ML16055A227

Response to Request for Additional Information and Emergency Action Level Technical Bases Document, Revision 1, Redline Version. Part 1 of 4

ML16055A227
Person / Time
Site:	Catawba
Issue date:	02/19/2016
From:	Henderson K Duke Energy Carolinas
To:	Office of Nuclear Reactor Regulation
Shared Package
ML16055A223	List: CNS-16-010, Response to Request for Additional Information and Emergency Action Level Technical Bases Document, Revision 1, Clean Version. Part 4 of 4 ML16055A226 ML16055A227 ML16055A228 ML16055A230
References
CNS-16-010, TAC MF6166, TAC MF6167
Download: ML16055A227 (104)

Text

Enclosure 1 Response to Request for Additional Information Catawba Nuclear Station, Unit I and 2 Docket Nos. 50-413 and 50-414 U.S. Nuclear Regulatory Commission CNS-1 6-010 Enclosure I Page 1 of 13 By letter dated April 30, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15125A149), Duke Energy requested approval of a proposed change to the Emergency Action Levels (EALs) used at Catawba Nuclear Station (CNS) which would revise the current CNS EAL scheme to one based upon Nuclear Energy Institute (NEI) document NEI 99-01, "Development of Emergency Action Levels for Non-Passive Reactors," Revision 6 (ADAMS Accession No. ML1 2326A805).

The NRC staff reviewed the request and determined that additional information is needed to complete their review. A letter requesting additional information was sent on January 20, 2016 (ADAMS Accession No. MLI16014A71 0).Duke Energy provides the following response to the request for additional information (RAI) regarding the License Amendment Request to revise the CNS EAL Scheme to one based on NEI 99-01, Revision 6. Changes to the CNS Technical Bases document as a result of this RAI are identified within the CNS RA! Response in the table below. Changes were also made to the CNS Technical Bases Document that were not the result of an RAI. These additional changes are described in a table below the RAI response, with an explanation of why each change was deemed necessary.

The revised CNS EAL Technical Bases Document is provided in Enclosure 2 with revision bars indicating changes from the original submittal.

Revision 1, clean version of CNS EAL Technical Bases Document is provided in Enclosure 3.RAI # SECTION!/usinCSRsos CNS- EALQusinCSR poe For Section 1.0, please clarify what change control process CNS has added the following to Section 1.0: will be used to maintain this document.

If appropriate, add "eas h nfraini ai ouetcnafc language to this section stating that this document will be emrncclsicaondiin-kng(g.th 1 1. mantaied n acordncewith10 FR 5.54q).Emergency Coordinator refers to it during an event), the NRC staff expects that changes to the basis document will be evaluated in accordance with the provisions of 10 CFR 50.54(q)." 2 GENERAL Section 2.5, "Technical Basis Information," includes a The CNS site specific and NEI 99-01 generic bases sections U.S. Nuclear Regulatory Commission CNS-1 6-010 Enclosure I Page 2 of 13 RAI # TSECTION/

usinCSRsos CNS- EALQusinCSRpoe Plant-Specific (CNS) basis section, in addition to a Generic (NEI 99-01) basis section. One of the enhancements provided in Revision 6 to NEI 99-01 is a separation of the developer's notes from the bases information.

This change was made to facilitate the use of bases information for the two distinct purposes, development and classification.

Considering that the EAL Technical Basis is provided to support proper emergency classification decision making, please explain why a Generic (NEI 99-01) basis section is provided rather than incorporated into Plant-Specific (CNS)basis section.have been combined into a single bases section for each EAL. Section 2.5 "Technical Bases Information" has been revised accordingly.

Redundant bases, where applicable, have been deleted.Escalation statements have been revised where appropriate to site specific EAL number.RA1 .3 bases has been revised to only reference liquid effluents.

RA1 .3 and RA1 .4 bases was revised to delete the cited paragraph related to effluent monitors.Specific examples include the following:

• Escalation should refer to CNS EAL numbering vice generic NEI 99-01 EAL numbering to facilitate timely assessments by the Emergency Coordinator.

• The Plant-Specific (CNS) basis section information should be specific to each EAL provided by the licensee.

The following are examples of apparent inconsistencies:

oFor the proposed RAI1.3, the NEI 99-01 basis discussion includes reference to gaseous radioactivity while the proposed RA1 .3 only applies to liquid effluent samples.

U.S. Nuclear Regulatory Commission CNS-1 6-010 Enclosure 1 Page 3 of 13 RAI # SECTION/ usinCSRsos CNS- EALQusinCSRpoe a For the proposed RA1 .3 and RA1 .4, the last paragraph of the NEI 99-01 basis discussion includes reference to effluent radiation monitors while the EAL only applies to field survey results.For Section 4.1, it appears to reference an incorrect CNS has revised the referenced ADAMS Accession Number ADAMS number for the endorsed version of NEI 99-01, to ML1 2326A805.3 4.1 Revision 6. The endorsed version is ML12326A805.

Please clarify the reference or correct this instance as well as others, if used later in the document as well.Section 4.3, "Instrumentation Used for EALs," to NEI 99-01, ONS has confirmed that all setpoints and indications used in Revision 6, states (in part): "Scheme developers should the proposed EAL scheme are within the calibrated range(s)ensure that specific values used as EAL setpoints are of the stated instrumentation and that the resolution of the within the calibrated range of the referenced instrumentation is appropriate for the setpointlindication.

4 N/A instrumentation." Please confirm that all setpoints and indications used in the proposed EAL scheme are within the calibrated range(s) of the stated instrumentation and that the resolution of the instrumentation is appropriate for the setpoint/indication.

Section 5.0, "Definitions," does not include definitions for The following definitions have been added to Section 5.0 550 the following:

consistent with NEI 99-01 Revision 6:* Alert,

• Alert,* Notification of Unusual Event,

• Unusual Event, U.S. Nuclear Regulatory Commission CNS-1 6-010 Enclosure 1 Page 4 of 13 RAI # SECTION/ usinCSRsos CNS- EALQusinCSRpoe

• Site Area Emergency,

• Site Area Emergency,* General Emergency,

• General/Emergency,* Emergency Action Level,

• Emergency Action Level,* Emergency Classification Level,

• Emergency Classification Level,* Fission Product Barrier Threshold,

• Fission Product Barrier Threshold,* Initiating Condition, and

• Initiating Condition, and* Independent Spent Fuel Storage Installation.

• Independent Spent Fuel Storage Installation.

Please provide justification for omitting these definitions, or revise to incorporate these definitions consistent with NEI 99-01, Revision 6.For the following EALs, please explain why the listed CNS has deleted Note 3 from RAl1.2, RS1 .2 and RG1 .2.RA1.2, NOTEs were included, or revise accordingly:

6 RS1.2,

• RAI.2 -NOTE-3 RG1.2

• RS1.2- NOTE-3* RG1 .2- NOTE-3 For EAL RA2.2, the information in the NEI 99-01 Basis CNS has re-instated the following text to the RA2.2 bases: secton oesnot ontin ll f th acualinfomaton rom "This EAL applies to irradiated fuel that is licensed for dry NEI 99-01, as it is germane to this particular EAL. Please storage up to the point that the loaded storage cask is 7 RA2.2 explain why this information was omitted, or revise sae.Oc eld aaet oddcs asn accordngly.loss of the CONFINEMENT BOUNDARY is classified in accordance with EAL EUI. 1."

U.S. Nuclear Regulatory Commission CNS-1 6-010 Enclosure 1 Page 5 of 13 RAI # SECTION!/usinCSRsos CNS- EALQusinCSRpoe For EALs CU1 .2, CA1 .2, CS1 .1 and OGI .1, please provide CNS has revised EALs CUl1.2, CA1 .2, CS1 .1 and CGI .1, to further detail as to why additional sumps and tanks cannot add a new Table C-6 that includes the following additional CUi1.2, be used for these EALs, or revise accordingly.

sumps and tanks: 8 CA1.2, Sumps: Residual Heat Removal/Containment Spray CS1.1 (ND/NS)CGI.1 Tanks: Reactor Coolant Drain Tank (NCDT)Pressure Relief Tank (PRT)Please provide further detail as to why CS1.1 and CS1.2 Although the current NUMARC/NESP-007 Rev. 2 based from NEI 99-01, Revision 6, cannot be adequately EALs provide thresholds utilizing NCS narrow range water developed.

A review of the current CNS EAL scheme level below the bottom of the hot leg, the design and shows that, while limited, CNS does have NCS water level operation of the CNS water level instrumentation is such CS1 .1, monitoring capability.

Please provide further justification for that the "site-specific level" (6" below the bottom ID of the CSl .2 the removal of these EALs from the proposed CNS EAL NCS loop and Top of Active Fuel) cannot be determined at scheme, or revise accordingly.

all times during Cold Shutdown or Refueling modes because the RVLIS instrumentation is not available at all times during these modes. There are no alternative means of assessing NCS water below the bottom of the NCS loop.For EALs CU2.1, SAlI.1, The incorporation of SATA Train CNS has revised Tables C-2 and S-1 to condition credit for CU2.1, A, and SATA Train B, into Table C-2, must include, as a SATA (Train A) and SATB (Train B) only if already aligned.10 CA1.1, note or as part of the table, that consideration for these AC S~l.1 Power Sources can only be given if they are already aligned, otherwise please remove from the table.

U.S. Nuclear Regulatory Commission CNS-1 6-010 Enclosure 1 Page 6 of 13 RAI # SECTION!IusinCSRsos CNS- EALQusinCSRpoe For EALs CA2.1, SS1.1, SG1.1, and SG1.2, Tables 0-2 CNS has deleted reference to Table 0-2/S-I AC power and S-I, "AC Power Sources" were included.

These tables source tables from CA2.1, SS1.1, SGI .1 and SGI1.2.are limited to those power supplies that are capable of CA1.1, providing power to the essential buses. However, the 11 SG.1 licensee may establish the capability to power an essential SGI .1, bus from an alternate power supply during the additional SG1 .2 time that may be potentially available.

Please justify including Tables C-2 and S-I for CA2.1, S1.1, SGI.1, and SG1 .2 or revise accordingly.

For EAL CA3.1, please explain why the CNS Basis has a CNS has added new Note 9 to CA3.1 that reads: statmen reate towha to o wen elibleNOS"In the absence of reliable NCS temperature indication 12 CA3.1 temperature indication is absent. If this is an accuratecasdbthlosfdeyhetrmolcpblty statement, then please explain why this is not provided as a clsicaonhudbeaedntmeobilaawenn NOTE for the EAL, or revise accordingly.

Mode 5 and 6" For EAL HU2.1, please explain in further detail the process Immediate control room alarm indication of an earthquake of used to determine if the seismic activity has exceeded the either 0.08 g horizontal or 0.053 g vertical or greater is Operating Basis Earthquake (OBE) threshold and its annunciated through the system's network control center classification timeliness.

If the OBE threshold (vertical) is (NCC), following seismic trigger actuation by at least two 13 HU2.1 not recognized in a timely fashion from indications in, or accelerographs (vertical switch settings are 2/3 of the near, the Control Room, then explain why the alternative respective horizontal switch settings).

Therefore exceeding EAL was not developed in accordance with NEI 99-01, either the horizontal or vertical OBE thresholds actuates the Revision 6, or revise accordingly.

specified alarm.Classification is based upon receipt of this alarm.

U.S. Nuclear Regulatory Commission CNS-1 6-010 Enclosure 1 Page 7 of 13 RAI # SECTION/QusonCSRpne CNS- EAL esinNSepoe The HU2.1 bases has been revised to clarify that the OBE alarm is received based on exceeding either acceleration.

Please explain why there was no EAL developed, possibly There is no site-specific lake level threat that is not as HU3.5, for ultimate heat sink (i.e., lake level) level adequately addressed through other Hazard and/or System 14 HU3 issues, or revise accordingly.

Malfunction EALs. High ultimate heat sink (i.e. lake level) is adequately addressed by HU3.4. Low lake level (loss of heat sink) is adequately addressed by CU3.1.For EALs HU4.1 and HU4.2, the areas listed in Table H-i Table H-i Fire Areas are based on CNS-1465.00-00-0006 seem to be vague or too all-encompassing.

Please explain Design Basis Specification for the Plant Fire Protection and if the listed areas are all the areas that contain equipment AP/0/A/5500/045 Plant Fire. Table H-i Fire Areas include needed for safe operation, safe shutdown and safe cool- those structures containing functions and systems required down, and if these areas can be fine-tuned to limit for safe operation, shutdown and cooldown of the plant consideration for these EALs, or revise accordingly. (SAFETY SYSTEMS).A balance must be established between defining major plant 15 HU4.1, structures containing safe shutdown equipment as fire areas HU4.2 versus a detailed list of areas for every safety system component location.

The Table H-i list of fire areas achieves that balance in support of timely and accurate emergency classification for the end-user.The list of areas could be further refined based on the Post Fire Safe Shutdown analyzed Fire Areas as given in the Safe Shutdown Design Basis Specification (CNS-i1435.00-00-0002).

However, further refinement would not result in U.S. Nuclear Regulatory Commission CNS-1 6-010 Enclosure 1 Page 8 of 13 RAI # SECTION/ usinCSRsos CNS- EALQusinCSRpoe any changes in how reporting would be performed.

For EALs HU4.3 and HU4.4, please confirm that the The CNS ISFSI is contained wholly within the plant 16 HU4.3, Independent Spent Fuel Storage Installation (ISFSI) would Protected Area. Therefore the ISFSI would be applicable to 16 HU4.4 be an area applicable to these EALs, or revise accordingly.

EALs HU4.3 and HU4.4 for fires within the plant Protected Area.For EAL HA5.1, please note in the CNS Basis that this EAL The following note has been added to the HA5.1 bases to is typically applicable in all operating modes, but is limited ensure HA5.1 mode applicability remains in alignment with to operating mode 4 based upon a review of applicable Table H-2 Room/Area mode applicability:

areas of concern. However, if the plant is modified such "NOTE: IC HA5 mode applicability has been limited to the that additional areas and/or operating modes becomeaplcleodsintfdinTleH2SeOerin&

applicable, this EAL must be revised accordingly.

Please applicabl modes/identi/fie ind abe H-2 Slafe operationg explain what process is in place which ensures that future ShtonRmsAe.Ifdeopltoerig plan chnge ar cosidred or the thn oeraingprocedure or plant configuration changes, the applicable plant changesre cosierdoroterthn.peatn plant modes specified in Table H-2 are changed, a 17 HA5.1 corresponding change to Attachment 3 'Safe Operation

&Shutdown Areas Tables R-2 & H-2 Bases' and to IC HA5 mode applicability is required." Operations procedure group will use their tracking mechanism to ensure that whenever "Controlling Procedure for Unit Shutdown," (OP/1/A/6100/002 or OP/2/A/6100/002) are revised, Emergency Planning (EP) will be required to review the changes to ensure that the changes are validated against HA5.1. Based on review by EP, if changes have________________been made such that additional areas and/or operating U.S. Nuclear Regulatory Commission CNS-1 6-010 Enclosure 1 Page 9 of 13 RAI # SECTION/QusonCSRpne CNS- EAL esinCSepoe modes become applicable, EAL will be revised accordingly.

For EAL HS6.1, please explain why the operating mode CNS has revised HS6.1 mode applicability from ALL to specificity to the key safety functions listed in the EAL was Modes 1 -6.not incorporated, or revise accordingly.

CNS has revised HS6.1 based upon an assessment of applicable modes for each of the listed safety function as follows: 'An event has resulted in plant control being transferred 18 HS6.1 from the Control Room to the Auxiliary Shutdown Panels or Standby Shutdown Facility (SSF)AND Con trol of any of the following key safety functions is not reestablished within 15 min. (Note 1):* Reactivity (Modes 1, 2 and 3 only)* Core Cooling* NCS heat removal" Under Category E -Independent Spent Fuel Storage CNS has deleted the following cited statement from the Installation (ISFSI) guidance, the statement: "Formal offsite Category E introduction planning is not required because the postulated worst-case "Formal offsite planning is not required because the 19 U .1 accident involving an ISFSI has insignificant consequences postulated worst-case accident involving an ISFSI has 19 EI. 1 to the public health and safety," is not applicable to this proposed EAL scheme. Please provide further justification insignificant consequences to the public health and safety." for this statement or revise accordingly to remove. Revised the ISFSI category introduction to read:_____In addition, please incorporate guidance related to the fact "The CNS ISFSI is contained wholly within the plant U.S. Nuclear Regulatory Commission CNS-1 6-010 Enclosure 1 Page 10 of 13 RAI # SECTIONI/usinCSRsos CNS- EALQusinNSRpoe that EALs HU1 and HAl are also considered for events that Protected Area. Therefore a security event related to the occur at the ISFSI, or explain basis for not including.

ISFSI would be applicable to EALs HUl.1, HAI.land HSI. 1." For EAL SU8.1, please explain why the information from The bases discussion related to declaration timing provides the ON Basis related to the timing of the declaration is not background on containment cooling system operating in the actual EAL or as a note, or revise accordingly.

design. The EAL threshold

"... one full train of containment cooling operating per design for > 15 min." includes the described operating characteristics and is fully understood by Control Room operators.

20 SU8.1 CNS has added new Note 10 to SU8.1 and Containment Potential Loss D.3 to re-inforce the bases information: "If the loss of containment cooling threshold is exceeded due to loss of both trains of VX-CARF, this EAL only applies if at least one train of VX-CARF is not operating, per design, after the 10 minute actuation delay for greater than or equal to 15 minutes" Under the Fission Product Barrier (FPB) Matrix, the cited As per response to RAI-CNS-2, the CNS site specific and NEI 99-01 Basis sections for several of the FPB criteria are NEI 99-01 Revision 6 bases have been unified.PB not from the NRC-endorsed NEI 99-01, Revision 6. Please 21 Mtrix either revise to what has actually been endorsed or, Bases depending on the response to RAI-03, unify the basis sections into one.

U.S. Nuclear Regulatory Commission CNS-1 6-010 Enclosure 1 Page 11 ofl13 RAI # SECTION/QusinCSRpoe CNS- EALQusinCSRpoe For the Fission Barrier Matrix, please provide the documentation supporting the values from Table F-2.22 FPB Matrix Bases Table F-2 The values presented in Table F-2 were derived from CNS Core Damage Assessment Guidelines (RPIOIAI5000101 5).The figures in RP/0/A/5000/015 are based on values derived in CNS Estimated Sample Dose and CDAG Setpoint Calculation in Support of PASS Elimination (DPC-1 229.00-00-0006).Table F-2 values are derived from RP/0/A/5000/015 Figures 1 and 3 as follows: FC Loss Column FC Loss represents, based on core damage assessment procedure, the expected containment high range radiation monitor (EMF53A & B) response based on a LOCA, for periods of 1, 2, 8 and 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> after shutdown, no sprays and NCS pressure < 1600 psig with -2% fuel failure.The value is derived as follows: RP/0/A/5000/015 Figure 3 Containment Radiation Level vs.Time for 100% Clad Damage 1, 2, 8 and 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> after shutdown without spray and NCS pressure < 1600 psig x 0.02 (rounded).

NCS Loss The value specified represents, based on core damage assessment procedure RP/0/A/5000/015 Figure 1, the U.S. Nuclear Regulatory Commission CNS-1 6-010 Enclosure 1 Page 12 of 13 RAI # SECTION/QusinCSRpoe CNS- EALQusinCSRpoe expected containment high range radiation monitor (EMF53A& B) response based on a LOCA, for periods of 1, 2, 8 and 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> after shutdown with no fuel failure.The value is derived as follows: RP/0/A/5000/01 5 Figure 1 Containment Radiation Level vs.Time for RCS Release for periods of 1, 2, 8 and 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> after shutdown (rounded).

CMT Pot. Loss The Table F-2 values, column CMT Potential Loss represents, based on core damage assessment procedure, the expected containment high range radiation monitor (EMF53A & B) response based on a LOCA, for periods of 1, 2, 8 and 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> after shutdown, no sprays and NOS pressure < 1600 psig with '-20% fuel failure.The value is derived as follows: RP/0/A15000/015 Figure 3 Containment Radiation Level vs.Time for 100% Clad Damage 1, 2, 8 and 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> after shutdown with no spray and NCS pressure < 1600 psig x 0.20 (rounded).

U.S. Nuclear Regulatory Commission CNS-1 6-010 Enclosure 1'Page 13 of 13 Attachment A Summary of EAL Changes Not Associated with RAI Responses The table below summarizes changes that have been incorporated into the EAL Technical Bases Document contained in Enclosure 2 that are not involved in the NRC RAI response.EAL Tech Basis#Change? Description HU1 .1 Yes Split EAL HUl1.1 into three separate EALs: HU1 .1, HUl1.2 and HU1 .3 to better support the offsite notification process.HA1 .1 Yes Split EAL HAl1.1 into two separate EALs: HAl1.1 and HAl1.2 to better support the offsite notification process.SU4.1 Yes Revised SU4.1 to clarify NCS coolant activity limits to encompass Facility Operating License limits.: "NCS activity > Technical Specification 3.4.16 limits or Facility Operating License limits (151/1 59), whichever is more restrictive" Enclosure 2 Catawba Nuclear Station Emergency Action Level Technical Bases Document Revision 1 (Redline Version)

• ,, DUKE CATAWBA NUCLEAR STATION EMERGENCY ACTION LEVEL TECHNICAL BASES Revision 1 Redline Version IRPII/o500oo1oo01 Rev. 1 IPage 1 of 247 TABLE OF CONTENTS SECTION PAGE 1.0 PURPOSE ..............................................................................................

3 2.0 DISCUSSION

...........................................................................................

3 2.1 Background

...........................................................................................

3 2.2 Fission Product Barriers .............................................................................

4 2.3 Fission Product Barrier Classification Criteria......................................................

4 2.4 EAL Organization.....................................................................................

5 2.5 Technical Bases Information

........................................................................

7 2.6 Operating Mode Applicability........................................................................

8 3.0 GUIDANCE ON MAKING EMERGENCY CLASSIFICATIONS

.....................................

9 3.1 General Considerations

............................................................................

10 3.2 Classification Methodology.........................................................................

10

4.0 REFERENCES

........................................................................................

14 4.1 Developmental

......................................................................................

14 4.2 Implementing........................................................................................

14 5.0 DEFINITIONS, ACRONYMS & ABBREVIATIONS

.................................................

15 6.0 CNS TO NEI 99-01 Rev. 6 EAL CROSS-REFERENCE

...........................................

24 7.0 ATTACHMENTS

......................................................................................

28 1 Emergency Action Level Technical Bases .................................................

29 Cateciory R Abnormal Rad Release / Rad Effluent..................................

29 Cateiqory C Cold Shutdown / Refueling System Malfunction

.......................

71 Catecqorv H Hazards .................................................................

108 Categiory S System Malfunction.....................................................

153 Cate~qory E ISFSI ....................................................................

197 Cateciorv F Fission Product Barrier Degradation..................................

200 2 Fission Product Barrier Loss / Potential Loss Matrix and Bases ...........................................................................

205 3 Safe Operation

& Shutdown Rooms/Areas Tables R-2 & H-2 Bases...................

253 IRP/OIA/5000/O01 I Rev. 1I Page 2 of 247

1.0 PURPOSE

This document provides an explanation and rationale for each Emergency Action Level (EAL)included in the EAL Upgrade Project for Catawba Nuclear Station (CNS). It should be used to facilitate review of the CNS EALs and provide historical documentation for future reference.

Decision-makers responsible for implementation of RP/OIA/5000/O01 Classification of Emergency, may use this document as a technical reference in support of EAL interpretation.

This information may assist the Emergency Coordinator in making classifications, particularly those involving judgment or multiple events. The basis information may also be useful in training and for explaining event classifications to off-site officials.

The expectation is that emergency classifications are to be made as soon as conditions are present and recognizable for the classification, but within 15 minutes or less in all cases of conditions present. Use of this document for assistance is not intended to delay the emergency classification.

Because the information in a basis document can affect emergency classification decision-making (e.g., the Emergency Coordinator refers to it during an event), the NRC staff expects that changes to the basis document will be evaluated in accordance with the provisions of 10 CFR 50.54(q).2.0 DISCUSSION

2.1 Background

EALs are the plant-specific indications, conditions or instrument readings that are utilized to classify emergency conditions defined in the CNS Emergency Plan.In 1992, the NRC endorsed NUMARC/NESP-007 "Methodology for Development of Emergency Action Levels" as an alternative to NUREG-0654 EAL guidance.NEI 99-01 (NUMARC/NESP-007)

Revisions 4 and 5 were subsequently issued for industry implementation.

Enhancements over earlier revisions included:* Consolidating the system malfunction initiating conditions and example emergency action levels which address conditions that may be postulated to occur during plant shutdown conditions.

• Initiating conditions and example emergency action levels that fully address conditions that may be postulated to occur at permanently Defueled Stations and Independent Spent Fuel Storage Installations (ISFSIs).* Simplifying the fission product barrier EAL threshold for a Site Area Emergency.

Subsequently, Revision 6 of NEI 99-01 has been issued which incorporates resolutions to numerous implementation issues including the NRC EAL Frequently Asked Questions (FAQs).Using NEI 99-01 Revision 6, "Methodology for the Development of Emergency Action Levels for Non-Passive Reactors," November 2012 (ADAMS Accession Number )VlL1 2326A805) (ref. Deleted:" ML110240324 4.1.1), CNS conducted an EAL implementation upgrade project that produced the EALs discussed herein.IRPIOIAI5000I100 Rev. 1 IPage 3 of 247

2.2 Fission

Product Barriers Fission product barrier thresholds represent threats to the defense in depth design concept that precludes the release of radioactive fission products to the environment.

This concept relies on multiple physical barriers, any one of which, if maintained intact, precludes the release of significant amounts of radioactive fission products to the environment.

Many of the EALs derived from the NEI methodology are fission product barrier threshold based. That is, the conditions that define the EALs are based upon thresholds that represent the loss or potential loss of one or more of the three fission product barriers. "Loss" and"Potential Loss" signify the relative damage and threat of damage to the barrier. A "Loss" threshold means the barrier no longer assures containment of radioactive materials.

A"Potential Loss" threshold implies an increased probability of barrier loss and decreased certainty of maintaining the barrier.The primary fission product barriers are: A. Fuel Clad (FC): The Fuel Clad Barrier consists of the cladding material that contains the fuel pellets.B. Reactor Coolant System (NCS): The NCS Barrier includes the NCS primary side and its connections up to and including the pressurizer safety and relief valves, and other connections up to and including the primary isolation valves.C. Containment (CMT): The Containment Barrier includes the containment building and connections up to and including the outermost containment isolation valves. This barrier also includes the main steam, feedwater, and blowdown line extensions outside the containment building up to and including the outermost secondary side isolation valve.Containment Barrier thresholds are used as criteria for escalation of the Emergency Classification Level (ECL) from Alert to a Site Area Emergency or a General Emergency 2.3 Fission Product Barrier Classification Criteria The following criteria are the bases for event classification related to fission product barrier loss or potential loss: Alert: Any loss or any potential loss of either Fuel Clad or NCS barrier Site Area Emergqency:

Loss or potential loss of any two barriers General Emergqency:

Loss of any two barriers and loss or potential loss of the third barrier R.P/0/15s000/100 Rev. 1 Page 4of 247 2.4 EAL Organization The CNS EAL scheme includes the following features:* Division of the EAL set into three broad 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 Defueled 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.

• Within each group, assignment of EALs to categories and subcategories:

Category and subcategory titles are selected to represent conditions that are operationally significant to the EAL-user.

The CNS EAL categories are aligned to and represent the NEI 99-01"Recognition Categories." Subcategories are used in the CNS scheme as necessary to further divide the EALs of a category into logical sets of possible emergency classification thresholds.

The CNS EAL categories and subcategories are listed below.IRPIO/A150001001 IRev. 1I Page 5 of 247 EAL Groups, Categories and Subcategories EAL Group/Category

_[EAL Subcategory Any Operatinga Mode: R -Abnormal Rad Levels / Rad Effluent 1 -Radiological Effluent 2 -Irradiated Fuel Event 3- Area Radiation Levels H -Hazards and Other Conditions 1 -Security Affecting Plant Safety 2 -Seismic Event 3 -Natural or Technological Hazard 4 -Fire 5 -Hazardous Gas 6 -Control Room Evacuation 7 -Emergency Coordinator Judgment E -Independent Spent Fuel Storage 1-CnieetBudr Installation (ISFSI) 1-CnieetBudr Hot Conditions:

S -System Malfunction 1 -Loss of Essential AC Power 2 -Loss of Vital DC Power 3 -Loss of Control Room Indications 4 -NCS Activity 5 -NCS Leakage 6 -RPS Failure 7 -Loss of Communications 8 -Containment Failure 9 -Hazardous Event Affecting Safety Systems F -Fission Product Barrier Degradation None Cold Conditions:

C -Cold Shutdown / Refueling System 1 -NCS Level Malfunction 2 -Loss of Essential AC Power 3 -NCS Temperature 4 -Loss of Vital DC Power 5 -Loss of Communications 6 -Hazardous Event Affecting Safety Systems The primary tool for determining the emergency classification level is the EAL Classification Matrix. The user of the EAL Classification Matrix may (but is not required to) consult the EAL Technical Bases Document in order to obtain additional information concerning the EALs under classification consideration.

The user should consult Section 3.0 and Attachments 1 & 2 of this document for such information.

2.5 Technical

Bases Information IRPIOIAI50001001 Rev. 1 Page 6 of 247 EAL technical bases are provided in Attachment 1 for each EAL according to EAL group (Any, Hot, Cold), EAL category (R, C, H, 5, F and E) and EAL subcategory.

A summary explanation of each category and subcategory is given at the beginning of the technical bases discussions of the EALs included in the category.

For each EAL, the following information is provided: Cateaqory Letter & Title Subcatecqory Number & Title Initiatingq Condition (IC)Site-specific description of the generic IC given in NEI 99-01 Rev. 6.EAL Identifier (enclosed in rectangqle)

Each EAL is assigned a unique identifier to support accurate communication of the emergency classification to onsite and offsite personnel.

Four characters define each EAL identifier:

1. First character (letter):

Corresponds to the EAL category as described above (R, C, H, S, F or E)2. Second character (letter):

The emergency classification (G, 5, A or U)G =General Emergency S = Site Area Emergency A = Alert U = Unusual Event 3. Third character (number):

Subcategory number within the given category.Subcategories are sequentially numbered beginning with the number one (1). If a category does not have a subcategory, this character is assigned the number one (1).4. Fourth character (number):

The numerical sequence of the EAL within the EAL subcategory.

If the subcategory has only one EAL, it is given the number one (1).Classification (enclosed in rectangqle):

Unusual Event (U), Alert (A), Site Area Emergency (5) or General Emergency (G)EAL (enclosed in rectangqle)

Exact wording of the EAL as it appears in the EAL Classification Matrix IRPIOIAI50001001 Rev. 1 Page 7 of 247 Mode Applicabilityi One or more of the following plant operating conditions comprise the mode to which each EAL is applicable:

1 -Power Operation, 2 -Startup, 3 -Hot Standby, 4 -Hot Shutdown, 5 -Cold Shutdown, 6 -Refueling, D -Defueled, or All. (See Section 2.6 for operating mode definitions)

Definitions:

If the EAL wording contains a defined term, the definition of the term is included in this section. These definitions can also be found in Section 5.1.Basis: A basis section that provides CNS-re!levant information concerning the EAL~ps well as a Dlte:Plant-Spcifc description of the rationale for the EAL as provided in NEI 99-01 Rev. 6. eee' hi sf~wdb[Generic basis section that provides CNS Basis Reference(s):

Site-specific source documentation from which the EAL is derived 2.6 Operating Mode Applicability (ref. 4.1.7)1 Power Operation Keff> 0.99 and reactor thermal power > 5%2 Startup_Keff > 0.99 and reactor thermal power < 5%3 Hot Standby Keff < 0.99 and average coolant temperature

> 350°F 3 Hot Shutdown Keff < 0.99 and average coolant temperature 350 0 F > Tavg > 200 0 F 4 Cold Shutdown Keff < 0.99 and average coolant temperature

< 200 0 F 5 Refuelinci One or more reactor vessel head closure bolts are less than fully tensioned o Defueled Reactor vessel contains no irradiated fuel The plant operating mode that exists at the time that the event occurs (prior to any protective system or operator action being initiated in response to the condition) should be compared to the mode applicability of the EALs. If a lower or higher plant operating mode is reached before the emergency classification is made, the declaration shall be based on the mode that existed at the time the event occurred.SRP/0/A/5000/001

[Rev. 1 Page 8 of 247

3.0 GUIDANCE

ON MAKING EMERGENCY CLASSIFICATIONS

3.1 General

Considerations When making an emergency classification, the Emergency Coordinator must consider all information having a bearing on the proper assessment of an Initiating Condition (IC). This includes the Emergency Action Level (EAL) plus the associated Operating Mode Applicability, Notes, and the informing basis information.

In the Recognition Category F matrices, EALs are based on loss or potential loss of Fission Product Barrier Thresholds.

3.1.1 Classification

Timeliness NRC regulations require the licensee to establish and maintain the capability to assess, classify, and declare an emergency condition within 15 minutes after the availability of indications to plant operators that an emergency action level has been exceeded and to promptly declare the emergency condition as soon as possible following identification of the appropriate emergency classification level. The NRC staff has provided guidance on implementing this requirement in NSIR/DPR-ISG-01, 'Interim Staff Guidance, Emergency Planning for Nuclear Power Plants" (ref. 4.1.12).3.1.2 Valid Indications All emergency classification assessments shall be based upon valid indications, reports or conditions.

A valid indication, report, or condition, is one that has been verified through appropriate means such that there is no doubt regarding the indicator's operability, the condition's existence, or the report's accuracy.

For example, verification could be accomplished through an instrument channel check, response on related or redundant indicators, or direct observation by plant personnel.

An indication, report, or condition is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment.

3.1.3 Imminent

Conditions For Its and EALs that have a stipulated time duration (e.g., 15 minutes, 30 minutes, etc.), the Emergency Coordinator should not wait until the applicable time has elapsed, but should declare the event as soon as it is determined that the condition has exceeded, or will likely exceed, the applicable time. If an ongoing radiological release is detected and the release start time is unknown, it should be assumed that the release duration specified in the IC/EAL has been exceeded, absent data to the contrary.3.1.4 Planned vs. Unplanned Events A planned work activity that results in an expected event or condition which meets or exceeds an EAL does not warrant an emergency declaration provided that: 1 ) the activity proceeds as planned, and 2) the plant remains within the limits imposed by the operating license. Such activities include planned work to test, manipulate, repair, maintain or modify a system or component.

In these cases, the controls associated With the planning, preparation and execution of the work Will ensure that compliance is maintained with all aspects of the operating license provided that the activity proceeds and concludes as expected.

Events or conditions of this type may be subject to the reporting requirements of 10 § CFR 50.72 (ref.4.1.4).IRPIOIA/50001001 Rev. 1 Page 9 of 247

3.1.5 Classification

Based on Analysis The assessment of some EALs is based on the results of analyses that are necessary to ascertain whether a specific EAL threshold has been exceeded (e.g., dose assessments, chemistry sampling, NCS leak rate calculation, etc.). For these EALs, the EAL wording or the associated basis discussion will identify the necessary analysis.

In these cases, the 15-minute declaration period starts with the availability of the analysis results that show the threshold to be exceeded (i.e., this is the time that the EAL information is first available).

The NRC expects licensees to establish the capability to initiate and complete EAL-related analyses within a reasonable period of time (e.g., maintain the necessary expertise on-shift).

3.1.6 Emergency

Coordinator Judgment While the EALs have been developed to address a full spectrum of possible events and conditions which may warrant emergency classification, a provision for classification based on operator/management experience and judgment is still necessary.

The NEI 99-01 EAL scheme provides the Emergency Coordinator with the ability to classify events and conditions based upon judgment using EALs that are consistent with the Emergency Classification Level (ECL) definitions (refer to Category H). The Emergency Coordinator will need to determine if the effects or consequences of the event or condition reasonably meet or exceed a particular ECL definition.

A similar provision is incorporated in the Fission Product Barrier Tables;judgment may be used to determine the status of a fission product barrier.3.2 Classification Methodology To make an emergency classification, the user will compare an event or condition (i.e., the relevant plant indications and reports) to an EAL(s) and determine if the EAL has been met or exceeded.

The evaluation of an EAL must be consistent with the related Operating Mode Applicability and~ Notes. If an EAL has been met or exceeded, the associated IC is likewise met, the emergency classification process "clock" starts, and the ECL must be declared in accordance with plant procedures no later than fifteen minutes after the process "clock" started.When assessing an EAL that specifies a time duration for the off-normal condition, the 'clock" for the EAL time duration runs concurrently with the emergency classification process "clock." For a full discussion of this timing requirement, refer to NSIR/DPR-ISG-01 (ref. 4.1.14).3.2.1 Classification of Multiple Events and Conditions When multiple emergency events or conditions are present, the user will identify all met or exceeded EALs. The highest applicable ECL identified during this review is declared.

For example:* If an Alert EAL and a Site Area Emergency EAL are met, whether at one unit or at two different units, a Site Area Emergency should be declared.There is no "additive" effect from multiple EALs meeting the same ECL. For example:* If two Alert EALs are met, whether at one unit or at two different units, an Alert should be declared.Related guidance concerning classification of rapidly escalating events or conditions is provided in Regulatory Issue Summary (RIS) 2007-02, Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events (ref. 4.1.2).3.2.2 Consideration of Mode Changes During Classification IRP/O/N50001001 Rev. 1 Page 10 of 247I The mode in effect at the time that an event or condition occurred, and prior to any plant or operator response, is the mode that determines whether or not an IC is applicable.

If an event or condition occurs, and results in a mode change before the emergency is declared, the emergency classification level is still based on the mode that existed at the time that the event or condition was initiated (and not when it was declared).

Once a different mode is reached, any new event or condition, not related to the original event or condition, requiring emergency classification should be evaluated against the ICs and EALs applicable to the operating mode at the time of the new event or condition.

For events that occur in Cold Shutdown or Refueling, escalation is via EALs that are applicable in the Cold Shutdown or Refueling modes, even if Hot Shutdown (or a higher mode) is entered during the subsequent plant response.

In particular, the fission product barrier EALs are applicable only to events that initiate in the Hot Shutdown mode or higher.3.2.3 Classification of Imminent Conditions Although EALs provide specific thresholds, the Emergency Coordinator must remain alert to events or conditions that could lead to meeting or exceeding an EAL within a relatively short period of time (i.e., a change in the ECL is IMMINENT).

If, in the judgment of the Emergency Coordinator, meeting an EAL is IMMINENT, the emergency classification should be made as if the EAL has been met. While applicable to all emergency classification levels, this approach is particularly important at the higher emergency classification levels since it provides additional time for implementation of protective measures.3.2.4 Emergency Classification Level Upgrading and Downgrading An ECL may be downgraded when the event or condition that meets the highest IC and EAL no longer exists, and other site-specific downgrading requirements are met. If downgrading the ECL is deemed appropriate, the new ECL would then be based on a lower applicable IC(s)and EAL(s). The ECL may also simply be terminated.

As noted above, guidance concerning classification of rapidly escalating events or conditions is provided in RIS 2007-02 (ref. 4.1.2).3.2.5 Classification of Short-Lived Events Event-based ICs and EALs define a variety of specific occurrences that have potential or actual safety significance.

By their nature, some of these events may be short-lived and, thus, over before the emergency classification assessment can be completed.

If an event occurs that meets or exceeds an EAL, the associated ECL must be declared regardless of its continued presence at the time of declaration.

Examples of such events include an earthquake or a failure of the reactor protection system to automatically trip the reactor followed by a successful manual trip.3.2.6 Classification of Transient Conditions Many of the ICs and/or EALs employ time-based criteria.

These criteria will require that the IC/EAL conditions be present for a defined period of time before an emergency declaration is warranted.

In cases where no time-based criterion is specified, it is recognized that some transient conditions may cause an EAL to be met for a brief period of time (e.g., a few seconds to a few minutes).

The following guidance should be applied to the classification of these conditions.

EAL momentarily met duringq expected plant response -In instances where an EAL is briefly met during an expected (normal) plant response, an emergency declaration is not warranted RP0/1I0/01Rev.

1 IPage 11 of 247I provided that associated systems and components are operating as expected, and operator actions are performed in accordance with procedures.

EAL momentarily met but the condition is corrected prior to an emercqency declaration

-If an operator takes prompt manual action to address a condition, and the action is successful in correcting the condition prior to the emergency declaration, then the applicable EAL is not considered met and the associated emergency declaration is not required.

For illustrative purposes, consider the following example: An ATWS occurs and the high pressure ECCS systems fail to automatically start. RPV level rapidly decreases and the plant enters an inadequate core cooling condition (a potential loss of both the fuel clad and NCS barriers).

If an operator manually starts a high pressure EGGS system in accordance with an EOP step and clears the inadequate core cooling condition prior to an emergency declaration, then the classification should be based on the ATWS only.It is important to stress that the 15-minute emergency classification assessment period (process clock) is not a "grace period" during which a classification may be delayed to allow the performance of a corrective action that would obviate the need to classify the event.Emergency classification assessments must be deliberate and timely, with no undue delays.The provision discussed above addresses only those rapidly evolving situations when an operator is able to take a successful corrective action prior to the Emergency Coordinator completing the review and steps necessary to make the emergency declaration.

This provision is included to ensure that any public protective actions resulting from the emergency classification are truly warranted by the plant conditions.

3.2.7 After-the-Fact Discovery of an Emergency Event or Condition In some cases, an EAL may be met but the emergency classification was not made at the time of the event or condition.

This situation can occur when personnel discover that an event or condition existed which met an EAL, but no emergency was declared, and the event or condition no longer exists at the time of discovery.

This may be due to the event or condition not being recognized at the time or an error that was made in the emergency classification process.In these cases, no emergency declaration is warranted; however, the guidance contained in NUREG-1 022 (ref. 4.1.3) is applicable.

Specifically, the event should be reported to the NRC in accordance with 10 CFR § 50.72 (ref. 4.1.4) within one hour of the discovery of the undeclared event or condition.

The licensee should also notify appropriate State and local agencies in accordance with the agreed upon arrangements.

3.2.8 Retraction

of an Emergency Declaration Guidance on the retraction of an emergency declaration reported to the NRC is discussed in NUREG-1022 (ref. 4.1.3).JRP/O/AI5000/O01 JRev. 1 Page 12 of 247

4.0 REFERENCES

4.1 Developmental

4.1.1 NEI 99-01 Revision 6, Methodology for the Development of Emergency Action Levels for Non-Passive Reactors, ADAMS Accession NumberMlL12326A805_

4.1.2 RIS 2007-02 Clarification of NRC Guidance for Emergency Notifications During Quickly Changing Events, February 2, 2007.4.1.3 NUREG-1022 Event Reporting Guidelines:

10CFR50.72 and 50.73 4.1.4 10 § CFR 50.72 Immediate Notification Requirements for Operating Nuclear Power Reactors 4.1.5 10 § CFR 50.73 License Event Report System 4.1.6 CNS-SLC-16.11-16 Figure 16.11-16-1 Unrestricted Area and Site Boundary for Radioactive Effluents 4.1.7 CNS UFSAR Figure 1-20 Plot Plan 4.1.8 Technical Specifications Table 1.1-1 Modes 4.1.9 OP/0/A/6100/014 Penetration Control for Modes 5, 6 and NO Mode -Enclosure 4.7 Setting, Maintaining and Securing from Containment Penetration Control 4.1.10 PRO-NGGC-0201 NGG Procedure Writers Guide 4.1.11 NSIRIDPR-ISG-01 Interim Staff Guidance, Emergency Planning for Nuclear Power Plants 4.1.12 CNS ISFSI Certificates of Compliance 4.1.13 CNS Emergency Plan 4.2 Implementing 4.2.1 RP/0/AN5000/001 Classification of Emergency 4.2.2 NEI 99-01 Rev. 6 to CNS EAL Comparison Matrix 4.2.3 CNS EAL MatrixDeleed:ML1 10240324 IRPIOIA150001001 Rev. 1 1Page 13 of 247 5.0 DEFINITIONS, ACRONYMS & ABBREVIATIONS

5.1 Definitions

(ref. 4.1.1 except as noted)Selected terms used in Initiating Condition and Emergency Action Level statements are set in all capital letters (e.g., ALL CAPS). These words are defined terms that have specific meanings as used in this document.

The definitions of these terms are provided below.Alert Events are in progress, or have occurred, which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of hostile action. Any releases are expected to be small fractions of the EPA Protective Action Guideline exposure levels.Confinement Boundary The barrier(s) between spent fuel and the environment once the spent fuel is processed for dry storage. As related to the CNS ISFSI, Confinement Boundary is defined as the Transportable Storage Canister (TSC) for both NAC-UMS and MAGNASTAR storage systems.Containment Closure The procedurally defined actions taken to secure containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions.

As applied to CNS, Containment Closure is established when the requirements of OP/O/A/6100/014 Penetration Control for Modes 5, 6 and NO Mode -Enclosure 4.7 Setting, Maintaining and Securing from Containment Penetration Control are met (ref. 4.1.9).Emergency Action Level (EAL)A pre-determined, site-specific, observable threshold for an Initiating Condition that, when met or exceeded, places the plant in a given emergency classification level.Emergency Classification Level (ECL)One of a set of names or titles established by the US Nuclear Regulatory Commission (NRC)for grouping off-normal events or conditions according to (1) potential or actual effects or consequences, and (2) resulting onsite and offsite response actions. The emergency classification levels, in ascending order of severity, are:* Unusual Event (UE)* Alert* Site Area Emergency (SAE)* General Emergency (GE)EPA PAGs Environmental Protection Agency Protective Action Guidelines.

The EPA PAGs are expressed in terms of dose commitment:

1 Remn TEDE or 5 Remn CDE Thyroid. Actual or projected offsite exposures in excess of the EPA PAGs requires CNS to recommend protective actions for the general public to offsite planning agencies.Explosion IRP/O/N50001001 Rev. 1 Page 14 of 247 A rapid, violent and catastrophic failure of a piece of equipment due to combustion, chemical reaction or overpressurization.

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

Such events require a post-event inspection to determine if the attributes of an explosion are present.Faulted The term applied to a steam generator that has a steam leak on the secondary side of sufficient size to cause an uncontrolled drop in steam generator pressure or the steam generator to become completely depressurized.

Fission Product Barrier Threshold A pre-determined, site-specific, observable threshold indicating the loss or potential loss of a fission product barrier.Fire Combustion characterized by heat and light. Sources of smoke such as slipping drive belts or overheated electrical equipment do not constitute fires. Observation of flame is preferred but is NOT required if large quantities of smoke and heat are observed.Flooding A condition where water is entering a room or area faster than installed equipment is capable of removal, resulting in a rise of water level within the room or area.General Emergency Events are in progress or have occurred which involve actual or imminent substantial core degradation or melting with potential for loss of containment integrity or hostile actions that result in an actual loss of physical control of the facility.

Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.Hostage A person(s) held as leverage against the station to ensure that demands will be met by the station.Hostile Action An act toward CNS or its personnel that includes the use of violent force to destroy equipment, take hostages, and/or intimidate the licensee to achieve an end. This includes attack by air, land, or water using guns, explosives, projectiles, vehicles, or other devices used to deliver destructive force. Other acts that satisfy the overall intent may be included.

Hostile action should not be construed to include acts of civil disobedience or felonious acts that are not part of a concerted attack on CNS. Non-terrorism-based EALs should be used to address such activities (i.e., this may include violent acts between individuals in the owner controlled area).Hostile Force One or more individuals who are engaged in a determined assault, overtly or by stealth and deception, equipped with suitable weapons capable of killing, maiming, or causing destruction.

Imminent The trajectory of events or conditions is such that an EAL will be met within a relatively short period of time regardless of mitigation or corrective actions.Impede(d)Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

Intrusion The act of entering without authorization.

Discovery of a bomb in a specified area is indication of intrusion into that area by a hostile force.Independent Spent Fuel Storage Installation (ISFSI)A complex that is designed and constructed for the interim storage of spent nuclear fuel and other radioactive materials associated with spent fuel storage.Initiating Condition (IC)An event or condition that aligns with the definition of one of the four emergency classification levels by virtue of the potential or actual effects or consequences.

Maintain Take appropriate action to hold the value of an identified parameter within specified limits.R.P/01A1000/00 1 IRev. 1 Page 16 of 247 Normal Levels As applied to radiological IC/EALs, the highest reading in the past twenty-four hours excluding the current peak value.Owner Controlled Area Area outside the PROTECTED AREA fence that immediately surrounds the plant. Access to this area is generally restricted to those entering on official business. (ref. 4.1.13).Projectile An object directed toward a Nuclear Power Plant that could cause concern for its continued operability, reliability, or personnel safety.Protected Area An area encompassed by physical barriers and to which access is controlled.

The Protected Area refers to the designated security area around the process buildings and is depicted in CNS UFSAR Figure 1-20 Plot Plan (ref. 4.1.7).NCS Intact The NCS should be considered intact when the NCS pressure boundary is in its normal condition for the cold shutdown mode of operation (e.g., no freeze seals or nozzle dams).Refueling Pathway The reactor refueling cavity, spent fuel pool and fuel transfer canal comprise the refueling pathway.Ruptured The condition of a steam generator in which primary-to-secondary leakage is of sufficient magnitude to require a safety injection.

Restore Take the appropriate action required to return the value of an identified parameter to the applicable limits Safety System A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the EGGS. These are typically systems classified as safety-related (as defined in 10CFR50.2):

Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure: (1) The integrity of the reactor coolant pressure boundary;(2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures.

Security Condition Any security event as listed in the approved security contingency plan that constitutes a threat/compromise to site security, threat/risk to site personnel, or a potential degradation to the level of safety of the plant. A security condition does not involve a hostile action.

Site Area Emergency Events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; 1 ) toward site personnel or equipment that could lead to the likely failure of or; 2) that prevent effective access to, equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA PAG exposure levels beyond the SITE BOUNDARY.Site Boundary Area as depicted in CNS-SLC-16.1 1-16 Figure 16.1 1-16-1 Unrestricted Area and Site Boundary for Radioactive Effluents (ref. 4.1.6).Unisolable An open or breached system line that cannot be isolated, remotely or locally.Unplanned A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient.

The cause of the parameter change or event may be known or unknown.Unusual Event Events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated.

No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of SAFETY SYSTEMS occurs.Valid An indication, report, or condition, is considered to be valid when it is verified by (1) an instrument channel check, or (2) indications on related or redundant indicators, or (3) by direct observation by plant personnel, such that doubt related to the indicator's operability, the condition's existence, or the report's accuracy is removed. Implicit in this definition is the need for timely assessment.

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

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

IRP/O/AI5000/O001 Rev. 1 Page 18 of 247I 5.2 Abbreviations/Acronyms 0 F...........................................................................

Degrees Fahrenheit

°.....................................................................................

Degrees AC...........................................................................

Alternating Current AP.............................................................

Abnormal Operating Procedure ATWS...................................................

Anticipated Transient Without Scram CA..........................................................................

Auxiliary Feedwater CNS..................................................................

Catawba Nuclear Station CDE...............................................................

Committed Dose Equivalent CFR ......................................................

Code of Federal Regulations CSFST ...................................................

Critical Safety Function Status Tree DBA.....................................................................

Design Basis Accident DC ................................................................................

Direct Current EAL ...................................................................

Emergency Action Level ECCS.......................................................

Emergency Core Cooling System EC.....................................................................

Emergency Coordinator ECL...........................................................

Emergency Classification Level EOF ...........................................................

Emergency Operations Facility FOP .........................................................

Emergency Operating Procedure EPA.........................................................

Environmental Protection Agency ERG..........................................................

Emergency Response Guideline EPIP ..............................................

Emergency Plan Implementing Procedure ESFE................................................................

Engineered Safety Feature FAA ...........................................................

Federal Aviation Administration FBI ............................................................

Federal Bureau of Investigation FEMA..............................................

Federal Emergency Management Agency FSAR.............................................................

Final Safety Analysis Report GE .........................................................................

General Emergency IC ............................................................................

Initiating Condition IPEEE.............

Individual Plant Examination of External Events (Generic Letter 88-20)ISFSI ...........................................

Independent Spent Fuel Storage Installation Keff.....................................................

Effective Neutron Multiplication Factor LCO ...........................................................

Limiting Condition of Operation LER.....................................................................

Licensee Event Report LOCA ................................................................

Loss of Coolant Accident LWR........................................................................

Light Water Reactor MPC.....................................................................

Multi-Purpose Canister MSIV...............................................................

Main Steam Isolation Valve MSL ...........................................................................

Main Steam Line mR, mRem, mrem, mREM..................................

milli-Roentgen Equivalent Man SRP/0/A/5000/001 Rev. 1 Page 19 of 247 MW ....................................................................................

Megawatt NCS...................................................................

Reactor Coolant System NEI ....................................................................

Nuclear Energy Institute NESP.................................................

National Environmental Studies Project NPP .......................................................................

Nuclear Power Plant NRC..........................................................

Nuclear Regulatory Commission NSSS ..........................................................

Nuclear Steam Supply System NORAD .....................................

North American Aerospace Defense Command (NO)UE ..........................................................

Notification of Unusual Event OBE ..............................................................

Operating Basis Earthquake OCA.....................................................................

Owner Controlled Area ODCM .......................................................

Off-site Dose Calculation Manual OR0 ..........................................................

Offsite Response Organization PA................................................................................

Protected Area PAG................................................................

Protective Action Guideline PRAIPSA................

Probabilistic Risk Assessment

/ Probabilistic Safety Assessment PWR ...............................................................

Pressurized Water Reactor PSIG..........................................................

Pounds per Square Inch Gauge R .......................................................................................

Roentgen Rem, rem, REM....................................................

Roentgen Equivalent Man RPS................................................................

Reactor Protection System RV...............................................................................

Reactor Vessel RVLIS ...............................................

Reactor Vessel Level Indicating System SAR.....................................................................

Safety Analysis Report SBGTS .....................................................

Stand-By Gas Treatment System SBO ............................................................................

Station Blackout SCBA....................................................

Self-Contained Breathing Apparatus SG ............................................................................

Steam Generator SI................................................................................

Safety Injection SLC ..........................................................

Selected Licensee Commitment SPDS ......................................................

Safety Parameter Display System SRO...................................................................

Senior Reactor Operator SSF .....................................................................

Safe Shutdown Facility TEDE .........................................................

Total Effective Dose Equivalent TOAF ........................................................................

Top of Active Fuel TSC .................................................................

Technical Support Center WOG ............................................................

Westinghouse Owners Group SRP/0/A/5000/001 Rev. 1 Page 20 of 247 6.0 CNS-TO-NEI 99-01 Rev. 6 EAL CROSS-REFERENCE This cross-reference is provided to facilitate association and location of a CNS EAL within the NEI 99-01 IC/EAL identification scheme. Further information regarding the development of the CNS EALs based on the NEI guidance can be found in the EAL Comparison Matrix.CNS NEI 99-01 Rev. 6 EAL IC Example EAL RU1.1 AU1 1, 2 RU1.2 AU1 3 RU2.1 AU2 1 RA1.1 AAI 1 RA1.2 AA1 2 RA1.3 AAI 3 RA1.4 AA1 4 RA2.1 AA2 I RA2.2 AA2 2 RA2.3 AA2 3 RA3.1 AA3 I RA3.2 AA3 2 RSI.1 ASI I RS1.2 AS1 2 RS1.3 AS1 3 RS2.1 AS2 I RG1.1 AGI 1 RGI.2 AGi 2 RG1.3 AGI 3 RG2.1 AG2 1 SRP/0/A/5000/001 Rev. I Page 21 of 247I CNS NEI 99-01 Rev. 6 EAL IC Example EAL CU1.1 CU1 1 CU1.2 CU1 2 CU2.1 CU2 1 CU3.1 CU3 1 CU3.2 CU3 2 CU4.1 CU4 1 CU5.1 CU5 1, 2, 3 CAI.1 CA1 1 CAI.2 CA1 2 CA2.1 CA2 1 CA3.1 CA3 1, 2 CA6.1 CA61 CS1.1 CS1 3 CG1.1 CGi 2 FAI.1 FA1 1 FS1.1 FSI I FGI.1 FG1 1 HU1.1 HUl 1,2 3 HU2.1 HU2 1 HU3.1 HU3 1 HU3,2 HU3 2 HU3,3 HU3 3 HU3.4 HU3 4 HU4.1 HU4 1 HU4.2 HU4 2= " i , i , i ,,' {I.!t IRPIoIAIooo0ooOQ1 Rev. 1 Page 22 of 2471 CNS NEI 99-01 Rev. 6 EAL IC Example EAL ICEAL HU4.3 HU4 3 HU4.4 HU4 4 HU7.1 HU7 1 HA1.1 HA1 1, 2 HA5.1 HA5 1 HA6.1 HA6 1 HA7.1 HA7 1 HS1.1 HSl 1 HS6.1 HS6 1 HS7.1 HS7 1 HG1.1 HG1 1 HG7.1 HG7 1 SU1.1 SU1 1 SU3.1 SU2 I SU4.1 SU3 1 SU4.2 SU3 2 SU5.1 SU4 1, 2, 3 SU6.1 SU5 1 SU6.2 SU5 2 SU7.1 SU6 1,2, 3 SU8.1 SU7 1,2 SA1.1 SA1 1 SA3.1 SA2 1 SA6.1 SA5 1 SA9.1 SA9 1 iv,¸SRP/0/A/5000/001 Rev. 1 Page 23 of 247 CNS NEI 99-01 Rev. 6 EAL IC Example EAL SS1.1 SS1 1 SS2.1 SS8 1 SS6.1 SS5 1 SG1.1 SG1 1 SG1.2 SG8 I EU1I. E-HUi 1 SRP/oA15ooo/ool IRev. 1 IPage 24 of 2471

7.0 ATTACHMENTS

7.1 7.2 Attachment 1, Emergency Action Level Technical Bases Attachment 2, Fission Product Barrier Matrix and Basis:- -o ..i l[SRP/0/A/5000/001 Rev. 1 Page 25 of 247I ATTACHMENT 1 EAL Bases Category R -Abnormal Rad Release / Rad Effluent EAL Group: ANY (EALs in this category are applicable to any plant condition, hot or cold.)Many EALs are based on actual or potential degradation of fission product barriers because of the elevated potential for offsite radioactivity release. Degradation of fission product barriers though is not always apparent via non-radiological symptoms.

Therefore, direct indication of elevated radiological effluents or area radiation levels are appropriate symptoms for emergency classification.

At lower levels, abnormal radioactivity releases may be indicative of a failure of containment systems or precursors to more significant releases.

At higher release rates, offsite radiological conditions may result which require offsite protective actions. Elevated area radiation levels in plant may also be indicative of the failure of containment systems or preclude access to plant vital equipment necessary to ensure plant safety.Events of this category pertain to the following subcategories:

1. Radiologqical Effluent Direct indication of effluent radiation monitoring systems provides a rapid assessment mechanism to determine releases in excess of classifiable limits. Projected offsite doses, actual offsite field measurements or measured release rates via sampling indicate doses or dose rates above classifiable limits.2. Irradiated Fuel Event Conditions indicative of a loss of adequate shielding or damage to irradiated fuel may preclude access to vital plant areas or result in radiological releases that warrant emergency classification.

3. Area Radiation Levels Sustained general area radiation levels which may preclude access to areas requiring continuous occupancy also warrant emergency classification.

SRP/0I/ 5000/001 Rev. 1 Page 26 of 2471 ATTACHMENT 1 EAL Bases Category:

R -Abnormal Rad Levels I Rad Effluent Subcategory:

1 -Radiological Effluent Initiating Condition:

Release of gaseous or liquid radioactivity

> 2 times the SLC/TS limits for 60 minutes or longer EAL: RUI.1 Unusual Event 'Reading on any Table R-1 effluent radiation monitor > column "UE" for ->60 mmn...(Notes 1, 2, 3)Note 1: The Emergency Coordinator 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.Table R-I Effluent Monitor Classification Thresholds Release Point Monitor J GE [ SAE [ Alert I UEUnit Vent Noble Gas Low 1/2EMF36L

.....4.1 8E+6 cpm 5.75E+3 cprn wUnit Vent Noble Gas High 1/2EMF36H 2.21 E+4 cpm 2.22E+3 cpm 2.42E+2 cpm ...~Liquid Waste Effluent Line 0EMF49L ....... 4.50E+6 cpm'Monitor Tank Discharge 0EMF57L ....... 4.97E+5 cpm Mode Applicability:

All Definition(s):

None Basis: The column "UE" gaseous and liquid release values in Table R-1 represent two times the appropriate SLC and Technical Specification release rate and concentration limits associated with the specified monitors (ref. 2, 3, 4, 7).,I¸ SRP/0/A/5000/001 Rev. 1 Page 27 of 247I ATTACHMENT 1 EAL Bases Gaseous Releases Instrumentation that may be used to assess this EAL is listed below (ref. 1, 5):* Unit Vent Noble Gas Low Range -1/2EMF36L has a range of 101 -10 7 cpm Liquid Releases Instrumentation that may be used to assess this EAL is listed below (ref. 1, 6):° Liquid Waste Effluent Line Monitor -0EMF49L (batch release) has a range of 101 -I107 cpm° Monitor Tank Discharge Monitor -OEM F57L has a range of 101 -1 0z cpm This IC addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release).

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

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

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

Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.Releases should not be prorated or averaged.

For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.This EAL addresses normally occurring continuous radioactivity releases from monitored gaseous or liquid effluent pathways.Escalation of the emergency classification level would be via IC RAl.CNS Basis Reference(s):

1. CNS ODOM Section 3.0 Setpoint Calculations

2. CNS-SLC 16.11-1 Liquid Effluents 3. CNS-SLC 16.11-6 Gaseous Effluents 4. EP-EALCALC-CNS-1401 CNS Radiological Effluent EAL Values, Rev. 0 5. UFSAR Table 11-20 Airborne Process Radiation Monitoring Equipment 6. UFSAR Table 11-19 Liquid Process Radiation Monitoring Equipment 7. Technical Specifications Section 5.5.5 Radioactive Effluent Controls Program IRPI0/A/5000/001 Rev. 1 Page 28 of 247 ATTACHMENT 1 EAL Bases 8. NEI 99-01 AU1 1 i[t}: .....t i " i"[{! i ;i[ , i,[,! , ,[ ",: *i ', o:,* ? .... ,,o ;RP/0/A15000/001 Rev. I Page 29 of 247 ATTACHMENT 1 , ... .EAL Bases ..Category:

R -Abnormal Rad Levels!/ Rad Effluent Subcategory:

1 -Radiological Effluent Initiating Condition:

Release of gaseous or liquid radioactivity greater than 2 times the SLC/TC limits for 60 minutes or longer.EAL: RU1.2 Unusual Event Sample analysis for a gaseous or liquid release indicates a concentration or release rate> 2 x SLC/TO limits for -> 60 min. (Notes 1, 2)Note 1: The Emergency Coordinator 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.Mode Applicability:

All Definition(s):

None Basis: This IC addresses a potential decrease in the level of safety of the plant as indicated by a low-level radiological release that exceeds regulatory commitments for an extended period of time (e.g., an uncontrolled release).

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

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

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

Releases should not be prorated or averaged.

For example, a release exceeding 4 times release limits for 30 minutes does not meet the EAL.This EAL addresses uncontrolled gaseous or liquid releases that are detected by sample analyses or environmental surveys, particularly on unmonitored pathways (e.g., spills of radioactive liquids into storm drains, heat exchanger leakage in river water systems, etc.).Escalation of the emergency classification level would be via IC RAl.IRP/o/A/5000/001 Rev. I Page 30 of 2471 ATTACHMENT I EAL Bases CNS Basis Reference(s):

1. CNS Offsite Dose Calculation Manual 2. CNS-SLC 16.11-1 Liquid Effluents 3. CNS-SLC 16.11-6 Gaseous Effluents 4. Technical Specifications Section 5.5.5 Radioactive Effluent Controls Program 5. AD-RP-ALL-2003 Investigation of Unusual Radiological Occurences

6. NEI 99-01 AU1 t, t _}=: ..... , :, ,,-,,.- ,'A IRP/0/A/5000/001 Rev. 1 Page 31 of 247I ATTACHMENT 1 EAL Bases Category:

R -Abnormal Rad Levels I Rad Effluent Subcategory:

1 -Radiological Effluent Initiating Condition:

Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE , EAL: RA1.1 Alert Reading on any Table R-1 effluent radiation monitor > column "ALERT" for > 15 min.(Notes 1, 2, 3,4), Note 1: The Emergency Coordinator 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 l 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 RAI .1, RS1I.1 and RG1I.1 should be used for emergency classification assessments until the results from a dose assessment using actual ..meteorology are available.

Table R-1 Effluent Monitor Classification Thresholds Release Point [Monitor GE SAE [ Alert ] UE SUnit Vent Noble Gas Low 1/2EMF36L

.....4.18E+6 cpm 5.75E+3 cpm C oUnit Vent Noble Gas High 1/2EMF36H 2.21 E+4 cpm 2.22E+3 cpm 2.42E+2 cpm ..-o Liquid Waste Effluent Line 0EMF4gL .........4.50E+6 cpm" Monitor Tank Discharge 0EMF57L .........4.97E+'5 cpm Mode Applicability:

All IRP/0/A/5000/001 Rev. 1I Page 32 of 247 ATTACHMENT 1 EAL Bases Definition(s):

None Basis: This EAL address gaseous radioactivity releases, that for whatever reason, cause effluent radiation monitor readings corresponding to site boundary doses that exceed either:* 10 mRemTEDE* 50 mRem ODE Thyroid The column "ALERT" gaseous effluent release values in Table R-1 correspond to calculated doses of 1% (10% of the SAE thresholds) of the EPA Protective Action Guidelines (TEDE or ODE Thyroid) (ref. 3, 4).Instrumentation that may be used to assess this EAL is listed below (ref. 1, 2):* Unit Vent Noble Gas High Range -EMF36H has a range of 101 -106 cpm This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases.

Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid ODE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid ODE.Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.Escalation of the emergency classification level would be via IC RSI.SRP/OIA/50001001 IRev. 1 Page 33 of 247 ATTACHMENT 1 i,;.:; ' :- : : EAL Bases i .... o _CNS Basis Reference(s):

1. CNS ODCM Section 3.0 Setpoint Calculations

2. UFSAR Table 11-20 Airborne Process Radiation Monitoring Equipment 3. EP-EALCALC-CNS-1401 CNS Radiological Effluent EAL Values, Rev. 0 4. SDQA-70400-COM Unified RASCAL Interface (URI)5. NEI 99-01 AA1 1, i" 5 'i-1 4[RP/0/AJ5000/001 1Rev. 1 Page 34 of 2471 Category: Subcategory:

Initiating Condition:

ATTACHMENT 1 EAL Bases R -Abnormal Rad Levels / Rad Effluent I -Radiological Effluent Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid ODE EAL: RA1.2 Alert Dose assessment using actual meteorology indicates doses > 10 mrem TEDE or 50 mrem thyroid ODE at or beyond the SITE BOUNDARY (Note,44)*Note 4: The pre-calculated effluent monitor values presented in EALs RAI .1, RSl .1 and RGI .1 should be used I for emergency classification assessments until the results from a dose assessment using actual meteorology are available.

Mode Applicability:

All Deleted:......, _Deleted: Note 3: If the effluent" 1 flow past an effluent monitor isl known to have stopped, indicating that the release path is isolated, the.] effluent monitor reading is no Ionge", L VALID for classification purposes.¶ Definition(s):

SITE BOUNDARY -Area as depicted in CNS-SLC-1 6.11-16 Figure 16.11-16-1 Unrestricted Area and Site Boundary for Radioactive Effluents.

Basis: Dose assessments are performed by computer-based methods (ref. 1, 2)This IC addresses a release of-gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases.

Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions.

SRP/0/A/5000/001 Rev. I Page 35 of 247 t ATTACHMENT 1 EAL Bases The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid ODE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid ODE.Classification based on effluent monitor readings assumes that a release path to the environment is established.

If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.Escalation of the emergency classification level would be via IC RS1.CNS Basis Reference(s):

1. HP/0/B/1 009/026 On-Shift Offsite Dose Assessment

2. AD-EP-ALL-0202, Emergency Response Offsite Dose Assessment

3. NEI 99-01 AA1{}, i"i}* [SRP/0/A1o000/001 Rev. I Page 36 of 2471 ATTACHMENT 1 EAL Bases R -Abnormal Rad Levels / Rad Effluent 1 -Radiological Effluent Category: Subcategory:

Initiating Condition: Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL: RA1 .3 Alert Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses > 10 mrem TEDE or 50 mrem thyroid CDE at or beyond the SITE BOUNDARY for 60 min. of exposure (Notes 1, 2)Note 1: The Emergency Coordinator 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.Mode Applicability: All Definition(s): SITE BOUNDARY-Area as depicted in CNS-SLC-16.11-16 Figure 16.11-16-1 Unrestricted Area and Site Boundary for Radioactive Effluents. Basis: Dose assessments based on liquid releases are performed per Offsite Dose Calculation Manual (ref. 1).This ,EAL addresses a release ofjliquid radio._ac_ tivity that results in projected or actual offsite.... doses greater than or equal to 1% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions. The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.,Escalation of the emergency cla~ssification level would be via IC RS1. .. .CNS Basis Reference(s):

1. CNS Offsite Dose Calculation Manual 2. NEI 99-01 MA1ed:I-tDlee:gaeu or efletmntrreadings assumes tha" a release path to the environment is established.

If the effluent flow past an effluent monitor Is known to have stopped due to actions to isolate the reading is no longer valid for tclassifiation p r e ...... ..... ........ ATTACHMENT 1 EAL Bases Category: R -Abnormal Rad Levels / Rad Effluent Subcategory: 1 -Radiological Effluent Initiating Condition: Reiease of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE EAL: RA1.4 Alert 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 mmi. of inhalation.(Notes 1, 2)Note 1: The Emergency Coordinator 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.Mode Applicability: All Definition(s): SITE BOUNDARY-Area as depicted in CNS-SLC-16.11-16 Figure 16.11-16-1 Unrestricted Area and Site Boundary for Radioactive Effluents. Basis: HP/0/B/1 009/004, Environmental Monitoring for Emergency Conditions Within the Ten Mile Radius of CNS provides guidance for emergency or post-accident radiological environmental monitoring (ref. 1).This IC addresses a release of gaseous or liquid radioactivity that results in projected or actual offsite doses greater than or equal to 1 % of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude represent an actual or potential substantial degradation of the level of safety of the plant as indicated by a radiological release that significantly exceeds regulatory limits (e.g., a significant uncontrolled release).Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions. The TEDE dose is set at 1% of the EPA PAG of 1,000 mrem while the 50 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid ODE.Iation of the emergency classification level would be via IC RS!................... IRP/0/A15000/001 IRev. 1 IPage 38 of 247 7.//1.'(I Deleted: Classirication based on effluent monitor readings assumes tha a release path to the environment is established, If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.¶f ATTACHMENT 1 EAL Bases CNS Basis Reference(s):

1. HPIOIBI1I009/004 Environmental Monitoring for Emergency Conditions Within the Ten Mile Radius of CNS 2. NEI 99-01 AA1{i}SRP/o/A15ooo/oo01 Rev. I Page 39of2471 Category: Subcategory:

Initiating Condition: ATTACHMENT 1 EAL Bases R -Abnormal Rad Levels / Rad Effluent I -Radiological Effluent Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid ODE EAL: RSI.1 Site Area Emergency Reading on any Table R-1 effluent radiation monitor > column "SAE" for > 15 min.(Notes 1, 2, 3,4)Note 1: The Emergency Coordinator 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 RAI .1, RSI .1 and RGI .1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available. Table R-1 Effluent Monitor Classification Thresholds K- Release Point IMonitor [ GE I SAE I Alert [ UE SUnit Vent Noble Gas Low 1/2EMF36L ........- 4.18E+6 cpm 5.75E+3 cpm cn Unit Vent Noble Gas High 1/2EMF36H 2.21 E+4 cpm 2.22E+3 cpm 2.42E+2 cpm ...'9 Liquid Waste Effluent Line OEMF49L .........4.50E+6 cpm SMonitor Tank Discharge 0EMF57L ..........-- 4.97E+5 cpm Mode Applicability: All Definition(s): None IRP/O/A/5000/O01 Rev. 1I Page 40 of 247 ATTACHMENT 1 EAL Bases Basis: This EAL address gaseous radioactivity releases, that for whatever reason, cause effluent radiation monitor readings corresponding to site boundary doses that exceed either:* 100 mRemTEDE* 500 mRem ODE Thyroid The column "SAE" gaseous effluent release value in Table R,-1 corresponds to calculated doses of 10% of the EPA Protective Action Guidelines (TEDE or ODE Thyroid) (ref. 1, 2).Instrumentation that may be used to assess this EAL is Unit Vent Noble Gas High Range-Monitor -EMF36H and has a range of 101 -106 cpm (ref 3, 4).This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public.Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions. The TEDE dose is set at 10% of the EPA PAG of 1,000 mrem while the 500 mrem thyroid ODE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid ODE.Classification based .on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.Escalation of the emergency classification level would be via IC RGI.CNS Basis Reference(s):

1. EP-EALCALC-CNS-1401 CNS R~adiological Effluent EAL Values, R~ev. 0 2. SDQA-70400-COM Unified RASCAL Interface (URI)3. ONS ODOM Section 3.0 Setpoint Calculations

4. UFSAR, Table 11-20 Airborne Process Radiation Monitoring Equipment 5. NEI 99-01 AS1 RP/PIOA/50001001 R Pev. 1 Page 41 of 247I ATTACHMENT 1 i EAL Bases ..... .... ... ... .i Category:

R -Abnormal Rad Levels / Rad Effluent ... ..." '" Subcategory: 1 -Radiological Effluent .. .Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than , ': 100 mrem TEDE or 500 mrem thyroid CDE EA L: i * ........RS1.2 Site Area Emergency .......Dose assessment using actual meteorology indicates doses > 100 mrem TEDE or .....500 mrem thyroid CDE at or beyond the SITE BOUNDARY (Note,4) Deleted: s 3,*Note 4: The pre-calculated effluent monitor values presented in EALs RAlI.1, RS1I.1 and RGI .1 should be used .Deleted:aNtea:n f h effluent mntr for emergency classification assessments until the results from a dose assessment using actual i '[known to have stopped, indicating metoroogyareavalabe., that the release path is isolated, the VALID for classification purposes.¶f All Definition(s): SITE BOUNDARY -Area as depicted in CNS-SLC-1 6.11-16 Figure 16.11-16-1 Unrestricted Area and Site Boundary for Radioactive Effluents. Basis: Dose assessments are performed by computer-based methods (ref. 1, 2)This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public.Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions. The TEDE dose is set at 10% of the EPA PAG of 1,000 mrem while the 500 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.Escalation of the emergency classification level would be via IC RG1.CNS Basis Reference(s):

1. SDQA-70400-COM Unified RASCAL Interface (URI)2. AD-EP-ALL-0202, Emergency Response Offsite Dose Assessment

3. NEI 99-01 ASI RP/0/A/5000/001 I Rev. 1 I Page 42 of 247 I* , ' }tI " .. .. .. i i[I I -I ATTACHMENT 1 EAL Bases! -I,-o f, ., i , SRPIOIA/50001001 Rev. 1 IPage 43 of 247 ATTACHMENT 1 EAL Bases Category:

R -Abnormal Rad Levels / Rad Effluent Subcategory: 1 -Radiological Effluent Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE EAL: RS1.3 Site Area Emergency Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:* Closed window dose rates > 100 mR/hr expected to continue for > 60 min.* Analyses of field survey samples indicate thyroid CDE > 500 mrem for 60 min. of inhalation.(Notes 1,2)Note 1: The Emergency Coordinator 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.Mode Applicability: All Definition(s): SITE BOUNDARY -Area as depicted in CNS-SLC-1 6.11-16 Figure 16.11-16-1 Unrestricted Area and Site Boundary for Radioactive Effluents. Basis: HP/0/B/1 009/004, Environmental Monitoring for Emergency Conditions Within the Ten Mile Radius of CNS provides guidance for emergency or post-accident radiological environmental monitoring (ref. 1).This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to 10% of the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude are associated with the failure of plant systems needed for the protection of the public.IRP/OIA15000/O01 Rev. 1 IPage 44 of 247 ATTACHMENT 1 EAL Bases Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions. The TEDE dose is set at 10% of the EPA PAG of 1,000 mrem while the 500 mrem thyroid ODE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid ODE.Escalation of the emergency classification level would be via IC RGI.CNS Basis Reference(s):

1. HP/0/B/1 009/004 Environmental Monitoring for Emergency Conditions Within the Ten Mile Radius of CNS 2. NEI 99-01 AS1* :,,,, , o,,, RP/0/A/5000/001 Rev. 1 Page 45 of 247 ATTACHMENT 1I.... ..EAL Bases ... Category:

R -Abnormal Rad Levels / Rad Effluent " Subcategory: 1 -Radiological Effluent .... .Initiating Condition: Release of gaseous radioactivity resulting in offsite dose greater than...1,000 mrem TEDE or 5,000 mrem thyroid ODE .....EAL: ..RGI.1 General Emergency Reading on any Table R-1 effluent radiation monitor > column "GE" for > 15 min... .(Notes 1,2, 3, 4) ...Note 1: The Emergency Coordinator 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. I..Note 4: The pre-caiculated effluent monitor values presented in EALs RAI .1, RSI .1 and RG1I.1 should be used for emergency classification assessments until the results from a dose assessment using actual ; ""'. .meteorology are available. ... .: Table R-1 Effluent Monitor ClassificationThresholds

' ' ...Release Point Monitor GE SAE Alert UE SUnit Vent Noble Gas Low 1/2EMF36L

.......4.18E+6 cpm 5.75E+3 cpm SUnit Vent Noble Gas High 1J2EMF36H 2.21 E+4 cpm 2.22E+3 cpm 2.42E+2 cpm ...~Liquid Waste Effluent Line 0EMF49L ............ 4.50E+6 cpm SMonitor Tank Discharge 0EMF57L ........... 4.97E+5 cpm i Mode Applicability: All Definition(s): None Basis: This EAL address gaseous radioactivity releases, that for whatever reason, cause effluent radiation monitor readings corresponding to site boundary doses that exceed either:* 1000 mRem TEDE* 5000 mRem CDE Thyroid}RP/OIA15000/O01 Rev. I Page 46 of 247 ATTACHMENT 1 EAL Bases The column "GE" gaseous effluent release values in Table R-1 correspond to calculated doses of 100% of the EPA Protective Action Guidelines (TEDE or CDE Thyroid) (ref. 1, 2).Instrumentation that may be used to assess this EAL is Unit Vent Noble Gas High Range Monitor -EMF36H and has a range of 101 -106 cpm (ref 3, 4).This IC addresses a release of gaseous radioactivity that results in projected or actual offsite : doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both , monitored and un-monitored releases. Releases of this magnitude will require implementation of protective actions for the public. 'Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions. The TEDE dose is set at the EPA PAG of 1,000 mrem while the 5,000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.CNS Basis Reference(s): i 1. EP-EALCALC-CNS-1401 CNS Radiological Effluent EAL Values, Rev. 0 2. SDQA-70400-COM Unified RASCAL Interface (URI)3. CNS 0DCM Section 3.0 Setpoint Calculations

4. UFSAR Table 11-20 Airborne Process Radiation Monitoring Equipment 5. NEI 99-01 AG1i SRP/0/A/5000/001 Rev. 1 Page 47 of 247 Category: Subcategory:

Initiating Condition: ATTACHMENT 1 EAL Bases R -Abnormal Rad Levels / Rad Effluent 1 -Radiological Effluent Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL: RG1.2 General Emergency Dose assessment using actual meteorology indicates doses > 1,000 mrem TEDE or 5,000 mrem thyroid ODE at or beyond the SITE BOUNDARY (Note,4)*Note 4: The pre-calculated effluent monitor values presented in EALs RAlI.1, RS1I.1 and RGI .1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available. Mode Applicability: All Definition(s): SITE BOUNDARY -Area as depicted in CNS-SLC-1 6.11-16 Figure 16.11-16-1 Unrestricted Area and Site Boundary for Radioactive Effluents. Bas is: Dose assessments are performed by computer-based methods (ref. 1, 2)This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude will require implementation of protective actions for the public.Radiological effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions. The TEDE dose is set at the EPA PAG of 1,000 mrem while the 5,000 mrem thyroid ODE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid ODE.Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.CNS Basis Reference(s):

1. SDQA-70400-COM Unified RASCAL Interface (URI)2. AD-EP-ALL-0202, Emergency Response Offsite Dose Assessment

3. NEI 99-01 AG1 IRP/0/A/5000/001 Rev. 1 page 48 of 247Deleted: s 3, Deleted: Note 3: If the effluent o, flow past an effluent monitor is known to have stopped, indicating i that the release path is isolated, the I effluent monitor reading is no longe' -VALID for classification purposes.¶ Category: Subcategory:

Initiating Condition: ATTACHMENT 1 EAL Bases R -Abnormal Rad Levels / Rad Effluent 1 -Radiological Effluent Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE EAL: RG1.3 General Emergency Field survey results indicate EITHER of the following at or beyond the SITE BOUNDARY:* Closed window dose rates > 1,000 mR/hr expected to continue for > 60 min.* Analyses of field survey samples indicate thyroid CDE > 5,000 mrem for 60 mai. of inhalation.(Notes 1, 2)Note 1: The Emergency Coordinator 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.Mode Applicability: All Definition(s): SITE BOUNDARY -Area as .depicted in CNS-SLC-1 6.11-16 Figure 16.11-16-1 Unrestricted Area and Site Boundary for Radioactive Effluents. Basis: HP/0/B/1009/004, Environmental Monitoring for Emergency Conditions Within the Ten Mile Radius of CNS provides guidance for emergency or post-accident radiological environmental monitoring (ref. 1).This IC addresses a release of gaseous radioactivity that results in projected or actual offsite doses greater than or equal to the EPA Protective Action Guides (PAGs). It includes both monitored and un-monitored releases. Releases of this magnitude will require implementation of protective actions for the public.Radi0logical effluent EALs are also included to provide a basis for classifying events and conditions that cannot be readily or appropriately classified on the basis of plant conditions alone. The inclusion of both plant condition and radiological effluent EALs more fully addresses the spectrum of possible accident events and conditions. The TEDE dose is set at the EPA PAG of 1,000 mrem while the 5,000 mrem thyroid CDE was established in consideration of the 1:5 ratio of the EPA PAG for TEDE and thyroid CDE.CNS Basis Reference(s):

1. HP/0/B/1 009/004 Environmental Monitoring for Emergency Conditions Within the Ten Mile Radius of CNS RP/0/A/5000/001 Rev. 1 Page 49 of 247 ATTACHMENT 1 EAL Bases 2. NEJ 99-01 AG1 1 I* I ,i i;i' , * }SRPIoA/5ooo/ool Rev. 1 Page 50of,2471 ATTACHMENT 1 EAL Bases R -Abnormal Rad Levels / Rad Effluent 2 -Irradiated Fuel Event Category: Subcategory:

Initiating Condition: Unplanned loss of water level above irradiated fuel EAL: RU2.1 Unusual Event UNPLANNED water level drop in the REFUELING PATHWAY as indicated by low water level alarm or indication AND UNPLANNED rise in corresponding area radiation levels as indicated by any of the following radiation monitors:* 1EMF15 (2EMF4) Spent Fuel Building Refueling Bridge* 1EMF17 (2EMF2) Reactor Building Refueling Bridge Mode Applicability: All Definition(s): UNPLANNED-. A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.REFUELING PATHWAY-. The reactor refueling cavity, spent fuel pool and fuel transfer canal comprise the refueling pathway.Basis: The spent fuel pool low water level alarm setpoint is actuated by 1 (2)KFPS51 20 at a setpoint of 39' (ref. 1). Water level restoration instructions are performed in accordance with AOPs (ref.2, 3).The specified radiation monitors are those expected to see increase area radiation levels as a result of a loss of REFUELING PATHWAY inventory (ref. 2, 3). Increasing radiation indications on these monitors in the absence of indications of decreasing REFUELING CAVITY level are not classifiable under this EAL.When the spent fuel pool and reactor cavity are connected, there could exist the possibility of uncovering irradiated fuel. Therefore, this EAL is applicable for conditions in which irradiated fuel is being transferred to and from the reactor vessel and spent fuel pool.This IC addresses a decrease in water level above irradiated fuel sufficient to cause elevated radiation levels. This condition could be a precursor to a more serious event and is also indicative of a minor loss in the ability to control radiation levels within the plant. It is therefore a potential degradation in the level of safety of the plant.RP/OIA15000/001 Rev. 1 Page 51 of 247 ATTACHMENT 1 EAL Bases A water level decrease will be primarily determined by indications from available level instrumentation. Other sources of level indications may include reports from plant personnel (e.g., from a refueling crew) or video camera observations (if available). A significant drop in the water level may also cause an increase in the radiation levels of adjacent areas that can be detected by monitors in those locations. The effects of planned evolutions should be considered. For example, a refueling bridge area radiation monitor reading may increase due to planned evolutions such as lifting of the reactor vessel head or movement of a fuel assembly. Note that this EAL is applicable only in cases where the elevated reading is due to an unplanned loss of water level.A drop in water level above irradiated fuel within the reactor vessel may be classified in accordance Recognition Category C during the Cold Shutdown and Refueling modes.Escalation of the emergency classification level would be via IC RA2.CNS Basis Reference(s):

1. OPI1(2)1B16100/10 IN E12 Spent Fuel Pool Level Hi/Lo 2. AP/1(2)/A/5500/026 Loss of Refueling Canal Level 3. AP/1(2)/A/5500/041 Loss of Spent Fuel Cooling or Level 4. NEI 99-01 AU2 IRPI0/AI5000/001 Rev. I Page 52 of 247 ATTACHMENT 1 EAL Bases " '": '* i:... Category:

R -Abnormal Rad Levels!/ Rad Effluent I, Subcategory: 2 -Irradiated Fuel Event Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuel i EAL: RA2.1 Alert Uncovery of irradiated fuel in the REFUELING PATHWAY i"'Mode Applicability: !All Definition(s): REFUELING PATHWAY-. The reactor refueling cavity, spent fuel pool and fuel transfer canal " comprise the refueling pathway." ...: Basis: .. " ,. .'This IC addresses events that have caused imminent or actual damage to an irradiated fuel ...".... , " assembly, or a significant lowering of water level within the spent fuel pool. These present radiological safety challenges to plant personnel and are precursors to a release of .. .'radioactivity to the environment. As such, they represent an actual or potential substantial ... ', ,!degradation of the level of safety of the plant.This EAL escalates from RU2*I in that the loss of level, in the affected portion of the REFUELING PATHWAY, is of sufficient magnitude to have resulted in uncovery of irradiated .....fuel. Indications of irradiated fuel uncovery may include direct or indirect visual observation ' .(e~g., reports from personnel or camera images), as well as significant changes in water and radiation levels, or other plant parameters. Computational aids may also be used (e.g., a boil- ...' *" :. : ;off curve). Classification of an event using this EAL should be based on the totality of available ,,-....: *...... ......indications, reports and observations. While an area radiation monitor could detect an increase in a dose rate due to a lowering of -, "-water level in some portion of the REFUELING PATHWAY, the reading may not be a reliable i. , .... 'indication of whether or not the fuel is actually uncovered. To the degree possible, readings ...should be considered in combination with other available indications of inventory loss. , A drop in water level above irradiated fuel within the reactor vessel may be classified in... ,: ,, ,.accordance Recognition Category C during the Cold Shutdown and Refueling modes ......:, ... ...Escalation of the emergency classification level would be via IC RS1.CNS Basis Reference(s): ..1. AP/1 (2)/A/5500/026 Loss of Refueling Canal Level 2. AP/1 (2)/A/5500/041 Loss of Spent Fuel Cooling or Level ....." '3. NEI 99-01 AA2 .' '" '... " SRP/0/A/5000/001 Rev. 1 Page 53 of 247 ATTACHMENT 1 EAL Bases IRP/0/A/5000/001 Rev. 1 Page 54 of 247 ATTACHMENT 1 EAL Bases Category: R -Abnormal Rad Levels / Rad Effluent Subcategory: 2 -Irradiated Fuel Event Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuel EAL: RA2.2 Alert Damage to irradiated fuel resulting in a release of radioactivity AND A Trip 2 radiation alarm on any of the following radiation monitor indications:

• 1EMF15 (2EMF4) Spent Fuel Building Refueling Bridge* 1 EMF1 7 (2EMF2) Reactor Building Refueling Bridge* 1 EMF42 (2EMF42) Spent Fuel Pool Ventilation
• 1 EMF39L (2EMF39L)

Containment Noble Gas Mode Applicability: All Definition(s): None Basis: The specified radiation monitors are those expected to see increase area radiation levels as a result of damage to irradiated fuel (ref. 1 ).The Trip 2 alarm setpoints for the radiation monitors are set to be indicative of significant increases in area and/or airborne radiation (ref. 2).This IC addresses events that have caused imminent or actual damage to an irradiated fuel assembly, or a significant lowering of water level within the spent fuel pool. These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment. As such, they represent an actual or potential substantial degradation of the level of safety of the plant.This EAL applies to irradiated fuel that is licensed for dry storage up to the point that the loaded storage cask is sealed. Once sealed, damage to a loaded cask causing loss of the CONFINEMENT BOUNDARY is classified in accordance with EAL EU1 .1.Escalation of the emergency would be based on either Recognition Category R or C ICs.This EAL addresses a release of radioactive material caused by mechanical damage to irradiated fuel. Damaging events may include the dropping, bumping or binding of an assembly, or dropping a heavy load onto an assembly. A rise in readings on radiation monitors should be considered in conjunction with in-plant reports or observations of a potential fuel damaging event (e.g., a fuel handling accident). IRPIOIAI50001001I Rev. 1 Page 55 of 247 ATTACHMENT 1 EAL Bases Escalation of the emergency classification level would be via IC RS1.CNS Basis Reference(s):

1. AP/1 (2)/A/5500/025 Damaged Spent Fuel 2. HP/0/B/1 000/010 Determination of Radiation Monitor Setpoints 3. NEI 99-01 AA2[RPI/0/A5000/O01 Rev. 1 Page 56 of 247 ATTACHMENT I EAL Bases R -Abnormal Rad Levels / Rad Effluent 2 -Irradiated Fuel Event Category: Subcategory:

Initiating Condition: Significant lowering of water level above, or damage to, irradiated fuel EAL: RA2..3 Alert Lowering of spent fuel pool level to 24.5 ft. (Level 2) on 1 (2)KFP5780 or 1 (2)NVP8790 Mode Applicability: All Definition(s): None Basis: Post-Fukushima order EA-12-051 (ref.l) required the installation of reliable SEP level indication capable of identifying normal level (Level 1), SFP level 10 ft. above the top of the fuel racks (Level 2) and SEP level at the top of the fuel racks (Level 3).SEP level indicators 1(2)KFP5780 (radar) or 1(2)NVP8790 (pressure) located on the back of 2MC7 provide continuous wide range SEP level indication to the top of the spent fuel racks (ref. 2).This IC addresses events that have caused imminent or actual damage to an irradiated fuel assembly, or a significant lowering of water level within the spent fuel pool. These events present radiological safety challenges to plant personnel and are precursors to a release of radioactivity to the environment. As such, they represent an actual or potential substantial degradation of the level of safety of the plant.Escalation of the emergency would be based on either Recognition Category R or C ICs.Spent fuel pool water level at this value is within the lower end of the level range necessary to prevent significant dose consequences from direct gamma radiation to personnel performing operations in the vicinity of the spent fuel pool. This condition reflects a significant loss of spent fuel pool water inventory and thus it is also a precursor to a loss of the ability to adequately cool the irradiated fuel assembles stored in the pool.Escalation of the emergency classification level would be via IC RS1.RP/0/A/5000/001 Rev. 1 Page 57 of 247 ATTACHMENT 1 EAL Bases CNS Basis Reference(s):

1. NRC EA-12-51 Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

2. EC109413 3 NEI 99-01 AA2 SRP/0/A/5000/001 Rev. I Page 58 of 247I

, ,,, .,, .ATTACHMENT 1 EAL Bases Category: R -Abnormal Rad Levels / Rad Effluent Subcategory: 2 -Irradiated Fuel Event Initiating Condition: Spent fuel pool level at the top of the fuel racks EAL: R S2.1 Site Area Emergency Lowering of spent fuel pool level to 14.5 ft. (Level 3) on 1 (2)KFP5780 or 1 (2)NVP8790 Mode Applicability: All Definition(s): None Basis: Post-Fukushima order EA-1 2-051 (ref.1) required the installation of reliable SEP level indication capable of identifying normal level (Level 1 ), SEP level 10 ft. above the top of the fuel racks (Level 2) and SEP level at the top of the fuel racks (Level 3).SEP level indicators 1 (2)KFP5780 (radar) or 1 (2)NVP8790 (pressure) located on the back of 2MC7 provide continuous wide range SEP level indication to the top of the spent fuel racks (ref. 2).This EAL addresses a significant loss of spent fuel pool inventory control and makeup capability leading to IMMINENT fuel damage. This condition entails major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration. It is recognized that this IC would likely not be met until well after another Site Area Emergency IC was met; however, it is included to provide classification diversity. Escalation of the emergency classification level would be via IC AG1 or RG2.CNS Basis Reference(s):

1. NRC EA-12-51 Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

2. EC109413 3. NEI 99-01 AS2[t"' ,!i i,,, :,,.4' '!?,: .....t'£i t"[_,., ...................

/ I SRP/O/AI50001001 Rev. 1I Page 59 of 247 ATTACHMENT 1 EAL Bases Category: R -Abnormal Rad Levels / Rad Effluent Subcategory: 2 -Irradiated Fuel Event Initiating Condition: Spent fuel pool level cannot be restored to at least the top of the fuel racks for 60 minutes or longer EAL: RG2.l General Emergency Spent fuel pool level cannot be restored to at least 14.5 ft. (Level 3) on 1(2)KFP5780 or 1(2)NVP8790 for > 60 mnm. (Note 1)Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.Mode Applicability: All Definition(s): None Basis: Post-Fukushima order EA-12-051 (ref.1) required the 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 SEP level at the top of the fuel racks (Level 3).SEP level indicators 1(2)KFP5780 (radar) or 1(2)NVP8790 (pressure) located on the back of 2MC7 provide continuous wide range SEP level indication to the top of the spent fuel racks (ref. 2).This EAL addresses a significant loss of spent fuel pool inventory control and makeup capability leading to a prolonged uncovery of spent fuel. This condition will lead to fuel damage and a radiological release to the environment. It is recognized that this IC would likely not be met until well after another General Emergency IC was met; however, it is included to provide classification diversity. CNS Basis Reference(s):

1. NRC EA-12-51 Issuance of Order to Modify Licenses with Regard to Reliable Spent Fuel Pool Instrumentation

2. EC109413 3. NEI 99-01 AG2 Category:

R -Abnormal Rad Levels / Rad Effluent Subcategory: 3 -Area Radiation Levels Initiating Condition: Radiation levels that IMPEDE access to equipment necessary for normal plant operations, cooldown or shutdown EAL: IRP/0/A/5000/001 Rev. 1 [Page 60 of 247I ATTACHMENT 1 EAL Bases RA3.1 Alert Dose rates > 15 mR/hr in EITHER of the following areas: Control Room (EMF12)OR Central Alarm Station (by survey)Mode Applicability: All Definition(s): IMPEDE(D) -Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed). Basis: Areas that meet this threshold include the Control Room and the Central Alarm Station (CAS).EMF Channel 12 monitors the Control room for area radiation (ref. 1). The CAS is included in this EAL because of its' importance to permitting access to areas required to assure safe plant operations. There is no permanently installed CAS area radiation monitors that may be used to assess this EAL threshold. Therefore this threshold must be assessed via local radiation survey for the CAS.This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or impede personnel from performing actions necessary to maintain normal plant operation, or to perform a normal plant cooldown and shutdown. As such, it represents an actual or potential substantial degradation of the level of safety of the plant. The Emergency Coordinator should consider the cause of the increased radiation levels and determine if another IC may be applicable. Escalation of the emergency classification level would be via Recognition Category R, C or F ICs.CNS Basis Reference(s):

1. OP/1(2)/B/6100/010Z C/2 Control Room 2. NEI 99-01 AA3 RP/0/A/5000/001 Rev. 1 Page 61 of 247 ATTACHMENT 1 EAL Bases Category:

R -Abnormal Rad Levels / Rad Effluent Subcategory: 3 -Area Radiation Levels Initiating Condition: Radiation levels that IMPEDE access to equipment necessary for normal plant operations, cooldown or shutdown EAL: RA3.2 Alert An UNPLANNED event results in radiation levels that prohibit or IMPEDE access to any Table R-2 rooms or areas (Note 5)Note 5: If the equipment in the lsted room or area was already inoperable or out-of-service before the event occurred, then no emergency ciassification is warranted. Table R-2 Safe Operation & Shutdown Rooms/Areas Bldg. Elevation Unit 1 Room/Area Unit 2 Room/Area Mode Rm 478 (1 EMXA) Rrn 469 (2EMXA) 4 Rm 496 (1ETA) Rrm 486 (2ETA) 4 uxiry Rm 496 (1 EMXS) Rm 486 (2EMXS) 4 AB-577', J J-57 (1MXK) AB-577', J J-57 (2MXK) 4 Rm 330(1 EMXJ) Rm 320 (2EMXJ) 4 Auxiliary 560' Rm 372 (1 ETB) Rmn 362 (2ETB) 4 Rm 372 (1 EMXD) Rrn 362 (2EMXD) 4 Mode Applicability: All Definition(s): IMPEDE(D) -Personnel access to a room or area is hindered to an extent that extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed). UNPLANNED -A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.Basis: If the equipment in the listed room or area was already inoperable, or out-of-service, before the event occurred, then no emergency should be declared since the event will have no adverse impact beyond that already allowed by Technical Specifications at the time of the event.The list of plant rooms or areas with entry-related mode applicability identified specify those rooms or areas that contain equipment which require a manual/local action as specified in operating procedures used for normal plant operation, cooldown and shutdown. Rooms or areas in which actions of a contingent or emergency nature would be performed (e.g., an IRP/0/A/5000/O01 Rev. 1I Page 62 of 247 ATTACHMENT 1 EAL Bases action to address an off-normal or emergency condition such as emergency repairs, corrective measures or emergency operations) are not included. in addition, the list specifies the plant mode(s) during which entry would be required for each room or area (ref. 1 ).This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or impede personnel from performing actions necessary to maintain normal plant operation, or .to perform a normal plant cooldown and shutdown. As such, it represents an actual or potential substantial degradation of the level of safety of the plant. The Emergency ..Coordinator should consider the cause of the increased radiation levels and determine if another IC may be applicable. For RA3.2, an Alert declaration is warranted if entry into the affected room/area is, or may be, procedurally required during the plant operating mode in effect at the time of the elevated radiation levels. The emergency classification is not contingent upon whether entry is actually necessary at the time of the increased radiation levels. Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., installing temporary shielding, requiring use of non-routine protective equipment, requesting an extension in dose limits beyond normal administrative limits).An emergency declaration is not warranted if any of the following conditions apply:*The plant is in an operating mode different than the mode specified for the affected room/area (i.e., entry is not required during the operating mode in effect at the time of the elevated radiation levels). For example, the plant is in Mode 1 when the radiation increase occurs, and the procedures used for normal operation, cooldown and shutdown do not require entry into the affected room until Mode 4.* The increased radiation levels are a result of a planned activity that includes compensatory measures which address the temporary inaccessibility of a room or area (e.g., radiography, spent filter or resin transfer, etc.).* The action for which room/area entry is required is of an administrative or record keeping nature (e.g., normal rounds or routine inspections).

• The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.Escalation of the emergency classification level would be via Recognition Category R, C or F nCs. , CNS Basis Reference(s):
• i 1. Attachment 3 Safe Operation

& Shutdown Rooms/Areas Tables R-2 & H-2 Bases 2. NEI 99-01 AA3 RP/0/A/5000/001 Rev. I Page 63 of 247 ATTACHMENT 1 EAL Bases, Category C -Cold Shutdown I Refueling System Malfunction EAL Group: Cold Conditions (NCS temperature -< 200°F); EALs 'in this category are applicable only in one or more cold operating modes.Category C EALs are directiy associated with cold shutdown or refueling system safety functions. Given the variability of plant configurations (e.g., systems out-of-service for maintenance, containment open, reduced AC power redundancy, time since shutdown) during i these periods, the consequences of any given initiating event can vary greatly. For example, a loss of decay heat removal capability that occurs at the end of an extended outage has less significance than a similar loss occurring during the first week after shutdown. Compounding these events is the likelihood that instrumentation necessary for assessment may also be inoperable. The cold shutdown and refueling system malfunction EALs are based on performance capability to the extent possible with consideration given to NCS integrity, containment closure, and fuel clad integrity for the applicable operating modes (5 -Cold Shutdown, 6 -Refueling, D -Defueled). The events of this category pertain to the following subcategories: !1. NCS Level Reactor Pressure Vessel water level is directly related to the status of adequate core cooling and, therefore, fuel clad integrity.

2. Loss of Essential AC Power Loss of essential plant electrical power can compromise plant safety system operability including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity.

This category includes loss of onsite and offsite power sources for 4160 VAC emergency buses.3. NCS Temperature Uncontrolled or inadvertent temperature or pressure increases are indicative of a potential loss of safety functions.

4. Loss of Vital DC Power Loss of emergency plant electrical power can compromise plant safety system operability

, including decay heat removal and emergency core cooling systems which may be necessary to ensure fission product barrier integrity. This category includes loss of power to or degraded voltage on the 125 VDC vital buses.IRP/0/A/5000/001 Rev. 1 Page 64 of 247 ATTACHMENT I EAL Bases 5. Loss of Communications Certain events that degrade plant operator ability to effectively communicate with essential personnel within or external to the plant warrant emergency classification.

6. Hazardous Event Affecting Safety Systems Certain hazardous natural and technological events may result in visible damage to or degraded performance of safety systems warranting classification.

RPIOIAI50001001 Rev. 1 Page 65 of 247 ATTACHMENT 1 EAL Bases Category: C -Cold Shutdown / Refueling System Malfunction Subcategory: 1 -NCS Level Initiating Condition: UNPLANNED loss of NCS inventory for 15 minutes or longer EAL: CUI.l Unusual Event UNPLANNED loss of NCS inventory results in NCS water level less than a required lower limit for 15 mai. (Note 1)Note 1: The Emergency Coordinator should deciare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.Mode Applicability: 5 -Cold Shutdown, 6 -Refueling Definition(s): UNPLANNED-. A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.Basis: NCS water level less than a required lower limit is meant to be less than the lower end of the level control band being procedurally maintained for the current condition or evolution. With the plant in Cold Shutdown, NCS water level is normally maintained above the pressurizer low level setpoint of 17% (ref. 1). However, if NCS level is being controlled below the pressurizer low level setpoint, or if level is being maintained in a designated band in the reactor vessel it is the inability to maintain level above the low end of the designated control band due to a loss of inventory resulting from a leak in the NCS that is the concern.With the plant in Refueling mode, NCS water level is normally maintained at or above the reactor vessel flange (Technical Specification LCO 3.9.6 requires at least 23 ft of water above the top of the reactor vessel flange in the refueling cavity during refueling operations) (ref. 2).This IC addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor NCS level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant.Refueling evolutions that decrease NCS water inventory are carefully planned and controlled. An UNPLANNED event that results in water level decreasing below a procedurally required limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered.This EAL recognizes that the minimum required NCS level can change several times during the course of a refueling outage as different plant configurations and system lineups are implemented. This EAL is met if the minimum level, specified for the current plant conditions, IRP/0/A15000/001 Rev. 1 Page 66 of 247 ATTACHMENT 1 EAL Bases cannot be maintained for 15 minutes or longer. The minimum level is typically specified in the applicable operating procedure but may be specified in another controlling document.The 15-minute threshold duration allows sufficient time for prompt operator actions to restore and maintain the expected water level. This criterion excludes transient conditions causing a brief lowering of water level.Continued loss of NCS inventory may result in escalation to the Alert emergency classification level via either IC CA1 or CA3.CNS Basis Reference(s):

1. EP/I(2)/A/5000/FR-l.2 Response to Low Pressurizer Level 2. CNS Technical Specifications Section 3.9.6 Refueling Cavity Water Level 3. NEI 99-01 CUl IRPO/0/A50001001 Rev. 1 Page 67 of 247 ATTACHMENT 1 EAL Bases C -Cold Shutdown / Refueling System Malfunction 1 -NCS Level Category: Subcategory:

Initiating Condition: UNPLANNED loss of NCS inventory EAL: CU1.2 Unusual Event NCS water level cannot be monitored AND EITHER* UNPLANNED increase in pyTable C-6 sump or tank level due to a loss of NCS inventory*Visual observation of UNISOLABLE NCS leakage I qupment Sump or lncore Sump (alarm)Table C-6 Sumps/Tanks

• Containment Floor & Equipment Sump* Incore Sump (alarm)* ND/NS sump* NCDT* PRT Mode Applicability:

5 -Cold Shutdown, 6 -Refueling Definition(s): UN/SOLABLE -An open or breached system line that cannot be isolated, remotely or locally.UNPLANNED-. A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.Basis: In Cold Shutdown mode, the NCS will normally be intact and standard NCS level monitoring means are available. NCS level in the Refueling mode is normally monitored using the sight glass.In this EAL, all water level indication is unavailable and the NCS inventory loss must be detected by indirect leakage indications (ref. 1). Level increases must be evaluated against other potential sources of leakage such as cooling water sources inside the containment to ensure they are indicative of NCS leakage. If the make-up rate to the NCS unexplainably rises above the pre-established rate, a loss of NCS inventory may be occurring even if the source of the leakage cannot be immediately identified. Visual observation of leakage from systems connected to the NCS that cannot be isolated could also be indicative of a loss of NCS inventory. The Incore Sump level cannot be monitored in the CR but alarms on high level.IRP/OIAI50001001 Rev. 1 Page 68 of 247 ATTACHMENT 1 EAL Bases This IC addresses the inability to restore and maintain water level to a required minimum level (or the lower limit of a level band), or a loss of the ability to monitor RPV level concurrent with indications of coolant leakage. Either of these conditions is considered to be a potential degradation of the level of safety of the plant.Refueling evolutions that decrease NCS water inventory are carefully planned and controlled. An UNPLANNED event that results in water level decreasing below a procedurally required limit warrants the declaration of an Unusual Event due to the reduced water inventory that is available to keep the core covered.This EAL addresses a condition where all means to determine RPV level have been lost. In this condition, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the NCS.Continued loss of NCS inventory may result in escalation to the Alert emergency classification level via either IC CA1 or CA3.CNS Basis Reference(s):

1. AP/1 (2)/A/5500/010 Reactor Coolant Leak 2. NEI 99-01 CU1 IRPIO/A150001001 Rev. I Page 69 of 247 ATTACHMENT 1 EAL Bases Category:

C -Cold Shutdown / Refueling System Malfunction Subcategory: 1 -NCS Level Initiating Condition: Loss of NCS inventory EAL: CAl.1 Alert UNPLANNED loss of NCS inventory as indicated by NCS water level < 6.5% (wide range)Mode Applicability: 5 -Cold Shutdown, 6 -Refueling Definition(s): UNPLANNED-. A parameter change or an event that is not 1 ) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.Basis: 6.5% wide range NCS level indication is the lowest level to assure adequate net positive suction head and prevent ND pump cavitation for all flow rates (ref. 1).This IC addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier). This condition represents a potential substantial reduction in the level of plant safety.For this EAL, a lowering of NCS water level below 6.5% indicates that operator actions have not been successful in restoring and maintaining NCS water level. The heat-up rate of the coolant will increase as the available water inventory is reduced. A continuing decrease in water level will lead to core uncovery.Although related, this EAL is concerned with the loss of NCS inventory and not the potential concurrent effects on systems needed for decay heat removal (e.g., loss of a Decay Heat Removal suction point). An increase in NCS temperature caused by a loss of decay heat removal capability is evaluated under IC CA3.If NCS water level continues to lower, then escalation to Site Area Emergency would be via IC CS1.IRPIOIN000IO0O1 Rev., 1 Page 70 of 2471 ATTACHMENT 1 EAL Bases CNS Basis Reference(s):

1. OPI1(2)/A/6150/006 Draining the Reactor Coolant System 2. NEI 99-01 CA1[RPIOIAI5000/100 Rev. 1I Page 71 of 247I ATTACHMENT 1 EAL Bases Category: Subcategory:

C -Cold Shutdown / Refueling System Malfunction 1 -NCS Level Initiating Condition: Loss of NCS inventory EAL: CA1.2 Alert NCS water level cannot be monitored for > 15 mmn. (Note 1)AND EITHER* UNPLANNED increase in any Table C-6 sump or tank leveldue to a loss of NCS inventory* Visual observation of UNISOLABLE NCS leakage LIDeleted: Containment Floor &IEquipment Sump or Incore Sump (alarm)Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.Table C-6 Sumps/Tanks

• Containment Floor & Equipment Sump* Incore Sump (alarm)* ND/NS sump* NCDT* PRT Mode Applicability:

5 -Cold Shutdown, 6 -Refueling Definition(s): UNISOLABLE -An open or breached system line that cannot be isolated, remotely or locally.UNPLANNED-. A parameter change or an event that is not 1 ) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.Basis: In Cold Shutdown mode, the NCS will normally be intact and standard NCS monitoring means are available. In the Refuel mode, the NCS is not intact and NCS level may be monitored by different means, including the ability to monitor level visually.In this EAL, all NCS water level indication would be unavailable for greater than 15 minutes, and the NCS inventory loss must be detected by indirect leakage indications (ref. 1). Sump level increases must be evaluated against other potential sources of leakage. If the make-up rate to the NCS unexplainably rises above the pre-established rate, a loss of NCS inventory may be occurring even if the source of the leakage cannot be immediately identified. Visual observation of leakage from systems connected to the NCS that cannot be isolated could also be indicative of a loss of NCS inventory. IRP/OIN50001001 Rev. 1 Page 72 of 247I ATTACHMENT 1 EAL Bases The Incore Sump level cannot be monitored in the CR but alarms on high level.This IC addresses conditions that are precursors to a loss of the ability to adequately cool irradiated fuel (i.e., a precursor to a challenge to the fuel clad barrier). This condition represents a potential substantial reduction in the level of plant safety.For this EAL, the inability to monitor NCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the NCS.The 15-minute duration for the loss of level indication was chosen because it is half of the EAL duration specified in IC CSI.If the NCS inventory level continues to lower, then escalation to Site Area Emergency would be via IC CS1.CNS Basis Reference(s):

1. AP/1 (2)/A/5500/01 0 Reactor Coolant Leak 2. NEI 99-01 CA1 SRPIOIAI50001001 Rev. 1 Page 73 of 247 ATTACHMENT 1 EAL Bases Category: Subcategory:

Initiating Condition: EAL: C -Cold Shutdown / Refueling System Malfunction 1 -NCS Level Loss of NCS inventory affecting core decay heat removal capability CSI1. Site Area Emergency NCS water level cannot be monitored for > 30 min. (Note 1)AND Core uncovery is indicated by any of the following:

• UNPLANNED increase in any Table C-6 sump or tank leveldue to a loss of NCS ..inventory* Visual observation of UNISOLABLE NCS leakage* Reactor Building Refueling Bridge Monitor 1EMF17 (2EMF2) reading > 9,000 mR/hr* Erratic Source Range or Gamma Metric Monitor indication containment Floor &Equipment Sump or Incore Sump (eaam~)Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.Table C-6 Sumps/Tanks
• Containment Floor & Equipment Sump* Incore Sump (alarm)* ND/NS sump* NCDT* PRT Mode Applicability:

5 -Cold Shutdown, 6 -Refueling Definition(s): UNISOLABLE -An open or breached system line that cannot be isolated, remotely or locally.UNPLANNED-. A parameter change or an event that is not 1I) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.IRP/0/A/5000/001 IRev. I Page 74 of 247 ATTACHMENT 1 EAL Bases Basis: The lowest measurable NCS level is the elevation of the NCS hot leg mid-loop. Therefore, NCS inventory loss relative to the NCS level elevation corresponding to the top of active fuel must be detected by indirect leakage indications (ref. 1). Sump level increases must be evaluated against other potential sources of leakage. If the make-up rate to the NCS unexplainably rises above the pre-established rate, a loss of NCS inventory may be occurring even if the source of the leakage cannot be immediately identified. Visual observation of leakage from systems connected to the NCS in areas outside the containment that cannot be isolated could also be indicative of a loss of NCS inventory (ref. 2).The Incore Sump level cannot be monitored in the CR but alarms on high level.In the Refueling Mode, as water level in the reactor vessel lowers, the dose rate above the core will increase. The dose rate due to this core shine should result in indications on installed area radiation monitors. 1 EMF17 (2EMF2), Reactor Building Refueling Bridge Monitor is located in the containment in proximity to the reactor cavity and is designed to provide monitoring of radiation due to a fuel handling event or loss of shielding during refueling operations. If this radiation monitor reaches and exceeds 9,000 mR/hr (90% of instrument scale), a loss of inventory with potential to uncover the core is likely to have occurred.Post-TMI accident studies indicated that the installed PWR nuclear instrumentation will operate erratically when the core is uncovered and that this should be used as a tool for making such determinations. This IC addresses a significant and prolonged loss of reactor vessel/NCS inventory control and makeup capability leading to IMMINENT fuel damage. The lost inventory may be due to a NCS component failure, a loss of configuration control or prolonged boiling of reactor coolant.These conditions entail major failures of plant functions needed for protection of the public and thus warrant a Site Area Emergency declaration. Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If NCS level cannot be restored, fuel damage is probable.The 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring. The inability to monitor NCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from the NCS.This EAL addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal;SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management. IRP/OIN50001001 1Rev. I Page 75 of 247 ATTACHMENT 1 EAL Bases Escalation of the emergency classification level would be via IC CGI or RGI CNS Basis Reference(s):

1. OP/1 (2)/A/61 50/006 Draining the Reactor Coolant System 2. AP/1(2)/A/5500/010 Reactor Coolant Leak 3. NEI 99-01 CS1 IRP/OIA15000/O01 Rev. 1 Page 76 of 247 ATTACHMENT 1 EAL Bases Category: Subcategory:

Initiating Condition: C -Cold Shutdown / Refueling System Malfunction 1 -NCS Level Loss of NCS inventory affecting fuel clad integrity with containment challenged EAL: CG1.1 General Emergency NCS level cannot be monitored for 30 min. (Note 1)AND Core uncovery is indicated by any of the following:

• UNPLANNED increase in any Table C-6 sump or tank leveldue to a loss of NCS inventory* Visual observation of UNISOLABLE NCS leakage* Reactor Building Refueling Bridge Monitor 1EMF17 (2EMF2) reading > 9,000 mR/hr* Erratic Source Range or Gamma Metric Monitor indication AND Any Containment Challenge indication, Table C-i Equipment Sump or Incore Sump (alarm)Note 1: The Emergency Coordinator 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.Table C-I Containment Challenge Indications
• CONTAINMENT CLOSURE not established (Note 6)* Containment hydrogen concentration

> 6%* UNPLANNED rise in containment pressure Table C-6 SumpsrTanks

• Containment Floor & Equipment Sump* Incore Sump (alarm)* ND/NS sump* NCDT* PRT IRP/0/A/5000/001 IRev. I Page 77'of2471 ATTACHMENT 1 EAL Bases Mode Applicability:

5 -Cold Shutdown, 6 -Refueling Definition(s): CONTAINMENT CLOSURE -The procedurally defined conditions or actions taken to secure Primary or Secondary Containment and its associated structures, systems, and components as a functional barrier to fission product release under shutdown conditions. As applied to CNS, Containment Closure is established when the requirements of OP/0/A/61 00/014 Penetration Control for Modes 5, 6 and NO Mode -Enclosure 4.7 Setting, Maintaining and Securing from Containment Penetration Control are met.UNISOLABLE -An open or breached system line that cannot be isolated, remotely or locally.UNPLANNED-. A parameter change or an event that is not 1 ) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.Basis: The lowest measurable NCS level is the elevation of the NCS hot leg mid-loop. Therefore, NCS inventory loss relative to the NCS level elevation corresponding to the top of active fuel must be detected by indirect leakage indications (ref. 1). Sump level increases must be evaluated against other potential sources of leakage. If the make-up rate to the NCS unexplainably rises above the pre-established rate, a loss of NCS inventory may be occurring even if the source of the leakage cannot be immediately identified. Visual observation of leakage from systems connected to the NCS in areas outside the containment that cannot be isolated could also be indicative of a loss of NCS inventory (ref. 2).The Incore Sump level cannot be monitored in the CR but alarms on high level.In the Refueling Mode, as water level in the reactor vessel lowers, the dose rate above the core will increase. The dose rate due to this core shine should result in indications on installed area radiation monitors. 1 EMF1 7 (2EMF2), Reactor Building Refueling Bridge Monitor is located in the containment in proximity to the reactor cavity and is designed to provide monitoring of radiation due to a fuel handling event or loss of shielding during refueling operations. If this radiation monitor reaches and exceeds 9,000 mR/hr (90% of instrument scale), a loss of inventory with potential to uncover the core is likely to have occurred.Post-TMI accident studies indicated that the installed PWR nuclear instrumentation will operate erratically when the core is uncovered and that this should be used as a tool for making such determinations. Three conditions are associated with a challenge to containment integrity:

• CONTAINMENT CLOSURE is not established (Ref. 3).* In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a core uncovery could result in an explosive mixture of dissolved gases in the containment.

However, containment monitoring and/or sampling should be performed to verify this assumption and a General Emergency declared if it is determined that an explosive mixture exists. An explosive mixture can be formed when hydrogen gas[RP/O/A/5000/01 1 Rev. 1 Page 78 of 247 ATTACHMENT 1 EAL Bases concentration in the containment atmosphere is greater than 6% by volume in the presence of oxygen (>5%).*Any unplanned increase in containment pressure in the Cold Shutdown or Refueling mode indicates a potential loss of containment closure capability. Unplanned containment pressure increases indicates containment closure cannot be assured and the containment cannot be relied upon as a barrier to fission product release.This IC addresses the inability to restore and maintain reactor vessel level above the top of active fuel with containment challenged. This condition represents actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity. Releases can be reasonably expected to exceed EPA PAG exposure levels offsite for more than the immediate site area.Following an extended loss of core decay heat removal and inventory makeup, decay heat will cause reactor coolant boiling and a further reduction in reactor vessel level. If NCS level cannot be restored, fuel damage is probable.With CONTAINMENT CLOSURE not established, there is a high potential for a direct and unmonitored release of radioactivity to the environment. If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute time limit, then declaration of a General Emergency is not required.The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen burn will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity. It therefore represents a challenge to Containment integrity. In the early stages of a core uncovery event, it is unlikely that hydrogen buildup due to a core uncovery could result in an explosive gas mixture in containment. If all installed hydrogen gas monitors are out-of-service during an event leading to fuel cladding damage, it may not be possible to obtain a containment hydrogen gas concentration reading as ambient conditions within the containment will preclude personnel access. During periods when installed containment hydrogen gas monitors are out-of-service, operators may use the other listed indications to assess whether or not containment is challenged. The 30-minute criterion is tied to a readily recognizable event start time (i.e., the total loss of ability to monitor level), and allows sufficient time to monitor, assess and correlate reactor and plant conditions to determine if core uncovery has actually occurred (i.e., to account for various accident progression and instrumentation uncertainties). It also allows sufficient time for performance of actions to terminate leakage, recover inventory control/makeup equipment and/or restore level monitoring. The inability to monitor NCS level may be caused by instrumentation and/or power failures, or water level dropping below the range of available instrumentation. If water level cannot be monitored, operators may determine that an inventory loss is occurring by observing changes in sump and/or tank levels. Sump and/or tank level changes must be evaluated against other potential sources of water flow to ensure they are indicative of leakage from theNCS.This EAL addresses concerns raised by Generic Letter 88-17, Loss of Decay Heat Removal;SECY 91-283, Evaluation of Shutdown and Low Power Risk Issues; NUREG-1449, Shutdown SRPIOIN/50001001 Rev. 1 Page 79 of 247] ATTACHMENT 1 EAL Bases and Low-Power Operation at Commercial Nuclear Power Plants in the United States; and NUMARC 91-06, Guidelnes for Industry Actions to Assess Shutdown Management. CNS Basis Reference(s):

1. OP/1(2)/A/6150/006 Draining the Reactor Coolant System 2. AP/1 (2)/A/5500/01 0 Reactor Coolant Leak 3. OPI/OA/61001014 Penetration Control for Modes 5, 6 and NO Mode. Enclosure 4.7 Setting, Maintaining and Securing from Containment Penetration Control 4. NEI 99-01 CG1 IRP/O/AI5000/O01 Rev. 1I Page 80 of 247 ATTACHMENT 1 EAL Bases Category: Subcategory:

Initiating Condition: C -Cold Shutdown I Refueling System Malfunction 2 -Loss of Essential AC Power Loss of all but one AC power source to essential buses for 15 minutes or longer EAL: CU2.1 Unusual Event AC power capability, Table C-2, to essential 41 60V buses 1 (2)ETA and I (2)ETB reduced to a single power source for > 15 mmn. (Note 1)AND Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.Table C-2 AC Power Sources Offsite:* ATC (Train A)* SATA (Train A) (if already aligned)* ATD (Train B)* SATB (Train B) (if already aligned)Onsite:* D/G A(Train A)* DIG B (Train B)Mode Applicability: 5 -Cold Shutdown, 6 -Refueling, D -Defueled IRPI/0A/5000/O01 IRev. 1 IPage 81 of 2471 ATTACHMENT 1 EAL Bases Definition(s): SAFETY SYSTEM -A system required for safe plant operation, cooling down the plant and/or placing it in the cold shutdown condition, including the EGOS. These are typically systems classified as safety-related (as defined in 10OCFR50.2): Those structures, systems and components that are relied upon to remain functional during and following design basis events to assure: (1) The integrity of the reactor coolant pressure boundary;(2) The capability to shut down the reactor and maintain it in a safe shutdown condition; (3) The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures. Basis: The 4160 VAC System provides the power requirements for operation and safe shutdown of the plant. The essential switchgear are buses ETA (Train A) and ETB (Train B) (ref. 1).The essential buses are normally powered from the 6.9KV offsite power system through their respective 6.9KV/41 60V Normal Auxiliary Transformers (ATC & ATD). Additionally, a standby source of power to each 4160V essential bus is provided from the 6.9KV offsite power system via two separate and independent 6.9KV/4160V transformers (SATA & SATB). These transformers are shared between the two units (ref. 1, 2). However, alignment of SATA or SATB to an essential bus takes longer than 15 minutes and therefore should only be credited if already aligned.Each essential bus has a dedicated diesel generator (DIG A & DIG B) to supply an onsite emergency source of power to safe shutdown loads in the event of a loss of the normal power source or loss of off-site power. The DIGs will automatically start and tie onto the essential buses if the normal power source or off-site power is lost (ref. 1 ).This cold condition EAL is equivalent to the hot condition EAL SAI .1.This IC describes a significant degradation of offsite and onsite AC power sources such that any additional single failure would result in a loss of all AC power to SAFETY SYSTEMS. In this condition, the sole AC power source may be powering one, or more than one, train of safety-related equipment. When in the cold shutdown, refueling, or defueled mode, this condition is not classified as an Alert because of the increased time available to restore another power source to service.Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition is considered to be a potential degradation of the level of safety of the plant.An "AC power source" is a source recognized in AOPs and EOPs, and capable of supplying required power to an essential bus. Some examples of this condition are presented below.* A loss of all offsite power with a concurrent failure of all but one emergency power source (e.g., an onsite diesel generator).

• A loss of emergency power sources (e.g., onsite diesel generators) with a single train of emergency buses being fed from an offsite power source.SRP/0/A/5000/001 Rev. 1 Page 82 of 247 ATTACHMENT 1 EAL Bases Fifteen minutes was selected as a threshold to exclude transient or momentary losses of power.The subsequent loss of the remaining single power source would escalate the event to an Alert in accordance with IC CA2.CNS Basis Reference(s):

1. UFSAR Section 8.0 Electric Power 2. AP/1(2)/A/5500/007 Loss of Normal Power 3. NEI 99-0i CU2 1RPI/o100/0sooooo Rev. 1 Page 83 of2471 ATTACHMENT

1. ..EAL Bases Category:

C -Cold Shutdown / Refueling System Malfunction, Subcategory: 2 -Loss of Essential AC Power Initiating Condition: Loss of all offsite and all onsite AC power to essential buses for 15 minutes or longer EAL: CA2.1 Alert Loss of all offsite and all onsite AC power capability, to essential 4160V buses 1(2)ETA I .Deleted:, Table C-2, and 1(2)ETB for > 15 min. (Note 1)Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.* ..... Deleted: ¶Mode Applicability: Table C-2 AC Power Sources 5 -Cold Shutdown, 6 -Refueling, D -Defueled Basis: The 4160 VAC System provides the power requirements for operation and safe shutdown of the plant. The essential switchgear are buses ETA (Train A) and ETB (Train B) (ref. 1).The essential buses are normally powered from the 6.9KV offsite power system through their respective 6.9KV/4160V Normal Auxiliary Transformers (ATC & ATD). Additionally, a standby source of power to each 4160V essential bus is provided from the 6.9KV offsite power system via two separate and independent 6.9KV/4160V transformers (SATA & SATB). These transformers are shared between the two units (ref. 1, 2). However, alignment of SATA or SATB to an essential bus takes longer than 15 minutes and therefore should only be credited if already aligned.Each essential bus has a dedicated diesel generator (DIG A & D/G B) to supply an onsite emergency source of power to safe shutdown loads in the event of a loss of the normal power source or loss of off-site power. The D/Gs will automatically start and tie onto the essential buses if the normal power source or off-site power is lost (ref. 1 ).This cold condition EAL is equivalent to the hot condition loss of all offsite AC power EAL SS1.1.This IC addresses a total loss of AC power that compromises the performance of all SAFETY SYSTEMS requiring electric power including those necessary for emergency core cooling, containment heat removal/pressure control, spent fuel heat removal and the ultimate heat sink.When in the cold shutdown, refueling, or defueled mode, this condition is not classified as a Site Area Emergency because of the increased time available to restore an essential bus to service. Additional time is available due to the reduced core decay heat load, and the lower temperatures and pressures in various plant systems. Thus, when in these modes, this condition represents an actual or potential substantial degradation of the level of safety of the plant.Fifteen minutes was selected as a threshold to exclude transient or momentary power losses.IRPIOIA/5000/O01 Rev. 1 Page 84 of 247 ATTACHMENT 1 EAL Bases Escalation of the emergency classification level would be via IC CS1 or RSt.CNS Basis Reference(s):

1. UFSAR Section 8.0 Electric Power 2. AP/1(2)/A/5500/007 Loss of Normal Power 3. ECA-0.0 EP/II(2)/5000IECA-0.0 Loss of All AC Power 4. NEI 99-01 CA2 IRPIO,/Aooo0oo0 I Rev. 1 Page 85 of 2471 ATTACHMENT 1 EAL Bases Category:

C -Cold Shutdown / Refueling System Malfunction Subcategory: 3 -NCS Temperature Initiating Condition: UNPLANNED increase in NCS temperature EAL: CU3.t Unusual Event UNPLANNED increase in NCS temperature to > 200 0 F due to loss of decay heat removal capability Mode Applicability: 5 -Cold Shutdown, 6 -Refueling Definition(s): UNPLANNED-. A parameter change or an event that is not 1) the result of an intended evolution or 2) an expected plant response to a transient. The cause of the parameter change or event may be known or unknown.Basis: Several instruments are capable of providing indication of NCS temperature with respect to the Technical Specification cold shutdown temperature limit (200°F, ref. 1) including both hot leg and cold leg RTDs and core exit TICs (ref. 2, 3).In the absence of reliable NCS temperature indication caused by a loss of decay heat removal capability, classification should be based on EAL CU3.2 should NCS level indication be subsequently lost.This IC addresses an UNPLANNED increase in NCS temperature above the Technical Specification cold shutdown temperature limitand represents a potential degradation of the level of safety of the plant. If the NCS is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency Coordinator should also refer to IC CA3.A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification. This EAL involves a loss of decay heat removal capability, or an addition of heat to the NCS in excess of that which can currently be removed, such that reactor coolant temperature cannot be maintained below the cold shutdown temperature limit specified in Technical Specifications. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation. During an outage, the level in the reactor vessel will normally be maintained at or above the reactor vessel flange. Refueling evolutions that lower water level below the reactor vessel flange are carefully planned and controlled. A loss of forced decay heat removal at reduced inventory may result in a rapid increase in reactor coolant temperature depending on the time after shutdown.Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication. IRP/0/A/5000/001 Rev. 1 Page 86 of 247 ATTACHMENT 1 EAL Bases Escalation to Alert would be via IC CA1 based on an inventory loss or IC CA3 based on exceeding plant configuration-specific time criteria.CNS Basis Reference(s):

1. CNS Technical Specifications Table 1.1-1 2. CNS UFSAR Section 7,0 Instrumentation and Controls 3. API1(2)1N55001019 Loss of Residual Heat Removal System 4. NEI 99-01 CU3 IRPIOIAJ5000I100 Rev. 1 Page 87 of 247 ATTACHMENT 1 EAL Bases Category:

C -Cold Shutdown / Refueling System Malfunction Subcategory: 3 -NCS Temperature Initiating Condition: UNPLANNED increase in NCS temperature EAL: CU3.2 Unusual Event Loss of all NCS temperature and NCS level indication for > 15 min. (Note 1 )Note 1: The Emergency Coordinator should declare the event promptly upon determining that time limit has been exceeded, or will likely be exceeded.Mode Applicability: 5 -Cold Shutdown, 6- Refueling Definition(s): None Basis: Several instruments are capable of providing indication of NCS temperature with respect to the Technical Specification cold shutdown temperature limit (200°F, ref. 1) including both hot leg and cold leg RTDs and core exit T/Cs (ref. 2, 3).NCS water level is normally monitored using various instruments including NC System narrow range and wide range monitors, RVLIS, NC System sightglass, tygon tube and Pressurizer level instruments (ref. 4).This EAL addresses the inability to determine NCS temperature and level, and represents a potential degradation of the level of safety of the plant. If the NCS is not intact and CONTAINMENT CLOSURE is not established during this event, the Emergency Coordinator should also refer to IC CA3.This EAL reflects a condition where there has been a significant loss of instrumentation capability necessary to monitor NCS conditions and operators would be unable to monitor key parameters necessary to assure core decay heat removal. During this condition, there is no immediate threat of fuel damage because the core decay heat load has been reduced since the cessation of power operation. Fifteen minutes was selected as a threshold to exclude transient or momentary losses of indication. Escalation to Alert would be via IC CA1 based on an inventory loss or IC CA3 based on exceeding plant configuration-specific time criteria.CNS Basis Reference(s):

1. CNS Technical Specifications Table 1.1-1 2. CNS UFSAR Section 7.0 Instrumentation and Controls 3. AP/1(2)/A/5500/019 Loss of Residual Heat Removal System RP011I0/01Rev.

1 Page 88 of 247 ATTACHMENT 1 EAL Bases 4. OP/1 (2)/A/61 50/006 Draining the Reactor Coolant System 5. NEI 99-01 CU3 IRPIO/A150001001 Rev. I Page 89 of 247}}