Text

Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 3 of 8
	ML16071A181
Person / Time
Site:	Hatch, Vogtle, Farley
Issue date:	03/03/2016
From:	; Southern Nuclear Operating Co
To:	; Office of Nuclear Reactor Regulation
Shared Package
ML16071A108	List: ML16071A110; ML16071A126; ML16071A132; ML16071A136; ML16071A137; ML16071A140; ML16071A144; ML16071A146; ML16071A147; ML16071A149; ML16071A150; ML16071A152; ML16071A153; ML16071A158; ML16071A160; ML16071A166; ML16071A170; ML16071A174; ML16071A176; ML16071A180; ML16071A181; ML16071A184; ML16071A185; ML16071A187; ML16071A188; ML16071A193; ML16071A195; ML16071A198; NL-15-1898, Enclosure 2: EAL Deviations and Differences Maxtrix (Farley, Hatch, and Vogtle) Part 1 of 4; NL-15-1898, Enclosure 2: EAL Deviations and Differences Maxtrix (Farley, Hatch, and Vogtle) Part 2 of 4; NL-15-1898, Enclosure 2: EAL Deviations and Differences Maxtrix (Farley, Hatch, and Vogtle) Part 3 of 4; NL-15-1898, Enclosure 2: EAL Deviations and Differences Maxtrix (Farley, Hatch, and Vogtle) Part 4 of 4; NL-15-1898, Enclosure 3: Hatch EAL Calculations - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 1 of 3; NL-15-1898, Enclosure 3: Hatch EAL Calculations - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 2 of 3; NL-15-1898, Enclosure 3: Hatch EAL Calculations - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 3 of 3; NL-15-1898, Enclosure 4: EAL Verification and Validation Documents - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 1 of 6; NL-15-1898, Enclosure 4: EAL Verification and Validation Documents - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 2 of 6; NL-15-1898, Enclosure 4: EAL Verification and Validation Documents - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 3 of 6; NL-15-1898, Enclosure 4: EAL Verification and Validation Documents - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 4 of 6; NL-15-1898, Enclosure 4: EAL Verification and Validation Documents - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 5 of 6; NL-15-1898, Enclosure 4: EAL Verification and Validation Documents - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 6 of 6; NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 1 of 8; NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 2 of 8; NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 3 of 8; NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 4 of 8; NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 5 of 8; NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 6 of 8; NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 7 of 8; NL-15-1898, Enclosure 5: Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 8 of 8; NL-15-1898, Enclosure 5: Vogtle Marked-Up EAL Schemes - License Amendment Request for Changes to EAL Schemes to Adopt NEI 99-01 Rev. 6 and to Modify Radiation Monitors at Farley Nuclear Plant. Part 1 of 4; ... further results
References
	NL-15-1898
	Download: ML16071A181 (39)
	v • d • e

I-WR-CONTAINMENT BARRIER THRESHOLDS:

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 ECL from Alert to a Site Area Emergency or a General Emergency.

1. RCS or SG Tube Leakage Loss 1l.A This threshold addresses a leaking or RUPTURED Steam Generator (SG) that is also FAULTED outside of containment.

The condition of the SG, whether leaking or RUPTURED, is determined in accordance with the thresholds for RCS Barrier Potential Loss 1.A and Loss 1I.A, respectively.

This condition represents a bypass of the containment barrier.FAULTED is a defined term within the NEt 99-01 t [his determination is not necessarily dependent ,ipon entry into, or diagnostic steps within, an EOP. For example, if the pressure in a steam generator is decreasing uncontrollably

[part of the FAULTED definition]

and the faulted steam generator isolation procedure is not entered because EOP user rules arc dictating implementation of another procedure to address a higher priority condition, the steam generator is still considered FAULTED for emergency classification purposes.The FAULTED criterion establishes an appropriate lower bound on the size of a steam release that may require an emergency classification.

Steam releases of this size are readily observable with normal Control Room indications.

The lower bound for this aspect of the containment barrier is analogous to the lower bound criteria specified in IC SU3 for the fuel clad barrier (i.e., RCS activity values) and IC SU4 for the RCS barrier (i.e., RCS leak rate values).This threshold also applies to prolonged steam releases necessitated by operational considerations such as the forced steaming of a leaking or RUPTURED steam generator directly to atmosphere to cooldown the plant, or to drive an auxiliary (emergency) feed water pump. These types of conditions will result in a significant and sustained release of radioactive steam to the environment (e' dra thiis-similar to a FAULTED condition).

The inability to isolate the steam flow without an adverse effect on plant cooldown meets the intent of a loss of containment.

Steam releases associated with the expected operation of a SG power operated relief valve or safety relief valve do not meet the intent of this threshold.

Such releases may occur intenmittently for a short period of time following a reactor trip as operators process through emergency operating procedures to bring the plant to a stable condition and prepare to initiate a plant cooldown.

Steam releases associated with the unexpected operation of a valve (e.g., a stuck-open safety valve) do meet this threshold.

100 PWR.

PBA.R.ER.

THR.ESH.OLD.:

Following an SG tube leak or rupture, there may be minor radiological releases through a secondary-side system component (e.g., air ejectors, glad seal exhausters, valve packing, etc.). These types of releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category R ICs.The emergency classification levels resulting from primary-to-secondary leakage, with or without a steam release from the FAULTED SG, are summarized below.Affected SG is FAULTED Outside of Containment?

Yes No No classification No classification P-to-S Leak Rate Less than or equal to 25 gpm Greater than 25 gpm (fr--ohef Requires operation of a standby charging (makeup)pump (RCS barrier potential loss)Requires an automatic or manual ECCS (SI) actuation (RCS barrier loss)Unusual Event per SU4 Unusual Event per SU4 Site Area Emergency per FS 1 Site Area Emergency per FS 1 Alert per FA 1 Alert per FA 1 There is no potential loss threshold associated with RCS or SG Tube Leakage.Devoe~Ne~er ...A ...... g ....... pc .c .........

c ma l5 3b zcrdtc a t cpc......dmp..... z .... ......th r ' ap rcpit ..... , z .z, if i tzr.7. im...... rc may.. ., ldza ...... ...........

ri ....... z thzhd~ ... ........ .nd ? pr .,cn , 101 I'YIK tU1~ ~ I ti1.KKILK I HKLr~t1ULLra:

2. Inadequate Heat Removal There is no loss threshold associated with inadequate heat removal.Potential Loss 2.A This condition represents an IMMINENT core melt sequence whiehthat, if not corrected, could lead to vessel failure and an increased potential for containment failure. For this condition to occur, there must already have been a loss of the RCS barrier and the fuel clad barrier. If implementation of a procedure(s) to restore adequate core cooling is not effective (successful) within 15 minutes, it is assumed that the event trajectory will likely lead to core melting and a subsequent challenge of the containment barrier.The restoration procedure is considered "effective" if core exit thermocouple readings are decreasing and4Lor if reactor vessel level is increasing.

Whether or--net-the procedure(s) will be effective should be apparent within 15 minutes. The emergency director should escalate the emergency classification level as soon as it is determined that the procedure(s) will not be effective.

Severe accident analyses (e.g., NUREG- 1150) have concluded that function restoration procedures can arrest core degradation in a significant fraction of core damage scenarios, and that the likelihood of containment failure is very small in these events. Given this, it is appropriate to provide 15 minutes beyond the required entry point to determine if procedural actions can reverse the core melt sequence.lNc'*opcr Seine cite cpecific EOPs and/cr EUP ucer guidelinec m.ay establich decician making prcmpt irnpl....

tion ..... cccn ...... ratien a ctieno{'.,rs A raigf ......th For plarnts that ha-ve implemented We*ting:--" ..... G.... Emer... ..n...y o..p.....Guidelines, enter the patr.meterc and values ased in the Core Cooling Red Path..v 102

3. RCS Activity-/-Containment Radiation There is no loss threshold associated with RCS activity-I-containment radiation.

Potential Loss 3.A The radiation monitor reading corresponds to an instantaneous release of all reactor coolant mass into the containment, assuming that 20-%- tpcrccnt of the fuel cladding has failed. This level of fuel clad failure is well above that used to determine the analogous fuel clad barrier loss and RCS barrier loss thresholds.

NUREG-1228, Source Estimations During Incident Response to Severe Nuclear Power Plant Accidents, indicates the fuel clad failure must be greater than approximately 2°0%perccnt in order for there to be a major release of radioactivity requiring offsite protective actions. For this condition to exist, there must already have been a loss of the RCS barrier and the fuel clad barrier. It is therefore prudent to treat this condition as a potential loss of containment would then escalate the emergency classification level to a General Emergency.

there ic ,a cite specific analye',:

juctifyinzg ,a different -value, the reeading :ehould be gac a.nd izdine in:'entory, accocziated, -with 20% fuel cl.ad failu-re in"te the centainment

4. Containment Integrity or Bypass Loss 4.A These thresholds address a situation where containment isolation is required and one of two conditions exists as discussed below. UWere a-e reminded:

that t Ihere may be accident and release conditions that simultaneously meet both thresholds 4.A. 1 and 4.A.2.103 I'W R CU1'~I AIN~IL~ I BARRIEB ~I HRE~IrIOLD~:

4.A. 1 -Containment integrity has been lost, i.e., the actual containment atmospheric leak rate likely exceeds that associated with allowable leakage (er-sometimes referred to as design leakage).

Following the release of RCS mass into containment, containment pressure will fluctuate based on a variety of factors; a loss of containment integrity condition may (or may not) be accompanied by a noticeable drop in containment pressure.

Recognizing the inherent difficulties in determining a containment leak rate during accident conditions, it is expected that the emergency director will assess this threshold using judgment, and with due consideration given to current plant conditions, and available operational and radiological data (e.g., containment pressure, readings on radiation monitors outside containment, operating status of containment pressure control

............ sinhplified examples are provided in thc middle piping run of Figure 960-F-4!I. Taipfi-,.,, ..

are provided.

One is leakage from a penetration and the other is leakage from an in-service system valve. Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure.Another example ivoati4-.is a loss or potential loss of the RCS barrier, and the simultaneous occurrence of two FAULTED locations on a steam generator where one fault is located inside containment (e.g., on a steam or feedwater line) and the other outside of containment.

In this case, the associated steam line provides a pathway for the containment atmosphere to escape to an area outside the containment.

Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable (design) containment leakage through various penetrations or system components.

These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category R ICs.4.A.2 -Conditions are such that there is an UJNISOLABLE pathway for the migration of radioactive material from the containment atmosphere to the environment.

As used here, the term "environment" includes the atmosphere of a room or area, outside the containment, that may, in turn, communicate with the outside-the-plant atmosphere (e.g., through discharge of a ventilation system or atmospheric leakage).

Depending upon a variety of factors, this condition may or may not be accompanied by a noticeable drop in containment pressure.R-e-e-toSec a simplified example in the top piping run of Figure 9)6-F-4 I. l4i ,:_:.Imp,.ivid example, tl'he inboard and outboard isolation valves remained open after a containment isolation was required (i.e., containment isolation was not successful).

There is now an UNISOLABLE pathway from the containment to the environment.

The existence of a filter is not considered in the threshold assessment.

Filters do not remove fission product noble gases. In addition, a filter could become ineffective due to iodine and/or particulate loading beyond design limits (i.e., retention ability has been exceeded) or water saturation from steam/high humidity in the release stream.104 Leakage between two interfacing liquid systems, by itself, does not meet this threshold.

R-e-f~e--A simplified example is in the bottom piping run of Figure 46-F41. t-R thL= zimp~ificd exa-mplc, !l in an RCP seal cooler is allowing radioactive material to enter the Auxiliary Building.

The radioactivity would be detected by the Process Monitor. If there is no leakage from the closed water cooling system to the Auxiliary Building, then no threshold has been met. If the pump or system piping developed a leak that allowed steam/water to enter the Auxiliary Building, then threshold 4.B would be met. Depending upon radiation monitor locations and sensitivities, this leakage could be detected by any of the four monitors depicted in the figure and cause threshold 4.A. i to be met as well.Following the leakage of RCS mass into containment and a rise in containment pressure, there may be minor radiological releases associated with allowable (design) containment leakage through various penetrations or system components.

Minor releases may also occur if a containment isolation valve(s) fails to close but the containment atmosphere escapes to a closed system. These releases do not constitute a loss or potential loss of containment but should be evaluated using the Recognition Category R ICs.The status of the containment barrier during an event involving steam generator tube leakage is assessed using loss threshold 1.A.Loss 4.B Containment sump, temperature, pressure and/or radiation levels will increase if reactor coolant mass is leaking into the containment.

If these parameters have not increased, then the reactor coolant mass may be leaking outside of containment (i.e., a containment bypass sequence).

Increases in sump, temperature, pressure, flow and/or radiation level readings outside of the containment may indicate that the RCS mass is being lost outside of containment.

Unexpected elevated readings and alarms on radiation monitors with detectors outside containment she*ld-\x ill be corroborated with other available indications to confirm that the source is a loss of RCS mass outside of containment.

If the fuel clad barrier has not been lost, radiation monitor readings outside of containment may not increase significantly.,-

th lowever, other unexpected changes in sump levels, area temperatures or pressures, flow rates, etc. should be sufficient to determine if RCS mass is being lost outside of the containment.the simplilied example in the middle piping run of Figure leak has occurred at a reducer on a pipe carrying reactor coolant in the Auxiliary Building.

Depending upon radiation monitor locations and sensitivities, the leakage could be detected by any of the four monitors depicted in the figure and cause threshold 4.A. 1Ito be met as well.To ensure proper escalation of the emergency classification, the RCS leakage outside of containment must be related to the mass loss that is causing the RCS loss and/or potential loss threshold 1I.A to be met.DPWRl[ CONTAI.MENT lllt'"I BARR[IER IH EtllU,,lLDl1:2 105 Potential Loss 4.A If containment pressure exceeds the design pressure, there exists a potential to lose the containment barrier. To reach this level, there must be an inadequate core cooling condition for an extended period of time; therefore, the RCS and fuel clad barriers would already be lost. 4z1*s4'[his threshold is a discriminator between a Site Area Emergency and General Emergency since there is now a potential to lose the third barrier.Potential Loss 4.B The existence of an explosive mixture means, at a minimum, that the containment atmospheric hydrogen concentration is sufficient to support a hydrogen burn (i.e., at the lower deflagration limit). A hydrogen bum will raise containment pressure and could result in collateral equipment damage leading to a loss of containment integrity.

It therefore represents a potential loss of the containment barrier.Potential Loss 4.C This threshold describes a condition where containment pressure is greater than the setpoint at which containment energy (heat) removal systems are designed to automatically actuate, and less than one full train of equipment is capable of operating per design. The 15-minute criterion is included to allow operators time to manually start equipment that may not have automatically started, if possible.

This threshold represents a potential loss of containment iii-lth~ccausc containment heat removal/depressurization systems (e.g., containment sprays, ice condenser fans, etc., but not including containment venting strategies) are either lost or performing in a degraded manner.The Ite ......~ pr........

is- the ......in..n. de~ign pressure......e that ha. im.. plem .n... Wcstinghcuec O;;,nere Group Emerge.ncy Response~6eHfie5~preeeurc value in retentiat LZZ~ 'I ..~ ic mat ucco icr me canmamment itea Yam. II tnc Lontainment tz~ I contains mare tnan one t~co Patn ~uc ta atner dependenciec (e.g.. etatuz of containment icclatian), enter the highezt containment pre~eure ~'aluc ~hawn on the tree. Thb is ~~ically the cantnir.ment deIgn prc~urc.PWR CONTAINMENT BARRIER TIIRESIIOLDSz 106 Petential Less 1.B 5.

uppertX a hydregen bu.rn (i.e., the !lewer deflagratien limit). A ceneu-rent available in the Centrel PRe, m....t..r...h .st ......'i prssr ...... nt-vc:-alue that actuatscontainm.

nt ..... ur...c.ntr..

can alec be enter'e (e.g.. a eantainment spray fieaw rate less th-a a certain value).Other Indications Not aipplicablc ( includedt fbi iumhciinu consistent?)

This subeategory addresses ether site specific threshalds thai may be !ineluded teJ indicate characteristics not considere in the generic Less and/er Ptntia Les I If site emergency.

oFp.-ating prac, dures pr...ide for of' the .. cen ..i.... as a me..s I.MMINENT.

Centai:nment' -entring as part e~f rececve aetiens is classified in accordanceCONTA!NM'ENT ARRIER. THP.ESHOLDS, 107 Any addd shouald apprzx.'irnatzly tha t.hrca tc the 6. Emergency Director Judgment Loss 6.A This threshold addresses any other factors :h-tay-a;'be-used by the emergency director in determining whether the Containment Barrier is lost.Potential Loss 6.A This threshold addresses any other factors :ha: may-be-.used by the emergency director in determining whether the containment barrier is potentially lost. The emergency director shtldx.ii also consider whether or not to declare the barrier potentially lost in the event that barrier status cannot be monitored.108 Figure 96-F-4 : PWR Containment Integrity or Bypass Examples Effluent 7. .* rlrs fo Auxiliary Building Monit Vent RCP Seal Cooling 109 J.O7HAZARDS AND OTHER CONDITIONS AFFECTING PLANT SAFETY ICS/EALS GENERAL SITE AREAALTUNSLEVT EMERGENCY EMERGENCYALRUNSLEVT HGI HOSTILE 11S1 HOSTILE HA1 HOSTILE HUI Confirmed ACTION resulting in ACTION within the ACTION within the SECURITY loss of physical control PROTECTED AREA. OWNER CONDITION or threat.of the facility.

Op. Modes: All CONTROLLED AREA Op. Modes: All Op. Modes:" All or airborne attack threat within 30 minutes.______________Op.

Modes: All HU2 Seismic event greater than OBE levels.__________________________Op.

Modes: All HU3 Hazardous event.Op. Modes: All HU4 FIRE potentially degrading the level of safety of the plant.______________Op.

Modes: All HAS Gaseous release impeding access to equipment necessary for normal plant operations, cooldown, or shutdown.Op. Modes: All H1S6 Inability to HA6 Control Room control a key safety evacuation resulting in function from outside transfer of plant control the Control Room. to alternate locations.

Op. Modes: All Op. Modes: All HG7 Other conditions HS7 Other conditions HA7 Other conditions 11U7 Other conditions exist which in the exist which in the exist which in the exist which in the judgment of the judgment of the judgment of the judgment of the emergency director emergency director emergency director emergency director warrant declaration of a warrant declaration of a warrant declaration of warrant declaration of a General Emergency.

Site Area Emergency.

an Alert. Ot![.Op. Modes: All Op. Modes: All Op. Modes: All Op. Modes: All 110 HGI ECL: General Emergency Initiating Condition:

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

All Emergency Action Levels: (I) a. A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the site security fo~rcethe (sit. itic .eurity zhifl AND b. EITHER of the following has occurred: 1. ANY of the following safety functions cannot be controlled or maintained.

Reactivity control* Core cooling-fWR

RCS heat removal OR 2. Damage to spent fuel has occurred or is IMMINENT.Basis: I lOS] I1l At lCION: An act tovv ard a nuclear power plant (NIP) or its personnel that includes the use of' violentlforce to destroy cqtuiputcnt, take lIlOS'I AGES, and/or intimidate the licensee to achieve an end. Ilhis inchludes attack b) air. land, or w~ater usinvt guns. explosives.

I'R)JEC [lll+s, vehicles, or other devices used to deliver destructive force. Other acts that satisfy, the overall intent may hc included.

I lOS I lLE A( I[ION should not be construed to include acts of cMivi disobedience or feclonious acts that are not part of a concerted attack on the NIPP. Non-terrorism-based LAI~s should be used to address such activ ities) i.e., this may include violent acts bortvvten individuals in the owner controlled area (OCAM).IMMINE NT: !The trajectory ofe'ecnts or conditions is stuch that an EAI wvill be met within a relatively short period of tinte regardless of mitigation or corrective actions.PRO ,AREA (PAI: The area that ettcompasses all controlled areas vvithin the securitx protected area fence.This IC addresses an event in which a HOSTILE FORCE has taken physical control of the facility to the extent that the plant staff can no longer operate equipment necessary to maintain key safety functions.

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

111 Timely and accurate communications between Security shift supervision and the control room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program_].

Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.The. (cite "pefcccrt hf u e iin "ic th..title, ......n , ........ .in.... i.. i... u.. .l reep ....b...f.cue......

f t;.¢he ... chift cuity. f.r..net incaoracrtc Seaurto-, cencitiv'e infcreraaticn.

Thic i.nclu-des information that may2, be threat locatien.

Security .....iv information:_

cheu,.d be ...ntaind !n ..... public de........

cuach no the Security' Plan.With du o.....d.rat...

en g ... n +to .the .. abv ....elopr n..t.e, Ec ma:... contain alpha or numbc:red referenceacto eelected e. .ants d..coribed in the Security Plan and implementing proaedurec.

Suc.h ref.......

chould not a...... niza., decrit...

o event. F cr.....e,+ an EA may b.. v ..... oca ..S.curit...

vent ..... fl5 or ic reported by' the (cite speci.i cecurity shift+ sueriion).

",/LLL ,".ccignmen+:+t

.3. I .1..U 112 HG7 ECL: General Emergency Initiating Condition:

Other conditions exist which in the judgment of the emergency director warrant declaration of a General Emergency.

Operating Mode Applicability:

All Emergency Action Levels: (1) Other conditions exist which in the judgment of the emergency director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility.

Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels offsite for more than the immediate site area.Basis: IH()S' II AC F ON: An act to,, ard a nuclcar proxer planto tNPP) or its personncl that includcs thc usc of x jolent lbrcc to destroy equiprment, take I lOSI A(iLS. and/or intimidatc thc licenscc to achievec an cnd. [his includes attack b3 air. land. or using guns. explosivcs.

PROJEC' [I'lls. vehicles.

or other devices used to deliver destructive tbrcc. Othcr acts that satisfy thc o erall intent may bc included.

l10 fSI'LlE A(CI[ION should not be construed to include acts of civil disobcdience or felonious acts that arc not part ot a concerted attack on thc NPP. Non-tcrrorism-bascd EAI ,s should hc" used to addrcss such acti'.ities tice., this may includc violcnt acts bet'.'een indi' iduals in the owncr controlled area (0(A 1).IMMIINEN 1: 1lhe trajcctory of evcnts or conditions is such that an LAL wvill bc mct within a relativel\

short period of time rcgardless of mitigation nr con'ective actions.This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist whibthat are believed by the emergency director to fall under the emergency classification level description for a General Emergency.

113 HS1 ECL: Site Area Emergency Initiating Condition:

HOSTILE ACTION within the PROTECTED AREA.Operating Mode Applicability:

All Emergency Action Levels: (I) A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the site security spezific accurity' os..ft .......iion., Basis: I IOS I ILL AC [ItON: An act toxxard a nuclear power plant (NPP) or its personnel that includes the use of loree to destrox equipment.

take Il( )S IA(;iLS, and/or intimidate the licensee to achieve an end. [his includes attack by air, land, or \sater using guns. explosiv es, P~RO.ILC [Ill s, vehicles, or other des ices used to delix er destructive force. Other acts that satisfx the overall intent ma') he included.

[l()S ItILE ACI IO)N should not he construed to include acts of cix il disobedience or felhnious acts that are not par of a concerted attlack on the NPP. Non-terrorism-based liAls should be used to address such activities (i.e.. this max include violent acts bctxxccn individuals itt the owner cotttrolled area IO(CA)t.PR(l)I/ ARI'A (PA): ['he area that encompasses all controlled areas xxitltin the securitx protected area.a fence.This IC addresses the occurrence of a HOSTILE ACTION within the PROTECTED AREA (PAl}. This event will require rapid response and assistance due to the possibility for damage to plant equipment.

Timely and accurate communications between Security shift supervision and the control room is essential for proper classification of a security-related event.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].As time and conditions allow, these events require a heightened state of readiness by the plant staff and implementation of onsite protective measures (e.g., evacuation, dispersal.

or sheltering).

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

This IC does not apply to a HOSTILE ACTION directed at an ISFSI PROTECTED AREA located outside the plant PROTECTED AREA (PA); such an attack should be assessed using IC HA1. It also does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc.Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.114 Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.Escalation of the emergency classification level -;euld-be-v4auses IC HG 1.I9e...de... The (site+ specific';

......t s< hi+ft is the title cf the aro; -+I.+ I.... shftidiiua esasil forcf Phe .... hift .....ui+ty forc...E:;mergenypln s aI ... ;Implementing

.J,+ procedures 13r pbcdacuments;+

thcrcfcre EA2 s s hauld.....a. au ta ....... al .d....... .. u. h as... t.... arti..ular............ng a specific threat or threat !ccatieon.

Security sensitie infor,".atian be ccntained in nen public doceuments With due .....ider....i:n giv..... t.a the ... d..... ,.. ......, may ....nctain alpha ar numbered referen~c.Ao tc J~ctd evecnts described in the Security Plan and accia~ted implementing e...ple, an may be worded as "Securit e..ent f2, #5 cr/19 is reported by the (site. specif.c See++, the relate Deveope Not.. e in Apendix .................

fe guidance....the development .at a scheme definiticn far the PROTECTED AP.EA.ECL Assienment Attributes:

3.l.3.D 115 HS6 ECL: Site Area Emergency Initiating Condition:

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

All Emergency Action Levels: Note: The emergency director \v-xilI declare the Site Area Emergency promptly upon determining that '(zie zpzzifi% num-xbzr af I5 minutes-)

has been exceeded, or will likely be exceeded.(1) a. An event has resulted in plant control being transferred from the control room to 45ite -speeifiethc remote shutdown panels an:d Iccal contrcl ztaticn4).

AND b. Control of ANY of the following key safety functions is not reestablished within ('it ......i : nu ..... at-^ 15 minutes-).

Reactivity control* Core cooling-f4zlWR-

RCS heat removal Basis: This IC addresses an evacuation of the control room that results in transfer of plant control to alternate locations, and the control of a key safety function cannot be reestablished in a timely manner. The failure to gain control of a key safety function following a transfer of plant control to alternate locations is a precursor to a challenge to one or more fission product barriers within a relatively short period of time.The determination of whether Oi'-het-"control" is established at the remote safe shutdown location(s) is based on emergency director judgment.

The emergency director is expected to make a reasonable, informed judgment within site Tzifeic time fcr tranzfer)

I5 minutes ats to whether or'-ae~he operating staff has control of key safety functions from the remote safe shutdown location(s).

Escalation of the emergency classification level w.eu.ldc-b'-,4uses IC FGI or CGlI.Tha 3pzcifiz r...................

aca ac trz zt... .. .. .. .... .'.... .... th ......and .......The "sita pcVcific numb. mintes ..... tha time*; in whi:ch plant centrel must be (ar is ....... , 116 pcnzd may bc u~cd with apprcpriatz b~i~'ju~titic~icn.

4 h LCL A~Ignm~r~t

'Atriflutc~:

I. 1.J.B 117 HS7 ECL: Site Area Emergency Initiating Condition:

Other conditions exist which in the judgment of the emergency director warrant declaration of a Site Area Emergency.

Operating Mode Applicability:

All Emergency Action Levels: (1) Other conditions exist which in the judgment of the emergency director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts, (:1) toward site personnel or equipment that could lead to the likely failure of or, 42) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.Basis: ttlOS FlIIF: ACTION: An act toward a nuclear p~oxcr plant (NPP') or its personnel that includes thc use of jiolent foree to destroy equipment.

take I lOS I1A~iLS. and/or intimidate tthe licensee to achieve an end. This includes attack by air. land. or water using guns. explosix es, I'ROjltj;'+IFlls.

\ ehiclcs, or other des ices used to delivcr dcstructixc force. Other acts that satisfx the overall intent may be included.

I-lOS IILL ACTION should not be" construed to include acts of civil disobcdience or kilonious acts that are not pall ot a conccrted attack on thle NPP. Non-tcrrorism-bascd BAI~s should be used to address such activities (i.e.. this mas inchudcacts betwccn indiv iduals in the ow+ner controllcd area (0(A)).This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist whi-h-that are believed by the emergency director to fall under the emergency classification level description for a Site Area Emergency.

118 HA1 ECL: Alert Initiating Condition:

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

All Emergency Action Levels: (1 or 2)(1) A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the site security zpecifiz security shift (2) A validated notification from NRC of an aircraft attack threat within 30 minutes of the site.Basis: t lOSIHlIE, AC I ION: An act towaard a nulclea'r po\\,er plant tN!PP) or its personnel that includes the use of violent force to destroy equipment, take ttOSTAGiES.

andior intimidate the licensee to achieve an end. T'his includes attack by' air, land. or water using guns, explosives.

PROJ ECI'II,Es.

vehicles, or other devices used to deliver destructive force. Other acts that satisfy' the overall intent may he included.

IIOS'HIE ACTION should not he construied to include acts of ci, il disobedience or felonious acts that arc not part of a concerted attack on the N PP. Non-terrorism-hased EAI~s should be used to address such activities (i.e.. this max include violent acts betx\.een indiv iduals in thje owner controlled area (O)CA)).OWNER CONiRO1LI.E)

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

The Alert declaration will also heighten the awareness of offsite response organizations, allowing them to be better prepared should it be necessary to consider further actions.This IC does not apply to incidents that are accidental events, acts of civil disobedience, or otherwise are not a HOSTILE ACTION perpetrated by a HOSTILE FORCE. Examples include the crash of a small aircraft, shots from hunters, physical disputes between employees, etc.119 Reporting of these types of events is adequately addressed by other EALs, or the requirements of 10 CFR § 73.71 or 10 CFR § 50.72.EAL # 1 is applicable for any HOSTILE ACTION occurring, or that has occurred, in the OWNER CONTROLLED AREA (OCA). This includes any action directed against an ISFSI that is located outside the plant PROTECTED AREA (PA t.EAL #2 addresses the threat from the impact of an aircraft on the plant, and the anticipated arrival time is within 30 minutes. The intent of this EAL is to ensure that threat-related notifications are made in a timely manner so that plant personnel and OROs are in a heightened state of readiness.

This EAL is met when the threat-related information has been validated in accordance with slal ion ... .. rc~stoe .pei.. preed, e)The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft.

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

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.Escalation of the emergency classification level -we',i! be :'auscs IC HSI.ad-vantogecue to a potential adversary, su-ch ac the particulars ceneer:ing a specific thrat or numbered referececs te cete e... ent.... described in the Security Plan ......iate (site specific security ......

See the related De-velpecr Note in Appendbx B, Definitien.s, for guidance en the 120 ECL Aaaign.mznt Attrib"utz:

3.'.2.D 121 HA5 ECL: Alert Initiating Condition:

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

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

(1) a. Release of a toxic, corrosive, asphyxiant or flammable gas into any of4he fel4owisi F'able Ill plant rooms or areas: Table II I Mlode Room Name Room Number Electrical Penetration Room 334. 333, 347/2334. 2333. 2347 I lalhvax Outside Filter Room 312. 332/~ MCC(VIM ah.~ 2312, 2332 Sample Room and ria Cllbs323, 324 /2323. 2324 Sample Room and Primary Cl IM lahs 323, 324;/4 2323. 2324 RRil) !lx Room, 128/2128 idn Lid AND b. Entry into the room or area is prohibited or impeded.Basis: This IC addresses an event involving a release of a hazardous gas that precludes or impedes access to equipment necessary to maintain normal plant operation, or required for a normal plant cooldown and shutdown.

This condition represents an actual or potential substantial degradation of the level of safcy' ef he-plantplanl safety.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 gaseous release. The emergency classification is not contingent upon whether entry is actually necessary at the time of the release.Evaluation of the IC and EAL do not require atmospheric sampling; it only requires the emergency director's judgment that the gas concentration in the affected room/area is sufficient to preclude or significantly impede procedurally required access. This judgment may be based on a variety of factors including an existing job hazard analysis, report of ill effects on personnel, 122 advice from a subject matter expert or operating experience with the same or similar hazards.Access should be considered as impeded if extraordinary measures are necessary to facilitate entry of personnel into the affected room/area (e.g., requiring use of protective equipment, such as SCBAs, that is not routinely employed).

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

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

The access control measures are of a conservative or precautionary nature, and would not actually prevent or impede a required action.An asphyxiant is a gas capable of reducing the level of oxygen in the body to dangerous levels.Most commonly, asphyxiants work by Inefey-displacing air in an enclosed environment.

This reduces the concentration of oxygen below the normal level of around 19%- pei'cent, which can lead to breathing difficulties, unconsciousness or even death.This EAL does not apply to firefighting activities that automatically or manually activate a fire suppression system in an area.Escalation of the emergency classification level --eu.l be Recognition Category R, C or F ICs.The ' ..., ^, l,,ep.e,-,.

.. , __; -N.... ..: ... c '/"e *.... ..Thc uoic opcifcls -- pln.t, r, m r ra it n relat..d..m.d......li..bilit...id.ntifi..d" ohul ze~ythocron o aec ha cnai eupmntwhc rqureamaua'123 cto rn~pact tzyzna mat alrcaay wi~'za ry ccnnIcaI ~pc~lricaticn~

at mn~ mime ci inc ~'cnm.ECL Aci:x.mzznt 3.i.2.B 124 HA6 ECL: Alert Initiating Condition:

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

Operating Mode Applicability:

All Emergency Action Levels: (1) An event has resulted in plant control being transferred from the control room to (ie speilthe remote shutdown panels 13za1 czntrz! statical).

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

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

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

Escalation of the emergency classification level w:,eui14be-:4auscs IC HS6.125 HA7 ECL: Alert Initiating Condition:

Other conditions exist which in the judgment of the emergency director warrant declaration of an Alert.Operating Mode Applicability:

All Emergency Action Levels: (1) Other conditions exist which, in the judgment of the emergency director, indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.Basis: IItO)S]I IUt ACT ItI)N: An act toxxard a nuclear po'~er phlan tNPP~) or its personnel that includcs the usc of \,iolent three to dcstroy equipment.

take I IOS'IAi AS. and/or intirnidatc the licensec to achicxc an cnd. [his includes attack b3 air. land, or xxater using guns, explosives.

PROJE/C [IllFs. vehicles.

or other devices used to delivcr destructive three. Othter acts that sat isfx thc oxverall i ntent max hc. included.

I lOS~ltE AC'I[ION should not hc construed to include acts of cix ii disobedience or tdhnious acts that are not part of a concerted attack on the NI'P. Non-tcrrorisii-hased LAI~s should he used to address such activities (i.e., this may include violentt acts between individuals in dhe owner controlled area QOCA9).This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist whieh-that are believed by the emergency director to fall under the emergency classification level description for an Alert.126 HU1 ECL: Notification of Unusual Event Initiating Condition:

Confirmed SECURITY CONDITION or threat.Operating Mode Applicability:

All Emergency Action Levels: (1 or 2 or 3)(I) A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the site security lbrcc(sitc sp"if" .......y : ..hift .........(2) Notification of a credible security threat directed at I'.(3) A validated notification from the NRC providing information of an aircraft threat.Basis: SlI1(/RI I1Y ('ONI)I [II(N: Any Sccurity [.xent as listed in thle approxed sccurity contingency plan that constitutcs a threaftcompronmise to sice secuirit).

thrcaturisk to site pcrsonnel.

or a potential degradation to thc level of salaryv of thc plant. A SI-Cti RI INY CON DI fION docs not in\ olve a I It()S Ill .l ACi ION.I It()STII l! ACIION: An act toxxard a nuclear power' plant (N IPP or its personnel that includes thc usc o1 \iolent liwcc to destre? equipment, take tiels fAtI:S, and/or intimidate the licensee to achievec an end. I his includes attack b) air, land, or xx.ater using guns. explosi'.cs.

lPROJtEC IlI .s, vehicles.

or other devices used to deliver destructive force. Other acts that satisf\ thc o~ erall intcnt tnay hc included.

I lOS fILE AC [ION should not hc construed to include acts of civil disobedicnce or felonious acts that arc not part oF a concerted attack on thc N PP. Non-tcrroristn-bascd L!AI ,s should he uscd to addrcss such acthiviics ti.e'., this max includc j olent acts Ihth\ecn indixiduals in thc owxner controlled area O(CA t).This IC addresses events that pose a threat to plant personnel or SAFETY SYSTEM equipment, and t-iis-represent a potential degradation in the level of plant safety. Security events which do not meet one of these EALs are adequately addressed by the requirements of 10 CFR § 73.71 or 10 CFR § 50.72. Security events assessed as HOSTILE ACTIONS are classifiable under ICs HAl, HSl and [1G1.Timely and accurate communications between Security Shift Supervision and the Control Room is essential for proper classification of a security-related event. Classification of these events will initiate appropriate threat-related notifications to plant personnel and ORes.Security plans and terminology are based on the guidance provided by NEI 03-12, Template for the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan [and Independent Spent Fuel Storage Installation Security Program].EAL #1 references site security three (site specific shift because these are the individuals trained to confirm that a security event is occurring or has occurred.

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

127 EAL #2 addresses the receipt of a credible security threat. The credibility of the threat is assessed in accordance with stat ion proccduric:,(sit spzcf pccLcdu.....

.EAL #3 addresses the threat from the impact of an aircraft on the plant. The NRC Headquarters Operations Officer (HOO) will communicate to the licensee if the threat involves an aircraft.The status and size of the plane may also be provided by NORAD through the NRC. Validation of the threat is performed in accordance with station procedures(s'tc spccific .r... u,,).Emergency plans and implementing procedures are public documents; therefore, EALs should not incorporate security-sensitive information.

This includes information that may be advantageous to a potential adversary, such as the particulars concerning a specific threat or threat location.

Security-sensitive information should be contained in non-public documents such as the Security Plan.Escalation of the emergency classification level w,-eul.: be i.'auscs IC HAl.superisiaen cf the on shift securi.ty force.The (site specific precedure) is the pr..d... s used .. by, Centrel Ree... Scc....i:y ersc.... tg ....... c i a stn:a!a-;eurt, threat is rcbl, an t.. .aliat...r...

ipt ef aircraft threat e such as the Seuri'ty Plan.With du ......d rat... n gi-ven te -.th ....c de-velepcr nete, EAL may ......a.. alpha er numbcred.refcrcnc..,te

.,e.eSted

..... n dar.... i : t hc Security*

Plan .. an ...sseciated implementing procedures.

Su.ch mferences sah'uld net eenmin a recognizable dcescription ef the event. For c~spl ... anEA m: be....d as "Securir5 cnt #2. #5 er #9 is ep-t~ed by thc (sit...pecific ISUL Asslgnmcnt

/'dtrltutes: .J.I2.P.128 HU2 ECL: Notification of Unusual Event Initiating Condition:

Seismic event greater than OBE levels.Operating Mode Applicability:

All Emergency Action Levels: lbI Seismic event greater than Operating Basis Earthquake (OBE) as indicated by seismic switch activation usith the seismhic s~stem computer indicating ElIllIER of the followving:

Basis: This IC addresses a seismic event that results in accelerations at the plant site greater than those specified for an Operating Basis Earthquake An earthquake greater than an OBE but less than a Safe Shutdown Earthquake (SSE)8 should have no significant impact on safety-related systems, structures, and componentsi-, hi towever, some time may be required for the plant staff to ascertain the actual post-event condition of the plant (e.g., performs walk-downs and post-event inspections).

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

Depending upon the plant mode at the time of the event, escalation of the emergency classification level wel--ul be-.'4auscs IC CA6 or SA9.compcsr.entc

":.ust bz design~ed tc~ re-.=ain f'-nctizn:al.

129 1ndicatian~

d ~rib.A in th~ EAL hculd bc lirnitcd t~ thcx~ that ~ irnmcdiat~Ay availablz tc Cantrzl Rzcm p~rcnr.cl and which can bc rcadilya c~cd. Indicaticn~

avai!ablc 3ut5idc thc Ccntrcl Rccrn and/zr which rcguirc lcngthy timc~ L. ~ (.g.. przcczing cf scratch platcs cr r~ccrdcd data) shculd nct bc usc!. Tk gcal is tz spccify indicatians that can bc ass~sscd within 15 mir.utcs cf thc actual cr suspcctcd scismic cvcnt.Far sitcs that dc nat ha~c rcadily assassablc OBE indicatiens within the Central Reem.de~'clcpers sheuld use the follewing alternate EAL (Cr similar werding).(I) a. Central Ream persennel feel an actual er potential seismic v.ent.AND b. The eccurrence af a seismic event i~ cenfirmed in manner deemed opprepriate by the Shift Manager er Emergency Directer.1k EAL 1.b statcment is included to ensure that a dec!araticn dees nct result frcm felt vibratizr.s caused by a r.zn seismic source (c.g.. a drepped heavy laad). The Shift Managac er Emcrgency Dircctzr may sack c~temal vcrificatian if dccmed appropriate (e.g., a call to the USGS, chcck internet news scurces, ctc.); hcwevcr, the verification actien must net preeludc a timcly emergency declaratien.

It is recegnized that this alternate EAL werding may cause a sitc te declare ar. Unusual Evcnt whilc anether site, similarly affected but with readily assessable ORE indicatiens in thc Centre! Reem, may net.The above altcmate warding may al bcu dt d'elepaeempensator~'EAL for use during periods when a seismic monitoring systcm capable ef detecting an ORE is cut ef sen.ice for maintenanec or repair.EUL Assienment Attr:butes:

.3.1.1 .A 130 r HU3 ECL: Notification of Unusual Event Initiating Condition:

Hazardous event.Operating Mode Applicability:

All Emergency Action Levels: (! or 2 or 3 or 4 or 5)Note: EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.(I) A tornado strike within the PROTECTED AREA.(2) Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component needed for the current operating mode.(3) Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).(4) A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.(5) Sustained hurricane th~ree tgreater than 74 mph Iborecast to he at the plant site in thc n tforho urs. (St ... pccific .........natur .l ..........

g.cal ......d .......Basis: IR()ROII C ITD A RI A (PA): I he area that e all cont rolled areas the security protected area t~ncc.SAFET Y SYS I tM: A s~stem required lor saf.c plant operation.

cooling down the plant antd/or placing it in the cold shutdoxsn condition.

the FCCS. Ilhese are t~ pical Iy s\ stems classified as safet\-related.

This IC addresses hazardous events that are considered to represent a potential degradation of the level of plant safety-of-the-pleat.

EAL # 1 addresses a tornado striking (touching down) within the PROTECTED AREA (PA).EAL #2 addresses flooding of a building room or area that results in operators isolating power to a SAFETY SYSTEM component due to water level or other wetting concerns.

Classification is also required if the water level or related wetting causes an automatic isolation of a SAFETY SYSTEM component from its power source (e.g., a breaker or relay trip). To warrant classification, operability of the affected component must be required by Technical Specifications for the current operating mode.EAL #3 addresses a hazardous materials event originating at an offsite location and of sufficient magnitude to impede the movement of personnel within the PROTECTED AREA (P)A).131 EAL #4 addresses a hazardous event that causes an on-site impediment to vehicle movement and significant enough to prohibit the plant staff from accessing the site using personal vehicles.Examples of such an event include site flooding caused by a hurricane, heavy rains, up-river water releases, or dam failure, etc., or an on-site train derailment blocking the access road.This EAL is not intended to apply to routine impediments such as fog, snow, ice, or vehicle breakdowns or accidents, but rather to more significant conditions such as the Hurricane Andrew strike on Turkey Point in 1992, the flooding around the Cooper Station during the Midwest floods of 1993, or the flooding around Ft. Calhoun Station in 2011.EAL #5 addresses phenomena of the hurricane based on the severe mitigation procedure.

(,site ,zpecifi.c ,ccip....

n).Escalation of the emergency classification level weutd-bei8 based on ICs in Recognition Categories A, F, S or C.location and': chararictie;:c..

enable prompt dcfiniticn and ef cempeneatory ar co:rrective meazurec no"nereae in rick to the public.EAi+ c... Evnt of less;er impact .....d be cx+pee t.. cauc......

onl ..mall and ,-ai ,,!zed d.amz.agc.

The consequence~s from these typcc of events a.re adcguately, an:d addrcssed in accorda~ncc with Technical Spccficationc.

In addition.-

h" oc..urren.e or eff.ct.....h...

en ECL Accioment ,A,,tr.ibute~s:

3I.1.1 , and 3.1.1.C 132 HU4 ECL: Notification of Unusual Event Initiating Condition:

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

All Emergency Action Levels: (1 or 2 or 3 or 4)Note: The emergency director declare the Unusual Event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.

I (I) a. A FIRE is NOT extinguished within 15-minutes of ANY of the following FIRE detection indications:

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

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

Field verification of a single fire alarm AND b. The FIRE is located within ANY af the faollewing plant I able 11t2 rooms or areas.1,112 ~n221fI2 WA ai olani rqCm:; Cr areW;, (2) a. Receipt of a single fire alarm (i.e., no other indications of a FIRE).AND b. The FIRE is located within ANY ef the fcl"cwir-g plnt .... 1. rom r re........p. ifie.....

efaplant12 rooms oraareas AND c. The existence of a FIRE is not verified within 30-minutes of alarm receipt.(-2-)3) A FIRE within the plant PkOIl'lI5 I1E1), ARI, or ISFSI [fer;,c.:t.v vit!: an !SFSI c:;ideplant Precected Arce.] PROTECTED AREA not extinguished within 60-minutes of the initial report, alarm or indication.

f.-)(4) A FIRE within the plant PR( I or ISFSI

l'it anr ISFSlcau~ldc t!e Prateetcd,.lre.]

PROTECTED AREA that requires fire fighting support by an offsite fire response agency to extinguish.

Table 112 A\uxiliary Building tDicese Generator Service Water Intake Structure (SVWISt C 7ontainnment 133 Basis: 1 11(1 (Cnmbustion charatctrized by heat and light. Sources of smoke such as drise belts or oxerheated e lectricall equipment do not constitute F IRtIS. Obhserxation of flame is prefibrrcd hut is NOTi required if large quantities of stuoke and heat are observed.PR( I LCTEDItI ARt'A (PA): I he area that encoifpasses all controlled areas w~ithin the security protected area t~zncc.This IC addresses the magnitude and extent of FIRES that may be indicative of a potential degradation of the level of plant safety-e~f hepla,'.EAL # 1 The intent of the 15-minute duration is to size the FIRE and to discriminate against small FIRES that are readily extinguished (e.g., smoldering waste paper basket). In addition to alarms, other indications of a FIRE eould-einclude a drop in fire main pressure, automatic activation of a suppression system,-et.

Upon receipt, operators will take prompt actions to confirm the validity of an initial fire alarm, indication, or report. For EAL assessment purposes, the emergency declaration clock starts at the time that the initial alarm, indication, or report was received, and not the time that a subsequent verification action was performed.

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

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

EAL #3 In addition to a FIRE addressed by EAL #1 or EAL #2, a FIRE within the plant PROTECTED AREA (PA) not extinguished within 60-minutes may also potentially degrade the level of plant safety. This basis extends to a FIRE occurring within the PROTECTED AREA {lPA\ of an 134 ISFSI located outside the plant PROTECTED AREA (PA). [Sc: .tccfor p'cas w.'th an S !G :,'wdct plant Prate~tgcd Arcal]EAL #4 If a FIRE within the plant or ISFSI [,b, .... t:h ans !SFSI o.:jtidc r.' ;p!a.n: Prorc.ctdd, !rea.]PROTECTED AREA is of sufficient size to require a response by an offsite firefighting agency (e.g., a local town Fire Department), then the level of plant safety is potentially degraded.

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

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

!n -a~di..e!anAppendix R to 10 CFR 50, requires, among other considerations, the use of 1-hour fire barriers for the enclosure of cable and equipment and associated non-safety circuits of one redundant train (G.2.c). As used in EAL #2, the 30-minutes to verify a single alarm is well within this worst-case I-hour time period.Depending upon the plant mode at the time of the event, escalation of the emergency classification level ....l .e*db.,-ec IC. A6or.A9 the plant Pretectedi ,Ara.LuSL ,ztagnme"ntq

,,'ttrrnute:

a.,.i:.;'135 HU7 ECL: Notification of Unusual Event Initiating Condition:

Other conditions exist which in the judgment of the emergency director warrant declaration of a NOUE.Operating Mode Applicability:

All Emergency Action Levels: (I) Other conditions exist which in the judgment of the emergency director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated.

No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.Basis: This IC addresses unanticipated conditions not addressed explicitly elsewhere but that warrant declaration of an emergency because conditions exist whieh-thai are believed by the emergency director to fall under the emergency classification level description for a NOUE.136 II8SSYSTEM MALFUNCTION ICS/EALS GENERAL SITE AREAAL TUNS LEV T EMERGENCY EMERGENCYALRUNSLEVT SG1 Prolonged loss of SSI Loss of all offsite SA1 Loss of all but one SUI Loss of all offsite all offsite and all onsite and all onsite AC power AC power source to AC power capability to AC power to emergency to emergency buses for emergency buses for 15 emergency buses for 15 buses. 15 minutes or longer. minutes or longer. minutes or longer.Op. Modes: Power Op. Modes: Power Op. Modes: Power Op. Modes: Power Operation, Startup, Hot Operation, Startup, Hot Operation, Startup, Hot Operation, Startup, Hot Standby, Hot Shutdown Standby, Hot Shutdown Standby, Hot Shutdown Standby, Hot Shutdown SA2 UNPLANNED SU2 UNPLANNED loss of Control Room loss of Control Room indications for 15 indications for 15 minutes or longer with a minutes or longer.significant transient in Op. Modes: Power progress.

Operation, Startup, Hot Op. Modes: Power Standby, Hot Shutdown Operation, Startup, Hot Standby, Hot Shutdown SU3 Reactor coolant activity greater than Technical Specification allowable limits.Op. Modes: Power Operation, Startup, Hot_________________Standby, Hot Shutdown SU4 RCS leakage for 15 minutes or longer.Op. Modes: Power Operation, Startup, Hot Standby, Hot Shutdown SSS Inability to SA5 Automatic or SU5 Automatic or shutdown the reactor manual trip fails to manual trip fails to causing a challenge to shutdown the reactor, and shutdown the reactor.core cooling or RCS heat subsequent manual Op. Modes: Power removal, actions taken at the Operation Op. Modes: Power reactor control consoles Operation are not successful in shutting down the reactor.Op. Modes: Power____________________________________Operation____________

137 GENERAL SITE AREA EMREC EEGNYALERT UNUSUAL EVENT SU6 Loss of all onsite'or offsite communications capabilities.

Op. Modes: Power Operation, Startup, Hot Standby, Hot Shutdown SU7 Failure to isolate containment or loss of containment pressure control.-4ZW-R-Op. Modes: Power Operation, Startup, Hot Standby, Hot Shutdown SG8 Loss of all AC SS8 Loss of all vital and vital DC power DC power for 15 minutes sources for 15 minutes or or longer.longer. Op. Modes: Power Op. Modes: Power Operation, Startup, Hot Operation, Startup, Hot Standby, Hot Shutdown Standby, Hot Shutdown SA9 Hazardous event affecting a SAFETY SYSTEM needed for the current operating mode.Op. Modes: Power Operation, Startup, Hot Standby, Hot Shutdown 138 I-WR-CONTAINMENT BARRIER THRESHOLDS: