hazardous Event Affecting Safety Systems 5 of 113
EAL Comparison Matrix MNS Table 2 - NEI / MNS EAL Identification Cross-Reference NEI MNS IC Example IC EAL Category and Subcategory EAL AU1 1
R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RU1.1 AU1 2
R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RU1.1 AU1 3
R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RU1.2 AU2 1
R - Abnormal Rad Levels / Rad Effluent, 2 - Irradiated Fuel Event RU2.1 AA1 1
R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RA1.1 AA1 2
R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RA1.2 AA1 3
R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RA1.3 AA1 4
R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RA1.4 AA2 1
R - Abnormal Rad Levels / Rad Effluent, 2 - Irradiated Fuel Event RA2.1 AA2 2
R - Abnormal Rad Levels / Rad Effluent, 2 - Irradiated Fuel Event RA2.2 AA2 3
R - Abnormal Rad Levels / Rad Effluent, 2 - Irradiated Fuel Event RA2.3 AA3 1
R - Abnormal Rad Levels / Rad Effluent, 3 - Area Radiation Levels RA3.1 AA3 2
R - Abnormal Rad Levels / Rad Effluent, 3 - Area Radiation Levels RA3.2 AS1 1
R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RS1.1 AS1 2
R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RS1.2 AS1 3
R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RS1.3 6 of 113
EAL Comparison Matrix MNS NEI MNS IC Example IC EAL Category and Subcategory EAL AS2 1
R - Abnormal Rad Levels / Rad Effluent, 2 - Irradiated Fuel Event RS2.1 AG1 1
R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RG1.1 AGI 2
R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RG1.2 AG1 3
R - Abnormal Rad Levels / Rad Effluent, 1 - Radiological Effluent RG1.3 AG2 1
R - Abnormal Rad Levels / Rad Effluent, 2 - Irradiated Fuel Event RG2.1 Cui I
C - Cold SD/ Refueling System Malfunction, 1 - NCS Level CU1.1 CUl 2
C - Cold SD/ Refueling System Malfunction, 1 - NCS Level CU1.2 CU2 1
C - Cold SD/ Refueling System Malfunction, 2 - Loss of ESF AC Power CU2.1 CU3 1
C - Cold SD/ Refueling System Malfunction, 3 - NCS Temperature CU3.1 CU3 2
C - Cold SD/ Refueling System Malfunction, 3 - NCS Temperature CU3.2 CU4 1
C - Cold SD/ Refueling System Malfunction, 4-Loss of Vital DC Power CU4.1 CU5 1, 2, 3 C - Cold SD/ Refueling System Malfunction, 5 - Loss of Communications CU5.1 CA1 1
C - Cold SD/ Refueling System Malfunction, 1 - NCS Level CA1.1 CA1 2
C - Cold SD/ Refueling System Malfunction, 1 - NCS Level CA1.2 CA2 1
C - Cold SD/ Refueling System Malfunction, 1 - Loss of ESF AC Power CA2.1 CA3 1,2 C - Cold SD/ Refueling System Malfunction, 3 - NCS Temperature CA3.1 CA6 1
C - Cold SD/ Refueling System Malfunction, 6 - Hazardous Event Affecting Safety Systems CA6.1 CS1 1
N/A N/A 7 of 113
EAL Comparison Matrix MNS NEI MNS Example Category and Subcategory EAL EAL CS1 2
N/A N/A CS1 3
C-Cold SD/ Refueling System Malfunction, 1 - NCS Level CS1.1 CG1 1
N/A N/A CG1 2
C -Cold SD/ Refueling System Malfunction, 1 - NCS Level CG1.1 E-HU1 1
E - ISFSI EU1.1 FA1 1
F - Fission Product Barrier Degradation FA1.1 FS1 1
F - Fission Product Barrier Degradation FS1.1 FG1 1
F - Fission Product Barrier Degradation FG1.1 HU1 1, 2, 3 H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security HU1.1 HU2 1
H - Hazards and Other Conditions Affecting Plant Safety, 2 - Seismic Event HU2.1 HU3 1
H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technological Hazard HU3.1 HU3 2
H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technological Hazard HU3.2 HU3 3
H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technological Hazard HU3.3 HU3 4
H - Hazards and Other Conditions Affecting Plant Safety, 3 - Natural or Technological Hazard HU3.4 HU3 5
N/A N/A HU4 1
H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire or Explosion HU4.1 HU4 2
H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire or Explosion HU4.2 HU4 3
H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire or Explosion HU4.3 8 of 113
EAL Comparison Matrix MNS NEI MNS IC Example Category and Subcategory EAL EAL HU4 4
H - Hazards and Other Conditions Affecting Plant Safety, 4 - Fire or Explosion HU4.4 HU7 1
H - Hazards and Other Conditions Affecting Plant Safety, 7 - Judgment HU7.1 HAl 1, 2 H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security HA1.1 HA5 1
H - Hazards and Other Conditions Affecting Plant Safety, 5 - Hazardous Gases HA5.1 HA6 1
H - Hazards and Other Conditions Affecting Plant Safety, 6 - Control Room Evacuation HA6.1 HA7 1
H - Hazards and Other Conditions Affecting Plant Safety, 7 - Judgment HA7.1 HS1 1
H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security HS1.1 HS6 1
H - Hazards and Other Conditions Affecting Plant Safety, 6 - Control Room Evacuation HS6.1 HS7 1
H - Hazards and Other Conditions Affecting Plant Safety, 7 - Judgment HS7.1 HG1 1
H - Hazards and Other Conditions Affecting Plant Safety, 1 - Security HG1.1 HG7 1
H - Hazards and Other Conditions Affecting Plant Safety, 7 - Judgment HG7.1 SUl 1
S - System Malfunction, 1 - Loss of Emergency AC Power SU1.1 SU2 1
S - System Malfunction, 3 - Loss of Control Room Indications SU3.1 SU3 1
S - System Malfunction, 4 - NCS Activity SU4.1 SU3 2
S - System Malfunction, 4 - NCS Activity SU4.2 SU4 1,2,3 S - System Malfunction, 5 - NCS Leakage SU5.1 SU5 1
S - System Malfunction, 6 - RPS Failure SU6.1 SU5 2
S - System Malfunction, 6 - RPS Failure SU6.2 9 of 113
EAL Comparison Matrix MNS NEI MNS IC Example Category and Subcategory EAL EAL SU6 1, 2,3 S - System Malfunction, 7 -Loss of Communications SU7.1 SU7 1,2 S - System Malfunction, 8 -Containment Failure SU8.1 SA1 1
S - System Malfunction, 1 - Loss of Emergency AC Power SA1.1 SA2 1
S - System Malfunction, 3 - Loss of Control Room Indications SA3.1 SA5 1
S - System Malfunction, 6 - RPS Failure SA6.1 SA9 1
S - Hazardous Event Affecting Safety Systems SA9.1 SS1 1
S - System Malfunction, 1 - Loss of Emergency AC Power SS1.1 SS5 1
S - System Malfunction, 6 - RPS Failure SS6.1 SS8 1
S - System Malfunction, 2 - Loss of Vital DC Power SS2.1 SG1 1
S - System Malfunction, 1 - Loss of Emergency AC Power SG1.1 SG8 1
S - System Malfunction, 1 - Loss of Emergency AC Power SG1.2 10 of 113
EAL Comparison Matrix MNS Table 3 - Summary of Deviations NEI MNS IC Example EAL EAL Description N/A N/A N/A N/A 11 of 113
EAL Comparison Matrix MNS Category A Abnormal Rad Levels / Radiological Effluent 12 of 113
EAL Comparison Matrix MNS NEI IC#
NEI IC Wording and Mode MNS MNS IC Wording and Mode Difference Justification Applicability IC#(s)
Applicability AUL1 Release of gaseous or liquid RU1 Release of gaseous or liquid The MNS SLC is the site-specific effluent release controlling radioactivity greater than 2 times radioactivity greater than 2 times the document.
the (site-specific effluent release SLC limits for 60 minutes or longer controlling document) limits for MODE: All 60 minutes or longer.
MODE: All NEI Ex.
NEI Example EAL Wording MNS MNS EAL Wording Difference Justification EAL #
EAL #
1 Reading on ANY effluent Reading on any Table R-1 effluent Example EALs #1 and #2 have been combined into a single radiation monitor greater than 2 radiation monitor > column "UE" for >
EAL. Example EAL #2 addresses batch releases through the times the (site-specific effluent 60 min.
Liquid Waste Effluent Line. The alarm setpoint for this release controlling document)
(Notes 1, 2, 3) release path is not set as a function of SLC release rate limits for 60 minutes or longer:
limits but is based on expected maximum release rates for (site-specific monitor list and the specific release. This setpoint is generally a very small threshold values corresponding fraction of the SLC/TS release rate limits. This release path to 2 times the controlling threshold is instead based on the calculated Table R-1 value document limits) which is a function of 2 times the SLC release limit consistent with the intent of the IC.
2 Reading on ANY effluent The NEI phrase "...effluent radiation monitor greater than 2 radiation monitor greater than 2 RU1.1 times the (site-specific effluent release controlling times the alarm setpoint document)" and "effluent radiation monitor greater than 2 established by a current times the alarm setpoint established by a current radioactivity radioactivity discharge permit for discharge permit " have been replaced with "...any Table R-1 60 minutes or longer.
effluent radiation monitor > column "UE".
UE thresholds for all MNS continuously monitored gaseous release pathways are listed in Table R-1 to consolidate the information in a single location and, thereby, simplify identification of the thresholds by the EAL user. The values shown in Table R-1 column "UE", consistent with the NEI bases, represent two times the ODCM release limits for both liquid and gaseous release.
13 of 113
EAL Comparison Matrix MNS NEI Ex.
NEI Example EAL Wording MNS MNS EAL Wording Difference Justification EAL #
EAL #
3 Sample analysis for a gaseous or RU1.2 Sample analysis for a gaseous or The MNS SLC is the site-specific effluent release controlling liquid release indicates a liquid release indicates a concentration document.
concentration or release rate or release rate > 2 x SLC limits for >
greater than 2 times the (site-60 min.
specific effluent release (Notes 1, 2) controlling document) limits for 60 minutes or longer.
Notes e
The Emergency Director N/A Note 1:
The Emergency The classification timeliness note has been standardized should declare the Unusual Coordinator/EOF Director across the MNS EAL scheme by referencing the "time limit" Event promptly upon should declare the event specified within the EAL wording.
determining that 60 minutes promptly upon determining has been exceeded, or will that time limit has been likely be exceeded.
exceeded, or will likely be If an ongoing release is exceeded.
The classification timeliness note has been standardized detected and the release Note 2:
If an ongoing release is across the MNS EAL scheme by referencing the "time limit" start time is unknown, detected and the release specified within the EAL wording.
assume that the release start time is unknown, duration has exceeded 60 assume that the release minutes.
duration has exceeded the If the effluent flow past an specified time limit.
effluent monitor is known to Note 3:
If the effluent flow past an None have stopped due to actions effluent monitor is known to to isolate the release path, have stopped, indicating that then the effluent monitor the release path is isolated, reading is no longer valid for the effluent monitor reading classification purposes.
is no longer VALID for classification purposes.
14 of 113
EAL Comparison Matrix MNS Table R-1 Effluent Monitor Classification Thresholds Release Point Monitor GE SAE Alert UE
= Unit Vent Noble Gas Low 1(2)EMF36L 4.85E+6 cpm 3.10OE+3 cpm 0
o Unit Vent Noble Gas High 1(2)EMF36H 2.61E+4 cpm 2.61E+3 cpm 2.70E+2 cpm
-V Liquid Waste Effluent Line High EMF49H 2.15E+2 cpm CVUCDT High 1(2)EMF44H 4.29E+2 cpm 15 of 113
EAL Comparison Matrix MNS NEI IC#
NEI IC Wording and Mode MNS MNS IC Wording and Mode Difference Justification Applicability IC#(s)
Applicability AU2 UNPLANNED loss of water level RU2 Unplanned loss of water level above None above irradiated fuel.
irradiated fuel MODE: All MODE: All NEI Ex.
MNS EAL E NEI Example EAL Wording EAL #
MNS EAL Wording Difference Justification
- a. UNPLANNED water level RU2.1 UNPLANNED water level drop in the The site-specific list of radiation monitors are listed in bullet drop in the REFUELING REFUELING PATHWAY as indicated format for ease of reading.
PATHWAY as indicated by by low water level alarm or indication 1 EMF1 6 (2EMF3) Containment Building Refueling Bridge ANY of the following:
AND monitors are only operable when in Mode 6 (Refueling).
(site-specific level UNPLANNED rise in corresponding indications),
area radiation levels as indicated by AND EITHER of the following radiation
- b. UNPLANNED rise in area radiation levels as indicated by ANY of the following 0
1EMF17 (2EMF4) Spent Fuel radiation monitors.
Building Refueling Bridge (site-specific list of area
° 1 EMF1 6 (2EMF3) radiation monitors)
Containment Building Refueling Bridge (Mode 6) 16 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification AA1 Release of gaseous or liquid RA1 Release of gaseous or liquid None radioactivity resulting in offsite radioactivity resulting in offsite dose dose greater than 10 mrem TEDE greater than 10 mrem TEDE or 50 or 50 mrem thyroid CDE.
mrem thyroid CDE MODE: All MODE: All NEI Ex.
MNS EAL Wording Difference Justification Reading on ANY of the following RAI.1 Reading on any Table R-1 effluent The MNS radiation monitors that detect radioactivity effluent radiation monitors greater than radiation monitor > column "ALERT" release to the environment are listed in Table R-1. UE, Alert, the reading shown for 15 for > 15 min. (Notes 1, 2, 3, 4)
SAE and GE thresholds for all MNS continuously monitored minutes or longer:
gaseous and liquid release pathways are listed in Table R-1 to consolidate the information in a single location and, (site-specific monitor list and thereby, simplify identification of the thresholds by the EAL-threshold values) user.
2 Dose assessment using actual RA1.2 Dose assessment using actual The site boundary is the site-specific receptor point.
meteorology indicates doses meteorology indicates doses > 10 greater than 10 mrem TEDE or mrem TEDE or 50 mrem thyroid CDE 50 mrem thyroid CDE at or at or beyond the SITE BOUNDARY beyond (site-specific dose (Notes 3, 4) receptor point).
3 Analysis of a liquid effluent RA1.3 Analysis of a liquid effluent sample The site boundary is the site-specific receptor point.
sample indicates a concentration indicates a concentration or release or release rate that would result rate that would result in doses > 10 in doses greater than 10 mrem mrem TEDE or 50 mrem thyroid CDE TEDE or 50 mrem thyroid CDE at or beyond the SITE BOUNDARY at or beyond (site-specific dose for 60 min. of exposure (Notes 1, 2) receptor point) for one hour of exposure.
17 of 113
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.
Analyses of field survey samples indicate thyroid CDE greater than 50 mrem for one hour of inhalation.
RA1.4 Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:
Closed window dose rates > 10 mR/hr expected to continue for
> 60 min.
Analyses of field survey samples indicate thyroid CDE
> 50 mrem for 60 min. of inhalation.
(Notes 1, 2)
The site boundary is the site-specific receptor point.
4 4
4
+
Notes 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 emeraencv classification N/A Note 1:
The Emergency Coordinator/EOF Director should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.
Note 2:
If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.
Note 3:
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.
Note 4 The pre-calculated effluent monitor values presented in EALs RA1.1, RS1.1 and RG1.1 should be used for The classification timeliness note has been standardized across the MNS EAL scheme by referencing the "time limit" specified within the EAL wording.
The classification timeliness note has been standardized across the MNS EAL scheme by referencing the "time limit" specified within the EAL wording.
None Incorporated site-specific EAL numbers associated with generic EAL#1.
18 of 113
EAL Comparison Matrix MNS assessments until the results from a dose assessment using actual meteorology are available.
emergency classification assessments until the results from a dose assessment using actual meteorology are available.
1 ___________________________________.1 __________
+/-
19 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification AA2 Significant lowering of water RA2 Significant lowering of water level None level above, or damage to, above, or damage to, irradiated fuel irradiated fuel.
MODE: All MODE: All NEI Ex.
MNS EAL Wording Difference Justification Uncovery of irradiated fuel in the RA2.1 Uncovery of irradiated fuel in the None REFUELING PATHWAY.
REFUELING PATHWAY 2
Damage to irradiated fuel RA2.2 Damage to irradiated fuel resulting in a The NEI phrase "...from the fuel as indicated by ANY of the resulting in a release of release of radioactivity following radiation monitors" has been replaced with "...AND radioactivity from the fuel as AND A high radiation alarm on any of the following radiation indicated by ANY of the following monitor indications" for clarification that the classification radiation monitors:
A Trip 2 radiation alarm on any of the requires two conditions: damage to fuel and a resultant high (site-specific listing of radiation following radiation monitor indications:
radiation alarm.
monitors, and the associated 0
1 EMF17 (2EMF4) Spent Fuel The site-specific list of radiation monitors are listed in bullet readings, setpoints and/or Building Refueling Bridge format for ease of reading.
alarms) 1 EMF1 6 (2EMF3)
The Trip 2 setpoints for the radiation monitors are indicative of Containment Building significant increases in area and/or airborne radiation.
Refueling Bridge (Mode 6) 1EMF16 (2EMF3) Containment Building Refueling Bridge monitors are only operable in Mode 6.
1 EMF42 (2EMF42) Fuel Building Ventilation 1 EMF39 (2EMF39)
Containment Gas 3
Lowering of spent fuel pool level RA2.3 Spent fuel pool level < -15 ft. (756 ft.
Post-Fukushima order EA-1 2-051 required the installation of to (site-specific Level 2 value).
ele.) (KFP5350 or NVPG6530) reliable SFP level indication capable of identifying normal level
[See Developer Notes]
(Level 1), SFP level 10 ft. above the top of the fuel racks (Level 2) and SFP level at the top of the fuel racks (Level 3).
For MNS SFP Level 2 is -15 ft. (756 ft. ele.) as indicated on 20 of 113
EAL Comparison Matrix MNS KFP5350 or NVPG6530 Deleted "Lowering of..
as level at or below Level 2 can only be attained by lowering water level.
MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification AA3 Radiation levels that impede RA3 Radiation levels that IMPEDE access None access to equipment necessary to equipment necessary for normal for normal plant operations, plant operations, cooldown or cooldown or shutdown shutdown MODE: All MODE: All NEI Ex.
MNS EAL Ex NEI Example EAL Wording EAL #
MNS EAL Wording Difference Justification 1
Dose rate greater than 15 mR/hr RA3.1 Dose rate > 15 mR/hr in EITHER of No other site-specific areas requiring continuous occupancy in ANY of the following areas:
the following areas:
exist at MNS.
Control Room Control Room (1EMF 12) 1EMF Channel 12 monitors the Control room for area Central Alarm Station OR radiation.
The CAS does not have installed area radiation monitoring (other site-specific Central Alarm Station (by survey) adtu utb eemndb uvy areas/rooms) and thus must be determined by survey.
2 An UNPLANNED event results RA3.2 An UNPLANNED event results in Table R-2 contains the site-specific list of plant rooms or areas in radiation levels that prohibit or radiation levels that prohibit or with entry-related mode applicability identified.
impede access to any of the IMPEDE access to any Table R-2 following plant rooms or areas:
rooms or areas (Note 5)
(site-specific list of plant rooms or areas with entry-related mode applicability identified)
Note If the equipment in the listed Note 5 If the equipment in the listed room or None room or area was already area was already inoperable or out-of-inoperable or out-of-service service before the event occurred, 21 of 113
EAL Comparison Matrix MINIS before the event occurred, then then no emergency classification is no emergency classification is warranted.
warranted.
Table R-2 Safe Operation & Shutdown Rooms/Areas Bldg. Elevation Unit I Room/Area Unit 2 Room/Area Modes Auxiliary 716' P/C, RHole, near 1NI-185, ABPC thru CAD Door, FF59 4
Outside CAD 212 800 (1 EMXA) 820 (2EMXA) 3, 4 803 (1 ETA) 805 (2ETA) 3, 4 702 (Elec. Pene.)
713 (Elec. Pene.)
3 Auxiliary 733' 722 (1 EMXB-1) 724 (2EMXB-1) 3, 4 705 (1ETB) 716 (2ETB) 3,4 22 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification AS1 Release of gaseous radioactivity RS1 Release of gaseous radioactivity None resulting in offsite dose greater resulting in offsite dose greater than than 100 mrem TEDE or 500 100 mrem TEDE or 500 mrem thyroid mrem thyroid CDE CDE MODE: All MODE: All MODE: All NEI Ex.
MNS EA NEI Example EAL Wording EAL MNS EAL Wording Difference Justification EAL #
EAL #
1 Reading on ANY of the following RS1.1 Reading on any Table R-1 effluent The MNS radiation monitors that detect radioactivity effluent radiation monitors greater than radiation monitor > column "SAE" for release to the environment are listed in Table R-1. UE, Alert, the reading shown for 15
> 15 min.
SAE and GE thresholds for all MNS continuously monitored minutes or longer:
(Notes 1, 2, 3, 4) gaseous and liquid release pathways are listed in Table R-1 to (site-specific monitor list and consolidate the information in a single location and, thereby, threshold values) simplify identification of the thresholds by the EAL-user.
2 Dose assessment using actual RS1.2 Dose assessment using actual The site boundary is the site-specific receptor point.
meteorology indicates doses meteorology indicates doses > 100 greater than 100 mrem TEDE or mrem TEDE or 500 mrem thyroid CDE 500 mrem thyroid CDE at or at or beyond the SITE BOUNDARY beyond (site-specific dose (Notes 3, 4) receptor point) 3 Field survey results indicate RS1.3 Field survey results indicate EITHER The site boundary is the site-specific receptor point.
EITHER of the following at or of the following at or beyond the SITE beyond (site-specific dose BOUNDARY:
receptor point):
Closed window dose rates >
Closed window dose rates 100 mR/hr expected to continue greater than 100 mR/hr for > 60 min.
expected to continue for 60 minutes or longer.
Analyses of field survey Analyses of field survey samples indicate thyroid CDE >
samples indicate thyroid 500 mrem for 60 min. of 23 of 113
DE greater than 500
]inhalation.
mrem for one hour of (Notes 1, 2) nh lto.inhalation._
______________________________________________I____
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.
Note 1:
The Emergency Coordinator/EOF Director should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.
Note 2:
If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.
Note 3:
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.
Note 4 The pre-calculated effluent monitor values presented in EALs RA1.1, RS1.1 and RG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
The classification timeliness note has been standardized across the MNS EAL scheme by referencing the "time limit" specified within the EAL wording.
The classification timeliness note has been standardized across the MNS EAL scheme by referencing the "time limit" specified within the EAL wording.
None Incorporated site-specific EAL numbers associated with generic EAL#1.
24 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification AS2 Spent fuel pool level at (site-RS2 Spent fuel pool level at the top of the Top of the fuel racks is the site-specific Level 3 description.
specific Level 3 description) fuel racks MODE: All NEI Ex.
MNS EAL E NEI Example EAL Wording EAL #
MNS EAL Wording Difference Justification 1
Lowering of spent fuel pool level RS2.1 Spent fuel pool level < -25 ft. (746 ft.
Post-Fukushima order EA-1 2-051 (ref.1) required the to (site-specific Level 3 value) ele.) (KFP5350 or NVPG6530) installation of reliable SFP level indication capable of identifying normal level (Level 1), SFP level 10 ft. above the top of the fuel racks (Level 2) and SFP level at the top of the fuel racks (Level 3).
For MNS SFP Level 3 is -25 ft. (746 ft. ele.) as indicated on KFP5350 or NVPG6530.
Deleted "Lowering of..." as level at or below Level 2 can only be attained by lowering water level.
25 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification AG1 Release of gaseous radioactivity RG1 Release of gaseous radioactivity None resulting in offsite dose greater resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 than 1,000 mrem TEDE or 5,000 mrem thyroid CDE.
mrem thyroid CDE MODE: All MODE: All NEI Ex.
MNS EAL Wording Difference Justification 1
Reading on ANY of the following RG1.1 Reading on any Table R-1 effluent The MNS radiation monitors that detect radioactivity effluent release radiation monitors greater than radiation monitor > column "GE" to the environment are listed in Table R-1. UE, Alert, SAE and GE the reading shown for 15 for > 15 min.
thresholds for all MNS continuously monitored gaseous or liquid minutes or longer:
(Notes 1, 2, 3, 4) release pathways are listed in Table R-1 to consolidate the (site-specific monitor list and information in a single location and, thereby, simplify identification of threshold values) the thresholds by the EAL-user.
2 Dose assessment using actual RG1.2 Dose assessment using actual The site boundary is the site-specific receptor point.
meteorology indicates doses meteorology indicates doses >
greater than 1,000 mrem TEDE 1,000 mrem TEDE or or 5,000 mrem thyroid CDE at 5,000 mrem thyroid CDE at or or beyond (site-specific dose beyond the SITE BOUNDARY receptor point).
(Notes 3, 4) 3 Field survey results indicate RG1.3 Field survey results indicate The site boundary is the site-specific receptor point.
EITHER of the following at or EITHER of the following at or beyond (site-specific dose beyond the SITE BOUNDARY:
receptor point):
e Closed window dose rates >
e Closed window dose rates 1,000 mR/hr expected to greater than 1,000 mR/hr continue for > 60 min.
expected to continue for 60 minutes or longer.
a Analyses of field survey
> 5,000 mrem for 60 min. of greater than 5,000 mrem for inhalation.
26 of 113
EAL Comparison Matrix MNo MNS Ione hour of inhalation.
I I____
(Notes 1, 2) 1 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.
Note 1:
The Emergency Coordinator/EOF Director should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.
Note 2:
If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded the specified time limit.
Note 3:
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.
Note 4 The pre-calculated effluent monitor values presented in EALs RA1.1, RS1.1 and RG1.1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
The classification timeliness note has been standardized across the MNS EAL scheme by referencing the "time limit" specified within the EAL wording.
The classification timeliness note has been standardized across the MNS EAL scheme by referencing the "time limit" specified within the EAL wording.
None Incorporated site-specific EAL numbers associated with generic EAL#1.
27 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification AG2 Spent fuel pool level cannot be RG2 Spent fuel pool level cannot be Top of the fuel racks is the site-specific Level 3 description.
restored to at least (site-specific restored to at least the top of the fuel Level 3 description) for 60 racks for 60 minutes or longer minutes or longe MODE: All NEI Ex.
NEI Example EAL Wording MNS MNS EAL Wording Difference Justification EAL #
EAL #
1 Spent fuel pool level cannot be RG2.1 Spent fuel pool level cannot be Post-Fukushima order EA-1 2-051 (ref. 1) required the restored to at least (site-specific restored to > -25 ft. (746 ft. ele.)
installation of reliable SFP level indication capable of Level 3 value) for 60 minutes or (KFP5350 or NVPG6530) for > 60 identifying normal level (Level 1), SFP level 10 ft. above the longer min. (Note 1) top of the fuel racks (Level 2) and SFP level at the top of the fuel racks (Level 3).
For MNS SFP Level 3 is plant elevation -25 ft. (746 ft. ele.) as indicated on KFP5350 or NVPG6530 Replaced "to at least" with ">"
Note The Emergency Director should N/A Note 1:
The Emergency The classification timeliness note has been standardized declare the General Emergency Coordinator/EOF Director across the MNS EAL scheme by referencing the "time limit" promptly upon determining that should declare the event specified within the EAL wording.
60 minutes has been exceeded, promptly upon determining or will likely be exceeded.
that time limit has been exceeded, or will likely be exceeded.
28 of 113
Co pa so at MNS Category C Cold Shutdown / Refueling System Malfunction 29 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification Cui UNPLANNED loss of (reactor CU1 UNPLANNED loss of NCS None vessel/RCS [PWR] or RPV inventory for 15 minutes or
[BWR]) inventory for 15 minutes longer or longer.
MODE: 5 - Cold Shutdown, 6 -
MODE: Cold Shutdown, Refueling Refueling NEI Ex.
NEI Example EAL Wording MNS MNS EAL Wording Difference Justification EAL#
EAL #
UNPLANNED loss of reactor CU1.1 UNPLANNED loss of reactor None coolant results in (reactor coolant results in NCS water vessel/RCS [PWR] or RPV level less than a required lower
[BWR]) level less than a limit for > 15 min. (Note 1) required lower limit for 15 minutes or longer.
2
- a. (Reactor vessel/RCS [PWR]
CU1.2 NCS water level cannot be Added the phrase "due to a loss of NCS inventory" because the NEI or RPV [BWR]) level cannot monitored basis states: "Sump and/or tank level changes must be evaluated be monitored.
AND EITHER against other potential sources of water flow to ensure they are AND Uindicative of leakage from the NCS."
Contanmen UNL irease i Added bulleted criteria "Visual observation of UNISOLABLE NCS Containment Floor or
- b. UNPLANNED increase in Equipment Sump due to a leakage" to include direct observation of NCS leakage.
(site-specific sump and/or loss of NCS inventory tank) levels.
- Visual observation of UNISOLABLE NCS leakage Note The Emergency Director N/A Note 1: The Emergency The classification timeliness note has been standardized across the should declare the Unusual Coordinator/EOF MNS EAL scheme by referencing the "time limit" specified within the Event promptly upon Director should EAL wording.
determining that 15 minutes declare the event has been exceeded, or will promptly upon likely be exceeded.
determining that time 30 of 113
EAL Comparison Matrix MNS limit has been exceeded, or will likely be exceeded.
31 of 113
EAL Comparison Matrix MNS MNS NEI IC Wording IC#(s)
MNS IC Wording Difference Justification Loss of all but one AC power CU2 Loss of all but one AC power The MNS essential buses are the site-specific emergency buses.
source to emergency buses for source to essential buses for 15 15 minutes or longer.
minutes or longer.
MODE: Cold Shutdown, MODE: 6 - Cold Shutdown, 6 -
Refueling, Defueled Refueling, NM - No Mode NEI Ex.
NEI Example EAL Wording EAL MNS EAL Wording Difference Justification EAL #
EAL #
- a. AC power capability to (site-CU2.1 AC power capability, Table C-2, 4160V buses 1(2)ETA and 1(2)ETB are the site-specific emergency specific emergency buses) is to essential 4160V buses buses.
reduced to a single power 1(2)ETA and 1(2)ETB reduced Site-specific AC power sources are listed in Table C-2.
source for 15 minutes or to a single power source for > 15 longer.
min. (Note 1)
AND AND
- b. Any additional single power Any additional single power source failure will result inAnadioalsgepwr source failure will result in loss of loss of all AC power to all AC power to SAFETY SAFETY SYSTEMS.
SYSTEMS Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Unusual Event Coordinator/EOF MNS EAL scheme by referencing the "time limit" specified within the promptly upon determining that Director should declare EAL wording.
15 minutes has been exceeded, the event promptly or will likely be exceeded.
upon determining that time limit has been exceeded, or will likely be exceeded.
32 of 113
EAL Comparison Matrix MNS Table C-2 AC Power Sources Offsite:
ATC (Train A)
SATA (Train A)
ATD (Train B)
SATB (Train B)
Onsite:
D/G 1(2) A (Train A)
D/G 1(2) B (Train B) 33 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification CU3 UNPLANNED increase in RCS CU3 UNPLANNED increase in NCS None temperature temperature MODE: Cold Shutdown, MODE: Cold Shutdown, 6 -
Refueling Refueling NEI Ex.
MNS EA Ex NEI Example EAL Wording EAL MNS EAL Wording Difference Justification EAL #
EAL #
1 UNPLANNED increase in RCS CU3.1 UNPLANNED increase in NCS 200°F is the site-specific Tech. Spec. cold shutdown temperature temperature to greater than (site-temperature to > 200OF due to limit.
specific Technical Specification loss of decay heat removal Added "due to loss of decay heat removal capability" to reinforce the cold shutdown temperature limit) capability generic bases that states "EAL #1 involves a loss of decay heat removal capability" 2
Loss of ALL RCS temperature CU3.2 Loss of all NCS temperature and None and (reactor vessel/RCS [PWR]
NCS level indication for > 15 min.
or RPV [BWR]) level indication (Note 1) for 15 minutes or longer.
Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Unusual Event Coordinator/EOF MNS EAL scheme by referencing the "time limit" specified within the promptly upon determining that Director should declare EAL wording.
15 minutes has been exceeded, the event promptly upon or will likely be exceeded determining that time limit has been exceeded, or will likely be exceeded.
34 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification CU4 Loss of Vital DC power for 15 CU4 Loss of Vital DC power for 15 None minutes or longer.
minutes or longer.
MODE: Cold Shutdown, MODE: 5 - Cold Shutdown, 6 -
Refueling Refueling NEI Ex.
MNS EA Ex NEI Example EAL Wording EAL MNS EAL Wording Difference Justification EAL #
EAL #
1 Indicated voltage is less than CU4.1
< 105 VDC bus voltage indications 105 VDC is the site-specific minimum vital DC bus voltage.
(site-specific bus voltage value) on Technical Specification DC operability requirements are specified in Technical on required Vital DC buses for 15 required 125 VDC buses for > 15 Specifications.
minutes or longer.
min. (Note 1)
Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Unusual Event Coordinator should MNS EAL scheme by referencing the "time limit" specified within promptly upon determining that declare the event promptly the EAL wording.
15 minutes has been exceeded, upon determining that time or will likely be exceeded.
limit has been exceeded, or will likely be exceeded.
35 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification CU5 Loss of all onsite or offsite CU5 Loss of all onsite or offsite None communications capabilities, communications capabilities.
MODE: Cold Shutdown, MODE: Cold Shutdown, 6 -
Refueling, Defueled Refueling, NM - No Mode NEI Ex.
MNS EI NEI Example EAL Wording EAL MNS EAL Wording Difference Justification EAL #
EAL #
1 Loss of ALL of the following CU5.1 Loss of all Table C-4 onsite Example EALs #1, 2 and 3 have been combined into a single onsite communication methods:
communication methods EAL for simplification of presentation.
(site specific list of OR Table C-4 provides a site-specific list of onsite, ORO and NRC communications methods)
Loss of all Table C-4 ORO communications methods.
communication methods 2
Loss of ALL of the following ORO OR communications methods:
Loss of all Table C-4 NRC (site specific list of communication methods communications methods) 3 Loss of ALL of the following NRC communications methods:
(site specific list of communications methods) 36 of 113
EAL Comparison Matrix MNS Table C-4 Communication Methods System Onsite ORO NRC Public Address X
Internal Telephones X
Onsite Radios X
DEMNET X
Offsite Radio System X
Commercial Telephones X
X NRC Emergency Telephone System (ETS)
X 37 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification CA1 Loss of (reactor vessel/RCS CA1 Loss of NCS inventory None
[PWR] or RPV [BWR]) inventory MODE: Cold Shutdown, 6 -
MODE: Cold Shutdown, Refueling Refueling NEI Ex.
MNS EAL E NEI Example EAL Wording EAL #
MNS EAL Wording Difference Justification 1
Loss of (reactor vessel/RCS CA1.1 Loss of NCS inventory as 5.1 in. above hotleg centerline (rounded to 5 in.) NCS level indication
[PWR] or RPV [BWR]) inventory indicated by NCS water level < 5 is the lowest level to assure adequate net positive suction head and as indicated by level less than in. above hotleg centerline prevent ND pump cavitation for all flow rates.
(site-specific level).
2
- a. (Reactor vessel/RCS [PWR]
CA1.2 NCS water level cannot be Added the phrase "due to a loss of NCS inventory" because the NEI or RPV [BWR]) level cannot monitored for > 15 min. (Note 1) basis states: "Sump and/or tank level changes must be evaluated be monitored for 15 minutes against other potential sources of water flow to ensure they are orAND EITHER indicative of leakage from the NCS."
AND e UNPLANNED increase in Added bulleted criteria "Visual observation of UNISOLABLE NCS Containment Floor or leakage" to include direct observation of NCS leakage.
- b. UNPLANNED increase in Equipment Sump due to a (site-specific sump and/or loss of NCS inventory tank) levels due to a loss of Visual observation of (reactor vessel/RCS [PWR]
UNISOLABLE NCS leakage or RPV [BWR]) inventory.
Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Alert promptly upon Coordinator/EOF Director MNS EAL scheme by referencing the "time limit" specified within the determining that 15 minutes has should declare the event EAL wording.
been exceeded, or will likely be promptly upon determining that exceeded time limit has been exceeded, or will likely be exceeded.
38 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification CA2 Loss of all offsite and all onsite CA2 Loss of all offsite and all onsite The MNS essential buses are the emergency buses.
AC power to emergency buses AC power to essential buses for for 15 minutes or longer 15 minutes or longer.
MODE: Cold Shutdown, MODE: Cold Shutdown, 6 -
Refueling, Defueled Refueling, NM - No Mode NEI Ex.
MNS EAL Ex NEI Example EAL Wording EAL #
MNS EAL Wording Difference Justification 1
Loss of ALL offsite and ALL CA2.1 Loss of all offsite and all onsite 4160V buses 1(2)ETA and 1(2)ETB are the site-specific emergency onsite AC Power to (site-specific AC power capability, Table C-2, buses.
emergency buses) for 15 to essential 4160V buses Site-specific AC power sources are tabularized in Table C-2.
minutes or longer.
1(2)ETA and 1(2)ETB for > 15 min. (Note 1)
Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Unusual Event Coordinator/EOF MNS EAL scheme by referencing the "time limit" specified within the promptly upon determining that Director should declare EAL wording.
15 minutes has been exceeded, the event promptly or will likely be exceeded.
upon determining that time limit has been exceeded, or will likely be exceeded.
39 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification CA3 Inability to maintain the plant in CA3 Inability to maintain the plant in None cold shutdown.
cold shutdown.
MODE: Cold Shutdown, MODE: Cold Shutdown, 6 -
Refueling Refueling NEI Ex.
NIEapeELWrig MNS EAL E NEI Example#
EAL #
MNS EAL Wording Difference Justification 1
UNPLANNED increase in RCS UNPLANNED increase in NCS Example EALs #1 and #2 have been combined into a single EAL temperature to greater than temperature to > 200OF for as EAL # is the alternative threshold based on a loss of NCS (site-specific Technical
> Table C-3 duration temperature indication.
Specification cold shutdown (Note 1) 200'F is the site-specific Tech. Spec. cold shutdown temperature temperature limit) for greater OR limit.
than the duration specified in the following table.
CA3.1 UNPLANNED NCS pressure Table C-3 is the site-specific implementation of the generic NCS increase > 20 psig due to a Heat-up Duration Threshold table.
2 UNPLANNED RCS pressure loss of NCS cooling (this does 20 psig is the site-specific pressure increase readable by Control increase greater than (site-not apply during water-solid Room indications.
specific pressure reading). (This plant conditions)
EAL does not apply during water-solid plant conditions.
[PWR])
Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Unusual Event Coordinator/EOF MNS EAL scheme by referencing the "time limit" specified within promptly upon determining that Director should the EAL wording.
15 minutes has been exceeded, declare the event or will likely be exceeded.
promptly upon determining that time limit has been exceeded, or will likely be exceeded.
40 of 113
EAL Comparison Matrix MNS Table: RCS Heat-up Duration Thresholds RCS Status Containment Closure Status Heat-up Duration Intact (but not at reduced Not applicable 60 minutes*
inventory [PWR])
Not intact (or at reduced Established 20 minutes*
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, the EAL is not applicable.
Table C-3: NCS Heat-up Duration Thresholds NCS Status Containment Closure Status Heat-up Duration Intact (but not reduced N/A 60 mi.*
inventory)
N/A_60_min,*
Not intact established 20 min.*
OR At reduced inventory not established 0 min.
- If an NCS heat removal system is in operation within this time frame and NCS temperature is being reduced, the EAL is not applicable.
41 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification CA6 Hazardous event affecting a CA6 Hazardous event affecting a None SAFETY SYSTEM needed for SAFETY SYSTEM needed for the current operating mode.
the current operating mode.
MODE: Cold Shutdown, MODE: 5 - Cold Shutdown, 6 -
Refueling Refueling 42 of 113
EAL Comparison Matrix MNS NEI Ex.
MNS EAL Wording Difference Justification
- a. The occurrence of ANY of CA6.1 The occurrence of any Table The hazardous events have been tabularized in Table C-5.
the following hazardous CA5 he aourrenent events:
C-5 hazardous event
" Seismic event AND EITHER:
(earthquake) o Event damage has caused
" Internal or external indications of degraded flooding event performance in at least one
" High winds or tornado train of a SAFETY SYSTEM strike needed for the current
" EXPLOSION operating mode
" (site-specific hazards) o The event has caused
" Other events with similar VISIBLE DAMAGE to a hazard characteristics as SAFETY SYSTEM determined by the Shift component or structure Manager needed for the current AND operating mode
- 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.
43 of 113
EAL Comparison Matrix MNS Table C-5 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 44 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification CS1 Loss of (reactor vessel/RCS CS1 Loss of NCS inventory affecting None
[PWR] or RPV [BWR]) inventory core decay heat removal affecting core decay heat capability removal capability.
MODE: Cold Shutdown, 6 -
MODE: Cold Shutdown, Refueling Refueling NEI Ex.
MNS EI E NEI Example EAL Wording EAL #
MNS EAL Wording Difference Justification EAL #
A#
1
- a. CONTAINMENT CLOSURE N/A N/A The design and operation of water level instrumentation is such that not established.
the "site-specific level" (6" below the bottom ID of the NCS loop)
AND cannot be determined at any time during Cold Shutdown or Refueling modes, Classification is accomplished in accordance with EAL #3.
- b. (Reactor vessel/RCS [PWR]
or RPV [BWR]) level less than (site-specific level).
2
- a. CONTAINMENT CLOSURE N/A N/A The design and operation of water level instrumentation is such that established.
the "site-specific level" (top of active fuel) cannot be determined at AND any time during Cold Shutdown or Refueling modes, Classification is accomplished in accordance with EAL #3.
b.(Reactor vessel/RCS [PWR]
or RPV [BWR]) level less than (site-specific level).
3
- a. (Reactor vessel/RCS [PWR]
CS1.1 NCS water level cannot be Added bulleted criteria "Visual observation of UNISOLABLE NCS or RPV [BWR]) level cannot monitored for > 30 min. (Note 1) leakage" to include direct observation of NCS leakage.
be monitored for 30 minutes AND or longer.
Core uncver isnutes i
d b 1EMF16 (2EMF3), Reactor Building Refueling Bridge Monitor is or longer.
Core uncovery is indicated by located in the containment in proximity to the reactor cavity and is AND any of the following:
designed to provide monitoring of radiation due to a fuel handling
- b. Core uncovery is indicated by UNPLANNED increase in event or loss of shielding during refueling operations. If this radiation
- b.
Core uncoveroind d bContainment Floor or monitor reaches and exceeds 9,000 mR/hr (90% of instrument ANY of the following:
Equipment Sump due to a scale), a loss of inventory with potential to uncover the core is likely 45 of 113
EAL Comparison Matrix MNS (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) loss of NCS inventory
" Visual observation of unisolable NCS leakage
" Reactor Building Refueling Bridge Monitor 1EMF16 (2EMF3) reading > 9,000 mR/hr (Mode 6)
" Erratic Source Range or Wide Range Flux Monitor indication to have occurred.
1EMF16 (2EMF3) Containment Building Refueling Bridge monitors are only operable in Mode 6 (Refueling).
Erratic Wide Range Flux Monitor indication has been added to the MNS EAL because it may provide indication of core uncovery.
Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Site Area Coordinator/EOF MNS EAL scheme by referencing the "time limit" specified within the Emergency promptly upon Director should declare EAL wording.
determining that 30 minutes has the event promptly upon been exceeded, or will likely be determining that time exceeded limit has been exceeded, or will likely be exceeded.
46 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification CG1 Loss of (reactor vessel/RCS CG1 Loss of NCS inventory affecting None
[PWR] or RPV [BWR]) inventory fuel clad integrity with affecting fuel clad integrity with containment challenged containment challenged MODE: Cold Shutdown, 6 -
MODE: Cold Shutdown, Refueling Refueling NEI Ex.
NEMxmleELWrdnSA EAL #
NEI Example EAL Wording MNS MNS EAL Wording Difference Justification 1
- a. (Reactor vessel/RCS [PWR] or N/A N/A The design and operation of water level instrumentation is such RPV [BWR]) level less than that the "site-specific level" (6" below the bottom ID of the NCS (site-specific level) for 30 loop) cannot be determined at any time during Cold Shutdown or minutes or longer.
Refueling modes, Classification is accomplished in accordance AND with EAL #3.
- b. ANY indication from the Containment Challenge Table (see below).
2
- a. (Reactor vessel/RCS [PWR] or CG1.1 NCS water level cannot be Added bulleted criteria "Visual observation of UNISOLABLE NCS RPV [BWR]) level cannot be monitored for > 30 min. (Note 1) leakage" to include direct observation of NCS leakage.
monitored for 30 minutes or AND 1EMF16 (2EMF3), Reactor Building Refueling Bridge Monitor is longer.
Core uncovery is indicated by located in the containment in proximity to the reactor cavity and is AND any of the following:
designed to provide monitoring of radiation due to a fuel handling
- b. Core uncovery is indicated by
- UNPLANNED increase in event or loss of shielding during refueling operations. If this b Y Corte uncoveyind d bContainment Floor or radiation monitor reaches and exceeds 9,000 mR/hr (90% of ANY of the following:
Equipment Sump level due instrument scale), a loss of inventory with potential to uncover the (Site-specific radiation to a loss of NCS inventory core is likely to have occurred.
monitor) reading greater o Visual observation of 1EMF16 (2EMF3) Containment Building Refueling Bridge monitors than (site-specific value)
UNISOLABLE NCS are only operable in Mode 6 (Refueling).
Erratic source range leakage Erratic Wide Range Flux Monitor indication has been added to the monitor indication [PWR]
47 of 113
EAL Comparison Matrix MNS 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 (see below).
Bridge Monitor 1EMF16 (2EMF3) reading > 9,000 mR/hr (Mode 6)
Erratic Source Range or Wide Range Flux Monitor indication AND Any Containment Challenge indication, Table C-1 Table C-1 provides a tabularized list of containment challenge indications.
> 6% hydrogen concentration in the presence of oxygen represents an explosive mixture in containment.
i i
i Note The Emergency Director should declare the General Emergency promptly upon determining that 30 minutes has been exceeded, or will likely be exceeded.
N/A N/A Note 1: The Emergency Coordinator/EOF Director should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.
Note 6: If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, declaration of a General Emergency is not required.
The classification timeliness note has been standardized across the MNS EAL scheme by referencing the "time limit" specified within the EAL wording.
Note 6 implements the asterisked note associated with the generic Containment Challenge 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 time limit, then declaration of a General Emergency is not required.
48 of 113
EAL Comparison Matrix MNS Table C-1 Containment Challenge Indications CONTAINMENT CLOSURE not established (Note 6)
Containment hydrogen concentration > 6%
UNPLANNED rise in containment pressure 49 of 113
EAL Comparison Matrix MNS Category D Permanently Defueled Station Malfunction 50 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification PD-AU1 Recognition Category D N/A N/A NEI Recognition Category PD ICs and EALs are applicable only to PD-AU2 Permanently Defueled Station permanently defueled stations. MNS is not a defueled station.
PD-SU1 PD-HU1 PD-HU2 PD-HU3 PD-AA1 PD-AA2 PD-HA1 PD-HA3 51 of 113
EAL Comparison Matrix MNS Category E Independent Spent Fuel Storage Installation 52 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification E-HU1 Damage to a loaded cask EU1 Damage to a loaded cask None CONFINEMENT BOUNDARY CONFINEMENT BOUNDARY MODE: All MODE: All NEI Ex.
MNS EAL E NEI Example EAL Wording EAL #
MNS EAL Wording Difference Justification 1
Damage to a loaded cask EU1.1 Damage to a loaded canister The values shown in Table E-1 represent 2 times the limits CONFINEMENT BOUNDARY as CONFINEMENT BOUNDARY specified in the ISFSI Certificate of Compliance Technical indicated by an on-contact as indicated by an on-contact Specification for radiation external to a loaded TSC for the NAC radiation reading greater than (2 radiation reading on the surface MAGNASTOR, NAC-UMS and TN casks.
times the site-specific cask of a loaded spent fuel cask >
specific technical specification any Table E-1 dose limit allowable radiation level) on the surface of the spent fuel cask.
Table E-1 ISFSI Dose Limits NAC Magnastor NAC UMS Transnuclear (TN-32) 190 mrem/hr 0
100 mrem/hr 0
120 mrem/hr (gamma) or 20 mrem/hr (gamma) on the side (neutron +
(neutron) on top of the cask of the cask (excludes gamma) on the air inlet/outlet ports) side of the cask
- 340 mrem/hr (gamma) or 40 mrem/hr (neutron) on the sides of the radial neutron 10 mrem/hr (neutron) o 100 mrem/hr shield on the side of the (neutron +
560 mrem/hr (gamma) or 280 mrem/hr cask (excludes air gamma) on the top (neutron) on the side surfaces above the inlet/outlet ports) of the cask radial neutron shield region
- 900 mrem/hr
- 200 mrem/hr (neutron + gamma)
(neutrn +220 mrem/hr (gamma) or 400 mrem/hr on the top of the gamma) at air (neutron) on the side surfaces below the cask (excludes air inlets and outlets radial neutron shield region inlet/outlet ports)
I 53 of 113
EAL Comparison Matrix MNS 54 of 113
Co pa so at MNS Category F Fission Product Barrier Degradation 55 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification FA1 Any Loss or any Potential Loss of FA1 Any loss or any potential loss of None either the Fuel Clad or RCS either Fuel Clad or NCS barrier.
MODE: 1 - Power Operation, 2 -
MODE: Power Operation, Hot Startup, 3 - Hot Standby, 4 - Hot Standby, Startup, Hot Shutdown Shutdown NEI Ex.
MNS EAL Wording Difference Justification 1
Any Loss or any Potential Loss of FA1.1 Any loss OR any potential loss Table F-1 provides the fission product barrier loss and potential loss either the Fuel Clad or RCS of either Fuel Clad or NCS (Table thresholds.
barrier.
F-1) 56 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification FS1 Loss or Potential Loss of any two FS1 Loss or potential loss of any two None barriers barriers MODE: Power Operation, Hot MODE: 1 - Power Operation, 2 -
Standby, Startup, Hot Shutdown Startup, 3 - Hot Standby, 4 - Hot Shutdown NEI Ex.
NEMxmleELWrdnSA EAL E NEI Example EAL Wording MNS MNS EAL Wording Difference Justification 1
Loss or Potential Loss of any two FS1.1 Loss OR potential loss of any Table F-1 provides the fission product barrier loss and potential loss barriers two barriers thresholds.
57 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification FG1 Loss of any two barriers and Loss FG1 Loss of any two barriers and loss None or Potential Loss of third barrier or potential loss of the third MODE: Power Operation, Hot barrier Standby, Startup, Hot Shutdown MODE: 1 - Power Operation, 2 -
Startup, 3 - Hot Standby, 4 - Hot Shutdown NEI Ex.
MNS EAL E NEI Example EAL Wording EAL #
MNS EAL Wording Difference Justification 1
Loss of any two barriers and FG1.1 Loss of any two barriers Table F-1 provides the fission product barrier loss and potential loss Loss or Potential Loss of third AND thresholds.
barrier Loss OR potential loss of the third barrier (Table F-1) 58 of 113
EAL Comparison Matrix MNS PWR Fuel Clad Fission Product Barrier Degradation Thresholds NEI MNS FPB NEI Threshold Wording FPB MNS FPB Wording Difference Justification FPB#
FPB #(s)
FC Loss RCS or SG Tube Leakage N/A N/A N/A 1
Not Applicable FC Loss Inadequate Heat Removal FC Loss Core Cooling-RED Path Consistent with the generic developers note options CSFST Core 2
A. Core exit thermocouple 1.1 conditions met Cooling Red Path is used in lieu of CET temperatures.
readings greater than (site-specific temperature value).
FC Loss RCS ActivitylCMNT Rad FC Loss EMF51A/B > Table F-2 column EMF51A/B are the site-specific containment high range radiation 3
A. Containment radiation C.1 "FC Loss" monitors. The Table F-2 values, column FC Loss represents, monitor reading greater than based on core damage assessment procedure, the expected monite-speifing gealue) tcontainment high range radiation monitor (EMF51A & B)
(site-specific value) response based on a LOCA, for periods of 1, 2 and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after OR shutdown, no sprays and NCS pressure < 1600 psig with -2%
B.
(Site-specific indications fuel failure.
that reactor coolant activity is ghatreater th lan t 3
tivity dse FC Loss Dose equivalent 1-131 coolant None greater than 300 [tCi/gm dose activity > 300 pCi/gm equivalent 1-131)
C.2 FC Loss CNMT Integrity or Bypass N/A N/A N/A 4
Not Applicable FC Loss Other Indications N/A N/A No other site-specific Fuel Clad Loss indication has been identified 5
for MNS.
A.
(site-specific as applicable) 59 of 113
EAL Comparison Matrix MNS NEI MNS FPB NEI Threshold Wording FPB MNS FPB Wording Difference Justification FPB#
FPB #(s)
FC Loss ED Judgment FC Loss Any condition in the opinion of None 6
A. ANY condition in the E.1 the Emergency Coordinator/EOF Director that opinion of the Emergency indicates loss of the fuel clad Director that indicates Loss ofbare the Fuel Clad Barrier.
FC RCS or SG Tube Leakage N/A N/A See FC P-Loss B.1. The NCS level threshold is implemented as P-Loss A.
RCS/reactor vessel level CSFST Core Cooling Orange Path conditions met.
1 less than (site-specific level)
FC Inadequate Heat Removal FC Core Cooling-ORANGE Path Consistent with the generic developers note options CSFST Core P-Loss P-Loss conditions met Cooling Orange Path is used in lieu of CET temperatures.
P-os A. Core exit thermocouple B.1 2
readings greater than (site-specific temperature value)
OR FC Heat Sink-RED Path conditions Consistent with the generic developers note options CSFST Heat B.
Inadequate RCS heat P-Loss met Sink Red Path is used.
removal capability via steam B.2 AND The phrase "and heat sink required" was added to preclude the generators as indicated by need for classification for conditions in which NCS pressure is less (site-specific indications).
Heat sink is required than SG pressure or Heat Sink-RED path entry was created through operator action directed by an EOP.
FC RCS ActivitylCMNT Rad N/A N/A N/A P-Loss Not Applicable 3
FC CNMT Integrity or Bypass N/A N/A N/A P-Loss Not Applicable 4
FC Other Indications N/A N/A No other site-specific Fuel Clad Potential Loss indication has been P-Loss identified for MNS.
A. (site-specific as applicable) 5 60 of 113
EAL Comparison Matrix MNS NEI MNS FPB NEI Threshold Wording FPB MNS FPB Wording Difference Justification FPB#
FPB #(s)
FC Emergency Director FC Any condition in the opinion of None P-Loss Judgment P-Loss the Emergency E.1 Coordinator/EOF Director that 6
A. Any condition in the opinion indicates potential loss of the of the Emergency Director that fuel clad barrier indicates Potential Loss of the Fuel Clad Barrier.
Table F-2 Containment Radiation - R/hr (EM F51A & B)
Time After S/D (Hrs.)
NCS Loss FC Loss CMT Potential Loss 0-1 8.8 550 5500 1-2 8.4 400 4000 2-8 7.0 160 1600
>8 6.2 100 1000 61 of 113
EAL Comparison Matrix MNS PWR RCS Fission Product Barrier Degradation Thresholds NEI MNS FPB FPB NEI IC Wording
- (s MNS FPB Wording Difference Justification FPB#
- (s)
RCS RCS or SG Tube Leakage NCS Loss An automatic or manual None Loss A. An automatic or manual A.1 ECCS (SI) actuation required 1
ECCS (SI) actuation is by EITHER:
required by EITHER of the a UNISOLABLE NCS following:
leakage
- 2. SG tube RUPTURE.
RCS Inadequate Heat Removal N/A N/A N/A Loss Not Applicable 2
RCS RCS Activity/CMNT Rad NCS Loss EMF51A/B > Table F-2 column EMF51A/B are the site-specific containment high range radiation Loss A. Containment radiation C.1 "NCS Loss" monitors. The Table F-2 values, column NCS Loss represents, 3
monitor reading greater than represents, based on core damage assessment procedure mnitepeading gealue). tRP/O/A/5700/015 Figure 1, the expected containment high range (site-specific value).
radiation monitor (EMF51A & B) response based on a LOCA, for periods of 1, 2 and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after shutdown with no fuel failure.
RCS CNMT Integrity or Bypass N/A N/A N/A Loss Not Applicable 4
RCS Other Indications N/A N/A No other site-specific NCS Loss indication has been identified for Loss MNS.
A. (site-specific as applicable) 5 62 of 113
EAL Comparison Matrix MNS NEI MNS FPB FPB NEI IC Wording
- (s MNS FPB Wording Difference Justification FPB#
- (s)
RCS Emergency Director Judgment NCS Loss Any condition in the opinion None Loss A. ANY condition in the opinion E.1 of the Emergency Coordinator/EOF Director that 6
of the Emergency Director that indicate os of ethe NCS indiate Los oftheRCSindicates loss of the NCS indicates Loss of the RCSbare Barrier.
barrier RCS RCS or SG Tube Leakage NCS Operation of a standby None P-Loss 1 A. Operation of a standby P-Loss A.1 charging pump is required by charging (makeup) pump is EITHER:
required by EITHER of the
- UNISOLABLE NCS following:
leakage
- 1. UNISOLABLE RCS e SG tube leakage leakage OR NCS Integrity-RED Path conditions Consistent with the generic developers note options CSFST
- 2.
SG tube leakage.
P-Loss A.2 met Integrity Red Path is used.
OR B.
RCS cooldown rate greater than (site-specific pressurized thermal shock criteria/limits defined by site-specific indications).
RCS Inadequate Heat Removal NCS Heat Sink-RED Path conditions Consistent with the generic developers note options CSFST Heat P-Loss 2 A. Inadequate RCS heat P-Loss B.1 met Sink Red Path is used.
removal capability via steam AND The phrase "and heat sink required" was added to preclude the generators as indicated by need for classification for conditions in which NCS pressure is less (site-specific indications).
Heat sink is required than SG pressure or Heat Sink-RED path entry was created through operator action directed by an EOP.
RCS CS Activity/CMNT Rad N/A N/A N/A P-Loss 3 Not Applicable 63 of 113
EAL Comparison Matrix MNS NEI MNS FPB FPB NEI IC Wording
- (s MNS FPB Wording Difference Justification FPB#
- (s)
RCS CNMT Integrity or Bypass N/A N/A N/A P-Loss 4 Not Applicable RCS Other Indications N/A N/A No other site-specific NCS Potential Loss indication has been P-Loss 5 A.
(site-specific as applicable) identified for MNS.
RCS Emergency Director Judgment NCS Any condition in the opinion of None P-Loss 6 A. ANY condition in the opinion P-Loss E.1 the Emergency Coordinator/EOF Director that of the Emergency Director thatincaepontllssfth indiatesPotntia Los oftheindicates potential loss of the indicates Potential Loss of thebarrier RCS Barrier.
64 of 113
EAL Comparison Matrix MNS PWR Containment Fission Product Barrier Degradation Thresholds NEI MNS FPB NEI IC Wording FPB MNS FPB Wording Difference Justification FPB#
FPB #(s)
CNMT RCS or SG Tube Leakage CNMT A leaking or RUPTURED SG is None Loss Loss FAULTED outside of containment A.
A leaking or RUPTURED SG is 1
FAULTED outside of containment.
A.1 CNMT Inadequate Heat Removal N/A N/A N/A Loss Not Applicable 2
CNMT RCS ActivitylCMNT Rad N/A N/A N/A Loss Not applicable 3
CNMT CNMT Integrity or Bypass CNMT Containment isolation is required None Loss A.
Containment isolation is required Loss AND EITHER:
4 D.1 AND
- Containment integrity has been EITHER of the following:
lost based on EC judgment
- 1. Containment integrity has been 9 UNISOLABLE pathway from lost based on Emergency containment to the environment Director judgment.
exists OR CNMT Indications of NCS leakage outside of None
- 2.
UNISOLABLE pathway from Loss containment the containment to the D.2 environment exists.
OR B. Indications of RCS leakage outside of containment.
65 of 113
EAL Comparison Matrix MNS NEI MNS FPB#
NEI IC Wording FPB #(s)
MNS FPB Wording Difference Justification CNMT Other Indications N/A N/A No other site-specific Containment Loss indication has Loss been identified for MNS.
A.
(site-specific as applicable) 5 CNMT Emergency Director Judgment CNMT Any condition in the opinion of the None Loss ANY condition in the opinion of the Loss Emergency Coordinator/EOF Director 6
A nY Dirtio the oindin Lof EA that indicates loss of the containment Emergency Director that indicates Loss E.1 bare of the Containment Barrier.
CNMT RCS or SG Tube Leakage N/A N/A N/A P-Loss Not Applicable 1
CNMT Inadequate Heat Removal CNMT Core Cooling-RED Path conditions met Consistent with the generic developers note options P-Loss A.
- 1. (Site-specific criteria for entry P-Loss AND CSFST Core Cooling Red Path is used in lieu of CET 2
into core cooling restoration B.1 Restoration procedures not effectiveand NCS levels.
procedure) within prot e
Added Note 1 consistent with other thresholds with a within 15 mD. (Note 1) timing component.
AND
- 2.
Restoration procedure not effective within 15 minutes.
CNMT RCS ActivitylCMNT Rad CNMT EMF51A/B > Table F-2 column "CMT EMF51A/B are the site-specific containment high P-Loss A. Containment radiation monitor P-Loss Potential Loss" range radiation monitors. The Table F-2 values, 3
reading greater than (site-specific C.1 column CMT Potential Loss represents, based on core value).
damage assessment procedure, the expected containment high range radiation monitor (EMF51A &
B) response based on a LOCA, for periods of 1, 2 and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after shutdown, no sprays and NCS pressure
< 1600 psig with -20% fuel failure.
66 of 113
EAL Comparison Matrix MNS NEI MNS FPB NEI IC Wording FPB MNS FPB Wording Difference Justification FPB#
FPB #(s)
CNMT CNMT Integrity or Bypass CNMT Containment-RED Path conditions me Consistent with the generic developers note options P-Loss P-Loss CSFST Containment Red Path is used in lieu of A.
Containment pressure greater than containment pressure.
4 (site-specific value)
D.1 OR B.
Explosive mixture exists inside CNMT Containment hydrogen concentration
> 6% hydrogen concentration in the presence of containment P-Loss
> 6%
oxygen represents an explosive mixture in OR D.2 containment.
C. 1. Containment pressure greater than (site-specific pressure setpoint)
AND CNMT Containment pressure > 3 psig with <
The Containment pressure setpoint (3 psig) is the P-Loss one full train of containment cooling pressure at which the Containment Spray System
- 2.
Less than one full train of (site-operating per design for > 15 min. (Note should actuate and begin performing its function.
specific system or equipment)
D.3 1) is operating per design for 15 Added Note 1 consistent with other thresholds with a minutes or longer.
timing component.
CNMT Other Indications N/A N/A No other site-specific Containment Potential Loss P-Loss indication has been identified for MNS.
A.
(site-specific as applicable) 5 CNMT Emergency Director Judgment CNMT Any condition in the opinion of the None P-Loss A.
ANY condition in the opinion of the P-Loss Emergency Coordinator/EOF Director A. AY cndiion n te oinio ofthethat indicates potential loss of the 6
Emergency Director that indicates E.1 containment barrier Potential Loss of the Containment Barrier.
67 of 113
Co pa so at MNS Category H Hazards and Other Conditions Affecting Plant Safety 68 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification HU1 Confirmed SECURITY HU1 Confirmed SECURITY None CONDITION or threat CONDITION or threat.
MODE: All MODE: All NEI Ex.
MNS EI E NEI Example EAL Wording EAL MNS EAL Wording Difference Justification EAL #
EAL #
1 A SECURITY CONDITION that HU1.1 A SECURITY CONDITION that Example EALs #1, 2 and 3 have been combined into a single EAL does not involve a HOSTILE does not involve a HOSTILE for ease of presentation and use.
ACTION as reported by the (site-ACTION as reported by the The Security Shift Supervision is defined as the Security Shift specific security shift supervision).
Security Shift Supervision Supervision.
2 Notification of a credible security OR threat directed at the site.
Notification of a credible security threat directed at the site 3
A validated notification from the OR NRC providing information of an aircraft threat.
A validated notification from the NRC providing information of an aircraft threat 69 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification HU2 Seismic event greater than OBE HU2 Seismic event greater than OBE None levels levels MODE: All MODE: All NEI Ex.
MNS NEI Example EAL Wording EAL MNS EAL Wording Difference Justification EAL #
EAL #
1 Seismic event greater than HU2.1 Seismic event > OBE as The MNS OBE indicator is the OBE EXCEEDED alarm on 1AD-1 3, Operating Basis Earthquake indicated by OBE EXCEEDED E7.
(OBE) as indicated by:
alarm on 1AD-1 3, E7 (site-specific indication that a seismic event met or exceeded OBE limits) 70 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification HU3 Hazardous event.
HU3 Hazardous event None MODE: All MODE: All NEI Ex.
MNS NEI Example EAL Wording EAL MNS EAL Wording Difference Justification EAL #
EAL #
1 A tornado strike within the HU3.1 A tornado strike within the None PROTECTED AREA.
PROTECTED AREA 2
Internal room or area flooding of a HU3.2 Internal room or area FLOODING None magnitude sufficient to require of a magnitude sufficient to manual or automatic electrical require manual or automatic isolation of a SAFETY SYSTEM electrical isolation of a SAFETY component needed for the current SYSTEM component needed for operating mode.
the current operating mode 3
Movement of personnel within the HU3.3 Movement of personnel within the None PROTECTED AREA is impeded PROTECTED AREA is due to an offsite event involving IMPEDED due to an offsite event hazardous materials (e.g., an involving hazardous materials offsite chemical spill or toxic gas (e.g., an offsite chemical spill or release).
toxic gas release) 4 A hazardous event that results in HU3.4 A hazardous event that results in Added reference to Note 7.
on-site conditions sufficient to on-site conditions sufficient to prohibit the plant staff from prohibit the plant staff from accessing the site via personal accessing the site via personal vehicles.
vehicles (Note 7) 5 (Site-specific list of natural or N/A N/A No other site-specific hazard has been identified for MNS.
technological hazard events)
Note EAL #3 does not apply to routine N/A Note 7:
This EAL does not This note, designated Note #7, is intended to apply to generic traffic impediments such as fog, apply to routine traffic example EAL #4, not #3 as specified in the generic guidance.
71 of 113
EAL Comparison Matrix MNS 72 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification HU4 FIRE potentially degrading the HU4 FIRE potentially degrading the None level of safety of the plant.
level of safety of the plant MODE: All MODE: All NEI Ex.
MNS EA Ex NEI Example EAL Wording EAL MNS EAL Wording Difference Justification EAL #
EAL #
- a.
A FIRE is NOT extinguished HU4.1 A FIRE is not extinguished within Table H-1 provides a tabularized list of site-specific fire areas.
within 15-minutes of ANY of the 15 min. of any of the following following FIRE detection FIRE detection indications (Note indications:
1):
Report from the field (i.e.,
o Report from the field (i.e.,
visual observation) visual observation)
Receipt of multiple (more o Receipt of multiple (more than 1) fire alarms or than 1) fire alarms or indications indications Field verification of a single o Field verification of a single fire alarm fire alarm AND AND
- b.
The FIRE is located within The FIRE is located within any ANY of the following plant rooms Table H-1 area or areas:
(site-specific list of plant rooms or areas) 2
- a.
Receipt of a single fire alarm HU4.2 Receipt of a single fire alarm Table H-1 provides a list of site-specific fire areas.
(i.e., no other indications of a (i.e., no other indications of a FIRE).
FIRE)
AND AND
- b.
The FIRE is located within The fire alarm is indicating a 73 of 113
EAL Comparison Matrix MNS ANY of the following plant rooms FIRE within any Table H-1 area or areas:
AND (site-specific list of plant rooms or The existence of a FIRE is not areas) verified within 30 min. of alarm AND receipt (Note 1)
- c. The existence of a FIRE is not verified within 30-minutes of alarm receipt.
3 A FIRE within the plant or ISFSI HU4.3 A FIRE within the plant MNS has an ISFSI located inside the plant Protected Area.
[for plants with an ISFSI outside PROTECTED AREA not the plant Protected Area]
extinguished within 60 min. of the PROTECTED AREA not initial report, alarm or indication extinguished within 60-minutes of (Note 1) the initial report, alarm or indication.
4 A FIRE within the plant or ISFSI HU4.4 A FIRE within the plant MNS has an ISFSI located inside the plant Protected Area.
[for plants with an ISFSI outside PROTECTED AREA that the plant Protected Area]
requires firefighting support by PROTECTED AREA that requires an offsite fire response agency to firefighting support by an offsite extinguish fire response agency to extinguish.
Note Note:
The Emergency Director N/A Note 1: The Emergency The classification timeliness note has been standardized across the should declare the Unusual Event Coordinator/EOF Director MNS EAL scheme by referencing the "time limit" specified within the promptly upon determining that should declare the event EAL wording.
the applicable time has been promptly upon exceeded, or will likely be determining that time exceeded.
limit has been exceeded, or will likely be exceeded.
74 of 113
EAL Comparison Matrix MNS Table H-1 Fire Areas Containment Auxiliary Building Diesel Generator Rooms FWST Dog Houses Standby Shutdown Facility (SSF) 75 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification HU7 Other conditions exist which in the HU7 Other conditions existing that in None judgment of the Emergency the judgment of the Director warrant declaration of a Emergency/EOF Director (NO)UE Coordinator warrant declaration MODE: All of a UE MODE: All NEI Ex.
MNS EA E NEI Example EAL Wording EAL MNS EAL Wording Difference Justification EAL #
EAL #
Other conditions exist which in the HU7.1 Other conditions exist which in None judgment of the Emergency the judgment of the Emergency Director indicate that events are in Coordinator/EOF Director indicate progress or have occurred which that events are in progress or indicate a potential degradation of have occurred which indicate a the level of safety of the plant or potential degradation of the level indicate a security threat to facility of safety of the plant or indicate a protection has been initiated. No security threat to facility protection releases of radioactive material has been initiated. No releases of requiring offsite response or radioactive material requiring monitoring are expected unless offsite response or monitoring are further degradation of safety expected unless further systems occurs.
degradation of SAFETY SYSTEMS occurs.
76 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification HA1 HOSTILE ACTION within the HA1 HOSTILE ACTION within the None OWNER CONTROLLED AREA or OWNER CONTROLLED AREA airborne attack threat within 30 or airborne attack threat within 30 minutes.
minutes MODE: All MODE: All NEI Ex.
MNS EA Ex NEI Example EAL Wording EAL MNS EAL Wording Difference Justification EAL #
EAL #
1 A HOSTILE ACTION is occurring or HA1.1 A HOSTILE ACTION is Example EALs #1 and #2 have been combined into a single EAL has occurred within the OWNER occurring or has occurred within for ease of use.
CONTROLLED AREA as reported the OWNER CONTROLLED The Security Shift Supervision is the site-specific security shift by the (site-specific security shift AREA as reported by the supervision.
supervision).
Security Shift Supervision 2
A validated notification from NRC of OR an aircraft attack threat within 30 A validated notification from minutes of the site.
NRC of an aircraft attack threat within 30 min. of the site 77 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification HA5 Gaseous release impeding N/A Gaseous release IMPEDING Mode applicability has been limited to the Table H-2 applicable access to equipment necessary access to equipment necessary modes of 3 - Hot Standby and 4 - Hot Shutdown.
for normal plant operations, for normal plant operations, cooldown or shutdown.
cooldown or shutdown.
MODE: All MODE: 3 - Hot Standby, 4 - Hot Shutdown NEI Ex.
MNS EAL Wording Difference Justification
- a.
Release of a toxic, HA5.1 Release of a toxic, corrosive, Table H-2 provides a list of safe shutdown rooms/areas and corrosive, asphyxiant or asphyxiant or flammable gas into applicable operating modes.
flammable gas into any of the any Table H-2 rooms or areas following plant rooms or areas:
AND (site-specific list of plant rooms Entry into the room or area is or areas with entry-related mode applicability identified) prohibited or IMPEDED (Note 5)
AND
- b.
Entry into the room or area is prohibited or impeded.
Note Note:
If the equipment in the Note 5 If the equipment in the listed None listed room or area was already room or area was already inoperable or out-of-service inoperable or out-of-service before the event occurred, then before the event occurred, then no emergency classification is no emergency classification is warranted.
warranted.
78 of 113
EAL Comparison Matrix MNS Table H-2 Safe Operation & Shutdown RoomslAreas Bldg. Elevation Unit 1 Room/Area Unit 2 Room/Area Modes Auxiliary 716' P/C, RHole, near 1NI-185, ABPC thru CAD Door, FF59 4
Outside CAD 212 800 (1 EMXA) 820 (2EMXA) 3, 4 803 (1 ETA) 805 (2ETA) 3, 4 702 (Elec. Pene.)
713 (Elec. Pene.)
3 Auxiliary 733' 722 (1EMXB-1) 724 (2EMXB-1) 3,4 705 (1ETB) 716 (2ETB) 3, 4 79 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification HA6 Control Room evacuation HA6 Control Room evacuation None resulting in transfer of plant resulting in transfer of plant control to alternate locations, control to alternate locations MODE: All MODE: All NEI Ex.
MNS EAL Ex NEI Example EAL Wording EAL #
MNS EAL Wording Difference Justification 1
An event has resulted in plant HA6.1 An event has resulted in plant The Auxiliary Shutdown Panels and Standby Shutdown Facility control being transferred from the control being transferred from the (SSF) are the site-specific remote shutdown panels/local control Control Room to (site-specific Control Room to the Auxiliary stations.
remote shutdown panels and Shutdown Panels or Standby local control stations).
Shutdown Facility (SSF) 80 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification HA7 Other conditions exist which in the HA7 Other conditions exist that in the None judgment of the Emergency Director judgment of the Emergency warrant declaration of an Alert.
Coordinator/EOF Director warrant MODE: All declaration of an Alert MODE: All NEI Ex.
MNS NEI Example EAL Wording EAL MNS EAL Wording Difference Justification EAL #
EAL #
Other conditions exist which, in the HA7.1 Other conditions exist which, in the None judgment of the Emergency Director, judgment of the Emergency indicate that events are in progress or Coordinator/EOF Director, indicate that have occurred which involve an actual or events are in progress or have occurred potential substantial degradation of the which involve an actual or potential level of safety of the plant or a security substantial degradation of the level of event that involves probable life safety of the plant or a security event that threatening risk to site personnel or involves probable life threatening risk to damage to site equipment because of site personnel or damage to site HOSTILE ACTION. Any releases are equipment because of HOSTILE expected to be limited to small fractions ACTION. Any releases are expected to of the EPA Protective Action Guideline be limited to small fractions of the EPA exposure levels.
Protective Action Guideline exposure levels.
81 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification HS1 HOSTILE ACTION within the HS1 HOSTILE ACTION within the None PROTECTED AREA PROTECTED AREA MODE: All MODE: All NEI Ex.
MNS EAL E NEI Example EAL Wording EAL #
MNS EAL Wording Difference Justification 1
A HOSTILE ACTION is occurring HS1.1 A HOSTILE ACTION is occurring or has The Security Shift Supervision is the site-specific security or has occurred within the occurred within the PROTECTED AREA shift supervision.
PROTECTED AREA as reported as reported by the Security Shift by the (site-specific security shift Supervision supervision).
82 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification HS6 Inability to control a key safety HS6 Inability to control a key safety function None function from outside the Control from outside the Control Room Room.
MODE: All MODE: All NEI Ex.
MNS EAL E NEI Example EAL Wording EAL #
MNS EAL Wording Difference Justification
- a. An event has resulted in plant HS6.1 An event has resulted in plant control The Auxiliary Shutdown Panels and Standby Shutdown control being transferred from the being transferred from the Control Room Facility (SSF) are the site-specific remote shutdown Control Room to (site-specific to the Auxiliary Shutdown Panels or panels/local control stations.
remote shutdown panels and local Standby Shutdown Facility (SSF) control stations).
AND AND Control of any of the following key safety
- b.
Control of ANY of the functions is not reestablished within 15 following key safety functions is min. (Note 1):
not reestablished within (site-e Reactivity specific number of minutes).
" Reactivity control e
Core cooling
" Core cooling [PWR] / RPV NCS heat removal water level [BWR]
" RCS heat removal 83 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification HS7 Other conditions exist which in HS7 Other conditions existing that in the None the judgment of the Emergency judgment of the Emergency Director warrant declaration of a Coordinator/EOF Director warrant Site Area Emergency.
declaration of a Site Area Emergency MODE: All MODE: All NEI Ex.
MNS EA Ex NEI Example EAL Wording EAL MNS EAL Wording Difference Justification EAL #
EAL #
Other conditions exist which in HS7.1 Other conditions exist which in the None the judgment of the Emergency judgment of the Emergency Director indicate that events are Coordinator/EOF Director indicate that in progress or have occurred events are in progress or have occurred which involve actual or likely which involve actual or likely major major failures of plant functions failures of plant functions needed for needed for protection of the protection of the public or HOSTILE public or HOSTILE ACTION that ACTION that results in intentional damage results in intentional damage or or malicious acts, (1) toward site personnel malicious acts, (1) toward site or equipment that could lead to the likely personnel or equipment that could failure of or, (2) that prevent effective lead to the likely failure of or, (2) access to equipment needed for the that prevent effective access to protection of the public. Any releases are equipment needed for the not expected to result in exposure levels protection of the public. Any which exceed EPA Protective Action releases are not expected to Guideline exposure levels beyond the result in exposure levels which SITE BOUNDARY.
exceed EPA Protective Action Guideline exposure levels beyond the site boundary.
84 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification HG1 HOSTILE ACTION resulting in HG1 HOSTILE ACTION resulting in loss of None loss of physical control of the physical control of the facility facility.
MODE: All MODE: All NEI Ex.
MNS EI E NEI Example EAL Wording EAL #
MNS EAL Wording Difference Justification EAL #
A#
1
- a.
A HOSTILE ACTION is HG1.1 A HOSTILE ACTION is occurring or has The Security Shift Supervision is the site-specific security occurring or has occurred within occurred within the PROTECTED AREA shift supervision.
the PROTECTED AREA as as reported by the Security Shift reported by the (site-specific Supervision security shift supervision).
AND EITHER of the following has AND occurred:
- b.
EITHER of the following has Any of the following safety functions occurred:
cannot be controlled or maintained
- 1.
ANY of the following safety 9 Reactivity control functions cannot be controlled or maintained.
Reactivity control NCS heat removal Core cooling OR
[PWR]IRPV water Damage to spent fuel has occurred level [BWR]
or is IMMINENT RCS heat removal OR
- 2.
Damage to spent fuel has occurred or is IMMINENT.
85 of 113
EAL Comparison Matrix MNS NEI IC#
NEI IC Wording MNS MNS IC Wording Difference Justification IC#(s)
MSI odn HG7 Other conditions exist which in HG7 Other conditions exist which in the None the judgment of the Emergency judgment of the Emergency Director warrant declaration of a Coordinator/EOF Director warrant General Emergency declaration of a General Emergency MODE: All MODE: All NEI Ex.
MNS NEI Example EAL Wording EAL MNS EAL Wording Difference Justification EAL #
EAL #
Other conditions exist which in HG7.1 Other conditions exist which in the None the judgment of the Emergency judgment of the Emergency Director indicate that events are Coordinator/EOF Director indicate that in progress or have occurred events are in progress or have occurred which involve actual or which involve actual or IMMINENT IMMINENT substantial core substantial core degradation or melting degradation or melting with with potential for loss of containment potential for loss of containment integrity or HOSTILE ACTION that results integrity or HOSTILE ACTION in an actual loss of physical control of the that results in an actual loss of facility. Releases can be reasonably physical control of the facility, expected to exceed EPA Protective Releases can be reasonably Action Guideline exposure levels offsite expected to exceed EPA for more than the immediate site area.
Protective Action Guideline exposure levels offsite for more than the immediate site area.
86 of 113
MNS EAL Comparison Matrix Category S System Malfunction 87 of 113
EAL Comparison Matrix MNS MNS NEI IC Wording IC#(s)
MNS IC Wording Difference Justification Loss of all offsite AC power SUl Loss of all offsite AC power None capability to emergency buses for capability to essential buses for 15 minutes or longer.
15 minutes or longer MODE: Power Operation, Startup, MODE: 1 - Power Operation, 2 -
Hot Standby, Hot Shutdown Startup, 3 - Hot Standby, 4 - Hot Shutdown NEI Ex.
NEI Example EAL Wording EAL MNS EAL Wording Difference Justification EAL #
EAL #
1 Loss of ALL offsite AC power SU1.1 Loss of all offsite AC power 4,160V buses 1(2)ETA and 1(2)ETB are the site-specific emergency capability to (site-specific capability, Table S-1, to essential buses.
emergency buses) for 15 minutes 4,160V buses 1(2)ETA and Site-specific AC power sources are listed in Table S-1.
or longer.
1(2)ETB for a 15 min. (Note 1)
Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Unusual Event Coordinator/EOF MNS EAL scheme by referencing the "time limit" specified within the promptly upon determining that 15 Director should declare EAL wording.
minutes has been exceeded, or the event promptly upon will likely be exceeded.
determining that time limit has been exceeded, or will likely be exceeded.
88 of 113
EAL Comparison Matrix MNS Table S-1 AC Power Sources Offsite:
ATC (Train A)
SATA (Train A)
ATD (Train B)
SATB (Train B)
Onsite:
D/G 1(2) A (Train A)
D/G 1(2) B (Train B) 89 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification SU2 UNPLANNED loss of Control SU3 UNPLANNED loss of Control None Room indications for 15 minutes Room indications for 15 minutes or longer.
or longer.
MODE: Power Operation, MODE: 1 - Power Operation, 2 -
Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex.
MNS NEI Example EAL Wording EAL MNS EAL Wording Difference Justification EAL #
EAL #
An UNPLANNED event results in SU3.1 An UNPLANNED event results in The site-specific Safety System Parameters are listed in Table S-2.
the inability to monitor one or the inability to monitor one or Added "in at least one SIG" for auxiliary feed flow consistent with the more of the following parameters more Table S-2 parameters from S/G level parameter.
from within the Control Room for within the Control Room for > 15 15 minutes or longer.
min. (Note 1)
Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Unusual Event Coordinator/EOF MNS EAL scheme by referencing the "time limit" specified within the promptly upon determining that Director should declare EAL wording.
15 minutes has been exceeded, the event promptly upon or will likely be exceeded.
determining that time limit has been exceeded, or will likely be exceeded.
90 of 113
[BWR parameter list]
[PWR parameter list]
Reactor Power Reactor Power RPV Water Level RCS Level RPV Pressure RCS Pressure Primary Containment Pressure In-Core/Core Exit Temperature Suppression Pool Level Levels in at least (site-specific number) steam generators Suppression Pool Temperature Steam Generator Auxiliary or Emergency Feed Water Flow Table S-2 Safety System Parameters Reactor power NCS level NCS pressure Core exit TIC temperature Level in at least one S/G Auxiliary feed flow in at least one S/G 91 of 113
EAL Comparison Matrix MNS MNS NEI IC Wording IC#(s)
MNS IC Wording Difference Justification Reactor coolant activity greater SU4 NCS activity greater than Changed 'reactor coolant activity" to "NCS activity" to conform to site than Technical Specification Technical Specification allowable specific terminology.
allowable limits, limits MODE: Power Operation, Startup, MODE: 1 - Power Operation, 2 -
Hot Standby, Hot Shutdown Startup, 3 - Hot Standby, 4 - Hot Shutdown NEI Ex.
NEI Example EAL Wording EAL MNS EAL Wording Difference Justification EAL #
EAL #
1 (Site-specific radiation monitor)
N/A N/A MNS does not have any site-specific radiation monitor that can reading greater than (site-specific provide readings that correspond to TS coolant activity limits.
value).
2 Sample analysis indicates that a SU4.1 Dose Equivalent 1-131 activity > 1 Revised wording to list the MNS T.S. coolant activity limits.
reactor coolant activity value is pCi/gm MNS T.S. Section 3.4.16 provides the TS allowable coolant activity greater than an allowable limit OR limits.
specified in Technical Specifications.
Dose Equivalent Xe-1 33 activity >
280 pCi/gm 92 of 113
EAL Comparison Matrix MNS MNS NEI IC Wording IC#(s)
MNS IC Wording Difference Justification RCS leakage for 15 minutes or SU5 NCS leakage for 15 minutes or None
- longer, longer MODE: Power Operation, MODE: 1 - Power Operation, 2 -
Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex.
MNS EAL Wording Difference Justification 1
RCS unidentified or pressure SU5.1 NCS unidentified or pressure Example EALs #1, 2 and 3 have been combined into a single EAL boundary leakage greater than boundary leakage > 10 gpm for >
for usability.
(site-specific value) for 15 15 min.
minutes or longer.
OR 2
RCS identified leakage greater NCS identified leakage > 25 gpm than (site-specific value) for 15 for > 15 min.
minutes or longer.
OR 3
Leakage from the RCS to a Leakage from the NCS to a location outside containment location outside containment > 25 greater than 25 gpm for 15 gpm for > 15 min.
minutes or longer.
(Note 1)
Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Unusual Event Coordinator/EOF MNS EAL scheme by referencing the "time limit" specified within promptly upon determining that Director should declare the EAL wording.
15 minutes has been exceeded, the event promptly upon or will likely be exceeded.
determining that time limit has been exceeded, or will likely be exceeded.
93 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification SU5 Automatic or manual (trip [PWR]
SU6 Automatic or manual trip fails to None
/ scram [BWR]) fails to shut down the reactor shutdown the reactor.
MODE: 1 - Power Operation MODE: Power Operation NEI Ex.
MNS EI #
MNS EAL Wording Difference Justification EAL #
A#
1
- a.
An automatic (trip [PWR] /
SU6.1 An automatic trip did not shut As specified in the generic developers guidance "Developers may scram [BWR]) did not shutdown down the reactor as indicated by include site-specific EOP criteria indicative of a successful reactor the reactor.
reactor power > 5% after any shutdown in an EAL statement, the Basis or both (e.g., a reactor AND RPS setpoint is exceeded power level)." Reactor power < 5% is the site-specific indication of a
- b. A subsequent manual action AND successful reactor trip.
takenbat.l A subsequent a
c a
n o
Added the words "... as indicated by reactor power > 5% after any taken at the reactor control A subsequent automatic trip or RPS setpoint is exceeded" to clarify that it is a failure of the consoles is successful in manual trip action taken at the shutting down the reactor.
reactor control console (manual automatic trip when a valid trip signal has been exceed.
reactor trip switches or turbine Manual reactor trip switches and turbine manual trip are the site-manual trip) is successful in specific reactor control console trip switches credited for a shutting down the reactor as successful manual trip.
indicated by reactor power < 5%
(Note 8) 2
- a.
A manual trip ([PWR] I SU6.2 A manual trip did not shut down As specified in the generic developers guidance "Developers may scram [BWR]) did not shutdown the reactor as indicated by include site-specific EOP criteria indicative of a successful reactor the reactor.
reactor power > 5% after any shutdown in an EAL statement, the Basis or both (e.g., a reactor AND manual trip action was initiated power level)." Reactor power < 5% is the site-specific indication of a
- b. EITHER of the following:
AND successful reactor trip.
A subsequent automatcllowin:
Added the words "... as indicated by reactor power > 5% after any
- 1. AsubsequentmanualA subsequent automatic trip or manual trip action was initiated" to clarify that it is a failure of any 1.Asbeuetmna manual trip action taken at the action taken at the reactor reactor control console (manual manual trip when an actual manual trip signal has been inserted.
control consoles is reactor trip switches or turbine Combined conditions b.1 and b.2 into a single statement to simplify successful in shutting manual trip) is successful in the presentation.
94 of 113
EAL Comparison Matrix MNS down the reactor.
shutting down the reactor as Manual reactor trip switches and turbine manual trip are the site-OR indicated by reactor power < 5%
specific reactor control console trip switches credited for a (Note 8) successful manual trip.
2 A subsequent automatic (trip [PWR] / scram
[BWR]) is successful in shutting down the reactor.
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.
N/A Note 8: 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.
None 95 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification SU6 Loss of all onsite or offsite SU7 Loss of all onsite or offsite None communications capabilities, communications capabilities.
MODE: Power Operation, MODE: 1 - Power Operation, 2 -
Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex.
MNS EAL E NEI Example EAL Wording EAL #
MNS EAL Wording Difference Justification 1
Loss of ALL of the following SU7.1 Loss of all Table S-4 onsite Example EALs #1, 2 and 3 have been combined into a single EAL onsite communication methods:
communication methods for simplification of presentation.
(site-specific list of OR Table S-4 provides a site-specific list of onsite, ORO and NRC communications methods)
Loss of all Table S-4 ORO communications methods.
2 Loss of ALL of the following communication methods ORO communications methods:
OR (site-specific list of Loss of all Table S-4 NRC communications methods) communication methods 3
Loss of ALL of the following NRC communications methods:
(site-specific list of communications methods) 96 of 113
EAL Comparison Matrix MNS Table S-4 Communication Methods System Onsite ORO NRC Public Address X
Internal Telephones X
Onsite Radios X
DEMNET X
Offsite Radio System X
Commercial Telephones X
X NRC Emergency Telephone System (ETS)
X 97 of 113
EAL Comparison Matrix MNS MNS NEI IC Wording IC#(s)
MNS IC Wording Difference Justification Failure to isolate containment or SU8 Failure to isolate containment or None loss of containment pressure loss of containment pressure control. [PWR]
control MODE: Power Operation, MODE: 1 - Power Operation, 2 -
Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex.
MNS EAL Wording Difference Justification 1
- a.
Failure of containment to EITHER:
Reworded EAL to better describe the intent. Penetrations cannot isolate when required by an Any penetration is not close, but they can be isolated by closure of one or more isolation actuation signal.
isolated within 15 min. of a valves associated with that penetration. The revised wording AND VALID containment isolation maintains the generic example EAL intent while more clearly signal describing failure to isolate threshold.
- b.
ALL required penetrations OR are not cloied with 5ionuts COn t pThe containment pressure setpoint (3 psig) is the pressure at arofthe actuaionsi within EITHE ainutes faiainm sure of 3
which the containment depressurization equipment (NS and VX-both trains of NS OR failure CARF) should actuate and begin performing its function.
2
- a. Containment pressure SU8.1 of both trains of VX-CARF for greater than (site-specific
> 15 min.
pressure).
(Note 1)
AND
- b.
Less than one full train of (site-specific system or equipment) is operating per design for 15 minutes or longer.
N/A N/A N/A Note 1: The Emergency Added Note 1 to be consistent in its use for EAL thresholds with a Coordinator/EOF Director timing component.
should declare the event 98 of 113
EAL Comparison Matrix MNS promptly upon determining that time limit has been exceeded, or will likely be exceeded.
99 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification SA1 Loss of all but one AC power SA1 Loss of all but one AC power None source to emergency buses for source to essential buses for 15 15 minutes or longer.
minutes or longer.
MODE: Power Operation, MODE: 1 - Power Operation, 2 -
Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex.
MNS NEI Example EAL Wording EAL MNS EAL Wording Difference Justification EAL #
EAL #
1
- a.
AC power capability to (site-SAI.1 AC power capability, Table S-1, 4160V buses 1(2)ETA and 1(2)ETB are the site-specific emergency specific emergency buses) is to essential 4160V buses buses.
reduced to a single power source 1(2)ETA and 1(2)ETB reduced to Site-specific AC power sources are listed in Table S-1.
for 15 minutes or longer, a single power source for > 15 AND min. (Note 1)
AND
- b.
Any additional single power source failure will result in a loss Any additional single power of all AC power to SAFETY source failure will result in loss of SYSTEMS.
all AC power to SAFETY SYSTEMS Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Alert promptly upon Coordinator/EOF MNS EAL scheme by referencing the "time limit" specified within the determining that 15 minutes has Director should declare EAL wording.
been exceeded, or will likely be the event promptly upon exceeded.
determining that time limit has been exceeded, or will likely be exceeded.
100 of 113
EAL Comparison Matrix MNS Table S-1 AC Power Sources Offsite:
SATA (Train A)
ATC (Train A)
SATB (Train B)
ATD (Train B)
Onsite:
D/G 1(2) A (Train A)
L D/G 1(2) B (Train B) 101 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification SA2 UNPLANNED loss of Control SA3 UNPLANNED loss of Control None Room indications for 15 minutes Room indications for 15 minutes or longer with a significant or longer with a significant transient in progress.
transient in progress.
MODE: Power Operation, MODE: 1 - Power Operation, 2 -
Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex.
MNS EI E NEI Example EAL Wording EAL #
MNS EAL Wording Difference Justification EAL# #A An UNPLANNED event results in SA3.1 An UNPLANNED event results in The site-specific Safety System Parameters are listed in Table S-2.
the inability to monitor one or the inability to monitor one or the nablit to onior ne r th inbilty o moito on or The site-specific significant transients are listed in Table S-3.
more of the following parameters more Table S-2 parameters from from within the Control Room for within the Control Room for > 15 MNS is a PWR and thus does not include thermal power 15 minutes or longer.
min. (Note 1) oscillations > 10%.
AND AND ANY of the following transient Any significant transient is in events in progress.
progress, Table S-3 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]
102 of 113
EAL Comparison Matrix MNS Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Unusual Event Coordinator/EOF MNS EAL scheme by referencing the "time limit" specified within promptly upon determining that Director should declare the EAL wording.
15 minutes has been exceeded, the event promptly upon or will likely be exceeded.
determining that time limit has been exceeded, or will likely be exceeded.
[BWR parameter list]
[PWR parameter list]
Reactor Power Reactor Power RPV Water Level RCS Level RPV Pressure RCS Pressure Primary Containment Pressure In-Core/Core Exit Temperature Suppression Pool Level Levels in at least (site-specific number) steam generators Suppression Pool Temperature Steam Generator Auxiliary or Emergency Feed Water Flow Table S-2 Safety System Parameters Reactor power NCS level NCS pressure Core exit T/C temperature Level in at least one S/G Auxiliary or emergency feed flow Table S-3 Significant Transients Reactor trip Runback > 25% thermal power Electrical load rejection > 25% electrical load Safety injection actuation 103 of 113
EAL Comparison Matrix MNS MNS NEI IC Wording IC#(s)
MNS IC Wording Difference Justification Automatic or manual (trip [PWR] /
SA6 Automatic or manual trip fails to None scram [BWR]) fails to shutdown shut down the reactor and the reactor, and subsequent subsequent manual actions taken manual actions taken at the at the reactor control consoles reactor control consoles are not are not successful in shutting successful in shutting down the down the reactor reactor.
MODE: 1 - Power Operation MODE: Power Operation NEI Ex.
NEI Example EAL Wording EAL MNS EAL Wording Difference Justification EAL #
EAL #
1
- a.
An automatic or manual (trip SA6.1 An automatic or manual trip fails As specified in the generic developers guidance "Developers may
[PWR] / scram [BWR]) did not to shut down the reactor as include site-specific EOP criteria indicative of a successful reactor shutdown the reactor.
indicated by reactor power shutdown in an EAL statement, the Basis or both (e.g., a reactor AND
Ž5%
power level)." Reactor power < 5% is the site-specific indication of a AND successful reactor trip.
- b.
Manual actions taken at the reactor control consoles are not Manual trip actions taken at the The manual reactor trip switches and turbine manual trip are the successful in shutting down the reactor control console (manual site-specific reactor control console trip switches credited for a succssfl i shutin don te recto cotro conole(maual successful manual trip.
reactor.
reactor trip switches or turbine manual trip) are not successful in shutting down the reactor as indicated by reactor power > 5%
(Note 8)
Notes Note:
A manual action is any N/A Note 8: A manual action is any None operator action, or set of actions, operator action, or set of which causes the control rods to actions, which causes be rapidly inserted into the core, the control rods to be and does not include manually rapidly inserted into the driving in control rods or implementation of boron injection include manually driving 104 of 113
EAL Comparison Matrix MNS strategies.
in control rods or implementation of boron injection strategies.
105 of 113
EAL Comparison Matrix MNS MNS T I
NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification SA9 Hazardous event affecting a SAFETY SYSTEM needed for the current operating mode.
MODE: Power Operation, Startup, Hot Standby, Hot Shutdown SA9 Hazardous event affecting a SAFETY SYSTEM needed for the current operating mode MODE: 1 - Power Operation, 2 -
Startup, 3 - Hot Standby, 4 - Hot Shutdown None 106 of 113
EAL Comparison Matrix MNS NEI Ex MNS NEIL E NEI Example EAL Wording EAL #
MNS EAL Wording Difference Justification 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.
SA9.1 The occurrence of any Table S-5 hazardous event AND EITHER:
" Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM needed for the current operating mode
- The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure needed for the current operating mode The hazardous events have been listed in Table S-5.
107 of 113
EAL Comparison Matrix MNS Table S-5 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 108 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification SS1 Loss of all offsite and all onsite SS1 Loss of all offsite and all onsite The MNS essential buses are the site-specific emergency buses.
AC power to emergency buses AC power to essential buses for for 15 minutes or longer.
15 minutes or longer MODE: Power Operation, MODE: 1 - Power Operation, 2 -
Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex.
MNS EI #
MNS EAL Wording Difference Justification EAL# #A 1
Loss of ALL offsite and ALL SS1.1 Loss of all offsite and all onsite 4160V buses 1 (2)ETA and 1(2)ETB are the site-specific emergency onsite AC power to (site-specific AC power capability, Table S-1, buses.
emergency buses) for 15 minutes to essential 4160V buses Site-specific AC power sources are listed in Table S-1.
or longer.
1 (2)ETA and 1 (2)ETB for > 15 min. (Note 1)
Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Unusual Event Coordinator/EOF MNS EAL scheme by referencing the "time limit" specified within the promptly upon determining that Director should declare EAL wording.
15 minutes has been exceeded, the event promptly or will likely be exceeded.
upon determining that time limit has been exceeded, or will likely be exceeded.
109 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification SS5 Inability to shutdown the reactor SS6 Inability to shut down the None causing a challenge to (core reactor causing a challenge to cooling [PWR] I RPV water level core cooling or NCS heat
[BWR]) or RCS heat removal, removal MODE: Power Operation MODE: 1 - Power Operation NEI Ex.
NIEapeELWrig MNS EAL E NEI Example#
EAL W
MNS EAL Wording Difference Justification
- a.
An automatic or manual (trip SS6.1 An automatic or manual trip fails As specified in the generic developers guidance "Developers may
[PWR] / scram [BWR]) did not to shut down the reactor as include site-specific EOP criteria indicative of a successful reactor shutdown the reactor.
indicated by reactor power shutdown in an EAL statement, the Basis or both (e.g., a reactor AND 5%
power level)." Reactor power < 5% is the site-specific indication of a
- b.
All manual actions to AND successful reactor trip.
shutdown the reactor have been All actions to shut down the Indication that core cooling is extremely challenged is manifested unsuccessful.
reactor are not successful as by CSFST Core Cooling RED Path conditions met.
AND indicated by reactor power Indication that heat removal is extremely challenged is manifested
> 5%
by CSFST Heat Sink RED Path conditions met.
- c.
EITHER of the following AND EITHER:
conditions exist:
(Site-specific indication of 9 Core Cooling RED Path an inability to adequately conditions met remove heat from the e Heat Sink RED Path core) conditions met (Site-specific indication of an inability to adequately remove heat from the RCS) 110 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification SS8 Loss of all Vital DC power for 15 SS2 Loss of all vital DC power for 15 None minutes or longer.
minutes or longer.
MODE: Power Operation, MODE: 1 - Power Operation, 2 -
Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex.
MNS EAL E NEI Example EAL Wording EAL #
MNS EAL Wording Difference Justification 1
Indicated voltage is less than SS2.1 Loss of all 125 VDC power 105 VDC is the site-specific minimum vital DC bus voltage.
(site-specific bus voltage value) based on battery bus voltage DC buses EVDA and EVDD are the site-specific vital DC buses.
on ALL (site-specific Vital DC indications < 105 VDC on both busses) for 15 minutes or longer, vital DC buses EVDA and EVDD for > 15 min (Note 1)
Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Unusual Event Coordinator/EOF Director MNS EAL scheme by referencing the "time limit" specified within the promptly upon determining that should declare the event EAL wording.
15 minutes has been exceeded, promptly upon determining that or will likely be exceeded.
time limit has been exceeded, or will likely be exceeded.
111 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification SG1 Prolonged loss of all offsite and SGla Prolonged loss of all offsite and NEI ICs SG1 and SG8 are grouped under the same MNS IC for all onsite AC power to all onsite AC power to essential simplification.
emergency buses.
buses The MNS essential buses are the site-specific emergency buses.
MODE: Power Operation, MODE: 1 - Power Operation, 2 -
Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex.
MNS EAL Ex NEI Example EAL Wording EAL #
MNS EAL Wording Difference Justification
- a.
Loss of ALL offsite and ALL SG1.1 Loss of all offsite and all onsite 4160V buses 1(2)ETA and 1(2)ETB are the site-specific emergency onsite AC power to (site-specific AC power capability to essential buses.
emergency buses).
4160V buses 1(2)ETA and 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is the site-specific SBO coping analysis time.
AND 1 (2)ETB CSFST Core Cooling RED Path conditions met indicates significant
- b.
EITHER of the following:
AND EITHER:
core exit superheating and core uncovery.
SRestoration of at least
- Restoration of at least one emergency bus in < 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> one AC emergency bus in i
o iey(oe1 less than (site-specific is not likely (Note 1) hours) is not likely.
9 Core Cooling RED Path conditions met (Site-specific indication of an inability to adequately remove heat from the core)
Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the General Emergency Coordinator/EOF MNS EAL scheme by referencing the "time limit" specified within promptly upon determining that Director should declare the EAL wording.
(site-specific hours) has been the event promptly exceeded, or will likely be upon determining that exceeded.
time limit has been exceeded, or will likely be exceeded.
112 of 113
EAL Comparison Matrix MNS MNS NEI IC#
NEI IC Wording IC#(s)
MNS IC Wording Difference Justification SG8 Loss of all AC and Vital DC SG1b Loss of all AC and vital DC NEI ICs SG1 and SG8 are grouped under the same MNS IC for power sources for 15 minutes or power sources for 15 minutes or simplification.
longer.
longer MODE: Power Operation, MODE: 1 - Power Operation, 2 -
Startup, Hot Standby, Hot Startup, 3 - Hot Standby, 4 - Hot Shutdown Shutdown NEI Ex.
MNS NEI Example EAL Wording EAL MNS EAL Wording Difference Justification EAL#
EAL#
1
- a. Loss of ALL offsite and ALL SG1.2 Loss of all offsite and all onsite 4160V buses 1(2)ETA and 1(2)ETB are the site-specific emergency onsite AC power to (site-specific AC power capability, Table S-1, buses.
emergency buses) for 15 minutes to emergency 4160V buses Site-specific AC power sources are tabularized in Table S-1.
or longer.
1(2)ETA and 1(2)ETB for > 15 AND min.
105 VDC is the site-specific minimum vital DC bus voltage.
- b. Indicated voltage is less than AND EVDA and EVDD are the site-specific vital DC buses.
(site-specific bus voltage value)
Loss of all 125 VDC power on ALL (site-specific Vital DC based on battery bus voltage busses) for 15 minutes or longer, indications < 105 VDC on both vital DC buses EVDA and EVDD for > 15 min.
(Note 1)
Note The Emergency Director should N/A Note 1: The Emergency The classification timeliness note has been standardized across the declare the Unusual Event Coordinator/EOF Director MNS EAL scheme by referencing the "time limit" specified within the promptly upon determining that 15 should declare the event EAL wording.
minutes has been exceeded, or promptly upon determining that will likely be exceeded.
time limit has been exceeded, or will likely be exceeded.
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