ML17164A141
| ML17164A141 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 05/31/2017 |
| From: | Exelon Generation Co |
| To: | Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML17164A149 | List: |
| References | |
| NMP1L3158 | |
| Download: ML17164A141 (67) | |
Text
CCNPP Page 1 of 67 NEI 99-01 Rev 6 Proposed EAL Justification AG1 Initiating Condition - GENERAL EMERGENCY Release of gaseous radioactivity resulting in offsite dose greater than 1,000 mrem TEDE or 5,000 mrem thyroid CDE.
Operating Mode Applicability: All Example Emergency Action Levels: (1 or 2 or 3)
Notes:
The Emergency Director should declare the General Emergency promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.
If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.
The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
- 1. Reading on any of the following radiation monitors greater than the reading shown for 15 minutes or longer:
(site specific monitor list and threshold values)
- 2. Dose assessment actual meteorology indicates doses greater than 1000 mrem TEDE or 5000 mrem thyroid CDE at or beyond (site specific dose receptor point)
- 3. Field survey results indicate EITHER of the following at or beyond (site specific dose receptor point):
Closed window dose rates greater than 1000 mR/hr expected to continue for 60 minutes or longer.
Analysis of field survey samples indicate thyroid CDE greater than 5000 mrem for one hour of inhalation.
RG1 Initiating Condition:
Release of gaseous radioactivity resulting in offsite dose greater than 1000 mRem TEDE or 5000 mRem thyroid CDE.
Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Levels (EAL) :
Notes:
The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.
Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.
The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
- 1. Reading on the sum of U1 and U2 WRNGM (RIC-5415) Effluent Monitors
> 1.94 E+09 µCi/sec for > 15 minutes.
- 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER:
- 3. Field survey results at or beyond the site boundary indicate EITHER:
- a. Gamma (closed window) dose rates >1000 mR/hr are expected to continue for >
60 minutes.
- b. Analyses of field survey samples indicate > 5000 mRem CDE Thyroid for 60 minutes of inhalation.
No Change Difference Deviation
- 1) Listed site-specific monitors and Threshold values to ensure timely classification.
- 2) Added "Classification based on effluent monitor readings assumes that a release path to the environment is established." To the third bullet in order to delete the following from the basis section " Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefore readily available on the matrix used by the SM.
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CCNPP Page 2 of 67 NEI 99-01 Rev 6 Proposed EAL Justification AS1 Initiating Condition - SITE AREA EMERGENCY Release of gaseous radioactivity resulting in offsite dose greater than 100 mrem TEDE or 500 mrem thyroid CDE.
Operating Mode Applicability: All Example Emergency Action Levels: (1 or 2 or 3)
Notes:
The Emergency Director should declare the General Emergency promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.
If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.
The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
- 1..Reading on any of the following radiation monitors greater than the reading shown for 15 minutes or longer:
(site specific monitor list and threshold values)
- 2. Dose assessment actual meteorology indicates doses greater than 100 mrem TEDE or 500 mrem thyroid CDE at or beyond (site specific dose receptor point)
- 3. Field survey results indicate EITHER of the following at or beyond (site specific dose receptor point):
Closed window dose rates greater than 100 mR/hr expected to continue for 60 minutes or longer.
Analysis of field survey samples indicate thyroid CDE greater than 500 mrem for one hour of inhalation.
RS1 Initiating Condition:
Release of gaseous radioactivity resulting in offsite dose greater than 100 mRem TEDE or 500 mRem thyroid CDE.
Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Levels (EAL) :
Notes:
The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.
Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.
The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
- 1. Reading on the sum of U1 and U2 WRNGM (RIC-5415) Effluent Monitors
> 1.94 E+08 µCi/sec for > 15 minutes.
- 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER:
- 3. Field survey results at or beyond the site boundary indicate EITHER:
- a. Gamma (closed window) dose rates >100 mR/hr are expected to continue for > 60 minutes.
- b. Analyses of field survey samples indicate > 500 mRem CDE Thyroid for 60 minutes of inhalation.
No Change Difference Deviation
- 1) Listed site-specific monitors and Threshold values to ensure timely classification.
- 2) Added "Classification based on effluent monitor readings assumes that a release path to the environment is established." To the third bullet in order to delete the following from the basis section " Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes."
This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the matrix used by the SM.
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CCNPP Page 3 of 67 NEI 99-01 Rev 6 Proposed EAL Justification AA1 Initiating Condition - ALERT Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mrem TEDE or 50 mrem thyroid CDE.
Operating Mode Applicability: All Example Emergency Action Levels: (1 or 2 or 3)
Note:
The Emergency Director should declare the Alert promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.
If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.
The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
- 1. Reading on any of the following radiation monitors greater than the reading shown for 15 minutes or longer:
(site-specific monitor list and threshold values)
- 2. Dose assessment actual meteorology indicates doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond (site specific dose receptor point)
- 3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than 10 mrem TEDE or 50 mrem thyroid CDE at or beyond (site-specific dose receptor point) for one hour of exposure.
- 4. Field survey results indicate EITHER of the following at or beyond (site specific dose receptor point):
Closed window dose rates greater than 10 mR/hr expected to continue for 60 minutes or longer.
Analysis of field survey samples indicate thyroid CDE greater than 50 mrem for one hour of inhalation.
RA1 Initiating Condition:
Release of gaseous or liquid radioactivity resulting in offsite dose greater than 10 mRem TEDE or 50 mRem thyroid CDE.
Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Levels (EAL) :
Note:
The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 15 minutes.
Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.
The pre-calculated effluent monitor values presented in EAL #1 should be used for emergency classification assessments until the results from a dose assessment using actual meteorology are available.
- 1.
Reading on the sum of U1 and U2 WRNGM (RIC-5415) Effluent Monitors
> 1.94 E+07 µCi/sec for > 15 minutes.
- 2. Dose assessment using actual meteorology indicates doses at or beyond the site boundary of EITHER:
- a.
- b.
- 3. Analysis of a liquid effluent sample indicates a concentration or release rate that would result in doses greater than EITHER of the following at or beyond the site boundary
- 4. Field survey results at or beyond the site boundary indicate EITHER:
- a. Gamma (closed window) dose rates > 10 mR/hr are expected to continue for > 60 minutes.
- b.
- b. Analyses of field survey samples indicate > 50 mRem CDE Thyroid for 60 minutes of inhalation.
No Change Difference Deviation
- 1) Listed site-specific monitors and Threshold values to ensure timely classification.
- 2) Added "Classification based on effluent monitor readings assumes that a release path to the environment is established." To the third bullet in order to delete the following from the basis section "Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the matrix used by the SM.
- 3) Calculations were performed, in accordance with (IAW) guidance provided in NEI 99-01 revision 6 EAL AA1, to determine the effluent monitor response for a radioactive liquid release and a WGDT release via the normal site release pathway. The release would contain activity equivalent to provide 10mRem TEDE or 50mRem thyroid CDE at the site boundary. The calculation determined the effluent monitor responses would be
>110% of the instruments maximum range and as such, IAW NEI 99-01 Rev 6 guidance, was not included in this EAL.
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CCNPP Page 4 of 67 NEI 99-01 Rev 6 Proposed EAL Justification AU1 Initiating Condition - UNUSUAL EVENT Release of gaseous or liquid radioactivity greater than 2 times the (site-specific effluent release controlling document) limits for 60 minutes or longer Operating Mode Applicability: All Example Emergency Action Levels: (1 or 2 or 3 )
Note:
The Emergency Director should declare the Alert promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded.
If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes.
If the effluent flow past an effluent monitor is known to have stopped, indicating that the release path is isolated, the effluent monitor reading is no longer valid for classification purposes.
- 1. Reading on ANY effluent radiation monitor greater than 2 times the (site-specific effluent release controlling document) limits for 60 minutes or longer:
(site-specific monitor list and threshold values corresponding to 2 times the controlling document limits)
- 2. Reading on ANY effluent radiation monitor greater than 2 times the alarm setpoint established by a current radioactivity discharge permit for 60 minutes or longer.
- 3. Sample analysis for a gaseous or liquid release indicates a concentration or release rate greater than 2 times (site-specific effluent release controlling document limits) for 60 minutes or longer.
RU1 Initiating Condition:
Release of gaseous or liquid radioactivity greater than 2 times the ODCM limits for 60 minutes or longer.
Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Levels (EAL) :
Note:
The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
If an ongoing release is detected and the release start time is unknown, assume that the release duration has exceeded 60 minutes.
Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes.
- 1. Reading on ANY of the following effluent monitors > 2x the Adjustable /
Maximum set point established by a current radioactive release discharge permit for 60 minutes.
Liquid Radwaste Effluent Monitor (0-RIC-2201)
S/G Blowdown Monitor (1/2-RCI-4095)
S/G Blowdown Tank Monitor (1/2-RIC-4014)
Gaseous Radwaste Processing System Monitor (0-RI-2191)
Wide Range Noble Gas Monitor (WRNGM) (1/2-RIC-5415) (During WGDT release)
Main Vent Gas Monitor (1/2-RI-5415) (During WGDT release)
Discharge Permit specified Monitor OR
- 2. Reading on the sum of U1 and U2 WRNGM (RIC-5415) Effluent Monitors
> 5.09 E+05 µCi/sec for > 60 minutes.
- 3. Confirmed sample analyses for gaseous or liquid releases indicate concentrations or release rates > 2x ODCM Limit with a release duration of > 60 minutes.
No Change Difference Deviation
- 1) Listed site-specific monitors and Threshold values to ensure timely classification.
- 2) Added "Classification based on effluent monitor readings assumes that a release path to the environment is established." To the third bullet in order to delete the following from the basis section "Classification based on effluent monitor readings assumes that a release path to the environment is established. If the effluent flow past an effluent monitor is known to have stopped due to actions to isolate the release path, then the effluent monitor reading is no longer valid for classification purposes." This allows for more timely classification since all the basis information pertaining to Note bullet 3 will be contained in the IC and therefor readily available on the matrix used by the SM.
- 3) The order of EALs #1 and #2 to conform with the legacy Exelon fleet.
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CCNPP Page 5 of 67 NEI 99-01 Rev 6 Proposed EAL Justification AG2 Initiating Condition -- GENERAL EMERGENCY Spent fuel pool level cannot be restored to at least (site-specific Level 3 description) for 60 minutes or longer.
Operating Mode Applicability: All Example Emergency Action Levels:
NOTES: The Emergency Director should declare the General Emergency promptly upon determining that 60 minutes has been exceeded, or will likely be exceeded
- 1. Spent fuel pool level cannot be restored to at least (site-specific Level 3 description) for 60 minutes or longer.
RG2 Initiating Condition:
Spent fuel pool level cannot be restored to at least 45.167 ft. for 60 minutes or longer.
Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Level (EAL):
Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
Spent fuel pool level cannot be restored to at least 45.167 ft. as indicated on EITHER 0-LI-2003 OR 0-LI-2003A for > 60 minutes.
No Change Difference Deviation
- 1) Listed site-specific indicator and Threshold values to ensure timely classification X
CCNPP Page 6 of 67 NEI 99-01 Rev 6 Proposed EAL Justification AS2 Initiating Condition - SITE AREA EMERGENCY Spent fuel pool level at (site-specific Level 3 description)
Operating Mode Applicability: All Example Emergency Action Levels:
- 1. Spent fuel pool level at (site-specific Level 3 description)
RS2 Initiating Condition:
Spent fuel pool level at 45.167 ft.
Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Level (EAL):
Lowering of spent fuel pool level to 45.167 ft. as indicated on EITHER 0-LI-2003 OR 0-LI-2003A.
No Change Difference Deviation
- 1) Listed site-specific indicator and Threshold values to ensure timely classification X
CCNPP Page 7 of 67 NEI 99-01 Rev 6 Proposed EAL Justification AA2 Initiating Condition - ALERT Significant lowering of water level above, or damage to, irradiated fuel.
Operating Mode Applicability: All Example Emergency Action Levels: (1 or 2 or 3 )
- 1. Uncovery of irradiated fuel in the REFUELING PATHWAY.
- 2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by ANY of the following radiation monitors:
(site-specific listing of radiation monitors, and the associated readings, setpoints and/or alarms)
- 3. Lowering of spent fuel pool level to (site-specific Level 2 value).
RA2 Initiating Condition:
Significant lowering of water level above, or damage to, irradiated fuel.
Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Levels (EAL) :
- 1. Uncovery of irradiated fuel in the REFUELING PATHWAY.
- 2. Damage to irradiated fuel resulting in a release of radioactivity from the fuel as indicated by ANY Table R2 Radiation Monitor Alarm.
- 3. Lowering of spent fuel pool level to 50.167 ft. as indicated on EITHER 0-LI-2003 OR 0-LI-2003A.
Table R2 Radiation Monitors RMS Area Monitored RI-5420 Fuel Handling Area Vent 0RIC-7023 Channel 4 SFP Area RM-320 El-69 0RIC-7023 Channel 3 Spent Fuel Handling Machine RI-5316/A/B/C/D Unit1/2 CNTMT EL-69 No Change Difference Deviation
- 1) Listed site-specific monitors and Threshold values to ensure timely classification.
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CCNPP Page 8 of 67 NEI 99-01 Rev 6 Proposed EAL Justification AU2 Initiating Condition: UNUSUAL EVENT UNPLANNED loss of water level above irradiated fuel Operating Mode Applicability: All Example Emergency Action Levels:
- 1. a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated by ANY of the following:
(site-specific level indications).
AND
- b. UNPLANNED rise in area radiation levels as indicated by ANY of the following radiation monitors.
(site-specific list of area radiation monitors)
RU2 Initiating Condition:
UNPLANNED loss of water level above irradiated fuel Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Levels (EAL) :
- 1.
- a. UNPLANNED water level drop in the REFUELING PATHWAY as indicated by ANY of the following:
Inability to restore and maintain SFP level > Technical Specification limit (65 ft 7 in)
Inability to restore and maintain RFP level > Technical Specification limit (56 ft 8.5 in)
Indication or report of a drop in water level in the REFUELING PATHWAY AND
- b. UNPLANNED Area Radiation Monitor reading rise on ANY radiation monitors in Table R2.
Table R2 Radiation Monitors RMS Area Monitored RI-5420 Fuel Handling Area Vent 0RIC-7023 Channel 4 SFP Area RM-320 El-69 0RIC-7023 Channel 3 Spent Fuel Handling Machine RI-5316/A/B/C/D Unit1/2 CNTMT EL-69 No Change Difference Deviation
- 1) Listed site-specific levels and indications to ensure timely classification.
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CCNPP Page 9 of 67 NEI 99-01 Rev 6 Proposed EAL Justification AA3 Initiating Condition - ALERT Radiation levels that impede access to equipment necessary for normal plant operations, cooldown or shutdown.
Operating Mode Applicability: All Example Emergency Action Levels: (1 or 2)
Note: If the equipment in the listed room or area was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted
- 1. Dose rate greater than 15 mR/hr in ANY of the following areas:
- Control Room
- Central Alarm Station
- (other site-specific areas/rooms)
- 2. An UNPLANNED event results in radiation levels that prevent or significantly impede access to any of the following plant rooms or areas:
(site-specific list of plant rooms or areas with entry-related mode applicability identified)
RA3 Initiating Condition:
Radiation levels that impede access to equipment necessary for normal plant operations, cooldown or shutdown.
Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Levels (EAL) :
Note: If the equipment in the room or area listed in Table R4 was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted
- 1. Dose rate greater than 15 mR/hr in ANY of the areas contained in Table R3:
Table R3 Areas Requiring Continuous Occupancy Main Control Room (by survey)
Central Alarm Station (CAS) (by survey)
- 2. UNPLANNED event results in radiation levels that prohibit or significantly impede access to any of the following Table R4 plant rooms or areas:
Table R4 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability 45 West Electrical Penetration Rooms Modes 3, 4, and 5 69 Electrical Penetration Rooms Modes 3, 4, and 5 ECCS Pump Rooms Modes 3, 4, and 5 Charging Pump Rooms Modes 3, 4, and 5 Component Cooling Rooms Modes 3, 4, and 5 No Change Difference Deviation
- 1) Listed site specific plant rooms and areas with identified mode applicability to ensure timely classification.
- 2) Additional discussion added to the basis section describing Table R4 as follows:
This IC addresses elevated radiation levels in certain plant rooms/areas sufficient to preclude or impede personnel from performing actions necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal plant procedures. As such, it represents an actual or potential substantial degradation of the level of safety of the plant. The Emergency Director should consider the cause of the increased radiation levels and determine if another IC may be applicable.
Assuming all plant equipment is operating as designed, normal operation is capable from the Main Control Room (MCR). The plant is also able to transition into a hot shutdown condition from the MCR, therefore Table R4 is a list of plant rooms or areas with entry-related mode applicability that contain equipment which require a manual/local action necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal operating procedures (establish shutdown cooling), where if this action is not completed the plant would not be able to attain and maintain cold shutdown. This Table does not include rooms or areas for which entry is required solely to perform actions of an administrative or record keeping nature (e.g.,
normal rounds or routine inspections).
Rooms and areas listed in EAL #1 do not need to be included in EAL #2, including the Control Room.
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CCNPP Page 10 of 67 NEI 99-01 Rev 6 Proposed EAL Justification SU3 Initiating Condition: UNUSUAL EVENT Reactor coolant activity greater than Technical Specification allowable limits.
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels:
- 1. (Site-specific radiation monitor) reading greater than (site-specific value).
- 2. Sample analysis indicates that a reactor coolant activity value is greater than an allowable limit specified in Technical Specifications.
RU3 Initiating Condition:
Reactor coolant activity greater than Technical Specification allowable limits.
Operating Mode Applicability:
1, 2, 3, 4 Emergency Action Levels (EAL):
- 1. Letdown monitor RY-202-1 high alarm (> 1E+06 cpm)
- 2. Sample analysis indicates Coolant activity > ANY of the following:
Dose equivalent I-131 0.5 uCi/gm for 100 hrs. continuous Dose equivalent I-131 acceptable region of T.S. Fig. 3.4.15-1 Dose equivalent I-131 137.5 uCi/gm Gross activity 100/E-bar uCi/gm No Change Difference Deviation
- 1) Listed site-specific monitor and threshold value to ensure timely classification.
- 2) Listed this system category EAL in the radiological category EAL section to maintain consistency with previous revisions of Exelon EALs. This will ensure a timely classification since the threshold values are more aligned with the radiological category vice system category.
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CCNPP Page 11 of 67 NEI 99-01 rev 6 Fission Product Barrier Matrix Fission Product Barrier Matrix Hot Matrix GENERAL EMERGENCY SITE AREA EMERGENCY ALERT FG1 Loss of any two barriers AND Loss or Potential Loss of the third barrier. 1,2,3, 4 FS1 Loss or Potential Loss of ANY two barriers. 1,2,3, 4 FA1 ANY Loss or ANY Potential Loss of either Fuel Clad or RCS 1,2,3, 4 Sub-Category FC - Fuel Clad RC - Reactor Coolant System CT - Containment Loss Potential Loss Loss Potential Loss Loss Potential Loss
A. An automatic or manual ECCS (SI) actuation is required by EITHER of the following:
- b. SG tube RUPTURE.
A. Operation of a standby charging (makeup) pump is required by EITHER of the following:
- b. SG tube leakage.
OR B. RCS cooldown rate greater than (site specific pressurized thermal shock criteria/limits defined by site specific indications)
A leaking or RUPTURED SG is FAULTED outside of containment.
None
- 2. Inadequate Heat Removal A. Core exit thermocouple readings greater than (site specific temperature value)
A. Core exit thermocouple readings greater than (site specific temperature value)
OR B. Inadequate RCS heat removal capability via steam generators as indicated by (site specific indications).
None A. Inadequate RCS heat removal capability via steam generators as indicated by (site specific indications).
None A. 1. (site specific criteria for entry into core cooling restoration procedure)
AND
- 2. Functional Restoration Procedures not effective in < 15 minutes.
3.RCS Activity/
Containment Radiation A. Containment radiation monitor reading greater than (site specific value)
OR B. (Site specific indications that reactor coolant activity is greater than 300 uCi/gm dose equivalent I-131).
None A. Containment radiation monitor reading greater than (site specific value)
None None A. Containment radiation monitor reading greater than (site specific value) 4.Containment Integrity or Bypass None None None None A.Containment isolation is required AND EITHER of the following:
- 1. Containment integrity has been lost based on Emergency Director judgement.
- 2. UNISOLABLE pathway from containment to the environment exists.
OR B Indication of RCS leakage outside of containment A. Containment pressure greater than (site specific value)
OR B. Explosive mixture exists inside containment.
OR C. 1. Containment pressure greater than (site specific value)
AND
- 2. Less than one full train of (site specific equipment) is operating per design for >15 minutes.
- 5. Emergency Director Judgment A. Any Condition in the opinion of the Emergency Director that indicates Loss of the Fuel Clad Barrier.
A. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.
A. ANY Condition in the opinion of the Emergency Director that indicates Loss of the RCS Barrier.
A. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.
A. Any Condition in the opinion of the Emergency Director that indicates Loss of the Containment Barrier.
A. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.
CCNPP Page 12 of 67 Proposed Fission Product Barrier Matrix Fission Product Barrier Matrix Hot Matrix GENERAL EMERGENCY SITE AREA EMERGENCY ALERT FG1 Loss of any two barriers AND Loss or Potential Loss of the third barrier. 1 2 3 4 FS1 Loss or Potential Loss of ANY two barriers. 1 2 3 4 FA1 ANY Loss or ANY Potential Loss of either Fuel Clad or RCS 1 2 3 4 Sub-Category FC - Fuel Clad RC - Reactor Coolant System CT - Containment Loss Potential Loss Loss Potential Loss Loss Potential Loss
- b. SG tube RUPTURE.
- 2. RCS leak rate > 50 gpm with letdown isolated due to EITHER of the following:
- b. SG tube leakage.
- 3. Uncontrolled RCS cooldown and to the left of Max Operating Pressure Curve (EOP, RCS Pressure Temperature Limits)
A leaking or RUPTURED S/G > 50 gpm is FAULTED outside containment.
None
- 2. Inadequate Heat Removal
- 1. Core Exit Thermocouple readings
> 1200°F
- 2. Core Exit Thermocouple readings
> 700°F OR
- 3. Once Through Core Cooling (OTCC) in effect.
None Once Through Core Cooling (OTCC) in effect.
None 1 a. Core Exit Thermocouple readings
> 1200°F AND
- b. Restoration procedures not effective in < 15 minutes.
- 2.
- a. Core Exit Thermocouples > 700 ºF AND
- b. RVLMS indicates < 10 inch alarm AND
- c. Restoration procedures not effective in < 15 minutes.
- 3. Containment Radiation / RCS Activity
- 1. Containment radiation monitor (5317A/B) reading > 7,000 R/hr.
- 2.
Coolant activity > 300 uCi/gm Dose Equivalent I-131 OR
- 3.
Post-accident sample dose rate >
40mRem/hr. (1ft from sample)
None Containment radiation monitor (5317A/B) reading > 12 R/hr.
None None Containment radiation monitor (5317A/B) reading > 70,000 R/hr.
- 4. Containment Integrity or Bypass None None None None
- 1. Containment isolation is required AND ANY of the following:
- a. UNPLANNED lowering in containment pressure following initial pressure rise OR
- c. UNISOLABLE pathway from containment to the environment exists.
- 2. Indication of RCS leakage outside of containment
- 3. Containment Pressure > 50 psig and rising.
- 4. Hydrogen Concentration in Containment
> 4%.
- 5. a. Containment pressure > 4.25 psig AND
- b. Cannot meet containment design cooling by at least one of the following for > 15 minutes:
2 Containment Spray Pumps Operating OR 3 CACs Operating OR 1 Containment Spray Pump and 2 CACs Operating
- 5. Emergency Director Judgment
- 1. Any Condition in the opinion of the Emergency Director that indicates Loss of the Fuel Clad Barrier.
- 2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.
- 1. Any Condition in the opinion of the Emergency Director that indicates Loss of the RCS Barrier.
- 2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.
- 1. Any Condition in the opinion of the Emergency Director that indicates Loss of the Containment Barrier.
- 2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.
CCNPP Page 13 of 67 NEI 99-01 Rev 6 Proposed EAL Justification FC1 Category: Fuel Clad Barrier RCS or SG tube leakage Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:
Potential Loss A. RCS/reactor vessel level less than (site-specific level).
FC1 Category: Fuel Clad Barrier RCS or SG tube leakage Operating Mode Applicability:
1, 2, 3, 4 Fission Product Barrier (FPB) Threshold:
POTENTIAL LOSS RVLMS indicates < 10 inch alarm No Change Difference Deviation
- 1) Listed site-specific threshold value to ensure timely classification.
X
CCNPP Page 14 of 67 NEI 99-01 Rev 6 Proposed EAL Justification FC2 Category: Fuel Clad Barrier Inadequate Heat Removal Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:
Loss A. Core exit thermocouple readings greater than (site-specific temperature value).
Potential Loss A. Core exit thermocouple readings greater than (site-specific temperature value).
OR B. Inadequate RCS heat removal capability via steam generators as indicated by (site-specific indications).
FC2 Category: Fuel Clad Barrier RCS Activity Operating Mode Applicability:
1, 2, 3, 4 Fission Product Barrier (FPB) Threshold:
LOSS
- 1. Core Exit Thermocouple readings > 1200°F POTENTIAL LOSS
- 2. Core Exit Thermocouple readings > 700°F OR
- 3. Once Through Core Cooling (OTCC) in effect.
No Change Difference Deviation
- 1) Listed site-specific threshold value to ensure timely classification.
- 2) Potential Loss #3, The initiation of Once-Through-Cooling, creates a controlled opening of the RCS to the containment by an open PORV. This is indicative of the steam generators inability to remove heat from the RCS and represents a potential challenge to the FC barrier and is considered a potential loss.
X
CCNPP Page 15 of 67 NEI 99-01 Rev 6 Proposed EAL Justification FC3 Category: Fuel Clad Barrier Containment Radiation / RCS Activity Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:
Loss A. Containment radiation monitor reading greater than (site-specific value).
OR B. (Site-specific indications that reactor coolant activity is greater than 300 Ci/gm dose equivalent I-131).
FC3 Category: Fuel Clad Barrier Containment Radiation / RCS Activity Operating Mode Applicability:
1, 2, 3, 4 Fission Product Barrier (FPB) Threshold:
LOSS
- 1. Containment radiation monitor (5317A/B) reading > 7000 R/hr.
- 3. Post-accident sample dose rate > 40mRem/hr. (1ft from sample)
No Change Difference Deviation
- 1) Listed site-specific monitor and threshold value to ensure timely classification.
- 2) In Accordance with NEI 99-01 Revision 6, reactor coolant activity above 300
µCi/gm is greater than that expected for iodine spikes and corresponds to an approximate range of 2% to 5% fuel clad damage. The radiation level in EAL #1 is based on 2% fuel clad damage
- 3) Added Loss Threshold #3 is an equivalent threshold for indication of >
300uCi/gm DEI 131.
X
CCNPP Page 16 of 67 NEI 99-01 Rev 6 Proposed EAL Justification FC6 Category: Fuel Clad Barrier Emergency Director Judgment Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:
Loss A. Any Condition in the opinion of the Emergency Director that indicates Loss of the Fuel Clad Barrier.
Potential Loss A. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.
FC5 Category: Fuel Clad Barrier Emergency Director Judgment Operating Mode Applicability:
1, 2, 3, 4 Fission Product Barrier (FPB) Threshold:
Loss
- 1. Any Condition in the opinion of the Emergency Director that indicates Loss of the Fuel Clad Barrier.
Potential Loss
- 2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Fuel Clad Barrier.
No Change Difference Deviation X
CCNPP Page 17 of 67 NEI 99-01 Rev 6 Proposed EAL Justification RC1 Category: Reactor Coolant System Barrier RCS or SG Tube Leakage Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:
Loss A. An automatic or manual ECCS (SI) actuation is required by EITHER of the following:
- 2. SG tube RUPTURE.
Potential Loss A. Operation of a standby charging (makeup) pump is required by EITHER of the following:
- 2. SG tube leakage.
OR B. RCS cooldown rate greater than (site-specific pressurized thermal shock criteria/limits defined by site-specific indications).
RC1 Category: Reactor Coolant System Barrier RCS or SG Tube Leakage Operating Mode Applicability:
1, 2, 3, 4 Fission Product Barrier (FPB) Threshold:
LOSS
- b. SG tube RUPTURE.
POTENTIAL LOSS
- 2. RCS leak rate > 50 gpm with letdown isolated due to EITHER of the following:
- b. SG tube leakage.
- 3. Uncontrolled RCS cooldown and to the left of Max Operating Pressure Curve (EOP Attachment 1, RCS Pressure Temperature Limits)
No Change Difference Deviation
- 1) Listed site-specific threshold value to ensure timely classification.
- 2) Due to variability in site-specific charging pump alignment, an RCS leak rate of 50 gpm is used as an alternate potential loss threshold in accordance with guidance of NEI 99-01 Revision 6. The additional words of with letdown isolated ensures this value excludes normal reductions in RCS inventory.
X
CCNPP Page 18 of 67 NEI 99-01 Rev 6 Proposed EAL Justification RC2 Category: Reactor Coolant System Barrier Inadequate Heat Removal Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:
Potential Loss A. Inadequate RCS heat removal capability via steam generators as indicated by (site-specific indications).
RC2 Category: Reactor Coolant System Barrier Inadequate Heat Removal Operating Mode Applicability:
1, 2, 3, 4 Fission Product Barrier (FPB) Threshold:
POTENTIAL LOSS Once Through Core Cooling (OTCC) in effect.
No Change Difference Deviation
- 1) The initiation of Once Through Core Cooling creates a controlled opening of the RCS to the containment by an open PORV. The opening of the RCS represents a potential challenge to the RCS barrier and is considered a potential loss.
X
CCNPP Page 19 of 67 NEI 99-01 Rev 6 Proposed EAL Justification RC3 Category: Reactor Coolant System Barrier Containment Radiation / RCS Activity Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:
Loss A. Containment radiation monitor reading greater than (site-specific value).
RC3 Category: Reactor Coolant System Barrier Containment Radiation / RCS Activity Operating Mode Applicability:
1, 2, 3, 4 Fission Product Barrier (FPB) Threshold:
LOSS Containment radiation monitor (5317A/B) reading > 12 R/hr.
No Change Difference Deviation
- 1) Listed site-specific equipment and threshold values to ensure timely classification.
X
CCNPP Page 20 of 67 NEI 99-01 Rev 6 Proposed EAL Justification RC6 Category: Reactor Coolant System Barrier Emergency Director Judgment Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:
Loss A. Any Condition in the opinion of the Emergency Director that indicates Loss of the RCS Barrier.
Potential Loss A. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.
RC5 Category: Reactor Coolant System Barrier Emergency Director Judgment Operating Mode Applicability:
1, 2, 3, 4 Fission Product Barrier (FPB) Threshold:
Loss
- 1. ANY Condition in the opinion of the Emergency Director that indicates Loss of the RCS Barrier.
Potential Loss
- 2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the RCS Barrier.
No Change Difference Deviation X
CCNPP Page 21 of 67 NEI 99-01 Rev 6 Proposed EAL Justification CT1 Category: Containment Barrier RCS or SG Tube Leakage Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:
Loss A. A leaking or RUPTURED SG is FAULTED outside of containment.
CT1 Category: Containment Barrier RCS or SG Tube Leakage Operating Mode Applicability:
1, 2, 3, 4 Fission Product Barrier (FPB) Threshold:
LOSS A leaking or RUPTURED S/G > 50 gpm is FAULTED outside containment.
No Change Difference Deviation
- 1) Added leakrate of > 50gpm as per guidance contained in NEI 99-01 Revision 6 as follows:
Affected SG is FAULTED Outside of Containment?
Primary to Secondary Leak Rate Yes No Less than or equal to 25 gpm No classification No classification Greater than 25 gpm Unusual Event per MU6 Unusual Event per MU6 Greater than 50 gpm with letdown isolated (RCS Barrier Potential Loss)
Site Area Emergency per FS1 Alert per FA1 Requires an automatic or manual ECCS actuation (RCS Barrier Loss)
Site Area Emergency per FS1 Alert per FA1 X
CCNPP Page 22 of 67 NEI 99-01 Rev 6 Proposed EAL Justification CT2 Category: Containment Barrier Inadequate Heat Removal Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:
Potential Loss A.
- 1. (Site-specific criteria for entry into core cooling restoration procedure)
AND
- 2. Restoration procedure not effective within 15 minutes.
CT2 Category: Containment Barrier Inadequate Heat Removal Operating Mode Applicability:
1, 2, 3, 4 Fission Product Barrier (FPB) Threshold:
POTENTIAL LOSS
- 1. a. Core Exit Thermocouple readings > 1200°F AND
- b. Restoration procedures not effective in < 15 minutes.
- 2. a. Core Exit Thermocouples > 700 ºF AND
- b. RVLMS indicates < 10 inch alarm AND
- c. Restoration procedures not effective in < 15 minutes.
No Change Difference Deviation
- 1) Listed site-specific threshold values to ensure timely classification.
X
CCNPP Page 23 of 67 NEI 99-01 Rev 6 Proposed EAL Justification CT3 Category: Containment Barrier Containment Radiation / RCS Activity Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:
Potential Loss A.
Containment radiation monitor reading greater than (site-specific value).
CT3 Category: Containment Barrier Containment Radiation / RCS Activity Operating Mode Applicability:
1, 2, 3, 4 Fission Product Barrier (FPB) Threshold:
POTENTIAL LOSS Containment radiation monitor (5317A/B) reading > 70,000 R/hr.
No Change Difference Deviation
- 1) Listed site-specific threshold values to ensure timely classification.
X
CCNPP Page 24 of 67 NEI 99-01 Rev 6 Proposed EAL Justification CT4 Category: Containment Barrier Containment Integrity or Bypass Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:
Loss A. Containment isolation is required AND EITHER of the following:
- 1. Containment integrity has been lost based on Emergency Director judgment.
- 2. UNISOLABLE pathway from the containment to the environment exists.
OR B. Indications of RCS leakage outside of containment.
Potential Loss A. Containment pressure greater than (site-specific value)
OR B. Explosive mixture exists inside containment OR C. 1. Containment pressure greater than (site-specific pressure setpoint)
AND
- 2. Less than one full train of (site-specific system or equipment) is operating per design for 15 minutes or longer.
CT4 Category: Containment Barrier Containment Integrity or Bypass Operating Mode Applicability:
1, 2, 3, 4 Fission Product Barrier (FPB) Threshold:
LOSS
- 1. Containment isolation is required AND ANY of the following:
- a. UNPLANNED lowering in containment pressure following initial pressure rise.
- c. UNISOLABLE pathway from containment to the environment exists.
- 2. Indication of RCS leakage outside of containment POTENTIAL LOSS
- 3. Containment Pressure > 50 psig and rising.
- 4. Hydrogen Concentration in Containment > 4%.
- 5. a. Containment pressure > 4.25 psig AND
- b. Cannot meet containment design cooling by at least one of the following for > 15 minutes:
2 Containment Spray Pumps Operating OR 3 CACs Operating OR 1 Containment Spray Pump and 2 CACs Operating No Change Difference Deviation
- 1) Listed site-specific monitor and threshold value to ensure timely classification.
X
CCNPP Page 25 of 67 NEI 99-01 Rev 6 Proposed EAL Justification CT6 Category: Containment Barrier Emergency director Judgment Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Fission Product Barrier Threshold:
Loss A. Any Condition in the opinion of the Emergency Director that indicates Loss of the Containment Barrier.
Potential Loss A. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.
CT5 Category: Containment Barrier Emergency Director Judgment Operating Mode Applicability:
1, 2, 3, 4 Fission Product Barrier (FPB) Threshold:
Loss
- 1. Any Condition in the opinion of the Emergency Director that indicates Loss of the Containment Barrier.
Potential Loss
- 2. Any Condition in the opinion of the Emergency Director that indicates Potential Loss of the Containment Barrier.
No Change Difference Deviation X
CCNPP Page 26 of 67 NEI 99-01 Rev 6 Proposed EAL Justification SG1 Initiating Condition: GENERAL EMERGENCY Prolonged loss of all offsite and all onsite AC power to emergency buses.
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels:
Note: The Emergency Director should declare the General Emergency promptly upon determining that (site-specific hours) has been exceeded, or will likely be exceeded.
- 1. a. Loss of ALL offsite and ALL onsite AC power to (site-specific emergency buses).
AND
- b. EITHER of the following:
Restoration of at least one emergency bus in less than (site-specific hours) is not likely.
(Site-specific indication of an inability to adequately remove heat from the core)
MG1 Initiating Condition:
Prolonged loss of all offsite and all onsite AC power to emergency buses.
Operating Mode Applicability:
1, 2, 3, 4 Emergency Action Levels (EAL) :
Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
AND
- 2. EITHER of the following:
- a. Restoration of at least one 4kV vital bus in
< 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is not likely.
- b. Core exit thermocouples > 1200°F.
No Change Difference Deviation
- 1) Listed site specific equipment to ensure timely classification.
X
CCNPP Page 27 of 67 NEI 99-01 Rev 6 Proposed EAL Justification SS1 Initiating Condition: SITE AREA EMERGENCY Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or longer.
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels:
Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.
Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses) for 15 minutes or longer.
MS1 Initiating Condition:
Loss of all offsite and onsite AC power to emergency busses for 15 minutes or longer.
Operating Mode Applicability:
1, 2, 3, 4 Emergency Action Levels (EAL):
Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
AND
- 2. Failure to restore power to at least one 4kV vital bus in < 15 minutes from the time of loss of both offsite and onsite AC power.
No Change Difference Deviation
- 1) Listed site specific equipment to ensure timely classification.
- 2) Formatted to be EAL 1 and 2, as this conforms to the Exelon fleet format.
X
CCNPP Page 28 of 67 NEI 99-01 Rev 6 Proposed EAL Justification SA1 Initiating Condition: ALERT Loss of all but one AC power source to emergency buses for 15 minutes or longer.
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels:
Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.
- 1. a. AC power capability to (site-specific emergency buses) is reduced to a single power source for 15 minutes or longer.
AND
- b. Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS.
MA1 Initiating Condition:
Loss of all but one AC power source to emergency buses for 15 minutes or longer.
Operating Mode Applicability:
1, 2, 3, 4 Emergency Action Levels (EAL):
Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. AC power capability to 4kV vital buses 11(21) and 14(24) reduced to only one of the following power sources for > 15 minutes.
500kV transmission line 5051*
500kV transmission line 5052*
500kV transmission line 5072*
SMECO line, if aligned Emergency Diesel Generator 1(2)A DG Emergency Diesel Generator 1(2)B DG Emergency Diesel Generator 0C DG, if aligned
- A credited 500kV line must have an independent 13kV service transformer AND
- 2. Any additional single power source failure will result in a loss of ALL AC power to SAFETY SYSTEMS.
No Change Difference Deviation
- 1) Listed site specific equipment to ensure timely classification.
X
CCNPP Page 29 of 67 NEI 99-01 Rev 6 Proposed EAL Justification SU1 Initiating Condition: UNUSUAL EVENT Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels:
Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.
Loss of ALL offsite AC power capability to (site-specific emergency buses) for 15 minutes or longer MU1 Initiating Condition:
Loss of all offsite AC power capability to emergency buses for 15 minutes or longer.
Operating Mode Applicability:
1, 2, 3, 4 Emergency Action Levels (EAL):
Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
Loss of ALL offsite AC power capability to 4kV vital buses 11(21) and 14(24) for
> 15 minutes.
500kV transmission line 5051*
500kV transmission line 5052*
500kV transmission line 5072*
SMECO line, if aligned
- A credited 500kV line must have an independent 13kV service transformer No Change Difference Deviation
- 1) Listed site specific equipment to ensure timely classification.
X
CCNPP Page 30 of 67 NEI 99-01 Rev 6 Proposed EAL Justification SG8 Initiating Condition: GENERAL EMERGENCY Loss of all AC and Vital DC power sources for 15 minutes or longer.
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels:
Note: The Emergency Director should declare the General Emergency promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.
- 1. Loss of ALL offsite and ALL onsite AC power to (site-specific emergency buses) for 15 minutes or longer.
AND Indicated voltage is less than (site-specific bus voltage value) on ALL (site-specific vital DC busses) for 15 minutes or longer.
MG2 Initiating Condition:
Loss of all AC and Vital DC power sources for 15 minutes or longer.
Operating Mode Applicability:
1, 2, 3, 4 Emergency Action Levels (EAL):
Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
AND
- 2. Voltage is < 105 VDC on 125 VDC buses 11, 12, 21, and 22.
AND
No Change Difference Deviation
- 1) Listed site specific voltage and equipment to ensure timely classification.
- 2) Removed the word "indicated" this will allow for an indication problem to not cause confusion on the need to declare.
- 3) Changed formatting to be 1 AND 2 AND 3 formatting.
X
CCNPP Page 31 of 67 NEI 99-01 Rev 6 Proposed EAL Justification SS8 Initiating Condition: SITE AREA EMERGENCY Loss of all Vital DC power for 15 minutes or longer.
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels:
Note: The Emergency Director should declare the Site Area Emergency promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.
Indicated voltage is less than (site-specific bus voltage value) on ALL Vital DC buses for 15 minutes or longer.
MS2 Initiating Condition:
Loss of all Vital DC power for 15 minutes or longer.
Operating Mode Applicability:
1, 2, 3, 4 Emergency Action Levels (EAL):
Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
Voltage is < 105 VDC on 125 VDC busses 11, 12, 21, and 22 for > 15 minutes.
No Change Difference Deviation
- 1) Listed site specific voltage and equipment to ensure timely classification.
- 2) Removed the word "indicated" this will allow for an indication problem to not cause confusion on the need to declare.
X
CCNPP Page 32 of 67 NEI 99-01 Rev 6 Proposed EAL Justification SS5 Initiating Condition: SITE AREA EMERGENCY Inability to shutdown the reactor causing a challenge to (core cooling [PWR] / RPV water level [BWR]) or RCS heat removal.
Operating Mode Applicability:
Power Operation Example Emergency Action Levels:
- 1. a. An automatic or manual (trip [PWR] / scram [BWR]) did not shutdown the reactor.
AND
- b.
All manual actions to shutdown the reactor have been unsuccessful.
AND
- c. EITHER of the following conditions exist:
- 1. (Site-specific indication of an inability to adequately remove heat from the core)
- 2. (Site-specific indication of an inability to adequately remove heat from the RCS)
MS3 Initiating Condition:
Inability to shutdown the reactor causing a challenge to core cooling or RCS heat removal.
Operating Mode Applicability:
1,2 Emergency Action Levels (EAL):
- 1. Automatic or Manual Trip did not shutdown the reactor as indicated by Reactor Power > 5%.
AND
- 2. All DSS / manual actions to shutdown the reactor have been unsuccessful as indicated by Reactor Power > 5%.
AND
- 3. ANY of the following conditions exist:
- a. Core exit thermocouples > 1200°F.
- b. Once Through Core Cooling(OTCC) in effect.
No Change Difference Deviation
- 1) Listed site specific indications to ensure timely classification.
- 2) Mode 2 included in operating mode applicability as per developer notes.
- 3) Removed the following sentence A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria from the basis section since the reactor shutdown criteria is now listed within the EAL.
X
CCNPP Page 33 of 67 NEI 99-01 Rev 6 Proposed EAL Justification SA5 Initiating Condition: ALERT Automatic or manual (trip [PWR] / scram [BWR]) fails to shutdown the reactor, and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor.
Operating Mode Applicability:
Power Operation Example Emergency Action Levels:
Note: A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.
- 1. a. An automatic (trip [PWR] / scram [BWR]) did not shutdown the reactor.
AND
- b.
Manual action taken at the reactor control consoles are not successful in shutting down the reactor.
MA3 Initiating Condition:
Automatic or manual trip fails to shutdown the reactor, and subsequent manual actions taken at the reactor control consoles are not successful in shutting down the reactor.
Operating Mode Applicability:
1,2 Emergency Action Levels (EAL):
Note: A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.
- 1. Automatic or manual Trip did not shutdown the reactor as indicated by Reactor Power > 5%.
AND
- 2. DSS / manual actions taken at the Console Center are not successful in shutting down the reactor as indicated by Reactor Power > 5%.
No Change Difference Deviation
- 1) Listed site specific indications to ensure timely classification.
- 2) Mode 2 included in operating mode applicability as per developer notes.
- 3) Removed the following A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria from the basis section since the reactor shutdown criteria is now listed within the EAL.
X
CCNPP Page 34 of 67 NEI 99-01 Rev 6 Proposed EAL Justification SU5 Initiating Condition: UNUSUAL EVENT Automatic or manual (trip [PWR] / scram [BWR]) fails to shutdown the reactor.
Operating Mode Applicability:
Power Operation Example Emergency Action Levels: (1 or 2)
Note: A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.
- 1. a. An automatic (trip [PWR] / scram [BWR]) did not shutdown the reactor.
AND
- b.
A subsequent manual action taken at the reactor control consoles is successful in shutting down the reactor.
- 2. a. A manual trip ([PWR] / scram [BWR]) did not shutdown the reactor.
AND
- b. EITHER of the following:
- 1. A subsequent manual action taken at the reactor control consoles is successful in shutting down the reactor.
- 2. A subsequent automatic (trip [PWR] / scram [BWR]) is successful in shutting down the reactor.
MU3 Initiating Condition:
Automatic or manual trip fails to shutdown the reactor.
Operating Mode Applicability:
1,2 Emergency Action Levels (EAL):
Note: A manual action is any operator action, or set of actions, which causes the control rods to be rapidly inserted into the core, and does not include manually driving in control rods or implementation of boron injection strategies.
- 1. a. Automatic Trip did not shutdown the reactor as indicated by Reactor Power > 5%.
AND
- b. Subsequent DSS / manual action taken at the Console Center is successful in shutting down the reactor as indicated by reactor power <
5%.
- 2. a. Manual Trip did not shutdown the reactor as indicated by Reactor Power
> 5%.
AND
- b. EITHER of the following:
- 1. Subsequent DSS / manual action taken at the Console Center is successful in shutting down the reactor as indicated by reactor power < 5%.
- 2. Subsequent DSS / automatic Trip is successful in shutting down the reactor as indicated by reactor power < 5%.
No Change Difference Deviation
- 1) Listed site specific indications to ensure timely classification.
- 2) Mode 2 included in operating mode applicability as per developer notes.
- 3) Removed the following A reactor shutdown is determined in accordance with applicable Emergency Operating Procedure criteria from the basis section since the reactor shutdown criteria is now listed within the EAL.
X
CCNPP Page 35 of 67 NEI 99-01 Rev 6 Proposed EAL Justification SA2 Initiating Condition: ALERT UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress.
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels:
Note:
The Emergency Director should declare the Alert promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.
- 1. a. An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the Control Room for 15 minutes or longer.
[see table below]
[ BWR parameter list]
[ PWR parameter list]
Reactor Power Reactor Power RPV Level RCS Level RPV Pressure RCS Pressure Primary Containment Pressure In Core/Core Exit Temperature Suppression Pool Level Levels in at least (site specific number) steam generators Suppression Pool Temperature Steam Generator Auxiliary or Emergency Feed Water Flow AND
- b. Any of the following transient events in progress.
Automatic or Manual runback greater than 25% thermal reactor power Electrical load rejection greater than 25% full electrical load Reactor Scram [BWR] / trip [PWR]
ECCS (SI) actuation Thermal power oscillations greater than 10% [BWR]
MA4 Initiating Condition:
UNPLANNED loss of Control Room indications for 15 minutes or longer with a significant transient in progress.
Operating Mode Applicability:
1, 2, 3, 4 Emergency Action Levels (EAL):
Note:
The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. a UNPLANNED event results in the inability to monitor one or more Table M1 parameters from within the Control Room for > 15 minutes.
Table M1 Control Room Parameters Reactor Power PZR Level RCS Pressure In Core/Core Exit Temperature Level in at least one Steam Generator.
Auxiliary Feed Water Flow AND
- b. ANY Table M2 transient in progress.
Table M2 Significant Transients Automatic Turbine Runback >25% thermal reactor power Electrical Load Rejection >25% full electrical load Reactor Trip Safety Injection Actuation No Change Difference Deviation
- 1) Listed site specific number of steam generators in Table M1 to ensure timely classification.
- 2) Changed the wording of 1a when referring to the site specific Table format.
- 3) Removed reference to manual runback since CCNPP does not have this capability.
X
CCNPP Page 36 of 67 NEI 99-01 Rev 6 Proposed EAL Justification SU2 Initiating Condition: UNUSUAL EVENT UNPLANNED loss of Control Room indications for 15 minutes or longer.
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels:
Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.
An UNPLANNED event results in the inability to monitor one or more of the following parameters from within the Control Room for 15 minutes or longer.
[see table below]
[ BWR parameter list]
[ PWR parameter list]
Reactor Power Reactor Power RPV Level RCS Level RPV Pressure RCS Pressure Primary Containment Pressure In Core/Core Exit Temperature Suppression Pool Level Levels in at least (site specific number) steam generators Suppression Pool Temperature Steam Generator Auxiliary or Emergency Feed Water Flow MU4 Initiating Condition:
UNPLANNED loss of Control Room indications for 15 minutes or longer.
Operating Mode Applicability:
1, 2, 3, 4 Emergency Action Levels (EAL):
Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
UNPLANNED event results in the inability to monitor one or more Table M1 parameters from within the Control Room for > 15 minutes.
Table M1 Control Room Parameters Reactor Power PZR Level RCS Pressure In Core/Core Exit Temperature Level in at least one Steam Generator.
Auxiliary Feed Water Flow No Change Difference Deviation
- 1) Listed site specific number of steam generators in Table M1 to ensure timely classification.
- 2) PZR Level used as the parameter that monitors RCS Level as allowed by the developer notes.
X
CCNPP Page 37 of 67 NEI 99-01 Rev 6 Proposed EAL Justification SA9 Initiating Condition: ALERT Hazardous event affecting a SAFETY SYSTEM needed for the current operating mode.
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels:
- 1. a. The occurrence of ANY of the following hazardous events:
Seismic event (earthquake)
Internal or external flooding event High winds or tornado strike FIRE EXPLOSION (site-specific hazards)
Other events with similar hazard characteristics as determined by the Shift Manager AND
- b. EITHER of the following:
- 1. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM needed for the current operating mode.
- 2. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure needed for the current operating mode.
MA5 Initiating Condition:
Hazardous event affecting a SAFETY SYSTEM required for the current operating mode.
Operating Mode Applicability:
1, 2, 3, 4 Emergency Action Levels (EAL):
Note:
If it is determined that the conditions of MA5 are not met then assess the event via HU3, HU4, or HU6.
- 1. The occurrence of ANY of the following hazardous events:
Seismic event (earthquake)
Internal or external flooding event High winds or tornado strike FIRE EXPLOSION Other events with similar hazard characteristics as determined by the Shift Manager AND
- 2. EITHER of the following:
- a. Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.
- b. The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure required by Technical Specifications for the current operating mode.
No Change Difference Deviation
- 1) No additional site specific hazards noted
- 2) Changed the word "needed" to "required" in the IC and "required by Technical Specification" in the EAL to be consistent with terminology used by operators and minimize confusion.
- 3) Added note to easily direct the operator to potential lesser ICs.
X
CCNPP Page 38 of 67 NEI 99-01 Rev 6 Proposed EAL Justification SU4 Initiating Condition: UNUSUAL EVENT RCS leakage for 15 minutes or longer.
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: (1 or 2 or 3)
Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.
- 1. RCS unidentified or pressure boundary leakage greater than (site-specific value) for 15 minutes or longer.
- 2. RCS identified leakage greater than (site-specific value) for 15 minutes or longer
- 3. Leakage from the RCS to a location outside containment greater than 25 gpm for 15 minutes or longer MU6 Initiating Condition:
RCS leakage for 15 minutes or longer.
Operating Mode Applicability:
1, 2, 3, 4 Emergency Action Levels (EAL):
Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. RCS unidentified or pressure boundary leakage > 10 gpm for > 15 minutes OR
- 3. Leakage from the RCS to a location outside containment >25 gpm for
> 15 minutes No Change Difference Deviation
- 1) Listed site specific values to ensure timely classification.
- 2) For EAL #1 a site-specific leak rate value of 10 gpm was used, for EAL #2 and EAL #3 a site-specific value of 25 gpm was used in accordance with guidance of NEI 99-01 Revision 6.
X
CCNPP Page 39 of 67 NEI 99-01 Rev 6 Proposed EAL Justification SU6 Initiating Condition: UNUSUAL EVENT Loss of all onsite or offsite communications capabilities Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: (1 or 2 or 3)
- 1. Loss of ALL of the following onsite communication methods:
(site-specific list of communications method
- 2. Loss of ALL of the following ORO communications s) methods:
(site-specific list of communications methods)
- 3. Loss of ALL of the following NRC communications methods:
(site-specific list of communications methods)
MU7 Initiating Condition:
Loss of all onsite or offsite communication capabilities.
Operating Mode Applicability:
1, 2, 3, 4 Emergency Action Levels (EAL):
- 1. Loss of ALL Table M3 Onsite communications capability affecting the ability to perform routine operations.
- 2. Loss of ALL Table M3 Offsite communication capability affecting the ability to perform offsite notifications.
- 3. Loss of ALL Table M3 NRC communication capability affecting the ability to perform NRC notifications.
Table M3 Communications Capability System Onsite Offsite NRC Plant Page System X
CCNPP Radio System X
X Commercial landline telephones X
X X
FTS 2001 telephone system (HPN, ENS)
X Satellite Phone System X
X No Change Difference Deviation
- 1) Listed site specific communication methods to ensure timely classification.
- 2) Added a descriptor sentence as to the ability being affected for each EAL.
X
CCNPP Page 40 of 67 NEI 99-01 Rev 6 Proposed EAL Justification SU7 Initiating Condition: UNUSUAL EVENT Failure to isolate containment or loss of containment pressure control. [PWR]
Operating Mode Applicability:
Power Operation, Startup, Hot Standby, Hot Shutdown Example Emergency Action Levels: (1 or 2)
- 1. a. Failure of containment to isolate when required by an actuation signal.
AND
- b.
ALL required penetrations are not closed within 15 minutes of the actuation signal.
- 2. a. Containment pressure greater than (site-specific pressure).
AND
- b. Less than one full train of (site-specific system or equipment) is operating per design for 15 minutes or longer.
MU8 Initiating Condition:
Failure to isolate containment or loss of containment pressure control.
Operating Mode Applicability:
1, 2, 3, 4 Emergency Action Levels (EAL):
- 1. a. Failure of containment to isolate when required by an actuation signal.
AND
- b. ANY required penetration remains open > 15 minutes from the actuation signal.
- 2. a. Containment pressure > 4.25 psig AND
- b. Cannot meet containment design cooling by at least one of the following for > 15 minutes:
2 Containment Spray Pumps Operating 3 CACs Operating 1 Containment Spray Pump and 2 CACs Operating No Change Difference Deviation
- 1) Listed site specific indications to ensure timely classification.
- 2) Reworded EAL 1.b to be a positive statement X
CCNPP Page 41 of 67 NEI 99-01 Rev 6 Proposed EAL Justification CA2 Initiating Condition: ALERT Loss of all offsite and all onsite AC power to emergency buses for 15 minutes or longer.
Operating Mode Applicability:
Cold Shutdown, Refueling, Defueled Example Emergency Action Levels:
Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.
Loss of ALL offsite and ALL onsite AC Power to (site-specific emergency buses) for 15 minutes or longer.
CA1 Initiating Condition:
Loss of all offsite and all onsite AC power to emergency busses for 15 minutes or longer.
Operating Mode Applicability:
5, 6, D Emergency Action Levels (EAL):
Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
AND
- 2. Failure to restore power to at least one 4kV vital bus in < 15 minutes from the time of loss of both offsite and onsite AC power.
No Change Difference Deviation
- 1) Listed site specific equipment to ensure timely classification.
- 2) Formatted to 1 and 2 to keep the formatting consistent within the EALs.
X
CCNPP Page 42 of 67 NEI 99-01 Rev 6 Proposed EAL Justification CU2 Initiating Condition: UNUSUAL EVENT Loss of all but one AC power source to emergency buses for 15 minutes or longer.
Operating Mode Applicability:
Cold Shutdown, Refueling, Defueled Example Emergency Action Levels:
Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.
- 1. a. AC power capability to (site-specific emergency buses) is reduced to a single power source for 15 minutes or longer.
AND
- b. Any additional single power source failure will result in loss of all AC power to SAFETY SYSTEMS.
CU1 Initiating Condition:
Loss of all but one AC power source to emergency buses for 15 minutes or longer.
Operating Mode Applicability:
5, 6, D Emergency Action Levels (EAL):
Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. AC power capability to 4kV vital buses 11(21) and 14(24) reduced to only one of the following power sources for > 15 minutes.
500kV transmission line 5051*
500kV transmission line 5052*
500kV transmission line 5072*
SMECO line, if aligned Emergency Diesel Generator 1(2)A DG Emergency Diesel Generator 1(2)B DG Emergency Diesel Generator 0C DG, if aligned
- A credited 500kV line must have an independent 13kV service transformer AND
- 2. ANY additional single power source failure will result in a loss of ALL AC power to SAFETY SYSTEMS.
No Change Difference Deviation
- 1) Listed site specific equipment to ensure timely classification.
X
CCNPP Page 43 of 67 NEI 99-01 Rev 6 Proposed EAL Justification CA6 Initiating Condition - ALERT Hazardous event affecting SAFETY SYSTEM needed for the current operating mode.
Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels:
- 1. a. The occurrence of ANY of the following hazardous events:
Seismic event (earthquake)
Internal or external flooding event High winds or tornado strike FIRE EXPLOSION (site-specific hazards)
Other events with similar hazard characteristics as determined by the Shift Manager AND
- b. EITHER of the following:
- 1.
Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM needed for the current operating mode.
- 2.
The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure needed for the current operating mode.
CA2 Initiating Condition:
Hazardous event affecting SAFETY SYSTEM required for the current operating mode.
Operating Mode Applicability:
5, 6 Emergency Action Levels (EAL):
Note:
If it is determined that the conditions of CA2 are not met then assess the event via HU3, HU4, or HU6.
- 1. The occurrence of ANY of the following hazardous events:
Seismic event (earthquake)
Internal or external flooding event High winds or tornado strike FIRE EXPLOSION Other events with similar hazard characteristics as determined by the Shift Manager AND
- 2. EITHER of the following:
- a.
Event damage has caused indications of degraded performance in at least one train of a SAFETY SYSTEM required by Technical Specifications for the current operating mode.
- b.
The event has caused VISIBLE DAMAGE to a SAFETY SYSTEM component or structure required by Technical Specifications for the current operating mode.
No Change Difference Deviation
- 1) No additional site specific hazards noted
- 2) Changed the word "needed" to "required" in the IC and "required by Technical Specification" in the EAL to be consistent with terminology used by operators and minimize confusion.
- 3) Added note to easily direct the operator to potential lesser ICs.
X
CCNPP Page 44 of 67 NEI 99-01 Rev 6 Proposed EAL Justification CU4 Initiating Condition: UNUSUAL EVENT Loss of Vital DC power for 15 minutes or longer.
Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels:
Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.
Indicated voltage is less than (site-specific bus voltage value) on required Vital DC buses for 15 minutes or longer.
CU3 Initiating Condition:
Loss of Vital DC power for 15 minutes or longer.
Operating Mode Applicability:
5, 6 Emergency Action Levels (EAL):
Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
Voltage is < 105 VDC on required 125 VDC busses 11, 12, 21, and 22 for > 15 minutes.
No Change Difference Deviation
- 1) Listed site specific voltage and equipment to ensure timely classification.
- 2) Removed the word "indicated" this will allow for an indication problem to not cause confusion on the need to declare.
X
CCNPP Page 45 of 67 NEI 99-01 Rev 6 Proposed EAL Justification CU5 Initiating Condition: UNUSUAL EVENT Loss of all onsite or offsite communications capabilities Operating Mode Applicability:
Cold Shutdown, Refueling, Defuled Example Emergency Action Levels: (1 or 2 or 3)
- 1. Loss of ALL of the following onsite communication methods:
(site-specific list of communications method
- 2. Loss of ALL of the following ORO communications s) methods:
(site-specific list of communications methods)
- 3. Loss of ALL of the following NRC communications methods:
(site-specific list of communications methods)
CU4 Initiating Condition:
Loss of all onsite or offsite communication capabilities.
Operating Mode Applicability:
5, 6, D Emergency Action Levels (EAL):
- 1. Loss of ALL Table C1 Onsite communications capability affecting the ability to perform routine operations.
- 2. Loss of ALL Table C1 Offsite communication capability affecting the ability to perform offsite notifications.
- 3. Loss of ALL Table C1 NRC communication capability affecting the ability to perform NRC notifications.
Table C1 Communications Capability System Onsite Offsite NRC Plant Page System X
CCNPP Radio System X
X Commercial landline telephones X
X X
FTS 2001 telephone system (HPN, ENS)
X Satellite Phone System X
X No Change Difference Deviation
- 1) Listed site specific communications methods to ensure timely classification
- 2) Added a descriptor sentence as to the capability being affected for each EAL.
X
CCNPP Page 46 of 67 NEI 99-01 Rev 6 Proposed EAL Justification CA3 Initiating Condition: ALERT Inability to maintain the plant in cold shutdown.
Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)
Note: The Emergency Director should declare the Alert promptly upon determining that the applicable has been exceeded, or will likely be exceeded.
- 1. UNPLANNED increase in RCS temperature to greater than (site-specific Technical Specification cold shutdown temperature limit) for greater than the duration specified in the following table.
- 2. UNPLANNED RCS pressure increase greater than (site-specific pressure reading). (This EAL does not apply during water-solid plant conditions.
[PWR])
Table: RCS Heat-up Duration Thresholds RCS Status Containment Closure Status Heat-up Duration Intact (but not RCS Reduced Inventory [PWR])
Not Applicable 60 minutes*
Not Intact (or at reduced inventory
[PWR])
Established 20 minutes*
Not Established 0 minutes
- If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, the EAL is not applicable.
CA5 Initiating Condition:
Inability to maintain plant in cold shutdown.
Operating Mode Applicability:
5, 6 Emergency Action Levels (EAL):
Note:
The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.
- 1. UNPLANNED rise in RCS temperature > 200ºF for > Table C2 duration.
Table C2 RCS Heat-up Duration Thresholds RCS Status Containment Closure Status Heat-up Duration Intact Not Applicable 60 minutes*
Not Intact OR Reduced Inventory Established 20 minutes*
Not Established 0 minutes
- If an RCS heat removal system is in operation within this time frame and RCS temperature is being reduced, then EAL #1 is not applicable.
- 2. UNPLANNED RCS pressure rise > 10 psig as a result of temperature rise. (This EAL does not apply in solid plant conditions.)
No Change Difference Deviation
- 1) Listed site specific Technical Specification cold shutdown temperature limit to ensure timely classification.
- 2) Listed site specific pressure reading to enhance timely classification.
- 3) Added the following note, taken from the basis section of the EAL, to bring it to the attention of the SM/ED when using the procedure matrix (11x17 quick reference control room document) A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when heat removal function is available does not warrant classification.
- 4) Changed the word increase to rise in the EALs to be consistent with operations language and training.
- 5) In Table C2 removed (but not RCS reduced inventory) from Intact since it was redundant to the RCS status of Not Intact or Reduced Inventory.
X
CCNPP Page 47 of 67 NEI 99-01 Rev 6 Proposed EAL Justification CU3 Initiating Condition: UNUSUAL EVENT UNPLANNED increase in RCS temperature.
Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)
Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.
- 1. UNPLANNED increase in RCS temperature to greater than (site-specific Technical Specification cold shutdown temperature limit).
[BWR]) level indication for 15 minutes or longer.
CU5 Initiating Condition:
UNPLANNED rise in RCS temperature.
Operating Mode Applicability:
5, 6 Emergency Action Levels (EAL):
Note:
The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when the heat removal function is available does not warrant a classification.
- 1. UNPLANNED rise in RCS temperature > 200ºF.
- 2. Loss of the following for > 15 minutes.
ALL RCS temperature indications AND ALL reactor vessel/RCS level indications No Change Difference Deviation
- 1) Listed site specific Technical Specification cold shutdown temperature limit to ensure timely classification.
- 2) Changed the word increase to rise in the initiating condition to be consistent with operations language and training.
- 3) Added the following note, taken from the basis section of the EAL, to bring it to the attention of the SM/ED when using the quick reference matrix A momentary UNPLANNED excursion above the Technical Specification cold shutdown temperature limit when heat removal function is available does not warrant classification.
X
CCNPP Page 48 of 67 NEI 99-01 Rev 6 Proposed EAL Justification
CCNPP Page 49 of 67 CG1 Initiating Condition: GENERAL EMERGENCY Loss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory affecting fuel clad integrity with containment challenged.
Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)
Note: The Emergency Director should declare the Unusual Event promptly upon determining that 30 minutes time has been exceeded, or will likely be exceeded.
- 1. a. (Reactor vessel/RCS [PWR] or RPV [BWR]) vessel level less than (site-specific level) for 30 minutes or longer.
AND
- b. ANY indication from the Containment Challenge Table
- 2. a.. (Reactor vessel/RCS [PWR] or RPV [BWR]) vessel level cannot be monitored for 30 minutes or longer.
AND
- b. Core uncovery is indicated by ANY of the following:
(Site-specific radiation monitor) reading greater than (site-specific value)
Erratic source range monitor indication [PWR]
UNPLANNED increase in (site-specific sump and/or tank levels) of sufficient magnitude to indicate core uncovery (Other site-specific indications)
AND
- c. ANY indication from the Containment Challenge Table).
Table: Containment Challenge Table CONTAINMENT CLOSURE not established*
(Explosive mixture) exists inside containment UNPLANNED increase in containment pressure Secondary containment radiation monitor reading above (site-specific value) [BWR]
- if CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency is not required.
CG6 Initiating Condition:
Loss of reactor vessel / RCS inventory affecting fuel clad integrity with containment challenged.
Operating Mode Applicability:
5, 6 Emergency Action Levels (EAL):
Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. a. RCS Level < 32.9 ft. (10 in. 8th alarm on RVLMS*) for > 30 minutes.
- This alarm is 10 in. above top of active fuel, use only when a valid RFP/RCS level indication is not available.
AND
- b. ANY Containment Challenge Indication (Table C4)
- 2. a. Reactor vessel / RCS level cannot be monitored for > 30 minutes.
AND
- b. Core uncovery is indicated by ANY of the following:
Table C3 indications of a sufficient magnitude to indicate core uncovery.
OR Erratic WRNI indication.
OR Containment Radiation reading > 3 R/hr.
AND
- 3. ANY Containment Challenge Indication (Table C4)
Table C3 Indications of RCS Leakage UNPLANNED Containment Sump level rise*
UNPLANNED Auxiliary Bldg. Sump level rise*
UNPLANNED Miscellaneous Waste System Tank level rise*
UNPLANNED RWT level rise*
UNPLANNED RC Waste System Tank level rise*
UNPLANNED rise in RCS makeup Observation of leakage or inventory loss
- Rise in level is attributed to a loss of reactor vessel/RCS inventory.
Table C4 Containment Challenge Indications Hydrogen Concentration in Containment > 4%
UNPLANNED rise in containment pressure CONTAINMENT CLOSURE not established*
- If CONTAINMENT CLOSURE is re-established prior to exceeding the 30-minute core uncovery time limit, then escalation to a General Emergency is not required for this containment challenge.
No Change Difference Deviation
- 1) Listed site specific radiation indication to ensure timely classification
- 2) Listed site specific sumps and tanks to ensure timely classification
- 3) Listed Explosive mixture in the Containment Challenge Table to ensure timely classification
- 4) Changed the word increase to rise to be consistent with operations language and training.
X
CCNPP Page 50 of 67 NEI 99-01 Rev 6 Proposed EAL Justification CS1 Initiating Condition: SITE AREA EMERGENCY Loss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory affecting core decay heat removal capability.
Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2 or 3)
Note: The Emergency Director should declare the Unusual Event promptly upon determining that 30 minutes time has been exceeded, or will likely be exceeded.
- 1. a. CONTAINMENT CLOSURE not established.
AND
- b. (Reactor vessel/RCS [PWR] or RPV [BWR]) level less than (site-specific level).
- 2. a. CONTAINMENT CLOSURE established.
AND
- b. (Reactor vessel/RCS [PWR] or RPV [BWR]) level less than (site-specific level).
- 3.
- a. (Reactor vessel/RCS [PWR] or RPV [BWR]) level cannot be monitored for 30 minutes or longer.
AND
- b. Core uncovery is indicated by ANY of the following:
(Site-specific radiation monitor) reading greater than (site-specific value)
Erratic source range monitor indication [PWR]
UNPLANNED increase in (site-specific sump and/or tank levels) of sufficient magnitude to indicate core uncovery (Other site-specific indications)
CS6 Initiating Condition:
Loss of reactor vessel / RCS inventory affecting core decay heat removal capabilities.
Operating Mode Applicability:
5, 6 Emergency Action Levels (EAL):
Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. With CONTAINMENT CLOSURE established RCS Level < 32.9 ft. (10 in. 8th alarm on RVLMS*)
- This alarm is 10 in. above top of active fuel, use only when a valid RFP/RCS level indication is not available.
- 2. With CONTAINMENT CLOSURE not established RCS Level < 34.7 ft.
(19 in. 7th alarm on RVLMS)
- 3. a. Reactor vessel / RCS level cannot be monitored for >30 minutes.
AND
- b. Core uncovery is indicated by ANY of the following:
Table C3 indications of a sufficient magnitude to indicate core uncovery.
OR Erratic WRNI indication.
OR Containment Radiation reading > 3 R/hr.
Table C3 Indications of RCS Leakage UNPLANNED Containment Sump level rise*
UNPLANNED Auxiliary Bldg. Sump level rise*
UNPLANNED Miscellaneous Waste System Tank level rise*
UNPLANNED RWT level rise*
UNPLANNED RC Waste System Tank level rise*
UNPLANNED rise in RCS makeup Observation of leakage or inventory loss
- Rise in level is attributed to a loss of reactor vessel/RCS inventory.
No Change Difference Deviation
- 1) Listed site specific radiation indication to ensure timely classification
- 2) Listed site specific sumps and tanks to ensure timely classification
X
CCNPP Page 51 of 67 NEI 99-01 Rev 6 Proposed EAL Justification CA1 Initiating Condition: ALERT Loss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)
Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes time has been exceeded, or will likely be exceeded.
- 1. Loss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory as indicated by level less than (site-specific level).
- 2.
- a. (Reactor vessel/RCS [PWR] or RPV [BWR]) level cannot be monitored for 15 minutes or longer AND
- b. UNPLANNED increase in (site-specific sump and/or tank) levels due to a loss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory.
CA6 Initiating Condition:
Loss of reactor vessel / RCS inventory Operating Mode Applicability:
5, 6 Emergency Action Levels (EAL):
Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
< 35.6 ft. (29 in. 6th alarm on RVLMS).
- 2. a. Reactor vessel / RCS level cannot be monitored for > 15 minutes.
AND
- b. Loss of reactor vessel / RCS inventory per Table C3 indications.
Table C3 Indications of RCS Leakage UNPLANNED Containment Sump level rise*
UNPLANNED Auxiliary Bldg. Sump level rise*
UNPLANNED Miscellaneous Waste System Tank level rise*
UNPLANNED RWT level rise*
UNPLANNED RC Waste System Tank level rise*
UNPLANNED rise in RCS makeup Observation of leakage or inventory loss
- Rise in level is attributed to a loss of reactor vessel/RCS inventory.
No Change Difference Deviation
- 1) Listed site specific levels to ensure timely classification.
- 2) Listed site specific sumps and tanks to ensure timely classification.
X
CCNPP Page 52 of 67 NEI 99-01 Rev 6 Proposed EAL Justification CU1 Initiating Condition: UNUSUAL EVENT UNPLANNED loss of (reactor vessel/RCS [PWR] or RPV [BWR]) inventory for 15 minutes or longer.
Operating Mode Applicability:
Cold Shutdown, Refueling Example Emergency Action Levels: (1 or 2)
Note: The Emergency Director should declare the Unusual Event promptly upon determining that 15 minutes has been exceeded, or will likely be exceeded.
- 1. UNPLANNED loss of reactor coolant results in (reactor vessel/RCS
[PWR] or RPV [BWR]) level less than a required lower limit for 15 minutes or longer.
- 2. a. (Reactor vessel/RCS [PWR] or RPV [BWR]) level cannot be monitored.
AND
- b. UNPLANNED increase in (site-specific sump and/or tank) levels.
CU6 Initiating Condition:
UNPLANNED loss of reactor vessel / RCS inventory for 15 minutes or longer.
Operating Mode Applicability:
5, 6 Emergency Action Levels (EAL):
Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. UNPLANNED loss of reactor coolant results in the inability to restore and maintain reactor vessel / RCS level to > procedurally established lower limit for > 15 minutes.
- 2. a. Reactor vessel / RCS level cannot be monitored.
AND
- b. Loss of reactor vessel / RCS inventory per Table C3 indications.
Table C3 Indications of RCS Leakage UNPLANNED Containment Sump level rise*
UNPLANNED Auxiliary Bldg. Sump level rise*
UNPLANNED Miscellaneous Waste System Tank level rise*
UNPLANNED RWT level rise*
UNPLANNED RC Waste System Tank level rise*
UNPLANNED rise in RCS makeup Observation of leakage or inventory loss
- Rise in level is attributed to a loss of reactor vessel/RCS inventory.
No Change Difference Deviation
- 1) Listed site specific sumps and tanks to ensure timely classification.
- 2) Described a required lower limit as a procedurally established lower limit.
This is consistent with the basis discussion in NEI 99-01 Rev 6 CU1 due to variable limits.
X
CCNPP Page 53 of 67 NEI 99-01 Rev 6 Proposed EAL Justification HG1 Initiating Condition: GENERAL EMERGENCY HOSTILE ACTION resulting in loss of physical control of the facility.
Operating Mode Applicability:
All Example Emergency Action Levels:
- 1. a. A HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the (site-specific security shift supervision).
AND
- b. EITHER of the following:
- 1. ANY of the following safety functions cannot be controlled or maintained.
Reactivity control Core cooling [PWR] / RPV water level [BWR]
- 2. Damage to spent fuel has occurred or is IMMINENT Not used No Change Difference Deviation EAL HG1 has two distinct parts, they will be addressed separately as follows:
- 1. Hostile Action in the Protected Area is bounded by EALs HS1 and HS7.
Hostile Action resulting in a loss of physical control is bound by EAL HG7, as well as any event that may lead to radiological releases to the public in excess of Environmental Protection Agency (EPA) Protective Action Guides (EPA PAGs).
- a. If, for whatever reason, the Control Room (CR) must be evacuated, and control of safety functions (reactivity control, core cooling (PWR) cannot be reestablished, then EAL HS6 would apply, as well as EAL HS7 if desired by the EAL decision-maker.
- b. Also, as stated above, any event (including Hostile Action) that could reasonably be expected to have a release exceeding EPA PAGs would be bound by EAL HG7.
- c. From a Hostile Action perspective, EALs HS1, HS7, and HG7 are appropriate and therefore makes this part of HG1 redundant and unnecessary.
- d. From a loss of physical control perspective, EALs HS6, HS7, and HG7 are appropriate and therefore makes this part of EAL HG1 redundant and unnecessary.
- 2. Any event which causes a loss of spent fuel pool level will be bounded by EALs AA2, AS2, and AG2 (Exelon RG2, RS2 and RA2) regardless of whether it was based upon a Hostile Action or not, thus making this part of HG1 redundant and unnecessary.
- a. An event that leads to a radiological release will be bounded by EALs AU1, AA1, AS1, and AG1 (Exelon RG1, RS1, RA1 and RU1). Events that lead to radiological releases in excess of EPA PAGs will be bounded by EALs AG1 (Exelon RG1) and HG7, thus making this part of EAL HG1 redundant and unnecessary.
X
CCNPP Page 54 of 67 NEI 99-01 Rev 6 Proposed EAL Justification HS1 Initiating Condition: SITE AREA EMERGENCY HOSTILE ACTION within the Protected Area.
Operating Mode Applicability:
All Example Emergency Action Levels:
A HOSITLE ACTION is occurring or has occurred within the PROTECTED AREA as reported by the (site-security shift supervision).
HS1 Initiating Condition:
HOSTILE ACTION within the PROTECTED AREA.
Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Levels (EAL):
A notification from the Security Force that a HOSTILE ACTION is occurring or has occurred within the PROTECTED AREA.
No Change Difference Deviation
- 1) List site security shift supervision as Security Force.
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CCNPP Page 55 of 67 NEI 99-01 Rev 6 Proposed EAL Justification HA1 Initiating Condition: ALERT HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.
Operating Mode Applicability:
All Example Emergency Action Levels: (1 or 2)
- 1. A HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLLED AREA as reported by the (site-specific security shift supervision).
- 2. A validated notification from NRC of an aircraft attack threat within 30 minutes of the site.
HA1 Initiating Condition:
HOSTILE ACTION within the OWNER CONTROLLED AREA or airborne attack threat within 30 minutes.
Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Levels (EAL):
- 1. A validated notification from NRC of an aircraft attack threat < 30 minutes from the site.
- 2. Notification by the Security Force that a HOSTILE ACTION is occurring or has occurred within the OWNER CONTROLED AREA.
No Change Difference Deviation
- 1) List site security shift supervision as Security Force.
- 2) Changed order of EALs to conform with the current legacy Exelon Fleet order.
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CCNPP Page 56 of 67 NEI 99-01 Rev 6 Proposed EAL Justification HU1 Initiating Condition: UNUSUAL EVENT Confirmed SECURITY CONDITION or threat.
Operating Mode Applicability:
All Example Emergency Action Levels: (1 or 2 or 3)
- 1. A SECURITY CONDITION that does not involve a HOSTILE ACTION as reported by the (site-specific security shift supervision).
- 2. Notification of a credible security threat directed at the site.
- 3. A validated notification from the NRC providing information of an aircraft threat.
HU1 Initiating Condition:
Confirmed SECURITY CONDITION or threat.
Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Levels (EAL):
- 1. Notification of a credible security threat directed at the site as determined per SY-AA-101-132, Security Assessment and Response to Unusual Activities.
- 2. A validated notification from the NRC providing information of an aircraft threat.
- 3. Notification by the Security Force of a SECURITY CONDITION that does not involve a HOSTILE ACTION.
No Change Difference Deviation
- 1) List site security shift supervision as Security Force.
- 2) Further described credible security threat through listing a site specific procedure.
- 3) Changed order of EALs to conform with the current legacy Exelon Fleet order.
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CCNPP Page 57 of 67 NEI 99-01 Rev 6 Proposed EAL Justification HS6 Initiating Condition: SITE AREA EMERGENCY Inability to control a key safety function from outside the Control Room.
Operating Mode Applicability:
All Example Emergency Action Levels: (1 and 2)
Note: The Emergency Director should declare the event promptly upon determining that (site-specific number of minutes) has been exceeded, or will likely be exceeded.
- 1. An event has resulted in plant control being transferred from the Control Room to (site-specific remote shutdown panels and local control stations).
- 2. Control of ANY of the following key safety functions is not reestablished within (site-specific number of minutes).
Reactivity control Core cooling [PWR] / RPV water level [BWR]
RCS heat removal HS2 Initiating Condition:
Inability to control a key safety function from outside the Control Room.
Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Levels (EAL):
Note: The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per:
AOP-9A Control Room Evacuation and Safe Shutdown Due to a Severe Control Room Fire OR AOP-11 Control Room Evacuation and Safe Shutdown - Non-Fire Conditions AND
- 2. Control of ANY Table H1 key safety function is not reestablished in
< 15 minutes.
Table H1 Safety Functions Reactivity Control (ability to shut down the reactor and keep it shutdown)
Core and RCS Heat Removal (ability to cool the core and maintain heat sink)
No Change Difference Deviation
- 1) EAL uses the site specific Control Room evacuation procedures to effectively list all of the alternate locations, panels, and stations requested by the developer notes. This would be the procedures the Control Room would enter should such an event occur, this allows for greater clarity as to when this EAL would apply than if each panel and station used in alternate shutdown were to be listed,
- 2) Added descriptors to better explain each safety function and allow for a timely classification.
- 3) Changed "An event" to" A Control Room evacuation" to remove confusion if partial plant control was transferred to outside the control room with the control room still manned, due to testing or equipment failure.
- 4) Combined the safety functions of core cooling and RCS heat removal as per Calvert Cliffs Nuclear Power Plant Post-Trip Immediate Actions EOP-0 Technical Basis Document. The basis document states:
Per the Emergency Procedure Guidelines (EPG), the application of the safety function concept in a restructured format is acceptable as the format contains actions and acceptance criteria necessary to control, and fulfill, the individual safety functions, and the safety function hierarchy is preserved.
Throughout the Emergency Operating Procedures (EOPs), CCNPP combined the. and the Core Heat Removal and the RCS Heat Removal safety function into Core and RCS Heat Removal safety function.
To maintain consistency with the CCNPP EOPs the same was performed here.
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CCNPP Page 58 of 67 NEI 99-01 Rev 6 Proposed EAL Justification HA6 Initiating Condition: ALERT Control Room evacuation resulting in transfer of plant control to alternate locations.
Operating Mode Applicability:
All Example Emergency Action Levels:
An event has resulted in plant control being transferred from the Control Room to (site-specific remote shutdown panels and local control stations).
HA2 Initiating Condition:
Control Room evacuation resulting in transfer of plant control to alternate locations.
Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Levels (EAL):
A Control Room evacuation has resulted in plant control being transferred from the Control Room to alternate locations per:
AOP-9A Control Room Evacuation and Safe Shutdown Due to a Severe Control Room Fire OR AOP-11 Control Room Evacuation and Safe Shutdown - Non-Fire Conditions No Change Difference Deviation
- 1) EAL uses the site specific Control Room evacuation procedures to effectively list all of the alternate locations, panels, and stations requested by the developer notes. This would be the procedures the Control Room would enter should such an event occur, this allows for greater clarity as to when this EAL would apply than if each panel and station used in alternate shutdown were to be listed,
- 2) Changed "An event" to" A Control Room evacuation" to remove confusion if partial plant control was transferred to outside the control room with the control room still manned, due to testing or equipment failure.
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CCNPP Page 59 of 67 NEI 99-01 Rev 6 Proposed EAL Justification HU4 Initiating Condition: UNUSUAL EVENT FIRE potentially degrading the level of safety of the plant.
Operating Mode Applicability:
All Example Emergency Action Levels: (1 or 2 or 3 or 4)
Note: The Emergency Director should declare the Unusual Event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
- 1. a.
A FIRE is NOT extinguished within 15-minutes of ANY of the following FIRE detection indications:
Report from the field (i.e., visual observation)
Receipt of multiple (more than 1) fire alarms or indications Field verification of a single fire alarm AND
- b. The FIRE is located within ANY of the following plant rooms or areas:
(site-specific list of plant rooms or areas)
- 2. a. Receipt of a single fire alarm (i.e., no other indications of a FIRE).
AND
- b. The FIRE is located within ANY of the following plant rooms or areas:
(site-specific list of plant rooms or areas)
AND
- c. The existence of a FIRE is not verified within 30-minutes of alarm receipt.
- 3. A FIRE within the plant or ISFSI [for plants with an ISFSI outside the plant Protected Area] PROTECTED AREA not extinguished within 60-minutes of the initial report, alarm or indication.
- 4. A FIRE within the plant or ISFSI [for plants with an ISFSI outside the plant Protected Area] PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.
HU3 Initiating Condition:
FIRE potentially degrading the level of safety of the plant.
Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Levels (EAL):
Note:
The Emergency Director should declare the event promptly upon determining that the applicable time has been exceeded, or will likely be exceeded.
Escalation of the emergency classification level would be via IC CA2 or MA5.
- 1. a.
A FIRE in any Table H2 area is not extinguished in <15-minutes of ANY of the following FIRE detection indications:
Report from the field (i.e., visual observation)
Receipt of multiple (more than 1) fire alarms or indications Field verification of a single fire alarm OR
- 2. a. Receipt of a single fire alarm in any Table H2 area (i.e., no other indications of a FIRE).
AND
- b. The existence of a FIRE is not verified in <30-minutes of alarm receipt.
- 3. A FIRE within the plant PROTECTED AREA or ISFSI PROTECTED AREA not extinguished in <60-minutes of the initial report, alarm or indication.
- 4. A FIRE within the plant PROTECTED AREA or ISFSI PROTECTED AREA that requires firefighting support by an offsite fire response agency to extinguish.
Table H2 Vital Areas Containment Building Auxiliary Building Diesel Generator Rooms Intake Structure 1A/0C DG Buildings RWT RWT Rooms CST N0.12 FOST No.21 Auxiliary Feed Pump Rooms No Change Difference Deviation
- 1) Listed site specific list of plant rooms or areas that contain SAFETY SYSTEM equipment to ensure timely classification.
- 2) Incorporated 1.b into 1.a, and 2.b into 2.a
- 3) Added note to easily direct the operator to the potential escalation ICs.
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CCNPP Page 60 of 67 NEI 99-01 Rev 6 Proposed EAL Justification HU2 Initiating Condition: UNUSUAL EVENT Seismic event greater than OBE levels.
Operating Mode Applicability:
All Example Emergency Action Levels:
Seismic event greater than Operating Basis Earthquake (OBE) as indicated by:
- a. (site-specific indication that a seismic event met or exceeded OBE limits)
HU4 Initiating Condition:
Seismic event greater than OBE levels.
Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Levels (EAL):
Note:
Escalation of the emergency classification level would be via IC CA2 or MA5 For emergency classification if EAL 2.b is not able to be confirmed, then the occurrence of a seismic event is confirmed in manner deemed appropriate by the Shift Manager or Emergency Director in < 15 mins of the event.
- 1. Seismic Acceleration Recorder (0-YRC-001) Event Indicator indicates
> Operating Basis Earthquake (OBE)
- 2. When Seismic Monitoring Equipment is not available:
- a. Control Room personnel feel an actual or potential seismic event.
AND
- b. ANY one of the following confirmed in < 15 mins of the event:
The earthquake resulted in Modified Mercalli Intensity (MMI) > VI and occurred < 3.5 miles of the plant.
The earthquake was magnitude > 6.0 The earthquake was magnitude > 5.0 and occurred < 125 miles of the plant.
No Change Difference Deviation
- 1) Listed site specific indication to determining OBE limits have been met or exceeded to ensure timely classification.
- 2) A difference to HU4.2 has been taken to make use of guidance contained in Reg Guide 1.166, Pre-earthquake Planning and Immediate Nuclear Power Plant Operator Post-earthquake Actions, Appendix A that provides guidance to plants without OBE seismic detection on applicable OBE determination. The revised HU4 EAL ensures that the SM/ED will make a timely determination by placing a 15 min clock on the ability to gain additional information through the addition of a note.
- 3) Added note to easily direct the operator to the potential escalation ICs X
CCNPP Page 61 of 67 NEI 99-01 Rev 6 Proposed EAL Justification HA5 Initiating Condition: ALERT Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.
Operating Mode Applicability:
All Example Emergency Action Levels:
Note: If the equipment in the listed room or area was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted.
- 1. a. Release of a toxic, corrosive, asphyxiant or flammable gas into any of the following plant rooms or areas:
(site-specific list of plant rooms or areas with entry-related mode applicability identified)
AND
- b. Entry into the room or area is prohibited or impeded.
HA5 Initiating Condition:
Gaseous release impeding access to equipment necessary for normal plant operations, cooldown or shutdown.
Operating Mode Applicability:
3, 4, 5 Emergency Action Levels (EAL):
Note: If the equipment in the listed room or area was already inoperable, or out of service, before the event occurred, then no emergency classification is warranted.
- 1. Release of a toxic, corrosive, asphyxiant or flammable gas in ANY Table H3 area.
Table H3 Areas with Entry Related Mode Applicability Area Entry Related Mode Applicability 45 West Electrical Penetration Rooms Modes 3, 4, and 5 69 Electrical Penetration Rooms Modes 3, 4, and 5 ECCS Pump Rooms Modes 3, 4, and 5 Charging Pump Rooms Modes 3, 4, and 5 Component Cooling Rooms Modes 3, 4, and 5 AND
- 2. Entry into the room or area is prohibited or impeded No Change Difference Deviation
- 1) Listed plant specific rooms and areas with entry related mode applicability to ensure timely classification.
- 2) Restricted Mode applicability to the modes applicable to Table H3.
- 3) Additional discussion added to the basis section describing Table R4 as follows:
This IC addresses an event involving a release of a hazardous gas that precludes or impedes access to equipment necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal plant procedures. This condition represents an actual or potential substantial degradation of the level of safety of the plant.
Assuming all plant equipment is operating as designed, normal operation is capable from the Main Control Room (MCR). The plant is also able to transition into a hot shutdown condition from the MCR, therefore Table H3 is a list of plant rooms or areas with entry-related mode applicability that contain equipment which require a manual/local action necessary to transition the plant from normal plant operation to cooldown and shutdown as specified in normal operating procedures (establish shutdown cooling), where if this action is not completed the plant would not be able to attain and maintain cold shutdown.
This Table does not include rooms or areas for which entry is required solely to perform actions of an administrative or record keeping nature (e.g., normal rounds or routine inspections).
This Table does not include the Control Room since adequate engineered safety/design features are in place to preclude a Control Room evacuation due to the release of a hazardous gas.
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CCNPP Page 62 of 67 NEI 99-01 Rev 6 Proposed EAL Justification HU3 Initiating Condition: UNUSUAL EVENT Hazardous Event Operating Mode Applicability:
All Example Emergency Action Levels: (1 or 2 or 3 or 4)
Note: EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.
- 1. A tornado strike within the PROTECTED AREA.
- 2. Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component needed for the current operating mode.
- 3. Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).
- 4. A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.
- 5. (Site-specific list of natural or technological hazard events)
HU6 Initiating Condition:
Hazardous Event Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Levels (EAL):
Note:
EAL #4 does not apply to routine traffic impediments such as fog, snow, ice, or vehicle breakdowns or accidents.
Escalation of the emergency classification level would be via IC CA2 or MA5.
- 1. Tornado strike within the PROTECTED AREA.
- 2. Internal room or area flooding of a magnitude sufficient to require manual or automatic electrical isolation of a SAFETY SYSTEM component required by Technical Specifications for the current operating mode.
- 3. Movement of personnel within the PROTECTED AREA is impeded due to an offsite event involving hazardous materials (e.g., an offsite chemical spill or toxic gas release).
- 4. A hazardous event that results in on-site conditions sufficient to prohibit the plant staff from accessing the site via personal vehicles.
- 5. Abnormal Bay water level, as indicated by EITHER:
- a. Bay water level > bottom of the traveling screen cover housing
(+120 in. Mean Sea Level)
- b. Bay water level< 13.6 feet below intake concrete level (-43.2 in. Mean Sea Level)
No Change Difference Deviation
- 1) Included bay water level as part of the site-specific list of natural or technological hazard events.
- 2) Changed the word "needed" to "required by Technical Specifications" in the EAL to be consistent with terminology used by operators and minimize confusion.
- 3) Added note to easily direct the operator to the potential escalation ICs.
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CCNPP Page 63 of 67 NEI 99-01 Rev 6 Proposed EAL Justification HG8 Initiating Condition: GENERAL EMERGENCY Other conditions exist which in the judgment of the Emergency Director warrant declaration of a General Emergency.
Operating Mode Applicability:
All Example Emergency Action Levels:
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 off-site for more than the immediate site area.
HG7 Initiating Condition:
Other conditions exist which in the judgment of the Emergency Director warrant declaration of a General Emergency.
Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Levels (EAL):
Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or IMMINENT substantial core degradation or melting with potential for loss of containment integrity or HOSTILE ACTION that results in an actual loss of physical control of the facility. Releases can be reasonably expected to exceed EPA Protective Action Guideline exposure levels off-site for more than the immediate site area..
No Change Difference Deviation X
CCNPP Page 64 of 67 NEI 99-01 Rev 6 Proposed EAL Justification HS8 Initiating Condition: SITE AREA EMERGENCY Other conditions exist which in the judgment of the Emergency Director warrant declaration of a Site Area Emergency.
Operating Mode Applicability:
All Example Emergency Action Levels:
Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.
HS7 Initiating Condition:
Other conditions exist which in the judgment of the Emergency Director warrant declaration of a Site Area Emergency.
Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Levels (EAL):
Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve actual or likely major failures of plant functions needed for protection of the public or HOSTILE ACTION that results in intentional damage or malicious acts; (1) toward site personnel or equipment that could lead to the likely failure of or; (2) that prevent effective access to equipment needed for the protection of the public. Any releases are not expected to result in exposure levels which exceed EPA Protective Action Guideline exposure levels beyond the site boundary.
No Change Difference Deviation X
CCNPP Page 65 of 67 NEI 99-01 Rev 6 Proposed EAL Justification HA6 Initiating Condition: ALERT Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert.
Operating Mode Applicability:
All Example Emergency Action Levels:
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.
HA7 Initiating Condition:
Other conditions exist which in the judgment of the Emergency Director warrant declaration of an Alert.
Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Levels (EAL):
Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which involve an actual or potential substantial degradation of the level of safety of the plant or a security event that involves probable life threatening risk to site personnel or damage to site equipment because of HOSTILE ACTION. Any releases are expected to be limited to small fractions of the EPA Protective Action Guideline exposure levels.
No Change Difference Deviation X
CCNPP Page 66 of 67 NEI 99-01 Rev 6 Proposed EAL Justification HU7 Initiating Condition: UNUSUAL EVENT Other conditions existing which in the judgment of the Emergency director warrant declaration of an UNUSUAL EVENT.
Operating Mode Applicability:
All Example Emergency Action Levels:
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.
HU7 Initiating Condition:
Other conditions existing which in the judgment of the Emergency director warrant declaration of an Unusual Event.
Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Levels (EAL):
Other conditions exist which in the judgment of the Emergency Director indicate that events are in progress or have occurred which indicate a potential degradation of the level of safety of the plant or indicate a security threat to facility protection has been initiated. No releases of radioactive material requiring offsite response or monitoring are expected unless further degradation of safety systems occurs.
No Change Difference Deviation X
CCNPP Page 67 of 67 NEI 99-01 Rev 6 Proposed EAL Justification E-HU1 Initiating Condition: UNUSUAL EVENT Damage to a loaded cask CONFINEMENT BOUNDARY.
Operating Mode Applicability:
All Example Emergency Action Levels:
Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading greater than (2 times the site-specific cask specific technical specification allowable radiation level) on the surface of the spent fuel cask.
E-HU1 Initiating Condition:
Damage to a loaded cask CONFINEMENT BOUNDARY.
Operating Mode Applicability:
1, 2, 3, 4, 5, 6, D Emergency Action Levels (EALs):
Damage to a loaded cask CONFINEMENT BOUNDARY as indicated by an on-contact radiation reading:
> 200 mr/hr on the Horizontal Storage Module (HSM) access door OR
> 40 mr/hr on the Horizontal Storage Module (HSM) sides No Change Difference Deviation
- 1) Listed 2x the site specific cask specific allowable radiation level as per the Certificate of Compliance Attachment A.
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